Examining Montana\u27s Right to Attack Unconstitutional Prior Convictions at Sentencing: State v. Maine

The Maine Court had good reason to reject Custis. Between 1967 when Burgett announced the rule that a current sentence could not be enhanced based on an unconstitutional prior sentence and 1994 when Custis limited the scope of that rule, all but one of the federal circuit courts to consider the issue held the Burgett Court’s rationale for barring the use of a conviction obtained in violation of Gideon must apply to other constitutional rights as well. The arguments for limiting collateral attacks on prior convictions at sentencing to only claims of Gideon violations are unpersuasive. Faced with the decision of either following Custis or rejecting it, the Montana Supreme Court wisely chose to reject it. It may find in the future, however, that there are good reasons to restrict the scope of Maine to exclude claims that don’t undermine confidence in the reliability of a prior conviction

Examining Montana\u27s Right to Attack Unconstitutional Prior Convictions at Sentencing: State v. Maine

The Maine Court had good reason to reject Custis. Between 1967 when Burgett announced the rule that a current sentence could not be enhanced based on an unconstitutional prior sentence and 1994 when Custis limited the scope of that rule, all but one of the federal circuit courts to consider the issue held the Burgett Court’s rationale for barring the use of a conviction obtained in violation of Gideon must apply to other constitutional rights as well. The arguments for limiting collateral attacks on prior convictions at sentencing to only claims of Gideon violations are unpersuasive. Faced with the decision of either following Custis or rejecting it, the Montana Supreme Court wisely chose to reject it. It may find in the future, however, that there are good reasons to restrict the scope of Maine to exclude claims that don’t undermine confidence in the reliability of a prior conviction

Spectrally-resolved Imaging of the Transverse Modes in Multimode VCSELs

Vertical-cavity surface-emitting lasers (VCSELs) enable a range of applications such as data transmission, trace sensing, atomic clocks, and optical mice. For many of these applications, the output power and beam quality are both critical (i.e. high output power with good beam quality is desired). Multi-mode VCSELs offer much higher power than single-mode devices, but this comes at the expense of lower beam quality. Directly observing the resolved mode structure of multi-mode VCSELs would enable engineers to better understand the underlying physics and help them to develop multi-mode devices with improved beam quality. In this work, a low-cost, high-resolution (\u3c3 \u3epm) Echelle grating spectrometer system is used to map the two-dimensional VCSEL near-field emission profile. The system spectrally disperses the VCSEL beam and images it with high magnification onto a CMOS camera. The narrow spectral content of each LP mode allows direct observation of the modal content of the VCSEL

Stillbirths: recall to action in high-income countries.

Variation in stillbirth rates across high-income countries and large equity gaps within high-income countries persist. If all high-income countries achieved stillbirth rates equal to the best performing countries, 19,439 late gestation (28 weeks or more) stillbirths could have been avoided in 2015. The proportion of unexplained stillbirths is high and can be addressed through improvements in data collection, investigation, and classification, and with a better understanding of causal pathways. Substandard care contributes to 20-30% of all stillbirths and the contribution is even higher for late gestation intrapartum stillbirths. National perinatal mortality audit programmes need to be implemented in all high-income countries. The need to reduce stigma and fatalism related to stillbirth and to improve bereavement care are also clear, persisting priorities for action. In high-income countries, a woman living under adverse socioeconomic circumstances has twice the risk of having a stillborn child when compared to her more advantaged counterparts. Programmes at community and country level need to improve health in disadvantaged families to address these inequities.Mater Research Institute – The University of Queensland provided infrastructure and funding for the research team to enable this work to be undertaken. The Canadian Research Chair in Psychosocial Family Health provided funding for revision of the translation of the French web-based survey of care providers.This is the author accepted manuscript. The final version is available from Elsevier via http://dx.doi.org/10.1016/S0140-6736(15)01020-

Care in subsequent pregnancies following stillbirth: An international survey of parents

Objective: To assess the frequency of additional care, and parents' perceptions of quality, respectful care in pregnancies subsequent to stillbirth. Design: Multi-language web-based survey. Setting: International. Population: 2,716 parents, from 40 high- and middle-income countries. Methods: Data were obtained from a broader survey of parentsâ experiences of stillbirth. Data were analyzed using descriptive statistics and stratified by geographical region. Subgroup analyses explored variation in additional care by gestational age at index stillbirth. Main outcome measures: Frequency of additional care, and perceptions of quality, respectful care. Results: The majority (66%) of parents conceived their subsequent pregnancy within one year of stillbirth. Additional antenatal care visits and ultrasound scans were provided for 67% and 70% of all parents, respectively, although there was wide variation across geographical regions. Care addressing psychosocial needs was less frequently provided, such as visits to a bereavement counsellor (10%) and access to named care provider's phone number (27%). Compared to parents whose stillbirth occurred at 29 weeks' gestation or less, parents whose stillbirth occurred at 30 weeksâ gestation or greater were more likely to receive various forms of additional care, particularly the option for early delivery after 37 weeks. Around half (47-63%) of all parents felt that elements of quality, respectful care were consistently applied, such as spending enough time with parents and involving parents in decision-making. Conclusions: Care in pregnancies subsequent to stillbirth appears inconsistent. Greater attention is required to providing thoughtful, empathic, and collaborative care in all pregnancies following stillbirth. Training for health professionals is needed

Proton-Implanted Photonic Crystal and Holey Vertical -Cavity Surface -Emitting Lasers

81 p.Thesis (Ph.D.)--University of Illinois at Urbana-Champaign, 2007.Etched photonic crystals and wedge-shaped holes are fabricated in the top mirror of proton-implanted vertical-cavity surface-emitting laser (VCSEL) diodes to achieve single-fundamental-mode operation. A model of the effective transverse index of refraction profile for both cases is presented. The holes are etched a variety of depths for various designs to study the influence on single-mode emission. To investigate both the index confinement provided by the etched pattern and its effect on optical loss, continuous-wave and pulsed excitation experiments are performed. It is shown that proper pattern design leads to improved fundamental-mode output power, decreased threshold, and increased efficiency relative to unetched, but otherwise identical implant VCSELs. These improvements indicate a significant reduction in diffraction loss to the fundamental mode due to the index guiding provided by the etched pattern. Etching to shallow depths provides the ability to scale to large aperture sizes while etching deeply allows single-mode emission of small diameter devices. Optimized designs are then used in the fabrication of high-speed VCSELs with coplanar contacts on polyimide. The effect of photonic crystal design, and its associated improvements to loss and increased parasitic resistance, on small-signal modulation bandwidth is studied. Optimized devices exhibit a record 15-GHz small-signal modulation bandwidth.U of I OnlyRestricted to the U of I community idenfinitely during batch ingest of legacy ETD