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With textualism's ascendancy, courts increasingly invoke the canon to assume "ordinary meaning" unless the context indicates otherwise and the rule to enforce "plain meaning" regardless of extratextual considerations. Yet the relationship between ordinary meaning and plain meaning can become confused in practice. Courts use the terms interchangeably, and they conflate them doctrinally. Ordinary meaning and plain meaning are distinct. Ordinary meaning is what the text would convey to a reasonable English user in the context of everyday communication. Plain meaning refers to a judgment that whatever the text conveys in context is clear from the text. Thus, a term's ordinary meaning is also its plain meaning only when it is clear from how the term is used in the statute that its context is ordinary, as opposed to technical. Courts conflate the two, however, when they assume ordinary meaning under the ordinary meaning canon and then conclude that they are therefore bound to enforce that meaning under the plain meaning rule. As a result, they end interpretation prematurely, excluding extratextual aids that might well show that the ordinary meaning assumption should give way. This Article is the first to investigate the relationship between ordinary meaning and plain meaning. It clarifies their differences, identifies the ways in which they are conflated, and evaluates when they should converge. For textualists, greater clarity on this score illuminates when and how to bring ordinary meaning and plain meaning together in a principled manner. For methodological pluralists, understanding the gap between ordinary meaning and plain meaning opens opportunities to argue beyond the text in our increasingly textualist world. [ABSTRACT FROM AUTHOR]

Objective: Rare coexistence of disease or pathology Background: Barrett's esophagus (BE) is a metaplastic change in the normal esophageal squamous epithelium and is a wellrecognized precursor of esophageal adenocarcinoma (EAC). Nowadays, focal radiofrequency ablation is a valid technique for BE treatment by inducing a superficial and focal thermic destruction of metaplastic tissues. According to the literature, the most frequent patient-related adverse events of this procedure are esophageal iatrogenic stenosis, mucosal laceration or perforation of the esophagus, chest pain, and odynophagia/dysphagia. Postoperative heart rhythm abnormalities have been reported very rarely. Case Report: A 74-year-old patient with HE was treated by radiofrequency ablation (RFA) with the Barrx™ catheter system. He had 2 symptomatic episodes of atrial flutter in the immediate postoperative period requiring an external electrical cardioversion to induce a return to sinus cardiac rhythm. After atrial flutter ablation, 2 more radiofrequency procedures were performed, without adverse events. A laparoscopic Nissen fundoplication was carried out with complete endoscopic and histologic eradication of BE after 12-month follow-up. To the best of our knowledge, this is the first reported case of atrial flutter after esophageal RFA. Different mechanisms acting on an anatomic predisposing substrate can potentially play a role in starting atrial flutter, and include in- flammation, autonomic activation, and myocardial injury. Conclusions: The occurrence of this new type of adverse effect could potentially modify indications and postoperative monitoring of RFA treatment for BE. Endoscopists should know the possibility of this procedural complication in high-risk patients and they should propose alternative techniques or implement close cardiac monitoring in the postoperative period. [ABSTRACT FROM AUTHOR]

Background. The assessment of long-term mortality in acute decompensated heart failure (ADHF) is challenging. Respiratory failure and congestion play a fundamental role in risk stratification of ADHF patients. The aim of this study was to investigate the impact of arterial blood gases (ABG) and congestion on long-term mortality in patients with ADHF. Methods and results. We enrolled 252 patients with ADHF. Brain natriuretic peptide (BNP), blood urea nitrogen (BUN), phase angle as assessed by means of bioimpedance vector analysis, and ABG analysis were collected at admission. The endpoint was all-cause mortality. At a median follow-up of 447 d (interquartile range [IQR]: 248–667), 72 patients died 1–840 d (median 106, IQR: 29–233) after discharge. Respiratory failure types I and II were observed in 78 (19%) and 53 (20%) patients, respectively. The ROC analyses revealed that the cut-off points for predicting death were: BNP > 441 pg/mL, BUN > 1.67 mmol/L, partial pressure in oxygen (PaO2) ≤69.7 mmHg, and phase angle ≤4.9°. Taken together, these four variables proved to be good predictors for long-term mortality in ADHF (area under the curve [AUC] 0.78, 95% CI 0.72–0.78), thus explaining 60% of all deaths. A multiparametric score based on these variables was determined: each single-unit increase promoted a 2.2-fold augmentation of the risk for death (hazard ratio [HR] 2.2, 95% CI 1.8–2.8, p<.0001). Conclusions. A multiparametric approach based on measurements of BNP, BUN, PaO2, and phase angle is a reliable approach for long-term prediction of mortality risk in patients with ADHF. [ABSTRACT FROM AUTHOR]

