Security Transactions—Mortgage on Shifting Stock of Merchandise—Mortgagor\u27s Duty to Account

Washington businessmen using mortgages on shifting stocks of merchandise as a security arrangement received encouragement from United States Rubber Co. v. Young, that more liberal agreements and procedures may be allowed. However, by failing to expressly overrule certain prior judicial restrictions on the use of this type of security, the Washington Supreme Court has left some unnecessary confusion to be resolved in the future

Annexation by Municipal Corporations

Problems caused by the growth of urban fringe areas have increased, particularly since World War II. As the population of these areas increases, so does the need for public services and the attendant need for effective local government. County government in Washington has remained generally unchanged since its inception one hundred years ago. Conceived in contemplation of a rural, lightly populated area requiring only a minimum of services, county government was not designed to deal with urban problems. As a result, the task of providing governmental services has been assumed by existing municipalities, which, in order to gain the requisite jurisdiction over fringe areas, must annex them. Annexation often brings higher taxes, zoning restrictions, and other municipal control, causing dissention among the inhabitants of the area proposed to be annexed. The purpose of this Comment is to discuss certain problems and considerations raised by annexation, with particular emphasis upon the applicable Washington law. The comment is divided into a discussion of five general areas: 1) The procedure for accomplishing annexation; 2) Land which may properly be annexed; 3) Remedies available for attacking annexation; 4) Circumstances in which annexation may be collaterally attacked; and 5) The doctrine of de facto corporation

Establishment of Photo-Activated Localization Microscopy (PALM) for Imaging Signaling Complexes on the Surfaces of Cells

Photoactivated Localization Microscopy (PALM) permits visualization of single molecules inside cells at ~10 times the resolution of existing optical microscopes. The 10-50 nanometer resolution afforded by PALM is ideally suited to studying the organization of receptor signal transduction occurring on the surfaces of cells. Initial efforts presented here focused on cells expressing Fc receptor fused to photoactivatable green fluorescent protein (paGFP). A small fraction of the paGFP molecules were photoactivated using a 405 nm laser pulse, resulting in single molecule spots that could then be imaged using 488 nm laser excitation until they photobleached. Both lasers illuminated the sample through the objective lens using Total Internal Reflection (TIR) excitation which allowed for selective imaging of molecules within about 200 nm of the cell/coverglass interface. Iterations of alternating laser excitations results in thousands of images of single molecules. These images were analyzed using the ImageJ plugin, QuickPALM, which performs a least squares fit of a two dimensional Gaussian to each diffraction-limited (~250 nm wide) fluorescent spot captured in the PALM images (Henriques). This process recovers the most probable position to within ~40 nm accuracy of each paGFP molecule. This information is used to create the super resolution image of the cell. Ongoing efforts are aimed at establishing two-color PALM to determine the distribution of signaling receptors relative to key sub-resolution regulators of signaling. A better understanding of the nanoscale molecular activities within cells will allow for more in depth studies into many different fields including biophysics, molecular biology, and medicine

Communicative and linguistic development in preterm children: a longitudinal study from 12 to 24 months.

BACKGROUND: Research conducted on preterm children's linguistic skills has provided varying pictures, and the question of whether and to what extent preterm children are delayed in early language acquisition remains largely unresolved. AIMS: To examine communicative and linguistic development during the second year in a group of Italian children born prematurely using the 'Primo Vocabolario del Bambino' (PVB), the Italian version of the MacArthur-Bates Communicative Development Inventory. The primary goal was to compare action/gesture production, word comprehension, and word production, and the relationship between these three domains in preterm children and to normative data obtained from a large sample of Italian children born at term. A second aim was to address the longstanding debate regarding the use of chronological versus corrected gestational age in the assessment of preterm children's abilities. METHODS & PROCEDURES: Parents of twelve preterm children completed the PVB questionnaire at five age points during the children's second year, and scores were compared with those from a normative sample of full-term children and those of 59 full-term children selected as a control group from the normative sample for the PVB. OUTCOMES & RESULTS: Preterm children exhibited a delay in all three aspects of communication and language. In particular, communicative-linguistic age tended to lag approximately 3 months behind chronological age when children were between the ages of 12 and 24 months. When chronological age was used, preterm children's percentile scores for all three components of communication and language fell within the lower limits of the normal range, while scores calculated using corrected age either fell at or above the 50th percentile. CONCLUSIONS & IMPLICATIONS: Findings suggest that despite the significant biological risk engendered by premature birth, early communicative and linguistic development appears to proceed in a relatively robust fashion among preterm children, with tight relations across communicative domains as in full-term children. Employing both chronological and corrected gestational age criteria in the evaluation of preterm children's abilities may provide important information about their progress in language acquisition. This may be especially important during the initial stages of communicative and linguistic development, inasmuch as comparisons of the two sets of scores may provide clinicians with a way to distinguish children who may be at risk for language problems from those who may be expected to progress normally

