Chalet Laetitia in Meribel has been reduced from £1,139 per person to £699 per person. The deal is for a catered, seven-night stay starting 9 February and Gatwick flights and transfers are included. The chalet has a private hot tub, sauna and cinema room.
Chalet Hepatica in La Plagne also comes up with a hefty discount, down from £1,230 per person to £649 per person. Price includes Gatwick flights, transfers and chalet catering for 7 nights, also departing on the 9 February. It's in Plagne Soleil, 100m from the nearest piste and has a private sauna and outdoor hot tub.


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text:
The Prairie, by J. Fenimore Cooper
"The Prairie" was the third in order of Fenimore Cooper's Leatherstocking Tales. Its first appearance was in the year 1827. The idea of the story had suggested itself to him, we are told, before he had finished its immediate forerunner, "The Last of the Mohicans." He chose entirely new scenes for it, "resolved to cross the Mississippi and wander over the desolate wastes of the remote Western prairies." He had been taking every chance that came of making a personal acquaintance with the Indian chiefs of the western tribes who were to be encountered about this period on their way in the frequent Indian embassies to Washington. "He saw much to command his admiration," says Mrs. Cooper, "in these wild braves... It was a matter of course that in drawing Indian character he should dwell on the better traits of the picture, rather than on the coarser and more revolting though more common points. Like West, he could see the Apollo in the young Mohawk."
Source: The Prairie By J. Fenimore Cooper, available at Preject Gutenberg
List of articles in category The Prairie, by J. Fenimore Cooper
The Prairie: Chapter 10	 Written by J. Fenimore Cooper	 Hits: 1360

redpajama_set_name: RedPajamaCommonCrawl


The allocation for the agriculture sector in the proposed budget for fiscal year (FY) 2018-19 has declined further.
As per the proposed budget, the allocation for the farm sector has dropped to 2.99 per cent from 3.40 per cent in FY 2017-18, a decrease of 0.41 per cent.
The allocation was 6.39 per cent in FY '14 while 4.95 per cent in FY '15, 4.47 per cent in FY '16 and 3.78 per cent in FY '17.
For FY '19, the government has allocated Tk 139 billion for the agriculture ministry.
According to the Ministry of Agriculture (MoA) data, the contribution of the sector to the Gross Domestic Product (GDP) has also been declining.
The sector's contribution to the country's GDP (constant price and base year FY 2005-06) came down to 14.11 per cent in FY '18 from 14.72 per cent in FY '17.
The growth of the sub-sector (crops and vegetables) was less than 1.0 per cent in the outgoing fiscal year in terms of the GDP.
Expressing their concern, experts said expenditure on the farm sector should be raised for the sake of food security.
Professorial Fellow at Bangladesh Institute of Development Studies (BIDS) Md Asaduzzaman said the crop sector saw its growth rate declining due to two spells of floods last year.
Floods caused severe damage to paddy and the production of vegetables also affected.
The government had to import 3.95 million tonnes of rice worth US$ 1.6 billion this fiscal year due to a plunge in its production, he said.
"Output in the current Boro season is good, but the farmers are not getting even their production costs."
The farmers should receive more compensation this fiscal year as they lost everything to the two spell of floods.
Mr. Asaduzzaman said the allocation farmers should be increased to help ensure food security in the country.
Centre for Policy Dialogue (CPD) director (research) Khandoker Golam Moazzem said more than 2.5 million farmers switched to other professions from agriculture in the last five years, finding it non-profitable.
Both subsidy and allocation for the agriculture sector have been declining in terms of the country's GDP and total budget, he said.
The government should raise the allocation for farmers to encourage them to stick to agriculture, he added.
He said the fisheries and livestock sector showed better performance in the last few years.
The government should also provide incentives to fisheries, poultry and cattle farmers to boost output, he added.


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Needed for webdesign and playin CS competatively Is getting slower by the day!
Im putting it down to viruses. Ive go Sophos Anti-Virus which apparently is very good? All i see it do is tell me i have 37 viruses on my computer.
I have Search and Destroy. Which, when i run i get 50 pop ups telling me acess was denied to a virus file.. I dont want to view it ffs.. I wanna delete it!
And ive got: Lavasoft Ad-Aware.
So why do i still have 37 viruses on my comp after i scan!.. Ive got some pretty serious one tbh.. I wouldnt be suprised if they were steeling bandwidth and sending out more viruses or something like that?
Also Other that viruses, How do i check if i have the right drivers installed on my computer? I keep downloadin songs and alot of them wont play sound. This never happened my bro's computer so i dont think its the .mp3's. Also photoshop brushes are lagging something terrible. You would think i have the 'Flow' option set to 20..
As chow says you're riddled with viruses, with that amount plus all the spyware best to save all u want to save, format and start again. if u have space partition the drive with partition magic, copy over all files u want to save (music,personal files) from your c drive to your new partition this way youre music will be saved on youre partition and u can format your c drive and start.
Next Kazaa imho DONT USE IT. the fasttrack network is riddled with viruses.
K, Ill talk to you on MSN But i dont wanna waste your time by getting rid of al the viruses then getting them back again in a month.. I dont thikn i have a firewall other than 'The one on my router' So says my brother..
As for re-formating.. It has taken me over a year to get this computer to not blue screen a week after format.. So i dont trust harddrives at all anymore.. and It would cost me alot of money in the long run if it blue screened again. It shouldnt I know but it did for about 4 months straight..
You should use a firewall that can block out going traffic from your comp like zone alarm. Also start scaning what you download with a virus scanner before you use it.
I still think you should post a hijackthis log as a lot of nasty spyware etc......is missed by the programs because its hidden or they dont know what to look for.


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Sir TapTap » Articles » Alex Mauer Debacle: The DMCA Abuse That Is (and Isn't) Possible on Youtube
Alex Mauer Debacle: The DMCA Abuse That Is (and Isn't) Possible on Youtube
Author Sir TapTapPosted on 2017-07-20 Categories ArticlesTags copyright, dmca, harassment, youtube
So YouTube has a DMCA problem. We all knew this, since the DMCA itself sucks and YouTube doesn't have the best track record regarding copyright. But what do you need to know if you're affected? What's the long and short of it?
Editor's Note: I don't have an editor.
Sir TapTap's Note: If I did have an editor, they'd probably note that I've already written an extensive timeline on the Alex Mauer DMCA Debacle here, so if you don't know what that is or wish to learn more, start there. This article is mostly about YouTube's process and it's problems and solutions, not the Alex case itself.
What's the Problem, Chief?
YouTube's DMCA Process
A Counter-Notified Strike Is Toothless
Youtube Allows Abuse of Multiple Emails and Retractions
Real Channel Takedowns Are Extremely Unlikely
This Whole Thing Sucks
YouTube's DMCA/Copyright Strike system is being abused by Alex Mauer.
That's bad.
But Alex Mauer's Starr Mazer DMCAs were reversed en masse.
Alex changed to harassing players of a different game and more importantly this sort of abuse could be engendered by almost anyone.
But Counter Notifications can largely reverse harm by harassing parties!
The Counter Notice contains potassium benzoate (and also expose your real address to a potentially harassing party).
So how does Youtube's DMCA process, also known as "Copyright Strikes" all work?
First, I'd like to clear up that YouTube's Copyright Strike system is a DMCA-compliant system. A lot of people say it's a "fake" DMCA and thus more exploitable, and thus also not carrying penalty of perjury.
That's not true; YouTube's Copyright Complaint Form actually specifically mentions that submissions are verified by submitting party under penalty of perjury, and more importantly if they weren't "real" DMCA takedowns, YouTube's system wouldn't qualify for Safe Harbor protections.
It may just be a web form, but it is a crime to abuse this form.
So, once Youtube gets a DMCA complaint and confirms it is a legitimate complaint (no, they are not required to take down everything if anyone asks—it has to be valid) a channel is "struck".
Note that YouTube does not have the best record of preventing malicious actors from filing DMCA claims that are spurious, despite their ability any duty to reject them. In fact, Alex Mauer was (briefly) stopped by YouTube's copyright office…until they dropped the ball again a few days later.
Now once a channel is "struck" it will force the user to go through "copyright school", a condescending video tutorial and brief multiple choice test before you can use your account again at all. Fortunately it's a pathetically easy test and is mostly just patronizing garbage.
Once you've "passed" said test, you can use your channel almost normally provided only one "strike" has occurred. The claimed video will be unavailable indefinitely, and certain restrictions will be placed on your account. You can't create a new Paid Channel. If the claimed video was a livestream or stream archive you will completely lose the ability to livestream. If the claimed video was an upload, you will lose features related to uploading such as the ability to upload videos longer than 15 minutes.
Even if no action is taken on your behalf, most of these restrictions will automatically expire after 90 days if no action is taken, though the video will remain down.
However you can also issue a Counter Notice from the Copyright Notices page; what this means is that you assert your belief that the claim is illegitimate and/or your use of the material is entirely within the law. For this process you must submit a brief statement as to why you believe this and provide your legal name and address.
The first thing you need to know is counter notified strikes cannot take down your channel. The DMCA process is really, really bad, but you are not irreparably harmed the instant they're filed on YouTube.
Counter Notifying is basically saying to Youtube "hey, this is not legitimate, this a-hole will either have to sue me or f-off into the sun".
Once the Counter Notice is received and approved by YouTube, it goes to the claimant. The claimant has 10 business days to provide evidence to YouTube that they are taking legal action against you; if they cannot, the claim will expire, your video goes back up, and restrictions on your account are removed even if the 90 days are not up.
Since Alex Mauer's claims are fraudulent and she has no capacity (or legal standing) to sue, her claims can be safely Counter Noticed and they will (and have been) removed once the 10 days are up.
