As Dr. Victoria Ward listens patiently to her clients spilling the horrible, painful stories of domestic violence, she reminisces on her own childhood and the very reason for her chosen profession. She sees her own mother through the eyes of the very women who bare their souls, day after day. And she wonders what makes men do this to the best part of their lives? Who do they think they are? What gives them the right? Rather than speculating on her role in the issue, Victoria takes fate into her own hands, making the matter right. It might be illegal in the eyes of the law, but this has to stop. Death is not good enough. These men must suffer to the point of madness while admitting their ultimate sins. As Victoria investigates her next "client", she relives every injustice ever served at her father's hands. No, death is not good enough.
I was beyond angry from page one on. The author shows no restraint in bringing the reader face-to-face with the evil act of physical abuse. Even with the end justifying the means, the rage reflected in this work is palpable. Provocation: Pen Pals and Serial Killers Book 2 by Jo Michaels is a first class tale of spousal abuse and neglect in which the author projects the surprising final twist. The reader is left questioning the happy façade of the couple next door while gaining a new perspective on happily ever after. Provocation is a riveting single sitting read that will haunt one's dreams long after the final page is turned.
If you like your thrillers bloodcurdling, read Provocation: Pen Pals and Serial Killers Volume 2 by Jo Michaels. This is one of the most delectably gruesome psychological thrillers I've read in a long time, with a raison d'etre that will strike a chord in the hearts of most victims of abuse, especially females. To the old saying about the fury of a woman scorned, thanks to Jo Michaels, we can now add another: there's no greater revenge that that of a woman abused…or the woman who does what the abused woman can't do for herself.
Psychiatrist Victoria Ward is the avenger, the champion for abused women. As she listens to one patient after another telling her of the suffering they endure at the hands of their men, just like her beloved mother did with her father, she seethes with anger. She burns with rage. If the victim's abuser were in her office right now, she'd kill him outright. But that would only land her in jail. That cannot happen if she is to fulfill what she sees as her life's mission. So, with her military background, considerable skills and enough money to up and move often enough to elude the police when men go missing, she exacts revenge on these husbands and boyfriends. That revenge isn't so much sweet as it is horrific, bloodcurdling; it will have readers squirming as they read. If this were a movie, it would be hard to watch.
Jo Michaels is a skilled writer. Her plot is well-thought out and developed. Characters are believable, and the plot? Well, it never stops moving. And the twist at the end comes as a shock that neither Victoria Ward nor readers expect. I hated this book because I couldn't put it down until 4:30 a.m. I just had to finish reading it. But truth is, I loved it! One of the best psychological thrillers I've ever read. Jo Michaels can add me to her fan club. I would love to read more by this mind-blowing author!
Provocation is the second book in the Pen Pals and Serial Killers series, a powerful blend of crime and psychological thriller by Jo Michaels. Doctor Victoria Ward has witnessed abuse first-hand, with her father's rough treatment of her mother, and she's made up her mind to stand up against men who are abusive, starting with her father. In this novel, the reader follows her journey as she leaves victims in her wake, determined to uphold justice for abused women. It is not until she meets young Kelly that everything changes for her. Her work of thirty years has been aimed at protecting the innocent, but with deception looming ahead, can she continue on this path? Read on to discover what happens when her past catches up with her.
Jo Michaels' novel is a riveting read, beautifully plotted, and fast-paced. The characters are compelling and readers will enjoy the way the author explores the psychology of a serial killer. On the surface, Dr. Victoria Ward appears to be very normal, intelligent, insightful, and understanding — perhaps a female version of Hannibal Lecter? The story has psychological depth and the interactions of the protagonist with women who are accused are intelligently written, exposing her brilliance. But then, there is something wrong with her way of seeing reality — she believes she is righteous and that it's the mission of the righteous ones to punish those who hurt women. The chapters are well-written and each explores a deeper layer of the conflict, each more intense that what comes before it. Provocation is gripping, entertaining, and insanely absorbing. You'll want to know what will happen to the protagonist, but before then, you want to guess who the next victim could be. It's a work of sheer brilliance and great entertainment.


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Q: AS - Translation Editor - How to delete string in all languages at once? I have few strings that translated to 4 languages, but interface changed, and now I'm wondering, if there are any possibility to delete string in all languages at once? (I'm using Android Studio 2.2)
Now it's not a big problem now, but when there are will be more than 4 languages it could be difficult. Maybe I should create feature request for Android Studio about it?

A: In Android Studio 2.3 I've found a little button, but it searches for usages before deletion and it takes really long time.
In the translation editor select a string key and then press little "-" button at top left. Screenshot attached.

redpajama_set_name: RedPajamaStackExchange


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Fuzz Townsend's Net Worth. His Wife, Age in Wiki-Bio.
dvn September 22, 2021 No Comments
Fuzz Townshend is a TV presenter, a journalist and a musician but most famous for appearing as a presenter in 'Cars SOS.' He is a car enthusiast and has various automobile-related investments like garages and car restoration business.
Fuzz Townshend is undeniably one of the leading causes people love to watch Nat Geo's 'Car SOS.' We can't give all the credit to him however after all the important contribution from his show's another presenter, Tim Shaw. His TV fame has given him a large sum of salary to form his incredible net worth. Learn all about with other facts from his wiki like his age, wife and married life. Also, learn about his co-star and presenter Tim Shaw.
Fuzz Townshend's Net Worth.
Believe it or not, Fuzz Townshend began his career as a musician and joined the band known as 'General Public and later shifted to the local Indie band 'Pop will eat itself' and played with them as a drummer for 4 and a half years. He was a great success over the UK and also toured over North America with Nine Inch Nails. The drummer released in solo 'Hello Darlin' in 1996. He became a college lecturer for music since 2004.
The 'Car SOS' star also has had a career in writing and journalism and has written for Practical Classics and Technical Editor. He moved on to doing freelance but again shifted career to automobiles like his recent find of Classic Friendly Ltd. a garage for classic cars. He has also invested in traditional cars restoration business and other garages. His diverse career and hard work must result in very impressive net worth.
Caption:- Fuzz Townsend's Net Worth is $5 Million.
If we are to talk about his net worth, then we can't leave out his TV career. He was invited for a screening of 'Cars SOS' and quickly got the job in the National Geographic Show. It is here he met fellow presenter Tim Shawn, and they show great chemistry on TV. Being associated with such ad namely network and show means that he must have a surprising amount of net worth. His net worth is accumulated to be of around $5 million.
Fuzz Townshend's Wife and Married Life
Fuzz is a private man who likes to keep things like his married life away from the media, but still, he wasn't persistent enough to hide the fact that he is married. His wife goes by the name Cressida Townshend, and though you can find her name in any Fuzz Townshend related article, there is not much written about his wife. That is because 'Car SOS' star has done a great job in keeping his wife's details a secret.
He might not let out much on his married life, but it seems like that he can't keep the part of his children out. He looks like a good husband just by looking at how good of a father he is with his three children, all sons; Honor, Oscar, and Johnny. He often puts pictures of his youngest son Johnny on his Twitter.
Fuzz Townshend's Wiki-bio
Fuzz Townshend was born on 31st July 1964 which makes her 53 years of age. His wiki-bio tells that he was unique in his school for his afro and also got his name there as Fuzz. His real name is John Richard, Keith Townshend. His mother had bought him a drum kit with the prize money she received instead of a Vauxhall Chevette she won. He learned to play at a local jazz club called Al Reed and made his debut in March 1977.

redpajama_set_name: RedPajamaCommonCrawl


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Size: Adjustable 6 to 8 inches. 8mm beads.
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Q: fastest way to store comment data python Hi I have a small comment shoutbox type cgi process running on a server and currently when someone leaves a comment I simply format that comment into html i.e

$title

$comment

and store in a flat file.
Would it be faster and acceptably low in LOC to reimplement the storage in xml or json, in a simple spec of my own or stick with the simple html route?.
I don't want to use relational database for this.

A: If a flat file is fast enough, then go with that, since it's very simple and accessible. Storing as XML and JSON but still using a flat file probably is very comparable in performance.
You might want to consider (ignore this if you just left it out of your question) sanitizing/filtering the text, so that users can't break your HTML by e.g. entering "
" in the comment text.

A: XML is nice, clean way to store this type of data.  In Python, you could use lxml to create/update the file:
from lxml import etree

P_XML = 'xml_file_path.xml'

def save_comment(title_text, comment_text):
  comment = etree.Element('comment')
  title = etree.SubElement(comment, 'title')
  title.text = title_text
  comment.text = comment_text
  f = open(P_XML, 'a')
  f.write(etree.tostring(comment, pretty_print=True))
  f.close()

save_comment("FIRST!", "FIRST COMMENT!!!")
save_comment("Awesome", "I love this site!")

That's a simple start, but you could do a lot more (i.e. set up an ID for each comment, read in the XML using lxml parser and add to it instead of just appending the file).

A: A flat-file is the fastest form of persistence.  Period.  There's no formatting, encoding, indexing, locking, or anything.
JSON (and YAML) impose some overheads.  They will be slower.  There's some formatting that must be done.
XML imposes more overheads than JSON/YAML.  It will be slower still.  There's a fair amount of formatting that must be done.
The more overhead, the slower it will be.
None of these have anything to do with sanitizing the comment input so that it will display as valid HTML.  You should use cgi.escape to escape any HTML-like character sequences in the comment before saving the text to a file.


