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Monday, May 9, 2016
2016 ASCL ANNUAL MEETING Call for Papers
The Younger Comparativists Committee (YCC) of the American Society of Comparative Law (ASCL) is pleased to invite submissions to fill a panel on "New Perspectives in Comparative Law," to be held at the Society's 2016 Annual Meeting ASCL Annual Meeting, which will be held October 28-29, 2016 at the University of Washington in Seattle. The purpose of the panel is to highlight the scholarship of new and younger comparativists. The younger scholars who are selected for the panel will each be paired with a senior discussant in their field who will provide comments and suggestions on their papers.
Submissions will be accepted on any subject of public or private comparative law from scholars who have been engaged as law teachers for ten years or fewer as of July 1, 2016. Only scholars who are affiliated with ASCL-member institutions are eligible to participate on the panel.
The Scholarship Advisory Group of the YCC will review submissions with the authors' identities concealed. Up to two submissions will be chosen for the panel. Submissions will not be accepted from scholars whose work has been featured in a prior younger scholars' panel at the ASCL Annual Meeting.
To submit an entry, scholars should email an abstract of 1000-1500 words (including footnotes) no later than Friday, June 24, 2016, at 5:00 pm CDT to Yolanda Huggins at the following address: firstname.lastname@example.com. Please indicate "ASCL Annual Meeting Submission" in the subject line. Late submissions will not be accepted. Abstracts should reflect original research that will not yet have been published by the time of the Society's Annual Meeting. The abstract should be accompanied by a separate cover sheet indicating the author's name, title of the paper, institutional affiliation, contact information, and a statement confirming that the author (or at least one of the authors, if co-authored) has been engaged as a law teacher for ten years or less as of July 1, 2016 and is affiliated with an ASCL member institution. The abstract itself must not contain any references that identify the author or the author's institutional affiliation.
May 9, 2016 | Permalink | Comments (0)
Sunday, April 24, 2016
Comparative Law Works-In-Progess Workshop
I'm recently back from ASCL's Works-in-Progress Workshop held last weekend at the University of Illinois College of Law. Seven papers were discussed at the workshop. If you write in the field of comparative law, having a draft selected to be discussed at this workshop is an extraordinary opportunity for receiving feedback from experts in the field. The annual conference is organized by several leading comparative law scholars including: Maximo Langer (UCLA), Jacqueline Ross (University of Illinois), and Kim Lane Scheppele (Princeton). This year, the workshop papers represented a variety of nationalities and topics in both public and private comparative law. Antonia Baraggia (University degli Studi di Milano), Wei Cui (University of British Columbia), Yuliya Guseva (Rutgers), Adam S. Hofri-Winogradow (Hebrew University), Mariana Pargendler (Escola de Direito-Brazil), and Bui Ngoc Son (National University of Singapore).
April 24, 2016 | Permalink | Comments (0)
Wednesday, April 20, 2016
The War Over Video Game Warriors
With special guest blogger YiYang Jiang (Clifton Wolcott), third-year undergraduate student at the School of Law, Shanghai University of Political Science and Law
China has long had the reputation for fostering rampant piracy of copyrighted works. The Chinese legal system has made great strides in addressing such piracy, including accession to various international conventions on intellectual property rights and implementation of a copyright law very similar to those in the U.S. and elsewhere. Enforcement of these copyright laws has apparently been somewhat lax in the past, but even this has improved in recent years, at least with regard to blatant reproduction of protected works. The Chinese government has heightened its copyright enforcement efforts by increasing the number of raids on counterfeiters, deliberating on several enhancements to administrative enforcement abilities, enhanced infringement penalties, and perhaps even increasing public perception of copyright infringement as illegal. Protection of copyrighted works may have a way to go yet in China, but China does seem to be making progress.
One of the issues that the Chinese copyright system is also facing is infringement not through out-and-out reproduction of a work in part or in whole but rather infringement by copying only isolated elements of a protected work in order to create a new work. Such partial copying raises issues not only of infringement but also of the copyrightability of the elements copied. A prime example of this is at issue in a case currently pending before the Northern District of California. U.S.-based companies Blizzard Entertainment, Inc. and Valve Corporation sued uCool, Inc. and China-based Lilith Games Co. Ltd. for infringement of the characters, among other elements, in Blizzard and Valve's copyrighted video games. At least two of the characters in Lilith's mobile game Soul Hunters, for example, are clearly copied in large part from those in Blizzards' game World of Warcraft ("WoW"). Although not exactly like their WoW counterparts, the Lilith characters have the identical clothing, weaponry, and even skin color; the only real difference between the two sets of characters is that Lilith's versions are more cartoon-like, two-dimensional, and cuter than WoW's more three-dimensional and intimidating versions. Both us feel that such a high degree of imitation, although not exact reproduction, clearly indicates Lilith's intent to free-ride on the success of Blizzard's games.
Indeed, the characters, scenes, storylines, and other elements in Blizzard's immensely popular and profitable games have apparently been the subject of rampant copying in China and elsewhere. Blizzard does not yet seem to have filed suit in mainland China, however, although it has filed suit in Taiwan against Longtu Games for copyright infringement of Blizzard's characters. If Blizzard decided to file suit against Lilith and others in China, it is unclear whether Blizzard would prevail. Neither the U.S. nor the Chinese copyright statute states that characters as copyrightable subject matter, and indeed, infringement involving characters entails difficult questions of copyrightability, a problem Blizzard and Valve face in their lawsuit in the U.S. In dismissing (with leave to amend) Blizzard and Valve claim of infringement of the copyright in their games' characters, the District Court noted that characters are most often not separately copyrightable subject matter and that the plaintiffs therefore face a significant hurdle in showing that their game characters are the exception to the rule. As with most copyrightability issues, the copyrightability of characters as stand-alone "works" depends on the particularity with which they are expressed. Blizzard could not, for example, assert a character copyright over all weapon-toting mythical creatures in general because these are stock characters common to many video games. Blizzard can, however, assert copyright ownership over a particular character if it is "especially distinctive" – whether Blizzard can meet this standard remains to be seen.
It also remains to be seen what approach the Chinese courts will take to any potential claims of character copyright infringement that Blizzard might file in the future. Chinese often apply the same legal standards that courts in the U.S. and other countries use when it comes to intellectual property cases, although the approach often varies in practice. Indeed, the Chinese courts have addressed a number of cases similar to Blizzard's, including a number where the defendant was alleged to have copied popular cartoon characters on unauthorized consumer goods (e.g., Ltd. Shenzhen Huaqiang Digital Animation Co. v. Vanguard Superstore; Futabasha Publishers v. Ltd. Shanghai Enjia Trade Development Co.) or in video games characters (e.g., Creative Power Entertainment v. Shaanxi YouJiu Digital Technology Co., Ltd.). The Chinese courts have frequently found for the copyright owners in these cases, but in doing so, the courts have protected the copyrighted characters not as characters per se but as "fine arts" (Article 3(4)) – what under U.S. copyright law would be considered pictorial or graphic work (17 US.C. § 102(a)(5)). This is perhaps a wiser, as the copyrightability of illustrated or animated characters is easier to determine when classified as pictorial or graphic works, avoiding the question of whether the underlying character is a separately copyrightable work; where a character is based on a literary description or live-action depiction, by contrast, the determining copyrightability unavoidably involves more difficult issue of "exceptional distinctiveness." That being said, the courts in these cases have also looked not only at the similarity between the two works but also the fame or reputation of the characters at issue, suggesting that the Chinese courts may also have implicitly adopted aspects of the U.S. approach to the copyrightability of characters more generally.
April 20, 2016 | Permalink | Comments (0)
Sunday, April 3, 2016
Research Handbook on Global Administrative Law
Edward Elgar Publishing has just published the "Research Handbook on Global Administrative Law." The book is edited by Sabino Cassese,
This Handbook explores the main themes and topics of the emerging field of Global Administrative Law with contributions by leading scholars and experts from universities and organizations around the world. The variety of the subjects addressed and the internationality of the Handbook's perspectives make for a truly global and multi-dimensional view of the field.
The book first examines the growth of global administrations, their interactions within global networks, the emergence of a global administrative process, and the development of the rule of law and democratic principles at a global level. It goes on to illustrate the relationship between global law and other legal orders, with particular attention to regional systems and national orders. The final section, devoted to the emergence of a global legal culture, brings the book full circle by identifying the growth of a global epistemic community.
The Research Handbook on Global Administrative Law provides a contemporary overview of the nascent field in detailed yet accessible terms, making it a valuable book for university courses. Academics and scholars with an interest in international law, administrative law, public law, and comparative law will find value in this book, as well as legal professionals involved with international and supranational organizations and national civil servants dealing with supranational organizations.
Here is a link to the book's Table of Contents.
April 3, 2016 | Permalink | Comments (0)
Friday, March 18, 2016
Is the English Adversarial Process Changing?
Two recent articles in The Criminal Law Review highlight possible changes in the adversarial system in England.
First, new Crown Prosecution guidance allows prosecutors to prepare some vulnerable witnesses before their testimony at trial, although coaching as we know it in the United States remains forbidden. Laura Hoyano, Reforming the Adversarial Trial for Vulnerable WItnesses and Defendants, [2015] 2 Crim. L. Rev. 107.
Second, an article describes recent case law that seeks to make clear that the object of cross-examination is to investigate the truth through clear, understandable questions rather than to so-called 'put the case' to the witness or trap the witness in inconsistencies. Emily Henderson, Theoretically Speaking: English Judges and Advocates Discuss the Changing Theory of Cross-Examination,[2015] 2 Crim. L. Rev. 929.
March 18, 2016 | Permalink | Comments (0)
Sunday, March 13, 2016
Italian Law Journal: Call for Submissions
The newly launched Italian Law Journal is looking for submissions for its next issue. Submissions are now open for the next issue and are being accepted until mid-April.
