Littérature scientifique sur le sujet « Judicial error – United States – Case studies »

AbstractThis essay explores judicial responses to legal restrictions on worship during the COVID-19 pandemic and draws two lessons, one comparative and one relating specifically to U.S. law. As a comparative matter, courts across the globe have approached the problem in essentially the same way, through intuition and balancing. This has been the case regardless of what formal test applies, the proportionality test outside the United States, which expressly calls for judges to weigh the relative costs and benefits of a restriction, or the Employment Division v. Smith test inside the United States, which rejects judicial line-drawing and balancing in favor of predictable results. Judges have reached different conclusions about the legality of restrictions, of course, but doctrinal nuances have made little apparent difference. With respect to the United States specifically, the pandemic has revealed deep divisions about religion and religious freedom, among other things—divisions that have inevitably influenced judicial attitudes toward restrictions on worship. The COVID-19 crisis has revealed a cultural and political rift that makes consensual resolution of conflicts over religious freedom problematic, and perhaps impossible, even during a once-in-a-century pandemic.

AbstractGauge-calibrated radar estimates of daily precipitation are compared with daily observed values of precipitation from National Weather Service (NWS) Cooperative Observer Network (COOP) stations to evaluate the multisensor precipitation estimate (MPE) product that is gridded by the National Centers for Environmental Prediction (NCEP) for the eastern United States (defined as locations east of the Mississippi River). This study focuses on a broad evaluation of MPE across the study domain by season and intensity. In addition, the aspect of precipitation type is considered through case studies of winter and summer precipitation events across the domain. Results of this study indicate a north–south gradient in the error of MPE and a seasonal pattern with the highest error in summer and autumn and the lowest error in winter. Two case studies of precipitation are also considered in this study. These case studies include instances of intense precipitation and frozen precipitation. These results suggest that MPE is less able to estimate convective-scale precipitation as compared with precipitation variations at larger spatial scales. In addition, the results suggest that MPE is subject to errors related both to the measurement gauges and to the radar estimates used. Two case studies are also included to discuss the differences with regard to precipitation type. The results from these case studies suggest that MPE may have higher error associated with estimating the liquid equivalent of frozen precipitation when compared with NWS COOP network data. The results also suggest the need for more analysis of MPE error for frozen precipitation in diverse topographic regimes.

This paper examines Lisa Austin’s (2015) concept of lawful illegality, which interrogates the legal foundations for potentially unlawful surveillance practices by United States (US) signals intelligence (SIGINT) agencies. Lawful illegality involves the technically lawful operation of surveillance powers that might be considered unlawful when examined through a rule of law framework. We argue lawful illegality is expanding into domestic policing through judicial decisions that sanction complex and technically sophisticated forms of remote online surveillance, such as the use of malware, remote hacking, or Network Investigative Techniques (NITs). Operation Pacifier targeted and dismantled the Playpen dark web site, which was used for distributing child exploitation material (CEM), and has generated many judicial rulings examining the legality of remote surveillance by the FBI. We have selected two contrasting cases that demonstrate how US domestic courts have employed distinct logics to determine the admissibility of evidence collected through the NIT deployed in Operation Pacifier. The first case, United States v. Carlson (2017 US Dist. LEXIS 67991), offers a critical view of the use of NITs by the FBI, with physical geography constraining the legality of this form of surveillance in US criminal procedure. The second case, United States v. Gaver (2017 US Dist. LEXIS 44757), authorizes the use of NITs because the need to control crime is believed to justify suspending the geographic limits on police surveillance to identify people involved in the creation and dissemination of CEM. We argue this crime control emphasis expands the reach of US police surveillance while undermining due process of law by removing the protective function of geography. We conclude by suggesting the permissive geographic scope of police surveillance reflected in United States v. Gaver (2017 US Dist. LEXIS 44757), and many other Playpen cases, erodes due process for all crime suspects, but is particularly acute for people located outside the US, and suggest a neutral transnational arbiter could help limit contentious forms of remote extraterritorial police surveillance.

