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Foles Fracture; Vick Starting Season Finale
Somehow, even Christmas Eve can't be devoid of intrigue and bizarre happenstance when it comes to the Eagles.
Andy Reid announced Monday that an MRI revealed a hairline fracture in the second metacarpal in quarterback Nick Foles' throwing hand, suffered just before halftime of Sunday's loss to the Redskins. The second part of the stunner: Instead of going with Trent Edwards, who has been backing up Foles lately, Reid plans to start Michael Vick in what is very likely to be the final Eagles game for both Reid and Vick.
"That's the direction we're going in, as we speak," Reid said. Reid said Vick, cleared after suffering a concussion Nov. 11, is excited, something Vick spokesman Chris Shigas confirmed to your Eagletarian. Shigas said Vick cherishes the opportunity to "leave it on the field," and obviously, getting a shot at showing potential 2013 employers he is healthy and sharp can't hurt, either.
Reid also said DT Fletcher Cox and LB Mychal Kendricks have concussions. There is no word on their availablity for the finale Sunday at the Giants.
Reid said Foles' injury did not show up on X-rays taken at the stadium Sunday but was visible on the MRI Monday. He said it would typically be a three-week injury.
It seems Foles must have been injured three snaps before Alex Henery's 38-yard field goal, which was kicked with 21 seconds left in the half. Foles was driven into the turf by unblocked Redskins defensive lineman Barry Cofield, as Foles dumped the ball successfully to LeSean McCoy for a short gain. Foles went down face-first, on his hand.
Reid didn't really offer a clear rationale for the turnabout from having Vick in street clothes as the inactive, healthy third quarterback against the Redskins to making him the starter again the next day. When Reid said last week Vick would be the third QB, observers hypothesized that if something should happen to Foles, the Eagles didn't need a quarterback they are likely to discard coming in and muddying the waters with an electrifying performance, and that Vick wasn't looking to take any more brutal hits in a season that has been full of them.
But if any of that were true, Edwards would be starting against the Giants, who still can make the playoffs if they beat the Eagles and several other dominoes fall.
"He's had a couple of weeks of practice here," Reid said of Vick. "I thought the first week, he was a little bit rusty out there, I thought this past week, he threw it around well, he feels good ... He obviously deserves an opportunity to play."
Reid said the choice between Vick and Edwards came down to the fact that Vick "had been the No. 1."
Foles' rookie season is over; the next regime will have to judge his potential off six starts and seven appearances, in which he completed 161 of 265 passes (60.8 percent) for 1,699 yards, six touchdowns and five interceptions. He was sacked 20 times and compiled a 79.1 passer rating. Vick's passer rating this season is nearly identical, 79.2. Vick has completed 58.5 percent of his passes, with 11 touchdowns and nine interceptions.
Reid said his evaluation of Foles is that he's "a quarterback who gives your team the oppportunity to win." He noted that the other rookie quarterbacks he is being evaluated against in this strong QB class have been playing all season (with better offensive lines in front of them and offenses that weren't missing key weapons, as the Eagles have been the past month or so). "He has enough skill and ability to play," Reid said. "It's been a valuable expererience for him, but yeah, you'd love to have one more game."
Reid said Foles "really just needs to play ... Every week, I thought the game slowed down for him."
Reid lauded Foles for finishing the game with a broken hand. He said Foles had some trouble gripping the ball right after the hit, but when he warmed up for the second half, he felt he was good to go. Foles completed 18 of 26 passes for 188 yards in the second half. He said afterward his hand didn't affect the ball he threw short of an open Jeremy Maclin in the end zone in the final seconds, but Reid indicated Monday that the hand might have been a factor.


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Jack Balkin: jackbalkin at yahoo.com Bruce Ackerman bruce.ackerman at yale.edu Ian Ayres ian.ayres at yale.edu Corey Brettschneider corey_brettschneider at brown.edu Mary Dudziak mary.l.dudziak at emory.edu Joey Fishkin joey.fishkin at gmail.com Heather Gerken heather.gerken at yale.edu Abbe Gluck abbe.gluck at yale.edu Mark Graber mgraber at law.umaryland.edu Stephen Griffin sgriffin at tulane.edu Jonathan Hafetz jonathan.hafetz at shu.edu Jeremy Kessler jkessler at law.columbia.edu Andrew Koppelman akoppelman at law.northwestern.edu Marty Lederman msl46 at law.georgetown.edu Sanford Levinson slevinson at law.utexas.edu David Luban david.luban at gmail.com Gerard Magliocca gmaglioc at iupui.edu Jason Mazzone mazzonej at illinois.edu Linda McClain lmcclain at bu.edu John Mikhail mikhail at law.georgetown.edu Frank Pasquale pasquale.frank at gmail.com Nate Persily npersily at gmail.com Michael Stokes Paulsen michaelstokespaulsen at gmail.com Deborah Pearlstein dpearlst at yu.edu Rick Pildes rick.pildes at nyu.edu David Pozen dpozen at law.columbia.edu Richard Primus raprimus at umich.edu K. Sabeel Rahmansabeel.rahman at brooklaw.edu Alice Ristroph alice.ristroph at shu.edu Neil Siegel siegel at law.duke.edu David Super david.super at law.georgetown.edu Brian Tamanaha btamanaha at wulaw.wustl.edu Nelson Tebbe nelson.tebbe at brooklaw.edu Mark Tushnet mtushnet at law.harvard.edu Adam Winkler winkler at ucla.edu Compendium of posts on Hobby Lobby and related cases The Anti-Torture Memos: Balkinization Posts on Torture, Interrogation, Detention, War Powers, and OLC The Anti-Torture Memos (arranged by topic) Recent Posts Glenn Beck as civil libertarian and Joe Lieberman as authoritarian
Tuesday, May 04, 2010
Glenn Beck as civil libertarian and Joe Lieberman as authoritarian Sandy Levinson
I note, with some admitted astonishment, the following from a story just posted on the New York Times about the right-wing criticisms being directed at the Administration for deigning to respect any legal rights of the "Times Square bomber":
It had always been an expatriating act (leading to loss of citizenship) to serve in the armed forces of a foreign state engaged in an armed conflict with the US. It is not, therefore, so great a step to expand that to also include serving in the armed forces of a foreign non-state terrorist group engaged in an armed conflict with the US.
In a series of cases including Afroyim v. Rusk and Vance v. Terrazas the Court ruled that expatriation was too serious a consequence to be the result of an unintentional act. However, these cases dealt with innocent acts like voting in a foreign election or filling out some foreign government paperwork. So while civil intent to surrender citizenship may be a legitimate requirement for a paperwork violation, Congress could change the law and the Court could be pressed to revisit the question of whether criminal intent (to serve in the armed forces of an enemy of the US or to aid a terrorist organization in attacks on the US) provides sufficient "intent" to meet the Constitutional requirement discussed in those cases even when this Treason is not accompanied by any explicit plan to surrender citizenship. Let us be clear that this envisions Congress passing legislation that, although in line with the pre-Afroyim practicesm, appears on its face to be a violation of the language of Terrazas. It would then present the Court with an opportunity to clarify whether Terrazas really applied not just to filling out a Mexican government form but also to serving in the armed forces of a foreign enemy that seeks the mass slaughter of American civilians. Perhaps, on reflection, the Court would find that it did not intend to include that type of action in its earlier decisions. Alternately, the Court could explain that these acts are so serious as to inherently incorporate the required intent which the previous cases indicated could be expressed "by actions" as well as "by word". That said, expatriation is always a civil (not a criminal) procedure but it is an serious matter that requires judicial process and the protection of the rights of the accused. If this is done, then adding loss of citizenship to the other consequences of these acts is not historically unusual.
Kudos to Sandy for noticing the precise moment when Glenn Beck's clock was right. The argument that Lieberman puts forward is nothing new here--its the basic argument for keeping suspected enemies locked up in Gitmo--but it is frightening to consider extending that policy to apply to US citizens.
