text:
Before GRUENDER and BENTON, Circuit Judges, and TUNHEIM,  Chief District Judge.
Defendant-Appellant Randy Ford was arrested for being a felon in possession of a firearm. Ford moved to suppress evidence of the handgun at issue and his related incriminating statements. After an evidentiary hearing, the trial court denied his motion. Ford pled guilty, and the trial court sentenced him to a mandatory minimum sentence of 180 months under the Armed Career Criminal Act. This appeal follows.
On January 19, 2016, Iowa Department of Corrections ("DOC") Officer Mike Evans received a tip that Defendant-Appellant Randy Ford was staying at a particular Des Moines residence owned by a woman named Dawn. Evans was part of a DOC fugitive unit tasked with locating and arresting parole violators. The unit had an arrest warrant for Ford. Evans was told that Ford used a cell phone in the southeast bedroom window as a surveillance device when he was present in the residence. Evans was also told that Ford had recently been seen with a handgun, and that he may be suicidal. The DOC officers had not met the tipper before that day, but an officer verified that the home at that address was owned by a woman named Dawn. And, when four or five DOC officers and two U.S. Marshals went to the residence, they saw a cell phone in the window of the southeast bedroom.
As the officers approached the house, they encountered a woman outside. The nature of that interaction is a matter of dispute. DOC Officer Smith testified that the woman indicated that Ford was inside the home, either verbally or through a gesture. The woman testified that she told officers that she did not know whether Ford was inside. The trial court noted that the woman had known Ford for about a month and, like Ford, was on parole. It concluded that "[t]he court does not believe her" testimony. Ford argues that no credible fact finder could reach that conclusion.
Ford also disputes the trial court's conclusion that DOC Officer Kness "observed a hand in the window of the southeast bedroom before entering the residence." Ford insists that such an observation would have been impossible because the bedroom windows were covered by curtains glued tightly to the walls. He notes that several video recordings of the curtains made by the homeowner were received into evidence at the suppression hearing. Ford also says that the bed was located in front of the window, blocking anyone from walking up to it.
It is undisputed that officers entered the house without knocking or forcing entry and split up to look for Ford. The trial court found that officers methodically "cleared" each room. When Evans arrived in the southeast bedroom, he moved the bed from the wall and checked the closet for Ford. At the same time, another officer found Ford hiding in the closet of the southwest bedroom. Evans assisted with his arrest, then returned to the southeast bedroom. There, he saw a handgun in plain view. After Ford was given Miranda warnings, he admitted that the gun was his and that he had thrown it under the bed when he saw police approaching the residence.
Ford argues that his Fourth Amendment rights were violated by the officers' entry into the home without a search warrant and by the scope of their protective sweep incident to his arrest. As a result, Ford says, evidence of the handgun and his statements should have been suppressed. "A mixed standard of review applies to the denial of a motion to suppress evidence." United States v. Smith, 820 F.3d 356, 359 (8th Cir. 2016) (citing United States v. Williams, 777 F.3d 1013, 1015 (8th Cir. 2015)). The trial court's findings of fact are reviewed for clear error and its denial of the suppression motion is reviewed de novo. Id.
We must determine as a preliminary matter whether Ford waived his right to advance his argument about the scope of the protective sweep by failing to assert it below. Waiver is "'the intentional relinquishment or abandonment of a known right, ' whereas forfeiture is 'the failure to make the timely assertion of a right.'" United States v. Chavarria-Ortiz, 828 F.3d 668, 670-71 (8th Cir. 2016) (quoting United States v. Olano, 507 U.S. 725, 733 (1993)). The former precludes review altogether, while the latter requires a plain-error standard of review. Id. at 671. We conclude that Ford did not intend to waive this issue, and apply a Rule 52(b) plain-error standard of review. To prevail, Ford must show that there is "(1) error, (2) that is plain, and (3) that affects substantial rights. If all three of those conditions are met, an appellate court may then exercise its discretion to notice a forfeited error, but only if (4) the error seriously affects the fairness, integrity, or public reputation of judicial proceedings." United States v. Miranda-Zarco, 836 F.3d 899, 902 (8th Cir. 2016) (quoting United States v. Ault, 598 F.3d 1039, 1042 (8th Cir. 2010)) (internal quotation marks omitted).
Because there is no clear error in the trial court's findings of fact, no error in its conclusions of law as to the officers' entry into the home, and no plain error with regard to the scope of the protective sweep, we will affirm the decision below.
Ford argues that his Fourth Amendment rights were violated by the officers' entry into the home without a search warrant.

matches: v. v. v. v. v. v.


text:
On 26 March 2014 the Supreme Court gave a lengthy judgment in Kennedy v Charity Commission  UKSC 20, running to 248 paragraphs. The Supreme Court decision is full of surprises. The Court decided to depart from the arguments of the parties- the majority insisted that common law rights rather than the Human Rights Act were the key to the case; and then embarked on an extended and wide ranging obiter discussion of public law issues, revealing further disagreements between the Justices.
Mr Kennedy, a Times journalist, raised concerns about how George Galloway MP ran his controversial Iraq charity, the Miriam Appeal. He alleged that public donations were used to fund visits by Mr Galloway to Iraq and to support political campaigns against UN sanctions and against Israel. As a result, the Charity Commission which held three inquires under the Charities Act 2006, which dismissed the complaints in very brief terms, leaving unanswered questions which the Supreme Court thought were of considerable public importance.
Mr Kennedy then requested disclosure from the Commission of documents which might explain the inquiries’ conclusions under the Freedom of Information Act (FOIA). He accepted that some information might attract absolute exemption from disclosure under FOIA (such as confidential information under s 41) and that other parts came within the scope of qualified exemptions and therefore required weighing up rival public interests under s 2(2).
However, the Commission said that all the documents were subject to an absolute exemption under s 32, on the basis that s 32 exempts the Commission from any duty to disclose documents held by a Court or persons conducting an inquiry or arbitration. Mr Kennedy responded by arguing that the absolute exemption under s 32(2) fell away once the inquiry concluded, either as a matter of ordinary construction or by interpreting s 32 in accordance with s 3 of the Human Rights Act. The protracted litigation began with a FOIA request in June 2007, followed by a detailed consideration by the Information Commissioner, two hearings before the First Tier Tribunal, a High Court hearing and two hearings before the Court of Appeal, which Mr Kennedy appealed to the Supreme Court.
