A Reexamination of the Non-Dischargeability of Criminal Restitutive Obligations in Chapter 13 Bankruptcies

In 1990, the Supreme Court held that criminal restitution was dischargeable as a debt in a Chapter 13 bankruptcy proceeding. Congress subsequently amended the bankruptcy laws to exclude criminal restitution from the debts dischargeable in Chapter 13 proceedings. This amendment represents the elevation of the states\u27 interest in their criminal laws at the expense of the policies served by the bankruptcy laws. By tracing the origins of criminal restitution as a form of punishment, examining the development of bankruptcy discharge policy, and considering the interrelation of state and federal laws, this Note proposes a more equitable solution. Rather than viewing the conflict between the aims of the states\u27 criminal laws and the aims of the federal bankruptcy laws as irreconcilable, this Note suggests the use of a conditional discharge so that both aims can be served

Dynamic Reflectarray Technology for Electro-Optical Sensors

An array of two or more tunable electro-optical reflecting elements where the phase response of one to more elements may be adjusted by a variety of approaches including, but not limited to a liquid crystal superstrate, schottky contact(s), ultra-violet radiation pulses, and illumination of photoconductive substances. Methods and apparatus for direct and/or adaptive control of phase response via the above approaches are also discussed

The relationship between nurse staffing and inpatient complications

Aim: To compare characteristics of hospitalizations with and without complications and examine the impact of nurse staffing on inpatient complications across different unit types. Background: Studies investigating the relationship between nurse staffing and inpatient complications have not shown consistent results. Methodological limitations have been cited as the basis for this lack of uniformity. Our study was designed to address some of these limitations. Design: Retrospective longitudinal hospitalization-level study. Method: Adult hospitalizations to high intensity, general medical and general surgical units at three metropolitan tertiary hospitals were included. Data were sourced from Western Australian Department of Health administrative data collections from 2004–2008. We estimated the impact of nurse staffing on inpatient complications adjusted for patient and hospital characteristics and accounted for patients with multiple hospitalizations. Results: The study included 256,984 hospitalizations across 58 inpatient units. Hospitalizations with complications had significantly different demographic characteristics compared with those without. The direction of the association between nurse staffing and inpatient complications was not consistent for different inpatient complications, nurse skill mix groups or for hospitalizations with different unit movement patterns. Conclusion: Our study design addressed limitations noted in the field, but our results did not support the widely held assumption that improved nurse staffing levels are associated with decreased patient complication rates. Despite a strong international focus on improving nurse staffing to reduce inpatient complications, our results suggest that adding more nurses is not a panacea for reducing inpatient complications to zero