This year we celebrate a United States Supreme Court decision that marks the beginning of modern jurisdiction over constitutional questions: Marbury v. Madison. This is all the more remarkable since, when it was decided two hundred years ago in 1803, it was controversial and many still maintain it was wrongly decided. Chief Justice Marshall ruled on a dispute which he had earlier had a hand in causing, since the alleged legal error – the untimely delivery of a commission to Justice of the Peace Marbury – fell within his area of responsibility as Secretary of State. He dismissed the petition because the incorrect legal procedure had been chosen. However, he did not examine this question at the outset but – contrary to the accepted procedural rules of his time – at the end. This left room for a wide-ranging discussion of the right of judicial review, which was not required by law, and was, therefore, obiter dicta. Thomas Jefferson later referred to this discussion as the Chief Justice's “obiter dissertation.” Of course, Adams himself contended that the case turned on the judicial right of review, since this was a component of his argument that the petition should be dismissed.

Abstract This article examines the historical correlations between Chinese exclusion law enforcement and the career patterns of immigration attorneys in San Francisco. Built on a rich historiography about Chinese exclusion and state formation in the United States, it views these attorneys as a unique interest group to make sense of their intermediary role between the administrative state and the transnational Chinese community. Drawing from both traditional sources and a collection recently made public by Stanford University, it looks at three groups of Euro-American lawyers who, for five decades, dominated the business of Chinese immigration legal services at the Golden Gate: lawyers from the private sector, former United States attorneys, and officials-turned-attorneys who emerged in the late 1910s. The article argues that these lawyers’ background and priorities closely corresponded and evolved with the decline of judicial review and the rise of the immigration authorities’ near-plenary power over the project of exclusion. The lawyers’ work provides fresh insights into the key paradox in the history of Chinese exclusion, that despite its constant search for efficiency, local enforcement of the exclusion laws often reduced the anti-Chinese policy to routinized, counterproductive procedures. It finds that many US attorneys and immigration inspectors who later chose to become attorneys for the Chinese had been diligent federal employees. Their shifting positions prove bureaucratic malice towards Chinese immigrants to be anything but monolithic and challenge historians’ established dichotomy between an anti-Chinese state and Chinese in America.

The United States Environmental Protection Agency models CORMIX2 and UM were used to predict the ambient temperature rises from thermal discharges near Charlestown, Rhode Island, and Jamesport, Long Island, New York. Observations from two scaled model laboratory studies conducted at Alden Research Laboratories Inc. (ARL) were compared with temperature rise predictions from two numerical models. For the ARL diffuser at Jamesport, both numerical models underestimated the observed temperature rises. In the Charlestown study, UM produced results that were in good agreement with the temperature rises observed, whereas CORMIX2 underpredicted observations but remained within the model's stipulated ±50% error. However, UM was unable to model the plume shape properly, since it is primarily intended for alternating diffusers. The predicted wastefield shapes of CORMIX2 were similar to those observed in the laboratory but of greater surface area. Key words: multiport diffusers, thermal discharges, initial dilution.

The exercise of constitutional review by an independent and active judiciary is commonly regarded as against the interest of current government officials, who presumably prefer to exercise power without interference. In this article, I advance an “overcoming obstructions” account of why judicial review might be supported by existing power holders. When current elected officials are obstructed from fully implementing their own policy agenda, they may favor the active exercise of constitutional review by a sympathetic judiciary to overcome those obstructions and disrupt the status quo. This provides an explanation for why current officeholders might tolerate an activist judiciary. This dynamic is illustrated with case studies from American constitutional history addressing obstructions associated with federalism, entrenched interests, and fragmented and cross-pressured political coalitions.

Following the 2006 retirement of Sandra Day O'Connor and the confirmation of Samuel Alito to succeed her, Roman Catholics formed a majority on the United States Supreme Court for the first time in this institution's 210-year history. This Catholic majority was further strengthened by the appointment of Sonia Sotomayor in 2009. Perhaps even more remarkably, by the time of Elena Kagan's first case in October of 2010, not a single Protestant sat on the nation's highest judicial body.By way of comparison, in 1960 the Court consisted of seven Protestants, one Catholic and one Jew; in 1985, eight Protestants and one Catholic sat on the Court. This phenomenon is further reflected in judicial appointments. Since 1985, only one Protestant has been appointed,4 Justice David Souter, compared to seven Catholics and three Jews. The prima facie reason for this transformation is simple: President Reagan began the Protestant erosion by appointing two Catholics; George H.W. Bush followed by appointing a Catholic; and Bill Clinton, George W. Bush, and Barack Obama chose only Jewish and Catholic nominees. The deeper reasons, which are considerably more complex, are the focus of this article.

