text:
Don't Say Mickey: Crony Capitalism and the First Amendment
by Michael C. Dorf
In a recent blog post, Professor Eugene Volokh considers the question whether Florida's imminent withdrawal of the very substantial legal benefits it had bestowed on the Disney Corporation--in obvious retaliation for Disney's opposition to Florida's "Don't Say Gay" legislation--violates the First Amendment. Although Professor Volokh's views overall could be fairly called center-right (with a strong libertarian streak) while mine could be called center-left, we often agree and sometimes work together (e.g., here) on free speech issues.
I find Professor Volokh's post characteristically thoughtful and balanced. He first sets out the precedents and principles that might lead one to conclude that Florida will violate Disney's free speech rights if, as seems likely, it revokes Disney's various privileges and breaks. Employee speech cases are most apt here. As a Justice of the Massachusetts Supreme Judicial Court, Oliver Wendell Holmes, Jr. famously wrote that a man "may have a constitutional right to talk politics, but he has no constitutional right to be a policeman." That view--that the greater power to deny someone a government job includes the lesser power to condition employment on the relinquishment of free speech rights--is not the current state of the law. Rather, modern case law recognizes that government employees have a right to speak on matters of public concern, except that if the speech is in the course of official duties, the government may limit that speech where it has an interest that goes beyond the (illegitimate) interest it has in limiting the speech of citizens who are not government employees.
After acknowledging the force of the government employee speech precedents, Professor Volokh suggests two grounds for concluding that Florida's impending actions relating to Disney might be different. First, he observes that, as opposed to the run-of-the-mill government employee, "officials exercising political power are generally not protected from retaliation by other political figures, at least when the retaliation consists of benefits conferred by the other political figures in the first place." The extraordinary powers that Florida has invested in Disney include those ordinarily reserved for government entities.
Second, Professor Volokh notes that Florida would be withdrawing special benefits from Disney that go well beyond "the sorts of contracts (there, for trash disposal) that pretty much any company could bid for," so that "withdrawing th[e company's "extraordinary"] status would simply put Disney in the same position as other companies in that geographical area, and the bulk of other companies in Florida."
Although Professor Volokh does not offer a bottom-line conclusion one way or the other about whether withdrawal of Disney's special status would be constitutional, I read him as tentatively leaning towards a conclusion that the withdrawal would be valid. Accordingly, I want to push back a little on the two lines of argument mentioned above to explain why I lean tentatively in the other direction--towards concluding that what Florida proposes to do is unconstitutional.
Glossing over any distinctions one might draw between the free speech rights of individuals and corporations (as Professor Volokh does), it strikes me that the kinds of political power that Disney exercises are not relevant to its speech on the Don't-Say-Gay law. Here's a description from the NY Times:
Disney's special zone is called the Reedy Creek Improvement District and gives the company considerable control over the planning and permitting process for construction on its 25,000-acre property, including road building. Reedy Creek also levies taxes on Disney to pay for the resort's own fire and medical response battalions, among other services.
Put differently, in some respects Disney is a local government. So let's try to construct an analogy that's a bit different from the ones Professor Volokh gives--in which government officials lose their special privileges (like a member of Congress losing the chairmanship of a committee) in response to political statements or actions out of step with leadership.
Consider Bridgegate. The Democratic mayor of a municipality did not support the state's Republican governor's re-election bid; in response, people working for the governor retaliated against the municipality. Let's assume that the mayor speaks for the municipality. After all, he was elected. And he clearly exercises political power over the municipality--probably more local government authority than Disney has. Even so, when the governor's staff punished the municipality, it seems that they were punishing it for speech unrelated to the political power that the mayor and municipality exercise.
But wait. What about Professor Volokh's second observation? In the actual Bridgegate, the retaliation took the form of needlessly creating a traffic jam and endangering public safety; in that sense the governor's staff punished Fort Lee by making the municipality worse off than other New Jersey municipalities. Might the case look different if instead the governor's staff had retaliated by withdrawing some special benefit that Fort Lee had previously enjoyed?
Maybe, but I'm not so sure. That view sounds a bit too much like Holmes's no-right-to-be-a-policeman. We can think of a government job--even a low-ranking one--as a "special" benefit in the sense that most people aren't employed by the government. The relevant question for determining whether the loss of a benefit for political speech implicates the First Amendment strikes me as the one that the Court asks in the employee speech cases: does the government have an interest in controlling employees' speech that goes beyond its interest in controlling the general public's speech?
Where the speech relates to the official duties, the answer will generally be yes. And with respect to political appointees, the job is inherently political, so patronage of some sort is inevitable. But where the speech of an individual, local government, or corporation with some special governmental authority is on a matter wholly unrelated to the exercise of the governmental authority that individual, locality, or corporation possesses, the interest in retaliating in response is no different from the (nonexistent) interest in retaliating against ordinary citizens for speaking out on matters of public concern.
Accordingly, I find the garden-variety government employee speech cases more like the Disney case than Professor Volokh does. Nonetheless, I too hold my position tentatively because of the difficulty of proving illicit motive in most cases.
Governor DeSantis is trying to burnish his image as an anti-woke ideologue. Thus, he has gone out of his way to make plain that he wants the Florida legislature to revoke Disney's current status specifically in retaliation for Disney's opposition to Don't-Say-Gay. However, in the typical case in which government revokes some special status (or takes any action that disadvantages a company, local government, or individual), legislative motive will be more difficult to prove. And even when motive is clear, illicit legislative motive can be a problematic basis for invalidating legislation--as Professor Richard Fallon and I discussed in the Harvard Law Review (his article here; my response here).
Thus, at the end of the day, both Professor Volokh and I think it unresolved whether what Florida aims to do to Disney is constitutional, and neither of us is sure what the right answer is.
However, if the constitutional issues are difficult, the policy issues are not. What DeSantis and the GOP-controlled Florida legislature aim to do here is fundamentally corrupt--in much the same way that the repeal of state and local tax (SALT) deductibility by the then-Republican-controlled Congress and President Trump was. Their pretty obvious goal was to punish blue states for their political positions by shifting more of the tax burden onto them from red states. In analyzing that legislation in a Verdict column in late 2017, I noted First Amendment and other objections that parallel the ones I've noted here, as well as the same reservation about the difficulty of proving motive in cases less obvious than the attack on Disney. My bottom line with respect to SALT deductibility was this:
[N]o one should be fooled by the limits of what can be proven in court. In shifting some of the nation's tax burden from over-represented red states to under-represented blue ones, congressional Republicans and President Trump acted in a crassly partisan manner and betrayed core [American] ideals . . . .
Likewise here, whether or not Disney can prevail in court, in wielding government authority in a crassly partisan manner, DeSantis and the Florida legislature act as corrupt bullies.
Postscript: After I drafted but before I posted the foregoing, I came across Ian Millhiser's analysis of the same topic on Vox. He concludes, largely on the strength of the SCOTUS opinion in Hartman v. Moore, that Florida's revocation of Disney's privileges obviously violates the First Amendment. Although I am often in agreement with Millhiser's usually astute analysis, I respectfully disagree that this is an easy case as to which the existing precedents provide a determinate answer.
It's true that the Hartman case includes the language Millhiser quotes: "official reprisal for protected speech offends the Constitution . . . ." But that language is surely less sweeping in practice than on its face. Hartman was a criminal prosecution, not the withdrawal of benefits, and the case could hardly have been meant to overrule the decisions allowing the withdrawal of all special statuses--such as chairing a committee, as in Professor Volokh's example--in response to speech. It's also notable that the Court in Hartman rejected the free speech damages claim that the appeals court had accepted (prompting a dissent by Justices Ginsburg and Breyer).
To be clear, my normative bottom line is close to Millhiser's. I just don't share his certainty about where the law currently stands.
Posted by Michael C. Dorf at 7:30 AM
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text:
Mian Chilan (, also Romanized as Mīān Chīlān; also known as Meyān Chīlāq and Mīān Chīlāq) is a village in Rudkhaneh Bar Rural District, Rudkhaneh District, Rudan County, Hormozgan Province, Iran. At the 2006 census, its population was 87, in 26 families.

References

Populated places in Rudan County

redpajama_set_name: RedPajamaWikipedia


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Since moving to the UK I've been singing at various venues and events across the country, covering a wide variety of musical genres. I traveled through 11 countries in Asia, as well as South America working as a lead vocalist for Royal Caribbean International. At the Chairman's Summer Ball, a fundraiser for the British Olympic Association, I was MC, introducing such artists as Spellbound and Lord Jeffery Archer. Other work includes lead vocalist with the James O'Carroll Big Band, Ronnie Scott's and numerous corporate events with the vocal act, The Best Singing Waiters. Recently I filmed an online viral for Rowenta, which has reached over removed hits, a new promo for Dave Gorman Modern Life is Goodish Series 2 and an episode of Channel 5's new series of Countdown to Murder where I play the role of Brighton murderer, Ty Medland.