The principal issues before the Supreme Court were whether the absolute exemption ended with the inquiry’s conclusion, either as a matter of ordinary construction or under the extended meaning permitted by s 3 of the HRA. The Supreme Court had little difficulty in deciding against Mr Kennedy that the absolute exemption under s 32 continued after the inquiries ended. The principal battleground therefore focused on the scope of Art 10.
Unfortunately, the Strasbourg jurisprudence on whether freedom of expression entails a right of access to information is not entirely straightforward. In the older cases (which include Grand Chamber decisions), Leander v Sweden (1987) 9 EHRR 433, Gaskin v UK (1989) 12 EHRR 36, Guerra v Italy (1998) 26 EHRR 357 and Roche v UK (32555/96) (2005) 42 EHRR 30, the ECtHR deny that a right of access to information falls within the scope of Art 10. However, a series of later cases, Matky v Czech Republic Judgment 10 July 2006, Tarsasag v Hungary (2011) 53 EHRR 3 and Kenedi v Hungary (31475/05) (2009) 27 BHRC 335 say what Article 10 conferred a right of access to information, at any rate for those who exercise of the functions of a social watchdog, like the press.
Lord Judge CJ in Independent News and Media  1 WLR 2262 observed that the Strasbourg jurisprudence appeared to have developed a wider scope since Leander. But when the point was argued before the Supreme Court in Sugar v BBC  1 WLR 439, Lord Brown disagreed, holding in trenchant terms [88-96] that Art 10 creates no general right to freedom of information. Lords Mance and Wilson agreed with his analysis.
Since Sugar there have been four more ECtHR cases indicating that Art 10 confers a right of access to information: the Grand Chamber decision in Gillberg v Sweden (2012) 34 BHRC 247, Shapovalov v Ukraine, Judgment 32 July 2012, Youth Initiative for Human Rights v Serbia Judgment, June 25, 2013 and Österreichische v Austria, Judgment, 28 November 2013 (which was in fact given after the oral argument).
Mr Kennedy asked the Supreme Court to overrule Sugar before a seven judge court. Lord Mance, in giving the leading judgment (with which Lords Neuberger, Clarke and Sumption agreed) scrutinised the four new Strasbourg decisions [76-96]. He concluded, on the unsatisfactory state of the case law, that Art 10 did not confer a positive right of access to information . He also said  that it was unfortunate that the ECtHR chambers did not refer cases to the Grand Chamber where it disagreed with older Grand Chamber judgments.
Lord Mance’s approach is open to question on several grounds. His views appear to be out of line with current Strasbourg practice concerning referrals to the Grand Chamber, fail to acknowledge the dynamic interpretative techniques it uses when considering the scope of Convention rights (which Lord Wilson stressed in his dissenting judgment at ) and seem to imply that Strasbourg applies a system of precedent- which it does not.
Another curious feature of the decision is how the majority seized on a reference in the Commission’s printed case to s 78 of FOIA- which states that nothing in the Act ‘is to be taken to limit the powers of a public authority to disclose information held by it’. Section 78 was mentioned by the Commission for the limited purpose of arguing that its refusal to disclose was not an ‘interference’ with Art 8. However, the majority used s 78 as a launch pad to discuss obiter extending the common law principles of open justice, as developed by R (Guardian Newspapers) v City of Westminster Magistrates’ Court  QB 618, where the Court of Appeal held that the magistrates acted unlawfully in refusing to disclose the skeleton arguments, witness statements and other documents.
The majority’s extension of the Guardian News principle presented a number of difficult issues (which were not raised before the parties). Lord Mance [48-50] appeared to regard this development as a modest one, taking the view that, having regard to the terms of the Charity Act, the Commission should accede to Mr Kennedy’s request for disclosure in the public interest- unless there were powerful countervailing arguments to be advanced: see, also Lord Toulson at [124-129]. By contrast, Lord Carnwath was sceptical about such a broad proposition [236-242], pointing to a basic fallacy, that statutory tribunals did not sit in public, so that the cornerstone principle of Guardian News was absent. In Lord Carnwath’s view the alternative common law approach was, ‘arguably, a bolder leap into the unknown than the modest step’ the Supreme Court was being asked to take (after full argument) in relation Art 10.
The Supreme Court also disagreed about the standard to be applied when assessing whether the principle of open justice was overridden by countervailing factors. Lord Mance stated [52-54]- that the Wednesbury standard had developed an issue-sensitive scale of intervention to enable the Courts to perform their constitutional function in an increasing polity and concluded that the proportionality test is relevant to judicial review outside the scope of Convention and EU law, apparently performing the burial rights to the Wednesday principle which Dyson LJ foreshadowed in [34-37] in R (ABCIFER) v Secretary of State for Defence  QB 1397. Lord Carnwath was much more cautious , pointing out that the jurisprudential basis for this flexible approach remains uncertain and that it was, at best, uncertain whether proportionality had become part of domestic public law.
Another curiosity in the judgment concerns how Mr Kennedy can now take his case forward. Lord Sumption emphasised  that a fresh request based on common law grounds would not necessarily result in a favourable outcome. Furthermore, if Mr Kennedy tried to judicially review a refusal to provide the documents requested, those new proceedings might be time-barred under CPR 54.5(1) since the ground of challenge arose so long ago. Lord Toulson suggested  that it would be harsh for the claim to be treated as time barred under CPR 54.5(1) because of the legal uncertainty concerning the correct route he should take. However, it is far from clear whether legal uncertainty in these circumstances will constitute a ‘good reason’ for extending time under the Civil Procedure Rules: so that any future judicial review case will fall at the first hurdle. Assuming the Administrative Court reached the stage of deciding the case on common law grounds, it is equally uncertain whether Mr Kennedy will prevail.
The upshot is Mr Kennedy may yet find that he will need to obtain a ruling from the ECtHR concerning whether Art 10 entails a right of access to information- sooner that the Supreme Court appear to have assumed.
Richard Clayton QC practises from 4-5 Grays’ Inn Square and Kings Chambers, Birmingham and is an Associate Fellow at the Centre for Public Law, Cambridge University. He represented the Media Legal Defence Initiative and the Campaign for freedom of Information in their intervention in the Kennedy case before the Supreme Court.

