3,609 research outputs found
Rossby wave dynamics of the North Pacific extra-tropical response to El Niño: importance of the basic state in coupled GCMs
The extra-tropical response to El Nino in a "low" horizontal resolution coupled climate model, typical of the Intergovernmental Panel on Climate Change fourth assessment report simulations, is shown to have serious systematic errors. A high resolution configuration of the same model has a much improved response that is similar to observations. The errors in the low resolution model are traced to an incorrect representation of the atmospheric teleconnection mechanism that controls the extra-tropical sea surface temperatures (SSTs) during El Nino. This is due to an unrealistic atmospheric mean state, which changes the propagation characteristics of Rossby waves. These erroneous upper tropospheric circulation anomalies then induce erroneous surface circulation features over the North Pacific. The associated surface wind speed and direction errors create erroneous surface flux and upwelling anomalies which finally lead to the incorrect extra-tropical SST response to El Nino in the low resolution model. This highlights the sensitivity of the climate response to a single link in a chain of complex climatic processes. The correct representation of these processes in the high resolution model indicates the importance of horizontal resolution in resolving such processes
Torts—Pleading Elements of Negligence
Howard Stores Corp. v. Pope, 1 N. Y. 2d 110, 134 N. E. 2d 63 (1956)
State v. Pope Respondent\u27s Brief Dckt. 47290
https://digitalcommons.law.uidaho.edu/not_reported/7261/thumbnail.jp
State v. Pope Appellant\u27s Brief Dckt. 47290
https://digitalcommons.law.uidaho.edu/not_reported/7260/thumbnail.jp
Grappling with “Solicitation”: The Need For Statutory Reform in North Carolina after Lawrence v. Texas
Teresa Pope was charged with solicitation of the crime against nature for offering oral sex for money to two undercover police officers.5 Solicitation is an inchoate offense-like attempt or conspiracy-that relies on the criminality of the underlying conduct. 6 Although oral sex by itself cannot be criminalized post-Lawrence, the North Carolina Court of Appeals held in State v. Pope that the charge of solicitation of the crime against nature survived Lawrence by virtue of an exception in that decision allowing criminalization of prostitution. 10 In State v. Richardson, the Supreme Court of North Carolina construed this statute to apply only to vaginal, heterosexual sex.11 Consistent with the canon that criminal laws are to be interpreted narrowly, the court explained that [i]f the legislature wishes to include within [the prostitution statute] other sexual acts, such as cunnilingus, fellatio, masturbation, buggery or sodomy, it should do so with specificity
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Multi-model evaluation of the sensitivity of the global energy budget and hydrological cycle to resolution
This study undertakes a multi-model comparison with the aim to describe and quantify systematic changes of the global energy and water budgets when the horizontal resolution of atmospheric models is increased and to identify common factors of these changes among models. To do so, we analyse an ensemble of twelve atmosphere-only and six coupled GCMs, with different model formulations and with resolutions spanning those of state-of-the-art coupled GCMs, i.e. from resolutions coarser than 100 km to resolutions finer than 25 km. The main changes in the global energy budget with resolution are a systematic increase in outgoing longwave radiation and decrease in outgoing shortwave radiation due to changes in cloud properties, and a systematic increase in surface latent heat flux; when resolution is increased from 100 to 25 km, the magnitude of the change of those fluxes can be as large as 5 W m−2. Moreover, all but one atmosphere-only model simulate a decrease of the poleward energy transport at higher resolution, mainly explained by a reduction of the equator-to-pole tropospheric temperature gradient. Regarding hydrological processes, our results are the following: (1) there is an increase of global precipitation with increasing resolution in all models (up to 40 × 103 km3 year−1) but the partitioning between land and ocean varies among models; (2) the fraction of total precipitation that falls on land is on average 10% larger at higher resolution in grid point models, but it is smaller at higher resolution in spectral models; (3) grid points models simulate an increase of the fraction of land precipitation due to moisture convergence twice as large as in spectral models; (4) grid point models, which have a better resolved orography, show an increase of orographic precipitation of up to 13 × 103 km3 year−1 which explains most of the change in land precipitation; (5) at the regional scale, precipitation pattern and amplitude are improved with increased resolution due to a better simulated seasonal mean circulation. We discuss our results against several observational estimates of the Earth's energy budget and hydrological cycle and show that they support recent high estimates of global precipitation
Notice and the Missouri Probate Nonclaim Statutes: The Lingering Effects of Pope
The stem warnings published in Missouri newspapers used to read, All creditors of the decedent are notified to file claims in court within six months from the date of first publication of this notice or be forever barred. \u27 This language reflected section 473.360 of the Revised Statutes of Missouri. However, the decision of the United States Supreme Court in Tulsa Professional Collection Services, Inc. v. .Pope limited the effective operation of this strict statute. This Comment will review the case law addressing notice requirements and nonclaim statutes, discuss Missouri\u27s response to Pope, analyze the issues that are likely to be faced in the future, and, when appropriate, propose some legislative solutions to these problems
Probate: Notice to Estate Creditors: The Effect of Tulsa Professional Collection Services v. Pope
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