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Edward Coke: Common Law Protection for Liberty
Coke Contributed to America's Independent Judiciary and Judicial Review
Jim Powell
Why were civil liberties first secured in England?
One important reason was the development of common law principles and precedents independent of a ruler. Edward Coke (pronounced "Cook") was more responsible for this than anybody else. Murray N. Rothbard called him a "great early seventeenth century liberal." Winston S. Churchill observed that "His knowledge of the Common Law was unique." Historian George Macaulay Trevelyan considered him "one of the most important champions of our liberties." F.A. Hayek referred to him as "the great fountain of Whig principles."
Coke had a gift for expressing common law principles in unforgettable ways. "The common law," he wrote, "is the best and most common birth-right that the subject hath for the safeguard and defense, not merely of his goods, lands and revenues, but of his wife and children, his body, fame and life. . . . No man ecclesiastical or temporal shall be examined upon secret thoughts of his heart. . . . the house of an Englishman is to him as his castle."
As a lawyer and judge, Coke worked with arguments based on precedents, which one might think would mean that if he couldn't cite precedents he didn't have a case. But he was the best at discovering precedents for liberty. If at times he claimed that precedents went back farther and proved more than they actually did, he was almost always right about fundamental principles.
His Reports and Institutes did much to give the English a coherent constitution. Even his rival Francis Bacon conceded: "Had it not been for Sir Edward Coke's reports . . . law by this time had been almost like a ship without ballast; for that the cases of modern experience are fled from those that are judged and ruled in former times."
Although Coke embraced conventional religious beliefs, he did much for religious toleration. As Chief Justice of common law courts, he worked to keep many cases out of ecclesiastical courts that sentenced religious dissenters to be tortured, imprisoned, or burned. He appointed Puritan ministers to the churches he owned. He hired an independent-minded secretary named Roger Williams, who went on to establish Rhode Island as a sanctuary for religious toleration. At Coke's death, his personal library included major Puritan writings of the previous half century.
Coke was more than a jurist; he deserves much credit for the emergence of representative government. Under Queen Elizabeth I, Parliament was a cipher for the monarch. Members of Parliament lacked the ideological vision as well as practical experience to provide effective opposition or leadership. In 1621, 1624, 1625, and 1628, Parliament spearheaded attacks against the ministers of James I and Charles I. Parliament articulated constitutional principles and took initiative in formulating policy. Coke certainly wasn't the only important figure in these parliaments, but he framed the issues, served on more parliamentary committees, delivered more committee reports and speeches than anybody else. He did much to secure the principle that ministers must be accountable for their actions—a critic remarked that Coke "would die if he could not help ruin a great man every seven years." His ideas helped inspire the revolution which, two decades later, toppled Charles I.
"Coke's great influence both in the Commons and in Parliament as a whole is easily explained," according to Wesleyan University historian Stephen D. White. "His extensive governmental experience both in and out of Parliament and his formidable legal reputation naturally brought him respect from other members. He had held many high offices in both central and local government. . . . He had participated in every meeting of Parliament since 1589, had served as Speaker of the Commons in 1593, and was an expert on parliamentary precedents and procedure. And his published writings and his years as a judge and legal officer of the crown had established his reputation as the most eminent legal authority of the era."
Coke has had an enormous influence in America. Coke's principal legacy: the independence of the judiciary and the principle that judges may overturn statutes which are contrary to the Constitution.
An Imposing, Difficult Man
Biographer Catherine Drinker Bowen noted that "Coke stood out above a crowd, a noticeably handsome man, tall, big-boned, inclined to spareness. His face was oval and a trifle long; between mustache and pointed short beard the lower lip showed full and red. Dark hair, cut even with the ears, had as yet no trace of gray but had begun to recede at the temples, accentuating the height of his forehead. Coke's eyebrows were heavy and smooth, his complexion somewhat swarthy; there were few lines to his face. His eyes, large, dark, and brilliant, bore the watchful look of a man ambitious and self-contained."
Coke, to be sure, was often a difficult character. "Pedant, bigot, and brute as he was," historian Thomas Babington Macaulay wrote in his essay on Bacon, "he had qualities which bore a strong, though a very disagreeable resemblance to some of the highest virtues which a public man can possess. . . . He behaved with gross rudeness to his juniors at the bar, and with execrable cruelty to prisoners on trial for their lives. But he stood up manfully against the King and the King's favourites. No man of that age appeared to so little advantage when he was opposed to an inferior, and was in the wrong. But, on the other hand, it is but fair to admit that no man of that age made so creditable a figure when he was opposed to a superior, and happened to be in the right."
Edward Coke was born with law in his blood, February 1, 1552, in Mileham, Norfolk, England. His father, Robert Coke, was a lawyer practicing in London and Norfolk. His mother, Winifred Knightley, was the daughter of an attorney.
After attending the Norwich Free Grammar School for seven years, Coke entered Trinity College, Cambridge, and was four years there. Destined for a legal career, he began studying at Clifford's Inn in 1571 and the next year transferred to Inner Temple. These were guilds where young men went to acquire knowledge of common law that would be needed for professional practice. Common law was the law applying to everyone. It included Saxon legal customs, standard commercial practices for resolving disputes, parliamentary statutes, judicial decisions and, yes, some royal decrees. In addition, there were treatises going back several hundred years, written by respected judges like Henry Bracton, Anthony Fitzherbert, John Fortesque, John Glanville, and Thomas Littleton. Students of the common law had to learn "law French," the language of common law pleadings, and Latin, the language in which medieval court records were kept. Coke began a lifelong practice of arising at 3:00 A.M. so that he could gain several hours for learning more about law before the day began.
Coke started practicing law in 1578. He spent a lot of time in Coventry, Essex, Norwich, and London, and he always had a notebook which he filled with his observations about courtroom proceedings. He was to continue recording his observations for more than four decades—they became the basis of the published works that secured his reputation.
When Coke was 30, he married 17-year-old Bridget Paston, who descended from a wealthy Suffolk family and came with a dowry of \P30,000. He developed ties with Lord Burghley, a councilor to Queen Elizabeth. After a succession of minor positions, he was appointed Solicitor General by Queen Elizabeth in 1592. She named him speaker of the House of Commons the following year, and in 1594 chose him over Francis Bacon to be attorney general.
Bacon and Coke were to be rivals for nearly three decades. Bacon, nine years younger than Coke, was the son of an Elizabethan courtier, the Lord Keeper of the Great Seal. Bacon's father died before he could buy his son an estate, so he had to work for a living. He learned law at Gray's Inn, then pulled political strings and got elected to Parliament in 1584. He urged religious toleration for loyal citizens, but otherwise he was a thoroughgoing government man. As a consequence, he acquired estates and secretaries, including Thomas Hobbes, who later distinguished himself as a theoretician for political absolutism.
In his lucid essays (first edition, 1597), Bacon expressed admiration for Machiavelli's political writings and declared that governments shouldn't be judged by the moral standards that apply to ordinary people. Bacon made clear his distrust of Parliament and his belief in political absolutism. He approved of war because it promoted a strong state.
Coke, meanwhile, prospered as a vigorous defender of royal prerogative and enforced laws against religious dissenters. His wife died, and he soon remarried Lady Elizabeth Hatton, granddaughter of Lord Burghley and niece of Robert Cecil, the most influential minister of Queen Elizabeth and, for a while, of her successor, James I. This second marriage was rocky, but it brought him even more property.
Coke, unlike Bacon, was critical of patents of monopoly which the government had issued since 1552 to generate revenue. The patents were issued for mechanical inventions, chemical processes, and other things. There were many complaints because patents of monopoly benefited a few individuals at the expense of everybody else. Coke handled some of the most important cases against monopolists. As he explained, "it appeareth that a man's trade is accounted his life, because it maintaineth his life; and therefore the Monopolist that taketh a man's trade, taketh away his life."
England had the lowest taxes in Europe, but toward the end of her reign Elizabeth needed more revenue. After the Spanish Armada was smashed in 1588, Spain built more ships for another possible attack on England, requiring new English defenses. Elizabeth was at war with France, too. Bacon recognized the danger of taxation. In 1593, he remarked: "wee breed discontentment in the people and in a cause of Jopardie her Majesties saftie must consist more in the love of her people then in their welthe."
The Ascension of James I
Elizabeth died on March 24, 1603, and was succeeded by the 37-year-old James VI of Scotland, who became James I of "Great Britain"—he revived the name from early medieval times. Elizabeth, he soon discovered, left a pile of debts. "My lord treasurer," wrote one official in September 1603, "is much disquieted how to find money to supply the King's necessities." This official found "all means shut up of yielding any relief." London bankers twice refused to loan the government any more money, claiming they had suffered big losses because of the plague, but Venetian ambassador Nicolo Molin reported: "ill-will is also suspected as the cause."
A monarch was supposed to pay the cost of maintaining his palace and retainers with hereditary income, while Parliament financed national defense and wars. But James asked Parliament—taxpayers—to help cover his extravagant royal household expenses.
The king's personal habits made his political problems worse. "James was a loutish savage," wrote historian Paul Johnson. "When hunting, he liked to plunge his bandy legs into the stag's bowels. . . . He delighted in getting the young court ladies drunk, and seeing them collapse in vomit at his feet. He would sit there, laughing. . . . Everything James did, and everything he omitted to do, was certain to evoke protest."
Attorney General Coke made his reputation as a tough prosecutor in three sensational trials. First came the Earl of Essex, an adventurer who had blundered in Ireland, disobeyed Elizabeth's orders, and burst into her private quarters (1601); Walter Raleigh, who allegedly plotted against James (1603); and Guy Fawkes and his fellow Catholic conspirators who dug a tunnel for 35 barrels of gunpowder under Westminster Palace, which they hoped to blow up when the King and royal family gathered for the opening of Parliament (1605). Coke caused quite a stir as he repeatedly underscored key points, displayed his eloquent Latin, picturesque English, and formidable knowledge of legal precedents.
Bacon and Coke were at each other's throats. Parliament turned down James's request for more revenue, and he attempted an "end run" around Parliament by doubling tariffs, an idea backed by Bacon. James's "New Impositions" meant that imports were subject to the delay and expense of being inspected twice. John Bates, an importer of Venetian currants, tried to evade the "New Impositions" and was brought before the Court of the Exchequer. It ruled that tariff policy was the king's jurisdiction, not Parliament's. The House of Commons named a commission to look into the matter. Coke was the point man. He insisted the king's jurisdiction was to protect England against foreign enemies, but the "New Impositions" were for revenue, and Parliament's approval was required.
"It is odd, indeed," noted biographers Hastings Lyon and Herman Block, "that Bacon, the philosopher, should have failed to apprehend what Coke, the legist, apparently did see: namely, that if the enforced loans, benevolences and monopolies were permitted, the King would have a nearly complete system of extra-Parliamentary taxation, and Parliament would soon become an unnecessary assembly, with a consequent corruption of the State into tyranny."
Chief Justice of the Court of Common Pleas
In June 1606 James appointed him Chief Justice of the Court of Common Pleas, which mostly handled private actions between citizens. This was a position where Coke would have to do the king's bidding or be dismissed. The "New Impositions" didn't generate enough revenue, and soon James issued a writ which forced people in England's seaports to equip his fleet. (Elizabeth had issued such a writ but there was more political support for it because she faced the Spanish Armada.) Coke authored the "Protestations from the House of Commons," which declared, in part, that "from the time of Magna Carta the liberties, franchises, privileges and jurisdiction of Parliament are the ancient and undoubted birthright and inheritance of the subjects of England." This outraged James.