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Q: In the Eclipse IDE, how do I display the Hover values in Hex and not decimal? Is there a way to change the format of the data shown when I hold the mouse cursor over a variable (i.e., Hovers as Eclipse calls them)?  The format is Decimal, but I would like to change them to Hex, Octal, or Binary if that is possible?  Under Preferences -> C/C++ -> Editor -> Hovers there is nothing about the format.  Perhaps there is a way to hack a configuration file or something??
Any help is greatly appreciated.
Regards,
Mark

A: If viewing in the register view, there is a down arrow triangle in the upper right that has Number Format on the drop down menu. If you select the rows first, it will apply to all of them. Also, eclipse preferences (window->preferences->c/c++->debug lets you set all displays permanently. However, it appears that this has been moved in eclipse neon and I can't find it anymore @#$%$%^$@!~

redpajama_set_name: RedPajamaStackExchange


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text:
Showing Results: 1 - 10 of 19
Camille Saint-Saëns letter and photograph, 22 December 1917
Scope and Contents This small collection consists of a handwritten letter by French composer, organist, conductor and pianist Camille Saint-Saëns and a photograph portrait of Saint-Saëns. The letter is dated December 22, 1917 and it is unclear to whom it is addressed. The French letter has not yet been translated, therefore the subject matter is presently unknown.
Dates: 1917 December 22
Found in: The Monsignor Field Archives & Special Collection Center / Camille Saint-Saëns letter and photograph, 22 December 1917
William T. and Marie J. Henderson family papers
Abstract William and Marie Henderson were New Jersey natives who were actively involved with the Seton Hall University community and the larger Catholic community in the South Orange area, through the Bayley Seton League, the Society for the Propagation of the Faith, the a Kempis Club of New Jersey, the Mercier Club, and other organizations. The William T. and Marie J. Henderson papers include the personal papers of William and Marie Henderson related to various activities, some photographs, and some...
Found in: The Monsignor Field Archives & Special Collection Center / William T. and Marie J. Henderson family papers
Office of the President & Chancellor: James F. Mooney records
Abstract James F. Mooney was the eighth president of Seton Hall College, from 1907-1922. The collection contains correspondence, a memorial card from Rev. Mooney's funeral, and a photograph of President Mooney.
Found in: The Monsignor Field Archives & Special Collection Center / Office of the President & Chancellor: James F. Mooney records
Office of the President & Chancellor: Thomas H. McLaughlin records
Abstract Thomas H. McLaughlin was the ninth President of Seton Hall College, from 1922-1933. The collection contains correspondence; professional papers such as appointment books and diaries, a report to the Board of Trustees, notes on a new scholarship award, and a proposal to move the Immaculate Conception Seminary; and research and lecture notes.
Found in: The Monsignor Field Archives & Special Collection Center / Office of the President & Chancellor: Thomas H. McLaughlin records
Office of the President & Chancellor: James H. Corrigan records
Abstract James H. Corrigan was the fourth president of Seton Hall College, from 1876-1888. The collection contains correspondence, a photograph of Rev. James Corrigan, and a photograph scrapbook.
Found in: The Monsignor Field Archives & Special Collection Center / Office of the President & Chancellor: James H. Corrigan records
Seton Junior League records
Abstract The Seton Junior League was founded in 1940 by young women fond of the idea of service in hopes of one day becoming part of the Bayley-Seton League. The Seton Junior League collection includes reports, meeting minutes, correspondence, and other materials related to the operation of the League.
Found in: The Monsignor Field Archives & Special Collection Center / Seton Junior League records
Office of the President & Chancellor: John A. Stafford records
Abstract John A. Stafford was the seventh president of Seton Hall College, from 1899-1906. The collection contains letters and lecture notes from his time teaching.
Found in: The Monsignor Field Archives & Special Collection Center / Office of the President & Chancellor: John A. Stafford records
W. Paul Stillman papers
Abstract Primarily original documents pertaining to land transactions in the early 1800s. Limited correspondence of Mr. Stillman's, and various Government banking proclamations.
Dates: 1800-1989 (bulk 1800-1933); Majority of material found within 1800 - 1933
Found in: The Monsignor Field Archives & Special Collection Center / W. Paul Stillman papers
Office of the President & Chancellor: Bernard J. McQuaid records
Abstract Bernard J. McQuaid was the first president of Seton Hall College, from 1856-1867. The collection consists of letters and reproductions of letters sent to Rev. McQuaid and an image of Rev. McQuaid.
Found in: The Monsignor Field Archives & Special Collection Center / Office of the President & Chancellor: Bernard J. McQuaid records
Subject: Letters X
Seton Hall University -- History. 8
Catholics -- Newark (N.J.) -- History 2
Appointment books. 1
Bankers. 1
Bible -- Criticism, interpretation, etc. 1
Bishop 1
Catholic converts -- New Jersey. 1
College theater. 1
Composers -- France 1
Deeds. 1
Ephemera. 1
French language -- Study and teaching. 1
Funeral prayer cards. 1
Membership cards. 1
Middle East -- Studies and teaching. 1
Mortgages. 1
Obituaries. 1
Periodicals. 1
Portrait photography. 1
Prayer books. 1
Promissory notes. 1
Racism -- Religious aspects -- Christianity 1
Religion and science. 1
Religious communities. 1
Research -- History. 1
Romanticism in music -- France 1
Saint- Saëns, Camille (1835-1921) 1
Stillman School of Business -- History. 1
Theater - Reviews. 1
Theater management. 1
Theatrical posters. 1

redpajama_set_name: RedPajamaCommonCrawl


text:
Q: Java "Duplicate local variable" - is the error thrown in Java or Eclipse? In the following code:
private static void example() {
    String inputString = "test";
    switch (inputString) {
        case "test":
            String outputString = "The string said test";
        case "not test":
            String outputString = "The string did not say test";
    }
    /*Do stuff with ouputString*/
}

Eclipse highlights the line after Case "not test" with the error Duplicate local variable outputString. However, since they are in separate branches of the switch statement, they are not actually in conflict, as only one can ever be in effect at a time.
Obviously, in this case I could get around the problem by moving the outputString declaration outside the switch statement. However, in more complex programs, the solution might not be so simple.
Is this simply an error thrown by Eclipse to prevent poor programming technique, or an actual Java error?
I'm very new to Java, so apologies if this is a newbie question - I've had a google for "Duplicate local variable Java", but so far all that turned up were people asking for help with fixing the problem (the usual solution being to rename one of the variables), not discussion of the problem itself.

A: The scope of a variable in each case of a switch statement in java is the whole switch statement.
You can create further nested scopes by adding braces like so:
 switch (inputString) {
        case "test": {
            String outputString = "The string said test";
            break;
        }
        case "not test": {
            String outputString = "The string did not say test";
            break;
        }
    }

A: You are assuming that each case label creates a separate scope - which they don't. The scope here is the switch block, so you really have declared 2 variables with the same name within a scope.
You could introduce a new scope for each of the case labels, e.g.
switch (inputString) {
    case "test": {
        String outputString = "The string said test";
        break;
    }
    case "not test": {
        String outputString = "The string did not say test";
        break;
   }
}

Or if your switch is already big, perhaps you should make a method for each case that wraps all the work you do there


Phelisanong is a grassroots project that thrives in a very challenging environment. An initiative led by Africans of vision and boundless energy, the project's success rests on the shoulders of those who work, day in and day out, to sustain it. Every penny the group receives is used to maximum effect.
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In order to take the over crowding pressure of the resident buildings, we would like to build two new buildings. One for boys and one for girls.
Presently our caregivers sleep in the youth resident buildings. We would like to provide a space for our caregivers to rest and take breaks, which will provide a healtheir work environment.
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Phelisanong owns and has access to a large amount of land capable of producing food. There are orchards, shade houses and food gardens that currently provide food. We would like to hire someone who can plan and manage these resources to it's maximum capacity, which will provide nutrition and help the centre grow.
Our road to Phelisanong is down a hill that, when it rains, disintigrates to the stage where it's very difficult to travel. The road needs to be repaired so access to and from the Centre is easier and quicker.
We already operate a small vocational training centre, but we would like to expand it to a larger, well-staffed vocational training centre. Education in Lesotho does not guarantee a secure job or future so training in woodwork, plumbing sewing and other practical trades is often a more practical option when finishing school.