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Before I had serious Google problems to complain about--like Android--I use to complain that the online giant suffered from "throw it at the wall and see what sticks" disease, where it would appear to just release, willy-nilly, any web service or application that some random employee came up with over a weekend.
Apparently this is changing under new CEO Larry Page, and the company announced this week via the Official Google Blog that it is cleaning house and eliminating a bunch of truly silly products.
"Over the next few months we'll be shutting down a number of products and merging others into existing products as features," Google SVP Alan Eustace writes. "This will make things much simpler for our users, improving the overall Google experience. It will also mean we can devote more resources to high impact products—the ones that improve the lives of billions of people. All the Googlers working on these projects will be moved over to higher-impact products."
Much is being made in the tech blogosphere about this change--John C. Dvorak notes that many of these things are "unknown to most people" and argues that Google, like Yahoo before it is "totally clueless about marketing and publicity"--but I think the bigger point here is that Google is finally growing up. I have no idea why it bothered with this cruft in the first place. But getting rid of it all is absolutely the correct decision.
Indeed, this is the type of hard-nosed decision making Microsoft should be making when it comes to removing similarly pointless applications and services from Windows 8. I'm talking about things like Media Center, which even Microsoft admits no one uses, or the reprehensible XPS document platform, which never should have been hatched in the first place.


