Isolated showers before 7pm, then a slight chance of drizzle or light rain after 7pm. Patchy fog after 7pm. Otherwise, mostly cloudy, with a low around 56. South wind 8 to 10 mph. Chance of precipitation is 20%.
Areas of drizzle before 1pm, then a chance of showers and thunderstorms after 1pm. Areas of fog before 1pm. Otherwise, cloudy, with a high near 72. South wind 10 to 15 mph. Chance of precipitation is 40%.
Showers and thunderstorms, mainly after 7pm. Some of the storms could produce gusty winds and heavy rain. Low around 61. South wind around 16 mph. Chance of precipitation is 90%. New rainfall amounts between three quarters and one inch possible.
Showers and thunderstorms before 1pm, then showers likely. Some of the storms could produce gusty winds and heavy rain. High near 68. Southeast wind 14 to 18 mph. Chance of precipitation is 80%. New rainfall amounts between a half and three quarters of an inch possible.
Showers likely, mainly before 7pm. Mostly cloudy, with a low around 52. Chance of precipitation is 60%. New precipitation amounts of less than a tenth of an inch possible.


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Archive for December 3rd, 2011
GM Offers to Buy Back Chevy Volts
Posted in Main Blog (All Posts) on December 3rd, 2011 5:45 am by HL
General Motors will buy Chevrolet Volts back from any owner afraid the electric cars will catch fire, CEO Dan Akerson said Thursday. Fires have broken out in Volts after side-impact crash-tests performed by the National Highway Traffic Safety Administration. Around 6,000 Volts are currently on the road. "I think in the interest of General Motors, the industry, the electrification of the car, it's best to get it right now than when you have — instead of 6,000 — 60,000 or 600,000 cars on the road," Akerson said.
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Late Late Night FDL: Ringing of the Bells
From Muppet Studios — Ringing of the Bells.
Grab your popcorn, put your feet up on the coffee table, and try to keep the spitballs off the screen please. This is Late Late Night FireDogLake, where off topic is the topic … so dive in. What's on your mind?
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Preoccupied by Health and Safety
This week on Truthdig Radio in association with KPFK: Robert Scheer condemns the eviction of Occupy L.A.; the protesters police themselves; the NBA lockout ends and so does Herman Cain's campaign, and we get a feminist analysis of Penn State.
December 2, 2011 Jesus and the 99 Percent
December 1, 2011 Celebrating the End of Kids' Wall Street Dreams
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Former Democratic Presidential Candidate George McGovern Hospitalized After Falling, Hitting Head
SIOUX FALLS, S.D. — Former Democratic presidential candidate George McGovern was hospitalized Friday after he fell and hit his head on the pavement outside of…
White House Threatens Veto Of Indefinite Detention Bill
WASHINGTON — Accusing the Senate of "political micromanagement" of national security, the White House Friday stood by its threat to veto a defense bill over…
Ann Beeson: Not Rick Perry's Texas
Because of its sheer size, Texas has the ability to change the direction of the country. Despite the current Tea Party stranglehold and lackluster Democrats, that change is more and more likely to trend progressive.
Rafael Lemaitre: Obama Drug Policy: Reforming the Criminal Justice System
There is no simple, straightforward fix to America's drug problem. Successfully combating this social challenge requires an approach that blends drug treatment, smart law enforcement and alternatives to incarceration.
Santorum Defends Health Insurance Companies
While speaking to a group of high school students in New Hampshire on Friday, Republican presidential candidate Rick Santorum defended insurers for denying coverage or…
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Myths And Falsehoods About Judicial Nominee Caitlin Halligan
With Senate Majority Leader Harry Reid (D-NV) having filed a motion to cut off a filibuster of the nomination of Caitlin Halligan to the U.S. Court of Appeals for the D.C. Circuit, often called the second most important court in the country, Media Matters presents a rebuttal to myths and falsehoods right-wing media have used to attack Halligan.
MYTH: Halligan Is A "Radical Choice" For The Federal Bench
MYTH: Halligan's Legal Record Shows Hostility Toward Gun Rights
MYTH: Halligan Has Revealed "A Decided Slant" On The Issue Of Same-Sex Marriage
MYTH: Halligan Took An Out-Of-The-Mainstream Position On Military Detentions Since 9-11
MYTH: Halligan's Views On Diversity In Education Are Outside The Mainstream
MYTH: Halligan's Testimony That She Will Look At Text And Original Intent To Interpret The Constitution Is "Not Believable"
MYTH: The D.C. Circuit's Case Load Is So Low It Does Not Need Another Judge
MYTH: GOP Senators Can Filibuster Halligan Based On The Standards They Have Set Up
CLAIM: Halligan Is A "Radical Choice." In a March 21 editorial, The Washington Times declared Halligan, as well as two other Obama judicial nominees, to be "radical choices for federal judgeships." [The Washington Times, 3/21/11]
CLAIM: "Halligan's Record Strongly Suggests That She's Hard Left On A Broad Array Of Issues." National Review Online blogger Ed Whelan wrote in a January 31 blog post: "On initial review, Halligan's record strongly suggests that she's hard Left on a broad array of issues." [National Review Online, 1/31/11]
REALITY: Halligan Has Support From Lawyers Across The Political Spectrum
FACT: Twenty-Three People Who Clerked For Justices Rehnquist, Scalia And Other Justices, And Who Served With Halligan, Called Halligan "A Talented And Fair-Minded Colleague." Halligan served as a law clerk for Supreme Court Justice Stephen Breyer during the 1997-98 term. Twenty-three people who served as Supreme Court clerks at the same time as Halligan wrote a letter in support of her nomination to the U.S. Court of Appeals for the D.C. Circuit. Signers included people who had clerked for the conservative then-Chief Justice William Rehnquist as well as Justices Antonin Scalia, Anthony Kennedy, and other justices. They wrote:
Our shared experience left us with an indelible impression of Caitlin's brilliant legal mind, her collegiality and fair-mindedness, and her abiding respect for the rule of law. Even now, almost a decade and a half later, as we have moved on to disparate careers in the government, private sector, and the legal academy, we retain a distinct appreciation of Caitlin's sharp intelligence and her ability to cooperate with others in resolving difficult legal problems.
Throughout the year, Caitlin displayed a keen ability to listen to and accommodate the views of others, all the while simultaneously expressing and justifying her own view of the law. Although the Court during the 1997 Term issued an unusually high proportion of unanimous decisions, Caitlin's demeanor as a law clerk exuded reasonableness and collegiality even in those areas where we law clerks — and the Justices for whom we worked — disagreed.
In sum, we hold Caitlin Halligan in high regard as a talented and fair-minded colleague who was a pleasure to work with in a sophisticated and demanding legal setting. We have no doubt that if she is confirmed by the Senate, her colleagues on the federal bench will soon arrive at a similar conclusion, and we appreciate your attention to her nomination. [Letter from Halligan's Supreme Court co-clerks, 2/28/11, via JudgingTheEnvironment.org]
FACT: Other Lawyers From Across The Political Spectrum, Including Former Bush D.C. Circuit Nominee Miguel Estrada, "Enthusiastically Support" Halligan. In addition to Halligan's colleagues from her time as a Supreme Court clerk, 21 other prominent attorneys from across the political spectrum wrote a letter saying that they "enthusiastically support" Halligan's nomination. Several of the signers worked in the office of the U.S. Solicitor General, including Miguel Estrada, whom President George W. Bush nominated for a seat on the same court as Halligan but withdrew his nomination in the face of opposition from Senate Democrats. The lawyers wrote:
We write in enthusiastic support of the nomination of Caitlin Halligan to be a judge on the United States Court of Appeals for the District of Columbia Circuit. We are lawyers who have worked with Caitlin in various capacities. We believe that Caitlin is an outstanding selection for the D.C. Circuit. She is a first-rate lawyer and advocate. She is well respected and highly regarded as a leader of the profession. Caitlin also has an ideal judicial temperament. She brings reason, insight and judgment to all matters. Even those of us who have been on opposite sides of Caitlin in litigation have been greatly impressed with her ability and character. We have no doubt that she would serve with distinction and fairness. [Letter from 21 attorneys, 3/4/11, via JudgingTheEnvironment.org]
FACT: Law Enforcement Personnel Strongly Support Halligan. Halligan represented law enforcement officials as New York State's solicitor general and currently serves as counsel to the New York County District Attorney, the Manhattan prosecutor's office. She has received the support of police officers and sheriffs, the current New York City police commissioner Raymond Kelly, and New York state prosecutors. The following people or groups have written in support of Halligan:
National District Attorneys Association: Halligan "Would Be An Outstanding Addition" To The D.C. Circuit. [National District Attorney Association letter, 6/2/11, via JudgingTheEnvironment.org]
New York Women In Law Enforcement: Halligan "Exemplifies All The Characteristics Of A Person We Would Want To Serve The People Of This Country In Such A Crucial Judgeship." [New York Women in Law Enforcement letter, 5/31/11, via JudgingTheEnvironment.org]
NYC Police Commissioner Kelly: Halligan "Posesses The Three Qualities Most Important For A Nominee: Intelligence, A Judicial Temperament, And Personal Integrity." [Raymond Kelly letter, 5/26/11, via JudgingTheEnvironment.org]
New York State Sheriffs' Association: "We Have Every Confidence That [Halligan] Will Make An Outstanding Judge." [New York State Sheriffs' Association, Inc. letter, 5/2/11, via JudgingTheEnvironment.org]
New York State Association Of Chiefs Of Police: Halligan "Has Demonstrated An Understanding Of The Need For Strong Law Enforcement To Protect Those In Our Communities Least Able To Protect Themselves." [New York State Association of Chiefs of Police, Inc. letter, 4/27/11, via JudgingTheEnvironment.org]
National Center For Women & Policing: Halligan Is "A Person Of Solid Standing And Integrity" Who Would "Provide Fair And Equal Justice." [National Center for Women & Policing letter, 6/8/11, via JudgingTheEnvironment.org]
District Attorneys Association Of The State Of New York: Halligan "Has Tirelessly Upheld The Ideals Of Strong Law Enforcement." [District Attorneys Association of the State of New York letter, 4/22/11, via JudgingTheEnvironment.org]
Current Manhattan District Attorney: "I Was Impressed" With Halligan's "Fairness And Lack Of Partisanship." [Cyrus Vance letter, 3/4/11, via JudgingTheEnvironment.org]
Former Manhattan District Attorney: Halligan "Brings Solid Law Enforcement Perspective To Her Work, And Upholds The Highest Standards." [Robert Morgenthau letter, 3/23/11, via JudgingTheEnvironment.org]
Director Of Criminal Justice For Former Gov. Pataki: Halligan "Would Be A Fantasic Judge." [Chauncey Parker letter, 2/28/11, via JudgingTheEnvironment.org]
Franklin County, NY, District Attorney: Halligan Has "Unparalleled Legal Reasoning Skills And A Firm Commitment To Our Constitutional Values. [Derek Champagne letter, 2/14/11, via JudgingTheEnvironment.org]
Staten Island District Attorney: Halligan Would Be An "Ideal Appointee" To The D.C. Circuit. [Daniel Donovan letter, 2/25/11, via JudgingTheEnvironment.org]
Onondaga County, NY, District Attorney: "I Do Not Think Any President, Democrat Or Republican, Could Find A More Qualified, A More Honorable Or A Finer Candidate Than Caitlin Halligan." [William Fitzpatrick letter, 2/16/11, via JudgingTheEnvironment.org]
CLAIM: Halligan Has "A Very Troubling Record Of Dismissing The Second Amendment." From a National Review Online post by Gary Marx, executive director of the Judicial Crisis Network, on Halligan's nomination to the U.S. Court of Appeals for the D.C. Circuit:
Since Ed and Carrie's entries were published, it has come to my attention that Halligan has a very troubling record of dismissing the Second Amendment while embracing discredited legal theories favored by trial lawyers.
In 2003, while serving as the solicitor general for the State of New York, Halligan signed the brief in the New York Supreme Court case The People vs. Sturm, Ruger & Co., a lawsuit brought against handgun manufacturers, wholesalers, and retailers.
Luckily, like most courts that have addressed such claims, the court saw through the "public safety" facade and concluded that the nexus between the alleged conduct and the harm was "too tenuous and remote" to hold the industry liable.
Several years later, in City of New York v. Beretta U.S.A. Corp., Halligan filed an amicus brief in support of New York City in a lawsuit in which it made similar public-nuisance claims against handgun manufacturers, wholesalers, and retailers.
Those lawsuits were part of a coordinated, national litigation strategy aimed at destroying the handgun industry. And they were just the latest in a long series of steps taken by trial lawyers to use public nuisance lawsuits to transfer wealth from targeted industries — asbestos, tobacco, lead paint, lead pigment, guns — to themselves. [National Review Online, 3/10/11]
CLAIM: Halligan's "Record Is Particularly Troubling On Second Amendment Rights." From a Washington Times editorial:
Another nominee already through the committee is D.C. Circuit choice Caitlin J. Halligan, whose record is particularly troubling on Second Amendment rights as she signed a brief arguing that gun manufacturers should be held liable in class-action lawsuits for harm inflicted when guns are used illegally. [The Washington Times, 3/21/11]
REALITY: Halligan Has Testified That She Will Uphold Second Amendment Rights
FACT: Halligan Said She "Would Follow" Supreme Court Precedent Finding That The Second Amendment Protects An Individual's Right To Keep And Bear Arms. From the Senate Judiciary Committee's hearing on Halligan's nomination:
SEN. CHUCK GRASSLEY (R-IA): Well, that's pretty clear, so I won't have to follow up with another question I had on that subject.
On the Second Amendment, in 2003 you gave a speech expressing concern about federal legislation to limit the liability of gun manufacturers. You said, quote, "Such an action would likely cut off at the pass any attempt by states to find solutions through the legal system or their own legislatures that might reduce gun crime," end of quote. Many who opposed the Second Amendment rights made similar arguments against – after the Supreme Court decided Heller.
Do you personally agree that the Second Amendment protects individual rights to keep and bear arms?
MS. HALLIGAN: The Supreme Court has been clear about that. Yes, it does protect individual rights to bear arms, Senator.