matches:
UKSC
Art 10
Art 10
Art 10
Art 10
Art 10
Art 8
Art 10
Art 10


text:
1949 Bromley v. Romford (sc/tc/sl tr) £30.
1953 Harwich & Parkeston v. Pegasus (cr, sl/grubby) £10.
1954 Bishop Auckland v. Crook Town £10.
1955 Bishop Auckland v. Hendon £8.
1957 Bishop Auckland v. Wycombe £8.
1960 Hendon v. Kingstonian £5.
1961 Walthamtow Avenue v. West Auckland Town £5.
1962 Crook Town v. Hounslow £5, Replay (@ Middlesbrough) £40.
1963 Sutton v. Wimbledon £8.
1966 Hendon v. Wealdstone £5.
1967 Enfield v. Skelmersdale £3, Replay (@ Maine Road) £2.
1968 Chesham v. Leytonstone £3.
1970 Dagenham v. Enfield (sc/tc) £2.
1971 Dagenham v. Skelmersdale £2.
1972 Enfield v. Hendon £2.
1973 Slough v. Walton & Hersham £2.
1974 Bishops Stortford v. Ilford (cr) £2.
1974 Ilford v. Leathearhead (tc) £2, Ashington v. Bishops Stortford (Replay, sc/tc) £2.

matches: v. v. v. v. v. v. v. v. v. v. v. v. v. v. v. v. v. v. v.


§ 102.61 Contents of petition for certification; contents of petition for decertification; contents of petition for clarification of bargaining unit; contents of petition for amendment of certification.
§ 102.62 Election agreements; voter list; Notice of Election.
§ 102.63 Investigation of petition by regional director; notice of hearing; service of notice; Notice of Petition for Election; Statement of Position; withdrawal of notice of hearing.
§ 102.64 Conduct of hearing.
§ 102.65 Motions; intervention; appeals of hearing officer's rulings.
§ 102.66 Introduction of evidence: rights of parties at hearing; preclusion; subpoenas; oral argument and briefs.
§ 102.67 Proceedings before the regional director; further hearing; action by the regional director; appeals from actions of the regional director; statement in opposition; requests for extraordinary relief; Notice of Election; voter list.
§ 102.68 Record in pre-election proceeding; what constitutes; transmission to Board.
§ 102.69 Election procedure; tally of ballots; objections; certification by the regional director; hearings; hearing officer reports on objections and challenges; exceptions to hearing officer reports; regional director decisions on objections and challenges.
§ 102.71 Dismissal of petition; refusal to proceed with petition; requests for review by the Board of action of the regional director.
§ 102.72 Filing petition with general counsel: investigation upon motion of general counsel; transfer of petition and proceeding from region to general counsel or to another region; consolidation of proceedings in same region; severance; procedure before general counsel in cases over which the general counsel has assumed jurisdiction.
2 Procedure under the first proviso to sec. 8(b)(7)(C) of the Act is governed by subpart D of this part.


text:
On December 4, 2017, the Supreme Court of the United States heard oral arguments in Christie v. National Collegiate Athletic Association, No. 16-476, regarding the constitutionality of the Professional and Amateur Sports Protection Act (“PASPA”), a federal law that prohibits states from authorizing and regulating sports wagering. The case could have significant implications for legal and regulated gambling across the country, including Pennsylvania, where the General Assembly recently passed legislation that would authorize sports wagering in the Commonwealth if PASPA is found to be unconstitutional or is repealed by Congress.
Enacted into law in 1992, PASPA placed prohibitions on legal sports betting across the country. The law specifically prohibits any government or individual to operate, sponsor or license a gambling or wagering scheme, which included lotteries and sweepstakes, that are based directly or indirectly on the outcome of competitive games in which athletes participate. The law excluded certain forms of competitive sports, including jai alai and pari-mutuel horse and dog racing. The law also grandfathered in states that had already authorized sports wagering, which included Delaware, Oregon and Montana, each of which had authorized sports lotteries within its borders, and Nevada, which had authorized full-scale sports wagering prior to PASPA’s enactment.
Also, Congress provided a one-year window under PASPA during which certain eligible states could authorize sports wagering. This option was limited to states that had at least 10 years of licensed casino gaming at the time of enactment of PASPA, and was included in the law to provide New Jersey with the opportunity to add sports wagering to its existing gaming regime. However, New Jersey failed to act within the one-year window provided under PASPA.
Nearly two decades after failing to authorize sports wagering during the one-year window under PASPA, in 2012, the New Jersey Legislature passed a law legalizing and regulating sports betting. The 2012 law was subsequently challenged in federal district court by the major sports organizations – the National Collegiate Athletic Association, Major League Baseball, the National Basketball Association, the National Football League and the National Hockey League. The challengers argued that New Jersey’s law violated PASPA’s clear ban on governments establishing or licensing sports wagering. New Jersey responded by arguing that PASPA violated the 10th Amendment to the U.S. Constitution. The federal court agreed with the sports organizations, and struck down New Jersey’s sports wagering law. The decision was subsequently upheld on appeal to the Third Circuit. National Collegiate Athletic Association v. Christie, 730 F.3d 208 (3rd Cir. 2013), and the Supreme Court declined to review the decision.
In response to these setbacks, New Jersey adopted a new tactic: in 2014 it passed new legislation which deregulated sports wagering and removed the state’s existing ban on sports wagering, but only as it related to casinos and racetracks within the state. This 2014 legislation was again the subject of litigation brought by the major sports organizations, and like before the state lost at both the federal district court and the Third Circuit. National Collegiate Athletic Association v. Christie, 832 F.3d 389 (3rd Cir. 2016).
This time, however, the Supreme Court granted New Jersey’s petition for a writ of certiorari. At the hearing in the appeal held on December 4, 2017, the Court appeared especially interested in an argument advanced by the Petitioner, that PASPA unconstitutionally commandeers the regulatory powers of the states to enforce federal law, in violation of the 10th Amendment and the Court’s decisions in New York v. United States, 505 U.S. 144 (1992) and Printz v. United States, 521 U.S. 898 (1997).
Since PASPA directly limits a state’s ability to regulate, or not regulate, sports wagering within its borders, while not establishing any standards or regulations of its own at the federal level, the Petitioner argued that PASPA is a direct command to the states, without any effort by the federal government to regulate sports wagering itself. Simply put – Congress could have developed a federal ban on sports wagering, which would have superseded any state law regulating or permitting such gambling. But the federal government did not establish any set of standards instituting a federal ban, but rather left the state’s no alternative but to prohibit sports wagering on its own.