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text:
The Harvard Plan That Failed Asian Americans
Fisher's Cautionary Tale and the Urgent Need for Equal Access to an Excellent Education
Comment by Kimberly Jenkins Robinson
Harvard Law Review Forum
The Future of Affirmative Action
Responding to Kimberly Jenkins Robinson, The Supreme Court, 2015 Term — Comment: Fisher's Cautionary Tale and the Urgent Need for Equal Access to an Excellent Education
Response by Elise C. Boddie
130 Harv. L. Rev. F. 38
It is hard to remember a time in recent memory when the problems of racial injustice have been more visible and the need to promote opportunities for people of different racial and ethnic backgrounds has seemed more urgent. The very rawness and extent of these injustices are too disturbing to bear: videos of police killing unarmed African Americans;1× 1. See, e.g., Two Police Shootings, Two Videos, Two Black Men Dead, CNN (July 7, 2016, 2:25 PM), http://www.cnn.com/2016/07/07/us/shootings-alton-sterling-philando-castile/index.html [https://perma.cc/SNB6-NJFL]. reports by the Department of Justice documenting law enforcement's excessive force against, and harassment of, African Americans in Baltimore2× 2. See Civil Rights Div., U.S. Dep't of Justice, Investigation of the Baltimore City Police Department 3–11 (Aug. 10, 2016), https://www.justice.gov/opa/file/883366/download [https://perma.cc/2EKS-GHGS] (describing racial disparities in the policing of Baltimore's African American neighborhoods). and Ferguson;3× 3. See Civil Rights Div., U.S. Dep't of Justice, Investigation of the Ferguson Police Department 1–6 (Mar. 4, 2015), https://www.justice.gov/sites/default/files/opa/press-releases/attachments/2015/03/04/ferguson_police_department_report.pdf [https://perma.cc/X9GQ-7R7A] (describing racial disparities in the policing in Ferguson). xenophobic targeting of American Muslims and Mexican Americans by a presidential candidate;4× 4. See, e.g., Lydia O'Connor & Daniel Marans, Here Are 13 Examples of Donald Trump Being Racist, Huffington Post (Feb. 29, 2016, 5:17 PM), http://www.huffingtonpost.com/entry/donald-trump-racist-examples_us_56d47177e4b03260bf777e83 [https://perma.cc/7JK8-3J7Q]. judicial findings of overt minority voter suppression5× 5. See, e.g., N.C. State Conference of the NAACP v. McCrory, 831 F.3d 204, 214 (4th Cir. 2016) (concluding that voter restrictions "target[ed] African Americans with almost surgical precision," and that such restrictions were intentionally discriminatory); cf. Veasey v. Abbott, 830 F.3d 216 (5th Cir. 2016) (concluding that Texas voter restrictions had discriminatory impact under the Voting Rights Act). — to say nothing of systemic problems like disproportionately high unemployment6× 6. See Thomas J. Sugrue, Less Separate, Still Unequal: Diversity and Equality in "Post–Civil Rights," in Our Compelling Interests: The Value of Diversity for Democracy and a Prosperous Society 39, 60–62 (Earl Lewis & Nancy Cantor eds., 2016) [hereinafter Our Compelling Interests] (describing blacks' comparatively high unemployment and citing a study that found that "job applicants with names like Emily and Greg were more likely to be hired than those with comparable credentials named Lakisha and Jamal," id. at 61); Valerie Wilson, State Unemployment Rates by Race and Ethnicity at the End of 2015 Show a Plodding Recovery, Econ. Pol'y Inst. (Feb. 11, 2016), http://www.epi.org/publication/state-unemployment-rates-by-race-and-ethnicity-at-the-end-of-2015-show-a-plodding-recovery [https://perma.cc/8UWZ-2KMU] (discussing comparatively high unemployment rates of African Americans and Hispanics in specific states). and school7× 7. See generally Gary Orfield et al., The Civil Rights Project, UCLA, Brown at 60: Great Progress, a Long Retreat, and an Uncertain Future (May 15, 2014), [https://perma.cc/SX8V-LKME] (discussing the rise in the "double segregation" of students of color by race and class). and housing segregation8× 8. See Margery Austin Turner, Why Haven't We Made More Progress in Reducing Segregation?, N.Y.U. Furman Ctr. (Apr. 2014), http://furmancenter.org/research/iri/essay/why-havent-we-made-more-progress-in-reducing-segregation [https://perma.cc/87TR-F52Z]. that have long drained opportunities from communities of color. The list goes on and on.9× 9. See Sugrue, supra note 6, at 59–60, 63–68 (discussing persistent income inequality, higher rates of poverty, and the racial wealth gap); cf. Christopher Ingraham, Americans Say Racism Is a Bigger Problem Today Than at Any Point in the Past 20 Years, Wash. Post: Wonkblog (Aug. 5, 2015), https://www.washingtonpost.com/news/wonk/wp/2015/08/05/americans-say-racism-is-a-bigger-problem-today-than-at-any-point-in-the-past-20-years [https://perma.cc/5M6K-Y5U8] (commenting on a Pew Research poll that found that half of Americans think racism is a "big problem" in this country).
Given this persistent racism, we should put an end to the fiction fostered by the Supreme Court for the last several decades10× 10. See, e.g., Shaw v. Reno, 509 U.S. 630, 643 (1993) ("Classifications of citizens solely on the basis of race 'are by their very nature odious to a free people whose institutions are founded upon the doctrine of equality.'" (quoting Hirabayashi v. United States, 320 U.S. 81, 100 (1943))). that colorblindness is an appropriate response to our racial problems.11× 11. See Sugrue, supra note 6, at 47 ("Since the 1960s, it has become commonplace for Americans to express support for the ideal of 'colorblindness.'"). Along with a growing body of evidence about the pervasiveness and impact of implicit bias,12× 12. See Kwame Anthony Appiah, The Diversity of Diversity, in Our Compelling Interests, supra note 6, at 161, 164–66 (discussing how implicit bias corrupts our judgment about merit, skewing our decisionmaking against socially disfavored groups); Jerry Kang et al., Implicit Bias in the Courtroom, 59 UCLA L. Rev. 1124, 1130–31 (2012) (describing implicit bias as "pervasive," "large in magnitude (as compared to standardized measures of explicit bias," id. at 1130, and "predict[ive] [of] certain kinds of real-world behavior," id. at 1131). these events counsel instead that we focus on building a society that is more open, inclusive, and welcoming of racial and ethnic differences. That project requires a measure of intentionality that only affirmative action can deliver.
Fisher v. University of Texas at Austin (Fisher II)13× 13. 136 S. Ct. 2198 (2016). is cause for celebration because it reinforces the legitimacy of the diversity rationale for affirmative action in higher education and, therefore, underscores a principle of racial inclusion that has otherwise been absent from the Court's equal protection doctrine.14× 14. See, e.g., Parents Involved in Cmty. Sch. v. Seattle Sch. Dist. No. 1, 551 U.S. 701, 723–33 (2007) (declaring unconstitutional localities' use of race as a decisive factor in public school assignments as part of an effort to achieve the educational benefits of diversity, to "reduce the potentially harmful effects of racial isolation," id. at 786 (Kennedy, J., concurring in part and concurring in the judgment), and to avoid replicating racially segregated housing patterns in school enrollment, id. at 786–87); Adarand Constructors, Inc. v. Pena, 515 U.S. 200, 235 (1995) (concluding that racial classifications in a federal contracting program are subject to strict scrutiny); City of Richmond v. J.A. Croson Co., 488 U.S. 469, 510–11 (1989) (plurality opinion) (rejecting use of race to remedy racial disparities in local contracting); Regents of the Univ. of Cal. v. Bakke, 438 U.S. 265, 310 (1978) (opinion of Powell, J.) (rejecting "societal discrimination" as a justification for affirmative action in medical school admissions); Washington v. Davis, 426 U.S. 229, 239 (1976) (rejecting disparate impact standard under the Equal Protection Clause to challenge police exam that disadvantaged black applicants). In this respect, Fisher II matters because of what it was not: a loss that closed yet another door to opportunity for people of color.
Professor Kimberly Jenkins Robinson's Comment portrays Fisher II differently. She argues that the decision imposes a "demanding evidentiary burden" on universities that practice race-conscious admissions15× 15. See Kimberly Jenkins Robinson, The Supreme Court, 2015 Term — Comment: Fisher's Cautionary Tale and the Urgent Need for Equal Access to an Excellent Education, 130 Harv. L. Rev. 185, 188 (2016) ("Fisher II offers some assistance to institutions that want to employ affirmative action, but also provides a cautionary tale about the demanding evidentiary burden that [they] must carry to prevail."); id. at 189 ("Fisher II may benefit universities that seek to consider an applicant's race among many factors to assemble a diverse class. . . . [A]t the same time, Fisher II may make it harder for universities that do so to withstand the Court's demanding evidentiary burden."). and, therefore, runs the risk of chilling affirmative action.16× 16. See id. at 204 ("Fisher II's insistence on such thorough data and research on these issues may chill the use of affirmative action on campuses that want to avoid the risks of litigation or the costs of preparing a potential defense."). More specifically, she contends that the Court in Fisher I17× 17. Fisher v. Univ. of Tex. at Austin (Fisher I), 133 S. Ct. 2411 (2013). and Fisher II tightened Grutter v. Bollinger's18× 18. 539 U.S. 306 (2003). narrow-tailoring standard.19× 19. See Robinson, supra note 15, at 200 ("The Court in Fisher I moved away from [Grutter's] deferential approach, and in Fisher II applied a more demanding evidentiary analysis than that of Grutter.").
It is not clear, however, that the standard articulated in Fisher I, as applied in Fisher II, is meaningfully different from that in Grutter.20× 20. Compare Grutter, 539 U.S. at 339 ("Narrow tailoring does not require exhaustion of every conceivable race-neutral alternative. Nor does it require a university to choose between maintaining a reputation for excellence or fulfilling a commitment to provide educational opportunities to members of all racial groups. Narrow tailoring does, however, require serious, good faith consideration of workable race-neutral alternatives that will achieve the diversity the university seeks." (citations omitted)), with Fisher II, 136 S. Ct. 2198, 2208 (2016) ("Though '[n]arrow tailoring does not require exhaustion of every conceivable race-neutral alternative' or 'require a university to choose between maintaining a reputation for excellence [and] fulfilling a commitment to provide educational opportunities to members of all racial groups,' it does impose 'on the university the ultimate burden of demonstrating' that 'race-neutral alternatives' that are both 'available' and 'workable' 'do not suffice.'" (alterations in original) (first and second quoting Grutter, 539 U.S. at 339, and then quoting Fisher I, 133 S. Ct. at 2420)). At most, the Court in Fisher II clarified that the "serious, good faith consideration" requirement from Grutter meant that a university must "demonstrat[e]" the insufficiency of race-neutral alternatives. Rather, what the Court objected to in Fisher I was the Fifth Circuit panel's misinterpretation of language in Grutter that "the narrow-tailoring inquiry . . . must be calibrated to fit the distinct issues raised by the use of race to achieve student body diversity in public higher education."21× 21. Grutter, 539 U.S. at 333–34. The court of appeals read that language to mean that it should defer to the university's judgment about the necessity of using race.22× 22. See Fisher v. Univ. of Tex. at Austin, 631 F.3d 213, 232 (5th Cir. 2011) ("[T]he narrow-tailoring inquiry — like the compelling-interest inquiry — is undertaken with a degree of deference to the University's constitutionally protected, presumably expert academic judgment."), rev'd, Fisher I, 133 S. Ct. 2411; see also id. at 233 ("Grutter teaches that so long as a university considers race in a holistic and individualized manner, and not as part of a quota or fixed-point system, courts must afford a measure of deference to the university's good faith determination that certain race-conscious measures are necessary to achieve the educational benefits of diversity, including attaining critical mass in minority enrollment.").
A more plausible reading of the Grutter language is that the Court intended the narrow-tailoring inquiry to accommodate the unique educational benefits that accompany diversity-focused admissions policies in higher education. The Grutter opinion took pains to distinguish its diversity analysis — which focuses on ensuring consideration of all "pertinent elements of diversity in light of the particular qualifications of each applicant" — from its other (nondiversity-based) affirmative action jurisprudence where such concerns do not figure into the Court's equal protection standard.23× 23. Grutter, 539 U.S. at 334 (quoting Regents of the Univ. of Cal. v. Bakke, 438 U.S. 265, 317 (1978) (opinion of Powell, J.)). The relevant portion of Grutter reads in full:
Since Bakke, we have had no occasion to define the contours of the narrow-tailoring inquiry with respect to race-conscious university admissions programs. That inquiry must be calibrated to fit the distinct issues raised by the use of race to achieve student body diversity in public higher education. Contrary to Justice Kennedy's assertions, we do not "abando[n] strict scrutiny." Rather, as we have already explained, we adhere to Adarand's teaching that the very purpose of strict scrutiny is to take such "relevant differences into account."
To be narrowly tailored, a race-conscious admissions program cannot use a quota system — it cannot "insulat[e] each category of applicants with certain desired qualifications from competition with all other applicants." Instead, a university may consider race or ethnicity only as a "'plus' in a particular applicant's file," without "insulat[ing] the individual from comparison with all other candidates for the available seats." In other words, an admissions program must be "flexible enough to consider all pertinent elements of diversity in light of the particular qualifications of each applicant, and to place them on the same footing for consideration, although not necessarily according them the same weight."
We find that the Law School's admissions program bears the hallmarks of a narrowly tailored plan. As Justice Powell made clear in Bakke, truly individualized consideration demands that race be used in a flexible, nonmechanical way. It follows from this mandate that universities cannot establish quotas for members of certain racial groups or put members of those groups on separate admissions tracks. Nor can universities insulate applicants who belong to certain racial or ethnic groups from the competition for admission. Universities can, however, consider race or ethnicity more flexibly as a "plus" factor in the context of individualized consideration of each and every applicant.
Id. at 333–34 (alterations in original) (citations omitted) (first quoting id. at 394 (Kennedy, J., dissenting), second quoting Adarand Constructors, Inc. v. Pena, 515 U.S. 200, 228 (1995), third quoting Bakke, 438 U.S. at 315 (opinion of Powell, J.), and then quoting Bakke, 438 U.S. at 317). Understood in this way, Fisher I did not impose a more burdensome narrow-tailoring standard than Grutter but merely clarified that narrow tailoring was not less burdensome than what Grutter intended.24× 24. See Fisher II, 136 S. Ct. at 2208 ("Fisher I clarified that no deference is owed when determining whether the use of race is narrowly tailored to achieve the university's permissible goals."). Robinson asserts that Fisher I "raised the evidentiary bar on the consideration of race-neutral alternatives" because it "held that a 'court must ultimately be satisfied that no workable race-neutral alternatives would produce the educational benefits of diversity.'" Robinson, supra note 15, at 200–01 (quoting Fisher I, 133 S. Ct. at 2420). Robinson's claim might be read to suggest that a university must exhaust consideration of race-neutral policies to show that no "workable" and "available" race-neutral alternatives actually exist. Fisher II, however, emphasized that although a university bears "'the ultimate burden of demonstrating' that 'race-neutral alternatives' that are both 'available' and 'workable' 'do not suffice,'" Fisher II, 136 S. Ct. at 2208 (quoting Fisher I, 133 S. Ct. at 2420), it need not "exhaust[] . . . every conceivable race-neutral alternative," id. (quoting Grutter, 539 U.S. at 339). The Court stated that a university can satisfy its burden by showing that a given race-neutral alternative "would not promote its interest in the educational benefits of diversity 'about as well and at tolerable administrative expense,'" id. (quoting Fisher I, 133 S. Ct. at 2420), because such an alternative would "require a university to choose between maintaining a reputation for excellence [and] fulfilling a commitment to provide educational opportunities to members of all racial groups," id. (quoting Grutter, 539 U.S. at 339); cf. id. at 2212–13 (rejecting the petitioner's argument that race-neutral alternatives existed because "none of her proposed alternatives was a workable means for the University to attain the benefits of diversity it sought," id. at 2212). Thus, while the university bears the burden of showing why a given alternative would not allow it to meet its educational objectives, the Court's willingness to factor in a university's reputational interests and broad commitment to providing educational opportunities appears to set a soft baseline for meeting this requirement.
Other aspects of the Fisher II opinion also cast some doubt on the notion that the Court has imposed a more demanding burden of proof.25× 25. See Robinson, supra note 15, at 198 ("Fisher II increased the evidentiary burdens for universities and colleges to prove the interrelated requirements that the consideration of race is necessary and that they faithfully assessed workable race-neutral alternatives beyond the standard required in Grutter."). Indeed, the decision recognizes that some evidentiary uncertainty inheres in the educational nature of the diversity rationale. As Justice Kennedy observed, "[a] university is in large part defined by those intangible 'qualities which are incapable of objective measurement but which make for greatness,'"26× 26. Fisher II, 136 S. Ct. at 2214 (quoting Sweatt v. Painter, 339 U.S. 629, 634 (1950)). meaning that the benefits of inclusion cannot necessarily be captured with quantitative precision.27× 27. Cf. Grutter, 539 U.S. at 328 ("Our scrutiny of the interest asserted by the Law School is no less strict for taking into account complex educational judgments in an area that lies primarily within the expertise of the university."). Of course, we can reasonably assume that future higher education cases might lead courts to compare the evidentiary record of defending institutions with that compiled by the University of Texas. And, from this perspective, Fisher II provides welcome guidance about the kinds of evidence that similarly situated universities might offer to justify their policies.28× 28. See Robinson, supra note 15, at 197 ("Most importantly, Fisher II provides much-needed guidance on the types of evidence that colleges and universities will need to present in court to survive a constitutional challenge given the minimal guidance in Grutter. . . . Fisher II offers an instructive roadmap for university officials."). However, this does not mean that the Court has in fact heightened the evidentiary standard beyond what Grutter required, as Robinson contends.29× 29. Cf. id. at 198 ("Despite [Fisher II's] potential benefits, however, [it] also erected new hurdles.").
Robinson also cautions that we should be wary of Fisher II because Justice O'Connor's 2003 Grutter opinion sets an expiration date for affirmative action. Robinson points to Justice O'Connor's declaration that the Court "expect[s]" explicit uses of race to "no longer be necessary" in twenty-five years,30× 30. Grutter, 539 U.S. at 343 ("It has been 25 years since Justice Powell first approved the use of race to further an interest in student body diversity in the context of public higher education. Since that time, the number of minority applicants with high grades and test scores has indeed increased. We expect that 25 years from now, the use of racial preferences will no longer be necessary to further the interest approved today." (citation omitted)). which, if taken literally, would mean that affirmative action would end in 2028.31× 31. See Robinson, supra note 15, at 186 ("[T]he Court in Grutter v. Bollinger stated that affirmative action to ensure diversity's educational benefits must eventually come to an end and suggested that that end point would be twenty-five years after Grutter."). But see id. at 196 ("Fisher II did not mention the need for a termination point for affirmative action."). At times Robinson appears to equivocate on the anticipated timeline for affirmative action. See, e.g., id. at 196 ("The Court's silence in Fisher II about any durational limits on affirmative action, rather than reaffirming the importance of a termination point or Grutter's 2028 endpoint, may allow institutions to employ affirmative action beyond the 2028 deadline as long as they are engaging in periodic review.").
