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Double Aspect
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Tag: niqab
Can an agency choose not to enforce Bill 21?
Last week, the English Montreal School Board [EMSB] announced that it is refusing to to implement Bill 21, introduced by the Quebec government. The law would ban workers in the public sphere in positions of authority from wearing "religious symbols" while at work. The government, apparently cognizant of the challenges this could raise under the Canadian Charter of Rights and Freedoms, signalled its intention to invoke the notwithstanding clause to immunize its law from constitutional scrutiny by the judiciary.
In pre-emptively declining to implement the law, the EMSB invoked constitutional objections under the Charter against the ban:
Vice-Chair Joe Ortona, who drafted the resolution, said that the EMSB believes this proposed legislation would be contrary to paragraph 2 (a) of the Canadian Charter of Rights and Freedoms which guarantees everyone's right to freedom of conscience and freedom of religion and contrary to paragraph 2 (b) of the Canadian Charter of Rights and Freedoms which guarantees everyone's right to freedom thought, belief, opinion and expression.
Furthermore Mr. Ortona said that the EMSB believes this proposed legislation would be contrary to subsection 15 (1) of the Canadian Charter of Rights and Freedoms which guarantees that everyone is equal before and under the law and guarantees the right to equal protection and equal benefit of the law without discrimination and, in particular, without discrimination based on religion and contrary to section 3 of the Charter of Human Rights and Freedoms which guarantees freedom of conscience, freedom of religion, freedom of opinion, and freedom of expression.
Quite aside from the merits of the issue, there is a legitimate question of administrative law, here: can an administrative agency like a school board, empowered by statute, simply decline to enforce a law that it believes is unconstitutional? More specifically, can the agency decline to enforce the law if the law invokes the notwithstanding clause? Whatever the answer is, should agencies be able to come to their own determinations of constitutional law?
The place to start is probably the Martin and Conway line of cases. The core issues in those cases were the conditions under which an administrative agency can choose not to apply statutory provisions in its enabling statute that it considers to be unconstitutional—and if so, whether there is a power to issue personal remedies under the Charter. So these cases go, if an agency has the express or implied power to decide questions of law under the challenged provision (see Martin, at para 37), then it presumptively has the power to determine questions of constitutional law. The implied inquiry looks to a number of considerations (see Martin at para 41):
Relevant factors will include the statutory mandate of the tribunal in issue and whether deciding questions of law is necessary to fulfilling this mandate effectively; the interaction of the tribunal in question with other elements of the administrative system; whether the tribunal is adjudicative in nature; and practical considerations, including the tribunal's capacity to consider questions of law. Practical considerations, however, cannot override a clear implication from the statute itself, particularly when depriving the tribunal of the power to decide questions of law would impair its capacity to fulfill its intended mandate. As is the case for explicit jurisdiction, if the tribunal is found to have implied jurisdiction to decide questions of law arising under a legislative provision, this power will be presumed to include jurisdiction to determine the constitutional validity of that provision.
The presumption can be rebutted by the party seeking to dislodge the Charter jurisdictional presumption, by pointing to an express or implied withdrawal of authority to decide constitutional questions: the concern is discerning whether there is an intention to "exclude the Charter, or more broadly, a category of questions of law encompassing the Charter, from the scope of the questions of law to be addressed by the tribunal (Martin, at para 42).
So the question at the outset for the EMSB is whether it has been conferred the ability to decide questions of law, either explicitly or impliedly. The enabling statute for the EMSB is the Education Act. Under s.111 of that statute, the province of Quebec is divided into "two groups of territories," with one group constituting English school boards, like the EMSB. The EMSB, under the statute, is "a legal person established in the public interest" (s.113). There is at least some reason (even if weak) to believe under the Education Act the EMSB has the power to decide questions of law, but only a limited one pertaining to its particular mission under the Education Act. For example, under the statute, the EMSB has the power to "ensure that the basic school regulation established by the Government is implemented" (s.222) and can exempt students from that basic regulation "[f]or humanitarian reasons or to avoid serious harm to a student" (s.222). Assume for now that these rather vague and limited provisions confer a general power to decide questions of law: that general power, interpreted in light of the text, context, and purpose of the Education Act as it relates to school boards, would probably only relate to the organization of quality educational services (s.207.1), although one could argue that the same concern could apply to the context of Bill 21.
Even if this could be seen as an implicit signal of constitutional jurisdiction under the Education Act, it is a bit orthogonal to the core interpretive question. Martin, the key case on point, says that the real question is whether the EMSB has power to decide questions of law under the challenged provision in its enabling statute (see paras 27-28, 35). But here, there is not only no challenged provision yet, but it is not the EMSB's enabling statute. This presents two further problems: can agencies issue prophylactic constitutional rulings? And even if they can, can they do so by choosing not to apply a statute that is not their enabling statute?
It would seem odd, in light of the Supreme Court's cases, to suggest that an administrative agency can prophylactically choose not to apply a law that otherwise applies to it. Administrative agencies are creatures of statute, and so are subject to the statutory conditions that the legislature imposes on them. Under Bill 21, the terms of the statute clearly apply to school boards (see Schedule I, (7)). Short of some dispute arising within the confines of the statutory regime created by the Education Act, there does not seem warrant for the EMSB to go out on a limb and refuse to apply a statute that has yet to have created any particular problems within its statutory jurisdiction. This seems to be what Abella J suggested in Conway, where she concluded that tribunals could "have the authority to resolve constitutional questions that are linked to matters properly before them" (Conway, at para 78).
More important than this issue, though, is the idea that the EMSB can choose not to apply a statute that is not its enabling statute. The main Supreme Court cases dealing with this issue, even the ones that predate Martin, involve the enabling statute of the decision-maker under consideration (Conway, at para 49: "These cases dealt with whether administrative tribunals could decide the constitutionality of the provisions of their own statutory schemes." Consider the cases on this point: in Cuddy Chicks, the issue was whether the Ontario Labour Relations Board could determine the constitutionality of a provision in the Labour Relations Act. In Martin, the question was whether the Nova Scotia Workers' Compensation Appeals Tribunal could decide a s.15 Charter claim under the Workers' Compensation Act and associated regulations. All of these cases involved claims tied to the regime under which the decision-maker was established, with cases "properly before them." And this makes sense: it would be odd for Parliament to delegate power to an administrative agency, confined by a statutory scheme, to pass on the constitutionality of other statutory provisions that may only tangentially be related to the part of the Education Act (for example) that the EMSB must apply.
Even if none of this were true, the notwithstanding clause effectively limits any independent choice an agency could have about the constitutionality of the statute under which it is invoked. For one, even if one could impute an intention to the legislature that presumptively allows the EMSB to make constitutional determinations, the notwithstanding clause is a good reason to say that the legislature has rebutted that presumption with respect to the particular category of question at issue here: this is the upshot of Martin and Conway. More fundamentally, a use of the notwithstanding clause cannot be legally questioned by any actor in the system, including the judiciary. The EMSB cannot legally second-guess the choice of the provincial government (its master) to insulate legislation from constitutional scrutiny. The invocation of the notwithstanding clause flows down the entire machinery of the state, and whether we like it or not, its use is legally justifiable by the fiat of the legislature.
To my mind, the use of the notwithstanding clause also renders null any arguments that one could make that the EMSB is justified in its prophylactic ruling because of an abstract notion of "Charter values." Despite the fact that the spectre of Charter values is increasingly being called into question, and the precedential force of cases like Trinity Western should be questioned because of the lack of reasoning on the point (see, embarrassingly for the TWU majority, para 59), the notwithstanding clause is a legislative command that compels executive actors to ignore the Charter when implementing the law in question. There would be no point in invoking the notwithstanding clause if administrative actors could choose to "independently" opine on the constitutionality of laws in the face of it. The lightning rod for a consideration of Charter values is discretion, and the notwithstanding clause neutralizes any discretion at all on the constitutional question.
To my mind, there is little warrant for the EMSB to prophylactically say it will not enforce Bill 21, given its limited statutory domain and the use of the notwithstanding clause. And this is likely how it should be. It is one thing for an administrative agency, when implementing a statute in the context of a concrete dispute, to have to pass on the constitutionality of a statutory provision—in its own statute—in order to resolve the dispute. In that case, there are at least colourable reasons why the agency should have the power to do this: if one believes in the idea that agencies have expertise on matters arising within the confines of their statute, one could say that they could also have expertise on Charter matters arising in relation to that same statute. One could also say that the legislature delegated to the agency the power to make Charter determinations, even through the imperfect proxy of a general power to decide questions of law. These same justifications lose their force when considering statutory provisions outside the enabling statute. While Bill 21 certainly does affect the realm of the EMSB, the EMSB is not conferred a general power to make constitutional determinations arising under other statutes.
Author Mark ManciniPosted on April 4, 2019 Categories Administrative Law, Constitutional lawTags bill 21, Charter, niqab, notwithstanding clause2 Comments on Can an agency choose not to enforce Bill 21?
Bashing Bill 62
Criticism of Québec's face-veil ban coming from elsewhere in Canada is neither hypocritical nor disproportionate
In an op-ed in The Globe and Mail that has generated some discussion, at least in Québec, Jean Leclair remonstrates with "English Canadian politicians and journalists" for their criticism of Québec's recently enacted legislation that could prevent women who wear face veils (and perhaps other people, such as those who wear sunglasses) from taking the bus or accessing any other public services. Prof. Leclair faults the classes that chatter in English for their hypocrisy and for the excesses of their rhetoric. With respect, it is he who is wrong.
Prof. Leclair thinks that English Canadian criticism of the former Bill 62 is hypocritical because the rest of Canada too has its share of racists and of people who support legislation targeting religious minorities. That is no doubt true. But it is no less true that in no province other than Québec has legislation similar to the "Charter of Values" that was proposed by Québec's previous government, Bill 62, or beefed-up versions of the latter being proposed by both main opposition parties in Québec been enacted. To my knowledge, no provincial political party has made such legislation official policy. More broadly, no provincial political party has attempted to trade on or pander to the racism that undoubtedly exists in Canadian society in the way that all the main parties in Québec have done. The Conservative Party of Canada, in the death throes of the last federal election campaign, tried to do so, and having failed, abandoned the attempt. Prof. Leclair writes as if there is no difference between discriminatory attitudes existing in society and these attitudes being shared, or indulged for partisan purposes, by those in power. This is not so.
Prof. Leclair also thinks that the critics of Bill 62 are hypocrites insofar as they appear to him to celebrate the wearing of niqabs, or at least to be "stigmatizing all people who do not wish to 'celebrate' the right of a woman to wear a veil". "How many" of them, he asks, "would rejoice if their daughter, one day, chose to wear one?" Prof. Leclair does not mention any names, and I am puzzled as to whether anyone actually is celebrating the fact that niqabs are being worn in Canada. What is worthy of celebration is the fact people are free to act in ways of which many, probably a majority, of their fellow citizens disapprove. Prof. Leclair insists that people should be free to criticize the wearing of the face veils without being accused of being racists, and I agree with him so far as this goes. But, once again, there is a difference between insisting that people are free to criticize others' choices, even religiously-inspired ones, and defending their purported freedom to support or vote for policies that coerce those who make choices they deem wrong. Criticism is a right in a free society; coercion is not.