The legal address and name aspect is a bit of a conundrum though; you'll have to decide what matters more to you; keeping the video up/fighting the illegal claim/keeping your channel's features, or exposing your address to a harassing party.
Thissucks, and the awful DMCA law is mostly at fault (to a lesser extent as is YouTube for not more thoroughly rejecting illegal claims), but it's the present reality of the situation.
Personally I won't concede to terrorists, so I counter notified to show I won't be cowed, but I fully respect anyone who considers it not worth it as well.
There's a hitch in this system though, one so bad it caused me to write all this.
Alex's early threats claimed that three strikes from her DMCA claims would disable a YouTube channel; YouTube doesn't quite work like that. YouTube does have a Three Strikes, You're Out rule, but multiple copyright claims from the same source only ever count as one "strike", whether one video is claimed or a thousand. You have to be hit by three different accounts (usually companies) for your channel to be in mortal danger.
What's the hitch then? Somewhere along the line Alex realized her bluff wasn't working, and that she'd need to actually hit channels from multiple sources in order to take down channels. So she did. And YouTube let her.
Alex made at least two (almost certainly three) total emails and thus YouTube accounts to file her claims separately, and specifically targeted YouTube accounts with three or more videos that fit the criteria of her illegal DMCA claims, stating her intent was to take down channels (oops, guess this WASN'T just about taking control of her music, huh!).
This way, even though she was only one claimant, she could abuse the system to trigger YouTube's Three Strikes rule which is specifically designed to prevent this.
In addition, Alex retracted her initial DMCA claims before they expired, and was then allowed to re-file claims on the same videos. It seems that any video for which the 10 days hadn't expired was still vulnerable to this retract-and-resend abuse.
Using these two forms of abuse, she successfully took down Starr Mazer's YouTube channel for less than 24 hours, though an unknown amount of other channels may have been affected. Over 100+ DMCA claims were admitted by Alex herself, but only a small handful of those affected (like me!) have publicly addressed the issue.
Both of these actions by Mauer are blatant exploits in YouTube's system itself, not a DMCA problem. YouTube should immediately address these issues and shoulders the full blame for allowing these particular harassment vectors. Using multiple emails to evade a ban is also against YouTube's terms of service, and apparently by retracting claims she was able to wipe counter notices and refile as if counter notices were never issued.
While the fake multi-outlet scamming is incredibly disgusting, petty, offensive, a violation of Youtube's Terms of Service, and downright criminal harassment, it's still not a free ticket even for someone as unscrupulous as Alex Mauer.
Worst case, you just reflile a counter notice, that way your timer is 10 business days instead of 90 days. And even if she does hit you with all three accounts, she still can't destroy your account completely.
You see, even if you fall afoul of Youtube's "Three Strikes" rule, you have 7 days to file counter notices. Again, so long as you counter-notify all incoming strikes, your channel cannot be taken down without real, legal action by the harassing party. Your channel will be "down" in the front end (just like videos are from single strikes), but nothing should be lost once the Counter Notice time expires and no action is taken against you.
This is no get-out-of-jail-free card from legitimate claims of course either; a large company you've actually infringed upon will quite likely actually be willing to enact legal action against you. But if you are sure they will not/cannot sue or are willing to take it to court, a counter notification is fairly safe.
In the end, every party but the YouTuber is partially at fault here; Alex Mauer is committing perjury and sending illegal claims. The DMCA is enabling her harassment and provides no direct vectors to stop her, and also most of the bad things YouTube does they have to do because of this law. YouTube is allowing their own system to be gamed by malicious actors and not screening verified frauds from future DMCA notices on the same videos they were previously found to be fraudulently claiming.
In a perfect world, Alex Mauer should be in jail for perjury, YouTube would plug the holes in their abusable system, and the DMCA would be struck down or massively reworked to fit the modern reality of the Internet (and more generally, to remove it's absurd, downright offensive Guilty-Until-Proven-Innocent nature that is an affront to American law).
The courts (civil, criminal, or both) will have to take care of Mauer, but YouTube and the law itself still must be addressed. If you have contacts in YouTube, pressure them. Start a hashtag campaign. Slide into their mentions (politely). Do what you can to make them realize this is not a small issue, let them know by name what channels are affected if your favorite YouTuber is suffering from all this. Remember this is not a problem that starts or ends with Mauer.
YouTube's necessary solutions are threefold: First, retracting a DMCA claim should permanently flag that video and claimant pair in a way that makes repeating a DMCA for purposes of harassment ineffective.
Second, a claimant using the same exact name claiming the same exact content should NOT be able to do so from multiple accounts! Internet Abuse 101 here.
Third, once a known fraud is identified (as Alex Mauer was), the entire Copyright office should be made known of it and their emails should be flagged properly so brute force is not an effective way to slip by once a malign actor is identified.
Finally, the DMCA itself is a big part of this problem. If you're an American citizen, contact your representatives letting them know this is a real issue. People's jobs, hobbies, lives, are being harmed here. The law is an ancient relic as far as practicality is concerned and needs a major overhaul.
You can find and contact your reps easily with Democracy.io or find their contact information with House.gov or Senate.gov to leave a call.
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Author: Sir TapTap
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Epicosymbia albivertex är en fjärilsart som beskrevs av Swinhoe 1892. Epicosymbia albivertex ingår i släktet Epicosymbia och familjen mätare. Inga underarter finns listade i Catalogue of Life.

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Home Anti-Corruption Bureaux De Change Involved in $2.1bn Arms Scandal will not be Spared...
Bureaux De Change Involved in $2.1bn Arms Scandal will not be Spared -Magu
Wilson Uwujaren
Ibrahim Magu of EFCC
Acting Chairman of Economic and Financial Crimes Commission, Ibrahim Magu, has said that no Bureau De Change operator involved in the ongoing $2.1bn arms deal probe will be spared.
Magu, who was speaking during a courtesy call to his office in Abuja by Bureau De Change operators on Tuesday, January 5, 2015, also re-iterated the existing mutual relationship between the Commission and the group in the areas of sensitisation and training.
According to him, "My operatives often tell me what they see during investigations. We need to talk to you, as some of your operators are fond of carrying huge amounts of money out of the country, since they can no longer withdraw more than $300 using the ATM.
''There are fraudulent involvements of Bureau De Change operators in the arms deal scandal. There are reports of some of your members withdrawing as much as N500million in two, three, four tranches in this arms deal scam. So, I am greatly disturbed. I think there should be a documentation regarding your activities, as this will enable your group to checkmate anyone who is involved in any fraudulent activity."
Earlier, the Chairman of Bureau De Change operators, Alhaji Aminu Gwadabe, had expressed the resolve of the group to join hands with the Commission in the ongoing war against corruption and economic crimes.
Gwadabe said the delegation was in the Commission to congratulate Magu and seek collaboration with the EFCC.
"I want to congratulate you on your appointment as acting Chairman of EFCC and pray for God's guidance, most especially as it is a period of tough choices and decisions," he said.
He also highlighted some major challenges that the Bureau De Change operators were facing from policy regulators and security agencies.
Gwadabe decried the activities of black marketers who, according to him, had been giving the licensed operators a bad name.''Most of the time, fraud is perpetrated within the banking premises. However, whenever there is an issue, it is the Bureau De Change operators who are usually attacked. Another problem is the issue of BVN registration, which I believe should have been extended to three years in order to allow more people to be registered", he said.
He, therefore, urged the Commission to organise seminars, workshop and sensitization programmes, as part of efforts to improve the knowledge of the operators.
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US 10th Cir./
UNITED STATES v. McCANE
UNITED STATES v. McCANE (2009)
United States Court of Appeals,Tenth Circuit.
UNITED STATES of America, Plaintiff-Appellee, v. Markice Lavert McCANE, Defendant-Appellant.
No. 08-6235.
Decided: July 28, 2009
Before MURPHY, ANDERSON, and TYMKOVICH, Circuit Judges. William H. Campbell, Campbell Law Office, Oklahoma City, OK, for Defendant-Appellant. Edward J. Kumiega, Assistant United States Attorney (John C. Richter, United States Attorney, with him on the briefs), Oklahoma City, OK, for Plaintiff-Appellee.
I. INTRODUCTION
In April 2007, Defendant-Appellant Markice McCane was stopped for a suspected traffic violation by an Oklahoma City police officer. After determining McCane was driving under a suspended license, the officer arrested McCane, handcuffed him, and placed him in the back seat of the patrol car. The officer then conducted a search of the passenger compartment of the vehicle and discovered a firearm in the pocket of the driver's side door. McCane was charged with being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). McCane filed a motion to suppress the firearm as fruit of an unlawful search. The district court denied the motion, concluding the search was properly undertaken as incident to a lawful arrest. While the case was pending on appeal, the United States Supreme Court issued its decision in Arizona v. Gant, --- U.S. ----, 129 S.Ct. 1710, 173 L.Ed.2d 485 (2009). In Gant, the Court concluded a vehicle search is not valid as incident to a lawful arrest when a defendant is stopped for a traffic violation and handcuffed in the back of the patrol car at the time of the search. Id. at 1719. In light of Gant, the district court erred in concluding the search was valid as incident to a lawful arrest. Exercising jurisdiction pursuant to 28 U.S.C. § 1291, we nevertheless affirm the district court's denial of the motion to suppress based upon the good-faith exception to the exclusionary rule.
