CONSTITUTIONAL LAW--DUE PROCESS AND THE BILL OF RIGHTS--SELF-INCRIMINATION

In the course of evolving workable doctrines which give substance and meaning to the skeletal phrase due process of law as used in the Fourteenth Amendment to limit state action, the Supreme Court has frequently been called on to determine the scope of the several prohibitions and guarantees of the Bill of Rights of the federal Constitution. This general problem, and more particularly the application of the Fifth Amendment self-incrimination clause to state criminal proceedings, was again presented in a recent case and resulted in a sharp division of opinion within the Court

PROCESS-OBTAINING PERSONAL JURISDICTION OVER FOREIGN CORPORATION BY SERVICE OF PROCESS ON LOCAL SALES AGENT

Defendant, a Texas manufacturing corporation, employed a corporate agent to solicit orders in New York. The agent maintained a showroom, used defendant\u27s name on its office door and stationery, and paid all the expenses of the New York business out of sales commissions. All orders were subject, to acceptance by the defendant and were filled from Texas. In an action for trade-mark infringement brought in the New York state court and removed to the federal district court, service of summons and complaint was made upon the manager of the New York agency. The district court quashed the service and dismissed the complaint for want of jurisdiction, holding that mere solicitation of orders plus defendant\u27s other local activities did not subject defendant to personal service. On appeal, held, reversed. Service was properly made under New York law, and there is no such burden on defendant as to make the service invalid under the federal Constitution. Bomze v. Nardis Sportswear, Inc., (C.C.A. 2d, 1948) 165 F. (2d) 33

WILLS-DEPENDENT RELATIVE REVOCATION WHEN REVOCATORY CODICIL CONTAINS INEFFECTIVE SUBSTITUTED BEQUEST

Testator\u27s will, executed in 1926, provided a trust fund for his adopted daughter, then a minor, and named his wife as residuary legatee. By the terms of the will the daughter was to receive the trust income after she became twenty-one and the principal when she reached the age of thirty-five. In 1942, when the daughter was thirty-one, married, and the mother of two children, the testator added a codicil which included the following provision: I hereby revoke the Trust Fund in favor of my Daughter Mildred, and substitute a lump sum of ___ dollars in cash. The testator died in 1946 without having completed the blank space in the codicil. The probate court held that the revocation was ineffective. On appeal by the widow, held, affirmed. Since the dispositive part of the codicil failed because of an intrinsic defect of the instrument, the doctrine of dependent relative revocation applies. In Re Braun\u27s Estate, (Pa. 1948) 56 A. (2d) 201

Is increased hepatitis C virus case-finding combined with current or 8-week to 12-week direct-acting antiviral therapy cost-effective in UK prisons? A prevention benefit analysis

UNLABELLED: Prisoners have a high prevalence of hepatitis C virus (HCV), but case-finding may not have been cost-effective because treatment often exceeded average prison stay combined with a lack of continuity of care. We assessed the cost-effectiveness of increased HCV case-finding and treatment in UK prisons using short-course therapies. A dynamic HCV transmission model assesses the cost-effectiveness of doubling HCV case-finding (achieved through introducing opt-out HCV testing in UK pilot prisons) and increasing treatment in UK prisons compared to status quo voluntary risk-based testing (6% prison entrants/year), using currently recommended therapies (8-24 weeks) or interferon (IFN)-free direct-acting antivirals (DAAs; 8-12 weeks, 95% sustained virological response, £3300/week). Costs (British pounds, £) and health utilities (quality-adjusted life years) were used to calculate mean incremental cost-effectiveness ratios (ICERs). We assumed 56% referral and 2.5%/25% of referred people who inject drugs (PWID)/ex-PWID treated within 2 months of diagnosis in prison. PWID and ex-PWID or non-PWID are in prison an average 4 and 8 months, respectively. Doubling prison testing rates with existing treatments produces a mean ICER of £19,850/quality-adjusted life years gained compared to current testing/treatment and is 45% likely to be cost-effective under a £20,000 willingness-to-pay threshold. Switching to 8-week to 12-week IFN-free DAAs in prisons could increase cost-effectiveness (ICER £15,090/quality-adjusted life years gained). Excluding prevention benefit decreases cost-effectiveness. If >10% referred PWID are treated in prison (2.5% base case), either treatment could be highly cost-effective (ICER<£13,000). HCV case-finding and IFN-free DAAs could be highly cost-effective if DAA cost is 10% lower or with 8 weeks' duration. CONCLUSIONS: Increased HCV testing in UK prisons (such as through opt-out testing) is borderline cost-effective compared to status quo voluntary risk-based testing under a £20,000 willingness to pay with current treatments but likely to be cost-effective if short-course IFN-free DAAs are used and could be highly cost-effective if PWID treatment rates were increased. (Hepatology 2016;63:1796-1808)

A hepatitis C avidity test for determining recent and past infections in both plasma and dried blood spots

