295 research outputs found

    Repetitive Post-Conviction Petitions Alleging Ineffective Assistance of Counsel: Can the Pennsylvania Supreme Court Tame the Monster ?

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    Pennsylvania\u27s Post Conviction Hearing Act includes several provisions designed to discourage repetitive requests for collateral relief from criminal convictions. According to the author, a series of decisions by the Pennsylvania Supreme Court, culminating in Commonwealth v. Watlington, have weakened these protective measures by making them vulnerable to frivolous allegations of ineffective assistance of counsel. The author examines the leading decisions and discusses the supreme court\u27s recent attempt, in Commonwealth v. Alexander, to provide guidelines to lower courts for dealing with petitions making these allegations. He concludes by proposing a statutory modification to the Post Conviction Hearing Act which would empower lower courts to dispose of such petitions in a summary proceeding that determines whether specific errors by prior counsel prejudiced the petitioner\u27s constitutional rights

    Patents - Statutory Interpretation - Patentability of Living Microorganisms

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    The United States Supreme Court has held that a live, human-made, genetically engineered microorganism is patentable subject matter under 35 U.S.C. § 101. Diamond v. Chakrabarty, 100 S. Ct. 2204 (1980)

    Grape variety affects larval performance and also female reproductive performance of the European grapevine moth Lobesia botrana (Lepidoptera: Tortricidae)

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    For insect herbivores, the quality of the larval host plant is a key determinant of fitness. Therefore, insect populations are supposed to be positively correlated with the nutritional quality of their host plant. This study aimed to determine if and how different varieties of grapes (including the wild grape Lambrusque) affect both larval and adult performance of the polyphagous European grapevine moth Lobesia botrana (Denis & Schiffermüller). Significant differences were found in larval development time, but not in pupal mass, adult emergence rate, or sex ratio. Although the fecundity of females is not different among varieties, females fed on some varieties produced eggs of different sizes which are correlated to their fertility. Thus, females adapt resource allocation to eggs depending on their diet as larvae. Using a fitness index, the average reproductive output was found to be highest for females reared on cv. Chardonnay. Females reared on wild grape produced a fitness index identical to the cultivated grapes. However, Lambrusque and Gewurztraminer separate themselves from the cultivated varieties according to our discriminant analyses. It is emphasized, through this study, that cultivars fed on by larvae should be considered in the population dynamics of L. botrana and that egg number is insufficient to determine host plant qualit

    Attraction of flower visitors to plants that express indirect defence can minimize ecological costs of ant-pollinator conflicts

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    Thousands of plant species throughout tropical and temperate zones secrete extrafloral nectar (EFN) (see www.biosci.unl.edu/emeriti/keeler/extrafloral/worldlistfamilies.htm) to attract ants, whose presence leads to an indirect defence against herbivores (Chamberlain & Holland 2009, Heil 2008, Heil & McKey 2003, Rico-Gray & Oliveira 2007). Although termed ‘extrafloral' because the nectar is not involved in pollination, EFN can also be secreted within the inflorescences (Bentley 1977, Holland et al. 2010, Martins 2009). Because ants tend to defend reliable food sources against all types of putative competitors, it has been hypothesized that the presence of extrafloral nectaries close to flowers may lead to competition among ants and pollinators, or even to direct ant-pollinator conflicts. Such antagonistic interactions would reduce the access of pollinators to flowers and, thereby, may cause significant ‘ecological costs' of indirect, ant-mediated defences (Heil 2002

    Larval host plant origin modifies the adult oviposition preference of the female European grapevine moth Lobesia botrana

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    According to the ‘natal habitat preference induction' (NHPI) hypothesis, phytophagous insect females should prefer to lay their eggs on the host species on which they developed as larvae. We tested whether this hypothesis applies to the breeding behaviour of polyphagous European grapevine moth, Lobesia botrana, an important pest in European vineyards. We previously found that different grape cultivars affect several life history traits of the moth. Because the different cultivars of grapes are suspected to provide different plant quality, we tested the NHPI hypothesis by examining oviposition choice of L. botrana among three Vitis vinifera cultivars (Pinot, Chasselas and Chardonnay). In a choice situation, females of L. botrana that had never experienced grapes were able to discriminate between different grape cultivars and preferentially selected Pinot as an oviposition substrate. This ‘naive' preference of oviposition could be modified by larval environment: Females raised on grapes as larvae preferred to lay eggs on the cultivar that they had experienced. Furthermore, experience of the host plant during adult emergence could be excluded because when pupae originating from our synthetic diet were exposed to grapes, the emerging adults did not show preference for the cultivar from which they emerged. The NHPI hypothesis that includes the two sub-hypothesis "Hopkins host selection principle” and "chemical legacy” may thus be relevant in this syste

    Uncovering Cryptic Parasitoid Diversity in Horismenus (Chalcidoidea, Eulophidae)

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    The file attached is the Published/publisher’s pdf version of the article.© 2015 Kenyon et al. This is an open access article distributed under the terms of the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original author and source are credited
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