text:
F. Scott Fitzgerald once wrote that "[t]here are no second acts in American lives."[i] Yet popular culture is replete with numerous instances of entertainers getting a second wind and pulling off seemingly improbable comebacks. In 1968, for example, Elvis Presley broke through a decade-long career malaise with a hit television special that reintroduced him to a generation of music fans that had long since discarded him for the Beatles and the Rolling Stones. Four years later, legendary filmmaker Charlie Chaplin briefly returned to the U.S. to claim an honorary Academy Award after spending twenty years in political exile. Even 1960s icon Cher made an unlikely return to musical relevance in 1999 when she scored a number one hit song over twenty-four years after her last single topped the charts.[ii]
Other comebacks are less celebrated. In 2000, the Centers for Disease Control (CDC) reported that the measles had been virtually eradicated in the U.S. The few cases that still occurred were usually traced to foreigners who brought the disease into the country. Only thirteen years after it was relegated to a historical footnote, however, the measles reemerged with a vengeance in several communities. In late 2009 and early 2010, for example, a measles breakout occurred among upstate New York's Orthodox Jewish population. More than 3,500 people were sickened.[iii] Another outbreak in June 2013 resulted in forty-eight more confirmed cases of the disease.[iv] More recently, a measles epidemic sickened twenty-one members of the Eagle Mountain Church in Copeland, Texas. As of August 2013, there were 135 documented cases of the measles this year alone.[v]
While the overall vaccination rate in most areas remains high enough to sustain effective herd immunity coverage for the entire population, the anti-vaccination movement in general—and the rampant use of religious and philosophical exemptions to compulsory child vaccination laws by parents in particular—poses a danger to the public health in several different regions of the U.S. Young children and infants are among the most vulnerable in these areas. In a single whooping cough outbreak in Tarrant County, Texas, hundreds of unvaccinated children became ill and two infants too young to be vaccinated died from the disease. Not surprisingly, the number of parents living in the region who had procured vaccine exemptions for their children had more than doubled during the five years prior to the outbreak.[vi]
Under the current legal framework, states can lawfully use their police powers to enact public health laws mandating vaccination as a prerequisite for school attendance. At the same time, state legislatures have taken advantage of the broad discretion granted to them by the U.S. Supreme Court in matters of public health to enact religious and philosophical exemptions to child vaccine mandates. In response to the recent spate of outbreaks of vaccine-preventable disease in vaccine-hesitant communities, bioethicist Art Caplan has argued that tort law should be used to hold parents civilly liable for injuries caused by their unvaccinated children. While tort law is valuable as a tool for obtaining legal redress for injured parties, it raises difficult procedural and jurisdictional issues in the context of vaccination and is ineffective at achieving important public policy goals secured by herd immunity.
As the chief molders of public policy, state legislatures should instead take the initiative of using their broad police powers to prevent the harm caused by the rampant use of non-medical vaccine exemptions from occurring in the first place. Rather than relying on tort, through public health law states can better address the underlying factors contributing to soaring vaccine exemption rates in certain parts of the U.S. More precisely, states should limit the scope of religious and philosophical exemptions to make it more difficult for parents to obtain them. At the same time, states should counter popular vaccine myths by increasing vaccine access and education. Parents in particular should understand the benefits of vaccination, as well as the potential health consequences of failing to vaccinate a child, before obtaining an exemption.
The Legal Framework: Mandatory Vaccination and Exemptions
Mandatory vaccination laws are designed to further the public health by "slow[ing] the spread of disease" and "reduc[ing] mortality and morbidity."[vii] Compulsory vaccination accomplishes this by achieving herd immunity.[viii] Herd immunity derives from the notion that
[v]accines are never one hundred percent effective for everybody, so even vaccinated people can become infected with diseases against which they were immunized. But if enough people in a population are effectively immunized against a disease, the population can achieve a herd immunity that protects everybody. The idea is that the disease will not break out in the population because too few people are capable of carrying it and passing it on to others.[ix]
Herd immunity does not just protect those who are immunized; it protects unvaccinated individuals, too, by forming a protective shield of immunity around them. This inhibits potential outbreaks from occurring in the first place. For herd immunity to provide effective coverage, the CDC recommends that 90% of the population be vaccinated in a given area.[x]
Opposition to mandatory vaccination is hardly novel. Vaccines have prompted controversy ever since Dr. Edward Jenner became the first physician to utilize "systematic, deliberate inoculation based on scientific principles" to control smallpox outbreaks in the mid-eighteenth century.[xi] Although Dr. Jenner's groundbreaking program succeeded in reducing smallpox outbreaks from devastating epidemics to manageable emergencies, public distrust and governmental inaction thwarted efforts to implement public vaccination laws around the globe for many years. Vaccine shortages were common, and inexperienced medical professionals often botched the procedure. Deficiencies like these aggravated public confidence in vaccination, but the fear of contracting smallpox eventually overwhelmed enough peoples' reservations that compulsory vaccination laws were enacted throughout much of Europe by the 1850s.[xii]
In the U.S., the rise of mandatory vaccination is inextricably linked to the states' contemporaneous policy interest in securing regular school attendance for children. In 1827, Massachusetts became the first state to require vaccinations for children as a prerequisite for school attendance.[xiii] These laws made practical sense for state and municipal governments because "the bringing together of large numbers of children clearly facilitated the spread of smallpox, and since vaccination provided a relatively safe preventative, it was natural that compulsory school attendance laws should lead to a movement for compulsory vaccination."[xiv] Vaccines were a relatively inexpensive way of benefiting entire communities. By vaccinating almost every child at a young age and tying it to education, state and local governments made a long-term investment in the health and welfare of their residents in one fell swoop.[xv]
Mandatory "vaccinations are . . . among the most cost-effective and widely used public health interventions."[xvi] Nevertheless, the emergence of aggressive public health laws in the late nineteenth-century renewed anti-vaccine sentiment in the U.S. and elsewhere. Many dissenters believed myths that vaccines caused disease instead of preventing it. Others objected to vaccination for religious, philosophical, or constitutional reasons. To them, aggressive state vaccination schemes violated their individual liberty and personal autonomy.[xvii] Under the current legal framework, however, states hold broad police power to enact public health legislation. Given the U.S. Supreme Court's traditional deference to state legislatures in this regard, states have crafted mandatory school vaccination laws replete with medical, religious, and philosophical exemptions for parents who choose to withhold vaccination from their children for personal reasons.
Mandatory Vaccination Laws
In Jacobson v. Massachusetts, 197 U.S. 11 (1905),the U.S. Supreme Court held that mandatory vaccination laws were constitutional exercises of state police power. Factually, Jacobson centered on a Massachusetts state law that allowed city governments to enact compulsory vaccination ordinances if the local board of health deemed them "necessary" to protect the public health or safety.[xviii]In response to a smallpox outbreak in late 1901, the city of Cambridge's board of health enacted such an ordinance. The law mandated smallpox vaccinations for every person aged twenty-one years and older that had not been vaccinated against the disease within the preceding five years. Those who failed to comply with the ordinance were subject to a five-dollar fine.[xix]
The plaintiff, Henning Jacobson, believed that vaccination "quite often" caused serious injuries or death and refused to obey the law.[xx] He also refused to pay the small penalty for noncompliance and was arrested.[xxi] The trial court found Jacobson guilty of violating the ordinance and ordered him to confinement until he paid the five-dollar fine. Jacobson appealed, but the Massachusetts Supreme Court affirmed his conviction. Jacobson appealed again, this time to the U.S. Supreme Court, reiterating his arguments that the ordinance violating his Due Process rights under the Fourteenth Amendment.[xxii]
The Court disagreed. Writing for the majority, Justice Harlan drew on social contract theory to justify the vaccination ordinance as a lawful extension of the state's broad police power to enact legislation that had a "real" and "substantial relation" to the protection of "the public health, the public morals, or the public safety."[xxiii] Under this analysis, "the police power of a state must be held to embrace, at least, such reasonable regulations established directly by legislative enactment as will protect" public health and safety.[xxiv] Because Cambridge's vaccine mandate represented a "reasonable and proper" exercise of state police power to advance public health goals, it passed constitutional muster.[xxv]
At the same time, the Court also limited the reach of state police powers utilized to enact public health legislation. States must exercise police power in congruence with "the necessity of the case" and cannot employ it to achieve "unreasonable, arbitrary, and oppressive" ends.[xxvi] The Court developed a proportionality test to determine whether a public health law satisfies this requirement: any law designed to protect the public health or safety must bear a "real or substantial relation to those objects, or is [not] . . . a plain, palpable invasion of rights secured by" the law.[xxvii] Under this analysis, for example, the Court carved out a medical exemption to vaccination because it would be unreasonable for an individual who could be harmed by the procedure due to legitimate health reasons to be forced to submit to it.[xxviii]
While Jacobson granted state legislatures wide latitude to enact vaccine mandates, it left unanswered the more specific question of whether state laws requiring vaccination as a prerequisite for school admission were constitutionally valid. Seventeen years after Jacobson, the Court removed any lingering doubt. In Zucht v. King, 260 U.S. 174 (1922),the Court extended the Jacobson rationale to uphold a city ordinance that compelled childhood vaccination in order for students to attend local schools as a valid extension of state police power. The Court explicitly reaffirmed states' "broad discretion" to enact public health laws as each sees fit, including the ability to delegate power to city governments to apply and enforce health laws.[xxix]
Vaccine Exemptions
Jacobson and Zucht made it clear that state legislatures maintain broad, though not absolute, discretion when crafting compulsory vaccination laws. Accordingly, every state currently mandates vaccination as a prerequisite for school attendance.[xxx] States have also developed specialized medical, religious, and philosophical exemptions to childhood vaccination requirements. While medical exemptions release children whose health could be compromised by vaccinations from being forced to undergo them, religious and philosophical exemptions allow parents to withhold vaccination for personal reasons.[xxxi] With the exception of Mississippi and West Virginia, every state currently offers a religious vaccine exemption.[xxxii] Additionally, seventeen states[xxxiii] offer broader philosophical vaccine exemptions that typically command a lower standard of proof to obtain than religious exemptions.[xxxiv]
While some critics believe that vaccine exemptions represent onerous proof that vaccines have become "the victims of their own success," proponents argue that religious and philosophical exemptions serve important policy interests of their own.[xxxv] To the latter, non-medical exemptions protect a crucial "sphere of protected individual liberties" for parents who genuinely object to vaccination.[xxxvi] Under this view, non-medical exemptions safeguard fundamental parental rights protected by the Constitution. Without religious and philosophical exemptions in place, vaccine mandates take this important parenting choice away by substituting a parent's judgment with the government's.[xxxvii]
Given the U.S. Supreme Court's traditional acquiescence to state legislatures in matters of public health, it is not surprising that religious and philosophical vaccine exemptions vary dramatically from state to state.[xxxviii] Nevertheless, religious exemption laws typically take one of two forms. In Nebraska and a majority of states, individuals who belong to "a recognized religious denomination" or have "personal and sincerely followed religious beliefs" can obtain an exemption.[xxxix] South Carolina, on the other hand, represents the minority of states that still require that a parent belong to "a recognized religious denomination" with "tenets and practices" that "conflict with immunizations."[xl] Additionally, among states that offer broader philosophical exemptions, the requirements for obtaining one are typically even more lax than those for religious exemptions.[xli] In Maine, for example, parents can obtain an exemption for "an opposition to the immunization for philosophical reasons."[xlii] This means that parents in Maine can exempt their children from vaccination for virtually any reason whatsoever, regardless of whether it derives from a religious conviction.