Note to Mr. Lieberman: when you find yourself right of Glenn Beck, you should stop drifting rightward. Also, try to spend less vacation time in the Arizona legislature.
"Affiliation" is a vague term that does not appear to mean to be the same as "enlistment" which is a more clear-cut matter.
National citizenship is lost there because you are pledging allegiance to another nation. Pledging alliance to a group is not the same thing. I also don't know what the fact it is somehow "foreign" is determinative. The KKK did much more harm than some Mexican rebel group in 1870, right? Isn't the Catholic Church, for instance, a foreign institution? I hear priests don't want to follow immigration laws, influenced by foreign based propaganda. But, it takes injustice to another level to argue that mere charges, not even civil judicial process, should even be a credible consideration to strip someone of citizenship. I hope JL here never did any defense work. Beck might be a bit of a nut. But, even he, I guess, has limits.
Beck's position was unsurprising. We share the position that the Constitution protects the rights of the People and not foreign enemies who war against the People.
Shahzad is a citizen. He gets a trial. I would only hope that Justice tries to assemble a case for treason instead some weak assisting terror charge and seeks the death penalty. Traitors are the lowest form of human life and should be treated as such.
It's a pretty sad day when Glenn Beck and Baghdad Bart are the voices of reason in the GOP, however temporarily.
On the other hand, Baghdad, do you really think he should be put to death for being a failure as a terrorist?
It is obviously unsettling that election officials are arguing for a legal regime where mere allegations of terrorism are enough to strip U.S. citizens of their Constitutional rights.
However, I think there is something to the idea that we also ought to be somewhat wary of creating an entire two-track system for the prosecution of alleged terrorists. If we allow citizenship to be the golden ticket, and let non-citizen languish under some other set of much more harsh rules, we will do two things: first, create an incentive for foreign terrorist groups to merely recruit more U.S. citizens, and second, continue to destroy what good will remains from foreign countries when we hold their nationals under circumstances we don't tolerate for U.S. citizens. Someone (maybe it was Ben Wittes?) argued that to create a long-lasting legal regime that will earn international buy-in, we can't afford such a naked two-track process. Whatever process we employ, it ought to be created via the legislature and not the judiciary.
Joe's comparison of "affiliation" and "enlistment" makes me think that in an immigrant nation such as America there continue ethnic ties with foreign places that sometimes may appear to be anathema to America's interests (that may be changing from time to time), testing a citizen's (whether by birth or naturalization) loyalties, even where such a citizen may have good intentions. Here, the line was crossed. But in many instances, there are gray areas.
I don't know why this should be particularly shocking. As a general rule, it's not that conservatives want less respect for the constitution than liberals. They just tend to want it violated in different ways. Your average liberal gets to think of himself as more civil-libertarian than conservatives only by dint of refusing to recognize as rights those civil rights he wants violated, such as property rights, or the 2nd amendment.
So, Beck isn't a cardboard cutout anti-civil-civil liberties hatemonger conservative. This would only surprise people who'd never listened to him.
At the WaPo today (5/5/10), Ann Telnaes' video cartoon "Sen. McCain and Rep. King Speak Out Against Reading Suspected NYC Bomber His Miranda Rights" is quite explosive.
As for Glenn Beck, he is joined here by our former backpacker and Brett to replace a past slapstick trio; no, not the Marx or Ritz Brothers.
do you really think he should be put to death for being a failure as a terrorist?
Yes, yes, and an emphatic "yes."
In light of Scalia's opinion in Hamdi, I'm not sure there are 5 votes which would support tightening the denationalization rules. Of course, this is Scalia....
do you really think he should be put to death for being a failure as a terrorist?
Yes, yes, and an emphatic "yes." # posted by PMS_CC : 10:49 AM Why? He didn't kill anyone. Why the bloodlust?
The notion that you should lose your rights as a citizen the moment you're accused of engaging in terrorism was already on full display in 2002 in the mistreatment of Jose Padilla.
I was also heartened by Glenn Beck's adoption of Martin Luther King's pledge. See "Libertarian Pledge of Nonviolence."
Why would the veins-in-my-teeth crowd want to denaturalize someone for attacking the United States at the behest of a foreign power? That seems like treason with a death penalty. Unless they have so debased the English language that treason now applies only to Obama and not traitors.
Lower that child molesters, Bart? Lower than serial rapists? Lower than genocidaires, Bart? That's pretty low!
Yes, traitors are the lowest of the low. After this country embraced him and extended the privilege of citizenship, Shahzad betrayed his fellow citizens and attempted to mass murder hundreds of New Yorkers by burning them alive with a car fire bomb at the behest of a foreign terror group. Being put down like the family dog with a lethal injection is far too good for this scumbag.
Baghdad, you seriously think that trying to kill people is worse than actually accomplishing it? That is pretty F'd up.
I assume you are outraged that Terry Nichols was not put to death?
I share Bart's attitude as to what a scuzzball this guy is for signing up for citizenship and then doing this.
That said, I am not sure it meets the legal definition of treason. Not every terrorist bombing is an act of war. If he joined Al Qaeda after becoming a citizen and then participated in this plot, it might constitute adhering to the country's enemies, giving them aid and comfort. Seems to me there's a nice cold cell at ADX Florence waiting for this guy.
I am just a layperson here, but hopefully some of the bright legal minds who contribute to this site can educate me. I do have a couple of questions that I've been pondering over the last news cycle.
1) Do the 5th and 6th Amendments only apply to US Citizens? My reading of the text (which is amateurish and plain) is that all persons are entitled to basic Constitutional protections, so whether Joe Terrorist were a US citizen or not is frankly beside the point. If he is subject to prosecution under US law then he retains protection under the Constitution's rights of the accused. 2) It is also my understanding that very clearly the Miranda warning does not confer any rights upon the accused -- those rights are already preserved in the 5th and 6th Amendments -- but rather, the Miranda warning is required to ensure that any potentially self-incriminating evidence stemming from interrogation of a detained person occurs only after (a) the accused person has been advised of his existing Constitutional rights as an accused person, and (b) the person understands those rights and (c) the person willingly waives those rights. The state may not simply assume that a person has waived their rights unless (a) and (b) have both been met. But after they have been met, then a person may waive their rights by the simple act of opening their mouth and speaking. So am I wrong, or am I really, really wrong, about one or both of these?
Howard Gilbert:
It had always been an expatriating act (leading to loss of citizenship) to serve in the armed forces of a foreign state engaged in an armed conflict with the US. It is not, therefore, so great a step to expand that to also include serving in the armed forces of a foreign non-state terrorist group engaged in an armed conflict with the US. I'd read that present law has one exclusion to the prohibition on serving in a foreign military: People are allowed to serve in the Israeli military without penalty. I don't know if this is true. Does anyone else have any more information on this?
Arne, I'm pretty sure you can serve in any foreign military you like, as long as they're not at war with us. There is no special Israel exception that I know of. Some background information here.
There are two expatriating acts: To serve as an officer in any foreign army (even in peace time), and to serve as an enlisted man in the army of a foreign state engaged in an armed conflict with the US.
There is no special rule for any particular foreign country. If your long term plans involve a three year hitch in the French Foreign Legion, you can be assured that there will be no legal consequences (because you cannot become an officer in the Legion in less than three years and because it seems a safe bet that France will not declare war on the US).
Rights of the People have been held to extend to citizens and aliens who reside among the citizenry as part of the People. Shahzad definitely enjoys the Bill of Rights. Until the Boumediene case, no court of which I am aware ever held that foreign enemy combatants at war with the People enjoyed constitutional rights - in that case habeas corpus. The Supremes in In re Quirin held during WWII that German saboteurs did not enjoy 5th or 6th Amendment rights.