The article explores Landscape configuration can influence the distribution of species across multiple spatial scales. The primary factors related to this process are connectivity, the size and position of habitat patches, and edge effects. These factors together determine the overall fragmentation of a landscape, which in turn influences species occurrence. Although some species show a negative response to fragmentation, others benefit from it.

Scientists have warned decision‐makers about the severe consequences of the global environmental crisis since the 1970s. Yet ecological degradation continues and little has been done to address climate change. We investigated early‐career conservation researchers' (ECR) perspectives on, and prioritization of, actions furthering sustainability. We conducted a survey (n = 67) and an interactive workshop (n = 35) for ECR attendees of the 5th European Congress of Conservation Biology (2018). Building on these data and discussions, we identified ongoing and forthcoming advances in conservation science. These include increased transdisciplinarity, science communication, advocacy in conservation, and adoption of a transformation‐oriented social–ecological systems approach to research. The respondents and participants had diverse perspectives on how to achieve sustainability. Reformist actions were emphasized as paving the way for more radical changes in the economic system and societal values linked to the environment and inequality. Our findings suggest that achieving sustainability requires a strategy that (1) incorporates the multiplicity of people's views, (2) places a greater value on nature, and (3) encourages systemic transformation across political, social, educational, and economic realms on multiple levels. We introduce a framework for ECRs to inspire their research and practice within conservation science to achieve real change in protecting biological diversity. [ABSTRACT FROM AUTHOR]

Water-filled tree holes (WHs), commonly referred to as dendrotelmata, develop when water accumulates in cavities related to tree architecture or in rotten parts of the tree. These structures can occur in forest ecosystems and may represent essential microhabitats in the life cycle of various animal species. WHs form temporary microhabitats during wet periods and sometimes sustain water throughout dry seasons. Research on the use of WHs by organisms mainly focuses on invertebrates developing in these while vertebrates are rarely mentioned. A literature search on the use of WHs by vertebrates revealed that attention has been given only to vertebrates in tropical and subtropical systems, mostly to groups with aquatic stages, such as amphibians. To fill the knowledge gap on the use of WHs by vertebrates in temperate forests, we conducted a camera study in three sites across Germany. We identified a total of 28 vertebrate species including 11 mammal, 17 bird and one amphibian species using the WHs. The recorded videos showed that vertebrates use the WHs mainly for nutrition and hydration. With an expected future increase in frequency and intensity of dry spells in central Europe, these microhabitats may sustain healthy forest ecosystems by providing resources for wildlife. Reliable, updated data about the importance of WHs for vertebrates is required to urge forest managers and stakeholders to enforce the preservation of these microhabitats. [ABSTRACT FROM AUTHOR]

What kind of tree should be preserved from logging for biodiversity conservation is a matter of debate. Large and old trees are potential candidates due to the structures they can bear, like cavities and other tree-related microhabitats (TreMs). One of the most studied TreM is woodpecker-made cavities, which, in addition to be breeding sites for primary cavity-nesters, are often the main breeding sites for secondary cavity-nesters, especially in managed forests. Therefore, understanding which trees woodpeckers select for cavities is relevant to forest management, especially in management regimes where individual trees are logged or spared, as in retention forestry. We used data from a forest inventory, TreM inventory and woodpecker counts in one-hectare plots in the Black Forest (southwest Germany) to investigate which features make a retention tree suitable for woodpeckers. By employing a resource selection probability function, we tested several variables for their influence on the probability of tree choice by woodpeckers including altitude, tree species, TreM richness and abundance, diameter at breast height (DBH) and deviation from the mean DBH per plot. The results show that the probability of selection by woodpeckers does not correlate with individual tree diameter. Instead, the probability is driven mainly by the deviation from the mean DBH per plot. We were able to identify a relative size for the selection of trees indicating that woodpeckers prefer trees that are about 15–20 cm larger than the mean DBH per plot. Thereby, we argue, that using absolute diameter thresholds to select retention might not be the best management solution in the short-term, as in managed forests woodpeckers might select sub-optimal trees. Apparently, more knowledge concerning relative thresholds, as detected in our study, is required to improve our understanding of the potential ecological value of retention trees. [ABSTRACT FROM AUTHOR]

