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Across The River & Into The Trees Liev Schreiber Green Military Coat
Do you want to make an alluring addition into your wardrobe? Well we have launched the green colored coat in our latest collection that you can also give as a gift to your father or uncle. The outer fabric of this coat has fabricated from the high quality cotton fabric and the inner fabric has a soft viscose lining. Notch lapel style collar and buttoned with belted closure along with open hem cuffs are the features that will make this coat dynamic and dreamy. So what are you waiting for? Shop this elegant green colored coat now to make a unique and sophisticated addition into your wardrobe.


text: "She says, "I love the movement, the passion and the playfulness of spoken word poetry. At the same time, I believe that a poem should be thoughtfully crafted and complex enough that it bears reading and then re-reading. That the reader should get something new, understand or see something fresh, even after multiple readings. I try to combine the best of both worlds."

subset: commoncrawl


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Architect Charles Allerton Coolidge, FAIA, was a founding partner of the firm Shepley, Rutan & Coolidge in 1886. After graduating from Harvard University in 1881 with additional study in architecture at the Massachusetts Institute of Technology, Coolidge worked for H. H. Richardson before forming his own office. His firm would later undergo several name changes: Coolidge & Shattuck; Coolidge, Shepley, Bulfinch & Abbott; and Coolidge & Hodgdon. Coolidge was known for his design of academic buildings and libraries at Stanford, Yale, and Brown Universities; the hospital and medical schools at Vanderbilt University and the University of Chicago; and for the law and medical schools and Fogg Art Museum at Harvard University. He also designed the Art Institute of Chicago and that city's public library, and served as the consulting architect for Constantinople College in Turkey. He was a trustee of both the American Academy in Rome and the Art Institute of Chicago. For his work on the Paris Exposition of 1899, Coolidge was named a Chevalier of the French Legion of Honor. He was awarded an honorary doctorate of arts by Harvard University in 1906.
CFA Service:


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AFP warns of traffic infringement email scam
The Australian Federal Police has issued a warning about a traffic infringement email scam that is circulating around Australia.
THE AUSTRALIAN FEDERAL POLICE (AFP) has issued a warning about an email scam that is circulating around Australia. The bogus traffic infringement has been supposedly issued by the AFP requesting payment for an AFP Traffic Infringement Notice.
The scam email initially asks the recipient to pay an 'AFP fine' of approximately $150. If links within the message are clicked, the recipient's computer is infected with malware which renders it inoperable. At that point ransomware is activated where the recipient is asked to pay thousands of dollars to reactivate their computer.
AFP National Coordinator Cyber Crime Adrian Norris said anyone who receives the email should delete it immediately.
"This email has taken off widely and looks legitimate, and many people have been compromised, so I would urge people to be vigilant," Superintendent Norris said.
"The AFP never sends out traffic infringement notices via email, so if you have received an email that purports to be from the AFP and have doubt about its authenticity, do not make a payment or provide personal details.
"This email scam looks legitimate and contains AFP branding and may be from email addresses like TrafficInfringement.afp.org, TrafficInfringement.afp.com. or similar.
"Payment of this Traffic Infringement Notice will not go to the AFP, your money will be going to scammers overseas."
Practical Motoring editor, Isaac Bober received this scam email this morning and says, "it's a timely reminder for members of the public to ensure their anti-virus software is up to date and that they should think before clicking any link".
Members of the public who believe they have been a recipient of the fraudulent email should report it to the Australian Cyber Crime Online Reporting Network (ACORN) immediately via http://www.acorn.gov.au/ or to ScamWatch http://www.scamwatch.gov.au


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Ghanbari Encourages Fire Departments to Apply for MARCS Grant
State Rep. Haraz N. Ghanbari (R-Perrysburg) encourages local Wood County fire departments to apply for the Multi-Agency Radio Communication System (MARCS) grant that is now accepting online applications. Ghanbari pushed for funding this grant within the state budget that passed in the General Assembly over the summer.
"As a member of the House Finance Committee, I directly fought to include significant funding for these MARCS grants in order to assist our fire departments' communications and technology systems so that they can efficiently and effectively respond to emergency situations," said Ghanbari.
The grant funding is available through the Ohio Department of Commerce Division of State Fire Marshal. Ghanbari helped secure a total of $3.5 million that was earmarked for the fire department grants to be used for MARCS.
Additionally, as a big and consistent proponent of public safety, Ghanbari also secured $500,000 locally for the Bowling Green MARCS Tower within the budget bill.
Eligible participants that apply and receive funding can use it to purchase systems, equipment, or services that are a part of MARCS operated by the State of Ohio to provide fire protection services.
Fire departments can apply for the grant here: https://apps2.com.ohio.gov/fire/Grants/ApplicationMARCS.aspx.


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Wonder kid at WWDC
Anvitha Vijay, a nine-year-old Indian-origin wonder girl from Australia, has become the youngest app developer at WWDC 2016, Apple's annual developer conference, with her apps for children, according to a report by Fortune. At WWDC she will get an opportunity to rub shoulders with the top award-winning Apple developers from around the world.
Tim Cook singled out Anvitha at WWDC
Anvitha was singled out by Apple CEO Tim Cook as one of the best, brightest, and youngest app developers in the world. Tim Cook used his keynote speech at WWDC in San Francisco to highlight Apple sponsored 350 students invited to Apple's event, while showering praise on the youngest participant Anvita.
Out of 350 recipients of Apple scholarship, 22% are women
Every year Apple gives away free tickets to hundreds of students to attend the WWDC. Out of 350 lucky recipients this year, 120 are students under the age of 18. The number of women who applied for the scholarship tripled this year and 22% of scholarship winners are women, which is an increase from last year.
Anvitha taught herself coding, watching YouTube videos
She taught herself how to code when she was just seven, using YouTube and online videos. Anvitha wanted to make an app that would help her toddler sister to identify animals. Two years later 'Smartkins Animals,' an educational app aimed at small kids made it into Apple's App Store.
The iOS app helped her to win one of the 350 Apple scholarships for young coders to attend WWDC. Her interactive Smartkins Animals app helps kids identify over 100 animal names and sounds. Her next app, Smartkins Rainbow Colors, is designed to help young kids learn about colors.
She won Student Edge $10,000 Media kit Prize at the OzApp awards in Australia
This Mount View Primary School student from Melbourne designed and prototyped the app GoalsHi, over the summer holidays, for which she won Student Edge $10,000 Media kit Prize at the OzApp awards in Australia in 2015. Anvitha's mother Buvana Vijay, a business adviser with IBM is the inspiration for her daughter.
Her father is a capital projects manager for APA Group.
Works and thinks like a seasoned professional
Anvitha is already focused on her next app, which will set the goal of empowering young girls and help them develop confidence in the classroom. She used Apple's Swift coding language to develop the second app, and now keen to get her hands on Swift Playground, Apple's new app announced at WWDC, which teaches children to code. Describing her coding experience, the nine-year-old said like a professional developer, that it required a lot of hard work to turn the idea into an app and processes like prototyping, designing, wireframing, coding, and testing.
Steve Jobs is her role model
Apple co-founder and former chief executive Steve Jobs is Anvitha's role model. Like Steve Jobs, she also wants to be one of the top entrepreneurs in the world. She is also like any other normal kid on the block, who likes to play with her friends and roller-skate.


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"Q" as a Sinogram and a Sinitic morpheme
« previous post | next post »
Jules Quartly (appropriate surname!) has an informative article on this subject in Taiwan Business TOPICS, "The True Story of Q" (1/21/20) — a takeoff from the most famous Chinese short story of the 20th century, "The True Story of Ah Q" (Ā Q Zhèngzhuàn 阿Q正傳 / 阿Q正传; serialized 12/4/21-2/12/22, published 1923). Toward the end of his article, Quartly quotes extensively from this post of mine: "Is Q a Chinese Character?" (4/15/10). In the rest of the article, however, he offers a panoply of his own and others' insights about just what "Q" signifies as a mouthfeel in Taiwan.
Here follow some delicious, selected passages from Quartly's article:
A decade or so ago, the restaurant reviews by local writers in the Taiwan newspaper where I was features editor often dwelt at great length on the chewy nature of certain dishes.
To vary the wording, the reviewers resorted to ever more tortuous ways to describe the texture of the delicacy in question. Among the adjectives plucked from the pages of Roget's Thesaurus were "leathery," "gristly," and "globular" – terms that reviewers in Western publications might only apply with malice aforethought.
As a then relatively recent arrival in Taiwan, I sensed that something was clearly going on that I was sadly ignorant about. When I asked the authors about their perceived need to describe the essential "bounciness" or "springiness" of food in such detail, they responded that it was all about "Q" – the degree of chewiness of a given food and how it feels against the teeth and tongue.
Q is considered one of the keys to good food in Taiwan, on a par with taste, color, and consistency. Given how frequently Q is referred to on menus and in general conversation, it appears that Taiwanese appreciate mouthfeel or texture more than most people. The Italians do have al dente, which literally means "to the tooth" and describes pasta or rice that is slightly undercooked, but it's not easy to find other examples.
Making his own attempt to explain Q, journalist George Liao says: "In Taiwanese, when we say something is very 'Q,' we mean it tastes good-chewy, which is usually associated with being delicious. Some snacks have to be chewy to be delicious, and when that quality comes out, we usually praise the food by saying it's very Q. Sometimes it also means sticky, as some Chinese or Taiwanese foods need to be sticky to be delicious, such as mochi" (the Japanese-style confectionery made with glutinous rice).
So, is Q now a Chinese character? Robert Matthews, a former university instructor, alludes to a rare Chinese character, 飲蚯, pronounced kiu in Mandarin. It is a fusion of the characters yin (drink, 飲) and qiu (sip, 蚯)… [VHM: Question to the assembled readership — is that in Unicode or otherwise available online?]
In reply to Quartly's question, there's no doubt that Q has been part of the Chinese writing system for at least nearly a century.
For me, the quintessential "Q" texture is that of the chewy, round balls in boba (also known as pearl milk tea or bubble milk tea; zhēnzhū nǎichá 珍珠奶茶, bōbà nǎichá 波霸奶茶) that you swish around in your mouth before biting them and slurpily swallowing them down. One of my favorite desserts, which I loved long before I started drinking bubble tea (fairly recently), is tapioca the way my sister Heidi and I prepare it — with meringue generously folded in and decadently rich whipped cream piled on top served with sugared cut strawberries. Unfortunately, for it to be super good, you need big pearl tapioca, and with boba having taken the world by storm, it has become increasingly difficult to find big pearl tapioca. (I realize that it is still available through specialized sources, but you have to try harder to get it than in the past.)
Selected readings
"cactus wawa: the strange tale of a strange character" (11/1/14)
"Cactus Wawa revisited " (4/24/16)
"Bubble tea blooper " (9/28/17)
[h.t. John Rohsenow]