Fostering medical students' lifelong learning skills with a dashboard, coaching and learning planning.

IntroductionTo develop lifelong learning skills, students need feedback, access to performance data, and coaching. A new medical curriculum incorporated infrastructural supports based on self-regulated learning theory and the Master Adaptive Learner framework to engage students in reflection and learning planning. This study examines students' experience with a performance dashboard, longitudinal coaching, and structured time for goal-setting.MethodsFocus groups with first-year medical students explored performance dashboard usage, coaching and learning planning. We analyzed findings using thematic analysis. Results informed development of a 29-item survey rated strongly disagree (1) to strongly agree (5) to investigate experience with the dashboard, coaching and learning goals program. The survey was distributed to one first-year medical student class. We performed descriptive statistics and factor analysis.ResultsIn three focus groups with 21 participants, students endorsed using the dashboard to access performance information but had trouble interpreting and integrating information. They valued coaches as sources of advice but varied in their perceptions of the value of discussing learning planning. Of 152 students, 114 (75%) completed the survey. Exploratory factor analysis yielded 5 factors explaining 57% of the variance: learning goals development (α = 0.88; mean 3.25 (standard deviation 0.91)), dashboard usage (α = 0.82; 3.36 (0.64)), coaching (α = 0.71; 3.72 (0.64)), employment of learning strategies (α = 0.81; 3.67 (0.79)), and reflection (α = 0.63; 3.68 (0.64)).DiscussionThe student performance dashboard provides efficient feedback access, yet students' use of this information to guide learning is variable. These results can inform other programs seeking to foster lifelong learning skills

Personal Jurisdiction in the Bankruptcy Context: A Need for Reform

This Article analyzes and evaluates the debate concerning a bankruptcy court\u27s ability to assert personal jurisdiction over a foreign entity. Additionally, this Article advocates that the Bankruptcy Rules be amended to conform to the new federal long-arm statute, FRCP 4. More specifically, this Article asserts and demonstrates that: (1) the current status of the law in bankruptcy cases regarding personal jurisdiction is uncertain; (2) prior to the 1993 amendments to FRCP 4, some courts improperly broadened the jurisdiction of bankruptcy courts by allowing them to assert power over defendants by focusing on a defendant\u27s nationwide contacts as opposed to contacts with the forum state; and (3) in light of the new expansion of FRCP 4, Congress should enact a parallel version of the federal long-arm statute in Rule 7004(e).Part I of this Article outlines the Supreme Court\u27s standard on personal jurisdiction, thereby exploring the nature of service of process and personal jurisdiction, both in general civil litigation and in bankruptcy litigation. Part II of this Article analyzes and distinguishes the approaches courts have utilized in assessing whether bankruptcy courts may use aggregate nationwide contacts when asserting jurisdiction over a foreign defendant. Finally, Part III of this Article recommends that Rule 7004 be updated to reflect changes in the amended version of FRCP 4. By enacting the federal long-arm statute in FRCP 4(k)(2), Congress closed a loophole through which foreign defendants were permitted to conduct business in the United States while evading legal responsibility for their actions in the United States. As a result, the Bankruptcy Rules should follow the trend the 1993 amendments to FRCP 4 began by closing this parallel loophole in the bankruptcy context. Explicit expansion of Rule 7004(e)\u27s scope, to encompass foreign defendants as amenable to service under a federal long-arm statute, would prevent the existing judicial error in interpretation from continuing. Personal Jurisdiction, Bankruptcy, Rule 700