Coke clashed with the king on fundamental issues. "The state of monarchy," James maintained, "is the supremest thing upon earth. For Kings are not only God's lieutenants upon earth and sit upon God's throne, but even by God himself they are called Gods . . . for they exercise a manner or resemblance of divine power upon earth." James, like Elizabeth, considered judges to be agents of the crown. They certainly weren't supposed to render independent decisions.
English common law was a murky field, and Coke made the most of it when countering the king. Judicial decisions weren't systematically based on precedents, because it was difficult to determine what the precedents were. "Argument from decided cases, though frequent and persuasive," noted English constitutional law scholar Charles M. Gray, "did not dominate courtroom dialogue. Prior decisions were sometimes followed by judges who professed not to agree with them, but they were sometimes rejected for reason or simply ignored."
On November 13, 1608, there was an epic confrontation between James and Coke. James described judges as "shadows and ministers." Coke replied that "the King in his own person cannot adjudge any case . . . but that this ought to be determined and adjudged in some Court of Justice, according to the law and Custom of England."
James countered "that he thought the law was founded upon reason, and that he and others had reason as well as the Judges." Coke: "God had endowed his Majesty with excellent science and great endowments of Nature. But his Majesty was not learned in the Laws of his Realm of England; and Causes which concern the Life, or Inheritance, or Goods, or Fortunes of his Subjects are not to be decided by natural Reason but by the artificial Reason and Judgment of Law, which requires long Study and Experience before that a man can attain to the cognizance of it."
James was outraged, as one observer reported: "his Majestie fell into that high indignation as the like was never knowne in him, looking and speaking fiercely with bended fist, offering to strike [Coke]."
Meanwhile, Coke labored to share his knowledge of common law. He had begun issuing an annual Report on cases in 1600, and he continued until 1616. The prefaces were in English, texts in "law French," and pleadings in Latin. "Anything that could be gleaned in Westminster, London Guildhall or the circuit courts in the counties he set down in his own form and fashion, adding comment, aside, comparison," noted biographer Bowen. "No law reports had hitherto been half so comprehensive; Coke must have lived and walked and sat and talked with notebook in hand. At once the books became—as Blackstone indicated in 1765—an intrinsic authority in the courts of justice."
Bacon, whom James had named Solicitor General in 1607, considered the king legibus solutus—above the law. Lord High Chancellor Ellesmere, the highest judicial official, declared Rex est lex loquens—"the king is the law."
Bacon advised James, in Peacham's Case, to try influencing court decisions by presenting judges with the allegations in a case and asking their opinion before trial. Edmund Peacham was a Puritan minister who criticized a bishop's religious intolerance, for which he was brought before the High Commission. As Bacon reported to the king, "Upon these interrogatories, Peacham was examined before torture, in torture, between torture, and after torture; nothing could be drawn from him, he still persisting in his obstinate and inexcusable denials and former answers." Coke wouldn't cooperate with Bacon, saying that "taking of opinion is not according to the custom of this realm." Coke considered it unfair to present judges with allegations when neither a defendant nor defense counsel were present for cross-examination. Bacon told James that Coke's "over-confidence, doth always subject things to a great deal of chance." Peacham died in prison.
In Bonham's Case, Coke ruled that the common law stood above Parliament. The case involved Dr. Thomas Bonham, jailed for practicing medicine without a certificate issued by the Royal College of Physicians. He filed suit for false imprisonment. Coke observed that according to the Royal College's statute of incorporation, it pocketed half the fines from violators like Bonham. This, he noted, meant the Royal College was both a party and judge in every action. Citing a common law principle, Aliquis non debet esse judex in propria causa [Nobody should be judge in his own cause], Coke ruled: "in many cases the common law will control acts of Parliament and some times adjudge them to be utterly void; For when an Act of Parliament is against common right and reason, or repugnant, or impossible to be performed, the common law will control it and adjudge such Act to be void." This was the most controversial decision he ever rendered.
James asserted his power by issuing proclamations that he insisted had the force of law. In September 1610, Coke presented his view of these proclamations to the Privy Council, which had the responsibility of advising the king on executive, judicial, and financial business and seeing that the king's will was done. "All indictments," he observed, "conclude with the words, Against the law and custom of England, Contra legem et consuetudinem Angliae; or against laws and statutes, Contra leges et statuta. But I never heard an indictment to conclude, Contra regiam proclamationem; against the king's proclamation." Coke went on to review the legal history of royal proclamations. Accordingly, the Privy Council resolved "That the King by his proclamation cannot create any offense which was not an offence before, for then he may alter the law of the land by his proclamation in a high point; for if he may create an offence where none is, upon that ensues fine and imprisonment. Also the law of England is divided into three Parts: Common Law, Statute Law, and Custom; but the King's Proclamation is none of them."
Coke issued "prohibitions" aimed at curbing the power of ecclesiastical courts, especially the High Commission, which imprisoned individuals for preaching Nonconformist doctrines. A prohibition ordered the ecclesiastical courts not to proceed with a case if there was any reason it might belong in a common law court. Coke defended his prohibitions by showing how they had long been issued by common law courts. Moreover, he explained how, during the past 60 years, the High Commission had expanded its power beyond what had been specified in any statute.
James called Parliament in 1610 because he needed money, but Members drew up a Petition of Grievances. Among the principles at stake: "there is none which they have accounted more dear and precious than this, to be guided and governed by the certain rule of law, which giveth to the head and the members that which of right belongeth to them, and not by any uncertain and arbitrary form of government."
James took offense: "We are an old and experienced king, needing no such lessons." Coke rose to defend the Petition: "I never spake but mine own conscience. The privileges of this House is the nurse and life of all our laws, the subject's best inheritance. If my sovereign will not allow my inheritance, I must fly to Magna Carta and entreat explanation of his Majesty. Magna Carta is called Charta libertatis quia liberos facit. . . . The Charter of Liberty because it maketh freeman. When the King says he cannot allow our liberties of right, this strikes at the root. We serve here for thousands and ten thousands."
James fumed, "The House of Commons is a body without a head. The members give their opinions in a disorderly manner. At their meetings nothing is heard but cries, shouts, and confusion. I am surprised that my ancestors should ever have permitted such an institution to come into existence. I am a stranger, and found it here when I arrived, so that I am obliged to put up with what I cannot get rid of."
James dissolved Parliament the following year, and Coke stood alone against the king. He issued two rulings that limited the discretionary power of the High Commission. James snapped that the rulings were "of a nature extraordinary and showing more the perverseness of [Coke's] spirit than any other prohibitions." James summoned Coke and several like-minded judges to explain themselves. Coke endured a three-day interrogation.
Chief Justice of the King's Bench
In 1613, Bacon had an idea for taming Coke: promote him to Chief Justice of the King's Bench, which handled criminal as well as civil actions; and promise him a seat on the 12-member Privy Council. "Coke will thereupon turn obsequious," Bacon assured James. Coke became Chief Justice of the King's Bench in October, but Bacon and James were in for a surprise.
Conflict developed when James granted two income properties to the Bishop of Coventry. The grant was contested by two men who claimed the property was theirs—this became known as the Case of Commendams (which meant the bishop could collect the income while having somebody else perform whatever services might be required). Coke and his fellow judges were about to conduct a hearing on the dispute when James ordered them not to proceed, because his prerogative was at issue. Coke countered that "The stay required by your Majesty was a delay of justice and therefore contrary to law and the Judges' oath." Bacon, who had become Attorney General and a member of the Privy Council, denounced Coke, for behaving improperly. James stepped up the pressure. The judges relented, except for Coke who, a court reporter noted, told the king "That when the case should be, he would do that should be fit for a Judge to do." Coke was dismissed as Chief Justice.
"Coke had not striven in vain," noted historian George Macaulay Trevelyan. "He had enlisted the professional pride of the students of the common law against the rival systems of law specially favoured by the Crown in the Star Chamber, the admiralty and the Ecclesiastical Courts. He had turned the minds of the young gentlemen of the Inns of Court, who watched him from afar with fear and reverence, to contemplate a new idea of the constitutional function and of the political affinities of their profession, which they were destined in their generation to develop in a hundred ways, as counsel for England gone to law with her King."
Coke was so desperate to regain a high position that he pressured his 14-year-old daughter, Frances, to marry John Villiers, the impotent older brother of James's most influential adviser, George Villiers (later the Duke of Buckingham). Bacon filed a complaint against Coke for riotous behavior. This was surely the low point of Coke's career. Although he didn't get back his judgeship, he regained his position on the Privy Council. Apparently, the king and Buckingham still hoped that showing him some favor would undermine his independent spirit. Bacon was subsequently appointed Lord High Chancellor, which made him the highest-ranking person outside the royal family.
James summoned Parliament, which met on January 13, 1621, the first time in seven years. James again needed money, and Members intended to negotiate about their grievances.
Among other things, Parliament was intent on limiting royal power by rooting out corruption. The top target was Buckingham, who had gained considerable influence with the king. After he had sent Walter Raleigh to attnd he was summoned before the House of Lords. He apologized for his brothers who had taken bribes and avoided prosecution by sheer political clout. The House of Commons turned to drafting a bill which would curb monopolies.
Bacon's Downfall
The House of Commons then formed a Committee for Inquiring into Abuses in the Courts of Justice. A trail of dubious payments led to Bacon's door. Coke soon emerged as the leading inquisitor. The inquiry against Bacon led eventually to the charge of bribery.
Coke objected to James's proposal that a special commission should investigate the charges, because it couldn't be counted on to recommend prosecution. Accordingly, Parliament began impeachment proceedings for the first time in 160 years. It reported a growing list of bribes. Since the bribes had been delivered in the presence of his servants, Bacon didn't mount a defense. "Condemn and censure me," he wrote the House of Lords—thereby offending the House of Commons.
He was impeached, dismissed as Lord High Chancellor, fined £40,000, imprisoned in the Tower of London, then banished from London and the law courts. The historian Lord Acton later remarked, "the Commons, guided by the most famous English lawyer, Coke, struck down Bacon, and deprived the Stuarts of the ablest counsellor they ever had. Impeachment and responsibility of ministers remained."
Coke Imprisoned
On December 18, James dissolved Parliament, and soon afterwards Coke was summoned to appear before the Privy Council. "You have forgotten the duty of a servant, the duty of a Councilor of State and the duty of a subject," he was told. Guards escorted him to a damp, bitter-cold, urine-soaked cell in the Tower of London. Denied access to books, he wrote Latin verses with pieces of coal. He was interrogated by the President of the Privy Council who reported: "I charge you therefore with treason. I have heard you, Sir Edward, affirm that by law he is a traitor who goes about to withdraw subjects' hearts from their King." But after seven months of going through Coke's personal papers and investigating his affairs, crown officials concluded they couldn't find any evidence of wrongdoing. He was released. No charges were ever filed.
The Parliament of 1624 came on the heels of a four-year business depression, and there were a lot of complaints about monopolies. Coke led the attack against monopolies over wool, brick-making, glass-making, salmon fishing, and the transcribing of wills.
James died on March 27, 1625. He had achieved a long period of peace which enabled the English to prosper. But he left a debt of over \P200,000. His 24-year-old son became King Charles I, and right away he began spending money at a reckless pace. Then, as Buckingham had arranged, he married the 15-year-old French Catholic princess, Henriette Marie, who came with an 800,000-crown dowry; the idea here was that if there wasn't going to be a marriage to promote peace with Spain, then there should be a marriage to help secure an ally against Spain if needed.