SEN. GRASSLEY: And would you say that making it a functional right under McDonald was something you agree with as well?
MS. HALLIGAN: That's clearly what the Supreme Court held and I would follow that precedent, Senator. [Senate Judiciary Committee hearing on the nomination of Caitlin Halligan, 2/2/11]
FACT: In The Cases To Which Her Opponents Point, Halligan Was Representing The State Of New York, Not Her Own Personal Views, And Played A Role In Appeals As New York State Solicitor General. Marx cites two cases in which Halligan participated. In both cases, Halligan's name was on appellate briefs filed by the state of New York:
In People v. Sturm, Ruger Co. Inc., Halligan's name appears on a New York state appellate court brief filed by then-New York attorney general Eliot Spitzer on behalf of the people of New York. [People v. Sturm, Ruger Co. Inc., 6/24/03, via FindLaw.com]
In City of New York v. Beretta U.S.A. Corp., Halligan's name appears on a federal appellate court brief filed by then-New York attorney general Andrew Cuomo on behalf of the state of New York. [City of New York v. Beretta U.S.A. Corp., 4/30/08, via Lexis]
FACT: NY Solicitor General "Is Responsible For Preparing And Arguing Civil And Criminal Appeals In Both State And Federal Court." From the New York state attorney general's website:
The Division of Appeals and Opinions operates under the direction of the Solicitor General, who, by statute, is appointed by the Attorney General. The Division is responsible for preparing and arguing civil and criminal appeals in both state and federal courts. The Division determines which cases are to be appealed and determines which legal arguments will be advanced on behalf of the State of New York. The Division also provides advice and counsel to the Attorney General and to Attorneys throughout the Office. [Office of the New York attorney general, accessed 12/1/11]
FACT: Neither Of The Cases At Issue Dealt With The Second Amendment At All.
Sturm, Ruger Case Dealt With New York State's Attempt To Hold Gun Manufacturers Liable For Crimes Committed With Guns Illegally Distributed In New York. In deciding People v. Sturm, Ruger Co. Inc., the New York State Supreme Court, Appellate Division stated: "Plaintiff's complaint, as pertinent here, claims that illegally possessed handguns are a common-law public nuisance because they endanger the health and safety of a significant portion of the population." In its decision siding with the gun manufacturers and against the state of New York, the New York Supreme Court, Appellate Division did not once mention the Second Amendment. [People v. Sturm, Ruger Co. Inc., 6/24/03, via FindLaw.com]
Beretta Case Dealt With A Tenth Amendment Challenge To A Federal Law Restricting Gun Lawsuits Against Gun Manufacturers. In City of New York v. Beretta U.S.A. Corp., the United States Court of Appeals sided with gun manufacturers who sought dismissal of New York City's lawsuit against certain gun manufacturers under the federal Protection of Lawful Commerce in Arms Act. While the court cited the First and Tenth Amendments, it did not mention the Second Amendment. [City of New York v. Beretta U.S.A. Corp., 4/30/08, via Lexis]
CLAIM: As New York State Solicitor General, Halligan Issued An Opinion That "Reveals A Decided Slant In Favor Of A Constitutional Right To Same-Sex Marriage." From a National Review Online blog post by Whelan:
Let's begin our review of D.C. Circuit nominee Caitlin Halligan's record by examining the March 2004 opinion on same-sex marriage that Halligan issued in her capacity as solicitor general of New York.
Halligan's opinion has three parts. First, she construes New York's Domestic Relations Law ("DRL") to require that a marriage performed in New York be between persons of opposite sex. Second, she outlines at length the "serious constitutional concerns" that her reading of the DRL supposedly raises. Third, she advises, based on a single trial-court ruling (which ended up being reversed), that New York law "presumptively requires that parties to [same-sex] unions must be treated as spouses for purposes of New York law." (Oddly, Halligan's own summary of the opinion in her Senate questionnaire response discloses the first part of her advice but not the second or third.)
Halligan's opinion doesn't undertake to resolve definitively the "serious constitutional concerns" that it raises. That said, the opinion in several respects reveals a decided slant in favor of a constitutional right to same-sex marriage. [National Review Online, 1/31/11]
REALITY: Halligan Concluded That, At The Time, New York State Law "Did Not … Authorize Same-Sex Marriage"
FACT: Even Though New York Did "Not Explicitly Prohibit Same-Sex Marriages," Halligan's Opinion Stated That "The Legislature Did Not Intend To Authorize Same-Sex Marriage." From a memo Halligan wrote on the issue of same-sex marriage:
We can provide no certain guidance as to how New York courts will ultimately rule with respect to whether New York law permits or prohibits marriage by same-sex couples. Although the DRL [Domestic Relations Law] does not explicitly prohibit same-sex marriages, it is our view that the Legislature did not intend to authorize same-sex marriage. The exclusion of same-sex couples from eligibility for marriage, however, presents serious constitutional concerns, which we outline below. [New York attorney general's office, 3/3/04]
FACT: Halligan Advised New York State Officials Not To Perform Same-Sex Marriages. Halligan signed her memo a few days after the mayor of the small New York town of New Paltz began marrying same-sex couples. Halligan wrote that New York state officials should not be "issu[ing] marriage licenses to same-sex couple" or "solemniz[ing] the marriages of same-sex couples":
Because the purpose of the marriage licensing process is to "provide[] a definite, well-chartered procedure for entrance into marriage, so that parties following the statutory requirements can have a fair degree of certainty in their marital status," Practice Commentaries to DRL § 13 at 149, we recommend that clerks not issue marriage licenses to same-sex couples, and officiants not solemnize the marriages of same-sex couples, until these issues are adjudicated by the courts. [New York attorney general's office, 3/3/04]
FACT: Halligan Gave Reasons Why Courts Could Either Uphold And Strike Down A Same-Sex Marriage Ban. In her memo, Halligan stated that, unlike other issues, "[w]hether New York's courts would uphold a same-sex marriage prohibition based on an interest in preserving traditional notions of marriage is a closer question." Halligan then reviewed federal court decisions and decisions from various state courts that have come to different conclusions on whether same-sex marriage bans are constitutional. [New York attorney general's office, 3/3/04]
Courts And Other Legal Scholars Have Found Constitutional Bans To Be Constitutionally Problematic. There is nothing odd or suspect about a state official such as Halligan noting that courts might very well strike down a ban on same-sex marriage. At the time, a New York state court had struck down New York's ban on same-sex marriage, a decision that was reversed by New York's highest court after Halligan wrote her opinion. Furthermore, state courts across the nation have ruled that same-sex marriage bans are unconstitutional. In addition, Ted Olson, who served as solicitor general under President George W. Bush, has argued that same-sex marriage bans violate the U.S. Constitution. [Media Matters, 2/1/11]
CLAIM: Halligan Was A Signatory To A Report On Military Detentions That "Embodies … Left-Wing Extremism." From a National Review Online blog post by Whelan:
In March 2004, Caitlin Halligan was a signatory to a 154-page report issued by the Association of the Bar of the City of New York's Committee on Federal Courts, titled "The Indefinite Detention of 'Enemy Combatants': Balancing Due Process and National Security in the Context of the War on Terror." The report embodies the sort of left-wing extremism that the courts have rejected and that the Obama administration has had to retreat from. For example:
The NYC Bar report maintains (p. 110) that the congressional Authorization for Use of Military Force (enacted September 18, 2001) does not authorize indefinite detention of enemy combatants. But Justice O'Connor's June 2004 opinion in Hamdi v. Rumsfeld specifically ruled that the AUMF does authorize indefinite detention of enemy combatants.
The NYC Bar report likewise argues vigorously against the use of military commissions to try alien terrorists for violations of the laws of war (even while grudgingly acknowledging the possible legality of their use). (See pp. 113-152.) Among its arguments for instead using Article III civilian courts:
It seems self-evident that the same [constitutional] protections [afforded ordinary criminals] should presumptively extend to those individuals whom the government has seized and proposes to detain for an extended, and perhaps indefinite, period of time because they are suspected of having engaged in conduct intended to further terrorist aims, thus violating applicable criminal laws."
But there is nothing remotely "self-evident" about the position that alien enemy combatants whose only connection with this country consists of their acts of war against it should enjoy the constitutional rights that American citizens have. That position is instead a highly dubious policy choice — one that even the Obama administration has abandoned.
The NYC Bar report also contains highly tendentious rhetoric that misconceives the rationale of detention policy, such as this passage from its executive summary (ES 4):
Why should the First Amendment right of free speech, or the Fourth Amendment right to be free of unreasonable searches, be any less subordinate to the President's war power than the core due process right to remain free of unilateral executive detention? Pick your favorite constitutional amendment or right: its survival during the war on terror cannot be assumed if the legitimacy of these indefinite detentions is sustained.
All in all, the fact that Halligan would sign her name to the NYC Bar report ought to weigh heavily against her being confirmed to a court that has such an important role in national-security cases. [National Review Online, 2/1/11]
REALITY: Halligan Testified That She Did Not Approve Of The Military Detention Report In Question
FACT: Halligan Testified Under Oath That She Had Not Previously Reviewed The Detainee Report, And She Now Found It "Clearly Incorrect" In Some Parts, And Was "Taken Aback" By Its Tone. During the Senate Judiciary Committee's hearing on Halligan's nomination, Halligan said, "the bottom line is that the report does not represent my work. It does not reflect my views":
SENATOR CHRISTOPHER COONS (D-DE). Thank you. In reviewing the background for this hearing today, I read, in particular, about a report that was issued by the Federal Courts Committee of the New York City Bar.
It was entitled "The Indefinite Detention of Enemy Combatants," and further titled, "Balancing Due Process and National Security in the Context of the War on Terror."
I was a little concerned about this report, in particular, to the extent that it seemed to conclude the United States lacks the authority to detain folks who are considered enemy combatants, and I know you served on that Committee at the time the report was issued.
If you could tell me something about your role in writing this report, whether you affirmed it or agree with it, and then, if possible, something about your view of the impact of terrorism on our communities and the importance of appreciating and respecting that impact, as you have conducted yourself in your recent legal roles.
HALLIGAN: Thank you, Senator. I am really grateful to have the opportunity to address that report.
I first became aware of the existence of that report this summer, when I went to the City Bar Association. In responding to this committee's questionnaire, I wanted to make sure that I had done full diligence, and I knew that I had been a member of the Committee that you referred to.
And so I went through the bar association's files and I discovered this report. I was, frankly, taken aback by it, for a couple of reasons.
First of all, the Supreme Court has clearly held that indefinite detention is authorized by the AUMF statute. And so the notion that the President lacks that authority, I think, is clearly incorrect.
I also was a little bit taken aback by the tone of the report. I think that the issues of indefinite detention and any issues in the national security realm are very serious ones, and I think that approaching those issues as respectfully as possible is the most productive way to proceed.
But the bottom line is that the report does not represent my work. It does not reflect my views. [Senate Judiciary Committee hearing on the nomination of Caitlin Halligan, 2/2/11]
CLAIM: Briefs Filed By Halligan In Supreme Court Cases Dealing With Diversity In Education May Be A Cause For Concern. From a National Review Online blog post by Whelan a day after he had said that Halligan's record suggests she is "hard Left" on a variety of issues:
I've barely found time to glance at them, but given tomorrow's hearing, I'll also call to the attention of readers that D.C. Circuit nominee Caitlin Halligan was the lead counsel on multi-state amicus briefs in the companion cases of Grutter v. Bollinger and Gratz v. Bollinger (both decided in 2003) and in the Seattle and Louisville schools cases (both decided in 2007).
Halligan's joint brief in Grutter and Gratz argued that the racial preferences in the University of Michigan's admissions programs for the college and for the law school did not violate the Equal Protection Clause. (By different majorities, with only Justice O'Connor and Justice Breyer in the majority in both cases, the Court struck down the college program but upheld the law school's.)
Halligan's joint brief in the Seattle and Louisville schools cases argued that the racial-assignment plans at issue did not violate the Equal Protection Clause. (By a 5-4 vote, the Court ruled that they did.) [National Review Online, 2/1/11]
REALITY: Halligan Was Representing A Client In Diversity Cases, Not Presenting Her Own Views
FACT: Halligan Filed The Briefs On Diversity As Solicitor General Of New York In Order To Defend New York State's Freedom To Pursue Policies Regarding Racial Diversity.
Halligan Filed Brief In Grutter And Gratz On Behalf Of The State Of New York And Wrote That The States Filing The Brief Had An Interest In Having The Freedom "To Take Race Or Ethnicity Into Account In College Admissions." From the brief:
The need to take race or ethnicity into account in college admissions, like the mission, goals, and student body of each institution, varies over time and requires periodic re-evaluation. Some public colleges and universities that do not currently consider race may choose to in the future, while others that consider race now may not tomorrow. The Court's decision in these cases will therefore affect the ability of all public higher education institutions to decide how best to achieve the educational benefits of diversity for their students and their citizens. [Amici Curiae brief of 21 states and the Territory of the U.S. Virgin Islands in Grutter v. Bollinger and Gratz v. Bollinger, accessed 12/1/11]