The argument seemed to hit home with many of the justices, some of whom argued that the costs, expectations and “political accountability” of prohibiting sports wagering squarely falls to the states, while Congress has no federal policy or prohibition of its own in place to serve as preemption. Justice Kennedy went as far to say, “[PASPA] leaves in place a state law that the state does not want, so the citizens of the State of New Jersey are bound to obey a law that the state does not want but that the federal government compels the state to have.” Christie v. National Collegiate Athletic Association, No. 16-476, Tr. at *32.
Not all justices were convinced of New Jersey’s argument that PASPA moves away from preemption and enters the unconstitutional world of commandeering. Some justices were skeptical that the lack of a detailed regulatory structure automatically makes PASPA unconstitutional. In addition, the Responded sports leagues argued that unless Congress tells the states that they must regulate or pass prescribed legislation, it is not commandeering. The leagues added that PASPA does not demand states to maintain a prohibition; states just cannot license or regulate the activity. If New Jersey completely repealed its prohibition on sports wagering, it would not be in violation of PASPA. However, the 2014 law constituted only a partial repeal, which still left some form of regulation in place.
A decision in this case is expected this summer. As with any oral argument before the Supreme Court, we should not draw conclusions from the remarks of the justices on how the Court will ultimately decide the case. But if the Court rules that PASPA is unconstitutional as many are hoping, the decision could significantly impact Pennsylvania.
Last October, the General Assembly passed Act 42 of 2017, a sweeping and comprehensive gambling expansion bill that addresses the issue of sports wagering. We previously discussed other provisions of Act 42 here. In addition, Act 42 contains provisions to legalize and regulate sports betting in the Commonwealth, but would only apply if PASPA is overturned by a federal court decision or repealed by the federal government. Sports wagering would be permitted at casinos, non-primary locations, and online, pending additional federal changes.
As with previous gaming expansions, sports wagering, if legalized would result in a potential financial windfall to the state and local municipalities. Act 42 establishes a $10 million fee for casinos to add sports wagering, and taxes the activity at a 34% rate. In addition, Act 42 establishes a 2% local share assessment that is directed to the Commonwealth Financing Authority for projects across the state.
If the Supreme Court rules in favor of New Jersey this summer, Pennsylvania will be primed to offer sports wagering within its borders. If the case is decided on more narrow grounds, lawmakers in Pennsylvania will likely need to revisit the issue if sports wagering is to be permitted in the Commonwealth. Regardless of the Court’s decision, it is expected to result in much more discussion and debate regarding sports wagering in Pennsylvania and throughout the country. According to the American Gaming Association, Americans wager $150 billion in illegal sports bets each year. Estimated tax revenues in Pennsylvania alone could be in excess of hundreds of millions of dollars if sports wagering was legalized. Time will tell whether Pennsylvania’s sports wagering bet in Act 42 pays off.
The author thanks William Thomas, who assisted in the preparation of this post. Bill served as the Executive Director of the House Gaming Oversight Committee from 2010-2014, and remained heavily involved in gaming policy for the House as the Leadership Executive Director for the House Democratic Caucus Secretary from 2014-2017. He now is President of Mid-Atlantic Strategic Solutions, a McNees subsidiary and government affairs and political consulting firm. Bill can be reached at 717-574-2923.
The McNees Public Sector Blog seeks to provide solicitors, auditors, governmental officials and financial advisors in Pennsylvania with the latest updates, analysis, and commentary on the unique legal issues that face governmental entities. Our number one priority is to provide you with a strategy to reach the best overall result for your organization.
Need Help with Your Municipal Manager Position?
New Continuing Disclosure Rules Go into Effect – Are You Prepared?
McNees Wallace & Nurick LLC is a full-service law firm. The Public Finance & Government Services Group is a team of accomplished lawyers from various practice areas with the experience to provide specialized legal services to government entities at all levels. State agencies, political subdivisions, school districts, municipalities, and authorities turn to McNees attorneys for comprehensive, responsive advice regarding the complex legal issues and challenges they face.


text:
Disclaimer: I authored an amicus brief on behalf of the Marine Corps Defense Services Organization and in support of the appellee’s position in this case. The brief is available here and is discussed in this post.
CAAF will hear oral argument in the certified Air Force case of United States v. Chin, No. 15-0749/AF (CAAFlog case page), on Wednesday, January 13, 2016, at 9:30 a.m. The case challenges the authority of the Air Force Court of Criminal Appeals to grant relief for an unreasonable multiplication of charges despite the appellee having waived the issue in a pretrial agreement.
Whether the Air Force Court of Criminal Appeals (AFCCA) abused its discretion and committed legal error by finding that unreasonable multiplication of charges was not waived, in direct contradiction of this court’s binding precedent in United States v. Gladue, 67 M.J. 311 (C.A.A.F. 2009).
Whether the Air Force Court of Criminal Appeals (AFCCA) committed legal error by finding that unreasonable multiplication of charges was not waived, in direct contradiction of this court’s binding precedent in United States v. Gladue, 67 M.J. 311 (C.A.A.F. 2009).
In accordance with a pretrial agreement, the appellee pleaded guilty at a general court-martial composed of a military judge alone to six specifications of failure to obey a lawful general order or regulation, seven specifications of dereliction of duty, one specification of larceny, and five specifications of unauthorized possession of documents relating to the national defense and failure to deliver said documents to the officer or employee of the United States entitled to receive them, in violation of Articles 92, 121, and 134. The charges related to the appellee’s mishandling of classified material. The adjudged sentence was confinement for 12 months, total forfeitures, reduction to E-2, and a bad-conduct discharge. The convening authority approved only 10 months of confinement (as an act of clemency unrelated to the terms of the pretrial agreement).
The appellee’s pretrial agreement included a provision by which the appellee waived all waivable motions. Waiver is the intentional relinquishment of a known right. Waiver is distinct from forfeiture, which is the failure to preserve an error. Making a timely objection preserves an error. Whether an error is preserved (by objection), forfeited (by failure to object), or waived (by intentional and knowing relinquishment) affects the entitlement to relief from the error. An appellant is entitled to relief from a preserved, non-harmless error. An appellant is also entitled to relief from a forfeited error upon showing that the error was plain, obvious, and prejudicial (the plain error test). However, an appellant is not entitled to relief for a waived error.