The wedding took place at Notre Dame de Paris, and Charles was represented by a stand-in, the Duc de Chevreuse, because of the risk of Charles falling in the hands of a foreign power. Buckingham himself escorted the new queen back to England, biographer John Bowle reported, with "fifteen lords, twenty-four 'knights of great worth', and far too many pages." Henriette Marie was accompanied by her servants—a bishop and 28 priests.
Charles summoned Parliament in May 1625 and faced mounting skepticism. For openers, Members were distracted because several thousand people a week were dying from plague in London. Buckingham had approved military adventures against France and Spain which were fiascos, convincing many Members of Parliament that the previous subsidy they approved was a mistake. Buckingham proposed more military adventures, one to attack Spain and another to save the Protestant Elector of Palatine—which meant becoming embroiled in the conflict that would become known as the Thirty Years War. Parliament voted for two small subsidies and authorized Charles to spend customs revenue only for a year. Charles was in trouble because the Lord Treasurer reported the government didn't have any money or credit left. Assuming Parliament would give him what he needed, Charles had drawn from his own resources to pay \P136,000 for a subsidy to Denmark, wages for British soldiers serving in the Low Countries, and food and ammunition for the British navy. "By the grace of God," Charles remarked, "I will carry on the war if I risk my crown." He dissolved Parliament.
Short of money, Charles resorted to conscription. The government rounded up as many able-bodied men as they could find around the port towns. Reportedly many men paid bribes to avoid being conscripted. The government didn't spend money on army barracks, so it forced thousands of private individuals to feed and house the recruits. This, of course, provoked widespread resentment, and the result was martial law. The first adventure, against Spain, was a fiasco which Charles and Buckingham tried to cover up, and by the end of the year Charles pawned some of his jewelry and silverware for more money.
Charles summoned Parliament again. In an effort to undermine resistance, he appointed his half-dozen most troublesome opponents, including Coke, as sheriffs, which kept them out of parliamentary proceedings for at least a year. But this enabled a formidable orator, John Eliot, to step forward as a leader. Though he had befriended Buckingham as a young man, he witnessed the return of wretched British soldiers from one of Buckingham's disastrous expeditions against Spain, and he resolved to bring down the Duke. Eliot declared that Parliament wasn't a tool of the king and that Members were morally obligated to follow their conscience. He urged that Buckingham be impeached.
Asked for further subsidy, Members of the House of Commons began impeachment proceedings against Buckingham. Charles responded by ordering Eliot and another outspoken Member, Dudley Diges, imprisoned in the Tower of London. But the Commons charged Buckingham anyway, for failing to suppress piracy in the English Channel, for choosing incompetent leaders of the Spanish expedition, for taking bribes and for scheming with Catholics. On June 12, 1627, Charles dissolved his second Parliament, saving Buckingham's skin.
"At the back of the Parliamentary movement in all its expressions lay a deep fear," explained Winston S. Churchill. "Everywhere in Europe they saw the monarchies becoming more autocratic. The States-General, which had met in Paris in 1614, had not been summoned again; it was not indeed to be summoned until the clash of 1789. The rise of standing armies, composed of men drilled in firearms and supported by trains of artillery, had stripped alike the nobles and the common people of their means of independent resistance. Rough as the times had been in the earlier centuries, 'bills and bows' were a final resource which few kings had cared to challenge. But now on the Parliamentary side force as yet was lacking."
Needing money, Charles resorted to high-handed revenue-raising measures, and on March 27, 1628, Charles summoned Parliament for the third time.
Parliament was aboil over squandered money, conscription, billeting of soldiers in private homes, forced loans. Citing common law precedents, Coke maintained that "the King cannot order any man arrested, because there is no remedy against him." Coke insisted people could be legitimately imprisoned only upon the order of a judge. On March 21, 1628, Coke presented a bill which specified that no one could be imprisoned more than three months without being brought to trial. The House of Commons approved resolutions saying that nobody should be imprisoned unless the government cited the alleged crimes, and the writ of habeas corpus must not be denied.
The House of Commons approved the subsidies that Charles asked for, provided he would agree to respect the liberties of Englishmen. Charles resisted, and the House of Lords was reluctant to break with him. The Lords eventually approved a declaration that the Magna Carta remained in force and that the king must not infringe on "any of his loyal people in the property of their goods or liberty of their person." But then the Lords hedged, suggesting that "as touching his majesty's royal prerogative intrinsical to his sovereignty and entrusted to him from God . . . in the case, for the security of his Majesty's Royal person, the common safety of his people, or the peaceable government of his kingdom, his Majesty shall find just cause, for reason of State, to imprison or restrain any man's persons, his Majesty would graciously declare that within a convenient time, he shall and will express the cause of the commitment or restraint, either general or special."
Coke thundered: "Is the confirmation of the Great Charter a matter of grace? What are just liberties? Who were the best of his Majesty's predecessors? We see what advantage they have that are learned in the law in penning articles above them that are not, how wise soever. What is intrinsical prerogative? It is a word, we find not much in the law. Intrinsical prerogative is not bounded by any law, or by any law qualified. Admit this intrinsical prerogative, and all our laws are out. This intrinsical prerogative it appears is entrusted to the king by God. It is jure divino [divine law]. No law can take it away. His majesty can commit when he pleases."
When the king continued to resist, Coke proposed on May 8 that Parliament adopt a Petition of Right for the king's agreement on "1. The personal liberty of the subject. 2. His propriety in his goods. 3. Unbilletting of soldiers. And 4. Silencing of martial law in time of peace."
Charles dispatched a letter to the Lords, saying he must be able to imprison people without filing specific charges. For 18 days, the Lords tried to figure out how they could draft something agreeable both to Charles and the Commons. Then Coke rose in the Commons and spoke: "Let us palliate no longer. If we do, God will not prosper us. I think the Duke of Buckingham is the cause of all our miseries, and till the King be informed thereof, we shall never go on with honor or sit with honor here. That man is the grievance of grievances. Let us set down the cause of all our disasters and they will reflect on him."
On June 8, Charles met both Houses of Parliament at 4:00 in the afternoon. Then he signified the words of approval which gave a bill the force of law: "Soit droict fait comme est desire."
"We reach here," wrote Churchill, "amid much confusion, the main foundation of English freedom. The right of the Executive Government to imprison a man, high or low, for reasons of State was denied; and that denial, made good in painful struggles, constitutes the charter of every self-respecting man at any time in any land. Trial by jury of equals, only for offenses known to the law, if maintained, makes the difference between bond and free."
Coke's Greatest Work
Coke retired to Stoke House in Stoke Poges, Buckinghamshire, just west of London, where he completed his life work.
Scholars traditionally wrote commentaries on established authorities, and that's how Coke proceeded with his greatest work. He prepared commentaries on Thomas Littleton's Treatise on Tenures, a fifteenth-century text about land law. "The ornament of the common law," Coke called it, "the most perfect and absolute work that ever was written in any human science, and as free from error as any book that I have known to be written of any human learning." Coke covered about 500 years of English property law.
His health declined in 1634. On June 9, he asked for a pen and paper to affirm his religious faith. While he lay dying, the government—"by order of his Majesty's Privy Council"—issued a warrant to search his house for documents which might threaten the monarchy. Police took manuscripts for his Institutes and for two unpublished volumes of Reports. Coke died at Stoke House on Wednesday, September 3, 1634, around 11 P.M. A month later, he was buried in the church graveyard at Tittleshall, about six miles southwest of Fakenham, Norfolk, next to his first wife.
Charles trashed Coke's principles. He did everything he pledged not to do in the Petition of Right, and he refused to call another Parliament for 11 years. But the principles had taken root. When the Long Parliament met in 1640, it arranged for publication of the Institutes because they "contain many monuments of the subject's liberties."
The Second Part of the Institutes appeared in 1642. In this commentary on Magna Carta and almost 40 other charters and statutes, Coke distilled the views he had promoted throughout his public life. He believed individual liberty was best protected by "due process of the common law." He asserted that "Generally all monopolies are against this great charter, because they are against the liberty and freedome of the subject, and against the law of the land." He affirmed that "The interpretation of all statutes concerning the clergy, being parcell of the lawes of the realme, do belong to the judges of the common law."
The Third and Fourth Parts of the Institutes were published in 1644. The Third Part covered a variety of crimes. Coke defined a crime, explained the penalties, and covered the legal history of it.
The Fourth Part developed his familiar themes about the role of Parliament.
Coke urged his successors in the common law: "And you, honorable and revered judges and justices, that do or shall sit in the high tribunals or seats of justice, fear not to do right to all, and to deliver your opinions justly according to the laws; for fear is nothing but a betraying of the succors which reason should afford; and if you shall sincerely execute justice, be assured of three things: first, though some will malign you, yet God will give you his blessing; secondly, that though thereby you may offend great men and favorites, yet you shall have the favourable kindness of the Almighty, and be his favorite; and lastly, that in so doing, against all scandalous complaints and pragmatic devices against you God will defend you as with a shield."
Coke inspired freedom fighters in England and the American colonies. When Roger Williams established Rhode Island, he reflected in 1652: "how many thousand times since I had the honorable and precious remembrance of his person, and the life, the writings, the speeches, and the example of that glorious light. And I may truly say, that besides my natural inclination to study and activity, his example, instruction, and encouragement have spurred me on to a more than ordinary, industrious, and patient course in my whole course hitherto."
By the time of the Glorious Revolution (1688), long-standing English grievances had been resolved. The monarchy had a Protestant succession. There was a considerable degree of religious toleration. People were protected from arbitrary search and seizure. They couldn't be held in prison unless formal charges were filed, alleging violation of a law. Above all, the power of the monarch was limited by Parliament which had achieved supremacy. Ironically, this meant judges couldn't overturn an act of Parliament. Judges could only rule that the government exceeded the powers granted by a statute—a situation which continues to this day.
The American Founders learned constitutional principles from Coke. Thomas Jefferson remarked that "Coke Lyttleton was the universal elementary book of law students and a sounder Whig never wrote nor of profounder learning in the orthodox doctrines of . . . British liberties." Patrick Henry, John Adams, John Quincy Adams, John Jay, Daniel Webster, and many other influential Americans read Coke. Joseph Story, who became a Jeffersonian Supreme Court Justice, wrote: "When I had completed the reading of the most formidable work, I felt that I breathed a purer air and that I had acquired a new power."
American constitutional historian Bernard Schwartz observed that "The influence of Coke may be seen at all of the key stages in the development of the conflict between the Colonies and the mother country."
Especially since the Constitution was ratified, an independent judiciary and judicial review have become bedrock principles of American law. While judges have made plenty of bad decisions, at least they have the power to strike down unconstitutional statutes, and sometimes they do. This is a big advance from the era when judges were everywhere intimidated into doing what a ruler wanted. Eloquent testimony to the vision, courage, and devotion of Edward Coke.
Jim Powell, senior fellow at the Cato Institute, is an expert in the history of liberty. He has lectured in England, Germany, Japan, Argentina and Brazil as well as at Harvard, Stanford and other universities across the United States. He has written for the New York Times, Wall Street Journal, Esquire, Audacity/American Heritage and other publications, and is author of six books.