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text:
IPL 2019: Pant's blitz hands Delhi six-wicket win over Rajasthan
Rishabh Pant played made an unbeaten 78 to lead Delhi Capitals to a six-wicket win over Rajasthan Royals.
P. K. Ajith Kumar
JAIPUR 23 April, 2019 00:54 IST
Rishabh Pant plays a shot en route to his unbeaten 78. - IPL
It is not every night that a sparkling hundred in a T20 game gets overshadowed and becomes inconsequential. But, then, with Rishabh Pant, anything is possible.
The 21-year-old left-hander played a blistering knock (78 not out, 36b, 6*4, 4*6) to lead Delhi Capitals to a six-wicket win over Rajasthan Royals with four balls to spare. With the fifth away win in six games, Delhi also moved to the top of the table.
The Royals may have felt its 191 for six – 32 more than the average first-innings score in Jaipur this year – was good enough.
Opener Ajinkya Rahane's unbeaten (105 not out, 63 b, 11*4, 3*6) would have been a match-winning effort in most games, but not on a night when Pant took the bowlers to the cleaners.
SCORECARD | COMMENTARY
The Delhi wicket-keeper had walked in after his team lost the wickets of opener Shikhar Dhawan (54, 27b, 8*4, 2*6) and captain Shreyas Iyer. At 77 for two in 8.5 overs, the match was well poised.
Pant added 84 for the third wicket with Prithvi Shaw, who took good advantage of the catch spilled by Ashton Turner when he was on 10 as he went on to make 42 before he fell to Shreyas Gopal.
The Royals' hopes were revived when Sherfane Rutherford was dismissed by Dhawal Kulkarni in the next over.
At the end of the 18th over, Delhi was 175 for four – exactly what Rajasthan was at the same stage. But, Pant dispatched Jofra Archer's last ball in the 19th over long-on for a six.
Now, Delhi needed just six from the last over. After Colin Ingram took a single off the first ball, Pant pulled Jayadev Unadkat over mid-wicket for a six to finish off the run chase in style.
Rahane hits second IPL ton
Earlier, Rahane had to see his opening partner Sanju Samson getting run out without facing a ball and the catch he offered – while trying to sweep Axar Patel – being put down at short fine leg by Ishant Sharma.
He rubbed salt into Axar's wound, hitting him for a straight six the very next ball. In the following over, he treated Rabada – the leading wicket-taker in the IPL – the same way, for a similar outcome.
Ajinkya Rahane celebrates after reaching his hundred. - IPL
Later on, he would send Chris Morris also into the stands, but Rahane's batting is more about timing and placement. It was no different on Monday night.
He received excellent support from Smith (50), as the duo added 130 off 72 balls. But Smith's dismissal proved a setback for his team.
The Royals were 150 for two after 15 overs, but from the last five, they could make just 41. That proved very costly in the end.
Among the four wickets they lost in that period was that of Ashton Turner, who was out for his third golden duck in as many IPL matches.
Quite a turnaround for the Australian, whose last visit to India had made him a star with an astonishing knock.
On a good batting surface, Delhi rode on Dhawan and Shaw's fine start and was buoyed further by Pant's blistering knock as Delhi cantered to a comfortable win.
Shreyas Iyer
Kagiso Rabada
Dhawal Kulkarni
Prithvi Shaw


text:
Legendary Hollywood actor Al Pacino, 81, 'began dating Mick Jagger's ex-girlfriend Noor Alfallah, 28
Al Pacino is confirmed to be dating Mick Jagger's ex-girlfriend Noor Alfallah, who is 53 years his junior, with sources claiming that the couple's romance began during the pandemic. The 81-year-old Hollywood legend was recently seen cozying up to his 28-year-old girlfriend during a dinner party with actor Jason Momoa after visiting Julian Schnabel's latest Pace gallery in the Mid City area of LA.
April 14, 2022 | 7:53 pm


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"faithful" in the midst pf life threatening adversity. Jeff, you have proved that you ARE a Godly man. I am so proud of you BOTH. God is Good!
God is soooo good! Love you, jasmin!
Belief comes in beautiful ways, you and your family are true examples of the power of belief. Josef and I and so happy that all is good.
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God bless you and everyone who has seen you through this experience that has no doubt left you stronger than you could have ever imagined.
You are a wonderful testament to the power of prayer. We have followed your progress since the first day we knew. !ou are amazing!


text:
| Wharton Undergraduate Healthcare Conference addresses impact of COVID-19 on health care
Wharton Undergraduate Healthcare Conference addresses impact of COVID-19 on health care
By Hannah Norman 02/02/21 1:20am
(Photo from Hannah Gross)
This year's Wharton Undergraduate Healthcare Conference focused on the impact of COVID-19 on the health care industry, featuring speakers from Moderna and NewYork-Presbyterian.
The conference, titled Healthcare in the Wake of COVID-19: The Future of a Changing Industry, took place virtually on Jan. 30. The event included keynote addresses from NewYork-Presbyterian Executive Vice President and Chief Operating Officer Laura Forese and Moderna Chief Medical Officer Tal Zaks, as well as four panels: Health Disparities & Inequities, The Future Of Health Coverage, Outbreaks Of Disease, and Digital Health.
Panelists included legal, medical, and policy experts from a variety of universities and health systems, who shared their experiences with COVID-19. Speakers also addressed the potential long-term impacts of the pandemic on the United States' healthcare system, including an increase in the prevalence of telemedicine, the confrontation of pre-existing health disparities, and the switch to another model of healthcare, such as a single-payer system.
Forese, who oversees operations at 10 hospital campuses in New York, discussed the importance of leadership during the COVID-19 pandemic, focusing on its application to vaccine hesitancy and supply chain coordination. Zaks, a professor of Medicine at the Perelman School of Medicine, discussed the use of mRNA technology in the development of COVID-19 vaccines and other potential uses in healthcare.
Zeke Emanuel details how COVID-19 has exacerbated inequities in healthcare at Penn event
Age, race, and occupation: Penn's experts weigh in on order of vaccination distribution
During the Outbreaks of Disease panel, panelists discussed the initial response to COVID-19 and attempts to limit its spread.
Abraar Karan, a resident at the Brigham and Women's Hospital and Harvard Medical School, recalled wondering if COVID-19 would be the "next big pandemic" in it's early stages.
"We realized this was going to be really difficult," Karan said. "It's just been a game of trying to stay afloat."
Senior Director of the System-wide Special Pathogens Program at NYC Health + Hospitals Syra Madad said one of the biggest challenges involved adjusting to rapidly changing clinical guidance and resource availability at hospitals.
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Panelists also discussed how the COVID-19 pandemic impacted all aspects of life, not just health care. Wharton professor Mauro Guillén detailed the pandemic's impact on globalization and business, while Eric Pevzner from the Centers for Disease Control and Prevention's Epidemic Intelligence Service touched on the role of the CDC and the U.S. government in preventing future outbreaks.
Wharton and College junior and WUHC Conference Chair Eric Hsieh said The Future of Health Coverage panel was particularly interesting because of the diversity of fields the panelists came from, including politics, medicine, and law.
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"It was definitely challenging transitioning to an online Zoom format, while still maintaining the interactive and engaging nature of the WUHC Conference," Lee said. "However, we realized that having this event online opened up a multitude of possibilities in terms of the speakers we could get and who we could market the conference towards."


text:
Mildred Blanche Coles, née le  à Los Angeles et morte le  à Paradise (Californie), est une actrice américaine.

Biographie
Elle est la fille de Thomas R. Coles de l'Ohio et de Josephine Elizabeth Warrick de l'Illinois. C'est leur seul enfant. Elle grandit à Van Nuys et à l'Occidental College à Los Angeles.

Elle est étudiante quand elle signe avec la Paramount en 1938. Elle arrête le cinéma en 1948.

Elle a été marié avec John Rodney Frost le  et divorcé le , ils ont eu quatre enfants, Josephine Faith Frost en 1942, Susan Elizabeth Frost en 1944, Jacqueline May Frost en 1949 et Sally Anne Frost en 1950.

Elle se remarie avec monsieur Call dans les années 80.

Filmographie
 1939 : André Hardy s'enflamme
 1939 : La Fille de la Cinquième Avenue
 1939 : Femmes
 1939 : Ladies Must Live
 1940 : Money and the Woman
 1940 : Finie la comédie
 1940 : Une dépêche Reuter
 1940 : La Piste de Santa Fe
 1941 : Play Girl
 1941 : Here Comes Happiness
 1941 : Hurry, Charlie, Hurry
 1941 : Lady Scarface
 1941 : Scattergood Meets Broadway
 1942 : Sleepytime Gal
 1943 : So This Is Washington
 1948 : Song of the Drifter
 1948 : Oklahoma Badlands
 1948 : Bob and Sally
 1948 : Marshal of Amarillo
 1948 : Back Trail
 1948 : Blonde Ice
 1948 : Desperadoes of Dodge City
 1948 : Bungalow 13

Notes et références

Liens externes

Actrice américaine
Naissance à Los Angeles
Naissance en juillet 1920
Décès en août 1995
Décès à 75 ans


text:
Are There Any People Still Receiving the Promised At Home COVID-19 Tests?
Are all the millions of N-95 masks or COVID-19 at home tests that the federal government made free? Some people claim that they have received the COVID-19 at-home tests, but many others have not.
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The White House has said that 60 million American households have ordered the tests, and tens of millions of N-95 masks have been shipped as well, but it's not clear when they are expected to arrive.
The White House says that the COVID-19 tests will ship seven to 12 days after a household places an order.
Inside Edition also looked into whether the 400 million masks that were free across the nation could still be found. But, according to our reporters they couldn't find them in New York City.
According to a Monmouth University poll, Americans are becoming less comfortable wearing masks despite being given free ones.
Seventy percent of people voted that they believed COVID-19 was here to stay and that people need to get on with their lives.
To date, the U.S. has recorded more than 75,000,000 COVID-19 cases. In the United States, COVID-19 has claimed the lives of more than 890,000.
David Letterman's 1994 Epic Appearance on Conan O'Brien
Bridgewater College shooting: Two police officers are killed in a campus manhunt


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text:
Q: RowFilter on a DataTable to display in a gridview I have the following code which doesn't seem to work. In the Page_Load function I populate the DataSet and display the results in a grid view.
newsCommand = new SqlCommand("SQL code here", dbConnection);
newsDataSet = new DataSet();
newsDataAdapter = new SqlDataAdapter(newsCommand);
newsDataAdapter.SelectCommand = newsCommand;
newsDataAdapter.Fill(newsDataSet, "Bulletins");

if (!Page.IsPostBack)
{
    GridViewMain.DataSource = newsDataSet;
    GridViewMain.DataBind();
}

I have some links which call this function to filter the data (yearID is passed as a parameter):
DataTable newsTable = new DataTable();
newsTable = newsDataSet.Tables[0];

DataView dvData = new DataView(newsTable);
dvData.RowFilter = "Year > '" +  yearID + "'";

GridViewMain.DataSource = dvData;
GridViewMain.DataBind();

Yet the gridview shows the data it orignally loaded, and not the filtered data. The only thing I can think of is that I'm not using the DataTable in the Page_Load function. What else am I missing?
Thanks,
Adrian

A: Changed the code in the function to:
DataView dataView = newsDataSet.Tables[0].DefaultView;
dataView.RowFilter = "NewsDate2 Like '%" + yearID + "'";

GridViewMain.DataSource = dataView;
GridViewMain.DataBind();

It must have been something in the RowFilter statement.