In United States v. Gladue, 67 M.J. 311 (C.A.A.F. 2009) – also an Air Force case – CAAF held that issues of multiplicity and unreasonable multiplication of charges may be waived in a pretrial agreement. Gladue affirms that the provision in the pretrial agreement in Chin that waived all waivable motions served to waive the issue of unreasonable multiplication of charges, meaning that the appellee was not entitled to any relief from this issue. However, despite the waiver, the AFCCA found that there was an unreasonable multiplication of charges and granted limited relief.
[E]ven after Gladue, this court’s statutory authority to affirm findings of guilty and any or all of the resultant sentence is limited to affirming only those that we find correct in law and fact and determine, on the basis of the entire record, should be approved. See Article 66(c), UCMJ. Because of the unreasonable multiplication of charges so plainly presented in this case, we elect to exercise our plenary, de novo power of review and have determined that not all of the findings of guilty should be approved. We recognize this is a significant departure from our consistent practice of declining to review, on appeal, issues that were waived at trial. This deviation from our past treatment and application of waiver is warranted by the facts of this case, as explained in the analysis that follows. We differentiate this case from those in which we have found waiver, in that the totality of the circumstances presented here convinces us that the charging scheme grossly exaggerates the appellant’s criminality. Under our broad Article 66(c) authority, we find that not all of the appellant’s convictions should be approved.
The certified issue challenges the CCA’s authority to take this action.
AFCCA erroneously declined to apply waiver to this case despite the clear and binding guidance from this Court.
Gladue clearly commands that when an appellant expressly waives multiplicity and unreasonable multiplication of charges, appellate review of those issues is extinguished.
Gov’t Br. at 12. Put differently, the Government asserts that the CCA had no authority to grant relief despite the waiver.
In this case, AFCCA properly exercised its Article 66(c), UCMJ, powers to evaluate the circumstances of appellee’s waiver to ensure it was knowing and voluntary. However, upon finding an affirmative waiver, AFCCA erred by substantively addressing this foreclosed issue.
Army Br. at 10 (emphasis added).
CCAs can assess the record and determine whether the findings and sentence “should be approved,” thus Article 66(c) empowers CCA’s to perform an appropriateness review of courts-martial findings and sentence.
In the event a CCA finds error, the CCA may disapprove a court-martial finding, even if the error does not rise to the level of requiring disapproval of the finding as a matter of law; e.g., in the context of trial errors in which doctrines applicable to issues of law, such as waiver, would preclude CCA action in the absence of the “should be approved” language of Article 66(c).
In a case referred to it, the Court of Criminal Appeals . . . may affirm only such findings of guilty, and the sentence or such part or amount of the sentence, as it finds correct in law and fact and determines, on the basis of the entire record, should be approved.
(emphasis added). CAAF has explained that the courts of criminal appeals have the inherent authority to determine, in the interest of justice, that a certain finding or sentence should not be approved. United States v. Claxton, 32 M.J. 159, 162 (C.M.A. 1991). They may “determine the circumstances, if any, under which [they] would apply waiver or forfeiture.” United States v. Quiroz, 55 M.J. 334, 338 (C.A.A.F. 2001). They may even “act to disapprove findings that are correct in law and fact.” United States v. Nerad, 69 M.J. 138, 147 (C.A.A.F. 2010).
A court of criminal appeals “may affirm only such findings of guilty, and the sentence or such part or amount of the sentence, as it finds correct in law and fact and determines, on the basis of the entire record, should be approved.” Article 66(c), UCMJ. An accused may waive such review under limited circumstances. See Article 61, UCMJ. However, such waiver may not be “compel[led], coerce[d], or induce[d].” Rule for Courts-Martial 1110(c). Further, “a term or condition in a pretrial agreement shall not be enforced if it deprives the accused of . . . the complete and effective exercise of post-trial and appellate rights,” Rule for Courts-Martial 705(c)(1)(B).
Appellee’s pretrial agreement did not waive appellate review and, even if it did, any such waiver would be invalid.
The facts of this case potentially present two separate questions: Whether there was an unreasonable multiplication of charges and whether the Court of Criminal Appeals was able to consider that issue despite the waiver in the pretrial agreement. The certification raises only the latter question, and the amended certified issue raises it only in the context of whether a court of criminal appeals is prevented from considering a waived issue as a matter of law. In particular, the amended certified issue removes the originally certified question of whether the Court of Criminal Appeals abused its discretion in considering the waived issue in this case.
When a court of criminal appeals disapproves findings that are correct in law and fact, as occurred here, this Court “accept[s] the CCA’s action unless in disapproving the findings the CCA clearly acted without regard to a legal standard or otherwise abused its discretion.” Nerad, 69 M.J. at 147. Yet in the amended certified issue the Judge Advocate General of the Air Force removed the question of whether the Court of Criminal Appeals abused its discretion in this case. The certified issue now questions only whether the Court of Criminal Appeals could disapprove the findings of guilt to the unreasonably multiplied charges, and not whether it should have done so under the facts of this case.
DSO Br. at 7-8 (emphases in original).
The fact that the certified issue was amended to remove any reference to whether the CCA abused its discretion in granting relief is a significant factor. If CAAF limits its review to that question, then it will only determine whether a CCA has the power to grant relief for a waived issue (and not whether the power was appropriately exercised in this case). The appellee in this case may well have received a totally undeserved windfall when the CCA granted relief for an unreasonable multiplication of charges despite the waiver provision in the pretrial agreement. However, the possible existence of such a windfall is not what the Government asked CAAF to review.
Our #5 Military Justice Story of 2015 was the trend towards narrow reading of the jurisdiction of the courts of criminal appeals. If CAAF finds that the Air Force CCA committed legal error in this case by using its Article 66(c) power to grant relief for a waived issue, it would continue that trend.

matches: v. v. v. v. v. v. v.


text:
Thank you for your interest in our online shop. The protection of your privacy is very important to us. Below we inform you in detail about the handling of your data.
You can visit our websites without providing any personal information. Each time a website is accessed, the web server only automatically saves a so-called server log file, which contains the name of the requested file, your IP address, date and time of access, transferred data volume and the requesting provider (access data) and documents the access.
This access data is evaluated exclusively for the purpose of ensuring trouble-free operation of the site and improving our services. Pursuant to Art. 6 para. 1 sentence 1 lit. f DSGVO, this serves to safeguard our predominantly legitimate interests in a correct presentation of our offer as part of a balancing of interests. All access data will be deleted at the latest seven days after the end of your page visit.