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Child Education in Dominican Republic
The Dominican Republic is located in the Caribbean Sea and shares the island of Hispaniola with Haiti in the west. The country has a tropical climate and is located in the middle of a hurricane belt. Therefore, the Dominican Republic has major problems with natural disasters. After several decades of economic decline caused by political unrest, the country has now stabilized, but is still struggling with widespread corruption and low confidence in the authorities.
Domestic violence is widespread and women and children are particularly vulnerable. Illegal trafficking, drug trafficking and organized crime also pose a threat to the development and safety of children and young people.
The past year has been challenging for the Dominican Republic. As many as three major hurricanes have ravaged the country, causing floods, food shortages and health problems. In addition, public institutions have become more unstable since the election and this has affected cooperation between the authorities and civil society organizations. The economy has strengthened, but still 41 percent of the population lives in poverty and almost 10 percent in extreme poverty.
Some results from the past year
Plan International works to strengthen children's and young people's right to survival, development, protection and participation. Over the past year, we have, among other things, worked constructively with the authorities to improve children's rights. Through education and advocacy work, we have fought together with girls to ensure that their rights are met. In this work, 5,541 inhabitants have received training in gender equality.
Security and protection
Young people change the marriage law
I had to get away from my family. They have beaten me, they beat me with sticks and did not let me go to school. I thought that by getting married I would be able to live in a safe house, be able to eat, sleep and go out. But marriage was just the start of a new hell.
Shaquira, 15 years
Shaquira is just one of many girls in the Dominican Republic who have been divorced as children. Through the advocacy campaign # 18nomenos, Plan International, together with hundreds of girls and boys, has been part of changing the marriage law and removing loopholes in the law that allow boys and girls to get married before the age of 18.
The opportunity to influence
Michelle and Sara took over
I called on the President to ratify the law, which states that only persons over 18 years of age can enter into marriage.
International Girls' Day falls on October 11 every year. In 2017, thousands of girls from 60 countries marked the day, taking over hundreds of leadership positions to raise girls' rights and potential. One of all these girls was Michelle who got the chance to speak in front of an entire assembly of decision makers about the importance of changing the marriage law in the Dominican Republic. Another girl, Sara, took over the role of president and helped President Medina declare October 11 a national girls' day.
Dreaming of your own home
Yolinda had three children when she was young. Now she is divorced and well on her way to earning her own income through organic farming. She received her education through Plan International.
Yolinda is 24 years old and has three children. Since her divorce, she has been living with her parents in Enriquillo Barahona in the southwestern Dominican Republic. She shares her old bedroom with her three children and is dependent on her parents' and boyfriend's income. She herself dreams of becoming a pediatrician so that she can take care of the children and help them to a better life.
– I want my children to finish school and I want them to have clean clothes and enough food to eat, says Yolinda.
Yolinda came in contact with Plan International's project "So my dreams" which is about giving young people knowledge about agriculture. In the project, she has learned about organic farming and food production with the environment in mind.
– I felt that this was an opportunity I did not want to miss, says Yolinda.
Yolinda never finished high school and now she does not have the financial opportunities to go to school.
– If I like school? Of course! It's just that sometimes it just does not work. I got married very young, and it limited me because I had to take care of the children and help them move forward in life instead, she says.
Now she wants to change her own life. With the education she received, Yolinda believes that she could earn her own income, instead of being dependent on others. Her dreams for the future are humble, she intends to work hard for a better life without poverty – and she dreams of her own house.
Dominican Republic
Capital: Santo Domingo
Population: 10 million
Life expectancy: 74 years
Infant mortality rate: 26 per 1000 births
Proportion of children starting school: 86.5%
Literacy: 90.9%
Proportion of women in parliament: 26.8%


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I found out I won second place in an idea contest at work and am being granted ~$400 to spend at Best Buy (the web site for any unfamiliar). Originally, I believe the second place prize was going to be an iPad, but it looks like they've decided to just allow me to pick something in that ballpark price range.
I suspect there are a fair amount of tech saavy folks on LW and thought I'd inquire as to whether you've purchased a device or accessory (or anything from Best Buy-ish stores) that has brought you an increase in efficiency, usefulness, pleasure, etc. The idea of a tablet appeals to me, but I'm not entirely sure what I'd do with it. Also, a data plan is not in my budget, so many typical uses are not applicable in my case.
Anyway, just hoping to probe some collective knowledge about this decision. I'm not very knowledgeable on devices and/or how longer term usage/satisfaction matches expectations or even money spent.
Thanks for any assistance!


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Columbia, SC – Scott and Company LLC is pleased to announce that Kim Hearn Johnson, CPA has been approved for her license as a Certified Public Accountant in South Carolina.
Johnson has been with the firm since 2017, when she joined as a senior accountant in the Tax and Advisory Services department. In addition to being designated as a CPA, she is also an Enrolled Agent (EA), certified to represent taxpayers before the Internal Revenue Service.
"We are all very proud of Kim for her achievement," said Don Mobley, CPA, Managing Member. "Her hard work and dedication have certainly paid off. This designation will propel both her career, and the service she provides to her clients."
Johnson holds a Bachelor of Science in Accounting from the University of South Carolina and a Bachelor of Science in Computer Science from DeVry University. She is currently a member of the American Institute of Certified Public Accountants (AICPA) and the South Carolina Association of Certified Public Accountants (SCACPA).
Scott and Company LLC provides a comprehensive range of tax, assurance, small business and specialized consulting services to clients across the state. With clients ranging from individuals to multi-state and international organizations, the firm has particularly deep expertise in serving closely-held businesses and their owners, as well as leaders in the healthcare, hospitality, real estate, government, manufacturing, professional services and non-profit arenas. The firm is an independent member of the BDO Alliance USA, providing talent and resources to clients through a network of thousands of skilled professionals in more than 400 independent alliance firm locations across America. Learn more online at www.scottandco.com.
SCBIZtv is part of the SC Biz News family, serving 100,000 high-level business execs throughout South Carolina. Click for more from SCBIZtv.