Prof. Leclair also argues that the criticism of Québec's anti-veil (and perhaps anti-sunglasses) legislation is overwrought. After all, "Canada's approach to the regulation of religious symbols and clothing … is not the only legal path followed in the liberal-democratic world". A number of European countries have banned full-faced veils, and these bans have been upheld by the European Court of Human Rights. This, to prof. Leclair, proves that, though the bans may be wrong ― as he thinks ―, they are not "synonymous with blind racism". Yet I fail to see how the fact that some countries ― even some democratic countries ― do something should shield that thing from forceful criticism. Admittedly, I do not know whether Prof. Leclair personally has ever criticized, say, the American criminal justice system as barbaric, but plenty of people in Canada and in Europe do not hesitate to do so. Does prof. Leclair think they should all keep mum? For my part, I think that to the extent that human rights involve universal principles, there is nothing inherently untoward in arguing that the interpretation of these principles by another polity, or group of polities, is perverse.
And the European approach to face veils is indeed perverse. Whether or not it proceeds from "blind racism", as I have argued here, the reasoning of the Strasbourg Court is repressive, and indeed totalitarian. It rests on the premises that the state is entitled to impose conditions on human interaction that the individuals doing the interacting do not wish to be subject to, and that individuals have some kind of obligation to enter into "open interpersonal relations" with others, whether or not they want to do so. This reasoning is incompatible with belief in a free society, where people decide whether they wish to interact with others, and on what terms, so long as they are refraining from using force or fraud and not harming third parties. Prof. Leclair insists that even if the banning face veils is wrong, it is not arbitrarily repressive, as if the state were "regulating such things as baseball caps or miniskirts". Face veils are associated with oppression against women, and the desire to outlaw them is therefore comprehensible even if misguided. I'm not sure about skirt length requirements, but certainly prohibitions on women joining certain occupations, or working outside the home at all, or voting, were once justified by claims that these activities took away women's dignity. We have learned not just to politely disagree with such claims, but to reject them out of hand (which, of course, does not mean to shout them down or censor them). I hope that, in due course, we will also learn to reject out of hand claims that the dignity of women requires them to be prevented from dressing in accordance with their religious beliefs.
In my view, then, Prof. Leclair and others who, like him, disagree with Québec's ban on face veils and proposals to extend this ban are wrong to object to the criticism with which this ban has been received in the rest of the country. This criticism is not made hypocritical by the existence of racist citizens outside Québec, nor is it made disproportionate by the fact that similar bans are regarded as acceptable in Europe. Prof. Leclair and others might view the criticism as an instance of "Québec-bashing", the application of double standards to their province. Their are mistaken. Not only is there no double standard, as I've argued above, but the intensity of the criticism is, at least in part, likely driven by a recognition of the existence of the chauvinist and illiberal tendencies elsewhere in Canada. There might be no need to criticise Québec's legislation so much if we were certain that it would never be replicated elsewhere. But precisely because there can be no such assurance, it is important that scholars, journalists, and politicians across Canada denounce it for what it is ― a manifestation of bigoted illiberalism.
Author Leonid SirotaPosted on November 5, 2017 November 5, 2017 Categories Constitutional law, Law and ReligionTags Bill 62, Canada, European Court of Human Rights, niqab, Québec, veil, voileLeave a comment on Bashing Bill 62
The Swearing Show
Niqabs at citizenship oath swearing ceremonies are a big deal. Not really a big deal, mind you, because, as Radio-Canada reports, according to Citizenship and Immigration Canada, there have been exactly two women since 2011 who refused to go through with the oath because of the ban on the niqab which the government had illegally decreed. But politically a big deal. Yet while the niqab and the citizenship oath are the hot new celebrity couple of Canadian politics, all the attention is focused on the niqab, even though all that there was to say about it has already been said some time ago, by Emmett Macfarlane and by Tabatha Southey. If there was anything left to add, Andrew Coyne has added it. The oath, for its part, languishes in obscurity. I would like to remedy that.
You might think that focusing on the oath is a waste of time; that it is only a pretext for the Conservatives to score some political points by attacking the infinitesimal minority of Muslim women who wear the niqab. But why was this particular pretext chosen? After all, the same party is apparently uninterested by banning niqabs from the polling stations ― and yet you'd think that this would be at least as much of a bigot-vote-winner as banning them from citizenship oath ceremonies. So I think it is worth asking what is special about the oath.
There are two ways of seeing the citizenship oath. One is presented in the judgments of the Ontario courts that have upheld its reference to the Queen against a constitutional challenge by some anti-Monarchists who refused to swear "true allegiance" to Elizabeth II, her heirs and successors. The persons challenging the oath argued that the Queen symbolized inequality, privilege, and oppression. Not so, held the Superior Court of Justice in McAteer et al. v. Attorney General of Canada, 2013 ONSC 5895: "the oath to the Queen is in fact an oath to a domestic institution that represents egalitarian governance and the rule of law." [65] For its part, the Court of Appeal for Ontario, in McAteer v. Canada (Attorney General), 2014 ONCA 578, held that the oath represented "a symbolic commitment to our form of government and the unwritten constitutional principle of democracy." [62]
As I explained in a paper arguing that, contrary to the courts' findings, the citizenship oath is indeed an unconstitutional violation of freedom of conscience, the other way of seeing the Canadian citizenship oath, as all loyalty oaths, is as an expression of the state's fear of its new citizens' disloyalty. I wrote that
if there is an implicit logic that can justify imposing the oath of allegiance on all would-be naturalized citizens, it is that they are all people whose commitment to Canada is doubtful (their decision to seek Canadian citizenship notwithstanding!), if not potential traitors. (158)
Otherwise, why is the oath even necessary? The government and the courts never answered this question (in part, one must admit, because the people challenging the oath did not dare ask it ― they accepted the principle of the oath unquestioningly).
To me at least, the role that the citizenship oath has come to play in the niqab controversy suggests that my jaundiced view of the oath is closer to reality than the courts' optimistic one. If the oath were about equality, it would not be seen as an opportunity for singling out a minuscule unpopular group for legal retribution and public opprobrium. If it were about the Rule of Law, it would not be the occasion for bending legal procedures and ignoring legal advice in order to score political points. If it were about respecting our form of government, it would not be the scene of a blatant violation of the Canadian Charter of Rights of Freedoms. On the other hand, if what the oath really represents is a fear of the outsiders, of those who are different ― whether they think differently (like the anti-Monarchists) or dress differently (like the women who wear the niqab) ― and who are therefore said to stand against Canadian values and deemed disloyal despite the absence of any evidence of their disloyalty, then it makes a lot of sense for the oath to be treated in these ways.
We would do well, I submit, to ask ourselves again why exactly it is that we need an oath of citizenship. Mr. Coyne writes that "[n]o one else's life is made the poorer because, somewhere in Canada, a women is swearing allegiance to this country with her face covered." Nor are anyone's rights infringed. That is true of course. But the same thing would be true if one simply became a citizen upon having satisfied a citizenship judge that one has met the legal requirements. The theatre of the oath-swearing can be dispensed with. The actors do not even understand their lines, and now we're fighting over their costumes too. There are other shows in town more deserving of everyone's time and attention.
Author Leonid SirotaPosted on October 2, 2015 Categories Political philosophyTags Canada, citizenship, niqab, oath, politicsLeave a comment on The Swearing Show
Des fois, Boisvert a tort
J'avais beaucoup de respect, de l'admiration même, pour Yves Boisvert. Il est sans doute l'un des observateurs les plus perspicaces et les plus justes du système judiciaire et des enjeux reliés au droit dans les médias traditionnels. Il a fait preuve de sagesse et de respect pour la différence lors du débat sur la Charte de la honte péquiste. Pourtant, ces derniers mois, ces qualités semblent lui faire de plus en plus souvent défaut. J'ai déjà discuté ici de son attaque injustifiée contre les Cours fédérales, dans laquelle il insinuait que certains Québécois ne le sont pas « suffisamment », et de sa critique, tout aussi injustifiée, de l' « Américanisation » du système judiciaire canadien qui résulterait de la nomination de quelques juges présumés « conservateurs ». Cette tendance à l'intolérance de la différence se confirme, hélas, dans la récente chronique de M. Boisvert dans La Presse+ au sujet du niqab.
M. Boisvert y défend la position du premier ministre Harper qui passe dernièrement son temps à pourfendre les femmes qui portent le niqab à leur prestation du serment de citoyenneté. M. Boisvert est d'avis qu'
[u]n pays n'est pas « islamophobe » parce qu'il dit à ses nouveaux arrivants : le jour très solennel où vous deviendrez citoyens du Canada, vous montrerez votre visage.
Les raisons pour lesquelles M. Boisvert défend cette violation de la liberté religieuse ― et il est bien conscient qu'il s'agit d'une violation, lui qui « ne voi[t] pas comment on pourrait » interdire le port du niqab en public, comme certains pays européens l'ont fait ― ne sont pas exactement limpides. D'une part, pour lui, comme pour le premier ministre, le niqab serait problématique en soi. En cachant le visage d'une femme, dit M. Boisvert, le niqab « abolit son identité publique. Il est issu du fond des âges et promu par la frange combattante de l'islam radical ». Il serait apparenté à ces « pratiques barbares » que le gouvernement n'a de cesse de dénoncer. D'autre part, M. Boisvert semble avoir des préoccupations quant à la sécurité ou à l'identification:
pour témoigner à la cour ou dans une cérémonie de prestation de serment, pour être fonctionnaire, pour demander des services de l'État, on a le droit d'appliquer le « test de l'aéroport ». Montrez-vous, s'il vous plaît.
Or, cette préoccupation est mal-fondée. M. Boisvert reconnaît lui-même que « [l]'identité de la nouvelle citoyenne est évidemment vérifiée avant la prestation de serment », qu'elle porte le niqab ou pas. Il faut donc croire que c'est bien le premier argument, celui voulant que le niqab soit intrinsèquement problématique, qui explique la position de M. Boisvert. Pourtant, si le niqab est réellement une « pratique barbare », il m'est difficile de comprendre pourquoi on l'interdirait dans certaines situations et non dans d'autres. On n'interdit pas le mariage forcé seulement le jour où les parents deviennent citoyens canadiens, n'est-ce pas?
Cependant, au-delà de leur contradiction, ces deux arguments contre le niqab ne découlent tout simplement pas des de leurs prémisses. Le niqab est le fruit d'une « culture antifemmes »? Oui, sans doute. Sauf que comme l'a noté l'excellente Tabatha Southey dans le Globe and Mail,
[i]f women didn't wear clothes that were "rooted in a culture that is anti-women," we'd be naked. You can argue that the veil isn't a choice, that Muslim women wear the niqab only because of cultural pressure and family. These are the only reasons I wear clothes in August.
Le niqab est-il promu par les islamistes radicaux? Oui, sans doute. Et alors? Les islamistes veulent aussi que les hommes portent la barbe. Devons nous raser tous les hipsters du Plateau, pour les dépiter? L'important, me semble-t-il, n'est pas de savoir qui le promeut, mais qui le porte. Et la réponse et cette question n'est pas celle à laquelle MM. Harper et Boisvert voudraient nous faire croire. Par exemple, Zunera Ishaq, la femme à l'origine de la controverse actuelle, qui s'est récemment expliquée dans le Tornto Star, est une diplômée universitaire, impliquée dans communauté et porte le niqab malgré les souhaits de sa famille, et non à cause d'eux. C'est la mépriser que de prétendre la forcer à être libre ― être libre selon la compréhension que s'en font des hommes qui, en fait, cherchent à restreindre sa capacité de faire ses propres choix.
Remarquez, on n'est pas obligé d'être d'accord avec ces choix. Je crois, moi, que même s'il reflète un choix personnel, le niqab n'en est pas moins un symbole funeste. Je n'aime pas le voir. Mme. Ishaq dit que son niqab oblige les gens à aller au-delà des apparences pour interagir avec elle. Peut-être bien, mais c'est un effort supplémentaire que, dans la vie de tous les jours, on n'est pas tenu de faire.
Cela dit, il y a beaucoup de symboles funestes, et plus encore de symboles de mauvais goût, qu'on accepte dans notre société. Personne, à ma connaissance, ne songe à interdire les chandails à l'effigie de Che Guevara ou de Lénine, que ce soit lors de la prestation du serment de citoyenneté ou dans d'autres contextes. Ce sont pourtant, là aussi, des symboles d'une idéologie oppressive, meurtrière et destructrice. Comme avec le niqab, on peut très bien porter un regard désapprobateur sur les personnes qui affichent ces symboles. Or, désapprouver est une chose; interdire en est une autre.
Du reste, la société québécoise est loin de désapprouver tous les symboles de l'oppression. Comme je l'écrivais ici,
[p]ersonne ne s'empresse de renommer les rues Laflèche ou Bourget, disons, partout au Québec, pour ce que les évêques ultramontains ont fait, des décennies durant, à la démocratie. Ni la station de métro nommée en l'honneur de l'auteur de L'Appel de la Race. Oh, et le fameux crucifix installé par Maurice Duplessis, il est toujours à l'Assemblée nationale. Le paysage (symbolique) québécois est parsemé d'éloges d'un passé, pas si lointain, qui n'était pas si différent des fantasmes [des islamistes d'aujourd'hui].
L'indignation collective à laquelle se joint M. Boisvert est donc fort sélective. Elle n'en a rien à foutre de notre passé collectif ultramontain ou des conneries pseudo-révolutionnaires des enfants gâtés de notre bourgeoisie nationale, mais elle se déchaîne à la vue du niqab. Or le trait distinctif de ce symbole n'est pas d'être associé à une idéologie répressive, ce que d'autres symboles sont aussi, mais bien d'être associé à des gens différents de nous.