If you would like to receive updates from the Italian Law Journal, please sign up for their newsletter and they will keep you posted on their activities. You can do so by sending your request to: email@example.com.
March 13, 2016 | Permalink | Comments (0)
Sunday, February 28, 2016
Recent Comparative Law Papers
This week we highlight two recent SSRN postings in the field:
1. Dmitriy Kamensky, a Fulbright Faculty Development Fellow at Stetson University College of Law, has posted "Introducing Corporate Criminal Liability in Ukraine: Terra Incognita." From the abstract:
Modern political developments, globalized economy, and further synchronization of legal systems around the world provide a unique forum for expanding existing national-law frameworks, establishing new principles and doctrines of law. Criminal law is everything but an exception. New international threats, such as terrorism, economic criminality and public corruption, require deep rethinking of national and international criminal law regimes respectively. This Article is focused on the advantages and flaws of corporate criminal liability in yet another European jurisdiction – in Ukraine. American corporate liability model will serve its virtual "sparring partner" role for the purposes of evaluating both progress and potential pitfalls on Ukraine's way to establishing effective legal framework to combat corporate crime.
The Criminal Code of Ukraine ("CCU") has been recently amended by introducing quasi-criminal liability for organizations in the form of specific criminal law measures. This by all means historical legislative step highlights a few significant points. First, from now on liability may be imposed on an artificial legal entity – not just a natural person. Second, Ukraine is serious about its commitment to becoming a member of the European Union. Finally, at this point of the national criminal law developments in the direction of democracy, rule of law, and free-market economy neither judiciary, law enforcement, nor legal community in general are willing to accept criminal corporate liability statutes, due to their novelty and absence of meaningful and comprehensive doctrinal explanation. Meanwhile Ukrainian legal commentary remain quite skeptical about the current model of corporate liability and argue that the traditional approach to individual criminal liability should remain the only remedy available.
2. Darryl K. Brown, University of Virginia School of Law has posted, "Free Market Criminal Justice: How Democracy and Laissez Faire Undermine the Rule of Law." This paper adds an interesting perspective on the democratic accountability of prosecutors.
February 28, 2016 | Permalink | Comments (0)
Monday, February 15, 2016
Guest Post: Justice Scalia - Civil Lawyer in a Common Law America
We are pleased to publish this guest post by James R. Maxeiner J.D., LL.M., Ph. D. in Law (Munich), Associate Director, Center for International and Comparative Law, and Associate Professor of Law, University of Baltimore School of Law
Justice Scalia - Civil Lawyer in a Common Law America
Justice Scalia was well-known for textualism and originalism. He was known for his opposition to the Supreme Court looking to foreign law for guidance.
It is little known, however, that, notwithstanding the Justice's opposition to the Court's relying on foreign law, he was the most earnest opponent of common law methods (including stare decisis) and an ardent proponent of civil law methods.
Maxeiner, James R., Scalia & Garner's Reading Law: A Civil Law for the Age of Statutes? (August 15, 2013). 6 Journal of Civil Law 1 (2013). Available at SSRN: http://ssrn.com/abstract=2132581 orhttp://dx.doi.org/10.2139/ssrn.2132581
In Reading Law: The Interpretation of Legal Texts U.S. Supreme Court Justice Antonin Scalia and American legal lexicographer Bryan A. Garner challenge Americans to start over in dealing with statutes in the Age of Statutes. They propose ― "textualism," i.e., ― "that the words of a governing text are of paramount concern, and what they convey in their context is what the text means." Textualism is to remedy American lack of ― "a generally agreed-on approach to the interpretation of legal texts." That deficiency makes American law unpredictable, unequal, undemocratic and political. In the book's Foreword Chief Judge Frank Easterbrook calls the book ― "a great event in American legal culture." It is a remarkable book because it challenges common law traditions. This review essay shows how Scalia and Garner challenge common law and summarizes the content of their challenge. This essay contrasts the methods of Reading Law with the methods of the Continental civil law. It shows that textualism is consistent with modern civil law methods. It shows also, however, that pure textualism, which largely restricts interpretation to grammatical and historical interpretation and excludes non-textual interpretation such as equitable, pragmatic and purposive approaches, is not consistent with modern civil law methods. In modern civil law, textualism and non-textualism coexist. They must, if law is to honor legal certainty, justice and policy.
February 15, 2016 | Permalink | Comments (0)
Friday, February 12, 2016
International Megan's Law
On February 8, President Obama signed a new bill (H.R. 515), International Megan's Law, requiring that 1) the U.S. Immigration and Customs Enforcement Agency notify foreign officials when a convicted child sex offender is traveling to their country; and 2) the State Department put a "unique identifier" on the passports of persons who have been convicted of a sex crime involving a child (even if they were children at the time themselves and no matter when the conviction arose) who have been listed on a public sex offender registry. A lawsuit challenging the constitutionality of this law has been filed by California Reform Sex Offender Laws (CA RSOL). The plaintiffs include CEOs of major international companies who travel extensively – and innocently – for business.
The bill was signed eight days after it left Congress and four days after it was received by the White House. Supporters say that the law will help prevent sex trafficking by making it more difficult for sex offenders to "[plan] their trips around locations where the most vulnerable children can be found," in the words of Congresswoman Ann Wagner, who co-sponsored the bill. Critics assert that there has been no connection established between people on US sex registries and international sex trafficking; that the branding of passports will do nothing to protect the United States from its own sex offenders who, indeed, will be limited in leaving the United States, even for innocuous purposes; that such limitations are unconstitutional; and that the "unique identifier" endangers the safety of such tourists and anyone flying with them. Moreover, a large percentage of people on the registry for child sex offenses were themselves minors when they were convicted, usually of engaging in sexual conduct as with a minor incapable of consent only because of age. Significantly, too, many Americans use their passports not for travel but simply for identification purposes – and those people will be unfairly subjected to all of the negative consequences of such identification.
Aside from my own personal sense that there seems to be no limit to the US urge to stigmatize and punish "the other," I can't help but ask if that urge - or any ostensible need to protect US citizens - is really justified by a law that is designed to prevent sex crimes in other countries. Significantly, other countries' sex registry rules are very different from those of the United States. Why are we imposing our uniquely US view on other countries? Shouldn't other jurisdictions decide who should be excluded from entering based on their own legal and cultural standards, which they are fully capable of doing? Reciprocal international efforts to limit sex trafficking are legitimate, but this Act seems overbroad, probably unconstitutional, arrogant, and paternalistic.
Related Readings:
- David Post, The Yellow Star, the Scarlet Letter, and 'International Megan's Law', The Washington Post (Jan. 6, 2016).
- Press Release, Congresswoman Ann Wagner, Wagner Speaks in Support of International Megan's Law (Feb. 1, 2016).
- Press Release, Florida Action Committee, Lawsuit Filed Against International Megan's Law (Feb. 9, 2016).
- International Megan's Law, H.R. 515, 114th Cong. (2016) (summary for H.R. 515).
- Obama Signs Controversial Legislation Designed to Prevent Sex Tourism, NYTLive (Feb. 9, 2016).
- Doe v. Kerry et al., No. 3:16-cv-0065
- Lissa Griffin & Kate Blacker, Megan's Law and Sarah's Law: A Comparative Study of Sex Offender Community Notification Schemes in the United States and the United Kingdom, 46 Crim. L. Bull. 987 (2010) (SSRN).4 (N.D. Cal. Feb. 9, 2016
February 12, 2016 | Permalink | Comments (0)
Thursday, February 4, 2016
From Common Constitutional Core to Dialogue Among Courts
We are happy to publish this guest post from Associate Professor Quirino Camerlengo, University of Pavia (Italy), Department of Management and Business (PhD in Constitutional Law) who previously served as a Law Clerk in Italy's Constitutional Court.
The Dialogue Among Courts
Dialogue among courts consists of comparing the interpretations of law. The Courts conduct this dialogue through mutual citation. Written constitutions give the interpreter a wide range of possible options as regards the meaning to give to individual rules while keeping the limitations imposed by the original intent of their creators. Elements taken from the jurisprudential experience of other states can be used when interpreting a constitution.
In the context of fundamental rights, the factors determining change in the interpretation differ in consistency from one state to another. Moreover, some states may promote their more far-reaching interpretative evolutions as suitable for other states to imitate. Consequently, comparison with the laws of other states can give courts innovative elements to use in the interpretation of domestic law, beginning with constitutional interpretation.
Successful dialogue depends on the willingness of domestic courts to compare their interpretations with those of other states.
The experience of the United States confirms the consistency of the resistance towards inter-court dialogue (Jackson 2005, p. 109). Reluctance to drawing comparisons is widespread, as summed up by Justice Scalia (in Printz v. United States, 521 U.S. 898, 1997) who said: "we think such comparative analysis inappropriate to the task of interpreting a Constitution, though it was of course quite relevant to the task of writing one".
The Thesis
I will try to show that:
- a reasonable uniform level of protection for fundamental rights can be reached tank to dialogue among national judiciaries;
- the dialogue among courts is the consequence of the presence of an essential constitutional common core (an ensemble of common fundamental principles belonging to the constitutional systems of western countries);
- the principles belonging to the constitutional common core can be identified by considering the expectations of rights protection on the part of specific actors within the state, in this case, foreign guest workers;
- the rules born of this inter-court dialogue flow into a cosmopolitan constitutional law, according to the Kantian theory of the Weltbürgerrecht.
Western constitutionalism and common constitutional roots
To find a reasonable balance in the levels of safeguard of fundamental rights, particularly among western states, dialogue among foreign courts can develop hand in hand with the awareness that the constitutional system is not the exclusive product of the tradition of a determinate people, but is based on, and continually nourished by, a shared heritage of fundamental principles.