The procedural requirements for obtaining religious and philosophical exemptions also differ between jurisdictions. These variations are significant because the level of difficulty involved in obtaining exemptions directly affects the number of parents who seek them. The more exacting the procedure, the less likely it is that parents will exempt their child from vaccination.[xliii] Satisfying Wisconsin's requirements is relatively easy. Parents merely fill out a standard form that requires them to check a box next to the applicable exemption.[xliv] Texas, on the other hand, imposes some of the most daunting procedures for obtaining a religious or philosophical exemption in the nation. Parents must file a signed affidavit under penalty of perjury every two years that explains the basis for the objection.[xlv]
A Theory in Tort: Holding Parents Civilly Responsible for Injuries Caused by Unvaccinated Children
With a working concept of state vaccine mandate and exemption laws in mind, it is important to consider the context surrounding the criticism of religious and philosophical exemptions in some states. High religious and philosophical vaccine exemption rates have been tied to many of the recent outbreaks of the whooping cough and the measles that have occurred throughout the U.S.[xlvi] Some parents seek exemptions for their children based on sincerely held religious and philosophical beliefs. Others use them as a means of avoiding the inconvenience and expense of having to vaccinate their child. Generally speaking, though, high exemption rates are most common in communities where anti-vaccine parents have clustered together. In Ashland, Oregon, for example, nearly one-third of children claimed vaccine exemptions in 2008, and measles and whooping cough outbreaks are far more common than among the general populace.[xlvii]
In response to the problem of decreasing vaccination rates in Ashland and other communities with high non-medical exemption rates, bioethicist Art Caplan has advocated for using tort law as a policy-shaping tool to help achieve public health goals regarding vaccine mandate compliance. Caplan believes that statutory religious and philosophical exemptions should still be available to parents, but that liability for negligence should flow from any harm caused by their decision to withhold vaccination from a child regardless of whether an exemption has been procured.[xlviii] As Caplan explains,
If your kid gets the measles, and remember public health officials are getting very, very good at tracing outbreaks to their source, and makes my kid sick (can happen since vaccine is not 100% effective), my newborn baby die (newborns can't benefit from vaccines) or my wife miscarry (fetuses are at especially high risk), then shouldn't I be able to sue you for the harm you have done?[xlix]
In a typical case, the plaintiff would shoulder the burden of proving each element of a traditional negligence claim in order to recover against the parent of an unvaccinated child: duty, breach of duty, causation, and damages. As to duty, Caplan contends that parents have a general duty to prevent foreseeable harm to others. Because the failure to vaccine could result in reasonably foreseeable harm to the child and others, this duty applies regardless of whether a parent has obtained a religious or philosophical exemption. Caplan believes that exemptions do "not negate the fundamental duty one has to act reasonably in preventing the spread of disease to others," and the failure to vaccinate a child represents a breach of duty regardless.[l]
With respect to causation, Caplan argues that modern biomedical science has "adequate scientific capability" to prove "with a great deal of confidence, though not absolute certainty," when one individual conveys a disease to another.[li] Accordingly, plaintiffs would have to rely on epidemiology to trace the course of an outbreak in order to help identify a causal connection between the plaintiff and the unvaccinated individual that transmitted a particular illness.[lii] To satisfy proximate causation, the plaintiff would also have to show that a parent's decision not to vaccine their child was a "substantial factor" in causing his injuries.[liii] For example, a plaintiff would have to prove that a reasonable person in the parent's position would have foreseen that the failure to vaccinate their child could lead result in harm to others.[liv] Assuming the plaintiff could demonstrate the duty, breach, and causation components, the plaintiff would only have to prove damages in order to substantiate a prima faciecase of negligence.[lv]
Caplan's negligence theory has its merits. After all, tort law does play an important role in shaping public policy by redressing private wrongs committed by one individual against another. This could include using tort to hold parents accountable for injuries caused by their decision to withhold vaccination from a child.[lvi] Nevertheless, a number of practical drawbacks make tort law unappealing as a means of achieving the crucial public health interests served by mandatory vaccination. For example, tort law is ineffective at redressing the unrealized harms posed by the widespread failure to vaccinate.[lvii] Although unvaccinated children undoubtedly pose a cognizable health risk to themselves and others, the greatest threat wrought by dangerously high exemption rates is an unrealized one—"an increase in the risk of exposure to contagions in the event of an outbreak."[lviii] It is difficult to prove unrealized harms in tort, especially if a widespread disease outbreak has not yet occurred. Even if an outbreak has occurred, unrealized harms trigger complicated jurisdictional problems if specific injuries cannot be identified given the unpredictable way that contagious disease can spread.[lix]
Moreover, proving causation on the basis of the failure to vaccinate is complicated due to the limits of modern scientific testing and analysis. Although technological advances have made tracking the spread of disease more reliable than ever, it is still "difficult to trace contagions through both place and time."[lx] Tracing the spread of a disease in communities with large numbers of unvaccinated children is a particularly daunting task. Even when diseases can be accurately traced, it remains unclear who should ultimately be held responsible in a negligence action. Should it be the parent of the child "who directly infected the plaintiff, or every unvaccinated person who passed on the contagion?"[lxi] Even if a responsible party can be isolated and identified, the limits of medical testing mean that infected individuals must be swabbed anywhere from three to seven days after the onset of a disease to collect reliable samples for analysis. If samples are taken more than ten days after an infection, viral isolation cannot be performed at all and crucial evidence is lost.[lxii]
Perhaps the biggest drawback with relying on tort law in this context is its inherent ineffectiveness as a policymaking tool for matters of public health and safety. Tort remedies private damages. It is not designed to further the larger public health goals tied to compulsory vaccination. While parties could conceivably rely on tort theories to obtain compensation for injuries caused by an unvaccinated individual, civil litigation is ultimately an "adversarial remedy" that complicates "community cohesion" and frustrates vaccine compliance by alienating already hesitant parents even further from the community.[lxiii] This is a significant drawback given that the primary threat posed by the widespread failure to vaccinate children is the heightened risk of disease outbreaks among the most vulnerable members of society.[lxiv] For these reasons and others, tort is simply the wrong means to achieve higher childhood vaccination rates.
Preventative Care: A Public Health Law Approach to Vaccine Health
Fortunately, a better policy mechanism exists: public health law. As the U.S. Supreme Court once noted, "[p]rimarily it is for the lawmakers to determine the public policy of the state."[lxv] State legislatures should act accordingly by taking a proactive, multi-faceted approach to increase the number of children who obtain vaccinations despite the existence of religious and philosophical exemptions. Instead of relying on individuals to file private tort actions after an injury has occurred and the harm has already been done, legislatures should update existing exemption laws and implement new public health initiatives designed to prevent vaccine noncompliance-related harm from occurring in the first place. More specifically, states should use their broad police powers in matters of public health—particularly the parens patriae power—to amend existing non-medical exemption laws in order to make it more difficult for parents to obtain them. Doing so would be morally justified under the Harm Principle. Additionally, states should make increased efforts to educate parents about vaccine benefits and also provide greater access to them by providing them to the public for free.
State Police Powers: Amending Vaccine Exemptions
Under Zucht and Jacobson, state legislatures clearly retain wide discretion to use police power to enact ambitious mandatory vaccination laws in order to protect the public health.[lxvi] If states can implement this authority to create religious and philosophical exemptions to such mandates, it follows that state legislatures should also be able to limit the scope of exemptions when necessary to secure the public health and safety. Withholding vaccinations from children should require more than checking a box on a standard form, as in Wisconsin. States that currently enforce lax standards for obtaining religious and philosophical exemptions should instead follow the lead of Texas and impose more exacting requirements that discourage parents from obtaining exemptions without eliminating them altogether. By asking parents to submit biennial written and signed affidavits that expose them to the penalty of perjury if they lie under oath, states reduce the likelihood that parents will seek exemptions in general, including for insincere reasons of convenience.[lxvii] Moreover, because the impact of widespread vaccine non-compliance is felt mostly at a local or regional level, states could also empower municipal governments to enact mandatory vaccination ordinances that limit or eliminate exemptions altogether as a preventative health measure in areas afflicted with high exemption rates.[lxviii]
Amending current exemption laws in response to the burgeoning health threat that widespread vaccine noncompliance poses to several communities is not only supported by existing case law; it is ethically justified under the Harm Principle. The Harm Principle is arguably "[t]he single most prominent moral principle reflected in U.S. social policy and law" throughout the nation's history.[lxix] As John Stuart Mill articulated, the Harm Principle holds that "[t]he only purpose for which power can be rightfully exercised over any member of a civilized community, against his or her will, is to prevent harm to others."[lxx] Mill's definition is grounded in terms of standing:[lxxi]
As soon as any part of a person's conduct affects prejudicially the interests of others, society has jurisdiction over it, and the question whether the general welfare will or will not be promoted by interfering with it, becomes open to discussion. But there is no room for entertaining any such question when a person's conduct affects the interests of no persons besides himself, or needs not affect them unless they like . . . . In all such cases there should be perfect freedom, legal and social, to do the action and stand the consequences.[lxxii]
By emphasizing the relationship between individual conduct and its impact on the larger community, the U.S. Supreme Court drew on the Harm Principle in much of its analysis in Jacobson. The Court expressly refused to recognize a right to absolute individual liberty. Instead, "[t]here are manifold restraints to which every person is necessarily subject for the common good. On any other basis organized society could not exist with safety to its members."[lxxiii] A society organized around the concept that "one is a law unto himself," the Court stressed, would end in "disorder and anarchy."[lxxiv] As a result, the Massachusetts Legislature maintained the right to act in "self-defense" by mandating vaccination to protect against the spread of contagious disease.[lxxv] The Jacobson result made it clear that the health and safety of the community could not be held hostage by a fringe group of vaccine resisters.[lxxvi]
High vaccine exemption rates have been linked to whooping cough and measles outbreaks in several different communities and pose a threat to the general public health and safety in those areas.[lxxvii] At the same time, state legislatures should remain cognizant of the health implications that individual unvaccinated children face to themselves and others by exercising parens patriae power accordingly. Parens patriae power is a specialized police power that allows the state to act in loco parentis in order to protect children from a potentially dangerous parenting decision.[lxxviii] Children occupy a "special place" in society, and because their "constitutional rights . . . cannot be equated with those of adults" they command special protection under the law.[lxxix] Consequently, parens patriae doctrine provides an alternative basis for states to restrict the scope of existing religious and philosophical exemptions or eliminating them altogether in order to protect children from the dangerous parenting choice of leaving them unvaccinated.
