Rationalizing Relatedness: Understanding Personal Jurisdiction\u27s Relatedness Prong in the Wake of \u3ci\u3eBristol-Myers Squibb\u3c/i\u3e and \u3ci\u3eFord Motor Co.\u3c/i\u3e

Ford Motor Co. v. Montana Eighth Judicial District Court marked a watershed in the U.S. Supreme Court’s personal jurisdiction jurisprudence. There, the Court came to a reasonable conclusion: Ford, a multinational conglomerate carrying on extensive business throughout the United States, was subject to personal jurisdiction in states where it maintained substantial contacts that were related to the injuries that prompted the suits. This was so, even though the business it conducted in those states was not the direct cause of the suit. While justifying that conclusion, however, the Court drastically altered the personal jurisdiction inquiry’s relatedness prong, which concerns whether the suit arises out of or relates to the defendant’s contacts with the forum state. The Court’s new framework muddied the water of a doctrine that was already convoluted and, at times, difficult to apply. This Note examines the application of Ford Motor Co.’s relatedness analysis to different factual scenarios presented to state courts and federal appellate courts. While those courts have focused on several different factors, this Note suggests that the inquiry does not have to be so varied. This Note concludes that the relatedness test should apply narrowly to situations that are factually similar to those in Ford Motor Co. and Bristol-Myers Squibb Co. v. Superior Court. Once the relatedness test is triggered, this Note maintains that a comparison between Bristol-Myers Squibb and Ford Motor Co. reveals that only two factors are determinative: the location of the injury and the extent to which the plaintiff is attempting to buy into the forum

\u27Scared Straight\u27 and Other Juvenile Awareness Programs for Preventing Juvenile Delinquency

Background: \u27Scared Straight\u27 and other similar programs involve organized visits to prison by juvenile delinquents or children at risk for criminal behavior. Programs are designed to deter participants from future offending through firsthand observation of prison life and interaction with adult inmates. These programs remain in use despite research questioning their effectiveness. This is an update of a 2002 review. Objectives: To assess the effects of programs comprising organized visits to prisons by juvenile delinquents (officially adjudicated, that is, convicted by a juvenile court) or pre-delinquents (children in trouble but not officially adjudicated as delinquents), aimed at deterring them from delinquency. Search methods: To update this review, we searched 22 electronic databases, including CENTRAL, MEDLINE, PsycINFO, and Criminal Justice Abstracts, in December 2011. In addition, we searched clinical trials registries, consulted experts, conducted Google Scholar searches, and followed up on all relevant citations. Selection criteria: We included studies that tested programs involving the organized visits of delinquents or children at risk for delinquency to penal institutions such as prisons or reformatives. Studies that had overlapping samples of juvenile and young adults (for example, ages 14 to 20 years) were included. We only considered studies that assigned participants to conditions randomly or quasi-randomly (that is, by odd/even assignment to conditions). Each study had to have a no-treatment control condition and at least one outcome measure of \u27post-visit\u27 criminal behavior. Data collection and analysis: The search methods for the original review generated 487 citations, most of which had abstracts. The lead review author screened these citations, determining that 30 were evaluation reports. Two review authors independently examined these citations and agreed that 11 were potential randomized trials. All reports were obtained. Upon inspection of the full-text reports, two review authors independently agreed to exclude two studies, resulting in nine randomized trials. The lead review author extracted data from each of the nine study reports using a specially designed instrument. In cases in which outcome information was missing from the original reports, we made attempts via correspondence to retrieve the data for the analysis from the original investigators. Outcome data were independently checked by a second review author (CTP). In this review, we report the results of each of the nine trials narratively. We conducted two meta-analyses of seven studies that provided postintervention offending rates using official data. Information from other sources (for example, self-report) was either missing from some studies or critical information was omitted (for example, standard deviations). We examined the immediate post-treatment effects (that is, \u27first-effects\u27) by computing odds ratios (OR) for data on proportions of each group reoffending, and assumed both fixed-effect and random-effects models in our analyses. Main results: We have included nine studies in this review. All were part of the original systematic review; no new trials meeting eligibility criteria were identified through our updated searches. The studies were conducted in eight different states of the USA, during the years 1967 to 1992. Nearly 1000 (946) juveniles or young adults of different races participated, almost all males. The average age of the participants in each study ranged from 15 to 17 years. Meta-analyses of seven studies show the intervention to be more harmful than doing nothing. The OR (fixed-effect) for effects on first post-treatment effect on officially measured criminal behavior indicated a negative program effect (OR 1.68, 95% confidence interval (CI) 1.20 to 2.36) and nearly identical regardless of themeta-analytic strategy (random-effects OR 1.72, 95% CI 1.13 to 2.62). Sensitivity analyses (random-effects) showed the findings were robust even when removing one study with an inadequate randomization strategy (OR 1.47, 95% CI 1.03 to 2.11), or when removing one study with high attrition (OR 1.96, 95% CI 1.25 to 3.08), or both (OR 1.68, 95% CI 1.10 to 2.58). Authors\u27 conclusions: We conclude that programs such as \u27Scared Straight\u27 increase delinquency relative to doing nothing at all to similar youths. Given these results, we cannot recommend this program as a crime prevention strategy. Agencies that permit such programs, therefore, must rigorously evaluate them, to ensure that they do not cause more harm than good to the very citizens they pledge to protect