David Beatty wrote: "the basic principles of constitutional law are essentially the same around the world, even though there is considerable variation in what guarantees constitutions contain and in the language that they employ" (Beatty 1995, p. 10).
The sharing of common roots is inherent to the concept of western constitutionalism, it being a current of thought that has extolled the role of the constitution as a defensive bulwark of fundamental rights. The assertion of constitutionalism has gradually brought states closer together, reducing the differences in legal traditions that were previously thought to be insurmountable. Constitutionalism has promoted reciprocal interaction among legal traditions, which has affected the very concept of law.
The dialogue achieved with a reasonable use of comparison can encourage states to look for the most suitable solutions for safeguarding fundamental rights.
Nevertheless, the identification of shared fundamental principles is harder than it looks.
Two obstacles make it difficult to reconstruct the common heritage of fundamental constitutional principles:
- the constitutions tend to change over time, though marginally and very slowly, which throws into question the stability of the common heritage as a factor of cohesion among states;
- the constitutions tend to be self-referring.
To address these obstacles:
- it should be assumed that every constitution is born and develops from a stable and intangible essential core;
- to identify the fundamental principles of the common heritage, a foreign element must be injected into the constitutional systems in order to verify whether these principles are able to guarantee an adequate level of safeguard for fundamental rights. This foreign element makes it possible to make the comparisons required to identify the limits and shortcomings of constitutional systems.
The essential constitutional core
The constitutional system is the organic combination of heterogeneous elements, whose cohesion is intended to interactive achievement of certain aims.
The comparison between systems is a comparison of the key elements that determine the essence of every system.
The basic elements are the core of the system. Each complex entity develops starting from a limited set of constitutive factors which define its main features, essentially as regards identity (structural dimension) and its concrete capacity of affecting existing entities (functional dimension).
The essential core incorporates fundamental constitutional principles that guarantee the stability of the state: their elimination would cause a radical transformation of the state itself.
These principles are the basic principles identified through a consideration of their position in the constitution and in constitutional jurisprudence, without forgetting the historical, cultural, and political traditions of the country itself.
This lowest common denominator is precisely the theorized essential constitutional core.
These principles reflect the fundamental aims of the constitutional system. Constitutions embody "deeper imperatives that continue to shape their struggle for power and legitimacy" (Ackerman 1998, p. 384). These 'deeper imperatives', such as the separation of powers or judicial review of legislation, are principles that have not been invented ex novo by a state, but rather are the common heritage of western countries linked to the English tradition.
But how does one identify the characteristics of this essential core?
It should be considered that the constitutional system:
- is formed starting from a small number of constitutive elements expressing its embryonic condition (birth);
- it is a compact body of elements with specific characteristics derived from its genetic matrix (identity);
- it survives thanks to the indissoluble cohesion and stability of its constitutive elements which assure a permanently balanced structure (existence);
- it evolves by following the development trajectories traced by its original elements (development).
Therefore, the essential core is:
α. necessary: the constitution is derived from the core. The other elements aggregate around the core to form the system;
β. substantial: the essential core gives the system its specific identity as a complex of peculiar characteristics which define its original physiognomy. The essential core incorporates the 'genetic code' of the system;
γ. indivisible: the elements incorporated in the core cannot be separated;
δ. dynamic: the core guarantees and guides the evolution of the constitutional system.
Every western constitutional system has an essential core incorporating its fundamental principles. It is the interaction of these principles, in turn, that satisfies the characteristics of the essential core: thanks to this interaction, these principles really are fundamental.
Now, the common constitutional heritage of western states must be reconstructed by interrogating the essential 'cause' of the various constitutional systems. In other words, the principles incorporated into the common essential constitutional core must be selected.
The identification of the fundamental principles in the common essential core began with article 16 of the Déclaration des Droits de l'Homme et du Citoyen of 1789, considered by many to be the epitome of constitutionalism: "toute société dans laquelle la garantie des droits n'est pas assurée, ni la séparation des pouvoirs déterminée, n'a point de constitution".
Comparing the constitutional systems of western states and using the abovementioned selection criteria, it can be demonstrated that the common essential core includes the following fundamental principles:
- safeguard of fundamental rights and the rule of law;
- equal protection of the laws;
- separation of powers;
- democracy;
- pluralism;
- supremacy of the constitution.
The safeguard of fundamental rights is the typical aim of constitutions. In turn, the safeguard of fundamental rights trusts in the rule of law institutions. Without equal protection of the laws it's not possible to imagine a fair and strong safeguard of fundamental rights. Every unjustified discrimination is a menace to fundamental rights. The separation of powers is the solution best suited to the protection of fundamental rights. The absence of checks and balances would make it the only power to be absolute arbitrator for the destiny of basic rights (Ackermann 2000). Democracy is the principle best able to guarantee the fundamental rights in a State governed by the rule of law and by the separation of power. In a constitutional system orientated towards freedom, the safeguard of rights presupposes that their limitations are decided in ways that there is a virtual identification between the holders of power and those who are the object of the rules (political representation). Pluralism aids democracy. There can be no democracy without pluralism. In fact, pluralism means the recognition of the many social and political realities of the State. Finally, the supremacy of the constitution is the basic condition that they be guaranteed fundamental rights. Chief Justice Marshall had guessed right when he said that "the constitution is either a superior, paramount law, unchangeable by ordinary means, or it is on a level with ordinary legislative acts, and like other acts, is alterable when the legislature shall please to alter it" (Marbury v. Madison, 5 U.S. (1 Cr.) 137, 1803).
The "foreign element"
A constitutional system is not ideal if an appreciable level of protection for fundamental rights has not yet been realized. Indeed, a constitutional system is inefficient if it does not draw upon the arrangement of the fundamental principles belonging to the constitutional essential core.
To test the realization of this condition, it is not correct to use the internal standards of a country. In this context, a state is introvert if it does not accept comparison with other states for the purpose of assessing its level of rights-protecting juridical culture.
An introvert state measures its degree of maturation by exclusive use of reference parameters taken from its own history. The 'introverted' nature of the United States, despite enjoying the reputation of providing a broad scope for the protection of fundamental rights, sometimes makes it difficult for the comparison among the standards of safeguard reached by other countries.
Dialogue among courts is the antidote to this introverted nature: "the uses of external norms may mark a radical and deliberate departure from parochial practice […] or they may signal little more than a serendipity not soon to be reparted" (Amann 2004, pp. 597-598).
To provide an external standard, a citizen from another state might provide the external means for comparing systems.
The admission of this element is due to the entrance of citizens from other states: individuals with expectations regarding minimum threshold standards regarding the protection of their fundamental rights. Guest citizens abandon their countries in the hope of improving their starting conditions of life. Consequently, states will be more willing to accept new individuals, and, therefore, the level of conflict will decrease.
International networks of legal practitioners or labor activists are a precious source of transmission of knowledge of alternative interpretations. Legal organizations propagandize to prod transformations in legislation and jurisprudence (law-in-progress). The foreign guest worker, on the other hand, starts legal proceedings in which the law is interpreted and applied in concrete cases (law–in-action).
The main challenge for foreign guest workers initiating court action to secure rights protection is to obtain recognition of fundamental rights when the relevant written constitution refers to citizens only. In such a case, the use of the principle of equal protection of the laws could cause the extension of fundamental rights protection to foreign guest workers.
Just think of the decisions of the United States Supreme Court in the context of Guantanamo Bay, in which the fundamental right of habeas corpus (above all the suspension clause) was recognized as applying to foreign prisoners, even if enemy combatants (Rasul v. Bush, 542 U.S. 466, 2004; Hamdan v. Rumsfeld, 542 U.S. 507, 2006; Boumediene v. Bush, 553 U.S. 723, 2008).
After obtaining recognition as a subject having access to a state's constitutional mechanisms of fundamental rights protection, the foreign guest worker could plan his judicial defense with reference to interpretations of common constitutional principles such as personal freedom, and the freedoms of religion, association, assembly, and thought, that originate in the jurisprudence of her own (rather than the host) country.
In this way, inter-court dialogue can achieve a healthy evolution of mechanisms for rights protection, regardless of the citizenship of the parties.
In considering the position of guest citizens when selecting the principles of the common essential core, the result will be the identification of the principles belonging to the constitutional common core:
- to make tendentiously and reasonably uniform the standards of defence concerning the protection of fundamental rights;
- by placing stress on the individual owner of these rights;
- as a consequence of the comparison between the constitutional cores of different countries.
The arrangement of the principles belonging to the constitutional common core must satisfy the requirements of the essential core mentioned above: necessity, substantialness; indivisibility; dynamism.
Towards a cosmopolitan constitutional law
Dialogue among courts has been often discussed in recent studies of comparative law (L'Heureux-Dubé 1998; Slaughter 2003; Berman 2004; Hirschl 2004; Markesinis and Fedtke 2006).
The basis of dialogue among courts is the core of constitutional principles common to western constitutional systems. So, this dialogue is not a cultural process; rather, it is a legal process based on respect for fundamental constitutional principles.
Western countries share the same fundamental constitutional principles. Constitutional systems aim to protect fundamental rights and constitutional principles provide solutions to questions related to the safeguard of fundamental rights. As these principles can be applied in different ways, the solutions found by a particular national court will not always the best ones. So, the inter-court dialogue helps national courts find the best solution.
The presence of the foreign guest worker provides a useful occasion for the development of inter-court dialogue. He can draw from pertinent arguments to discover a new or better solution deriving from common constitutional law, though the dialogue could develop in spite of the absence of this external element.
The Kantian ius cosmopoliticum is the theoretical frame in which the legal basis of the dialogue among courts can be put (Kant 1795).