In the context of processing on our behalf, a third party provider provides us with the services of hosting and display of the website. This serves to safeguard our predominantly legitimate interests in a correct presentation of our offer within the framework of a weighing of interests. All data collected within the framework of the use of this website or in the forms provided for this purpose in the online shop as described below will be processed on its servers. Processing on other servers only takes place within the framework described here.
We collect personal data when you voluntarily provide us with it in connection with your order or when contacting us (e.g. via contact form or e-mail). Mandatory fields are marked as such, because in these cases we need the data to process the contract or to process your contact and you cannot send the order or contact without their information. Which data is collected can be seen from the respective input forms. We use the data provided by you pursuant to Art. 6 Para. 1 S. 1 lit. b DSGVO to process contracts and your enquiries. If you have given your consent to this in accordance with Art. 6 Para. 1 S. 1 lit. a DSGVO by deciding to open a customer account, we will use your data for the purpose of opening a customer account. After complete completion of the contract or deletion of your customer account, your data will be restricted for further processing and deleted at the end of the tax and commercial retention periods, unless you have expressly consented to further use of your data or we reserve the right to use more data, which is permitted by law and about which we inform you in this statement. The deletion of your customer account is possible at any time and can take place either by a message to the contact possibility described below or over a function intended for it in the customer account.
In order to fulfil the contract pursuant to Art. 6 Para. 1 S. 1 lit. b DSGVO, we pass on your data to the shipping company commissioned with the delivery, insofar as this is necessary for the delivery of ordered goods. Depending on which payment service provider you select in the ordering process, we will pass on the payment data collected for this purpose to the credit institution and payment service provider commissioned by us or to the selected payment service in order to process payments. In some cases, the selected payment service providers also collect this data themselves if you create an account there. In this case, you must register with the payment service provider using your access data during the ordering process. In this respect, the data protection declaration of the respective payment service provider shall apply.
If you subscribe to our newsletter, we will use the data required for this purpose or provided separately by you in order to send you our e-mail newsletter regularly on the basis of your consent pursuant to Art. 6 Para. 1 S. 1 lit. a DSGVO.
Unsubscribing from the newsletter is possible at any time and can be done either by sending a message to the contact person described below or via a link provided for this purpose in the newsletter. After you unsubscribe, we will delete your e-mail address unless you have expressly consented to the further use of your data or unless we reserve the right to use further data that is permitted by law and about which we inform you in this declaration.
If we receive your e-mail address in connection with the sale of a product or service and you have not objected to this, we reserve the right to send you regular offers for similar products to those already purchased from our range by e-mail on the basis of § 7 para. 3 UWG. This serves to protect our predominantly legitimate interests in an advertising approach to our customers within the framework of a weighing of interests.
You can object to this use of your e-mail address at any time by sending a message to the contact option described below or via a link provided for this purpose in the advertising mail, without incurring any costs other than the transmission costs according to the basic tariffs.
The newsletter is sent as part of a processing on our behalf by a service provider to whom we forward your e-mail address for this purpose.
This service provider is based in the USA and is certified under the EU-US Privacy Shield. A current certificate can be here can be seen. As a result of this agreement between the USA and the European Commission, the latter has established an adequate level of data protection for companies certified under the Privacy Shield.
Furthermore, we reserve the right to use your first and last name as well as your postal address for our own advertising purposes, e.g. to send you interesting offers and information about our products by letter post. This serves to safeguard our predominantly legitimate interests in advertising to our customers in accordance with Art. 6 Para. 1 S. 1 lit. f DSGVO within the scope of a weighing of interests.
The advertising mailings are provided within the scope of processing on our behalf by a service provider to whom we pass your data.
You can object to the storage and use of your data for these purposes at any time by sending a message to the contact person described below.
Klarna uses the information received on the statistical probability of non-payment for a balanced decision on the establishment, execution or termination of the contractual relationship.
You can revoke your consent at any time by sending a message to the contact data below. As a result, we may no longer be able to offer you certain payment options. You can revoke your consent to this use of your personal data at any time, even vis-à-vis Klarna.
The Trusted Shops Trustbadge is integrated on this website to display our Trusted Shops seal of approval and the possibly collected evaluations as well as to offer the Trusted Shops products to buyers after an order.
This serves to safeguard our predominantly legitimate interests in optimal marketing within the framework of a balancing of interests by enabling secure purchasing in accordance with Art. 6 para. 1 sentence 1 lit. f DSGVO. The Trustbadge and the services applied for thereby are an offer of the Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne. The trust badge is provided by a CDN provider (Content-Delivery-Network) as part of order processing. Trusted Shops GmbH also uses service providers from the USA. An adequate level of data protection is ensured. You can find further information on data protection at Trusted Shops GmbH at here.
When the trustbadge is called up, the web server automatically saves a so-called server log file, which also contains your IP address, the date and time of the call, the amount of data transferred and the requesting provider (access data) and documents the call. Individual access data is stored in a security database for the analysis of security vulnerabilities. The log files are automatically deleted 90 days after creation at the latest.
Further personal data are transferred to the Trusted Shops GmbH if you decide after conclusion of an order for the use of Trusted Shops products or have already registered for the use. The contractual agreement between you and Trusted Shops applies. For this an automatic collection of personal data from the order data takes place. Whether you as a buyer are already registered for a product use is automatically checked on the basis of a neutral parameter, the e-mail address hashed by cryptological one-way function. The e-mail address is converted to this hash value, which cannot be decrypted for Trusted Shops, before transmission. After checking for a match, the parameter is automatically deleted.
This is necessary for the fulfilment of our and Trusted Shops' predominantly legitimate interests in the provision of the buyer protection linked to the specific order and the transactional valuation services in accordance with Art. 6 Para. 1 S. 1 lit. f DSGVO. Further details, including objections, can be found in the Trusted Shops data protection declaration linked above and in the Trustbadge.
If cookies are not accepted, the functionality of our website may be restricted.
This website uses Google (Universal) Analytics for website analysis. The web analysis service is provided by Google Ireland Limited, a company incorporated and operated under Irish law with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland (www.google.de). This serves to safeguard our predominantly legitimate interests in an optimised presentation of our offer in accordance with Art. 6 para. 1 sentence 1 lit. f DSGVO within the scope of a weighing of interests. Google (Universal) Analytics uses methods that allow an analysis of the use of the website by you, such as cookies. The automatically collected information about your use of this website is usually transferred to a Google server in the USA and stored there. By activating IP anonymisation on this website, the IP address is shortened before transmission within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. The anonymous IP address transmitted by your browser as part of Google Analytics is not merged with other Google data. The data collected in this context will be deleted after the purpose and end of the use of Google Analytics by us.
