A Constitutional Case for Extending the Due Process Clause to Asylum Seekers: Revisiting the Entry Fiction After \u3ci\u3eBoumediene\u3c/i\u3e

In the last two decades, the U.S. Supreme Court has actively grappled with balancing the interests of immigrant detainees and the federal government in the context of prolonged immigration detention by reconciling the statutory framework with constitutional guarantees of due process. The Court has focused on how prolonged detention without an opportunity for an individualized custody determination poses a serious constitutional threat to an alien’s liberty interest. The Court’s jurisprudence has focused, however, on aliens who have effected an entry into the United States. The constitutional entitlements of nonresidents who are detained upon presenting themselves at the border have so far been excluded from this new immigration narrative and continue to be governed by a more than halfcentury-old precedent establishing the “entry fiction” and acceding to the plenary power of the Executive. This Note focuses on a discrete category of aliens, namely nonresident arriving aliens seeking asylum who are detained pursuant to section 235 of the Immigration and Nationality Act (INA). These aliens stand on a different legal footing than other categories of aliens detained under the INA because they are subject to the entry fiction doctrine, which has manifest ramifications for not only their legal status but also the degree of constitutional protections they are entitled to. This Note discusses how developments in the extraterritorial application of the Constitution inform the entry fiction doctrine in the context of extending procedural protections to asylum seekers detained upon entry into the United States. This Note shows how the functional approach to extraterritoriality articulated in Boumediene v. Bush alters the legal landscape and affords an opportunity to extend due process protections to nonresident arriving aliens. Cognizant of the limitations imposed by the plenary power doctrine, this Note does not argue for extending the complete panoply of procedural protections to section 1225(b) detainees; instead it focuses on how a discrete remedy— bond hearings—would help alleviate the procedural deficiencies in the statutorily prescribed procedure. In so doing, this Note departs from the approach that has currently been adopted by lower courts by positing that recent Supreme Court precedent provides a very strong constitutional basis for extending procedural protections to section 1225(b) detainees, and it would be remiss to rely solely on Clark v. Martinez-inspired constitutional avoidance arguments

Nonunion After Hybrid Plating with Locking and Nonlocking Screws in Radius and Ulna Shaft Fractures: Report of Two Cases

Conventional compression plating has been found effective in treating forearm diaphyseal fractures, providing stability as well as resistance to axial, torsional, and bending forces. Locked plating has provided stability without frictional force between the bone-plate interface, which may help preserve periosteal blood supply, and is useful in treating metaphyseal, comminuted, and osteoporotic fractures. Hybrid plating has been used in an attempt to combine the strengths of these two techniques; however, in the context of simple forearm diaphyseal fractures with healthy bone, its effectiveness is only theoretical. We describe two patients in whom open reduction and internal fixation with hybrid plating to treat radius and ulna diaphyseal fractures resulted in nonunion. We performed a revision procedure using conventional compression plating and achieved full healing with complete union in both cases. These findings suggest that hybrid fixation for treating such fractures may not lead to better outcomes than conventional plating

COVID-19 trajectories among 57 million adults in England: a cohort study using electronic health records

