Is that a threat?: Elonis v. United States and the Standard of Intent for True Threat Convictions

This commentary analyzes the Supreme Court case Elonis v. United States where the Court will determine the applicable criminal-intent standard required to convict a defendant for threatening speech. After a series of violent Facebook posts against coworkers and his estranged wife, Petitioner Elonis was convicted for making so-called true threats of violence--speech not granted First-Amendment protection. Elonis argues that the prosecution should have been required to prove that he actually had the intent to threaten people when he wrote the posts, not simply that a reasonable person would find the posts threatening. The Author argues that the Court should rule in the Petitioner\u27s favor and require a finding of subjective intent because such a mens rea requirement is suggested in the plain meaning, legislative history, and by the Court\u27s true-threat jurisprudence

Is that a threat?: Elonis v. United States and the Standard of Intent for True Threat Convictions

This commentary analyzes the Supreme Court case Elonis v. United States where the Court will determine the applicable criminal-intent standard required to convict a defendant for threatening speech. After a series of violent Facebook posts against coworkers and his estranged wife, Petitioner Elonis was convicted for making so-called true threats of violence--speech not granted First-Amendment protection. Elonis argues that the prosecution should have been required to prove that he actually had the intent to threaten people when he wrote the posts, not simply that a reasonable person would find the posts threatening. The Author argues that the Court should rule in the Petitioner\u27s favor and require a finding of subjective intent because such a mens rea requirement is suggested in the plain meaning, legislative history, and by the Court\u27s true-threat jurisprudence

Duality in Shearing Rheology Near the Athermal Jamming Transition

We consider the rheology of soft-core frictionless disks in two dimensions in the neighborhood of the athermal jamming transition. From numerical simulations of bidisperse, overdamped, particles, we argue that the divergence of the viscosity below jamming is characteristic of the hard-core limit, independent of the particular soft-core interaction. We develop a mapping from soft-core to hard-core particles that recovers all the critical behavior found in earlier scaling analyses. Using this mapping we derive a duality relation that gives the exponent of the non-linear Herschel-Bulkley rheology above jamming in terms of the exponent of the diverging viscosity below jamming.Comment: 5 pages, 4 figures. Manuscript revisions: new title, additional text concerning connections to experiment, revised Fig. 4, other minor changes and clarifications in text. Conclusions remain essentially unchanged. Accepted for publication in Phys. Rev. Let

Wetting transitions in polydisperse fluids

The properties of the coexisting bulk gas and liquid phases of a polydisperse fluid depend not only on the prevailing temperature, but also on the overall parent density. As a result, a polydisperse fluid near a wall will exhibit density-driven wetting transitions inside the coexistence region. We propose a likely topology for the wetting phase diagram, which we test using Monte Carlo simulations of a model polydisperse fluid at an attractive wall, tracing the wetting line inside the cloud curve and identifying the relationship to prewetting.Comment: 4 Pages, 4 figures. Accepted for publication in Physical Review Letter

An Exploratory Look at Supermarket Shopping Paths

We present analyses of an extraordinary new dataset that reveals the path taken by individual shoppers in an actual grocery store, as provided by RFID (radio frequency identification) tags located on their shopping carts. The analysis is performed using a multivariate clustering algorithm not yet seen in the marketing literature that is able to handle data sets with unique (and numerous) spatial constraints. This allows us to take into account physical impediments (such as the location of aisles and other inaccessible areas of the store) to ensure that we only deal with feasible paths. We also recognize that time spent in the store plays an important role, leading to different cluster configurations for short, medium, and long trips. The resulting three sets of clusters identify a total of 14 canonical path types that are typical of grocery store travel, and we carefully describe (and cross-validate) each set of clusters These results dispel certain myths about shopper travel behavior that common intuition perpetuates, including behavior related to aisles, end-cap displays, and the racetrack. We briefly relate these results to previous research (using much more limited datasets) covering travel behavior in retails stores and other related settings

Trends in Availability and Prices of Subsidized ACT over the First Year of the AMFm: Evidence from Remote Regions of Tanzania

Background: The Affordable Medicines Facility for malaria (AMFm) is a pilot supra-national subsidy program that aims to increase access and affordability of artemisinin combination therapy (ACT) in public sector clinics and private retail shops. It is unclear to what extent the AMFm model will translate into wide scale availability and price reductions in ACT, particularly for rural, remote areas where disparities in access to medicines often exist. This study is the first to rigorously examine the availability and price of subsidized ACT during the first year of the AMFm, measured through retail audits in remote regions of Tanzania. Methods: Periodic retail audits of Accredited Drug Dispensing Outlets (ADDOs) were conducted in two remote regions of Tanzania (Mtwara and Rukwa). Temporal and spatial variation in ACT availability and pricing were explored. A composite measure of ADDO remoteness, using variables, such as distance to suppliers and towns, altitude and population density, was used to explore whether ACT availability and price vary systematically with remoteness. Results: Between February 2011 and January 2012, the fraction of ADDOs stocking AMFm-ACT increased from 25% to 88% in Mtwara and from 3% to 62% in Rukwa. Availability was widespread, though diffusion throughout the region was achieved more quickly in Mtwara. No significant relationship was found between ACT availability and remoteness. Adult doses of AMFm-ACT were much more widely available than any other age/weight band. Average prices fell from 1529 TZS (1.03 USD) to 1272 TZS (0.81 USD) over the study period, with prices in Rukwa higher than Mtwara. The government recommended retail price for AMFm- ACT is 1,000 TZS ($0.64 USD). The median retail ACT price in the final round of data collection was 1,000 TZS. Conclusions: The AMFm led to large increases in availability of low priced ACT in Tanzania, with no significant variation in availability based on remoteness. Availability did remain lower and prices remained higher in Rukwa, which is a more remote region overall. Low availability of child and adolescent ACT doses could be due in part to lower quantities of non-adult packs imported into Tanzania. Future research will explore whether increased availability and affordability persists and whether it translates into higher ACT use in Tanzania

