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An Analysis of United States v. Morta: Refining the Application of the Other-Indicia Approach to Criminal-Alias Mail
Get PDFAmericans who use their legal names to send and receive mail through traditional postal services have long maintained a reasonable expectation of privacy in that mail under the Fourth Amendment. Courts have also recognized that even those who use aliases with traditional postal services have a reasonable expectation of privacy in their mail. But circuit courts have split over whether Americans who use aliases in mail purely for criminal purposes—such as sending or receiving drugs—should have that same expectation of privacy. More specifically, courts disagree over the correct approach to analyze a defendant’s criminal-alias mail for purposes of Fourth Amendment standing, which is a prerequisite for determining if the government has violated a defendant’s reasonable expectation of privacy. Should courts analyze other indicia relevant to the defendant’s criminal-alias mail to affirm or deny Fourth Amendment standing? Or should courts legalistically affirm or deny Fourth Amendment standing for Americans who use criminal-alias mail? This Note analyzes a recent case, United States v. Morta, in which the Ninth Circuit joined several sister courts and adopted the “other indicia” approach. This Note argues that the Ninth Circuit was right to do so, because the other-indicia approach provides a more thorough analysis of Fourth Amendment standing than the “legalistic” approach. Moreover, the Note argues that Morta refined the application of the other-indicia approach by explicitly articulating the need for courts to consider indicia of “connection” in their other-indicia analysis. Ultimately, by adopting and refining the other-indicia approach, Morta makes it easier to prove Fourth Amendment standing for Americans who use aliases in mail for lawful purposes, while appropriately making it harder to prove Fourth Amendment standing for those who use aliases in mail for purely criminal purposes
X-Currents and Extreme Brightening Events
No full textThe solar-terrestrial interaction is a dynamic process which manifests itself in the ionosphere. Interplanetary (IP) shocks or solar wind dynamic pressure pulses can generate enhanced brightening in dayside aurora. Foreshock transients are capable of inducing pressure changes, larger in magnitude than solar wind pressure pulses, which also contribute to intensifying dayside aurora. These pressure variations can accelerate particles into the ionosphere, generating field- aligned currents that produce magnetic impulse events and enhanced dayside auroral activity with periods of increased brightening. This study presents several dayside auroral brightening events which are not associated with IP shocks or solar wind dynamic pressure pulses. The dayside auroral brightening events are associated with a green (557.7 nm) to red (630.0 nm) ratio which is greater than 10. These Extreme Brightening Events (EBEs) begin on the eastern or western end of a pre-existing dayside auroral arc. Periodic pulses of enhanced brightening’s are correlated with large sharp increases in the X-component from ground magnetometers in the IMAGE network. EBE’s occur predominately before magnetic noon and with X- component signatures from high latitude stations. Ground-based data is obtained from the Kjell Henriksen Observatory in Longyearbyen and the IMAGE magnetometer network
Utilizing High Resolution Micro-Computed Tomography to Determine the Mechanism of Desiccation for Barnacles
No full textEcosystem disruption due to climate change is one of the paramount environmental concerns of our time, with marine ecosystems experiencing the disproportionate brunt of the impact due to rising temperatures and sea levels. Barnacles, intertidal filter feeders, emerge as vulnerable populations to the dangers of desiccation based on their positioning at higher altitudes on shore. Given the imperative role that marine life plays in providing sustenance and ecological stability, the significance of understanding the dynamics of desiccation of barnacles cannot be overstated. Barnacles experience stress through their exposure to air and harsh wave action. We seek to better understand the potential effects that desiccation has on barnacles and the mechanism or behaviors they exhibit under a heightened stress environment. We will collect a variety of barnacle species, namely under the genus Balanus, most commonly found in the Malibu, California coastline. We will anesthetize the barnacles to capture high resolution images from the micro-computer tomography or uCT. These uCT images will be taken at different stages of the desiccation process for each barnacle and later compared between species. These results will provide further insight on the future of our marine ecosystems as climate change continues to alter environments and increase stress for rocky intertidal organisms. Our research will contribute valuable information and insight on the further effects of climate change on coastal benthic sessile communities
Leadership in social service non-profit organizations: an interpreative phenomenlogical analysis of executive leadership high attrition levels and proposals for change
Get PDFThe purpose of this study is to address how leaders who are employed at non-profit organizations can utilize change management frameworks, leadership style, strategic planning and organizational best practices to reduce attrition levels at their organizations. The focus of this study is three-fold: a) to understand why high attrition takes place at non-profits; identify what change model/s, types of leadership styles and best practices can be effective in reducing leader attrition, b) explore the development of a leadership framework by understanding how to manage change at nonprofits through the Carnall (1986), Shields (1999) and Cummings and Worley (2009) change management models which focus on how management transition, sharpening management skills and successfully managing organizational culture and politics can assist nonprofit leaders and boards to implement change required to select and retain leaders, and 3) identify frameworks and policy and organizational culture adjustments and changes nonprofit leaders can utilize to create an environment in which leaders can be successful and be encouraged to remain at the organization. The study results will reveal how servant leadership and strategic leadership is relevant or beneficial as a leadership style, the role moral motivation plays with guiding nonprofit leader’s decisions and leader traits most relevant useful for leaders with longevity at social services nonprofits which lead to organizational and non-profit board best practices