II. BACKGROUND
On April 18, 2007, Officer Aaron Ulman of the Oklahoma City Police Department was patrolling his precinct when he observed a vehicle traveling eastbound on a four-lane thoroughfare. The vehicle was straddling the center line of the two eastbound lanes. After following the vehicle for approximately three blocks, Officer Ulman decided to conduct a traffic stop based upon his belief the driver was violating state traffic law and his suspicion the driver was intoxicated. After pulling the vehicle over to the side of the road, Officer Ulman approached the vehicle and asked the driver, later identified as McCane, for his license and insurance information. A passenger, Joseph Carr, was also in the vehicle.
After McCane informed him that his license was suspended, Officer Ulman asked McCane to exit the vehicle and accompany him to the patrol car. McCane complied, and Carr remained in the front seat of the vehicle. Upon exiting the vehicle, McCane left the driver's door open, and the door remained open for the duration of the stop. Officer Ulman conducted a pat-down search of McCane and placed him in the back seat of the patrol car. Officer Ulman then conducted a records check, which indicated McCane's license was suspended and the vehicle was not registered to McCane. At that time, Officer Ulman arrested McCane for driving with a suspended license, placed him in handcuffs, and again placed him in the back seat of the patrol car. After requesting dispatch to contact a wrecker service to tow the vehicle, Officer Ulman asked Carr to exit the vehicle and sit in the back seat of the patrol car along with McCane. Carr did so, and Officer Ulman then searched the passenger compartment of the car.
During the search, Ulman discovered a .25 caliber firearm hidden under a rag in the side pocket of the open door. The firearm was loaded with a magazine containing seven rounds of ammunition. Officer Ulman removed the firearm from the vehicle and took it back to the patrol car in order to secure it. The patrol car was parked directly behind McCane's vehicle. According to Officer Ulman, when McCane saw the firearm he stated, "I forgot that was even there." Officer Ulman then advised McCane of his Miranda rights (Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966)), and McCane did not make any additional statements. After the vehicle was impounded, Carr was released, and McCane was transported to the police station for booking.
McCane was charged with being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). Before the district court, McCane filed motions to suppress the firearm and exclude his alleged inculpatory statement. The district court denied these motions, concluding the statement was made voluntarily and the search of McCane's vehicle did not violate the Fourth Amendment because it was properly undertaken as a search incident to lawful arrest. Following a jury trial, McCane was found guilty of the charged offense. McCane then appealed to this court alleging: (1) the district court erred in denying his pretrial motions to suppress the evidence stemming from the search of his vehicle; (2) insufficient evidence existed from which to convict him of the offense; and (3) the felon in possession statute at 18 U.S.C. § 922(g)(1) is unconstitutional in light of the Supreme Court's decision in District of Columbia v. Heller, --- U.S. ----, 128 S.Ct. 2783, 171 L.Ed.2d 637 (2008).
While the case was pending before this court, the Supreme Court issued its decision in Arizona v. Gant. --- U.S. ----, 129 S.Ct. 1710, 173 L.Ed.2d 485. On facts almost identical to the facts of this case, the Supreme Court held that the search-incident-to-lawful-arrest exception to the warrant requirement of the Fourth Amendment is not applicable when a defendant has been arrested for a traffic violation and remains handcuffed in the back of a patrol car while the search is conducted. Id. at 1719. After noting that lower courts have widely upheld searches "in this precise factual scenario," the Court stated that an officer may "search a vehicle incident to a recent occupant's arrest only when the arrestee is unsecured and within reaching distance of the passenger compartment at the time of the search" or when it is "reasonable to believe evidence relevant to the crime of arrest might be found in the vehicle." Id. at 1718-19 (quotations omitted).
The parties agree that, in light of Gant, the district court erred in denying the motion to suppress the firearm on the grounds that the search was proper as incident to lawful arrest. The parties disagree, however, as to whether the district court's denial of the motion to suppress can be affirmed on an alternative ground. Thus, the issues now before the court are: (1) whether the district court's denial of the motion to suppress the firearm may be affirmed based upon the good-faith exception to the exclusionary rule or the inevitable discovery doctrine, (2) whether sufficient evidence existed on which to convict McCane, and (3) whether 18 U.S.C. § 922(g) is constitutional.1
III. DISCUSSION
A. Motion to Suppress
This court may affirm the district court on any basis supported by the record. Kellogg v. Metro. Life Ins. Co., 549 F.3d 818, 825 (10th Cir.2008). As an alternative ground for affirming the district court's decision to deny the motion to suppress the firearm as fruit of an unlawful search, the government claims that Officer Ulman reasonably relied upon settled pre-Gant Tenth Circuit case law, and the good-faith exception to the exclusionary rule should be extended to this search.2 To prevail on this alternative ground, the government must establish that the search of the vehicle was supported by extant Tenth Circuit precedent and that the principle of deterrence underlying the exclusionary rule is not undermined.
1. Pre-Gant Tenth Circuit Precedent
The Supreme Court in Gant expressed concern that its precedent, New York v. Belton, 453 U.S. 454, 101 S.Ct. 2860, 69 L.Ed.2d 768 (1981), was being generally applied far beyond the underlying justifications for warrantless vehicle searches incident to arrest of a recent occupant, i.e., officer safety and preservation of evidence. Gant, 129 S.Ct. at 1718-19. It observed that Belton "has been widely understood to allow a vehicle search incident to the arrest of a recent occupant even if there is no possibility the arrestee could gain access to the vehicle at the time of the search." Id. at 1718. Tenth Circuit precedent anteceding Gant was not an exception.
The decision in United States v. Humphrey, 208 F.3d 1190 (10th Cir.2000), is exemplary of this circuit's precedent and is factually indistinguishable from the instant case. In Humphrey, the defendant was stopped for a traffic violation, arrested on the basis of an outstanding warrant, and handcuffed in the patrol car at the time of the search of his vehicle. See id. at 1202. The defendant's arguments that neither officer safety nor preservation of evidence were in play were to no avail. Id. This court held the search was proper "without regard to the fact that the search occurred after Defendant had been restrained and without regard to the nature of the offense for which he was arrested." Id. (citation omitted). Other circuit opinions are consistent with Humphrey.3 United States v. Brothers, 438 F.3d 1068, 1073 (10th Cir.2006) (upholding search undertaken incident to lawful arrest after the defendant had been restrained, but before the defendant was removed from the scene of the arrest) 4 ; United States v. Cotton, 751 F.2d 1146, 1148-49 (10th Cir.1985); United States v. Murphy, 221 Fed.Appx. 715, 721-22 (10th Cir.2007) (unpublished disposition). The search in this case was wholly consistent with and supported by this court's precedent prior to Gant.
2. Application of the Good-Faith Exception to the Exclusionary Rule
"The Fourth Amendment protects the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, but contains no provision expressly precluding the use of evidence obtained in violation of its commands." Herring v. United States, ---U.S. ----, 129 S.Ct. 695, 699, 172 L.Ed.2d 496 (2009) (quotations omitted). There is, however, the judicially created exclusionary rule which, when applied, excludes evidence obtained in violation of the Fourth Amendment from being used at trial. Id. The exclusionary "rule is designed to safeguard Fourth Amendment rights generally through its deterrent effect." Id. (quotation omitted). "The fact that a Fourth Amendment violation occurred-i.e., that a search or arrest was unreasonable-does not necessarily mean that the exclusionary rule applies." Id. at 700.
"The exclusionary rule is not an individual right and applies only where it results in appreciable deterrence." Id. (quotations omitted). Because the purpose of the exclusionary rule is to deter police misconduct, United States v. Leon, 468 U.S. 897, 906, 104 S.Ct. 3405, 82 L.Ed.2d 677 (1984), in determining whether to apply the rule the court is to weigh the benefits of the resulting deterrence against the costs of applying the rule. Herring, 129 S.Ct. at 700. "The principal cost of applying the rule is, of course, letting guilty and possibly dangerous defendants go free-something that offends basic concepts of the criminal justice system." Id. at 701 (quotation omitted). Consequently, "[t]he rule's costly toll upon truth-seeking and law enforcement objectives presents a high obstacle for those urging its application." Id. (quotation omitted).
Various principles have been established to limit the application of the exclusionary rule. Id. at 700. One such principle is the good-faith exception. Id. at 701. In Leon, the Supreme Court established the good-faith exception to the exclusionary rule, declining to apply the exclusionary rule when police reasonably and in good faith relied upon a warrant subsequently declared invalid. 468 U.S. at 922, 104 S.Ct. 3405. The Court, relying on the deterrent purpose of the exclusionary rule, determined it was improper to apply the rule in this context, explaining:
First, the exclusionary rule is designed to deter police misconduct rather than to punish the errors of judges and magistrates. Second, there exists no evidence suggesting that judges and magistrates are inclined to ignore or subvert the Fourth Amendment or that lawlessness among these actors requires application of the extreme sanction of exclusion. [ ] Third, and most important, we discern no basis, and are offered none, for believing that exclusion of evidence seized pursuant to a warrant will have a significant deterrent effect on the issuing judge or magistrate․ Judges and magistrates are not adjuncts to the law enforcement team; as neutral judicial officers, they have no stake in the outcome of particular criminal prosecutions. The threat of exclusion thus cannot be expected significantly to deter them.
Id. at 916-17 (footnote omitted). The Court concluded the exclusionary rule "cannot be expected, and should not be applied, to deter objectively reasonable law enforcement activity." Id. at 919.
In Illinois v. Krull, the Court extended the good-faith exception to warrantless administrative searches performed in reliance upon a statute later declared unconstitutional. 480 U.S. 340, 349-53, 107 S.Ct. 1160, 94 L.Ed.2d 364 (1987). The Court first explained that applying the exclusionary rule in this situation would have little deterrent effect on the officer's actions, stating:
Unless a statute is clearly unconstitutional, an officer cannot be expected to question the judgment of the legislature that passed the law. If the statute is subsequently declared unconstitutional, excluding evidence obtained pursuant to it prior to such a judicial declaration will not deter future Fourth Amendment violations by an officer who has simply fulfilled his responsibility to enforce the statute as written. To paraphrase the Court's comment in Leon: Penalizing the officer for the legislature's error, rather than his own, cannot logically contribute to the deterrence of Fourth Amendment violations.