A: Filter data from DataTable and display it in Gridview.
        string category = ddlcat.SelectedItem.Value; // this can be any input by user
        DataTable dt = filter_dt; //filter_dt is DataTable object, contains actual data, from there we will filter
        DataView dataView = dt.DefaultView;
        if (!string.IsNullOrEmpty(category))
        {
            dataView.RowFilter = "Category = '" + category + "'";
        }
        Gridview1.DataSource = dataView;
        Gridview1.DataBind();

If any doubt,feel free to ask.
Thank you


text:
Investigating the Obama Birth Mysteries
The Latest!
Contacts & Media
← Horace Binney Directly Refutes the Mario Apuzzo/ Leo Donofrio Lie that it Takes Two Citizen Parents to Make a Natural Born Citizen
Minor v Happersett and "Natural Born Citizen" →
In US v. Wong Kim Ark, the Supreme Court Set a Binding Precedent as to Who Is a Natural Born Citizen
Posted on April 1, 2012 by John Woodman
Two Citizen Parents Not Required: the Supreme Court Clearly Found Wong Kim Ark to Be a Natural Born Citizen.
Note: This post is an adaptation (with some additions, mostly for context) of one single post from an entire online debate with "birther" lawyer Mario Apuzzo. (Unfortunately, as an adaptation of an online post in a debate against an unreasonable opponent, it may not be as readable as some of my other writings. Apologies for that.)
It summarizes some of what the Supreme Court said about the meaning of "natural born citizen" in the 1898 case United States v Wong Kim Ark. It's been added here to make clear that the two-citizen-parent claim is effectively dead.
Will it continue as a fringe political movement? Are there people who will sincerely believe it? Undoubtedly, for as long as there are charlatans and grifters and sincere but sadly deceived people willing to push the claim, and eager followers who want to believe it. But from a factual, historical, legal point of view, the theory doesn't have a leg to stand on. Legally, as you will see in this article, the idea was officially laid to rest back in 1898.
The full debate with Mr. Apuzzo can be seen here.
In US v. Wong Kim Ark, the US Supreme Court Established a Binding Precedent as to Who Is a Natural Born Citizen.
Lawyers Leo Donofrio and Mario Apuzzo, and others following in their footsteps, have recently promoted the claim that birth on US soil plus two citizen parents at birth are Constitutionally required to make a person a "natural born citizen" and eligible to run for President.
As a key part of their arguments to the public, they've repeatedly claimed that the 1898 Supreme Court case US v Wong Kim Ark (widely recognized by legal scholars and courts as a precedent) ruled that young Mr. Wong, born of Chinese parents in San Francisco, was a "citizen" — but that the Court supposedly "stopped short of" finding him to be a "natural born citizen."
They've been able to plausibly make this claim because the Court was asked to determine whether Wong Kim Ark was a citizen… So at their very final conclusion the Court simply said (in essence) "Yes, we find that Wong Kim Ark is a citizen."
Because Wong Kim Ark was only trying to avoid being deported — and not running for President — they didn't deliberately and explicitly spell out Wong's future Presidential eligibility (he was only about 25 years old in 1898) when it came time for their grand finale pronouncement. That is, they didn't make it some big point to say, "We hereby find that Wong Kim Ark is quite specifically a natural born citizen, and will therefore one day be eligible to run for President of the United States." There simply was no reason for them to.
Now if Mr. Wong had been running for President, I haven't the slightest doubt that they would have spelled it out explicitly, using the magic phrase in their summing up. They certainly did conclude that he was a natural born citizen, and they clearly told us so. But Wong Kim Ark wasn't trying to get elected President. He just wanted to go peacefully back home to San Francisco and work as a cook without getting hassled and deported to China by the US government — which he was fortunately finally able to do.
As we will see, the claim made by the birther lawyers is simply not true. The Court very clearly found Wong Kim Ark to be a natural born citizen, in their arguments leading up to that final pronouncement declaring the resolution of the specific question at hand.
Let's look at two key passages from the ruling that establish as fact that the Court found Wong to be not only a "citizen" but also "natural born" — and therefore a natural born citizen.
I. Quoting the 1898 Supreme Court Case US v Wong Kim Ark:
"It thus clearly appears that, by the law of England for the last three centuries, beginning before the settlement of this country and continuing to the present day, aliens, while residing in the dominions possessed by the Crown of England, were within the allegiance, the obedience, the faith or loyalty, the protection, the power, the jurisdiction of the English Sovereign, and therefore every child born in England of alien parents was a natural-born subject unless the child of an ambassador or other diplomatic agent of a foreign State or of an alien enemy in hostile occupation of the place where the child was born.
III. The same rule was in force in all the English Colonies upon this continent down to the time of the Declaration of Independence, and in the United States afterwards, and continued to prevail under the Constitution as originally established."
1. The Court in this brief passage therefore made the following CLEAR AND UNAMBIGUOUS STATEMENT:
Every child born in England of alien parents — going back for centuries — was a NATURAL-BORN SUBJECT unless the child of an ambassador or other diplomatic agent of a foreign State, or of an alien enemy in hostile occupation of the place where the child was born.
2. The phrases "natural born citizen" and "natural born subject" were clearly and undeniably used INTERCHANGEABLY in the early United States. And here is solid PROOF of that.
As if that were not enough, the Supreme Court in Wong Kim Ark also approvingly quoted Justice Gaston of the Supreme Court of North Carolina, in his statement that the term "citizen" is "PRECISELY ANALOGOUS" to the term "subject:"
"Upon the Revolution, no other change took place in the law of North Carolina than was consequent upon the transition from a colony dependent on an European King to a free and sovereign State; . . . British subjects in North Carolina became North Carolina freemen; . . . and all free persons born within the State are born citizens of the State. . . . The term 'citizen,' as understood in our law, is precisely analogous to the term 'subject' in the common law, and the change of phrase has entirely resulted from the change of government. The sovereignty has been transferred from one man to the collective body of the people, and he who before was a 'subject of the king' is now 'a citizen of the State.'"
3. The Court in the brief passage above also made the following CLEAR AND UNAMBIGUOUS STATEMENT:
"The same rule was in force in all the English Colonies upon this continent down to the time of the Declaration of Independence, and in the United States afterwards, and continued to prevail under the Constitution as originally established."
The Supreme Court in US v Wong Kim Ark therefore CLEARLY stated that THE RULE IN FORCE IN THE ENGLISH COLONIES BEFORE INDEPENDENCE, IN THE UNITED STATES AFTER INDEPENDENCE, AND IN THE UNITED STATES AFTER THE ESTABLISHMENT OF THE CONSTITUTION, WAS THAT EVERY CHILD BORN ON OUR SOIL OF ALIEN PARENTS (unless meeting those limited exceptions) WAS A NATURAL BORN CITIZEN OR SUBJECT HERE.
There are those who continue to claim that the Wong Court failed to find that Mr. Wong was a natural born citizen. But given the words of the Court, any continued claim to this effect is simply false. But wait… there's more.
II. Quoting US v Wong Kim Ark again:
"The foregoing considerations and authorities [that is, the Court's entire discussion to date] irresistibly lead us to these conclusions: the Fourteenth Amendment affirms the ancient and fundamental rule of citizenship by birth within the territory, in the allegiance and under the protection of the country, including all children here born of resident aliens, with the exceptions or qualifications (as old as the rule itself) of children of foreign sovereigns or their ministers, or born on foreign public ships, or of enemies within and during a hostile occupation of part of our territory, and with the single additional exception of children of members of the Indian tribes owing direct allegiance to their several tribes. The Amendment, in clear words and in manifest intent, includes the children born, within the territory of the United States, of all other persons, of whatever race or color, domiciled within the United States. Every citizen or subject of another country, while domiciled here, is within the allegiance and the protection, and consequently subject to the jurisdiction, of the United States. His allegiance to the United States is direct and immediate, and, although but local and temporary, continuing only so long as he remains within our territory, is yet, in the words of Lord Coke in Calvin's Case, 7 Rep. 6a, 'strong enough to make a natural subject, for if he hath issue here, that issue is a natural-born subject;' and his child, as said by Mr. Binney in his essay before quoted, "if born in the country, is as much a citizen as the natural-born child of a citizen, and by operation of the same principle." It can hardly be denied that an alien is completely subject to the political jurisdiction of the country in which he resides…"
Let's condense that and pull out the most relevant parts:
The allegiance TO THE UNITED STATES of every citizen or subject of another country, while domiciled here, is "strong enough to make a natural subject," and "IF HE HATH ISSUE [a CHILD] HERE, THAT ISSUE [or, that CHILD] IS A NATURAL-BORN SUBJECT" [quoting the exact words of the English Lord Coke from the year 1607 or, in United States terms — a NATURAL-BORN CITIZEN.]
It is therefore CLEAR and UNDENIABLE that the United States Supreme Court found Wong Kim Ark to be not ONLY a "citizen" — they ALSO found — and they stated it as an "IRRESISTIBLE" "CONCLUSION" — that Wong Kim Ark was "NATURAL BORN." [1]
And the majority of the Court (6 to 2) stated that, clearly, not once but twice.
The Supreme Court CLEARLY found that Wong Kim Ark was a NATURAL BORN CITIZEN.
III. Furthermore, even Justice Fuller in the dissent in the case recognized that the majority had found Wong Kim Ark to be a natural born citizen and therefore eligible to be President! He wrote, in that very dissent:
"I submit that it is unreasonable to conclude that "natural-born citizen" applied to everybody born within the geographical tract known as the United States, irrespective of circumstances, and that the children of foreigners, happening to be born to them while passing through the country, whether of royal parentage or not, or whether of the Mongolian, Malay or other race, were eligible to the Presidency, while children of our citizens, born abroad, were not."
All of these being the case, it is PERFECTLY CLEAR that the Supreme Court in US v Wong Kim Ark found young Mr Wong to be NOT ONLY "a citizen," but a NATURAL BORN CITIZEN. They tell us not once, not twice, but three times and in three different ways, that the ruling is that Wong Kim Ark is a natural born citizen and/ or eligible for the Presidency. And on this point, both the majority and the minority of the Court agreed.
To deny the Court's plain words and state that they made no such clear statement is simply to lie.
The Court's Statement In this Regard Is Binding Legal Precedent.
And since this entire discussion was clearly central to the question before the Court, this was all part of the rationale for the decision — or, to use the formal legal term for it, the "ratio decidendi." [For much more information on this topic, see the full discussion of what is and is not binding legal precedent in my articles on Minor v. Happersett.]
As such, by the long-established and fundamental rules of our court system, this determination serves as a binding precedent regarding who is a natural born citizen. And since according to the Constitution, only natural born citizens are eligible to the Presidency, it therefore serves as binding precedent for who is eligible to run for President of the United States!
But is this really what the Court intended? Did they really intend to hand down a ruling that a Chinerman was eligible to run for President of the United States?!? Did they really understand what they were saying here??
ABSOLUTELY they did. And ALL of the members of the Supreme Court understood that.
We've already seen that the two dissenting Justices objected partly on the very grounds that the majority was finding Wong Kim Ark — a Chinerman — eligible to run for President.
But that very majority mentioned the implications of their ruling, too. As they noted:
"The Constitution of the United States, as originally adopted, uses the words 'citizen of the United States,' and 'natural-born citizen of the United States.' By the original Constitution, every representative in Congress is required to have been 'seven years a citizen of the United States,' and every Senator to have been 'nine years a citizen of the United States.' and 'no person except a natural-born citizen, or a citizen of the United States at the time of the adoption of this Constitution, shall be eligible to the office of President.'"
They absolutely knew they were ruling Wong Kim Ark — and every other person, Chinese or otherwise, born in the US of non-citizen parents (unless meeting a few narrow exceptions as we discussed above) eligible to run for, and be elected, President. They therefore knew they were setting a binding precedent not only for citizenship, but also — by extension — for Presidential eligibility.
This binding precedent means that until and unless the Supreme Court ever overturns their own decision in this case (which almost never happens, and honestly never would happen in a 6-2 decision in which the dissent was, to be frank, poorly supported), or until and unless the Constitution itself is changed through amendment, US courts are required to rule similarly in all similar cases.
This also means that Barack Obama, Bobby Jindal, and Marco Rubio are all entirely eligible to run for and serve as President.
And this precedent explains why challenges brought on the "two citizen parent" grounds against Mr. Obama have been repeatedly dismissed by state and federal courts who've heard the question. It also explains why no challenge brought on these exact grounds against any other candidate is ever going to prevail in the US court system. And it explains why you may have grown up hearing (as I did) that any kid born in America can grow up to be President.
Because the United States Supreme Court has already decided the question — 114 years ago.
For the entire debate with Mario Apuzzo that this post is adapted from, see here. This debate reveals literally a dozen different verifiably false claims made by Mr. Apuzzo. Many of these same claims have also been made by Leo Donofrio and other "birthers."
For a summary of conclusions on nearly a year of investigating the Obama and Constitutional eligibility claims, see this post. Finally, see also this "wrap-up" post.
If you've already read the footnote below, you might want to skip to the comments.
[1] The birthers are fond of completely ignoring the plain language just mentioned, that states clearly that a person in Wong Kim Ark's situation is "natural born." In fact, birther lawyer Leo Donofrio performed radical surgery on the passage I've quoted, selectively omitting the one phrase in that passage that clearly stated that such a child was natural born!
Donofrio then took that freshly-gutted quote and used it as the basis for an entire blog post claiming the exact opposite of the truth, titling his post: "Justice Horace Gray Clearly Indicated Wong Kim Ark Was Not a Natural Born Citizen."
He did so by taking the next phrase and claiming it says something it did not say.
The next phrase is: "and his child, as said by Mr. Binney in his essay before quoted, 'If born in the country, is as much a citizen as the natural-born child of a citizen…"
Note first of all that we don't need this phrase to establish that Wong Kim Ark, and other children similarly born on US soil of non-citizen parents, is natural-born. The phrase before this one — the one that Leo Donofrio handily deleted — has clearly established that for us.
Note secondly that Mr. Binney didn't say that the US born child of an alien parent is not a natural-born citizen. He simply said that such a child was "as much a citizen as the natural-born child of a citizen."
This is a lot like saying my neighbor's tomatoes are just as nutritious as the organic tomatoes from the grocery store. Is that a pronouncement that my neighbor's tomatoes are NOT organic? No. They might well be. Or, they might not. The sentence doesn't tell us. It simply tells us that they're just as nutritious.
And yet both Donofrio and Mario Apuzzo make the false claim that Binney was here saying that the US-born child of an alien parent is NOT a natural born citizen.
Now it turns out that we know the actual doctrine of prominent lawyer (and former United States Representative) Horace Binney regarding the natural-born citizenship status of children born on US soil of non-citizen parents — because Binney himself tells us, in the exact same essay quoted by the Supreme Court. Horace Binney tells us, clearly, that such a child is also a natural born citizen.