TERRORISM IN AFRICA: AN ANALYSIS OF THE EFFICACY OF U.S. COUNTERTERRORISM
Get PDFThis paper seeks to identify whether United States aid to Africa has impacted violent terrorist activity on the continent. The existing literature has produced a range of critiques. Many have voiced concern about foreign terrorist organizations (FTO) growing and blame ineffective efforts by the U.S. for this reality. Instances of African nations, in the face of persisting security challenges from FTOs, turning to political adversaries of the U.S. for assistance is evidence of this sentiment. Furthermore, terror attacks since the onset of the U.S. Global War on Terror (GWOT) have only remained higher than in the previous era. Others have noted the limited scope of U.S. operations on the continent and their inherently finite ability to produce a lasting change for the host nation’s security environment. This paper aims to add, not counter, the existing literature. By adjusting the lens through which U.S. military activity on the continent has been understood, it is possible to see how terrorism has reacted. A qualitative analysis of terrorism databases and publicly available data on U.S. troop presence was conducted. FTOs were found to have adjusted their attack strategies from high-volume attacks with low casualty rates to low-volume attacks with higher subsequent casualties. It was concluded that this shift in tactics results from pressure from US-led counterterrorism. FTOs have effectively been forced to place increased strategic value on each attack and seek to maximize the casualties inflicted. The implications of these findings offer a renewed view of US operations on the continent and suggest an impact has been made, even if not as palpable as traditional strategic victories
China-Venezuela Relations in the 21st Century and a Proposed U.S. Policy Response
Get PDFIn light of the Biden Administration’s 2023 decision to lift sanctions on Venezuela, and Venezuela’s failure to comply with the US conditions for relief, this paper analyzes China-Venezuela relations and how US policy toward Venezuela affects both Venezuela and China. Venezuela has been China’s strongest ally in the Americas since 2000. This alliance led to Chinese loans of over $40 billion, a majority of China’s investment in the continent. When Venezuela’s economy collapsed, China was left with the decision to cut ties, but chose to defend its Latin partner as the west criticized the Maduro regime. Recently, Venezuela has failed to meet US conditions for sanctions relief, prompting debate over the appropriate US response. At the same time, Venezuela has threatened military conflict with its neighbor Guyana. Based on a policy analysis that considers effects on both Venezuela and China, this paper recommends the following policy actions: a partial reimplementation of sanctions until Venezuela complies with all conditions, additional conditions for sanctions relief that provides oversight of both the Venezuelan Election Commission and the Venezuelan media, continued humanitarian aid, and movement of military forces to the region to deter a military conflict
Exploring the impact of the Covid-19 pandemic on adolescent mental health: an integrative systematic review
Get PDFAn integrative systematic review was conducted to understand the potential impact of the COVID-19 pandemic on adolescent mental health and to identify what contributing risk and protective factors increased or decreased the likelihood that these mental health outcomes were experienced among adolescents, including those from diverse and vulnerable communities. Furthermore, this review examined interventions and coping strategies identified within the literature that were beneficial in mitigating these harmful pandemic-related effects. Methods. Data was collected from five electronic databases and included peer-reviewed, English-language articles published between 2020-present in the United States, comprised of adolescent participants aged 11-19. All studies were required to address the impact of the COVID-19 pandemic on adolescent mental health, describe contributing risk and protective factors associated with this impact, and/or provide information regarding interventions and coping skills used to support adolescents during the pandemic. Results. Findings from 49 included studies revealed increased rates of mental health symptoms (65.30%; n = 32) including the following: general mental health, depression, anxiety, negative affect, PTSD/trauma, stress, diminished physical & sexual health/activity, sleep disturbances, externalizing symptoms, substance use, body-image/disordered eating, psychiatric crisis/hospitalization, suicidal ideation/self-harm, interpersonal challenges, and isolation/loneliness. Additionally, 57.14% of articles (n = 28) addressed differential levels of systemic support (e.g., academic/school, caregiver, community, sociocultural impact/political exposure, and peer support), as well as, associated risk and protective factors among impacted adolescents. Lastly, a total of 22 records (44.89%) identified both interventions and coping strategies (e.g., adaptive and maladaptive) used by adolescents to manage their pandemic-related experiences. Conclusions. COVID-19 related adolescent mental health impact was widely recognized among the articles included in this review, indicating elevated symptom rates across multiple diagnostic categories and mental health conditions. Furthermore, levels of systemic support appear to play key roles in increasing or decreasing the likelihood of adolescent mental health impact and should be examined further when considering how to mitigate similar future experiences, especially among vulnerable adolescent communities. Lastly, while certain interventions and coping strategies identified in this review did support adolescents in managing pandemic-related stressors, more research is needed to ascertain the effectiveness of these telehealth adapted strategies and interventions. The strengths of this study include its synthesis of the current literature on the COVID-19 pandemic and specific impact on adolescent mental health, as well as its recommendations to families/caregivers, school administrators/faculty, and governmental officials/policy-makers/stakeholders who have direct exposure to and influence on impacted adolescent communities