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Sunday, October 31, 2010
Federalism, Marriage, Perry and DOMA: Sanders on States Amicus Brief
Steve Sanders has posted an interesting commentary on the amicus brief filed by thirteen states in Perry v. Schwarzenegger, the Proposition 8 case now in the Ninth Circuit, which we last discussed here.
Sanders points to the inconsistency in the arguments in this amicus brief with the appeal in Commonwealth of Massachusetts v. HHS, the DOMA case in which the district judge agreed that DOMA conflicts with the Massachusetts' Tenth Amendment reserved powers. He writes that these 13 states are "unlikely to link arms with Massachusetts," because given "the choice between a consistent position in favor of states' rights over marriage, or a consistent position against recognition of same-sex marriages by any level of government, it is predictable that they will choose the latter."
The Tenth Amendment argument in the Massachuetts DOMA case also poses consistency issues for those relying on the Tenth Amendment in the context of challenges to Arizona's immigration law, SB 1070.
October 31, 2010 in Family, Federalism, Sexual Orientation, Tenth Amendment | Permalink | Comments (1) | TrackBack (0)
Saturday, October 30, 2010
Arizona SB1070, Legislative Process, and Constitutional Consequences
As so-called "copycat" legislation of Arizona's SB 1070 is being contemplated by 25 other states, some provocative reporting from NPR discusses the genesis of such laws. In part one of the report, NPR states that it "spent the past several months analyzing hundreds of pages of campaign finance reports, lobbying documents and corporate records. What they show is a quiet, behind-the-scenes effort to help draft and pass Arizona Senate Bill 1070 by an industry that stands to benefit from it: the private prison industry." In part two, NPR continues its reporting on American Legislative Exchange Council, ALEC,and states:
Here's how it works: ALEC is a membership organization. State legislators pay $50 a year to belong. Private corporations can join, too. The tobacco company Reynolds American Inc., Exxon Mobil Corp. and drug-maker Pfizer Inc. are among the members. They pay tens of thousands of dollars a year. Tax records show that corporations collectively pay as much as $6 million a year.
With that money, the 28 people in the ALEC offices throw three annual conferences. The companies get to sit around a table and write "model bills" with the state legislators, who then take them home to their states.
Again, NPR focuses on SB1070 and similar legislation, as the NPR image below illustrates.
This reporting raises several constitutional issues. First, and perhaps most obviously, are the First Amendment issues regarding lobbying, disclosure, and campaign finance, especially from the perspective of the public's "right to know." Second, the "government interests" prong of analysis in constitutional challenges is implicated. Might a court reject a government's proferred statement of interest in favor of an unarticulated - - - and illegitimate - - - interest such as improving business for a private corporation?
October 30, 2010 in Campaign Finance, Current Affairs, Due Process (Substantive), Equal Protection, First Amendment, Fourteenth Amendment, Interpretation, News, Speech | Permalink | Comments (0) | TrackBack (0)
Thursday, October 28, 2010
O'Donnell, Jefferson on Separation of Church and State
Republican Senate Candidate Christine O'Donnell's 2008 primary campaign manager Jonathon Moseley this week offered a $1,000.00 reward to anyone who could find the phrase "separation of church and state" in the Constitution. (Thanks to Carrie Beth Clark for the tip.) The offer comes on the heels of O'Donnell's statement in her debate last week with Democrat Chris Coons that the First Amendment contains no such phrase and requires no such separation.
The phrase, of course, comes from Thomas Jefferson's January 1, 1802, letter to the Danbury Baptist Association in response to that group's address congratulating him on his election as president. The Library of Congress, with the help of the FBI, analyzed Jefferson's handwritten draft of the letter, including Jefferson's edits, and featured the letter in a 1998 exhibit on church and state. The LoC gives us an historical context here. The text of Jefferson's final letter is here; the unedited text is here.
From the LoC:
Jefferson revealed that he hoped to accomplish two things by replying to the Danbury Baptists. One was to issue a "condemnation of the alliance between church and state." This he accomplished in the first, printed, part of the draft. Jefferson's strictures on church-state entanglement were little more than rewarmed phrases and ideas from his Statutes Establishing Religious Freedom (1786) and from other, similar statements. To needle his political opponents, Jefferson paraphrased a passage, that "the legitimate powers of government extent to . . . acts only" and not to opinions, from the Notes on the State of Virginia, which the Federalists had shamelessly distorted in the election of 1800 in an effort to stigmatize him as an atheist. So politicized had church-state issues become by 1802 that Jefferson . . . considered the articulation of his views on the subject, in messages like the Danbury Baptist letter, as ways to fix his supporters' "political tenets."
Here's what Moseley had to say:
Jefferson was not in the Constitutional Convention that wrote the U.S. Constitution. . . . Jefferson was also not a member of the first U.S. Congress that wrote the Bill of Rights, either. . . .
The law clerks over in the U.S. Supreme Court should stop reading people's letters and re-read the U.S. Constitution itself.
October 28, 2010 in Current Affairs, Establishment Clause, Free Exercise Clause, News, Religion | Permalink | Comments (1) | TrackBack (0)
Wednesday, October 27, 2010
Sixth Circuit Holds Teacher Has No First Amendment Right in Assignments
Shelley Evans-Marshall taught English and Creative Writing in high school, to ninth, eleventh and twelfth graders. She assigned Herman Hesse's Siddhartha. She assigned Ray Bradbury's Fahrenheit 451 and to explore that book's theme of government censorship, she developed an assignment based on the American Library Association's "banned books."
Some parents protested about the book and assignment choices, the principal disapproved, and Ms. Evans-Marshall was terminated.
In its opinion the Sixth Circuit has rejected the teacher's First Amendment challenge. Applying Garcetti v. Ceballos, the court found that the teacher could not "overcome Garcetti": "When government employees speak "pursuant to their official duties," Garcetti teaches that they are "not speaking as citizens for First Amendment purposes."
The court emphasized how Garcetti controls rather than Pickering v. Board of Education:
When Pickering sent a letter to the local newspaper criticizing the school board, he said something that any citizen has a right to say, and he did it on his own time and in his own name, not on the school's time or in its name. Yet when Evans-Marshall taught 9th grade English, she did something she was hired (and paid) to do, something she could not have done but for the Board's decision to hire her as a public school teacher.
Opinion at 11. As for any "academic freedom" argument, the panel opined that such a concept is limited to universities and does not extend to high schools. Opinion at 16.
October 27, 2010 in Books, First Amendment, Speech | Permalink | Comments (0) | TrackBack (0)
Mississippi Court Allows Personhood Initiative To Appear on Ballot
Mississippi Circuit Court Judge Malcolm Harrison ruled yesterday that a ballot initiative to define "person" did not violate a state constitutional provision that prohibits the use of initiatives to modify the state Bill of Rights. (Clarionledger.com reports here.)
The initiative, Initiative Measure 26, would amend the state constitution to define the word "person" as follows:
Section 33. Person defined. As used in this Article III of the state constitution, "The term 'person' or 'persons' shall include every human being from the moment of fertilization, cloning, or the functional equivalent thereof."
The measure would add Section 33 to the Mississippi Constitution Bill of Rights (Article III of the state constitution).
But Section 273(5)(a) of the constitution prohibits the use of the initiative to amend the state Bill of Rights:
(5) The initiative process shall not be used . . . [f]or the proposal, modification or repeal of any portion of the Bill of Rights of this Constitution.
Thus plaintiffs in the case argued that the initiative was unconstitutional. Judge Harrison disagreed. In a remarkably short order, apparently dodging the plaintiffs' constitutional claim, he wrote (without citation):
Plaintiffs carry a heavy burden in attempting to restrict the citizenry's right to amend the Constitution. Initiative Measure No. 26 has received more than the required amount of signatures to be placed on the ballot and the Constitution recognizes the right of citizens to amend their Constitution. The Court finds plaintiffs have not met their burden.
The order's analysis seems surprising for a variety of reasons, not least of which this: Subsection (5)(a) is pretty clear; and the Mississippi Supreme Court and state attorney general seem to think that other, similarly clear subsections in Section 273 basically mean what they say.
The case is likely headed to the Mississippi Supreme Court.
October 27, 2010 in Comparative Constitutionalism, Elections and Voting, News, Recent Cases, State Constitutional Law | Permalink | Comments (0) | TrackBack (0)
Court Conclusions of Unconstitutionality and Government Decisions to Appeal
The Obama DOJ's footnote one in the Emergency Motion appealing the district judge's injunction of the military's "don't ask, don't tell" policy states the DOJ has a "longstanding practice of defending the constitutionality of federal statutes." But is that really true?
In an excellent column published today, Tony Mauro thinks not. He contends that the DOJ has declined to defend the constitutionality of a federal statute "at least 13 times" since 2004. Indeed, Mauro relates that as recently as June, the Obama DOJ decided not to appeal the D.C. Circuit's opinion in SpeechNow.org v. FEC that declared unconstitutional two provisions of the Federal Election Campaign Act of 1971 limiting contributions to political committees. Mauro also provides some other examples that are staples of ConLaw: Buckley v. Valeo (1973) and INS v. Chadha (1983).
Additionally, the stated (if untrue) DOJ policy to defend is in contrast with recent decisions in some states not to defend a statute. Florida, for example, recently chose not to appeal a decision that its homosexual adoption ban was unconstitutional. In California, the Governor and the Attorney General both chose not to defend Proposition 8 in a challenge to its constitutionality, and then chose not to appeal the judge's decision.
Meanwhile, the Obama DOJ has filed its notice of appeal of the district judge's ruling that section 3 of the Defense of Marriage Act, DOMA, is unconstitutional.
October 27, 2010 in Courts and Judging, Current Affairs, History, News, Sexual Orientation | Permalink | Comments (0) | TrackBack (0)
Tuesday, October 26, 2010
Arizona Voter Identification Law Unconstitutional as Preempted by National Voter Registration Act
A Ninth Circuit panel opinion today, with retired Justice Sandra Day O'Connor sitting by designation, has declared Arizona Proposition 200 regarding citizenship identification for voting, invalid as preempted. Judge Sandra Ikuta begins her opinion for the majority of the panel with this description:
Proposition 200 requires prospective voters in Arizona to present documentary proof of citizenship in order to register to vote, Ariz. Rev. Stat. §§ 16-152, 16-166, and requires registered voters to present proof of identification in order to cast a ballot at the polls, Ariz. Rev. Stat. § 16-159. This appeal raises the questions whether Proposition 200 violates the Voting Rights Act § 2, 42 U.S.C. § 1973, is unconstitutional under the Fourteenth or Twenty-fourth Amendments of the Constitution, or is void as inconsistent with the National Voter Registration Act (NVRA), 42 U.S.C. § 1973gg et seq. We hold that the NVRA supersedes Proposition 200's voter registration procedures, and that Arizona's documentary proof of citizenship requirement for registration is therefore invalid.
The panel considered the preemption doctrine under Election Clause preemption rather than under Supremacy Clause preemption: "Because the Elections Clause empowered Congress to enact the NVRA," the preemption analysis under that Clause is applicable." The panel derived its approach from two cases 120 years apart: Ex Parte Siebold, 100 U.S. 371 (1879) and Foster v. Love, 522 U.S. 67 (1997).
