Daubert & Danger: The Fit of Expert Predictions in Civil Commitments

Never make predictions, especially about the future. But in civil commitments, courts predict future behavior all the time. Judicial action here has severe results for the individual: deprivation of liberty, potentially unwanted and intrusive treatment, and the stigma of mental illness. Judicial inaction can also do harm: erroneous release can lead to injury of the person or others. Resolving these risks requires courts to find the person poses a danger to him/herself or others because of a mental illness

Popular Culture as a Lens on Legal Professionalism

Why use art to teach lawyering?\u27 Despite divergences in method and intention, the two disciplines overlap. If the prevalence of lawyers in movies, television, literature, and even humor means anything, popular culture remains fascinated with lawyers. Our practices, our ethics, and our professional personae serve as a mine for image and narrative, a target for cultural critique, and a catalyst for expression. Not surprisingly, images of lawyers in cartoons, film, television, and literature offer unique opportunities to teach and explore professionalism. The proliferation of lawyer images in popular culture provides an array of material ranging from career choice to particular actions and behavior. This material elicits powerful responses about the morality, purpose, role, and identity of lawyers, in addition to traditional questions of legal ethics. The responses prompt students to reflect on career choice, professional persona in the legal world, and their development as human beings within a web of professional commitments. This Article argues that the cultural images of lawyering provide opportunities for teaching professionalism that go well beyond the teaching of ethical rules using hypothetical facts. We contend that use of different media allows teachers to chart the broad middle ground between disciplinary minima and aspirational maxima-the map of realistic professional practice. This ground includes both rule- and conduct-based ideas ofprofessionalism: careful role definition; responsible practice management; appropriate balance between public and private commitments; and concerns over manners, dress, and work ethic. The middle ground also includes less traditional content, discussion of which brings students to appreciate the subjective disciplines of lawyering. The subjective dimension includes the feel of lawyering for the practitioner: the psychic demands of an active, fully engaged practice. It also includes the subjective experience of the clients who use lawyers, as well as the complex interweaving of subjective and external factors in the situations in which lawyers are called to act. Using cultural representations of lawyers thus expands the notion of professionalism outside the bounds of the codified professional rules of conduct. One professor of ethics and professionalism refers to the examination of the varying layers of legal work as involving macro and micro contexts. We accept this distinction, and extend it: the rules of ethics provide a micro-context, around which popular media provide a macro context within which to appraise a different (and fuller) notion of professionalism. What renders the use of media unique is its tendency to prompt immediate imaginative experience and assessment of the various dimensions of professionalism. Through a well-chosen excerpt, one can consider both what the rules of ethics require alongside discussions of the moral complexity, emotional content, or even spiritual challenge posed by the situation. From these conversations, students can emerge with their language and awareness enlarged to include a richer and more reflective vision of their own identities as lawyers. Our argument proceeds in three phases. First, we review widespread notions of professionalism, illustrating and explicating our notion of professionalism as occupying the middle ground between discipline and aspiration. Second, we provide examples of teaching plans in which we have used different media, including examples of cartoons, movies, and short fiction as vehicles for teaching. Finally, we appraise the common challenges and objections to using the arts for these purposes; while law students form our first and most immediate pool of critics, these objections may have also occurred to others who have used the arts in this way. We recognize that our approach builds on the enthusiastic use of fictional representation in many modem law school ethics classes. We do not criticize, but rather seek to expand the range of what a teacher can do by using the arts in this way. We also hope to suggest the richness and power of conversations with students in which the traditional focus of classes on professionalism intersects with the more open-ended, expressive concerns of art

Staphylococcus aureus Biofilms Induce Macrophage Dysfunction Through Leukocidin AB and Alpha-Toxin.

