How the Court Got It Wrong in Woodford v. NGO By Saying No to Simple Administrative Exhaustion Under the PLRA

Congress has estimated that the number of people who have been sexually assaulted in America\u27s prisons over the past twenty years tops one million. Some inmates are sexually assaulted by guards, and some by other inmates, facilitated by guards. The problem is so rampant that Congress enacted the Prison Rape Elimination Act of 2003. Though the State has a constitutional obligation to provide humane conditions of confinement, sometimes it fails. To receive compensation for or relief from such harm, a prisoner must conform to the guidelines provided in the Prison Litigation Reform Act of 1995 (PLRA), which requires an inmate to file a grievance for his injury with the very administration responsible for not providing humane conditions. Additionally, a prisoner who has just suffered the assault has a limited time in which to lodge his complaint, generally no more than fifteen days, and in nine states only between two and five days. A proper exhaustion requirement precludes an inmate from filing a lawsuit in federal court unless he has proceeded through each step of his prison\u27s grievance procedure while meeting all procedural requirements, including deadlines. On the other hand, simple exhaustion, or exhaustion simpliciter, permits an inmate to file a lawsuit as long as the administrative grievance procedure is no longer available, provided that he has not intentionally circumvented the administrative process

Forestry policy and practices of the People's Republic of Kampuchea, 1979-1989

What amounts to the squandering of Cambodia's natural resources since 1991 stands in sharp contrast to the stewardship mentality that appears to have pervaded the PRK government's approach to forestry management throughout the 1980s. As evidenced by the internal documents of the regime that have been cited throughout this paper, forestry policy was in line with the scale of needs required for national reconstruction after the catastrophe of the preceding 10 years of bitter civil conflict. Forests were exploited for development purposes, to raise revenue, earn foreign currency, and repay loans according to contracts taken out with countries providing assistance, particularly Vietnam. Theft was investigated and other abuses were roundly condemned, as the report of the Economic Commission to the thirteenth session of the National Assembly in 1987 illustrates. The Center drafted and passed laws to regulate the forestry industry. Structures were put in place to oversee the implementation of those laws and regulations. That those same laws and regulations were apparently so easily circumvented and contravened had as much to do with the fragile nature of the PRK local-level administration as it did with traditional patterns and notions of power in Cambodia. Provincial governors and department chiefs took advantage of the Center's weaknesses, as well as of the privileges granted by the system of provinces twinned with Vietnam, to recreate their fiefdoms. Given the client-state nature of the PRK regime, Cambodian forestry department officials were helpless in the face of rebel PAVN units that stole timber. As the dynamics of international politics shifted toward the end of the decade, ideological conviction gave way to personal greed and ambition. Regional forestry policies also played their part, as logging bans in neighbouring countries brought pressure to bear on Cambodia's own rich forest resources. The PRK period was one of genuine achievement in the face of overwhelming odds. The C̀ambodian people can only hope that this current and overly long period of "transition" will soon end and that balance will be restored to the country's forestry policies and practices

The Commercialisation of Rice Farming in Cambodia

In this and the next five chapters the focus is on the commercialisation of rice farming in the Central Plain of Cambodia. Particularly since 2010, rice has come to be seen as more than merely a subsistence crop or a staple for domestic consumption but as “white gold”—a commodity with major commercial, including export potential. This chapter sets the scene for the in-depth studies on the commercialisation of rice farming in Cambodia by describing the rice-growing environment in Cambodia as a whole, outlining the history of rice production in Cambodia, examining the role of the rice sector in the rapid agricultural and economic growth in Cambodia since 1993, highlighting the changes at the farm level that have underpinned this agricultural growth, and providing a profile of Takeo Province within this larger context. Cambodia has a long history and comparative advantage in rice production. With relative political stability and access to improved varieties and other inputs, farmers have been able to increase the area cultivated and especially per-hectare yields so that total production has grown at over 5% since 1990. From being a rice-deficit country in the 1980s, the country has achieved self-sufficiency and, since 2010, become a serious exporter of paddy and milled rice. Rice farmers in Takeo Province have long made an important contribution to Cambodia’s rice production and currently contribute 8% of wet season output and 19% of dry season output, as well as a major share of exports

The Rich Get Richer: Brain Injury Elicits Hyperconnectivity in Core Subnetworks

<div><p>There remains much unknown about how large-scale neural networks accommodate neurological disruption, such as moderate and severe traumatic brain injury (TBI). A primary goal in this study was to examine the alterations in network topology occurring during the first year of recovery following TBI. To do so we examined 21 individuals with moderate and severe TBI at 3 and 6 months after resolution of posttraumatic amnesia and 15 age- and education-matched healthy adults using functional MRI and graph theoretical analyses. There were two central hypotheses in this study: 1) physical disruption results in increased functional connectivity, or hyperconnectivity, and 2) hyperconnectivity occurs in regions typically observed to be the most highly connected cortical hubs, or the “rich club”. The current findings generally support the hyperconnectivity hypothesis showing that during the first year of recovery after TBI, neural networks show increased connectivity, and this change is disproportionately represented in brain regions belonging to the brain's core subnetworks. The selective increases in connectivity observed here are consistent with the preferential attachment model underlying scale-free network development. This study is the largest of its kind and provides the unique opportunity to examine how neural systems adapt to significant neurological disruption during the first year after injury.</p></div

Probability distribution for TBI and HC groups at separate time points.

<p>Degree distributions for healthy control and TBI samples. Node degree (k), calculated as the sum of the weights on edges incident to a given node, is plotted against the fraction of nodes having given degree P(k), for each group at each time point. Values binned at increments of 2. <b>Inset</b>: the frequency of component members appearing in the heavy tail of p(k), or the most highly connected nodes. A-insula-ACC = anterior insula-anterior cingulate cortex (anterior salience network); dDMN = posterior cingulate to medial frontal (dorsal default mode network); LECN = Left dorsolateral prefrontal cortex and parietal (executive control network; P-insula = posterior insula (Salience Network); Par-FEF: Intraparietal Sulcus/Frontal Eye Fields (Visuospatial Network); RECN = right dorsolateral prefrontal cortex and parietal (executive control network); vDMN = Retrosplenial Cortex/Medial Temporal Lobe (Ventral Default Mode Network); B.Ganglia = basal ganglia. <b><i>Note</i></b>: inset is collapsed to include all possible components assigned to each specific subnetwork and organized from highest to lowest node incidence in the TBI sample.</p