Formation of early-type galaxies from cosmological initial conditions

We describe high resolution Smoothed Particle Hydrodynamics (SPH) simulations of three approximately $M_*$ field galaxies starting from \LCDM initial conditions. The simulations are made intentionally simple, and include photoionization, cooling of the intergalactic medium, and star formation but not feedback from AGN or supernovae. All of the galaxies undergo an initial burst of star formation at $z \approx 5$, accompanied by the formation of a bubble of heated gas. Two out of three galaxies show early-type properties at present whereas only one of them experienced a major merger. Heating from shocks and -PdV work dominates over cooling so that for most of the gas the temperature is an increasing function of time. By $z \approx 1$ a significant fraction of the final stellar mass is in place and the spectral energy distribution resembles those of observed massive red galaxies. The galaxies have grown from $z=1 \to 0$ on average by 25% in mass and in size by gas poor (dry) stellar mergers. By the present day, the simulated galaxies are old ($\approx 10 {\rm Gyrs}$), kinematically hot stellar systems surrounded by hot gaseous haloes. Stars dominate the mass of the galaxies up to $\approx 4$ effective radii ($\approx 10$ kpc). Kinematic and most photometric properties are in good agreement with those of observed elliptical galaxies. The galaxy with a major merger develops a counter-rotating core. Our simulations show that realistic intermediate mass giant elliptical galaxies with plausible formation histories can be formed from \LCDM initial conditions even without requiring recent major mergers or feedback from supernovae or AGN.Comment: accepted for publication in Ap

Promoting Bicycle Commuter Safety, Research Report 11-08

We present an overview of the risks associated with cycling to emphasize the need for safety. We focus on the application of frameworks from social psychology to education, one of the 5 Es—engineering, education, enforcement, encouragement, and evaluation. We use the structure of the 5 Es to organize information with particular attention to engineering and education in the literature review. Engineering is essential because the infrastructure is vital to protecting cyclists. Education is emphasized since the central focus of the report is safety

The Evolution of Early-Type Galaxies in Distant Clusters

We present results from an optical-IR photometric study of early-type galaxies in 19 galaxy clusters out to z=0.9. The galaxy sample is selected on the basis of morphologies determined from HST WFPC2 images, and is photometrically defined in the K-band to minimize redshift-dependent selection biases. The optical-IR colors of the early-type cluster galaxies become bluer with increasing redshift in a manner consistent with the passive evolution of an old stellar population formed at an early cosmic epoch. The degree of color evolution is similar for clusters at similar redshift, and does not depend strongly on the optical richness or X-ray luminosity of the cluster, suggesting that the history of early-type galaxies is relatively insensitive to environment. The slope of the color-magnitude relationship shows no significant change out to z=0.9, providing evidence that it arises from a correlation between galaxy mass and metallicity, not age. Finally, the intrinsic scatter in the optical-IR colors is small and nearly constant with redshift, indicating that the majority of giant, early-type galaxies in clusters share a common star formation history, with little perturbation due to uncorrelated episodes of later star formation. Taken together, our results are consistent with models in which most early-type galaxies in rich clusters are old, formed the majority of their stars at high redshift in a well-synchronized fashion, and evolved quiescently thereafter.Comment: 55 pages, 24 figures, uses AASTeX. Accepted for publication in The Astrophysical Journa

Insecticide-treated net use before and after mass distribution in a fishing community along Lake Victoria, Kenya: successes and unavoidable pitfalls

Abstract Background Insecticide-treated nets (ITNs) have proven instrumental in the successful reduction of malaria incidence in holoendemic regions during the past decade. As distribution of ITNs throughout sub-Saharan Africa (SSA) is being scaled up, maintaining maximal levels of coverage will be necessary to sustain current gains. The effectiveness of mass distribution of ITNs, requires careful analysis of successes and failures if impacts are to be sustained over the long term. Methods Mass distribution of ITNs to a rural Kenyan community along Lake Victoria was performed in early 2011. Surveyors collected data on ITN use both before and one year following this distribution. At both times, household representatives were asked to provide a complete accounting of ITNs within the dwelling, the location of each net, and the ages and genders of each person who slept under that net the previous night. Other data on household material possessions, education levels and occupations were recorded. Information on malaria preventative factors such as ceiling nets and indoor residual spraying was noted. Basic information on malaria knowledge and health-seeking behaviours was also collected. Patterns of ITN use before and one year following net distribution were compared using spatial and multi-variable statistical methods. Associations of ITN use with various individual, household, demographic and malaria related factors were tested using logistic regression. Results After infancy (<1 year), ITN use sharply declined until the late teenage years then began to rise again, plateauing at 30 years of age. Males were less likely to use ITNs than females. Prior to distribution, socio-economic factors such as parental education and occupation were associated with ITN use. Following distribution, ITN use was similar across social groups. Household factors such as availability of nets and sleeping arrangements still reduced consistent net use, however. Conclusions Comprehensive, direct-to-household, mass distribution of ITNs was effective in rapidly scaling up coverage, with use being maintained at a high level at least one year following the intervention. Free distribution of ITNs through direct-to-household distribution method can eliminate important constraints in determining consistent ITN use, thus enhancing the sustainability of effective intervention campaigns.http://deepblue.lib.umich.edu/bitstream/2027.42/111296/1/12936_2014_Article_3656.pd