But Justice O'Connor's statement suggests goals that are more aspirational than mandatory.32× 32. See Parents Involved in Cmty. Sch. v. Seattle Sch. Dist. No. 1, 551 U.S. 701, 731 (2007) ("The Ninth Circuit below stated that it 'share[d] in the hope' expressed in Grutter">https://1.next.westlaw.com/Link/Document/FullText?findType=Y&serNum=2003444559&originatingDoc=I6f68b25c258611dcaf8dafd7ee2b8b26&refType=RP&originationContext=document&transitionType=DocumentItem&contextData=%28sc.Search%29″>Grutter that in 25 years racial preferences would no longer be necessary to further the interest identified in that case." (alteration in original) (quoting Parents Involved in Cmty. Sch. v. Seattle Sch. Dist. No. 1, 426 F.3d 1162, 1192 (9th Cir. 2005), rev'd on other grounds, 551 U.S. 701)); see also Vinay Harpalani, Narrowly Tailored but Broadly Compelling: Defending Race-Conscious Admissions After Fisher, 45 Seton Hall L. Rev. 761, 775–76 (2015) (observing that, unlike remedial rationales, "diversity is ageless in its reach into the future," id. at 776). Her statement begins with the observation that "the number of minority applicants with high grades and test scores increased" in the twenty-five years between Grutter and Regents of the University of California v. Bakke,33× 33. 438 U.S. 265 (1978). where the diversity rationale first surfaced.34× 34. Grutter, 539 U.S. at 343. Justice O'Connor's twenty-five-year declaration likely reflects her assumption that such progress would continue through the next quarter century, obviating the need for race-specific measures to enhance minority representation in higher education.35× 35. See id. As recent history illustrates, however, we are nowhere close to the kind of sustained improvement in opportunities for people of color that would justify Justice O'Connor's optimism.36× 36. Cf. Parents Involved, 551 U.S. at 787 (Kennedy, J., concurring in part and concurring in the judgment) ("The enduring hope is that race should not matter; the reality is that too often it does."); Earl Lewis & Nancy Cantor, Introduction: the Value of Diversity for Democracy and a Prosperous Society, in Our Compelling Interests, supra note 6, at 1, 10–11 ("[W]e cannot simply presume progress, especially as patterns of residential, educational, and economic segregation have in many ways hardened over decades." Id. at 10.); Sugrue, supra note 6, at 46 (describing the half century following the civil rights movement of the 1960s as one of "gains and setbacks, of expanding opportunities and still-wrenching injustices, of disadvantages by race and ethnicity sometimes overcome, but just as often intensified and compounded"). The Court's recognition of this hard reality may explain why Fisher II nowhere mentions Justice O'Connor's hope for permanently sunsetting affirmative action.37× 37. Robinson acknowledges this point. See Robinson, supra note 15, at 196. The permanent ban on affirmative action suggested by Robinson is not the same as requiring sunset provisions in affirmative action policies in order to incentivize institutions to revisit the necessity of such policies.
It is worth emphasizing that Fisher II embraces Grutter's central conclusion about the social benefits of diversity.38× 38. Fisher II, 136 S. Ct. 2198, 2210 (2016) ("[A] university may institute a race-conscious admissions program as a means of obtaining 'the educational benefits that flow from student body diversity.'" (quoting Fisher I, 133 S. Ct. 2411, 2419 (2013)); Grutter, 539 U.S. at 327–32. As Robinson notes, the decision approvingly cites the University of Texas's goals of reducing stereotypes, promoting cross-racial understanding, preparing the student body for diversity in the workplace and the rest of society, and cultivating leaders who have "legitimacy in the eyes of the citizenry" because of their diverse backgrounds.39× 39. Fisher II, 136 S. Ct. at 2211 (quoting Supplemental Joint Appendix at 1a, Fisher II, 136 S. Ct. 2198 (No. 14-981)). Thus, as in Grutter,40× 40. 539 U.S. at 327–32. Fisher II acknowledges that the benefits of diversity not only inure to students in institutions of higher education but also accrue more broadly to the workforce and to society as a whole.41× 41. See Fisher II, 136 S. Ct. at 2211 ("All of these objectives, as a general matter, mirror the 'compelling interest' this Court has approved in its prior cases.").
We should pause on the potential significance of this acknowledgment. Like Grutter,42× 42. See Grutter, 539 U.S. at 332 ("As we have recognized, law schools 'cannot be effective in isolation from the individuals and institutions with which the law interacts.'" (quoting Sweatt v. Painter, 339 U.S. 629, 634 (1950))). Fisher II recognizes that universities do not operate in isolation from other social institutions. The recognition that diversity can deepen our connections across different settings suggests that the diversity rationale should be extended beyond higher education. If preparing students to engage in an increasingly diverse society justifies the narrow consideration of race in college admissions, why not allow similar affirmative action policies in the workforce43× 43. See Anthony Carnevale & Nicole Smith, The Economic Value of Diversity, in Our Compelling Interests, supra note 6, at 106, 108–23 (discussing diversity's benefits in the workplace). See generally Cynthia L. Estlund, Working Together: The Workplace, Civil Society, and the Law, 89 Geo. L.J. 1 (2000) (same). and K-12 education, for example? The nature of the diversity rationale — that our interactions provide opportunities to help us understand one another better44× 44. See, e.g., Regents of the Univ. of Cal. v. Bakke, 438 U.S. 265, 313 n.48 (1978) (opinion of Powell, J.) ("[I]nformal 'learning through diversity' [can occur through] the unplanned, casual encounters with roommates, fellow sufferers in an organic chemistry class, student workers in the library, teammates on a basketball squad, or other participants in class affairs or student government [and] can be subtle and yet powerful sources of improved understanding and personal growth." (quoting William G. Bowen, Admissions and the Relevance of Race, Princeton Alumni Wkly., Sept. 26, 1977, at 9)). — should justify its constitutional legitimacy not only in colleges and universities but also across the institutional spectrum.45× 45. Cf. Grutter, 539 U.S. at 331–32 ("[E]nsuring that public institutions are open and available to all segments of American society, including people of all races and ethnicities, represents a paramount government objective." (quoting Brief for the United States as Amicus Curiae Supporting Petitioner at 16, Grutter, 539 U.S. 306 (No. 02-241))).
Of course, the Court has yet to uphold diversity policies outside higher education.46× 46. See, e.g., Parents Involved in Cmty. Sch. v. Seattle Sch. Dist. No. 1, 551 U.S. 701 (2007); City of Richmond v. J.A. Croson Co., 488 U.S. 469 (1989). And, as the majority opinion notes, Fisher II's somewhat unique facts may limit its future application.47× 47. Fisher II, 136 S. Ct. at 2208 (describing admissions program as "sui generis"); id. at 2209 ("The fact that this case has been litigated on a somewhat artificial basis . . . may limit its value for prospective guidance."). But some optimism may be justified if we interpret Fisher II to shift equal protection's focus from eliminating affirmative action itself, as the Court's pre-Grutter cases suggest,48× 48. See supra note 14 (listing cases). to ensuring the accountability of institutions that practice it. As Fisher II counsels, institutions that rely on race-conscious measures must articulate their institutional goals for diversity in "sufficiently measurable" terms,49× 49. Fisher II, 136 S. Ct. at 2211. thoughtfully demonstrate why race-neutral alternatives do not suffice for meeting those goals,50× 50. Id. at 2208. and ensure meaningful and ongoing deliberation about the continued necessity of using race.51× 51. Id. at 2210 ("Through regular evaluation of data and consideration of student experience, the University must tailor its approach in light of changing circumstances, ensuring that race plays no greater role than is necessary to meet its compelling interest."); id. at 2214–15 ("The University must continue to use this data to scrutinize the fairness of its admissions program; to assess whether changing demographics have undermined the need for a race-conscious policy; and to identify the effects, both positive and negative, of the affirmative-action measures it deems necessary."). That burden is not light — it requires particular care when adopting and implementing race-conscious policies — as Grutter's original "serious, good faith consideration" standard might indicate.52× 52. Grutter, 539 U.S. at 339. But this rigor does not mean the death knell for affirmative action, as Robinson suggests, so long as institutions invest in the proper procedural safeguards to facilitate judicial scrutiny of race-conscious policies.53× 53. See Fisher II, 136 S. Ct. at 2211 (stating that the institutions' goals should be "sufficiently measurable to permit judicial scrutiny of the policies adopted to reach them" by providing "a 'reasoned, principled explanation' for [their] decision[s]" (quoting Fisher I, 133 S. Ct. at 2419)).
Indeed, Fisher II may give institutions that provide the same kinds of institutional safeguards some constitutional safe harbor to pursue race-conscious diversity policies beyond the context of higher education.54× 54. Cf. Parents Involved in Cmty. Sch. v. Seattle Sch. Dist. No. 1, 551 U.S. 701, 782 (2007) (Kennedy, J., concurring in part and concurring in the judgment) (discussing the virtues of diversity in "[t]he Nation's schools"). Justice Kennedy's concurrence in Parents Involved in Community Schools v. Seattle School District No. 155× 55. 551 U.S. 701. hints at this possibility for K-12 education. Justice Kennedy joined in the Court's opinion that the Seattle and Jefferson County school districts' blunt racial classifications were neither properly conceptualized nor narrowly tailored.56× 56. Id. at 735 ("Classifying and assigning schoolchildren according to a binary conception of race is an extreme approach in light of our precedents and our Nation's history of using race in public schools, and requires more than such an amorphous end to justify it."). A significant problem for Justice Kennedy was that it was difficult to understand precisely why and how the school districts were considering race.57× 57. See id. at 784–85 (Kennedy, J., concurring in part and concurring in the judgment) ("Jefferson County in its briefing has explained how and when it employs [racial] classifications only in terms so broad and imprecise that they cannot withstand strict scrutiny."); cf. Grutter, 539 U.S. at 327–28 ("Before this Court, as they have throughout this litigation, respondents assert only one justification for their use of race in the admissions process: obtaining 'the educational benefits that flow from a diverse student body.'" (quoting Brief for Respondents at i, Grutter, 539 U.S. 306 (No. 02-241))).
Justice Kennedy departed, however, from the plurality's suggestion that diversity itself was not a constitutionally legitimate interest in K-12 education.58× 58. Parents Involved, 551 U.S. at 782 (Kennedy, J., concurring in part and concurring in the judgment) ("The Nation's schools strive to teach that our strength comes from people of different races, creeds, and cultures uniting in commitment to the freedom of all. In these cases two school districts in different parts of the country seek to teach that principle by having classrooms that reflect the racial makeup of the surrounding community. That the school districts consider these plans to be necessary should remind us our highest aspirations are yet unfulfilled."); see also id. at 782–83 (expressing agreement with the Court's judgment but noting that "[his] views do not allow [him] to join the balance of the [plurality's] opinion . . . , which seems . . . inconsistent in both its approach and its implications with the history, meaning, and reach of the Equal Protection Clause"). He asserted that promoting diversity and redressing racial isolation can be permissible objectives,59× 59. Id. at 788–89. but that the school districts had fallen short because they did not clearly articulate their educational goals or their means for accomplishing them.60× 60. Id. at 784 ("The government bears the burden of justifying its use of individual racial classifications. As part of that burden it must establish, in detail, how decisions based on an individual student's race are made in a challenged governmental program."). While indicating his continuing wariness of racial classifications,61× 61. Id. at 790 ("And individual racial classifications employed in this manner may be considered legitimate only if they are a last resort to achieve a compelling interest."). Justice Kennedy's concurrence suggests that appropriately calibrated policies that advance clear diversity goals may yet satisfy strict scrutiny in other contexts,62× 62. Id. at 783 ("Diversity, depending on its meaning and definition, is a compelling educational goal a school district may pursue."). if institutions are willing to do some homework on the front end. As a reliable indicator of the Court's center-right race jurisprudence, Justice Kennedy's Parents Involved concurrence hardly signals the end of diversity-based affirmative action,63× 63. In Schuette v. Coalition to Defend Affirmative Action, Integration and Immigrant Rights and Fight for Equality by Any Means Necessary (BAMN), 134 S. Ct. 1623 (2014), the Court voted to uphold a state constitutional amendment banning affirmative action, but this was enacted by voter referendum and is distinguishable from affirmative action policies that are voluntarily adopted by public institutions. particularly when we pair it with his majority opinion in Fisher II.
All that said, it is hard to ignore that the Court decided Fisher II against the backdrop of deep racial unrest, spurred by long-simmering frustrations over police brutality and the multiple failures of our institutions to address pervasive inequality,64× 64. See generally Elise C. Boddie, Adaptive Discrimination, 94 N.C. L. Rev. 1235 (2016) (discussing persistence of racial inequality over time). including concentrated, racialized poverty.65× 65. See, e.g., John Eligon, Racial Violence in Milwaukee Was Decades in the Making, Residents Say, N.Y. Times (Aug. 14, 2016), http://www.nytimes.com/2016/08/15/us/racial-violence-in-milwaukee-was-decades-in-the-making-residents-say.html [https://perma.cc/8J5W-6THM]. The irony of Fisher II's win for diversity-based affirmative action, therefore, is that it points to a broader problem, typically lost in the public conversation about race, that the Court over the last several decades has consistently blocked more robust race-conscious policies that could have helped match the expanse and intensity of our dynamic racial problems.66× 66. See Regents of the Univ. of Cal. v. Bakke, 438 U.S. 265, 310 (1978) (opinion of Powell, J.).
Eliminating entrenched racial disadvantage admittedly requires a different kind of affirmative action than diversity policies can deliver.67× 67. See Sugrue, supra note 6, at 39–41 ("Diversity is necessary but far from sufficient to ensure a more just and equal society." Id. at 40.). A more vigorous form of affirmative action — effectively disallowed by the Court since Bakke — would promote opportunity for African Americans, Latinos, Asians, and other racially marginalized groups through more race-targeted means. The road to the kind of doctrinal change that would allow such policies is surely long,68× 68. Cf. Parents Involved in Cmty. Sch. v. Seattle Sch. Dist. No. 1, 551 U.S. 701, 797 (2007) (Kennedy, J., concurring in part and concurring in the judgment) ("The idea that if race is the problem, race is the instrument with which to solve it cannot be accepted as an analytical leap forward."). but Fisher II may hold clues for pushing equal protection in that direction. If what really matters is the kind of institutional transparency that guarantees meaningful judicial review (and likely also public accountability), then why not allow racial considerations for the purpose of redressing racial disadvantage?
As in Grutter, such a shift would necessarily require the Court to recognize a new brand of compelling interest: promoting the inclusion of racial groups that historically have been abandoned at the margins of society. With some significant social pressure, perhaps from Black Lives Matter and other quarters, the Court may well be persuaded that the country would be best served by a more inclusionary focus than the diversity rationale alone can accommodate.
Response To
Fisher's Cautionary Tale and the Urgent Need for Equal Access to an Excellent Education by Kimberly Jenkins Robinson
This leads me to what I take to be the central point of Robinson's Comment — that we should foster a more intentional focus on remedying educational disadvantage.69× 69. Robinson, supra note 15, at 188 ("[M]uch greater care and attention must be paid to the educational opportunity gaps and resulting achievement gaps that prompt many colleges and universities to rely on affirmative action."). She is right to direct our attention — not only in this Comment, but in her larger body of work — to the searing racial inequality in our nation's public schools.70× 70. See, e.g., Kimberly Jenkins Robinson, Resurrecting the Promise of Brown: Understanding and Remedying How the Supreme Court Reconstitutionalized Segregated Schools, 88 N.C. L. Rev. 787 (2010). Her scholarship justly calls attention to federal constitutional barriers, like San Antonio Independent School District v. Rodriguez,71× 71. 411 U.S. 1 (1973). that disable cities and towns from securing the necessary resources for chronically underfunded schools.72× 72. See Robinson, supra note 15, at 230. The key lesson is that equal protection has precluded the very kinds of measures that would most meaningfully advance educational opportunity for students of color while at the same time limiting the kinds of affirmative action that would compensate for significant deficiencies in public education.
I agree with Robinson, therefore, that we should focus particular attention on educationally underserved populations, including African Americans and Latinos who are uniquely burdened by the disadvantages that accompany concentrated poverty.73× 73. See Sugrue, supra note 6, at 63–65 (discussing poverty). But I am skeptical that we can get there through means that are strictly race-neutral, as Robinson suggests.74× 74. See Robinson, supra note 15, at 188 (recommending "that universities consider 'educational disadvantage' as a race-neutral alternative in admissions"). The extent of the problem is so deep and so pervasive that it calls for more targeted uses of race.
Effectuating the doctrinal shift that would allow such racially specific policies, however, would require the Court to confront the assumption, now deeply embedded in equal protection, that advancing racial equality can come only at the expense of anxious and resentful whites.75× 75. See Elise C. Boddie, The Sins of Innocence in Standing Doctrine, 68 Vand. L. Rev. 297, 324–30 (2015) (discussing the Court's conceptualization of white resentment as a racial injury); Reva B. Siegel, From Colorblindness to Antibalkanization: An Emerging Ground of Decision in Race Equality Cases, 120 Yale L.J. 1278, 1293–99 (2011) (discussing the Court's concerns about white resentment over the use of racially explicit forms of affirmative action). Justice Powell argued fairly explicitly in Bakke that broadening affirmative action would be racially divisive because it would cost whites, as a group, access and power.76× 76. See Regents of the Univ. of Cal. v. Bakke, 438 U.S. 265, 294 n.34 (1978) (opinion of Powell, J.); Boddie, supra note 75, at 324–35. His influential opinion concluded that strict scrutiny should apply even to racially benign government programs, such as affirmative action, and that redressing "societal discrimination" was not a sufficiently compelling interest to justify particularized uses of race.77× 77. Bakke, 438 U.S. at 310. In place of race-specific policies that targeted people of color, Justice Powell opted for a different path that gave birth to the modern diversity rationale that was affirmed by the Court in Grutter.78× 78. See Grutter v. Bollinger, 539 U.S. 306, 343 (2003) ("[T]he Equal Protection Clause does not prohibit the Law School's narrowly tailored use of race in admissions decisions to further a compelling interest in obtaining the educational benefits that flow from a diverse study body."). The Court also recognized the benefits of diversity, though in different terms, in Sweatt v. Painter:
The law school, the proving ground for legal learning and practice, cannot be effective in isolation from the individuals and institutions with which the law interacts. Few students and no one who has practiced law would choose to study in an academic vacuum, removed from the interplay of ideas and the exchange of views with which the law is concerned.
339 U.S. 629, 634 (1950). His opinion also laid the foundation for later equal protection decisions invalidating racial classifications designed to achieve racial diversity and to avoid racial isolation and promote equitable access to public schools;79× 79. See Parents Involved in Cmty. Sch. v. Seattle Sch. Dist. No. 1, 551 U.S. 701 (2007). to provide jobs for people of color in contracting at the state and local levels;80× 80. City of Richmond v. J.A. Croson Co., 488 U.S. 469, 511 (1989) (plurality opinion); cf. Adarand Constructors, Inc. v. Pena, 515 U.S. 200, 235 (1995). and to increase opportunities for racial minorities to elect candidates of their choice through majority-minority voting districts.81× 81. Shaw v. Hunt, 517 U.S. 899, 918 (1996) (declaring majority-minority voting district unconstitutional).
In order to reshape equal protection to allow more robust affirmative action, the Court and the public itself must see that the fate of our increasingly diverse country is tied in significant part to the fate of people of color.82× 82. See William H. Frey, The "Diversity Explosion" Is America's Twenty-First-Century Baby Boom, in Our Compelling Interests, supra note 6, at 16, 16–35 (describing significant increase in populations of color and arguing that "demography is destiny," id. at 28). As recent events make clear, racial inclusion, whether under the auspices of diversity or other race-conscious policies, benefits the country and whites as a whole; only by bringing all racial groups into the social, economic, and political fold can the country hope to move forward. Affirmative action, in other words, is not counter to the interests of whites, as the Court has long assumed. Rather, it aligns with their interests directly.83× 83. See Lewis & Cantor, supra note 36, at 6 (posing the question: "Is the perceived legitimacy of American institutions — from those that educate to those that adjudicate, from those that promulgate free expression to those that safeguard our security — at risk when so many are left behind in the 'land of opportunity'?").
This takes me back to where this Response began, which is about how we align equal protection with the hard realities of entrenched racial inequality. As people of color become a majority of the population, it may become more self-evident to the Court that their future is this country's future. Fisher II may be a small, but meaningful, step in that direction.
* Henry Rutgers University Professor, Professor of Law & Robert L. Carter Scholar, Rutgers Law School. I am grateful to Robin Lenhardt and to the editors of the Harvard Law Review for their insightful comments on earlier drafts of this Response.
Nov '16 Vol 130 No. 1