Halligan Filed Brief In Seattle And Louisville Cases On Behalf Of State Of New York And Wrote That The States Were Interested In Having The Court "Continue To Afford A Degree Of Deference … To School Boards' Educational Decisions" To Reduce Racial Isolation. From the brief:
The States and their subdivisions are responsible for the public education of America's school children, and Amici States are firmly committed to the tradition of local control of those schools. Control of public K-12 education at the local level provides parents the opportunity to participate in decisionmaking regarding the education of their children, increases the accountability and responsiveness of school districts to local needs, and leads to greater community support for the schools. It also encourages experimentation and innovation in the schools' operation, leading to higher quality education.
At the same time, to effectively plan and operate their school systems, school boards require stability and predictability in the legal landscape governing their schools. For the past 35 years, school boards that have voluntarily sought to reduce racial isolation in their schools have done so with the understanding that federal courts also recognize the importance of local control of public schools and the value of integrated education. The importance of these values should be reaffirmed in these cases, and the Court should continue to afford a degree of deference, within constitutional limits, to States' and local school boards' educational decisions as to how to advance these goals. [Amici Curiae brief of 17 states, the District of Columbia, and the Commonwealth of Puerto Rico in Parents Involved in Community Schools v. Seattle School District No. 1 and Meredith v. Jefferson County Board of Education, 10/10/06]
FACT: The Supreme Court Ruled That Schools Could Take Race Into Account In Order To Achieve More Diverse Classrooms. In Grutter v. Bollinger, the Supreme Court sided by a 5-4 margin with the argument that Halligan made, stating that "the Equal Protection Clause does not prohibit the Law School's narrowly tailored use of race in admissions decisions to further a compelling interest in obtaining the educational benefits that flow from a diverse student body." In the other cases, the Court ruled by narrow margins that the schools' programs violated the Constitution. [Grutter v. Bollinger, 6/23/03; Gratz v. Bollinger, 6/23/03; Parents Involved in Community Schools v. Seattle School District No. 1, 6/28/07]
FACT: In Two Of The Cases, Halligan's Brief Was Joined By The Republican Attorney General Of Utah. One of the other people who signed the brief filed by Halligan in the Parents Involved in Community Schools and Meredith v. Jefferson County cases was Mark Shurtleff, the Republican attorney general of Utah. [Amici Curiae brief of 17 states, the District of Columbia, and the Commonwealth of Puerto Rico in Parents Involved in Community Schools v. Seattle School District No. 1 and Meredith v. Jefferson County Board of Education, 10/10/06]
FACT: In The Other Two Cases, A Bipartisan Group Of 29 Retired Military Officers And Other National Security Experts Filed Briefs On The Same Side As Halligan. In Grutter and Gratz, a bipartisan group of 29 retired military officers and other national security experts filed a brief on the same side as Halligan. The group included former Sen. William Cohen (R-ME), who served as Secretary of Defense under President Bill Clinton; Robert "Bud" McFarlane, a former Marine who served as National Security Advisor to President Ronald Reagan; and Gen. H. Norman Schwarzkopf, who served as commander of the coalition forces in the first Gulf War in 1991. The brief argued:
Based on decades of experience, amici have concluded that a highly qualified, racially diverse officer corps educated and trained to command our nation's racially diverse enlisted ranks is essential to the military's ability to fulfill its principal mission to provide national security. The primary sources for the nation's officer corps are the service academies and the ROTC, the latter comprised of students already admitted to participating colleges and universities. At present, the military cannot achieve an officer corps that is both highly qualified and racially diverse unless the service academies and the ROTC use limited race-conscious recruiting and admissions policies. Accordingly, these institutions rely on such policies [Amici Curiae brief of Lt. Gen. Julius W. Becton Jr., et al. in Grutter v. Bollinger and Gratz v. Bollinger, 2/19/03]
FACT: Sixty-Five Leading Businesses Also Filed A Brief On The Same Side As Halligan. Sixty-five leading American businesses, including 3M, Boeing, Coca-Cola, Hewlett-Packard, Intel, Kraft Foods, Microsoft, Nike, PepsiCo, Pfizer, Reebok, Sarah Lee, Shell Oil, and Whirlpool, filed a brief on the same side as Halligan. The brief argued:
Now more than ever, the ability of universities, such as the University of Michigan, to consider all of an applicant's attributes is essential to create the educational environment necessary to best train all their students to succeed. The students of today are this country's corporate and community leaders of the next half-century. For these students to realize their potential as leaders, it is essential that they be educated in an environment where they are exposed to diverse people, ideas, perspectives, and interactions. In the experience of the amici businesses, today's global marketplace and the increasing diversity in the American population demand the cross-cultural experience and understanding gained from such an education. Diversity in higher education is therefore a compelling government interest not only because of its positive effects on the educational environment itself, but also because of the crucial role diversity in higher education plays in preparing students to be the leaders this country needs in business, law, and all other pursuits that affect the public interest.
If the University of Michigan is not able to consider all qualities of each applicant to the University, including his or her racial or ethnic background, the University will be hampered in its search for students with the most promise, and its graduates will be less likely to receive an education that gives them "'wide exposure' to the ideas and mores of students as diverse as this Nation of many peoples." Regents of the University of California v. Bakke, 438 U.S. 265, 313 (1978) (opinion of Powell, J.). The University's graduates will therefore be less likely to possess the skills, experience, and wisdom necessary to work with and serve the diverse populations of the United States and the global community. Graduates with such an education are important to the community as a whole, as well as to the amici businesses. [Amici Curiae brief of 65 leading American businesses in Grutter v. Bollinger and Gratz v. Bollinger, 2/18/03]
CLAIM: Halligan's Testimony That The Best Way To Interpret The Constitution Is To Look At Constitutional Text And Original Intent Is "Not Believable." In a National Review Online blog post, Whelan wrote:
Imagine for the moment what the response from the Left would be if a Republican president nominated to the D.C. Circuit a 43-year-old lawyer who:
– Testified at his confirmation hearing that "the best way in which we can interpret [the Constitution] is to look to the text and the original intent of the Framers";
– Opined (in the face of contrary Supreme Court precedent) that it is not "ever appropriate to rely on foreign law in deciding the meaning of the U.S. Constitution";
– Rejected Justice William Brennan's constitutional vision;
– Stated that judicial doctrine should not "incorporate the evolving understandings of the Constitution forged through social movements, legislation, and historical practice"; and
– Rejected the notion that empathy should play a role in a judge's consideration of a case.
Further assume that the nominee has net assets worth eight million dollars, and I think that it's rather clear that the Left would attack the nominee as a fatcat reactionary.
Well, it turns out that the nominee I've described is none other than President Obama's pick for the D.C. Circuit, Caitlin Halligan. Why, one might wonder, is the Left supporting the nomination? And why aren't conservatives celebrating it? The answer, I'd submit, is that everyone recognizes that Halligan's confirmation testimony is, in the core sense of the word, incredible — not believable.
As it happens, Halligan's responses to post-hearing questions provide additional reason (beyond her record, which I've addressed in previous posts) to disbelieve her testimony. In particular, asked whether she had ever before espoused the "original intent" methodology, Halligan responded, "I do not recall expressing an opinion on this issue in the past." Halligan gave the identical answer to the question whether she had ever before stated that it is not appropriate to rely on foreign law in deciding the meaning of the Constitution. (See answers 1.b and 3.b to questions from Senator Sessions, on pages 15 and 17 of this collection of Halligan's responses to post-hearing questions.) I guess that the prep sessions in which Halligan was apparently coached to testify as she did about original intent and foreign law didn't fall within the ambit of the questions. [National Review Online, 2/24/11]
REALITY: Halligan's Testimony Is In Line With What Other Progressives Believe
FACT: Some Progressives Strongly Believe That The Text And History Of The Constitution Should Form The Basis Of Constitutional Interpretation. It is not odd for progressives to argue that the constitutional text and its history are the best sources of constitutional interpretation. For instance, the Constitutional Accountability Center says:
The text of the Constitution must be the primary source of judicial guidance in deciding constitutional cases: that is what the judicial oath requires. An approach to constitutional interpretation that starts with a very careful parsing of the words of the Constitution is sometimes called "textualism." It is an approach best exemplified by great Supreme Court opinions written by justices such as John Marshall, the first John Marshall Harlan, and Hugo Black.
While history cannot trump text, historical sources such as the Federalist Papers can provide critical clues about what specific words meant to the framers and ratifying generation. As important, the best interpretations of the Constitution's general terms and embedded principles are informed by a careful consideration of historical events that led to the creation of the Constitution and made necessary changes to the document. [Constitutional Accountability Center, accessed 12/1/11]
FACT: Whelan Himself Acknowledges That "There Are Progressives Who Strongly Believe That The Text And History Of The Constitution Should Form The Basis Of Constitutional Interpretation." From a National Review Online blog post by Whelan:
How does Media Matters contrive to rehabilitate Halligan? First, carefully avoiding the phrase "original intent," it points out that "there are progressives who strongly believe that the text and history of the Constitution should form the basis of constitutional interpretation." Indeed, there are. But there is nothing — zilch, nada — in Halligan's record to suggest that she is one of them. Also, "progressive" advocates of some form of originalism routinely (uniformly, I suspect) condemn the "original intent" species of originalism. For a progressive to talk favorably of "original intent" is rather like a supposed aficionado of baseball to talk of how many "points" a team has scored — in other words, a basic marker of fakery. [National Review Online, 2/28/11]
CLAIM: The D.C. Circuit Is "Underworked." From a National Review Online blog post by Whelan:
1. I am reliably informed that the D.C. Circuit, for the second straight year, has canceled scheduled argument days for the spring because it doesn't have cases for the argument days.
2. According to this table prepared by the Administrative Office of the U.S. Courts, filings in the D.C. Circuit fell 17% for the most recent 12-month period measured (ending March 31, 2010), as compared to the previous 12-month period.
3. Using that same table, one can calculate for each federal court of appeals the number of case filings per authorized judgeship. I readily concede that this is a crude measure of caseload, in part because the average D.C. Circuit case might be more complicated than the average case from other circuits, in part because it doesn't take into account the resources provided by senior judges. Nonetheless, the results are striking and would seem to confirm what those most familiar with the D.C. Circuit freely say — that the court is underworked. Specifically, by this measure the D.C. Circuit's caseload per judge is 96, whereas the aggregate figure for the other regional courts of appeals is 357 — nearly four times higher. (The per-circuit numbers for the other circuits range from 196 for the Tenth Circuit to 558 for the Eleventh.) [National Review Online, 2/2/11]
CLAIM: "The D.C. Circuit Has A Relatively Low Caseload." From a Washington Times editorial:
The D.C. circuit has a relatively low caseload. This seat should remain unfilled until Ms. Halligan's record is straightened out. [The Washington Times, 2/9/11]
REALITY: Senate Confirmed Bush Judges When Caseload Was At A Lower Level
FACT: In 2005, The Republican-Controlled Senate Filled The 11th Seat On The D.C. Circuit By Confirming Bush Nominee Thomas Griffith. The Senate confirmed Thomas Griffith to a seat on the D.C. Circuit on June 14, 2005. At the time, the D.C. Circuit had 12 seats and Griffith's confirmation left the court with one vacancy, meaning that Griffith filled the 11th seat. [Senate vote on the nomination of Thomas Griffith, vote no. 136, 6/14/05; Administrative Office of U.S. Court chronological history of authorized judgeships in U.S. Courts of Appeals, accessed 12/1/11; Administrative Office of U.S. Courts archive of judicial vacancies, 7/1/05]
FACT: With Griffith Confirmed, There Were Approximately 121 Pending Cases Per D.C. Circuit Judge. According to statistics compiled by the Administrative Office of U.S. Courts, on June 30, 2005, less than a month after Griffith was confirmed, there were 1,329 pending cases. Since there were 10 active judges on the court before Griffith was confirmed, this meant that there were approximately 133 pending cases per active D.C. Circuit judge at the time, and after Griffith's confirmation, there were approximately 121 pending cases per active judge. [Administrative Office of U.S. Courts statistics for the federal judiciary, accessed 12/1/11]
FACT: Halligan Would Be Filling The 9th Seat On The D.C. Circuit. In 2008, Congress decreased the number of D.C. Circuit judgeships to 11. The court currently has three vacancies, which means that if confirmed, Halligan would fill the ninth seat on the court. [Administrative Office of U.S. Court chronological history of authorized judgeships in U.S. Courts of Appeals, accessed 12/1/11; Administrative Office of U.S. Courts list of judicial vacancies, accessed 12/1/11]