Logging can affect breeding performance and offspring survival in birds, but such effect can change over time. We investigated this question, deploying nest boxes for blue tits (Cyanistes caeruleus) in four forest stands, differing in the time since the last harvesting event occurred: 2, 10, 20 and 45 years ago. We recorded laying date, clutch and brood size and number of fledglings in the four stands over two years (2014-2015). We modelled reproductive success as a function of laying date and number of offspring. In the first year, the first laying date was about ten days earlier in the older stands, while in the second year the laying date did not differ among stands. Clutch size differed between stands in the first year but in the second year. Brood size dropped in 2015, except in one of the oldest stands. Reproductive success changed markedly between years and stands and was determined mainly by laying date. Though our results should be considered preliminary, we acknowledge that such year-to-year variability is likely attributed to climatic and structural differences between years and stands, respectively. [ABSTRACT FROM AUTHOR]

Individuals with Chronic Obstructive Pulmonary Disease (COPD) experience sleep disturbances due to the impact of respiratory symptoms on sleep quality. We explored whether sleep disturbances in COPD are linked to heterogeneity of airway constriction. The impact of breathing problems on sleep quality was measured in consecutive COPD outpatients with the COPD and Asthma Sleep Impact Scale (CASIS) questionnaire. Impulse oscillometry technique (IOS) was employed to assess heterogeneity of airway constriction. Subjects with a previous or concomitant diagnosis of asthma or obstructive sleep apnea (OSA) were excluded. Fifty COPD subjects (M/F 40/10; age: 71 ± 8 yrs, Body Mass Index (BMI): 26.2 ± 4.7 kg/m2, Forced Expiratory Volume in the first second (FEV1): 65 ± 25% predicted; mean ± SD) were enrolled. The mean CASIS score was 36 ± 3.3, and the R5-R20 value was 0.2 ± 0.15 kPa s L−1. The CASIS score was significantly higher in subjects with increased R5-R20 (>0.07 kPa s L−1) (39 ± 24; p = 0.02) compared to normal R5-R20 (21 ± 17). When subjects were categorized on the basis of lung function in severely versus non severely obstructed (FEV1 ≤ or >50% predicted) or air trappers versus non air trappers (Residual Volume, RV ≥ or <120% predicted) the CASIS score remained unchanged (for FEV1: 37 ± 23 versus 33 ± 25, respectively, p = 0.61; for RV: 30 ± 20 versus 40 ± 23, p = 0.16). Sleep disturbances due to COPD symptoms are associated with heterogeneity of airway constriction, possibly reflecting peripheral airway dysfunction. [ABSTRACT FROM AUTHOR]

The article discusses the potential impact of citizen science on long-term ecological research. While citizen science can contribute to ecological research by providing data at an increasing rate, there are concerns that this influx of data could lead to a decline in support for long-term field-based research. The availability of citizen science-generated data sets may discourage researchers from engaging in long-term ecological research, as it is easier and less time-consuming to use citizen science data. However, it is important to note that citizen science data is most abundant in easily accessible areas, and long-term scientific engagement is necessary to ensure data collection in infrastructure-poor areas. The article raises questions about the role of field scientists in long-term ecological research and calls for increased funding and support for these scientific endeavors. [Extracted from the article]