Existing case law bolsters the notion that states could utilize parens patriae power to protect individual children from a parent's decision to withhold vaccination, regardless of whether a statutory exemption applies. For example, the U.S. Supreme Court held in Prince v. Massachusetts, 321 U.S. 158 (1944) that a state could invoke parens patriae doctrine to enact public health laws designed to secure "the healthy, well-rounded growth of young people into full maturity as citizens," regardless of whether doing so intruded on fundamental religious and parental liberties.[lxxx] More specifically, the Court determined that religious liberty could not insulate the family unit from the reach of public interest legislation. On the contrary, parents' religious or philosophical convictions may not be used "to claim freedom from compulsory vaccination for the child."[lxxxi]
The Court also reaffirmed states' "wide range of power for limiting parental freedom and authority in things affecting the child's welfare; and . . . this includes, to some extent, matters of conscience and religious conviction."[lxxxii] Child vaccination ranks among the areas of religious liberty that states can lawfully control in lieu of parents as "[t]he right to practice religion freely does not include liberty to expose the community or the child to communicable disease or the latter to ill health or death."[lxxxiii] Because unvaccinated children are thirty-five times more likely to contract disease than their vaccinated peers, obtaining a religious or philosophical exemption constitutes a poor parenting choice that imperils children in areas with high exemption rates.[lxxxiv]
Other Public Health Initiatives
Although tightening the legal requirements for obtaining religious and philosophical exemptions would likely discourage vaccine-hesitant parents from seeking them, other measures should be taken to increase vaccine access and education. Because of vaccines, most parents in the U.S. today simply "have not witnessed the tragic effects of diseases like polio, smallpox, measles, and whooping cough" that led to the enactment of vaccine mandates in the first place.[lxxxv] The advent of the Internet has also fueled a great deal of anti-vaccine sentiment. Anti-vaccine websites have created a subculture of doubt about vaccine efficacy by "questioning the scientific veracity" of vaccines and claiming that they are unsafe for children.[lxxxvi] Consequently, state governments should try to demystify common vaccine myths and counter widespread misinformation about their health and safety through initiatives of their own.
In terms of educating the public, public health officials and the media should use "clear, non-sensationalized" efforts to communicate the individual and collective health benefits to vaccine-hesitant parents.[lxxxvii] The media should downplay "personalized" and "dramatic" news reporting tactics and emphasize "historical, institutional, and social contexts" when reporting on vaccination.[lxxxviii] At the same time, public health officials should avoid using "shock tactics" and scary statistics to grab public attention and shame anti-vaccine parents.[lxxxix] States should adopt public health "communication infrastructure" that accurately, quickly, and directly delivers sound health information to the public in order to avoid distortion by third parties.[xc] What must ultimately occur is a wholesale change in mindset among vaccine-hesitant parents in order to engage them in the community and help them to forego their individual interest in withholding vaccination from their child. As the molders of public policy, state legislatures are uniquely equipped to accomplish this, but only if they communicate the message effectively.[xci]
Among other things, state legislatures could institute an informed refusal process for parents to obtain religious and philosophical exemptions for their children. Under this requirement, doctors would inform parents of the health risks of refusing vaccination for their child. Parents would then have to sign a release form acknowledging that they understand the individual and collective risks of exemption.[xcii] This would provide one of the most effective means of offering direct and accurate information from a medical professional about vaccine safety before a parent makes the choice to exempt their child from vaccination. States should also increase vaccine access by allocating more resources to provide free vaccinations to all children, regardless of socioeconomic status.[xciii]
Mandatory vaccination programs represent one of the greatest public health achievements in human history. While tort law might provide redress for private harms caused by a parent's decision not to vaccinate their child, public health policy is best served by proactive state legislatures that wield police power appropriately in order to curb the adverse impact of high non-medical exemption rates within their borders. By increasing vaccine education and access as well, state legislatures can effectively corral the public health risks posed by high concentrations of unvaccinated children in a given area. With appropriate public health laws in place, perhaps Fitzgerald will be vindicated and the measles' second act will be its last. The health and wellbeing of countless people depend on it.
[i] Robert McCrum, Great Scott! Fitzgerald is Enjoying a Third Act, The Guardian, Feb. 4, 2012, http://www.theguardian.com/books/2012/feb/05/scott-fitzgerald-gatsby-mccrum.
[ii] Peter Guralnick, Careless Love: The Unmaking of Elvis Presley 322-25 (1999); David Robinson, Chaplin: His Life and Art 622-25 (1985); Keith Caulfield, Cher Shines with No. 1 in Sixth Consecutive Decade, Billboard (Jan. 18, 2011, 12:30 PM), http://www.billboard.com/articles/news/473595/cher-shines-with-no-1-in-sixth-consecutive-decade.
[iii] David Schultz, To Stem Mumps Outbreak, Doctors Try an Extra Vaccination, NPR, (Oct. 31, 2012, 5:01 PM), http://www.npr.org/blogs/health/2012/10/31/164024772/in-an-orthodox-jewish-community-two-vaccine-doses-wasn-t-enough.
[iv] Daniel Sayani, Examiner.com, June 6, 2013, http://www.examiner.com/article/measles-outbreak-hits-brooklyn-s-ultra-orthodox-community.
[v] Liz Szabo, Texas Measles Outbreak Linked to Church, USA Today, Aug. 25, 2013, http://www.usatoday.com/story/news/nation/2013/08/23/texas-measles-outbreak/2693945/; Texas Megachurch Scrutinized Following Measles Outbreak, CBS DFW (Aug. 31, 2013, 12:43 PM), http://dfw.cbslocal.com/2013/08/31/texas-megachurch-scrutinized-following-measles-outbreak/.
[vi] Becca Aaronson, NY Times, Sept. 7, 2013, http://www.nytimes.com/2013/09/08/us/outbreaks-make-a-case-for-vaccinations.html; Liz Szabo, Texas Measles Outbreak Linked to Church, USA Today, Aug. 25, 2013, http://www.usatoday.com/story/news/nation/2013/08/23/texas-measles-outbreak/2693945/.
[vii] Daniel B. Rubin & Sophie Kasimow, Noncompliance: Public Health Goals and the Limitations of Tort Law, 107 Mich. L. Rev. First Impressions 114, 114 (2009), http://www.michiganlaw
[viii] Paul E.M. Fine, Herd Immunity: History, Theory, Practice, 15 Epidemiologic Rev. 265, 267 (1993).
[ix] Note, Toward a Twenty-First Century Jacobson v. Massachusetts, 121 Harv. L. Rev. 1820, 1821 (2008).
[x] Ryan Jaslow, CBS News (Sept. 12, 2013, 3:01 PM), http://www.cbsnews.com/8301-204_162-57602677/cdc-vaccine-philosophical-differences-driving-up-u.s-measles-rates/.
[xi] James G. Hodge, Jr. & Lawrence O. Gostin, School Vaccination Requirements: Historical, Social, and Legal Perspectives, 90 Ky. L.J. 831, 838 (2001).
[xii] Id. at 840-41.
[xiii] Michael Poreda, Comment, Reforming New Jersey's Vaccination Policy: The Case for the Conscientious Exemption Bill, 41 Seton L. Rev. 765, 769-70 (2011).
[xiv] John Duffy, School Vaccination: The Precursor to School Medical Inspection, 33 J. Hist. Med. 344, 344 (1978).
[xv] Hodge & Gostin, supra note 11, at 851.
[xvi] Id. at 844.
[xvii] Id. at 844-45.
[xviii] Jacobson v. Massachusetts, 197 U.S. 11, 27 (1905).
[xix] Id. at 22-24.
[xx] Id. at 36.
[xxi] Id.
[xxii] Id. at 22-24, 29-30.
[xxiii] Id. at 30-31.
[xxiv] Id. at 24-25.
[xxv] Id. at 27-30, 34-37.
[xxvi] Id. at 26.
[xxvii] Id. at 31.
[xxviii] Id. at 39.
[xxix] Zucht v. King, 260 U.S. 174, 175-77 (1922).
[xxx] Poreda, supra note 13, at771.
[xxxi] Note, supra note 9, at 1825.
