Brief of Scholars of the History and Original Meaning of the Fourth Amendment as Amici Curiae in Support of Petitioner, Carpenter v. United States, No. 16-402 (U.S. Aug. 14, 2017)

Obtaining and examining cell site location records to find a person is a “search” in any normal sense of the word — a search of documents and a search for a person and her personal effects. It is therefore a “search” within the meaning of the Fourth Amendment in that it constitutes “examining,” “exploring,” “looking through,” “inquiring,” “seeking,” or “trying to find.” Nothing about the text of the Fourth Amendment, or the historical backdrop against which it was adopted, suggests that “search” should be construed more narrowly as, for example, intrusions upon subjectively manifested expectations of privacy that society is prepared to recognize as reasonable.Entrusting government agents with unfettered discretion to conduct searches using cell site location information undermines Fourth Amendment rights. The Amendment guarantees “[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches.” The Framers chose that language deliberately. It reflected the insecurity they suffered at the hands of “writs of assistance,” a form of general warrant that granted state agents broad discretion to search wherever they pleased. Such arbitrary power was “unreasonable” to the Framers, being “against the reason of the common law,” and it was intolerable because of its oppressive impact on “the people” as a whole. As emphasized in one of the seminal English cases that inspired the Amendment, this kind of general power to search was “totally subversive of the liberty of the subject.” James Otis’s famous speech denouncing a colonial writ of assistance similarly condemned those writs as “the worst instrument of arbitrary power,” placing “the liberty of every man in the hands of every petty officer.” Thus, although those who drafted and ratified the Fourth Amendment could not have anticipated cellphone technology, they would have recognized the dangers inherent in any state claim of unlimited authority to conduct searches for evidence of criminal activity. Cell site location information provides insight into where we go and what we do. Because this information is constantly generated and can be retrieved by the government long after the activities it memorializes have taken place, unfettered government access to cell site location information raises the specter of general searches and undermines the security of “the people.

Steady State Performance Prediction Of Directly Lubricated Fluid Film Journal Bearings

LecturePredicting the performance of directly lubricated bearings is a challenge facing bearing manufacturers and end users alike. In this study, thermoelastohydrodynamic (TEHD) theories are applied to analyze three directly lubricated bearings that have been experimentally investigated by the Turbomachinery Laboratory at Texas A&M University, including two inlet groove bearings and one spray bar bearing. The main aspects of the TEHD models are presented, including an extensive discussion on groove mixing. Comparisons are made between the theoretical and experimental results for the pad temperatures and shaft centerline locations. The results, which show generally good agreement, indicate that the TEHD theories are capable of predicting the steady state performance of these directly lubricated bearings with reasonable accuracy. Limitations of the simple groove mixing model and the elastic model were also identified

Fundamentals of Fluid Film Journal Bearing Operation and Modeling

TutorialTutorial 14: Widely used in turbomachinery, the fluid film journal bearing is critical to a machine’s overall reliability level. Their design complexity and application severity continue to increase making it challenging for the plant machinery engineer to evaluate their reliability. This tutorial provides practical knowledge on their basic operation and what physical effects should be included in modeling a bearing to help ensure its reliable operation in the field. All the important theoretical aspects of journal bearing modeling, such as film pressure, film and pad temperatures, thermal and mechanical deformations and turbulent flow are reviewed. Through some examples, the tutorial explores how different effects influence key performance characteristics like minimum film thickness, Babbitt temperature as well as stiffness and damping coefficients. Due to their increasing popularity, the operation and analysis of advanced designs using directed lubrication principles, such as inlet grooves and associated starvation issues, are also examined with several examples including comparisons to manufacturers’ test data

Energy Efficient Algorithms based on VM Consolidation for Cloud Computing: Comparisons and Evaluations