Ackerman, B.A. (2000), "The New Separation of Powers," 113 Harvard Law Review, pp. 633-729.
Amann, D.M. (2004), "'Raise the Flag and Let it Talk': On the Use of External Norms in Constitutional Decision Making", 2 International Journal of Constitutional Law, pp. 597-610.
Beatty, D.M. (1995), Constitutional Law in Theory and in Practice, University of Toronto, Toronto.
Berman, P.S. (2004), "Judges as Cosmopolitan Transnational Actors," 12 Tulsa Journal of Comparative and International Law, pp. 101-121.
Hirschl, R. (2004), Towards Juristocracy: The Origins and Consequences of New Constitutionalism, Harvard University Press, Cambridge (Mass.).
Jackson, V.C. (2005), "Constitutional Comparisons: Convergence, Resistance, Engagement", 119 Harvard Law Review, pp. 109-128.
Kant, I. (1795), "Perpetual Peace: A Philosophical Sketch," in Reiss, H. (ed.). Kant: Political Writings, Cambridge University Press, Cambridge, [1991].
L'Heureux-Dubé, C. (1998), "The Importance of Dialogue: Globalization and the International Impact of the Rehnquist Court", 34 Tulsa Law Journal, pp. 15-40.
Markesinis, B. – Fedtke, J. (2006), Judicial Recourse to Foreign Law: A New Source of Inspiration?, UCL Press, London.
Slaughter, A.-M. (2003), "A Global Community of Courts", 44 Harvard International Law Journal, pp. 191-219.
February 4, 2016 | Permalink | Comments (0)
Monday, January 18, 2016
Keeping an Arm's Length
In the aftermath of Cologne, Germany's New Year's Eve festivities, close to 500 women have little to cheer about. That is the number of women who have come forward to the police and reported that they were victimized by sexual violence that night. Many women were forced to run a gauntlet through "masses of heavily intoxicated men." Women victimized because the police force that was deployed that night was understaffed and overwhelmed and could not stop the mob violence against women. Incredulously, the police department originally reported that "the night had passed off peaceably."
One would think that reporters would have been all over this story from the start. Yet it took the German public broadcasting channel, ZDF, four days to report on the event. Given that many of the attackers were described as having a "North African background," some politicians on the right have accused the government of trying to suppress the reports in order not to stoke anti-immigrant violence.
While anti-immigrant violence is a definite concern, German attitudes towards rape are a concern as well. In the wake of the mass sexual assaults the city's mayor, is quoted as saying:
There's always the possibility of keeping a certain distance of more than an arm's length—that is to say to make sure yourself you don't look to be too close to people who are not known to you, and to whom you don't have a trusting relationship.
No the mayor is not a conservative, white male, politician, but a woman-Henriette Reker. Sadly, her views dovetail with many German citizens' indifference to sexual crimes against women in general. Indeed, German commentator Sasha Lobo has gone so far as to write that "the majority of the German public cares so shockingly little about sexual violence -- unless it is committed by "men with a North African or Arab appearance."
While there are close to 500 victims of the Cologne assaults, only one perpetrator is currently in custody on sexual assault charges. Even if more perpetrators are arrested, Germany's current rape laws are not helpful to rape victims. It is not enough for a victim to have said "no." The court must find that the perpetrator used violence, threatened life or limb, or coerced the victim. The structure of the law requires women not just to refuse to consent, but to forcibly resist. A German association of rape crisis organizations and counseling centers, organization, the BFF, "has documented over a hundred cases where attackers escaped sexual assault convictions because of this loophole."
Despite the fact that in 2011, the Council of Europe enacted the Istanbul Convention which states that any "non-consensual" sexual act must be criminalized, Germany has dragged its feet on updating its rape laws.
Unfortunately, the German government has not just left German women unprotected, but female refugees as well. Last August, four social work organizations and women's rights groups, addressed a letter to Minister of Integration and Social Affairs in the state of Hesse. The letter flagged conditions at the refugee reception center in Giessen and stated:
"It is a fact that women and children are unprotected. This situation is opportune to those men who already regard women as their inferior and treat unaccompanied women as "fair game". As a consequence, there are reports of numerous rapes, sexual assaults and increasingly of forced prostitution. These are not isolated incidents."
If there is a silver lining to this incident it is that Germany may finally update its rape laws. A bill that redefines rape has the support of the Chancellor and is now making its way through the system. Still, simply changing the law will not keep perpetrators at arm's length.
Krishnadev Calamur, "The Fallout from the Reports of Sexual Assault in Cologne," The Atlantic, January 6, 2016.
"Cologne Assaults: Police Report Outlines 'Chaotic and Shameful' New Year's Eve," Spiegel Online, January 7, 2016.
Kate Connelly, "Tensions Rise in Germany Over Handling of Mass Sexual Assaults in Cologne," The Guardian, January 7, 2016.
Ben Knight, "Germany Set to Finally Update its Rape Law," Deutsche Welle, January 8, 2016.
Sascha Lobo, "Mobs and Counter-Mobs: Pitfalls, Prejudice and the Cologne Sexual Assaults," Spiegel Online, January 8, 2016.
Situation der Flüchtlingsfrauen in der Hessischen Erstaufnahmeeinrichtung und deren Außenstellen
January 18, 2016 | Permalink | Comments (0)
Friday, January 15, 2016
Thinking Out Loud on Comparative IP Law - Israel's Proposed New Industrial Design Law
After spending an extremely enjoyable part of last week at The Many Faces of Innovation conference, hosted jointly by Bar-Ilan University and Ono Academic College in Israel (http://www.ono.ac.il/37235/), I started to reflect on the question, Is there really is any such thing as "comparative intellectual property law" anymore?
I've pondered the question off and on for a while now, but a comment made by Prof. Marty Adelman (Geo. Wash. Univ. Law) at the conference seemed directly on point. In chairing one of the panels, Prof. Adelman observed that a number of us had failed to specify exactly which nation's IP laws were the focus of our conference papers. His observation was a valid one, as we were an international group, but most of us considered our work to apply to multiple jurisdictions. After all, so much of intellectual property law has been harmonized due to both globalization and international treaties and agreements such as TRIPS and the Berne Convention. Is there – and should there be – any real remaining differences between countries to compare?
The answer is, of course, yes. Most commentators, for example, seem to agree that developing economies need different approaches to IP than do developed countries, the TRIPS agreement notwithstanding. But even among developed countries, variations in government taxation on or support for intellectual property or additions to international minimum protection standards are widespread. This latter point in particular was brought home in a presentation on Israel's proposed new industrial design law by Asa Kling, Commissioner of Patents at the Israel Patent Office. Protection for industrial designs covers things such as the shape, color, configuration, pattern, or other aesthetic elements of what would otherwise be purely utilitarian articles. In the U.S., industrial designs can be protected under both copyright and design patents, although neither are a seen as particularly satisfactory. Israel's proposed industrial design law will be a replacement for its current Patents and Designs Ordinance, which dates back to 1924 and is ill-suited to address modern industrial designs such as GUIs, computer icons, and so on. Part of the Israel Patent Office's intent in drafting the proposed law is also to prepare for accession to the Hague Agreement Concerning the International Deposit of Industrial Designs, which, like many of the international intellectual property agreements, sets some minimum baselines for protection but leaves up to its respective signatories many other details, including duration and formalities.
And not surprisingly, it is in these details that we can see plenty of fodder for comparative analysis. Both the United States and Japan acceded to the Hague Agreement in 2015, for example, but in doing so the U.S. changed its design patent term from fourteen years to fifteen years whereas Japan had already changed its design patent term from fifteen to twenty years back in 2008. The European Union, by contrast, not only grants registered industrial designs protection for twenty-five years but also grants protection to unregistered designs, albeit much more limited in scope and only for three years. In its proposed law, Israel has opted to follow the E.U.'s example, changing Israel's protection for registered designs from fifteen to twenty-five years and providing three years of protection for unregistered designs.
There are many other significant provisions in the proposed bill as well as differences from other jurisdictions, of course, but the bill is a good example of the diversity still remaining among IP laws. This diversity is undoubtedly a good thing: despite globalization, culture, economics, governmental intervention, and a variety of other factors relevant to IP still vary as well.
January 15, 2016 | Permalink | Comments (0)
Tuesday, December 22, 2015
CALL FOR PAPERS: Cambridge Journal of International and Comparative Law
The editors of the Cambridge Journal of International and Comparative Law (CJICL) welcome submissions for the CJICL 5th Annual Conference to be held at the University of Cambridge on 8-9 April 2016. Accepted papers will be considered for publication in a special issue of the Cambridge Journal of International and Comparative Law. Abstracts should be submitted on the basis that the subsequent paper will be available for publication if selected.
"Public and Private Power"
The theme for the CJICL 5th Annual Conference is "Public and Private Power". We are interested in doctrinal, theoretical, institutional and comparative perspectives from international, European and comparative law on the regulation of public and private power.
We are interested in exploring how the landscape of public and private power is changing, where new and important networks and partnerships between public and private power are emerging and where public power is co-opting or commissioning private power in larger projects. This interconnectivity can be seen at all levels, challenges traditional divisions between public and private, and raises new problems for regulation.
How is public and private power understood at the international, European and national levels? How should public and private power be allocated between and within the international, European and national levels? What new controls are necessary or desirable for existing or emerging areas of public and private power? What is distinctive about public and private power? How important is the distinction between public and private power? Is the distinction sustainable in different areas of regulation? How is the relationship between public and private power changing?
We are particularly interested in international, comparative and EU perspectives on the following topics:
- the distinctiveness of public or private power;
- the changing structure of the public-private divide;
- the value of distinguishing between public and private power;
- the allocation of public and private power; and
- the control of public and private power.