Posted March 18, 2019 by efpdw & filed under Designers.
A & B Group , established in the year 1979 is one of the few firms in Kerala , specializing in Interior decoration and designing . Located in the heritage town of Thripunithura , the firm is promoted by Mr Antony Joseph who has more than 25 years of experience in the field of Interior & Building Design. He is not just an excellent painter but is equally famous for his expertise in sculpturing and Art Direction . Mr. Antony Joseph is also incomparable for his impeccable knowledge in vaasthu shastra .The unique blend of tradition and technology he imparts in his work be it interior designing, sculpturing, painting or landscaping is one the major reason why the group has now become a big success in a relatively short time span. He is also one of the few in the state who uses vaasthu vidya from various north Indian states and Mumbai in his works.
AB is one of the leading professional interior design organization from Cochin, undertaking contract works for building. With nearly a decade of experience in the field of building contracts, AB aims in constructing building in old fashion way. The company aspires and endeavors to meet client's requirement to the maximum. Our services include building construction, interior designs.
Our task include both the designing and constructors. Any built structure is an outcome of close coordination and participation of a number of people, technical and non-technical, including architects, contractors, surveyors, engineers, designers along with bricklayers, masons, carpenters, electricians, plumbers etc. Everyone is specialized in his own area hence beyond comparison.
The work starts on the basis of ideas and requirements of the client like its appearance, financial budget and time frame. Demand for interior designers continue to be high with these no longer limiting to corporate offices and hotels alone. One can see it coming into houses in a big way. Interior designers require abstract reasoning and three dimensional space perception to translate ideas into realities. Understanding client's need is at the very core of the profession. models and graghic are also used for presentations. Once the plans are finalised and accepted by the client, the architect has to obtain the approval and permission of the local authority for construction.