Id. at 349-50, 107 S.Ct. 1160 (quotation omitted). The Court then noted that the exclusionary rule was aimed at deterring misconduct on the part of police, not legislators. Id. at 350, 107 S.Ct. 1160. To the extent consideration of the deterrent effect upon legislators was appropriate, however, the initial inquiry was whether there was "evidence to suggest that legislators are inclined to ignore or subvert the Fourth Amendment." Id. (quotation omitted). In answering this question in the negative, the Court stated that, "[a]lthough legislators are not neutral judicial officers, as are judges and magistrates, neither are they adjuncts to the law enforcement team." Id. at 350-51, 107 S.Ct. 1160 (citation and quotation omitted). In enacting laws to carry out the criminal justice system, "legislators' deliberations of necessity are significantly different from the hurried judgment of a law enforcement officer engaged in the often competitive enterprise of ferreting out crime." Id. at 351, 107 S.Ct. 1160 (quotation omitted). Finally, the Court noted that even if it were to conclude that legislators were distinguishable from officers of the judicial system, there was "no reason to believe that applying the exclusionary rule will have [a deterrent] effect. Legislators enact statutes for broad, programmatic purposes, not for the purpose of procuring evidence in particular criminal investigations." Id. at 352, 107 S.Ct. 1160.
The Court next extended the good-faith exception to police reliance upon mistaken information in a court's database indicating an arrest warrant was outstanding. Arizona v. Evans, 514 U.S. 1, 14-16, 115 S.Ct. 1185, 131 L.Ed.2d 34 (1995). In Evans, the Court explained that the mistake of a judicial employee would not justify exclusion of evidence for three reasons: (1) the exclusionary rule was established to deter police misconduct, not the conduct of court employees; (2) there was no evidence court employees were likely to "ignore or subvert the Fourth Amendment"; and (3) there was no basis for believing application of the exclusionary rule would deter the conduct at issue since "court clerks are not adjuncts to the law enforcement team engaged in the often competitive enterprise of ferreting out crime, they have no stake in the outcome of particular criminal prosecutions." Id. at 14-15, 115 S.Ct. 1185 (citation omitted).
Finally, in its recent good-faith decision, Herring, the Court extended the good-faith exception to police reliance upon the negligent mistake of a fellow law enforcement employee, as opposed to a neutral third party. 129 S.Ct. at 704. In Herring, the court applied the good-faith exception where, in making an arrest, police relied upon a record-keeping error in the police computer database indicating there was an active warrant for the arrestee. Id. at 698, 702-04. In discussing the principles of the exclusionary rule, the Court stated that "[t]he extent to which the exclusionary rule is justified by [ ] deterrence principles varies with the culpability of the law enforcement conduct." Id. at 701. Thus, "assessment of the flagrancy of the police misconduct constitutes an important step in the calculus of applying the exclusionary rule." Id. (quotation omitted).
The Court went on to explain that "evidence should be suppressed only if it can be said that the law enforcement officer had knowledge, or may properly be charged with knowledge, that the search was unconstitutional under the Fourth Amendment." Id. (quotations omitted). As such, "the [past] abuses that gave rise to the exclusionary rule featured intentional conduct that was patently unconstitutional." Id. at 702. The Court concluded the conduct at issue did not rise to this level, clarifying that the good-faith inquiry "is confined to the objectively ascertainable question whether a reasonably well trained officer would have known that the search was illegal in light of all of the circumstances." Id. at 703 (quotations omitted).
Two inseparable principles have emerged from the Supreme Court cases and each builds upon the underlying purpose of the exclusionary rule: deterrence. First, the exclusionary rule seeks to deter objectively unreasonable police conduct, i.e., conduct which an officer knows or should know violates the Fourth Amendment. See, e.g., Herring, 129 S.Ct. at 701-04; Krull, 480 U.S. at 348-49, 107 S.Ct. 1160. Second, the purpose of the exclusionary rule is to deter misconduct by law enforcement officers, not other entities, and even if it was appropriate to consider the deterrent effect of the exclusionary rule on other institutions, there would be no significant deterrent effect in excluding evidence based upon the mistakes of those uninvolved in or attenuated from law enforcement. See, e.g., Evans, 514 U.S. at 14-15, 115 S.Ct. 1185; Krull, 480 U.S. at 351-52, 107 S.Ct. 1160; Leon, 468 U.S. at 916-17, 104 S.Ct. 3405. Based upon these principles, we agree with the government that it would be proper for this court to apply the good-faith exception to a search justified under the settled case law of a United States Court of Appeals, but later rendered unconstitutional by a Supreme Court decision.
Just as there is no misconduct on the part of a law enforcement officer who reasonably relies upon the mistake of a court employee in entering data, Evans, 514 U.S. at 15, 115 S.Ct. 1185, or the mistake of a legislature in passing a statute later determined to be unconstitutional, Krull, 480 U.S. at 349-50, 107 S.Ct. 1160, a police officer who undertakes a search in reasonable reliance upon the settled case law of a United States Court of Appeals, even though the search is later deemed invalid by Supreme Court decision, has not engaged in misconduct.5 The refrain in Leon and the succession of Supreme Court good-faith cases is that the exclusionary rule should not be applied to "objectively reasonable law enforcement activity." 486 U.S. at 919, 108 S.Ct. 2218. Relying upon the settled case law of a United States Court of Appeals certainly qualifies as objectively reasonable law enforcement behavior.
The Supreme Court's line of good-faith cases clearly indicates that the reach of the exclusionary rule does not extend beyond police conduct to punish the mistakes of others, be they judicial officers or employees, or even legislators. Evans, 514 U.S. at 14, 115 S.Ct. 1185 ("[T]he exclusionary rule was historically designed as a means of deterring police misconduct, not mistakes by court employees."); Krull, 480 U.S. at 350, 107 S.Ct. 1160 ("We noted in Leon as an initial matter that the exclusionary rule was aimed at deterring police misconduct. Thus, legislators, like judicial officers, are not the focus of the rule." (citation omitted)); Leon, 468 U.S. at 916, 104 S.Ct. 3405 ("[T]he exclusionary rule is designed to deter police misconduct rather than to punish the errors of judges and magistrates."). In the case of judicial officers, the Supreme Court has stated that "there exists no evidence suggesting that judges and magistrates are inclined to ignore or subvert the Fourth Amendment or that lawlessness among these actors requires application of the extreme sanction of exclusion." Leon, 468 U.S. at 916, 104 S.Ct. 3430. Thus there is no basis for believing that excluding evidence resulting from an error of the court will "have a significant deterrent effect on the issuing judge[s]." Id. Courts are neutral arbiters charged with interpreting the law, and have "no stake in the outcome of particular criminal prosecutions." Id. at 917, 104 S.Ct. 3430. Consequently, excluding evidence based on judicial error would serve no deterrent purpose. The Supreme Court has consistently relied upon the deterrent purpose of the exclusionary rule in deciding the scope of the good-faith exception. The Court has declined to apply the exclusionary rule when no deterrent effect would result from its application. Consistent with this practice, this court declines to apply the exclusionary rule when law enforcement officers act in objectively reasonable reliance upon the settled case law of a United States Court of Appeals.6 The good-faith exception to the exclusionary rule applies in this case. The district court therefore properly denied the motion to suppress.7
B. Sufficiency of the Evidence
This court reviews de novo the sufficiency of the evidence, "ask[ing] only whether taking the evidence-both direct and circumstantial, together with the reasonable inferences to be drawn therefrom-in the light most favorable to the government, a reasonable jury could find the defendant guilty beyond a reasonable doubt." United States v. Brown, 400 F.3d 1242, 1247 (10th Cir.2005) (quotation omitted). This court does not "assess the credibility of witnesses or weigh conflicting evidence ․ [and] may reverse only if no rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt." Id. (quotation omitted). "In order to obtain a conviction against [a defendant] under § 922(g), the government was required to prove that [the defendant] had previously been convicted of a felony, [the defendant] thereafter knowingly possessed a firearm, and such possession was in or affected interstate commerce." United States v. Michel, 446 F.3d 1122, 1128 (10th Cir.2006).
McCane claims there was insufficient evidence from which the jury could find he had possession of the firearm. Possession of a firearm for purposes of 18 U.S.C. § 922(g)(1) can be either actual or constructive. Id. "Actual possession exists when a person has direct physical control over a firearm at a given time." United States v. Jameson, 478 F.3d 1204, 1209 (10th Cir.2007). "Constructive possession exists when a person knowingly holds the power and ability to exercise dominion and control over a firearm." Id. (quotation omitted).
"When a defendant has exclusive possession of the premises on which a firearm is found, knowledge, dominion, and control can be properly inferred because of the exclusive possession alone." Id. However, "[i]n cases of joint occupancy, where the government seeks to prove constructive possession by circumstantial evidence, it must present evidence to show some connection or nexus between the defendant and the firearm." Michel, 446 F.3d at 1128 (quotation omitted). "Proximity alone [ ] is insufficient to establish knowledge and access to (and dominion and control over) a firearm in a joint occupancy case." Jameson, 478 F.3d at 1209. "But when combined with other evidence in the case linking the defendant to the firearm, proximity is material and probative evidence that may be considered in deciding whether a defendant had knowledge of and access to (and dominion and control over) the [firearm]." Id. "[A]n inference of constructive possession is reasonable if the conclusion flows from logical and probabilistic reasoning." Michel, 446 F.3d at 1128-29 (quotation omitted).