[xxxii] Religious vaccine exemption statutes for each respective state and Washington, D.C., are located at Ala. Code. § 16-30-3 (Westlaw through the end of the 2013 Regular Session); Alaska Admin. Code tit. 4, § 06.055 (Westlaw through June 7, 2013 (Register 206)); Ariz. Rev. Stat. Ann. § 36-883 (Westlaw through the First Regular and First Special Sessions of the Fifty-First Legislature); Ark. Code Ann. § 6-18-702 (West, Westlaw through end of 2013 Regular Session); Cal. Code Regs. tit. 17, § 6051 (Westlaw through 10/11/13 Register 2013, No. 41); Colo. Rev. Stat. Ann. § 25-4-903 (West, Westlaw through the First Regular Session of the Sixty-Ninth General Assembly (2013)); Conn. Gen. Stat. Ann. § 10-204a (West, Westlaw through the current acts of the 2013 January Regular Session of the Connecticut General Assembly); 14 Del. Code Ann. tit. 14, § 131 (West, Westlaw through 79 Laws 2013, chs. 1-185(end)); D.C. Code § 38-506 (Westlaw through July 29, 2013); Fla. Stat. Ann. § 1002.20 (West, Westlaw through Ch. 272 (End) of the 2013 1st Reg. Sess. Of the Twenty-Third Legislature); Ga. Code Ann. § 20-2-771 (West, Westlaw through the end of the 2013 Regular Session); Haw. Rev. Stat. § 302A-1156 (West, Westlaw through Act 288 [End] of the 2013 Regular Session); Idaho Code Ann. § 39-4802 (West, Westlaw through (2013) Chs. 1-354 (End)); 105 ILCS 5/27-8.1 (Westlaw through P.A. 98-486, with the exception of P.A. 98-455, P.A. 98-456, and P.A. 98-463, of the 2013 Reg. Sess.); Ind. Code Ann. § 20-34-3-2 (West, Westlaw through all 2013 legislation); Iowa Code Ann. § 139A.8 (West, Westlaw through legislation from the 2013 Reg. Sess.); Kan. Stat. Ann. § 65-508 (West, Westlaw through 2013 regular and special sessions); Ky. Rev. Stat. Ann. § 214.036 (West, Westlaw through the end of the 2013 regular session and the 2013 extraordinary session); La. Rev. Stat. Ann. § 40:31.16 (Westlaw through the 2013 Regular Session); Me. Rev. Stat. tit. 20-A, § 6355 (Westlaw through the 2013 First Regular Session and First Special Session of the 126th Legislature); Md. Code Ann., Educ. § 7-403 (West, Westlaw through all chapters of the 2013 Regular Session of the General Assembly); Mass. Gen. Laws Ann. ch. 76, § 15 (West, Westlaw through Chapter 114 of the 2013 1st Annual Session); Mich. Comp. Laws Ann. § 333.9215 (West, Westlaw through P.A.2013, No. 138, of the 2013 Regular Session, 97th Legislature); Minn. Stat. Ann. § 121A.15 (West, Westlaw through the 2013 Regular and First Special Sessions effective through July 31, 2013); Mo. Ann. Stat. § 167.181 (West, Westlaw through the end of the 2013 First Regular Session of the 97th General Assembly, pending corrections received from the Missouri Revisor of Statutes. Constitution is current through the November 6, 2012 General Election); Mont. Code Ann. § 20-5-405 (Westlaw through chapters effective July 1, 2013, and the 2012 general election. Statutory changes are subject to classification and revision by the Code Commissioner); Neb. Rev. Stat. § 79-221 (2013); Nev. Rev. Stat. Ann. § 392.437 (West, Westlaw through the 2011 76th Regular Session of the Nevada Legislature, and technical corrections received from the Legislative Counsel Bureau (2012)); N.H. Rev. Stat. Ann. § 141-C:20-c (Westlaw through Chapter 279 of the 2013 Reg. Sess., not including changes and corrections made by the State of New Hampshire, Office of Legislative Services); N.J. Stat. Ann. § 18A:61D-3 (West, Westlaw through L.2013, c. 165 and J.R. No. 11); N.M. Stat. Ann. § 24-5-3 (West, Westlaw through Ch. 228 (end) of the First Regular Session of the 51st Legislature (2013)); N.Y. Pub. Health Law § 2164 (McKinney, Westlaw through L.2013, chapters 1 to 340); N.C. Gen. Stat. Ann. § 130A-157 (West, Westlaw through S.L. 2013-257 of the 2013 Regular Session of the General Assembly); N.D. Cent. Code Ann. § 23-07-17.1 (West, Westlaw through the 2013 Regular Session of the 63rd Legislative Assembly); Ohio Rev. Code Ann. § 3313.671 (West, Westlaw through 2013 Files 24 and 26 to 38 of the 130th GA (2013-2014)); Okla. Stat. Ann. tit. 10, § 413 (West, Westlaw through the First Regular Session of the 54th Legislature (2013) effective July 1, 2013); Or. Rev. Stat. Ann. § 433.267 (West, Westlaw through the 2013 Reg. and Sp. Sess. legislation effective through 10/8/13. Revisions to Acts made by the Oregon Reviser were unavailable at the time of publication); 28 Pa. Code § 23.84 (Westlaw through Pennsylvania Bulletin, Vol. 43, Num. 42, dated October 19, 2013); R.I. Gen. Laws Ann. § 16-38-2 (West, Westlaw through chapter 534 of the 2013 Regular Session); S.C. Code Ann. § 44-29-180 (Westlaw through End of 2012 Reg. Sess.); S.D. Codified Laws § 13-28-7.1 (Westlaw through 2013 Regular Session and Supreme Court Rule 13-08); Tenn. Code Ann. § 37-10-402 (West, Westlaw through end of 2013 First Reg. Sess.); Tex. Health and Safety Code Ann. § 161.004 (West, Westlaw through the end of the 2013 Third Called Session of the 83rd Legislature); Utah Code Ann. § 53A-11-302 (West, Westlaw through 2013 First Special Session); Vt. Stat. Ann. tit. 18, § 1122 (West, Westlaw through the laws of the First Session of the 2013-2014 Vermont General Assembly (2013); Va. Code Ann. § 22.1-271.4 (West, Westlaw through the End of the 2013 Reg. Sess. and the End of the 2013 Sp. Sess. I.); Wash. Rev. Code Ann. § 28A.210.090 (West, Westlaw through all 2013 Legislation); Wis. Stat. Ann. § 252.04 (West, Westlaw through 2013 Wisconsin Act 45, published 8/06/2013); Wyo. Stat. Ann. § 21-4-309 (West, Westlaw through the 2013 General Session).
[xxxiii] Philosophical exemption statutes for each respective state can be found at Ariz. Rev. Stat. Ann. § 15-873(Westlaw through the First Regular and First Special Sessions of the Fifty-first Legislature); Ark. Code Ann.§ 6-18-702 (West, Westlaw through end of 2013 Regular Session); Cal. Code Regs. tit. 17, § 6051 (Westlaw through 10/11/13 Register 2013, No. 41), Colo. Rev. Stat. Ann. § 25-4-903 (West, Westlaw through the First Regular Session of the Sixty-Ninth General Assembly (2013)); Idaho Code Ann. § 39-4802 (West, Westlaw through (2013) Chs. 1-354 (End)); La. Admin. Code tit. 51, pt. II § 701 (Westlaw through rules published in the Louisiana Register dated August 20, 2013); Me. Rev. Stat. tit. 20-A, § 6355 (Westlaw through the 2013 First Regular Session and First Special Session of the 126th Legislature); Mich. Comp. Laws Ann. § 333.9215 (West, Westlaw through P.A.2013, No. 138, of the 2013 Regular Session, 97th Legislature); Minn. Stat. Ann. § 121A.15 (West, Westlaw through the 2013 Regular and First Special Sessions effective through July 31, 2013); N.D. Cent. Code Ann. § 23-07-17.1 (West, Westlaw through the 2013 Regular Session of the 63rd Legislative Assembly); Ohio Rev. Code Ann. § 3313.671 (West, Westlaw through 2013 Files 24 and 26 to 38 of the 130th GA (2013-2014)); Okla. Stat. Ann. tit. 10, § 413 (West, Westlaw through the First Regular Session of the 54th Legislature (2013) effective July 1, 2013); Tex. Health and Safety Code Ann. § 161.004 (West, Westlaw through the end of the 2013 Third Called Session of the 83rd Legislature); Utah Code Ann. § 53A-11-302 (West, Westlaw through 2013 First Special Session); Vt. Stat. Ann. tit. 18, § 1122 (West, Westlaw through the laws of the First Session of the 2013-2014 Vermont General Assembly (2013); Wash. Rev. Code Ann. § 28A.210.090 (West, Westlaw through all 2013 Legislation); Wis. Stat. Ann. § 252.04 (West, Westlaw through 2013 Wisconsin Act 45, published 8/06/2013).
[xxxiv] Note, supra note 9, at 1825; Ross D. Silverman, No More Kidding Around: Restructuring Non-Medical Childhood Immunization Exemptions to Ensure Public Health Protection, 12 Annals Health L. 277, 282 (2003); Katherine Southard, One Step Forward, Two Steps Back: How Mandating the Human Papillomavirus Vaccine Will Increase the Use of Vaccine Exemptions and Negatively Impact our Nation's Health, 18 J.L. & Pol'y 503, 520 (2009).
[xxxv] Anthony Ciolli, Mandatory School Vaccinations: The Role of Tort Law, 81Yale J. Biology & Med. 129, 131 (2008); Sabrina Tavernise, Washington State Makes it Harder to Forgo Immunizations, NY Times, Sept. 19, 2012, http://www.nytimes.com/2012/09/20/health/washington-state-makes-it-harder-to-forgo-immunizations.html?_r=0.
[xxxvi] Note, supra note 9, at 1823.
[xxxvii] See Quilloin v. Walcott, 434 U.S. 246, 255 (1978) ("We have recognized on numerous occasions that the relationship between parent and child is constitutionally protected . . . . It is cardinal with us that the custody, care and nurture of the child reside first in the parents, whose primary function and freedom include preparation for obligations the state can neither supply nor hinder.")
[xxxviii] See supra Part. II.A.
[xxxix] Neb. Rev. Stat. § 79-221 (2013).
[xl] S.C. Code Ann. Regs. 61-8 (West, Westlaw through State Register Volume 37, Issue 9, effective September 27, 2013).
[xli] Lara Salahi, Vermont Debates Parent's Choice to Vaccinate, ABC News, Apr. 25, 2012, http://abcnews.go.com/Health/vermont-debates-parents-choice-vaccinate/story?id=16204212.
[xlii] Me. Rev. Stat. tit. 20-A, § 6355 (West, Westlaw through the 2013 First Regular Session and First Special Session of the 126th Legislature).
[xliii] Sabrina Tavernise, Washington State Makes it Harder to Forgo Immunizations, NY Times, Sept. 19, 2012, http://www.nytimes.com/2012/09/20/health/washington-state-makes-it-harder-to-forgo-immunizations.html?_r=0.
[xliv] Wis. Stat. Ann. § 252.04 (West, Westlaw through 2013 Wisconsin Act 45, published 8/06/2013.