A collaboration with a design school about reimagining together quantum physics.
Quantum Design ? The framework.
After a previous project about superconductivity, physicists specialists of quantum physics have once again worked with a design school, the ENSCI-Les Ateliers, this time about quantum physics. Students were asked to imagine a new way of showing quantum physics and describing its laws and strange behaviors to make them more accessible to large public. Quantum physics was also a source of inspiration in order to reimagine new tools, new objects and new uses, even new methods. The creations issued from this project are bridging outreach, art and design.
This project was developed in collaboration between the students of the workshop « Design and Research » of François Azamboug at the school of design ENSCI-Les Ateliers, and the physicist Julien Bobroff (Physics Autrement, LPS, University Paris -South). The quantum design project is a partnership between the ENSCI-LES ATELIERS and physicists from université Paris Sud and CNRS. It was supportes by la Diagoale Paris-Saclay, the institut de Physique of the CNRs, université Paris Sud and the Société Française de Physique.


I am flying down to California tomorrow to visit family and attend the Santa Barbara Writers Conference. There will be many exciting workshops, panels and talks to attend. I'm looking forward to learning a lot, meeting new people, and of course getting some writing done in the midst of it all. I will have a chance to pitch Heir to Elara to few agents as well.
Ray Bradbury will be giving the key note speech again. I wrote a post called "Ray Bradbury Speaks" about his inspiring speech last year.