Author Leonid SirotaPosted on March 17, 2015 April 26, 2015 Categories Law and ReligionTags Boisvert, extremism, niqab, Québec, religionLeave a comment on Des fois, Boisvert a tort
Facing Justice ― English Version
I wrote last year about the Supreme Court's decision on whether a witness in a criminal proceeding could testify while wearing a niqab, a full-face veil, R. v. N.S., 2012 SCC 72, [2012] 3 SCR 726. Of course, the questions about balancing trial fairness and freedom of religion which the Court had to confront in that case do not only arise in Canada. An English criminal trial court recently had to confront them too, delivering its decision on the matter in R. v D(R) [2013] EW Misc 13 (CC) yesterday.
One difference between the English and the Canadian cases is that in N.S., it was a witness (namely, the complainant) who asked to testify with her face covered. In D(R) it was the accused. Judge Murphy, who decided D, thought it was an important distinction:
there are different considerations in these instances. For example, the public has a strong interest in encouraging women who may be the victims of crime from coming forward, without the fear that the court process may compromise their religious beliefs and practices. On the other hand, the rights of the defendant in any resulting criminal proceedings must also be protected. So there is a potential for a challenging conflict of competing public interests. A defendant may, of course, be a witness; but this does not define her role in the proceedings. As a defendant, she plays the central role throughout proceedings, and unlike a witness, she is brought before the court under compulsion and does not appear as a matter of choice (par. 8).
Another distinction which Judge Murphy made in discussing N.S. concerns the significance of the right to religious freedom in Canadian law, by virtue of the Canadian Charter of Rights and Freedoms, which he took to be far greater than that of the "qualified" right to freedom of religion under the European Convention on Human Rights. (I think that Judge Murphy is wrong about this. He takes the protection of freedom in s. 2(a) of the Charter to be absolute, because that provision lacks a qualifying clause like the corresponding one of European Convention ― but of course the Charter does have a qualifying clause, albeit a general one, s. 1.)
One element of N.S. that judge Murphy rejects is the preliminary step of inquiring into the sincerity of the accused's belief that she must wear the niqab. Such an inquiry would be too difficult to undertake, and different results in different cases would lead to "a kind of judicial anarchy" (par. 15). Better to have a general rule that will apply unless the prosecution decides to bring some evidence suggesting that the accused is, in fact, insincere.
These distinctions notwithstanding, Judge Murphy's understanding of the basic problem facing the court is not very different from that of the majority in N.S. There is a clash of long-standing, fundamental principles: freedom of religion on the one hand, trial fairness on the other. Religious freedom means being able to wear the clothes one's religion prescribes. Trial fairness means requires the judge, the jury, and counsel to be able to observe the witness who gives evidence, and the accused even when she is not giving evidence.
Judge Murphy's views on the trial process, however, are similar to (and borrow from) those of Justice Lebel's concurrence in N.S. A trial is a "communicative" process, and seeing the accused throughout is very important. It would be unfair to all the other participants in the proceedings if they could not observe the accused's face. Judge Murphy goes further still. He finds that because "[t]he Court may not discriminate between different religious traditions, or between those with a religious belief and those with none," if a woman wearing the niqab "is entitled to keep her face covered, it becomes impossible for the Court to refuse the same privilege to others, whether or not they hold the same or another religious belief, or none at all" (par. 60). Furthermore, if judges had to accommodate niqab-wearers on the mere assertion of their religious beliefs, they would in effect be deprived of their entitlement to control their courts' procedures.
Balancing these considerations against the freedom of religion, Judge Murphy concludes that the accused may not wear a niqab while giving evidence, but may do so at other moments of the trial, except when it is necessary to identify her. To be sure, this may mean that some accused will choose not to give evidence, or will experience discomfort while doing so. Giving evidence, if one wishes to, is a right of the accused. However, this right "involves a corresponding duty to submit that evidence to the scrutiny of the jury" (par. 70). While in other cases it is often possible to accommodate religious beliefs, it would be too much of a strain, and indeed an impairment of rights, to arrange for trials of niqab-wearers to involve only women (as judges, jurors, and counsel).
As I said in my comments on N.S., I am more comfortable with the case-by-case approach taken by the majority in that case than with a bright-line rule. However, it seems clear enough to me that the majority's approach will, in reality, far more often than not lead to witnesses being ordered to remove the niqab while giving evidence. The practical difference between the N.S. approach and the one taken in D is thus likely to be very minor.
What I don't like in Judge Murphy's reasons are his comments on discrimination and the need to have the same rule apply to all. Of course the law should not discriminate between different religions. But to accommodate a peculiar duty that the members of one faith have is not to make them a special favour; an accommodation made on account of such a duty need not be extended to those who have no such duty. The fact that a Sikh boy has the right to wear a kirpan to school does not mean that others ought to be able to bring knives, which they are not compelled to do by their conscience. The fact that a woman who feels in conscience bound to wear the niqab may (sometimes) do so in court need not mean allowing others to wear a mask. Of course, these differences mean that an inquiry into the sincerity of a belief is sometimes necessary (though often sincerity will be admitted by all parties), which is another point where Judge Murphy, in my view, goes wrong.
In any case, despite these problems, his opinion is thoughtful, and a useful read for those interested in the topic of religious accommodation.
Author Leonid SirotaPosted on September 18, 2013 December 9, 2013 Categories Criminal Law/Policy, Law and Religion, The Justice SystemTags conflict of rights, England, niqab, religious exemptionsLeave a comment on Facing Justice ― English Version
Facing Justice
In a decision delivered this morning, R. v. N.S., 2012 SCC 72, the Supreme Court has ruled that the rights of a witness who, for sincere religious reasons, wishes to testify with her face covered and those of an accused against whom she testifies must be balanced on a case-by-case basis, eschewing a bright-line rule, though suggesting that in doubt the accused's right to a fair trial prevails and militates in favour of an order that the witness remove the face covering. (If you want a less convoluted version of this summary, look at media titles: most, including the National Post, the Toronto Star and all the French-language media―Radio-Canada, Le Devoir, La Presse, and Le Journal de Montréal―go for something like "Niqab allowed in some cases," but the CBC and the Globe & Mail go for variations on "Judge can order niqab to be removed." I wanted to avoid this glass half-empty or half-full problem.)
The appellant, N.S., is due to testify at the trial of two relatives whom she accuses of raping her. She wants to do it while wearing a niqab. The accused say she ought to be ordered to remove it while testifying, because not seeing her face prevents the trier of fact (judge or jury members) from making accurate credibility findings and their lawyers from cross-examining her effectively, thus jeopardizing the fairness of their trial. There are thus fundamental rights involved on both sides, freedom of religion and the right to a fair trial. What gives?
First of all, says Chief Justice McLachlin for the majority, it is important to check whether the witness's insistence on covering her face is motivated by a sincere belief. The first instance judge in this case did not conduct that inquiry properly, so the rest of the reasons is hypothetical―it only presumes that this first requirement has been satisfied.
The second question to be answered is whether allowing the witness to wear a niqab actually compromises trial fairness in the circumstances. Where the evidence the witness will give is uncontested, that is not the case. When credibility is at issue, however, fairness will be compromised. The Chief Justice rejects the claim of the appellant and some interveners that there is nothing much to be learned from seeing a witness's face. The common law has always proceeded on the contrary assumption, she points out, and while such assumptions are known to have sometimes resulted from unfounded misconceptions and even myths, they should not be discarded without any evidence that such is the case.
If it finds that both a sincere religious belief and trial fairness are implicated in the circumstances of a case, the court must attempt to reconcile them by accommodating both. However, it may well be that there is no accommodation which upholds both rights to be found.
If so, the rights at stake must be balanced to determine which is to prevail, again, in the circumstances of the case. "The question," says the Chief Justice, "is whether the salutary effects of requiring the witness to remove the niqab, including the effects on trial fairness, outweigh the deleterious effects of doing so, including the effects on freedom of religion" (par. 34). The Chief Justice sets out a number of factors for courts to consider. On the side of freedom of religion, they include the degree of impairment which a particular witness's freedom would suffer if she is ordered to remove the niqab, but also the risk that witnesses will simply refuse to come forward if they cannot comply with their religious obligations and thus crimes―very serious crimes like rape in this case―will go unreported or unpunished. On the side of trial fairness, there is the extent to which credibility is central to the case, the stage of the proceedings, and whether the trier of fact is a judge or a jury. The list, however, is rather tentative, and non-exhaustive.
Finally, the Chief Justice turns to the proposed alternatives to this uncertain balancing―clear rules either allowing or prohibiting the niqab at all times. Always allowing it, she says, undermines trial fairness and increases the risk of wrongful convictions. Always prohibiting it, on the other hand, in the name of making courts religiously neutral spaces, "is inconsistent with Canadian jurisprudence, courtroom practice, and our tradition of requiring state institutions and actors to accommodate sincerely held religious beliefs insofar as possible" (par. 60). It infringes religious freedom even when doing so does nothing for trial fairness. And, the Chief Justice points out, it is simply not true that we evacuate religion from the courtroom―witnesses have the option to swear on the Bible, the Koran, etc. The state must be neutral towards religion, but it should not hinder it gratuitously.
The two other opinions urge the adoption of the clear rules that the majority rejects.
While concurring in the disposition of the appeal, Justice Lebel, writing for himself and Justice Rothstein, argues that trial fairness and the openness of courts are too fundamental ever to be compromised. Evidence that might be unchallenged at one stage of the trial could be called in question at the next. Anyway, while special rules departing from ordinary procedures can be put in place in order to facilitate communication between the various actors of a trial, a niqab only impedes it, "on the basis of the assertion of a religious belief in circumstances in which the sincerity and strength of the belief are difficult to assess or even to question" (par. 77).
Justice Abella, dissenting, takes the contrary position. In her view, a witness should always be allowed to wear a niqab, except in cases where identity itself is at issue. Otherwise, while "seeing more of a witness' facial expressions is better than seeing less" (par. 82), seeing less does not prevent the trier of fact from assessing credibility. Anyway, the law already makes any number of exceptions that allow people to testify in ways that prevent their demeanour from being visible to and assessed by the trier of fact. That a witness must testify with her face open is only a general expectation, not a general rule, while the risk of being required to breach one's religious duty will deter women from acting as witnesses, and is thus a sign of exclusion of religious minorities.
The contrast of style between the majority, on the one hand, and the concurrence and the dissent is as strong as the substantive difference. The majority's opinion is rather dry and legalistic. The concurrence and the dissent are thick with talk of values and quite impassioned.
For my part, I think that the majority has it right. There really are two very serious rights at issue here. Justice Lebel's snide comment about the possible insincerity of niqab-wearers and Justice Abella's claim that since we already compromise fairness some of the time there is nothing wrong with compromising it some more do not persuade me. Case-by-case balancing―although the Chief Justice's comments suggest that in practice the balance will be tipped towards trial fairness and thus ordering the witness to remove the niqab― might be frustrating, but I don't think that there is a better way to resolve the clash of rights.
Author Leonid SirotaPosted on December 20, 2012 September 23, 2014 Categories Constitutional law, Criminal Law/Policy, Law and ReligionTags conflict of rights, niqab, rights, witnessLeave a comment on Facing Justice
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Fundraising event to feature a wide variety of food from local restaurants.
On Saturday, April 27, from 6:30 to 9:30 p.m., the Westfield Friends School will be hosting "A Taste of Our Towns". An fundraising event featuring a wide variety of foods from local restaurants.
"Join us in supporting our wonderful school at our spring restaurant event and silent auction. You are invited to this adult-only event to stimulate your senses with small bites, wine flights and various brews at a night of culinary delights," said Lily Taylor of the Westfield Friends School Development Committee.
Westfield Friends School is located at 2201 Riverton Rd. in Cinnaminson.
Tickets for the event are $75 per person and include all food and drink. Visit westfieldfriends.org to purchase.