DBS testing has been used successfully to detect HCV antibody positive individuals. Determining how long someone has been infected is important for surveillance initiatives. Antibody avidity is a method that can be used to calculate recency of infection. A HCV avidity assay was evaluated for both plasma and DBS. Study design: To measure antibody avidity a commercial HCV ELISA was modified using 7 M urea. The plasma samples were split into: group 1 (recently infected N = 19), group 2 (chronic carrier N = 300) and group 3 (resolved infection N = 82). Mock DBS made from group 1 (N = 12), group 2 (N = 50), group 3 (N = 25) and two seroconverter panels were evaluated. 133 DBS taken from patients known to have a resolved infection or be a chronic carrier were also tested. The avidity assay cut-off was set at AI ≤ 30 for a recent infection. Using sequential samples the assay could detect a recent infection in the first 4–5 months from the point of infection. Most of the false positive results (AI < 30 among cases known not to have had recent infection) were detected among known resolved infections, in both the plasma and DBS; as a result, a testing algorithm has been designed incorporating both PCR and two dilution factors. The sensitivity and specificity of the assay on plasma was 100% and 99.3%, respectively, while DBS had 100% sensitivity and 98.3% specificity. The HCV avidity assay can be used to distinguish between chronic and recent infection using either plasma or DBS as the sample type

12．グルタミン酸ナトリウムはglucagon like peptide-1の食後早期の分泌を促進し, 食後血糖の上昇を抑制する

The purpose of this study was to compare the growth and nutritional status of infants fed different diets, some of whom received a low-fat formula. Beginning at four to six months of age, 101 infants were fed whole cow\u27s milk, one of two low-fat follow-up formulas, or a standard infant formula until 12 months of age. Weight, recumbent length, and head circumference were measured at one-month intervals. Analyses of status (values at an age) for all examinations showed no significant differences among the feeding groups in status for weight or recumbent length, but there were significant differences in head circumference for boys and for girls after adjustments for the initial values. Head circumferences were smaller in those fed whole cow\u27s milk and relatively large in those fed follow-up formula, but these differences were small and not of clinical significance. Comparisons with national reference data showed growth in weight, recumbent length, and head circumference was normal regardless of feeding group. These results indicate that, during the second half year of infancy, the use of lower fat concentrations in the follow-up formulas did not retard growth in weight, recumbent length, or head circumference

Performance of Monolayer Graphene Nanomechanical Resonators with Electrical Readout

The enormous stiffness and low density of graphene make it an ideal material for nanoelectromechanical (NEMS) applications. We demonstrate fabrication and electrical readout of monolayer graphene resonators, and test their response to changes in mass and temperature. The devices show resonances in the MHz range. The strong dependence of the resonant frequency on applied gate voltage can be fit to a membrane model, which yields the mass density and built-in strain. Upon removal and addition of mass, we observe changes in both the density and the strain, indicating that adsorbates impart tension to the graphene. Upon cooling, the frequency increases; the shift rate can be used to measure the unusual negative thermal expansion coefficient of graphene. The quality factor increases with decreasing temperature, reaching ~10,000 at 5 K. By establishing many of the basic attributes of monolayer graphene resonators, these studies lay the groundwork for applications, including high-sensitivity mass detectors

Ancient DNA evidence for the ecological globalization of cod fishing in medieval and post-medieval Europe

Understanding the historical emergence and growth of long-range fisheries can provide fundamental insights into the timing of ecological impacts and the development of coastal communities during the last millennium. Whole-genome sequencing approaches can improve such understanding by determining the origin of archaeological fish specimens that may have been obtained from historic trade or distant water. Here, we used genome-wide data to individually infer the biological source of 37 ancient Atlantic cod specimens (ca 1050-1950 CE) from England and Spain. Our findings provide novel genetic evidence that eleventh- to twelfth-century specimens from London were predominantly obtained from nearby populations, while thirteenth- to fourteenth-century specimens were derived from distant sources. Our results further suggest that Icelandic cod was indeed exported to London earlier than previously reported. Our observations confirm the chronology and geography of the trans-Atlantic cod trade from Newfoundland to Spain starting by the early sixteenth century. Our findings demonstrate the utility of whole-genome sequencing and ancient DNA approaches to describe the globalization of marine fisheries and increase our understanding regarding the extent of the North Atlantic fish trade and long-range fisheries in medieval and early modern time

Prospective, multicenter study of managing lower extremity venous ulcers

Seventy patients with 90 venous ulcers were randomly assigned to hydrocolloid or conventional dressing and compression therapy at four study centers. The ulcers had been present for a mean of 47.8 in the control and 46.2 weeks in the treatment group and 42% of all patients had recurrent ulcers. Ulcers treated with hydrocolloid dressings reduced 71% and control treated wounds reduced 43% in area after 7.2 weeks of treatment. Thirty-four percent of all ulcers healed. Mean time to healing was 7 weeks for the hydrocolloid dressing group and 8 weeks for the control group. Most ulcers were less painful at final evaluation, but reduction in pain was more pronounced in hydrocolloid-dressed ulcers ( p =0.03). At baseline as well as during follow-up, significant differences between study centers were observed. Ulcers in patients in the United Kingdom were larger and less likely to heal ( p =0.001). Size of the ulcer at baseline was associated with treatment response and time to healing ( p =0.002). Percent reduction in ulcer area after 2 weeks was also correlated with treatment outcome ( p =0.004) and time to healing ( p =0.002). When all treatment outcome predictors were analyzed together, only percent reduction in area after 2 weeks remained statistically significant ( p =0.002), with percent reduction during the first 2 weeks of treatment >30% predicting healing .Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/41373/1/10016_2005_Article_BF02132997.pd