Time Is Not on Your Side: Establishing a Consistent Statute of Limitations for the Alien Tort Claims Act

This Comment argues that inconsistent application of limitations periods to ATCA claims does not provide sufficient and certain notice to potential parties to allow them to bring a timely claim, thereby potentially denying them an opportunity to receive a fair hearing in federal courts. Absent a U.S. Supreme Court ruling to provide consistent guidance on the applicable ATCA limitations period, Congress should amend the statute to provide a specific ten-year limitations period for most torts. Because both international and U.S. laws provide that murder committed as part of the crime of genocide has no statute of limitations, ATCA claims arising from genocidal acts should also be free of any limitations period. Part II provides general background on statute of limitations jurisprudence and related concepts, such as borrowing statutes, the doctrines of repose and laches, equitable tolling, and the discovery rule. Part II also examines the application of limitations law in federal courts. Part III reviews the history and progression of application of limitations law to the ATCA, focusing on the inconsistency of the limitations periods in representative ATCA claims. Part IV examines arguments for and against amending the ATCA to include a fixed limitations period, and evaluates several proposed alternatives for Congress to consider when amending the ATCA. Part IV also presents the key elements that the amended ATCA should contain. Part V presents conclusions about the appropriate limitations period for Congress to adopt

Time Is Not on Your Side: Establishing a Consistent Statute of Limitations for the Alien Tort Claims Act

This Comment argues that inconsistent application of limitations periods to ATCA claims does not provide sufficient and certain notice to potential parties to allow them to bring a timely claim, thereby potentially denying them an opportunity to receive a fair hearing in federal courts. Absent a U.S. Supreme Court ruling to provide consistent guidance on the applicable ATCA limitations period, Congress should amend the statute to provide a specific ten-year limitations period for most torts. Because both international and U.S. laws provide that murder committed as part of the crime of genocide has no statute of limitations, ATCA claims arising from genocidal acts should also be free of any limitations period. Part II provides general background on statute of limitations jurisprudence and related concepts, such as borrowing statutes, the doctrines of repose and laches, equitable tolling, and the discovery rule. Part II also examines the application of limitations law in federal courts. Part III reviews the history and progression of application of limitations law to the ATCA, focusing on the inconsistency of the limitations periods in representative ATCA claims. Part IV examines arguments for and against amending the ATCA to include a fixed limitations period, and evaluates several proposed alternatives for Congress to consider when amending the ATCA. Part IV also presents the key elements that the amended ATCA should contain. Part V presents conclusions about the appropriate limitations period for Congress to adopt

Deep phenotyping of the unselected COPSAC2010 birth cohort study

BACKGROUND: We hypothesize that perinatal exposures, in particular the human microbiome and maternal nutrition during pregnancy, interact with the genetic predisposition to cause an abnormal immune modulation in early life towards a trajectory to chronic inflammatory diseases such as asthma and others. OBJECTIVE: The aim of this study is to explore these interactions by conducting a longitudinal study in an unselected cohort of pregnant women and their offspring with emphasis on deep clinical phenotyping, exposure assessment, and biobanking. Exposure assessments focus on the human microbiome. Nutritional intervention during pregnancy in randomized controlled trials are included in the study to prevent disease and to be able to establish causal relationships. METHODS: Pregnant women from eastern Denmark were invited during 2008–2010 to a novel unselected ‘COPSAC(2010)’ cohort. The women visited the clinic during pregnancy weeks 24 and 36. Their children were followed at the clinic with deep phenotyping and collection of biological samples at nine regular visits until the age of 3 and at acute symptoms. Randomized controlled trials of high‐dose vitamin D and fish oil supplements were conducted during pregnancy, and a trial of azithromycin for acute lung symptoms was conducted in the children with recurrent wheeze. RESULTS: Seven hundred and thirty‐eight mothers were recruited from week 24 of gestation, and 700 of their children were included in the birth cohort. The cohort has an over‐representation of atopic parents. The participant satisfaction was high and the adherence equally high with 685 children (98%) attending the 1 year clinic visit and 667 children (95%) attending the 2 year clinic visit. CONCLUSIONS: The COPSAC(2010) birth cohort study provides longitudinal clinical follow‐up with highly specific end‐points, exposure assessments, and biobanking. The cohort has a high adherence rate promising strong data to elucidate the interaction between genomics and the exposome in perinatal life leading to lifestyle‐related chronic inflammatory disorders such as asthma

