Appellate Review under the New Felony Sentencing Guidelines: Where Do We Stand

Now that it has been more than four years since Senate Bill 2 became effective, this is a good time to analyze the cases to see where courts stand in their interpretations of the guidelines. This article will review the case law and show how different courts have dealt with the legislation. My analysis concentrates on one aspect of the guidelines in particular: the standard of review that appeals courts have used to determine the propriety of sentences. To illustrate my points, I focus on the issue of when judges can impose maximum prison sentences under the guidelines, one of the most frequently litigated issues before our court. After initially analyzing the origins and development of Senate Bill 2, I will show that courts have not used consistent standards of review. This inconsistency, I argue, is especially problematic because it will result in inconsistent sentences for convicted felons, whose sentences will be greatly influenced by the section of the state, or appellate district, where their crimes occurred-just what Senate Bill 2 was designed to avoid

Plankton patchiness investigated using simultaneous nitrate and chlorophyll observations

The complex patterns observed in marine phytoplankton distributions arise from the interplay of biological and physical processes, but the nature of the balance remains uncertain centuries after the first observations. Previous observations have shown a consistent trend of decreasing variability with decreasing length-scale. Influenced by similar scaling found for the properties of the water that the phytoplankton inhabit, ‘universal' theories have been proposed that simultaneously explain the variability seen from meters to hundreds of kilometers. However, data on the distribution of phytoplankton alone has proved insufficient to differentiate between the many causal mechanisms that have been suggested. Here we present novel observations from a cruise in the North Atlantic in which fluorescence (proxy for phytoplankton), nitrate and temperature were measured simultaneously at scales from 10 m to 100 km for the first time in the open ocean. These show a change in spectra between the small scale (10–100 m) and the mesoscale (10–100 km) which is different for the three tracers. We discuss these observations in relation to the current theories for phytoplankton patchiness

Plankton patchiness investigated using simultaneous nitrate and chlorophyll observations

The complex patterns observed in marine phytoplankton distributions arise from the interplay of biological and physical processes, but the nature of the balance remains uncertain centuries after the first observations. Previous observations have shown a consistent trend of decreasing variability with decreasing length-scale. Influenced by similar scaling found for the properties of the water that the phytoplankton inhabit, ‘universal' theories have been proposed that simultaneously explain the variability seen from meters to hundreds of kilometers. However, data on the distribution of phytoplankton alone has proved insufficient to differentiate between the many causal mechanisms that have been suggested. Here we present novel observations from a cruise in the North Atlantic in which fluorescence (proxy for phytoplankton), nitrate and temperature were measured simultaneously at scales from 10 m to 100 km for the first time in the open ocean. These show a change in spectra between the small scale (10–100 m) and the mesoscale (10–100 km) which is different for the three tracers. We discuss these observations in relation to the current theories for phytoplankton patchiness

Quantifying mesoscale-driven nitrate supply: a case study

The supply of nitrate to surface waters plays a crucial role in maintaining marine life. Physical processes at the mesoscale (~10-100?km) and smaller have been advocated to provide a major fraction of the global supply. Whilst observational studies have focussed on well-defined features, such as isolated eddies, the vertical circulation and nutrient supply in a typical 100-200?km square of ocean will involve a turbulent spectrum of interacting, evolving and decaying features. A crucial step in closing the ocean nitrogen budget is to be able to rank the importance of mesoscale fluxes against other sources of nitrate for surface waters for a representative area of open ocean. While this has been done using models, the vital observational equivalent is still lacking.To illustrate the difficulties that prevent us from putting a global estimate on the significance of the mesoscale observationally, we use data from a cruise in the Iceland Basin where vertical velocity and nitrate observations were made simultaneously at the same high spatial resolution. Local mesoscale nitrate flux is found to be an order of magnitude greater than that due to small-scale vertical mixing and exceeds coincident nitrate uptake rates and estimates of nitrate supply due to winter convection. However, a non-zero net vertical velocity for the region introduces a significant bias in regional estimates of the mesoscale vertical nitrate transport. The need for synopticity means that a more accurate estimate can not be simply found by using a larger survey area. It is argued that time-series, rather than spatial surveys, may be the best means to quantify the contribution of mesoscale processes to the nitrate budget of the surface ocean

Fine-mapping of the HNF1B multicancer locus identifies candidate variants that mediate endometrial cancer risk.