Reading Siebold and Foster together, we derive the following approach for considering whether federal enactments under the Elections Clause displace a state's procedures for conducting federal elections. First, as suggested in Siebold, we consider the state and federal laws as if they comprise a single system of federal election procedures. If the state law complements the congressional procedural scheme, we treat it as if it were adopted by Congress as part of that scheme. If Congress addressed the same subject as the state law, we consider whether the federal act has superseded the state act, based on a natural reading of the two laws and viewing the federal act as if it were a subsequent enactment by the same legislature. With this approach in mind, we consider whether the NVRA and Proposition 200 operate harmoniously in a single procedural scheme for federal voter registration.
Opinion at 17643 (citations omitted). The panel concluded that the state law did not operate "harmoniously" with the NVRA.
Dissenting, Judge Alex Kozinski was highly critical of the majority, ending his own opinion by writing, "Few panels are able to upset quite so many apple carts all at once. Count me out." Dissenting Opinion at 17704. Kozinski's argument is that the panel has evaded the law of the Circuit and weakened the rules surrounding the law of the case. He argues that the panel is wrong not to take precedent seriously and wrong that the precedent it disregards was erronelously decided.
October 26, 2010 in Current Affairs, Elections and Voting, Fundamental Rights, Opinion Analysis, Preemption | Permalink | Comments (1) | TrackBack (0)
Monday, October 25, 2010
Kansas Court Extends Right to Counsel to Habeas Petition
The Kansas Court of Appeals (the state's intermediate appellate court) ruled last week in Merryfield v. Kansas that a person involuntarily confined in the Kansas Sexual Predator Treatment Program has a right to counsel under due process and equal protection in a habeas petition that is not subject to summary dismissal under state law.
Dustin Merryfield filed his habeas petition alleging that conditions of confinement were unconstitutional. He also requested court-appointed counsel for his petition. Under Kansas law, his petition was not subject to summary dismissal. The Court of Appeals therefore remanded the case for a hearing and granted his request for counsel.
The court ruled that both due process and equal protection support a right to counsel. The court wrote that while Merryfield's habeas petition did not involve an initial deprivation of liberty (which triggers a constitutional right to counsel, as in In re Gault), it also did not involve a collateral attack on a criminal conviction (which does not trigger a constitutional right to counsel, as in Pennsylvania v. Finley). Merryfield's liberty interest was different, but sufficient:
His liberty interest is manifest, and he contends--with sufficient basis to warrant an evidentiary hearing--that the treatment provided to him is so ineffective that it could never give him the help he would need to regain his freedom. A person like Merryfield, who has been involuntarily committed in a civil proceeding that explicitly recognizes that the detention may be for a long-term period--more than a decade so far for Merryfield--must be entitled to the assistance of counsel in the resolution of such substantial claims. . . .
Merryfield's claim that the treatment program is so poor that he will never regain his liberty is certainly among the most significant that could be brought by a person confined under the Kansas program for treatment of sexually violent offenders.
Op. at 12.
The court wrote that equal protection also compels appointment of counsel. The court wrote that Kansas law provides court-appointed counsel for inmates who have been imprisoned after felony convictions when their habeas petitions cannot be summarily dismissed. If Kansas law provides counsel for this class, under equal protection it must also provide counsel for the similarly situated class that includes Merryfield.
For more on right to counsel in civil proceedings, check out the National Coalition for a Civil Right to Counsel.
October 25, 2010 in Due Process (Substantive), Equal Protection, Fourteenth Amendment, Fundamental Rights, Procedural Due Process, Recent Cases | Permalink | Comments (0) | TrackBack (0)
Courtroom Spectator Speech: Red Clipboards and Judicial Ethics
A Minnesota judge's reaction to a court monitoring project, WATCH, has been attracting attention from the likes of the ABA Journal and WSJ Law Blog, as well as the local City Pages.
The underlying incident involves members of WATCH appearing in court with "red clipboards," which the judge addressed in a rather lengthy statement read from the bench, including allegations that the red clipboards were were a "not very subtle threat to the judge," were "arguably ex parte communications to judges about pending cases," were "strongly partisan communications of a threatening nature to judges," and the "dynamic of the phenomenon is essentially the same" as "gang members allegedly using gang signs and insignia to influence or intimidate witnesses." This is according to the Board of Judicial Standards of Minnesota's Complaint. The judge's Response specifically raises the question of spectator speech: "The effect of spectator conduct and the concomitant effort to influence the proceeding" remains an "open question."
Thus, while the present controversy is in the context of a judicial ethics proceeding, it raises the important issue of speech acts by members of the public in the courtroom.
[image from WATCH website via]
October 25, 2010 in Courts and Judging, Current Affairs, First Amendment, Speech | Permalink | Comments (0) | TrackBack (0)
Wednesday, October 20, 2010
Fed Independence, Fed Capture
Would the Federal Reserve do better to drop its independence and become (once again) more accountable to elected officials? Timothy Canova takes on this question in the current issue of The American Prospect. He concludes that a period of Fed accountability during the 1940s, under Chair Marriner Eccles, resulted in far more successful and coordinated monetary policy, independent from the financial sector.
Canova writes that during this period a more accountable, more transparent, and "socially neutral" Fed worked with the Office of Price Administration to accommodate congressional spending and borrowing priorities (and not, as now, to serve the interests of the financial sector by, e.g., buying up their toxic assets). As a result, interest rates did not rise, even though federal spending and borrowing were much higher than today (as a percentage of GDP). Why? Because, argues Canova, an accountable Fed bought government securities "in any amount and at any price needed to maintain the interest-rate pegs at Treasury." The net result: A Fed monetary policy that accommodated congressional fiscal policy that effectively dug us out of the Great Depression.
Canova suggests that Fed independence in 1951 opened up space for financial industry capture, a conclusion buttressed by a report last month from Reuters titled Cozying up to Big Investors at Club Fed. According to the Reuters report, there's a fast-moving revolving door between the Fed and the financial industry and "information flow sometimes goes both ways as Fed officials let their guard down with former colleagues and other close private sector contacts."
Canova concludes his piece with this paragraph:
Few economists ever learn this period in Federal Reserve history, which has been airbrushed from most mainstream texts, including Bernanke's own economics textbook. To the extent that the Eccles period is discussed at all, it is dismissed as an anomaly--which, sadly, it was. Today's new normal is a central bank captured by private financial interests that is pursuing an elite agenda of deregulation, fiscal austerity, and bailouts and bonuses for bankers. But as our nation's own history shows at one of America's finest hours, it doesn't have to be that way.
October 20, 2010 in Separation of Powers | Permalink | Comments (0) | TrackBack (0)
Ninth Circuit Grants Stay in Don't Ask Don't Tell
The Ninth Circuit has granted the DOJ Motion and issued an Order staying the district court's injunction (and refusal to stay the injunction) of the military's "don't ask don't tell" policy which the judge had declared unconstitutional:
This court has received appellant's emergency motion to stay the district
court's October 12, 2010 order pending appeal. The order is stayed temporarily in
order to provide this court with an opportunity to consider fully the issues
Appellee may file an opposition to the motion for a stay pending appeal by
October 25, 2010. To expedite consideration of the motion, no reply shall be filed.
October 20, 2010 in Current Affairs, Due Process (Substantive), First Amendment, Sexual Orientation | Permalink | Comments (0) | TrackBack (0)
Lawyering in the Age of Terror: Panel Discussion
In New York City, October 27, 2010:
October 20, 2010 in Conferences, Criminal Procedure, Current Affairs, Due Process (Substantive), Equal Protection, First Amendment, Foreign Affairs, Fundamental Rights, International | Permalink | Comments (0) | TrackBack (0)
Obama DOJ Appeals Denial of "Don't Ask Don't Tell" Stay to Ninth Circuit
Judge Phillips denial of the DOJ's motion to stay her injunction of the military's "don't ask don't tell" policy in Log Cabin Republicans v. US is being appealed by the DOJ in an Emergency Motion (with memo) to the Ninth Circuit filed today. District Judge Phillips original declaration of unconstitutionality is here.
The DOJ memo includes rather cursory constitutional arguments, mainly arguing the doctrine regarding granting a stay. One argument, however, rests upon the Ninth Circuit's opinion in Witt, essentially that the Ninth Circuit in Witt v. Department of Air Force, 527 F.3d 806 (9th Cir. 2008), remanded for the district court to determine whether the statute had been validly applied to the plaintiff, which "makes no sense if the Act is unconstitutional on its face." Thus the "district court's decision is thus inconsistent with controlling precedent, as well as with numerous appellate decisions upholding various applications of the statute." The district court in Witt recently ruled that Witt should be reinstated.
Footnote one on the DOJ Emergency Motion, as in the district court pleadings, seeks to distance the Obama Administration from "Don't Ask, Don't Tell," even as it seeks to have the policy reinstated by the Ninth Circuit:
The Administration does not support § 654 as a matter of policy and strongly
believes that Congress should repeal it. The Department of Justice in this case has
followed its longstanding practice of defending the constitutionality of federal
statutes as long as reasonable arguments can be made in support of their
[UPDATE here]
October 20, 2010 in Current Affairs, Fifth Amendment, First Amendment, Sexual Orientation | Permalink | Comments (0) | TrackBack (0)
Tuesday, October 19, 2010
Judge Phillips Denies Motion to Stay Order on "Don't Ask, Don't Tell"
In the latest round of Log Cabin Republicans v. United States, in which Federal District Judge has held the military's policy regarding "homosexuality" in the military unconstitutional, Judge Phillips has issued an Order denying the Government's Request to Stay.
Highlights from the Judge's six page Order include an implicit admonishment to the Government attorneys:
Turning to the circumstances present here, the Court first notes Defendants had an opportunity to, but did not, present any of the evidence or arguments now advanced before the injunction issued. When the Court issued its Memorandum Opinion on September 9, 2010, it set out a briefing schedule regarding the form of the injunction. Although Defendants objected to the issuance of the injunction and its scope, they provided no evidence regarding the alleged disruption or need to revise "dozens of policies and regulations," as described in the Declaration of Clifford L. Stanley ("Stanley Declaration") . . . . Furthermore, to the extent Defendants now submit evidence in the form of the Stanley Declaration, that evidence is conclusory and unpersuasive. It is belied by the uncontroverted evidence presented at trial regarding the Don't Ask, Don't Tell Act's effect on military readiness and unit cohesion.
Order at 2-3.
On the "public interest" prong of the stay analysis, the Judge rejected the Government's argument regarding the status quo:
The Court's analysis of the public interest is not so narrow . . . the evidence at trial showed that the Don't Ask, Don't Tell Act harms military readiness and unit cohesion, and irreparably injures servicemembers by violating their fundamental rights. The public has an interest in military readiness, unit cohesion, and the preservation of fundamental constitutional rights. While Defendants' interests in preventing the status quo and enforcing its laws are important, these interests are outweighed by the compelling public interest of safeguarding fundamental constitutional rights.
Order at 6.
For the moment, the military's "don't ask don't tell" policy cannot be enforced. News outlets, such as SF Chronicle, WaPo, WSJ, USA Today, and CNN report that recruiting offices are refraining from asking about sexual orientation and discharges on the basis of sexuality have ceased.
[UPDATE here]
[image: Lt. Dan Choi advocating for repeal of military policy, via]
October 19, 2010 in Current Affairs, Fifth Amendment, Fundamental Rights, News, Sexual Orientation | Permalink | Comments (0) | TrackBack (0)
Chemerinsky: A Conservative Assault on the Constitution
