The Charter of Rights and Freedoms and the Rebalancing of Liberal Constitutionalism in Canada, 1982-1997

This article presents a statistical analysis of the first 352 Charter of Rights and Freedoms decisions by the Supreme Court of Canada between 1982 and 1997. The author argues that the emerging approach to Charter review by the Supreme Court of Canada has led to a rebalancing of liberal constitutionalism and to a reconciliation between Charter rights and federalism. This stands in stark contrast to the highly activist approach to Charter review detected in studies by Morton, Russell, and Withey and, to a lesser extent, by Morton, Russell, and Riddell. Several factors illustrate the rebalancing of liberal constitutionalism in Canada. First, the Court\u27s support for the rights claimant has stabilized at 34 per cent. Second, Charter review now focuses on the conduct of public officials; statutes and regulations constitute a declining portion of Charter challenges. This has important implications for the relationship between Charter review and federalism, as the centralization thesis lacks a consistent empirical basis to be a true characterization of the Charters effect on provincial autonomy. Finally, the Court during Lamer C.J.C.\u27s tenure emerged as a centrist Court, as most judges fall within a narrow range of the Court\u27s support rate for the rights claimant in both criminal and non-criminal cases

Fatal Attraction?: Intraguild Facilitation and Suppression Among Predators

Competition and suppression are recognized as dominant forces that structure predator communities. Facilitation via carrion provisioning, however, is a ubiquitous interaction among predators that could offset the strength of suppression. Understanding the relative importance of these positive and negative interactions is necessary to anticipate community-wide responses to apex predator declines and recoveries worldwide. Using state-sponsored wolf (Canis lupus) control in Alaska as a quasi experiment, we conducted snow track surveys of apex, meso-, and small predators to test for evidence of carnivore cascades (e.g., mesopredator release). We analyzed survey data using an integrative occupancy and structural equation modeling framework to quantify the strengths of hypothesized interaction pathways, and we evaluated fine-scale spatiotemporal responses of nonapex predators to wolf activity clusters identified from radio-collar data. Contrary to the carnivore cascade hypothesis, both meso- and small predator occupancy patterns indicated guild-wide, negative responses of nonapex predators to wolf abundance variations at the landscape scale. At the local scale, however, we observed a near guild-wide, positive response of nonapex predators to localized wolf activity. Local-scale association with apex predators due to scavenging could lead to landscape patterns of mesopredator suppression, suggesting a key link between occupancy patterns and the structure of predator communities at different spatial scales

Temperature-tuning of near-infrared monodisperse quantum dot solids at 1.5 um for controllable Forster energy transfer

We present the first time-resolved cryogenic observations of Forster energy transfer in large, monodisperse lead sulphide quantum dots with ground state transitions near 1.5 um (0.83 eV), in environments from 160 K to room temperature. The observed temperature-dependent dipole-dipole transfer rate occurs in the range of (30-50 ns)^(-1), measured with our confocal single-photon counting setup at 1.5 um wavelengths. By temperature-tuning the dots, 94% efficiency of resonant energy transfer can be achieved for donor dots. The resonant transfer rates match well with proposed theoretical models

Semantic Annotation of Mutable Data

Electronic annotation of scientific data is very similar to annotation of documents. Both types of annotation amplify the original object, add related knowledge to it, and dispute or support assertions in it. In each case, annotation is a framework for discourse about the original object, and, in each case, an annotation needs to clearly identify its scope and its own terminology. However, electronic annotation of data differs from annotation of documents: the content of the annotations, including expectations and supporting evidence, is more often shared among members of networks. Any consequent actions taken by the holders of the annotated data could be shared as well. But even those current annotation systems that admit data as their subject often make it difficult or impossible to annotate at fine-enough granularity to use the results in this way for data quality control. We address these kinds of issues by offering simple extensions to an existing annotation ontology and describe how the results support an interest-based distribution of annotations. We are using the result to design and deploy a platform that supports annotation services overlaid on networks of distributed data, with particular application to data quality control. Our initial instance supports a set of natural science collection metadata services. An important application is the support for data quality control and provision of missing data. A previous proof of concept demonstrated such use based on data annotations modeled with XML-Schema