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A piece for iNews today following Lord Hain's decision to invoke Parliamentary privilege to name Philip Green in defiance of a court injunction.
You can read my musings here.
A piece for iNews today following Lord Hain's decision to invoke Parliamentary privilege to name Philip Green in defiance of a court injunction.
You can read my musings here.
This will be (for now) my last word on the Tommy Robinson appeal. My legal analysis based on the facts as we now know them deals exhaustively and exhaustingly with the law; my reflections at the conclusion of that piece on whether I was too hasty to assume the correctness of the procedure, I stand by. Being quick to form views in the absence of the full facts is a bear trap I haughtily deplore when others fall in; it is only right to acknowledge if and when I teeter on the brink myself.
But I want to say something, for what little it is worth, about our understanding of justice. And my leaping-off point for this is something that a number of people have drawn my attention to today – this leader in The Sun.
The tweets to me accompanying this photo have been almost uniform: Who'd Have Thunk it, The Sun sticking it to Robinson and Co, Good On 'Em.
And parts of this leader are indeed brilliant. Whacking to pieces the myth of this oppressed citizen journalist is vital, and needs doing as often as the piñata is reassembled by far-right agitators. Pointing out that the reporting restrictions that Robinson breached have nothing to do with political correctness and everything to do with ensuring a fair trial – the genius is in the simplicity of its expression. Spelling out in equally simple and clear terms the danger that such actions pose to victims of crime receiving justice – [INSERT MERYL STREEP APPLAUSE GIF].
But there's a line buried within which troubles me, and echoes a sentiment that has been tweeted at me a lot in the erroneous assumption that I share it:
"His many convictions stretch from violence to fraud. We have no sympathy."
This ugly and unnecessary throwaway reveals one of the biggest problems we have with our understanding of justice; the same problems that many of us are quick to highlight in our opponents. And that is that Robinson's character, conduct and previous convictions, as reprehensible as they may be, are utterly irrelevant to the issue determined at the appeal, namely whether he received a fair hearing. If he did not – and he did not – he is as entitled as any of us to redress, or at the very least to an acknowledgment of being wronged. The attitude of "Who cares? He's a criminal" mirrors the exact sentiment that has left the criminal justice system – from legal aid through to prisons – in its present desperate state.
It is immaterial whether Robinson has committed horrible crimes. Many people who appear before the courts have, especially in my line of work. And rights, if they mean anything, have to apply to everyone. It's an obvious point, but this fundament of the rule of law is too often forgotten when we are confronted by society's most unlovely.
If we neglect our first principles of justice, we fall into the trap carefully lain by the far-right. Their entire, dishonest thesis – from Trump through to Robinson – is that they are deprived of natural justice by its unequal, unprincipled application at the hands of liberal enemies of the people. By denigrating and distorting the rule of law they aim to undermine and ultimately destroy it. Implying that Robinson's previous criminal record renders him less deserving of justice than the rest of us hands the far-right the prize they crave.
Don't be fooled by the strained triumphalism of the far-right over yesterday's outcome. This result is a disaster for them. It categorically disproves to a global audience every conspiratorial tenet of their religion. The liberal judges are not locking up political dissidents. There is no state cover-up. Mistakes, when made in the legal system, can and often will publicly be righted.
They may be proclaiming that they fought the law and won, but for the truth just ask The Clash. The winner, if we must talk in such terms, is justice.
Which moves me back to The Sun, and the risk of an equivalent false triumphalism on the other side. For just as the far-right mendaciously spin this righting of a procedural wrong as a "victory for free speech" – by which they mean the right to hound Asians accused of criminal offences – so we risk self-denigration by dismissing, or worse revelling in, the punitive effect of the court's error. The joy that some are taking in the notion of Robinson's imprisonment borders on the macabre.
I'm afraid if you're supportively tweeting me amidst the blizzard of the racist bots to share a gloat that Robinson has maybe spent more time in prison than he should have, or to gleefully cross fingers that he gets longer next time, I'm not your ally in this cause.
It may be, when the contempt matter is dealt with anew by the Old Bailey, that a sentence is passed which matches or even exceeds what Robinson has already served. But at present, he served a sentence that followed an unlawful procedure. That shouldn't happen. To anybody.
And if he does receive a lesser sentence – if the court, after a full and leisurely hearing at which all mitigation is made available finds that the appropriate sentence is much lower than he received first time round – and if it means he has therefore served longer than he should have, all the arguments I've made in my book about miscarriages of justice apply. It's wrong. He should be entitled to an apology, and recompense, and all the other make-goods I demand on behalf of others. His perceived or actual shittiness is not material. If he has been imprisoned when he should not have been due to state error, it's as much a problem as if it happened to "one of the good guys".
So those are my closing musings. I have no issue at all – and nor should any of us – with Robinson seeking to and succeeding to challenge the lawfulness of his treatment at the hands of the courts. We are all entitled to due process, and should all expect, however abominable others may consider us to be, that the law will be applied fairly and correctly. My concern, contrary to what the Breitbarters would like to pretend, has always been the mob lining up behind Robinson to spread lies and quite literal fake news as to what took place, what the factual and legal issues are and how the law operates. Those peddlers of hate and deceit – the UKIPs, the Breitbarts, the Rebel Media, the Infowars, the unmentionable Twitter favourites – I will continue to resist as long as I keep up this vainglorious mission to bring law to the people who own it.
But as for what happens to Robinson now, all that should matter is that he gets justice. If, in his righteous pursuit, he encourages his supporters to continue their threats to the rule of law, their riots, their organised campaigns of racialised misinformation, I will be there waving my tiny paper sword on the front line.
But taking any sort of pleasure in anybody being failed by the justice system? We're better than that. Let's show it.
Today the Court of Appeal (Criminal Division) handed down judgment in the appeal of Stephen Yaxley-Lennon (AKA Tommy Robinson), partially allowing the appeal and directing a rehearing at the Crown Court.
What does this mean? Has Tommy been proven innocent? Is this a victory for freedom of speech?
Let's break it down.
Yaxley-Lennon was committed to prison for 13 months on 25 May 2018, after attending a trial at Leeds Crown Court and streaming a live-feed on Facebook in which he broadcasted details of the trial and of the defendants. That particular trial was subject to reporting restrictions imposed by the judge, prohibiting reporting of the details until the conclusion of the trial, and of other linked proceedings. By broadcasting in the way that he did, Yaxley-Lennon was in breach of the reporting restriction, an act which amounts to contempt of court. A year earlier, he had committed a separate contempt of court at Canterbury Crown Court by broadcasting prejudicial material about the case. On that occasion he had been made subject to a suspended sentence of 3 months. On 25 May 2018, when he was found to have committed contempt of court again, he was given 10 months for the new contempt, and the 3 months from Canterbury was "activated" and ordered to run consecutively, making a total period of imprisonment of 13 months.
Contempt of court is a broad, catch-all term for various offences against the administration of justice. The law(s) of contempt are designed to safeguard the fairness of legal proceedings and to maintain the authority and dignity of the court. Some contempts are set out in statute, including the aptly-named Contempt of Court Act 1981. This sets out what is referred to as "strict liability contempt" – the rule that it is a contempt to publish any matter which creates a substantial risk of serious prejudice or impediment to the course of justice in legal proceedings, irrespective of the intention behind the publication.
The reason is straightforward. The priority in every criminal case is ensuring a fair trial. This of course matters not just to the defendant, whose liberty is on the line, but to the witnesses, complainants, victims and public. Prejudicial material – such as televised speculation over whether a defendant "did it", or orchestrated campaigns by special interest groups seeking to secure one type of verdict for political reasons – could potentially influence a jury. We don't sequester juries in England and Wales (barricade them in hotels cut off from the world for the duration of trials). They are instead allowed to continue their normal lives, but are given firm directions by judges not to conduct their own research into the case they are trying,
The reason, juries are told, is twofold. Firstly, a jury's own independent research runs the risk of being unreliable, even more so in the era of fake news. Deciding the case on flawed information risks catastrophic miscarriages of justice. Secondly, it is not fair to the parties. The advocates in court address the jury and make arguments on the evidence. If juries have taken into account their own private research about which the advocates are unaware, the parties are unable to assess or test its reliability, or to address the jury on what their client (either defendant or prosecution) says about it.
Thirdly, strict rules of evidence operate in criminal trials to filter the evidence that juries hear in a case, to ensure it is (a) relevant, (b) reliable and (c) not overly prejudicial to the defendant. It rather defeats the point if as soon as a juror turns on the TV they are confronted by a perma-tanned bozo offering half-baked opinions on the very matters that a judge has ruled a jury shouldn't be told about.
No, far from it. Anything can be reported which is not prejudicial (and which is not subject to reporting restrictions – see below). And if something prejudicial is reported in the course of fair and accurate reporting of an ongoing case, there is a specific statutory defence available to publishers (which includes newspapers, TV and social media users) who can show they were providing "a fair and accurate report of legal proceedings held in public, published contemporaneously and in good faith". Similarly, publications contributing in good faith to discussions of public affairs or matters of public interest if the risk of prejudice created is merely incidental to the discussion. So, to give a topical example, the media is allowed to discuss and debate the way in which we should deal with the rising incidence of acid attacks, even though there are many such trials ongoing across the country and there is arguably a risk of prejudice in ingraining hostile attitudes among potential jurors. No media outlet has been accused of contempt, and nor is anyone likely to be, for taking part in this general discussion.
So we can see that the law gives considerable latitude to the press and ensures that the media do not shy away from accurate, factual reporting of criminal proceedings, or of discussing matters of public interest. The idea is to balance the importance of open justice with the centrality of ensuring a fair trial.
Not always. Other contempts are more eclectic, such as the prohibition on taking photographs or moving images inside a court building (or even drawing a picture – court sketch artists have to draw outside the court from memory – section 41 of the Criminal Justice Act 1925).
Then there are contempts which strike at the authority of the court, where there is no requirement that the fairness of proceedings be prejudiced. There are what are referred to as "civil contempts", where, for example, an order made by a court ordering one party to do something is breached, and the other party complains to the court.