UNLABELLED: The macrophage response to planktonic Staphylococcus aureus involves the induction of proinflammatory microbicidal activity. However, S. aureus biofilms can interfere with these responses in part by polarizing macrophages toward an anti-inflammatory profibrotic phenotype. Here we demonstrate that conditioned medium from mature S. aureus biofilms inhibited macrophage phagocytosis and induced cytotoxicity, suggesting the involvement of a secreted factor(s). Iterative testing found the active factor(s) to be proteinaceous and partially agr-dependent. Quantitative mass spectrometry identified alpha-toxin (Hla) and leukocidin AB (LukAB) as critical molecules secreted by S. aureus biofilms that inhibit murine macrophage phagocytosis and promote cytotoxicity. A role for Hla and LukAB was confirmed by using hla and lukAB mutants, and synergy between the two toxins was demonstrated with a lukAB hla double mutant and verified by complementation. Independent confirmation of the effects of Hla and LukAB on macrophage dysfunction was demonstrated by using an isogenic strain in which Hla was constitutively expressed, an Hla antibody to block toxin activity, and purified LukAB peptide. The importance of Hla and LukAB during S. aureus biofilm formation in vivo was assessed by using a murine orthopedic implant biofilm infection model in which the lukAB hla double mutant displayed significantly lower bacterial burdens and more macrophage infiltrates than each single mutant. Collectively, these findings reveal a critical synergistic role for Hla and LukAB in promoting macrophage dysfunction and facilitating S. aureus biofilm development in vivo. IMPORTANCE: Staphylococcus aureus has a propensity to form multicellular communities known as biofilms. While growing in a biofilm, S. aureus displays increased tolerance to nutrient deprivation, antibiotic insult, and even host immune challenge. Previous studies have shown that S. aureus biofilms thwart host immunity in part by preventing macrophage phagocytosis. It remained unclear whether this was influenced solely by the considerable size of biofilms or whether molecules were also actively secreted to circumvent macrophage-mediated phagocytosis. This is the first report to demonstrate that S. aureus biofilms inhibit macrophage phagocytosis and induce macrophage death through the combined action of leukocidin AB and alpha-toxin. Loss of leukocidin AB and alpha-toxin expression resulted in enhanced S. aureus biofilm clearance in a mouse model of orthopedic implant infection, suggesting that these toxins could be targeted therapeutically to facilitate biofilm clearance in humans

Novel non-invasive algorithm to identify the origins of re-entry and ectopic foci in the atria from 64-lead ECGs: A computational study.

Atrial tachy-arrhytmias, such as atrial fibrillation (AF), are characterised by irregular electrical activity in the atria, generally associated with erratic excitation underlain by re-entrant scroll waves, fibrillatory conduction of multiple wavelets or rapid focal activity. Epidemiological studies have shown an increase in AF prevalence in the developed world associated with an ageing society, highlighting the need for effective treatment options. Catheter ablation therapy, commonly used in the treatment of AF, requires spatial information on atrial electrical excitation. The standard 12-lead electrocardiogram (ECG) provides a method for non-invasive identification of the presence of arrhythmia, due to irregularity in the ECG signal associated with atrial activation compared to sinus rhythm, but has limitations in providing specific spatial information. There is therefore a pressing need to develop novel methods to identify and locate the origin of arrhythmic excitation. Invasive methods provide direct information on atrial activity, but may induce clinical complications. Non-invasive methods avoid such complications, but their development presents a greater challenge due to the non-direct nature of monitoring. Algorithms based on the ECG signals in multiple leads (e.g. a 64-lead vest) may provide a viable approach. In this study, we used a biophysically detailed model of the human atria and torso to investigate the correlation between the morphology of the ECG signals from a 64-lead vest and the location of the origin of rapid atrial excitation arising from rapid focal activity and/or re-entrant scroll waves. A focus-location algorithm was then constructed from this correlation. The algorithm had success rates of 93% and 76% for correctly identifying the origin of focal and re-entrant excitation with a spatial resolution of 40 mm, respectively. The general approach allows its application to any multi-lead ECG system. This represents a significant extension to our previously developed algorithms to predict the AF origins in association with focal activities

Geometagenomics illuminates the impact of agriculture on the distribution and prevalence of plant viruses at the ecosystem scale

Disease emergence events regularly result from human activities such as agriculture, which frequently brings large populations of genetically uniform hosts into contact with potential pathogens. Although viruses cause nearly 50% of emerging plant diseases, there is little systematic information about virus distribution across agro-ecological interfaces and large gaps in understanding of virus diversity in nature. Here we applied a novel landscape-scale geometagenomics approach to examine relationships between agricultural land use and distributions of plantassociated viruses in two Mediterranean-climate biodiversity hotspots (Western Cape region of South Africa and Rhône river delta region of France). In total, we analysed 1725 geo-referenced plant samples collected over two years from 4.5 × 4.5 km2 grids spanning farmlands and adjacent uncultivated vegetation. We found substantial virus prevalence (25.8–35.7%) in all ecosystems, but prevalence and identified family-level virus diversity were greatest in cultivated areas, with some virus families displaying strong agricultural associations. Our survey revealed 94 previously unknown virus species, primarily from uncultivated plants. This is the first effort to systematically evaluate plant-associated viromes across broad agro-ecological interfaces. Our findings indicate that agriculture substantially influences plant virus distributions and highlight the extent of current ignorance about the diversity and roles of viruses in nature