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Nordold Completes IT Structure Integration into Enterprise Communications
Nord Gold N.V., international gold mining company (Nordgold, the company, LSE: NORD) announces completion of integration of its IT infrastructure into enterprise communications network. The contract for this ambitious project was awarded to I.T. Co.
In order to increase operational efficiency and optimize management of assets, a unified informational environment was deployed in Nordgold HQ in Moscow and at 9 gold mines in Russia, Kazakhstan, Guinea and Burkina Faso. The unified IT infrastructure enables continuous communications and rapid data sharing between the employees and supports deployment of business systems of the company.
I.T. Co. managed to simultaneously deploy commutating infrastructure over 10 geographically dispersed objects and completed the project in accordance with global quality standards.
The project was launched in Autumn 2013. I.T. Co. specialists have developed a technical plan for organizational and technical complex of software, computational and communicational solutions, detailed designs for system services and operating regulations. After that, system components were deployed on each object including city offices and mines, and inherited data was migrated to the new environment.
The model, designed according to IT Nordgold enterprise model, included: authentication and authorization service, DNS and DHCP services, enterprise email and antivirus security service.
As a result, in the geographically dispersed company Nordgold, unification and standardization of IT service and data procession was completed fully. IT resource management was centralized by creating unified informational space for every Nordgold mine and office and centralization of data storage systems. In addition, IT service reliability was increased considerably by introducing data protection and IT software and hardware mirroring. In total, the infrastructure had united about 9000 employees of the gold mining company.
Victor Skorobogatov, Head of IT, Nordgold, said:
"Before the project was successfully complete, we were faced with challenges of introducing new business applications on every level of the corporation, because to deploy a unified IT system, one has to get their infrastructure prepared first. Our company, composing 9 enterprises, had inherited a diverse IT environment with no sole automation policy. Now, every Nordgold enterprise is integrated into a unified data transmission network, enabling rapid integration of centralized systems that simplifies solving business tasks and delivers IT services of established enterprise standard and level."
Mikhail Rechkunov, manager of the project, I.T. Co., commented:
"We were really interested in completing such an ambitious and important project, managing people and processes in different time zones and parts of the world. From different points, differently atomized and under different laws, we have composed a unified IT infrastructure developed using best world practices."
About Nordgold
Nordgold (LSE: NORD) is an independent international gold mining company founded in 2007, with its GDR traded at London Stock Exchange. The company had rapidly expanded thanks to obtaining new and developing existing assets, reaching record growth terms for the industry. In 2013, Nordgold overall gold production reached 924 thousand ounce, compared to 717 thousand in 2012.
The company controls 9 operating mines, 2 development projects, 4 localized resource projects and a huge portfolio of geological surveillance projects and licenses in Russia, Kazakhstan, Burkina Faso, Guinea and French Guiana. Currently Nordgold employs about 10 000 people.
To find additional information about Nordgold, visit: www.nordgold.com
Information infrastructure / IT infrastructure monitoring and management, Infrastructure software


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We are happy to announce that we have completed the judging process for the 2013 Creative Expression Contest for No Name-Calling Week. The competition was tough this year with submissions from all over the country. After much debate, we are excited to announce that Larchmont Charter Elementary School is the winner!
The judges loved the way Larchmont creatively connected social justice leaders throughout history to the No Name-Calling Week mission. Civil rights heroes featured in the mural faced bullying and were consistently called names, but they responded with nonviolence, setting an example for every student. Larchmont's "mosaic mural aims to represent visually that each and every student plays a part in achieving a school culture of nonviolence and peace where there is no place for bullying or name calling." Larchmont has made a clear commitment to ending name-calling and bullying. We will reward this effort with a No Name-Calling Week prize pack.


If you ever have any issues at work – we want you to know this: Every UFCW member has the right to insist that a steward or union representative be present for any discussion or meeting with any manager or supervisor that might be related to discipline. Your UFCW steward or union representative can act as a witness and make sure a manager does not treat you unfairly.
Your workplace rights are known as Weingarten rights. To invoke your Weingarten rights, you must request your representative out loud. You can use the language included below to do so. If the manager refuses to allow the representative to attend the discussion, you may refuse to answer the manager's questions. Any manager who disciplines you for invoking this right violates federal labor law.
If this discussion could in any way lead to my being disciplined or terminated, or affect my personal working conditions, I request that my steward or union representative be present at the meeting. Without representation, I choose not to answer any questions.


Nazareth, Cana, Bethlehem, the Sea of Galilee. These are just a few places whose names we know because they are the settings for many of the events that are recounted in the Bible.
However, many of us probably only picture such places as they might have been thousands of years ago. What's it like to go there now?
Well, our next guest should be able to shed some light on that question as he has just returned from a week-long trip to the Holy Land.
Joe Supple spoke to Wendy about his recent travel experiences.


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NetSetMan's Network Scanner is the most thought-through and user-friendly solution you'll find for exploring computer networks!
If you're already using NetSetMan, you're only one click away from this useful feature. Otherwise simply download the lightweight Non-Commercial Freeware and you'll quickly understand why NetSetMan is often referred to as an indispensable Swiss army knife for networks!
Find out more about the leading network settings manager or watch the short introduction video on YouTube.


In a small northern First Nations community, all lines of communication, as well as the power, have been disconnected without explanation. Winter has arrived and panic has set in. Has something happened down south? Is help on the way? And who is this mysterious survivalist, Jason Scott, who has arrived in town?
I thought Waubgeshig Rice did a great job showing how panic slowly made its way into the heads of the community leaders as well as townsfolk. Not allowing the reader to be aware of what caused the communication and utility disruption down South helped put the audience in the same mindset as the characters, so you're less likely to trust anyone who would arrive looking for food and shelter.
As the novel progresses, it comes off as an allegory for colonialism, which I would be shocked if that wasn't the author's intention. I felt this was extremely effective as the novel itself seems to be about distrust, isolation and perseverance – all common themes that can easily be found in the early days of European arrival.
The novel's main protagonist, Evan Whitesky, is a very grounded and relatable character. He's admirable in his attempt to keep the community's situation from exploding, but also isn't presented as its saviour either, although he has several dreams during the story that help to point him in the right direction. These were my favorite scenes. One in particular near the novel's climax involving Jason spooked me!
My only complaint is that I had wished the writing was a little stronger. A lot of the depictions of characters, clothing, locations were pretty bare bones with basic descriptors, being so noticeable, that they often took me out of the story.


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Did MARIAM KIGHENDA and her daughter, AMANDA, use the ferry to commit suicide-Shocking details of Likoni tragedy emerge
0 News 01:56
Sunday October 13, 2019-The husband to Mariam Kighenda, the woman who died in the Likoni ferry tragedy, has rubbished claims that she might have killed herself and their 4-year-old daughter Amanda Mutheu.
Speaking during an interview, John Wambua urged the police to speed up investigations to bring the matter to an end.
He wondered how his wife could have reversed into the car into the Indian Ocean yet it was in parking mode and the hand brake was on.
"I would not want to conclude what really happened, I'm only asking the police to investigate this matter," Wambua stated.
"The car was in parking gear and its handbrake up. We do not understand how the car in such a state could have slid into the ocean," lamented Wambua.
Further, Wambua described his wife as a jovial and God-fearing woman who was always willing to go out of her way to help others.
"My wife took people's problems as her own and she would go an extra mile to help where she could.
"She was very hard-working. She used to manage our farm in Msambweni," he added.
Kighenda and Amanda will be buried in Makueni and the family is awaiting post-mortem results before taking their bodies.


A charity is urging hillwalkers to become Corbett Connoisseurs to help fund its safety work.
Mountain Aid wants walkers to pull on their boots during May and summit one of Scotland's 222 corbetts.
Cash raised will help the organisation continue its work providing free skills training and safety lectures for those heading for the hills.
Mountain Aid said it wants to put someone on the summit of every corbett during the month of May. It wants outdoor enthusiasts to pick a hill and make their way to the top of the corbett. The charity is also asking those taking part in the fundraiser to donate to its work.
A spokesperson said: "Make a donation to Mountain Aid – £10 is suggested but please give what you can.
Mountain Aid has set up a Corbetts for Course Facebook page to register interest in a particular hill, and a PayPal page at which to donate.
The charity's activities include an annual programme of free practical navigation, winter skills and outdoor first aid training courses; a series of free winter mountain-safety lectures at venues across the country; and organising Skills for the Hills and Scottish Mountain Safety Days. These exhibition style events offer hill-goers a chance to meet and talk to agencies involved in the great outdoors in Scotland.
Scotland's 222 corbetts, named after John Rooke Corbett, who first compiled the list in the 1920s, are mountains between 2,500ft and 3,000ft with a prominence of 500ft.
The highest, Beinn a' Chlaidheimh, is just a foot shy of the 3,000ft mark that would qualify it as a munro. It was classed as a munro until a 2012 survey revealed its height as 2,999ft.
The lowest, Beinn na h-Uamha, tops the 2,500ft height by 12 inches.
Details of the challenge can be found on the Corbetts for Course Facebook page.


