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Jack L. Weinberg, Assistant Prosecutor, argued the cause for respondent Edward F. Borden, Jr. In this case, as in State v. Dillihay, N. For the reasons set forth in Dillihay, supra, N. Antonio Brana was arrested following the sale of over grams of cocaine to undercover agents. Pursuant to a prior arrangement, undercover members of the Narcotics Task Force of the Camden County Prosecutor's office met Brana's co-defendant, Edwardo Bravo, to purchase a large amount of cocaine. Bravo joined the undercover agents in their car and directed them to a location in Camden where the transaction was to take place. Bravo directed the agents to park and walked to a nearby Toyota in which Brana was the passenger. Agents observed Brana hand Bravo a package of cocaine, which Bravo in turn sold to the agents on returning to their car. That transaction occurred within 1, feet of a school zone. After additional agents were summoned, the Toyota sped away and Camden police chased first the Toyota and then its occupants after they abandoned the car. During the car chase, the police observed Brana discard a gun from the Toyota. Brana was apprehended and arrested. He was charged with and convicted of the following offenses:. The Law Division merged the conspiracy violation count three into the distribution violation count one and sentenced Brana to fifteen years, with a five-year period of parole ineligibility, for distributing cocaine. Brana filed a notice of appeal with the Appellate Division. Before the Appellate Division heard arguments on the appeal, Brana filed a motion for direct certification with this Court. We granted the motion to consider whether defendant's third-degree conviction for the school-zone violation should merge with his first-degree conviction for distributing cocaine. In Dillihay, we held that federal double-jeopardy principles 'lead inevitably to the conclusion that to allow multiple punishments for related convictions under Section 5 and Section 7 of the Act is constitutionally impermissible. Nevertheless, recognizing our duty to construe a statute as constitutional 'if it is reasonably susceptible to such interpretation,' State v. Profaci, 56 N. Accordingly, we held that 'the school-zone statute must be construed to allow merger of school-zone offenses into first- and second-degree Section 5 offenses provided that a defendant convicted of a drug offense in a school zone is sentenced to no less than the mandatory minimum sentence provided in the school zone statute. As a result, we conclude that defendant's Section 7 conviction for distribution of controlled dangerous substances within a school zone must merge into his Section 5 conviction for distribution of more than five ounces of cocaine. Defendant raises two further issues. First, he contends that he received ineffective assistance of counsel at trial. The record is clear that defendant has failed to satisfy the two-prong Strickland test. Strickland v. Washington, U. Second, defendant contends that N. Defendant recognizes that prior challenges to the DEDR penalty provisions have been rejected, but urges that we find those cases to have been decided wrongly. We decline to do so. See State in the Interest of L. Gonzalez, N. Anaya, N. We reverse so much of the judgment below as denied merger, and remand the case to the trial court for an amended judgment vacating defendant's conviction for distribution of cocaine within a school zone under N. The judgment is, in all other respects, affirmed. I would affirm the judgment for the reasons expressed in my opinion in State v. Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes. Get free summaries of new Supreme Court of New Jersey opinions delivered to your inbox! Brana State v. Brana Annotate this Case. The Supreme Court of New Jersey. Argued September 11, Decided January 27, I Antonio Brana was arrested following the sale of over grams of cocaine to undercover agents. He was charged with and convicted of the following offenses: 1. Distribution of more than five ounces of cocaine N. Distribution of cocaine within a school zone N. Conspiracy to distribute Controlled Dangerous Substances N. Unlawful possession of a handgun N. II In Dillihay, we held that federal double-jeopardy principles 'lead inevitably to the conclusion that to allow multiple punishments for related convictions under Section 5 and Section 7 of the Act is constitutionally impermissible. III Defendant raises two further issues. Toggle button Get free summaries of new Supreme Court of New Jersey opinions delivered to your inbox! Enter Your Email. Justia Legal Resources. Find a Lawyer. Law Schools. US Federal Law. US State Law. Other Databases. Marketing Solutions.
State v. Brana
Branas buy cocaine