There is also a common law offence of "criminal contempt", which is defined by the courts as "conduct that denotes wilful defiance of, or disrespect towards the court, or that wilfully challenges or affronts the authority of the court or the supremacy of the law itself." This might include refusing to answer questions in court, physically disrupting court proceedings, interfering with witnesses or jurors (where not charged as a distinct offence of witness intimidation or perverting the course of justice) or defying a judge's order. Such as, for instance, a reporting restriction.
Contempt – however committed – carries a maximum penalty of committal to prison for up to two years. Note that slightly tortured phrasing – "committal to prison", rather than "sentenced to imprisonment". It's a distinction which becomes relevant at the appeal.
The starting point of our criminal justice system is that justice must be seen to be done. However, the law provides for exceptions to open justice, known generally as "reporting restrictions". Reporting restrictions apply in a wide range of situations – from automatic restrictions preventing the identification of a complainant in a sexual allegation, to restrictions preventing reporting of Youth Court proceedings, to discretionary restrictions protecting the identity of child witnesses in the adult courts. Further details, if you are interested, can be found here.
One breed of restriction order is something called a "postponement order", under section 4(2) of the Contempt of Court Act 1981. Postponement orders are not unusual, particularly where there are a series of linked trials – for example, where allegations of drug networks involving 30 defendants are concerned, there will be several trials (it not being physically possible to accommodate 30 defendants in a single courtroom). To avoid jurors having their deliberations contaminated by what they might read or hear about the earlier linked trials, reporting of all of them is often postponed until the end. Where there is a separate-but-related issue, such as a contempt of court involving a third party, this can also be the subject of a section 4(2) order. The test is:
He was dealt with for two contempts of court. It helps to take them in turn.
On 8 May 2017, during the course of a rape trial at Canterbury Crown Court involving four (Asian) defendants, Yaxley-Lennon attended court and attempted to film the defendants for an online broadcast entitled "Tommy Robinson in Canterbury exposing Muslim child rapists". He was thwarted by the judge making arrangements for the defendants and jurors to leave court through alternative routes, and so settled for filming himself on camera, both on the court steps and inside the court building, preaching to his online followers about "Muslim paedophiles". He was interrupted and told by court staff that recording was prohibited (section 41 of the Criminal Justice Act 1925,), but continued to record, insisting that he had been told by a different court that he was entitled to film the defendants (notwithstanding that court buildings are plastered with signs reminding people not to do this). His video diatribe – in which he said that "the paedophiles are hiding", that the police had asked him not to "expose" them as paedophiles (presumably on the basis that they were, at that time, defendants in a live trial) but that "we will", and that he would be "going round to their house" to catch the defendants on camera – thus continued. The judge hearing the rape trial was made aware, and he was brought before court to be dealt with for contempt of court.
It was held that this behaviour was capable of prejudicing the ongoing trial. The finding of the judge, from the judgment, was that in acting in this way, Yaxley-Lennon had committed a "criminal contempt" – what is otherwise known as a contempt "in the face of the court". He was also in contempt by virtue of filming in breach of section 41. He was committed to prison for 3 months, but this was suspended for a period of 18 months. What this meant, as he was told, was as follows:
"[Y]ou should be under no illusions that if you commit any further offence of any kind, and that would include, I would have thought, a further contempt of court by similar actions, then that sentence of three months would be activated, and that would be on top of anything else that you were given by any other court.
In short, Mr Yaxley-Lennon, turn up at another court, refer to people as "Muslim paedophiles, Muslim rapists" and so and so forth while trials are ongoing and before there has been a finding by a jury that that is what they are, and you will find yourself inside. Do you understand?"
Fast-forward to this year. On 25 May 2018, Yaxley-Lennon attended Leeds Crown Court to "report" on an ongoing trial. [The subject of this trial is still subject to reporting restrictions and so is not mentioned here. I will update when the restriction is lifted.] He live-streamed a Facebook video in which he made various comments about the defendants, including reading out their names and referring to their religion, ethnicity and questioning the need for reporting restrictions. He encouraged people to share the video, which many did. This was at a time when, as Robinson knew, a "postponement order" under s.4(2) of the Contempt of Court Act 1981was in place, which prohibited any reporting on the details of the trial until the conclusion of a "linked trial" – as explained above.
If you breach a reporting restriction, you are in contempt of court. This is irrespective of your intent or motive.
And this is where Yaxley-Lennon found himself. Arrested by police (initially for a breach of the peace, but then dealt with in court for contempt – this is entirely unremarkable, despite the attention given to it by Yaxley-Lennon's supporters) and brought before the judge facing an allegation of contempt. Contempt having been admitted, Yaxley-Lennon's barrister advanced mitigation, and HHJ Marson committed YL to prison for a total of 13 months. 10 months was for the new offence, with the three-month suspended sentence activated and ordered to run consecutively. The process was quick – 5 hours from arrest to imprisonment.
The appeal focussed on three principal arguments:
A contemnor (as is the official term) has an automatic right to appeal to the Court of Appeal (unlike ordinary convictions or sentences where the Court of Appeal must give permission to a would-be appellant). However this has to be exercised within 28 days of the finding appealed against. While the appeal against the length of the committal (the "sentence", if you like) was lodged in time, it was not until some time later that Robinson decided that he wanted to appeal against the findings of contempt. He therefore required the court to grant an extension of time for him to appeal.
Given the misinformation that has been spread, it is worth emphasising two things at this stage. Firstly, it was widely reported (including by me) before the appeal hearing that Robinson was not appealing against the findings of contempt. We did so because this is what Robinson's official spokesperson, and the media organisation supporting him, publicly announced. He deliberately chose not to publicise the fact that he was appealing against the findings of contempt, and the first that this was known was on the day of the appeal. Secondly, the arguments against the findings of contempt was entirely procedural. In other words, his barrister explicitly accepted that what Robinson had done amounted to contempt of court. The argument was simply that the court hadn't dealt with it as the law requires.
The Criminal Procedure Rules were introduced in 2005 to impose some sort of order on the routine chaos of criminal proceedings. They are lengthy and comprehensive, and prescribe the procedures that the criminal courts must follow.
Contempt proceedings can be started either by the court (i.e. the judge), or following a reference to the Attorney General, who as the "guardian of the integrity of the administration of justice" often takes charge.
When the court is dealing with an alleged contempt of court, the relevant procedure is set out at Criminal Procedure Rule 48. The law permits the court to deal with contempts summarily – i.e. straight away – or to adjourn to another date, as long as the procedure is fair. What is appropriate will depend on the circumstances. Where someone is interrupting a trial, for instance, it will usually be right for the court to deal with the contempt immediately to avoid further disruption. However the Court of Appeal, referring to case law, emphasised that this procedure should be used sparingly. Where there can safely be an adjournment, there should be.
Another important feature is that the court should "particularise" the contempt – spell it out so that the alleged contemnor knows what they are supposed to have done. An extract of the procedure is here:
If, having completed the initial procedure (which includes offering the contemnor a chance to apologise), the judge decides that further action is to be taken, the court must embark upon an "enquiry" (the name for the hearing of a criminal contempt). A court can postpone an enquiry for further investigation.
It didn't. Robinson argued that the judge had failed to provide the written statement of particulars of the contempt required by Rule 48.7. However, the Court of Appeal, following the appeal hearing last month, came into receipt of "late disclosure", which showed that "a deliberate tactical decision was made by [Robinson's] legal advisers at Canterbury to be complicit in the court's failure to comply with Rule 48." The appellant waived legal privilege (a common request made by the Court of Appeal in appeals where criticism is made of how Crown Court proceedings were conducted) which allowed the Court of Appeal to read the legal advice he received. And it emerged that a conscious decision was taken by his legal team not to invite the judge to follow the correct procedure, as they thought they would secure a tactical advantage by making the judge "uneasy" about the proceedings.
The Court of Appeal was not impressed, telling Robinson:
"It lies ill in the mouth of an appellant to complain of the failure of the court below to follow the appropriate procedural steps when that failure was fully appreciated at the time and remained deliberately uncorrected for tactical reasons and collateral advantage."
The Court added that the new barristers instructed for the appeal were unaware of this until after the appeal hearing, and disclosed it promptly when it came to their attention.
In any case, the Court of Appeal said that nothing procedurally was flawed in Canterbury. The judge had adjourned the contempt hearing for 12 days to allow time for him to take legal advice. Any failure to follow the CrimPR was immaterial.
The appeal against the Canterbury contempt was therefore dismissed.
10. What about Leeds Crown Court?
This was very different. The time between arrest and imprisonment was five hours. The Court of Appeal was highly critical:
"Such haste gave rise to a real risk that procedural safeguards would be overlooked, the nature of the contempt alleged would remain inadequately scrutinised and that points of significant mitigation would be missed. Those risks materialised."
The Court of Appeal said that the judge was right to order that Robinson immediately take down the video, but that he should then have "taken stock". He should have either adjourned for a later hearing, or referred the matter to the Attorney General to consider. The Court of Appeal displayed some sympathy towards the judge's position, but made clear it disapproved of his chosen course:
"We recognise that the judge was placed in an invidious position because he was concerned about the integrity of the trial which was almost at its end. The three trials, of which this was the second, were exceptionally difficult and sensitive. Having decided to suspend the deliberations of the jury, it is understandable that he may have felt under some pressure to resolve the issue of the appellant's contempt expeditiously. However, once it had become apparent that the appellant was co-operating in removing the material from the internet, there was no reason why the jury could not have been permitted to resume their deliberations. If there was any doubt about the intentions of the appellant, the judge could have sought an undertaking from or ordered, the appellant not to comment further on the trial or approach the court until the trial (or trials) had concluded."