FACT: If Halligan Were Confirmed There Would Be 143 Pending Cases Per D.C. Circuit Judge. According to the Administrative Office of U.S. Courts statistics, as of June 30, 2011, there were 1,289 pending D.C. Circuit cases. With eight judges currently sitting on the court, there are approximately 161 pending cases for each active D.C. Circuit judge. If Halligan were confirmed, there would be approximately 143 pending cases for each active D.C. Circuit judge. [Administrative Office of U.S. Courts, accessed 12/1/11]
FACT: Even Whelan Acknowledges That "The Average D.C. Circuit Case Might Be More Complicated Than The Average Case From Other Circuits." From a National Review Online blog post by Whelan:
Using that same table, one can calculate for each federal court of appeals the number of case filings per authorized judgeship. I readily concede that this is a crude measure of caseload, in part because the average D.C. Circuit case might be more complicated than the average case from other circuits, in part because it doesn't take into account the resources provided by senior judges. Nonetheless, the results are striking and would seem to confirm what those most familiar with the D.C. Circuit freely say — that the court is underworked. Specifically, by this measure the D.C. Circuit's caseload per judge is 96, whereas the aggregate figure for the other regional courts of appeals is 357 — nearly four times higher. (The per-circuit numbers for the other circuits range from 196 for the Tenth Circuit to 558 for the Eleventh.) [National Review Online, 2/2/11]
FACT: National Review Contributor Has Said That The D.C. Circuit Is "Often Considered The Second Most Important Court In The Land." From an October 2008 National Review article by law professor Jonathan Adler:
Wheeler's scenario suggests dramatic changes circuit-by-circuit as well. Ten of the thirteen federal appellate courts have a majority of Republican-nominated judges, including the U.S. Court of Appeals for the D.C. Circuit, often considered the second most important court in the land. Yet after a President Obama's first term, Wheeler projects that only three circuit courts — the Fifth, Eighth and Tenth — would continue to have Republican-nominated majorities. Confirmation of Obama nominees would create Democratic majorities on the First, Second, Third, Fourth, Seventh, Eleventh and D.C. Circuits, and increase the Democratic margin in the Ninth. [National Review, 10/31/08]
CLAIM: GOP Senators Who Have Said That Filibusters Of Judicial Nominees Are Unconstitutional Can Nevertheless Filibuster Obama Nominees. From a National Review Online blog post by Whelan:
As for the category of Republican senators who maintained that the Democratic filibuster of judicial nominees was unconstitutional: The authoritative body on this constitutional question, the Senate itself, has plainly concluded by its practices that the filibuster is constitutionally permissible. Although it seems to me permissible for a senator to continue to abide by his own contrary view, I don't see why, alternatively, he can't view the Senate as having authoritatively settled the question adversely to his view.
Again, consider an analogy: Let's say that the Supreme Court has adopted a reading of Congress's Commerce Clause powers that a particular senator believes is overly expansive. Must the senator abide by his own more restrictive view? Or is he free to recognize that the Supreme Court's reading meaningfully defines the legal landscape and to operate within that landscape? Or let's say that a president disagrees with a Supreme Court decision that strikes down a federal criminal statute on constitutional grounds. Must the president continue to insist that federal prosecutors enforce that statute? I'd be very surprised if anyone flinging the hypocrite label at Republican senators would seriously maintain that the senator and the president in these hypotheticals are hypocrites if they choose to abide by the Supreme Court's rulings. [National Review Online, 5/20/11]
CLAIM: Filibustering Judicial Nominations Is "A Bad Practice," But That's Why Republicans Should Do It. From a National Review Online blog post by Whelan:
I continue to hold the view that I've expressed since the outset of Bench Memos in 2004 — that the filibuster of judicial nominees is constitutionally permissible but a bad practice. It's clear, however, that unilateral disarmament by Republicans would do nothing to deter Democrats from filibustering Republican nominees. As with the independent-counsel statute, the only sensible choice for Republican senators who want to get rid of the filibuster in the long run is to employ it against very bad judicial nominees by President Obama. [National Review Online, 5/17/11]
CLAIM: "A Republican Senator Should Put An Indefinite Hold On" Halligan's Nomination. From a February 9 Washington Times editorial:
There are disturbing discrepancies in Senate testimony by D.C. federal appellate-court nominee Caitlin Halligan. If majority Democrats won't allow a full investigation, a Republican senator should put an indefinite hold on the nomination.
The controversy is over a 2004 New York City bar association report on enemy combatants, which concluded that indefinite detention during wartime is unconstitutional. Ms. Halligan was listed as a signatory on the document but told Sen. Jon Kyl, Arizona Republican, that she first "became aware of the existence of the report" last summer. Now that the report is controversial, she claims its conclusion was "incorrect," that she was "a little bit taken aback by the tone of the report," and that it doesn't represent her work or views.
Edward Whelan, president of the Ethics and Public Policy Center, is suspicious about the timing of Ms. Halligan's skepticism, especially since she listed this on a Judiciary Committee questionnaire among reports for which she had been "a member of the committee approving them." Review of the e-mail trail should show what role Ms. Halligan played and "whether she agreed with the positions that she now distances herself from," Mr. Whelan wrote for NRO.
REALITY: Many GOP Senators Have Said Filibusters Of Judicial Nominees Are Unconstitutional
FACT: Republican Senators Have Said Or Suggested That It Is Unconstitutional To Filibuster Judicial Nominees. Defenders of Wildlife's Judging the Environment project has compiled quotations from sitting senators who have said or suggested that it is unconstitutional to filibuster judicial nominees. Some of those senators have maintained that position during the Obama administration. [JudgingTheEnvironment.org, accessed 12/1/11]
Sen. Johnny Isakson (R-GA): "The Way To Comply With The Constitution Is To Have An Up-Or-Down Vote On [Judicial] Nominees." [CNSNews, 5/5/11]
Sen. John Thune (R-SD): "I Believe That Well-Qualified Judicial Nominees Should Receive A Vote On The Floor Of The United States Senate." From a statement that appeared on Thune's website as recently as March 2011:
I take very seriously the role that the U.S. Senate has when it comes to the Constitutional responsibility of "advise and consent" concerning judicial nominees. After reviewing their records, I believe that well-qualified judicial nominees should receive a vote on the floor of the United States Senate. [Thune.Senate.gov, 3/4/11, via Archive.org]
Sen. Orrin Hatch (R-UT): "The Constitution's Assignment Of Roles In The Judicial Selection Process Counsels Against Using The Filibuster To Defeat Majority-Supported Nominees." [Congressional Record, 11/17/09]
Sen. John Cornyn (R-TX): "An Up-Or-Down Vote Is A Matter Of Fundamental Fairness, And It Is The Senate's Constitutional Duty To Act On Each Nomination." [Cornyn.Senate.gov, 2/7/08]
Sen. Mike Crapo (R-ID) And Former Sen. Larry Craig (R-ID): "The Constitution Requires The Senate To Hold Up-Or-Down Votes On All Nominees." [Idaho Examiner, 5/25/05]
Sens. Saxby Chambliss (R-GA) And Isakson: "The Constitution Require[s] An Up-Or-Down Vote." [Isakson.Senate.gov, 5/24/05]
Sen. James Inhofe (R-OK): Democrats "Unconstitutionally Filibuster Any Judge They Do Not Like." [Inhofe.Senate.gov, 5/24/05]
Sen. Jeff Sessions (R-AL): "The Constitution Is Clear That A Majority Is What We Were Looking For." [Congressional Record, 5/23/05]
Sen. Chuck Grassley (R-IA): "We Need To Give These Nominees The Up-Or-Down Vote The Constitution Requires." [Congressional Record, 5/23/05]
Sen. Kay Bailey Hutchison (R-TX): By Filibustering Judicial Nominees, Senators Are "Changing The Constitution Without Going Through The Process Of A Constitutional Amendment." [Congressional Record, 5/19/05]
Sen. Richard Burr (R-NC): "Denying Judicial Nominees Of Both Parties … An Up-Or-Down Vote … Was Certainly Not The Intention Of Our Founding Fathers." [Congressional Record, 5/19/05]
Sen. Jim DeMint (R-SC): Senators Who Filibuster Judicial Nominees "Are Trying To Thwart The Will Of The American People And The Constitution." [Congressional Record, 5/12/05]
Sen. Pat Roberts (R-KS): If Filibusters Are Allowed, "We Are Really Changing The Constitutional Design Of What It Takes To Basically Nominate And Approve Any Judge." [Fox Broadcasting Co., Fox News Sunday, 3/2/03, via FoxNews.com]
FACT: Republican Senators Also Pledged That They Would Not Filibuster Judicial Nominees Even If They Were Picked By A Democratic President. Defenders of Wildlife's Judging the Environment project has also compiled examples of a number of Republican senators who pledged not to filibuster judicial nominees no matter who was in the White House. [JudgingTheEnvironment.org, accessed 12/1/11]
Sen. Lamar Alexander (R-TN): "I Have Pledged And I Still Pledge To Give Up My Right To Filibuster Any President's Nominee For The Appellate Courts, Including The Supreme Court Of The United States." [Congressional Record, 5/20/05]
Isakson On His Support For Ending Judicial Filibusters: "Were I In The Minority Party And The Issues Reversed, I Would Take Exactly The Same Position." [Congressional Record, 5/19/05]
DeMint: "One Of My Goals As A Senator Is To Confirm Highly Qualified Judges By Ensuring Timely Up-Or-Down Votes For All Nominees No Matter Who Is President, No Matter Which Party Is In The Majority." [Congressional Record, 5/12/05]
Sen. Tom Coburn (R-OK): "I Will Continue To Insist That The Judicial Nominations From Any President — Republican Or Democrat — Receive The Courtesy Of An Up-Or-Down Vote." [Coburn.Senate.gov, 5/11/05]
Sen. Lisa Murkowski (R-AK): "I Support An Up-Or-Down Vote On All Nominations Brought To The Senate Floor, Regardless Of The President Nominating Them Or Which Party Controls The Senate." [Juneau Empire, 5/9/05]
Isakson: "Every Judge Nominated By This President, Or Any President, Deserves An Up-Or-Down Vote." [Congressional Record, 4/28/05]
FACT: Some Republican Senators Have Taken The Position That Nominees Can Only Be Filibustered In "Extraordinary Circumstances." In 2005, a "Gang of 14" senators agreed not to filibuster judicial nominees except in "extraordinary circumstances." Republican senators, including Sessions, Cornyn, Grassley, John McCain (AZ), and Jon Kyl (AZ), have purported to apply the "extraordinary circumstances" test in Senate floor speeches in 2011. [Media Matters, 11/3/11]
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FEC Deadlocks On Question Of 'Uncoordinated' Coordination
The Federal Election Commission just deadlocked on a request by Karl Rove's "super PAC" to allow advertisements shot in coordination with candidates for federal office to be considered uncoordinated and not amount to in-kind donations. A motion in support of a draft opinion to reject the request failed on a three-to-three vote.
NY Assemblyman Accused Of Soliciting Bribes To Pay Legal Fees For Corruption Trial
New York Assemblyman William Boyland, Jr. was arrested this week for allegedly soliciting $250,000 in bribes from undercover FBI agents, just a short time after he was cleared of other corruption charges….
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Herman Cain's Turd Polish
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Stay Tuned: New Ad Calls for Debate on Nuclear Weapons
In the first Republican presidential debate on national security issues, held on November 12th, the closest the Republican candidates came to holding a discussion on nuclear weapons was when they got into a bidding war over who could deploy the…
Republican Foreign Policy Debate, Ugh
If nothing else, devoting an entire GOP campaign forum to national security and foreign policy — the CBS News / National Journal organizers called it the "Commander in Chief Debate" — helps accentuate the preparation and seriousness the candidates have…
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U.S. Death Toll In Afghanistan At Two-Year Low
The Washington Post reports today that 17 U.S. troops were killed in Afghanistan in November and that "[t]he last time the monthly death toll came in under 17 was in December 2009." While 2011 is still on track to be one of the deadliest of the war for American forces, and November falls outside of […]
The Washington Post reports today that 17 U.S. troops were killed in Afghanistan in November and that "[t]he last time the monthly death toll came in under 17 was in December 2009." While 2011 is still on track to be one of the deadliest of the war for American forces, and November falls outside of the traditional "fighting season," the Post adds that "the relatively low toll still appears to be a testament to officials' claims of progress against insurgents, particularly in the south."
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The GOP's Jimmy Carter fixation
Don't look now, but all of a sudden, Republicans are running against Jimmy Carter again. Or at least trying to.
* The GOP gleefully pointed to a Gallup poll earlier this week that showed President Obama's numbers dipping below Carter's at the same point in their respective terms.
* The National Republican Senatorial Committee released a web video Wednesday titled "Malazy" – a hybrid of Carter's "malaise" and Obama's "lazy" quotes.
Read full article >>
Unemployment rate falls to 8.6 percent in November, raising hopes for growth
The unemployment rate plummeted to its lowest level in more than two years in November, according to a new government report that shows both promise and hazards for President Obama in the election year ahead.
The jobless rate fell to 8.6 percent last month from 9 percent in October, the lowest level since the economic free fall in March 2009. Job creation was steady, with employers reporting that they added 120,000 people to their payrolls.
Smokey Bear up in smoke? House GOP takes aim
Is nothing sacred? We get that House Republicans are dead serious in their efforts to trim federal spending and cut the national debt, but we had no idea how far they were willing to go…until now.
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20 April 2019, 02:12 Died on level 235 by Tyrion, Kamasutra, Yagoftw, Crusher Dreams, Hallvard and Lokiyo.
20 April 2019, 01:18 Died on level 236 by a sea serpent.
20 April 2019, 00:24 Died on level 236 by Tyrion, Hallvarorz and Crusher Dreams.
19 April 2019, 22:40 Died on level 236 by Drakov Ms, Pang Boom and Venvixuss.
18 April 2019, 01:05 Died on level 211 by a serpent spawn.
13 April 2019, 01:47 Died on level 186 by a quara hydromancer scout.
11 April 2019, 19:13 Died on level 154 by a serpent spawn.
3 April 2019, 20:09 Died on level 130 by Spartibus.