Working in the Public Interest Law Conference

The two-day conference included a variety of panel discussions and roundtables on such topics as: civil liberties; race and the criminal justice system; decriminalizing mental illness; funding public defender systems; the media\u27s role in the law; immigration; lesbian, gay, bisexual and transgendered youth in state sponsored institutions; environmental justice; and women\u27s reproductive rights

The Changing Landscape for Stroke\ua0Prevention in AF: Findings From the GLORIA-AF Registry Phase 2

Background GLORIA-AF (Global Registry on Long-Term Oral Antithrombotic Treatment in Patients with Atrial Fibrillation) is a prospective, global registry program describing antithrombotic treatment patterns in patients with newly diagnosed nonvalvular atrial fibrillation at risk of stroke. Phase 2 began when dabigatran, the first non\u2013vitamin K antagonist oral anticoagulant (NOAC), became available. Objectives This study sought to describe phase 2 baseline data and compare these with the pre-NOAC era collected during phase 1. Methods During phase 2, 15,641 consenting patients were enrolled (November 2011 to December 2014); 15,092 were eligible. This pre-specified cross-sectional analysis describes eligible patients\u2019 baseline characteristics. Atrial fibrillation disease characteristics, medical outcomes, and concomitant diseases and medications were collected. Data were analyzed using descriptive statistics. Results Of the total patients, 45.5% were female; median age was 71 (interquartile range: 64, 78) years. Patients were from Europe (47.1%), North America (22.5%), Asia (20.3%), Latin America (6.0%), and the Middle East/Africa (4.0%). Most had high stroke risk (CHA2DS2-VASc [Congestive heart failure, Hypertension, Age  6575 years, Diabetes mellitus, previous Stroke, Vascular disease, Age 65 to 74 years, Sex category] score  652; 86.1%); 13.9% had moderate risk (CHA2DS2-VASc = 1). Overall, 79.9% received oral anticoagulants, of whom 47.6% received NOAC and 32.3% vitamin K antagonists (VKA); 12.1% received antiplatelet agents; 7.8% received no antithrombotic treatment. For comparison, the proportion of phase 1 patients (of N = 1,063 all eligible) prescribed VKA was 32.8%, acetylsalicylic acid 41.7%, and no therapy 20.2%. In Europe in phase 2, treatment with NOAC was more common than VKA (52.3% and 37.8%, respectively); 6.0% of patients received antiplatelet treatment; and 3.8% received no antithrombotic treatment. In North America, 52.1%, 26.2%, and 14.0% of patients received NOAC, VKA, and antiplatelet drugs, respectively; 7.5% received no antithrombotic treatment. NOAC use was less common in Asia (27.7%), where 27.5% of patients received VKA, 25.0% antiplatelet drugs, and 19.8% no antithrombotic treatment. Conclusions The baseline data from GLORIA-AF phase 2 demonstrate that in newly diagnosed nonvalvular atrial fibrillation patients, NOAC have been highly adopted into practice, becoming more frequently prescribed than VKA in Europe and North America. Worldwide, however, a large proportion of patients remain undertreated, particularly in Asia and North America. (Global Registry on Long-Term Oral Antithrombotic Treatment in Patients With Atrial Fibrillation [GLORIA-AF]; NCT01468701

Georgia Law of Evidence (2013-2014 edition)

The new edition reflects Georgia’s adoption of the federal rules of evidence and assesses the impact of the new code on prior Georgia law and its creation of new areas of argument. Excerpt reprinted with permission of Thomson Reuters.https://digitalcommons.law.uga.edu/books/1082/thumbnail.jp

Making law, making place: Lawyers and the production of space

In this paper, we develop a conceptual framework for theorizing the role of lawyers in legal geography research to foster better understandings of the processes and the people co-constituting space and law. We argue that the practice of law is missing from existing legal geography scholarship. Adding insights from legal studies and geography, we propose an agenda for research that places lawyers at the center of analyses of legal (and political) claims-making, particularly place-claims in land-use disputes. We illustrate our call with an example from a study of conflict over a manufactured housing park in Georgia. © The Author(s), 2009