Abstract Error characteristics of model output statistics (MOS) temperature forecasts are calculated for over 200 locations around the continental United States. The forecasts are verified on a station-by-station basis for the year 2001. Error measures used include mean algebraic error (bias), mean absolute error (MAE), relative frequency of occurrence of bias and MAE values, and the daily forecast errors themselves. A case study examining the spatial and temporal evolution of MOS errors is also presented. The error characteristics presented here, together with the case study, provide a more detailed evaluation of MOS performance than may be obtained from regionally averaged error statistics. Knowledge concerning locations where MOS forecasts have large errors or biases and why those errors or biases exist is of great value to operational forecasters. Not only does such knowledge help improve their forecasts, but forecaster performance is often compared to MOS predictions. Examples of biases in MOS forecast errors are illustrated by examining two stations in detail. Significant warm and cold biases are found in maximum temperature forecasts for Los Angeles, California (LAX), and minimum temperature forecasts for Las Vegas, Nevada (LAS), respectively. MAE values for MOS temperature predictions calculated in this study suggest that coastal stations tend to have lower MAE values and lower variability in their errors, while forecasts with high MAE and error variability are more frequent in the interior of the United States. Therefore, MAE values from samples of MOS forecasts are directly proportional to the variance in the observations. Additionally, it is found that daily maximum temperature forecast errors exhibit less variability during the summer months than they do over the rest of the year, and that forecasts for any one station rarely follow a consistent temporal pattern for more than two or three consecutive days. These inconsistent error patterns indicate that forecasting temperatures based on recent trends in MOS forecast errors at an individual station is usually not a good strategy. As shown in earlier studies by other authors and demonstrated again here, MOS temperature forecasts are often inaccurate in the vicinity of strong temperature gradients, for locations affected by shallow cold air masses, or for stations in regions of anomalously warm or cold temperatures. Finally, a case study is presented examining the spatial and temporal distributions of MOS temperature forecast errors across the United States from 13 to 15 February 2001. During this period, two surges of cold arctic air moved south into the United States. In contrast to error trends at individual stations, nationwide spatial and temporal patterns of MOS forecast errors could prove to be a powerful forecasting tool. Nationwide plots of errors in MOS forecasts would be useful if made available in real time to operational forecasters.

In response to the topic of Global Justice and Human Rights: Country Case Studies, I will discuss the origin and continuation of violence against Native American women in the United States. In a report named Maze of Injustice: The Failure to Protect Indigenous Women from Violence by Amnesty International, the organization deemed the current status of violence against indigenous women one of the most pervasive yet hidden human rights abuses. The U.S Department of Justice has found that Native American and Native Alaskan women are 2.5 times more likely to be raped or sexually assaulted. During an International Expert Group Meeting discussing Combatting Violence Against Indigenous Women and Girls, the United Nations Department of Economic and Social Affairs declared it a human rights issue of epidemic proportions. One in three Native American women are raped and three in five are physically assaulted. In reference to interracial violence, four out of five Native American victims of sexual assault reported that the perpetrator was white. Unfortunately due to the shame and stigma surrounding topics such as sexual assault and rape it is estimated that in reality these numbers are far higher. Scholars and historians of pre-colonial Native societies have found that during this period women held prominent positions and violence against women was rare. With colonization came a radical change to the role of women in Native society. Gender based violence and the exclusion of women in important positions was a powerful tool used by British settlers to dismantle the structures of native society and ultimately conquer it. Presently, due to the inadequate legal power given to Indian nations the crisis is not being dealt with efficiently. For example, Indian nations are unable to prosecute non-Indian offenders. In my discussion of violence against Native women in the United States I will begin by analyzing its colonial origins. Next I will discuss why this violence persists today with reference to laws and judicial processes. Finally, I will discuss what must be done to end these human rights abuses.