As I work towards my long distance training goals I've recently realised that my core strength needs improving.
Pre-pregnancy I always had strong abs (even if they were at times rather padded!). Unfortunately the C-section incision which helped my breech baby come into the world also sliced through my lower stomach muscles and they've never really recovered. An emergency appendectomy 18 months ago didn't help either.
I'm well aware of the benefits of efficient hip/core driven rotation in powering swimmers through the water on longer distances, but my now slightly squishy tum isn't very good at performing this task, so it often feels like my hips and shoulders are playing catch up with each other rather than working on the same plane.
I do a little yoga and it has helped strengthen my core. But, as I'm hyper mobile, too much tends to trigger joint problems, particularly when over-zealous teachers 'adjust' me into extreme stretches.
I've tried pilates too, and I can tell some of the basic moves (such as the straight leg roll up) really do hit your core properly. However some just seem ridiculous. There have got to be better ways to work out than by lying on your side, grinning and repeating tiny non-functional movements that have literally NO USE.
Any sequence this supported will take hundreds of reps to have a measurable effect. In fact, I find most mat-based classes aimed at women boring and patronising. 'Thighs, bums and tums' classes can do one. Yes, it would be nice to have 'amazing' legs. But I'd rather be able to do a muscle up than be able to wear hot pants.
What to do about the old core strength problem then? The husband, somewhat bemused by a pilates video I was watching, suggested getting into rings.
Gymnastic ring training (and body weight training in general) has boomed thanks to peeps like BarStarzz and is the hubble's preferred form of exercise.
I've fancied the idea of being able to do pull ups for a while now, ever since I saw a woman campusing at my local bouldering centre, so as we've already got the ring set up it seemed a good place to start.
For my first day I did assisted pull ups with a hammer grip, which felt the most natural. If you want to have a go, loop resistance bands around your gymnastic rings/pull up bar and stand in them – you'll need to hook your foot in and push down until the loop touches the floor.
The resistance bands need to be good quality (the fear of one breaking and smacking me in the face was real!) and heavy duty. These green ones are from MyProtein.com and take 23 to 54kg resistance as a pair – effectively this means they are taking this much weight out of the equation if you stretch them to their full extent.
Once you're standing in the loops, pull up slowly from a hang (hold your shoulders into your body) and lower at least as slowly. The temptation is to bounce, which I think was how I managed to do 15 twice, before concentrating more on form and hitting a lower third set tally.
Three sets to failure is plenty, and with a minute in between you're only looking at 5 minutes or so for the whole thing.
The other half decided day one had probably been too easy for me, so we moved onto negatives.
If, like me, you can't manage a single pull up yet (I can get about half way), the problem is progression. How are you supposed to get better if you just can't do it at all? Negatives are one answer.
Get up quickly by pushing off a chair or bench using one foot – it'll need to be quite far in front of you so that you don't catch it with your knees on the way down. Don't jump up – this is cheating as you're using too much momentum to get to the top of the motion.
Once you're at the top don't hang around too long. The key thing is to lower down in a controlled slow manner – this is what will challenge your muscles and help you work up to a full pull up.
To make it harder you need to go to the full range of the movement, so cross your ankles behind you and keep your shins parallel to the floor.
Don't hang with shoulders locked out – you need to keep your muscles working all the way down to avoid over-extending the joint.
Our dog is looking at me like I've lost the plot, but I've always liked more extreme exercises, and I could really FEEL this stuff straight away. I managed about 6 negatives – filming and taking pictures is a bit distracting so I'm not entirely sure of my total.
Then we had a little play on the rings. I did gymnastics as a kid (the cause of some of my joint problems now) and had forgotten how fun it was to play.
This was the best bit and I can't wait to try it again!
Shortly afterwards it was off to the pool for my Saturday morning tech set. I'm not sure whether thinking about my core so much earlier on had anything to do with it, but I definitely felt more connected to it and managed to knock out some fast (for me) sprints.
I'll update when I've done a few more sessions but so far, so fun!
← Should I swim with a cold?


