Limits of the Inevitable Discovery Doctrine in United States v. Young: The Intersection of Private Security Guards, Hotel Guests, and the Fourth Amendment

This Note analyzes the Young court’s opinion and the potential consequences of the majority’s cursory rejection of the government’s inevitable discovery argument. This Note also reconciles the differing applications of the inevitable discovery doctrine by the Young majority and dissent and highlights the speculative nature of employing the inevitable discovery doctrine based on the facts of Young. Part I of this Note presents the background of the case and the historical development of Fourth Amendment jurisprudence, focusing on the inevitable discovery doctrine as articulated by the Supreme Court in Nix v. Williams. Part II outlines the Young decision and analyzes Young’s expectation of privacy in comparison with other cases involving similar facts and the inevitable discovery doctrine. Part II also discusses the dissent’s vigorous, but misguided, argument in favor of applying the inevitable discovery doctrine to Young’s case. Part III discusses the potential consequences of the majority’s cursory examination of the inevitable discovery doctrine and presents a more in-depth analysis of why the inevitable discovery doctrine does not apply in this case

Beyond Piecework: Employment for Persons with Intellectual and Developmental Disabilities

All people deserve competitive, fulfilling employment (Lysaght, Cobigo, Hamilton, 2011). Many people with intellectual or developmental disabilities (I/DD) have difficulty obtaining competitive employment despite desiring to work (Lysaght, Ouellett-Kuntz, & Lin, 2010). In past years, people with I/DD have been employed in sheltered workshops; however, they are often paid below minimum wage, do not receive benefits, and are viewed as subordinates. Workers report the desire to work outside of sheltered employment. Competitive employment (integrated/supported employment), can lead to social justice, social inclusion, personal growth, and improved financial situations (Migliore, Mank, Grossi, & Rogan, 2007). Occupational therapists are suited to assist individuals with I/DD in obtaining and maintaining employment through development of skills and environmental supports. The purpose of this session is to present the results of an evidence based review on effective interventions to increase integrated/supported work engagement for individuals with I/DD, as well as discuss the significance in occupational therapy practice. A comprehensive literature review was performed to identify best practice. CINAHL, PubMed, OT Search, Scopus, ERIC, and Cochrane databases were searched. Peer reviewed articles published between 2003-2013, relating to interventions regarding integrated/supported employment for adults with I/DD, and within the scope of occupational therapy were included in the literature review. The review examined 12 articles that investigated the most effective interventions to increase integrated/supported work engagement in adults with I/DD. Reviewers used Law and McDermid’s (2003) Appendix M+N and PRISMA Systematic Review Form to critique the articles. There was one primary and one secondary reviewer per article; discrepancies were resolved through peer discussion. Upon review and synthesis of the articles, two main outcome themes, accuracy and quality of life were identified. Accuracy was typically related to the intervention of assistive technology. Interventions related to quality of life included choice-making, microenterprise, and peer support. In addition to expanding occupational therapy’s scope of practice, understanding the most effective interventions to promote employment for adults with I/DD allows occupational therapists to make informed decisions to increase the opportunities for integrated/supported work engagement for this population. References: Law, M. & McDermid, J. (2003). Appendix M and N (pp 414-423). In Evidence-Based Rehabilitation. Thorofare, NJ: SLACK, Inc. Lysaght, R., Cobigo, V., & Hamilton, K. (2012). Inclusion as a focus of employment-related research in intellectual disability from 2000 to 2010: A scoping review. Disability and rehabilitation, 34(16), 1339-1350. Lysaght, R., Ouellette-Kuntz, H., & Lin, C. J. (2012). Untapped potential: Perspectives on the employment of people with intellectual disability. Work: A Journal of Prevention, Assessment and Rehabilitation, 41(4), 409-422. Migliore, A., Mank, D., Grossi, T., & Rogan, P. (2007). Integrated employment or sheltered workshops: Preferences of adults with intellectual disabilities, their families, and staff. Journal of Vocational Rehabilitation, 26(1), 5-19

Biomimetic, Hierarchical, Multidimensional Patterning of Conductive Polymers on High-Aspect-Ratio Microstructures