We didn't actually need his help — but Mr. Binney himself confirms what the Supreme Court has already told us in this case: If you're born in America, your parents don't have to have been citizens for you to be a natural-born citizen of the USA.
Resume reading main article on US v Wong Kim Ark
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7 Responses to In US v. Wong Kim Ark, the Supreme Court Set a Binding Precedent as to Who Is a Natural Born Citizen
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BrianH says:
As noted earlier, it's a most telling thing that this article — on the SCOTUS case that actually delved deeply into the meaning of "natural born citizen" in a case involvling a person born in the U.S. to alien parents — has gotten no replies. Notice the deafening silence here compared to the Birther response on the articles involving purely historical sources.
Though what is observed here (or, more precisely, what isn't here) is consistent with the dialogue you referenced above (http://www.ballot-access.org/2012/03/20/larry-klayman-files-presidential-qualifications-lawsuit-in-florida/comment-page-3/) I note your Post #21, in which you cite to numerous specific provisions of the WKA opinion, went unanswered as well.
Here I'll add a few points in supplement of your article, noting the various ways Justice Gray in WKA analyzes the meaning of "natural born citizen" using a framework that is antithetical to the Birther analysis.
1. The Meaning of "NBC" is Integral to the Court's Analysis.
At the outset of the opinion in Wong Kim Ark, Justice Gray notes:
In Minor v. Happersett, Chief Justice Waite, when construing, in behalf of the court, the very provision of the Fourteenth Amendment now in question, said: "The Constitution does not, in words, say who shall be natural-born citizens. Resort must be had elsewhere to ascertain that." And he proceeded to resort to the common law as an aid in the construction of this provision. 21 Wall. 167.
The Birther world-view sees a person in Mr. Wong's position as NOT a natural born citizen by virtue of Minor v. Happersett. If Justice Gray believed Minor issued a definition of "natural born citizen," as Birthers claim Minor did, it would make no sense for Justice Gray to explore the meaning of NBC at the outset of his opinion in WKA. And this is true for two reasons: 1) NBC, being an Article II term, would then have absolutely nothing to do with Mr. Wong, given his case tested his citizenship status, and 2) it would be utterly silly for Justice Gray to undertake — though he did — extensive analysis of the common law meaning underpinning "natural born citizen." Why does he not just cite to Minor and leave it at that? Rather, that Justice Gray does extensive analysis of the common law meaning of "natural born citizen" indicates very clearly that the WKA court understood Minor did not "define" the term in the context of a person having alien parents. The Minor case didn't present that question. But the Wong Kim Ark case DID present that question. Hence, Justice Gray explores the meaning of "natural born citizen" as it relates to someone like Mr. Wong.
2. Justice Gray Indicates the Semantic Underpinning of "NBC" is to be Found by Reference to the English Common Law.
The Birther position is that the "common law" underpinning of "natural born citizen" is to be understood by reference to an "American" common law. Justice Gray writing for the majority in WKA takes a different approach:
There is no common law of the United States, in the sense of a national customary law, distinct from the common law of England as adopted by the several States each for itself, applied as its local law, and subject to such alteration as may be provided by its own statutes. . . . There is, however, one clear exception to the statement that there is no national common law. The interpretation of the Constitution of the United States is necessarily influenced by the fact that its provisions are framed in the language of the English common law, and are to be read in the light of its history.
The contrast between the Birther methodology and the methodology of the U.S. Supreme Court in Wong Kim Ark is immediate and stark. In undertaking analysis of the meaning of "natural born citizen," Justice Gray states explicitly courts should understand the terminology by reference to English common law. He makes no reference at all to any notion of a unique "American common law."
3. Justice Gray Explicitly Rejects the Argument that the "Law of Nations" has Provided a Different Rule of Understanding.
Further in the opinion, after comparing the English jus soli rule of "natural born subject" and noting that the SAME RULE has been in force in America since the founding of the nation, Justice Gray takes up the argument that the "law of nations" indicates that a different rule should apply based in part on jus sanguinis:
IV. It was contended by one of the learned counsel for the United States that the rule of the Roman law, by which the citizenship of the child followed that of the parent, was the true rule of international law, as now recognized in most civilized countries, and had superseded the rule of the common law, depending on birth within the realm, originally founded on feudal considerations.
But at the time of the adoption of the Constitution of the United States in 1789, and long before, it would seem to have been the rule in Europe generally, as it certainly was in France, that, as said by Pothier, "citizens, true and native-born citizens, are those who are born within the extent of the dominion of France," and
mere birth within the realm gives the rights of a native-born citizen, independently of the origin of the father or mother, and of their domicil;
and children born in a foreign country, of a French father who had not established his domicil there nor given up the intention of returning, were also deemed Frenchmen, as Laurent says, by "a favor, a sort of fiction," and Calvo, "by a sort of fiction of exterritoriality, considered as born in France, and therefore invested with French nationality." Pothier Trait des Personnes, pt. 1, tit. 2, sect. 1, nos. 43, 45; Walsh-Serrant v. Walsh-Serrant, (1802) 3 Journal du Palais, 384; S.C., S. Merlin, Jurisprudence, (5th ed.) Domicile, § 13; Prefet du Nord v. Lebeau, (1862) Journal du Palais, 1863, 312 and note; 1 Laurent Droit Civil, no. 321; 2 Calvo Droit International, (5th ed.) § 542; Cockburn on Nationality, 13, 14; Hall's International Law, (4th ed.) § 68.
It was Justice Fuller writing in dissent who appeals to de Vattel. The majority opinion clearly rejects the argument that Vattel's citizenship view holds sway.
4. The Fourteenth Amendment Incorporated the Common Law Rules, It Didn't Create a New Citizenship Category.
Contrary to the Birther position that some new "Fourteenth Amendment Citizen" classification was created, Justice Gray makes clear the Amendment did not create (nor limit) the citizenship rules that existed under the Common Law. Rather, it was declaratory in operation, making the citizenship rules that were previously operative as to white persons equally operative as to persons of color. For Justice Gray makes abundantly clear that prior to the Amendment, U.S.-born children of white aliens were "native born" citizens:
Passing by questions once earnestly controverted, but finally put at rest by the Fourteenth Amendment of the Constitution, it is beyond doubt that, before the enactment of the Civil Rights Act of 1866 or the adoption of the Constitutional [p675] Amendment, all white persons, at least, born within the sovereignty of the United States, whether children of citizens or of foreigners, excepting only children of ambassadors or public ministers of a foreign government, were native-born citizens of the United States.
"Native-born" and "natural born" are interchangeable terms (and they have been used interchangeably, even by authorities that Birthers cite to, such as Quintilianus, de Vattel, and Blackstone). So it's undeniable from this passage that — even before enactment of the Fourteenth Amendment — there were "natural born citizen" of alien parentage. It's just that such was recognized as to white persons . The Fourteenth Amendment made the same true as to children of African and Asian descent (as in the case of Mr. Wong), but it did not create some new category of citizenship that hadn't previously existed.
5. Justice Gray Treats the Question of NBC Under the Common Law and the Question of "Born in … the United States, and Subject to the Jurisdiction Thereof" as Being the Same Question.
That this is true can be observed by noting (as Mr. Woodman notes above) what Justice Gray concludes about each matter. As to the common law meaning of "natural born," he writes:
Then, speaking of the meaning of the enactment of the Fourteenth Amendment, he writes:
The real object of the Fourteenth Amendment of the Constitution, in qualifying the words, "All persons born in the United States" by the addition "and subject to the jurisdiction thereof," would appear to have been to exclude, by the fewest and fittest words (besides children of members of the Indian tribes, standing in a peculiar relation to the National Government, unknown to the common law), the two classes of cases — children born of alien enemies in hostile occupation and children of diplomatic representatives of a foreign State — both of which, as has already been shown, by the law of England and by our own law from the time of the first settlement of the English colonies in America, had been recognized exceptions to the fundamental rule of citizenship by birth within the country. Calvin's Case, 7 Rep. 1, 18b; Cockburn on Nationality, 7; Dicey Conflict of Laws, 177; Inglis v. Sailors' Snug Harbor, 3 Pet. 99, 155; 2 Kent Com. 39, 42.
So the Supreme Court makes clear that the Fourteen Amendment didn't create some new "Fourteenth Amendment Citizen" category (a term neither WKA nor any other court has ever applied to any person). Rather, Justice Gray makes clear that the Amendment incorporates formally the common law meaning of "natural born citizen" as to the same jus soli rule and excepting the same categories of persons from that rule. So, per Justice Gray, "natural born citizen" and "born . . in the U.S. and subject to the jurisdicdtion thereof" mean the same thing! So, indeed, under the Supreme Court's analysis, Mr. Wong was at once a person "born . . . in the U.S and subject to the jurisdiction thereof" under the Fourteenth Amendment and a "natural born citizen" under the common law rules which the Fourteenth Amendment incorporated, because Justice Gray defines those two concepts identically.
The Wong Kim Ark decision is fatal to the Birther "two citizen parent" argument. It's apparent why they ignore pertinent questions about specific statements made by Justice Gray and quickly try to move the discussion to their preferred historical sources.
John Woodman says:
Thanks for your excellent comments, which essentially expand what was always a very brief article on US v Wong Kim Ark that only ever hit the high points.
As you've noted, there is a LOT more in that case than what I've written on. I simply stopped there because I felt that even that much was fatal to the birther claims.
Your last paragraph deserves repeating, in bold:
gorefan says:
TJ McCann,
In the appellant brief filed by the US government in the Wong Kim Ark case,
"The question presented by this appeal may be thus stated: Is a person born within The United States of alien parents domiciled therein a citizen thereof by the fact of his birth? The appellant maintains the negative, and in that behalf assigns as error the ruling of the district court that the respondent is a natural-born citizen, and on that ground holding him exempt from the provisions of the Chinese exclusion act and permitting him to land."
Judge Morrow of the District Court never ruled Wong Kim Ark as natural born, in fact that term is nowhere in his decision.
Why did the US Government assume that Judge Morrow's ruling made Wong a "natural born citizen"?
In his dissenting opinion Chief Justice Fuller states that the majority of the court is using English Common Law to define the term "natural born citizen".
Why doesn't he remind them of the binding precedent of the Minor decision?
Also Chief Justice Fuller writes,
"Considering the circumstances surrounding the framing of the Constitution, I submit that it is unreasonable to conclude that "natural-born citizen" applied to everybody born within the geographical tract known as the United States, irrespective of circumstances, and that the children of foreigners, happening to be born to them while passing through the country, whether of royal parentage or not, or whether of the Mongolian, Malay or other race, were eligible to the Presidency, while children of our citizens, born abroad, were not."
Why does he say that the majority opinion makes someone like Wong eligible to be President?
Why does he not remember that the Minor decision would prevent someone like Wong from being President?
In the District Court ruling, Judge Morrow wrote,
"The question is an important one, not alone from an abstract point of view, but because of the consequences a decision unfavorable to the petitioner would involve; for, if the contention of counsel for the government is correct, it will inevitably result that thousands of persons of both sexes who have been heretofore considered as citizens of the United States, and have always been treated as such, will be, to all intents and purposes, denationalized remanded to a state of alienage."
So is Judge Morrow say that ynder US law before 1898, people born in the US to alien parents were considered citizens?
gorefan,
Thanks for being willing to actively educate TJ McCann. From his behavior so far, I suspect it's probably going to be kind of like trying to teach algebra to a duck, but you certainly get credit for trying. 😉
I was also hoping to drag his a$$ over here where it belongs. We'll see if he takes the bait.
Sometimes people get confused by what they believe the law should be with what the law is. Judge Morrow summed it up in his decision in Wong Kim Ark,
"Counsel for the United States have argued with considerable force against the common-law rule and its recognition, as being illogical, and likely to lead to perplexing, and perhaps serious, international conflicts, if followed in all cases. But these observations are, obviously, addressed to the policy of the rule, and not to its interpretation. The doctrine of the law of nations, that the child follows the nationality of the parents, and that citizenship does not depend upon mere accidental place of birth, is undoubtedly more logical, reasonable, and satisfactory, but this consideration will not justify this court in declaring it to be the law against controlling judicial authority. It may be that the executive departments of the government are at liberty to follow this international rule in dealing with questions of citizenship which arise between this and other countries, but that fact does not establish the law for the courts in dealing with persons within our own territory."
TJ McCann says:
[Moderator's note: The contents of your post has been deleted, due to your failure to respond to the request that you post discussion of US v Wong Kim Ark in a thread appropriate to that case, such as this one.
It's really not that hard, TJ. Look at the guide to the site, find the article that seems to really discuss what you want to talk about, go and read the article and subsequent commentary, and then make relevant comments.]
[Additional moderator's note, 2/4/2013: I was rereading this article today (months after retiring from this issue) and noted that the comments on this page seem slightly messed up. I don't know exactly why this is the case. But it looks to me as if some comment by TJ McCann might have gone missing, and another might be misplaced here.
In any event, we conducted an extensive debate with Mr. McCann in October 2012, centered in the article titled "The 'Grandfather Clause' Regarding the 'Natural Born Citizen' Requirement of the Constitution — Was It Ever Needed or Used?" Readers who might be interested in hearing what Mr. McCann had to say can begin with that article and find extensive airings of his views.]
An Easy-to-Find Guide to the Content of This Site
Epilogue: Confirmed, Confirmed, and Reconfirmed
"Birther's Digest:" A List of Obama Ineligibility Claims — With Their Status
The Arpaio Posse's Fatally Flawed "Analysis" of Barack Obama's Birth Certificate
The "Grandfather Clause" Regarding the "Natural Born Citizen" Requirement of the Constitution — Was It Ever Needed or Used?
Genuine, World-Class Computer Expert Evaluates Obama's Birth Certificate PDF
Exclusive! "Hawaii Girl" Confirms Her Parents' Race — and I Crack the Actual Entries, Confirming that Arpaio's Codes Don't Match the Hawaii Codes, Either.
Exposed: Sheriff Joe Arpaio Birther Scam — Here's the Proof that Arpaio's Posse Fabricated Evidence and Lied to the Nation
Answering Critics
Birther Scam
Sheriff Joe Arpaio
Stuff Birthers Believe
Two Kinds of Citizen | Obama Conspiracy Theories – What Inquiring Minds Want to Know on Get the Book!
Birther "Expert" Albert Renshaw now retracts his analysis | RC Radio Blog on Get the Book!
John Woodman–An Epilogue | RC Radio Blog on Epilogue: Confirmed, Confirmed, and Reconfirmed
John Woodman–An Epilog | RC Radio Blog on Get the Book!
John Woodman on "Birther's Digest:" A List of Obama Ineligibility Claims — With Their Status