text:
La Capella de Manyaques, ara per ara d'advocació desconeguda, és la capella del mas Manyaques, situat a l'actual terme de la comuna del Tec, a la comarca del Vallespir (Catalunya del Nord).

Està situada al costat sud-occidental del mas Manyaques, a prop a l'esquerra del Tec, a l'extrem nord-est del terme, prop del límit amb Montferrer.

La capella, exteriorment intacta, ha estat interiorment transformada en un apartament, com la resta de dependències del mas Manyaques.

Característiques
Es tracta d'una capella probablement del , d'una sola nau, amb l'absis orientat al nord-oest. En el frontis sud-est hi ha un petit cloquer d'espadanya obrat amb maons, com la resta l'església.

Bibliografia

Referències

Esglésies del Tec
Esglésies del Vallespir

redpajama_set_name: RedPajamaWikipedia


Do you suffer with Abdominal pain or Cramping?
Have you been getting a bloated feeling?
Do you suffer with Diarrhoea or Constipation — sometimes alternating bouts of constipation and diarrhoea?
Do you generally feel Gas Formation / Flatulence?
Are you occasionally experiencing an urgent need to go to the toilet?
Have you been noticing Mucus in the stool?
If your answer to any of these questions is "YES" – those may be some of IBS symptoms. What you need is – a safe, effective and time-tested Ayurvedic Remedy for balancing your digestion fire i.e. Agni!!
Ath Samdeepan is a natural solution for digestion related complications. An effective Ayurvedic remedy which helps you correct them at root cause level without any side effects.
Irritable bowel syndrome (IBS) is a gastrointestinal disorder which mostly affects the large intestine or colon. Chronic in nature, IBS has become a common health issue with reportedly 2.4 to 3.5 million patients taking the problem to their physicians in India every year. Surveys also suggest that about 70% of the patients suffer from mild IBS and never visit a doctor for treatment. Considering its growing occurrence, it is important to know some important aspects of the disorder.
Ayurvedic Explanation of IBS, it's causes and resolution has been explained by Dr. Arora in the video below, English transcript of the same is available here.
Fortunately there are several natural herbs that can help you treat chronic digestion issues without creating any side-effects. Effective herbal supplements based on age-old science of Ayurveda are available to fight the symptoms of IBS and other digestion problems and get long term relief. Ath-Samdeepan is a natural and safe way to get relief from IBS and other digestion issues including Colitis etc. without any side-effects.
There are many natural fruits and herbs like Bel, Kutaj, Saunf, Makoy, Chitrak, Chiraita, Nagarmotha etc. which are recommended to treat IBS.
..Act to realise your imagination, take action now to get well soon.
Get Ath Samdeepan, which is a natural and safe way to treat IBS (Irritable Bowel Syndrome) without any side-effects (संग्रहणी का प्राकृतिक एवं सुरक्षित उपाय).
Indications: Irritable Bowel Syndrome (IBS) – संग्रहणी, Colitis, Ulcerative Colitis etc.
Each Samdeepan capsule contains water extract from from Bel, Kutaj, Saunf, Makoy, Chitrak, Nagarmotha, Chirayta, Jeerak, Ajwain, Pudina, Kutki, Shunthi, Marich, Pippali, Chavya, Haritaki, Atis, Vai Vidang, Hingu, Sauvarchal Lawan, Sandhav Lawan, Yav Chhar.
1 Morning walk 1 Green leafy vegetables e.g. spinach, mustard leaves etc.
2 Trikatu churn over the vegetables, juices or as it is – 2 Raw salad, heavy pulses like Urad, Rajma, Chana etc.
1 Green leafy vegetables e.g. spinach, mustard leaves etc.
2 Raw salad, heavy pulses like Urad, Rajma, Chana etc.
WARNING: Common Drugs And Therapies Used To Treat IBS & Its Symptoms, Can Have Serious Side Effects, While Samdeepan is quite Safe.
Ath Samdeepan works naturally, gently and very effectively to heal all the relevant elements from inside which helps balancing your agni (digestion power), ensuring that you get not only symptomatic relief but it also strengthens the weak parts and functions of your body system so that you do not slip into the problem again.


