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US Supreme Court Doctrine in the State High Courts challenges theoretical and empirical accounts about how state high courts use US Supreme Court doctrine and precedent. Michael Fix and Benjamin Kassow argue that theories that do not account for the full range of ways in which state high courts can act are, by definition, incomplete. Examining three important precedents – Atkins v. Virginia, Lemon v. Kurtzman, and DC v. Heller/McDonald v. Chicago – Fix and Kassow find that state high courts commonly ignore Supreme Court precedent for reasons of political ideology, path dependence, and fact patterns in cases that may be of varying similarity to those found in relevant US Supreme Court doctrine. This work, which provides an important addition to the scholarly literature on the impact of Supreme Court decisions, should be read by anyone interested in law and politics or traditional approaches to the study of legal decision-making.
A field study was conducted in 2015 and 2016 at the H. Rouse Caffey Rice Research Station (RRS) near Crowley, Louisiana to evaluate the interactions of quizalofop and a mixture of propanil plus thiobencarb applied sequentially or mixed for weedy rice and barnyardgrass control. Visual weed control evaluations occurred at 14, 28, and 42 d after treatment (DAT). Quizalofop was applied at 120 g ai ha-1 at 7, 3, and 1 days before and after propanil plus thiobencarb were each applied at 3360 g ai ha-1. In addition, quizalofop was applied alone and in a mixture with propanil plus thiobencarb at d 0. Control of red rice, ‘CL-111’, and ‘CLXL-745’ was greater than 91% for quizalofop applied alone at d 0, similar to control for quizalofop applied 7, 3, and 1 d prior to propanil plus thiobencarb at all evaluation dates. Control for the same weeds treated with quizalofop plus propanil plus thiobencarb applied in a mixture at d 0 was 70% to 76% at each evaluation date, similar to quizalofop applied 1 or 3 d after propanil plus thiobencarb. A similar trend occurred for barnyardgrass control with 88% to 97% control for quizalofop applied alone and 48% to 53% control for the mixture at 14, 28, and 42 DAT. ‘PVL01’ rough rice yield was 4060 kg ha-1 when treated with quizalofop alone; however yield was reduced to 3180 kg ha-1 when treated with quizalofop mixed with propanil plus thiobencarb at d 0, similar to PVL01 rice treated with quizalofop 1 or 3 d following the propanil plus thiobencarb application.
The pyridine carboxylic acid (PCA) herbicide family can exhibit differential activity within and among plant species, despite molecular resemblances. Aminocyclopyrachlor (AMCP), a pyrimidine carboxylic acid, is a recently discovered compound with similar use patterns to those of the PCA family; however, relative activity among PCAs and AMCP is not well understood. Therefore, the objective of this study was to quantify relative activity among aminopyralid, picloram, clopyralid, triclopyr, and AMCP in canola, squash, and okra using dose-response whole-plant bioassays. Clopyralid was less active than all other herbicides in all species and did not fit dose-response models. Aminopyralid and picloram performed similarly in squash (ED50 = 21.1 and 23.3 g ae ha−1, respectively). Aminopyralid was 3.8 times and 1.7 times more active than picloram in canola (ED50 = 60.3 and 227.7 g ha−1, respectively) and okra (ED50 = 10.3 and 17.3 g ha−1, respectively). Triclopyr (ED50 = 37.3 g ha−1) was more active than AMCP (ED50 = 112.9 g ha−1) and picloram in canola. Aminocyclopyrachlor (ED50 = 6.6 g ha−1) and triclopyr (ED50 = 7.8 g ha−1) were more active in squash than aminopyralid and picloram. In okra, AMCP (ED50 = 14.6 g ha−1) and aminopyralid (ED50 = 10.3 g ha−1) performed similarly but were more active than triclopyr (ED50 = 88.2 g ha−1). Herbicidal activity among AMCP and PCAs was vastly different despite molecular similarities that could be due to variable target-site sensitivity among species.
