The Legality of Washington Shoreline Development Moratoria in the Wake of \u3ci\u3eBiggers v. City of Bainbridge Island\u3c/i\u3e

The Washington State Supreme Court struck down the temporary shoreline development moratorium at issue in Biggers v. City of Bainbridge Island, 162 Wash. 2d 683, 169 P.3d 14 (2007); yet the court fragmented on the broader question of whether a local government has authority to adopt a moratorium on shoreline development during long-term land-use planning. In light of upcoming deadlines for the state’s local governments to revise their shoreline-management plans, constraints on local authority to adopt shoreline moratoria during the planning process take on heightened importance for hundreds of local governments. The question highlights the tension between private property rights and government authority to regulate for the public welfare. This Note argues that, when presented with a reasonable moratorium, Washington courts should deem persuasive the agreement of the Biggers’ concurrence and dissent, which form a majority in favor of the legality of reasonable moratoria. Biggers provides binding legal precedent pursuant to the narrowest-grounds rule for interpreting plurality decisions, holding only that an unreasonable shoreline moratorium contravenes Washington law. Courts that adopt this position will remain in harmony with the state’s long history of broad local police powers while continuing the traditional requirement that land-use ordinances be reasonable. Public policy, particularly environmental imperatives, also favors upholding the reasonable shoreline moratorium. This Note proposes substantive and procedural factors, applicable in future cases, that likely fulfill the reasonableness requirement in Biggers

Radical Immersions: Navigating between virtual/physical environments and information bubbles - DRHA 2019 Conference Proceedings

This publication consists of the peer-reviewed papers and posters presented at the DRHA 2019 Conference "Radical Immersions: navigating between virtual / physical environments and information bubbles". The conference was held at Watermans Arts Centre, London (8-10 September 2019). For further information: http://www.2019.drha.uk

Vitamin d insufficiency in older female community-dwelling acute hospital admissions and the response to supplementation

Objectives: A significant proportion of the older population may exhibit vitamin D insufficiency. We sought to establish the proportion of 25-hydroxyvitamin D (25OHD) insufficient individuals in an older female cohort presenting for acute medical admission and how they responded to supplementation. Design: A prospective cohort study. Setting: Hospital admissions followed up as a population-based study. Subjects: A total of 114 consecutive female acute medical admissions aged over 65 years from November 2003 to January 2004 were enrolled. All admissions with hypercalcaemia, metabolic bone disease (other than osteoporosis/osteomalacia) and creatinine >= 150 mu mol/l were excluded. Interventions: iPTH, calcium and 25OHD levels were measured in each patient. Of the total, 22 were already receiving calcium and vitamin D supplementation at enrolment. The remaining 92 were commenced on 800 IU of vitamin D and 1 g calcium, and levels were reassessed after supplementation for 3 months. Results: 25-Hydroxyvitamin D insufficiency, as defined by a 25OHD concentration of < 50 nmol/l, was present in 86 (75.4%) patients at initial assessment (mean 35.8 nmol/l, s.d. 23.3). Secondary hyperparathyroidism was present in only 36.7% of those with 25OHD deficiency at baseline. Of the total, 51 (44.7%) patients presented for follow-up. 25-Hydroxyvitamin D concentration increased in this group from 42.1 nmol/l (s.d. 26.6) to 59.5 nmol/l (s.d. 27.4) after supplementation, P < 0.001, but 18(35.3%) still remained deficient. There was no significant change in iPTH or calcium following supplementation. Assessment of compliance revealed 6 (11.7%) admitted to partial or non-compliance. Conclusions: Insufficiency of 25OHD was very common in this cohort. Despite calcium and vitamin D supplementation, 25OHD concentrations failed to reach normality in a significant proportion. Maintaining vitamin D and calcium intake at the level of current recommended doses may not be sufficient to ensure adequate 25OHD stores

Vitamin d insufficiency in older female community-dwelling acute hospital admissions and the response to supplementation

Objectives: A significant proportion of the older population may exhibit vitamin D insufficiency. We sought to establish the proportion of 25-hydroxyvitamin D (25OHD) insufficient individuals in an older female cohort presenting for acute medical admission and how they responded to supplementation. Design: A prospective cohort study. Setting: Hospital admissions followed up as a population-based study. Subjects: A total of 114 consecutive female acute medical admissions aged over 65 years from November 2003 to January 2004 were enrolled. All admissions with hypercalcaemia, metabolic bone disease (other than osteoporosis/osteomalacia) and creatinine >= 150 mu mol/l were excluded. Interventions: iPTH, calcium and 25OHD levels were measured in each patient. Of the total, 22 were already receiving calcium and vitamin D supplementation at enrolment. The remaining 92 were commenced on 800 IU of vitamin D and 1 g calcium, and levels were reassessed after supplementation for 3 months. Results: 25-Hydroxyvitamin D insufficiency, as defined by a 25OHD concentration of < 50 nmol/l, was present in 86 (75.4%) patients at initial assessment (mean 35.8 nmol/l, s.d. 23.3). Secondary hyperparathyroidism was present in only 36.7% of those with 25OHD deficiency at baseline. Of the total, 51 (44.7%) patients presented for follow-up. 25-Hydroxyvitamin D concentration increased in this group from 42.1 nmol/l (s.d. 26.6) to 59.5 nmol/l (s.d. 27.4) after supplementation, P < 0.001, but 18(35.3%) still remained deficient. There was no significant change in iPTH or calcium following supplementation. Assessment of compliance revealed 6 (11.7%) admitted to partial or non-compliance. Conclusions: Insufficiency of 25OHD was very common in this cohort. Despite calcium and vitamin D supplementation, 25OHD concentrations failed to reach normality in a significant proportion. Maintaining vitamin D and calcium intake at the level of current recommended doses may not be sufficient to ensure adequate 25OHD stores

Pfge analysis of listeria monocytogenes isolates of clinical, animal, food and environmental origin from ireland

Listeria monocytogenes is an important foodborne human pathogen. Human infection is associated with high mortality rates. Epidemiological investigation and molecular subtyping can be useful in linking human illness with specific sources of infection. This retrospective study describes the use of PFGE to examine relationships of 222 isolates from human and non-human sources in Ireland. Human clinical isolates from other countries were also examined. Eight small clusters of human and non-human isolates (mostly serotype 4b) that were indistinguishable from one another were detected, suggesting potential sources for human infection. For non-human isolates, some PFGE types appeared to be exclusively associated with a single source, whereas other PFGE-types appeared to be more widely disseminated. Indistinguishable, or highly related clusters of isolates of Irish and non-Irish origin suggest that some PFGE patterns may be globally distributed