Improving the Methodology for Identifying Mild Cognitive Impairment in Intellectually High-Functioning Adults Using the NIH Toolbox Cognition Battery

Objective: Low scores on neuropsychological tests are considered objective evidence of mild cognitive impairment. In clinical practice and research, it can be challenging to identify a cognitive deficit or mild cognitive impairment in high-functioning people because they are much less likely to obtain low test scores. This study was designed to improve the methodology for identifying mild cognitive impairment in adults who have above average or superior intellectual abilities. Method: Participants completed the National Institutes of Health Toolbox for the Assessment of Neurological and Behavioral Function Cognition Battery (NIHTB-CB). The sample included 384 adults between the ages of 20 and 85 who had completed either a 4-year college degree or who scored in the above average, superior, or very superior range on a measure of intellectual functioning, the Crystallized Composite score. Algorithms were developed, based on the absence of high scores and the presence of low scores, for identifying mild cognitive impairment. Results: Base rate tables for the presence of low scores and the absence of high scores are provided. The base rate for people with high average crystalized ability obtaining any one of the following, 5 scores \u3c 63rd percentile, or 4+ scores \u3c 50th percentile, or 3+ scores ≤ 25th percentile, or 2+ scores ≤ 16th percentile, is 15.5%. Conclusions: Algorithms were developed for identifying cognitive weakness or impairment in high-functioning people. Research is needed to test them in clinical groups, and to assess their association with clinical risk factors for cognitive decline and biomarkers of acquired neurological or neurodegenerative diseases

Association Between Concussions and Suicidality in High School Students in the United States

Importance: Prior research has shown a statistically significant association between sustaining a concussion and suicidality in adolescents, but this prior research controlled for relatively few variables predictive of suicidality. Objective: To examine whether sustaining a concussion remained a significant predictor of suicidality after controlling for relevant covariates (e.g., sexual abuse/assault, bullying, substance use, depression), hypothesizing that the relationship between concussion and suicidality would become non-significant after controlling for these variables. Design: This study involved secondary data analysis of the 2019 Youth Risk Behavior Surveillance (YRBS) System, a national cross-sectional study of adolescents. Analyses were stratified by gender. Setting: A national sampling of U.S. high school students. Participants: Eleven thousand two hundred sixty-two students in the YRBS database, including 5,483 boys and 5,779 girls. Exposure(s): Participants included in the analyses reported whether, in the last year, they experienced a concussion and/or suicidality. Main Outcomes and Measures: The main outcome was suicidality (i.e., ideation, planning, attempt), which was predicted by concussion in an unadjusted analysis and by concussion along with other risk factors in a multivariable analysis. Results: The final sample included 11,262 participants with available data on concussion and suicidality in the last year (14–18 years-old; 51.3% girls; 49.0% White). Per unadjusted odds ratios with 95% confidence intervals, there was a relationship between concussion and suicidal ideation [girls: OR = 1.46 (1.24, 1.73); boys: OR = 1.69 (1.41, 2.03)], planning (girls: OR = 1.39 [1.16, 1.66]; boys: OR = 1.76 [1.44, 2.14]), and attempt [girls: OR = 1.70 (1.32, 2.19); boys: OR = 3.13, (2.37, 4.15)]. These relationships became mostly non-significant after controlling for relevant risk factors for suicidality. The adjusted odds ratios showed no relationship between concussion and suicidal ideation [girls: OR = 1.11 (0.86, 1.44); boys: OR = 1.24 (0.92, 1.69)] or planning (girls: OR = 1.07 [0.82, 1.40]; boys: OR = 1.12 [0.82, 1.55]); but a significant relationship with suicide attempts in boys [OR = 1.98 (1.28, 3.04)], but not girls [OR = 1.05 (0.74, 1.49)]. Conclusions and Relevance: There was an association between concussion and suicidality in U.S. high school students; however, after controlling for other variables (e.g., depression, sexual abuse/assault, illicit drug use), there was no association between concussion and suicidality aside from a significant relationship between concussion and attempts in boys