100 research outputs found

    Debtor Needs to have Benefitted from Fraud to be Barred a Discharge Under 11 U.S.C. § 523(a)(2)(A)

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    (Excerpt) Title 11 of the United States Code (the “Bankruptcy Code”) provides that a court may grant a debtor a discharge of its debts, subject to certain conditions and exceptions. One exception to dischargeability is set forth in section 523(a)(2)(A), which bars a discharge from debt “for money, property, services, or an extension, renewal, or refinancing of credit, to the extent obtained by . . . false pretenses, a false representation, or actual fraud, other than a statement respecting the debtor\u27s or an insider\u27s financial condition.” A key phrase in the statute is “obtained by” and courts have applied a few different interpretations to this phrase. Further, the Supreme Court has broadly interpreted the “obtained by” requirement, signaling to lower courts that excepting more debts related to fraud from dischargeability is appropriate. This article examines the three interpretations courts have applied to section 523(a)(2)(A) and which is appropriate, especially considering the most recent Supreme Court decision. Part I focuses on the authority section 523(a)(2)(A) grants courts to except certain debts from a discharge and the requirements to fall under this exception. Part II examines two of the Supreme Court interpretations of section 523(a)(2)(A) to demonstrate the extent it is appropriate for lower courts to except certain debts from a discharge under the statute. Part III examines the three interpretations courts have applied to section 523(a)(2)(A) and references how the Supreme Court decisions impact these interpretations

    Modeling the Relations Among Morphological Awareness Dimensions, Vocabulary Knowledge, and Reading Comprehension in Adult Basic Education Students

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    This study extended the findings of Tighe and Schatschneider (2015) by investigating the predictive utility of separate dimensions of morphological awareness as well as vocabulary knowledge to reading comprehension in Adult Basic Education (ABE) students. We competed 2- and 3-factor structural equation models of reading comprehension. A 3-factor model of real word morphological awareness, pseudoword morphological awareness, and vocabulary knowledge emerged as the best fit and accounted for 79% of the reading comprehension variance. The results indicated that the constructs contributed jointly to reading comprehension; however, vocabulary knowledge was the only potentially unique predictor (p = .052), accounting for an additional 5.6% of the variance. This study demonstrates the feasibility of applying a latent variable modeling approach to examine individual differences in the reading comprehension skills of ABE students. Further, this study replicates the findings of Tighe and Schatschneider (2015) of the importance of differentiating among dimensions of morphological awareness in this population

    Who is a Nuisance? Criminal Activity Nuisance Ordinances in Ohio

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    Criminal Activity Nuisance Ordinances (CANOs) are local laws found in thousands of cities throughout the country which penalize property owners if repeated incidents of criminal activity related to their property occur over a set period of time (typically, 12 months). Nearly 50 cities in Ohio have CANOs, including more than 20 in Northeast Ohio.Drawing on extensive public records from a sample of Northeast Ohio cities, this report offers a snapshot of CANOs and how they are being used. • CANOs disproportionately impact renters, people using housing vouchers, and people of color. • Race and class stereotypes surface in public discussions of CANOs, and are sometimes invoked to justify the establishment or enhancement of CANOs • CANOs are frequently applied beyond their scope to target minor, non-criminal behavior • Many cities across Ohio put survivors of domestic violence at heightened risk of eviction by defining domestic violence as a “nuisance activity”; in some cities, more than half of CANO letters are sent in response to domestic violence incidents• If emergency services are sent to a home in response to a call made to a suicide hotline, that property can be deemed a nuisance • Seeking medical assistance for someone experiencing a drug overdose crisis is a common reason that properties are placed on a nuisance list • It is often difficult or even impossible for a property owner or tenant to challenge a mistaken nuisance designationWhile the findings presented in this report center on Northeast Ohio, residents in the thousands of other cities with CANOs across the country may be experiencing similar impact. We encourage policymakers, researchers, and community stakeholders to use this report to inform deeper conversations on the implications of CANOs, and to expand research on the use and consequences of these laws

    Patients with TNF Receptor Associated Periodic Syndrome (TRAPS) are hypersensitive to Toll‐like receptor 9 stimulation