The questions are depicted by linkages that relate interventions and outcomes. A dashed line indicates a health outcome that immediately follows an intermediate outcome. Comparative effectiveness: Control group received active intervention. Outcomes: No relevant outcomes. Intervention: Not a primary care—relevant behavioral counseling intervention, or drug misuse is not a primary target of the intervention. Study design: Not a randomized clinical trial or controlled clinical trial. Follow-up: Less than 3 months 12 weeks of follow-up after baseline does not apply to harms. Relevance: Study aim not relevant. Quality: Study was poor quality. Non—English-language: Publication not in English. Conference abstract: Study abstract from conference only. Weights are from random-effects analysis. Effect sizes are study-reported mean differences at follow-up Barlow et al 28 ; Barlow et al 26 and beta-weight Walkup et al Vertical dashed line indicates the overall measure of effect. NR indicates not reported; NS, not significant. Importance Illicit and nonmedical use in ways other than instructed drug use is common in adolescents and young adults and increases the risk of harmful outcomes such as injuries, violence, and poorer academic performance. Objective To review the benefits and harms of interventions to prevent illicit and nonmedical drug use in children, adolescents, and young adults to inform the US Preventive Services Task Force. Study Selection Clinical trials of behavioral counseling interventions to prevent initiation of illicit and nonmedical drug use among young people. Data Extraction and Synthesis Critical appraisal was completed independently by 2 investigators. Data were extracted by 1 reviewer and checked by a second. Random-effects meta-analysis was used to estimate the effect sizes associated with the interventions. Main Outcomes and Measures Number of times illicit drugs were used; any illicit drug or any cannabis use. Health, social, or legal outcomes such as mental health symptoms, family functioning, consequences of drug use, and arrests were reported in 19 trials and most showed no group differences. The percentage of participants using illicit drugs ranged from 2. The median absolute risk difference between groups was —2. The remaining 3 trials provided a perinatal home-visiting intervention to pregnant Native American youth. Across all 29 trials, only 1 trial reported on harms and found no statistically significant group differences. Conclusions and Relevance The evidence for behavioral counseling interventions to prevent initiation of illicit and nonmedical drug use among adolescents and young adults was inconsistent and imprecise, with some interventions associated with reduction in use and others associated with no benefit or increased use. Health, social, and legal outcomes were sparsely reported, and few showed improvements. Illicit drug use is common in adolescents and young adults. The Monitoring the Future report on adolescent drug use estimated that In , the US Preventive Services Task Force USPSTF concluded that evidence was insufficient to assess the balance of benefits and harms of primary care—based behavioral interventions to prevent or reduce illicit drug or nonmedical pharmaceutical use in children and adolescents I statement. This review addressed 3 key questions, shown in Figure 1. A draft of the analytic framework, review questions, and inclusion and exclusion criteria was posted on the USPSTF website from May 10 to June 7, , for the purpose of gathering public input. In addition to evaluating all trials included in the previous review 17 and references excluded from the previous review that would be eligible because of expanded inclusion criteria, MEDLINE, PubMed for publisher-supplied records only , PsycINFO, and the Cochrane Central Register of Controlled Trials were searched for relevant English-language literature published beginning January 1, , for children and adolescents or January 1, , for young adults up to age 25 years and ending January 31, eMethods in the Supplement. The database searches were supplemented with bibliographies of other relevant reviews, suggestions from experts, and monitoring of news and table-of-contents alerts. Ongoing surveillance was conducted after January through March 20, , to identify newly published studies that may affect the findings of the review. This was accomplished through review of publications in high—impact factor journals and article alerts. One relevant RCT was identified during the surveillance window and was included in this review. Two reviewers independently reviewed abstracts and full-text articles against prespecified inclusion criteria Figure 2. Discrepancies were resolved via discussion and consultation with another reviewer as needed. Interventions could target other risk behaviors in addition to illicit drug use eg, alcohol use, tobacco use, risky sexual behavior but were included only if there was some intervention content that directly addressed illicit drug use and the study reported a drug use outcome. Interventions that used components that could not be replicated in a health care setting, such as broad public health, media, or policy interventions, were excluded. Studies conducted in most other school settings were excluded because of concerns that generalizability to primary care may be limited. Studies were, however, included if they used schools only for recruitment purposes, as long as they recruited from multiple schools and most participants were not attending sessions at their own schools, or if they studied interventions that were conducted entirely online and did not involve interactions