Waiving Good-bye to Inconsistency: Factual Basis Challenges to Guilty Pleas in Federal Courts

Rule 11(b)(3) of the Federal Rules of CriminalProcedurerequires courts to determine that criminal defendants\u27guilty pleas have a factual basis. Once a district courtaccepts a guilty plea, appellate courts diverge in theirwillingness to review challenges to the sufficiency of theplea\u27s factual basis. Some federal circuits hold that afactual basis challenge is waived by the guilty plea. Otherjurisdictions will review a defendant\u27s factual basischallenge on appeal. Despite the lack of clarity on thispoint, the Supreme Court has not yet provided guidanceand the federal circuit courts have not offered a great dealof reasoning behind their treatment of the factual basischallenge.This Note argues that a challenge to the factual basis fora guilty plea should be waived by the plea. This positioncomports with the substantialpolicy interest in the efficacyand finality of guilty pleas. Other forms of relief availableto defendants who plead guilty make factual basischallenges otiose in this context. This Note then addressesthe practical problems attendant to an appellate review ofa guilty plea\u27s factual basis. Finally, it draws ameaningful distinction between compliance with theprocedural requirements of Rule 11 and the findings offact made by a district court during the guilty pleahearing

The Southern Baptist Convention Reformation, 1979-1990: A Social Drama.

From Michael Thompson, Richard Ellis, and Aaron Wildavsky\u27s cultural theory perspective, the authoritarian and the individualistic ways of life have coexisted in the Southern Baptist Convention (SBC) for more than a century. In 1979, Southern Baptist fundamentalists began a concerted movement to reform the SBC according to authoritarian beliefs and social practices. From Victor Turner\u27s dramaturgical perspective, the 1979-1990 Southern Baptist controversy was a social drama that transferred power and reshaped Southern Baptists\u27 perception of the past, present, and future. Rhetorical strategies facilitated each stage of the fundamentalists\u27 reformation movement and the moderate counter movement. The present study symbolically explicates the rhetoric expressed in two rival events that preceded the yearly SBC meetings, the Pastors\u27 Conferences (1979-1990) and the SBC Forums (1984-1990). The study focuses on the different meanings that participants constructed as speakers enacted conflicting definitions of the SBC. The study analyzes the polarized perceptions of the social drama and interprets the colliding epistemologies. The study offers a rhetorical and dramaturgical explanation of how the SBC Social Drama drove an ideological wedge between authoritarian and individualistic ways of life. A prominent conclusion is that the rhetoric in the Pastors\u27 Conferences and the SBC Forums displayed particular forms consisting of a breach (1979), a crisis (1980-1985), a redress (1986-1987), a recycled crisis (1988), and a mixed-result ending(1989-1990). The mixed-result ending suggests that the social drama resolved for some Baptists (i.e., as fundamentalists consolidated control of the SBC, and as some moderates formed schismatic organizations), but failed to resolve for other Southern Baptists. The failed social drama contributed to a growing social rift between some Baptists. Another conclusion is that speakers portrayed evolving roles as their constituents gained and lost status in the SBC. The role of fundamentalist rhetors moved from crusading reformers to management as their ideology gained ascendency, and the role of moderate rhetors moved from management to outsiders as their ideology lost support in the SBC

No time to die: An in-depth analysis of James Bond's exposure to infectious agents.

Global travelers, whether tourists or secret agents, are exposed to a smörgåsbord of infectious agents. We hypothesized that agents pre-occupied with espionage and counterterrorism may, at their peril, fail to correctly prioritize travel medicine. To examine our hypothesis, we examined adherence to international travel advice during the 86 international journeys that James Bond was observed to undertake in feature films spanning 1962-2021. Scrutinizing these missions involved ∼3113 min of evening hours per author that could easily have been spent on more pressing societal issues. We uncovered above-average sexual activity, often without sufficient time for an exchange of sexual history, with a remarkably high mortality among Bond's sexual partners (27.1; 95% confidence interval 16.4-40.3). Given how inopportune a bout of diarrhea would be in the midst of world-saving action, it is striking that Bond is seen washing his hands on only two occasions, despite numerous exposures to foodborne pathogens. We hypothesize that his foolhardy courage, sometimes purposefully eliciting life-threatening situations, might even be a consequence of Toxoplasmosis. Bond's approach to vector-borne diseases and neglected tropical diseases is erratic, sometimes following travel advice to the letter, but more often dwelling on the side of complete ignorance. Given the limited time Bond receives to prepare for missions, we urgently ask his employer MI6 to take its responsibility seriously. We only live once

Efficacy of Guanabenz Combination Therapy against Chronic Toxoplasmosis across Multiple Mouse Strains

