Standing Under State Search and Seizure Provision: Why the Minnesota Supreme Court Should Have Rejected the Federal Standards and Instead Invoked Greater Protection Under its Own Constitution in State v. Carter

In State v. Carter, the Minnesota Supreme Court considered whether a criminal defendant had “standing” to challenge an alleged search under the Fourth Amendment and Article 1, Section 10 of the Minnesota Constitution. The defendant moved to suppress evidence obtained by a police officer who had peered in the window of an apartment where the defendant was participating in a drug-packaging operation with the apartment\u27s leaseholder. A divided court held that the defendant had a legitimate expectation of privacy in the apartment. Therefore, the defendant had standing to challenge the legality of the police officer\u27s observations pursuant to the Fourth Amendment of the United States Constitution, and Article 1, Section 10 of the Minnesota Constitution. The court concluded that the police officer\u27s observations constituted an unreasonable search. Recently, the United States Supreme Court reversed the Minnesota Supreme Court\u27s decision, and held that the defendant did not have a legitimate expectation of privacy at the apartment. The Court justified this determination by focusing on the defendant\u27s status as a temporary guest and the fact that he was at the premises solely for commercial purposes. As a result, the Court denied him standing to challenge whether the police officer\u27s observations constituted an unreasonable search. This Note will criticize the Minnesota Supreme Court\u27s analysis in Carter, concluding that the court should have discarded the privacy-based standard. This analysis will integrate the recent United States Supreme Court reversal of State v. Carter, and the Author intends to demonstrate the increasing subjectivity of Fourth Amendment jurisprudence in the area of guest cases. Thus, instead of following the Supreme Court\u27s standards, the Minnesota Supreme Court should have analyzed the facts in Carter under its own state constitutional search and seizure provision, thereby adopting a standing rule that is textually based and supported by the purpose of the Fourth Amendment

Green Framing in Corporate Poultry Videos: An Analysis of Sustainability Messaging

Large broiler chicken companies have been under pressure by consumers to reduce their carbon footprint, improve animal welfare and labor practices, and enhance environmental quality across the industry. This study examines how large broiler chicken companies have addressed sustainability within video content directed toward consumers and posted on YouTube. To conceptualize this study, we used the 1990 Farm Bill definition of agricultural sustainability. It is important to examine articulations of agricultural sustainability as company messages often incorporate sustainability philosophies and ideologies while referencing specific production practices and goals. This study used qualitative content analysis to analyze 440 videos, and framing analysis to closely examine a subset of 55 videos, from three of the largest broiler chicken companies in the United States. The framing analysis revealed that stewardship, natural state, and catalyst for change were the three most frequently used sustainability frames across the companies. These frames focus on elements of caretaking, responsibility, and public accountability, and apply these ideals to people, chickens, and profit within the organization. Few discussions of environmental stewardship were found within our analysis. While frames were not necessarily connected to production practices, each company did tend to leverage frames in ways that align with brand positioning. Companies should consider implementing discussions of how production practices affect the environment more directly, since protecting the environment and replenishing natural resources are concepts consumers associate with sustainability

Further Characterization of the Mitigation of Radiation Lethality by Protective Wounding

There continues to be a major effort in the United States to develop mitigators for the treatment of mass casualties that received high-intensity acute ionizing radiation exposures from the detonation of an improvised nuclear device during a radiological terrorist attack. The ideal countermeasure should be effective when administered after exposure, and over a wide range of absorbed doses. We have previously shown that the administration of a subcutaneous incision of a defined length, if administered within minutes after irradiation, protected young adult female C57BL/6 mice against radiation-induced lethality, and increased survival after total-body exposure to an LD50/30 X-ray dose from 50% to over 90%. We refer to this approach as "protective wounding". In this article, we report on our efforts to further optimize, characterize and demonstrate the validity of the protective wounding response by comparing the response of female and male mice, varying the radiation dose, the size of the wound, and the timing of wounding with respect to administration of the radiation dose. Both male and female mice that received a subcutaneous incision after irradiation were significantly protected from radiation lethality. We observed that the extent of protection against lethality after an LD50/30 X-ray dose was independent of the size of the subcutaneous cut, and that a 3 mm subcutaneous incision is effective at enhancing the survival of mice exposed to a broad range of radiation doses (LD15-LD100). Over the range of 6.2-6.7 Gy, the increase in survival observed in mice that received an incision was associated with an enhanced recovery of hematopoiesis. The enhanced rate of recovery of hematopoiesis was preceded by an increase in the production of a select group of cytokines. Thus, a thorough knowledge of the timing of the cytokine cascade after wounding could aid in the development of novel pharmacological radiation countermeasures that can be administered several days after the actual radiation exposure

A Multi-Method Analysis of Diversity, Equity, and Inclusion Websites of Fortune 500 Agricultural and Food Companies

Each year, Fortune magazine publishes a list of the 500 largest corporations in the United States of America based on total revenue in the previous fiscal year. As successful companies, these organizations must prioritize diversity, equity, and inclusion (DEI) for a multitude of reasons. The purpose of this study was to determine how agricultural and food companies on the 2021 Fortune 500 list demonstrated a commitment to DEI efforts on their corporate websites. Thus, we analyzed the DEI website of each food and agricultural company listed on the 2021 Fortune 500 list. Quantitatively, most websites only required two clicks to access resources and information regarding how the company supports diverse audiences in the workplace when navigating from the main corporate website. Corporations should ensure DEI is a priority for and clearly communicate this on the website using definitions, statements, and employee resources on websites. Additionally, using visuals such as photos, videos, and graphics can improve communication in this space. For the qualitative portion of the study, we analyzed the use of executive and employee voices in communicating about DEI on the corporate landing page. Two themes emerged. Within the corporate theme came the work-to-be-done subtheme which addresses corporate DEI work as a work in progress. The second theme was the personal and professional theme which helps support the personal and professional wellbeing of employees and stakeholders. We offer suggestions for communicators and executives for communicating about DEI in the food and agriculture webspace and offer recommendations for future researc

Automated Fact Checking in the News Room

Fact checking is an essential task in journalism; its importance has been highlighted due to recently increased concerns and efforts in combating misinformation. In this paper, we present an automated fact-checking platform which given a claim, it retrieves relevant textual evidence from a document collection, predicts whether each piece of evidence supports or refutes the claim, and returns a final verdict. We describe the architecture of the system and the user interface, focusing on the choices made to improve its user-friendliness and transparency. We conduct a user study of the fact-checking platform in a journalistic setting: we integrated it with a collection of news articles and provide an evaluation of the platform using feedback from journalists in their workflow. We found that the predictions of our platform were correct 58\% of the time, and 59\% of the returned evidence was relevant

Lux et Lex: Volume 5, Number 1

This issue of Lux et Lex, a publication of the Chester Fritz Library at the University of North Dakota, was published in May 1998