Boumediene explicitly did not hold that detainees had Constitutional rights. That question was remanded to the lower courts. It found instead that the power of the Article III courts to issue Writs of Habeas Corpus extended to Guantanamo and could not be blocked by Congress unless it exercised the Suspension Clause. That is, it found that Judges in the DC Circuit have a Constitutional power to issue Writs to Guantanamo, not that detainees have any Constitutional right to demand it. Quirin clearly did not say that German saboteurs do not have rights under the Fifth and Sixth Amendments. What it said is that the Fifth and Sixth Amendments did not require a civilian trial: "In the light of this long-continued and consistent interpretation, we must conclude that § 2 of Article III and the Fifth and Sixth Amendments cannot be taken to have extended the right to demand a jury to trials by military commission, or to have required that offenses against the law of war not triable by jury at common law be tried only in the civil courts." A spy and saboteur once he has passed through lines of defense is subject to the concurrent jurisdiction of the military courts (for military offenses to which he is liable as an enemy combatant) and of the civilian courts (for ordinary civilian crimes that he commits while pretending to be a civilian). Thus if (hypothetically) a saboteur tries to rob a bank and is tried for bank robbery, he is entitled to all the protections of the Fifth and Sixth Amendments during the civilian trial of a civilian criminal matter. However, if he is instead tried before a military tribunal on the offense of being a saboteur, then he is entitled to the protections provided in international law and the statutes creating the military commission. For example, under the current Obama military commissions he would not be entitled to Fifth Amendment protection against the use of un-Mirandized statements in a Military Commission but would be in the hypothetical civilian trial.
In considering how reasonable the first part is, it is important to note two things:
first he says not "serving in the armed service of" but "affiliated with" a terrorist organization. Second, what counts legally as a terrorist organization is entirely up to the administration who decides such things by fiat. Under current interpretations of "terrorist organization" and "affiliation" this would include anyone who shipped medical supplies to a hospital in southern Lebanon, since all are connected to Hizbullah. The first part, therefore, is nearly as fascist as the last. Mark Lance
In the MCA, Congress expressly denied a statutory right to habeas corpus to Boumediene. The Suspension Clause implies a constitutional right to Habeas Corpus. When the Boumediene Five held that Congress did not properly suspend Habeas Corpus for Boumediene, it held that Boumediene had a constitutional right to habeas corpus. There is no other source for that right. As to Quirin, there is no substantive difference between the Court's holding that the rights guaranteed by the Fifth and Sixth Amendments do not extend to enemy belligerents and holding that the Amendments do not apply to them. Quirin expressly held that enemy belligerents fell under the customary law of war.
The Boumediene decision teaches us that a Writ was originally a royal command. It could be issued by the King or by the King's Bench (a judge acting in the King's name). The Writ of Habeas Corpus allowed the King's Bench to enforce the King's law preventing local jurisdictions from holding the King's important subjects unlawfully. After Magna Carta the King himself became subject to the law, and then the Writ could be used to inquire about a detention instigated by the King himself. In its core, the Writ is a power of the courts, part of the Judicial Power that Article III assigns to the judiciary. In common law, however, the Writ is a sua sponte power, initiated by the judge based on any reason he has to suspect that someone is being detained illegally. After the Revolution, the new Congress was not satisfied with the record of English courts protecting civilian rights. So instead of relying on the common law power of the courts to inquire about the legality of detention, they added a statutory right of citizens to petition the court, and a process where the response to the petition was automatic. The MCA stripped detainees in Gitmo of all statutory Habeas rights. What was left is common law Habeas which 1) under the Constitution cannot be blocked except by the exercise of the Suspension clause, 2) has never been used by any court in the history of the US since every prior Habeas proceeding was statutory Habeas, and 3) is a power of the judge and not a right of the detainee. Since there had never been a common law Habeas process, the Supreme Court left it up to the judges of the DC Circuit to figure out what the procedures would be. The Suspension Clause is not about individual rights. It is not in the Bill of Rights. It is part of the checks and balances system. Habeas is a power of the Court. Congress has a check on this power, but it can only be exercised in certain enumerated emergencies. There is a subtext of the decision that imposes a moral but not a legal right. The courts should be a protection against illegal detention. Therefore, if someone is illegally detained, and this becomes apparent to a judge having jurisdiction over the location of detention, then the judge has a obligation of his office to use the Writ to inquire about the case. However, if it is clear to the judge that the detention is legal, then the judge has no obligation to initiate any formal proceedings (unlike statutory Habeas where the petition automatically triggers some process and review). This distinction became critical to the logical analysis of Boumediene. Everyone before the decision assumed that the question before the courts was whether the detainees at Gitmo had rights under the Constitution. That triggered a long argument about the historical reach of the Bill of Rights outside the US. The Supreme Court corrected this and explained that since the Writ was a power of the court, it reached to any location where the Court could issue an arrest warrant, search warrant, subpoena, or order of protection. The DC Circuit has routinely issued such orders to Gitmo, so they must also be able to issue the Writ. Once you ask the right question, what seemed to be a complex question of law and history turns out to be a trivial question with an obvious answer. Of course, this meant that we still don't know if the Gitmo detainees have any rights under the Constitution because the Court bypassed that analysis to reach its trivial decision.
There is no federal common law. The MCA expressly withdrew all statutory authority for habeas corpus. The Court held: "Petitioners have the constitutional privilege of habeas corpus. They are not barred from seeking the writ or invoking the Suspension Clause's protections... " It is true that the Suspension Clause is considered to impliedly incorporate the common law habeas corpus right that existed at the time of the ratification of the Constitution, but there is no current federal common law basis for the writ. Of course, this did not prevent the Boumediene Five from effectively treating the Constitution as common law by incorporating a fictional privilege that never existed under the American common law of the day and indeed was contrary to the British common law cases of Rex v. Schiever, 97 Eng. Rep. 551 (K.B. 1759) and The Case of the Three Spanish Sailors, 96 Eng. Rep. 775 (K.B. 1779), which expressly held that foreign prisoners of war did not enjoy habeas corpus review or any other rights of Englishmen.
"There is no federal common law." Bart
"The writ of habeas corpus was preserved in the Constitution — the only common-law writ to be explicitly mentioned" from the opinion of Scalia and Stevens in Hamdi v Rumsfield. You quote: "Petitioners have the constitutional privilege of habeas corpus. They are not barred from seeking the writ" Since a Writ was a royal command, one may have the privilege to seek it but none has a right to demand it. You no more have a constitutional right to a common law Writ of Habeas Corpus than you have to a Writ of Certiorari.
Article I, Section 9 states in pertinent part: The privilege of the writ of habeas corpus shall not be suspended, unless when in cases of rebellion or invasion the public safety may require it. The writ of habeas corpus is only termed a "privilege" because Congress may suspend it under limited circumstances. Absent a proper suspension, the ability to petition for habeas corpus review is an implied constitutional right.
"There is no federal common law."