There was also confusion, due to the lack of particulars of the contempt, as to what conduct the judge was dealing with Robinson for. He was in breach of the reporting restriction, but the judge also appeared to suggest that other comments in the video – relating to the defendants' ethnicity and religion – would amount to a separate criminal contempt. But it was all rather fuzzy, and deeply unsatisfactory:
"In our judgment the failure to follow the requirements of Part 48 of the Rules was much more than a technical failure. In contempt proceedings, touching as they do on the liberty of the subject, there is a need for the contempt in question to be identified with precision and the conduct of the alleged contemnor identified with sufficient particularity to enable him, with the assistance of legal advice, to respond to what is a criminal charge, in all but name. In this case there was no clarity at all about what the appellant was admitting and for what parts of his broadcast he was considered by the judge to be guilty of contempt of court for breach of the section 4(2) order."
As far as the length of sentence was concerned, the Court of Appeal criticised the decision not to adjourn for a Pre-Sentence Report (or "Pre-Commital Report"), and accepted that the speed of the hearing meant that the level of detail of mitigation put before the court was "very limited indeed".
It did, and all consequential orders (i.e. the sentence) fell away. However that is not the end of it. The Court remitted (sent back) the contempt for a fresh hearing at the Crown Court before a different judge. When the contempt is established (as it surely will be given that Robinson has admitted through his barrister at the Court of Appeal that he breached the reporting restrictions), he will be sentenced afresh.
Not necessarily. There was a sting in the tail of the judgment. The Court of Appeal observed that "the alleged contempt was serious and the sentence might be longer than that already served." It also set out, for the benefit of any future sentencing court, the criteria that should be considered when passing sentence:
(a) the effect or potential consequences of the breach upon the trial or trials and upon those participating in them;
(b) the scale of the breach, with particular reference to the numbers of people to whom the report was made, over what period and the medium or media through which it was made;
(c) the gravity of the offences being tried in the trial or trials to which the reporting restrictions applied;
(d) the contemnor's level of culpability and his or her reasons for acting in breach of the reporting restrictions;
(e) whether or not the contempt was aggravated by subsequent defiance or lack of remorse;
(f) the scale of sentences in similar cases, albeit each case must turn on its own facts;
(g) the antecedents, personal circumstances and characteristics of the contemnor;
(h) whether or not a special deterrent was needed in the particular circumstances of the case.
Additionally, cases involving a breach of a section 4(2) postponement order will often give rise the following potential consequences:
(a) Trials may have to be abandoned irretrievably;
(b) Juries may have to be discharged and retrials ordered with all the consequent delays and expense;
(c) Witnesses, some of them perhaps vulnerable, may have to face the ordeal of giving evidence for a second time;
(d) The trial judge's decision upon how to manage the trial in response to the contempt may form the subject matter of an appeal which, whether or not successful, will generate additional anxiety, delay and expense.
No. It is a victory for the procedural rules, and a sharp reminder to the courts of the need to follow them. But certain key takeaways remain:
14. This shows that you know NOTHING, fake barrister. You were wrong, weren't you?
Yes. My initial impression, based on the limited information available, was that the summary procedure was appropriate in the Leeds case. As the Court of Appeal explained, it was not. There were alternatives open to the judge which should have been explored. There were also obvious failings to abide by the procedural rules, although I would plead in mitigation that none of that information was available at the time that the story was first reported. As a result, the hearing was not fair. Whether the sentence was appropriate was not decided by the Court of Appeal and may perhaps be best assessed by what the freshly-constituted Crown Court decides to do, (although my position on that was neutral – I observed simply that the sentence was not out of the ordinary for serious contempts of court.)
So I hold my hands up – imperfect information makes for imperfect predictions. But is there a wider issue here, among me and other legal commentators? Were we too quick to dismiss the case with a "nothing to see here" wave of the hand, blinded by the unappealing nature of Robinson's supporters and the organised maelstrom of fake news stirred up here and abroad? Maybe we were. Maybe we could have – should have – cleared our ears and browsers of the white (pride) noise and paid greater heed to the arguments of due process. Maybe a little more humility is required in these difficult cases. I am normally conscious in all legal blogging to couch in terms of conditionals – if this report is accurate, then the explanation might be X. Was I too quick to assume, wrongly, that the judge had acted correctly?
I think I may have been. But looking back over the litany of plainly false statements circulated between May and now – that Robinson's "reporting" was nothing more than the BBC had done; that he was targeted by the deep state; that Robinson's original barrister was an "unqualified duty solicitor"; that TR was never in contempt of court as the trial was over; that the courts were "covering up" serious crimes by certain racial groups; the dishonest framing of the debate as one of "free speech" rather than interfering with justice; and the other hundreds of fantastical theories clogging my Twitter notifications today – I'd suggest, self-servingly, that an inaccurate but well-meaning prediction – such as we all make in the courts every day – is lesser a social evil than the deliberate, racially-tinged misinformation campaign that we do our best to counter.
A homeless man who picked up a lost race number and "completed" the London Marathon has been jailed for 16 weeks.
Yesterday at Uxbridge magistrates' court, Stanislaw Skupian (38) was sentenced by magistrates having pleaded guilty at an earlier hearing on 18 May to fraud, after he picked up a race card number dropped by runner Jake Halliday at the 23-mile mark and illicitly joined the race himself. He crossed the finish line and celebrated with the medal intended for Mr Halliday, who found himself removed from the race 300 metres from the Finish line when marshals spotted that he was not wearing a race number.
The Chair of the bench passing sentence told Skupian, a homeless father-of-one who had recently suffered a temporary breakdown in his mental health, "The offences are so serious [that] only a prison sentence will suffice". 13 weeks' imprisonment was passed, with three weeks' imprisonment imposed consecutively for unrelated matters of theft.
The Chief Executive of the London Marathon, Nick Bitel, reportedly said that "justice has been done". His apparent pleasure with the sentence was not matched by many people on social media, who expressed consternation at a mentally-unwell homeless man being squeezed into our bursting prisons for a non-violent offence.
So what the Dickens has gone on?
The offences
Stanislaw Skupian was charged with fraud by false representation, contrary to sections 1 and 2 of the Fraud Act 2006. The "false representation" being, presumably, the implied representation that he was the rightful owner of Mr Halliday's race number and was entitled to complete the race and claim the finishers' medal. This offence carries a maximum sentence of 10 years' imprisonment in the Crown Court, or six months' imprisonment in the magistrates' court. He was sentenced to 13 weeks' imprisonment.
He was also charged with three unrelated offences of theft. He was arrested at the multi-faith prayer room at Heathrow Airport, where he was found with items including a primary school worker's identity card and a pink diary holding overtime hours worked by airline staff. It was said that Skupian viewed the airport as a temporary home and had picked up items discarded. This would amount to theft (referred to in court as "theft by finding") under s.1 of the Theft Act 1968. He received three weeks' imprisonment for these offences, to run consecutively to the 13 weeks imposed on the fraud (it is unclear whether this was one week consecutive for each of the three theft charges, or three weeks on each directed to run concurrently to each other, or some other mad configuration dreamed up by the magistrates).
He was further made subject to a Criminal Behaviour Order, which is the new replacement for the old-fashioned ASBO. These can be imposed where the court is satisfied that a defendant has engaged in behaviour that caused or was likely to cause harassment, alarm or distress to any person, and where a Criminal Behaviour Order will help in preventing the defendant from acting in that way. In this case, the court deemed that banning the defendant from Heathrow Airport for three years, unless he has a pre-booked flight, was an appropriate use of that power.
The Sentencing Guidelines
To look at what sentence we might expect, we have to look at the Sentencing Guidelines, which are published by the Sentencing Council and which courts are required by law to follow. So let's look at the Definitive Guideline for Fraud, Bribery and Money Laundering Offences. The seriousness of an offence is judged by considering the "culpability" of the offender and the "harm" caused by the offence.
On the Guideline for straightforward fraud, the first step is to assess culpability by reference to the below factors:
There are plainly no elements of "High culpability" in this case. It would appear, in the absence of any evidence to the contrary, that this was an opportunistic, one-off offence with very little planning, which points towards Lesser culpability.
Now we turn to the assessment of harm:
For fraud, you take as your starting point the financial loss to the victim. Here, it is very low indeed. The cost of entering the London Marathon ballot, at £39, is probably the closest financial value you can attach to this unusual offence (the value of the medal not being easily assessed due to it not being something purchasable on the open market). This puts us in the lowest category, Category 5.
But then we have to look at the impact upon the victim, to see whether it warrants the sentence being moved upwards. This is a slightly unusual case, because although (I expect) the charge would have been drafted with London Marathon as the nominal victim, the person most directly affected is arguably Jake Halliday. He was stopped 300 metres from the finishing line and told that he was not allowed to cross due to his number having fallen off. He had raised £49,000 for a charity, Bloodwise, and was prevented from completing the race, having run the best part of 26 miles, in the cruellest of circumstances. What was (one might expect) a lifetime ambition was snatched away. That no doubt had a considerable detrimental effect on him.
However. Can it really be suggested that Skupian was responsible for depriving Mr Halliday of his moment of glory? It was said in court (and seemingly not disputed) that he spied the discarded race identifier on the floor and saw an opportunity. He did not steal or otherwise remove the number from Mr Halliday. It does not appear that he watched it fall and swooped in. If, as the court apparently accepted, he had simply seen it on the ground, was the damage not already done? Perhaps he could have handed the card to an official, but it is unclear how it could have been reunited with Mr Halliday in order for him to have been able to complete the race. The London Marathon Final Instructions to runners emphasises the importance of taking care of the running number – "Duplicate numbers cannot be issued under any circumstances". It is also stated that anybody taking part without a number will be removed from the race by marshals "before you cross the Finish line". Once that number had fallen, it would appear (and I'll be happily corrected if I'm mistaken) that the game was over for Jake Halliday.
Against this backdrop, it might realistically be argued that while Skupian exploited Mr Halliday's misfortune, his criminal behaviour did not cause it. The anger and humiliation felt by Mr Halliday when he learned that somebody had claimed his number and completed the race in his stead may well be significant, but is it so great as to move the harm out of "Lesser impact"? I suppose it might. Just.
