Affirmative Immunity: A Litigation-Based Approach to Curb Appellate Courts’ Raising Qualified Immunity Sua Sponte

Qualified immunity, to put it simply, provides public officials with immunity from civil lawsuits if they have violated an individual’s constitutional rights under their official authority and those rights were not “clearly established” at the time of the official’s actions. The doctrine has evolved into an elaborate framework that has plagued civil rights plaintiffs, as well as courts, for decades. Qualified immunity is an affirmative defense, and affirmative defenses are waived if not raised appropriately by the defendant. Moreover, issues that are not properly raised before the trial court, including affirmative defenses, are generally not considered for the first time on appeal. Nevertheless, courts have a long history of defying this general rule, and qualified immunity is no exception. This Note examines the historical development of and rationales for the qualified immunity doctrine, the purposes of affirmative defenses, and the reasons for the general rule that appellate courts do not consider issues for the first time on appeal. Additionally, this Note summarizes an inconsistent trend among appellate courts, some of which raise qualified immunity sua sponte, while others hold that qualified immunity is waived if not raised at the trial court appropriately. After recognizing that the original goal of qualified immunity was to prevent public officials from enduring the burdens of litigation and that appellate courts generally have discretion to consider issues for the first time on appeal, this Note proposes a two-part solution to balance these values. This Note’s proposed framework returns qualified immunity to its original purpose and resolves the current inconsistency among appellate courts, while allowing appellate courts to raise issues for the first time on appeal when they consider it appropriate. The framework also prevents appellate courts from raising qualified immunity sua sponte inappropriately, which can unduly burden civil rights plaintiffs and make it harder for them to recover damages if their constitutional rights have been violated

EMG-Controlled Prosthetic Hand with Fuzzy Logic Classification Algorithm

In recent years, researchers have conducted many studies on the design and control of prosthesis devices that take the place of a missing limb. Functional ability of prosthesis hands that mimic biological hand functions increases depending on the number of independent finger movements possible. From this perspective, in this study, six different finger movements were given to a prosthesis hand via bioelectrical signals, and the functionality of the prosthesis hand was increased. Bioelectrical signals were recorded by surface electromyography for four muscles with the help of surface electrodes. The recorded bioelectrical signals were subjected to a series of preprocessing and feature extraction processes. In order to create meaningful patterns of motion and an effective cognitive interaction network between the human and the prosthetic hand, fuzzy logic classification algorithms were developed. A five-fingered and 15-jointed prosthetic hand was designed via SolidWorks, and a prosthetic prototype was produced by a 3D printer. In addition, prosthetic hand simulator was designed in Matlab/SimMechanics. Pattern control of both the simulator and the prototype hand in real time was achieved. Position control of motors connected to each joint of the prosthetic hand was provided by a PID controller. Thus, an effective cognitive communication network established between the user, and the real-time pattern control of the prosthesis was provided by bioelectrical signals

The non-minimally coupled symmetric teleparallel gravity with electromagnetic field

We construct a symmetric teleparallel gravity model which is non-minimally coupled with electromagnetic field in four dimensions inspired by its Riemannian equivalent. We derive the field equations by taking the variation of this model, which is written here for the first time. Then, we find some classes of spherically symmetric static solutions by the coincident gauge of symmetric teleparallel spacetime.Comment: 16 page

The Spirituality of Saint Tarcisius in the Role of Acolytes at Saint Francis Xavier Parish in Yogyakarta

