Interpreting Begay After Sykes: Why Reckless Offenses Should Be Eligible To Qualify as Violent Felonies Under the ACCA’s Residual Clause

Passed as part of the Armed Career Criminal Act, 18 U.S.C. § 924(e) subjects felons in possession of firearms to a strict mandatory minimum sentence if the offenders have three prior state or federal convictions that qualify as serious drug offenses or violent felonies. A crime qualifies as a violent felony under the residual clause, 18 U.S.C. § 924(e)(2)(B)(ii), if it is one of the enumerated offenses of burglary, arson, or extortion, involves use of explosives, or otherwise involves conduct that presents a serious potential risk of physical injury to another. Current federal circuit court interpretations of the Supreme Court\u27s decisions in Begay v. United States and Sykes v. United States exclude both crimes with lesser mens rea—recklessness or negligence—and strict-liability crimes from qualifying under the residual clause. This Note proposes that some reckless crimes, like drive-by shooting, would qualify if compared to their closest analogs among the enumerated offenses for purposes of determining similarity in kind, a requirement under Sykes and Begay. This proposed solution would bring some reckless offenses within the scope of the residual clause, allowing for increased, though narrow, targeting of the most dangerous felons: the armed career criminals

Evolution of virulence: triggering host inflammation allows invading pathogens to exclude competitors.

Virulence is generally considered to benefit parasites by enhancing resource-transfer from host to pathogen. Here, we offer an alternative framework where virulent immune-provoking behaviours and enhanced immune resistance are joint tactics of invading pathogens to eliminate resident competitors (transferring resources from resident to invading pathogen). The pathogen wins by creating a novel immunological challenge to which it is already adapted. We analyse a general ecological model of 'proactive invasion' where invaders not adapted to a local environment can succeed by changing it to one where they are better adapted than residents. However, the two-trait nature of the 'proactive' strategy (provocation of, and adaptation to environmental change) presents an evolutionary conundrum, as neither trait alone is favoured in a homogenous host population. We show that this conundrum can be resolved by allowing for host heterogeneity. We relate our model to emerging empirical findings on immunological mediation of parasite competition

Passivation of a Metal Contact with a Tunneling Layer

AbstractThe potential of contact passivation for increasing cell performance is indicated by several results reported in the literature. However, scant characterization of the tunneling layers used for that purpose has been reported. In this paper, contact passivation is investigated by insertion of an ultra-thin AlOx layer between an n-type emitter and a Ti/Pd/Ag contact. By using a 1.5nm thick layer, an increase of the minority carrier lifetime by a factor of 2.7 is achieved. Since current-voltage measurements indicate that an ohmic behavior is conserved for AlOx layers as thick as 1.5nm, a 1.5nm AlOx layer is found to be a candidate of choice for contact passivation

Influence of temperature and relative humidity on survival and fecundity of three tsetse strains

Background: Tsetse flies occur in much of sub-Saharan Africa where they are vectors of trypanosomes that cause human and animal African trypanosomosis. The sterile insect technique (SIT) is currently used to eliminate tsetse fly populations in an area-wide integrated pest management (AW-IPM) context in Senegal and Ethiopia. Three Glossina palpalis gambiensis strains [originating from Burkina Faso (BKF), Senegal (SEN) and an introgressed strain (SENbkf)] were established and are now available for use in future AW-IPM programmes against trypanosomes in West Africa. For each strain, knowledge of the environmental survival thresholds is essential to determine which of these strains is best suited to a particular environment or ecosystem, and can therefore be used effectively in SIT programmes. Methods: In this paper, we investigated the survival and fecundity of three G. p. gambiensis strains maintained under various conditions: 25 °C and 40, 50, 60, and 75 % relative humidity (rH), 30 °C and 60 % rH and 35 °C and 60 % rH. Results: The survival of the three strains was dependent on temperature only, and it was unaffected by changing humidity within the tested range. The BKF strain survived temperatures above its optimum better than the SEN strain. The SENbkf showed intermediate resistance to high temperatures. A temperature of about 32 °C was the limit for survival for all strains. A rH ranging from 40 to 76 % had no effect on fecundity at 25–26 °C. Conclusions: We discuss the implications of these results on tsetse SIT-based control programmes. (Résumé d'auteur

Effects of parenting style upon psychological well-being of young adults: Exploring the relations among parental care, locus of control, and depression.