among students at the same school or between students and teachers. RCTs and nonrandomized controlled intervention studies that did not have a true control group ie, comparative effectiveness trials were excluded, and allowable control groups included no intervention eg, usual care, wait list , a minimal intervention eg, pamphlets, links to preexisting internet resources, or no more than a single brief contact per year , and attention controls similar format and intensity but a different content area. Discordant quality ratings were resolved through discussion or consultation with another reviewer. One reviewer extracted key elements of included studies into standardized forms in DistillerSR Evidence Partners. A second reviewer checked the data for accuracy. Study design details were abstracted, along with population characteristics, intervention characteristics, and results. Summary tables were created for all KQs showing study, population, intervention characteristics, and outcomes. Three trials provided very intensive prenatal and postnatal home visits to pregnant American Indian youth. Illicit drug use was selected as the primary outcome for meta-analysis. Nineteen trials reported a continuous measure, most commonly the number of times illicit drugs were used over a specified period, and 13 trials reported the dichotomous outcomes of any illicit drug use or any cannabis use. For dichotomous outcomes, log odds ratios ORs were converted to Cohen d and then to Hedges g values using standard formulae. Pooled analyses of the general prevention trials were conducted using random-effects meta-analyses on SMDs for 3 categories of substances: illicit drugs, alcohol, and tobacco. Where multiple intervention groups or follow-up time points were provided, the intervention group with the most intensive or comprehensive drug prevention component was selected, reported at 6 to 12 months or the closest to that time frame. Dichotomous measures were selected over continuous measures, 1-month time frames were selected over longer observation windows, and outcomes assessing the use of any illicit drug over the use of a single drug eg, cannabis were selected when multiple outcomes were reported for the same study. In addition, ORs and between-group mean differences were pooled separately to better understand effects in the native units. Additionally, analyses of cannabis-specific results in native units are provided. The DerSimonian and Laird model was used to calculate the pooled effect estimate across studies. Funnel plots were generated and the Egger test was run to explore small-study effects, which can be related to publication bias. Stata version Duration ranged from 1 day to more than 3 years, with a median of 6 weeks interquartile range, 1 day to 26 weeks. Interventions for 12 of the trials were delivered exclusively through a computer. Only 4 trials appeared to focus on illicit drugs without explicit discussion of other substances or behaviors. Key Question 1. Do primary care—feasible or referable interventions to prevent drug use in children, adolescents, and young adults improve health outcomes or other related outcomes? Health, social, or legal outcomes were reported in 16 of the general prevention trials 24 , 25 , 31 , 33 , 35 , 36 , 38 , 41 , 43 , 49 - 51 , 54 , 57 - 59 and all 3 Family Spirit trials. Mental health outcomes, such as depression, anxiety, and externalizing symptoms, and family functioning were the most commonly reported health outcomes, reported by 9 of the general prevention trials 24 , 25 , 35 , 36 , 38 , 41 , 50 , 51 , 54 and all 3 Family Spirit trials. Measures of family functioning were reported in 5 of the general prevention trials. Across all time points up to 24 months , differences in change between groups in these trials most commonly fell between 0. The other 2 trials did not find group differences on measures of communication, 33 , 36 parental monitoring, 33 or positive parenting, although data needed to include these results on the forest plot were not provided. Key Question 2. Do primary care—feasible or referable interventions to prevent drug use in children, adolescents, and young adults improve drug use outcomes? The pooled OR for any illicit drug use or any cannabis use was 0. The percent using illicit drugs at follow-up ranged from 2. Results were very similar when limited to cannabis outcomes only, except that the pooled result was statistically significant for the proportion reporting any cannabis use OR, 0. Only 4 trials reported the effect of their interventions on misuse of prescription medications specifically. All 4 were computer-based interventions, and all broadly targeted substance use and other non—substance-related outcomes. Despite the small pooled result, some interventions did show statistically significant reductions in illicit drug use at 1 or more follow-up time points. Effects were generally maintained through 12 months or beyond in these trials. Most of these interventions involved 9 or more intervention sessions, all but 1 53 included components for parents or caregivers as well as the youth, and all addressed a broad range of skills and topics. Other interventions demonstrated beneficial effects