Fish Oil-Derived Fatty Acids in Pregnancy and Wheeze and Asthma in Offspring

© 2016 Massachusetts Medical Society. Bisgaard, H., Stokholm, J., Chawes, B. L., Vissing, N. H., Bjarnadóttir, E., Schoos, A.-M. M., … Bønnelykke, K. (2016). Fish Oil–Derived Fatty Acids in Pregnancy and Wheeze and Asthma in Offspring. New England Journal of Medicine, 375(26), 2530–2539. https://doi.org/10.1056/NEJMoa1503734BACKGROUND Reduced intake of n-3 long-chain polyunsaturated fatty acids (LCPUFAs) may be a contributing factor to the increasing prevalence of wheezing disorders. We assessed the effect of supplementation with n-3 LCPUFAs in pregnant women on the risk of persistent wheeze and asthma in their offspring. METHODS We randomly assigned 736 pregnant women at 24 weeks of gestation to receive 2.4 g of n-3 LCPUFA (fish oil) or placebo (olive oil) per day. Their children formed the Copenhagen Prospective Studies on Asthma in Childhood 2010 (COPSAC 2010) cohort and were followed prospectively with extensive clinical phenotyping. Neither the investigators nor the participants were aware of group assignments during follow-up for the first 3 years of the children's lives, after which there was a 2-year follow-up period during which only the investigators were unaware of group assignments. The primary end point was persistent wheeze or asthma, and the secondary end points included lower respiratory tract infections, asthma exacerbations, eczema, and allergic sensitization. RESULTS A total of 695 children were included in the trial, and 95.5% completed the 3-year, double-blind follow-up period. The risk of persistent wheeze or asthma in the treatment group was 16.9%, versus 23.7% in the control group (hazard ratio, 0.69; 95% confidence interval [CI], 0.49 to 0.97; P=0.035), corresponding to a relative reduction of 30.7%. Prespecified subgroup analyses suggested that the effect was strongest in the children of women whose blood levels of eicosapentaenoic acid and docosahexaenoic acid were in the lowest third of the trial population at randomization: 17.5% versus 34.1% (hazard ratio, 0.46; 95% CI, 0.25 to 0.83; P=0.011). Analyses of secondary end points showed that supplementation with n-3 LCPUFA was associated with a reduced risk of infections of the lower respiratory tract (31.7% vs. 39.1%; hazard ratio, 0.75; 95% CI, 0.58 to 0.98; P=0.033), but there was no statistically significant association between supplementation and asthma exacerbations, eczema, or allergic sensitization. CONCLUSIONS Supplementation with n-3 LCPUFA in the third trimester of pregnancy reduced the absolute risk of persistent wheeze or asthma and infections of the lower respiratory tract in offspring by approximately 7 percentage points, or one third. (Funded by the Lund-beck Foundation and others; ClinicalTrials.gov number, NCT00798226.)Lundbeck Foundatio

Workshops centered on authentic videos to enhance speaking

95 páginas : gráficos.Esta investigación explora la pertinencia que tiene el uso de videos auténticos para mejorar la habilidad de habla en los estudiantes de grado once de un colegio público en Bogotá. Principalmente se analizó cómo el diseño de tres talleres basados en esta clase de videos ayudó a los estudiantes a mejorar su comunicación oral a través de la imitación de situaciones reales. Los instrumentos empleados para recolectar la información fueron: portafolio oral, encuestas, artefactos y notas de campo. Esta investigación acción señaló que los estudiantes no encuentran un uso real del inglés y argumentaban que las clases no eran interesantes, ya que solo aprendían gramática basada en actividades escritas de los textos propuestos por el colegio. Los talleres diseñados basados en seis principios sugeridos por Tomlinson (1998) para el diseño de materiales, así como diferentes teorías acerca de autenticidad y habilidades de habla, proporcionaron a los estudiantes algunas estrategias para comunicarse de forma efectivamente en situaciones reales. Los hallazgos demostraron que los estudiantes mejoraron en su comunicación oral ya que aumentó su confianza al usar la lengua extranjera, haciendo más interesante y retador el proceso de aprendizaje.This research study explored the pertinence that authentic videos have to enhance eleventh graders' speaking in a public school in Bogota. It mainly analyzed how the designed workshops based on this kind of videos helped students improve their oral communication by imitating real life situations. The instruments used to collect data were: oral portfolio, surveys, artifacts and field notes. This action research study pointed out that learners did not find a real use of English and argued that the classes were not interesting since they just learnt grammar based on written activities from the books proposed by the school. The workshops designed based on the six principles suggested by Tomlinson (1998), for materials design as well as different theories about authenticity and speaking skills, provided students with helpful strategies to communicate effectively in daily life situations. The findings showed that students enhanced their oral communication since they fostered their confidence when using the target language, making learning process more interesting and challenging.Magíster en Evaluación y Aseguramiento de la Calidad de la EducaciónMaestrí