Officer Ulman testified that the firearm was located in the side pocket of the driver's door, "within inches of reach [of McCane] whenever the door [was] shut." In addition to his testimony regarding the proximity of the firearm to McCane, Officer Ulman testified that upon seeing the firearm, McCane stated, "I forgot that was even there." While McCane argues Officer Ulman was not a credible witness because he was "trying to save his felony arrest and obtain a conviction predicated on his actions," it was well within the discretion of the jury to credit Officer Ulman's testimony and this court will not assess the credibility of a witness on appeal. United States v. Winder, 557 F.3d 1129, 1137 (10th Cir.2009). McCane's statement, together with the proximity of the firearm, supports the conclusion that McCane had knowledge of the firearm as well as the power and ability to exercise dominion and control over it. See United States v. Hooks, 551 F.3d 1205, 1213 (10th Cir.2009) (concluding defendant's inculpatory statements along with other evidence regarding his earlier behavior and proximity to the firearm provided sufficient evidence from which a jury could find constructive possession of a firearm discovered beside a road). Thus, there existed sufficient evidence from which the jury could infer McCane's constructive possession of the firearm.
C. The Constitutionality of 18 U.S.C. § 922(g)
McCane first argues that in light of the Supreme Court's decision in Heller, in which the Court held that the Second Amendment provides an individual with a right to possess and use a handgun for lawful purposes within the home, 128 S.Ct. at 2822, § 922(g) violates the Second Amendment. The Supreme Court, however, explicitly stated in Heller that "nothing in our opinion should be taken to cast doubt on longstanding prohibitions on the possession of firearms by felons." 128 S.Ct. at 2816-17; see also United States v. Anderson, 559 F.3d 348, 352 & n. 6 (5th Cir.2009) (rejecting the argument that § 922(g) is unconstitutional in light of Heller ).
McCane next argues § 922(g) violates the Commerce Clause where, as here, the crime's only connection to interstate commerce is the firearm's crossing of state lines. This argument also lacks merit, as it has been explicitly rejected by this court. See, e.g., United States v. Urbano, 563 F.3d 1150, 1154 (10th Cir.2009) (rejecting Commerce Clause challenge to § 922(g) based upon the alleged insufficient connection to interstate commerce and stating "if a firearm has traveled across state lines, the minimal nexus with interstate commerce is met and the statute can be constitutionally applied"); United States v. Bolton, 68 F.3d 396, 400 (10th Cir.1995) (concluding "[§ ] 922(g)'s requirement that the firearm have been, at some time, in interstate commerce is sufficient to establish its constitutionality under the Commerce Clause" (quotation omitted)). Thus, we reject each of McCane's arguments challenging the constitutionality of § 922(g).
IV. CONCLUSION
For the reasons discussed above, we affirm the decision of the district court 8 .
I join in Judge Murphy's cogent opinion, but write separately regarding certain issues raised by our Second Amendment holding.
District of Columbia v. Heller instructs that it not be taken "to cast doubt on longstanding prohibitions on the possession of firearms by felons." --- U.S. ----, 128 S.Ct. 2783, 2816-17, 171 L.Ed.2d 637 (2008). This instruction, as McCane points out, is dictum. But Supreme Court dicta binds us "almost as firmly as ․ the Court's outright holdings." Surefoot LC v. Sure Foot Corp., 531 F.3d 1236, 1243 (10th Cir.2008) (quoting Gaylor v. United States, 74 F.3d 214, 217 (10th Cir.1996)). This is particularly so where, as here, the dictum is recent and not enfeebled by later statements. See id.; see also Carlton F.W. Larson, Four Exceptions in Search of a Theory: District of Columbia v. Heller and Judicial Ipse Dixit, 60 Hastings L.J. 1371, 1372 (2009) ("Although [Heller's ] exceptions are arguably dicta, they are dicta of the strongest sort."). I therefore concur with the majority in rejecting McCane's Second Amendment challenge.
I write separately, though, for two reasons. The first is to note, given the undeveloped history of felon dispossession laws, the possible tension between Heller's dictum and its underlying holding. The second reason is to express concern that the dictum inhibits lower courts from exploring the contours of Heller and its application to firearm restrictions.
My first point is that the felon dispossession dictum may lack the "longstanding" historical basis that Heller ascribes to it. Indeed, the scope of what Heller describes as "longstanding prohibitions on the possession of firearms by felons," 128 S.Ct. at 2816-17, is far from clear. To be sure, some sources would support the proposition. See Robert Dowlut, The Right to Arms: Does the Constitution or the Predilection of Judges Reign?, 36 Okla. L.Rev. 65, 96 (1983) ("Colonial and English societies of the eighteenth century ․ excluded ․ felons [from possessing firearms]."); Don B. Kates, Jr., Handgun Prohibition and the Original Meaning of the Second Amendment, 82 Mich. L.Rev. 203, 266 (1983) ("Founders [did not] consider felons within the common law right to arms.").
But more recent authorities have not found evidence of longstanding dispossession laws. On the contrary, a number have specifically argued such laws did not exist and have questioned the sources relied upon by the earlier authorities. See, e.g., Larson, supra, at 1374 (finding Kates's evidence of longstanding felon dispossession "surprisingly thin"); C. Kevin Marshall, Why Can't Martha Stewart Have a Gun?, 32 Harv. J.L. & Pub. Pol'y 695, 709-10, 714 (2009) (challenging the evidence cited by both Dowlut and Kates).1 Instead, they assert, the weight of historical evidence suggests felon dispossession laws are creatures of the twentieth-rather than the eighteenth-century. See, e.g., Marshall, supra, at 698-713 (comprehensively reviewing the history of state and federal dispossession laws); Larson, supra, at 1374 ("[S]o far as I can determine, no colonial or state law in eighteenth-century America formally restricted the ability of felons to own firearms."); Adam Winkler, Heller's Catch 22, 56 UCLA L.Rev. 1551, 1561, 1563 (2009) (same). Together these authorities cast doubt on a categorical approach to felon dispossession laws.
This uncertain historical evidence is problematic in light of Heller's Second Amendment interpretation. Central to the Court's holding are a detailed textual analysis and a comprehensive review of the Second Amendment's meaning at the time of its adoption. Heller, 128 S.Ct. at 2788-816. After conducting this analysis and review, Heller concludes the right "to keep and bear arms" is a corollary to the individual right of self-defense. E.g., id. at 2817 ("[T]he inherent right of self-defense has been central to the Second Amendment right."). At the "core" of the Second Amendment right, the Court found, is self-defense in the home. Id. at 2818.
Knowing the meaning of the Second Amendment right and having identified its individual nature, the issue becomes what limits the government may place on the right. Indeed, this is where the Second Amendment rubber meets the road. The restrictive firearm ownership and licensing laws at issue in Heller violated the right, the Court found. Id. at 2817-21. But what about other laws? For example, the broad scope of 18 U.S.C. § 922(g)(1)-which permanently disqualifies all felons from possessing firearms-would conflict with the "core" self-defense right embodied in the Second Amendment. Non-violent felons, for example, certainly have the same right to self-defense in their homes as non-felons. The validity of § 922(g)(1) was not at issue in Heller, so presumably the lower courts would be left to sort out this restriction-as well as other restrictions-and to wrestle with any complexities in applying Heller. But the issue was not really left to the lower courts.
In what could be described as the opinion's deus ex machina dicta, Heller simply declared that nothing in it "cast[s] doubt on longstanding prohibitions on the possession of firearms by felons" or various other gun control laws. 128 S.Ct. at 2816-17. And that was it. These provisions, and the various regulations they encompassed, were supported without any explanation of how they would fare in light of the Second Amendment's original meaning. See id. at 2827 (Stevens, J., dissenting); id. at 2869-70 (Breyer, J., dissenting).2 The reason the Court inserted these exceptions is unclear. Given the uncertain pedigree of felon dispossession laws, though, the dictum sanctioning their application while simultaneously sidestepping the Second Amendment's original meaning is odd. One wonders, at least with regard to felon dispossession, whether the Heller dictum has swallowed the Heller rule.
Heller's felon dispossession dictum is particularly noteworthy considering the scope of the § 922(g)(1) ban. The statute prohibits firearm possession by any person convicted of a felony, irrespective of the nature of the felony, the length of time elapsed since the felony conviction, and the treatment of the felony by the state in which the felon resides. Every individual right has exceptions, of course, and the application of § 922(g) to a violent felon such as Mr. McCane would appear appropriate under any Second Amendment reading. After all, felons lose out on fundamental rights such as voting and serving on juries, and face discrimination that need only survive rational basis review. The question may be less clear, however, where the underlying felony is non-violent, such as financial fraud, perjury, or misleading federal investigators. But § 922(g)(1) encompasses these (and other) non-violent felons as well, permanently restricting their Second Amendment right to self-defense.
