Constitutional Law: Search and Seizure—The Role of Police Officer Good Faith in Substantive Fourth Amendment Doctrine—Michigan v. De Fillippo, 443, U.S. 31 (1979)

This note challenges the Court\u27s implicit assumption that a policeman\u27s good faith reliance is relevant in determining whether the fourth amendment has been violated. That assumption is incompatible with precedent. Prior decisions suggest good faith reliance should not be considered until after the court has established that a violation occurred and applicability of the exclusionary rule is at issue. Without offering a coherent explanation for its departure from precedent, the DeFillippo Court casually added police good faith to the already complex body of substantive search and seizure law. Thus, the decision created yet another dimension of disquieting uncertainty in the doctrine. Moreover, the Court\u27s deference to a police officer\u27s good faith reliance on a substantive law encourages the use of sham substantive offenses to avoid fourth amendment limits. Finally, the Court\u27s emphasis on good faith reliance may misdirect the lower courts, prompting them to substitute the judgments of those who enact and enforce the laws for the disinterested scrutiny of a magistrate

The effect of video venue preaching on Christian life transformation

https://place.asburyseminary.edu/ecommonsatsdissertations/1229/thumbnail.jp

A Preliminary Quantification of the Impacts of Aspen to Conifer Succession on Water Yield Within the Colorado River Basin (A Process Aggravating the Salt Pollution Problem)

Heat pulse velocity techniques were developed for effectively monitoring water movement in aspen (Populus ttremuloides), subalpine fir (Abies lasiocarpa), and Englemann spruce (Picea engelmannii). Once the techniques were perfected, transpiration was monitored in replicated trees of each species for one year. This data was used to modify the plant activity index and the crop coefficient for each species within the model ASPCON, a deterministic, lumped-parameter model describing the hydrology of aspen to conifer succession. Results of the modeling indicate 18.5 cm(7.3 in) net loss of moisture available for stream flow when spruce replace aspen, and a loss of 7.1 cm (2.8 in) when fir forests cover the watershed. The aspen to conifer successional trend is therefore significantly reducing water yields within the Colorado River Basin, water that could be used to dilute salt downstream from the high water-yielding watersheds

Beneficial impacts of a national smokefree environments law on an indigenous population: a multifaceted evaluation

<p>Abstract</p> <p>Background</p> <p>Smokefree environments legislation is increasingly being implemented around the world. Evaluations largely find that the legislation is popular, compliance is high and report improved air quality and reduced exposure to secondhand smoke (SHS). The impact of the legislation on disadvantaged groups, including indigenous peoples has not been explored. We present findings from a multifaceted evaluation of the impact of the smokefree workplace provisions of the New Zealand Smokefree Environments Amendment Act on Māori people in New Zealand. Māori are the indigenous people of New Zealand. The Smokefree Environments Amendment Act extended existing smokefree legislation to almost all indoor workplaces in December 2004 (including restaurants and pubs/bars).</p> <p>Methods</p> <p>Review of existing data and commissioned studies to identify evidence for the evaluation of the new legislation: including attitudes and support for the legislation; stakeholders views about the Act and the implementation process; impact on SHS exposure in workplaces and other settings; and impact on smoking-related behaviours.</p> <p>Results</p> <p>Support for the legislation was strong among Māori and reached 90% for smokefree restaurants and 84% for smokefree bars by 2006. Māori stakeholders interviewed were mostly supportive of the way the legislation had been introduced. Reported exposure to SHS in workplaces decreased similarly in Māori and non-Māori with 27% of employed adult Māori reporting SHS exposure indoors at work during the previous week in 2003 and 9% in 2006. Exposure to SHS in the home declined, and may have decreased more in Māori households containing one or more smokers. For example, the proportion of 14–15 year old Māori children reporting that smoking occurred in their home fell from 47% in 2001 to 37% in 2007. Similar reductions in socially-cued smoking occurred among Māori and non-Māori. Evidence for the effect on smoking prevalence was mixed. Māori responded to the new law with increased calls to the national Quitline service.</p> <p>Conclusion</p> <p>The New Zealand Smokefree Environments Amendment Act had a range of positive effects, including reducing SHS exposure among Māori communities. If the experience is replicated in other countries with indigenous populations, it suggests that comprehensive smokefree environments legislation will have beneficial effects on the health of indigenous groups and could contribute to reducing inequalities in health within societies.</p