text:
Home » Ethics »
Ethics, Sienna News
Rafiki Mwema x Sienna – our latest fundraising collaboration
Meet our super-limited-release, fundraising collaboration, the Jamii Pack. 100% of all profits from the sale of this gorgeous collection are going to support the work of Rafiki Mwema in Kenya.
"I always wanted Sienna to be a beauty brand that gives back. I'm so proud for us to be partnering again with Rafiki Mwema. The kids they love, care and advocate for have gone through so much, it's just not fair. The work Rafiki does to heal their trauma and keep them safe is so important."
Danielle, Sienna Founder and Creative Director
Read on to learn more about the work Rafiki does and how the funds raised will make a difference.
Rafiki Mwema means 'Loyal Friend'
We work with families, in the communities, with schools, churches, villages and with government officials to ensure the cycle of abuse is broken and that children are given the chance to live as children should.
Funds from the sale of the Jamii Pack will help Rafiki Mwema keep their doors open. Their running costs are huge, on average about AUD$40,000 per month, and when you see everything they do, you'll understand why.
From little things, big things grow
Rafiki Mwema supports 70 children under the age of 12 who have experienced sexual abuse. The children live in therapeutic houses – there are two houses for girls and two for the boys – where they can be safe, loved and supported while they heal. Rafiki also supports another 130 children who have left their therapeutic homes via the Rafiki Outreach Team. As if all this wasn't enough, they have also organised, funded and installed two video links in local courts in Kenya so children can testify against their abusers safely, acquired a farm, then built a school on it, and started a weekly food program in town. Rafiki also runs regular training on topics like Building Attachments and Living with Trauma in the UK, Australia and Kenya.
Unbelievably, all this incredible work is facilitated via fundraising organised by Sarah Rosborg and a small group of wonderful volunteers who are based in the small seaside village of Lennox Head. Sarah's passion and dedication to making a difference are just extraordinary. You can see why we were moved to help.
Meet Sarah Rosborg
We spoke to Sarah about how she keeps going when the work is hard and the children have experienced so much trauma, so young.
There are days when I feel like I physically cannot continue. The sadness can be overwhelming and it can feel like we're not making a difference. But when I travel to Kenya I can SEE the change with my own eyes. I see that the future for that child HAS changed through our work and you never know where that can lead. We want to break the cycle of abuse so these kids can grow up and be balanced and loving adults… I would like to think someone would fight for Lovisa (Sarah's daughter) if I was not here. I believe we owe it to the world to honour our good life, but we should also be helping those who are not so lucky."
Are you crying? We're crying.
The three colours in Sienna x Jamii Pack are gorgeous, of course, but more than that, Sarah told us these colours – Huruma (Empathy), Upendo (Love) and Upunyaji (Healing) – represent all the children cared for by the Rafiki staff. Pass a tissue, please.
Head to the Rafiki Mwema website to read more about what they do. If their work resonates with you and you want to help Rafiki keep their doors open, they have lots of suggestions about how to help. From writing a letter to a child in Kenya to sponsorship options, there are lots of ways to get involved and everything helps. They also have a couple of really great events coming up with heaps of special guests, including An African Affair on the Gold Coast with Celeste Barber's infamous Hot Husband.
We're pretty sure this gorgeous capsule collection will fly off the shelves and we want to say a big thank you to our beautiful customers, who appreciate a good cause as much as they appreciate a good manicure.
With gratitude from all of us at Sienna.
Newer DIY vegan face masks you need to try this weekend!
Older Sienna FAQs – Part II