A field study was conducted during the 2016 and 2017 crop seasons at the LSU AgCenter H. Rouse Caffey Rice Research Station to evaluate weed control and rice yield after quizalofop-p-ethyl applications in water-seeded coenzyme A carboxylase (ACCase)–resistant ‘PVLO1’ long-grain rice production utilizing different flood systems, application timings, and quizalofop rates. The initial application of quizalofop was applied at five timings beginning when ‘PVLO1’ rice was at the coleoptile stage (PEG) through the one- to two-tiller stage. A total quizalofop rate of 240 g ai ha–1 was split into two applications: 97 followed by 143 g ha–1 or 120 followed by 120 g ai ha–1 in both pinpoint and delayed flood water-seeded management systems. A second quizalofop application was applied 14 d after initial treatment (DAIT). At 14 DAIT, a reduction in control of barnyardgrass and red rice was observed by delaying the initial quizalofop application to the two- to four-tiller stage compared with rice treated at earlier growth stages. At 42 DAIT, control of barnyardgrass was 94% to 96%, and red rice was 98% following the second application of quizalofop, regardless of initial application timing. Rice treated with quizalofop at the PEG and two- and three-leaf stage resulted in a rice height of 104 cm at harvest compared with 96 to 100 cm when the initial application of quizalofop was delayed to later growth stages. Applying the initial application of quizalofop to rice at the PEG timing in the pinpoint or the delayed flood system resulted in a total gross value per hectare of $450 and $590, respectively. Within each flood system, delaying the initial application of quizalofop to the one- to two-tiller stage resulted in a gross per-hectare value reduction of $100 ha-1 in the pinpoint flood and $110 ha-1 in the delayed flood.
The unsteady flow due to a sphere, immersed in a quiescent fluid, and suddenly rotated, is a paradigm for the development of unsteady boundary layers and their collision. Such a collision arises when the boundary layers on the surface of the sphere are advected towards the equator, where they collide, serving to generate a radial jet. We present the first particle image velocimetry measurements of this collision process, the resulting starting vortex and development of the radial jet. Coupled with new computations, we demonstrate that the post-collision steady flow detaches smoothly from the sphere’s surface, in qualitative agreement with the analysis of Stewartson (Grenzschichtforschung/Boundary Layer Research (ed. H. Görtler), Springer, 1958, pp. 60–70), with no evidence of a recirculation zone, contrary to the conjectured structure of Smith & Duck (Q. J. Mech. Appl. Maths, vol. 20, 1977, pp. 143–156).
Stictococcus vayssierei is a major pest of root and tuber crops in central Africa. However, data on its ecology are lacking. Here we provide an updated estimate of its distribution with the aim of facilitating the sustainable control of its populations. Surveys conducted in nine countries encompassing 13 ecological regions around the Congo basin showed that African root and tuber scale was present in Cameroon, Central African Republic, Congo, Democratic Republic of Congo, Equatorial Guinea, Gabon and Uganda. It was not found on the sites surveyed in Chad and Nigeria. The pest occurred in the forest and the forest-savannah mosaic as well as in the savannah where it was never recorded before. However, prevalence was higher in the forest (43.1%) where cassava was the most infested crop, compared to the savannah (9.2%) where aroids (cocoyam and taro) were the most infested crops. In the forest habitat, the pest was prevalent in all but two ecological regions: the Congolian swamp forests and the Southern Congolian forest-savanna mosaic. In the savannah habitat, it was restricted to the moist savannah highlands and absent from dry savannahs. The scale was not observed below 277 m asl. Where present, the scale was frequently (87.1% of the sites) attended by the ant Anoplolepis tenella. High densities (>1000 scales per plant) were recorded along the Cameroon–Gabon border. Good regulatory measures within and between countries are required to control the exchange of plant materials and limit its spread. The study provides information for niche modeling and risk mapping.