Engineering and Applied Science

Prevalence, underlying causes, and preventability of sepsis-associated mortality in US acute care hospitals

Importance: Sepsis is present in many hospitalizations that culminate in death. The contribution of sepsis to these deaths, and the extent to which they are preventable, is unknown. Objective: To estimate the prevalence, underlying causes, and preventability of sepsis-associated mortality in acute care hospitals. Design, Setting, and Participants: Cohort study in which a retrospective medical record review was conducted of 568 randomly selected adults admitted to 6 US academic and community hospitals from January 1, 2014, to December 31, 2015, who died in the hospital or were discharged to hospice and not readmitted. Medical records were reviewed from January 1, 2017, to March 31, 2018. Main Outcomes and Measures: Clinicians reviewed cases for sepsis during hospitalization using Sepsis-3 criteria, hospice-qualifying criteria on admission, immediate and underlying causes of death, and suboptimal sepsis-related care such as inappropriate or delayed antibiotics, inadequate source control, or other medical errors. The preventability of each sepsis-associated death was rated on a 6-point Likert scale. Results: The study cohort included 568 patients (289 [50.9%] men; mean [SD] age, 70.5 [16.1] years) who died in the hospital or were discharged to hospice. Sepsis was present in 300 hospitalizations (52.8%; 95% CI, 48.6%-57.0%) and was the immediate cause of death in 198 cases (34.9%; 95% CI, 30.9%-38.9%). The next most common immediate causes of death were progressive cancer (92 [16.2%]) and heart failure (39 [6.9%]). The most common underlying causes of death in patients with sepsis were solid cancer (63 of 300 [21.0%]), chronic heart disease (46 of 300 [15.3%]), hematologic cancer (31 of 300 [10.3%]), dementia (29 of 300 [9.7%]), and chronic lung disease (27 of 300 [9.0%]). Hospice-qualifying conditions were present on admission in 121 of 300 sepsis-associated deaths (40.3%; 95% CI 34.7%-46.1%), most commonly end-stage cancer. Suboptimal care, most commonly delays in antibiotics, was identified in 68 of 300 sepsis-associated deaths (22.7%). However, only 11 sepsis-associated deaths (3.7%) were judged definitely or moderately likely preventable; another 25 sepsis-associated deaths (8.3%) were considered possibly preventable. Conclusions and Relevance: In this cohort from 6 US hospitals, sepsis was the most common immediate cause of death. However, most underlying causes of death were related to severe chronic comorbidities and most sepsis-associated deaths were unlikely to be preventable through better hospital-based care. Further innovations in the prevention and care of underlying conditions may be necessary before a major reduction in sepsis-associated deaths can be achieved

Comprehensive Cardiovascular magnetic resonance of myocardial mechanics in mice using three-dimensional cine DENSE

<p>Abstract</p> <p>Background</p> <p>Quantitative noninvasive imaging of myocardial mechanics in mice enables studies of the roles of individual genes in cardiac function. We sought to develop comprehensive three-dimensional methods for imaging myocardial mechanics in mice.</p> <p>Methods</p> <p>A 3D cine DENSE pulse sequence was implemented on a 7T small-bore scanner. The sequence used three-point phase cycling for artifact suppression and a stack-of-spirals <it>k</it>-space trajectory for efficient data acquisition. A semi-automatic 2D method was adapted for 3D image segmentation, and automated 3D methods to calculate strain, twist, and torsion were employed. A scan protocol that covered the majority of the left ventricle in a scan time of less than 25 minutes was developed, and seven healthy C57Bl/6 mice were studied.</p> <p>Results</p> <p>Using these methods, multiphase normal and shear strains were measured, as were myocardial twist and torsion. Peak end-systolic values for the normal strains at the mid-ventricular level were 0.29 ± 0.17, -0.13 ± 0.03, and -0.18 ± 0.14 for <it>E_rr</it>, <it>E_cc</it>, and <it>E_ll</it>, respectively. Peak end-systolic values for the shear strains were 0.00 ± 0.08, 0.04 ± 0.12, and 0.03 ± 0.07 for <it>E_rc</it>, <it>E_rl</it>, and <it>E_cl</it>, respectively. The peak end-systolic normalized torsion was 5.6 ± 0.9°.</p> <p>Conclusions</p> <p>Using a 3D cine DENSE sequence tailored for cardiac imaging in mice at 7 T, a comprehensive assessment of 3D myocardial mechanics can be achieved with a scan time of less than 25 minutes and an image analysis time of approximately 1 hour.</p