redpajama_set_name: RedPajamaCommonCrawl


Which of the following contraceptive method offers continuous protection for up to 5 years?
The Pill, Norplant, and Depo-Provera injections work by inhibiting ovulation, altering the uterine lining, and thickening the cevical mucus so sperm cannot penetrate it. All three methods require prescriptions. All three are very effective in preventing unintended pregnancies, but they offer no protection against sexually transmitted diseases.
Norplant consists of 6 tubes surgically placed in the inner arm. These tubes release progesterone providing for five years of contraception.
Norplant is very convenient and highly effective (more than 99% effective.) The initial expense is great, but it is reasonable when we consider that it is efficient for five years. This method of birth control is associated with weight gain. Removal of the Norplant tubes may be difficult.
This injectable form of progesterone needs to be given every 11 weeks. Unfortunately, there is no way to reverse the medication if one is unhappy with the side effects during that time.
There are advantages and disadvantages to all modes of birth control. This method is associated with weight gain and, although many women quit having periods altogether while on this medication, spotting (irregular or unexpected menstrual bleeding) is common the first few months. It may also temporarily reduce bone mass.
This method is also highly effective (more than 99% effective) in preventing unintended pregnancies, but offers no protection against sexually transmitted diseases. There might be a delay of 9 to 18 months after stopping injections before a woman can conceive.


BOYD, Wis. — Residents are being allowed home after a gas leak prompted the evacuation of a village in Chippewa County.
Sheriff Jim Kowalczyk (koh-WAHL'-zik) says a 4-inch gas main was broken in Boyd, triggering the evacuation. The village has a population of about 550.
The Stanley Police Department posted on Facebook late Tuesday morning that the gas leak has been contained and that residents may return to their homes.
Students in Boyd were being taken to Stanley Elementary School where they were to be picked up by their parents. We Energies is on the scene.


text:
Q: Update XML using XMLStreamWriter I have a large XML and I want to update a particular node of the XML (like removing duplicate nodes).
As the XML is huge I considered using the STAX api class - XMLStreamReader. I first read the XML using XMLStreamReader. I stored the read data in user objects and manipulated these user objects to remove duplicates.
Now I want to put this updated user object back into my original XML. What I thought is that I can marshall the user object to a string and place the string at the right position in my input xml. But I am not able to achieve it using the STAX class - XMLStreamWriter
Can this be achieved using XMLStreamWriter? Please suggest.
If no, they please suggest an alternative approach to my problem.
My main concern is memory as I cannot load such huge XMLs into our project server's memory which is shared across multiple processes. Hence I do not want use DOM because this will use lot of memory to load these huge XML.

A: If you need to alter a particular value like text content /tag name etc. STAX might help. It would also help in removing few elements using createFilteredReader
Below code renames Name to AuthorName and adds a comment
public class StAx {
    public static void main(String[] args) throws FileNotFoundException,
            XMLStreamException {

        String filename = "HelloWorld.xml";

        try (InputStream in = new FileInputStream(filename);
                OutputStream out = System.out;) {
            XMLInputFactory factory = XMLInputFactory.newInstance();
            XMLOutputFactory xof = XMLOutputFactory.newInstance();
            XMLEventFactory ef = XMLEventFactory.newInstance();

            XMLEventReader reader = factory.createXMLEventReader(filename, in);
            XMLEventWriter writer = xof.createXMLEventWriter(out);

            while (reader.hasNext()) {
                XMLEvent event = (XMLEvent) reader.next();
                if (event.isCharacters()) {
                    String data = event.asCharacters().getData();
                    if (data.contains("Hello")) {
                        String replace = data.replace("Hello", "Oh");
                        event = ef.createCharacters(replace);
                    }
                    writer.add(event);
                } else if (event.isStartElement()) {
                    StartElement s = event.asStartElement();
                    String tagName = s.getName().getLocalPart();
                    if (tagName.equals("Name")) {
                        String newName = "Author" + tagName;
                        event = ef.createStartElement(new QName(newName), null,
                                null);
                        writer.add(event);
                        writer.add(ef.createCharacters("\n          "));
                        event = ef.createComment("auto generated comment");
                        writer.add(event);
                    } else {
                        writer.add(event);
                    }
                } else {
                    writer.add(event);
                }
            }
            writer.flush();
        } catch (Exception e) {
            e.printStackTrace();
        }
    }
}