BACKGROUND: Updatable estimates of COVID-19 onset, progression, and trajectories underpin pandemic mitigation efforts. To identify and characterise disease trajectories, we aimed to define and validate ten COVID-19 phenotypes from nationwide linked electronic health records (EHR) using an extensible framework. METHODS: In this cohort study, we used eight linked National Health Service (NHS) datasets for people in England alive on Jan 23, 2020. Data on COVID-19 testing, vaccination, primary and secondary care records, and death registrations were collected until Nov 30, 2021. We defined ten COVID-19 phenotypes reflecting clinically relevant stages of disease severity and encompassing five categories: positive SARS-CoV-2 test, primary care diagnosis, hospital admission, ventilation modality (four phenotypes), and death (three phenotypes). We constructed patient trajectories illustrating transition frequency and duration between phenotypes. Analyses were stratified by pandemic waves and vaccination status. FINDINGS: Among 57 032 174 individuals included in the cohort, 13 990 423 COVID-19 events were identified in 7 244 925 individuals, equating to an infection rate of 12·7% during the study period. Of 7 244 925 individuals, 460 737 (6·4%) were admitted to hospital and 158 020 (2·2%) died. Of 460 737 individuals who were admitted to hospital, 48 847 (10·6%) were admitted to the intensive care unit (ICU), 69 090 (15·0%) received non-invasive ventilation, and 25 928 (5·6%) received invasive ventilation. Among 384 135 patients who were admitted to hospital but did not require ventilation, mortality was higher in wave 1 (23 485 [30·4%] of 77 202 patients) than wave 2 (44 220 [23·1%] of 191 528 patients), but remained unchanged for patients admitted to the ICU. Mortality was highest among patients who received ventilatory support outside of the ICU in wave 1 (2569 [50·7%] of 5063 patients). 15 486 (9·8%) of 158 020 COVID-19-related deaths occurred within 28 days of the first COVID-19 event without a COVID-19 diagnoses on the death certificate. 10 884 (6·9%) of 158 020 deaths were identified exclusively from mortality data with no previous COVID-19 phenotype recorded. We observed longer patient trajectories in wave 2 than wave 1. INTERPRETATION: Our analyses illustrate the wide spectrum of disease trajectories as shown by differences in incidence, survival, and clinical pathways. We have provided a modular analytical framework that can be used to monitor the impact of the pandemic and generate evidence of clinical and policy relevance using multiple EHR sources. FUNDING: British Heart Foundation Data Science Centre, led by Health Data Research UK

Increasing frailty is associated with higher prevalence and reduced recognition of delirium in older hospitalised inpatients: results of a multi-centre study

Purpose: Delirium is a neuropsychiatric disorder delineated by an acute change in cognition, attention, and consciousness. It is common, particularly in older adults, but poorly recognised. Frailty is the accumulation of deficits conferring an increased risk of adverse outcomes. We set out to determine how severity of frailty, as measured using the CFS, affected delirium rates, and recognition in hospitalised older people in the United Kingdom. Methods: Adults over 65 years were included in an observational multi-centre audit across UK hospitals, two prospective rounds, and one retrospective note review. Clinical Frailty Scale (CFS), delirium status, and 30-day outcomes were recorded. Results: The overall prevalence of delirium was 16.3% (483). Patients with delirium were more frail than patients without delirium (median CFS 6 vs 4). The risk of delirium was greater with increasing frailty [OR 2.9 (1.8–4.6) in CFS 4 vs 1–3; OR 12.4 (6.2–24.5) in CFS 8 vs 1–3]. Higher CFS was associated with reduced recognition of delirium (OR of 0.7 (0.3–1.9) in CFS 4 compared to 0.2 (0.1–0.7) in CFS 8). These risks were both independent of age and dementia. Conclusion: We have demonstrated an incremental increase in risk of delirium with increasing frailty. This has important clinical implications, suggesting that frailty may provide a more nuanced measure of vulnerability to delirium and poor outcomes. However, the most frail patients are least likely to have their delirium diagnosed and there is a significant lack of research into the underlying pathophysiology of both of these common geriatric syndromes

A Constitutional Case for Extending the Due Process Clause to Asylum Seekers: Revisiting the Entry Fiction After \u3ci\u3eBoumediene\u3c/i\u3e