‘Policing Schools’ Strategies: A Review of the Evaluation Evidence

Background: Schools experience a wide range of crime and disorder, victimizing students and staff, and undermining attempts to create a safe and orderly environment for student learning. Police have long established programs with schools, but there has been no systematic review of evaluations of these programs, outside of police-led prevention classroom curriculum programs such as D.A.R.E.     Purpose: This paper documents a systematic search to identify experimental and quasi-experimental evaluations that assess the effectiveness of non-educational policing strategies and programs in schools.     Setting: Included studies took place in or around K-12 schools in the United States, Canada, and the United Kingdom.   Intervention: Studies were included if they reported on a specific school-based strategy that heavily involved police and did not exclusively involve the police teaching a curriculum or program such as Drug Abuse Resistance Education (D.A.R.E.).   Research Design:  Systematic review of experimental or quasi-experimental evaluations   Data Collection and Analysis: Only those impact studies that used experimental or quasi-experimental design, had at least one outcome measure of school crime or disorder, and were available through December 2009 were eligible.  Electronic searches and other methods were used to identify published and unpublished evaluation reports.       Findings: The searches identified a total of eleven quasi-experimental studies. Ten of the eleven studies would likely have received a “3” on the Maryland Scientific Methods Rating Scale, a common approach to classifying studies on the basis of internal validity.  If evidence rating criteria from the U.S. Department of Education’s What Works Clearinghouse (WWC) were applied, only one study would likely receive a grade of “Level 2” evidence (acceptable with reservations) and the other ten studies would likely not meet WWC evidence screening criteria.   Keywords: systematic review; police and schools; crime prevention&nbsp

The Least Known Celebration of America\u27s Founding Principles—Law Day

Every year since May 1, 1958, the United States has recognized Law Day. Codified in 1961, it is “a special day of celebration” for Americans to reaffirm “their loyalty to the United States” and rededicate themselves “to the ideals of equality and justice under law in their relations with each other and with other countries.” Its purpose is to “cultivat[e] . . . respect for law that is so vital to the democratic way of life.” It tasks the President with issuing an annual proclamation calling for “public officials to display the flag of the United States on all Government buildings on Law Day” and for “the people of the United States” to observe the day with “appropriate ceremonies,” through “public entities and private organizations and in schools and other suitable places.” This Essay discusses the history of Law Day and how its changing themes and proclamations showcase U.S. society’s evolving views about the rule of law and the United States’s system of government over the last sixty-five years. Additionally, although the American Bar Association (ABA) website provides access to many of the Law Day proclamations, there has not been one central, publicly available, comprehensive repository of all of the Law Day proclamations since 1958. This Essay includes an appendix with all of the presidential proclamations since Law Day’s inception

The Impact of the Safe and Successful Youth Initiative (SSYI) on City-Level Youth Crime Victimization Rates

Background: The physical, emotional, and financial costs resulting from youth violence are well documented. Purpose: This article summarizes the results of a quasi-experimental evaluation study to test a youth violence intervention program in eleven cities in Massachusetts. Setting: In 2011, Massachusetts initiated the Safe and Successful Youth Initiative (SSYI), which provides a comprehensive public health approach for young men believed to be at “proven risk” for being involved with firearms. Intervention: The SSYI program components include: (1) Specific identification of young men, ages 14-24, at highest risk for being involved in firearms violence; (2) Use of street outreach workers to find these young men, assess their needs, and act as brokers for services; (3) The provision of a continuum of comprehensive services including education, employment, and intensive supervision. Eleven cities with the highest count of violent offenses reported to the police in 2010 were selected for SSYI funding in 2011 and began implementing the program. Research Design:  Short-interrupted time series design with a comparison group. The observed and predicted trends in monthly violent victimization rates for the 11 SSYI cities were compared to the next 23 cities (as they ranked in reported violent crime in 2010). Data Collection and Analysis: Using police incident data, researchers examined SSYI's impact on monthly city level violent crime, aggravated assault and homicide rates for persons ages 14-24. Findings: Results indicated that SSYI had a statistically significant and positive impact on reducing the number of victims of violent crimes, aggravated assaults, and homicides per month that were reported to the police.  A city with SSYI has approximately 60 fewer victims of violence each year, ages 14-24, per 100,000 citizens over the post-intervention period. Keywords: quasi-experiment; interrupted time series; crime prevention; violence; Massachusett