Input
<?xml version="1.0"?>
<BookCatalogue>
    <Book>
        <Title>HelloLord</Title>
        <Name>
            <first>New</first>
            <last>Earth</last>
        </Name>
        <ISBN>12345</ISBN>
    </Book>
    <Book>
        <Title>HelloWord</Title>
        <Name>
            <first>New</first>
            <last>Moon</last>
        </Name>
        <ISBN>12346</ISBN>
    </Book>
</BookCatalogue>

Output
<?xml version="1.0"?><BookCatalogue>
    <Book>
        <Title>OhLord</Title>
        <AuthorName>
            <!--auto generated comment-->
            <first>New</first>
            <last>Earth</last>
        </AuthorName>
        <ISBN>12345</ISBN>
    </Book>
    <Book>
        <Title>OhWord</Title>
        <AuthorName>
            <!--auto generated comment-->
            <first>New</first>
            <last>Moon</last>
        </AuthorName>
        <ISBN>12346</ISBN>
    </Book>
</BookCatalogue>

As you can see things gets really complicated when modification is much more than this like swapping two nodes deleting one node based on state of few other node : delete All Books with price more than average price
Best solution in this case is to produce resulting xml using xslt transformation

redpajama_set_name: RedPajamaStackExchange


text:
"""Validate or replace the standard gdata authorization token."""

import filecmp
import optparse
import os
import shutil

from chromite.cbuildbot import constants
from chromite.lib import cros_build_lib as build_lib
from chromite.lib import operation

MODULE = os.path.splitext(os.path.basename(__file__))[0]
oper = operation.Operation(MODULE)

TOKEN_FILE = os.path.join(os.environ['HOME'], '.gdata_token')
CRED_FILE = os.path.join(os.environ['HOME'], '.gdata_cred.txt')

def _ChrootPathToExternalPath(path):
  """Translate |path| inside chroot to external path to same location."""
  if path:
    return os.path.join(constants.SOURCE_ROOT,
                        constants.DEFAULT_CHROOT_DIR,
                        path.lstrip('/'))

  return None

class OutsideChroot(object):
  """Class for managing functionality when run outside chroot."""

  def __init__(self, args):
    self.args = args

  def Run(self):
    """Re-start |args| inside chroot and copy out auth file."""

    # Note that enter_chroot (cros_sdk) will automatically copy both
    # the token file and the cred file into the chroot, so no need
    # to do that here.

    # Rerun the same command that launched this run inside the chroot.
    cmd = [MODULE] + self.args
    result = build_lib.RunCommand(cmd, enter_chroot=True,
                                  print_cmd=False, error_code_ok=True)
    if result.returncode != 0:
      oper.Die('Token validation failed, exit code was %r.' %
               result.returncode)

    # Copy the token file back from chroot if different.
    chroot_token_file = _ChrootPathToExternalPath(TOKEN_FILE)
    if not os.path.exists(chroot_token_file):
      oper.Die('No token file generated inside chroot.')
    elif (not os.path.exists(TOKEN_FILE) or not
          filecmp.cmp(TOKEN_FILE, chroot_token_file)):
      oper.Notice('Copying new token file from chroot to %r' % TOKEN_FILE)
      shutil.copy2(chroot_token_file, TOKEN_FILE)
    else:
      oper.Notice('No change in token file.')

class InsideChroot(object):
  """Class for managing functionality when run inside chroot.

  Note that some additional imports happen within code in this class
  because those imports are only available inside the chroot.
  """

  def __init__(self):
    self.creds = None     # gdata_lib.Creds object.
    self.gd_client = None # For interacting with Google Docs.
    self.it_client = None # For interacting with Issue Tracker.

  def _LoadTokenFile(self):
    """Load existing auth token file."""
    if not os.path.exists(TOKEN_FILE):
      oper.Warning('No current token file at %r.' % TOKEN_FILE)
      return False

    # Load token file, if it exists.
    self.creds.LoadAuthToken(TOKEN_FILE)
    return True

  def _SaveTokenFile(self):
    """Save to auth toke file if anything changed."""
    self.creds.StoreAuthTokenIfNeeded(TOKEN_FILE)

  def _ValidateDocsToken(self):
    """Validate the existing Docs token."""
    # pylint: disable=W0404
    import gdata.service

    if not self.creds.docs_auth_token:
      return False

    oper.Notice('Attempting to log into Docs using auth token.')
    self.gd_client.source = 'Package Status'
    self.gd_client.SetClientLoginToken(self.creds.docs_auth_token)

    try:
      # Try to access generic spreadsheets feed, which will check access.
      self.gd_client.GetSpreadsheetsFeed()

      # Token accepted.  We're done here.
      oper.Notice('Docs token validated.')
      return True
    except gdata.service.RequestError as ex:
      reason = ex[0]['reason']
      if reason == 'Token expired':
        return False

      raise

  def _GenerateDocsToken(self):
    """Generate a new Docs token from credentials."""
    # pylint: disable=W0404
    import gdata.service

    oper.Warning('Docs token not valid.  Will try to generate a new one.')
    self.creds.LoadCreds(CRED_FILE)
    self.gd_client.email = self.creds.user
    self.gd_client.password = self.creds.password

    try:
      self.gd_client.ProgrammaticLogin()
      self.creds.SetDocsAuthToken(self.gd_client.GetClientLoginToken())

      oper.Notice('New Docs token generated.')
      return True
    except gdata.service.BadAuthentication:
      oper.Error('Credentials from %r not accepted.'
                 '  Unable to generate new Docs token.' % CRED_FILE)
      return False

  def _ValidateTrackerToken(self):
    """Validate the existing Tracker token."""
    # pylint: disable=W0404
    import gdata.gauth
    import gdata.projecthosting.client

    if not self.creds.tracker_auth_token:
      return False

    oper.Notice('Attempting to log into Tracker using auth token.')
    self.it_client.source = 'Package Status'
    self.it_client.auth_token = gdata.gauth.ClientLoginToken(
      self.creds.tracker_auth_token)

    try:
      # Try to access Tracker Issue #1, which will check access.
      query = gdata.projecthosting.client.Query(issue_id='1')
      self.it_client.get_issues('chromium-os', query=query)

      # Token accepted.  We're done here.
      oper.Notice('Tracker token validated.')
      return True
    except gdata.client.Error:
      # Exception is gdata.client.Unauthorized in the case of bad token, but
      # I do not know what the error is for an expired token so I do not
      # want to limit the catching here.  All the errors for gdata.client
      # functionality extend gdata.client.Error (I do not see one that is
      # obviously about an expired token).
      return False

  def _GenerateTrackerToken(self):
    """Generate a new Tracker token from credentials."""
    # pylint: disable=W0404
    import gdata.client

    oper.Warning('Tracker token not valid.  Will try to generate a new one.')
    self.creds.LoadCreds(CRED_FILE)

    try:
      self.it_client.ClientLogin(self.creds.user, self.creds.password,
                                 source='Package Status', service='code',
                                 account_type='GOOGLE')
      self.creds.SetTrackerAuthToken(self.it_client.auth_token.token_string)

      oper.Notice('New Tracker token generated.')
      return True
    except gdata.client.BadAuthentication:
      oper.Error('Credentials from %r not accepted.'
                 '  Unable to generate new Tracker token.' % CRED_FILE)
      return False

  def Run(self):
    """Validate existing auth token or generate new one from credentials."""
    # pylint: disable=W0404
    import chromite.lib.gdata_lib as gdata_lib
    import gdata.spreadsheet.service

    self.creds = gdata_lib.Creds()
    self.gd_client = gdata.spreadsheet.service.SpreadsheetsService()
    self.it_client = gdata.projecthosting.client.ProjectHostingClient()

    self._LoadTokenFile()

    if not self._ValidateTrackerToken():
      if not self._GenerateTrackerToken():
        oper.Die('Failed to validate or generate Tracker token.')

    if not self._ValidateDocsToken():
      if not self._GenerateDocsToken():
        oper.Die('Failed to validate or generate Docs token.')