This brings me to my second point. The Court's summary treatment of felon dispossession in dictum forecloses the possibility of a more sophisticated interpretation of § 922(g)(1)'s scope. Applying Heller's individual right holding to various regulations would be complicated, and it is of course possible (if not probable) that different courts would articulate different standards. Already a number of commentators have considered and proposed approaches to the existing gun laws and the proper level of constitutional scrutiny. See, e.g., Eugene Volokh, Implementing the Right to Keep and Bear Arms for Self-Defense: An Analytical Framework and a Research Agenda, 56 UCLA L.Rev. 1443 (2009); Marshall, supra, at 728-31; Larson, supra, at 1379-1382. But the existence of on-point dicta regarding various regulations short-circuits at least some of the analysis and refinement that would otherwise take place in the lower courts. In this case, for example, we need not address the standard of review applicable to gun dispossession laws-strict scrutiny, intermediate, rational basis, or something else-or the examination of the governmental interests in light of the standard of review.3
Rather than seriously wrestling with how to apply this new Second Amendment rule, therefore, courts will continue to simply reference the applicable Heller dictum and move on. And in light of the Supreme Court's clear direction, this is perhaps how it should be. After all, "our job as a federal appellate court is to follow the Supreme Court's directions, not pick and choose among them as if ordering from a menu." Surefoot LC, 531 F.3d at 1243. I nevertheless wonder whether Second Amendment law would have been better served if the regulations Heller addressed in dicta had been left to later cases.
1. McCane makes a number of additional arguments in his opening brief which do not merit further analysis. First, McCane appears to argue that because Officer Ulman was not a credible witness, McCane's alleged inculpatory statement should have been suppressed and the initial traffic stop should not have been upheld. The determination of credibility, however, is within the province of the district court, and it was well within the district court's discretion to credit the testimony of Officer Ulman. United States v. Kimoana, 383 F.3d 1215, 1220 (10th Cir.2004). Second, McCane argues that probable cause, not reasonable suspicion, must exist in order for an officer to conduct a stop for a perceived traffic violation. This argument is foreclosed by circuit precedent. United States v. Vazquez, 555 F.3d 923, 928 (10th Cir.2009) ("A traffic stop is permissible under the Fourth Amendment if the officer has a reasonable articulable suspicion that a traffic violation has occurred or is occurring." (quotation omitted)).
2. The Supreme Court has indicated that in applying the good-faith exception to the exclusionary rule, "the standard of reasonableness [ ] is an objective one; the standard does not turn on the subjective good faith of individual officers." Illinois v. Krull, 480 U.S. 340, 355, 107 S.Ct. 1160, 94 L.Ed.2d 364 (1987).
3. Contrary to McCane's assertion, the decision in United States v. Edwards, 242 F.3d 928, 937-38 (10th Cir.2001), does not hold otherwise. In Edwards, this court concluded a search could not be justified as incident to lawful arrest because the arrestee had not been in the vehicle, and thus the contents of the vehicle could not have been in his immediate control, during the relevant time period preceding the arrest. Id. at 938. The court explained that because the defendant was 100-150 feet away from the car at the time he was arrested, there was no evidence that he had control over the vehicle immediately prior to or at the time of his arrest. Id. The time for a proper search incident to arrest had passed by the time he was handcuffed and placed in the police car 100-150 feet away from his vehicle. Id. The instant case is different: there is no dispute McCane was in his car during the relevant time period preceding the stop and arrest.
4. In United States v. Lugo, the defendant was in a moving police car en route to the police station at the time the vehicle was searched. 978 F.2d 631, 635 (10th Cir.1992). Because the search occurred after the defendant had left the scene, it was too remote in time and place from the arrest to constitute a search incident to lawful arrest. Id.See also United States v. Dennison, 410 F.3d 1203, 1209 (10th Cir.2005). In the instant case, there is no dispute McCane was still at the scene of the arrest when the search occurred.
5. McCane argues the retroactivity rule announced in Griffith v. Kentucky, 479 U.S. 314, 322-23, 107 S.Ct. 708, 93 L.Ed.2d 649 (1987), requires application of the Supreme Court's holding in Gant to this case. The issue before us, however, is not whether the Court's ruling in Gant applies to this case, it is instead a question of the proper remedy upon application of Gant to this case. In Leon, the Supreme Court considered the tension between the retroactive application of Fourth Amendment decisions to pending cases and the good-faith exception to the exclusionary rule, stating that retroactivity in this context "has been assessed largely in terms of the contribution retroactivity might make to the deterrence of police misconduct." 468 U.S. at 897, 912-13, 104 S.Ct. 3405. The lack of deterrence likely to result from excluding evidence from searches done in good-faith reliance upon settled circuit precedent indicates the good-faith exception should apply in this context. See Krull, 480 U.S. at 360, 107 S.Ct. 1160 (declining to apply a court decision declaring a statute unconstitutional to a case pending at the time the decision was rendered and instead applying the good-faith exception to the exclusionary rule because the officer reasonably relied upon the statute in conducting the search).
6. We note that in United States v. 15324 County Highway E., the Seventh Circuit declined to uphold a search based upon good-faith reliance on Seventh Circuit precedent later overturned by a Supreme Court decision, and instead upheld the search based upon the officer's good-faith reliance on a validly issued search warrant. 332 F.3d 1070, 1075-76 (7th Cir.2003). In declining to extend the good-faith rule to reliance on circuit case law, the court reasoned that "[s]uch expansion of the good-faith exception would have undesirable, unintended consequences, principal among them being an implicit invitation to officers in the field to engage in the tasks-better left to the judiciary and members of the bar more generally-of legal research and analysis." Id. at 1076. In the instant case, the Tenth Circuit jurisprudence supporting the search was settled. Thus, there was no risk that law enforcement officers would engage in the type of complex legal research and analysis better left to the judiciary and members of the bar.
7. Because we uphold the search as valid under the good-faith doctrine, we need not decide whether the denial of McCane's motion to suppress could be affirmed based upon the inevitable discovery doctrine.
8. Appellant's motion to strike Appellee's Notice of Supplemental Authority is denied.
1. While Mr. Kates does not address this evidence specifically, he maintains "there is ample historical support for excluding [felons] from the right to arms: Nations which accepted the right to arms invariably extended that right only to virtuous citizens; and at common law felons were 'civilly dead,' having lost all rights including the right to possess property of any kind." Don B. Kates, A Modern Historiography of the Second Amendment, 56 UCLA L.Rev. 1211, 1231 n. 100 (2009).
2. In one sense, Heller did overturn Tenth Circuit case law on this issue. Previously, we upheld the felon-in-possession statute against Second Amendment attack under a collective-rights theory-i.e., that felons have no right to possess firearms that are not reasonably connected to military service. See, e.g., United States v. Baer, 235 F.3d 561, 564 (10th Cir.2000) (holding that the felon-in-possession statute does not violate the Second Amendment "absent evidence that [the firearms in question] in any way affect the maintenance of a well regulated militia"); see generally David B. Kopel, The Second Amendment in the Tenth Circuit: Three Decades of (Mostly) Harmless Error, 86 Denv. U.L.Rev. 901 (2009). The Heller dictum, however, affirms the ultimate disposition-i.e., that the Second Amendment does not protect a felon's right to possess firearms.
3. By my count, at least six other circuits have rejected post-Heller challenges to the 18 U.S.C. § 922(g)(1) felon dispossession statute. Almost all these decisions cursorily cite the Heller dictum, and almost all are unpublished. See, e.g., United States v. Anderson, 559 F.3d 348, 352 n. 6 (5th Cir.2009); United States v. Brye, 318 Fed.Appx. 878, 879 (11th Cir.2009) (unpublished); United States v. Frazier, 314 Fed.Appx. 801, 807 (6th Cir.2008) (unpublished); United States v. Brunson, 292 Fed.Appx. 259, 261 (4th Cir.2008) (unpublished); United States v. Gilbert, 286 Fed.Appx. 383, 386 (9th Cir.2008) (unpublished); United States v. Irish, 285 Fed.Appx. 326, 327 (8th Cir.2008) (unpublished).
MURPHY, Circuit Judge.


text:
Supplied by Erick Laming
Topics: Justice | Interview
Indigenous researcher on where police funds should go instead
Erick Laming, from the Shabot Obaadjiwan First Nation, on how to prevent individuals from going through the criminal justice system
|  October 14, 2020
This interview is the last in a six-part series about rethinking the police.
Today, Indigenous people in Canada represent about three percent of the population, yet they comprise a staggering one third of inmates in jails and prisons across the country. It has become increasingly clear that racism in policing is at the core of these alarming statistics.
Erick Laming is from the Shabot Obaadjiwan First Nation, and a PhD candidate in criminology and sociolegal studies at the University of Toronto. His dissertation looks at police use of force in Ontario and its impact on Black and Indigenous community members.
Laming spoke with Albina Retyunskikh from his home in Toronto.
Albina Retyunskikh: What is the current situation in regards to policing Black and Indigenous communities?
Erick Laming: Well, it's not a good point in time right now, and honestly it really hasn't been for a long time. Things are just more exposed in the media. We have more videos, more people coming forward, and more cases. This is just highlighting the issues between police and marginalized communities.
AR: Where do you think police funds would be better invested?
EL: That money can go towards lots of different types of community organizations. Obviously, we need to be looking at mental health, and having professions be part of the process in responding to a lot of these calls. One of the issues today is that there are inconsistent and incomplete reports about how police respond to calls when people are having a mental health episode. So we have to be really transparent and understand how often police respond to these types of calls, because quite often this is where they use force. And most of the time, these are cases when we don't need a police response.
We can prevent individuals from going through the criminal justice process if we have trained mental health professionals who can appropriately respond to them. If somebody is having an emotional episode, we need people to just to talk to them and a lot of times that can de-escalate that situation without needing any support or backup from an armed officer.
If you get arrested, you remain stuck in the system; it's a cycle that keeps repeating itself. We have problems that the police can't solve, and we shouldn't expect them to solve them either. We need leadership from our governments to identify and recognize these issues, to do something about them. Police are not able to deal with these cases, and they shouldn't be expected to.
AR: Can you talk about some specific programs that can prevent people falling into the criminal justice system?