Beyond Blackboards: Engaging Underserved Middle School Students in Engineering

Beyond Blackboards is an inquiry-centered, after-school program designed to enhance middle school students’ engagement with engineering through design-based experiences focused on the 21st Century Engineering Challenges. Set within a predominantly lowincome, majority-minority community, our study aims to investigate the impact of Beyond Blackboards on students’ interest in and understanding of engineering, as well as their ability to align their educational and career plans. We compare participants’ and nonparticipants’ questionnaire responses before the implementation and at the end of the program’s first academic year. Statistically significant findings indicate a school-wide increase in students’ interest in engineering careers, supporting a shift in school culture. However, only program participants showed increased enjoyment of design-based strategies, understanding of what engineers do, and awareness of the steps for preparing for an engineering career. These quantitative findings are supported by qualitative evidence from participant focus groups highlighting the importance of mentors in shaping students’ awareness of opportunities within engineering

Meeting the ISTE Challenge in the Field: An Overview of the First Six Distinguished Achievement Award Winning Programs

The 2002 National Educational Technology Standards (NETS) Distinguished Achievement Awards, sponsored by the International Society for Technology in Education (ISTE), were awarded to six teacher education programs across the United States. The awards recognize institutions that exemplify successful integration of the National Educational Technology Standards for Teachers (NETS[solid dot]T) into teacher education programs. Institutions across the country completed an extensive application process to be selected one of the first six recipients of the ISTE Distinguished Achievement award. This process included online documentation that demonstrated the program\u27s implementation of the NETS[solid dot]T models and practices. This article provides a means of uniting various programs and program developers (teacher educators and instructional technologists) by looking at the most common obstacles they face in the pursuit of appropriate infusion of technology into teacher education programs and workable solutions for overcoming those obstacles

Formal System Processing of Juveniles: Effects on Delinquency

Justice practitioners have tremendous discretion on how to handle juvenile offenders. Police officers, district attorneys, juvenile court intake officers, juvenile and family court judges, and other officials can decide whether the juvenile should be “officially processed” by the juvenile justice system, diverted from the system to a program, counseling or some other services, or to do nothing at all (release the juvenile altogether). An important policy question is which strategy leads to the best outcomes for juveniles. This is an important question in the United States, but many other nations are concerned with the decision to formally process or divert juvenile offenders. There have been a number of randomized experiments in the juvenile courts that have examined the impact of juvenile system processing that should be gathered together in a systematic fashion to provide rigorous evidence about the impact of this decision on subsequent offending by juveniles. Our objective is to answer the question: Does juvenile system processing reduce subsequent delinquency? Based on the evidence presented in this report, juvenile system processing appears to not have a crime control effect, and across all measures appears to increase delinquency. This was true across measures of prevalence, incidence, severity, and self-report. Given the additional financial costs associated with system processing (especially when compared to doing nothing) and the lack of evidence for any public safety benefit, jurisdictions should review their policies regarding the handling of juveniles

Wastewater Sequencing Reveals Community and Variant Dynamics of the Collective Human Virome

Wastewater is a discarded human by-product, but its analysis may help us understand the health of populations. Epidemiologists first analyzed wastewater to track outbreaks of poliovirus decades ago, but so-called wastewater-based epidemiology was reinvigorated to monitor SARS-CoV-2 levels while bypassing the difficulties and pit falls of individual testing. Current approaches overlook the activity of most human viruses and preclude a deeper understanding of human virome community dynamics. Here, we conduct a comprehensive sequencing-based analysis of 363 longitudinal wastewater samples from ten distinct sites in two major cities. Critical to detection is the use of a viral probe capture set targeting thousands of viral species or variants. Over 450 distinct pathogenic viruses from 28 viral families are observed, most of which have never been detected in such samples. Sequencing reads of established pathogens and emerging viruses correlate to clinical data sets of SARS-CoV-2, influenza virus, and monkeypox viruses, outlining the public health utility of this approach. Viral communities are tightly organized by space and time. Finally, the most abundant human viruses yield sequence variant information consistent with regional spread and evolution. We reveal the viral landscape of human wastewater and its potential to improve our understanding of outbreaks, transmission, and its effects on overall population health