only for some patient subgroups, including 2 primary care—based interventions that used a computer-based assessment and intervention along with brief 1-time clinician counseling. However, many interventions showed no clear evidence of benefit, and 2 reported increased illicit drug use in youth participating in the interventions for at least 1 drug-related outcome. None of the potential effect modifiers examined study, population, intervention, and control characteristics appeared to explain variability in effect sizes Figure 6 , and there was no evidence of a small-studies effect. Other behavioral outcomes were sparsely reported, with most trials finding no differences between groups or finding differences only among some participant subgroups and not overall. Key Question 3. What are the harms of primary care—feasible or referable interventions to prevent drug use in children, adolescents, and adults? Only 1 of the included trials a Family Spirit trial directly reported on harms. This evidence review included 29 studies, with findings that were inconsistent for illicit and nonmedical drug use, and effects ranging from clearly beneficial to possibly harmful Table 2. While some interventions were associated with reduced illicit and nonmedical drug use, they tended to either target a relatively narrow population eg, to year-old Asian American girls, truant youth, eighth-grade girls in foster care with limited generalizability to other populations, or to not have had their results replicated. There is a growing body of evidence on substance use prevention in primary care settings, using electronically delivered interventions, typically along with a brief 1-time motivational interview with a clinician. However, these studies generally found benefits only in subgroup analyses, and the pattern of results was not consistent across studies. The previous USPSTF review on this topic 17 concluded that there was inadequate evidence to determine whether preventive interventions were effective in reducing the likelihood of illicit drug use, based on 6 trials, all of which were also included in the current review. Despite this expansion of scope, the strength of evidence was low that primary care—relevant interventions could prevent illicit and nonmedical drug use in children, adolescents, and young adults. This was because of the inconsistency in effects, the relatively narrow target populations for most of the interventions that showed a benefit, and the lack of benefit among studies conducted in US-based primary care settings, which were primarily limited to low-dose interventions. Most of the studies of interventions to prevent illicit and nonmedical drug use have been conducted in school classrooms or after-school settings, and other reviews have found these school-based prevention programs effective in reducing illicit drug use, including some approaches that would likely be feasible to implement in a health care setting. Familias Unidas 61 is a family-based preventive intervention to improve family communication, positive parenting, and parental monitoring to reduce risky substance use and sexual behaviors in Hispanic adolescents. Participants were generally recruited from middle schools, and sessions occurred outside of school hours. The intervention generally included 8 group sessions for parents and 4 family visits that included the adolescents. In contrast, the 3 trials in this review that either directly implemented or were based on the SFP did not prove to be effective outside of school settings. Nevertheless, the fact that the success of this program did not clearly translate to the health care setting illustrates the importance of testing the feasibility and effectiveness of prevention programs in health care settings before recommending their full-scale implementation. There are important limitations in the research that should be considered. First, reporting of health, social, and legal outcomes was sparse and heterogeneous, limiting the conclusions for these important outcomes. In addition, drug use outcomes were very heterogeneous, making it difficult to draw overall conclusions. Second, no evidence was found that included children younger than 10 years, likely because a very long follow-up window would be needed to determine the effect on illicit drug use. Additionally, very limited evidence on young adults was found, since this literature primarily focused on the reduction of use in those who were regular users, hazardous users, or who had a likely substance use disorder, which was excluded from the review. These types of secondary prevention trials are included in the USPSTF review on screening and interventions for drug misuse. Third, most of the interventions were studied by the teams who developed the intervention and have not been replicated by independent researchers. This may be especially important in this field, in which outcomes are measured by self-report and are subject to social desirability effects. In general, studies are needed that replicate in a health care context and that further refine and broadly implement some of the effective interventions described in this review. These include the clinician training and quality improvement