text:
Ragnhildur Guðmundsdóttir
Nationality: Icelandic
Partner Institute: University of Iceland
Start and end of PhD project: 2013-2018
e-mail: rag41@hi.is
Supervisors: Snæbjörn Pálsson, Bjarni K. Kristjánsson and Viggó Þ. Marteinsson
PhD title: Microorganisms associated with the groundwater amphipod Crangonyx islandicus
Description of research project:
Two subterranean freshwater amphipod species have been discovered in Iceland, Crymostygious thingvallensis (Kristjánsson & Svavarsson, 2004) and Crangonyx islandicus (Svavarsson & Kristjansson, 2006). These species are found within the volcanic active zone in groundwater springs. Genetic patterns within C. islandicus show different monophyletic groups in different geographic areas which indicates that the group has survived repeated glaciations in Iceland (Kornobis et al., 2010). The genetic pattern points to distinct groundwater systems within Iceland which might be characterized by distinct microbial fauna as well. Little is known of this groundwater ecosystem and nothing is known about its other species apart from our recent findings of ciliate epibionts on C. islandicus from two orders, Apostomatida and Philasterida (Gudmundsdottir et al. in press), nor the food source of the amphipods.
To explore this system further we study the microbial community in in the groundwater, the hyporheic zone and in the amphipods by targeting 16S and 18S RNA using the Illumina MiSeq high throughput sequencing technic (Degnan & Ochman, 2012). The focus has been set to the possible food source and symbiotic organism of the amphipods and variation of the microbial community in groundwater springs.
Degnan, P. H. and Ochman, H. 2012. Illumina-based analysis of microbial community diversity. ISME J 6: 183-194
Gudmundsdottir, R., Kornobis, E., Kristjánsson, B. K. & Pálsson, S. 2017. Genetic analysis of ciliates living on the groundwater amphipod Crangonyx islandicus (Amphipoda: Crangonyctidae). Acta Zoologica. In Press.
Kornobis, E., Pálsson, S., Kristjánsson, B. K. and Svavarsson, J. 2010. Molecular evidence of the survival of subterranean amphipods (Arthropoda) during Ice Age underneath glaciers in Iceland. Molecular Ecology 19: 2516-2530.
Kristjánsson, B. K. and Svavarsson, J. 2004. Crymostygidae, a new family of subterranean freshwater gammaridean amphipods (Crustacea) recorded from subarctic Europe. Journal of Natural History 38: 1881-1894.
Svavarsson, J. and Kristjánsson, B. K. 2006. Crangonyx islandicus sp nov., a subterranean freshwater amphipod (Crustacea, Amphipoda, Crangonyctidae) from springs in lava fields in Iceland. Zootaxa: 1-17.