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Ugh. The actual quote from Erie is "there is no federal general common law." Erie, of course, overturned Swift, from 1842, which allowed federal courts to create common law in traditional zones of state policy. Swift was closer to the text of the Constitution, where the federal courts are common law courts. Moreover, the Erie doctrine doesn't make much sense when one sees that the Seventh Amendment (still unincorporated) required a jury for cases at common law over $20. The pretense that there is no common law the federal courts makes the seventh superfluous Even after Erie, what about Bankruptcy? Admiralty? Federa Procedure? The Bill of Rights? What do you call that case law? I don't have time to address the misanalysis of habeas – and Howard has it under control |
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Carrots and Sticks: Unlock the Power of Incentives to Get Things Done (Bantam Books, 2010) Mark Tushnet, Why the Constitution Matters (Yale University Press 2010) Ian Ayres and Barry Nalebuff: Lifecycle Investing: A New, Safe, and Audacious Way to Improve the Performance of Your Retirement Portfolio (Basic Books, 2010) Jack M. Balkin, The Laws of Change: I Ching and the Philosophy of Life (2d Edition, Sybil Creek Press 2009) Brian Z. Tamanaha, Beyond the Formalist-Realist Divide: The Role of Politics in Judging (Princeton University Press 2009) Andrew Koppelman and Tobias Barrington Wolff, A Right to Discriminate?: How the Case of Boy Scouts of America v. James Dale Warped the Law of Free Association (Yale University Press 2009) Jack M. Balkin and Reva B. Siegel, The Constitution in 2020 (Oxford University Press 2009) Heather K. Gerken, The Democracy Index: Why Our Election System Is Failing and How to Fix It (Princeton University Press 2009) Mary Dudziak, Exporting American Dreams: Thurgood Marshall's African Journey (Oxford University Press 2008) David Luban, Legal Ethics and Human Dignity (Cambridge Univ. Press 2007) Ian Ayres, Super Crunchers: Why Thinking-By-Numbers is the New Way to be Smart (Bantam 2007) Jack M. Balkin, James Grimmelmann, Eddan Katz, Nimrod Kozlovski, Shlomit Wagman and Tal Zarsky, eds., Cybercrime: Digital Cops in a Networked Environment (N.Y.U. Press 2007) Jack M. Balkin and Beth Simone Noveck, The State of Play: Law, Games, and Virtual Worlds (N.Y.U. Press 2006) Andrew Koppelman, Same Sex, Different States: When Same-Sex Marriages Cross State Lines (Yale University Press 2006) Brian Tamanaha, Law as a Means to an End (Cambridge University Press 2006) Sanford Levinson, Our Undemocratic Constitution (Oxford University Press 2006) Mark Graber, Dred Scott and the Problem of Constitutional Evil (Cambridge University Press 2006) Jack M. Balkin, ed., What Roe v. Wade Should Have Said (N.Y.U. Press 2005) Sanford Levinson, ed., Torture: A Collection (Oxford University Press 2004) Balkin.com homepage Bibliography Conlaw.net Cultural Software Writings Opeds The Information Society Project BrownvBoard.com Useful Links Syllabi and Exams |

subset: commoncrawl


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A little tardy in getting this post up, but hey, better late than never --- Twin Infinities, a massive two-day group show, curated by Rich Jacobs and Sam James Velde, opened July 1st to July 2nd at the Nomad Art Gallery in Atwater, Los Angeles. Presented by Move & Tee Pee Records,Twin Infinities featured a huge line up of artists and musicians, some of whom have never shown works, including Chris Duncan, Sean Greene, Karoline Collins, Calef Brown, Sam James Velde, Rich Jacobs, Sandy Yang, Billy Sprague, Mike Sutfin, Ryan Patterson, Damon Robinson, Cynthia Connolly, Jeff Coad, Bert Queiroz, Ben Clark, Jordin Isip, Melinda Beck, James Gallagher, Matt Leines, Tim Kerr, Chris Johanson, Pat Graham, Chrissy Piper, Clint Woodside, James Ross, Sonny Kay, Jason Farrell, Ross Farrar, Josh Turner, Atiba Jefferson, Cali Dewitt, Mark McCoy, Nina Hartman, Otis Bee, Lee Spielman, James Wall, Malia James, Magdelena Wosinka, Jim Brown, David Pajo, Bill Daniel, Chris Shary, Brian Walsby, Rick Froberg and more.
Musical performance by Coliseum.
Work by Tim Kerr
Twin Infinities
Nomad Art Gallery
Opening Reception: July 1st to July 2nd
1993 Blake Avenue
Los Angeles, CA 90039
Works by Rich Jacobs.


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7 Singers Other Than Christina Aguiera Who Flubbed the National Anthem
Christina Aguilera has the right kind of voice to belt out a memorable national anthem. Unfortunately, her performance at Super Bowl XLV will be remembered for the wrong reason.
As you've probably heard, Aguilera flubbed the anthem, forgetting the lyric "o'er the ramparts we watched."
Aguilera is far from the first person to botch the Star Spangled Banner. Check out last night's flub an


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Saint Austell QIBLA DIRECTION There are many methods to find the Qiblah direction. One of the easiest ways is using compass. Qibla direction changes from city to city or country to country depending on the distance. From this site, you will easily find Qibla direction. The red pointer indicates magnetic north. There is much difference between the deflection angle with magnetic north. Therefore, we give two different Qibla direction angle. For Saint Austell use the angle 117
Note that there are no large metal objects around. (Not even smaller metal objects). If there are any larger metal objects, such as cars, please apply the process 10 meters off. Set your compass as the red needle shows the North. Then you can turn to 117° and pray to the Allah.


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LYON, France – A DNA match made by INTERPOL has led to the arrest of an Afghan national in Austria suspected of a series of rapes in the US and in Europe.
In December 2009, US authorities sent a DNA profile linked to a number of violent sex attacks in California between 2002 and 2004 to INTERPOL's General Secretariat headquarters in Lyon, France. INTERPOL's global DNA database matched the profile with another submitted by Austria as part of an investigation into a rape in Salzburg in April 2009.
Immediately after confirming the hit, INTERPOL's DNA unit alerted both countries which then exchanged further investigative information, including fingerprints and photographs in order to confirm the man's identity.
The 32-year-old Afghan man, identified by US authorities as Ali Achekzai, and who is believed to have visited a number of countries using an alias, was arrested in Salzburg on Tuesday and is now awaiting extradition to the US.
"There is no way that this arrest could have been made without INTERPOL's global DNA database," said INTERPOL Secretary General Ronald K. Noble. "This is a perfect example of the added value INTERPOL can bring to any investigation anywhere in the world, making connections between what appear to be unrelated cases.
"If the investigators in California had not sent the DNA profile from what was considered a 'cold case' to INTERPOL, and if Austria had not shared the information, it is 100 per cent certain that this man, who clearly poses a serious danger to women, would still be at large," said the INTERPOL chief.
"Austria has been a strong supporter of INTERPOL's DNA database since its launch. A crucial element in this case was the co-ordination between the National Central Bureaus in Vienna, Washington and the DNA unit in Lyon.
"I would particularly like to praise the actions of the Orange County Sheriff's office and Detective Ryan Coe of the Tustin Police Department. His foresight in sharing the DNA profile from these brutal attacks with the international police community was definitely a key factor in this arrest.
"In 2006 Congressman Dana Rohrabacher organized a meeting between INTERPOL and law enforcement officials from southern California so that they could learn how working with INTERPOL could both keep Californians safe and help solve serious crimes. I am convinced that the co-operation begun that day formed the basis for our joint success. For this I am grateful to Congressman Rohrabacher," added Mr Noble.
INTERPOL is now contacting all 188 member countries in order to determine which countries may have been visited by the 32-year-old and if he is wanted in connection with any other crimes around the world.
INTERPOL's DNA database – the only global database of its kind – was created in 2003 and currently contains approximately 95,000 profiles submitted by 55 member countries resulting in 250 potential international matches.
All DNA profiles submitted to INTERPOL are anonymous, with member countries retaining ownership of the profile data and controlling its inclusion, access and destruction in accordance with their national laws. Delegates at INTERPOL's 2009 General Assembly in Singapore endorsed a resolution for the expansion and increased use of INTERPOL's DNA and fingerprint databases by frontline officers in member countries to help solve crimes and identify fugitives through data comparison.


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Ergonomically designed for women, the Women's Trestles 30 is a reliable all-purpose bag for everything from weekend camping to days on the trail. SpiraFil high loft insulation, wave construction and 3D hood keep you warm and comfortable, while a long list of features gives you everything you'd expect from 40 years of crafting sleeping bags.
Feature List
- EN Tested
- SpiraFil High Loft Insulation
- Fold-Down Second Zipper Provides Easy Access
- Women's Specific Fit - More Insulation in Key Areas.