Common variants in the hepatocyte nuclear factor 1 homeobox B (HNF1B) gene are associated with the risk of Type II diabetes and multiple cancers. Evidence to date indicates that cancer risk may be mediated via genetic or epigenetic effects on HNF1B gene expression. We previously found single-nucleotide polymorphisms (SNPs) at the HNF1B locus to be associated with endometrial cancer, and now report extensive fine-mapping and in silico and laboratory analyses of this locus. Analysis of 1184 genotyped and imputed SNPs in 6608 Caucasian cases and 37 925 controls, and 895 Asian cases and 1968 controls, revealed the best signal of association for SNP rs11263763 (P = 8.4 × 10(-14), odds ratio = 0.86, 95% confidence interval = 0.82-0.89), located within HNF1B intron 1. Haplotype analysis and conditional analyses provide no evidence of further independent endometrial cancer risk variants at this locus. SNP rs11263763 genotype was associated with HNF1B mRNA expression but not with HNF1B methylation in endometrial tumor samples from The Cancer Genome Atlas. Genetic analyses prioritized rs11263763 and four other SNPs in high-to-moderate linkage disequilibrium as the most likely causal SNPs. Three of these SNPs map to the extended HNF1B promoter based on chromatin marks extending from the minimal promoter region. Reporter assays demonstrated that this extended region reduces activity in combination with the minimal HNF1B promoter, and that the minor alleles of rs11263763 or rs8064454 are associated with decreased HNF1B promoter activity. Our findings provide evidence for a single signal associated with endometrial cancer risk at the HNF1B locus, and that risk is likely mediated via altered HNF1B gene expression

Nature and consequences of interactions between Salmonella enterica serovar Dublin and host cells in cattle

International audienceAbstractSalmonella enterica is a veterinary and zoonotic pathogen of global importance. While murine and cell-based models of infection have provided considerable knowledge about the molecular basis of virulence of Salmonella, relatively little is known about salmonellosis in naturally-affected large animal hosts such as cattle, which are a reservoir of human salmonellosis. As in humans, Salmonella causes bovine disease ranging from self-limiting enteritis to systemic typhoid-like disease and exerts significant economic and welfare costs. Understanding the nature and consequences of Salmonella interactions with bovine cells will inform the design of effective vaccines and interventions to control animal and zoonotic infections. In calves challenged orally with S. Dublin expressing green fluorescent protein (GFP) we observed that the bacteria were predominantly extracellular in the distal ileal mucosa and within gut-associated lymph nodes 48 h post-infection. Intracellular bacteria, identified by flow cytometry using the GFP signal, were predominantly within MHCII+ macrophage-like cells. In contrast to observations from murine models, these S. Dublin-infected cells had elevated levels of MHCII and CD40 compared to both uninfected cells from the same tissue and cells from the cognate tissue of uninfected animals. Moreover, no gross changes of the architecture of infected lymph nodes were observed as was described previously in a mouse model. In order to further investigate Salmonella-macrophage interactions, net replication of S. enterica serovars that differ in virulence in cattle was measured in bovine blood-derived macrophages by enumeration of gentamicin-protected bacteria and fluorescence dilution, but did not correlate with host-specificity

Two-scale Moving Boundary Dynamics of Cancer Invasion:Heterotypic Cell Populations Evolution in Heterogeneous ECM

This book contains a collection of original research articles and review articles that describe novel mathematical modeling techniques and the application of those techniques to models of cell motility in a variety of contexts. The aim is to highlight some of the recent mathematical work geared at understanding the coordination of intracellular processes involved in the movement of cells. This collection will benefit researchers interested in cell motility as well graduate students taking a topics course in this area.