My assessment is that for these reasons, this case probably falls somewhere between, categories 4C and 5C:
We can see that the latter provides a starting point of a 'Band B fine', which equates to around 100% of somebody's weekly income. The category range is a discharge – a slap on the wrist – up to a medium level community order. If the harm caused is deemed serious enough to lift it up to the next category, the starting point is a medium level community order. Still the category range does not extend to custody. In order to arrive at a category where a custodial term is available, the court would have to have assessed culpability as "B". I find it tricky to see how this was done.
We then look at aggravating and mitigating factors:
The defendant had a previous conviction for attempted theft. That was the only matter mentioned in court. So while it is a similar type of offence, this is hardly the kind of record which would seriously aggravate a defendant's position to make the difference between custody and not-custody. No other aggravating features listed are relevant.
In mitigation, the court heard that the defendant has lived in the UK for 11 years. He suffered a neck injury in a serious car crash last year, forcing him to take sick leave from his catering job. His marriage broke down and he lost his home. Shortly before the race, he had suffered a "short, temporary breakdown in his mental state". It was also submitted that he had committed the offence out of excitement, without fully appreciating that what he was doing was wrong.
Putting all this together, I'd say there's more to mitigate his position than to aggravate it. This would mean moving below the starting point on the Guidelines.
We then have the issue of credit for guilty plea. He admitted the offence at the very first hearing, and so is entitled to one third off his sentence. This means that the magistrates must have taken a starting point of 20 weeks in order to arrive at a final sentence of 13 weeks for this offence.
[The thefts we shall put to one side as we do not know their value. What we can infer, however, is that they were considered significantly less serious than the fraud.]
Based on what we know, this appears to be a very harsh sentence. While this is not the type of fraud envisaged by those who drafted the Guidelines, it is difficult to see how a straightforward assessment of culpability and harm could lead a court to a starting point of 20 weeks for this single offence. The defendant has an automatic right to appeal his sentence to the Crown Court. I would not be surprised if he exercised it.
There are unknowns, of course. There would have been a Pre-Sentence Report prepared by the Probation Service, whose views would have informed the court's. It may be that they were unable to offer any alternative to custody, although experience would dictate that a homeless man with a limited criminal record and mental health problems is the kind of person the Probation Service try to persuade the courts to let them help. It would be a sad day indeed if all that our justice system could offer to improve this man were two pointless months of incarceration.
I have written about magistrates before, including in my book, and one of my criticisms is that sometimes a sense of perspective is lacking when these non-legally qualified volunteers are sentencing offenders. Just because a power of imprisonment exists does not mean that it has to be used. This sentence, based on what we know, appears to be one such example. That it can be said that the offence was so serious that only a prison sentence can suffice is, with respect to the sentencing court, perverse. Courts often find ways to avoid immediate custody in cases which are far more serious, involving offenders with significantly worse records.
And I'll seize on those words – "based on what we know" – to pirouette into a final flourish on my soapbox, if I may:
This case had received national media attention when Mr Skupian made his first appearance at court and pleaded guilty. It was plain to the court administration and to the magistrates that the outcome of this case would be widely reported. Yet still the magistrates did not see fit to publish written sentencing remarks explaining their decision.
This is a drum I have unapologetically beaten for some considerable time. Because while good court reporters should accurately reflect the full reasons given for a sentence passed, inevitably there will be occasions where something is missed in the hustle of a chaotic magistrates' court list. Submissions and decisions as to where the case falls in the Sentencing Guidelines, for example, hold little interest to the average reader and may understandably not make it into the final copy, but to lawyers analysing and explaining the decision these can be critical.
Magistrates, judges and lawyers cannot complain that their remarks or decisions have been unfairly portrayed if they don't bother to do the basics. It would have taken an extra ten minutes, one supposes, for the remarks to have been committed to paper, copied and distributed before being read out, and then everybody would be able to see how and why the decision was reached.
As it is, we are once again left groping in the dark, or at best the dusk, in trying to understand how our criminal justice system is – or in this case is apparently not – working.
My latest piece for iNews, on the Supreme Court decision concerning the victims of John Worboys and their fight for compensation for police failings in the investigation into Worboys' crimes, is available to read here, should this sort of thing be of interest:
Just a quick one. A number of people online were yesterday disturbed by this tweet from court reporting Twitter account @CourtNewsUK, relating to Michael Adebolajo, one of the two murderers of Drummer Lee Rigby:
Senior judge says it will be a 'great pity' if Lee Rigby's killer isn't given taxpayers' cash to help him sue the government.
— CourtNewsUK (@CourtNewsUK) October 31, 2017
The story has been picked up by The Mirror, which gasped with similar horror that a "top judge" has "insisted [Adebolajo] should be given taxpayer cash to pay for his court fight against the Ministry of Justice."
The anger has burned through the night and looks set to smoulder for the rest of the day, Radio 4's Today programme finding space for a mention among its bulletins. And I understand why. On its face, this appears an instinctively unjust state of affairs. A High Court Judge loftily calling for yet more taxpayers' hard-earned money to be poured into the pockets of a man guilty of unspeakable savagery.
But scratch beneath the surface, and you quickly see that there's more to this story than the tweet suggests. For a start, no decision has been made to grant Adebolajo legal aid for his personal injury claim against the Ministry of Justice, which arises out of injuries he sustained while being restrained by prison officers. Indeed, personal injury practitioners will correct me if I'm wrong, but I understand that legal aid for claims of this type is vanishingly rare. And proceedings are still at an early stage; today's hearing at which the judge's comments were made was a preliminary hearing. Details are scant. It is not clear whether the claim has any merit at all; whether it will run to trial, or whether it will be struck out as entirely frivolous.
But let's suppose that the claim is heading for a trial. And let's suppose the judge's comments above were fairly and accurately reported in their full context [SPOILER – they were not, and we'll come to that]. Here, resuscitating a thread I posted yesterday, are my thoughts on why legal representation should be made available to Michael Adebolajo, at taxpayer cost if need be:
Putting the above together, I think there's a compelling case for saying that justice – to all involved – is best served by having this man legally represented. Legal aid may or may not be granted; I do not know enough about this field to opine. But if it is, it will not be a taxpayer-funded privilege lavished on an ungrateful terrorist; it will be a sensible and restrained direction of public funds towards ensuring that justice is served to all involved – government, claimant, prison staff, prisoners and taxpayers. Which, when one looks at the judge's comments in context, is exactly what he was saying:
I'll be honest, out of all the 'robust debates' I've had online about criminal justice and sentencing of offenders, I would not have expected the most frustrating, fiery and ill-informed to be with someone advocating for less use of prison. It takes a special talent, I would suggest, to present an argument in such a way that you manage to alienate those who agree with your conclusion. Arise for your special badge, Lord Andrew Adonis, former Head of Policy at Number 10 Downing Street and erstwhile Transport Secretary.
The past few days have seen Lord Adonis stagger around Twitter swinging aimlessly at lawyers and judges like a punch-drunk case study on a late night police reality TV show. Every effort to gently usher him into the back of the van for some calm, reasonable, evidence-based discourse is met with another wild lunge towards camera – he has now blocked nearly every lawyer on Twitter – compounding the schadenfreude of rubbernecking passers-by. Unfortunately for Andrew, his identity is not pixellated to spare his embarrassment; rather emblazoned across each and every one of his (increasingly peculiar) assaults on the "cobwebbed judicial system".
Let's start with the common ground: Adonis believes that we have too many people in prison. I agree. As do, I would expect, most people who work in criminal justice. The statistics are trite, but no less shocking for that: England and Wales currently has around 85,500 people in prison. We imprison more people per capita than any other country in Western Europe (146 prisoners per 100,000 citizens). We have more prisoners serving indeterminate sentences – sentences for which there is no guaranteed release date – than the other 46 countries in the Council of Europe combined. Sixty-nine per cent of our prisons are overcrowded. Violence has soared by 68 per cent since 2006, with a 32% increase alone between 2015 and 2016 (a total of 25,000 assault incidents). Assaults on prison staff have risen by 40% in a decade. Deaths in custody have risen by 38% in between 2015 and 2016. The horror correlates with the £1bn cut to prison budgets by the last government and the 30% reduction in prison staff. And whatever else prison is supposedly achieving, stopping reoffending is not it: 44% of adults are reconvicted within one year of release. For those serving sentences of less than 12 months this increases to 59%.
And numbers have increased steeply over the past two decades. The prison population rose by 90 per cent from 1990 to 2016. This is a recent, and peculiarly English-and-Welsh, problem.
For Adonis, the prescription is simple. The problem is the judges, whacking their gavels and sending people to prison for longer:
THREAD:?I've been tweeting today about our judges. Like the vice chancellors, they have high opinion of themselves – 'world class' etc.
— Andrew Adonis (@Andrew_Adonis) October 2, 2017
4/ bold fact is that the prison population has TREBLED in last 60 yrs & the judges have played a big prt on this by comission & omission.
— Andrew Adonis (@Andrew_Adonis) October 2, 2017
Why are judges doing this? "Fear of tabloids", Adonis posits:
No. Judges say they agree but do opposite, fearing tabloids. Change needs top judges to practise what they preach in Garrick/dinner parties https://t.co/1OxRt4A7lg
— Andrew Adonis (@Andrew_Adonis) October 5, 2017
No, the judges are bidding up sentences & numbers jailed within sphere of judicial discretion. It's called 'running scared of the tabloids' https://t.co/AlwXqqPbA2
— Andrew Adonis (@Andrew_Adonis) October 7, 2017
Extracts cannot really do justice to the tirade of tweets that Adonis launched towards the judiciary on this theme, and I'd recommend reading his Twitter timeline (with a glass of something stiff) to get the full flavour, but this is the nub:
Nothing world class about our judiciary, which jails more people for longer than any judges in Europe & wash their hands of prison crisis
— Andrew Adonis (@Andrew_Adonis) October 7, 2017
Now some of us hacks did indeed offer a defence of judges (who, by constitutional convention, are not permitted to speak out publicly to defend themselves). And we did so not because, as Adonis suggests, we have a desire to become a judge (I think I have successfully set fire to that particular lifeboat for myself through this blog and my forthcoming book), or because we think all judges are wonderful (SPOILER: They're not – most are excellent, but some are significantly less so), but because we see criminals being sentenced every single day, and have a certain experience in this field. And I struggle to think of many cases I've been in, either prosecuting or defending, where I have suspected that a sentence has been inflated because of an eye on reporters in the public gallery.
