The Extension of the Bruton Rule at the Expense of Judicial Efficiency in Gray v. Maryland

An argument broke out between [Kevin] and Stacey in the 500 block of Louden Avenue. Stacey got smacked and then ran into Wildwood Parkway. Me, [Kevin], and a few other guys ran after Stacey .... We beat Stacey up

Abrogating the Exclusionary Rule Outside of the Criminal Trial Context? Pennsylvania Board of Probation & Parole v. Scott: One Step Closer to a Per Se Rule in Fourth Amendment Jurisprudence

As citizens of the United States, most of us would abhor warrantless police intrusion into our homes. The Fourth Amendment protects all citizens against unreasonable searches and seizures. When unaccompanied by a valid search warrant, a search of a residence is presumptively unreasonable. Thus, the law proscribes overly-aggressive investigatory methods that trammel the rights of American citizens. What happens, however, when the protected right belongs to a paroled felon suspected of violating the conditions of his parole? In Pennsylvania Board of Probation & Parole v. Scott, the United States Supreme Court refused to extend to parolees the remedies which are offered to other citizens when illegal police conduct infringes upon their Fourth Amendment guarantees

Do foraging methods in winter affect morphology during growth in juvenile snow geese?

Physical exertion during growth can affect ultimate size and density of skeletal structures. Such changes from different exercise regimes may explain morphological differences between groups, such as those exhibited by lesser snow geese (Chen caerulescens caerulescens; hereafter snow geese) foraging in southwest Louisiana. In rice-prairie habitats (hereafter rice-prairies), snow geese bite off or graze aboveground vegetation, whereas they dig or grub for subterranean plant parts in adjacent coastal marshes. Grubbing involves considerably more muscular exertion than does grazing. Thus, we hypothesized that rates of bone formation and growth would be lower for juveniles wintering in rice-prairies than those in coastal marshes, resulting in smaller bill and skull features at adulthood. First, we tested this exertion hypothesis by measuring bills, skulls, and associated musculature from arrival to departure (November-February) in both habitats in southwest Louisiana, using both banded birds and collected specimens. Second, we used the morphological data to test an alternative hypothesis, which states that smaller bill dimensions in rice-prairies evolved because of hybridization with Ross's geese (C.rossii). Under the exertion hypothesis, we predicted that bill and skull bones of juveniles would grow at different rates between habitats. However, we found that bill and skull bones of juveniles grew similarly between habitats, thus failing to support the exertion hypothesis. Morphometrics were more likely to differ by sex or change with sampling date than to differ by habitat. We predicted that significant, consistent skewness toward smaller birds could indicate hybridization with Ross's geese, but no skewness was observed in our morphological data, which fails to support the hybridization hypothesis. Further research is needed to clarify whether snow geese wintering in Louisiana represent a single polymorphic population that segregates into individually preferred habitats, which we believe at present to be more likely as an explanation than two ecologically and spatially distinct morphotypes.Canadian Wildlife Service, Louisiana Department of Wildlife and Fisheries (LDWF), Delta Waterfowl Foundation, Rockefeller Scholarship Program, USGS-Louisiana Cooperative Fish and Wildlife Research Unit, Graduate School; Agricultural Center, School of Renewable Natural Resources at Louisiana State UniversityPeer Reviewe

Detection, prevalence, and transmission of avian hematozoa in waterfowl at the Arctic/sub-Arctic interface: co-infections, viral interactions, and sources of variation

Background The epidemiology of avian hematozoa at high latitudes is still not well understood, particularly in sub-Arctic and Arctic habitats, where information is limited regarding seasonality and range of transmission, co-infection dynamics with parasitic and viral agents, and possible fitness consequences of infection. Such information is important as climate warming may lead to northward expansion of hematozoa with unknown consequences to northern-breeding avian taxa, particularly populations that may be previously unexposed to blood parasites. Methods We used molecular methods to screen blood samples and cloacal/oropharyngeal swabs collected from 1347 ducks of five species during May-August 2010, in interior Alaska, for the presence of hematozoa, Influenza A Virus (IAV), and IAV antibodies. Using models to account for imperfect detection of parasites, we estimated seasonal variation in prevalence of three parasite genera (Haemoproteus, Plasmodium, Leucocytozoon) and investigated how co-infection with parasites and viruses were related to the probability of infection. Results We detected parasites from each hematozoan genus in adult and juvenile ducks of all species sampled. Seasonal patterns in detection and prevalence varied by parasite genus and species, age, and sex of duck hosts. The probabilities of infection for Haemoproteus and Leucocytozoon parasites were strongly positively correlated, but hematozoa infection was not correlated with IAV infection or serostatus. The probability of Haemoproteus infection was negatively related to body condition in juvenile ducks; relationships between Leucocytozoon infection and body condition varied among host species. Conclusions We present prevalence estimates for Haemoproteus, Leucocytozoon, and Plasmodium infections in waterfowl at the interface of the sub-Arctic and Arctic and provide evidence for local transmission of all three parasite genera. Variation in prevalence and molecular detection of hematozoa parasites in wild ducks is influenced by seasonal timing and a number of host traits. A positive correlation in co-infection of Leucocytozoon and Haemoproteus suggests that infection probability by parasites in one or both genera is enhanced by infection with the other, or that encounter rates of hosts and genus-specific vectors are correlated. Using size-adjusted mass as an index of host condition, we did not find evidence for strong deleterious consequences of hematozoa infection in wild ducks.Geological Survey (U.S.) (Wildlife Program of the Ecosystem Mission Area)U.S. Fish and Wildlife ServiceDelta Waterfowl FoundationInstitute for Wetland and Waterfowl ResearchIcahn School of Medicine at Mount Sinai (Center for Research on Influenza Pathogenesis)Center of Excellence for Influenza Research and Surveillance (contracts HHSN272201400008C and HHSN266200700010C