[xlv] Tex. Health and Safety Code Ann. § 161.004-0041 (West, Westlaw through the end of the 2013 Third Called Session of the 83rd Legislature).
[xlvi] Saad B. Omer et al., Vaccination Policies and Rates of Exemption from Immunization, 2005-2011, 367 New Eng. J. Med. 1170-71 (2012).
[xlvii] Ciolli, supra note 35, at 131; Note, supra note 9, at 1826; JoNel Aleccia, Vaccine-Wary Parents Spark Public Health Worry, NBCNews.com, Aug. 22, 2008, http://www.nbcnews.com/
id/26291109/#.UoLM5o01ZOh; Editorial, Foolish Vaccine Exemptions, NY Times, Oct. 12, 2006,http://www.nytimes.com/2006/10/12/opinion/12thu4.html?_r=0.
[xlviii] Arthur Caplan, Liability for Failure to Vaccinate (May 23, 2013), Bill of Health, http://blogs.law.harvard.edu/billofhealth/2013/05/23/liability-for-failure-to-vaccinate/.
[xlix] Id.
[l] Arthur Caplan et al., Free to Choose but Liable for the Consequences: Should Non-Vaccinators Be Penalized for the Harm They Do? 40 J.L. Med. & Ethics 606, 608-09 (2012).
[li] Id. at 606-07.
[lii] Id. at 607.
[liii] Id.
[liv] Id.
[lv] Id.
[lvi] Ciolli, supra note 35, at 131-32.
[lvii] An unrealized harm occurs when a person acts tortuously, but no person or property is harmed. John C.P. Goldberg & Benjamin C. Zipursky, Unrealized Torts, 88 Va. L. Rev. 1624, 1638-39 (2002). Because "tort law concerns itself with wrongs, not every wrong or even every legal wrong is a tort. Tort utilizes a conception of wrongs that involves 'realized' wrongs." Id. at 1638. Nevertheless, "enhanced-risk" unrealized harms pleaded in tort do not necessarily fail. Id. at 1650. For example, a plaintiff could frame an unrealized harm as a realized harm by alleging that the defendant "expos[ed] the plaintiff to a still-extant risk of bodily harm or illness" or by linking it to a realizable harm like "emotional distress or economic loss." Id.
[lviii] Rubin & Kasimow, supra note 7, at 117.
[lix] Id.
[lx] Id. at 117-18.
[lxi] Id. at 118.
[lxii] Caplan, supra note 50, at 607, 609.
[lxiii] Rubin & Kasimow, supra note 7, at 117.
[lxiv] See, e.g., Thomas C. Galligan, Jr., Deterrence: The Legitimate Function of the Public Tort, 58 Wash. & Lee L. Rev. 1019 (2001) for a discussion of how tort law can effectively serve public policy by deterring others from committing wrongs that could result in civil liability.
[lxv] Twin City Pipe Line Co. v. Harding Glass Co., 283 U.S. 353, 357 (1931).
[lxvi] See supra Part II.
[lxvii] Omer et al., supra note 46, at 1170-71.
[lxviii] See Zucht, 260 U.S. at 176-77 ("[A] state may, consistently with the federal Constitution, delegate to a municipality authority to determine under what conditions health regulations shall become operative.").
[lxix] Ross D. Silverman & Thomas May, Private Choice Versus Public Health: Religion, Morality, and Childhood Vaccination Law, 1 U. Md. L.J. Race, Religion, Gender & Class 505, 510 (2001).
[lxx] John Stuart Mill, On Liberty 8 (Dover Publications, Inc. 2002) (1859).
[lxxi] Gerald J. Postema, Public Faces—Private Places: Liberalism and the Enforcement of Morality, in Morality, Harm, and the Law 76, 82 (Gerald Dworkin, ed., 1994).
[lxxii] Mill, supra note 70, at 8.
[lxxiii] Jacobson, 197 U.S. at 26.
[lxxiv] Id. at 26.
[lxxv] Id. at 27-28.
[lxxvi] Id. at 26.
[lxxvii] Daniel R. Feiken et al., Individual and Community Risks of Measles and Pertussis Associated with Personal Exemptions to Immunization, 284 JAMA 3145, 3146-50 (2000).
[lxxviii] Douglas S. Diekema, Parental Refusals of Medical Treatment: The Harm Principle as Threshold for State Intervention, 25 Theoretical Med. 243, 250 (2004).
[lxxix] Bellotti v. Baird,443 U.S. 622, 633-34 (1979).
[lxxx] Prince v. Massachusetts, 321 U.S. 158, 168-69 (1944).
[lxxxi] Id. at 166-67.
[lxxxii] Id. at 167.
[lxxxiii] Id. at 166-67.
[lxxxiv] Alicia Novak, The Religious and Philosophical Exemptions to State-Compelled Vaccination: Constitutional and Other Challenges, 7 U. Pa. J. Const. L. 1101, 1118-20 (2005).
[lxxxv] Rubin & Kasimow, supra note 7, at 118.
[lxxxvi] Felicia B. Eshragh, Same Debate, Different Result: Parental Opt-Outs of a Mandated HPV Vaccine, 2 St. Louis U. J. Health L. & Pol'y 205, 225 (2009).
[lxxxvii] Thomas May, Public Communication, Risk Perception, and the Viability of Preventive Vaccination Against Communicable Diseases, 19 Bioethics 407, 415 (2005).
[lxxxviii] Id.
[lxxxix] Id.
[xc] Id.
[xci] Id.
[xcii] Rubin & Kasimow, supra note 7, at 118-19.
[xciii] The federal government already provides vaccines to children from low-income families. See VFC Vaccines for Children Program (VFC), CDC, http://www.cdc.gov/vaccines/programs/vfc/index.html (last visited Nov. 25, 2013).


text:
Publication Date
Special edition of the College Heights Herald – The President Comes to Western
- Underwood, Jennifer. Ronald Reagan Cheers George Bush Campaign
- Miracle, Phonecia. Students Argue Work for Ideas
- Poore, Chris. Media Flock to Rally, Tell Different Stories
American Politics | Arts and Humanities | Communication | History | Journalism Studies | Mass Communication | Political History | Political Science | Public Relations and Advertising | Social and Behavioral Sciences | Social History | Sociology
Recommended Citation
WKU Student Affairs, "UA12/2/1 College Heights Herald, Vol. 64, No. 18 Special" (1988). WKU Archives Records. Paper 5958.
Included in
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subset: commoncrawl


text:
The Legacy of John Muir
April 21 is John Muir Day. If you are willing and able, I suggest that you "…break clear away…and climb a mountain…. Wash your spirit clean." Also of note is that e-book editions of many of John Muir's writings are available for free at Amazon.com and the iTunes book store.
"There is no repose like that of the green deep woods."
~John Muir
Our world is cacophony. Chaos. Noise and excitement, speed and expediency. Our world is stock prices, cash registers, concrete and steel. We hurry from office to office, meeting to meeting; seeking promotion, status, and wealth. Around us everyone is anxiously engaged in the same vicious, eternal round. Our neighbors are strangers, anonymous, and blank. A cordial nod or wave, and we are off to the races once again. Another day in rush our, another meeting, more status, and if we are lucky, more wealth. We might escape for a week to an amusement park where our daily pattern is microcosmically repeated—rush, wait, rush, wait, rush, wait. Our lives are spent in perpetual hurriedness. Our only reprieve is artificial, fleeting, and unfulfilling. When we die, we are sick and tired, worried. We are left wondering if our circular efforts have left anything of substance or merit to those we've left behind, who themselves are busy grasping at their own endless pursuits.
We ought to slow down.
We ought to breathe.
What value is there to life, if when it is finished, we leave only a legacy of speed and a debt of expectation?
But all is not lost. Nor is there reason for cynical, gloomy despair. "In God's wildness" wrote John Muir, "lies the hope of the world – the great fresh unblighted, unredeemed wilderness. The galling harness of civilization drops off, and wounds heal ere we are aware." Never before have those words been more appropriate. Technology has cascaded and tumbled into ubiquity, creating an automated, digital technocracy; a place where men and things are connected through a false sense of community and the self-aggrandizing dystopia of Likes and Followers. Our brains are becoming incapable of patient comprehension, our eyes capable only of scanning. Reading is mere looking; writing is stunted and amputated. However, in wild spaces we have no choice but to look closely, to be patient, and to listen intently.
In "God's wildness" we—along with our worries and our cares—are insignificant, forgotten. In the wilderness we are free to soak in the cold solitude of stone and rock, wind and rain. Indeed, wilderness is Truth itself. In the mountains there is no deception, no false promises, and no unearned, pretentious glory. The mountains simply are. And we, in them, are nothing. But in that, our true nature is laid bare, our wildness manifest, our souls fed and nourished. "Everybody needs beauty as well as bread," taught Muir, "places to play in and pray in, where nature may heal and give strength to body and soul alike." He invited each of us to "climb the mountains and get their good tidings. Nature's peace will flow into you as sunshine flows into trees. The winds will blow their own freshness into you, and the storms their energy, while cares will drop off like autumn leaves."
Open spaces, far from the hoot and whistle of cities and the thundering proselytizing of advertisement, entertainment, and business, are vital spaces. Muir observed that "thousands of tired, nerve-shaken, over-civilized people are beginning to find out that going to the mountains is going home; that wildness is a necessity; and that mountain parks and reservations are useful not only as fountains of timber and irrigating rivers, but as fountains of life." Life, above all else, is our ultimate end. Thomas Jefferson listed life first among self-evident, unalienable rights. Our quests for wealth and wellness are rooted in the perpetuation and betterment of life. Prophets of every religion and every sect have preached eternal life. We are unwilling to settle for mortality, and so we seek eternity and life everlasting. However, we forget sometimes that all around us eternity is displayed in metaphor and in embryo. Muir reminded us that "this grand show is eternal. It is always sunrise somewhere; the dew is never all dried at once; a shower is forever falling; vapor ever rising. Eternal sunrise, eternal sunset, eternal dawn and gloaming, on seas and continents and islands, each in its turn, as the round earth rolls."
If John Muir were alive today, would anyone pay him any attention?