Another post, just to show the working of the template.
This looks awsome! I'd love a download link, as even though its in testing and buggy, I still want it!
how to get a password on wordpress page?
Did you try https://codex.wordpress.org/Using_Password_Protection ?


text:
NEWS: Information for fans following iFollow video issue vs MK Dons
The EFL have confirmed that those supporters affected by the loss of video during Saturday's streaming of the Sky Bet League One clash against MK Dons will be refunded.
Overseas supporters who were affected by the loss of video are asked to email ifollow@efl.com to arrange a refund.
Audio commentary of the game was still available for supporters in the UK.
We apologise for any inconvenience caused to fans following the issue with the live stream on Saturday - the EFL are working to investigate what caused the issue and resolve it for our next league game.
NEWS: Watch Tuesday's away trip to Fleetwood Town on iFollow!
Coventry City's away game against Fleetwood Town on Tuesday night will be available to stream on iFollow for fans in the UK, as well as overseas.
NEWS: Watch the New Year's Day trip to Tranmere Rovers on iFollow
Coventry City's New Year's Day away game against Tranmere Rovers will be available to watch on iFollow for fans in the UK, as well as overseas.
NEWS: Sky Blues versus Wycombe Wanderers on iFollow in the UK this Sunday
Coventry City's away game against Wycombe Wanderers on Sunday afternoon will be available to watch on iFollow for fans in the UK as well as overseas.
NEWS: Sky Blues versus MK Dons available to watch on iFollow in the UK for £10
Coventry City's away game against MK Dons on Tuesday night will be available to watch on iFollow for fans in the UK as well as overseas.
RETAIL: Pre-order the Third Shirt!
The 2 Tone Third Kit is available to pre-order again now!
GALLERY: Fleetwood Town 0-0 Sky Blues
The Sky Blues extended their unbeaten run as they came away from Highbury with a point last night against Fleetwood Town.
VACANCY: Psychological Wellbeing Practitioner at Sky Blues in the Community
TEAM NEWS: Sky Blues Name Unchaged Team For Fleetwood Trip
The Sky Blues have named the same starting XI that played in the Emirates FA Cup at the weekend for tonight's Sky Bet League One clash against Fleetwood Town.


It is not necessary always to use substitution to factor polynomials with higher degrees or variable exponents. In the next example we use trial and error to factor two polynomials of higher degree and one with variable exponents. Remember that if there is a common factor to all terms, factor it out first.
Factor each polynomial completely. Variables used as exponents represent positive integers.
b) -18y7 + 21y4 + 15y = 3y(6y6 - 7y3 - 5) Factor out the common factor -3y first.
= 3y(2y3 + 1)(3y3 - 5) Factor the trinomial by trial and error.
2u2m - 5um - 3 = (2um + 1)(um - 3).


Seller > Flat / Apartment | Noida Extn, NOIDA.
Seller > Flat / Apartment | , NOIDA.
Seller > Flat / Apartment | Sec-121, NOIDA.
Seller > Flat / Apartment | Sector-78, NOIDA.
Seller > Agricultural Land | Expressway, NOIDA.
we are developing farmland for farmhouses on noida expressway, 50% we had developed.
Seller > Residential Plot/Land | Sector-150, NOIDA.
R you Interested Purchase in Residential Land for Invest Purpose.
Seller > Farm House | Greater NOIDA, NOIDA.


text:
SITE 2020 > Topics > Instructional Design
Topic: Instructional Design
Terence Cavanaugh
Lauren Cifuentes
Dorian Cook
Rebekah Davis
View all attendees
Pre-Service Teachers 3D Print Selections
Tuesday, April 7th 4:45 PM-5:15 PM
Terence Cavanaugh, University of North Florida, United States
Nicholas Eastham, University of North Florida, United States
Info Add Discuss Share Download Paper
Encouraging Awareness and Empathy for Diversity through Experiential, Practiced Simulations
Tuesday, April 7th 11:15-11:45 AM
Farah Vallera, Lehigh University, United States
Noor Syed, Lehigh University, United States
Universal Design for Learning in Online Environments
Wednesday, April 8th 4:15 PM-5:15 PM
Mollie Peuler, Appalachian State University, United States
Michelle Bartlett, North Carolina State University, United States
The Influence of a Cognitive Apprenticeship Model on Preservice Teachers' Beliefs and Attitudes Regarding Instructional Technology Use
Wednesday, April 8th 2:15-2:45 PM
Rebekah Davis, NC State University, United States
Teaching Data Collection and Analysis: Using DataCorral Technology to Create Lesson Plans for STEM Secondary Teachers
Nycole Marsh, University of Wyoming, United States
Dawn Palmquist-Whaley, University of Wyoming, United States
Andrea Burrows, University of Wyoming, United States
Shannon Albeke, University of Wyoming, United States
Rasana Manandhar, University of Wyoming, United States
Mike Borowczak, University of Wyoming, United States
Demystifying Online Teaching: A Year of Introducing Faculty at our University to an Online Course Quality Rubric
Brianne Leia Jackson, Virginia Commonwealth University, United States
Virginia Thompson, Virginia Commonwealth University, United States
Tim Luckritz Marquis, Virginia Commonwealth University, United States
Enhancing Motivation in Training with Casual Games: A Twelve Month Field Study
Karl Kapp, Bloomsburg University, United States
Deltcho Valtchanov, Axonify, United States
Ray Pastore, University of North Carolina Wilmington, United States
Transforming Zooniverse Data into STEM Lessons in a Secondary Classroom
Nycole Marsh, University of Wyoming - College of Education, United States
Andrea Burrows, University of Wyoming - College of Education, United States
Constructed Learning in Elementary Mathematics
Dorian Cook, Morehead State University, United States
Lesia Lennex, Morehead State University, United States
How and Why Educators use HyperDocs: What Teacher Educators Should Know
Thursday, April 9th 4:15 PM-5:15 PM
Tim Green, California State University, Fullerton, United States
Torrey Trust, University of Massachusetts Amherst, United States
Jeff Carpenter, Elon University, United States
Elementary Math Manipulatives: What Functions?
Formative Assessment with Game-Based Technology
Donovon Grier, Midwestern State University, United States
Stacia Miller, Midwestern State University, United States
Suzanne Lindt, Midwestern State University, United States
Online Course Design in Technology Pedagogy: Multiple Instructors, Designers, and Deliveries
Wednesday, April 8th 10:45 AM-11:15 AM
Lauren Cifuentes, New Mexico State University, United States
Xeturah Woodley, New Mexico State University, United States
David Rutledge, New Mexico State University, United States
Designing for Inclusivity in Teacher Education
Tuesday, April 7th 11:50 AM-12:10 PM
Nandita Gurjar, University of Northern Iowa, United States
Student group presentations in online courses without the stress
Loretta Donovan, Cal State Fullerton, United States
Teaching World Culture online as a recruitment tool for language programs.
Laetitia Knight, University of North Texas, United States
New to Online Distance Education Teaching? : One question, five answers, and lots of ideas in between.
Cora Causey, University of Alabama, Birmingham, United States
PBLCode: The impact of a problem-based introductory computer science curriculum on elementary students' knowledge, skills, and attitudes
Friday, April 10th 10:15-10:45 AM
Thomas Brush, Indiana University, United States
Anne Leftwich, Indiana University, United States
Kyungbin Kwon, Indiana University, United States
View all sessions