Wild Bird Migration across the Qinghai-Tibetan Plateau: A Transmission Route for Highly Pathogenic H5N1

BACKGROUND: Qinghai Lake in central China has been at the center of debate on whether wild birds play a role in circulation of highly pathogenic avian influenza virus H5N1. In 2005, an unprecedented epizootic at Qinghai Lake killed more than 6000 migratory birds including over 3000 bar-headed geese (Anser indicus). H5N1 subsequently spread to Europe and Africa, and in following years has re-emerged in wild birds along the Central Asia flyway several times. METHODOLOGY/PRINCIPAL FINDINGS: To better understand the potential involvement of wild birds in the spread of H5N1, we studied the movements of bar-headed geese marked with GPS satellite transmitters at Qinghai Lake in relation to virus outbreaks and disease risk factors. We discovered a previously undocumented migratory pathway between Qinghai Lake and the Lhasa Valley of Tibet where 93% of the 29 marked geese overwintered. From 2003-2009, sixteen outbreaks in poultry or wild birds were confirmed on the Qinghai-Tibet Plateau, and the majority were located within the migratory pathway of the geese. Spatial and temporal concordance between goose movements and three potential H5N1 virus sources (poultry farms, a captive bar-headed goose facility, and H5N1 outbreak locations) indicated ample opportunities existed for virus spillover and infection of migratory geese on the wintering grounds. Their potential as a vector of H5N1 was supported by rapid migration movements of some geese and genetic relatedness of H5N1 virus isolated from geese in Tibet and Qinghai Lake. CONCLUSIONS/SIGNIFICANCE: This is the first study to compare phylogenetics of the virus with spatial ecology of its host, and the combined results suggest that wild birds play a role in the spread of H5N1 in this region. However, the strength of the evidence would be improved with additional sequences from both poultry and wild birds on the Qinghai-Tibet Plateau where H5N1 has a clear stronghold

An intensive study of waterfowl populations on a small block of agricultural land, Minnedosa, Manitoba; the breeding, biology and production of some diving and dabbling ducks of the "pothole-agricultural" breeding habitat in south-central Manitoba

The thesis embodies the results of a two-year study, 1952 and 1953, of the breeding biology and production of some diving and dabbling ducks on the "pothole-agricultural” region of South-Central Manitoba. The study area was a section and a half block of pothole (small slough) country nine miles south of Minnedosa, Manitoba. Its knob and kettle topography was characteristic of the region and its land use, climate, and vegetative cover was typical of the southern aspen parklands. The objectives were to assess the waterfowl habitat, to determine species composition, productivity, reproductive efficiency, and to determine the environmental pressures as they applied to the waterfowl of this habitat. Breeding pairs of birds were trapped, then, color leg banded, painted, or neck banded in order to be followed. Broods were color marked by the injection of dyes into the eggs. Mallards were the most common species breeding here, making up 33.7$of total composition, blue-winged teal with 23.3Newly hatched broods were seen from May 23 to August 8 in 1952 and from June 2 to August 23 in 1953. 94.1 breeding pairs of birds in 1952 and 90.8 pairs in 1953 produced 49.4 and 60.2 broods respectively. Efficiency (brood/pair ratio) of dabblers varied from .28 for pintails to .85 for blue-wings. Mallard efficiency was .37 and .51 for the two years. Diver brood/pair ratio was higher than dabblers. The area of 1 square mile produced 331 young in 1952 and 355 in 1953. Average maximum brood size for all species and all age classes was 6.9. Reduction in brood size with increase in age was noted; Class I broods averaged 7.1, Class II - 6.8, Class III - 6.4. Nesting studies indicated that cattail was the chief nesting cover followed by upland grasses, whitetop, bulrush, annual weeds, and others. 52.6$ for divers. Desertion and Intolerance, agricultural activities, flooding, freezing weather and dye loss accounted for the rest. Brood hatching periods appeared to be later in 1953. Weather plays an important role in making available surface waters for breeding pairs and broods. Secondarily it influences nest hatching success. More dry potholes were recorded, at comparable times in 1952 than in 1953. Pothole water levels were all higher in 1953. Agricultural practices influence waterfowl production either immediately, through a destruction of nests and cover or through long term influences by encroachment on cover and conversion of waste uplands and potholes into crop lands. There is danger of future drainage in the region with subsequent loss of habitat. Predation was the chief cause of most of the nest destruction and undoubtedly had a marked effect on final production. The spatial requirements of breeding pairs is not clear. Blue-wing home ranges covered one-quarter of a section, mallards - one section, and canvasback -four sections. Aggressiveness varied in individual pairs from time of day and from day to day. Management suggestions for the region included the creation of more loafing spots, through chemical treatment of vegetation or through a building of small rafts. Management practices only apply if the pothole water areas are to be managed intensively. The concept of the community relationship of potholes will have to be taken into account before any future drainage is contemplated.Science, Faculty ofZoology, Department ofGraduat