Applications should be submitted to firstname.lastname@example.com by 10 January 2016. Applications should include a proposed abstract of not more than 300 words and a CV and applicants should expect to hear from the convenors by the end of January.
General registration for the conference will open in February 2015 http://cjicl.org.uk. Numbers are limited and early registration is highly recommended. Attendees are responsible for their own travel expenses and accommodation and should seek funding from their home institution or other bodies. The convenors can arrange a limited amount of accommodation at Emmanuel College at the attendee's expense. The conference fee will be confirmed in January and there will be a limited number of fee waivers or reductions at the discretion of the convenors in cases of financial hardship. The conference is aimed at both academic and professional attendees and will be CPD accredited
December 22, 2015 | Permalink | Comments (0)
Monday, December 21, 2015
New Papers in Comparative Law
This month we highlight two new Comparative Law Papers on SSRN:
To start, Martin Oyhanarte of the Universidad Austral in Argentina and the Universidad del Salvador has posted an article entitled, "Public Law Litigation in the U.S. and in Argentina: Lessons from a Comparative Study." From the abstract:
"This article provides a comparative study of Public Law Litigation and the use of structural remedies in the United States and in Argentina. The case of Argentina is interesting because it is one of the few countries with strong-form judicial review that has implemented this kind of litigation. The experiences in both countries reveal disparate results. Evidence suggests that sustained impact depends on certain political conditions and technical requirements. The article describes these conditions and requirements, fitting them into a model. The model may prove useful to assess the implementation of complex procedural devices under different legal environments. Further, it suggests possible courses of action to judges, legislators, or legal activists seeking to promote structural reform."
Our second paper is from T.J. McIntyre of the UCD Sutherland School of Law, who has posted a forthcoming book chapter entitled, "Judicial Oversight of Surveillance: The Case of Ireland in Comparative Perspective." From the abstract:
"This chapter examines how judicial oversight can regulate state surveillance, with a particular focus on Irish, European Convention on Human Rights (ECHR) and European Union (EU) law.
It begins by considering the general arguments for judicial oversight and the types of oversight structures which can be used, from ex ante authorisation to ex post review and the variants in between.
It then examines the extent to which Irish, ECHR and EU law require judicial oversight in particular circumstances - particularly in light of the landmark decision of the Court of Justice in Digital Rights Ireland v. Minister for Communications invalidating the Data Retention Directive.
Next, it takes as a case study the Irish experience of data retention and discusses how judicial oversight of data retention has operated and why it has failed to secure the rights of the individual.
It concludes with suggestions for improving the effectiveness of judicial oversight surveillance."
December 21, 2015 | Permalink | Comments (0)
Friday, December 4, 2015
Pistorius III - The Appeal
In prior blogs (here and here) we discussed both the trial of Oscar Pistorius, in South Africa, for the death of his girlfriend, and then the verdict, which found Pistorius guilty of culpable homicide, that is, what we in the United States would call manslaughter, but not guilty of murder. We commented, among other things, about the experience of seeing a single judge rendering a verdict (in which two invisible lay assessors joined), and of hearing a detailed statement of reasons – two experiences we rarely (as to the first) or never (as to the second) have in the United States. This week, the Supreme Court of Appeal in South Africa entertained the prosecution's appeal from that verdict and reversed it. The court convicted Pistorius of murder instead: a third unheard phenomenon in the US criminal justice system.
The appellate court held that the trial court had incorrectly applied the doctrine of dolus eventualis, which supports a murder conviction based, in essence, on recklessness, by concluding that because the defendant did not know who he was shooting at (error in objecto), he could not have understood that death was likely to follow. The court explained that "the accused's incorrect appreciation as to who was in the cubicle [in which he fired the fatal shots] is not determinative of whether he had the requisite criminal intent." The court also held that the trial court had incorrectly applied the law on circumstantial evidence by ignoring some of the relevant evidence.
As the Supreme Court of Appeal noted in the opening sentence of its opinion, "[t]his case involves a human tragedy of Shakespearean proportions;…".
Related Readings:
- Lissa Griffin, South Africa: Reflections on the Pistorius Trial, Comparative Law Prof Blog (Apr. 10, 2014).
- Lissa Griffin, The Pistorius Verdict, Comparative Law Prof Blog (Sept. 12, 2014).
- Director of Public Prosecutions, Gauteng v. Pistorius (96/2015) [2015] ZASCA 204 (3 Dec. 2015) (S. Afr.) (Court's PDF).
December 4, 2015 | Permalink | Comments (0)
Wednesday, November 25, 2015
Call for Papers: "Fundamental rights protection in Europe: theory and practice"
This conference aims to explore the features and the challenges of the fundamental rights protection system in Europe. The first day of the conference will feature keynote speakers such as Prof. Bruno De Witte, Prof. Morten Kjaerum, Prof. Federico Fabbrini, Prof. Cormac Mac Amhlaigh and Prof. Michael Addo.
The second day of the conference, after the keynote speech of Prof. Matej Avbelj, will be dedicated to the presentation of papers selected through this call.
The Convenors invite submissions from scholars in Comparative Public law, European law, International law at all levels. Submissions may address one or more of the following subjects:
1. Theory of fundamental rights
2. Pluralism within the European system of fundamental rights protection
3. The role of the judiciary in fundamental rights protection
4. The role of international/supranational agencies
5. The challenges of fundamental rights protection after the Eurozone-crisis
6. Social rights protection within the EU
7. Comparisons between the European fundamental rights protection system and other non-European experiences
Submission Instructions
Interested scholars should email no more than one (1) abstract of max. 500 words by December 10, 2015 to the following address: email@example.com
Successful applicants will be notified no later than December 30, 2015.
There is no cost to participate in the workshop. Successful applicants are responsible for securing their own funding for travel, lodging and other incidental expenses.
November 25, 2015 | Permalink | Comments (0)
Sunday, November 15, 2015
Legal Transfers as Processes of Cultural Translation: On the Consequences of a Metaphor
Lena Foljanty, Max Planck Institute for European Legal History, recently posted this interesting article on SSRN.
From the abstract:
November 15, 2015 | Permalink | Comments (0)
Monday, November 2, 2015
CALL FOR PAPERS: Irish Society of Comparative Law
The Irish Society of Comparative Law (ISCL) and the School of Law of the NUI Galway together with the Irish Centre for Human Rights are pleased to announce the seventh annual conference of the ISCL to be held in Galway on 23-24 May 2016. The keynote speaker will be Prof Mark Tushnet of Harvard Law School.
Theme: In an increasingly interconnected world, where geographies of protection are premised on the centrality of national territory and state sovereignty, the importance of being cognisant of the concept of location/geography/space/place in the comparative law arena, cannot be underestimated.
Does comparative law continue to contrast the laws of states, or is there now, a new focus? What effect does this have on the diversity inherent in plural legal systems? How are different types of laws (state/customary/indigenous/international) (dis/re)located? How does this (dis)location impact our analysis of these laws, including any effort at being a 'comparativist'? What does this mean for places of transience not holding enough significance to be regarded as legal places? This conference questions traditional narratives of comparative law, in the context of the increasing complexity of legal orders within, between and beyond states.
The conference aims to encourage theoretical and empirical interdisciplinary reflection on comparative law and space/place, to explore why location matters, and ensure cognisance of the sensitivities of location in comparative law. However, any comparative topic may be proposed, eg private law, criminal law and criminal justice, public or constitutional law, legal education, etc. In addition, proposals on European or International law will also be considered.
The deadline for receipt of proposals is Monday, 29 February 2016. Proposals by both members and non-members, as well as by professional academics and graduate students are welcome.
Proposals should be maximum 500 words in length and be sent to firstname.lastname@example.com. The conference fee will be €60 for members of the ISCL and €120 for non-members (membership fees are €60, student membership is free). The ISCL regrets that it cannot cover travel or accommodation expenses. All additional information about the conference (including a special Conference group rate in local hotels) will be posted in due course at http://www.conference.ie/Conferences/index.asp?Conference=218
November 2, 2015 | Permalink | Comments (0)
Thursday, October 22, 2015
Supreme Court Fellows Program
We are promoting the Supreme Court Fellows Program on the Comparative Law Blog this year because the program offers a placement in the Office of the Counselor for the Chief Justice that is particularly appropriate for comparative law scholars as well as current judicial clerks who may wish to pursue a career in the field of comparative law.
October 22, 2015 | Permalink | Comments (0)
Sunday, October 18, 2015
Bicameralism under Pressure: Constitutional Reform of National Legislatures
Conference Announcement: May 2nd and 3rd, 2016 (Rome, Italy)
The Center for Parliamentary Studies, LUISS Guido Carli University of Rome in cooperation with The University of Milan, Department of National and Supranational Public Law; The International Society of Public Law (ICON-S); and The Younger Comparativists Committee (YCC), American Society of Comparative Law
Subject-Matter of Symposium
We can trace the institutional evolution of bicameralism from ancient Greece and Rome, to Medieval Europe and the emergence of the House of Lords in fourteenth century, in the intellectual debates triggered by the French Revolution and the design of the United States Constitution, to the reflections in Alexis de Tocqueville's Souvenirs, through the present day. Bicameralism is today a common feature of constitutional democracy. At its best, bicameralism diversifies democratic representation, strengthens representative government, promotes legislative deliberation, and reinforces the separation of powers. Yet bicameralism has often failed either to fulfil its intended purposes or to keep pace with the evolution of constitutional democracy. Many constitutional states, for instance Canada, Ireland, Romania and the United Kingdom, have sought to revise their bicameral arrangements only to confront significant legal or political barriers to change. Only relatively few reforms have succeeded. This Symposium will inquire why. Drawing from country-specific and cross-national experiences with bicameralism, scholars in this Symposium will bring to bear comparative, doctrinal, historical, legal and theoretical perspectives to the study of constitutional reform of national legislatures.