Acetyl co-enzyme A carboxylase (ACCase)-resistant rice allows quizlaofop-p-ethyl to be applied as a POST control of troublesome grass weeds. A field study was conducted in 2017 and 2018 at the H. Rouse Caffey Rice Research Station near Crowley, LA, to evaluate the influence of a crop oil concentrate (COC), a silicon-based surfactant plus a nitrogen source (SNS), or a high-concentrate COC (HCOC) in overcoming the grass weed control antagonism of quizalofop-p-ethyl when mixed with bispyribac-Na. Quizalofop-p-ethyl was applied at 120 g ai ha−1, bispyribac-Na was applied at 34 g ai ha−1, and all adjuvants were applied at 1% vol/vol. Antagonistic interactions were observed at 14 d after treatment (DAT) when quizalofop-p-ethyl was mixed with bispyribac-Na with no adjuvant for control of barnyardgrass, the non–ACCase-tolerant rice cultivars ‘CL-111’ and ‘CLXL-745’, and red rice. At 14 DAT, antagonism of quizalofop-p-ethyl for control of barnyardgrass was observed when mixed with bispyribac-Na plus COC, SNS, or HCOC, with an observed control of 43%, 63%, and 86%, respectively, compared with an expected control of 95% for quizalofop-p-ethyl alone. However, the antagonism of quizalofop-p-ethyl when mixed with bispyribac-Na plus HCOC for barnyardgrass control at 14 DAT was overcome by 28 DAT, with an observed control of 91%, compared with an expected control of 97%. Synergistic or neutral interactions were observed at 14 and 28 DAT when COC, SNS, or HCOC was added to a mixture of quizalofop-p-ethyl plus bispyribac-Na for CL-111, CLXL-745, and red rice control. According to the results of this study, HCOC is the most effective adjuvant for quizalofop-p-ethyl and bispyribac-Na mixtures for control of weedy rice and barnyardgrass.
To describe an outbreak of bacteremia caused by vancomycin-sensitive Enterococcus faecalis (VSEfe).
An investigation by retrospective case control and molecular typing by whole-genome sequencing (WGS).
A tertiary-care neonatal unit in Melbourne, Australia.
Risk factors for 30 consecutive neonates with VSEfe bacteremia from June 2011 to December 2014 were analyzed using a case control study. Controls were neonates matched for gestational age, birth weight, and year of birth. Isolates were typed using WGS, and multilocus sequence typing (MLST) was determined.
Bacteremia for case patients occurred at a median time after delivery of 23.5 days (interquartile range, 14.9–35.8). Previous described risk factors for nosocomial bacteremia did not contribute to excess risk for VSEfe. WGS typing results designated 43% ST179 as well as 14 other sequence types, indicating a polyclonal outbreak. A multimodal intervention that included education, insertion checklists, guidelines on maintenance and access of central lines, adjustments to the late onset sepsis antibiotic treatment, and the introduction of diaper bags for disposal of soiled diapers after being handled inside the bed, led to termination of the outbreak.
Typing using WGS identified this outbreak as predominately nonclonal and therefore not due to cross transmission. A multimodal approach was then sought to reduce the incidence of VSEfe bacteremia.
A study was conducted in 2017 and 2018 at the H. Rouse Caffey Rice Research Station near Crowley, LA, to evaluate quizalofop at 120 g ai ha−1 applied independently or in a mixture with clomazone, pendimethalin, clomazone plus pendimethalin, or a prepackaged mixture of clomazone plus pendimethalin when PVLO1 rice reached the two- to three-leaf stage. A second application of quizalofop at 120 g ha−1 was applied 21 d after the initial application. At 7 days after treatment (DAT), antagonism of quizalofop occurred when mixed with clomazone at 334 g ai ha−1, clomazone at 334 g ai ha−1 plus pendimethalin at 810 g ai ha−1, or a prepackaged mixture of clomazone plus pendimethalin at 334 plus 810 g ai ha−1, respectively, when applied to barnyardgrass. At 7 DAT, a neutral interaction occurred with a mixture of quizalofop plus pendimethalin at 810 g ha−1. These data indicate the antagonism of quizalofop was overcome at 14, 28, and 42 DAT with a neutral interaction for barnyardgrass control, 94% to 98%, with all herbicide mixtures evaluated. A neutral interaction occurred for CL-111, CLXL-745, and red rice control when treated with all the herbicide mixtures evaluated across all evaluation dates. Rice yield decreased when not treated with the initial quizalofop application.