Cloud Computing paradigm has revolutionized IT industry and be able to offer computing as the fifth utility. With the pay-as-you-go model, cloud computing enables to offer the resources dynamically for customers anytime. Drawing the attention from both academia and industry, cloud computing is viewed as one of the backbones of the modern economy. However, the high energy consumption of cloud data centers contributes to high operational costs and carbon emission to the environment. Therefore, Green cloud computing is required to ensure energy efficiency and sustainability, which can be achieved via energy efficient techniques. One of the dominant approaches is to apply energy efficient algorithms to optimize resource usage and energy consumption. Currently, various virtual machine consolidation-based energy efficient algorithms have been proposed to reduce the energy of cloud computing environment. However, most of them are not compared comprehensively under the same scenario, and their performance is not evaluated with the same experimental settings. This makes users hard to select the appropriate algorithm for their objectives. To provide insights for existing energy efficient algorithms and help researchers to choose the most suitable algorithm, in this paper, we compare several state-of-the-art energy efficient algorithms in depth from multiple perspectives, including architecture, modelling and metrics. In addition, we also implement and evaluate these algorithms with the same experimental settings in CloudSim toolkit. The experimental results show the performance comparison of these algorithms with comprehensive results. Finally, detailed discussions of these algorithms are provided

Assessment of digital image correlation measurement errors: methodology and results

Optical full-field measurement methods such as Digital Image Correlation (DIC) are increasingly used in the field of experimental mechanics, but they still suffer from a lack of information about their metrological performances. To assess the performance of DIC techniques and give some practical rules for users, a collaborative work has been carried out by the Workgroup “Metrology” of the French CNRS research network 2519 “MCIMS (Mesures de Champs et Identification en Mécanique des Solides / Full-field measurement and identification in solid mechanics, http://www.ifma.fr/lami/gdr2519)”. A methodology is proposed to assess the metrological performances of the image processing algorithms that constitute their main component, the knowledge of which being required for a global assessment of the whole measurement system. The study is based on displacement error assessment from synthetic speckle images. Series of synthetic reference and deformed images with random patterns have been generated, assuming a sinusoidal displacement field with various frequencies and amplitudes. Displacements are evaluated by several DIC packages based on various formulations and used in the French community. Evaluated displacements are compared with the exact imposed values and errors are statistically analyzed. Results show general trends rather independent of the implementations but strongly correlated with the assumptions of the underlying algorithms. Various error regimes are identified, for which the dependence of the uncertainty with the parameters of the algorithms, such as subset size, gray level interpolation or shape functions, is discussed

Comparing Adult Cannabis Treatment-Seekers Enrolled in a Clinical Trial with National Samples of Cannabis Users in the United States

Background—Cannabis use rates are increasing among adults in the United States (US) while the perception of harm is declining. This may result in an increased prevalence of cannabis use disorder and the need for more clinical trials to evaluate efficacious treatment strategies. Clinical trials are the gold standard for evaluating treatment, yet study samples are rarely representative of the target population. This finding has not yet been established for cannabis treatment trials. This study compared demographic and cannabis use characteristics of a cannabis cessation clinical trial sample (run through National Drug Abuse Treatment Clinical Trials Network) with three nationally representative datasets from the US; 1) National Survey on Drug Use and Health, 2) National Epidemiologic Survey on Alcohol and Related Conditions-III, and 3) Treatment Episodes Data Set – Admissions. Methods—Comparisons were made between the clinical trial sample and appropriate cannabis using sub-samples from the national datasets, and propensity scores were calculated to determine the degree of similarity between samples. Results—Results showed that the clinical trial sample was significantly different from all three national datasets, with the clinical trial sample having greater representation among older adults, African Americans, Hispanic/Latinos, adults with more education, non-tobacco users, and daily and almost daily cannabis users. Conclusions—These results are consistent with previous studies of other substance use disorder populations and extend sample representation issues to a cannabis use disorder population. This illustrates the need to ensure representative samples within cannabis treatment clinical trials to improve the generalizability of promising findings

The position of graptolites within Lower Palaeozoic planktic ecosystems.