    self._SaveTokenFile()

def _CreateParser():
  usage = 'Usage: %prog'
  epilog = ('\n'
            'Run outside of chroot to validate the gdata '
            'token file at %r or update it if it has expired.\n'
            'To update the token file there must be a valid '
            'credentials file at %r.\n'
            'If run inside chroot the updated token file is '
            'still valid but will not be preserved if chroot\n'
            'is deleted.\n' %
            (TOKEN_FILE, CRED_FILE))

  return optparse.OptionParser(usage=usage, epilog=epilog)

def main(argv):
  """Main function."""
  # Create a copy of args just to be safe.
  argv = list(argv)

  # No actual options used, but --help is still supported.
  parser = _CreateParser()
  (_options, args) = parser.parse_args(argv)

  if args:
    parser.print_help()
    oper.Die('No arguments allowed.')

  if build_lib.IsInsideChroot():
    InsideChroot().Run()
  else:
    OutsideChroot(args).Run()

redpajama_set_name: RedPajamaGithub


text:
BackHome Respect 2021 Outfits Collection
Respect 2021 Jennifer Hudson Purple Coat
Collar: Large Peter PanCollar
Pockets: Two Large Patch Waist Pockets Outside, Two Pockets Inside
Color: Purple Color
Women's Purple Wool Blend Over Coat
Aretha Franklin Respect 2021 Jennifer Hudson Purple Wool-Blend Coat
"Respect" is an upcoming biopic, musical, drama movie, set to be launched on 13th August 2021 in the United States by United Artist and on 10th September 2021 in the United Kingdom by Universal Plus. This is Liesl Tommy's feature directorial debut film with the story written by Callie Khouri and Tracey Scott Wilson. The film features the real-life story of American singer and civil rights activist Aretha Franklin, who started as a gospel singer, but when she turned sixteen, she chose to embrace a secular-music career. Jennifer Hudson is portraying Aretha Franklin, daughter of C.L.Franklin, the minister at New Bethel Baptist Church in Detroit, Michigan, where she sang in the choir. She is looking lovely in this Respect 2021 Jennifer Hudson Purple Coat. You too have a chance to wear this beautiful coat that Jennifer is wearing in the film. All you need to do is; order your coat before stock ends.
This sophisticatedly beautiful women's long coat is made from superior quality wool blend material, with a soft viscose fabric lining inside. It is stylishly designed with a large Peter Pan collar, long sleeves with open hem cuffs, two large patch waist pockets outside, two pockets inside, and a front opening with a buttoned closure. This women's snazzy retro style wool blend overcoat is available in purple color.
Be the first to review "Respect 2021 Jennifer Hudson Purple Coat" Cancel reply


Published 04/20/2019 01:17:31 pm at 04/20/2019 01:17:31 pm in Circular Outdoor Couch.
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For many years there was a common understanding emerging that lifts were the recognised way for garage operators to carry out vehicle maintenance and inspection. However, over the last ten years or so there has been a growing understanding that vehicle testing pits have a lot to offer.
Generally initial set up costs are lower for lifts. However, it is very difficult to compare, amongst other things, it depends upon the length of the vehicle pit, the installation conditions, the accessories fitted etc. While on the other hand lift costs depend upon the type of lift and the quality, as some types of underground lifts are more expensive.
Vehicle pits can be used in buildings with lower roofs.
This is where vehicle pits win hands down. Once installed a pit can last forever. Lights and safety covers may need to be replaced from time to time but other than a re-spray the new steel prefabricated pits have very few other running costs.
Lifts need constant maintenance and replaced parts. On top of this, they have a finite life.
Lifts can also lead to cracked floors. The strength of the floor has to be considered. Also, unless large well bolted bases are incorporated into the posts constant use can lead to concrete floors deteriorating. Poor quality floors can lead to unstable lift posts.
Once installed it is difficult to relocate an existing pit, while on the other hand lifts can be moved easily to a new location at relatively low costs.
• Greater vehicle throughput – It is quicker and easier to set up and remove vehicles on a pit.
• No down time for maintenance with a pit.
• A pit makes it possible to work underneath a vehicle at the same time as above the vehicle.
• With lifts it is easier to walk to other parts of the workshop for tools etc. However pits are now available with built in below ground workshops.
• Pits can have built in brake testing units that are difficult to incorporate into lifts.
• Pits are available that make it possible to wash underneath vehicles.
• Two major problems with lifts are providing good quality directional lighting and when using air suspension there is a possibility of damaging the unit.
Traditionally, pits had a poor reputation amongst mechanics. They were seen as dirty, crumbling holes in the ground built to the wrong depth. Additionally, water leakage was a problem often leading to mechanics working up to their ankles in water. Lighting and fume extraction was poor. Modern prefabricated pits have overcome all these problems and as a result pits have become much more pleasant places to work.
Build up of fumes causing ill health and the chance of explosion.
Very often pit safety is assessed on very old sites that were built 30/40 years ago when health and safety was not considered.
Lifts have been known to collapse.
Cables lying across the floor create a trip hazard.
Other vehicles manoeuvring in the workshop can hit the lift.
Equipment left lying on the floor.
Poor floor conditions can result in unstable posts.
The development of safety covers. These can vary from top of the range electrically retractable aluminium covers to manually operated budget covers.
The incorporation of fume extraction equipment for petrol or gas vehicles.
Safety lights that are safe with any fumes that may linger in the pit, again, for petrol or gas vehicles.
Pits have therefore become very safe both for the people working in them and other people walking in the workshop.
Also pits give a feeling of safety while with lifts there is always the sensation of having to depend upon some mechanical or electrical devise. This is particularly daunting when working under a large CV or bus.
As can be seen there are benefits and drawbacks with both pits and lifts. Mainly since the advent of prefabricated pits many of the drawbacks presented by pits have been overcome. As a result the economics of testing and maintaining vehicles using pits, whether they are cars, vans, trucks, trains or buses are transformed both on day to day and lifetime assessment.


