Chained to the Past: An Overview of Criminal Expungement Law in Minnesota —State v. Schultz

This article explains Minnesota’s expungement law and analyzes a recent Minnesota Court of Appeals decision that limits the expungement remedy. Specifically, this article begins by examining the effects of a criminal record and the purposes of expungement.8 An expungement’s main purpose is to seal an individual’s criminal record from public view, thereby allowing the individual to fully reintegrate into society. This article then provides an overview of current expungement law and its history. This article also explains different types of criminal records and the different mechanisms used to seal each type of record. The focus of this article is on sealing records of convictions. One of the difficulties in sealing a criminal record is in the number of public and private agencies that have a record of the offense. In the past, a court could order all public agencies holding a record of the offense to seal the record. But under recent case law, specifically State v. Schultz, the Minnesota Court of Appeals found that, under the separation of powers doctrine, district courts only have the authority to seal judicial records. This finding leaves executive branch records available to the public. One example of an executive record is the Bureau of Criminal Apprehension (BCA) record, which is of particular concern because many landlords and employers use BCA records to conduct background checks on applicants. Limiting the district court’s power to seal to judicial records nullifies the expungement remedy and creates an inconsistency in records not contemplated by the court of appeals. Keeping executive branch records available to the public also ignores legislative intent and the practical realities of the separation of powers doctrine. Lastly, in response to the Schultz decision, this article offers some tools that could help defense attorneys avoid the Schultz holding

Lemon sole Microstomus kitt in the northern North Sea: a multidisciplinary approach to the early life-history dynamics

Lemon sole Microstomus kitt is a commercially valuable flatfish species that occurs in shelf waters around the northeast Atlantic. Only the most basic life-history information is available for the North Sea. Spawning is generally assumed to occur between early May and October, with a peak between May and August. Lemon sole larvae have been found in the water column in the northern North Sea in winter during standard surveys. Larvae captured in November/December 2016 and January/February 2017 using the International Council for the Exploration of the Seas standard 2 m Midwater Ring trawls (MIK) were analysed to gain a better understanding of the pelagic early life-history stages of lemon sole, especially in relation to the timing of spawning and the dispersal of overwintering larvae. Larval age was estimated from sagittal otolith primary increment counts. The larvae caught in November/December ranged in nominal age from 4 to 45 days post-hatching which suggests that spawning continues into late October and November. Most, but not all, of the larvae caught in January/February were post metamorphosis, and the difference in age between the two sampling dates was consistent with the elapsed time between samplings. The estimated hatching dates confirm that lemon sole spawning extends into late autumn in the northern North Sea, with overwintering larvae in all developmental stages. Drift modelling of eggs and larvae released at historically documented spawning grounds in the northern North Sea suggests that these grounds are also the source for all of the larvae sampled during the 2016–2017 surveys.publishedVersio

Getting the right balance: insole design alters the static balance of people with diabetes and neuropathy

BACKGROUND: Over 1 in 3 older people with diabetes sustain a fall each year. Postural instability has been identified as independent risk factor for falls within people with Diabetic Peripheral Neuropathy (DPN). People with DPN, at increased risk of falls, are routinely required to wear offloading insoles, yet the impact of these insoles on postural stability and postural control is unknown. The aim of this study was to evaluate the effect of a standard offloading insole and its constituent parts on the balance in people with DPN. METHODS: A random sample of 50 patients with DPN were observed standing for 3 × 30 s, and stepping in response to a light, under five conditions presented in a random order; as defined by a computer program; 1) no insole, 2) standard diabetic: a standard offloading insole made from EVA/poron®, and three other insoles with one design component systematically altered 3) flat: diabetic offloading insole with arch fill removed, 4) low resilient memory: diabetic offloading insole with the cover substituted with low resilience memory V9, 5) textured: diabetic offloading insole with a textured PVC surface added (Algeos Ltd). After each condition participants self-rated perceived steadiness. RESULTS: Insole design effected static balance and balance perception, but not stepping reaction time in people with DPN. The diabetic and memory shaped insoles (with arch fill) significantly increased centre of pressure velocity (14 %, P = 0.006), (13 %, P = 0.001), and path length (14 %, P = 0.006), (13 %, P = 001), when compared to the no insole condition. The textured shaped and flat soft insole had no effect on static balance when compared to the no insole condition (P > 0.05). CONCLUSION: Insoles have an effect on static balance but not stepping reaction time. This effect is independent of neuropathy severity. The addition of a textured cover seems to counter the negative effect of an arch fill, even in participants with severe sensation loss. Static balance is unaffected by material softness or resilience. Current best practice of providing offloading insoles, with arch fill, to increase contact area and reduce peak pressure could be making people more unstable. Whilst flat, soft insoles maybe the preferable design option for those with poor balance. There is a need to develop an offloading insole that can reduce diabetic foot ulcer risk, without compromising balance

Chained to the Past: An Overview of Criminal Expungement Law in Minnesota —State v. Schultz