Toxoplasma gondii, an obligate intracellular parasite that can cause life-threatening acute disease, differentiates into a quiescent cyst stage to establish lifelong chronic infections in animal hosts, including humans. This tissue cyst reservoir, which can reactivate into an acute infection, is currently refractory to clinically available therapeutics. Recently, we and others have discovered drugs capable of significantly reducing the brain cyst burden in latently infected mice, but not to undetectable levels. In this study, we examined the use of novel combination therapies possessing multiple mechanisms of action in mouse models of latent toxoplasmosis. Our drug regimens included combinations of pyrimethamine, clindamycin, guanabenz, and endochin-like quinolones (ELQs) and were administered to two different mouse strains in an attempt to eradicate brain tissue cysts. We observed mouse strain-dependent effects with these drug treatments: pyrimethamine-guanabenz showed synergistic efficacy in C57BL/6 mice yet did not improve upon guanabenz monotherapy in BALB/c mice. Contrary to promising in vitro results demonstrating toxicity to bradyzoites, we observed an antagonistic effect between guanabenz and ELQ-334 in vivo While we were unable to completely eliminate the brain cyst burden, we found that a combination treatment with ELQ-334 and pyrimethamine impressively reduced the brain cyst burden by 95% in C57BL/6 mice, which approached the limit of detection. These analyses highlight the importance of evaluating anti-infective drugs in multiple mouse strains and will help inform further preclinical studies of cocktail therapies designed to treat chronic toxoplasmosis

Role of Cellular Heparan Sulfate Proteoglycans in Infection of Human Adenovirus Serotype 3 and 35

Species B human adenoviruses (Ads) are increasingly associated with outbreaks of acute respiratory disease in U.S. military personnel and civil population. The initial interaction of Ads with cellular attachment receptors on host cells is via Ad fiber knob protein. Our previous studies showed that one species B Ad receptor is the complement receptor CD46 that is used by serotypes 11, 16, 21, 35, and 50 but not by serotypes 3, 7, and 14. In this study, we attempted to identify yet-unknown species B cellular receptors. For this purpose we used recombinant Ad3 and Ad35 fiber knobs in high-throughput receptor screening methods including mass spectrometry analysis and glycan arrays. Surprisingly, we found that the main interacting surface molecules of Ad3 fiber knob are cellular heparan sulfate proteoglycans (HSPGs). We subsequently found that HSPGs acted as low-affinity co-receptors for Ad3 but did not represent the main receptor of this serotype. Our study also revealed a new CD46-independent infection pathway of Ad35. This Ad35 infection mechanism is mediated by cellular HSPGs. The interaction of Ad35 with HSPGs is not via fiber knob, whereas Ad3 interacts with HSPGs via fiber knob. Both Ad3 and Ad35 interacted specifically with the sulfated regions within HSPGs that have also been implicated in binding physiologic ligands. In conclusion, our findings show that Ad3 and Ad35 directly utilize HSPGs as co-receptors for infection. Our data suggest that adenoviruses evolved to simulate the presence of physiologic HSPG ligands in order to increase infection

Primary hyperaldosteronism caused by adrenocortical carcinoma

Since the syndrome of primary hyperaldosteronism was described by Jerome Conn in 1955, over 300 patients with this disorder have been identified in the medical centers of Vanderbilt University and the University of Michigan. The most frequent cause of this endocrinopathy has been a solitary adenoma of the adrenal cortex (72%); bilateral adrenocortical hyperplasia has been the cause of primary hyperaldosteronism in 27% of cases; less frequently, the cause has been multiple and/or bilateral adenomas (1%). During the last 4 years in these 2 medical centers, we have encountered 3 patients who have had biochemically proven primary hyperaldosteronism due to adrenocortical carcinoma. Each of these unusual cases is summarized with review of the recent literature . Depuis que le syndrome d'hyperaldostéronisme primitif a été décrit par Jerôme Conn en 1955 plus de 300 sujets qui en étaient victimes ont été identifiés à la Vanderbilt University de Nashville et à l'University of Michigan de Ann Arbor. La cause la plus fréquente de cette endocrinopathie répond à un adénome solitaire de la cortico-surrénale (72%) alors que l'hyperplasie corticale des 2 surrénales est plus rarement à son origine (27%), les adénomes multiples et/ou bilatéraux étant rarissimes (1%). Au cours des 4 dernières années 3 cas d'hyperaldosteronisme dû à un cancer de la cortico-surrénale ont été observés dans les 2 centres. Chacun de ces cas exceptionnels est exposé cependant que la littérature récente concernant l'hyperalderosteronisme est analysée. Desde la descripción del síndrome de hiperaldosteronismo primario por Jeremo Conn en 1955, más de 300 pacientes con esta entidad han sido identificados en nuestros 2 centros médicos, la Universidad de Vanderbilt (Nashville) y la Universidad de Michigan (Ann Arbor). La causa más frecuente de esta endocrinopatía ha sido el adenoma solitario de la corteza suprarrenal (72%); la hiperplasia adrenocortical bilateral ha sido la causa del hiperaldosteronismo primario en 27% de los casos; con menor frecuencia se han presentado los adenomas multiples y/o bilaterales (1%). En los 4 últimos años hemos encontrado 3 pacientes con hiperaldosteronismo primario comprobado bioquímicamente producido por carcinoma adrenocortical. Se presenta cada uno de estos casos poco usuales junto con una revisión de la literatura reciente.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/41275/1/268_2005_Article_BF01655546.pd