Field experiments were conducted in 2012 and 2013 across four locations for a total of 6 site-years in the midsouthern United States to determine the effect of growth stage at exposure on soybean sensitivity to sublethal rates of dicamba (8.8 g ae ha−1) and 2,4-D (140 g ae ha−1). Regression analysis revealed that soybean was most susceptible to injury from 2,4-D when exposed between 413 and 1,391 accumulated growing degree days (GDD) from planting, approximately between V1 and R2 growth stages. In terms of terminal plant height, soybean was most susceptible to 2,4-D between 448 and 1,719 GDD, or from V1 to R4. However, maximum susceptibility to 2,4-D was only between 624 and 1,001 GDD or from V3 to V5 for yield loss. As expected, soybean was sensitive to dicamba for longer spans of time, ranging from 0 to 1,162 GDD for visible injury or from emergence to R2. Likewise, soybean height was most affected when dicamba exposure occurred between 847 and 1,276 GDD or from V4 to R2. Regarding grain yield, soybean was most susceptible to dicamba between 820 and 1,339 GDD or from V4 to R2. Consequently, these data indicate that soybean response to 2,4-D and dicamba can be variable within vegetative or reproductive growth stages; therefore, specific growth stage at the time of exposure should be considered when evaluating injury from off-target movement. In addition, application of dicamba near susceptible soybean within the V4 to R2 growth stages should be avoided because this is the time of maximum susceptibility. Research regarding soybean sensitivity to 2,4-D and dicamba should focus on multiple exposure times and also avoid generalizing growth stages to vegetative or reproductive.
Research was conducted from 2013 to 2015 across three sites in Mississippi to evaluate corn response to sublethal paraquat or fomesafen (105 and 35 g ai ha−1, respectively) applied PRE, or to corn at the V1, V3, V5, V7, or V9 growth stages. Fomesafen injury to corn at three d after treatment (DAT) ranged from 0% to 38%, and declined over time. Compared with the nontreated control (NTC), corn height 14 DAT was reduced approximately 15% due to fomesafen exposure at V5 or V7. Exposure at V1 or V7 resulted in 1,220 and 1,110 kg ha−1 yield losses, respectively, compared with the NTC, but yield losses were not observed at any other growth stage. Fomesafen exposure at any growth stage did not affect corn ear length or number of kernel rows relative to the NTC. Paraquat injury to corn ranged from 26% to 65%, depending on growth stage and evaluation interval. Corn exposure to paraquat at V3 or V5 consistently caused greater injury across evaluation intervals, compared with other growth stages. POST timings of paraquat exposure resulted in corn height reductions of 13% to 50%, except at V7, which was most likely due to rapid internode elongation at that stage. Likewise, yield loss occurred after all exposure times of paraquat except PRE, compared with the NTC. Corn yield was reduced 1,740 to 5,120 kg ha−1 compared with the NTC, generally worsening as exposure time was delayed. Paraquat exposure did not reduce corn ear length, compared with the NTC, at any growth stage. However, paraquat exposure at V3 or V5 was associated with reduction of kernel rows by 1.1 and 1.7, respectively, relative to the NTC. Paraquat and fomesafen applications near corn should be avoided if conditions are conducive for off-target movement, because significant injury and yield loss can result.