Erwin Chemerinsky released his new book, The Conservative Assault on the Constitution, late last month. It's a highly accessible, often first-hand account (through his own cases, his own advocacy) of how a rightward shift in the composition of the federal courts has changed the Constitution.
Among the topics Chemerinsky examines: school segregation; executive authority; religion clauses; rights of criminal defendants; and access to the courts.
Chemerinsky identifies separation of church and state as a key issue--one that happens to be in the headlines today, after Republican and Tea Partier Christine O'Donnell seemed to argue in her debate with Chris Coons that nothing in the First Amendment compels such separation. Here's part of what Chemerinsky has to say about it:
A major concern of the right wing is the separation of church and state. For decades, it was understood that the First Amendment's prohibition on the establishment of religion meant that there was a wall separating church and state, a wall that kept American governments secular. But conservatives, especially starting with the Reagan presidency, have sought to eliminate any such notion. They argue that the government should have broad latitude to aid religion andto include religion in government activities. With the arrival of Chief Justice Roberts and Justice Alito, there now appear to be five votes for radically changing the law in this area in a manner that conservatives have advocated for decades.
October 19, 2010 in Books, Establishment Clause, Free Exercise Clause, Interpretation, Religion, Scholarship | Permalink | Comments (2) | TrackBack (0)
Monday, October 18, 2010
Seventh Circuit Upholds Moment of Silence in Schools
A three-judge panel of the Seventh Circuit on Friday upheld an Illinois law requiring a moment of silence at the beginning of each school day. The case, Sherman v. Koch, involved this provision:
Period of Silence. Sec. 1. In each public school classroom the teacher in charge shall observe a brief period of silence with participation of all the pupils therein assembled at the opening of every school day. This period shall not be conducted as a religious exercise but shall be an opportunity for silent prayer or for silent reflection on the anticipated activities of the day.
The provision was previously discretionary, but the legislature in 2007 changed the "may" to "shall" (as in "teacher in charge shall observe") over the governor's veto.
Two of the three judges held that the provision satisfied the three-part Lemon test:
Secular Purpose. The majority ruled that the legislature enacted the moment of silence in order to help students get settled for the day. They relied upon the plain language of the provision--the choice that students have under the provision to engage in "silent reflection on the anticipated activities of the day"--in concluding that the legislature's purpose was secular.
Advance or Inhibit Religion. The majority ruled that the statute as written neither advanced nor inhibited religion. The provision as written need not necessarily advance or inhibit religion, and the plaintiffs (in their facial challenge) didn't show that the provision was applied in a way that advanced religion.
Entanglement. This wasn't at issue in the case.
The majority also concluded that the provision was not unconstitutionally vague.
Judge Williams dissented, taking aim particularly at the legislative purpose:
So while I recognize that we assess a legislature's stated purpose with some deference, let's call a spade a spade--statutes like these are about prayer in schools. In my view, the legislature's decision to make the Act mandatory represents an effort to introduce religion into Illinois public schools, couched in the "hollow guise" of a mandated period of silence. While the secular purposes articulated by the state might not be "shams," it seems clear to me that to whatever extent they are genuine, they are secondary to religious ones. I share the concerns raised by a number of legislators who expressed their doubts about the true purposes behind amending the Act.
Op. at 41-42 (citation omitted).
October 18, 2010 in Establishment Clause, First Amendment, Fourteenth Amendment, Fundamental Rights, Opinion Analysis, Recent Cases, Religion | Permalink | Comments (1) | TrackBack (0)
The Persons Case: A Canadian Anniversary
Are women persons? At one time, the Supreme Court of Canada answered this question in the negative, but the Privy Council disagreed, thus allowing women to be considered "qualified persons" to run for elective office.
It's the anniversary - - - the 81st - - - of the Privy Council decision. Our colleagues over at the Canda Supreme Court Blog have a good discussion of Edwards v. A.G. of Canada, the so-called Persons Case, as well as some of the subsequent Canadian gender equality cases.
[image via]
October 18, 2010 in Comparative Constitutionalism, Gender | Permalink | Comments (0) | TrackBack (0)
Sunday, October 17, 2010
Presidential Power and Torture/Surveillance: New Book
Charles Fried, former Solictor General and ConLawProf at Harvard Law
and his son, Gregory Fried, philosophy department, Suffolk University, have co-authored Because it is Wrong: Torture, Privacy and Presidential Power in the Age of Terror. The book promises both a legal and philosophical discussion of torture and survelliance. From the publisher's description:
Can torture ever be justified? When is eavesdropping acceptable? Should a kidnapper be waterboarded to reveal where his victim has been hidden? Ever since 9/11 there has been an intense debate about the government's application of torture and the pervasive use of eavesdropping and data mining in order to thwart acts of terrorism. To create this seminal statement on torture and surveillance, Charles Fried and Gregory Fried have measured current controversies against the philosophies of Aristotle, Locke, Kant, and Machiavelli, and against the historic decisions, large and small, of Jefferson, Lincoln, and Pope Sixtus V, among many others. Because It Is Wrong not only discusses the behavior and justifications of Bush government officials but also examines more broadly what should be done when high officials have broken moral and legal norms in an attempt to protect us.
An excerpt appears in the current Harvard Magazine; there is also an NPR interview with the authors and a discussion with the Gregory Fried on Firedoglake.
October 17, 2010 in Books, Executive Authority, Fifth Amendment, First Amendment, Foreign Affairs, Fourth Amendment, State Secrets | Permalink | Comments (0) | TrackBack (0)
Friday, October 15, 2010
Florida Health Care Decision: Democracy Reinforcing or Judicial Overreaching?
One of the several eye-catching features of this week's decision on health care reform out of the Northern District of Florida is this: The court's homage to publicity as a core value in our representative democracy. The remarkable statement comes in the section of the opinion dealing with Congress's taxing power--whether Congress can enact the individual mandate under its taxing power, when there's no clear indication from Congress that it intended to enact the mandate under its taxing authority and when Congress seemed to treat the mandate as anything but a tax in the public discourse. Thus:
In other words, to the extent that the [government is] correct and the penalty was intended to be a tax, it seems likely that the members of Congress merely called it a penalty and did not describe it as revenue-generating to try and insulate themselves from the potential electoral ramifications of their votes.
. . . In other words, the members of Congress would have reaped a political advantage by calling and treating it as a penalty while the Act was being debated . . . and then reaped a legal advantage by calling it a tax in court once it passed into law.
Op. at 27-28 (emphasis in original). And then this kicker:
This should not be allowed, and I am not aware of any reported case where it ever has been.
Op. at 28 (my emphasis). Further explained here:
Congress should not be permitted to secure and cast politically difficult votes on controversial legislation by deliberately calling something one thing, after which the defenders of that legislation take an "Alice-in-Wonderland" tack and argue in court that Congress really meant something else entirely, thereby circumventing the safeguard that exists to keep their broad power in check.
This isn't much of the court's 65-page opinion, to be sure. But consider this: The court addressed the issue of Congress's taxing power (including these passages) first, even before it addressed justiciability--the threshold questions of standing and ripeness. It seems that the court had something to say about the political branches' duplicity in enacting and defending the mandate.
By one reading, the court is reinforcing democracy, in the spirit of Ely. More particularly, it's imposing its value of publicity (and related values of transparency and accountability)--deliberative democracy values--upon the political branches. By demanding that members of Congress maintain consistency in their positions, the court helps educate citizens as to their representatives' true purposes and helps voters hold their representatives' feet to the fire.
But by another reading, the court is dramatically overreaching. It is imposing consistency and truth demands on Congress, requiring members to articulate their political claims in the same terms that the institution articulates its constitutional claims in court. While, as the court says, there's no precedent for upholding a tax law that was justified on the basis of a penalty, there seems to be no precedent the other way, either. The court seems to support its claim based only on normative principles: "This should not be allowed." This seems like a remarkable lack of deference to a co-equal branch interpreting its own constitutional authority.
And moreover the court's authority for its methodology seems quite thin: Helwig v. United States (1903). The court uses Helwig to delve into "the nature of the act" in order to determine what authority Congress relied upon in enacting the mandate. According to the court, the nature of the mandate includes legislative language, clear congressional intent (as to the authority it is employing), public defenses of the mandate under the Commerce Clause, the method of collection, and Congress's "fail[ure] to identify in the legislation any revenue that would be raised from it . . . ." According to the court, these all point away from the taxing power as authority for the mandate.
But Helwig didn't deal with "the nature of the act" in order to determine congressional authority in the abstract. Rather, Helwig, a 1903 case, looked to "the nature of the act" to determine specifically whether Congress intended the act to be a penalty (not authorized) or a tax (authorized). This penalty-tax dichotomy went away 73 years ago--24 years after Helwig. The court too easily glosses over the fact that the "Helwig methodology" that it borrows is in fact bound up (perhaps inextricably so) with the debunked penalty-tax dichotomy.
Whether the court was reinforcing democracy or overextending its judicial authority, it was clearly making a statement.
October 15, 2010 in Congressional Authority, Courts and Judging, Recent Cases, Separation of Powers, Taxing Clause | Permalink | Comments (0) | TrackBack (0)
Thursday, October 14, 2010
Florida District Judge Rules on Motion to Dismiss Health Care Reform Challenge
In a 65 page opinion issued today, Senior United States District Judge Roger Vinson of the Northern District of Florida has granted in part and denied in part the morion to dismiss the complaint.
The Complaint alleges that the Health Care Reform Act is unconstitutional on various grounds in six counts and the Motion to Dismiss was directed at all the counts.
Here is the bottom line:
(1) the individual mandate and concomitant penalty exceed Congressional authority under the Commerce Clause and violate the Ninth and Tenth Amendments; NOT DISMISSED
(2) the individual mandate and penalty violate substantive due process under the Fifth Amendment; DISMISSED
(3) if the penalty imposed for failing to comply with the individual mandate is found to be a tax, it is an unconstitutional unapportioned capitation or direct tax in violation of U.S. Const. art. I, § 9, cl. 4, and the Ninth and Tenth Amendments; DISMISSED AS MOOT
(4) the Act coerces and commandeers the states with respect to Medicaid by altering and expanding the program in violation of Article I and the Ninth and Tenth Amendments; NOT DISMISSED
(5) it coerces and commandeers with respect to the health benefit exchanges in violation of Article I and the Ninth and Tenth Amendments; DISMISSED
(6) the employer mandate interferes with the states' sovereignty as large employers and in the performance of government functions in violation of Article I and the Ninth and Tenth Amendments; DISMISSED
Thus, the case will proceed on the issue of whether the individual mandate is in excess of Congress' commerce power in contravention of the Tenth Amendment and on the issue of whether the Medicaid changes are in excess of Congress' Article I power and in contravention of the Tenth Amendment.
October 14, 2010 in Commerce Clause, Medical Decisions, Tenth Amendment | Permalink | Comments (0) | TrackBack (0)