Fundamental properties of the mammalian innate immune system revealed by multispecies comparison of type I interferon responses

The host innate immune response mediated by type I interferon (IFN) and the resulting up-regulation of hundreds of interferon-stimulated genes (ISGs) provide an immediate barrier to virus infection. Studies of the type I ‘interferome’ have mainly been carried out at a single species level, often lacking the power necessary to understand key evolutionary features of this pathway. Here, using a single experimental platform, we determined the properties of the interferomes of multiple vertebrate species and developed a webserver to mine the dataset. This approach revealed a conserved ‘core’ of 62 ISGs, including genes not previously associated with IFN, underscoring the ancestral functions associated with this antiviral host response. We show that gene expansion contributes to the evolution of the IFN system and that interferomes are shaped by lineage-specific pressures. Consequently, each mammal possesses a unique repertoire of ISGs, including genes common to all mammals and others unique to their specific species or phylogenetic lineages. An analysis of genes commonly down-regulated by IFN suggests that epigenetic regulation of transcription is a fundamental aspect of the IFN response. Our study provides a resource for the scientific community highlighting key paradigms of the type I IFN response

Unified Communications for Space Inventory Management

To help assure mission success for long-duration exploration activities, NASA is actively pursuing wireless technologies that promote situational awareness and autonomy. Wireless technologies are typically extensible, offer freedom from wire tethers, readily support redundancy, offer potential for decreased wire weight, and can represent dissimilar implementation for increased reliability. In addition, wireless technologies can enable additional situational awareness that otherwise would be infeasible. For example, addition of wired sensors, the need for which might not have been apparent at the outset of a program, night be extremely costly due in part to the necessary routing of cables through the vehicle. RFID, or radio frequency identification, is a wireless technology with the potential for significant savings and increased reliability and safety in space operations. Perhaps the most obvious savings relate to the application of inventory management. A fully automated inventory management system is highly desirable for long-term sustaining operations in space environments. This assertion is evidenced by inventory activities on the International Space Station, which represents the most extensive inventory tracking experience base in the history of space operations. In the short tern, handheld RFID readers offer substantial savings owing to reduced crew time for inventory audits. Over the long term, a combination of improved RFID technology and operational concepts modified to fully utilize the technology should result in space based inventory management that is highly reliable and requires very little crew time. In addition to inventory management, RFID is likely to find space applications in real-time location and tracking systems. These could vary from coarse-resolution RFID portals to the high resolution afforded by ultra-wideband (UWB) RFID. Longer range RFID technologies that leverage passive surface acoustic wave (SAW) devices are being investigated to track assets on a lunar or planetary surface

Fecal Coliform Release Studies and Development of a Preliminary Nonpoint Source Transport Model for Indicator Bacteria

The effect of grazing on water quality has been documented by bacteriological studies of streams adjacent to grazed areas. Bacterial release from fecal deposits is a parameter of the pollution transport mechanism that is poorly understood. The objective of this study was to determine a fecal coliform release function for cattle fecal deposits. Standard cowpies were rained on with a rainfall simulator, and the fecal coliform counts were determined using the most probably number (MPN) method of enumeration. The fecal deposits were rained on at ages 2 through 100 days. The effects of rainfall intensity and recurrent rainfall were tested. Naturally occurring fecal deposits were also tested to compare their results with the results from the standard cowpies. A log-log regression was found to describe the decline in peak fecal coliform release with fecal deposit age. The 100-day-old fecal deposits produced peak counts of 4,200 fecal coliforms per 100 milliliters of water. This quantity of release is insignificant compared to the release from fresher fecal material. Rainfall intensity had little effect on peak fecal coliform release from fecal deposits that ere 2 or 10 days old. At age 20 days the effect of rainfall intensity was significant; the highest intensity gave the lowest peak counts, and the lowest intensity gave the highest peak counts. The effect of rainfall intensity appears to be related to the dryness of the fecal deposits. Peak fecal coliform counts were significantly lowered by raining on the fecal deposits more than once. This decline was thought to be produced by the loss of bacteria from the fecal deposits during the previous wettings. Standard cowpies produced a peak release regression that was not significantly different from the regression for the natural fecal deposits. Apparently, grossly manipulating the fecal deposits did not significantly change the release patterns