A study was conducted at the Louisiana State University Agricultural Center’s H. Rouse Caffey Rice Research Station in 2017 and 2018 to evaluate a prepackaged mixture of clomazone plus pendimethalin applied delayed preemergence (DPRE) or POST within an herbicide residual overlay with saflufenacil, clomazone, or quinclorac. POST applications included penoxsulam or halosulfuron in combination with the second residual application. No differences were observed in barnyardgrass control (92% to 98%) at 14 days after treatment (DAT). At 42 DAT, barnyardgrass treated with clomazone plus pendimethalin in combination with either clomazone or quinclorac at either timing was controlled 95% to 96%. However, when saflufenacil was applied PRE, regardless of the POST herbicide or when saflufenacil was applied POST with halosulfuron, barnyardgrass control was reduced to 78% to 81%, compared with 95% to 96% with the control with all other residual combinations. Yellow nutsedge and rice flatsedge control increased when treated with halosulfuron compared with penoxsulam across all evaluation dates. At 28 and 42 DAT, texasweed treated with saflufenacil PRE, regardless of POST applications, was controlled 83% and 87%, respectively, and this was greater control than provided by clomazone or quinclorac applied PRE regardless of POST herbicide program.
Background: Chest tube insertion is a time and safety critical procedure with a significant complication rate (up to 30%). Industry routinely uses Lean and ergonomic methodology to improve systems. This process improvement study used best evidence review, small group consensus, process mapping and prototyping in order to design a lean and ergonomically mindful equipment solution. Aim Statement: By simplifying and reorganising chest tube equipment, we aim to provide users with adequate equipment, reduce equipment waste, and wasted effort locating equipment. Measures & Design: The study was conducted between March 2018 and November 2018. An initial list of process steps from the best available evidence was produced. This list was then augmented by multispecialty team consensus (3 Emergency Physicians, 1 Thoracic Surgeon, 1 medical student, 2 EM nurses). Necessary equipment was identified. Next, two prototyping phases were conducted using a task trainer and a realistic interprofessional team (1 EM Physician, 1 ER Nurse, 1 Medical student) to refine the equipment list and packaging. A final equipment storage system was produced and evaluated by an interprofessional team during cadaver training using a survey and Likert scales. Evaluation/Results: There were 47 equipment items in the pre-intervention ED chest tube tray. After prototyping 21 items were removed while nine critical items were added. The nine items missing from the original design were found in four different locations in the department. Six physicians and seven RNs participated in cadaver testing and completed an evaluation survey of the new layout. Participants preferred the new storage design (Likert median 5, IQR of 1) over the current storage design (median of 1, IQR of 1). Discussion/Impact: The results suggest that the lean equipment storage is preferred by ED staff compared to the current set-up, may reduce time finding missing equipment, and will reduce waste. Future simulation work will quantitatively understand compliance with safety critical steps, user stress, wasted user time and cost.
Introduction: Chest tube insertion, a critical procedure with a published complication rate (30%), is a required competency for emergency physicians. Microskills training has been shown to identify steps that require deliberate practice. Objectives were: 1. Develop a chest tube insertion microskills checklist to facilitate IPE, 2. Compare the microskills checklist with published best available evidence, 3. Develop an educational video based on the process map, 4. Evaluate the video in an interprofessional team prior to cadaver training as a proof of concept. Methods: The study was conducted between March 2018 and November 2018. An initial list of process steps from the best available evidence was produced. This list was then augmented by multispecialty team consensus (3 Emergency Physicians, 1 Thoracic Surgeon, 1 medical student, 2 EM nurses). Two prototyping phases were conducted using a task trainer and a realistic interprofessional team (1 EM Physician, 1 ER Nurse, 1 Medical student). A final microskills list was produced and compared to the procedural steps described in consensus publications. An educational video was produced and evaluated by an interprofessional team prior to cadaver training using a survey and Likert scales as a proof of concept. Participants were 7 EM RNs and 6 ATLS trained physicians. Participants were asked to fill out a nine-question survey, using a 5-point Likert Scale (1-strongly disagree to 5 strongly agree). Results: The final process map contained 54 interdisciplinary steps, compared to ATLS that describes 14 main steps and peer reviewed articles that describe 9 main steps. The microskills checklist described, in more detail, the steps that relate to team interaction and the operational environment. Physicians rated the training video were able to apply what they learned in the video with an average of 4.67 (median of 5, mode of 5, and an IQR of 0.75). Conclusion: The development of the process maps and microkills checklists provides interprofessional teams with more information about chest tube insertion than instructions described in commonly available courses and procedural steps derived by consensus.