An integrated approach has been used to assess the palaeoecology of graptolites both as a discrete group and also as a part of the biota present within Ordovician and Silurian planktic realms. Study of the functional morphology of graptolites and comparisons with recent ecological analogues demonstrates that graptolites most probably filled a variety of niches as primary consumers, with modes of life related to the colony morphotype. Graptolite coloniality was extremely ordered, lacking any close morphological analogues in Recent faunas. To obtain maximum functional efficiency, graptolites would have needed varying degrees of coordinated automobility. A change in lifestyle related to ontogenetic changes was prevalent within many graptolite groups. Differing lifestyle was reflected by differing reproductive strategies, with synrhabdosomes most likely being a method for rapid asexual reproduction. Direct evidence in the form of graptolithophage 'coprolitic' bodies, as well as indirect evidence in the form of probable defensive adaptations, indicate that graptolites comprised a food item for a variety of predators. Graptolites were also hosts to a variety of parasitic organisms and provided an important nutrient source for scavenging organisms

Social identity, social networks and recovery capital in emerging adulthood: a pilot study

Background It has been argued that recovery from substance dependence relies on a change in identity, with past research focused on ‘personal identity’. This study assessed support for a social identity model of recovery in emerging adults through examining associations between social identity, social networks, recovery capital, and quality of life. Methods Twenty participants aged 18–21 in residential treatment for substance misuse were recruited from four specialist youth drug treatment services - three detoxification facilities and one psychosocial rehabilitation facility in Victoria, Australia. Participants completed a detailed social network interview exploring the substance use of groups in their social networks and measures of quality of life, recovery capital, and social identity. Results Lower group substance use was associated with higher recovery capital, stronger identification with non-using groups, and greater importance of non-using groups in the social network. Additionally, greater identification with and importance of non-using groups were associated with better environmental quality of life, whereas greater importance conferred on using groups was associated with reduced environmental quality of life. Conclusions Support was found for the role of social identity processes in reported recovery capital and quality of life. Future research in larger, longitudinal samples is required to improve understanding of social identity processes during treatment and early recovery and its relationship to recovery stability. Keywords Social network Social identity Emerging adult Substance use Treatment Recovery Quality of lif

Are proton pump inhibitors the first choice for acute treatment of gastric ulcers? A meta analysis of randomized clinical trials

BACKGROUND: Gastric ulcers are a frequent problem in the United States. Proton pump inhibitors have been shown to increase healing rates and improve clinical symptoms. The objective of this study is to compare gastric ulcer healing rates for patients treated with a proton pump inhibitor (PPI) (omeprazole, rabeprazole, pantoprazole, or lansoprazole), an histamine 2- receptor antagonist (ranitidine) or placebo. METHODS: A literature search was conducted to identify randomized, controlled clinical trials that included a PPI in at least one treatment arm and assessed the gastric ulcer healing rates endoscopically. The healing rates were estimated for each treatment at specific time points, and Rate Ratios (RR) and 95% confidence intervals (CI) were estimated for each trial. RESULTS: Sixteen trials met the inclusion criteria: four compared a PPI versus placebo, nine compared a PPI versus ranitidine (no trials of rabeprazole versus ranitidine met the inclusion criteria), and three compared a newer PPI (lansoprazole, pantoprazole or rabeprazole) versus omeprazole. In relation to ranitidine, the pooled RR of PPIs (lansoprazole, omeprazole and pantoprazole) was 1.33 (95% CI 1.24 to 1.42) at four weeks. In each trial, greater improvement in the studied clinical symptoms was found with the newer PPIs (rabeprazole, pantoprazole and lansoprazole) when compared to omeprazole. CONCLUSION: In this study treatment with PPIs resulted in higher healing rates than ranitidine or placebo. This evidence suggests that the first choice for gastric ulcer treatment for the greater relief of symptoms is one of the newer PPIs