Schwalbe v. Jones: The Owner-Passenger Statute Held Constitutional - What Ever Happened to Brown v. Merlo

This Comment will demonstrate that no rationale exists to support differential treatment of an owner-passenger and a non-owner-passenger. An analysis of the Schwalbe decision will underscore the inconsistency of its rationale. If Schwalbe had been decided on its facts, the Court could have avoided entirely the issue of the owner-passenger statute\u27s constitutionality. In addition, the rationale suggested by the majority does not support the legislative purposes of the Vehicle Code financial responsibility and civil liability provisions. Finally, Schwalbe must be viewed within the context of California tort law, which is based on the fault principle and on the policy of fair compensation to injured plaintiffs. However, to understand the impact of Schwalbe, an examination of the guest statute\u27s background and of Brown is required

Retour d'expérience du démantèlement du barrage de Kernansquillec

National audienceKernansquillec dam in French Britany has been demolished in 1996. It was a multiple arch dam, 75-year-old, 15 m high , with a reservoir capacity of 400 000 m3. Due to the poor condition of the dam, risks involved downstream, and lack of an operator after the end of the concession, the Prefet decided the dam demolition. Management of the sediments, representing 50% of the reservoir capacity was achieved without interrupting water intakes for domestic water supply and fishfarming, situated few hundred meters downstream from the dam. The solution combined: hydrodredging of 90 000 m3 of sediments to restore the old river bed in the reservoir; in situ consolidation of the rest of the sediments, by slowly lowering the reservoir water level; construction of four little rockfill weirs downstream from the dam, for water decantation at the end of emptying. Total cost of the operation was just over 1 MA, including 0,6 MA for sediment management.Le barrage de Kernansquillec en Bretagne, vieux de 75 ans, a été démoli en 1996. C'était un barrage multi-voûtes de 15 m de hauteur et 400 000 m3 de capacité. Compte tenu de la vétusté de l'ouvrage, des risques induits pour l'aval et de l'absence de repreneur après la fin de concession, la décision de démolition a été prise par le préfet. Sa mise en oeuvre a été délicate du fait de l'envasement de la retenue et des enjeux liés à la consommation d'eau en aval. La vidange a pu être menée à bien avec succès en combinant : l'hydrocurage de 90 000 m3 de sédiments de façon à restaurer l'ancien lit de la rivière ; la consolidation en place des sédiments restants par un abaissement très lent du plan d'eau ; la construction de quatre seuils en enrochements en aval du barrage pour la décantation des sédiments en fin de vidange. Le coût total de l'opération fut d'un peu plus de 1 MA, dont 0,6 MA pour le seul poste de gestion des sédiments

Whole-Body CT after Motor Vehicle Crash: No Benefit after High-Energy Impact and with Normal Physical Examination

Background Debate continues about the risks and benefits of systematic whole-body CT when no injury is clinically suspected. Risks of whole-body CT include high radiation exposure and iodine contrast agent, but its effectiveness in reducing mortality in low-risk motor vehicle crashes is unclear. Purpose To assess unsuspected injuries revealed at whole-body CT in patients following motor vehicle crash (MVC) meeting only kinetic elements of the Vittel criteria for the severity of trauma, with no evidence of trunk injury and a Glasgow Coma Scale score of 15. Materials and Methods This retrospective study included all consecutive adult patients who consulted an emergency department of a level 1 trauma center between August 2016 and July 2017 if they underwent whole-body CT for one or more kinetic elements of the Vittel criteria, had a normal examination of the trunk, and had a Glasgow Coma Scale score of 15. Data of the MVC mechanism and physical and biologic examinations were collected, as well as patient treatment data after whole-body CT. Whole-body CT examinations were read by two double-blinded readers to help detect unsuspected injuries. Results Ninety-three patients were included; 72 were men with a mean age of 30.8 years ± 12.0 (standard deviation). Sixty-nine patients were occupants of a car. Seventeen patients were hit by a car while on motorbikes, three while on bicycles, and four as pedestrians. Unsuspected injuries were depicted at 11 whole-body CT examinations: eight lung contusions, one acetabular fracture, one sternal fracture, and one adrenal hematoma. None of these injuries required a specific treatment. One patient with lung contusion of more than 30% of lung volume was followed without requiring further treatment. Conclusion In this population, whole-body CT did not lead to any change in patient treatment. These results suggest whole-body CT should not be systematically performed when no evidence of trunk injury is observed in patients following motor vehicle crash meeting only kinetic elements of Vittel criteria. © RSNA, 2019 See also the editorial by Munera and Durso in this issue

Magnetothermodynamics of BPS baby skyrmions

The magnetothermodynamics of skyrmion type matter described by the gauged BPS baby Skyrme model at zero temperature is investigated. We prove that the BPS property of the model is preserved also for boundary conditions corresponding to an asymptotically constant magnetic field. The BPS bound and the corresponding BPS equations saturating the bound are found. Further, we show that one may introduce pressure in the gauged model by a redefinition of the superpotential. Interestingly, this is related to non-extremal type solutions in the so-called fake supersymmetry method. Finally, we compute the equation of state of magnetized BSP baby skyrmions inserted into an external constant magnetic field $H$ and under external pressure $P$, i.e., $V=V(P,H)$, where $V$ is the "volume" (area) occupied by the skyrmions. We show that the BPS baby skyrmions form a ferromagnetic medium.Comment: Latex, 39 pages, 14 figures. v2: New results and references added, physical interpretation partly change

Impact of Diabetes on Work Cessation: Data from the GAZEL cohort study

International audienceOBJECTIVE: To measure the impact of diabetes on work cessation, i.e., on the risks of work disability, early retirement, and death while in the labor force. RESEARCH DESIGN AND METHODS: We used data from the GAZEL prospective cohort of 20,625 employees of the French national gas and electricity company "EDF-GDF." We identified 506 employees with diabetes and randomly selected 2,530 nondiabetic employed control subjects matched for major sociodemographic and occupational characteristics. Using a multistate Cox model, we estimated hazard ratios (HRs) comparing the risks of transition from employment to disability, retirement, and death over time between participants with versus without diabetes. RESULTS: Employment rate decreased more rapidly in participants with diabetes (51.9 and 10.1% at 55 and 60 years, respectively) compared with nondiabetic participants (66.5 and 13.4%, respectively). Participants with diabetes had significantly increased risks of transition from employment to disability (HR 1.7 [95% CI 1.0-2.9]), retirement (HR 1.6 [1.5-1.8]), and death (HR 7.3 [3.6-14.6]) compared with participants without diabetes. Between 35 and 60 years, each participant with diabetes lost an estimated mean time of 1.1 year in the workforce (95% CI 0.99-1.14) compared with a nondiabetic participant. CONCLUSIONS: Our results provide evidence for a profound negative impact of diabetes on workforce participation in France. Social and economic consequences are major for patients, employers, and society-a burden that is likely to increase as diabetes becomes more and more common in the working-aged population

Vaccines against toxoplasma gondii : challenges and opportunities

Development of vaccines against Toxoplasma gondii infection in humans is of high priority, given the high burden of disease in some areas of the world like South America, and the lack of effective drugs with few adverse effects. Rodent models have been used in research on vaccines against T. gondii over the past decades. However, regardless of the vaccine construct, the vaccines have not been able to induce protective immunity when the organism is challenged with T. gondii, either directly or via a vector. Only a few live, attenuated T. gondii strains used for immunization have been able to confer protective immunity, which is measured by a lack of tissue cysts after challenge. Furthermore, challenge with low virulence strains, especially strains with genotype II, will probably be insufficient to provide protection against the more virulent T. gondii strains, such as those with genotypes I or II, or those genotypes from South America not belonging to genotype I, II or III. Future studies should use animal models besides rodents, and challenges should be performed with at least one genotype II T. gondii and one of the more virulent genotypes. Endpoints like maternal-foetal transmission and prevention of eye disease are important in addition to the traditional endpoint of survival or reduction in numbers of brain cysts after challenge