redpajama_set_name: RedPajamaCommonCrawl


BA with honors, Wesleyan University, where I studied with Stephen Fisher, David Schorr, and Ian Harvey. Coursework at Binghamton University with Linda Sokolowski. MFA in printmaking, Colorado State, with Jack Orman, Jim Dormer, and Steve Simons. Previously taught at Amherst, Wellesley, Mount Holyoke and Smith Colleges. Currently teaching at Berkshire Arts & Technology Charter School. I live in Western Massachusetts.


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Stop by Sunday, December 8th from 2:00-5:00pm to see for yourself!
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text:
Library of Congress News from the Library of Congress 2019 Hip Hop and Human-Computer Interaction Focus of 2020 ...
November 18, 2019 Hip Hop and Human-Computer Interaction Focus of 2020 Innovators in Residence
Press Contact: Ellis Brachman (202) 707-7816
Public Contact: Jaime Mears (202) 707-3979
Website: LC Labs
The Library of Congress today announced the arrival of its 2020 Innovators in Residence, who will break new ground at the intersections of technology and hip hop, historic newspapers and classic illustrations.
Established in 2017 to invite creative people to develop research concepts and projects that connect the American people with the Library's vast collections, the Innovator in Residence program brings some of the most creative and bold thinkers in-house at the largest library in the world. The Innovators in Residence for 2020 are Brian Foo and Benjamin Charles Germain Lee.
Brian Foo has over two decades of computer science and design experience and has worked in cultural heritage institutions for the past seven years. His work includes the design and development of a dynamic exhibit about climate change at the American Museum of Natural History, as well as Data-Driven DJ, a 10 song album produced entirely from public datasets and open source software to be exhibited in the Museum of the City of New York later this year.
During his time as an Innovator in Residence at the Library, Foo will create "Citizen DJ," an application enabling anyone with a web browser to create hip hop music with public domain audio and video materials from the Library's collections. "The goal of my project is to use the library's public domain audio as source material for hip hop music production," said Foo. "By embedding these materials in hip hop music, listeners can discover items in the library's vast collections that they likely would never have known existed."
Ben Lee is a Ph.D. student in computer science and engineering at the University of Washington, where he studies machine learning and its applications to information access. He has previously served as the inaugural Digital Humanities Associate Fellow at the United States Holocaust Memorial Museum, Visiting Fellow in Harvard's History Department, and is currently a National Science Foundation Graduate Research Fellow.
Lee's work as an Innovator in Residence will focus on using machine learning to extract photographs and illustrations from historic newspapers in the "Chronicling America" collection to make them searchable and accessible. He will also create a search interface that will allow users to browse the collection at scale. "A primary motivation behind my project is to encourage innovation by demonstrating the power of machine learning applied to library collections," said Lee. "The appeal of this research cuts three ways: first, it allows users to experience the Library's digital collections in an engaging way; second, it enables cultural heritage practitioners to ask new research questions; and third, it allows computer scientists to better understand how people are using the systems they build."
Library of Congress Labs established the Innovator in Residence program to leverage the expertise of outside experts to help spur technical creativity through short-term, high-impact projects. Data artist and educator Jer Thorp served as the first Innovator in Residence, where he produced the podcast "Artist in the Archive" and the "Serendipity Engine" project, a collection of proof of concept applications that upend traditional paradigms of search, supporting generally curious users to engage with large cultural heritage collections without specific research questions in mind. All of Thorp's works are available on the LC Labs website.
The LC Labs team enables the Library's Digital Strategy to support digital transformation at the Library of Congress. Through experiments, fellowships, and collaborations, the Labs team explores emerging styles of research and ways to maximize the use of Library content in the 21st Century. For more on the Innovator in Residence program, including the call for proposals for 2021, visit labs.loc.gov/people/innovator-in-residence-program.
The Library of Congress is the world's largest library, offering access to the creative record of the United States — and extensive materials from around the world — both on-site and online. It is the main research arm of the U.S. Congress and the home of the U.S. Copyright Office. Explore collections, reference services and other programs and plan a visit at loc.gov, access the official site for U.S. federal legislative information at congress.gov and register creative works of authorship at copyright.gov.
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Wow! It's been an interesting year, and with no intentions of ending on a boring note! As of this writing, it is being reported that the House and Senate have come to an agreement on the final tax, and the bill is expected to be approved and signed into law before year-end. This will be the most significant tax reform since 1986, before I even started my career, and impacts taxpayers at every level.
The promise of a simplified tax code has resulted in quite the opposite happening, at least in my practice. With that in mind, I will be focusing on things you can do for the 2017 tax year before the year ends, and then moving on to what to plan for in 2018 and forward.
· The tax bracket changes. Originally, there were to be four, down from seven. But the new bill preserved the seven brackets, and reduced the percentage of tax and earned income spread. How this will affect you is a big TBD, as it is any year, really. However, mostly my higher-income earner clients will see the most bang for their tax bucks.
· Elimination of certain itemized deductions. Only medical expenses (once exceeding over 7.5% of income), state income and property taxes (with a limit of $10,000 combined deductible), mortgage interest (limited to loans less than $750,000) and charitable deductions have survived. Unreimbursed business expenses (not to be confused with those who deduct self-employment business expenses) have been eliminated as deductions. This specifically impacts my flight crew and other clients with significant unreimbursed business expenses in a BIG (and BAD) way. Also, included in this eliminated deduction are fees paid to me and your fee-based investment advisor.
· Elimination of the personal exemption. Currently, most of us can further reduce our income by personal exemptions. Depending on your income bracket, every person listed on your return reduces your income by $4,050. A family of four reduces their income by $16,200. This extra deduction is eliminated after 2017.
· Lower tax burden on pass-through businesses. Many of my clients are self-employed, either as sole proprietorships, LLCs or S-Corps. While the words "lower tax burden" are appealing, the reality is that most small business will not qualify for the special tax treatment. If you are in a personal service industry, such as an attorney, engineer, doctor, accountant, consultant or "other personal service provider", the special tax treatment will not apply to you. We will be waiting to see the final list of excluded service industries, but in the meantime, for most of you, it will be business as usual. In addition, the IRS will be implementing measures that prevent abusive practices for those attempting to qualify for the special tax treatments. READ: UPTICK IN AUDITS.
· Elimination of alimony as a deduction, and as income. The new bill will remove the deduction for alimony paid by the payor, and the amount as income by the payee.
· Elimination of moving expenses. There will no longer be a deduction for these expenses.
· Alternative Minimum Tax. A very complicated and annoying tax was slated to be eliminated. But sadly, it will remain. This tax, known as AMT, reduces your deductions so that you pay a minimum amount of income tax on your income. It normally effects taxpayers with moderate to high income with a disproportionate amount of itemized deductions, as well as other factors.
· Education incentives preserved. This includes the tax credits for education.
· Capital gains exclusion on primary residence preserved. Live in your home for two of five years, make less than $250,000 single/$500,000 married filing joint, and you can exclude those capital gains from your income.
· Defer income. If you are expecting a large bonus or commission check, try to have it paid out in 2018. With the new tax rates, you may save a few dollars.
· Offset capital gains with any losses you (or your investment advisor) can find.
· Moving for your job? Before year-end would be the time to do it. If you are moving over 50 miles away to start work for a new employer, try to make that happen before the year ends so you can deduct specific moving expenses in 2017.
· Prepayment of your Q4 estimated state taxes. If you are set up for estimated payments, and you itemize, pay them before December 31st.
· Unreimbursed business expenses. If you are needing that computer for work, and your employer isn't reimbursing you, do it this year instead of waiting for next. Again, this is helpful if you itemize your deductions and can deduct your unreimbursed business expenses (subject to a 2% floor of your income).
· Prepay your mortgage interest for January in December.
· As always, charitable giving always helps.
LET'S TALK ALTERNATIVE MINIMUM TAX (AMT) FOR A MINUTE. The prepayment of your state and real estate taxes may seem like a great tax saving strategy for 2017, but remember, one of the big triggers of AMT is this very deduction. A good way to figure out if this is for you is to look at your 2016 tax return. Is your income for 2017 similar to 2016, or higher (line 37)? Did you itemize (line 40)? Did you pay AMT (line 45)? If you can answer yes to any of these questions, the deduction for your state and real estate taxes may be limited. Therefore, prepaying these taxes may be irrelevant.
As you know, tax season is always chaotic for us at Taxlink. It's the nature of the business, and we are familiar with the pressure and working in the shadow of the deadline. This year will be no different. Our first priority is to get your 2017 tax return filed by that deadline. We asked that you provide us with your tax documents as soon as possible. DO NOT DELAY!
My goal is to provide you with a written summary of tax guidance for the coming year along with your completed 2017 tax return. I ask that we hold off any specific tax planning until after tax season, where I can open up my schedule and meet with you personally to discuss how these changes will affect you.