Sex ratio is an essential demographic parameter and distortions from a balanced sex ratio may have contrasting effects on the population dynamics. However, observation of distorted sex ratio using counts or captures may reflect an actual ecological trait of the studied population but may also be an artefact due to different capture probabilities of males and females. We compared results obtained from Counts and Capture-Marking-Recapture (CMR) on both sexes in a population of a forest dwelling salamander, Salamandrina perspicillata, and we investigated if males and females had different capture probabilities. We surveyed available literature to compare information on sex ratio from other populations of S. perspicillata. The sex ratio from our counts was 0.65 and was significantly male-biased as reported in other studies. The estimated sex ratio from CMR data was 0.57. Although males showed higher recapture rates than females in every capture session, these differences were not statistically significant. Therefore, the skewed sex ratio towards males is not only an artefact due to different capture probabilities between males and females but reflects an actual demographic trait, although the magnitude of the skeweness was overestimated by counts. [ABSTRACT FROM AUTHOR]

Ecological traits affect species’ responses to human impacts. Amphibians are declining worldwide and one of the major causes of such decline is habitat loss. Forestry practices have a primary role in determining habitat loss and fragmentation for amphibians. Thus, researchers should provide forest practitioners with essential information in order to address proper forest management plans. Here, we studied ecological requirements in the terrestrial phase of salamanders and we tested the feasibility of repeated counts to infer habitat determinants of salamanders’ abundance in order to guide forest management plans. We employed the N-mixture models for the analysis of repeated count data of an Italian endemic salamander ( Salamandrina perspicillata ) on seventy-seven 100 m 2 plots, within a central-Italian forest. Modelling salamanders abundance as a function of site specific habitat features allowed us to give precise guidelines for forest management. Harvesting should be conducted preferably on south facing slopes, since salamanders’ occurrence and abundance are higher on northern slopes. Forest operations should be avoided or reduced within a buffer of some 150 m from reproductive sites. Since salamanders use tree bases as shelters, patches of forest with larger trees and higher canopy cover should be retained, ensuring the availability of moist shelters. The amount of the cost for the whole monitoring, from plot installation to data analyses was 4872 Euros (about 5558 USD). Given the ease of application and inexpensiveness of this sampling protocol, we encourage its employment in similar situations, in order to gather useful information, which are essential to couple forestry practices with species conservation strategies. [ABSTRACT FROM AUTHOR]

A reasonably-complete bird inventory is the crucial starting point for the analysis of the bird community. We evaluated the efficiency of point counts in detecting forest birds and verified how many sampling points or occasions are needed to adequately characterize the bird community. We sampled birds in 5 forest stands (conifer and beech forests) from northern to southern Italy in 2012. Sampling (through aural and visual clues) lasted 5 minutes, during which species were recorded. Data were analysed in relation to both the number of sampling points and the number of sampling occasions. Then, estimates of species richness were compared to random resampling of subsets of the original data. Results showed that after 3.8 sampling occasions (out of 19-24 sampling points) or 10.4 sampling points (given points are sampled 5 times), the species coverage of each community approached, or exceeded, the 90% threshold. Also, no difference in the mean values emerged with the subset estimates, but the latter appeared less precise. Our results suggest that the density of 1 sampling point per every 5 ha, each repeated at least 3 times, can represent an adequate optimization of the sampling effort. We provided useful methodological information for planning bird inventories in forest environments (applicable at least for Mediterranean and south-European mountain forests) when personnel and financial resources are limited, leading to a thoughtful fund management whilst providing a method to evaluate the reliability of species coverage for bird surveys. [ABSTRACT FROM AUTHOR]