text:
When a king spent Christmas in Southampton Castle
King Richard I spent Christmas in Southampton Castle
By Godfrey Collyer
WHILE Her Majesty and Prince Philip prepare to spend Christmas day with their bubble in Windsor, we look back at when a king spent the big day in Southampton Castle.
Most people are familiar with Richard the Lionheart or Richard I through the story of Robin Hood when his return to England, from the Crusades, was expected to restore peace and order after the scheming of his brother John during his absence.
Richard was the son of Henry II and Eleanor of Aquitaine and spent most of his life enforcing his father's rule in his French lands.
Following his father's death he was crowned King in September 1189.
Richard immediately set off on a crusade to the Holy Land with an army of around 8,000 men.
Richard planned to campaign alongside Philip II of France and others but they abandoned him to face Saladin's forces alone.
He eventually reached a truce with Saladin and set sail for home.
Following a shipwreck, he was forced to travel overland and was captured by Duke Leopold V of Austria who handed him over to the German emperor Henry VI who demanded a ransom for his release.
The ransom was raised with the help of Gervaise de Hampton, a very wealthy Southampton man.
Richard was released on February 4, 1194, and returned to England landing in Southampton where he spent time in the castle.
Richard then returned to France where he spent the next five years fighting to hold on to his lands.
Richard's reign lasted until April 1199, when he died from a gangrenous wound and was buried in France.
During his 10-year reign he spent only six months in England and just one Christmas, which was spent in Southampton Castle in 1194.
The celebration of Christmas for Richard would have been an important religious affair but a large part would also have been the feasting which would last several days.
Southampton's leaders would have been expected to provide the food and entertainment and with their reputation with the King at stake they would have wanted this to have been a great success.
Goose and, with the king's permission, swan would have been eaten and also woodcock. Medieval cooks covered the birds with butter and saffron which gave them a golden colour when served.
A boar's head was a central part of the feast. This wasn't just roasted but prepared and served as the elaborate exterior of a more familiar pork pie.
Venison would have been eaten with the best cuts kept for the king and his guests while the offal, then known as the "umbles", given to the poor and made into a pie from which the term "humble pie" originates.
Richard's brother John held a Christmas feast in 1213, and records show that he ordered large amounts of food including 24 hogshead of wine, 200 head of pork, 1,000 hens, 50 lbs of pepper, 2 lbs of saffron and 100 lbs of almonds.
In Medieval England a large mince pie was baked filled with various shredded meats along with spices and fruit.
A spicy, wheat-based medieval dessert known as frumenty would have been served which has evolved into the Christmas pudding we enjoy today.
Drink was important and an Anglo-Norman carol of the time tells us:
Christmas loves good drinking.
Wines of Gascoigne, France, Anjou,
English ale that drives out thinking,
Prince of liquors, old or new.
A hot mixture of ale, honey, and spices would be put in a large bowl, and the host would lift it and greet his companions with "waes hael" meaning "good health". The reply was "drinc hael," which meant "drink and be well."
Every neighbour shares the bowl,
Drinks of the spicy liquor deep,
Drinks his fill without control,
Till he drowns his care in sleep.
The Castle Hall would have been decorated with holly, and mistletoe. It was believed that the holly berries had been white before they were turned red by Christ's blood when he was made to wear the crown of thorns.
The real joy of Christmas was sharing food, feasting and drinking with friends kept warm by an oak Yule log stripped of its bark which burned for 12 days.