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IACHR and Its Special Rapporteurship for Freedom of Expression Condemn the Murder of Community Journalist and Indigenous Leader Pablo Isabel Hernández Rivera in Honduras, Call on the State to Diligently Investigate It
inter-American standards
Inter-American Court
Washington, D.C. – The Inter-American Commission on Human Rights (IACHR) and its Special Rapporteurship for Freedom of Expression condemn the murder of Lenca indigenous leader and community journalist Pablo Isabel Hernández Rivera in Honduras and urge the State to investigate this crime in a timely, diligent manner. Both institutions ask the State to establish—in keeping with inter-American standards—whether Hernández Rivera's activities as a human rights defender and a journalist may have been a motive for his murder.
According to publicly available reports, unknown attackers shot Hernández Rivera on January 9, 2022, while he was on his way to church in the municipality of San Marcos de Caiquín, in the Lempira department. The journalist died instantly. Hernández Rivera was the director of the community radio station Radio Tenán 94.1 FM, "The Lenca indigenous voice." He was well-known in his community for his critical reporting on matters of local interest. Radio Tenán 94.1 FM also broadcast the program "Voces contra el olvido" (Voices to Not Forget), produced by the Committee of Relatives of Individuals Who Went Missing While in Detention in Honduras (COFADEH, by its Spanish acronym).
As well as being a community journalist, Hernández Rivera stood out as an indigenous leader and a member of the Lempira Network of Human Rights Defenders (founded by the COFADEH), as a leader of the traditional government of the Lenca people, as president of the Indigenous Cultural Association, as secretary of the local indigenous council of Tierra Colorada, and as chairperson of the network of agroecology experts of the Cacique Lempira Señor de Las Montañas Biosphere Reserve.
The IACHR and its Special Rapporteurship know that Hernández Rivera had reported death threats in recent years. In December 2020, he had also been the target of stigmatizing comments. Radio Tenán had also been threatened with a shutdown and, in February 2021, had been sabotaged by unknown attackers who cut off wires and caused further damage to its infrastructure.
The IACHR and its Special Rapporteurship stress that murders of journalists entail not only a violation of the right to life, but also the most extreme form of censorship. Further, impunity leads to self-censorship by the media themselves. Principle 9 of the IACHR's Declaration of Principles on Freedom of Expression states: "[T]he murder, kidnapping, intimidation of and/or threats to social communicators, as well as the material destruction of communications media violate the fundamental rights of individuals and strongly restrict freedom of expression. It is the duty of the State to prevent and investigate such occurrences, to punish their perpetrators and to ensure that victims receive due compensation."
The IACHR and its Special Rapporteurship for Freedom of Expression also note the impact of this crime on the exercise of community journalism and on the defense of the human rights of indigenous peoples in Honduras. In a recent decision, the Inter-American Court said that community radio stations enable "indigenous peoples to engage more fully in public dialogue" and that they are "essential tools to ensure constant preservation, broadcasting, and development." For indigenous peoples, the loss of a leader or a defender might affect a given community's effective involvement in matters affecting its rights, inclusion, and self-determination and its free development within a multicultural and democratic State.
The IACHR and its Special Rapporteurship urge the State of Honduras to investigate these events on its own initiative (ex officio) and to try and punish both their perpetrators and their masterminds. In particular, the Commission and its Special Rapporteurship urge the State to conduct a thorough, serious, and impartial investigation that focuses on Hernández Rivera's role as a community journalist and as an indigenous leader as a potential motive for his murder. Similarly, the State must seek to adopt a differentiated ethnic–racial approach when investigating, trying, and punishing these crimes and when providing reparations for the families of all victims, as well as providing guarantees of non-recurrence.
Finally, the IACHR and its Special Rapporteurship stress the important work done by rights defenders and journalists within democratic societies, and the fact that these individuals can only do their work freely when they are not being subjected to physical or emotional attacks, threats, or any other form of harassment. Both institutions therefore ask the State to strengthen mechanisms to protect community journalists and social and indigenous leaders, as well as to take all necessary measures to protect the right to life, the integrity, and the safety of all human rights defenders and journalists in Honduras.
The Special Rapporteurship for Freedom of Expression is an office created by the IACHR to promote the defense of the right to freedom of thought and expression in the Americas, considering the fundamental role that right plays in the consolidation and development of any democratic system.


All perfumes delivered OUTSIDE of BANGKOK are delivered by post and usually take 2 days to arrive. All flowers are delivered by hand. Perfumes delivered INSIDE Bangkok can be hand delivered together with flowers if you wish.
Bangkok, the capital of Thailand, is appreciated for its art and culture prosperity lashed with its modernity's embrace.
The Phuket fragrance attracts attention with its fresh summery and fun.
Pattaya, the sleepless city that light is never dimmed after the sunset but shining spicy and rich merry on stage performance at its savor.
The queen of Siam white flowers. A unique scent so familiar as well. Opening with fresh Mok scent mixing with grapefruit to reinforce a little more refreshing.
Bright scents of Plumeria mentioned mix with ancient siam powder. The soft scent helps make the mind calm and relaxation.
Smell the fragrance of the queen of twilight flower, Vallaris Glabra. The special is a smell Mixed with the aromatic scents of pandan and melon.
The aroma of fresh flowers are sacred siam lily. In the Thai ancient belief this flower can be dispel the bad things away.
The scents of the highly valuable flower of China. Feels the Beautiful and aromatic agitated Coordination by opening scents of blueberries add luscious style. And fix lasting odorable with sandalwood incense.
Opening with a fresh citrus aroma, soft green tones in a typical men's fragrance.


It's so freakin' easy to play it small. And no wonder! From the time we're children, we're encouraged to let the guy win so we don't make him feel badly, to minimize our beauty so our friends won't get jealous, to tone down our genius so others won't feel threatened, to dim our light so no one feels dark in our shadow.
My seven-year-old daughter thinks she's brilliant, innovative, artistic, gorgeous, popular, and wildly lovable. And all of those things are true. At this age, she gets lots of support for being confident. People agree with her when she tells them how awesome she is. But the sad truth is that sometime in the next few years, no matter what I do to try to counterbalance the pressures, she'll be subjected to from all sides; my superstar child will start dialing it down. She'll shade her sparkle. She'll get socialized to fade.
What nobody tells you when you're twelve, learning how to be humble and unpretentious, is that we're giving up one of our greatest gifts when we agree to dim our light for the sake of being accepted into the world of unremarkable people. I'm not suggesting you can't be simultaneously humble and sparkly—just look at Jesus! But when we step away from our greatness in order to fit in, we dig our own graves, especially when it comes to our professional lives.
I've learned the hard way how to navigate the loneliness of being a bright, shiny light. But the older I get, the more fearless I am about stepping into my own greatness and embracing my light.
Others have reinforced that lately. Nia founder Debbie Rosas encouraged us to all step into our brilliance as we danced at the Nia White Belt Intensive. Mama Gena, in her School of Womanly Arts, encourages us to brag. In both programs, I got to practice—in tandem with hundreds of other women—stepping into my own greatness and being held in loving arms rather than being rejected. It felt liberating, like unhooking that too-tight bra and flinging it to the high heavens. When you step into your greatness, you finally feel the lightness of flight, rather than the burden of the weight of diminishing your brilliance.
Within your vulnerability lies your strength. Stepping into your greatness doesn't mean tooting your own horn. Sometimes, your greatest strength lies in your flaws, frailties, and foibles.
It's okay to brag. Yes, your vulnerabilities can be your strengths, but it's also okay to shout your triumphs from the rooftops. Imagine if we all gave ourselves permission to say, "I rocked it today!" What if we started every conversation by asking, "What's awesome in your life?" Wouldn't life be grand?
Or do you dim your light so nobody will think you shine too brightly? Do you frown upon confident people or label them arrogant? Have you figured out how to step into your greatness without cutting yourself off from the brilliance of Divine light? Share your stories here!


text:
All Press Releases for February 26, 2009
Schillings to Deliver Address at Legal Week Trust and Estates Litigation Forum
Schillings partner Rod Christie-Miller is to deliver the closing keynote address at this year's Trust & Estates Litigation Forum
LONDON, ENGLAND, February 26, 2009 /24-7PressRelease/ -- Schillings, one of the UK's top law firms dedicated to protecting the reputations of international corporations, brands and celebrities, will be delivering the closing keynote address at this year's Trust & Estates Litigation Forum.
Rod Christie-Miller, a partner at Schillings, will deliver the closing speech at the Legal Week-sponsored conference, which will discuss and offer advice on managing disputes amid market turbulence to a target audience of lawyers, banks and other financial companies.
With the world's financial markets having been in the grip of a debilitating crisis since mid-2008, this has inevitably affected the work of trust and estate litigators. The 2009 Trust and Estates Litigation conference programme will examine the impact of this turmoil along with some of the key issues surrounding the current contentious trust markets.
Rod Christie-Miller's closing address will highlight how the press will report on commercial litigation in the next year and what can be done about it. The press have always been interested in reporting on publicly available Court documents and public testimony as an easy and quick news source and recent commercial and legal developments mean that is going to be increasingly prevalent. Rod will look at the reasons behind this trend, and also outline how the law can be used to counteract that threat.
Rod Christie-Miller is a litigator and leading expert in using the law of defamation, privacy and breach of confidence to protect clients who find themselves in the media spotlight. He specialises in reputation management for companies and their senior executives, public figures, overseas investors, high-net worth individuals and entrepreneurs particularly from the UK and the former Soviet states.
The Legal Week Trust & Estates Forum will take place from the 26th - 28th February at the Four Seasons Resort Provence at Terre Blanche, France, in association with The American Lawyer and principally sponsored by Legal Week and RBC Wealth Management, with Blackberry, Appleby and Carey Olsen also offering their sponsorship to the event.
For further information about the event please contact Steve Hands on 020 7316 9602 or steve.hands@incisivemedia.com
About Schillings:
Schillings is one of Britain's top law firms dedicated to safeguarding the reputations of international corporations, brands, celebrities and high-profile business people. The firm's track-record in defamation, privacy and copyright cases, as well as commercial dispute resolution is second to none.
Defamation privacy and copyright are at the heart of the firm's work, prompting The Independent newspaper to call Schillings a "spectacularly efficient media law firm."
Schillings clients include Lord Browne of Madingley, Las Vegas Sands Casino owner Sheldon Adelson, supermodel Naomi Campbell, actress Nicole Kidman, seven times Tour de France winner Lance Armstrong, Harry Potter author JK Rowling as well as corporations such as GlaxoSmithKline, Kaupthing bank, steel maker Arcelor Mittal, the Harrods Group and the London Stock Exchange.
Source: Schillings
Website: http://www.schillings.co.uk/
Christopher Mills
Voice: +44 (0)20 7034 9132