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    Tumour necrosis factor receptor‐associated periodic syndrome (TRAPS) is an hereditary autoinflammatory disorder characterised by recurrent episodes of fever and inflammation. It is associated with autosomal dominant mutations in TNFRSF1A, which encodes tumour necrosis factor receptor‐1 (TNFR1). Our aim was to understand the influence of TRAPS mutations on the response to stimulation of the pattern recognition receptor TLR9. Peripheral blood mononuclear cells (PBMCs) and serum were isolated from TRAPS patients and healthy controls: Serum levels of fifteen pro‐inflammatory cytokines were measured to assess the initial inflammatory status. IL‐1β, IL‐6, IL‐8, IL17, IL22, TNF‐α, VEGF, IFN‐γ, MCP‐1 and TGF‐β were significantly elevated in TRAPS patients sera, consistent with constitutive inflammation. Stimulation of PBMCs with TLR9 ligand (ODN2006) triggered significantly greater upregulation of pro‐inflammatory signalling intermediates (TRAF3, IRAK2, TOLLIP, TRAF6, pTAK, TAB2, pTAB2, IRF7, RIP, NF‐kB p65, pNF‐κB p65, and MEK1/2) in TRAPS patients’ PBMCs. This upregulation of proinflammatory signalling intermediates and raised serum cytokines occurred despite concurrent anakinra treatment and no overt clinical symptoms at time of sampling. These novel findings further demonstrate the wide‐ranging nature of the dysregulation of innate immune responses underlying the pathology of TRAPS and highlights the need for novel pathway‐specific therapeutic treatments for this disease

    Internal standard-based analysis of microarray data2—Analysis of functional associations between HVE-genes

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    In this work we apply the Internal Standard-based analytical approach that we described in an earlier communication and here we demonstrate experimental results on functional associations among the hypervariably-expressed genes (HVE-genes). Our working assumption was that those genetic components, which initiate the disease, involve HVE-genes for which the level of expression is undistinguishable among healthy individuals and individuals with pathology. We show that analysis of the functional associations of the HVE-genes is indeed suitable to revealing disease-specific differences. We show also that another possible exploit of HVE-genes for characterization of pathological alterations is by using multivariate classification methods. This in turn offers important clues on naturally occurring dynamic processes in the organism and is further used for dynamic discrimination of groups of compared samples. We conclude that our approach can uncover principally new collective differences that cannot be discerned by individual gene analysi

    Profiling humoral immune responses to Clostridium difficile-specific antigens by protein microarray analysis

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    Clostridium difficile is an anaerobic, Gram-positive, and spore-forming bacterium that is the leading worldwide infective cause of hospital-acquired and antibiotic-associated diarrhea. Several studies have reported associations between humoral immunity and the clinical course of C. difficile infection (CDI). Host humoral immune responses are determined using conventional enzyme-linked immunosorbent assay (ELISA) techniques. Herein, we report the first use of a novel protein microarray assay to determine systemic IgG antibody responses against a panel of highly purified C. difficile-specific antigens, including native toxins A and B (TcdA and TcdB, respectively), recombinant fragments of toxins A and B (TxA4 and TxB4, respectively), ribotypespecific surface layer proteins (SLPs; 001, 002, 027), and control proteins (tetanus toxoid and Candida albicans). Microarrays were probed with sera from a total of 327 individuals with CDI, cystic fibrosis without diarrhea, and healthy controls. For all antigens, precision profiles demonstrated<10% coefficient of variation (CV). Significant correlation was observed between microarray and ELISA in the quantification of antitoxin A and antitoxin B IgG. These results indicate that microarray is a suitable assay for defining humoral immune responses to C. difficile protein antigens and may have potential advantages in throughput, convenience, and cost

    The application of protein microarray assays in psychoneuroimmunology

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    Protein microarrays are miniaturized multiplex assays that exhibit many advantages over the commonly used enzyme-linked immunosorbent assay (ELISA). This article aims to introduce protein microarrays to readers of Brain, Behavior, and Immunity and demonstrate its utility and validity for use in psychoneuroimmunological research. As part of an ongoing investigation of psychological and behavioral influences on influenza vaccination responses, we optimized a novel protein microarray to quantify influenza-specific antibody levels in human sera. Reproducibility was assessed by calculating intra- and inter-assay coefficients of variance on serially diluted human IgG concentrations. A random selection of samples was analyzed by microarray and ELISA to establish validity of the assay. For IgG concentrations, intra-assay and inter-assay precision profiles demonstrated a mean coefficient of variance of 6.7% and 11.5% respectively. Significant correlations were observed between microarray and ELISA for all antigens, demonstrating the microarray is a valid alternative to ELISA. Protein microarrays are a highly robust, novel assay method that could be of significant benefit for researchers working in psychoneuroimmunology. They offer high throughput, fewer resources per analyte and can examine concurrent neuro-immune-endocrine mechanisms
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