- Wave Construction
- Classic Trapezoidal Foot Box
- Compression Stuff Sack
- Feely Draw Cords
- Hood Draw Cord
- Second Side Zip
- Snagless Draft Tube
- Stash Pocket
- Two Hang Loops
- Two Way Zipper Sliders
- Velcro®-free Face Muff
- Zipper Guards
- Updated EN 13537 Rating
Main Materials
100% Polyester DWR 2.2 oz/yd, 100% Polyester Embossed DWR 2.2 oz/yd
Lining Material
100% Polyester Tafffeta DWR 2.2 oz/yd
Insulation Material
SpiraFil™ 120
Fill Weight
22.94oz (650g)
Bag Loft
Bag Temperature F
Bag Temperature C
EN Rating
Comfort: 33.3°F / 0.7°C | Lower Limit: 23°F / -5°C | Extreme: -7.9°F / -22.2°C
Interior Length
75in (191cm)
Bag Dimensions (Shoulder x Hip x Foot)
58in (147.3cm) x 58in (147.3cm) x 38in (96.5cm)
Bag Zipper position
3lbs 5.9oz (1528g)
SpiraFil™ is Marmot's own unique synthetic insulation used in our value-priced line of sleeping bags.
What is it?
SpiraFil™ is a unique blend of large, spiral hollow fibers for loft, and small polyester fibers for warmth, softness and compressability.
What are the benefits of this technology?
SpiraFil™ provides an exceptional combination of warmth, softness, low weight, and compactibility. Thermal bonding ensures high tear strength and long-term durability.
EN Tested
Testing Center
Marmot began as a sleeping bag company and we continue to pioneer performance, value and insulation standards in the outdoor industry. All Marmot sleeping bags are EN tested to ensure quality and performance. During the development process, we send all samples to the Thelma Testing Center in Norway. We continually use the Thelma Center to achieve continuity in our results.
What is the EN 13537 test? EN, short for European Norm, is a government test for sleeping bags.
How is the EN test conducted? First let's be clear that it is challenging to test temp ratings because there are so many variables. Every person will sleep differently in the same bag. Choices like clothing, sleeping pad, tent or no tent, eating and drinking before bed can all affect one's sleeping experience. For the EN test, a copper mannequin named Charlie is fitted with 20 sensors and a clothing layer (top, bottom, and socks) that provide a consistent thermal value. The mannequin is placed in the sleeping bag and put onto a wood platform roughly 12mm thick. The board is held above the floor with some support which allows air circulation under the board. The board is covered with a mattress that has a consistent thermal value then placed in a cold room. A mathematical formula is used to measure the data received from the sensors based on human modeling.
Why is there an EN Test hangtag on Marmot bags? Marmot sleeping bags sold in Europe require this testing and hangtag. We include this hangtag on all of our bags, as we believe it is the most reliable and accurate measure of the performance of a sleeping bag currently available.
How does EN testing differ from other methods and is it better? When Marmot first started testing bags, especially when we used Gore-Tex® fabric, our designers would go into meat lockers and sleep over night. Once they were able to sleep through the night they looked at the amount of fill to determine the temp range. Nowadays it is a bit more scientific. The testing method used in the US is very similar to the EN test. They use a copper mannequin, but the clothing, pad, and math formula are different. Again we feel the EN test is the most reliable and accurate measure of the performance of a sleeping bag currently available.
Has the feedback from the EN testing improved the designs of Marmot bags? Yes it has. The vast majority of our bags have tested to our current temp ratings. In some cases, the tests showed our bags were actually warmer than the rating we gave it. In another instance, there was a spot that showed room for improvement which led to more efficient baffle construction. With our baseline testing started in 2004, we can now measure improvement over time through new fabrics, insulation, and construction techniques.
Will the EN test become an industry wide standard? That is unknown. Currently our industry can't agree on how the testing should be done because of all the variables. The European government has stepped in and taken control of standardized testing. For the meantime, Marmot will continue to test with the EN standard.
Marmot rating vs. EN rating? Marmot's assigned temperatures are comparable to the EN lower limit rating. During Marmot's development process we send all samples to the Thelma Testing Center in Norway. Continually using the Thelma Center allows us to achieve continuity in our results.
Why do we encourage proper care of our clothing and gear?
Because you have invested in (or are thinking about investing in) one of the most technically advanced pieces of apparel or equipment you'll ever own and we want to make sure you have the information you need to protect and care for your purchase. Proper care assures you will optimize the performance of your Marmot product and maximize its service-life.
Sleeping Bag Care
- Hand wash warm, 105 degrees Fahrenheit or 40 degrees Celsius or machine wash Warm, Gentle cycle in a front load washer only.
- If you need to use a detergent, only use powdered form
- Rinse thoroughly
- Do not wring your sleeping bag
- Hang dry or tumble dry on low heat. If tumble drying a down bag, toss a couple of clean tennis balls in the dryer to help re-loft the bag
- After your bag is dry, store in a loose storage container. Cotton or mesh stuff sacks or extra-large pillow cases work well
- Do not store in a space where temperatures could exceed 125 degree Fahrenheit
- Do not bleach
- Do not iron
- Do not dry clean
Brand | Marmot |
Insulation Type | Synthetic |
Temperature Rating | -1°C |
Max Magnification | No |
If you have any questions about this product, then you can leave us a message via Facebook below


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Tom Foley is dead to me
I was looking forward to a spirited rematch between Gov. Dannel Malloy and his Republican challenger in the last gubernatorial race, Tom Foley.
I even think Foley, who has launched only an exploratory committee for the race, has been on his game so far, raising legitimate ethical questions that have had both Republicans and Democrats in the state squirming.
There is no question that Malloy, if he runs, as expected, is extremely vulnerable, running a state that seems to lag behind the rest of the country on most economic score sheets.
Then along came this week's government shutdown, sponsored by a cadre of crazed Republicans in Washington.
Malloy suddenly looks a lot better to me, and maybe to many sane Connecticut voters.
Foley, according to one newspaper interview he gave earlier this week, has sided with the tea party, saying that he endorses the strategy of House Republicans to shut down the government to extract changes in the Affordable Care Act.
"So I support what they are doing," Foley was quoted as saying.
That was enough to cross him off my list of people who might make a good Connecticut governor.
And I had thought, wrongly, apparently, that maybe Foley was the kind of level-headed Republican who would condemn the ransom-taking tactics of the extremists in the party.
After all, there are enough reasonable Republicans in the House to pass a bill today to reopen the government, if only their speaker, pandering to the far right wing of his party, would bring it to the floor for an honest vote.
I tried to reach Foley Thursday to find out if there was some nuance in his remarks about the shutdown I am missing.
I didn't have any luck.
First of all, the press releases from his exploratory committee don't have any contact information on them. Maybe that alone should disqualify him for office, sending out press releases without contact information.
I also left a message on his home phone in Greenwich. I didn't hear back.
In Googling around to try to find Foley, I did come across a listing indicating his 125-foot motor yacht, named Odalisque, after the female slave in a Turkish harem (I know, I know) is for sale for $5.9 million.
I emailed the broker, who wrote back and said he is in dialogue with the owner, who may take the yacht off the market.
Maybe that is part of Foley's exploratory process: He's thinking about spending more time on the yacht and giving up on another expensive run for governor.
I had hoped, too, that maybe some of the other possible Republican candidates for Connecticut governor might be counted in the reasonable GOP camp, like the Republican House members who would reopen the government without demanding changes to a health care program that is already the law of the land.
Alas, no.
I couldn't reach state Sen. Toni Boucher of Wilton, who also has an exploratory committee. But she told another newspaper this week, while complaining about the health care act, that we've had shutdowns before and they haven't been that bad.
So she's off my list.
Exploratory candidate Mark Boughton, mayor of Danbury, politely returned my call and explained that he thinks there's blame to go around both parties in Washington. But he said linking negotiations about the health care act to a government shutdown is OK with him.
"It's how sausage is made," he said.
He's off my list, too.
I came away from a long and spirited chat with declared gubernatorial candidate John McKinney of Fairfield, state Senate minority leader, impressed that he is a thoughtful candidate who was also willing to lay blame for the shutdown on both parties.
In the end, though, he seems to side with Boughton on the sausage-making theory. I could not get him to condemn the strategy of linking a government shutdown with demands to change the health care law.