intervention, 49 the computer-based Familias Unidas intervention, 33 and some of the computer-based interventions for adolescent girls. However, the relatively small overall evidence base and inconsistencies across studies indicate a need for further study of these interventions. It would also be valuable to conduct a trial in a health care setting of the full in-person version of the Familias Unidas intervention and other interventions proven to be effective in schools. It is important to continue to explore the influence of context and mechanisms of change. This review has several limitations. First, trials that did not report a drug use outcome were excluded, so studies that only included intermediate outcomes such as child development or school functioning were excluded, even if substance abuse prevention might have been a long-term aim. Second, interventions that did not explicitly address prevention of illicit and nonmedical drug use were excluded, although some broad prevention or resilience interventions may be effective in preventing illicit drug use. Third, since trials targeting alcohol and tobacco use without targeting illicit drug use were not comprehensively included, the results for the alcohol and tobacco outcomes do not represent all available evidence on these topics. The evidence for behavioral counseling interventions to prevent initiation of illicit and nonmedical drug use among adolescents and young adults was inconsistent and imprecise, with some interventions associated with reduction in use and others associated with no benefit or increased use. OConnor kpchr. Critical revision of the manuscript for important intellectual content: Thomas, Senger, Perdue, Robalino, Patnode. Administrative, technical, or material support: Thomas, Senger, Robalino, Patnode. Conflict of Interest Disclosures: None reported. AHRQ had no role in study selection, quality assessment, or synthesis. AHRQ staff provided project oversight; reviewed the report to ensure that the analysis met methodological standards, and distributed the draft for peer review. Otherwise, AHRQ had no role in the conduct of the study; collection, management, analysis, and interpretation of the data; and preparation, review, or approval of the manuscript findings. USPSTF members, peer reviewers, and federal partner reviewers did not receive financial compensation for their contributions. Comments were presented to the USPSTF during its deliberation of the evidence and were considered in preparing the final evidence review. It did not undergo additional peer review after submission to JAMA. Figure 1. View Large Download. Figure 2. KQ indicates key question. Figure 3. Figure 4. Figure 5. Figure 6. Table 1. Table 2. Podcast Subscribe to Podcast. Quality Assessment Criteria eTable 2. Number of national drug overdose deaths involving select prescription and illicit drugs, ages years old. National Institute on Drug Abuse. Published Accessed February 6, Risk of road accident associated with the use of drugs: a systematic review and meta-analysis of evidence from epidemiological studies. Cannabis, alcohol and fatal road accidents. Association of drug and alcohol use with adolescent firearm homicide at individual, family, and neighborhood levels. Predictors of self-harm emergency department visits in adolescents: a statewide longitudinal study. A systematic review of the relationship between high school dropout and substance use. Long-term consequences of adolescent cannabis use: examining intermediary processes. Brain activation to negative stimuli mediates a relationship between adolescent marijuana use and later emotional functioning. Non-acute residual neurocognitive effects of cannabis use: a meta-analytic study. Residual effects of cannabis use on neurocognitive performance after prolonged abstinence: a meta-analysis. The contribution of cannabis use to variation in the incidence of psychotic disorder across Europe EU-GEI : a multicentre case-control study. Association of cannabis use with adolescent psychotic symptoms. National adolescent drug trends in Monitoring the Future. Updated December 17, Accessed February 10, Center for Behavioral Health Statistics and Quality; Primary care behavioral interventions to reduce illicit drug and nonmedical pharmaceutical use in children and adolescents: U. Preventive Services Task Force recommendation statement. Primary care behavioral interventions to prevent or reduce illicit drug use and nonmedical pharmaceutical use in children and adolescents: a systematic evidence review for the U. Preventive Services Task Force. Effect of computer-based substance use screening and brief behavioral counseling vs usual care for youths in pediatric primary care: a pilot randomized clinical trial. United Nations Development Programme. Human Development Report. United Nations; Introduction to Meta-Analysis. National Center on Addiction and Substance Abuse. Missed opportunity: national survey of primary care physicians and patients on substance abuse. Accessed May 17, Bias in meta-analysis detected by a simple, graphical test. Computer-facilitated substance use screening and brief advice for teens in primary care: an international trial. Evaluation of a German