EL: One is called the Bear Clan Patrol, an organization that started in Winnipeg in the '90s, and resurfaced over the last few years. There's been over 35 communities that have adopted this type of program. They're essentially Indigenous-led initiatives where a group of volunteer Indigenous peoples and some other non-Indigenous community members will go around to certain communities that have usually have issues with the police. They will pick up needles on the ground, and give food away to people who can't afford it or who are struggling. They're also just there to talk to the community members because at the end of the day, that's what a lot of these members want. They don't want to deal with police if they're having an issue, they might just need somebody to talk to.
In a serious case, the patrol would call the police, and the police would respond to a violent situation. But again, this is a volunteer organization that is starting to get a little bit more support in terms of resources and financing. This is where money could be going. We need to have more of these types of programs to expand across Canada in urban areas where Indigenous peoples are forgotten about. And not just Indigenous community members: you could look at other marginalized communities and have this type of program or volunteer initiatives that do these things.
AR: Racial profiling is a big issue when police stop Black people. Is that an issue in Indigenous communities as well?
EL: From evidence we have, yes. We have street checks and we know that Black and Indigenous people in many cities are stopped and searched and targeted, and they're more overrepresented in these statistics compared to white people. And sadly, we don't really know their lived experiences. In my research, I've been able to interview a lot of community members. They are constantly targeted or harassed, and it really breaks down that trust.
Another issue is that there's a lot of talk about hiring more First Nations or Indigenous police officers. You could try that, but the evidence doesn't really suggest that diversifying the police force is going to change anything. Because a lot of the time, it's a cultural kind of influx that happens once you get into the policing subculture.
But then you can look at other areas, like reserves, for example, where we have standalone First Nations police services where most of those officers are from that community. They're Indigenous, so they can actually handle what goes on in those communities much more effectively than a white police officer. Many white police officers don't know what these people go through. They might be trained well, but training can only go so far. You have to be able to put yourself in those shoes. A lot of times, police officers lose patience, or even get scared in the situation, and that can escalate a situation very quickly.
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AR: Looking at what has been happening for the last few of months in the wake of George Floyd's death, how do you think recent events are changing the way that we approach these conversations? Do you think change is possible?
EL: I'm trying to be hopeful. As a researcher, it's hard…I'm just skeptical by nature. These are just issues that have been around for so long. The exact same thing that happened to George Floyd happened to Eric Garner in 2014. There were protests, and outrage, and at the end they implemented body cameras. But the situation didn't really change. Now, at least, the issue is not confined to the U.S., and we see a global movement.
We need to keep having those conversations and the public needs to be part of this process and keep demanding that change. I don't think we will see change overnight, and we have to be patient with it. Furthermore, a lot of the people from the communities I speak to have complained about the police, and those complaints are often deemed unsubstantiated and they're thrown out. So it pushes the trust away even more, not just in relation to the police, but in the system in general.
So yes, there's a lot of voices we need to start listening to. If we do that, we can at least say we're trying, we're doing something positive, but if we keep ignoring those voices, or not including them, then we're just going to keep repeating this cycle. The police really need to be open and start seeing the problem, instead of pretending like there are no issues here.
This interview has been condensed and edited.
Albina Retyunskikh is a writer based in Montreal.
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Jocelyn Bell
WG Nathaniel says: October 27, 2020
Thank you for your thoughts. Have you spent anytime in the front seat of patrol car in a mid to large Canadian city? I think if you spent say 3 shifts a month for a year that would be the minimum prerequisite to test your thesis. Your academic research and the veracity of your thesis would carry much more authority with me if it included this first hand experience.
Just a thought from a retired police chaplain and a current prison chaplain.
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Last September, as part of our partnership with the AMRC, we arranged for a number of digital companies to visit Factory 2050 to hear about their work and have a tour of the facility.
The aim was to help people working in digital to get a feel for how digital is being applied in advanced manufacturing and to think about how they might develop products or services for manufacturers.
How do manufacturing businesses work?
After the visit, many people mentioned that they would like the opportunity to find out more about what goes on in a manufacturing business so that they could better see what the opportunities were for digital solutions.
In response to this feedback, the Sheffield Innovation Programme has designed a two-day workshop to meet that need. It is completely free to attend and is being offered to the Sheffield Digital community first before it goes out to wider distribution.
The workshop is free to attend for digital businesses based in Sheffield City Region. It takes place on the 8th and 15th of March.
On the first day, the morning will consist of briefings from university experts on digitisation for manufacturing, the use of automation, robotics, simulation and digital modelling in manufacturing processes, and cyber-security and IoT optimisation. The afternoon will include two case studies from local manufacturers and a facilitated reflection session to allow delegates to discuss what they have learned during the day.
On the second, the morning will consist of a visit to Tinsley Bridge Ltd for a tour and networking lunch, followed by another facilitated session in the afternoon. In the evening, there will be a larger networking event bringing in more manufacturers and regional partners.
This intensive workshop is an excellent opportunity for people working in digital to broaden their understanding of the challenges faced by manufacturing, to think in depth about how digital can solve those challenges and to explore new business opportunities. We encourage you to book a space quickly.
If you can't make the workshop, you can still attend the networking event on the evening of 15th March. Contact Jayne Cupit (j.cupit@shu.ac.uk) at Sheffield Hallam University to request a place.
Update: Sheffield Innovation Programme are holding a related event at the Cutlers Hall in Sheffield on the 15th March. Juergen Maier, CEO of Siemens will be speaking, along with Mark Webber, MD of Tinsley Bridge Ltd and the Digital KTN.


text:
Upper Perk Football Looking for Improvement in 2013
The Upper Perk Indians football team got their first taste of action against another team on the field last Saturday with a scrimmage at home against Hatboro-Horsham. Above members of the offense gang up on a Hatters' ball carrier, halting his advance.
The upcoming 2013 football season has a completely different feel for head coach Steve Moyer and the rest of the Upper Perkiomen Indians.
Last year, Moyer was in his first year of guiding a new program. That led to a completely new teaching philosophy, changes to the offensive and defensive schemes and new terminologies.
Those growing pains led the team to a 0-10 finish overall, as the relatively young squad learned in a hurry the pace of varsity football.
This season, Moyer and company are hoping those hard lessons pay off.
"We're much further ahead this year than last," Moyer said. "The kids understand what we're trying to do; and we have known what we're doing since December –we're strides ahead in that regard."
Moyer hopes the biggest change in the team will be its toughness and attitude. And what the team lacks in terms of size and depth, Moyer hopes will be made up in pure grit and resolve.
"What I'm hoping will characterize the team would be its toughness," he said, "mentally and physically. We're not the biggest, so we need to be scrappy and not back down. If we can accomplish that, we're on the right track."
Upper Perk officially started its summer practices this past Monday, though voluntary workouts began last winter and continued throughout the spring and summer. This past Saturday, the team entertained Hatboro-Horsham in a scrimmage.
Moyer said the overall outcome of the scrimmage was positive, with the expected first-time mistakes of new varsity players. The team will travel tonight to J. Birney Crum Stadium in Allentown to take part in a tri-scrimmage with William Allen and Palisades high schools. The season will open a week after that at home against Quakertown Friday, Aug. 30 at 7 p.m.
Offensively, junior Wyatt Brumm will see his first varsity action at quarterback. He will be helped in the backfield by senior running back Aidan Schaffer, who rushed for over 1,000 yards last season, and senior fullback Randy Godshall.
Up front, the line will be anchored by centers Rico Marrero and Mitch Fretz, guards Mahlon Schaffer and David Weller, tackles Justin Crossley, Kyle Neumann and Nate Dunn and tight end Owen Leister. Wide receivers include senior Travis Kline, junior Jake Pirri, Chandler Carberry and Mark Saucedo.
Defensively, the team will be anchored at safety by Kline and Aidan Schaffer, with the linebacking corps consisting of Marrero, Leister, Chad Butler and Dylan Croissette. Up front, the line will feature Mahlon Schaffer, Dunn and Crossley, with Fretz, Weller and Jack Hovanec at ends. Pirri, Carberry and Mike Felix are expected to see action at cornerback.
The team will be led by its senior tri-captains Kline, Aidan Schaffer and Marrero.
"If we can be more physical, and play tougher, that should help us play better defense," Moyer said. "If we can do that, we will get better as a football team."
Besides improvements on defense, one of the other keys to the Indians' success will be its health. With a roster in the mid 50s, which includes the freshmen team which will play a JV schedule, Upper Perk doesn't have a whole lot of depth behind its starters. Any injuries would be especially significant as many players are expected to play on both sides of the ball.
"Our scrimmage was positive, and we liked our first week of two-a-days," Moyer said. "As far as what we can expect this year, I really don't know, there are a lot of guys who will see their first action.
"Our overall approach is good, and we've made changes offensively and defensively to make it simple enough but consistent to help the kids know what they're doing day in and day out."


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AMES, Iowa -- With the NCAA tournament just about a month away, teams are going to lean on their stars more than ever.
Iowa State standouts Melvin Ejim, DeAndre Kane and Georges Niang showed why the Cyclones could be in great shape come March.
Ejim scored 25 points, DeAndre Kane added 22 and Niang had 20 to help No. 17 Iowa State beat 19th-ranked Texas 85-76 on Tuesday night for its fifth victory in six games.
The trio shot 57 percent from the floor to lead the Cyclones (20-5, 8-5 Big 12), who became the third-fastest team to 20 wins in school history.
Iowa State outscored Texas 25-12 late in the second half to pull away and move within a game of the second-place Longhorns in the Big 12.
The Cyclones were keyed by Ejim, who had his second-best scoring game of the season, while Kane chipped in with five assists and zero turnovers and Niang helped keep Cameron Ridley without a field goal.
Isaiah Taylor had 26 points to lead the Longhorns (20-6, 9-4), who've followed up a seven-game winning streak by splitting their last four.