Can 100% Pasture-Based Livestock Farming Produce Enough Ruminant Meat to Meet the Current Consumption Demand in the UK?

© 2023 by the authors. Licensee MDPI, Basel, Switzerland. This is an open access article distributed under the terms of the Creative Commons Attribution License (CC BY), https://creativecommons.org/licenses/by/4.0/Grassland is grouped into temporary, permanent, and rough grazing types in the United Kingdom (UK), making up more than 60% of the national agricultural land area. It provides avenues for grazed fodder or ensiled forage contributing a large proportion of the diets consumed by cattle and sheep. The official agricultural census data in 2011 to 2020 showed that, on average, UK cattle and sheep farming can produce meat to satisfy 83.3 and 100.8% of domestic cattle beef and sheep meat consumption levels, respectively. Out of the large agricultural census datasets, we used the populations of cattle and sheep, as well as the UK definition of a standard livestock unit (SLU), to normalise the respective herd populations into a total standard livestock unit (TSLU). We then used the annual domestic meat production in dressed carcass weight to calculate cattle and sheep meat productivity per SLU. Using the potential herbal dry matter yields per year and areas of the different grassland types across the UK, the potential total available pasture feed was calculated. This potential production of herbal biomass was translated into the potential carrying capacity expressed in a TSLU. This total potential carrying capacity was partitioned into cattle and sheep sectors so that the routes of pasture-based-only options with which to produce ruminant meat to meet the current UK domestic consumption demands were assessed. The estimated mean potential annual pasture forage feed in 2011–2020 was approximately 82.0 million (M) metric tonnes (t), which can be translated into a potential carrying capacity of 17.9 M SLUs compared with the current mean 9.36 M SLUs in the survey data of the UK. With the ratio of sheep to cattle at 8.2:25 in the national TSLU, the UK national demands at present consumption levels of cattle and sheep meat can be arithmetically met with pasture grass utilisation rates at or above 65% and 50% by cattle and sheep farming systems, respectively.Peer reviewe

Analysis of Energy Flow in US GLOBEC Ecosystems Using End-to-End Models

End-to-end models were constructed to examine and compare the trophic structure and energy flow in coastal shelf ecosystems of four US Global Ocean Ecosystem Dynamics (GLOBEC) study regions: the Northern California Current, the Central Gulf of Alaska, Georges Bank, and the Southwestern Antarctic Peninsula. High-quality data collected on system components and processes over the life of the program were used as input to the models. Although the US GLOBEC program was species-centric, focused on the study of a selected set of target species of ecological or economic importance, we took a broader community-level approach to describe end-to-end energy flow, from nutrient input to fishery production. We built four end-to-end models that were structured similarly in terms of functional group composition and time scale. The models were used to identify the mid-trophic level groups that place the greatest demand on lower trophic level production while providing the greatest support to higher trophic level production. In general, euphausiids and planktivorous forage fishes were the critical energy-transfer nodes; however, some differences between ecosystems are apparent. For example, squid provide an important alternative energy pathway to forage fish, moderating the effects of changes to forage fish abundance in scenario analyses in the Central Gulf of Alaska. In the Northern California Current, large scyphozoan jellyfish are important consumers of plankton production, but can divert energy from the rest of the food web when abundant