This Symposium will devote one session to constitutional reform in Italy. Bicameralism in Italy has been a matter of controversy since the drafting of the Constitution in 1946-47. Both chambers in Italy are co-equal in the most important ways: they are directly elected, they exercise the same legislative powers, and they possess the same confidence relationship with the executive branch. Yet bicameralism in Italy has been the object of several failed reform efforts both to overcome the challenges of perfect bicameralism and its degeneration, as well as to guarantee a representation of local and regional authorities as the country moves toward greater regionalization. Italy is currently undertaking a major constitutional reform to its bicameral arrangements.
These and other developments raise important questions for constitutionalism. How should a legislature be structured, and what values—democracy, representation, efficiency, deliberation— should its design prioritize? Does bicameralism still fit the times in light of the globalization and Europeanisation of public policies, the increasing dominance of judicial and executive actors, mounting calls for greater devolution of legislative powers to subnational levels of government and the multiplication of levels of government? When and under what conditions is a bicameral arrangement to be preferred over a unicameral one? How can second chambers best perform their functions.
These questions, in particular with respect to Canada in comparative perspective, were the focus of the master's dissertation written by Gabriella Angiulli, a dear friend and colleague to whom this Symposium is dedicated. Gabriella Angiulli passed away in March 2013. She was a doctoral student at the University of Siena and a Teaching Assistant at LUISS Guido Carli University, where she earned her master's degree cum laude in Comparative Public Law in 2008 under the supervision of Prof. Carmela Decaro. The first conference held in her memory in 2014 explored "The preliminary reference to the Court of Justice of the European Union by Constitutional Courts." This second scholarly program will foster academic debate and collaboration on another important line of inquiry in contemporary constitutional law—on questions that formed the subject of Gabriella Angiulli's research when she was embarking on her promising academic career.
Structure of Symposium
The first day of the conference, Monday May 2, 2016, will be held entirely in English and will feature three panels each with two presenters. The second day of the conference, Tuesday, May 3, 2016, will be held in partly in English and Italian. There will be one roundtable in Italian focused on the constitutional reform of bicameralism in Italy, and two panels in English each with two presenters.
The Symposium will feature a keynote presentation by Professor John Uhr (Australian National University), one of the leading scholars in the study and design of bicameral legislatures.
Possible Subjects for Paper Proposals
The Convenors invite submissions from scholars in comparative public law at all levels, from doctoral candidates to senior professors. Submissions may address one or more of the following subjects from national, comparative, or European perspectives:
1. Constitutional history of bicameralism
2. Bicameralism in historical perspective
3. Bicameralism in constitution-making
4. Overcoming challenges and stalemate in bicameral and unicameral systems
5. Bicameralism in federal systems and in federalizing processes
6. Bicameralism, ICT revolution and open government
7. Bicameralism, representative democracy and minorities
8. Bicameralism and electoral systems
9. Bicameralism, the separation of powers and forms of governments
10. Bicameralism and lawmaking
11. Bicameralism and parliamentary oversight
12. Bicameralism in the framework of the European Union: intra- and inter-State dynamics
To Submit an Abstract
Interested scholars are invited to submit a CV and an abstract no longer than 500 words by
November 30, 2015 to
email@example.com. Applicants will be notified by December 30, 2015. Full drafts of papers will be due by email to firstname.lastname@example.com no later than April 1, 2016. Papers should be no longer than 10,000 words (footnotes included).
Papers presented at the conference will be published subject to successful blind peer-review. The remaining papers may be considered for publication in the LUISS School of Government Working Paper Series:
There is no cost to participate in the conference. The Convenors will provide meals and accommodations (for up to two nights) to presenters. Presenters are responsible for their own travel and incidental expenses.
For additional information, please contact Cristina Fasone at firstname.lastname@example.com.
October 18, 2015 | Permalink | Comments (0)


text:
This is the April 23, 2013 news archive. View today's AL Central rumors and news.
AL Central
AL Central News and Rumors
Parolee with White Sox tattoo accused of shooting in Wrigleyville robbery attemptyahoo.com Apr 23, 2013Chicago, Ill., hello! North Side, South Side. Chicago Cubs, Chicago White Sox. Sometimes, they meet. And it ain't pretty when they do. That allegedly was the case over the weekend, the Chicago Tribune and others have reported, when: A parolee shot anoth…Share Tweet
Valverde returns to closer role with DetroitSix months after the Tigers bid farewell to Jose Valverde, they welcomed him back Tuesday, signing him to a one-year Major League contract. If they take a lead into the ninth inning Wednesday night, he'll try to close out a win.Share Tweet
Marson likely to be activated off DL on WednesdayBackup catcher Lou Marson was back with the Indians on Tuesday, feeling better and itching to get back on the field.Share Tweet
Arcia's 1st career HR backs Correia, TwinsOswaldo Arcia hit his first career home run and Kevin Correia gave up two runs in seven innings, leading the Minnesota Twins over the Miami Marlins 4-3 Tuesday in the opener of a day-night doubleheader.Share Tweet
Tigers put Dotel on disabled list, recall RondonBruce Rondon is in the major leagues. Now the hard-throwing right-hander will try to earn a consistent role in the Detroit bullpen.Share Tweet
Rain washes out Indians-White Sox tiltA few hours before the scheduled first pitch, Tuesday's game between the White Sox and Indians was postponed due to persistent rain in Chicago. A makeup date has yet to be announced and the teams will play just one game on Wednesday before the Tribe hit…Share Tweet
Prospect Phegley offers value on both sides of the ballThere is certainly reason for optimism regarding White Sox catching prospect Josh Phegley.Share Tweet
Fernandez, Correia match up in twin bill openerWintry weather forced the postponement of Monday night's two-game Interleague series opener between the Twins and Marlins, so they will play a split doubleheader on Tuesday. Miami's Jose Fernandez will oppose Minnesota's Kevin Correia in the opener.Share Tweet
Asdrubal rallies Tribe, Masterson past White SoxAsdrbual Cabrera's two-out, two-run single in the eighth inning rallied the Indians to a 3-2 victory in the series opener at U.S. Cellular Field. Right-hander Justin Masterson moved to 4-1 and earned his second victory over the White Sox with seven stro…Share Tweet
Twins Edge Marlins To Take Game 1Apr 23Oswaldo Arcia hit his first career home run to lead Minnesota past Miami 4-3 in the opener of a day-night doubleheader.
Mint Condition: Veteran Receives Rookie CardApr 23Purple Heart recipient Daniel "Doc" Jacobs joins Michele Steele to discuss his Upper Deck trading card and his tryout with the Dodgers.
Dunn's Struggles ContinueApr 23Aaron Boone and Alex Cora discuss what's wrong with Adam Dunn and what he can provide to the White Sox's lineup when he gets back on track.

subset: commoncrawl


text:
"Save America's Treasures" has been totally eliminated—the largest Federal program supporting preservation of such treasures as the original Star Spangled Banner and George Washington's tent.
65% of Americans don't know what happened at the Constitutional Convention, according to a recent survey by Newsweek.
The "Teaching American History" grants—the largest Federal program supporting history education—have been completely eliminated.
Visits to the Top 20 Civil War battlefields have dropped in half from 1970 to 2009 according to official National Park Service statistics.
40% of Americans can't identify whom we fought in World War II, according to a recent survey by Newsweek.
A quarter of Americans believe Congress shares power over U.S. foreign policy with the United Nations, according to a recent Annenberg survey.
"There is little that is more important for an American citizen to know than the history and traditions of his country," John F. Kennedy wrote in American Heritage.
The "We the People Program," which touched some 30 million students and 90,000 teachers over 25 years, has been completely eliminated.
Two-thirds of Americans could not correctly name Yorktown as the last major military action of the American Revolution, according to a recent national Gallup survey.
The National Heritage Areas and Scenic Byways program, the only major Federal program encouraging visits to historic places, has been completely eliminated in Congressional committee.
The country's financial hub has a long history of lying, cheating, and stealing
No one likes recessions, but no one dislikes them more than the crooks who are an inevitable part of any financial market.
As the economy goes south, companies seeking to cut costs scrutinize their books more carefully and bring embezzlements to light. Investors take money out of higher-earning (and therefore inherently more risky) funds and put them into safer ones, and Ponzi schemes collapse as a result. Credit becomes tighter, and loan requests are more carefully investigated, so businesses with cooked books find their insolvency revealed. Read more »
After one Ford changed America, another accomplished something almost as amazing
I've always thought that one of the saddest words in the English language is has-been . While it has a modern ring—perhaps because the movies and television have produced so many stars who've enjoyed, in Andy Warhol's famous phrase, 15 minutes of fame—the phrase actually was first recorded in 1606, when London's Globe Theatre was the pinnacle of show business. Of course, there are has-beens to be found far from the stage.
A critic looks at 10 movies that show how Americans work together.
If the business of business is business, then it's the business of Hollywood to be skeptical. At least about business. Virtually from the beginning, the movies have seen American business as an object of farce or satire at best or some vaguely defined evil at worst. From more than eight decades of filmmaking, one is hard put to name a handful of films that portray businessmen in a heroic or even nonpredatory way. One might suspect Hollywood of an antibusiness bias if not for the fact that the film industry's view of labor is even darker.
How women entrepreneurs reshaped the American economic landscape in the wake of WWII.
When the National Foundation of Women Business Owners announced in May 1999 that women own nearly 40 percent of the nation's businesses, there was little fanfare or surprise. Americans have become increasingly accustomed to female entrepreneurs as an economic force. Since 1987, the number of women-owned small businesses has more than doubled, to 9.1 million firms generating $3.6 trillion in annual sales. Read more »
A student of an underappreciated literary genre selects some books that may change the way you see what you do.