This is classic pre-primary politics: reach to the extremes of your party, then hustle back to the center before the general election.
This time I think it may backfire, since moderate voters might remember for a long time the paychecks missed here in Connecticut and the economic harm done by the people who brought us the shutdown and debt ceiling jitters of 2013.
This is the opinion of David Collins.
Comment threads are monitored for 48 hours after publication and then closed.


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2.bp.blogspot.com |
I was on vacation with limited access to the Internet or television when the tragic Aurora shooting occurred. Hearing about the incident from afar didn't dampen the shock in the slightest, especially since it was so close to my home in Denver. Since I was out of town, I missed much of the local conversation surrounding the shooting. However, when a tragic event like this occurs, it's inevitable that the national conversation about guns and gun control will resurface. I was only in high school when the 1999 Columbine tragedy occurred (again, relatively close to my high school in Colorado Springs). It seems the gun debate just won't go away.
Before I share my opinion on gun control, I feel compelled to air any potential biases that affect my beliefs. First off, I'm not particularly fond of guns (I don't currently own one), but I've recently considered purchasing one for safety reasons. I must admit that I find guns intimidating and I don't like the loud noise they make when fired (especially if I don't have earplugs). Over the course of my life I have been to several shooting ranges and I have even been pheasant hunting too. However, shooting guns just for the fun of it doesn't really have much appeal to me. There are countless other things I'd rather be doing with my free time.
I can't remember exactly what prompted me to read it, but at one point during my freshmen year of college I read John Lott's book More Guns, Less Crime. At the time, I found Lott's overall argument very compelling, particularly his empirical work. Admittedly, I think I was, at least partly, also attracted to the contrarian conclusion he presented. More guns, less crime — it's so counterintuitive and such a fun point to argue! To call my college 'self' sophomoric is perhaps an understatement.
Years later I learned that there are also academics who have pored over the same crime and gun data, but have come to the exact opposition conclusion. How can this be? Well, my initial thought is that at least one of our political parties (but perhaps both) doesn't have an interest in the truth. Rather, they simply want to find evidence to confirm what they want to believe. In other words, they are guilty of committing confirmation bias, i.e., they have a conclusion in mind that they want to reach (e.g., guns cause less crime) and they look for data to confirm their belief and shun any evidence that goes against that belief. Given my predilection for liberty, I'm a fan of the second amendment, so it shouldn't come as a surprise that I was naturally and initially drawn to Lott's work and unfairly dismissive of the counter arguments and evidence. In other words, I was guilty of confirmation bias.
So, do gun control laws reduce crime? It appears to me that there are three possibilities: they produce the intended effect, they produce an unintended effect, or they don't produce an effect at all. The trouble is that I don't know what the right answer is and I don't think anyone else does either. I'm willing to bet that the people who claim to scientifically know the answer to this question have an idealogical axe to grind. Have you ever met anyone who is a passionate gun owner yet finds the scientific evidence against guns compelling? I didn't think so and the same thing can be said of anti-gun folks as well.
On the surface of it, the gun control question appears to be a scientific one. But before we waste all this time quibbling over the statistical techniques "the other side" is using, we probably first ought to ask ourselves an important epistemological question. Is it really possible to scientifically know if gun control laws (or the number of concealed weapon permits issued) reduce crime? I just happen to think the answer is 'no.' There are far too many complexities and variables to account for when doing econometric work on crime, guns, and gun control laws.
If I'm correct, then where does that leave us? Well, I think it leaves us with economic logic and if there's one thing I'm pretty confident is true, it's that incentives matter, even to criminals. When the cost (or potential cost) of committing a crime is high, we expect to see less crime. Regardless of what one thinks about the current federal and state marijuana laws, imagine what would happen if being caught in possession of marijuana came with a minimum of a twenty year prison sentence and was strictly enforced (meaning that a police officer could randomly come to your home at any time to check on you). Many of us would find this type of infringement on our personal liberty unpalatable (a cost), but if you think that the number of people that would possess marijuana would decrease significantly (a benefit?), then you understand how incentives work.
Another interesting thing to note about marijuana is that the fact that it's illegal hasn't made it any more difficult for people to obtain. Again, making something illegal doesn't necessarily make it costly. I suspect that today's American teenagers may actually have an easier time scoring illegal drugs, like marijuana, than they do alcohol which is legal for a certain demographic of the population. It's also worth remembering that there is a black market for illegal things and laws don't magically stop criminals from engaging in commercial activity on the black market. Also, lest we forget, guns don't mysteriously kill people, people do. Accordingly, I find the argument some people make for banning all guns to be absurd, but I also find the argument for the unimpeded right to own whatever type of firearms one wants equally absurd. I don't think that Americans have a right to own rocket launchers (I agree with Michael's point in his recent post about finding middle ground.)
So one way to reduce crime, according to economic logic, is to make the cost of committing a crime high. There are multiple ways of doing this and they don't necessarily involve creating or enforcing laws — incentives actually work in many ways. Consider the following thought experiment: imagine you are a burglar and have the choice of going to a house where you know the homeowner doesn't own a gun or the choice of going to one in which you know the homeowner has a gun. Which one would you choose to burglarize? If the answer isn't obvious please don't consider a career in crime. But would this line of reasoning really work with the likes of the Aurora shooter? Yes, even the Aurora shooter, lunatic that he is, responds to incentives. If he knew that there was a high probability that a moviegoer in one particular theater was armed and willing to shoot him, I bet he would have reconsidered his decision. He was crazy and evil, but apparently he wasn't suicidal.
A natural follow-up question is: Why can't stricter laws alone deter crimes by increasing the costs of crime? The answer, I think, is that they can, if only we were able to enforce them properly. Life, however, is full of trade-offs. If the punishment for committing a burglary were more severe and if there were a police officer assigned to patrol each and every street in America, then I suspect we would rarely ever see burglaries. This, however, would be pretty costly for the government, which brings up another interesting economics-related lesson, i.e., there is a cost to enforcing laws too and we must decide which costs are worth incurring and which are not. This may sound strange, but from a societal and economic perspective, the optimal number of burglaries is probably not zero (I think shootings are different due to the value of human life, but I'm sure some economist, somewhere, has extended the argument here before).
Here's what I know: if I had been unfortunate enough to be in the audience the night of the Aurora shooting, I would have desperately hoped that one of my fellow moviegoers had been armed. Similarly, had I been in the library at Columbine High School on the day of the shooting, I would have desperately hoped that the librarian was packing heat. The reason I'm generally not in favor of stricter gun control laws is a logical one, i.e., because I think criminals respond to incentives outside of the law.
It's an indisputable fact that most legal gun owners never commit a crime with their weapon. Making guns outright illegal won't necessarily stop the problem America is facing. Laws don't stop evil people from doing evil things. The increasing mass violence in our culture is the symptom of a much larger problem, one which is simply outside the scope of this essay. But please, let's stop blaming it entirely on guns.


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I have a three-year-old daughter going through a struggle at the moment. It's time for her to give up the teddy bear that follows her wherever she goes. But we'll hear a little more about her later, including what she can teach us about providing a richer user experience.
There is something comforting about knowing how to escape from a situation; knowing how to start again and knowing how to return home. Recall the famous in-flight safety demonstration you get each time you board a plane. What's the most memorable line? "In case of emergency, your exits are here, here, and here." As much as we mock the repetitive instruction, deep down we appreciate that if anything goes wrong at least we know how to get out alive.
Bringing it back to UX, a key to giving the user confidence in navigation is to help them know how to get back to the homepage. It's similar to the back button but with superpowers. The homepage can be a safe haven and a place to regroup or explore, but let's not give it too much credit. Sometimes going back to the homepage isn't a comforting experience, it's through pure frustration or defeat that you can't figure out where you are or where you are going. Returning back home can be a last resort, similar to going on a 10-hour car journey, getting lost 9 hours in and then deciding to go home and start again.