text:
#TeamSinBin
Partner w/TSB
2019-20 ECHL Fan Guide
Hockey Talk Podcast
In The Corners Podcast with C.C. Hawkley
2016 Preseason Transactions
2016-17 Trade Deadline
Evansville Thunderbolts
Fayetteville Marksmen
Huntsville Havoc
Macon Mayhem
Pensacola Ice Flyers
Quad City Storm
Roanoke Rail Yard Dawgs
Inside the SPHL Podcast
2018 SPHL Transactions
The Sin Bin
Home ECHL Mavericks Must Learn from Their Own Past
Photo Courtesy of John Howe / The Sin Bin
Mavericks Must Learn from Their Own Past
Joe Rozycki
The similarities are eerie. It's like we've seen this team before. I hate to bring up painful memories, but in this instance, it is necessary to look back in order to prevent a similar ending. I'm sure there are many among the Orange Army that have drawn their own comparisons at certain points throughout the season. The 2015-16 Missouri Mavericks remind me an awful lot of the the 2013-14 Missouri Mavericks.
There are good and bad things about that previous statement. That previous Mavericks team was the best in the league, dominant from start to finish, and won the regular season championship. They had a dominant first line anchored by the legendary Sebastien Thinel, with Eric Castonguay, and either Mike Ramsay or Andrew Courtney on the other wing. They posed incredible challenges to opposing defenses on a nightly basis. They got significant secondary scoring from players like Trevor Kell, Colt King, and John-Scott Dickson. They had one of the best goalies in the league in Shane Owen. Until this season, that was the best Missouri Mavericks team to date. This year's team also has a dominant top line with Rocco Carzo, Tyler Barnes, and Darian Dziurzynski (even without Jesse Root). They have secondary scoring with Courtney, Sebastien Sylvestre, and Josh Holmstrom. Between the pipes, they have Josh Robinson who no longer requires adjectives, as well as Steven Summerhays who has played extremely well since arriving from Anchorage. Similar characteristics indeed.
Tyler Barnes anchors a formidable top line for the Mavericks. (Photo: John Howe/The Sin Bin)
That being said, there are also stark differences between the two squads. Let's forget about the affiliation for argument's sake. While this year's team has been formidable on special teams, they 2013-14 Mavericks were the best in the league in both power play conversions and penalty kills. The current version of the Mavs is a far superior defensive club. That's no knock on players like Dave Pszenyczny, Matt Stephenson, or Henrik Odegaard. The present day Mavs are more committed to total team defense, and possess the best blue line this organization has ever seen. Granted, a lot of those guys are currently up in Bridgeport right now, but when draped in Orange, goals are hard to come by when facing the Central Division champions. There is also a considerable contrast in regards to style of play. The Scott Hillman-led Mavericks were much more run and gun, and could outscore any team on any given night. The Richard Matvichuk-led Mavericks were built from the back up, touting smothering team defense to suffocate the opposition.
Richard Matvichuk has brought a change in culture to Independence. (Photo: John Howe/The Sin Bin)
Both systems have had their success, however the current version of the Mavs are playing in a more sustainable system. Sometimes offenses can be stifled, as we have seen in years past. However the more defensive-minded system is something, barring mental mistakes, that can be replicated easily on a nightly basis. While some personnel losses have made that somewhat difficult as of late, the system itself is still in place and effective.
Why all of the comparisons to a team in which Courtney is the only remaining member still on the roster, you might ask? Don't you worry, I'll explain. If this team can take anything from the 2013-14 version of the Mavericks, we can only hope that they learn from their mistakes. Those mistakes ended in nightmarish fashion, getting knocked off by a number eight seed in the first round of the playoffs. That was a team with so much promise, and had played so well for 99 percent of the regular season. It is that one percent that could have possibly led to their downfall. That team was not playing great hockey at the end of the season and backed their way into the playoffs.
There is a common saying about playoff hockey that all you have to do is get there and anything can happen. There is a lot of truth to that. However, with a team as talented as the Mavericks, it could make all the difference in the world for this team to play at the level that they were a couple of months again, compared to what we have seen lately. Just this last week, after thumping Allen on their home ice earlier in the week, the Mavs took one on the chin against Tulsa, then split their pair of games against Wichita. It's hard to complain about finishing 13-1-0-1 against the Thunder this season, but with both of those losses coming in the last couple of weeks, it has to make you at least slightly raise an eyebrow. In fact the Mavs have dropped five of their last 10 games. By definition, that is mediocre. Teams playing at a mediocre level typically don't make a lot of noise in the postseason, just ask the 2013-14 Mavericks.
This team has done some incredible things, feats that will long be talked about within the organization and possibly around the league. Then again, prior to this year's campaign, we all looked at the 2013-14 season so fondly, and held it in the highest regard. The biggest possible difference between these two Mavericks teams is yet to be written. It's easy to just say "play better." I'm just a mouthpiece and have been known to ruffle a few feathers. I'm okay with that. It's my job to make these observations. It's their job to figure out what needs to be done in order for this team to be firing on all cylinders over these last couple of weeks heading into the postseason. With the body of work that Matvichuk has shown since the trade deadline last season, he's earned the benefit of the doubt. There's no guarantee that reinforcements are coming from Bridgeport, but there's enough talent on this team to accomplish the goals that were put in place when Matvichuk accepted the coaching job in Independence. Playing at the level that this team is capable of would be a good start. They have nine games to figure that out.
Please consider becoming a Patron as a way to say thanks and support us for what we do! https://www.patreon.com/thesinbinhockey
Andrew Courtney
Darian Dziurzynski
Dave Pszenyczny
Eric Castonguay
Henrik Odegaard
Jesse Root
Matt Stephenson
Mike Ramsay
Richard Matvichuk
Rocco Carzo
Scott Hillman
Sebastien Thinel
Shane Owen
Steven Summerhays
Tyler Barnes
PHOTOS: Orlando Solar Bears vs. Jacksonville Icemen – 01/18/20
PHOTOS: Orlando Solar Bears vs. Norfolk Admirals – 1/11/2020
Belpedio Beats Back Barracuda with OT Winner
2020 ECHL All-Star Classic
2020 ECHL ASC: Revisiting Preseason Picks
Viel, Barracuda Battle Back to Beat Wild
The Sin Bin is the premier source for coverage of the AHL, ECHL, and SPHL. We serve readers across the United States and Canada with team-based reporting, podcasts and more.
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The Web Design Business : Training, Education, Online Courses, Web Design and Development Fields is devoted to resources for Web design and development online training, online courses, or self-paced / self-study training and education in Web design, Web development, graphics design, information architecture, Web accessibility and usability and Web-related fields.
Annotated resources below include online Web-related courses, distance learning accredited universities, online business schools, online accredited universities, college courses, and other reputable online courses and classes for receiving Web design and development, graphics design training, education, or learning more about Web design, development, Web graphics, graphics design, and related areas. Some offer university degrees, some offer Web design degrees or certificates, and other types of completion certifications in Web design and related class majors.
Do you know of some good online or self-paced courses, distance learning programs, online university extensions, or other sources that could help with Web design or development education? Recommendations are welcome and encouraged!
Sessions offers more than sixty individual courses and certificate programs in graphic design, Web design, digital arts, multimedia, and business marketing design. You'll undoubtedly recognize faculty names such as Christopher Schmitt, Molly E. Holzschlag, and reknowned photographer Ken Milburn. These courses and programs prepare students for careers in the design industry by providing a rounded education in the skills and competencies necessary for professional success.
Download lectures and assignments from your student website and study them at your convenience.
Login to class at least four days per week for University of Phoenix or three days per week for Axia College of University of Phoenix classes. You choose the days and times.
Build teamwork skills by collaborating on learning team assignments.
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text:
Solar-powered plane completes Pacific crossing
International . Moderate
The world's largest solar - powered aircraft, Solar Impulse 2, has completed a three - day flight over the Pacific Ocean, a media report said on Sunday.
It flew over San Francisco's Golden Gate Bridge on Saturday at around 5:15 p. m. as it prepared to land in California, BBC reported.
The plane took off from Hawaii on Thursday, where it underwent repairs for the past eight months after its batteries were damaged during the flight from Japan.
This is the ninth leg of its attempt to fly round the world.
"I crossed the bridge. I am officially in America, " said pilot Bertrand Piccard as he flew above San Francisco Bay.
The plane started its journey in March 2015 in Abu Dhabi and it crossed Oman, India, Myanmar, and China.
The five - day, five - night crossing set a record for the longest ever non - stop solo aeroplane journey.
It then flew to Japan, before undertaking a 8, 924 km passage to Hawaii. The trip has involved two pilots - - Piccard and his business partner, Andre Borschberg - - flying separate legs.
The landing at the Moffett Airfield, located in Mountain View in Silicon Valley, is being delayed until winds drop.
The Solar Impulse gets all its energy from the sun - through the 17, 000 photovoltaic cells that cover the top surfaces of the craft.
These power propellers during the day, but also charge batteries that the vehicle's motors can then call on during the night.
The distance on this leg was 4, 000km or 2, 200 nautical miles.
Piccard and Borschberg intends to reach New York by the beginning of June, to begin preparations for an Atlantic crossing.
- - IANS
preparations photovoltaic undertaking propellers officially vehicle's underwent completed beginning batteries


Receiving emails from people globally is something I'm humbled by. Not only are the messages candid and sometimes confronting but so often they hold profound and brilliantly simple messages that I believe could help everyone who reads them.
Today's email of the week is from a girl named Sally and her concept of helping yourself so that you can help others is a message I strongly believe in.
Sally, I read all the messages!!
For all those reading who think they could do with spending a little time focusing on their values and passions, please don't wait- follow in the footsteps of Sally and treat yourself this weekend. you never know, it could help you and those around you!


What Are Website Terms and How Do They Protect Your Business?
While most people will skim through terms and conditions (at best!), having such a page on your website is of utmost importance.
The specifics depend on the website niche, the types of information, and the functionalities that the website gives access to. Legally speaking, terms and conditions are rules by which website visitors have to abide in order to access the respective content or service.
So many website owners do not put a lot of thought into crafting the terms and conditions page. In fact, they opt for a generic template – a serious mistake. The respective page is important because it can limit your liability in case a visitor or a customer may be considering taking you to court. Its purpose is to also protect the content and suggest permissible uses. Whenever a legal issue occurs, a court will examine the content of the terms and conditions page to determine its comprehensiveness.
The biggest question here is whether website terms and conditions are enforceable. The answer is that it depends on the circumstances. A court will examine situations on an individual basis, which is why having detailed terms of service is always a smart thing.
The page is, in essence, an agreement. It establishes the rules that website visitors must follow when interacting with the respective online platform. When the rules are clearly outlined, abusive behavior can be sanctioned. Such abusive behavior could consist of spamming, posting racist content, copying content from the website, etc. On the basis of these rules, a website administrator can terminate accounts without prior notice. When a website visitor fails to follow the established protocol, the termination clause of the usage agreement can be invoked.
A disclaimer typically states that the website owner cannot be held accountable for errors, outdated information, information published by website visitors, and readers taking information out of context to use it for a specific purpose.
To accomplish these goals, you cannot rely on generic terms and conditions, or on a text that is copied from another website (unfortunately, a common approach that many website owners adopt).
In order to experience the full range of protection, you need a page that is entirely crafted for the needs of your business and the purposes of your website. Working with a terms and conditions specialist attorney can give you peace of mind and the knowledge that all of the essentials have been covered.
What Is DMCA And Does It Apply To My Business?
The information provided on and through this website is not legal advice and no attorney-client relationship has been created herein. This website is for informational purposes. Those who sign up to receive email updates, as well as other website visitors, will be receiving advertising information about legal services but should not act upon this information without seeking professional legal counsel. You may opt-out of receiving communications from me and this website at any time by following the instructions in the emails you receive.


text:
Penn State Learning awards two undergraduates for study group leadership
News and Research Spotlights
New tool reveals DNA structures that influence disease
Eleven Eberly faculty featured as Highly Cited Researchers in 2019 by Clarivate
Alexis Davison on becoming a Beckman Scholar
Ernest C. Pollard Lecture Set for November 18, 2019
Showalter honored with Distinguished Faculty Mentoring Award
Two undergraduate winners have been selected to receive Outstanding Guided Study Group Leader Awards through Penn State Learning for the spring 2019 semester.
Miranda Chen and Taylor Hufnagel earned certificates of recognition for their work within Penn State Learning and a stipend of $500, thanks to the generosity of an anonymous donor and former study group leader.
This award acknowledges and rewards exemplary leaders who demonstrate academic excellence and integrity in their own studies and through the work undertaken while guiding their peers in co-curricular learning environments.
These leaders carry out their assigned roles and responsibilities in an exemplary manner by promoting and incorporating collaborative learning skills and practices into their tutorial sessions. They also lead by example, serve as a role models and mentors to peers and maintain a positive rapport with course-related faculty and staff. Finally, they must sustain welcoming, academically stimulating and challenging learning communities in which all participants can engage in knowledge acquisition, exchange and transfer. The recipients of this semester's award embody the criteria outlined above, as noted in the following comments from their nominators.
Miranda Chen '19 led the STAT 250: Biochemistry and molecular biology GSG for three semesters. Michelle Paret, a teaching lecturer in statistics, nominated Chen for the award and praised her work.
"Miranda is very proactive … And she is willing to help with anything that needs to be done to make the course successful," Paret said. "There is nothing more that I could expect from a GSG leader. Miranda is well prepared, intelligent, and the ideal role model that other students should aspire to be.
Chen graduated in May 2019 and is currently working for AmeriCorps Vista.
Taylor Hufnagel is a junior chemistry major and theatre minor. She is currently in her third semester leading the CHEM 110: General chemistry GSG. In addition to her role as GSG leader, Hufnagel has also worked as a learning assistant for CHEM 110. According to Todd Pontius, a lecturer in chemistry, she has been an asset to the students enrolled in the course.
"Taylor embodies the traits of an outstanding educator," Pontius said. "Through composite of her actions and attitude — her meticulous planning of sessions, her engaging demeanor, and her empathetic approach to education — she demonstrates not only a natural knack for teaching, but also a determination to continually improve as an educator. Given what she has already demonstrated and the work that she puts in, I have no doubt that she will continue to work fervently to actualize her extraordinary potential as an educator."
Additional information about the award process and other ways to give to Penn State Learning is available here. In addition to providing no-charge guided study groups supporting a wide range of courses, Penn State Learning also provides tutoring in mathematics, world languages, public speaking and writing.
Penn State Learning is part of Penn State Undergraduate Education, the academic administrative unit that provides leadership and coordination for University-wide programs and initiatives in support of undergraduate teaching and learning at Penn State. Learn more about Undergraduate Education at undergrad.psu.edu.