text:
Code for America: Inspiring a new generation of civic coders
November 16, 2010 By Alex Howard
What will the new Code for America Fellows be doing, now that the inaugural class has been chosen? Code for America's CTO, Dan Melton, offered more insight into the forthcoming projects at the International Open Government Data Conference (IOGDC) today in Washington, D.C., where he talked about school ID cards in Boston, civic leader networks in Philadelphia and Seattle, and CivicCommons in the District of Columbia.
Audio of Melton's talk is available on uStream. Melton and hundreds of attendees will be on the Code for America webinar today at 4 PM EST.
His presentation from IOGDC on "CRUD-ing the government," which I was unable to record or attend due to my involvement in a parallel panel, is embedded below:
Citizen 2.0, Gov 2.0, localgov, open government, open sourceCivic Commons, Code for America, gov 2.0, IOGDC, open government
Think Different About Hacking? | Gov 2.0: The Power of Platforms
[…] There's also more to "hacking" than lawbreaking. Around the globe, there's now a genuine movement of civic hacking afoot, which adds to the etymology of hacking "efforts that put technology, and particularly Internet technology, to work solving the problems of civic life," as Nick Judd writes at techPresident. "Civic hacktivists" (also known as favorably called "civic developers) now gather together around the globe. Code for America is inspiring a new generation of civic coders. […]
Reply	 August 3, 2011 at 9:37 pm
← What's the value proposition for open government data?
POPVOX tries to bring the voice of the people into Congress →


text:
Dominic West on the bond between Valjean and Javert in 'Les Miserables'
By Greg Braxton / Los Angeles Times
Since the original publication of Victor Hugo's novel "Les Miserables" more than 150 years ago, the brutal conflict between the convict-turned-savior Jean Valjean and ruthless pursuer Inspector Javert has been dramatized countless times on stage, screen and even radio.
Although most of the versions have been dramatic, the most dominant and popular adaptation of the 1862 novel is musical. The Tony Award-winning "Les Miserables," launched in Paris in 1980, has been featured on stages around the globe, and its colorful characters, luscious ballads and rousing anthems have been embraced by millions of theatergoers.
Dominic West is not among them.
The actor who came to prominence in the landmark HBO series "The Wire" and is starring in Showtime's "The Affair" has never seen "Les Miserables" on stage. And he didn't make it all the way through the 2012 film version starring Hugh Jackman and Russell Crowe.
Still, he understood how immensely popular the musical is. Which is one reason he had doubts about taking on the role when he was approached about playing Jean Valjean in a new dramatic six-hour adaptation of "Les Miserables."
"I thought, 'What's the point?'" West said as he sat in the front courtyard of a boutique hotel in Santa Monica recently. "They've made a very successful film, and the stage musical is so successful. Then I read the script, and I realized there was a lot more to it. In living memory there's been no six-hour version, no long-form version of the novel. The story you're familiar with and the characters you're familiar with are seen in greater depth."
The miniseries, which debuted Sunday 14 on PBS' "Masterpiece," also stars David Oyelowo ("Selma") as Javert, Lily Collins ("Rules Don't Apply") as the doomed seamstress Fantine and recent Oscar winner Olivia Colman ("The Favourite") as the abusive innkeeper Lady Thenardier. Andrew Davies, who has written adaptations of everything from "Pride and Prejudice" and "Bleak House" to "House of Cards" and "Bridget Jones's Diary," adapted Hugo's novel for the project, which was co-produced by "Masterpiece" with BBC Studios.
The bleakness and brutality of Hugo's vision is vividly depicted, alerting viewers immediately that there will be no catchy songs or light moments in this "Les Miserables." "Masterpiece" executive producer Rebecca Eaton said there are compelling differences that should appeal to fans of the musical and devotees of Hugo's work.
"The musical is great, the songs are great, but sometimes it covers up the story," Eaton said by phone. "What we've done is the narrative, with all its intricacies and subtleties that you just don't get in the musical. We're going much deeper. I love how Andrew humanizes and animates these 19th century tomes. He really went for the highs and the lows and is making a political statement about poverty and class."
The depiction of the virginal Fantine's fall into degradation and prostitution, for example, is explored in chilling and horrifying detail. One highlight of the musical is "Master of the House," a comic ode to the crooked operation of the inn run by the Thenardiers; in the "Masterpiece" version, the couple are much more menacing and manipulative.
And viewers who remember West as detective Jimmy McNulty from "The Wire" or are used to seeing him in various states of undress and in steamy sex scenes in "The Affair" may be startled when he is introduced as Prisoner 24601. He is almost unrecognizable, shorn of almost all his hair ("They cut my hair off with a knife and fork") and wearing a lengthy and unkempt beard.
But it's his performance, along with Oyelowo's, that is at the center of this "Les Miserables," and Eaton maintained that viewers will be captivated by how the actors play out the life-and-death battle between Valjean and Javert: "To watch these two is just mesmerizing, My weakness is actors, and when I'm in the presence of great actors, it's just wonderful."
Among the most prominent film adaptations was a 1935 Oscar-nominated film starring Frederic March, a 1998 film starring Liam Neeson and Geoffrey Rush, and a 2000 French miniseries starring Gerard Depardieu and John Malkovich.
West became a believer in this latest version after reading Davies' adaptation and Hugo's novel.
"Reading the book was the most pleasurable reading experience I've ever had," he said. "I think it's the best book ever written. It's even greater than Tolstoy. Valjean is the greatest hero in literature. His story of redemption and the battle he has against his adversaries and against himself make him such a compelling hero."
As Valjean, West had to connect with both his brutal side and his tenderness: "He's been imprisoned for 19 years for stealing a loaf of bread to feed his starving nieces and nephews," he said. "He knew when he went to prison that they would all die in starvation."
He added, "What's central to the book is Javert's view of the criminal, which is they are born and cannot be redeemed, and Hugo's more enlightened view, that you're a product of the way people treat you. If you're brutalized for 19 years, you will be a brute. His evolution from violent brute to pillar of the community and then romantic hero is what's so extraordinary about his character arc. Behind this beast is this great compassionate soul."
Then there's the core of "Les Miserables" — the clash between Valjean and Javert.
"There's an almost erotic bond between Valjean and Javert," West said. "Javert is nuts about him. We kind of hint at it. In these things, you always look for the strongest impulse, and that's always sex and love."
However, there was not much love between West and Oyelowo during the shoot.
"I kept trying to get to know David; I kept asking him out to dinner, and he was very aloof," West said with a laugh. "I thought, 'Boy, is he unfriendly! He's a bit snooty.' And then at the end, we finally went out — it was his birthday — and we had this great night. I said, 'Wow, we should have done this months ago,' and he said, 'No, no, I was deliberately avoiding you.' It was very clever. You do have a rapport with someone you hang out with on a set, and he didn't want to have that. He was bloody right."
He laughed again. "He has everything I lack. He has immense discipline, whereas I'm incapable of not wanting someone to be my friend. He's perfectly able for the benefit of the work to keep his distance. I admire him hugely as a person and as an actor."
Both he and Oyelowo are executive producers of "Les Miserables." "I had never done it before," West said. "David was good at it. He'd watch stuff and come out with useful notes the next day. I had a lot of opinions about the production until we got into the shoot. Then the only notes I had was, 'Could you hold on me a little longer? I think you're missing a bit of magic.'" He burst into a loud laugh. "Of course they ignored me."
West credits his role in "The Affair" with being a crucial tool in helping him prepare for "Les Miserables." The Showtime drama, which explores the impact of an extramarital affair from different perspectives, is filming its fifth and final season.
"There was never a light moment on 'The Affair,'" he said. "It was always emotionally expensive stuff. Lots of grief and emotion. It taught me a lot. I don't think I could have done Valjean without being on that show."
Even then, it took time for West to understand Valjean. "What I found so difficult to understand is why he surrenders himself to Javert. Why does he feel he's a bad guy when all he did was steal a loaf of bread? That took me a very long time, to realize what sort of psychology Hugo was anatomizing there," West said. "He's been so brutalized, told that he's an animal for 20 years. He believes he's not worthy of love, he believes he's not worthy of living in normal society, he believes the only thing he deserves is the brutal life of the prison."
As happy as he is with "Les Miserables," West is also coming to grips with wrapping up "The Affair." which also stars Maura Tierney and, until last season's plot twist, Ruth Wilson. "Five years is a long time for television, and I'm ready to move on, for sure."
Although he is looking forward to new projects, he is also constantly reminded of his past _ particularly "The Wire" which has only gained in reputation since its original five-season run, which started in 2002. The multilayered series about the narcotics scene in Baltimore is regarded as one of the most significant and compelling dramas in recent TV history.
"It's really extraordinary how it's grown in stature, and I feel very lucky to have been involved," West said.
"People always come up to me and say they've just watched it. If it came out now, I think it would have been lost in the sheer volume of great projects. But in some way, it can be said it catalyzed this golden age of television and to have raised the bar. For me, it's been the gift that keeps on giving."


text:
Just Strategy
Organizing and training for the public good.
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Are you a part of the Community College Community?
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The kitten who is the subject of this article is a good example of a pet whose breeder meant well and didn't see any immediate damage to the animal, yet the kitten became acutely ill on the raw chicken-only diet.
As in our Raw Prey component products Wild canines and felines eat nearly all the parts of their prey, including small bones, internal organs, blood, brain, eyes, tongue and other tasty treats. Many of these parts of prey animals provide important nutrients for dogs and cats. This is how carnivores in the wild nutritionally balance their diets.