It has always struck me that the best business novels are interactive. In them, the world of commerce is driven by people whose reality is made palpable to us but whose values, attitudes, and biases often compel us to question our own: As a businessperson, how would I relate to the kind of complex, unpredictable circumstances in which all-too-real fictional characters commonly find themselves?Read more »
A sampling of the wisdom of Americans from Ben Franklin to Cameron Crowe
All the perplexities, confusions, and distresses in America arise… from downright ignorance of the nature of coin, credit, and circulation. —John Adams, letter to Thomas Jefferson, August 25, 1787
Nothing but money is sweeter than honey. —Benjamin Franklin, Poor Richard's Almanac, 1735
… or why in America campaign-finance reform never succeeds
In the summer of 1787 a sweaty group of politicians was debating the clauses of a proposed constitution in humid Philadelphia. Endless problems reared their ugly heads: the distribution of power between large states and small states; slavery; the size of a standing army; the powers of the Presidency. The framers solved—or postponed—most of these dilemmas with their famous genius for compromise. But one quandary was solved differently. Read more »
THE VIDEO GAME turns twenty-five this year, and it has packed a whole lot of history into a mere quarter-century
In 1962 an M.I.T. student named Steven Russell pulled off the ultimate hack. Russell was the kind of kid people make jokes about: short, full of nervous energy, passionately devoted to B-grade science fiction, shy, and brilliant. He worked with the Tech Model Railroad Club, a campus organization that had recently begun turning its focus from toy trains to computers. TMRC members had their own vocabulary. Read more »
…and grow, and grow, from almost no employees to three million. Don't blame the welfare state, or the military; the truth is much more interesting.
The tradition of distrusting government—almost any government—has such deep roots in the American past that a newcomer could justifiably think of the United States as a nation of a quarter of a billion near-anarchists. After all, it was Tom Paine, a major voice of the American Revolution, who declared that "government, even in its best state, is but a necessary evil; in its worst state, an intolerable one." Is Paine too radical for you? Read more »
THE IMPERIUM OF modern television advertising was born in desperate improvisation
It was 1945, and everybody needed everything. If you knew how to build a car, a house, or a washing machine, you could sell it faster than you could make it. Car dealers, including fine old names that soon would be history—Hudson, Nash, Packard, and Studebaker—all had long waiting lists. Many dealers bluntly Quoted not the price of the car but the price of getting on their waiting lists. Read more »
© Copyright 1949-2016 American Heritage Publishing. All Rights Reserved.


text:
Category:High Legh
From Wikimedia Commons, the free media repository
English: High Legh is a village and civil parish in the unitary authority of Cheshire East and the ceremonial county of Cheshire, England. It lies six miles north west of Knutsford, seven miles east of Warrington and seventeen miles south west of Manchester City Centre.
This category has the following 2 subcategories, out of 2 total.
- ► St John's Church, High Legh (2 F)
Media in category "High Legh"
The following 39 files are in this category, out of 39 total.
- Routemaster (6159191837).jpg 5.23 MB
- Routemaster (6159196093).jpg 5.4 MB


text:
Is this restaurant good for special occasions?
Does this restaurant offer highchairs for toddlers?
Is this restaurant good for local cuisine?
Is this restaurant good for business meetings?
Is this restaurant good for lunch?
Is this restaurant good for dinner?
Is this a seafood restaurant?
Is this restaurant good for breakfast?
Can a gluten free person get a good meal at this restaurant?
Is this restaurant good for brunch?
Thanks for helping!
This restaurant has been consistently good for a number of years and offers good service along with good local food - and the view is hard to beat.
Great lobster dinners here. In a nice location close to sonic walks and shopping. For lobster suppers this is a great choice.
We spent two nights right beside Lobster Alley at St Anns Motel and wish we had enjoyed dinner there as planned. Twice we had reservations and both times, we found ourselves too far from the restaurant after exploring the Cabot Trail. The staff at Lobster Alley were friendly enough to make our reservations and even handed us a menu that...
Perhaps our mistake was going to a lobster shack and not getting lobster or seafood. So take this review with that in mind.
We had a lakeside table at sunset, and it was a gorgeous view. Go a little early so you can have a table by the windows.
An earlier review here raved about the burger they got, so...
Brenda was a little stiff initially then wow things blossomed and i had a great 2 pound lobster meal with Shiraz. That rum cake desert is a real fund too. Thanks to Brenda and The Lobster Galley. Hope to see you again, eh?
Friendly staff, great service, wonderful seaside views and mouth-watering food!
Homemade Caesar dressing on the salad is extra tasty. Of course, you have to try to chowder! Enjoyed it so much that we went two nights in a row!
Met the owner, Jeanine, who was very personable and genuine. Great business and location as you are entering or leaving the...
My friends and I visited this restaurant in mid-July for an evening meal. We started with an appetizer of mussels and enjoyed salmon or pan-fried haddock or fish and chips.All were excellent as well as the home made desserts of cheesecake and the specialty rum cake.The restaurant is clean, reasonably priced with friendly service and the view at sunset is...
Great place to stop as you start the Cabot Trail Loop. The food is very good and the view over the water is beautiful. A little pricey but not outrageous. We didn't try the lobster but the platter with the scallops, mussels, haddock and clams was great.
This is not fine dining, it is good dining. A great location, friendly staff and with good food it ticks all the boxes.
We sought refuge there from a disappointing experience where we were staying and it didn't take long for Kathy, our server, to lift our spirits. The food was good value for the money and the setting next...
We had lobster and mussels for dinner. Cooked well. Great job. Love that it was next to St Anne's motel.
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Hello there. I have a rather strange request. A friend of mine and his buddies were hunting on Hunters Mountain and decided to come down from the mountain for supplies. While there, he stopped at a restaurant for some chowder. We believe it was your restaurant although we are not 100 % sure. They were 'rugged mountain men' in an old army jeep with moose horns attached to the front grill. While there, they were asked if they would pose with some Sou' Westers that a lady went and got for them to wear. They held their guns, topped with the sou westers and the old army jeep. Quite a picture for sure, lol. The men were told that these pictures would go in the restaurant or be made into postcards. We are uncertain of the year, but possibly it would have been mid September of 2012 or 2013. Would you or any of your wait staff happen to remember this? The reason I have this request, is one of those men passed on Friday, May 1, 2015 and we would love to get a copy of the pictures that were taken. Any help would be greatly appreciated and a copy of the pictures would be a treasure. Thanks so much for you time in this matter. My home phone is 902-875-1268 and ask for Shelley or Todd. Thanks again.
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9305 Stonewall Road
Manassas, Virginia, 20110
Commute to Downtown Manassas
Some errands can be accomplished on foot.
About your score
9305 Stonewall Road has a Walk Score of 57 out of 100. This location is Somewhat Walkable so some errands can be accomplished on foot.
This location is in Manassas. Nearby parks include Baldwin Park and Byrd Park.
Explore how far you can travel by car, bus, bike and foot from 9305 Stonewall Road.
Rail lines:
Manassas Line
0.6 mi
Car shares:
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Popular apartment searches include pool, fitness and fireplace.
Search for homes in Manassas or find a Manassas real estate agent who knows walkable neighborhoods. Links will open on our partner site Redfin.com.
This location is in the city of Manassas, VA. Manassas has an average Walk Score of 41 and has 37,821 residents.Learn More About Manassas


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Cost Innovation: Schumpeter And Equilibrium - Part 1: Robinson Crusoe
Modifying a parallel dynamic programming approach to a simple deterministic economy, the authors consider the effect of an innovation in the means of production. The success of the innovation is assumed to depend on the availability of financing, locus of financial control, the amount of resources invested, and on a random event. The relationship between money and physical assets is critical. In this first part, stress is laid on the innovation behavior of Robinson Crusoe in a premonetary economy, then on his actions in a monetary economy in partial equilibrium. Part 2 considers the closed monetary economy with several differentiated agents.
Provided by: Yale University Topic: Innovation Date Added: Mar 2011 Format: PDF


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The Dual Force Vac System is a convenient and versatile solution for liquid material handling and spill clean up. Using powerful Transvector technology, the Dual Force Vac Drum Pump can either fill or discharge a 55 gallon drum in under two minutes. It switches easily -- with a 1/4 turn of a knob -- from fill to discharge mode. And the Dual Force Vac can handle viscous liquids and particulates. Quiet and safe, the Dual Force Vac is air-powered with no moving parts, meaning no motor burn out and no shock hazard. It quickly installs on a 55 gallon drum and comes with a 10 foot hose and nozzle. An optional aluminum wand and squeegee are available to facilitate spill pick up.
(1) Do not operate the Dual Force Vac Drum Pump at less than 50 psig or more than 100psig (2) Flow rates are based on a liquid viscosity of 0.8 cPs
The Dual Force Vac Drum Pump operates in two modes: FILL mode and DISCHARGE mode; it fills or empties a 55 gallon drum in less than two minutes. It is ideal for cleaning up spills and sumps, even with viscous liquids and particulates; and for material handling. No motors to burn out and no shock hazards.


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Get the Channels You Want with XFINITY TV in Columbia City, IN
TV is more enjoyable when you get the cable package you want, and thanks to XFINITY from Comcast, you and other Columbia City residents get the programming you're looking for. XFINITY TV fits your schedule with digital cable channels, DVR recording and playback, and On Demand.
Most Columbia City residents view 35 hours of TV per week, and XFINITY TV ensures that these hours are filled with the most entertainment possible. XFINITY TV provides Columbia City sports fans with their favorite local cable channels. XFINITY TV specials bring you all your favorite channels so you always have the television shows and movies you love.


