Not-So-Harmless Error: A Higher Standard for Mitigation Errors on Capital Habeas Review

This Comment looks at how federal courts handle mitigation errors during the penalty phase of capital punishment cases on habeas corpus review; it argues that the United States Supreme Court should expressly adopt the Chapman “harmless beyond a reasonable doubt” standard rather than the Brecht “substantial and injurious effect” standard. The heightened stakes of capital sentencing dictate that a higher standard of review should apply. The Court has yet to rule on this matter, and the United States Courts of Appeals cannot agree upon which standard to apply. Currently, a lopsided circuit split exists regarding whether harmless error review applies to mitigation errors, and if so, what standard should apply. While the Court has yet to decide this issue, it has dealt with harmless error review in non-capital cases. The Chapman harmless error standard, promulgated by the Court in 1967, requires that a state must prove that any constitutional errors were harmless beyond a reasonable doubt. In 1993, the Brecht Court found the Chapman standard too onerous for collateral attacks and determined that a lower standard was necessary: during collateral attacks, the defendant must show that the error had a substantial and injurious effect upon determining the jury’s verdict. Chapman placed the burden upon the State; Brecht placed the burden upon the defendant. This Comment argues that the higher Chapman standard should apply to collateral attacks in capital habeas cases because of the possibility of a total deprivation of one’s life and liberty. The Court has before determined that “death is different,” and in keeping with that sentiment, the Court should adopt an error standard that similarly acknowledges the difference between life and death

Not-So-Harmless Error: A Higher Standard for Mitigation Errors on Capital Habeas Review

This Comment looks at how federal courts handle mitigation errors during the penalty phase of capital punishment cases on habeas corpus review; it argues that the United States Supreme Court should expressly adopt the Chapman “harmless beyond a reasonable doubt” standard rather than the Brecht “substantial and injurious effect” standard. The heightened stakes of capital sentencing dictate that a higher standard of review should apply. The Court has yet to rule on this matter, and the United States Courts of Appeals cannot agree upon which standard to apply. Currently, a lopsided circuit split exists regarding whether harmless error review applies to mitigation errors, and if so, what standard should apply. While the Court has yet to decide this issue, it has dealt with harmless error review in non-capital cases. The Chapman harmless error standard, promulgated by the Court in 1967, requires that a state must prove that any constitutional errors were harmless beyond a reasonable doubt. In 1993, the Brecht Court found the Chapman standard too onerous for collateral attacks and determined that a lower standard was necessary: during collateral attacks, the defendant must show that the error had a substantial and injurious effect upon determining the jury’s verdict. Chapman placed the burden upon the State; Brecht placed the burden upon the defendant. This Comment argues that the higher Chapman standard should apply to collateral attacks in capital habeas cases because of the possibility of a total deprivation of one’s life and liberty. The Court has before determined that “death is different,” and in keeping with that sentiment, the Court should adopt an error standard that similarly acknowledges the difference between life and death

Development of media production processes for CAR-T therapies

Many of the standard cell culturing unit operations utilized by early stage CAR-T manufacturing processes have been derived from benchtop scale academic processes and require further development to become commercially viable. Critical unit operations, such as isolation, activation, transduction, and expansion are often the focus of next generation or automation technologies. Development of ancillary processes such as medium production, however, should not be overlooked and can take advantage of economies of scale and technologies that have been proven in other pharmaceutical industries like biologics. Special consideration should be taken when developing these medium scale-up processes since cell therapies are complex and can be highly sensitive to medium composition changes. In addition, significant changes may be needed to update medium production processes from a process suited for an academic setting to one suited for a commercialized product. This poster discusses Celgene’s approach for developing a commercially sustainable media preparation process by applying available filtration and bulk solution preparation technologies and the unique challenges associated with applying these technologies to CAR-T therapies

Urban Environmental Performance Index: The Quito Pilot Case

In the context of the adoption of the Sustainable Development Goals (SDG) and its indicators, especially Goal 11, the importance of indicators is paramount to the implementation, monitoring and eventual success of the SDG. However, a review of global sustainability indicators reveals major gaps in coverage, including scientific gaps. Indicators are often siloed, meaning at the urban scale where issues often overlap and intersect, existing indicators do not take into consideration cross-sectoral linkages. Finally, many indicators fail to adequately address social equity or inclusion, a high-priority issue identified as central to new definitions of green economy and sustainable development at Rio+20. This research we developed a case study to pilot new indicators based information available for the city of Quito that address these challenges. The development of this pilot indicators has involved the use of several data collection tools and particularly the treatment of data so it could be available for numerical and graphical analysis. The research relied heavily Open Source platforms and tools to perform the analysis. Ultimately, the objective of this research is to scale the study to other cities around the world and other indicators to create an index that is reliable in measuring the environmental performance of the cities, while considering the social distribution of the environmental impacts inside the city

Lattice QCD at the end of 2003

I review recent developments in lattice QCD. I first give an overview of its formalism, and then discuss lattice discretizations of fermions. We then turn to a description of the quenched approximation and why it is disappearing as a vehicle for QCD phenomenology. I describe recent claims for progress in simulations which include dynamical fermions and the interesting theoretical problems they raise. I conclude with brief descriptions of the calculations of matrix elements in heavy flavor systems and for kaons.Comment: Review for Int J Mod Phys A. 58 pages, latex, WSPC macros,, 22 postscript figure

What Is (Fake) News? Analyzing News Values (and More) in Fake Stories

‘Fake news’ has been a topic of controversy during and following the 2016 U.S. presidential election. Much of the scholarship on it to date has focused on the ‘fakeness’ of fake news, illuminating the kinds of deception involved and the motivations of those who deceive. This study looks at the ‘newsness’ of fake news by examining the extent to which it imitates the characteristics and conventions of traditional journalism. Through a content analysis of 886 fake news articles, we find that in terms of news values, topic, and formats, articles published by fake news sites look very much like traditional—and real—news. Most of their articles included the news values of timeliness, negativity, and prominence; were about government and politics; and were written in an inverted pyramid format. However, one point of departure is in terms of objectivity, operationalized as the absence of the author’s personal opinion. The analysis found that the majority of articles analyzed included the opinion of their author or authors