Lopez v. Gonzales & Toledo-Flores v. United States: State Felony Drug Convictions Not Necessarily Aggravated Felonies Requiring Deportation

The United States Courts of Appeals split over whether state felony drug convictions, which were punishable only as misdemeanors under federal law, constituted aggravated felonies under immigration law. The controversy was based upon the interpretation of the Immigration and Nationality Act (“INA”). Under the Act, an alien who is convicted of an “aggravated felony” is automatically deported from the United States. According to the INA, an aggravated felony includes “illicit trafficking in a controlled substance . . . including a drug trafficking crime (as defined in section 924(c) of Title 18).” Although the INA does not define “illicit trafficking,” Title 18 of the U.S. Code defines “the term ‘drug trafficking crime’ [as] any felony punishable under the Controlled Substances Act (21 U.S.C. [§] 801 et seq.).” While the Controlled Substances Act (“CSA”) is a federal statute, the INA’s definition of aggravated felonies expressly includes crimes “whether in violation of state and federal law.” Since the INA was intended to include state convictions, the Court needed to clarify whether an “aggravated felony” under the INA included a felony conviction by state court that under federal law would be classified only as a misdemeanor

VIABILITY OF GRAYWATER REUSE IN LESOTHO’S LOWLAND AGRICULTURAL DISTRICT

Water security has become a large issue with populations rising and weather patterns changing to drier and hotter conditions in southern Africa. Lesotho, a mountainous country landlocked by South Africa, is responsible for a large amount of the rainfall in southern Africa. As such, Lesotho provides water to South Africa in exchange for national economic growth. Lesotho, however, is also prone to droughts and with water reserves being sold to South Africa, water security has become a national issue. This study looked at Lesotho’s current water use habits and found that graywater reuse could lead to much more available water. The purpose of this study was to determine if recycled graywater would be a suitable replacement for improved water when irrigating edible gardens in Lesotho. A typical garden was constructed as well as a graywater collection system. The study was conducted using baby spinach plants that were treated with graywater irrigation or improved water irrigation. The garden was divided into separate treatment rows that were randomly assigned. The study garden went through a single growing season and then plants were measured for physical characteristics. It was found that there was no statistical difference between the two treatments in any of the measurement types. The results of the study suggest that there is no difference in the physical growth of spinach plants when graywater is used as an irrigation source

The Stamp Act: Revolutionary Resistance in New York

Prior to the first battles of the American Revolution, the BritishParliament imposed several duties on the American colonies to fund the expenses of the French and Indian War, continued attacks on the American frontier, taxed American colonists to assist with British finances, and garrisoned troops throughout America. One of these duties, the American Stamp Act, was passed and enacted in early 1765 throughout the North American British colonies. The correlation between battles, campaigns, and acts such as imposed duties, are all interrelated. Many historians traditionally view the colonial reaction to the Stamp Act as one singular political event or overshadowed by the battles fought in the war for American independence. This thesis has been written to examine the social and economic impact of the American Stamp Act of 1765, and to investigate the enforcement practices and reactions of those affected by the act, specifically in the colony of New York, and its impact on the subsequent war for American independence. The materials utilized in this study include both primary and secondary sources. The secondary sources aim to ensure a rounded understanding of the Stamp Act and pre-Revolutionary thought, while primary sources have been examined to understand specific localities as issues surrounding the Stamp Act unraveled. In this study, a more in-depth examination into the authority that enforced the Act, the relationship, and interactions between those affected and those who collected the levy, the various motives of opposition, and the eventual formation of organized resistance and action within New York in the broader context of colonial America are explored

The Significant Influencing Factors of Xenophobia

This paper serves as a review of the influencing factors of xenophobia and its behavioral products. Two primary categories of influencing factors of xenophobia are discussed: inherent factors and environmental factors. Inherent factors that are considered include genetic factors and personality factors; a variety of perspectives on the impact of these factors are reviewed. Discussion on the impact of environmental factors will focus on the impact of education and inter-group contact on xenophobic attitudes. The factors that influence xenophobia are clearly multifaceted, though conclusions about the extent to which environment and genetics play roles in the development of xenophobia and its by-products (racism, ethnocentrism, etc.) will require more research