Where information is transmitted to and stored by Google on servers located in the United States, the U.S. company Google LLC is certified under the EU-US Privacy Shield. A current certificate can be here can be seen. As a result of this agreement between the USA and the European Commission, the latter has established an adequate level of data protection for companies certified under the Privacy Shield.
As an alternative to the browser plugin, you can this link to prevent Google Analytics from collecting data from this website in the future. An opt-out cookie is stored on your end device. If you delete your cookies, you must click the link again.
We use Google Ads to advertise this website in Google search results and on third-party websites. When you visit our website, the so-called remarketing cookie is set by Google, which automatically enables interest-based advertising by means of a pseudonymous cookie ID and on the basis of the pages you visit. This serves to safeguard our predominantly legitimate interests in an optimal marketing of our website in accordance with Art. 6 Para. 1 S. 1 lit. f DSGVO within the scope of a weighing of interests. The data collected in this context will be deleted after the purpose and end of the use of Google Ads Remarketing by us.
Additional data processing will only take place if you have consented to Google linking your web and app browsing history to your Google Account and using information from your Google Account to personalize ads you see on the web. In this case, if you are logged in to Google during your visit to our website, Google will use your information in conjunction with Google Analytics data to create and define target audience lists for cross-device remarketing. Google will temporarily link your personal data with Google Analytics data in order to form target groups.
Google Ads is an offer from Google Ireland Limited, a company incorporated and operated under the laws of Ireland with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland (www.google.de).
Where information is transmitted to and stored by Google on servers located in the United States, the U.S. company Google LLC is certified under the EU-US Privacy Shield.
A current certificate can be here can be seen. As a result of this agreement between the USA and the European Commission, the latter has established an adequate level of data protection for companies certified under the Privacy Shield.
You can use the remarketing cookie via this link Deactivate You can also register at the Digital Advertising Alliance about the setting of cookies and make settings for this.
For the purpose of protection against misuse of our web forms and against spam, we use the Google reCAPTCHA service within the framework of some forms on this website. Google reCAPTCHA is an offer by Google Ireland Limited, a company incorporated and operated under the laws of Ireland and with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland. (www.google.de). By checking a manual entry, this service prevents automated software (so-called bots) from carrying out abusive activities on the website. In accordance with Art. 6 para. 1 sentence 1 lit. f DSGVO, this serves to safeguard our legitimate interests, which are predominant in the weighing of interests, in the protection of our website against misuse and in a trouble-free presentation of our online presence.
A reading or saving of personal data from the input fields of the respective form does not take place.
Our presence on social networks and platforms serves a better, active communication with our customers and prospective customers. There we inform about our products and current special offers.
When you visit our online presence in social media, your data may be automatically collected and stored for market research and advertising purposes. So-called user profiles are created from this data using pseudonyms. These can be used, for example, to place advertisements inside and outside the platforms that presumably correspond to your interests. For this purpose, cookies are usually used on your terminal device. The visitor behaviour and the interests of the users are stored in these cookies. Pursuant to Art. 6 para. 1 lit. f., this serves the following purpose DSGVO, the safeguarding of our predominantly legitimate interests in an optimised presentation of our offer and effective communication with customers and interested parties within the scope of a weighing of interests. If you are asked by the respective social media platform operators for their consent to data processing, e.g. with the help of a checkbox, the legal basis for data processing is Art. 6 Para. 1 lit. a DSGVO.
Insofar as the aforementioned social media platforms have their headquarters in the USA, the following applies: The European Commission has issued an adequacy decision for the USA. This goes back to the EU-US Privacy Shield. A current certificate for the respective company can be here can be seen.
The detailed information on the processing and use of the data by the providers on their pages as well as a contact option and your rights in this regard and setting options to protect your privacy, in particular opt-out options, please refer to the below linked data protection information of the providers. Should you need any help in this regard, please do not hesitate to contact us.
If you have given us your express consent to this during or after your order in accordance with Art. 6 Para. 1 S. 1 lit. a DSGVO, we will send your e-mail address to Trusted Shops GmbH, Subbelrather Str. 15c, 50823 Cologne (www.trustedshops.de), so that they can send you an evaluation reminder by e-mail.
This consent can be revoked at any time by sending a message to the contact option described below or directly to Trusted Shops.
If you have given us your express consent to this during or after your order in accordance with Art. 6 Para. 1 S. 1 lit. a DSGVO, we will send your e-mail address to Google Ireland Limited, Gordon House, Barrow Street Dublin 4, Ireland (https://google.de) so that they can send you an evaluation reminder by e-mail.
This consent may be revoked at any time by sending a message to the contact facility described below or directly to Google Ireland Limited.
the right, pursuant to Art. 17 DSGVO, to demand the deletion of your personal data stored by us, unless further processing is required.
the right to complain to a supervisory authority pursuant to Art. 77 DSGVO. As a rule, you can contact the supervisory authority at your usual place of residence or workplace or at our company headquarters.
If you have any questions regarding the collection, processing or use of your personal data, for information, correction, restriction or deletion of data as well as revocation of consents given or objection to a specific use of data, please contact us directly via the contact data in our imprint.
Insofar as we process personal data as described above in order to safeguard our predominantly legitimate interests as part of a weighing of interests, you may object to this processing with effect for the future. If the processing is carried out for direct marketing purposes, you may exercise this right at any time as described above. Insofar as processing is carried out for other purposes, you are only entitled to object if there are reasons arising from your particular situation.
After exercising your right of objection, we will not process your personal data further for these purposes unless we can prove compelling reasons for processing worthy of protection which outweigh your interests, rights and freedoms, or if the processing serves the assertion, exercise or defence of legal claims.

matches:
Art. 6
Art. 6
Art. 6
Art. 6
Art. 6
§ 7
Art. 6
Art. 6
Art. 6
Art. 6
Art. 6
Art. 6
Art. 6
Art. 6
Art. 6
Art. 6
Art. 17
Art. 77


text:
Herenz, P. H. Wex, A. Mangold, Q. Laffineur, I. V. Gorodetskaya, Z.L. Fleming, M. Panagi and F. Stratmann, CCN measurements at the Princess Elisabeth Antarctica Research station during three austral summers, Atmos. Chem. Phys., 19, 275-294, 2019.