This study examines the phenomenon of abusive violence (AV) in the context of the American Post-9/11 Counter-terrorism and Counter-insurgency campaigns. Previous research into atrocities by states and their agents has largely come from examinations of totalitarian regimes with well-developed torture and assassination institutions. The mechanisms influencing willingness to do harm have been examined in experimental studies of obedience to authority and the influences of deindividuation, dehumanization, context and system. This study used Interpretive Phenomenological Analysis (IPA) to examine the lived experience of AV reported by fourteen American military and intelligence veterans. Participants were AV observers, objectors, or abusers. Subjects described why AV appeared sensible at the time, how methods of violence were selected, and what sense they made of their experiences after the fact. Accounts revealed the roles that frustration, fear, anger and mission pressure played to prompt acts of AV that ranged from the petty to heinous. Much of the AV was tied to a shift in mission view from macro strategic aims of CT and COIN to individual and small group survival. Routine hazing punishment soldiers received involving forced exercise and stress positions made similar acts inflicted on detainees unrecognizable as abusive. Overt and implied permissiveness from military superiors enabled AV extending to torture, and extra-judicial killings. Attempting to overcome feelings of vulnerability, powerlessness and rage, subjects enacted communal punishment through indiscriminate beatings and shooting. Participants committed AV to amuse themselves and humiliate their enemies; some killed detainees to force confessions from others, conceal misdeeds, and avoid routine paperwork. Participants realized that AV practices were unnecessary, counter-productive, and self-damaging. Several reduced or halted their AV as a result. The lived experience of AV left most respondents feeling guilt, shame, and inadequacy, whether they committed abuse or failed to stop it.

This chapter cites how counterterrorism policies and operations have impacted human rights in liberal democracies. It highlights how detention without trial, torture, and extra-judicial killings impact negatively human rights. Human rights are defined as the fundamental moral rights of a person necessary for a life with human dignity. Additionally, counterterrorism, in the chapter, refers to policies formulated and actions taken to reduce, mitigate, or prevent terrorism. The chapter presents key factors and mechanisms at play through case studies of Northern Ireland in the 1970s and the United States ‘war’ against jihadist terrorism. It also looks at theories of international relations as they relate to how human rights impacts policies for counterterrorism.

The United States has been one of the most active countries in the deployment of municipal broadband networks. In America, many remote areas have no Internet access or are served by a single provider that might not meet local needs. Increasingly, access to the Internet is vital for social and economic development as well as prosperity. Without access, rural areas lose economic competitiveness and have lower quality of life standard of living. An attractive solution for such localities is to provide Internet access themselves, provided they believe that their area will realize significant benefits from it. However, the States’ complex legal frameworks are a significant barrier to local network success. Each state makes its own laws governing its municipalities, and states have almost unfettered ability to constrain, either by ban or by lesser restraint, the emergence of local networks. These states are further influenced by the lobbying of incumbent service providers. Moreover, judicial remedies can be used strategically by incumbents to hinder, delay, or prevent local networks from succeeding. Despite all this, local networks can be and have been successful. This chapter discusses various legal and political barriers to municipal networks and explores case studies with the goal of learning from past successes and failures.

Abstract Chapter 7 discusses the need for reforming investment law and arbitration and the problems which bilateral WTO appellate arbitration could pose for the coherence of world trade law. Like international trade law, the historical evolution of investor–state arbitration reflects conflicting neo-liberal, state capitalist, and ordo-liberal conceptions of economic law. Case studies demonstrate that even if human rights were invoked as investor claims, as defences of the host state, by third-party interveners or by arbitrators ex officio, the impact of human rights law on arbitration awards tended to remain marginal, for example due to the more precise and higher investment protection standards in investment treaties. The investor biases in investment treaties and arbitration (e.g. offering foreign investors higher protection standards than domestic investors) require procedural and substantive reforms like stronger protection of public interest legislation in investment law and arbitration procedures. Yet, it remains doubtful whether the United States and China will give up their past resistance against EU proposals for transforming the multilateral arbitration procedures of the International Center for the Settlement of Investment Disputes and of the UN Commission on International Trade Law (UNCITRAL) into new forms of public law adjudication by multilateral investment courts.

