Federal Criminal Conspiracy

Under 18 U.S.C. § 371, it is a crime for two or more persons [to] conspire . . . to commit any offense against the United States, or to defraud the United States, or any agency thereof in any manner or for any purpose. This Article first outlines, in Section I, the basic elements of a conspiracy offense under § 371. Defenses available to challenge charges brought under the statute are discussed in Section III of the Article. Section IV presents the evidentiary and constitutional guidelines governing admissibility of co-conspirator hearsay testimony at trials involving conspiracy charges. Section V surveys various procedural and substantive rules regarding enforcement of the statute. Finally, the rules governing a conspiracy conviction under the Federal Sentencing Guidelines are reviewed in Section VI

GRTS and Graphs: Monitoring Natural Resources in Urban Landscapes

Environmental monitoring programs are an important tool for providing land managers with a scientific basis for management decisions. However, many ecological processes operate on spatial scales that transcend management boundaries (Schonewald-Cox 1988). For example, adjacent lands may influence protected-area resources via edge effects, source-sink dynamics, or invasion processes (Jones et al. 2009). Hydrologic alterations outside management units also may have profound effects on the integrity of resources being managed (Pringle 2000). The impacts of climate change are presenting challenges to resource management at local-to-global scales (Karl et al. 2009). This potential disparity between ecological and political boundaries presents an interesting dilemma for natural resource monitoring and is readily apparent in urban and agricultural environments, which tend to be dominated by external stressors (Collins et al. 2000). Despite their limited control over external land use, natural resource managers are concerned with processes such as development in the surrounding landscape, as these may lead to habitat loss and degradation that directly impair their resources. As a consequence, the management of the natural resources in and around parks and other areas requires a broad and dynamic understanding of the spatio-temporal patterns of environmental change. If monitoring is to be successful in providing data that inform management, information about regional and landscape context should play a critical role in designing monitoring strategies

Alignments of the Dominant Galaxies in Poor Clusters

We have examined the orientations of brightest cluster galaxies (BCGs) in poor MKW and AWM clusters and find that, like their counterparts in richer Abell clusters, poor cluster BCGs exhibit a strong propensity to be aligned with the principal axes of their host clusters as well as the surrounding distribution of nearby (< 20/h Mpc) Abell clusters. The processes responsible for dominant galaxy alignments are therefore independent of cluster richness. We argue that these alignments most likely arise from anisotropic infall of material into clusters along large-scale filaments.Comment: 8 pages, 5 figure

An Eye-Opening Approach to Developing and Communicating Integrated Environmental Assessments

Communication among managers, the public, and scientists is the key to successful ecosystem management; however, the varied perspectives and interests of these groups can make such communication difficult. One way to achieve effective communication is to develop a common knowledge base by combining syntheses of key scientific results with information-rich visual elements. Within a management landscape, integrated environmental assessments provide a useful framework for evaluating resources and directing management efforts. The integrated assessment process involves (1) initial investigation, (2) development of a conceptual framework, (3) data navigation, (4) environmental report cards, and (5) science communication. Each step requires the synthesis and visualization of information on the status and trends connected with multiple natural resources. We provide a case study, using examples from selected National Park Service sites in the mid-Atlantic region of the United States. Visual elements (conceptual diagrams, maps, graphs, tables, and photographs) were used to facilitate comparative assessments and to provide a more visual, or eye-opening , approach to effective environmental decision making

Admission to the Bar: A Constitutional Analysis

This Special Project examines and analyzes selected constitutional challenges to requirements for permanent and temporary admission to the bar. In the area of permanent admission, the Special Project looks at constitutional challenges to three qualifications typically required of bar applicants by states: demonstration of good moral character, successful completion of a bar examination, and residency. In the area of admission pro hac vice , the Project examines constitutional challenges to the basis on which judges have denied temporary admission to an applicant

Field experiments and meta-analysis reveal wetland vegetation as a crucial element in the coastal protection paradigm

Increasing rates of sea-level rise and wave action threaten coastal populations. Defense of shorelines by protection and restoration of wetlands has been invoked as a win-win strategy for humans and nature, yet evidence from field experiments supporting the wetland protection function is uncommon, as is the understanding of its context dependency. Here we provide evidence from field manipulations showing that the loss of wetland vegetation, regardless of disturbance size, increases the rate of erosion on wave-stressed shorelines. Vegetation removal (simulated disturbance) along the edge of salt marshes reveals that loss of wetland plants elevates the rate of lateral erosion and that extensive root systems, rather than aboveground biomass, are primarily responsible for protection against edge erosion in marshes. Meta-analysis further shows that disturbances that generate plant dieoff on salt marsh edges generally hasten edge erosion in coastal marshes and that the erosion protection function of wetlands relates more to lateral than vertical edge-erosional processes and is positively correlated with the amount of below-ground plant biomass lost. Collectively, our findings substantiate a coastal protection paradigm that incorporates preservation of shoreline vegetation, illuminate key context dependencies in this theory, and highlight local disturbances (e.g., oil spills) that kill wetland plants as agents that can accelerate coastal erosion

Irrigated spring-planted small grains -- peat and muck soils: Klamath and Lake counties [2000]

Published March 1983. Reprinted January 2000. Please check for active titles in the OSU Extension Service Catalog: http://extension.oregonstate.edu/catalo

Telephone conversation impairs sustained visual attention via a central bottleneck

Recent research has shown that holding telephone conversations disrupts one's driving ability. We asked whether this effect could be attributed to a visual attention impairment. In Experiment 1, participants conversed on a telephone or listened to a narrative while engaged in multiple object tracking (MOT), a task requiring sustained visual attention. We found that MOT was disrupted in the telephone conversation condition, relative to single-task MOT performance, but that listening to a narrative had no effect. In Experiment 2, we asked which component of conversation might be interfering with MOT performance. We replicated the conversation and single-task conditions of Experiment 1 and added two conditions in which participants heard a sequence of words over a telephone. In the shadowing condition, participants simply repeated each word in the sequence. In the generation condition, participants were asked to generate a new word based on each word in the sequence. Word generation interfered with MOT performance, but shadowing did not. The data indicate that telephone conversation disrupts attention at a central stage, the act of generating verbal stimuli, rather than at a peripheral stage, such as listening or speaking

The institutional shaping of management: in the tracks of English individualism

Globalisation raises important questions about the shaping of economic action by cultural factors. This article explores the formation of what is seen by some as a prime influence on the formation of British management: individualism. Drawing on a range of historical sources, it argues for a comparative approach. In this case, the primary comparison drawn is between England and Scotland. The contention is that there is a systemic approach to authority in Scotland that can be contrasted to a personal approach in England. An examination of the careers of a number of Scottish pioneers of management suggests the roots of this systemic approach in practices of church governance. Ultimately this systemic approach was to take a secondary role to the personal approach engendered by institutions like the universities of Oxford and Cambridge, but it found more success in the different institutional context of the USA. The complexities of dealing with historical evidence are stressed, as is the value of taking a comparative approach. In this case this indicates a need to take religious practice as seriously as religious belief as a source of transferable practice. The article suggests that management should not be seen as a simple response to economic imperatives, but as shaped by the social and cultural context from which it emerges