In Steve Krug's excellent book Don't Make Me Think: A Common Sense Approach to Web Usability he writes: "Having a home button in sight at all times offers reassurance that no matter how lost I may get, I can always start over, like pressing a reset button or using a 'Get out of jail free' card."
It may be comforting to users that they can return home, but do we actually want them to?
What's the Value of Going Home?
Search engine optimization has resulted in the homepage losing its place as the single entrance to a website and in many cases is being bypassed more and more each year.
Gerry McGovern sums this up perfectly in his article "The decline of the homepage," stating: "Many marketers and communicators think their homepage is a giant billboard or megaphone. They become obsessed with its redesign and with placing lots of happy talk and smiling faces on it. Your customers don't want to get to your homepage. At best, the homepage is merely a series of signposts that will help them head in the right direction."
Of course the homepage plays an important role in any website and should not be ignored, but an unbalanced promotion of returning home can work against you. Suppose the user has just filled out a form or signed up to a mailing list (therefore showing an interest in your services) and the most obvious route to them is to return home. You may even have added a new button to make it easier for them to do so. Is that really the best option?
How Many Ways Home?
Users have varying expectations of where to find the home button and what it will look like based on their level of web experience. That wasn't always the case, have a glance at these original pages of some top sites when they were launched. It is difficult to see any consistency between the routes home on these original sites.
Today there are several standard ways to return:
- Home button with text "Home" or an icon of a house
- Clickable logo
- Breadcrumb trail
Research shows that a clickable logo isn't yet a universally understood way of returning home even though it is widely used that way. Leaving out a dedicated home button in the navigation risks confusing many users, but that isn't stopping the practice from gaining popularity. A study was conducted in 2011 by ProMediaCorp who looked at the top 500 websites (defined by Alexa) to determine if there was a home button in the site navigation. The results showed that 37.4% had a dedicated link and 62.6% did not.
So if many of the top sites are leaving out the home button, is it working? Here are the names of eight popular websites. Your task is to recall the main way to get back to the homepage. Answers at the end of this article (no cheating):
- Apple
- eBay
- Facebook (when logged in)
- LinkedIn (when logged in)
- Twitter (when logged in)
- YouTube
- Wikipedia
For sites where the homepage is a key feature, such as social networks, which can include a personalized news feed or act as a central hub for user activity, there are clear markers to direct you home. Over the past couple of years Facebook has even made some changes to the tool tip when you hover over the logo, reflecting a change in user understanding of how to get back home.
On the other hand, sites where the homepage is not the central hub of activity (such as eBay), the trend is to make the route home less prominent. One notable exception to this rule is Pinterest, in which the homepage is hugely important to the user but has no dedicated home button, only a clickable logo in the top center, and search in the top left.
Providing a Richer User Experience
Let's go back to my three-year-old daughter. The new rule in the house is that the teddy stays in the bedroom, always there if she wants to go and see it, but it isn't allowed to follow her around the house anymore as a constant companion. She initially found this difficult but it has introduced her to a new way of living and a richer experience. Some users will be in for a shock when they start to live life outside of the home button!
As UX designers, we have a responsibility to provide a rich user experience. By relying too much on sending the user back home, we limit the possibilities at every level and entry point of the site. Take a look at where you are driving your user base and decide if your user journeys rely too heavily on the homepage as the starting point. If you do not already know the behaviors and activities of your audience then consider using the Lean Startup approach and test your assumptions, then "pivot or persevere." Maybe it's time for a change.
If your audience is technically savvy, use it to your advantage. Make the navigation less cluttered, reduce the barrage of homepage routes, and instead enrich the user experience throughout. For those sites aimed at a less technically savvy audience, you may be forced to give up some real estate above the precious fold and provide an obvious way home, but you can still avoid this route becoming the be-all and end-all.
Let me know how you scored on the quiz and how you have chosen to employ the home button on your site. Share your viewpoint on whether the home button, whatever form it takes, should be active on the homepage itself. Apple and Google disagree. That's a great one for filling an awkward silence on a first date …
Answers to the quiz (correct at time of publication):
- Apple: clickable logo – top left in the primary navigation
- eBay: clickable logo, no separate home button
- Facebook: clickable logo and home button top right (when logged in)
- LinkedIn: clickable logo and home button top left (when logged in)
- Twitter: home button top left (when logged in)
- YouTube: clickable logo, no separate home button
- Google: clickable logo, home button bottom left
- Wikipedia: clickable logo, no separate home button
Image of girl and teddy bear courtesy Shutterstock.


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Easy DIY Projects for Teens to Make – Quick Sewing Tutorial for a DIY Eye Pillow – DIY Projects & Crafts by DIY JOY
How To Make Pillow Covers
Whether you have long-standing arts and crafts abilties or now not, a fun manner to add your own touch to babys nursery decor is thru a few DIY decorating. Making your own pillows can add coloration and texture right into a room while additionally letting you take manipulate of fabrics. Envelope pillow covers are especially beneficial because you can instantly change the look of a room with a new cowl. Learn the way to make a wellknown envelope pillow cowl with our 3 step guide.
1. Wash the material: Because unwashed sewn material can decrease or rip while you put it in the washer and dryer later on, you ought to wash the material you choose beforehand.
2. Measure the pillow: Take measuring tape and stretch it throughout the curve of the pillow. Once youve got your measurements, add 1 / 4 to a half of inch on every dimension to ensure which you have extra fabric. Its always better to have extra fabric left over than no longer enough!
3. Cut the cloth: Cut the primary panel material to suit the previous size of duration. Add a 1/2 to at least one inch to the peak and width. Cut some other two pieces (small panels) which can be kind of your length minus about 6 inches and the equal height.


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When Sir Arthur Conan Doyles Sherlock Holmes applied himself to a difficult case, he famously utilized his powers of deduction. Holmes assembled and examined the facts before him and employed a scientific method of analysis to arrive at a solution that took into account of all the elements of the case. The great fictional detectives who followed in his wake including Agatha Christie's Miss Jane Marple and Hercule Poirot, and G.K. Chesterton's Father Brown, all utilized Holmes's painstaking attention to detail and his inimitable, relentless logic.
Your chiropractor, as well, employs methods similar to Holmes in their search for the causes of your health issues and the keys that will provide access to abundant wellness and well-being. On the first office visit with a new patient, your chiropractor obtains a thorough health history, including current and past problems, past surgeries, medications, and everything else that is important to understanding your present health circumstances. Next is the physical examination, in which your chiropractor gathers objective findings such as the ranges of motion of your neck, lower back, and various extremities. The strength of key muscle groups is determined, reflexes are tested, and sensory patterns in your arms and legs are assessed.
Additionally, your chiropractor examines the mobility and overall function of the joints of your spine, especially in the cervical (neck) and lumbar (lower back) regions, to identify locations of spinal joint dysfunction and nerve interference. Finally, based on your health history and the physical examination findings, as well as information derived from X-rays and other special tests, if needed, your chiropractor deduces the likely source of your health complaints and devises a program of treatment that will help restore and maintain good health.
By utilizing a comprehensive process of deduction, your chiropractor ascertains the primary spinal regions of joint dysfunction and nerve irritation that are interfering with your ability to express optimal health and well-being. Treatment is directed at correcting these biomechanical problem areas by use of manual chiropractic methods and instruction in rehabilitative exercise routines. Your chiropractor may also help you to set-up a healthy eating program that works for you, as well as provide information on establishing nighttime habits to consistently obtain sound, restful sleep.
Regular chiropractic care is important for all of us, from the youngest members of our families to the oldest. By detecting and correcting sources of nerve interference, our chiropractors help us to demonstrate high levels of health and wellness, now and into the future. Habits of good health can spread throughout a neighborhood and a community. As a result, in the long run, everyone benefits.


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Editor's Note: This article was first published in 2011. Explore the latest scientific and archaeological insights into the historical Jesus on the CNN Original Series 'Finding Jesus,' Sundays at 9pm ET/PT on CNN.
NFL legend Mike Ditka was giving a news conference one day after being fired as the coach of the Chicago Bears when he decided to quote the Bible.