Abstract Multi-fractured horizontal wells have been an admirable completion technique for unconventional resources such as in Tuscaloosa Marine shale (TMS) and Eagle Ford Shale (EFS) plays located in the United States. Studies have shown that the productivity of multi-fractured wells of these two shale plays are majorly based on the fracture conductivity, which may be dependent on the type of the geometrical shape of the fractures connecting the fluid to the well. A reliable model is desirable to the operator to accurately capture the productivity of multi-fractured shale wells. Several mathematical models have been adopted with various assumptions that include simple slot geometry for fracture shape in the derivation of production rate models. These assumptions significantly simplify the existing model's applications but limit the efficiency of the models to accurately predict the fluid production rate. Failure to utilize an elliptical fracture shape and a correct drive mechanism-based model for analyzing flow rate have been considered as a vital reason for the disparity between the calculated results by the past investigators and the exact values obtained from TMS and EFS field measurements. In this study, an elliptical model based on the fracture geometry has been derived to analyze the productivity of multi-fractured shale wells considering the accurate drive mechanism for the shale play. The model validation has been achieved using field data from the Tuscaloosa Marine shale (TMS) and the Eagle Ford Shale (EFS) plays. The results generated from the newly improved model resulted in more accurate outcomes when compared with results presented by Yang and Guo (2019) and Guo and Schechter (1997); all these authors assumed the cross-sectional area of the induced fractures as being a slot showed nonconformity using real life values from the Tuscaloosa Marine shale (TMS) and the Eagle Ford Shale (EFS) plays as benchmarks. The newly improved model reduces the prediction percentage error to 0.55% and 0.43% compared to the percentage error reported by Yang and Guo (2019) as 9.1% and 3.5% and by Guo and Schechter (1997) respectively as 29.7% and 47.2 % using the actual oilfield results as their benchmark. The accurate prediction of the long-term productivity of multi-fractured oil shale depends on the ability to determine fracture geometry and the drive mechanisms that dominantly control flow in the shale play considered. Sample calculations of flow rate of the two fields considered and the controllable parameters influencing the flow rate have also been identified. The study would serve as a tool for accurate assessment of flow rate in multi-fractured wells of shale plays and analyzes its performance.

Abstract Uniaxial Compressive Strength (UCS) and Tensile Strength (TS) are among the essential rock parameters required and determined for rock mechanical studies in Petroleum Engineering. However, the determination of such parameters requires some laboratory experiments, which may be time-consuming and costly at the same time. In order to estimate these parameters efficiently and in a short period, some mathematical tools have been used by different researchers. When regression tools proved to give good results only in the limited range of data used, machine learning methods proved to be very accurate in generating models that can cover a wide range of data. In this study, two machine learning models were used to predict the UCS and TS, Support Vector Regression optimized by Genetic Algorithm (GA-SVR) and Artificial Neural Networks (ANNs). The results were discussed for both uniaxial compressive strength and tensile strength in terms of coefficient of determination R2, root mean squared error (RMSE) and mean average error (MAE). First, for the case of UCS, values of 0.99 and 0.99, values of 3.41 and 2.9 and values of 2.43 and 1.9 were obtained for R2, RMSE and MAE for the ANN and GA-SVR, respectively. Second, for the TS, the same analogy was followed, a coefficient R2 of 0.99 and 0.99, RMSE values of 0.41 and 0.45 and MAE values of 0.30 and 0.39 were obtained for ANNs and GA-SVR, respectively. The next step was to assess these models on a different dataset consisting of data obtained from Bakken Field in Williston Basin, North Dakota, United States. The models showed excellent results comparing to the correlations they were compared with, outperforming them in terms of R2, RMSE and MAE, giving the following results for ANN and SVR respectively, R2 of 0.93, 0.92, RMSE of 9.54, 11.22 and MAE of 7.28, 9.24. The resultant conclusion of this work is that the use of machine learning algorithms can generate universal models which reduce the time and effort to estimate some complex parameters such as UCS and Tensile Strength.