Souverijns, N., A. Gossart, I. V. Gorodetskaya, S. Lhermitte, A. Mangold, Q. Laffineur, A. Delcloo and N. P. M. Van Lipzig, How does the ice sheet surface mass balance relate to snowfall? Insights from a ground-based precipitation radar in East Antarctica, The Cryosphere, 12, 1987-2003, 2018.
Gossart, A., N. Souverijns, I. V. Gorodetskaya, S. Lhermitte, J. T. M. Lenaerts, J. H. Schween, A. Mangold, Q. Laffineur, N. P. M. Van Lipzig, Blowing snow detection from ground-based ceilometers: application to East Antarctica, The Cryosphere 11, 2755-2772, doi.org/10.519/tc-11-2755-2017, 2017.
Gorodetskaya, I.V., Kneifel, S., Maahn, M., Van Tricht, K., Thiery, W., Schween, J.H., Mangold, A., Crewell, S., Van Lipzig, N.P.M., Cloud and precipitation properties from ground-based remote-sensing instruments in East Antarctica, The Cryosphere, 9, 285-304, 2015.
Mangold, A., Q. Laffineur, A. Delcloo, C. Hermans, F. Hendrick, A. Gossart, N. Souverijns, P. Herenz, H. Wex, N. Van Lipzig and H. De Backer, Aerosol variability linked to clouds and precipitation in the Sor Rondane area, POLAR2018, SCAR/IASC Open Science Conference, Davos, Switzerland, 19-23 June 2018.
Herenz, P., H. Wex, A. Mangold, Q. Laffineur, I. V. Gorodetskaya, Z.L. Fleming, M. Panagi and F. Stratmann, Aerosol and CCN properties and sources in East Antarctica during austral summer, POLAR2018, SCAR/IASC Open Science Conference, Davos, Switzerland, 19-23 June 2018.
Souverijns, N., A. Gossart, S. Lhermitte, I. V. Gorodetskaya, S. Kneifel, M. Maahn, F. L. Bliven, A. Mangold, Q. Laffineur, A. Delcloo and N. P. M. Van Lipzig, Snowfall rate retrieval and its relation with the Antarctic surface mass balance, European Geosciences Union General Assembly 2018, Abstract EGU2018-12630, 8-13 April 2018, Vienna, Austria, 2018.
Mangold, A., Q. Laffineur, H. De Backer, A. Delcloo, P. Herenz, H. Wex, A. Gossart, N. Souverijns, I. Gorodetskaya, N. Van Lipzig, CCN and aerosol properties at Princess Elisabeth station, East Antarctica, combined with cloud and precipitation observations and air mass origin, European Geosciences Union General Assembly 2017, 23 - 28 April 2017, Vienna, Austria.
Mangold, A., Andy Delcloo, Veerle De Bock, Measurements of the aerosol composition of the Brussels sub-urban atmosphere and implications for the emission scheme of a regional chemical transport model, 6th International symposium on ultrafine particles, Air quality and climate, 10-11 May 2017, Brussels, Belgium.
Mangold, A., Aerosol-cloud-precipitation interaction at Princess Elisabeth station in the perspective of climate research, Conference of the Belgian National Committee for Geodesy and Geophysics, 12 May 2017, Brussels, Belgium.
Mangold, A., Atmospheric aerosol at Princess Elisabeth station, East Antarctica: what those tiny particles can tell us about the Antarctica atmosphere, Conference of the Belgian National Committee for Geodesy and Geophysics, 21 May 2015, Brussels, Belgium.
Mangold, A., Q. Laffineur, R. Van Malderen, C. Hermans, K. Nys, M. Verbruggen and H. De Backer, Total ozone, UV and radio sounding measurements in the Sør Rondane Mountains, POLAR2018, SCAR/IASC Open Science Conference, Davos, Switzerland, 19-23 June 2018.
Souverijns, N., Gossart, A., Lhermitte, S., Gorodetskaya, I.V., Kneifel, S., Maahn, M., Bliven, F.L., Mangold, A., Laffineur, Q., Delcloo, A., and van Lipzig, N.P.M. (2018) Snowfall Rate Retrieval and its Relation with the Antarctic Surface Mass Balance, Polar 2018, Davos, Switzerland, 18-26 June 2018.
Mangold, A., Q. Laffineur, H. De Backer, V. De Bock, A. Delcloo, C. Hermans, C. Gielen, P. Herenz, and H. Wex, Atmospheric aerosol and CCN properties in Dronning Maud Land, East Antarctica, European Aerosol Conference 2017, Zürich, Switzerland, Abstract T205N2a2, 2017.
Herenz, P., Wex, H., Mangold, A. and F. Stratmann, CCN measurements at the Princess Elisabeth Antarctica Research station, 20th International Conference on Nucleation and Atmospheric Aerosols, 25-30 June 2017, Helsinki, Finland.
Mangold, A., Laffineur, Q., Van Malderen, R., De Bock, V., Hermans, C., Nys, K. and H. De Backer, Analysis of total ozone and UV radiation and of vertical profile measurements of temperature, humidity and wind data at Princess Elisabeth Station, East Antarctica, BNCGG-BNCAR Symposium, Unlocking a continent: Scientific research at the Belgian Princess Elisabeth Station Antarctica 2008-2016, 29 April 2016, Brussels, Belgium.
Mangold, A., De Backer, H., De Bock, V., Delcloo, A., Hermans, C., Gorodetskaya, I., Herenz, P., Henning, S. and H. Wex, Atmospheric aerosol properties at Princess Elisabeth station, East Antarctica,: seasonality and indication of new particle formation, European Aerosol Conference 2015, 6-11 September 2015, Milan, Italy.
Herenz. P., Mangold, A., Wex, H., Rubach, F. and F. Stratmann, CCN measurements in the Arctic and Antarctic, European Geosciences Union General Assembly 2015, 12-17 April 2015, Vienna, Austria.
Mangold, A., 'Klima, Klimawandel, Treibhauseffekt', explaining to school children (13-14years and 17-19 years) of a technical secondary school (Robert Schuman Institute, Eupen) the topics of climate, climate change, greenhouse gas effect, 28 January 2016, Eupen, Belgium.
Mangold, A., L’Antarctique, le pôle Sud et la Belgique, explaining to school children of the Ecole Communale de Linkebeek (BE) what Antarctica is, why research is done there and what are the conditions for work and life, 28 May 2015 (7-8 years), 18 June 2015 (5-6 years), Linkebeek, Belgium.

matches: V. V. V. V. V. V.