As for Adonis' experience, I did ask how many judges he had seen passing excessive sentences out of fear of tabloid retribution, but received the following, less-than-full response:
A new dawn, a new attack on judges by @Andrew_Adonis, the same tumbleweed blowing when I politely ask for his evidence. pic.twitter.com/5rIRt0ildX
— The Secret Barrister (@BarristerSecret) October 8, 2017
The thing is, while to a layperson Adonis' criticism would seem to make sense – judges are the ones passing these sentences, after all – a little knowledge of the law teaches that, to a large extent, judges' hands are often tied, or at least lightly bound with handkerchiefs. That is because sentencing is not, as many might imagine from pop culture, an exercise in plucking a figure out of the air, whacking a (non-existent) gavel and intoning, "Take him down". Crown Court judges are instead required to apply a horrendously complex morass of sentencing law and guidelines, which severely limit their room for manoeuvre. While they have discretion to pass a sentence that meets the justice of an individual case, it is a fallacy to presume that this discretion is at large.
Firstly, there are Sentencing Guidelines for most criminal offences, which judges are required by law to follow. We've looked at these guidelines in previous posts dealing with specific cases, but in short, they provide judges with a mixture of flow-charts and grids, setting out sentence "starting points" and "ranges" depending on which factors are present in a particular case. There is ultimately discretion built in as to where on the guidelines a judge pitches a case, but you can see for yourself that there is often not a great deal of wiggle room. Guidelines are set by the Sentencing Council, whose members are drawn from the judiciary, magistracy, legal practitioners, academics, police and the Director of Public Prosecutions. Guidelines are subject to public consultation, and the Council is accountable to the Ministry of Justice and has a statutory duty to consult with Parliament. The Sentencing Council is not, lest you be confused by Adonis' complaints, a gaggle of judges operating under a cloak of secrecy.
Now I make clear – I do not agree with all of the guidelines. I think, for example, the way in which drugs are sentenced is largely ludicrous. A starting point of 4.5 years' imprisonment for someone selling a few wraps of crack cocaine to fund their own habit is, with respect, the hallmark of a society that doesn't have a clue what it is doing with drug policy, although the malaise for that lies with political culture at large, not the Sentencing Council. But even if you accepted Adonis' view that the Council was a bunch of industry insiders fixing oppressively long sentences out of a desire to placate the red tops, it does not explain how, as Adonis postulates, it is fair to level cowardice charges at the several hundred other judges who are required day-to-day to follow the guidelines.
And, more importantly, judges must follow the law. Sentencing legislation is made by Parliament, which includes among its members Lord Adonis, as a member of the House of Lords. And judges have to follow the law set by Parliament. There is no discretion here. That is the essence of the rule of law and our basic constitutional settlement. I say this, because Adonis has suggested that judges should have "argued against" the government's "policy" – by which he can only mean that they should have revolted and refused to follow the law that the government enjoined Parliament to make. So let's get that sixth-form concept straight: judges have to follow the law set by Parliament.
9/ didn't argue against this unjust policy & implemented it (including really shameful indeterminate sentences for 'public protection')
— Andrew Adonis (@Andrew_Adonis) October 2, 2017
Now, as for what the law says, we can see that over the past two decades, politicians have scrambled to salute Michael Howard's prison works squawk and increase the ways in which they can force judges to pass longer sentences. This included "mandatory minimum" sentences for repeat offenders – such as the 3-year minimum sentence for repeat burglars and the 7-year minimum for repeat drug traffickers – brought in by the New Labour government of which Adonis was a part. This same legislation – the Powers of Criminal Courts (Sentencing) Act 2000 – also introduced mandatory life sentences for offenders committing a second serious offence (a provision later abolished, re-imagined and re-enacted). And there are many, many others.
But for now, I want to look briefly at one area to which Lord Adonis refers in the above tweet – indeterminate sentences.
In 2003, when Adonis was ensconced in the bosom of Downing Street as Head of the Policy Unit, New Labour brought forth the Criminal Justice Act 2003, a huge, unwieldy piece of legislation which did many things, including introducing the notion of Imprisonment for Public Protection (IPPs). You may have heard of these – they have been in the news recently, as people given short "minimum terms" of as little as 10 months ended up serving over a decade under such sentences. The way that IPPs worked in theory was as follows: The judge would set a "minimum term", after which the defendant would be eligible for release on licence, as long as he could satisfy the parole board that he was no longer dangerous. If he could't satisfy the parole board, he would be detained until he could, potentially forever. As it happened, the government decided that they couldn't afford to provide the rehabilitation courses that prisoners were required to pass in order to satisfy the parole board, meaning IPP prisoners were trapped in a Kafka-esque nightmare. For this reason, the Court of Appeal found that then-Justice Secretary Jack Straw had acted unlawfully in failing to provide the rehabilitation programmes, and in 2012 IPPs were repealed (although those passed before that date remained).
Now when IPPs were first introduced, if a defendant convicted of certain violent or sexual offences was found to be "dangerous" – the legal test for which was that he posed a significant risk of serious harm to the public – an IPP had to be passed. The judge had no discretion – the law was clear. If the offender met the risk threshold, the judge was not allowed to deal with him in any other way. This, unsurprisingly, led to an explosion in prison numbers – around 3,700 prisoners were serving IPPs by 2007.
This was the law until 2008. Parliament, realising its error, then amended the legislation to give judges discretion as to whether to impose IPPs where certain criteria were met. The word "must" was changed to "may", and the threshold for imposing IPPs was heightened, to remove the scenario of tiny minimum terms (one as low as 28 days) resulting in years being spent behind bars. And, given discretion, judges stopped imprisoning as many people under IPPs.
Why do I focus on IPPs? It's because they are the prime factor responsible for the increased use of prison. As the Parliamentary statistics that Adonis himself cites shows (thanks to @ProfChalmers), the length of sentence for all offenders has remained relatively stable across the 11 year period (2005 – 2016) except for a notable increase in indeterminate sentences.
That is not to say that all IPPs imposed were rightly so. Judges after 2008 did have discretion, and no doubt there will have been instances where it can be argued that an IPP was imposed where it need not have been (and many such cases will have been argued successfully before the Court of Appeal).
But what this incontrovertibly shows is that far from judges imposing increasingly lengthy sentences "out of fear of tabloids", it was in fact politicians – Lord Adonis and his colleagues – forcing judges to impose certain types and lengths of sentence that was the greatest contributing factor to the increased use of prison. As for why politicians felt compelled to act in this way, you would have to ask them. But it may be there that "tabloid fear" finds its rightful resting place.
As for other factors of note that we can identify, we can see from the chart above an increase in determinate sentences of over 4 years. We can also see over the past 16 years a surge in prisoners convicted of violent and sexual offences:
Partly, this will be because of the increase in violent crime. Partly this will be attributable to the fact that the CPS are prosecuting more sex offences than ever, particularly allegations of historic (or "non-recent") sexual abuse. Neither of these factors have anything to do with the judges. And, faced with serious sexual or violent offending, the guidelines and the legislation make clear what judges are required to do.
Ultimately, this is a silly argument, given the broad area of agreement between Lord Adonis and most lawyers. But I waste my Sunday afternoon to unpick Adonis' complaints, even though I think we are on the same side, because there is no point embarking upon a remedy if you have mis-diagnosed the illness. And what is increasingly clear from Adonis' tweets is that he lacks some fairly rudimentary understanding of the legal system.
For example, he suggests that Lady Hale, as the new President of the Supreme Court should "call out the trend to ever longer sentences", apparently oblivious to how the Supreme Court operates.
11/ on the issue of sentencing & the prison crisis. She shd call out the trend to ever longer sentences, refuse to implement it within the
— Andrew Adonis (@Andrew_Adonis) October 2, 2017
Sentencing policy has nothing to do with the Supreme Court. The Supreme Court's only role in criminal sentencing is to rule on the infinitesimal number of criminal sentence appeals that make it to the Supreme Court from the Court of Appeal. Why are so few criminal sentence cases heard at the Supreme Court? It's because in order to appeal upwards from the Court of Appeal to the Supreme Court, either the Court of Appeal or the Supreme Court has to certify that "a point of law of general public importance is involved in the decision". This is a high threshold, and excludes the vast majority of sentence appeals (which tend to turn on their individual facts, rather than wider points of public importance). If you think that this threshold is too high, and that more criminal sentence cases should be capable of being litigated before the Supreme Court, you know who you can blame? Either the Parliament which enacted s.33 of the Criminal Appeal Act 1968. Or the Parliament which created the Supreme Court and defined its jurisdiction under the Constitutional Reform Act 2005. Head of Policy Unit at Number 10 Downing Street when the Supreme Court was created in 2005? Andrew Adonis.
Nor, regrettably, can the Lord Chief Justice, who is head of the judiciary and president of the Court of Appeal (Criminal Division), which hears sentence appeals from the Crown Court, decide of his own motion to "cut most sentences". What on earth does this mean? That every sentence appeal he sits on must be allowed, irrespective of merits, in order to achieve an overall reduction? That the current legal test that the Court of Appeal applies, allowing appeals against sentence where sentences are "wrong in law or principle" or "manifestly excessive" be lowered to something less? If so, that is not within the gift of the Lord Chief Justice alone.