text:
Baby dinosaurs hatched in the Arctic 70 million years ago
It's likely these tiny dinos lived in chilly Alaska year round.
Baby dinosaurs toddled around the chilly region that is now the Alaskan Arctic about 70 million years ago, according to the "unexpected" discovery of more than 100 baby dinosaur bones and teeth there, a new study reports.
It was surprising to find evidence of a prehistoric nursery in such a cold place, the researchers said. Even during the warm Cretaceous period (145 million to 66 million years ago), Alaska had an average monthly temperature of about 43 degrees Fahrenheit (6 degrees Celsius), and for about four months of the year, the dinosaurs would have lived in permanent darkness and dealt with snowy weather, they said.
The Prince Creek Formation of northern Alaska, where the fossils were found, is "the farthest north that dinosaurs ever lived," study co-lead researcher Gregory Erickson, a paleobiologist at Florida State University, told Live Science. "I don't think it was possible for them to live any farther north," as what is now Alaska was shifted closer to the North Pole than it is today. "It's right up there with Santa Claus," he said.
After analyzing the babies' teeth and bones, the research team determined that the remains belonged to seven different dinosaur species. The discovery indicates that dinosaurs likely lived in this frigid region all year, as the babies would have been too small for annual migrations shortly after hatching, Erickson said. If these wee dinosaurs and their parents stayed in Alaska year-round, they were likely warm-blooded, or endothermic — a feature that would have allowed them to stay active even when temperatures dropped, he added.
Related: Album: Discovering a duck-billed dino baby
Researchers have known that dinosaurs lived in polar regions since oil workers found dinosaur bones there in the 1950s, Erickson said. In the following decades, scientists with the University of Alaska Museum of the North discovered the remains of teensy baby dinosaurs in the state.
"Our work is like panning for gold, finding little bones in a sea of sediment," said study co-lead researcher Patrick Druckenmiller, a professor of geosciences and the director of the University of Alaska Museum of the North. Undergraduate and graduate students have contributed thousands of hours of work to the project, which uncovered baby dinosaurs belonging to several herbivorous species of duck-billed dinosaurs, ceratopsians (horned dinosaurs), thescelosaurids (small, bipedal ornithopods) and pachycephalosaurids (dome-headed dinosaurs). They also found baby remains from carnivores, including tyrannosaurids, deinonychosaurs (maniraptoran dinosaurs) and ornithomimosaurians (ostrich-like dinosaurs).
"The most recent surprise was the smallest ceratopsid tooth of which I am aware in North America, or anywhere really," Druckenmiller told Live Science in an email.
The winter months in the Alaskan Arctic at the time were probably the toughest, especially for the herbivores, whose food would have been either covered in snow or dead, Erickson said.
"How they pulled it off, we don't know," Erickson said. Some small dinosaurs might have burrowed and hibernated, but larger dinosaurs — such as duck-billed dinosaurs and tyrannosaurs — weren't able to burrow. "Maybe they just had to stick it out like a moose or musk oxen. Somehow, they got through," Erickson said.
Staying put and staying warm
Based on knowledge of dinosaur life cycles, the researchers concluded that these baby dinosaurs stayed put after hatching, as they wouldn't have had time to mature before winter set in. That's partly because dinosaur eggs took a long time to incubate — anywhere from three to six months, Erickson and colleagues determined in a 2017 study published in the journal Proceedings of the National Academy of Sciences.
These long egg-hatching times, "combined with the fact that you had a very short growing season up there to flourish before the winter set in, [baby dinosaurs] just did not have time" to grow big enough before migrating southward, Erickson said. "There's no way that these tiny dinosaurs made the march down to Alberta to escape the winter."
There is evidence that some long-necked sauropod dinosaurs and duck-billed dinosaurs at lower latitudes of western North America migrated, but it's likely that the Alaskan dinosaurs, especially the smaller individuals, stayed put, the researchers said. Spending the winter in polar conditions would be challenging for cold-blooded, or ectothermic, creatures. In fact, paleontologists haven't found ectothermic animal fossils — such as those from crocodilians, lizards or snakes — at Prince Creek Formation, Druckenmiller said. Moreover, there's only one ectotherm known from the Alaskan Arctic today: the wood frog, which essentially turns into an ice pop in the winter.
Based on this, as well as endothermy results from other studies analyzing dinosaurs' rapid growth rates, it's "likely dinosaurs had some degree of endothermy to cope with winter conditions, particularly the low/no light and cold temperatures," Druckenmiller wrote in the email.
The study was published online Thursday (June 24) in the journal Current Biology.
Originally published on Live Science.
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Laura is the archaeology and Life's Little Mysteries editor at Live Science. She also reports on general science, including paleontology. Her work has appeared in The New York Times, Scholastic, Popular Science and Spectrum, a site on autism research. She has won multiple awards from the Society of Professional Journalists and the Washington Newspaper Publishers Association for her reporting at a weekly newspaper near Seattle. Laura holds a bachelor's degree in English literature and psychology from Washington University in St. Louis and a master's degree in science writing from NYU.
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By Harry Baker
By Emily Cooke