Among vertebrates the concept of “habitat tree” in temperate forests, involving tree size and microhabitat occurrence, has been investigated mainly for birds and mammals. However, trees are also used by many amphibian species or sometimes by whole amphibian families that have evolved adaptations for living on trees. While there is a self-evident link between arboreal amphibians, which occur mainly in tropical forests, and trees, the relationship between trees and forest ground-dwelling amphibians is less widely studied and more difficult to understand. As a consequence, the effect of forestry practices on amphibian communities are commonly considered at the landscape scale, identifying habitat alteration and loss as major threats. We provide the first evidence that the combination of forestry practices and species conservation strategies may act at a smaller scale than those traditionally adopted: the single-tree scale. Our study focused on the Italian endemic spectacled salamander ( Salamandrina perspicillata ). In a hectare forest stand in central Italy we marked nearly 400 trees individually and for each we measured the DBH, the number of buttresses in the stump (BUT) and the number of cavities between soil and stump (HOL). Salamanders were sampled and individually marked at each tree in eleven sampling occasions, during 2013 and 2014. We discovered that the concept of “habitat tree” may also hold for salamanders, and that DBH and HOL are the best predictors of tree suitability for salamanders. Moreover, using the number of captures for the same individuals on the same tree, occurring in different years, we were able to distinguish between trees that act as permanent or temporary shelters for salamanders. Permanent shelters were not only used by the same individuals in different years, but also hosted a larger number of salamanders, and were characterized by a larger number of HOL. Our findings may be considered of importance for drawing up forest management plans and achieving conservation objectives. During forest harvest operations, for the purpose of salamander conservation we suggest retaining trees with a larger DBH (>30 cm) and a high number of HOL. Finally, since BUT is highly correlated with HOL but is less sensitive to variations during time, we suggest this parameter be used as a proxy of HOL. [ABSTRACT FROM AUTHOR]

Age represents an exclusion criterion in randomized clinical trials designed to test the efficacy and safety of inhaled drugs in asthma. As a consequence, data on efficacy and safety of inhaled corticosteroid (ICS) and long-acting β2 agonist (LABA) combinations in elderly asthmatics are scanty. Older age is associated with an increased proportion of comorbid conditions; in addition, all organ functions undergo a process of senescence, thus reducing their ability to metabolize the agents. Overall, these age-associated conditions may variably, and often unpredictably, affect the metabolism and excretion of respiratory drugs. However, pharmacological treatment of asthma does not follow specific recommendations in the elderly. In the elderly, the ICS/LABA combinations may carry an increased risk of local indesiderable effects, primarily due to the lack of coordination between activation of the device and inhalation, and systemic adverse events, mainly due to the greater amount of active drug that is available because of the age-associated changes in organ functions as well as drug-to-drug and drug-toconcomitant disease interactions. The extra-fine formulations of ICSs/LABAs, which allow for a more favorable drug deposition in the lungs at a reduced dose, may contribute to overcome this issue. This review revises the efficacy and safety of treatment with ICSs/LABAs, focusing on the main pharmacodynamic and pharmacokinetic properties of the drugs and highlighting the potential risks in the elderly asthmatic population. [ABSTRACT FROM AUTHOR]

The advantages of using birds as indicators of biodiversity and/or habitat quality in forest habitats rely principally (1) on their relative ease of detection and (2) on their strong association with many forest features. Here we investigate how forest structure can shape a bird community at the stand level (ca. 30 hectares), using an expeditious sampling protocol and a simple but reasoned guild approach. We focused on three beech ( Fagus sylvatica ) forests in Italy with different structures resulting from different management histories: Cansiglio, Chiarano-Sparvera and Marchesale. We hypothesise that the abundance of the selected guilds varies in relation to forest structure as a result of forest management; to test this hypothesis we modelled guild abundance along a latitudinal transect in a similar habitat ( i.e. beech forest) in order to offset the geographical and environmental sources of variability. Birds were surveyed through replicated aural/visual point counts. Thus we identified four guilds: generalist cavity nesters (TIT), generalist canopy nesters (WAR), insectivorous cavity nesters (INS) and granivorous canopy nesters (FIN). Forest structure and deadwood were estimated for each of the 27 sampling points. Guild abundance was estimated using the N-mixture models approach, which allows the mean abundance at each sampling location and the detectability to be estimated. Both the mean abundance and detectability were constrained to forest structure and time variables. Guild-estimated abundance was tested for differences among sites using ANOVA. Mean guild abundance proved different only for two guilds. INS was more abundant in Cansiglio than in Chiarano and Marchesale while between Chiarano and Marchesale there was no significant difference. Also WAR abundance was greater in Chiarano, followed by Marchesale and Cansiglio. Shelterwood management may result in a higher abundance of specialist guilds ( i.e. insectivorous cavity nesters), compared to other management options. Our results highlight this pattern in the Cansiglio forest, where the age and the applied treatments resulted in a lower tree density and in a larger mean diameter. Such features are often correlated with a larger amount of dead wood which, in turn, promotes the presence of cavity nesters, otherwise rare-to-absent in the bird community. Forest structure is largely influenced by forest management that can be guided to benefit specific bird assemblages by applying specific treatments focused at increasing structural diversity and at multi-functionality. [ABSTRACT FROM AUTHOR]

