You’ve Got Mail, But Not Jurisdiction: The Federal Tort Claims Act and the Mailbox Rule

The Federal Tort Claims Act provides private individuals with limited rights of action against the United States government if plaintiff-claimants meet certain jurisdictional requirements. Specifically, 28 U.S.C. § 2675(a) requires that plaintiff-claimants present claims to responsible federal agencies before filing suit in federal court. On March 7, 2019, in Cooke v. United States, the United States Court of Appeals for the Second Circuit, joining a majority of circuits to have considered the question, refused to apply the mailbox rule to the presentment requirement in section 2675(a). This Comment argues that the Second Circuit’s ruling in Cooke is correct because the doctrine of sovereign immunity requires a strict construction that precludes applying the mailbox rule to section 2675(a)’s presentment requirement

Major Reforms for Minors’ Confessions: Rethinking Self-Incrimination Protections for Juveniles

The right against self-incrimination has been a part of American law since before the enactment of the Fifth Amendment. In the twentieth century, extreme police interrogation methods led the U.S. Supreme Court to institute further protections of this constitutional principle. Most significantly, in 1966, in Miranda v. Arizona, the Supreme Court permanently altered American criminal procedure and culture by extending the now-famous Miranda rights to individuals before custodial interrogation. Over fifty years later, these procedural safeguards to the right against self-incrimination have met virtually universal criticism for their ineffectiveness. Matters are particularly dire for juveniles because the law has failed to establish meaningful protections to ensure that they can understand and use their right against self-incrimination. Further, there is a growing amount of evidence that developmental limitations make juveniles especially susceptible to making uninformed, involuntary choices during interrogation. The recent innocence revolution provides proof that this leads to false confessions that unduly prejudice children in the criminal justice system and result in wrongful convictions. This Note argues that major change is necessary to protect juveniles from self-incrimination, and that confession evidence from juvenile interrogation should be inadmissible in court for due process and evidentiary reasons

Yoga Therapy for Psychological Safety in Healthcare Staff

Establishing a culture of psychological safety is a necessary foundation for creating a High Reliability Organization. Healthcare professionals must practice emotional self-regulation to maintain equanimity and facilitate positive communications with their colleagues. This can be exceptionally challenging when increasing numbers of healthcare professionals are experiencing burnout. Using the framework of Polyvagal Theory, yoga practices have been demonstrated to support emotional self-regulation and reduce symptoms of burnout. The purpose of this project was to implement yoga therapy to increase the perception of psychological safety in healthcare staff. Veterans Affairs Long Beach Healthcare System (VALBHS) staff invited to attend one 45minute yoga therapy session. Participants completed the Neuroception of Psychological Safety Scale (NPSS) survey prior to the class and at one and five weeks following the class. Participants received an audio recording of all practices to support their home practice, as well as weekly email reminders for 5 weeks post-session. Comparisons of baseline and 1-week post session scores showed a statistically significant improvement in psychological safety, as well as the subscale body sensations. Further comparison with 5-week post session scores showed no significant difference, suggesting that changes were sustained over time. A brief yoga therapy intervention is an effective way to support healthcare staff to develop skills to support their own emotion regulation and psychological safety

The Microbiological and Health Impact of the Hydraid™ Plastic-Housing Biosand Filter in Rural Honduras: A Randomized Controlled Trial in Santa Rosa de Copan

Point-of-use (POU) drinking water treatment, such as the biosand filter (BSF), allows people to treat their water in the home. The purpose of this research was to document the ability of the Hydraid™ plastic-housing BSF to reduce diarrheal disease in households who received a filter. This randomized controlled trial of the Hydraid™ BSF was carried out in rural communities in western Honduras during April 2008 to February 2009. In August2008, 194 households were randomized in to BSF and control groups. Households were observed during 7 biweekly visits pre-randomization and 13 biweekly visits post-randomization. The incidence of diarrheal disease was reduced by approximately 40% (45% in children under 5) in households that had a HydrAid™ BSF compared to those without one. Households with a BSF had significantly better drinking water quality, regardless of water source or season. The HydrAid™ BSF appears to be an effective POU technology.Master of Science in Public Healt

Threatened lichens of Lower Silesia, Poland

A preliminary red list of threatened lichens of Lower Silesia (SW Poland) is presented. Species have been valuated according to the Red Data Book Categories (IUCN). The list comprises 602 taxa (ca. 60% of the whole lichen flora of Lower Silesia). 52 species are considered as rare (category R), 84 - as vulnerable (V), and 63 species - as endangered (E). The Silesian lichen flora is characterized by great numbers of taxa with extinct (Ex -140 taxa), and indeterminate (I - 263 taxa) categories.</jats:p

Tradycyjne czy nowoczesne media gwarantem sukcesu w wyborach. Analiza wydatków partii politycznych w kampanii wyborczej w 2011 r.

Udostępnienie publikacji Wydawnictwa Uniwersytetu Łódzkiego finansowane w ramach projektu „Doskonałość naukowa kluczem do doskonałości kształcenia”. Projekt realizowany jest ze środków Europejskiego Funduszu Społecznego w ramach Programu Operacyjnego Wiedza Edukacja Rozwój; nr umowy: POWER.03.05.00-00-Z092/17-00

Plants accumulating heavy metals in the Sudety Mts

The Sudeten flora consists of some plants we can recognize as heavy metal accumulators. Between others there are: &lt;em&gt;Thlaspi caerulescens&lt;/em&gt;, &lt;em&gt;Arabidopsis halleri&lt;/em&gt;, &lt;em&gt;Armeria maritima&lt;/em&gt; ssp. &lt;em&gt;halleri&lt;/em&gt; s.l. and probably the endemic fern &lt;em&gt;Asplenium onopteris&lt;/em&gt; var. &lt;em&gt;silesiaca&lt;/em&gt;. The authors present the concentrations of some important heavy metals measured in aboveground plant dry weight. The highest concentration of zinc was 8220 ppm (&lt;em&gt;Thlaspi&lt;/em&gt;), nickel - 3100 ppm (&lt;em&gt;Thlaspi&lt;/em&gt;), lead - 83 ppm (&lt;em&gt;Armeria&lt;/em&gt;), copper - 611 ppm (&lt;em&gt;Arabidopsis&lt;/em&gt;) and cadmium - 28 ppm (&lt;em&gt;Thlaspi&lt;/em&gt;). The concentrations depend rather on species or population specification than on ore deposit quality. There are no typical hyperaccumulator among plants we have examined, but some signs of hyperaccumulation of nickel, zinc and lead could be observed. There are no typical endemic taxa, only &lt;em&gt;Asplenium onopteris&lt;/em&gt; var. &lt;em&gt;silesiaca&lt;/em&gt; and &lt;em&gt;Armeria maritima&lt;/em&gt; ssp. &lt;em&gt;halleri&lt;/em&gt; may be recognized as neoendemic taxa, but still of unclear systematic position. During the study we tried to find out why some Sudeten vascular plants do not develop heavy metals hyperaccumulation and why they are rather latent hyperaccumulators. Finally, we suggest to protect some metallicolous areas in spite they are rather territories with low plant biodiversity.</jats:p

Longitudinal Study on Oral Health in Subjects with Alzheimer's Disease

Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/111087/1/j.1532-5415.1994.tb06074.x.pd