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Chicken & Black Bean Quesadillas
Total Time
Prep 30 mins
Cook 10 mins
This is a recipe I found on the Land O Lakes website, but I haven't had a chance to try it yet. Sounds amazing!
Ingredients Nutrition
- 236.59 ml shredded cooked chicken
- 158.51 ml sour cream
- 78.07 ml mayonnaise
- 59.14 ml sliced green onion
- 354.88 ml cheddar cheese, shredded
- 439.41 g can black beans, rinsed, drained
- 29.58 ml chopped green chilies, drained
- 12 (96 inch) flour tortillas
- 29.58 ml butter, melted
- Heat oven to 375°F Combine all quesadilla ingredients in large bowl except tortillas and butter.
- Spread about 1/4 cup filling on half of each tortilla; fold in half. Brush both sides of each tortilla with butter.
- Place filled tortillas onto ungreased baking sheets. Bake for 10 to 15 minutes or until heated through. Cut each quesadilla into 3 wedges. Serve with desired toppings.


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Europa League quarter-finals: Who Liverpool can face and whenThis Is Anfield on 17 March 2016
More: Europa League
Liverpool progressed to the Europa League quarter finals with a 3-1 aggregate win over Man United, here's who they can face in the last eight.
- Borussia Dortmund
- Athletic Bilbao
- Villareal
- Sparta Prague
- Shaktar Donetsk
- Sevilla
- Sporting Braga
The draw takes place tomorrow (Friday) in Nyon, with the two legs taking place on April 7th and 14th.
The draw starts at 12 noon (GMT). The This Is Anfield App will send a notification once the draw is made.
Fans Are Reading
Fan CommentsComments are retrospectively moderated. Some could be subject to delays before publication. They must obey the comment policy. Comments load below.
Please only discuss the article above. General chat can be made on our forums at forums.thisisanfield.com


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Missing Ashleigh Brook, Holmfirth
Sunday 31 January 2016
Police are appealing for information to help trace a missing vulnerable woman from Kirklees.
Ashleigh Brook, 21 was last seen at 11pm on Friday evening at her home address in Holmbridge, near Holmfirth.
It is out of character for Ashleigh to go missing and police are growing increasingly concerned for her welfare.
Ashleigh is described as a black female, 5" 8" tall of average build with short Afro hair, however she was wearing a shoulder-length black wig with a fringe when she was last seen. She was last seen wearing Minions design fleece pyjamas, a yellow top with a minion design on the front, and long bottoms that are royal blue with minion design all over them. Ashleigh was also wearing camouflage trainers and a camouflage coat carrying a black quilted handbag,
Anyone who has seen or heard from Ashleigh, or knows where she might be now is asked to contact police via 101.
For non-emergencies dial 101
In an emergency always dial 999


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Portside Resort
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How has this condo rated in the past?
- Suites
- Beach
- Free High-Speed Internet
- Swimming pool
- Kitchenette
- Free parking
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- Beach
- Swimming pool
- Free High-Speed Internet
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- Free parking
- Suites
TripAdvisor Reviews Portside Resort Panama City Beach
Travel Blogs from Panama City Beach
... to enjoy life because these moments don't come around twice. And in the end I had so many people complimenting on how I looked. After swimming we went out to dinner at a German restaurant. It was a cool atmosphere but I was just so tired after only having 3 hours sleep. So I was thankful when I got to bed by 10:30pm. I fell in love with Panama City Beach and I'm sad to leave ...
Panama City, Florida
... the bigger city of Tallahassee a skip, in favour of a small coastal city called Panama City (not to be confused with Panama the country). We left after lunch at about 1pm and made our way to a place we had no idea what to expect.
We arrived around 7pm and liked what we saw, a quiet town (population 72,000 so the city limits sign told us) with some great little pubs, restaurants and of course amazing beaches. That night we chose to stay ...
Second full day
The day started at breakfast. Rice Krispies believe it or not, nice English cereal! Had to be on the bus to leave New Orleans for 7.45am. Had to wait an hour on the bus as one girl had a few drinks the night before bless her and forgot her alarm but we found her in the end and got going. We then set off for Panama beach! Couple of hours later we stopped have way in Alabama!! Sweet ...
... right?) so was excited at the prospect. It was a touch disappointing in that we only caught one thing, and it wasn't a fish. I CAUGHT A TURTLE. And a big one at that. Snapping turtles like that can take a finger without hesitation, so he was let go ASAP! Turns out, we were fishing fresh water with saltwater bait so...not surprising! On last laze on the beach completed an incredible week in florida. New Orleans beckons, catch you all soon with an update! ...
Last day at topsail
... got to go do a little shopping. After that we did some laundry, man that piles up fast at beach stops! Dollar store proved useful for balloons, never a dull day with balloons! And ended the day with salmon on cedar plank. Oh wow. That's been mamas favorite so far, WAY ...


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How to Use GI and GL for Better Control
A little bit of knowledge and a pencil and paper are all you need to make use of these great tools.
By Chris Sparling
Learning how to use the glycemic index and glyemic load to help better manage your blood sugar is easier than you may think — and it may well be worth your while. Plenty of research has indicated that low-glycemic-load eating can contribute to reducing health risks, and not only for people with diabetes. The first step is to understand what these two terms mean.
• The Glycemic Index (GI) is a measure of the effects of carbohydrates on blood glucose levels. Carbohydrates that break down quickly during digestion, releasing glucose rapidly into the bloodstream (like those found in white bread), have a "high GI" (70 or higher); carbohydrates that break down slowly, releasing glucose gradually into the bloodstream (like those in whole grains and legumes), have a "low GI" (55 or lower).
• The Glycemic Load (GL) is a ranking system for the glycemic impact of foods, based on their carbohydrate content, portion size, and Glycemic Index. Low = 1 to 10; Medium = 11-19; High = 20 or higher.*
As explained in the book The New Glucose Revolution for Diabetes (Marlowe, 2007), the GL was developed by Harvard researchers, who posited that eating a small amount of a high-GI food would have the same effect on blood sugar as would eating large amounts of a low-GI food. Another issue with looking only at the GI of a food is that it's tied to the number of grams of carbohydrates in that food and, obviously, that number varies by large amounts. Watermelon is a good illustration of this problem. Watermelon's GI is high, 72. The GI, however, is based not on a normal portion, but on 50g of carbohydrates — whatever the food . To get 50g of watermelon carbs, you'd have to eat almost 5 cups. GL combines both the quality and the quantity of the actual carbohydrates consumed — and provides one "number." The GL of one cup of watermelon is about 9, which is low.
This leads us to our next step: understanding the math.
Not to worry, we're not talking about advanced algebraic equations; rather, the formula for calculating GL requires only some basic multiplication and division.
GL = (GI x the amount of carbohydrate) divided by 100.
Using an apple as an example, let's input the fruit's GI score of 38 and its 13 grams of carbohydrates into the equation and see what the resulting GL turns out to be.
GL = (38 x 13) / 100
GL of an apple = 5
Easy enough, right? Well then, how about we try something a bit starchier, like a baked potato (GI = 85; Total Carbs = 14)?
GL = (85 x 14) / 100
GL of a baked potato = 12
Based on these simple calculations, we see that the potato will have twice the glycemic effect on blood sugar as the apple will. Knowing this can help you make better decisions toward keeping blood sugar steady — and reducing the chances of unexpected spikes.
So, GI or GL? The Answer is Both
To keep your blood sugar in a healthy range, the best strategy is to consume a lot of low-GI carbohydrates but watch your portion sizes and use the GL calculation as a reality check on your choices. And remember, these tools are for carbohydrate foods — grains, starches, legumes, fruits, and veggies. Other rules apply when making choices about proteins and fats, of course. And even if you master the GI and GL approach, remember that diabetes is very individual, and the only way to know how foods will truly affect your blood sugar levels is to test yourself.
For more information on GI and GL, check out these resources:
The Official Site of the Glycemic Index
Oregon State University's Linus Pauling Institute: Micronutrient Research for Optimum Health, "Glycemic Index and Glycemic Load"
NutritionData: Glycemic Index
* Glycemic load ranges, according to David Mendosa
Reviewed by Susan Weiner, RD, MS, CDE, CDN. 4/11
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Mushroom and Red Bell Pepper Pinwheels Carb Free Spiced Coffee Parsley Party Potatoes Shrimp Lettuce Wraps Sweet Potato Fries (Gluten Free) Mashed Black Beans Stewed Peas and Beans Chicken & Cola Herbed Vegetables Grilled Veggies
As I mentioned in an earlier post, one of the benefits that made it cost-effective for me to go with the real healthcare (HSA) plan rather than the phony (HRA) plan is that my company is now covering "preventative" medicines at $0 copay. The formulary for these, as stated by CVS/Caremark (my pharmacy benefits provider), covers all test strips, lancets, and control solutions. I dutifully get my doctor to write up prescriptions for all of my testing needs, submit...


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Noble Foundation Plant Image Gallery
This online gallery contains numerous images of plants native primarily to the Oklahoma-Texas region. The images are divided into three main categories: Grasses & grasslike plants; Forbs; and Trees, shrubs and woody vines. Within each section, users can browse by common name, scientific name, or tribe index. Entries include a medium-sized image with some smaller close-ups and information on species, family, tribe, longevity, season, origin, height, flowers and a brief description. Users can... More
Material Type: Collection
Technical Format: HTML/Text
Date Added to MERLOT: April 26, 2000
Date Modified in MERLOT: March 30, 2013
Submitter: Carol Schneebeck
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Discussion for Noble Foundation Plant Image Gallery
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3 years ago
Jim Bidlack (Faculty)
This is a great site with an extensive collection of plant images. Very reputable source (Noble Foundation) and well-done!
Time spent reviewing site: 5 minutes