"Scripture tells you that all things shall pass," a choked-up Ditka said after leading his team to only five wins during the previous season. "This, too, shall pass."
Ditka fumbled his biblical citation, though. The phrase "This, too, shall pass" doesn't appear in the Bible. Ditka was quoting a phantom scripture that sounds like it belongs in the Bible, but look closer and it's not there.
Ditka's biblical blunder is as common as preachers delivering long-winded public prayers. The Bible may be the most revered book in America, but it's also one of the most misquoted. Politicians, motivational speakers, coaches - all types of people - quote passages that actually have no place in the Bible, religious scholars say.
These phantom passages include:
"God helps those who help themselves."
"Spare the rod, spoil the child."
And there is this often-cited paraphrase: Satan tempted Eve to eat the forbidden apple in the Garden of Eden.
None of those passages appear in the Bible, and one is actually anti-biblical, scholars say.
But people rarely challenge them because biblical ignorance is so pervasive that it even reaches groups of people who should know better, says Steve Bouma-Prediger, a religion professor at Hope College in Holland, Michigan.
"In my college religion classes, I sometimes quote 2 Hesitations 4:3 ('There are no internal combustion engines in heaven')," Bouma-Prediger says. "I wait to see if anyone realizes that there is no such book in the Bible and therefore no such verse.
"Only a few catch on."
Few catch on because they don't want to - people prefer knowing biblical passages that reinforce their pre-existing beliefs, a Bible professor says.
"Most people who profess a deep love of the Bible have never actually read the book," says Rabbi Rami Shapiro, who once had to persuade a student in his Bible class at Middle Tennessee State University that the saying "this dog won't hunt" doesn't appear in the Book of Proverbs.
"They have memorized parts of texts that they can string together to prove the biblical basis for whatever it is they believe in," he says, "but they ignore the vast majority of the text."
Phantom biblical passages work in mysterious ways
Ignorance isn't the only cause for phantom Bible verses. Confusion is another.
Some of the most popular faux verses are pithy paraphrases of biblical concepts or bits of folk wisdom.
Consider these two:
"God works in mysterious ways."
"Cleanliness is next to Godliness."
Both sound as if they are taken from the Bible, but they're not. The first is a paraphrase of a 19th century hymn by the English poet William Cowper ("God moves in a mysterious way, His wonders to perform).
The "cleanliness" passage was coined by John Wesley, the 18th century evangelist who founded Methodism, says Thomas Kidd, a history professor at Baylor University in Texas.
"No matter if John Wesley or someone else came up with a wise saying - if it sounds proverbish, people figure it must come from the Bible," Kidd says.
Our fondness for the short and tweet-worthy may also explain our fondness for phantom biblical phrases. The pseudo-verses function like theological tweets: They're pithy summarizations of biblical concepts.
Christianity's relics: The revered, the morbid and the bizarre
"Spare the rod, spoil the child" falls into that category. It's a popular verse - and painful for many kids. Could some enterprising kid avoid the rod by pointing out to his mother that it's not in the Bible?
It's doubtful. Her possible retort: The popular saying is a distillation of Proverbs 13:24: "The one who withholds [or spares] the rod is one who hates his son."
Another saying that sounds Bible-worthy: "Pride goes before a fall." But its approximation, Proverbs 16:18, is actually written: "Pride goeth before destruction, and an haughty spirit before a fall."
There are some phantom biblical verses for which no excuse can be offered. The speaker goofed.
That's what Bruce Wells, a theology professor, thinks happened to Ditka, the former NFL coach, when he strayed from the gridiron to biblical commentary during his 1993 press conference in Chicago.
Wells watched Ditka's biblical blunder on local television when he lived in Chicago. After Ditka cited the mysterious passage, reporters scrambled unsuccessfully the next day to find the biblical source.
They should have consulted Wells, who is now director of the ancient studies program at Saint Joseph's University in Pennsylvania. Wells says Ditka's error probably came from a peculiar feature of the King James Bible.
"My hunch on the Ditka quote is that it comes from a quirk of the King James translation," Wells says. "Ancient Hebrew had a particular way of saying things like, 'and the next thing that happened was…' The King James translators of the Old Testament consistently rendered this as 'and it came to pass.' "
When phantom Bible passages turn dangerous
People may get verses wrong, but they also mangle plenty of well-known biblical stories as well.
Two examples: The scripture never says a whale swallowed Jonah, the Old Testament prophet, nor did any New Testament passages say that three wise men visited baby Jesus, scholars say.
Those details may seem minor, but scholars say one popular phantom Bible story stands above the rest: The Genesis story about the fall of humanity.
Most people know the popular version - Satan in the guise of a serpent tempts Eve to pick the forbidden apple from the Tree of Life. It's been downhill ever since.
But the story in the book of Genesis never places Satan in the Garden of Eden.
"Genesis mentions nothing but a serpent," says Kevin Dunn, chair of the department of religion at Tufts University in Massachusetts.
"Not only does the text not mention Satan, the very idea of Satan as a devilish tempter postdates the composition of the Garden of Eden story by at least 500 years," Dunn says.
Getting biblical scriptures and stories wrong may not seem significant, but it can become dangerous, one scholar says.
Most people have heard this one: "God helps those that help themselves." It's another phantom scripture that appears nowhere in the Bible, but many people think it does. It's actually attributed to Benjamin Franklin, one of the nation's founding fathers.
The passage is popular in part because it is a reflection of cherished American values: individual liberty and self-reliance, says Sidnie White Crawford, a religious studies scholar at the University of Nebraska.
Yet that passage contradicts the biblical definition of goodness: defining one's worth by what one does for others, like the poor and the outcast, Crawford says.
Crawford cites a scripture from Leviticus that tells people that when they harvest the land, they should leave some "for the poor and the alien" (Leviticus 19:9-10), and another passage from Deuteronomy that declares that people should not be "tight-fisted toward your needy neighbor."
"We often infect the Bible with our own values and morals, not asking what the Bible's values and morals really are," Crawford says.
Where do these phantom passages come from?
It's easy to blame the spread of phantom biblical passages on pervasive biblical illiteracy. But the causes are varied and go back centuries.
Some of the guilty parties are anonymous, lost to history. They are artists and storytellers who over the years embellished biblical stories and passages with their own twists.
If, say, you were an anonymous artist painting the Garden of Eden during the Renaissance, why not portray the serpent as the devil to give some punch to your creation? And if you're a preacher telling a story about Jonah, doesn't it just sound better to say that Jonah was swallowed by a whale, not a "great fish"?
Others blame the spread of phantom Bible passages on King James, or more specifically the declining popularity of the King James translation of the Bible.
CNN Original Series 'Finding Jesus'
That translation, which marks 400 years of existence this year, had a near monopoly on the Bible market as recently as 50 years ago, says Douglas Jacobsen, a professor of church history and theology at Messiah College in Pennsylvania.
"If you quoted the Bible and got it wrong then, people were more likely to notice because there was only one text," he says. "Today, so many different translations are used that almost no one can tell for sure if something supposedly from the Bible is being quoted accurately or not."
Others blame the spread of phantom biblical verses on Martin Luther, the German monk who ignited the Protestant Reformation, the massive "protest" against the excesses of the Roman Catholic Church that led to the formation of Protestant church denominations.
"It is a great Protestant tradition for anyone - milkmaid, cobbler, or innkeeper - to be able to pick up the Bible and read for herself. No need for a highly trained scholar or cleric to walk a lay person through the text," says Craig Hazen, director of the Christian Apologetics program at Biola University in Southern California.
But often the milkmaid, the cobbler - and the NFL coach - start creating biblical passages without the guidance of biblical experts, he says.
"You can see this manifest today in living room Bible studies across North America where lovely Christian people, with no training whatsoever, drink decaf, eat brownies and ask each other, 'What does this text mean to you?"' Hazen says.
"Not only do they get the interpretation wrong, but very often end up quoting verses that really aren't there."