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Salesforce Brings Smarter Scheduling to Field Service Lightning
By: David Needle | April 17, 2018
The latest update to Salesforce.com's Field Service Lightning gives companies the ability to easily add scheduling to their consumer-facing websites and makes it easier for customers and technicians to return products.
Salesforce.com is rolling out several new features to its Field Service Lightning service that are designed to help technicians work more effectively in the field and make it easier for consumers to get the service they need.
One of the new features, Snap-ins Appointment Management, helps companies quickly add self-service appointment scheduling to their website. The new module lets consumers schedule, for example, an appointment to have their cable TV box upgraded without having to call in and wait on hold to connect to the right person and sort out a time and date that works.
Another new feature lets customers initiate a product return from a company's website. Field technicians can also create return orders onsite on a mobile device when, for example, a service call reveals a faulty part and streamline the process of getting the part or item back to the factory for repair or recycling.
How to Improve Remote Collaboration in 2021
The third key new feature is Crew Scheduling designed to make it easier for dispatchers to assign a team of workers to a job. Crew Scheduling should be especially useful for complex projects like the repair of an oil rig or the installation of a new elevator where staff with different expertise and skill levels are needed, according to Salesforce.
Salesforce launched Lightning Field Service a little over two years ago and has made several improvements to it since. "We believe the on-site experience can make or break the brand and our job is to make that experience easier every time. For far too long companies have viewed field service as an afterthought," Dana Chery, product marketing manager for Field Service Lightning, told eWEEK.
Salesforce is also leveraging its Trailhead learning platform to streamline the adoption of Field Service Lightning. The built-in Guided Set-Up uses a visual wizard that walks administrators through a simplified set-up process.
Salesforce says it has reduced the number of clicks needed to get started with Field Service Lightning by 66 percent on average. Over the course of several minutes, the wizard guides administrators through the process of configuring territories, job types and appointment booking windows to get their field service teams up and running.
"The Guided Set-Up really streamlines the process as far as helping companies get off the ground quickly without having to hire a consultant," Rebecca Wettemann, analyst at Nucleus Research, told eWEEK. "Field service really is the last mile of customer engagement and it's amazing how many folks are still using spreadsheets and paper forms."
Wettemann said Crew Scheduling, which offers real-time information on who is in the field and the status of work in progress, could go a long way to helping companies provide better service because too often a field service dispatcher doesn't have enough information to get the right people to the job.
Nucleus Research is finishing a report on Field Service Lightning and shared some of the early results that include comments from customers.
"One of the common things we've been hearing when talking to customers is that the dispatcher doesn't send the right people to the job. It almost seems like they're taking a blind spin when choosing who to send," she said.
In the Nucleus Research report, one Salesforce customer discussed the inefficiencies that crop when assigning field service workers. "In the past when the team would submit a request they'd have to look up an org chart and find someone to do a job," said the customer. "Now with service territories and resources they just have to know where the work is happening, and it automatically correlates to the right people."
Another customer is a municipality that has connected Field Service Cloud to Amazon's Alexa to let consumers make requests from home to remove graffiti at a specific location, for example.
Field Service Lightning is built on the Salesforce Service Cloud and connects to the entire service organization including call centers and dispatchers. All the features are available now except for Snap-ins Appointment Manager set for release in a pilot version in June at no additional charge to customers with a Field Service Lightning and Community Cloud license, according to Salesforce.
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Festival 22 Kerry Politzer Quintet feat. Alex Norris
« Festival 22 Noah Simpson Quartet
2022 Festival Headliner, pianist/composer Kerry Politzer premieres original music from her album, In a Heartbeat, coming out this fall on PJCE Records.
Washington, DC-born pianist/composer Kerry Politzer is a Portland-based jazz pianist, composer, and educator. She is on the music faculty of Portland State University and the University of Portland. Kerry received a Bachelor of Music in Jazz Piano from the New England Conservatory of Music and is now working on a Master of Music in Jazz Composition from Rowan University. Kerry has released six jazz CDs as a leader, including Blue in Blue, which featured saxophonist Donny McCaslin. She is about to release "In a Heartbeat" (PJCE Records).
Trumpeter/composer Alex Norris, who grew up in Columbia, MD, has performed and recorded extensively in the bands led by Lonnie Plaxico, Jason Lindner, and Ralph Irizarry. Norris has also worked with many noted jazz artists such as Slide Hampton, Joshua Redman, Brad Mehldau, Chris Potter, Carl Allen, John Patitucci, Mulgrew Miller, Brian Blade, Paquito D'Rivera and Chico O'Farrill. He appears on over 80 CDs as a sideman.
Lineup: Kerry Politzer, piano, compositions; Alex Norris, trumpet; Joe Manis tenor saxophone; Garrett Baxter, bass; George Colligan, drums
Festival, Portland Jazz
https://www.tickettomato.com/event/7641/montavilla-jazz-festival-22-kerry-politzer-quintet-featuring-alex-norris
Portland Metro Arts
9003 SE Stark St
Portland, OR 97216 United States + Google Map


Our prayers are with you during this difficult time. When a loved one has passed, contact the funeral home immediately (day or night). Once the funeral home is contacted, you will arrange a convenient time with them for their arrival. This will allow you any time necessary for those who may be want to be with you or your loved one before the funeral home arrives. Many times, the funeral home will contact the parish directly, but if you would like to call us, please do.
Msgr Donn Heiar, (608) 837-3798.


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Top 15 Reggae Albums For 2017
Top 15 Reggae Albums For 2017 - Billboard Magazine has published its Top 15 reggae albums for 2017.
The list was culled from the publication's weekly Billboard Reggae Album chart and ranks albums according to sales data released by Neilsen Music. The number of weeks spent on the chart and how far the albums reached, also factored.
Albums from five Jamaican artistes are on the list. They are Damian Marley, IamStylezMusic, Chronixx, Bob Marley and Stephen Marley.
The number one spot is occupied by Damian Marley's Stony Hill which was released by Republic Records on July 21, and reached number one on August 12. To date, the album has sold 16,000 copies and is up for a Grammy Award in January for Best Reggae Album.
At number two is Falling Into Place by California band Rebelution which was the top-selling reggae album of 2016. Released on June 3 last year, the album continues to do well; it went number one on June 25 last year and has sold more than 40,000 copies.
Lost in Paradise by Common Kings, another "Cali" band, is also nominated for Best Reggae Album. It finishes the year at number three. Released on February 3, it held the number one spot three weeks after and has to date sold 7,996 copies.
Wash House Ting by Hawaiian artiste J Boog is also up for Best Reggae Album. It is the fourth best-selling reggae set of 2017 with figures of 6,429 since its release on November 18, 2016. It went number one three weeks later.
The number five slot is held by dancehall artiste IamStylezMusic with his debut album Back to My Roots, released in August. It reached number one on September 9 and spent six non-consecutive weeks in that position. Back to My Roots has sold just over 6,000 copies.
The Grammy-nominated Chronology, debut album from Chronixx was released on July 7 by Chronixx Music Group under license with Virgin EMI. On July 29 it went number one and has to date sold 5,777 copies to finish at number six.
Live at Red Rocks closes at number seven. Released on October 28, 2016 it topped the chart on November 19 last year. To date it has sold 7,780 copies.
Know No Better (EP) is the lowest-selling album for EDM maestros Major Lazer, with figures of 5,312 copies. Ranked at number eight, the set was released on the trio's Mad Decent label on June 2, and hit number one three weeks later.
At number nine is Set in Stone by American band Stick Figure. Amazingly, this album was released on November 13, 2015 and continues to sell. It topped the chart on December 5, 2015, and has moved close to 27,000 copies.
Poetry in Motion by SOJA from Virginia is number 10. With 5,133 copies sold to date, the set was released on October 20 and went number one on November 18.
Good Life by Louisiana-born, Bermuda-reared Collie Buddz is number 11 with 4,602 copies. Released by Harper Digital on May 19, it was number one on June 10.
Marching Orders from The Green out of Hawaii is number 12. It came out on October 20 and went number one on November 11.
A Dollar Short & A Minute Late by Hawaiian surfer-turned singer Landon McNamara was released in December 2016. On February 1 it topped the chart, and has to date sold 4,278 copies, to end the year at number 13.
The Legend Live: Santa Barbara County Bowl November 25th 1979 by Bob Marley & the Wailers topped the chart on December 24 last year. Released in November 2016, it has so far sold 4,025 copies to be number 14.
Completing the top 15 is Stephen Marley's Revelation Part II: The Fruit of Life which was released on July 22, 2016. It also topped the Billboard chart and has to date sold 13,582 copies.
Source: jamaicaobserver.com
Pages related to Top 15 Reggae Albums for 2017
Reggae Artise Damian "Jr Gong" Marley
Reggae artiste Chronixx
Dancehall and Reggae Music Albums
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Ilocano, also spelled Ilokano, or Ilokan, also called Iloko, or Iloco, third largest ethnolinguistic group in the Philippines. When discovered by the Spanish in the 16th century, they occupied the narrow coastal plain of northwestern Luzon, known as the Ilocos region. The growth of their population later led to much migration to neighbouring provinces, to the southern Philippine island of Mindanao, and to Hawaii. Their language is closely related to others of northern Luzon, all of which belong to the Austronesian (Malayo-Polynesian) family of languages. In the early 21st century the Ilocano (Iloko) language was spoken by roughly 10 million people.
The major Ilocano provinces, Ilocos Norte, Ilocos Sur, and La Union, are among the most densely populated areas in the Philippines. Rice is the staple crop, grown on small fields and irrigated by rainfall during the rainy season. Vegetables and pigs, goats, and chickens are also raised. Tobacco is an important cash crop. Many Ilocano supplement their incomes by wage work or handicrafts.
The wealthier families generally reside in the cities and towns. Marriages are usually arranged so as to maintain class lines, the husband's family providing the sabong, or dowry of land. Most of the people are Roman Catholic.