Locke v. United States and the Definition of Probable Cause in U.S. Civil Forfeiture Proceedings

United States civil forfeiture laws are rooted in admiralty in rem forfeiture proceedings that go back to mid-1700s English customs law, and a statute called the Act of Frauds. The procedure was born of the necessity of international marine trade. Similarly, when it came to using in rem seizure to enforce the customs laws, the Crown used a burden shifting presumption that was also born of necessity. Vessel owners were required to come forward and exculpate their vessel once the Crown showed probable cause of a violation. In Locke v. United States, Justice Marshall upheld that burden shifting presumption and the definition of probable cause in the admiralty in rem seizure context as a showing of reasonable suspicion, something less than a prima facie case. Sixty years later, however, the United States courts would begin to uphold uses of in rem forfeiture outside of the context of customs law, and today, statutory forfeiture provisions are constitutional scholars question whether or not civil forfeiture proceedings, having entered the law in the narrow context of admiralty in rem forfeiture proceedings, do an end run around the Fourth Amendment and Due Process. The Locke Court never heard or considered any constitutional argument

Kalman Filter Estimation for Focal Plane Wavefront Correction

Space-based coronagraphs for future earth-like planet detection will require focal plane wavefront control techniques to achieve the necessary contrast levels. These correction algorithms are iterative and the control methods require an estimate of the electric field at the science camera, which requires nearly all of the images taken for the correction. We demonstrate a Kalman filter estimator that uses prior knowledge to create the estimate of the electric field, dramatically reducing the number of exposures required to estimate the image plane electric field. In addition to a significant reduction in exposures, we discuss the relative merit of this algorithm to other estimation schemes, particularly in regard to estimate error and covariance. As part of the reduction in exposures we also discuss a novel approach to generating the diversity required for estimating the field in the image plane. This uses the stroke minimization control algorithm to choose the probe shapes on the deformable mirrors, adding a degree of optimality to the problem and once again reducing the total number of exposures required for correction. Choosing probe shapes has been largely unexplored up to this point and is critical to producing a well posed set of measurements for the estimate. Ultimately the filter will lead to an adaptive algorithm which can estimate physical parameters in the laboratory and optimize estimation.Comment: 14 pages, 9 figures, SPIE Astronomical Telescopes and Instrumentation 2012 conference proceedings. Journal version at arXiv:1301.382

ANALYSIS OF THE DELAWARE MARKET FOR ORGANICALLY GROWN PRODUCE

Agribusiness,

New tools and new tests in comparative political economy - the database of political institutions

This paper introduces a large new cross-country database on political institutions: the Database on Political Institutions (DPI). The authors summarize key variables (many of them new), compare this data set with others, and explore the range of issues for which the data should prove invaluable. Among the novel variables they introduce: 1) Several measures of tenure, stability, and checks and balances. 2) Identification of parties with the government coalition or the opposition. 3) Fragmentation of opposition and government parties in legislatures. The authors illustrate the application of DPI variables to several problems in political economy. Stepan and Skach, for example, find that democracy is more likely to survive under parliamentary governments than presidential systems. But this result is not robust to the use of different variables from the DPI, which raises puzzles for future research. Similarly, Roubini and Sachs, find that divided governments in the OECD run higher budget deficits after fiscal shocks. Replication of their work using DPI indicators of divided government indicates otherwise, again suggesting issues for future research. Among questions in political science and economics, that this database may illuminate: the determinants of democratic consolidation, the political conditions for economic reform, the political and institutional roots of corruption, and the elements of appropriate and institutionally sensitive design of economic policy.Decentralization,Parliamentary Government,National Governance,Information Technology,ICT Policy and Strategies,National Governance,Parliamentary Government,ICT Policy and Strategies,Information Technology,Governance Indicators

New tools in comparative political economy: The database of political institutions.

[Dataset available: http://hdl.handle.net/10411/15987]