Reprinting Russia: Anti-Imperial Discourse in Elias Boudinot?s Cherokee Phoenix

While much work has explored American Indian print resistance to the encroaching United States, little scholarship has explored reprinting as a method of resistance. Building on Meredith McGill?s argument that reprinting is ?legible as an independently signifying act? (5), this analysis shows how Elias Boudinot, editor of the Cherokee Phoenix newspaper from 1828 to 1832, selectively reprinted articles about the Russian Empire to foster an anti-imperial spirit among his readers. This analysis shows that Boudinot subversively played on the idea of Russia as the United States? distant twin by predominantly republishing articles that portray Russia as cruel, weak, and an enemy to democratic ideals of liberty and freedom. Such a portrayal instills a resistant attitude in his readership against Russian-style imperialism and the countries which subscribe to it. This analysis calls for refocusing of attention away from great powers and onto smaller nations affected by great power politics

Assessing the Impact of a New Inlet Created by 2012 Hurricane Sandy on the Intensity of Algae Blooms in Bellport Bay NY

Harmful algae blooms (HABs) are a growing ecosystem health issue in environments worldwide, driven by excess nitrogen runoff (Eutrophication) alongside high summer temperatures. HABs strip oxygen from the environment and create toxic environments that impact other primary producers, fish, birds, mammals, reptiles, and any other organisms that enter an affected body of water. The purpose of this study is to analyze the impact of a new inlet, created by Hurricane Sandy in Long Island’s Bellport Bay, on the concentration of algae blooms during peak blooming periods (Jul-Aug) to inform ecosystem-based management. Google Earth Engine Code Editor and 2008-2017 Landsat 5-8 imagery correlated to the study area were used for imagery and data analysis. The colored infrared (CIR) before & after images of the study area clearly show the new inlet formation and shoal structure in Bellport Bay. Normalized Difference Vegetation Index (NDVI) imagery analysis found a significant decrease in algae bloom concentration, in close proximity to the new inlet formations. Additionally, NDVI imagery analysis found that algae concentration decreased across nearly the entire Moriches and Shinnecock bays, partly due to their pre-existing inlets. This shift is attributed to the differences in local watershed characteristics and waste management strategies across the bays, over the time period of analysis. This study concludes that the formation of new inlets can be beneficial in lowering algae concentrations in appropriate coastal areas afflicted by HABs. However, the primary focus for reducing HABs in all environments must be reductions in anthropogenic nitrogen loading, driven by ineffective land and water management practices overtime

Utility of Phylloplanins as Antibiotics, Selective Fungicides and for Enhancing Microbial Resistance in Plants

The present invention relates to plant proteins produced by a plant\u27s epidermal layer that contribute to the innate pest/disease resistance of the plant (“phylloplanins”), compositions comprising the phylloplanins and methods of using them. In particular the methods relate to inhibiting or preventing microbial, e.g., fungal or bacterial, growth on a subject, organism or surface by administering a phylloplanin. The invention also relates to transformed host cells that produce phylloplanins, and to transgenic plants producing phylloplanins conferring increased resistance to microbial infections/growth

Sequoia Pitch Moth in Pines

This fact sheet focuses on the sequoia pitch moth (SPM) (Sesiidae: Synanthedon sequoiae). It includes how to identify, life cycle, damage, and management

Physical and Digital Integration Strategies of Electronic Device Supply Chains and Their Applicability to ETO Supply Chains

The growth in the manufacture and distribution of electronic devices presents a source of continuing innovation. Electronic devices are products that integrate physical forms (i.e. hardware) and virtual forms (e.g. software) to deliver value to customers. These forms are very different from a product design and supply chain perspective, but nevertheless they need to work closely together in order to create value for the customers. For electronic device manufacturers, it is important that processes are in place to facilitate the seamless integration of both forms throughout the engineering, production, distribution and support stages of the product lifecycle. This chapter examines the role of physical and virtual supply chain innovation strategies in electronic device supply chains by exploring the commonalities and differences between the design, manufacturing, and distribution models of digital and physical elements. It also explores to what extent such strategies can be employed for engineer-to-order (ETO) supply chains