In the last two decades, the U.S. Supreme Court has actively grappled with balancing the interests of immigrant detainees and the federal government in the context of prolonged immigration detention by reconciling the statutory framework with constitutional guarantees of due process. The Court has focused on how prolonged detention without an opportunity for an individualized custody determination poses a serious constitutional threat to an alien’s liberty interest. The Court’s jurisprudence has focused, however, on aliens who have effected an entry into the United States. The constitutional entitlements of nonresidents who are detained upon presenting themselves at the border have so far been excluded from this new immigration narrative and continue to be governed by a more than halfcentury-old precedent establishing the “entry fiction” and acceding to the plenary power of the Executive. This Note focuses on a discrete category of aliens, namely nonresident arriving aliens seeking asylum who are detained pursuant to section 235 of the Immigration and Nationality Act (INA). These aliens stand on a different legal footing than other categories of aliens detained under the INA because they are subject to the entry fiction doctrine, which has manifest ramifications for not only their legal status but also the degree of constitutional protections they are entitled to. This Note discusses how developments in the extraterritorial application of the Constitution inform the entry fiction doctrine in the context of extending procedural protections to asylum seekers detained upon entry into the United States. This Note shows how the functional approach to extraterritoriality articulated in Boumediene v. Bush alters the legal landscape and affords an opportunity to extend due process protections to nonresident arriving aliens. Cognizant of the limitations imposed by the plenary power doctrine, this Note does not argue for extending the complete panoply of procedural protections to section 1225(b) detainees; instead it focuses on how a discrete remedy— bond hearings—would help alleviate the procedural deficiencies in the statutorily prescribed procedure. In so doing, this Note departs from the approach that has currently been adopted by lower courts by positing that recent Supreme Court precedent provides a very strong constitutional basis for extending procedural protections to section 1225(b) detainees, and it would be remiss to rely solely on Clark v. Martinez-inspired constitutional avoidance arguments

Evaluating The Impact of Giving Tooth Brushing Story Books on The Dental Plaque Levels of Children; A Parallel Arm Non-Randomized Clinical Trial

Objective: To assess the effect of giving toothbrushing storybooks along with verbal oral hygiene (OHI) instructions on plaque levels to schoolchildren. Methodology: This quasi-experimental study was conducted in a private school in Islamabad from October to November 2022. Children in Class V were selected as the Experimental Group I (Storybooks + OHI), while Class IV children were placed in the Control Group II (OHI alone). There were 20 students in each group. Plaque levels were compared at the baseline (before intervention) and after seven days. Toothbrushing practices were recorded at the baseline. Results: The mean age of the children was 9.6 + 1.08 years. A total of 16 (40%) boys and 24 (60%) girls were included in the study. Children in Group II had significantly better self-reported toothbrushing practices with 16 (80%) children brushing twice a day, as compared to 10 (50%) children from Group I (p = 0.041). There was no difference in the reduction in plaque scores between group I (0.14 + 0.21) and group II (0.08 + 0.21; p = 0.382). Conclusion: Giving story books to children is not an effective intervention to improve the oral hygiene status of children, as compared to oral hygiene instructions alone

Third Extensor Compartment Disruption and the Biomechanics of Thumb Extension

Background: Procedures involving release of the third dorsal wrist compartment have been thought to transpose the extensor pollicis longus (EPL) tendon from its anatomical position. Few studies, however, have reported on the effects this might have on function and mechanics of the thumb. We analyzed the impacts of intact extensor retinaculum, release of the third dorsal compartment, and removal of Lister’s tubercle on thumb extension. Methods: A total of 15 fresh-frozen cadaveric upper extremities (eight male, seven female; mean age, 52 years; range, 38-59 years) were used. For each specimen, three phases of testing were analyzed: the extensor retinaculum was intact, third dorsal compartment was released, and Lister’s tubercle was released. Force-displacement measurements were obtained to determine maximum extension and stiffness of the thumb by applying 1 N increments on the EPL until full extension of the thumb occurred. A one-way analysis of variance was used for statistical comparison. Results: In 14 of 15 specimens, the EPL tendon transposed during the first trial after release of the extensor retinaculum. No significant difference in mean maximum extension or stiffness of the thumb was found (P = 0.45 and P = 0.74, respectively). Conclusion: Functional loss of thumb extension may not occur with EPL transposition after release of the third dorsal compartment or removal of Lister’s tubercle. In patients with weakness in thumb extension, repairing the third dorsal compartment or creating a new pulley may not be effective

Indirect effects of the first two years of the COVID-19 pandemic on secondary care for cardiovascular disease in the UK : an electronic health record analysis across three countries