No doubt some would. But if he did manage to demand an audience, surely he'd be dismissed as an idealist, a dreamer, and one who is an "enemy of progress". Progress is well and good. But even better than progress, is greatness. Today we stand at the crossroads of two very different futures. In one direction, grandiosity; and in the other, restraint. Which road will we take? Our posterity will judge for themselves whether our actions constitute greatness, and whether they are worth remembering in celebration or condemning as tragedy. But if the past is any indicator, and if our present attitude about our National Parks—controversial in their conception and infancy—is a barometric reading into the future, then we will be remembered, and judged, not for our ability to engineer, and not for the glorious cities and dams and bridges that we might build; but instead, for our willingness to perpetuate and foster life. We will be celebrated, as we celebrate our grandfathers, for our ability to stay short-term benefit, in order to preserve long-term gratification.
John Muir's legacy is his tireless, brilliant, and poetic love for wildness. He claimed, absurdly to the practically minded, that our survival as a species was founded in wilderness. His recognition that "wildness is a necessity" changed the way that an entire nation thought about the mountains and meadows and deserts. His words touched the hearts of millions. He inspired the future conservation of land, but he also preserved an attitude; an attitude of patient, stoic reverence for the unmatched works of God's hand. His bright, lively eyes gleamed with vitality and joy as he gazed at the wonders of the Sierras and the Sequoia, the Grand Canyon, and Alaska. When he wandered into wilderness his mind and body were healed. His health improved, as did his mood, and his spirit. Are any of us any different?
John Muir believed that "there is a love of wild nature in everybody… ever showing itself whether recognized or no, and however covered by cares and duties." "Come to the woods" he insisted, "for here is rest… sleep in forgetfulness of all ill. Of all the upness accessible to mortals, there is no upness comparable to the mountains." The mountains, in our fool's errand for eternity, are our best and only substitute for heaven.
Can such sentimental, bromidic idealism survive our cynical, connected, artificial world? Are we too far removed from wildness to even bother with the upness of the mountains anymore? If so, then one must ask what plight we now find ourselves in if even our ideals are scoffed at, belittled, and scorned.
What will be our legacy?
John Muir is long dead. But his words are as true today as they ever were. And yet, even he was incapable of staying the relentless hand of "progress". Not even its inclusion in Yosemite National Park prevented the damming of the Hetch Hetchy Valley, a favorite among Muir's many beloved mountain valleys. "These temple-destroyers, devotees of ravaging commercialism, seem to have a perfect contempt for Nature, and instead of lifting their eyes to the God of the mountains, lift them to the Almighty Dollar. Dam Hetch Hetchy! As well dam for water-tanks the people's cathedrals and churches, for no holier temple has ever been consecrated by the heart of man." Today the Hetch Hetchy Valley is the Hetch Hetchy Reservoir. Certainly its practicality is obvious, but at what cost was that practicality purchased?
Wilderness, like liberty, must constantly be nourished and protected. Not (always) by the force of government, as it is a fickle, unreliable guardian. Instead, the protection of wilderness must come from the people. If we, the people, are willing to exercise restraint, and pursue greatness rather than progress, we may yet perpetuate the legacy of John Muir. We may yet escape the burden of duty, steel, and business. We, like Muir, might as long as we live "…hear waterfalls and birds and winds sing… interpret the rocks, learn the language of flood, storm, and the avalanche… and get as near the heart of the world as [we] can."


text:
OSCs. OnScreen Controls.
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Mississippi Governor Signs 18-Week Abortion Ban
On Wednesday, Mississippi Gov. Phil Bryant (R) signed a bill that will ban abortion 20 weeks after a woman's last menstrual period, or after 18 weeks' gestation, which is two weeks earlier than most so-called 20-week abortion bans.
Mississippi Gov. Phil Bryant (R) signed into law on Wednesday a bill that will ban abortion 20 weeks after a woman's last menstrual period, or after 18 weeks' gestation.
Twelve other states have passed 20-week abortion bans since 2010, relying on medically disputed claims that fetuses can feel pain at that age. But Mississippi's HB 1400, while popularly known as a "20-week ban," will actually outlaw abortion two weeks earlier than the 20-week bans in those other states.
The only other recent "20-week ban" that outlawed the procedure so early was Arizona's, and that was blocked by courts because it unconstitutionally restricted abortion pre-viability. A fetus is generally considered viable around 24 weeks.
In its original form, HB 1400 did ban abortion at 20 weeks "post-conception," which is similar to the language in other states and equates to 22 weeks after a woman's last menstrual period. But the senate amended the bill to push back the cutoff date.
Whether at 18 or 20 weeks, however, these bans contradict Supreme Court rulings that abortion cannot be banned before a fetus is viable. Three 20-week bans, including Arizona's, have already been blocked by courts for this reason, and West Virginia Gov. Earl Ray Tomblin (D) cited legal concerns when he recently vetoed a 20-week ban in his state.
Mississippi's bill contains no exceptions for rape or incest, and only a limited exception for severe health issues or fatal abnormalities in the fetus.
Advocates say that legislators are wasting time passing unconstitutional bills that limit women's health, especially in a state with such poor health outcomes for women as Mississippi. "With the women and families of their state facing extreme poverty, unacceptable rates of maternal mortality, and skyrocketing teen pregnancy, Mississippi's elected officials have more than enough real work to do to bolster women's well-being in their state," said Nancy Northup, president and CEO of the Center for Reproductive Rights, in a statement.
Mississippi has one remaining abortion clinic, which only performs abortion until 16 weeks of pregnancy, and which has been fighting in court to stay open since state legislators passed a law in 2012 intended to close it.


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Floor Plan:The Roanoke
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This fully online postgraduate qualification equips students with the knowledge and skills required to make meaningful contributions to cardiac rehabilitation practice. The scientific evidence for cardiovascular disease prevention and rehabilitation is compelling. As such, evidence-based practice features strongly together with multidisciplinary approaches to the comprehensive delivery of high-quality care. The effective implementation of intensive lifestyle and medical risk factor management together with enabling psychosocial health and wellbeing are cornerstone.
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- Delivered in partnership with the National Institute for Prevention and Cardiovascular Health (NIPC): This partnership enables an exceptional opportunity for students to interact with leading experts as well as engage in cutting-edge research and further opportunities in cardiovascular disease prevention and rehabilitation.
- Interdisciplinary expert teaching faculty: Students from a variety of backgrounds from all over the world interact with international leaders and clinical specialists from cardiology, nursing, nutrition, exercise, behavioural medicine and public health.
The course addresses the latest evidence-base, implementation of best-practice guidelines and healthcare policy, behavioural change strategies, lifestyle approaches to risk factor modification, psychosocial health and medical management of risk factors including hypertension, dyslipidaemia, diabetes mellitus, obesity and smoking. Outcome measures, health technology and innovation in service design also feature strongly to enable programme uptake and high-quality delivery.
Applications and Selections
Applications are made online via the University of Galway Postgraduate Applications System.
Who Teaches this Course
This course is delivered by an interdisciplinary teaching faculty of leading experts and clinical specialists in cardiovascular prevention and rehabilitation:
Noeleen Fallon
Specialist nurse in cardiovascular prevention and rehabilitation. Past-President of Irish Association of Cardiac Rehabilitation (IACR).
Elaine Robinson
Specialist nurse in tobacco cessation.
Suzanne Seery
Specialist dietitian in cardiovascular prevention and rehabilitation.
Denise Dunne
Specialist physiotherapist in cardiovascular prevention and rehabilitation.
Dr Catriona Jennings
Cardiovascular Nurse Specialist.
Dr Susan Connolly
Consultant Cardiologist; Clinical Lead in Cardiovascular Prevention and Rehabilitation.
Karen Cradock
Specialist Physiotherapist in Cardiac Rehabilitation; Past President of Irish Association of Cardiac Rehabilitation.
Laura Tobin
Specialist Physiotherapist; Healthy Ireland Project Lead.
Professor Derek O'Keeffe
Consultant Endocrinologist and Expert in Diabetes and Technology & Innovation.
Professor Francis Finucane
Consultant Endocrinologist and Expert in Obesity.
Health Health Behaviour Change Research Group and School of Psychology at University of Galway
The team contribute to teaching across content in health behaviour change, psychosocial health, sexual health and medication adherence.
Discipline of Health Promotion at University of Galway
The team contribute to teaching across content in health promotion approaches to cardiovascular health and diabetes prevention.
Professor Robyn Gallagher
Expert in Digital Health and Current President of the International Council of Cardiovascular Prevention and Rehabilitation.
Twitter Handle: @johnwmcevoy
View Profile
Requirements and Assessment
Key Facts
Entry Requirements
Successful applicants will possess at least a Second Class Honours, Grade 1 degree (or equivalent) in a health care discipline or related subject area (e.g., medicine, nursing, physiotherapy, dietetics, sport and exercise science, clinical or health psychology, pharmacy, health promotion, public health etc). For those who do not hold a primary degree at the required level, consideration will also be given to applicants with relevant work experience, background knowledge and skills.
Overseas students will need to satisfy the University's English Language requirement of IELTS 6.5 or above (or equivalent).
Additional Requirements
Recognition of Prior Learning (RPL)
5 months, part-time
Next start date
January 2024 | January 2025
A Level Grades ()
Average intake
QQI/FET FETAC Entry Routes
Closing Date
For Entry January 2024, closing date = 16 December 2023
For Entry January 2025, closing date = 9 December 2024
NFQ level
Mode of study
ECTS weighting
Course code
Course Outline
The Postgraduate Certificate in Cardiac Rehabilitation involves students participating in a 30 ECTS Level 9 module that runs from the first week of January to the end of May each year. This module is delivered fully online with scheduled virtual tutorials and workshops taking place typically 1–2 Thursday/Friday evenings (3-7 pm) and 1 Saturday per month.
- Unit 1: Evidence, Guidelines and Practice of Cardiac Rehabilitation
- Unit 2: Behaviour Change and Education
- Unit 3: Intensive Risk Factor Management
- Unit 4: Current Perspectives and Future Advances in Cardiac Rehabilitation
Each Unit above has an associated assessment which are all in the form of essays or equivalent, e.g., written assignments, poster presentations, case reviews. There are no exams—coursework accounts for 100% of the assessment.
Why Choose This Course?
Career Opportunities
There is an array of employment opportunities in public health, health promotion, healthcare management, academic and research settings and the pharmaceutical industry. Graduates of the course with a clinical background will also specifically benefit from career advancement in the specialty of cardiac rehabilitation as well as cardiovascular health more broadly.