Daniel Anglemyer is the 29th ranked of 75 active Michigan Pro Lightweights.
Daniel Anglemyer is the 162nd ranked of 387 active US Midwest Pro Lightweights.
Daniel Anglemyer is the 642nd ranked of 1472 active United States Pro Lightweights.


The WProgressBar can be used to indicate the progress of a certain operation. The text displayed in the progress bar can be customized by specializing text().
To use the progress bar widget, you need to give it a range (either by setRange() or by using setMinimum() and setMaximum()), and update the progress using setValue().
// Initially, only the start button is enabled.
// setup an interval timer which generates a timeout() signal every second.


Communication is an art. Rendering technical and scientific information in a readable form takes effort and skill. But it's not a mystery, and it's not beyond your reach.
Our Professional and Technical Communication certificate will teach you to take technical information and make it clear to those who need to understand and use it. This 12-credit program will teach you the fundamentals of desktop publishing and present methods for technical communications in a wide range of disciplines.
Over the course of these four classes, you'll work with up-to-date digital software and equipment to create computer-generated images and polished electronic publications.
Contact admissions for more information on entrance requirements, financial aid, and taking classes at DSU.


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Tag: cg
Anime Film Games
Kingsglaive: Final Fantasy XV
Kingsglaive: Final Fantasy XV isn't a game, but rather a CG-animated movie that acts as an intro to the world that will be depicted in the upcoming Final Fantasy XV game. My buddy James Mielke just reviewed the film for Rolling Stone (as part of its Glixel initiative, which will culminate in a proper game coverage offshoot site sometime this fall), and as you'll read, he didn't much care for it.
Tags Animation, cg, final fantasy xv, glixel, james mielke, kingsglaive: final fantasy xv
Asterix: The Land of the Gods
As far as I know, this is the first Asterix animated film done in CG, and they did a really great job with it. The animation is definitely on par with what you expect to see from an American CG movie these days, and I thought it was a great adaptation of the original book. Really funny stuff for me, although it might help if you're already very familiar with the series (I grew up reading those books countless times). Really hope they keep making more CG movies like this.
Tags Animation, asterix, asterix: the land of the gods, cg, Movies
Walt Disney Animation Studios Short Films Collection
This is one of the best things I've seen from Disney in forever. Such a fantastic collection of shorts, and it just made me realize how much I wish we got more things like this – not movies, not TV shows, but just shorts that allow for interesting bursts of creativity. Also, it makes me long for the days of 2D animation. Of all the shorts included here, the two weakest are the Tangled and Frozen ones, and the CG-animated shorts that do work the best are the ones that are made to look like traditional animation (like the absolutely fantastic "Paperman," pictured above). It's also a reminder that behind the giant conglomerate that is now Disney, there's still an amazing tradition of animation that hasn't completely disappeared. Can't recommend this enough.
Tags 2d animation, Animation, cg, Movies, paperman, shorts, walt disney, walt disney animation studios short films collection
I should start by saying that as a kid, Captain Harlock – or Albator, as I knew him in French – was my absolute favorite series. I loved that show so much, and my obsession with LEGO blocks was to constantly be building massive Arcadia-style ships, one after the other. So I was of course excited to see a CG animated version of it, and I must say, this film is stunning to look at. They really did an amazing job with the animation, and found the right balance between realism and the original look of the world and characters. In terms of the story, I honestly can't remember if it's similar to the series I watched as a kid (which would have been the one that aired in the early eighties), but it was fine, if not particularly special. I won't lie, most of my enjoyment from watching this was for the visuals, and to see all of these characters in action, and the giant ship battles – although I wouldn't have minded having a few more of those. I don't know if it was a financial success, but I sure hope they continue to make more.
Tags albator, Animation, Anime, captain harlock, cg, Lego, Movies


I honestly feel like nearly any wedding, especially any outdoor event, could add some moss to the decor and it would fit right in.
There is just something about moss that I'm drawn to. It looks natural and peaceful, but can also be dressed up in a wonderful way. These moss covered table numbers are a great way to incorporate a little green to your table scape, and can be customized to suit your needs.
Step 1: Design the numbers. For this, you'll want a font that is relatively thick so there's a surface to cover. I chose DIN Condensed and just used Word to adjust the size. I printed out my number onto plain printer paper and cut it out so I could use it as a tracing shape.
I went bare bones on my materials, so I used cardboard as my shape. I traced my number 2 onto cardboard scrap and then cut it out with an Exacto knife. If you'd rather save time instead of money, you can always buy pre-cut wooden numbers at a local craft store.
Step 2: Paint the numbers. You want to paint the number you just made green so the cardboard underneath blends in with the moss color. If there were any gaps I didn't want it to obviously scream cardboard brown. I used acrylic paint and had to add a little white, yellow and brown to my green paint to get the correct—or close enough—hue.
Step 3: Add the moss to the numbers. I used some reindeer moss that was nice and soft and came in large sections. I tore up the moss into smaller pieces so it was easier to manage. I used Modge Podge as an adhesive, and liberally applied the glue to the front of my number. After the front was covered in moss, I left it to dry overnight. To help keep the moss down and sticking in the glue, I put a book on top of the moss and number.
Step 4: Decide on how to display them. Depending on how you're going to use your number, you can use different finishing methods. I decided to only put moss on one side, which made things pretty easy. If guests will be able to see both sides of the shape, you'll obviously want to glue moss on both faces of your table numbers.
I decided to put my numbers into a frame shape, to give it some structure. I just took the glass out of a gold frame and attached my number right to white cardstock placed inside the frame. Since I mounted my number onto a frame with some depth, you couldn't tell it was made of cardboard. It's a nice way to skimp on materials since it won't matter anyway. To continue with the organic look, I stacked some old books and added a few votive candles.
You could also just lean your table numbers up against some other props and flowers, or include them into an arrangement.
Regardless of what you decide, these moss table numbers look great and are super simple.
This is great! I love this idea.
I love how you framed the table number! I didn't realize how simple it would be to great such a great look.


text:
package cn.enilu.flash.service.system;

import cn.enilu.flash.bean.entity.system.Dict;
import cn.enilu.flash.cache.DictCache;
import cn.enilu.flash.dao.system.DictRepository;
import cn.enilu.flash.service.BaseService;
import cn.enilu.flash.utils.factory.MutiStrFactory;
import org.slf4j.Logger;
import org.slf4j.LoggerFactory;
import org.springframework.beans.factory.annotation.Autowired;
import org.springframework.stereotype.Service;

import javax.annotation.Resource;
import java.util.List;
import java.util.Map;

/**
 * 字典服务
 *
 * @author fengshuonan
 * @date 2017-04-27 17:00
 */
@Service
public class DictService extends BaseService<Dict, Long, DictRepository> {
    private Logger logger = LoggerFactory.getLogger(DictService.class);
    @Resource
    DictRepository dictRepository;
    @Autowired
    private DictCache dictCache;

    public void addDict(String dictName, String dictValues) {
        //判断有没有该字典
        List<Dict> dicts = dictRepository.findByNameAndPid(dictName, 0L);
        if (dicts != null && dicts.size() > 0) {
            return;
        }

        //解析dictValues
        List<Map<String, String>> items = MutiStrFactory.parseKeyValue(dictValues);

        //添加字典
        Dict dict = new Dict();
        dict.setName(dictName);
        dict.setNum("0");
        dict.setPid(0L);
        this.dictRepository.save(dict);

        //添加字典条目
        for (Map<String, String> item : items) {
            String num = item.get(MutiStrFactory.MUTI_STR_KEY);
            String name = item.get(MutiStrFactory.MUTI_STR_VALUE);
            Dict itemDict = new Dict();
            itemDict.setPid(dict.getId());
            itemDict.setName(name);
            try {
                itemDict.setNum(num);
            } catch (NumberFormatException e) {
                logger.error(e.getMessage(), e);
            }
            this.dictRepository.save(itemDict);
        }
        dictCache.cache();
    }

    public void editDict(Long dictId, String dictName, String dicts) {
        //删除之前的字典
        this.delteDict(dictId);

        //重新添加新的字典
        this.addDict(dictName, dicts);

        dictCache.cache();
    }

    public void delteDict(Long dictId) {
        //删除这个字典的子词典
        List<Dict> subList = dictRepository.findByPid(dictId);
        dictRepository.deleteAll(subList);
        //删除这个词典
        dictRepository.deleteById(dictId);

        dictCache.cache();
    }

    @Override
    public Dict get(Long id) {
        return  dictRepository.getOne(id);
    }

    public List<Dict> findByNameLike(String name) {
        return dictRepository.findByNameLike(name);
    }

    public List<Dict> findByPid(Long pid) {
        return dictRepository.findByPid(pid);
    }
}

redpajama_set_name: RedPajamaGithub