Background Although morbidity and mortality from COVID-19 have been widely reported, the indirect effects of the pandemic beyond 2020 on other major diseases and health service activity have not been well described. Methods Analyses used national administrative electronic hospital records in England, Scotland and Wales for 2016-2021. Admissions and procedures during the pandemic (2020-2021) related to six major cardiovascular conditions (acute coronary syndrome, heart failure, stroke/transient ischaemic attack, peripheral arterial disease, aortic aneurysm, and venous thromboembolism) were compared to the annual average in the pre-pandemic period (2016-2019). Differences were assessed by time period and urgency of care. Results In 2020, there were 31,064 (-6%) fewer hospital admissions (14,506 [-4%] fewer emergencies, 16,560 [-23%] fewer elective admissions) compared to 2016-2019 for the six major cardiovascular diseases combined. The proportional reduction in admissions was similar in all three countries. Overall, hospital admissions returned to pre-pandemic levels in 2021. Elective admissions remained substantially below expected levels for almost all conditions in all three countries (-10,996 [-15%] fewer admissions). However, these reductions were offset by higher than expected total emergency admissions (+25,878 [+6%] higher admissions), notably for heart failure and stroke in England, and for venous thromboembolism in all three countries. Analyses for procedures showed similar temporal variations to admissions. Conclusion This study highlights increasing emergency cardiovascular admissions as a result of the pandemic, in the context of a substantial and sustained reduction in elective admissions and procedures. This is likely to increase further the demands on cardiovascular services over the coming years

Political players: Courtesans of Hyderabad

Important recent works on the Mughal state and women in the Indo-Muslim world have not considered courtesans or tawa’ifs, the singing and dancing women employed by Indo-Muslim states and nobles, to be significant participants in politics and society. Drawing on detailed archival data from late nineteenth century Hyderabad state and other historical materials, I argue that courtesans were often elite women, cultural standard-setters and wielders of political power. Women whose art and learning gained them properties and alliances with powerful men, they were political players in precolonial India and in the princely states. They successfully negotiated administrative reforms in princely states like Hyderabad, continuing to secure protection and patronage while in British India they began to be classified as prostitutes. Colonial and modern India have been less than kind to courtesans and their artistic traditions, and more research needs to be done on the history of courtesans and their communities

Infective Endocarditis After Transcatheter Versus Surgical Aortic Valve Replacement

Abstract Background Scarce data are available comparing infective endocarditis (IE) following surgical aortic valve replacement (SAVR) and transcatheter aortic valve replacement (TAVR). This study aimed to compare the clinical presentation, microbiological profile, management, and outcomes of IE after SAVR versus TAVR. Methods Data were collected from the “Infectious Endocarditis after TAVR International” (enrollment from 2005 to 2020) and the “International Collaboration on Endocarditis” (enrollment from 2000 to 2012) registries. Only patients with an IE affecting the aortic valve prosthesis were included. A 1:1 paired matching approach was used to compare patients with TAVR and SAVR. Results A total of 1688 patients were included. Of them, 602 (35.7%) had a surgical bioprosthesis (SB), 666 (39.5%) a mechanical prosthesis, 70 (4.2%) a homograft, and 350 (20.7%) a transcatheter heart valve. In the SAVR versus TAVR matched population, the rate of new moderate or severe aortic regurgitation was higher in the SB group (43.4% vs 13.5%; P < .001), and fewer vegetations were diagnosed in the SB group (62.5% vs 82%; P < .001). Patients with an SB had a higher rate of perivalvular extension (47.9% vs 27%; P < .001) and Staphylococcus aureus was less common in this group (13.4% vs 22%; P = .033). Despite a higher rate of surgery in patients with SB (44.4% vs 27.3%; P < .001), 1-year mortality was similar (SB: 46.5%; TAVR: 44.8%; log-rank P = .697). Conclusions Clinical presentation, type of causative microorganism, and treatment differed between patients with an IE located on SB compared with TAVR. Despite these differences, both groups exhibited high and similar mortality at 1-year follow-up