text:
Le Championnat d'Algérie de football de deuxième division 2005-2006 est remporté par l'OMR El Annasser.

Classement final

Calendrier

Résultats

|}
Résultats

Résultats

Records et statistiques
 Meilleure attaque : OMR El Annasser avec 65 buts marqués
 Meilleure défonce : JSM Béjaia avec 18 buts encaissés
 Plus large victoire : OMR El Annasser 7-0 AS Khroub

Voir aussi
 Championnat d'Algérie de football 2005-2006
 Coupe d'Algérie de football 2005-2006

Articles connexes

Notes et références

Championnat d'Algérie de football de deuxième division
Algerie
Football en Algérie en 2005
Football en Algérie en 2006


text:
Q: How to prevent silverlight XAP from external copy & use on someone elses domain I think I dont understand this process clearly.
Let's say I create a great SL application and host it on my web page. If someone downloads th XAP he can host it on his web page since it's just a file and it will work perfectly fine I think, even if its obfuscated.
I think there are couple of ways to protect it:

*

*Use authorization on my website
        (ASP.NET auth) and pass an auth token
        from it to the SL app so they at least
        will have to use my website to get
        th auth token in some way (although if
        not 2nd this could also be done in
        some unseen way, like webrequest or
        something to do everything a person would
        do to obtain th token & then it would
        again work on other domain just
        fine) and use WCF service operations with auth this auth token.

*Use some WCF service &
            cross domain restrictions to make
            sure XAP won't work good if hosted
            like that.
Looks like if second is valid 100% protected solution there is no need to make complicated auth on web site and pass token to Silverlight, and just SL authentication can be fine.
I would like to hear your thoughts about both approaches, and maybe some other ways to help this situation.
Maybe there is a way to protect XAP so it wont work at all if it was not downloaded from some specific domain?

A: You might want to read this: http://www.youpvp.com/blog/post/Protecting-your-Silverlight-application-from-a-hijacking.aspx

A: Why not do something like this, maybe in Application_Startup
if (Application.Current.Host.Source.Host != "mydomain.com")
    throw new ApplicationStolenException();

In theory someone could edit the xap file to change that string but you could obfuscate it to make it harder.
The authentication thing is not going to work. What are you going to do with that authentication token in your Silverlight app? Silverlight does not manage sessions, how are you going to prevent someone from reusing the token for ever?
The only reliable option is to have your application depend on a web service. And by depend I mean actually implementing part of the logic on the server. Otherwise it would be easy to just recreate a service that produce the same responses than yours.
As with all security related questions, it's all about balancing the risk and the investment.