Not codification that's needed – wh will prob bid sentences up still further – but for new LCJ & Pres of Supreme Court to CUT MOST SENTENCES https://t.co/gmakCyEyjY
— Andrew Adonis (@Andrew_Adonis) October 7, 2017
I fear that Adonis has a rather childlike conception of the interaction between our various courts. If the Big Judge at the top says something, then all the other little judges will do it, seems to be the gist. It is alas not that simple. Sentences will not become shorter across the board simply because Lady Hale decrees, a propos of nothing, that it should be so. It is the same simplistic view of the world that claims, with a straight face, that the judges should, somehow, have stopped Adonis' government from doing the reckless and damaging things it did:
9/ didn't argue against this unjust policy & implemented it (including really shameful indeterminate sentences for 'public protection')
— Andrew Adonis (@Andrew_Adonis) October 2, 2017
The solution, unfortunately for Lord Adonis, lies closer to home. Politicians, who are paid to make the arguments, need to change the tone of public debate on criminal sentencing. The corrosive tabloid culture that Adonis rightly decries is not going away. Parliamentarians need to be brave, and confront the toxic narrative of longer sentences and prison holiday camps that has informed Ministry of Justice policy for the past decade. Constituents should be told about the realities of prison and its proven limitations in reducing crime. The Dutch model that Adonis has held up as an example should be advocated by mainstream politicians on prime time interviews, not relegated to social media spats between ex-policy wonks and lawyers. The statutory manacles forcing judges to impose long sentences for certain offences should be re-examined and, where appropriate, released. The Justice Secretary could consider using s.128 of the Legal Aid Sentencing and Punishment of Offenders Act 2012, which would allow him to change the test for releasing the 4,000-odd remaining IPP prisoners who have served beyond their minimum terms. The plan to double the powers of magistrates – non-legally trained volunteers – to imprison people, allowing them to lock defendants up for a year for a single offence, could be snuffed out. If short prison sentences don't work, why not consider a presumption against their use, as proposed by the Lib Dems at the last election? The increasingly popular trend for the Attorney General to "refer" (appeal) sentences as "unduly lenient" to the Court of Appeal – and to feed the prison works narrative by boasting about its successes – could be challenged. There has been a 108 per cent increase in AG References since 2010, no doubt attributable in part to media campaigns whipping up anger at perceived "soft sentences", opinions often formed in wholesale ignorance of the facts.
There is a lot that could be considered as part of a remodelling of criminal sentencing. And no doubt judicial inclinations will form part of it. I don't deny that some judges use prison too readily; of course they do. They are subject to the same human frailties and cognitive biases as the rest of us. But it is Adonis' eagerness to pin the bulk of the blame on the judiciary, and the unsubstantiated assertion that they habitually falter out of genuflection to the tabloids, that I consider to be unfair. Because as we can see, that is not where the real problem lies.
In case anyone saw, listed amongst his various grievances with the legal system, the following tweet by Lord Adonis, I should like to make two brief points.
The Law Commission a talking shop which makes lawyers think they are effecting change when nothing changes https://t.co/fTSne2f6le
— Andrew Adonis (@Andrew_Adonis) October 7, 2017


text: My son had meningitis last Dec. He was so sick they did not think he would make it. He had a stroke on his right side. When he woke up he has dropped foot on his left side and a lot of weakness in his right leg. His arms were not weak at all. They assumed that this was from his stroke so did not do any sensory testing or anything. He also had a neurogenic bowel and bladder which they wouldn't call neurogenic because they thought it was from his stroke. It doesn't really matter but we found a different neurologist and she is starting to think his lower spinal cord was injured not that there will be anything on an MRI but that it still happened. She said that she has found a few meningitis cases that this has happened. My son has no reflexes in his legs. Loss of sensation on his butt and right thigh. Im not sure if it was worse before but I think it was. They never tested what sensation he had. He was only 7 and really sick so he wouldn't have noticed. His legs were in a lot of pain though. His anterior tibialis did not fire even with E-stim until about June. He does not wear a brace anymore and is starting to try to run. He still has bladder and bowel issues. He has to be cathed but as of April he can tell us when he needs to be and if it longer than 4 hour we just have him cath. He does it all on his own now. He seems to be recovering good. We see small improvements regularly but Im having a hard time finding other people with this type of injury. Is he doing well for how far out he is. I know that his urologist said that when his legs stop improving his bladder will too. If anyone could give me any advice that would be great. We are actually doing pretty well with a bowel program. He goes a few times a day not a lot but goes and then about twice a week we use Dulcolax orally. He seems to be doing good when we use Miralax he usually will have an accident. He has been able to tell us when it is a normal bowel movement that he has to go. that has been more recent. I would love any advice anyone has.

subset: commoncrawl


text:
I don't think I've mentioned it yet, but we got married! Yay! I have some follow-up info from previous posts now that the big day has come and gone.
The Dress
Some of you asked to see the dress before. I said no, because occasionally the
fiance HUSBAND! peeks at the blog, and I wanted no chance of him seeing it before the big day. I had a little bit of a conflict; I don't post pictures of myself, I forgot to take a picture of the dress by itself, and I didn't want to infringe on copyright for photographs taken of the dress professionally. But then I found someone else who posted a picture online. You can view it here.
I bought at David's Bridal. I was happy with the shopping experience. I was trying on dresses that seemed to just be way too much for the quality. I turned to my consultant and said, "You know, I have no problem buying off the clearance rack." BOOM. She brought in a dress that was exactly what I was asking for only higher quality. Originally $1,050. With the sale the store had going on, a coupon I had for booking my appointment on-line, and just general discounting from my consultant, the dress itself was $200. I was on cloud nine.
The alterations…that's a completely different story. The quote I got for alterations was $500. More than twice the price of the dress. I went home and examined my options. To move the hem up would be $150. I decided that if someone said they would pay me $150 to hold my dress up all night, I'd take it. So I didn't move the hem. Besides, don't most people take their shoes off at some point in the night anyways?
I cut a few other things out, too, and I'm glad I did. I was really disappointed by the quality of the work. The customer service was phenomenal. But after paying $300 for alterations, I expected a higher quality for the few things I did get done.
Also, another wardrobe cost I didn't even consider until I bought one severely overpriced: corsets. I shopped everywhere for them except the internet. And the bridal store was the only place that sold them. And they had two options. Which were okay, but not exactly what I wanted. The one I picked got the job done, but I remember in the early 2000s you could buy a corset at any one of a number of mall clothing stores. Were we just hoochies back then?
So if I could go back I would find a corset that fixed my frame the way I wanted first and then take it in with me when I tried on dresses. (I've since found Corset Deals, which is a resource I wish I had before my wedding.)
But as far as the dress itself, I was absolutely 100% thrilled.
His Ring
I wrote about buying the husband's ring with some trepidation before. I ordered it online and hoped he would like it. And that it would fit.
It fits. And he loves it.
Funny story: I left the ring at home. My sibling had to go back to my house, tear apart part of my house to find the hiding place (which I will never use again because it was pretty obvious where it was once the husband and I got home,) and then drive back to the venue. It's one of those things that wasn't really funny at all when it was happening. Siblingly love. (And thank goodness we didn't have a destination wedding.)


text:
In her pamphlet The Meeting Experience: Practicing Quakerism in Community, Marty Walton touches on what she identifies as the stages of worship. These stages resonate with me, and while I'm working on other posts, I thought I'd lift up this jewel of a pamphlet and share a bit about these stages.
Friend Marty offers these stages of corporate, unprogrammed worship:
1. Welcome and greeting one another. Being conscious of who is in the room; greeting one another with smiles, head nods, etc.Marty writes beautifully about each of these stages--my booklet is filled with underlined sections and notes in the margin.
2. Separating from one another. Beginning to focus inward; sinking into the silence; self-reflection.
3. Opening ourselves to the Light. Becoming aware of how we are or are not living in accordance with the Light, with "God's love and order." Often it is from this stage when opportunities for vocal ministry arise.
4. Experiencing communion with the Living Presence. Gathering of the meeting as a whole; joining together with God; transcending the earthly plane; sinking together into that Stream.
I found, though, that as I finished reading about these stages, that she does not address what I consider to be two additional stages of worship:
5. Emerging from the worship. Feeling released or detached from the inward seeking, self-reflection, or corporate worship; becoming vaguely aware again the physical space and of life beyond the meetingroom.As I look at these stages, I begin to see where and how disruptions might interfere with the overall process and experience of worship.
6. Closing. The actual shaking of hands and saying "Good morning"; restoration of the earth-bound consciousness and pre-meeting awareness.
For example, if the closing happens too early in the midst of the emergence from worship, Friends might feel that meeting was not completely over yet, that worship was broken too soon. Or if vocal ministry is offered while many Friends are still opening themselves to the Light and to each other, it may sway others to consider the message and the speaker more than necessary, thus interfering with the ability for the meeting to drop further into the stillness to experience a gathered meeting.
On the other hand, there are times when vocal ministry helps deepen the corporate worship. There is no way to know, except through testing and personal experience, how these stages of worship, and worship as a whole, are helped or disrupted by our individual offerings.


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APTOPIX roundup
Throughout the day, Associated Press photo editors comb through and designate a selection of the most newsworthy and visually breathtaking images as APTOPIX. Today, we feature a selection of APTOPIX photos from the past few weeks.