Who's Suited to This Course
Learning Outcomes
Transferable Skills Employers Value
Work Placement
Study Abroad
Related Student Organisations
Course Fees
Fees: EU
Fees: Tuition
Fees: Student levy
Fees: Non EU
Postgraduate students in receipt of a SUSI grant—please note an F4 grant is where SUSI will pay €4,000 towards your tuition (2024/25). You will be liable for the remainder of the total fee. A P1 grant is where SUSI will pay tuition up to a maximum of €6,270. SUSI will not cover the student levy of €70.
Postgraduate fee breakdown = Tuition (EU or NON EU) + Student levy as outlined above.
Note to non-EU students: learn about the 24-month Stayback Visa here.
Find out More
Dr Jennifer Jones,
Programme Director.
E: jennifer.jones@ universityofgalway.ie
What Our Graduates Say
Ruth Coleman | Senior Physiotherapist, Department of Health
I decided to undertake the Cert to ensure that clinically I was working to the highest standards of evidence available and that our service was optimised to ensure our patients met their goals also. While it was challenging to get back into the domain of research and online education, I really enjoyed the course and felt that we received a broad spectrum of knowledge and experiences while also meeting my objectives. I look forward to bringing in changes to how I work with the confidence the course has provided me with and am happy to recommend it to all professionals working or hoping to work in the area.
You may also be interested in...
Other programmes also offered within this suite of courses in Preventive Medicine and Cardiovascular Health include:


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Are you as busy as a bee? It might be time to slow down and smell the flowers.
Bees are also one of the most industrious creatures on the planet. They work tirelessly to gather food and build their homes. While working hard is commendable, sometimes we need to take a break and enjoy the fruits of our labor. The bee can teach us the importance of balance in our lives.
What else can a busy buzzing bee teach you? Keep reading to learn all about bee spirit animal meaning and symbolism.
What Does the Bee Symbolize?
The bee symbolizes hard work and productivity. Bees also symbolize abundance. When you see a bee, it reminds you to stay focused on your goals and keep working hard.
The bee is also a symbol of prosperity. Seeing one can signify that you're about to come into some money. But that doesn't mean you'll accidentally find the money. It'll likely be the result of all your hard work and investments.
Bee Symbolism in Religion
Bees appear a few times in the Christian bible, most often as a metaphor. In Proverbs, Solomon compares wisdom to honey (Proverbs 24:1314). Here, bees and their honey represent the sweetness of wisdom. In another instance, Samson finds a swarm of bees in the carcass of a lion he had killed (Judges 14:8). This finding is significant because it's a sign that Samson will defeat his enemies. Bees can also represent industriousness. In Matthew 6:26, Jesus compares God's care for us to the way bees collect nectar to make honey.
What about other religions? In ancient Egypt, bees had associations with royalty. The pharaohs often used a bee symbol in their art and jewelry. Bees were also associated with the goddess Isis. In Hinduism, bees are also a symbol of purity and self-sacrifice. They're also considered to be lucky symbols.
Bees in Mythology
There are many myths about bees across different cultures. In Greek mythology, for example, bees come from the tears of the goddess Artemis. Another story says that the first bee was born from the carcass of a cow. This story occurs in both Hindu and Egyptian mythology.
In Celtic mythology, bees are the souls of the dead. They were also thought to be able to predict the future. In some Native American cultures, bees were also messengers from the spirit world.
Bees also play a role in Chinese mythology. In one story, a bee leads an army of animals to victory against a tyrannical ruler. Surprisingly, this story is similar to The Tortoise and the Hare. Both stories have an unlikely character win, even though the odds are against them.
Bee Folklore and Fables
Have you ever heard the cautionary story of the busy bee?
A bee was flying around looking for something to do. It came across a flower and decided to pollinate it. Then, it came across a tree and decided to help make honey. After that, it came across a field and decided to help the farmers by pollinating their crops. The bee was so busy helping others that it didn't have time for anything else.
The moral of the story is that it's important to be productive and to help others. But you also need to make time for yourself. You can't work all the time, or you'll burn out. The bee is a reminder to find a balance between work and play.
Are Bees a Good Omen?
Bees are a good omen. Seeing a bee means good news is on the way. They also symbolize the soul. When you see a bee, it lets you know new life is all around you. Whether that means new opportunities or new friendships, let your path blossom.
Bees also represent the cycle of life. As we let go of the past, we make room for a brighter today. Let the bee guide you to a more fulfilling tomorrow.
Bee Meaning Discovery Questions
Bee's symbolism is personal. How the bee appears to you and how it makes you feel has a major impact on the message. For instance, seeing a flying honey bee means something different than seeing a bee crawling or resting.
A flying bee is busy collecting pollen and nectar from flowers. This bee is a reminder to enjoy life's sweetness and find pleasure in your work. On the other hand, a crawling bee may be a sign that you're feeling bogged down by all your responsibilities. This bee is a reminder to take a break and relax.
If you notice a bee while you're meditating, pay attention to what's going on in your life at that time. What are you working on? What goals are you trying to achieve? The bee may have some advice for you about better focusing your energies.
Did the bee have stripes? Black and yellow striped bees are common in North America. These bees, as spirit animals, are notorious for their short tempers. When you see a bee with these stripes, it's a sign that you're feeling irritable or on edge. In this case, the bee is a reminder to stay calm and focused.
What Is the Meaning of the Bee Spirit Animal?
If the bee is your animal, you are diligent, focused, and energetic. Bees spend their days flying from flower to flower, collecting nectar and pollen to bring back to the hive. Those with a bee spirit animal are also busy and productive. They are always buzzing about, taking on new projects and completing tasks skillfully. Like the bee, you understand the importance of teamwork and are always willing to pitch in and lend a helping hand.
Positive Characteristics of the Bee Spirit Animal
You're not just as busy as a bee; you're as bright as one too! Bees have a lot to offer the world. Let's look at all of the positive characteristics of a bee spirit animal:
- Hardworking
- Diligent
- Focused
- Energetic
- Productive
- Teamwork Oriented
- Helpful
- Lucky
- Prosperous
- Abundance
Which one of the traits from the list above represents you the most? Are you hard-working like the bee? Or are you more of a team player? Consider how the qualities of the bee spirit animal can help you in your life.
Bees are always on the go. They're also incredibly efficient and organized. If you have a bee spirit animal, you likely share these qualities. This type of energy is great when you want to start a business or a family.
Bees are one of the most resourceful spirit animals. Solitary bees store food for when they need it the most. If the bee is your spirit animal, you're probably great at stocking up on the things you need most. You find it easy to plan, and this helps you avoid some of life's biggest challenges.
Negative Characteristics of the Bee Spirit Animal
Bees are mostly associated with positive things but have a few negative characteristics. By acknowledging their shortcomings, anyone with this spirit guide can break free of old habits.
Negative characteristics of the bee:
- Angry
- Short-tempered
- Stinging
- Biting
Bees are usually calm and docile creatures. But, if disturbed, they can quickly become angry and short-tempered. They may even sting or bite in self-defense. You may also have these qualities if you have a bee spirit animal. You may be quick to anger or snap at people when you're feeling stressed. To avoid giving in to your darker energy, take time to recharge every day. For happiness to be possible, rest and restoration must become part of the bee's busy life.
The Meaning of a Bee Dream
Dreaming about a bee means your life will become busier than usual. Do whatever you can to prepare for this increase in activity. If you're not prepared, you may start to feel overwhelmed.
Bees also symbolize fertility and abundance. So, if you're trying to conceive, a bee dream could signify that you're about to get pregnant.
Was there a bee hive in your dream? This means you have a lot of untapped potential. It's time to start working on your goals and realize your full potential.
If you dream about a swarm of bees, it means someone will come into your life and shake things up. This person will likely be high-energy and very busy. They may even be a little overwhelming at first. But they'll eventually help you get out of your comfort zone and accomplish more than you ever thought possible.
Bee Dream Context
Think about how you felt during the dream too. Were you scared of the bees? Or were you fascinated by them? Your feelings will give you clues about what the dream means for you.
If you're scared of the bees in your dream, it could mean you're afraid of hard work. You're not lazy; you just don't know if you can handle the project. Remember, you don't have to be perfect. You may avoid something because you don't want to put in the effort, only to fail.
If you're fascinated by the bees in your dream, it means you admire their hard work and dedication. This dream is a sign that it's time to start working on your goals. Go after your dreams, whatever they might be!
What Does It Mean When a Bee Dies?
If you see a dead bee, it's a sign that something in your life is ending. This could be the end of a project, a relationship, or even a phase in your life. The symbolism applies in real life and in a dream context.
A dead bee may also symbolize lost potential. Perhaps you gave up on a goal too soon. Alternatively, you may have let someone else talk you out of pursuing your dreams. If this is the case, it's time to start working on regaining that lost potential.
Finally, a dead bee may also be a warning to watch out for someone upset with you. They might have ulterior motives for being nice to you. Don't let this warning make you paranoid. But instead, be wise about who you share your heart with.
Spirit Animals Similar to the Bee
There are a few spirit animals that are similar to the bee. Making friends with one of these compatible energies will set you up for success.
Similar spirit animals:
Like the bee, the butterfly is a symbol of transformation. It's also a sign of new beginnings. The dragonfly is another spirit animal that represents change and growth, just like the bee. It can also be a symbol of good luck. Finally, the ladybug is a sign of good fortune. It's also often seen as a protector of love and relationships.
Spirit Animals Opposite of the Bee
What animals present a challenge to the bee spirit animal? A few animal energies have trouble seeing eye to eye with bees.
Opposing spirit animals:
- Bear
- Wolf
- Tiger
- Snake
- Scorpion
Bears and bees both like honey, but that's all they have in common. Bears are loners, while bees are social creatures. Bears are also known to be fierce and aggressive, while bees are gentle and timid.
The wolf is another animal that doesn't get along well with bees. Wolves like to take their time, while bees are always moving quickly.
Finally, the tiger, snake, and scorpion represent danger and death. These energies can be a threat to the bee spirit animal. But that doesn't mean they're enemies. If you meet someone with a scorpion spirit animal, they can teach you a lot about stillness.
Final Thoughts on Bee Spirit Animal Meaning
The next time you see a bee, take a moment to connect with its energy. What qualities does this bee have that you can learn from? And, what qualities does this bee have that you need to work on? Use the bee as a guide to help you grow and develop into the best version of yourself.