Influence of healthy candidate bias in assessing clinical effectiveness for implantable cardioverter-defibrillators: cohort study of older patients with heart failure

Objective: To assess the potential contribution of unmeasured general health status to patient selection in assessments of the clinical effectiveness of implantable cardioverter-defibrillator (ICD) therapy. Design: Retrospective cohort study. Setting: Linked data from an ICD registry, heart failure registry, and Medicare claims data for ICDs implanted in 2005 through 2009. Participants: 29 426 patients admitted to hospital with heart failure aged 66 years or older and eligible for ICD therapy for primary prevention. Main outcome measures Non-traumatic hip fracture, admission to a skilled nursing facility, and 30 day mortality—outcomes unlikely to be improved by ICD therapy. Results: Compared with 17 853 patients without ICD therapy, 11 573 patients with ICD therapy were younger and had lower ejection fraction and more cardiac admissions to hospital but fewer non-cardiac admissions to hospital and comorbid conditions. Patients with ICD therapy had greater freedom from unrelated events after adjusting for age and sex: hip fracture (hazard ratio 0.77, 95% confidence interval 0.64 to 0.92), skilled nursing facility admission (0.53, 0.50 to 0.55), and 30 day mortality (0.12, 0.10 to 0.15). Conclusions: Lower risks of measured outcomes likely reflect unmeasured differences in comorbidity and frailty. The findings highlight potential pitfalls of observational comparative effectiveness research and support physician consideration of general health status in selecting patients for ICD therapy

An Uncommon Woman: Alison Snow Jones Unleashed!

Alison was like a diamond; truly unique in her brilliant multi-faceted array of talents, brains, passions and skills. Everyone who participated in developing this memorial book commented first on her brilliance. She was a scholar, a top notch statistician, an innovative researcher, a popular blogger about economics and ethics, an exceedingly competent horsewoman and boater, a tremendous cook and baker, someone who loved a good time with others and always a fighter for justice. She was extremely smart, able to form very complex, deep ideas and had an uncommon ability to communicate them easily and effectively to others, including the public

Comparisons of Aerosol Generation Across Different Musical Instruments and Loudness

Highlights•Aerosol number and mass concentrations measured during musical instrument playing.•A 1 dBA increase in sound pressure level yields ∼10% increase in number concentration.•Loudness of playing explains some but not all differences across instruments.•Musical instrument playing size distributions are consistent with those of breathing.•Simple songs sufficient to characterise aerosol emission during actual performance.AbstractRespiratory aerosols can serve as vectors for disease transmission, and aerosol emission is highly activity-dependent. COVID-19 severely impacted the performing arts due to concerns about disease spread by respiratory aerosols and droplets generated during singing and playing musical instruments. Aerosol generation from woodwind and brass performance is less understood compared to singing due to uncertainty about how the diverse range of musical instruments may impact respiratory aerosol concentrations and size distributions. Here, aerosol number and mass concentrations along with size distributions were measured for breathing, speaking, and playing four different woodwind and brass instruments by 23 professional instrumentalists. We find that a 1 dBA increase in sound pressure level corresponds to a ∼10% increase in aerosol number concentration. The aerosol size distribution is consistent with that of breathing. Differences in aerosol emission across musical instruments can be partly explained by the loudness of performance. Measuring aerosol generation from single notes or simple songs may be sufficient to characterise the aerosol emission range during actual performance, provided a range of loudnesses are accessed. These results provide insight into the factors contributing to aerosol emission during musical performance and facilitate risk assessments associated with infectious respiratory disease transmission in the performing arts