version of the Strengthening Families Programme a randomised controlled trial. Paraprofessional-delivered home-visiting intervention for American Indian teen mothers and children: 3-year outcomes from a randomized controlled trial. Home-visiting intervention to improve child care among American Indian adolescent mothers: a randomized trial. Engaging high risk families in community based intervention services. Two-year outcomes of a randomized, family-based substance use prevention trial for Asian American adolescent girls. Preventing substance use among early Asian-American adolescent girls: initial evaluation of a web-based, mother-daughter program. Effectiveness of the Strengthening Families programme in Poland: cluster randomized controlled trial. PubMed Google Scholar. Effectiveness of a brief integrative multiple substance use intervention among young men with and without booster sessions. Effects of promoting health among teens on dietary, physical activity and substance use knowledge and behaviors for African American adolescents. Substance use and delinquency among middle school girls in foster care: a three-year follow-up of a randomized controlled trial. Intervention effects on health-risking sexual behavior among girls in foster care: the role of placement disruption and tobacco and marijuana use. A brief, web-based personalized feedback selective intervention for college student marijuana use: a randomized clinical trial. Substance use outcomes in the Healthy School and Drugs program: results from a latent growth curve approach. Peer network counseling with urban adolescents: a randomized controlled trial with moderate substance users. Decision-making program for rural adolescents with asthma: a pilot study. Preventing substance use among adolescent girls: 1-year outcomes of a computerized, mother-daughter program. Computer-delivered, parent-involvement intervention to prevent substance use among adolescent girls. Using Facebook ads with traditional paper mailings to recruit adolescent girls for a clinical trial. Preventing drug abuse among adolescent girls: outcome data from an internet-based intervention. An online drug abuse prevention program for adolescent girls: posttest and 1-year outcomes. Preventing drug use among sexual-minority youths: findings from a tailored, web-based intervention. Randomized controlled trial of a paraprofessional-delivered in-home intervention for young reservation-based American Indian mothers. Computer and therapist based brief interventions among cannabis-using adolescents presenting to primary care: one year outcomes. A randomized controlled trial testing the efficacy of a brief cannabis universal prevention program among adolescents in primary care. Brief motivational interviewing intervention to reduce alcohol and marijuana use for at-risk adolescents in primary care. Systematic review of universal school-based resilience interventions targeting adolescent tobacco, alcohol or illicit drug use: review protocol. Familias Unidas website. Familias Unidas: a family-centered ecodevelopmental intervention to reduce risk for problem behavior among Hispanic adolescents. Parent-centered prevention of risky behaviors among Hispanic youths in Florida. Efficacy of a brief intervention to reduce substance use and human immunodeficiency virus infection risk among Latino youth. Published online September 19, Program descriptions. Strengthening Families Program. Randomized trial of brief family interventions for general populations: adolescent substance use outcomes 4 years following baseline. Benefits of universal intervention effects on a youth protective shield 10 years after baseline. Final research plan for drug use in adolescents and adults, including pregnant women: screening. Agency for Healthcare Research and Quality. Published August 13, This Recommendation Statement from the US Preventive Services Task Force concludes that the current evidence is insufficient to assess the balance of benefits and harms of primary care—based behavioral counseling interventions to prevent illicit drug use, including nonmedical use of prescription drugs, in children, adolescents, and young adults I statement. Wong, MD. This JAMA Patient Page summarizes the US Preventive Services Task Force recommendation concluding that evidence is insufficient to assess the balance of benefits and harms of primary care—based behavioral counseling interventions to prevent illicit drug use in children, adolescents, and young adults. Save Preferences. Privacy Policy Terms of Use. This Issue. Views 14, Citations View Metrics. X Facebook More LinkedIn. May 26, Scope of Review. Data Sources and Searches. Study Selection. Data Extraction and Quality Assessment. Data Synthesis and Analysis. Benefits of Interventions. Harms of Interventions. Back to top Article Information. Access your subscriptions. Access through your institution. Add or change institution. Free access to newly published articles. Purchase access. Rent article Rent this article from DeepDyve. Sign in to access free PDF. Save your search. Customize your interests. Create a personal account or sign in to:. Privacy Policy. Make a comment.
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