An acolyte, serving the priest during the Eucharist, plays a significant role in ensuring the smooth execution of the Eucharistic celebration, aiding the congregation in participating the Eucharist more devoutly. The Patron Saint of the acolytes is Saint Tarcisius, who dared to sacrifice himself to death to protect the Blessed Sacrament. Therefore, the acolyte needs to emulate Saint Tarcisius in carrying out his duties as an altar server. The acolytes at Saint Francis Xavier Parish, Kidul Loji, Yogyakarta lack a profound understanding of the patron of their ministry, leading to a deficiency in their representation during Eucharistic celebrations. This research aims to understand the extent to which the acolytes embody the spirituality of Saint Tarcisius, recognizing a gap in their knowledge about his life. Conducted descriptive qualitative research, this research focuses on active acolytes from Saint Francis Xavier Parish, totalling 20 individuals. Data collection involves observation, document study, and interviews. The findings revealed that a majority of the acolytes lacked a deep understanding of Saint Tarcisius's life story, resulting in a limited grasp of the spirituality he exemplified. In response to these findings, the researchers suggest that the parish should organize activities to familiarize acolytes with Saint Tarcisius and his spirituality. A proposed recollection activity aims to address these knowledge gaps, offering the acolytes a chance for spiritual enrichment and enthusiasm in carrying out their duties meaningfully. Keywords: spirituality; Saint Tarcisius; acolyt

‘Defeat, Victory, Repeat’: Russian Émigrés between the Spanish Civil War and Operation Barbarossa, 1936–1944

Tens of thousands of White Russians were forced to leave their country after 1920. Many of them were career officers and soldiers imbued with anti-communism, who were then hired by diverse armies. They acted as transnational soldiers of the counter-revolution during the interwar period. This article analyses the trajectory of some dozens of them, who volunteered for the Francoist army in 1936–8 during the Spanish Civil War. Afterwards, many of them joined the ranks of the Spanish ‘Blue Division’ as interpreters to take part in the invasion of their home country by the Germans. Their experience as occupiers was highly ambiguous and oscillated between disappointment and nostalgia once they perceived that the objective of the invasion was not to liberate Russia from communism, but to enslave the country and its inhabitants. However, once they returned to Spain, they cultivated a hero myth of their past experience and regarded themselves as winnersS

Married and cohabiting women's financial empowerment: a study on women's bank account ownership in Spain

Objective: The goal was to examine the conditions under which young adult women (aged 25-50) in heterosexual couples maintain their economic independence through a personal bank account. Background: Research has shown that in Spain, the pooling of economic resources is seen as an important aspect of being a couple and as a symbol of togetherness. However, in practice, joint management can be characterized by inequalities on several levels, such as access to money, control over money, and personal spending. Few studies have focused on household financial organization in Spain, and studies of women's financial autonomy are lacking. Method: We conducted a cross-sectional analysis of couples aged 25-50 in Spain (N = 1,281) using data from the 2020 National Survey on Family Life. Results: The findings reveal that women are significantly less likely to have a personal bank account if either partner does not endorse values of economic autonomy, the couple is married with children, or, if the male partner earns significantly more. Conclusion: The results suggest that there is still a long way to go for Spain to reach the levels of women's account ownership seen in countries such as those in Northern Europe. It is important to incorporate women's account ownership into the investigation of financial organization, given its substantial implications for women within couples and those navigating relationship dissolution.Implications: Government programs should promote women's account ownership. Also, policies targeting financial literacy can incorporate dimensions such as basic budgeting, saving, and debt management so that women can gain further financial skills

Comparison Analysis of Machine Learning Algorithms for Steel Plate Fault Detection

Metals are one of the most important building materials of modern times. Especially the production and metalworking process of flat metal sheets is very sensitive. Control of the manufacturing process affects not only the intermediate products but also the quality of final products. Early detection of defects on steel plate surfaces is an important task in industrial production. Process control and mistake detection have traditionally been done manually by experts. However, this method is not proper in terms of both time and cost. With the industrial revolution IR 4.0, machine learning (ML) techniques have been developed to solve fault detection problems in products. This study focuses on developing basic machine learning methods for the detection of six different error classes that may occur during production on steel surfaces. Five standard ML models: LD, KNN, DT, SVM, RF, and deep learning (DNN) model: one-dimensional DNN was developed for the classification problem. The UCI steel plate deformation data set was used as the experimental data set. Five performance criteria: Accuracy, Sensitivity, Specificity, Precision, and F1 value were used to determine the success of the methods. The success rates of LD, KNN, DT, SVM, RF and DNN classification methods were 90.136%, 91.7880%, 93.013%, 93.287%, 95.479%, 96.986%, respectively. The results show the significant impact of the machine learning approach on the steel plate fault diagnosis problem