The transient force exerted by a low-speed liquid droplet impinging onto a flat rigid surface is investigated experimentally. The measurements employ a high-sensitivity piezo-electric sensor, along with a high-speed camera, and cover four decades in droplet Reynolds number and greater than two decades in Weber number. Across these ranges, the peak of individual force profiles span from 3 mN to over 1300 mN. Once normalised, the force–time profiles support the existence of an inertially dominated self-similar regime. Within this regime, previous numerical and theoretical studies predict a
dependence of impact normal force during the initial pre-peak rise. While our measurements confirm this finding, they also indicate that, after the peak force the profiles exhibit an exponential decay. This long-time decay law suggests treatment of the momentum transport from the droplet using a lumped model. An observed linear dependence between the force and force decay rate supports this approach. The reason for the efficacy of treating this system via a lumped model apparently connects to the physics right at the surface that limit the rate of momentum transport from the droplet to the surface. This is explored by estimating the momentum transfer by solely using the deforming droplet shape, but under the condition of negligible momentum gradients within the droplet. The short- and long-time solutions are combined and the resulting model equation is shown to accurately cover the entire force–time profile.
Evidence is mixed on e-cigarette's effectiveness as a tobacco cessation aid. Research suggests that e-cigarette users face greater barriers to quitting tobacco.
To examine the association between e-cigarette use and tobacco cessation outcomes among quitline callers.
We examined 2,204 callers who enrolled and completed 7-month follow-up surveys between April 2014 and January 2017. We examined the association between any e-cigarette use and tobacco cessation. We also evaluated these relationships by e-cigarette use patterns between enrollment and 7-month follow-up: sustained, adopted, discontinued, and non-use. We used multivariable logistic regression to control for caller characteristics, tobacco history, and program utilization.
Overall, 18% of callers reported using e-cigarettes at enrollment, follow-up, or both. Compared to non-users, e-cigarette users were more likely to be younger, non-Hispanic, and report a mental health condition. The adjusted odds of tobacco cessation were not statistically different for callers who used e-cigarettes compared to those who did not (adjusted odds ratios = 1.02, 95% confidence interval 0.79–1.32). Results were similar when examining cessation by patterns of e-cigarette use.
E-cigarette use was not associated with tobacco cessation. This suggests that e-cigarette use may neither facilitate nor deter tobacco cessation among quitline callers. Future research should continue exploring how e-cigarette use affects quitting.
A glasshouse study was conducted on the Louisiana State University campus in Baton Rouge, LA, to evaluate the control of brook crowngrass, rice cutgrass, southern watergrass, and water paspalum. Florpyrauxifen-benzyl was applied at 30 g ai ha−1 to each grass species at the 3- to 4-leaf or 1- to 2-stolon stage of growth. Brook crowngrass treated with florpyrauxifen was controlled 71% at 21 d after treatment. Southern watergrass and water paspalum control did not exceed 56% and 36%, respectively, across all evaluations. Rice cutgrass treated with florpyrauxifen did not reach 15% control. Plants treated with florpyrauxifen, except rice cutgrass, displayed reduction in leaf number, stolon number, plant height, and plant fresh weight. These results indicate florpyrauxifen-benzyl can help manage a brook crowngrass infestation and suppress southern watergrass. However, florpyrauxifen-benzyl has little to no activity on water paspalum and rice cutgrass, and other management options should be employed if these weeds are present.