The current study explores the relations among parenting styles and depression among a representative longitudinal sample of 642 young Dutch adults. We assumed that if parents show their involvement during the first sixteen years of the lives of their children, these children are more likely to develop an internal locus of control. In turn, children with an internal locus of control would be less likely to experience feelings of depression later in life. Additionally, we examined the reverse relation, namely that depression leads to a shift away from the internal pole of the locus of control dimension. These notions were tested using structural equation models. The results indicated that our expectations were largely tenable. However, while the effects of mother's and father's involvement upon the development of an internal locus of control seemed to differ, for depression feelings we did not find much difference. Implications of the study are discussed. © 1997 OPA(Overseas Publishers Association)

Dynamical 1/N approach to time-dependent currents through quantum dots

A systematic truncation of the many-body Hilbert space is implemented to study how electrons in a quantum dot attached to conducting leads respond to time-dependent biases. The method, which we call the dynamical 1/N approach, is first tested in the most unfavorable case, the case of spinless fermions (N=1). We recover the expected behavior, including transient ringing of the current in response to an abrupt change of bias. We then apply the approach to the physical case of spinning electrons, N=2, in the Kondo regime for the case of infinite intradot Coulomb repulsion. In agreement with previous calculations based on the non-crossing approximation (NCA), we find current oscillations associated with transitions between Kondo resonances situated at the Fermi levels of each lead. We show that this behavior persists for a more realistic model of semiconducting quantum dots in which the Coulomb repulsion is finite.Comment: 18 pages, 7 eps figures, discussion extended for spinless electrons and typo

Analysis of the proteins synthesized in ultraviolet light-irradiated Escherichia coli following infection with the bacteriophages λ drif d 18 and λ dfus -3

The presence of EF-Tu, RNA polymerase subunit α, and EF-G on the λ dfus -3 genome and EF-Tu, ribosomal proteins L7/L12, and RNA polymerase subunit β on the λ drif d 18 genome has been confirmed using a two-dimensional gel electrophoresis technique sensitive to changes in isoelectric point and molecular weight. In this system two EF-Tu gene products could not be resolved. Following infection of ultraviolet light-irradiated Escherichia coli with either λ dfus -3 or λ drif d 18, the EF-Tu gene, tufA , near 65 minutes on the genetic map is expressed as 3–4 copies per EF-G molecule. The EF-Tu gene, tufB , near 79 minutes on the genetic map, is expressed at about one-third of this rate. α is expressed as 1 copy per EF-G molecule, β as 0.14 per EF-G molecule and L7/L12 as 2.5 per EF-G. These figures compare well with the relative amounts found in exponentially-growing cells, in which the ratio of EF-Tu to EF-G is approximately 5. Almost 90% of the total number of proteins (calculated on a molecular weight basis) which theoretically can be encoded on the λ drif d 18 have been identified on the two-dimensional gel.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/47541/1/438_2004_Article_BF00341733.pd

Prevalence of trypanosomes, salivary gland hypertrophy virus and Wolbachia in wild populations of tsetse flies from West Africa

Background: Tsetse flies are vectors of African trypanosomes, protozoan parasites that cause sleeping sickness (or human African trypanosomosis) in humans and nagana (or animal African trypanosomosis) in livestock. In addition to trypanosomes, four symbiotic bacteria Wigglesworthia glossinidia, Sodalis glossinidius, Wolbachia, Spiroplasma and one pathogen, the salivary gland hypertrophy virus (SGHV), have been reported in different tsetse species. We evaluated the prevalence and coinfection dynamics between Wolbachia, trypanosomes, and SGHV in four tsetse species (Glossina palpalis gambiensis, G. tachinoides, G. morsitans submorsitans, and G. medicorum) that were collected between 2008 and 2015 from 46 geographical locations in West Africa, i.e. Burkina Faso, Mali, Ghana, Guinea, and Senegal. Results: The results indicated an overall low prevalence of SGHV and Wolbachia and a high prevalence of trypanosomes in the sampled wild tsetse populations. The prevalence of all three infections varied among tsetse species and sample origin. The highest trypanosome prevalence was found in Glossina tachinoides (61.1%) from Ghana and in Glossina palpalis gambiensis (43.7%) from Senegal. The trypanosome prevalence in the four species from Burkina Faso was lower, i.e. 39.6% in Glossina medicorum, 18.08%; in Glossina morsitans submorsitans, 16.8%; in Glossina tachinoides and 10.5% in Glossina palpalis gambiensis. The trypanosome prevalence in Glossina palpalis gambiensis was lowest in Mali (6.9%) and Guinea (2.2%). The prevalence of SGHV and Wolbachia was very low irrespective of location or tsetse species with an average of 1.7% for SGHV and 1.0% for Wolbachia. In some cases, mixed infections with different trypanosome species were detected. The highest prevalence of coinfection was Trypanosoma vivax and other Trypanosoma species (9.5%) followed by coinfection of T. congolense with other trypanosomes (7.5%). The prevalence of coinfection of T. vivax and T. congolense was (1.0%) and no mixed infection of trypanosomes, SGHV and Wolbachia was detected. Conclusion: The results indicated a high rate of trypanosome infection in tsetse wild populations in West African countries but lower infection rate of both Wolbachia and SGHV. Double or triple mixed trypanosome infections were found. In addition, mixed trypanosome and SGHV infections existed however no mixed infections of trypanosome and/or SGHV with Wolbachia were found