APTOPIX Maple Leafs Predators Hockey
Nashville Predators forward Mike Fisher (12) scores a goal against Toronto Maple Leafs goalie Jonathan Bernier (45) in the third period of an NHL hockey game Tuesday, Feb. 3, 2015, in Nashville, Tenn. Also defending for the Maple Leafs are Jake Gardiner (51) and James van Riemsdyk (21). (AP Photo/Mark Humphrey)
APTOPIX People Hasty Pudding Poehler Harvard
Actress Amy Poehler, center, is kissed by Jason Hellerstein, left, and Sam Clark, who are dressed in drag, as she rides in a convertible through Harvard Square in Cambridge, Mass., Thursday Jan. 29, 2015. Poehler was honored as "Woman of the Year" by the Hasty Pudding Theatricals at Harvard University. (AP Photo/Charles Krupa)
APTOPIX Germany Auschwitz Anniversary
Flowers lie on a concrete slab of the Holocaust Memorial to mark the International Holocaust Remembrance Day and commemorating the 70th anniversary of the liberation of the Nazi Auschwitz death camp in Berlin, Tuesday, Jan. 27, 2015. (AP Photo/Markus Schreiber)
APTOPIX Ukraine
A baby is held at the window of a bus with people waiting to leave the town of Debaltseve, eastern Ukraine, Friday, Feb. 6, 2015. At left is a sign reading Slovyansk. Pro-Russia rebels and the Ukrainian authorities agreed Friday on a humanitarian corridor to evacuate civilians from the epicenter of fighting in eastern Ukraine as German and French leaders prepared to bring their peace plan to Moscow. (AP Photo/Evgeniy Maloletka)
APTOPIX France La Reunion Volcano
A person looks at the Piton de la Fournaise volcano in eruption Thursday, Feb. 5, 2015, in the French Indian Ocean island of La Reunion. This is the second eruption in the past year at Piton de la Fournaise after 3-years of quiet. (AP Photo/Fabrice Wislez)
APTOPIX Train Car Collision
New York Gov. Andrew Cuomo arrives to the site of a collision between a train and vehicle in Valhalla, N.Y., Tuesday, Feb. 3, 2015. A packed commuter train slammed into a sport utility vehicle on the tracks and the front of the train and the vehicle burst into flames, authorities said. (AP Photo/Seth Wenig)
APTOPIX Greece Golden Dawn
Supporters of Greece's extreme right party Golden Dawn hold flares during a rally to commemorate a 1996 incident which cost the lives of three Greek navy officers and brought Greece and Turkey to the brink of war, in Athens on Saturday, Jan. 31, 2015. The extreme right, anti-immigrant Golden Dawn party, which has Nazi roots, appears headed for a third-place finish in last Sunday's election. Its showing comes despite the fact that the party's leader and most of its lawmakers are behind bars, facing charges of participating in a "criminal organization" accused of murders, brutal attacks on migrants and others, extortion and arson. (AP Photo/Lefteris Pitarakis)
APTOPIX Rock Pythons
Edward Mercer, a nonnative wildlife technician with the Florida Fish and Wildlife Conservation Commission, holds a Burmese python, Thursday, Jan. 29, 2015, in Miami. The invasive Burmese python has proliferated in the Everglades, and officials are now working to keep another species, the Northern African python, from slithering into the same territory. (AP Photo/Lynne Sladky)
APTOPIX India Election
India's opposition Congress party supporters wait to enter the rally ground as policemen wait beside security gates during an election campaign rally ahead of Delhi state election in New Delhi, India, Wednesday, Feb. 4, 2015. Delhi goes to the polls on Feb. 7. (AP Photo/Tsering Topgyal)
APTOPIX Britain Northern Ireland Weather
A couple walk through the snow at Stormont, Belfast, Northern Ireland, Thursday, Jan. 29, 2015. Heavy snow falls swept across many parts of the United Kingdom and Ireland closing hundreds of schools and causing widespread traffic woes for motorists. (AP Photo/Peter Morrison)
APTOPIX World Cup Freestyle Aerials Skiing
Pavel Krotov, of Russia, trains for the men's freestyle World Cup aerials, Friday, Jan. 30, 2015, in Lake Placid, N.Y. (AP Photo/Mel Evans)
APTOPIX Brazil Carnival
A reveler performs during the Banda de Ipanema carnival parade in Rio de Janeiro, Brazil, Saturday, Jan. 31, 2015. Rio's over-the-top Carnival is the highlight of the year for many local residents. Hundreds of thousands of merrymakers are beginning to take to the streets in open-air "blocos" parties. (AP Photo/Silvia Izquierdo)
APTOPIX India Politics
Supporters of Aam Aadmi Party, or Common Man Party, cheer during an election rally addressed by their leader Arvind Kejriwal in New Delhi, India, Tuesday, Feb. 3, 2015. Delhi will go to the polls on Feb. 7. (AP Photo/Altaf Qadri)
APTOPIX Pelican Harbor Seabird Station
A pelican sits in the sun at Miami's Pelican Harbor Seabird Station, Tuesday, Feb. 3, 2015. Teresa Sepetuac, rehabilitation manager, reports 75percent of the seabirds treated at the station were damaged by fishing line and hooks. The station uses almost 40,000 pounds of fish a year. (AP Photo/J Pat Carter)
View the entire APTOPIX Roundup: Feb, 6, 2015 collection
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12 Days of Christmas Daily Give Away
Just in case Santa didn't deliver the right gift (wink, wink) - we have some very Muddy gifts to give away!
A big sparkly "thank you" to all our local business friends who have given us these gorgeous gifts to share with you lovely lot!
Starting on the 25th December, there'll be a daily prize up for grabs for the 12 Days of Christmas and all you have to do to win is …….
- Come and say "Hello" and follow us on Facebook and/or Instagram
- Instagram – show us the love with a heart and tag a friend.
- Facebook – simply 'like' the post, tag a friend and share!
It's as simple as that – you can enter daily and we'll draw a name and announce a winner the following morning when we showcase the next prize.
So let's have a peep inside Muddy's sack…
Day 1. £50 Intu Chapelfield Gift Card
Just in time for the January Sales – Intu Chapelfield has given us a £50 gift card to get you started!
Day 2. Two tickets to see Jonny Woo at The Playhouse, Norwich, Sat 12th January 2019
'In' or 'Out'? There's a hell of a lot to sing about – 'Referendum-dumb', 'Swivel Eyed Loon' and 'The Ballot Box Ballad'.
Drag Superstar Jonny Woo and Olivier Award winning composer of Jerry Springer the Opera, Richard Thomas bring you this sequin spangled musical ripped straight from the headlines. This is an uproarious yet seriously glamorous satire about the referendum of 2016 and the ensuing furore of 'Brexit.' Expect glittering star turns from Boris Johnson, Angela Merkel, Nigel Farage of course and a cameo from Theresa May.
Ps. this show comes with an official warning – it's a bit rude!
Day 3. An amazing bumper prize from the Twiggles at Bewilderwood!!!
Four fabulous day passes to run WILD in the woods plus a bundle of BeWILDergoodies including:
- a print of the original illustration of Mildred the Crocklebog helping Swampy, Moss and Leaflette along the Scaaaaary Lake
- Mildred the Crocklebog hand puppet
- "A Boggle at BeWILDerwood" book by Tom Blofeld
- a scrummy box of Sweetsludge Fudge to share (or perhaps not) this Christmas!
Hot off the press!
BeWILDerwood reopens February Half Term 2019 and it seems the Twiggles have added even more adventure to the woods – The Towering Treetop Tangles! Our lucky winner could be one of the first to scramble through the tangles to explore the giant flowers in the canopy!
Day 4. Personalised ESPA Facial (50 minutes) at Barnham Broom Hotel
If I could win (which I can't grrrrr) I'd be booked in on the 1st January – starting the year as I mean to go on with regular 'me' time.
The facial includes: cleansing, exfoliation, personalised mask treatment, tension relief face, shoulder and scalp massage and finished with serums and moisturisers chosen specifically for you!
Day 5. Woodfordes Brewery – 'Born in Norfolk' selection of 12 locally brewed beers
Just in case you haven't had enough booze this Christmas (never) – we have a lovely 'Born in Norfolk' selection pack of 12 locally brewed beers from Woodfordes Brewery.
If you're not a real ale kind of gal – give it to that special man in your life as a surprise post-Christmas gift and plant the seed that surprise gifts can be a thing all year round (hint hint!).
Day 6. Lisa Angel personalised horizontal bar necklace
I absolutely love this plated horizontal brass bar engraved necklace from our Muddy Award winner Lisa Angel. Choose the plating colour to suit your style and have it engraved with a personalisation of your choice – FABULOUS!
Day 7. Ted Baker Reed Diffuser from Jarrold
The London Residence Reed Diffuser from Ted Baker is infused with a delicate balance of wild rose and English leather, which has been inspired by the passion of Victorian London (the posh part I hope). The diffuser comes with a bundle of reeds which will slowly release the oils fragrance into your room – and relax!
Day 8. A one hour relaxation massage at the Orange Grove Clinic
A lovely little treat to start 2019 – reward yourself for surviving Christmas and book in for a relaxing massage courtesy of the lovely Massage Angels at The Orange Grove Clinic.
9. Cleopatra Statement earrings from Accessorize at Intu Chapelfield
Dress for drama with these Cleopatra statement earrings. Loaded with sequins, beads and gems, this silvery pair will make you sparkle!
Day 10. Sanoflore's Revitalising Rose Floral Water, Collen & Clare
Day 11. Lunch for two at the Dial House, Reepham
Sneak off for a lovely lunch at the Dial House and spend the rest of the afternoon perusing their lovely interiors and objects of interest. This is certainly dining with a difference – big, small, practical, impractical – literally everything is for sale!
Day 12. One night Bed & Breakfast at Park Farm Hotel & Leisure
And on the twelfth day we saved the best 'til last – a one night stay at the beautiful Park Farm Hotel, including a leisure pass. The stay must be booked before the 31st March 2019. (Excludes 8, 9 & 14 February) and is for over 18's only.
Day 13. A Nudge Boutique travel size Skin Care Gift Set
Unlucky for some but not for our 13th winner – you get to take home this gorgeous travel kit from the local producer of natural skin care products – Nudge Boutique. The kit contains a 5ml Saffron Glow Facial Oil Serum and 20g Kokum Body Boost Butter – all wrapped up in a beautiful gift box.
Good Luck everyone and wishing you all a very Muddy Christmas!
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Transaction Typesell
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Don't forget to check out the posts this week from the amazing co-hosts over at Prarie Gal Cooking and My Life Abundant!!