This article explains Minnesota’s expungement law and analyzes a recent Minnesota Court of Appeals decision that limits the expungement remedy. Specifically, this article begins by examining the effects of a criminal record and the purposes of expungement.8 An expungement’s main purpose is to seal an individual’s criminal record from public view, thereby allowing the individual to fully reintegrate into society. This article then provides an overview of current expungement law and its history. This article also explains different types of criminal records and the different mechanisms used to seal each type of record. The focus of this article is on sealing records of convictions. One of the difficulties in sealing a criminal record is in the number of public and private agencies that have a record of the offense. In the past, a court could order all public agencies holding a record of the offense to seal the record. But under recent case law, specifically State v. Schultz, the Minnesota Court of Appeals found that, under the separation of powers doctrine, district courts only have the authority to seal judicial records. This finding leaves executive branch records available to the public. One example of an executive record is the Bureau of Criminal Apprehension (BCA) record, which is of particular concern because many landlords and employers use BCA records to conduct background checks on applicants. Limiting the district court’s power to seal to judicial records nullifies the expungement remedy and creates an inconsistency in records not contemplated by the court of appeals. Keeping executive branch records available to the public also ignores legislative intent and the practical realities of the separation of powers doctrine. Lastly, in response to the Schultz decision, this article offers some tools that could help defense attorneys avoid the Schultz holding

Lemon sole Microstomus kitt in the northern North Sea: a multidisciplinary approach to the early life-history dynamics

Lemon sole Microstomus kitt is a commercially valuable flatfish species that occurs in shelf waters around the northeast Atlantic. Only the most basic life-history information is available for the North Sea. Spawning is generally assumed to occur between early May and October, with a peak between May and August. Lemon sole larvae have been found in the water column in the northern North Sea in winter during standard surveys. Larvae captured in November/December 2016 and January/February 2017 using the International Council for the Exploration of the Seas standard 2 m Midwater Ring trawls (MIK) were analysed to gain a better understanding of the pelagic early life-history stages of lemon sole, especially in relation to the timing of spawning and the dispersal of overwintering larvae. Larval age was estimated from sagittal otolith primary increment counts. The larvae caught in November/December ranged in nominal age from 4 to 45 days post-hatching which suggests that spawning continues into late October and November. Most, but not all, of the larvae caught in January/February were post metamorphosis, and the difference in age between the two sampling dates was consistent with the elapsed time between samplings. The estimated hatching dates confirm that lemon sole spawning extends into late autumn in the northern North Sea, with overwintering larvae in all developmental stages. Drift modelling of eggs and larvae released at historically documented spawning grounds in the northern North Sea suggests that these grounds are also the source for all of the larvae sampled during the 2016–2017 surveys

Mitchell Hamline School of Law Summer 2020 Covid-19 Legal Response Clinic

This essay is a reflection on lawyering in a time of crisis. It details the Mitchell Hamline School of Law Clinical Faculty’s response to the community needs resulting from the COVID-19 pandemic by creating the COVID-19 Legal Response Clinic. It also recounts the impact of the murder of George Floyd and the long overdue national reckoning with systemic racism, sparked in our city. Additionally, against this backdrop, it examines the trauma-informed approach taken in clinical work and the classroom to help students process their own trauma and apply this approach in their work with clients. Amid these concurrent crises in our city and country, five clinicians and eleven law students came together through the COVID-19 Legal Response Clinic to serve the community, working on a variety of issues including domestic violence, unemployment, workplace safety, and conditional medical release from prison. With the passage of time, this essay reflects, one year later, on the experience of renewed purpose and optimism through caring for our community, our students, and each other in an otherwise dark and challenging time

Lemon sole Microstomus kitt in the northern North Sea: a multidisciplinary approach to the early life-history dynamics

Lemon sole Microstomus kitt is a commercially valuable flatfish species that occurs in shelf waters around the northeast Atlantic. Only the most basic life-history information is available for the North Sea. Spawning is generally assumed to occur between early May and October, with a peak between May and August. Lemon sole larvae have been found in the water column in the northern North Sea in winter during standard surveys. Larvae captured in November/December 2016 and January/February 2017 using the International Council for the Exploration of the Seas standard 2 m Midwater Ring trawls (MIK) were analysed to gain a better understanding of the pelagic early life-history stages of lemon sole, especially in relation to the timing of spawning and the dispersal of overwintering larvae. Larval age was estimated from sagittal otolith primary increment counts. The larvae caught in November/December ranged in nominal age from 4 to 45 days post-hatching which suggests that spawning continues into late October and November. Most, but not all, of the larvae caught in January/February were post metamorphosis, and the difference in age between the two sampling dates was consistent with the elapsed time between samplings. The estimated hatching dates confirm that lemon sole spawning extends into late autumn in the northern North Sea, with overwintering larvae in all developmental stages. Drift modelling of eggs and larvae released at historically documented spawning grounds in the northern North Sea suggests that these grounds are also the source for all of the larvae sampled during the 2016–2017 surveys

Mitchell Hamline School of Law Summer 2020 Covid-19 Legal Response Clinic

This essay is a reflection on lawyering in a time of crisis. It details the Mitchell Hamline School of Law Clinical Faculty’s response to the community needs resulting from the COVID-19 pandemic by creating the COVID-19 Legal Response Clinic. It also recounts the impact of the murder of George Floyd and the long overdue national reckoning with systemic racism, sparked in our city. Additionally, against this backdrop, it examines the trauma-informed approach taken in clinical work and the classroom to help students process their own trauma and apply this approach in their work with clients. Amid these concurrent crises in our city and country, five clinicians and eleven law students came together through the COVID-19 Legal Response Clinic to serve the community, working on a variety of issues including domestic violence, unemployment, workplace safety, and conditional medical release from prison. With the passage of time, this essay reflects, one year later, on the experience of renewed purpose and optimism through caring for our community, our students, and each other in an otherwise dark and challenging time