Ultimately, bees are a symbol of new beginnings, hard work, and wisdom. They're a reminder that even the smallest creatures can have a big impact. The bee spirit animal has much to teach us about hard work, cooperation, and enjoying the sweetness of life. They remind us to focus on goals and to keep working hard. Anything is possible when you stay on track.
Which God sends bees?
As you see, bees have had many different representations in different mythologies and cultures. One such interesting example is how the Muses of Greek Mythology used bees to help employ their domains of science, art, and poetry. Specifically, the Muses commanded bees to help humans gain the ability of eloquence and other types of smooth talking. The little insects imparted and plastered honey on their lips which improved how their voices sounded. Talk about a sweet voice!
Bees' honey was also used to improve the musical quality and ability of singers. Believe it or not, they even helped to bring about increased charisma and even the effectiveness of politicians.
Many more depictions of bees affecting stories in mythology can be seen in the writings of Vergil, Sappho, Lucan, Plato, and Homer throughout both poetry and philosophy.
The photo featured at the top of this post is © iStock.com/William Jones-Warner
Thank you for reading! Have some feedback for us? Contact the AZ Animals editorial team.
- Ted Andrews (2022) Animal-Speak. Minnesota, US: Llewellyn, 1997.
- Dawn Brunke (2022) Spirit Animal Directory. New York, NY: Chartwell Books, 2015.
- Dr. Steven Farmer, Available here: https://drstevenfarmer.com/blog/


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On The Farm Memory Card Game.
Pig goes with Pig… I WIN!
Help your children build memory skills in a fun, innovative way by matching colourful, realistic photographs. No reading is required, but cards include the name of the picture to promote early sight reading. These cards can also be used to work on early matching skills and can be used in conjunction with other sets to work on sorting by category.


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When it comes to sex, the more advice, the better, right? Even if you think you know everything there is to possibly know when it comes time to being intimate with someone in the bedroom — or your sex location of choice — there's always more to learn about sex.
"Feeling comfortable talking about sex is important," Rachel Needle, Psy.D., licensed psychologist and certified sex therapist in West Palm Beach, Florida, tells Bustle. "It can lead to closer relationships, increased trust, and better sexual health. Talking to friends and others about sex can also be educational, and allows you to learn from each other. Sharing sex tips and techniques can help expand your sexual repertoire, encourage you to try new things, increase your comfort level, and become a better lover."
And, when it comes to sharing sex tips, there's no such thing as oversharing, as you're about to see. Perhaps you do some of the below already, or you'll get some #sexinspo for later. Below, 11 millennial women reveal the sex tips they swear by. Whether they learned these tips from friends, from magazines, or through first-hand experience, here's the great sex advice they want to share with others — like you.
Amber, 29
"Don't think about how [oral sex is] going; think about how much they must be enjoying it and you're sure to do a great job."
Rachel, 32
"Never do something you don't want to do! Listen to your instincts, always!"
Sarah, 31
"Stay in the moment is the best advice I can give someone. The more you're thinking about it — what sex position to do next or how your partner is feeling — the less into it you are, which will make it less enjoyable."
Emma, 30
"Spice things up. I think the death of a sex life with someone is routine and boredom. If your partner's not varying things up, someone has to, so always have some surprise move in your head or an accessory, like a blindfold, nearby!"
Sasha, 25
"My sex tip is: Don't get too caught up in having an orgasm. Enjoy the experience."
Tasha, 33
"Two words: More foreplay.... This can include everything from slowly caressing your partner (me!) to nibbling their neck or stomach... you get the picture!"
Reanne, 28
"When it comes to love and sex, your pleasure is every bit as important as your partner's. So make sure you get yours, girl. Tell him/her what you need. Don't be afraid to ask for what you want in bed. You know that old saying, 'you can't pour from an empty cup'? It rings true for intercourse, too." ;)
Lisa, 31
"Don't fake an orgasm. Not only are you sending the wrong message that something is working for you when it's not, you're missing out on your owl pleasure. Women are conditioned to be people-pleasers, and when you get to the point of faking it routinely you're missing out on what you deserve. And if you're with the right partner, they definitely don't want that happening."
Obviously, "best" has different definitions for different people, and there's no one-size-fits-all answer for what makes the best sex. However, if you try some of the above that resonate with you, as well as other sex tips you've gotten, you should be well on your way to a more satisfying sex life.


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In den vergangenen zehn Jahren sind via e-codices ca. 15% der Schweizerischen mittelalterlichen Handschriften digitalisiert worden. Das entspricht 1'500 Manuskripten, ungefähr 1'300 aus dem Mittelalter. Für über 350 Handschriften wurden in Zusammenarbeit mit Fachpersonen neue wissenschaftliche Beschreibungen erstellt (via Büro DLB bzw. e-codices newsletter 3/2016).
Update vom 1.4.2016: e-codices wird in «The Scout Report — Volume 22, Number 13» erwähnt:
«Sometimes one of the best uses of new technology is to allow us to enjoy old technology, and the e-codices Virtual Manuscript Library of Switzerland is designed to do just that. The mission of e-codices «is to provide free online access to medieval and early modern manuscripts from public and church-owned collections as well as from numerous private collections» in Switzerland. The digital reproductions are linked with corresponding scholarly descriptions, so that visitors to the website can enjoy images of 1,500 manuscripts, while simultaneously reading scholarly commentary. In addition, e-codices has made a commitment to using open source software and open standards. The Mirador viewer is provided for side by side comparison of pages, and an e-codices app is available for iPhone and iPad. In the spirit of open source, a wealth of technical and structural information for other digital library implementers can be found in the About section of the site. There's a person index and an index of annotations, and broad searches can be refined by a large number of facets, such as library/Collection, Country of origin, and whether the manuscript is illuminated or not.»


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Men's and women's hockey teams win Olympic test event in Tokyo.
Tokyo: The Indian men's as well as women's hockey teams won the Olympic Test event here on Wednesday, beating New Zealand 5-0 and Japan 2-1 respectively.
In the men's final, captain Harmanpreet Singh (7th minute) set the ball rolling before Shamsher Singh (18th minute), Nilakanta Sharma (22nd minute), Gursahibjit Singh (26th minute) and Mandeep Singh (27th minute) scored for India at the Oi Hockey Stadium here.
India had lost 1-2 to New Zealand earlier in round robin league-stage.
"We played very well. We managed to score our opportunities at the start of the game," Harmanpreet said after the triumph.
"I think the final was always going to be tough, we lost to New Zealand earlier. But we had been having practice sessions after that and worked on our mistakes to win today," he added.
Both teams began the match on a cautious note by turning over the ball in the mid-field. India won a penalty corner in the seventh minute, but couldn't capitalise on the opportunity.
However, skipper Harmanpreet didn't miss out on a re-awarded penalty corner. He executed a perfect dragflick to put India in the lead.
The Indian team continued to hold possession and put tremendous pressure on the New Zealand defense as they ended the first quarter at 1-0.
Shamsher scored India's second goal through a penalty corner in the 18th minute.
New Zealand managed to make only two circle entries in the second quarter as the Indian team scored three more goals.
Nilakanta found the back of the net in the 22nd minute before Gursahibjit and Mandeep scored in quick succession.
Vivek Prasad intercepted the ball brilliantly to assist a goal for Gursahibjit and Mandeep converted a penalty corner just before the half-time whistle.
After an action-packed first half, the intensity dropped from both sides. New Zealand tried to make a few inroads in the third quarter as they took a shot in the 37th minute which went wide of the post.
Jarmanpreet Singh saved a penalty corner in the next minute as India and New Zealand played out a goalless quarter but the former held the lead.
In the last quarter, India ensured they stayed in the lead and didn't allow New Zealand to break through their defense throughout the match. India's attacking approach in the match paid off as they walked off the pitch as winners of the competition.
Women rap hosts
The women's team did well too, with Navjot Kaur and Lalremsiami leading the side to victory.
Navjot Kaur (11th minute) opened the scoring to put India ahead but the lead was neutralised within a minute as Minami Shimizu (12') scored for the hosts.
Lalremsiami (33rd minute) struck the winning goal for India.
India dominated the first 10 minutes, and finally managed to find the breakthrough when Forward Navjot kept her nerves under pressure and produced a fine finish in front of the goal.
However, the next minute saw Japan strike back immediately with a well-crafted field goal which was put into the back of the net by Shimizu to make it 1-1.
Forward Lalremsiami slotted the ball into the back of the net to make it 2-1 for India.


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Born and raised in St. Cloud, Nick has over a decade of experience in the hospitality industry, running bars and restaurants as well as a liquor store in Central MN. He is a Certified Sommelier and has built award-winning restaurants, craft beer bars, and wine bars. Nick has become an authority on food and beverage pairing. His education also helped him develop his sensory perception skills and learn the many styles of beer and flavor profiles. His experience in the food and beverage industry helps ensure our beer selection is both comprehensive and unique.
Living in St. Cloud all his life but traveling to the great "Beervana's" of the U.S., Matt is an avid home brewer who set out to craft the perfect beer. He has a decade of sales experience and has an unmatched passion for craft beer. Matt is an avid outdoor enthusiast who prides himself on giving back to the community. Through passion, experience, and dedication, Matt helps ensure our quality beer reflects our mission and our passion.
A St. Cloud native, Chris cut his teeth in the professional brewing industry with O'Hara Brothers. He stayed with the brew system through the transition to McCann's and most recently brewed at Third Street Brewhouse in Cold Spring. Chris has unmatched sensory perception, which we believe is important to ensure each batch of beer produced is to the best of our abilities. To Chris, fast-paced growth is not as important as consistency and quality, so day in and day out, you can find Chris sampling our beer at each stage of production. His experience, sensory perception, and knowledge of the taste revolution is key to brewing world-class craft beer.


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Elementary and Middle School
VPK-8th grades Enrollment for 2023-24 School Year
Are you considering SCCS for your child's school year and want more info? Check out the links below. SCCS is currently enrolling for grades VPK – 8th for the 2023-24 school year. Openings are limited and enrollment is on first come, first served basis.
SCCS Ethics In Education Standards and Procedures
SCCS Reporting Professional Misconduct
Scholarships are available for families in need. The approval process can take several weeks so please let us know if you are in the application process and wish for your child to attend SCCS. Apply for a scholarship here: