Are Marine National Monuments Situated on Lands Owned or Controlled by the Government of the United States?

The ocean offers what may seem like endless supply of natural resources, ecosystem services, or for some, simple enjoyment. Yet, in the face of climate change and overexploitation, many of these unique ecosystems and their inhabitants face an uphill battle. A president\u27s use of the Antiquities Act establishing a national monument is an efficient and effective method of protecting these diverse ecosystems, as long as the area to be protected satisfies one of the Act\u27s limitations that the monument be situated on land owned or controlled by the federal government. Prior to a 2017 lawsuit concerning President Obama\u27s use of the Act to establish the Northeast Canyons and Seamounts Marine National Monument off the coast of New England, no one had specifically protested a marine national monument on grounds that it is not situated on land owned or controlled by the federal government. This Comment concludes that submerged lands qualify as land within the meaning of the Antiquities Act, and that, until Congress acts, the federal government maintains sufficient ownership and control of the submerged lands and waters within the Monument\u27s boundaries. Simply put, if the federal government doesn\u27t have sufficient ownership or control over the land and waters within the Exclusive Economic Zone, then who does

Northeastern Pennsylvania\u27s Forgotten Labor Massacre: Analysis pf the English Language Record of the Lattimer Massacre

The Lattimer Massacre occurred on September 10, 1897, in a small anthracite mining town in northeastern Pennsylvania. The bloody conflict erupted when an unarmed group of mostly Eastern European immigrant mine workers lethally clashed with militantly armed sheriff’s deputies who acted on behalf of private coal companies. Nineteen strikers died at the scene and dozens more were horrifically wounded. Despite the outraged shock of the community clamoring for justice which led to a murder trial that made international headlines, the Lattimer Massacre faded from local and national memory in the following decades. A combination of lingering nativist prejudice curated by capital and elite society and a lack of surviving evidence from the Eastern European immigrant community contributed to the Massacre’s absence from broader historical discussion of Gilded Age labor organization in the United States. This works seeks to position the Lattimer Massacre within Gilded Age American society in an effort to acknowledge the roots of ethnic and economic conflict between established immigrant groups and newly arriving Eastern and Southern Europeans in northeastern Pennsylvania. This study seeks to understand how the community memory of the Lattimer Massacre influenced historical scholarship. A lack of historicization of primary sources created a distorted understanding of the immigrant led strike activity. This distorted view positioned Lattimer as a rare moment of extremes rather than the explosion of decades of conflict between immigrant workers and capital. Analysis of the English-language newspaper record and community produced documents brings out fresh insights about the anthracite community of northeastern Pennsylvania and the evolution of Lattimer’s memory in the historical record. Appraisal of the source materials exposes the critical role of women and families in immigrant strike activity, demonstrates how Slavic immigrants understood their positions in an evolving American society, and creates a more complex understanding of how American society perceived and reacted to unionization and immigrant labor

Bandwidth efficient CCSDS coding standard proposals

The basic concatenated coding system for the space telemetry channel consists of a Reed-Solomon (RS) outer code, a symbol interleaver/deinterleaver, and a bandwidth efficient trellis inner code. A block diagram of this configuration is shown. The system may operate with or without the outer code and interleaver. In this recommendation, the outer code remains the (255,223) RS code over GF(2 exp 8) with an error correcting capability of t = 16 eight bit symbols. This code's excellent performance and the existence of fast, cost effective, decoders justify its continued use. The purpose of the interleaver/deinterleaver is to distribute burst errors out of the inner decoder over multiple codewords of the outer code. This utilizes the error correcting capability of the outer code more efficiently and reduces the probability of an RS decoder failure. Since the space telemetry channel is not considered bursty, the required interleaving depth is primarily a function of the inner decoding method. A diagram of an interleaver with depth 4 that is compatible with the (255,223) RS code is shown. Specific interleaver requirements are discussed after the inner code recommendations

Cardiac hemangioma of the right atrium in a neonate : fetal management and expedited surgical resection

Cardiac hemangioma is a rare tumor with a reported incidence of 1-2%. We describe the case of a neonate with a right atrial mass that was diagnosed prenatally. The fetus developed a supraventricular tachycardia and was delivered by cesarean section in the 35th week of gestation. The infant underwent surgery after 24 hours to remove the mass which was diagnosed as a cardiac capillary-cavernous hemangioma.peer-reviewe

Non-penalization and Non-Criminalization

The Oxford Handbook of International Refugee Law is a comprehensive, critical work, which analyses the state of research across the refugee law regime as a whole. Drawing together leading and emerging scholars, the Handbook provides both doctrinal and theoretical analyses of international refugee law and practice. It critiques existing law from a variety of normative positions, with several chapters identifying foundational flaws that open up space for radical rethinking. The Handbook aspires to be global, both legally and geographically. Contributions assess a wide range of international legal instruments relevant to refugee protection, including from international human rights law, international humanitarian law, international migration law, the law of the sea, and international and transnational criminal law. Ultimately, the Handbook provides an account, as well as a critique, of the status quo, and in so doing it sets the agenda for future academic research in international refugee law