The verse Ashleigh chose for us to look at this week is Hosea 2:15
Hosea is a book of the Bible that fills me with awe and wonder. It's a shocking and almost terrifying story of God's grace and his mercy. As those of us who see themselves the harlot, unfaithful to God even though He has given us, literally, everything we have, we see hope and renewal.
As a woman who has walked, completely in love with the Lord, for years, sometimes I want to overlook Hosea. Some days I forget who I was, and what God saved me from, and even who I would be today without Christ.
As life would have it I did some good ol' fashioned Fb stalking last night and I came across some people from high school I enjoyed finding. I scanned through their pictures, and enjoyed seeing them as spouses and parents. So many looked so very lost, in their mid 30's posting about their last drunken "good time", pictures with children throwing up gang signs, sadly even one in a orange jumper. My heart ached and I remembered what it felt like to search for happiness in a fleeting moment of numbing drunkenness or sex.
I remembered the feeling of longing and thinking it might be fulfilled by a person, a drink or by passion.
Only the great, fulfilling love of a Savior will bring contment.
I sat and thanked God for where He had brought me and I prayed. I prayed for those still lost. I prayed God would not give up on them, as he did not give up on me!!
The best part is, not only did he save me and show me grace, but He's given me life abundantly! He has given me a song of praise on my lips and the hope (even on the worst of days) of eternity spent with my Creator!!!
In case you didn't get to check them out last week…here are a couple that really stood out to me!!
If you need encouragement…Read this one:
If you are looking for some child friendly things to do try this one from
Tea Leaves and Chickadees
If you are hungry, make this (feel free to bring me one too!!):
Here are the few rules we have for the link-up:
- The link-up starts early Sunday morning (exact time varies a little!) and ends Friday at noon.
- This is a Christian link-up. All posts are required to be family friendly!
- There is no limit on the number of posts you share.
- This isn't a requirement, but it'd sure be nice if ya clicked on a few other links and left a comment! (Most bloggers will return the favor!)
- We will be giving away a entire FREE WEEK of advertising on PGC each week, all you have to do is add two links!
- By linking up you're giving PGC permission to use a picture in your post and link back to your site.
- And lastly, please follow Prairie Gal Cookin' on social media to see which of your posts get shared and featured, as well as to get updates on the latest link-ups!
Prairie Gal Cookin':
The Mom I Want to Be:
My Life Abundant:
So let's get on to the link-up!


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Lessu was the capital city of Ryloth.
During the Clone Wars, the Separatist Droid Army, commanded by Wat Tambor, took control of Ryloth and took the Twi'leks prisoner. The Separatists installed a plasma bridge as the only way to get into the city, which they could turn on or shut down. The capital was later freed by the combined forces of freedom fighters and the Galactic Republic, guided by Jedi Master Mace Windu and rebel leader Cham Syndulla, with aerial support from Anakin Skywalker and Ahsoka Tano's fighter squadron.[1]
During the Imperial occupation, a female Twi'lek named Isval traveled to the Octagon, a district in the heart of the city of Lessu. There, she encountered a Twi'lek escort named Ryiin and a drunken Imperial officer. After assaulting the Imperial officer, she spirited Ryiin away into a new home where she would be safe from slavery.[3]
- Star Wars: The Clone Wars – "Storm Over Ryloth" (First appearance) (Appears in flashback(s))
- Star Wars: The Clone Wars – "Innocents of Ryloth" (Mentioned only)
- Star Wars: The Clone Wars – "Liberty on Ryloth"
- Catalyst: A Rogue One Novel
- Lords of the Sith
- "Mercy Mission"—The Rise of the Empire
- Star Wars Rebels – "Homecoming" (Mentioned only)
- Bloodline
- "Liberty on Ryloth" Episode Guide on StarWars.com
- Star Wars: Rogue One: The Ultimate Visual Guide
- Star Wars: The Visual Encyclopedia
- Star Wars: On the Front Lines
- AAT Battle Tank History Gallery on StarWars.com (backup link)
- Star Wars Encyclopedia of Starfighters and Other Vehicles
- Battle Droid in the Databank (backup link)
- Wat Tambor in the Databank (backup link)


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Veterans and Aviation
As the holidays approach, it is easy to get sentimental thinking of all the things we can be thankful for, especially living in such a great nation where we enjoy so many of life's comforts. However, it is not without sacrifice from the few that we get to enjoy freedom and aviation. Many of our nation's finest will not be home with their families, but instead on the front lines of war. Although we wish and pray that they all come home, we are aware that is not reality. It is this struggle and sacrifice which galvanizes the bonds formed in the service.
Several of us transition out of the service and end up in aviation. For me it was a natural transition. I left my CH-53E unit, HMH-464, to attend Embry-Riddle Aeronautical University where I would receive my Bachelors in Aviation Maintenance, as well as my flight ratings. Unexpectedly I ended up in the commercial aftermarket when another Marine veteran "recruited" me for the position. I was excited to find that the company I worked for, much like Embry-Riddle, was filled with veterans.
Civilian aviation, like the military, requires a great deal of risk mitigation. There is a necessary level of attention to detail demanded from everyone involved. The receiving clerks, quality inspectors, mechanics, pilots, and management, all contribute to flight safety and operational risk management. Perhaps that's why we enjoy it so much. Every day is a challenge. Every task is important. Every time we show up to work we're making planes fly. Each service member performs a task critical to the fight. Each aviation employee performs a task critical to the flight. Whether you're flying the plane, or sourcing parts for the airlines, these aerodynamic chunks of metal need each person's help to get airborne. It is at that point that those wings can carry kids to their grandparents, gifts to loved ones, care packages to Afghanistan, food and supplies to those in need, and most importantly troops back to their families. So again, let us remember how blessed we are to work in such a great industry as aviation!


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Donna's Blog
What is so bad about PowerPoint?
- Details
- 01 November 2017
What is so bad about PowerPoint?
I don't hate PowerPoint, I just think it's misused.
PowerPoint was never meant to be a word processor, it was designed as a presentation tool. We had, and continue to have, Word for that.
Sadly, many use PowerPoint as a word processor and simply project documents onto a screen or overloaded with content and graphs, that are so small as to be un-readable.
Unfortunately, many organisations believe that a meeting or briefing cannot occur, an idea cannot be expressed or skill be taught without a "deck" of slides.
And why is that, do you think? Security blanket? Confirmation of knowledge transfer? Reduced attendance at meetings ("I'll send you the deck")? Covering your $%#@ ("it was in the deck")?
So … I don't hate PowerPoint, I just think it's misused.


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February is National Pet Dental Month! Since I am a dental assistant I take teeth very seriously. A lot of pet owners don't understand that dental care in our pets is very critical to their overall health. Dental disease can cause a lot of problems like bad breath, bleeding from the mouth and loss of appetite. Keeping an at home regimen of brushing your pets teeth is very important. Since I will be talking about what I do for Daze I will also talk about my daily dental regiment.
My dentist recommends on using a electric toothbrush. Manual toothbrushes can lead to gum recession from brushing too hard. I also like to switch toothpaste and mouthwash about every month or when it runs out. It's crazy how our our teeth and gums can adapt to that. I 100% recommend on going to the store right now and purchasing a Oral-B toothbrush! Costco! I love Costco and they are doing a deal right now for this toothbrush: Costco Oral-B. Note: you only have to purchase this one time and you just buy new heads for it. I can't believe how excited I am about talking about a toothbrush but it is seriously amazing. Right now I am currently using Colgate toothpaste and Listerine mouthwash.
Now lets move onto the actual topic of National Pet Dental Month and talk about Daze. I have tried and tried to get a picture of her teeth because they are just so cute and tiny. She definitely doesn't like anything but food or her toothbrush in her mouth (which sometimes has to be covered in peanut butter.) I can't say I'm perfect and brush her teeth everyday. Someday's she is just not having it so I will give her a freebie day off and give her a bone or treat. Bones are really great for dogs teeth. They can get any plaque off the teeth and make the teeth really strong. Plus they love it! In my experience I have found that the dog toothbrushes are way too big for Daze's mouth and she really hates them. I found the best option is a 0-2 year old baby toothbrush. The bristles are extra soft and it's tiny for her little mouth. I found that she is more willing to have me brush her teeth without any toothpaste so I go with it.
I can't tell if she's happy or nervous for this one
Or if she's not having it I will let her enjoy her bone
Make sure your vet looks at your dogs teeth and gums at the next routine exam! And don't forget about yourself and see your dentist! Check out these dental products at PetSmart: Dental Care
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So excited that BookArtsLA is having me back to teach my two-day Introduction to Paper Marbling intensive!
In this immersion class, students will learn the nuts and bolts of the art form, dive into traditional pattern making (foundation and advanced patterns) using the large marbling tank, and have time for creative exploration. You'll leave with a robust understanding of the art form, dozens of marbled papers, and the confidence to start marbling at home.
This class is fast paced and packed full of information. It is also physically demanding…we are on our feet all day and constantly moving from one end of the studio to the other. We also will be working both inside and outside of the studio so you will be exposed to the elements for brief bits of time (like sun!). But most of all, we have A LOT of fun.
Everything is provided in this class ~ just show up and have fun! To register, head on over to the BookArtsLA website.
Introduction to Paper Marbling
Saturday, August 25 and Sunday, August 26
9 a.m. - 4 p.m. (both days)
11720 Washington Place, Los Angeles


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Road to Manhunt International 2011
Mister Brazil 2011 will be held May 7, 2011, at the beautiful Hotel dos Frade, in breathtaking Angra dos Reis!! 40 of Brazil's finest will compete for the coveted title of Mister Brasil. The winner goes on to compete in Mister World, with the first and second runners-up representing Brazil at Manhunt International and Mister International.
Mister Brazil 2011 will be held May 7, 2011, at the beautiful Hotel dos Frade
For the first time in the history of the pageant, Mister Brazil will be broadcast live on national television!! TV UOL will be broadcasting the pageant live beginning at 10:00pm local time (that's 6:00 pm if you live in California) !! You can watch
Special thanks and credits to worldshowbiz.info