We aimed at exploring whether the prevalence of co-morbidities of chronic obstructive pulmonary disease (COPD) increases with COPD severity. Analysis of medical records of outpatients with established diagnosis of COPD was retrospectively performed. The lower limit of normality (LLN) for FEV1/FVC was applied to establish the occurrence of airway obstruction in the elderly population. The prevalence of co-morbidities was calculated, and the proportion of patients with each co-morbidity along with GOLD stages was analysed by chi-square for trend. A total of 326 (M/F: 256/70) consecutive outpatients with COPD (stage GOLD I to IV), aging 71.8 ± 9.2 years, were included in the analysis. The most frequent co-morbidities in the entire sample were systemic hypertension (64.7%), diabetes (28.5%), coronary artery disease (19.9%), arrhythmias (16.6%) and congestive heart failure (13.8%). Underweight patients were 8.0% of the sample while obese patients were 22.4%. None of the analyzed co-morbidities showed a trend towards increasing prevalence with COPD severity, except for nutritional problems. The current findings suggest that the occurrence and prevalence of co-morbidities is independent from the COPD severity, and encourage to assess co-morbidities even in the early stages of the COPD. [ABSTRACT FROM PUBLISHER]

Summary: Continuous positive airway pressure (CPAP) is the first‐choice treatment for obstructive sleep‐disordered breathing. Automatic bilevel ventilation can be used to treat obstructive sleep‐disordered breathing when CPAP is ineffective, but clinical experience is still limited. To assess the outcome of titration with CPAP and automatic bilevel ventilation, the charts of 356 outpatients (obstructive sleep apnea, n = 242; chronic obstructive pulmonary disease + obstructive sleep apnea overlap, n = 80; obesity hypoventilation syndrome [OHS], n = 34; 103 females) treated for obstructive sleep‐disordered breathing from January 2014 to April 2017 were reviewed. Positive airway pressure titration was considered successful in the case of sleep‐disordered breathing resolution (apnea–hypopnea index <10/hr) with cumulative time at SaO2 < 90% (CT90%) <10% and/or improved daytime arterial blood gases at the end of titration. CPAP was effective in 268 patients (75.0%). CPAP treatment failure (n = 88) occurred in 13.6% of obstructive sleep apnea, 32.5% of overlap, and 85.3% of OHS patients. Compared with successful CPAP cases, patients undergoing the automatic bilevel ventilation trial showed higher body mass index (39.3 ± 10.5 kg/m2 versus 34.8 ± 6.9 kg/m2, p < 0.0001), worse mean nocturnal SaO2 (89.2 ± 4.0% versus 91.3 ± 4.0%, p < 0.003) and CT90% (40.6 ± 28.6% versus 24.0 ± 23.3%), but similar age (62.8 ± 11.9 years versus 60.5 ± 12.0 years, p = 0.11), apnea–hypopnea index (39.4 ± 23.2/hr versus 41.0 ± 21.2/hr, p = 0.55) and oxygen desaturation index (37.8 ± 23.5/hr versus 39.2 ± 21.1/hr, p = 0.61) at diagnosis. Automatic bilevel ventilation was successful in 79.5% of CPAP treatment failures (n = 70). Automatic bilevel ventilation failure was independently associated with baseline body mass index >40 kg/m2 (odds ratio 6.16, confidence interval 1.50–25.17, p = 0.011) and CT90% >42% (odds ratio 5.87, confidence interval 1.39–24.83, p = 0.016). During follow‐up, automatic bilevel ventilation treatment failed in seven patients (10%), and compliance was similar in CPAP (4.5 ± 2.2 hr) and automatic bilevel ventilation (5.2 ± 2.3 hr, p = 0.09) groups. Automatic bilevel ventilation was useful to treat sleep‐disordered breathing, but failed in patients with severe OHS. [ABSTRACT FROM AUTHOR]