But even though Texas shot just 33 percent from the floor, it still hit some big shots in the second half.
The Longhorns could barely miss from the line either.
Javan Felix hit a 3 to match a crowd-energizing one from Matt Thomas, and Connor Lammert did as well with Iowa State on the verge of going ahead by double digits with 8:08 left.
Texas also hit its first 16 free throws and 23 of 25 overall to hang close. But Jonathan Holmes finally missed with 6:26 left, and Niang's ensuing putback gave Iowa State a 75-65 lead.
Felix had 16 points, but he needed 22 shots to get there.
Holmes and Ridley, who combined for 39 points and 18 rebounds in an 86-76 Texas win over Iowa State last month, teamed up for just 18 points and 14 rebounds on Tuesday.
Iowa State also outscored Texas 40-18 in the paint despite a 44-35 deficit on the boards.
The Cyclones had struggled of late on defense. They let up 102 points in a loss at West Virginia on Feb. 10 -- and followed that up by blowing an 18-point home lead against Texas Tech.
Iowa State's first defensive stand against the Longhorns was a disaster.
It got better from there, though.
The Cyclones allowed four consecutive offensive rebounds by Texas to open play, and Kane went to the bench with a neck injury. But Kane returned in time to hit Iowa State's first basket, and the Cyclones soon took a lead it would hold for most of the half.
Monte Morris found Ejim for an alley-oop to help Iowa State push its lead to 36-27, and his reverse dunk from the baseline made it 43-33. But Texas, which shot a dreadful 10 of 37 from the floor in the first half, hit six of their next 10 to pull even at 48-all with just over 14 minutes to go.
The Longhorns didn't have an answer for Ejim though -- and Kane and Niang also had their way with the Texas defense.


Size: What size weighted blanket should you buy? Weighted blankets are meant to fit the body, not the bed. The larger you are, the larger the blanket should be.
Weight: How heavy should a weighted blanket be? Well, the general rule of thumb is to choose a weight that is ten percent of the user's body weight with an additional pound or two included. Consider growth as well if it's for a child.
Color Options: Do you want it to match your decor? Do you want it to be your favorite color. Again, when choosing a weighted blanket, the color is based upon personal preference. There are usually many different colors to pick from.
Material: There are tons of weighted blanket materials out there that could be used for your blanket. This is another personal preference thing. However, you can choose from cotton for cool, flannel for warmth, satin-cotton for heat sensitivities, and more.
Weight Capacity: Your weight goes hand in hand with the size of your weighted blanket. The larger you are, the more weight you are going to need. So, a 20 lb weighted blanket would have a capacity of 150-200 pounds and so on.
Guarantee: Blankets are prone to ripping, loose stitching, and even the loss of the weights. This is why is it important to make sure that the weighted blanket of your choosing has a good enough guarantee in the event that something happens to it.
So now you know what to look for when asking "What is the best weighted blanket". These are just a piece of the puzzle that you would need to find the absolute best blanket you can. Our weighted blanket buying guide will help you find what you're looking for if you still aren't sure. If you're in a rush, check out our top pick. Do your pockets only have a little cash in them? Check out the budget pick.
At the top of our list is the Harkla Weighted Blanket. This has been selected as the top rated weighted blanket. The Harkla is made from a very soft Minky fabric that is soft to touch and kids will love it. There are extra slots that have sensory input when you run your hands over it. There are several options that you can choose from when it comes to size, color, and weight. This duvet-style weighted blanket is ideal for giving people calming pressure. It is easy to wash and dry with the 2-piece cover and padding removal. Not only can the weight of this blanket be super helpful for a variety of reasons, but it has a lifetime money back guarantee. If you aren't 100% satisfied, you are entitled to all of your money back. These reasons are why it's considered to be the best heavy blanket.
Even though the YnM Weighted Blanket is on here as our budget pick as the most inexpensive weighted blanket, it's still a great product. The inner layer of this blanket is made of 100% premium breathable cotton. Each one of the small compartments inside of this blanket is filled with hypoallergenic, odorless, non-toxic glass beads that aren't bumpy like the plastic pellets in the other blankets. The inner layer of the blanket is machine-washable on a gentle and low setting. You have many options available to you when it comes to sizes, colors, and weight. Right now, there are 22 color options that you can choose from between all of the different sizes. With all of the features that this blanket, it's hard to believe the affordable price. Due to the weight of it, it is not necessary to choose a huge size. It should be 10% of your body weight plus 1 lb more than what you weigh.
This Queen sized weighted blanket has a lot of cool features that come along with it.. You will find industry exclusive evenflow technology in the blanket that gives you maximum comfort and relaxation. This blanket can make you feel like you are being hugged thanks to the "calmforters" cloudsoft polyfill and stardust microbead weighing system. The Minky cover is ultra soft and you won't notice lumpy square pockets. There is a two-part construction for simple washing and a long lasting life. The cover simply zips apart and can be repeatedly washed. This blanket has a generous 60x80 dimension with a 12 lb weight and 120 lb weight capacity. You can double the blanket up for maximum pressure. Most studies show that the best blanket has a 12 lb weight for most users. If you want a lighter blanket, you have that option available to you.
The ZonLi is a great weighted blanket for adults because of its 60 x 80-inch dimension and 15 lb weight. It is made from premium 100% cotton that is sewn into small squares and filled with small pellets that help distribute weight evenly across your body to give you better comfort. There are multiple uses for your blanket including placing it on the lap, shoulders, neck, back, legs, and whole body. The inner weighted blankets are machine-washable on a gentle setting. However, it is better to dry clean or hand wash them. You can purchase the duvet cover for it if you would rather keep it clean that way. There are multiple sizes and weight options available, all the way up to 25 pounds. This is best for larger individuals up to 300 pounds. The twin size weighted blanket would be best for a kid and the larger sizes for the adults.
One of the best rated weighted blankets on the market right now is the Weighted Idea Weighted Blanket. This is a healthy and natural remedy for relaxation. It offers you the feeling of being hugged and it's the ideal size for more bed types. You want the blanket to cover the entire body, but you can use it on your legs as well. This weighted blanket is made of only the highest quality materials. This one is made from 100% premium cotton fabric that is breathable and natural to the body. There is a removable duvet cover that is made from Minky material. All of the sand-sized pellets are evenly distributed throughout the blanket for comfortable compression. At the moment, there are thirteen color options that you can choose from and 12 size and weight combinations. That's a pretty good selection, especially for the price. If for any reason you aren't happy, you can refund or exchange your product within 30-days.
The Kpblis Weighted Blanket is one of the most affordable items in this weighted blanket review guide. The inner layer of this blanket is made from 100% cotton fabric, which is breathable and natural. Each blanket is filled with non-toxic and hypoallergenic plastic poly pellets for weight. There is a unique square design sewn into small pieces throughout the blanket. These make the blanket evenly distribute weight so that the blanket is more durable and comfortable. The inner layer is machine washable on a low setting. You can also purchase the duvet to go along with the blanket. This blanket is a good choice for you if you are looking to feel the comforting pressure of a hug. It weighs 15 lbs and has a weight capacity of 150-200 lbs.
The Amy Garden blanket is a great weighted blanket for sleep. It is ideal for helping you fall asleep and stay asleep longer thanks to the comforting weight of the blanket. The size of this one is 48 x 72 inches and it weighs 15 lbs. It comes with three color options, but there are more options for the separate duvet cover. It's made from 100% cotton and all of the compartments are made with hypoallergenic and non-toxic plastic poly pellets. The weight is evenly distributed throughout the blanket for optimal comfort and durability. The inner blanket does require a dry cleaner to get it cleaned. This can be an expensive task, so the duvet cover is highly recommended. This weighted blanket should never go past the shoulders and should never cover your head. It has a weight capacity of 140-150 pounds.
This is among some of the best weighted blanket reviews for a variety of reasons. This blanket can be used at bedtime to create a calm and relaxing sleeping environment. You can also put it on your lap while you are reading or during a long ride or flight. This particular blanket can be draped over the shoulders for a calming hug-like feel. This particular blanket is made from cotton and microfleece. It has a weight capacity of 140-170 lbs and a weight of 15 lbs. The company is one of the many that offers a lifetime guarantee on their product. If for any reason you aren't satisfied with their product, you can return it for a full refund, no questions asked. Another great feature of this blanket is that is can be machine washed and air dried. Nothing like that fresh air smell on your blankets after a full day of swaying in the breeze.
If you're looking for something close to a king size weighted blanket, this is a good option. This 60 x 80 inch blanket by Rocabi is made from premium Minky Material. It also has a mixture of polyester and microfiber mixed in there as well. This adult weighted blanket can help you get a longer and deeper sleep with the hugging comfort that it comes with. It is engineered to be 7%-12% of your body weight. They take their maintenance very seriously, so the cover of this blanket is machine washable, interchangeable, hygienic, and removable to help prolong the lifespan of your blanket.
Weighted blankets are meant to create a sense of being swaddled. This helps to form a physical connection for a sense of warmth, comfort, and more. The Snuzi does this by grounding you. No, not like your parents did when you got caught doing something bad. It's actually called earthing and it's a type of calming effect. This 60 x 80 and 12 lb blanket is perfect for individuals up to 120 lbs. It is made with premium Minky material with a 100% cotton inner layer. It is weighed down with hypoallergenic and odorless pellets that are much more healthy than standard plastic pellets. This blanket is super easy to wash because the outer layer unzips. However, it should be air dried. There is no need to wash the inner blanket too much to maintain its durability and longevity. It's definitely a versatile blanket for everybody and if you need to, you can fold it in half for double the weight.


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