Objectives. Diagnostic errors are a known patient safety concern across all clinical settings, including the emergency department (ED). We conducted a systematic review to determine the most frequent diseases and clinical presentations associated with diagnostic errors (and resulting harms) in the ED, measure error and harm frequency, as well as assess causal factors. Methods. We searched PubMed®, Cumulative Index to Nursing and Allied Health Literature (CINAHL®), and Embase® from January 2000 through September 2021. We included research studies and targeted grey literature reporting diagnostic errors or misdiagnosis-related harms in EDs in the United States or other developed countries with ED care deemed comparable by a technical expert panel. We applied standard definitions for diagnostic errors, misdiagnosis-related harms (adverse events), and serious harms (permanent disability or death). Preventability was determined by original study authors or differences in harms across groups. Two reviewers independently screened search results for eligibility; serially extracted data regarding common diseases, error/harm rates, and causes/risk factors; and independently assessed risk of bias of included studies. We synthesized results for each question and extrapolated U.S. estimates. We present 95 percent confidence intervals (CIs) or plausible range (PR) bounds, as appropriate. Results. We identified 19,127 citations and included 279 studies. The top 15 clinical conditions associated with serious misdiagnosis-related harms (accounting for 68% [95% CI 66 to 71] of serious harms) were (1) stroke, (2) myocardial infarction, (3) aortic aneurysm and dissection, (4) spinal cord compression and injury, (5) venous thromboembolism, (6/7 – tie) meningitis and encephalitis, (6/7 – tie) sepsis, (8) lung cancer, (9) traumatic brain injury and traumatic intracranial hemorrhage, (10) arterial thromboembolism, (11) spinal and intracranial abscess, (12) cardiac arrhythmia, (13) pneumonia, (14) gastrointestinal perforation and rupture, and (15) intestinal obstruction. Average disease-specific error rates ranged from 1.5 percent (myocardial infarction) to 56 percent (spinal abscess), with additional variation by clinical presentation (e.g., missed stroke average 17%, but 4% for weakness and 40% for dizziness/vertigo). There was also wide, superimposed variation by hospital (e.g., missed myocardial infarction 0% to 29% across hospitals within a single study). An estimated 5.7 percent (95% CI 4.4 to 7.1) of all ED visits had at least one diagnostic error. Estimated preventable adverse event rates were as follows: any harm severity (2.0%, 95% CI 1.0 to 3.6), any serious harms (0.3%, PR 0.1 to 0.7), and deaths (0.2%, PR 0.1 to 0.4). While most disease-specific error rates derived from mainly U.S.-based studies, overall error and harm rates were derived from three prospective studies conducted outside the United States (in Canada, Spain, and Switzerland, with combined n=1,758). If overall rates are generalizable to all U.S. ED visits (130 million, 95% CI 116 to 144), this would translate to 7.4 million (PR 5.1 to 10.2) ED diagnostic errors annually; 2.6 million (PR 1.1 to 5.2) diagnostic adverse events with preventable harms; and 371,000 (PR 142,000 to 909,000) serious misdiagnosis-related harms, including more than 100,000 permanent, high-severity disabilities and 250,000 deaths. Although errors were often multifactorial, 89 percent (95% CI 88 to 90) of diagnostic error malpractice claims involved failures of clinical decision-making or judgment, regardless of the underlying disease present. Key process failures were errors in diagnostic assessment, test ordering, and test interpretation. Most often these were attributed to inadequate knowledge, skills, or reasoning, particularly in “atypical” or otherwise subtle case presentations. Limitations included use of malpractice claims and incident reports for distribution of diseases leading to serious harms, reliance on a small number of non-U.S. studies for overall (disease-agnostic) diagnostic error and harm rates, and methodologic variability across studies in measuring disease-specific rates, determining preventability, and assessing causal factors. Conclusions. Although estimated ED error rates are low (and comparable to those found in other clinical settings), the number of patients potentially impacted is large. Not all diagnostic errors or harms are preventable, but wide variability in diagnostic error rates across diseases, symptoms, and hospitals suggests improvement is possible. With 130 million U.S. ED visits, estimated rates for diagnostic error (5.7%), misdiagnosis-related harms (2.0%), and serious misdiagnosis-related harms (0.3%) could translate to more than 7 million errors, 2.5 million harms, and 350,000 patients suffering potentially preventable permanent disability or death. Over two-thirds of serious harms are attributable to just 15 diseases and linked to cognitive errors, particularly in cases with “atypical” manifestations. Scalable solutions to enhance bedside diagnostic processes are needed, and these should target the most commonly misdiagnosed clinical presentations of key diseases causing serious harms. New studies should confirm overall rates are representative of current U.S.-based ED practice and focus on identified evidence gaps (errors among common diseases with lower-severity harms, pediatric ED errors and harms, dynamic systems factors such as overcrowding, and false positives). Policy changes to consider based on this review include: (1) standardizing measurement and research results reporting to maximize comparability of measures of diagnostic error and misdiagnosis-related harms; (2) creating a National Diagnostic Performance Dashboard to track performance; and (3) using multiple policy levers (e.g., research funding, public accountability, payment reforms) to facilitate the rapid development and deployment of solutions to address this critically important patient safety concern.