text:
Monday, November 19, 2001
Isn't this … um … entrapment?
I received the following spam today in email:
And it goes on for some 180 more lines of this drivel. But I find it rather amusing thatThanks to recent dramatic advances in the laboratorial processes for the extraction of botanical/herbal alkaloids and glycocides, we are now able to offer what has already been the most incredibly potent marijuana/cannabis alternative available on the planet … KATHMANDU TEMPLE KIFF!!! It is NEW, IMPROVED and 20 times more stokin'-tokin' potent in its formulation.


text:
Racism at work isn't going away
We're uncomfortable about talking about race in the workplace, so issues are going unresolved.
While fixing the issues holding women back in business has jumped right to the top of leaders' to-do lists, tackling those surrounding ethnicity hasn't gained as much traction. Yet racism at work hasn't gone anyway.
Almost three in 10 (28%) of black, Asian and minority ethnic (BAME) employees had experienced or witnessed racial harassment by a manager in the last five years, compared to 17% of white staff, according to a YouGov survey of more than 6,000 people. A quarter of Pakistanis had suffered it personally, the highest proportion.
Of those who reported managerial racism, 30% said it happened in the last year. That's less than 10% overall, but given the pervasive, lasting impact of workplace discrimination that's still far too high.


text:
AT&T Rewards Centre | Available benefits at AT&T Rewards Centre
AT&T Rewards Centre | Available benefits at AT&T Rewards Centre: AT&T is an American multinational telecommunication corporation. It was founded in 1983 and is headquartered in Whitacre Tower, Dallas, Texas, United States. AT&T is spread crosswise over six continents.
It is the second-largest provider of mobile telephony and the largest fixed telephony provider in the United States.AT&T likewise provides broadband subscription television service and furthermore has the country's largest 4G network and operates the country's largest Wi-Fi network. Once you subscribe to AT&T or buy its products you can get rewards from the AT&T Rewards Card Center. For getting these rewards you need to initially activate your card online and access your account.
Recommended Articles;
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- How To Check Walmart Gift Card Balance Online
- ATT Uverse Login Account – How To Sign In ATT Uverse Account
- Open the URL https://rewardcenter.att.com/home.aspx in your web browser
- On the top screen at the second number on your left side, you will see the alternative of "activate my reward card", right-click on it.
- A new window would open in which you will be asked to enter your card number.
- Begin your card actuation process by entering the initial four digits of your reward card number.
- Then click "Continue" Enter the entire card number and your 4-digit PIN which is the last 4 digits of your account number.
- Then just follow the prompts given by the AT&T site to complete the actuation process.
- You can repeat the same procedure to check your balance
Also, Read; How to Activate Bank of America Credit Card through an easy step
- Go to the website mentioned above and access the official homepage of AT&T Reward Center.
- On the correct side of the screen, there would be a case giving several choices of either composing in your redemption id or account number and postal district.
- Enter affirmation number or redemption id or account number and postal division.
- For redeeming different honors you need to click on the specific associated account for it.
- After you have opened your account you will see a rundown of rewards hanging tight for you.
- You can either redeem them online or print paper rebate frames when applicable.
- You can likewise check the status of any rewards you have redeemed.
- After introducing your AT&T equipment or service you will receive a reward warning inside 4 weeks.
- Open the redemption letter in your mail.
- Sign in to www.att.com/rewardcenter by giving your reward card number (the initial four digits just) and press "continue"Follow the easy online redemption steps given in the type of easily understandable prompts
- You will then receive rewards by means of your mail inside 4-6 weeks from completed reward redemption
- Activate your reward card online for use with the card number and PIN.
AT&T Cardholder Frequently Asked Questions
Charge Schedule
As a rule, beneficiaries won't need to pay a charge to make purchases.
Schedule of Bank Fees
Bank Fees for AT&T my Rewards Debit Card transactions will be charged to your account on a daily premise as they happen.
Services with no fees
Services with no fees | |
Purchase Transactions | Fee |
Purchase at Merchants (signed, using a PIN, online, phone, or mail purchases) | No Fee |
Other Services | |
Online, Automated, Live or International Customer Service Inquiry | No Fee |
Services with fees
Services with fees | |
Other Service Fees | Fee |
Card Replacement Domestic | $5.00 per request |
Card Replacement – Express Delivery (additional charge) | $15.00 per request |
Card Replacement International (outside the U.S.) | $15.00 per request |
International Transaction Fee | 3% of U.S. Dollar amount of transaction |
Mailed Account Statement | $1.00 per statement |
PIN Changes | 1 free per year, $0.50 thereafter |
Account Closure Check Issuance | $5.00 per check |
Note: For any inquiries identified with the above charge schedule, if it's not too much trouble call the Debit Card Customer Service Center at (888) 373-5801, (866) 656-5913 TTY, or (423) 262-1650 (Collect when calling outside the U.S.). For questions with respect to your Incentive payments, it would be ideal if you visit AT&T on my Rewards website.
General Debit Card Program Information
AT&T my Rewards Debit Card is a simple, progressively secure, and advantageous approach to get your AT&T employee rewards. You don't need to have a bank account to get the AT&T my Rewards, Debit Card.
You'll approach your funds 24 hours per day, 7 days per week by means of purchases wherever MasterCard® debit cards are acknowledged.
Here's the way the cards will work:
- Once you get an employee reward from AT&T, Bank of America will make an account in your name, and Funds will be sent by Electronic Funds Transfer to your AT&T my Rewards Debit Card.
- You would then be able to utilize the AT&T my Rewards Debit Card to make purchases until the funds are depleted.
- You can't make any additional deposits to the account. Just AT&T my Rewards can fund the card.
- This isn't a credit card and endeavoring to utilize your card for purchases that surpass your balance may bring about the transaction being declined.
Debit Card Benefits
Convenience and flexibility
You need not bother with a bank account for your AT&T my Rewards debit card. The card is cost-productive, secure, simple to utilize, and gives numerous alternatives to making purchases.
Benefits of the card include:
- Use wherever MasterCard debit cards are acknowledged – in-stores, online or by telephone
- Use your cards to pay bills face to face or online
- Account information and customer service – accessible 24 hours every day, 7 days per week
*>> Point of offer: a retail dealer that acknowledges debit cards.
How Do I File An AT&T Card Disputes?
Cardholders who don't get month to month account statements via mail
All account disputes ought to be coordinated with the AT&T my Rewards Debit Card Customer Service Center at (888) 373-5801. You should contact customer service when you can on the off chance that you think a blunder has happened in your Account.
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Bank of America must get a notification from you no later than 60 days after the most punctual date you electronically access your account if the mistake or issue could be seen in your electronic history, or the date we sent the FIRST written history on which the blunder or issue showed up.
A Bank of America AT&T my Rewards Debit Card Customer Service agent will furnish you with a dispute form to finish and return.
Cardholders who get month to month account statements via mail
All account disputes ought to be coordinated with the AT&T my Rewards Debit Card Customer Service Center at (888) 373-5801. You should contact customer service when you can on the off chance that you think your statement or receipt isn't right, or in the event that you need more information about a transaction listed on the statement or receipt.
Bank of America must get notification from you no later than 60 days after we sent the FIRST statement on which the issue or blunder showed up.
A Bank of America AT&T my Rewards Debit Card Customer Service delegate will furnish you with a dispute form to finish and return.
What if The Card Expired?
One month before the lapse date listed on the facade of your Debit Card, you will get another card with another termination date. It would be ideal if you make certain to activate your new card and devastate your terminated card. Your balances and payments will be accessible on your new card after initiation.
What Do I Do If My Card Get Lost or Stolen?
On the off chance that your card is lost or stolen, the Bank of America "Zero Liability" Policy secures you against deceitful transactions (subject to specific conditions). You need just contact the AT&T my Rewards Debit Card Customer Service Center at (888) 373-5801 to report your card lost or stolen and to demand a replacement card.
• If the card has been utilized, the bank will give the replacement card in the measure of the rest of the balance.
In the event that the mail station can't convey an AT&T my Rewards Debit Card, it will become back to the bank. Contact the AT&T my Rewards Debit Card Customer Service Center at (888) 373-5801 to update your address information and solicitation another card to be sent to you.
How Do I Use the Debit Card To Pay bills?
Pay bills online, face to face, or via telephone. By using the AT&T my Rewards Debit Card to pay bills online or via telephone, you can keep away from exorbitant expenses charged by money order cashiers and others.
What Are The most effective method to Use Your Debit Card?
- For Purchases
You can utilize your card wherever Visa debit cards are acknowledged.
To lead purchases with a mark:
- 1. Present or swipe your card.
- 2. Choose "credit."
- 3. Sign, take your card and receipt.
To lead purchases with a PIN:
- 1. Swipe your card.
- 2. Choose "debit" and enter your PIN.
- 3. Take your card, cash, and receipt.
2. For Special Transactions
Service stations – Paying at the siphon may cause a hold of up to $100; consider paying inside, saying the amount you need to purchase, and marking the receipt.
Restaurants – Restaurants may check you have enough in your account for the bill. Make sure you have enough funds to cover any added tips.
Inns – The inn may hold the measure of your evaluated bill, making that sum inaccessible for different purchases. At the point when you check out, the hold may take a couple of days to be removed.
Auto rentals – You may utilize your card for conclusive payment for a rental vehicle, however, a credit card might be important to reserve a rental vehicle.
Returns – Store merchandise exchanges fluctuate. You may get a credit to your account or store credit. A credit to your account may take seven days to process before funds are accessible for use.
How Do I Check My Debit Card Balance Inquiries?
To Know your balance
Traders are commonly not ready to decide the balance on your card, so you ought to consistently confirm the balance before using your AT&T my Rewards Debit Card. Endeavoring to utilize your card for purchases that surpass your balance may bring about the card being declined.
Cardholders can check the balance on their cards and audit all their account transaction activity 24 hours per day online or by calling (888) 373-5801.
- There is no expense for online and phone balance requests.
- Sign up for free low-balance cautions (mobile instant message and email) by signing in to your account.
In Case My Address Changes, What Do I Do?
Address changes might be done online through the Profile page once you are marked on to this website. You can likewise contact the AT&T my Rewards Debit Card Customer Service Center at (888) 373-5801. In addition to reaching AT&T my Rewards Debit Card Customer Service Center, if it's not too much trouble tell AT&T by visiting the AT&T my Rewards website.
That is is all about AT&T Rewards at the AT&T Rewards Centre
Below are Useful Links that can help you as well:
How Do I Get AT&T Reward Center Number?
If you're an AT&T customer, you can earn rewards by participating in certain activities. To find out more, visit the AT&T Reward Center online or call the number listed below.
Tel: (888) 373-5801.
The AT&T Reward Center is a great way to get rewarded for being an AT&T customer.
There are many different ways to earn rewards, and the more you participate, the more rewards you can earn. To learn more about the AT&T Reward Center, visit the website or call the number listed below.
Tel: (888) 373-5801.
AT&T Reward Card not received, What Do I do?
If you're an AT&T customer and you haven't received your reward card, don't worry. There are a few things you can do to troubleshoot the situation.
First, check your AT&T account online to see if the card has been shipped. If it says that the card has been shipped, but you still haven't received it, contact AT&T customer service. They should be able to help you track down your missing card.
If your account doesn't show that the card has been shipped yet, it's possible that there was an issue with your order. In this case, you'll need to contact AT&T customer service to resolve the issue. You can as well use AT&T Rewards App on your device to easily reach out anytime any day!
AT&T Rewards App Usefulness
The AT&T Rewards App is an easy way to keep track of your AT&T reward points. You can use the app to check your balance, redeem rewards, and view recent transactions. The app is available for both iPhone and Android devices.
To get started, simply download the AT&T Rewards App from the AT& T Thank App from App Store | AT&T Rewards App or AT&T Thank App on Google Play. Once you have installed the app, open it and sign in with your AT&T account information.
Once you are signed in, you will be able to view your current point balance and redeem rewards.
To check your balance, simply tap on the "Balance" tab at the bottom of the screen. To redeem rewards, tap on the "Rewards" tab and select the reward you would like to redeem.
If you have any questions about the AT&T Rewards App, simply tap on the "Help" tab at the bottom of the screen.
Here you will find a list of frequently asked questions as well as contact information for customer support.
We hope you enjoy using the AT&T Rewards App!


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Full length group photograph of three of the Blue Devils, taken by Bert Studios, Kansas City, (left to right): Theo Ross, Lester Young, and Buster Smith, ca. 1932. Source: Jimmy Jewel.
Smith, Buster
Parker was born in Kansas City, Kansas, on August 29, 1920. He grew up in Kansas City, Missouri, where he played in jazz clubs as a teenager and young man. The local jazz culture based in the Vine Street nightclub district cultivated his talents as a teenager. Indeed, it was during this period that Kansas City made notable contributions to jazz with hometown artists such as Count Basie, Bennie Moten, and Buster Smith.
On September 23, 1923, the Bennie Moten Orchestra made its first recording consisting of eight songs. By strict musical standards, the songs themselves were unrefined and not much removed from existing blues music. But the Bennie Moten Orchestra would soon build upon its earliest recordings to develop a distinct Kansas City style of jazz that later dominated the jazz scene in the late 1930s and 1940s.