Hue (pronounced hway), 13 km (8 miles) inland from the South China Sea in the foothills of the Annamite Mountains (Truong Son Mountains), stands as a reminder of Vietnam's imperial past. The seat of 13 Nguyen-dynasty emperors between 1802 and 1945, Hue was once Vietnam's splendid Imperial City. Although it was devastated by the French in the 19th century and again in the 20th (as well as enduring much suffering because of its close proximity to the DMZ), the monument-speckled former capital has a war-ravaged beauty. One can still imagine its former splendor, despite gaping holes in its silhouette. Hue is a UNESCO World Heritage Site, and the city's gems are slowly being restored. Although much of the Imperial City was reduced to rubble, many sections still exist, and Hue's main draw continues to be the remnants of its glorious past. Today tourists keep the city thriving, drawn by the ancient Citadel, mausoleums, pagodas, and palaces. Winding through this historic capital is Perfume River (Song Huong), overshadowed by the walled Forbidden City on its north bank. Built under Emperor Gia Long in 1805, this fortress covers 5 km (3 miles) of Hue's waterfront. Equally appealing are the tombs scattered throughout the city, including the Khai Dinh mausoleum that stands out from the pack due to its detailed mosaic work. With so many attractions, Hue should not be rushed. Avoid visiting Hue during the worst of the rainy season, between November and late December.


Enjoy the beautiful seascapes, surrounding islands and lovely Hawaiian skies above meticulous, palm-lined grounds. Winter whale season from approx end of Nov to mid Apr. Catch the occasional view of resident turtles from the lanai. The peace within may entice you to re-think your plans to leave!! This unit has all the amenities suited to facilitate a very comfortable and enjoyable Maui holiday on the Valley Isle.
Gentle tradewinds, nature's "Air Conditioning", brings in cool air from the West Maui mountains.
Maalaea Small Boat Harbor and Shops are a short walk from the unit . Explore the stores and shops at the harbor, enjoy a charter boat trip, and maybe dine at one of the area restaurants. Aside from the harbor, shops and restaurants, you will find a water park with miniature golf, water bumper boats, and a rock-climbing wall within walking distance.
The Maui Ocean Center (Hawaii's only saltwater aquarium) is located at Maalaea Small Boat Harbor. A delightful way to spend the morning or afternoon with friends and family learning about Hawaii's marine life. For those quiet times, take a long walk down a sandy beach that stretches for miles.
Your Maui holiday awaits you!!
This is an awesome condo and a great price. The view is amazing and the condo was stocked with everything you can imagine. We watched turtles play right at our feet and enjoyed the sun rise every morning behind the volcano. We will definitely be back.
I am so happy to hear that you had a wonderful stay! We look forward to you staying with us again.. We greatly appreciate your review as well.
We had a great time in the Maalaea Kai condo ,located on oceanfront with the views to dream for.Well stocked and clean.
I am so happy to hear that you had a wonderful stay and found it had a great location! We constantly work towards guest satisfaction . We greatly appreciate your review as well.
all was great we left the condo extremely clean wash all towels and all bed sheets the place was spotless .but we were charged condo cleaning fee.?????
Outstanding condo, awesome view from the lanai, quiet, good parking, nice pool, great amenities in the room. I really enjoyed the camera tripod to borrow and take pictures and sunset pictures. Beach chairs could use an upgrade. Property manager was awesome and provided quick response getting us a couple of much needed box fans. Made a world of distance. Great fun looking for and seeing literally hundreds of turtles on the beach wall out in front. Friendly and helpful condo maintenance personnel. Excellent and well organized recycling area, reduced garbage a lot. Good to see.
I am so happy to hear that you had a awesome and wonderful stay! We greatly appreciate your review as well.
The condo is nicely located with a fantastic view onto the ocean. In the afternoon you can see sea turtles from your lanai. The location is good, as you can easily get to all other locations on the island with a rental car.


I spent the night in the car ready for another great snow day on Friday at Glencoe. The Glencoe digger and piste basher were working through the wee hours trying their best to clear the car park and access road. I had breakfast while waiting on John who's driving up for his first day snowboarding in a long time. It soon became obvious though that the snow overnight had made conditions on the access road tricky and the cars were queuing along the A82. John texted me to let me know he was at the turn off. However it would be about 45 minutes before he got up into the car park. It wasn't till after 11 we got up the hill.
The winds were a bit gusty once we got up the mountain. Unfortunately this meant the Cliffhanger Chair would not run for the whole day. We got ourselves up the plateau to discover that the Wall T-bar had stopped for a while so we decided after a few warm up runs to go for the Dark Side. A black run that takes you back to the car park.
It was a fun ride down the side of the large waterfall that run don the mountain. The snow was excellent and we got a few nice power turns in before the steeper, trickier terrain where there were a few tumbles wherever the snow gave way to heather.
The visibility was better as we descended towards the bottom cafe where we decided to grab coffee before taking the access lift back up the mountain.
Show flurries continued to pass through and visibility degraded as the day went on. The wall t-bar was back on and we made our way to the summit and took a run down happy valley. All runs are complete and the mountain is looking as good as it has done for a long time. Most of the rocks are covered and gullies filled. Flypaper remains closed due to avalanche risk and I didn't try the Spring Run. Visibility became close to zero towards the end of the day we decided to make for the lift down.
John had decided to stay for the following day as the weather was forecast to be sunny and with the epic snow. It looked like an amazing day was on the cards.
We decided to pop in to Fort William for something to eat. However, the snow was falling and only seemed to be getting heavier.
Fort William was clear and after dinner our return to Glencoe and Rannoch moor was met with intense snow fall. The ploughs had been out and the main road itself felt ok, bit the snow streaking onto my headlights was very disorienting.
We made it to the access road for the resort around 10 at night. There were cars traveling up the road in front, as we drew closer we raised they had stopped.
The driver of the car in front of us came out to explain that the bright spark driving he van up ahead had decided to attach his snow chains while still on the access road. This was not a wide road and has passing places. We were waiting 10-15 minutes before the car in front attempted to squeeze past the van. It started sliding and soon we found ourselves, along with others on the road, pushing the car. We were getting soaked in the heavy snow as we put our weight into the vehicle, eventually getting it up to the car park. Next we had to get behind the van itself. It was hard going, but eventually we got that up and onto the hill.
Driving up behind the van had left us on an incline and when it came to me to get the car up the hill I found myself sliding to the high side of the road, despite four-wheel drive.
I had to reverse and give it another run. With the help of everyone behind, I eventually made it myself up onto the car park. I pulled in beside Johnathan's car which had sat there being covered in more and more snow.
We chilled out watching a movie on the iPad and wound down from the exertion of pushing the cars. I had a pretty good sleep in the back of the car that night, but the traffic kept coming. People were arriving all through the night, being pushed, towed and manhandled up the access road. Everyone knew it was going to be a cracking day on Saturday.


text:
Q: Transaction reverted: function call to a non-contract account I want to call a function from external contract (Exchange) which was created from another contract (Factory)
For that, I am passing the contract address to create an instance.
I am getting following error if I call the addLiquidity function:
Error: Transaction reverted: function call to a non-contract account
      at Exchange.getReserve (src/contracts/Exchange.sol:72)
      at runMicrotasks (<anonymous>)
      at processTicksAndRejections (internal/process/task_queues.js:93:5)
      at EthModule._estimateGasAction (/Users/ag/Documents/eth_swap/node_modules/hardhat/src/internal/hardhat-network/provider/modules/eth.ts:421:9)
      at HardhatNetworkProvider._sendWithLogging (/Users/ag/Documents/eth_swap/node_modules/hardhat/src/internal/hardhat-network/provider/provider.ts:126:22)
      at HardhatNetworkProvider.request (/Users/ag/Documents/eth_swap/node_modules/hardhat/src/internal/hardhat-network/provider/provider.ts:103:18)
      at JsonRpcHandler._handleRequest (/Users/ag/Documents/eth_swap/node_modules/hardhat/src/internal/hardhat-network/jsonrpc/handler.ts:188:20)
      at JsonRpcHandler._handleSingleRequest (/Users/ag/Documents/eth_swap/node_modules/hardhat/src/internal/hardhat-network/jsonrpc/handler.ts:167:17)

I am testing using the local environment from hardhat.
addLiquidity = async (tokenAmount: string, ethAmount: string) => {
  this.setState({ loading: true });
  const accounts = await this.state.web3.eth.getAccounts();
  try {
    const dexAddress = await this.state.factory.methods
      .getExchange(this.state.tokenAddress.toString())
      .call();

    if (dexAddress.startsWith('0x00')) {
      console.log('IN');
      await this.state.factory.methods
        .createExchange(this.state.tokenAddress)
        .send({ from: this.state.account });
      const dexAddress = await this.state.factory.methods
        .getExchange(this.state.tokenAddress)
        .call();
      this.setState({ exchangeAddress: dexAddress });
    } else {
      console.log('IN2');
      const dexAddress = await this.state.factory.methods
        .getExchange(this.state.tokenAddress)
        .call();
      this.setState({ exchangeAddress: dexAddress });
    }
    const exchange = new this.state.web3.eth.Contract(
      Exchange.abi as AbiItem[],
      this.state.exchangeAddress
    );

    await this.state.token.methods
      .approve(this.state.exchangeAddress, tokenAmount)
      .send({
        from: accounts[0],
      });

    await exchange.methods.addLiquidity(tokenAmount).send({
      from: accounts[0],
      value: ethAmount,
    }).on('receipt', (hash: any) => {
      console.log('LP');
      this.setState({ loading: false });
    })
    .on('error', (error: any, receipt: any) => {
      // If the transaction was rejected by the network with a receipt, the second parameter will be the receipt.
      console.log(error);
      if (error.code === 4001) {
        this.setState({ loading: false });
      }
    });
  } catch (err) {
    console.log(err);
    this.setState({ loading: false });
    return;
  }
};