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We hope to have our Junior Sport afternoon on Friday 29th June as planned. However, the weather forecast is for continued hot weather and we need to ensure that we have enough shade for us to enjoy an exciting and safe afternoon.
For the sport afternoon to go ahead we need to have at least 15 gazebos set up on the playing field. With the shade that these and the trees provide we will be able to have children and families sit safely in the shade whilst not racing.
If you are able to bring a gazebo to school and put it up on the playing field on Friday morning before 1pm please ring school to let Mrs. Howis know as soon as possible. Once we have had 15 offers of help we will be able to confirm that sport afternoon can carry on. You will then need to take down your gazebo at the end of the afternoon at 3.30pm.
If we have not had 15 offers of help by 9.30am on Thursday morning and the forecast is still for hot weather we will unfortunately have to postpone junior sport afternoon.
Thankyou for any help or support you are able to give us in helping sport afternoon go ahead as planned.
R. Averis


text:
The Taga Harmony Platinum S-100 Surround Speaker Surround Speaker (Pair) is the flagship of TAGA Harmony speakers. The eye catching, stylish curved cabinets made of strong and thick MDF boards equipped with advanced drivers and high quality crossovers give crisp, clear, natural and dynamic sound performance.
- Design:
- 2-way, 4 drivers, Surround speakers,
- Wall mounts, TLIE Enclosure,
- crossover point 4.5kHz
- High-Frequency Driver: 2 x 25mm (1"), TPTTD, TWG faceplate
- Bass / Midrange Driver: 2 x 133mm (5.25"), TPACD
- Recommended Amplifier Power: 20-180W
- Frequency Response: 38Hz-40kHz
- Impedance: 6 ohm
- Sensitivity: 88dB
- Dimensions (H x W x D): 28 x 27.7 x 17.2 cm
- Weight (net): 10kg pair


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"Liking" a political candidate, cause, or consumer product on a Facebook page should constitute protected speech under the First Amendment. Interpreting the First Amendment's "freedom of speech" clause, the Supreme Court has held that the ability to criticize government and government officers is "the central meaning of the First Amendment." [1. New York Times v. Sullivan, 376 U.S. 254, 273 (1964).] At the same time, the Court has declared that other forms of speech and expression are protected by the First Amendment.[2. Times, Inc. v. Hill, 385 U.S. 374, 388 (1967).] Government employees should not get fired for "liking" or supporting a particular political candidate on a Facebook page.
In April 2012, a court ruling by the Eastern District of Virginia in Bland v. Roberts stirred a lot of controversy. In Bland, several state employees of the Sheriff's Department in the City of Hampton, Virginia, were fired for "liking" a Facebook page of a political candidate who ran against the Sheriff in his bid for reelection.[3. Bland v. Roberts, 2012 WL 1428198 (E.D. Va. Apr. 24, 2012).] The fired employees sued the Sheriff for violation of their First Amendment rights to speech.[4. Id.] The district court granted summary judgment in favor of the defendant based on the ground that "liking" a Facebook page is "insufficient speech" and not "substantive" enough to guarantee constitutional protection. [5. Id. at *3-4.] The court here applied a three-prong test laid out in McVey v. Stacy.[6. 157 F.3d 271 (4th Cir.1998). Id. at *2.] Under the McVey test, to identify whether a public employee has stated a claim under the First Amendment for retaliatory discharge, we must determine (1) whether the public employee was speaking as a citizen upon a matter of public concern or as an employee about a personal matter of personal interest; (2) whether the employee's interest in speaking upon the matter of public concern outweighed the government's interest in providing effective and efficient services to the public; and (3) whether the employee's speech was a substantial factor in the employee's termination decision.[7. Id. at 277-278.] In Bland, after stating that "[t]he first prong of the McVey test necessarily require[d] that speech exist[ed] before an evaluation of the remaining prongs [could] occur," the district court held that the plaintiffs did not "sufficiently" allege engaging in "expressive speech." [8. Bland, 2012 WL 1428198, at *3.]
I believe the district court came to the erroneous conclusion in the instant case: "liking" someone on Facebook should warrant constitutional protections. Clicking a "Like" button on a Facebook page involves an act of volition and judgment. This button is not clicked to proceed to a next page or to navigate back as it happens when users almost automatically and habitually click "OK", "Cancel", and "Back" buttons in Internet browsers and Microsoft Windows applications. Clicking a "Like" button requires deliberation and contemplation on part of a user: it is not a mere, unsubstantial act of browsing and navigation between pages on the Internet. Clicking a "Like" button triggers a whole chain of events. First, an announcement is posted on the user's personal page proclaiming the fact that he likes, supports, endorses, or enjoys the "liked" page and his whole network of friends gets notified about his action. Secondly, his click of a "Like" button comes with consequences. Now, various advertisements will populate on the individual's screens that are similar to the product he or she "liked." This demonstrates that hitting a "Like" button on Facebook is not a mere navigational feature on the Internet; but rather a firm and concrete statement of expression that should be protected by the Frist Amendment. In fact, hitting a "Like" button is analogous to posting a flag outside someone's door. [9. See Texas v . Johnson, 491 U.S. 397 (1989) (holding that a communicative conduct such as flag burning is constitutionally protected form of speech).]
Further, the law has not kept up with emerging Internet technologies and their constitutional consequences. However, we are not left completely in the dark. As we certainly have some guidance on this novel issue. For instance, a recent holding in Fraley v. Facebook,[10. 830 F. Supp. 2d 785, 804-05 (N.D. Cal. 2011)] , provides a persuasive authority on this matter. In Fraley, the Court held that "liking" things on Facebook is "newsworthy."[11. Id.] This decision stands contrary to the district court ruling in Bland where the court held that "liking" someone's Facebook page is not an expressive speech or conduct. Moreover, in a 2011 United States Supreme Court ruling, Justice Scalia stated that "[l]ike the protected books, plays, and movies.., video games communicate ideas – and even social messages."[12. Brown v. Entm't Merch. Ass'n, 131 S.Ct. 2729 (2011).] We can view Justice Scalia's quote on video games as dicta for the novel issue at hand. Analogous to video games, some social networking activities, such as "liking" or supporting someone, should be viewed as vehicles that communicate ideas and social and political messages. Thus, a social networking activity that conveys a message or statement such as "liking" a political candidate's Facebook page should be protected under the First Amendment of the United States Constitution because it is just someone's way of expressing his/her freedom of speech.
After an adverse ruling by the district court in Bland, the plaintiffs have filed an appeal. Furthermore, in August 2012, two third-party organizations — Facebook, Inc. and ACLU — submitted their individual briefs as amicus curiae in support of the plaintiffs-appellants on the issue of whether or not "liking" someone on Facebook constituted a form of protected speech under the First Amendment.
Certainly Facebook, Inc. has a substantial business interest in this matter: it does not wish its users to be limited and restricted in their online activities. This social networking giant also does not want to lose its advertising revenues it generates every time a user hits a "Like" button. Contrary to the district court ruling, Facebook contends that every time a user hits a "Like" button, it becomes a "statement that will be viewed by a small group of Facebook friends or by a vast community of online users." [13. Brief for Facebook as Amici Curae Supporting Plaintiff-Appellant, Bland v. Roberts, 2012 WL 1428198 (2012) (No. 12-1671).]
A nationwide, nonprofit organization ACLU which "has been committed to protecting the freedoms guaranteed by the First Amendment" viewed the district court holding in Bland as an "unduly restrictive view of constitutionally protected speech." [14. Brief for ACLU et al. as Amici Curae Supporting Plaintiffs-Appellants, Bland v. Roberts, 2012 WL 1428198 (2012) (No. 12-1671), 2012 WL 3191380.] ACLU asserts that "'Liking' a political candidate on Facebook – just like holding a campaign sign – is constitutionally protected speech." [15. Id.] ACLU further contends that hitting a "Like" button is "verbal expression, as well as symbolic expression."[16. Id.]
Based on the little precedent we have on this novel issue involving social media and freedom of speech, I expect the Fourth Circuit will reverse the district court on this point and find that "liking" a political candidate, cause, or product should warrant the First Amendment protection.


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Factors To Put In Mind About Classical Music
Classical music is associated with elevator music which comes in many people's mind. However, it is impractical to say that elevator music is classical music despite the similarity. They emanate from a generic term used in pronouncing music. The characteristic of classical music is embroiled with a variety of other styles of music which has stayed for a long time for up to 700 years read more here. The article is good to discuss What you need to know about classical music.
The Latin word classics is the origin of classical music with the deeper meaning high-class taxpayers. It is important to notice that classical music is also emotional, however naturally understood by the audiences when it comes to its dramatic output. Drama is the keyword which is the same as classical music whereby the play has different characters similarly, classical music has themes which are intervals and where you begin is not regular finish. The differences that are attributed to classical music and pop music are imminent as discussed below. Classical music is always longer, as compared to pop music which is associated with music videos whereby a piece of classical music is associated to full-length features this is because the development of the plot will take longer. The differences emanating from classical music and pop music can be categorized in the structure and expression whereby classical music has high dependence view here .
The subtle changes of harmonic expressed by classical music is because of the structural nature and expression. There is no need to understanding them, but the feeling of harmonic emanating from your chest is immense. As a major attribute of classical music is its dependence on variety and constructs. Classical music is much more constant as compared with music, which can maintain its clear mood and can eventually be first in one instance slow, loud in another and whispering. The constant effect in which major classical music can maintain its mood is longer than pop music, and in turn asks you to compare and contrast this site.
Another important attribute of classical music is its multiple simultaneous voices or counterpoints, it doesn't matter if it's a fugue or quartet the number of things going on is always more than one at a particular moment Whether it fugue or quartet. Another important characteristic of classical music is its importance active listening as compared to pop music. The assumption being created here is that classical music has a strict adherence to ideas formation that emanates from the changes that come along while the different pieces are being built info. .
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