text:
Bristol Clean Air Zone plans set for approval despite concerns they are not 'terribly fair'
"We have a moral, ecological and legal duty to clean up the air we breathe"
Amanda CameronLocal democracy reporter
The proposed clean air zone and diesel ban map (Image: Bristol City Council)
Sign up to our free email alerts for the top Planet Bristol stories sent straight to your e-mail
Bristol's ruling Labour administration is set to approve its controversial clean air plans today (November 5), despite concerns they are unfair and will hit low-income families the hardest.
Bristol City Council is under a legal obligation to reduce air pollution in the city by lowering toxic nitrogen dioxide (NO2) levels to within legal limits as quickly as possible.
Bristol's controversial clean air plans approved - here's what happens next
After detailed technical modelling and public consultation, Bristol City Council has proposed a clean air zone (CAZ) that polluting commercial vehicles would be charged to enter and a daily eight-hour, inner-city ban on privately owned diesel vehicles.
Officers said it is the only "reasonable" way to meet the legal requirement, as the only other alternative would involve charging private drivers to enter the CAZ zone as well.
This is an option the city's elected mayor, Marvin Rees, has said would disproportionately affect people earning less than £25,000 a year.
Setting the scene for tonight's decision on the clean air plans, Mr Rees said: "We have a moral, ecological and legal duty to clean up the air we breathe.
"Anyone promising alternative proposals is simply misleading the city".
If implemented, the plans are required to be in place by March 2021 and are predicted to reduce NO2 levels to within the legal limit by 2025.
Marvin Rees, Mayor of Bristol (Image: Bristol Live)
The outline proposals have been broadly welcomed by elected members of the council who agree on the urgent need to tackle air pollution, which is estimated to kill 300 Bristolians a year.
But the plans, yet to be finalised, have been criticised by some members of the public and the automotive industry.
And top scrutiny councillors, whose job it is to examine council policy, have raised several concerns which they would like addressed before the final plans are submitted to government early next year.
Key among their concerns was the fear the plans would simply drive air pollution into residential areas, as traffic skirted around the CAZ to avoid charges and fines.
Crews filming for new BBC Two drama in city centre
Members of the council's overview and scrutiny board also worried the proposals were "unfair" and would see people fined for visiting the hospital between 7am and 3pm if they drive a diesel car.
A senior officer said the council was still "zeroing in" on the final scheme and would be consulting on mitigations, exemptions and requirements before coming to a final plan.
The diesel ban zone takes in the Bristol Royal Infirmary and the Bristol Royal Hospital for Children.'
Scrutiny board member, Conservative councillor Claire Hiscott, said: "The main thing I want to flag up is that the hospitals and our accident and emergency are within the diesel ban zone which means that should you need to access accident and emergency from a large part of the city you are going to incur a penalty if you drive in.
'I think the poorest are going to suffer'
"That worries me that as a parent, you try to do the right thing and buy a diesel car because the government told me to, and I would take my child in an emergency to the children's hospital and incur a penalty.
"I think that blanket ban on private cars is going to cause all sorts of problems that we haven't really teased out.
"I think the poorest are going to suffer."
Cllr Hiscott and others pointed out changing a car is a "massive big deal" for a family, even if they get £2,000 from a proposed diesel vehicle scrappage scheme.
Fears clean air zones will create 'rat runs' and worsen air pollution in Bristol's suburbs
Adam Crowther, the council's head of strategic city transport, said low-income households would be prioritised in any scrappage scheme, but warned the government would not necessarily agree to fund such a scheme.
Board members also raised concerns the diesel ban did not discriminate between older and newer diesel vehicles.
Labour councillor Jo Sergeant said she didn't think the ban was "terribly fair" on families who have invested in a modern Euro 6 diesel vehicle.
But Mr Crowther said Euro 6 diesel vehicles still produce "quite significant emissions" and, since the Volkswagen emissions scandal, there were questions over whether the published emission levels of diesel vehicles were lower than the actual output.
City Hall, College Green
Liberal Democrat group leader Gary Hopkins asked whether it would be possible to grade the CAZ charges for commercial vehicles, depending on how polluting they were.
Mr Crowther said it was something the council could take a look at, but warned grading the charges would add a level of complexity to the scheme that could prevent it being "comprehensible and enforceable".
"There has to be a degree of understandability to a scheme," he said, noting there have to be clear signs telling people what they have to pay and what that charge relates to.
The committee heard an estimated 40,000 fines would be issued in the first year of the scheme to businesses which did not pay the CAZ charge of £9 a day for taxis and light-goods vehicles or £100 a day for buses and heavy-goods vehicles.
Martin Lewis reveals pros and cons of Tesco's new Clubcard - can it really save you money?
Board members raised concerns about the impact of the charges on shops and other businesses, including smaller bus operators and tourist attractions such as We The Curious.
Liberal Democrat councillor Anthony Negus called for "much greater mitigation measures" to reduce the impact on individuals and businesses affected by the clean air proposals.
Green councillor Jerome Thomas said he was worried plans had been chosen to fit the mayor's preferences.
"I'm genuinely not sure how much the mayor's very public refusal to countenance charging [private] cars is driving our approach," he said.
Anthony Negus
"I'm concerned that what's happening is that the evidence is being shaped to in order to support the mayor's personal agenda.
"And it's particularly important because the government is going to kick up a stink about a complete ban on diesel cars and lots of people who have invested £25,000 to £40,000 in a Euro 6 diesel car are going to kick up a big stink about being excluded from large parts of the city."
Mr Rees was not at the scrutiny meeting on October 30, but Mr Crowther said the only other option which would reach compliance faster than the plan on the table was not seen as "reasonable".
That option would combine the private diesel vehicle ban with CAZ charges for privately owned and commercial vehicles that do not meet emissions standards.
Mr Crowther said: "The mayor has expressed his concerns about the impact of schemes on lower income households and we've taken time to give that issue more consideration.
"But it has not been the organising framework for the [clean air plan] work. That has been organised entirely around the legal test for compliance."
Response from Marvin Rees
Mr Rees told the Local Democracy Reporting Service today (November 5): "People can have views but they need to be informed.
"Only two methods will meet our legal duty to reach compliance.
"The first is the proposed 'hybrid' plan, including a small area diesel ban and no charging for private vehicles.
"The other is a CAZ D, where everyone has to pay a charge, every time they access a large area of the city centre. This option also has a disproportionate impact on the people in the city who earn less than £25,000.
"No other option will reach legal compliance and so cannot be considered."
Cabinet is due to meet at 4pm at City Hall today.
If approved tonight, the outline clean air plans will be further developed into final plans, which are due to be submitted to government in February 2020.
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For the latest news in and around Bristol, visit and bookmark Bristol Live's homepage.
Marvin Rees


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Armorers and Bout Committee: please check in by 7:30 AM.
You may leave when you are released by the assigner of officials or tournament organizers. We estimate a 6:00 PM end to fencing.
Please dress according to the USFA referee dress code, or as close to it as possible.
The NEIFC will provide breakfast and lunch for referees and tournament officials. If you have specific food requests/requirements, please contact us.
Referees will be paid according to the schedule below. You will be paid according to your highest rating, regardless of which weapon you are assigned to referee.
Additionally, referees who referee more than one weapon in the day will be paid an additional $50.00 bonus.
The NEIFC has a pool of $500.00 set aside for to reimburse travel expenses incurred by referees and tournament officials. If the total requests for travel reimbursement are $500.00 or less, all requests will be paid in full. If the total requests exceed $500.00, all requests will be reimbursed a proportional portion of their request, so that the amount paid out does not exceed $500.00.
Only expenses incurred for travel to/from the NEIFC Championships are eligible for reimbursement (gas, tolls, bus tickets, e.g.). The NEIFC reserves the right to determine which expenses are eligible for reimbursement.


A matte lip can be oh so perfect. Here are a few of my favorite products.
Posted on June 10, 2014 June 7, 2014 by Oh Chanti	This entry was posted in LIVING and tagged lipstick, matte, STYLE, tips. Bookmark the permalink.


(New York, N.Y.) – (RealEstateRama) — The Flatiron/23rd Street Partnership Business Improvement District (BID) today issued the seventh annual Flatiron: Where Then Meets Now report showcasing the significant development and growth of the commercial and residential sectors in the district.
Subtitled "Resilient Retail in the Flatiron District," this year's report comprehensively describes the district's 2017 vital statistics, and highlights the strength of the district's retail sector despite the difficult environment for retail across New York City. The report is among a suite of publications from the BID that focuses on the real estate market in the neighborhood. The report is available at http://www.flatirondistrict.nyc/about-the-bid/reports-and-data.
Bordered by 21st and 28th streets and Sixth and Third avenues, the BID boundaries cover about 21.6 million square feet of commercial space and house approximately 4,200 commercial tenants and 570 ground-floor businesses. Since the establishment of the BID—one of 74 in the city—in 2006, Flatiron has undergone a dramatic transformation into a safe, clean, and desirable neighborhood sought out by all types of people, businesses, industries, and interests.
While many neighborhoods have seen widespread brick-and-mortar store closures due to changing economic forces, Flatiron's retail sector has continued to thrive over the past year. One sign of the neighborhood's continued growth, is that retailers are increasingly deciding to make their New York City debuts in Flatiron. In 2017, British lifestyle brand The White Company and kitchen and bath manufacturer Kohler each opened flagship stores in the district.
Other retailers, seeking new ways to engage customers, have opened innovative concept stores in Flatiron, following the lead of neighborhood destination Eataly, a pioneer in experiential retail that opened in 2010. In late 2016 menswear brand Todd Snyder and Fujifilm's Wonder Photo Shop each opened experiential stores in the district.
•	The retail availability rate is 5.6%, one of the lowest in Manhattan.
•	There are over 570 ground floor businesses in the district—36.1% are national, and 63.9% are locally-owned independent businesses.
•	The Fifth Avenue Corridor along the southern edge of the district has transformed in recent years with the addition of major tenants like The White Company, Bandier, and Fujifilm's Wonder Photo Shop.
•	Average asking rents along the Fifth Avenue Corridor have risen 18% since spring 2016 to $456 per square foot, which is by far the largest increase of any Manhattan retail corridor, and one of only two retail corridors to see an increase since 2016.
•	Dubbed "The Fitness District," Flatiron is home to 47 fitness gyms and studios, a 15.8% increase since 2014. Fitness retailer Alo Yoga will soon call Flatiron home, joining Athleta, Equinox, Sweaty Betty, and AKT NoMad. The fitness and wellness categories represent more than 1 out of every 10 —or 10.3%—of all ground-floor businesses in the district.
•	Flatiron is now home to more than 230 restaurants, bars, and quick and casual food establishments, representing 4 out of every 10—or 42.2%—of Flatiron's ground-floor businesses. So far in 2017, 28 restaurants have opened in the district, with another seven on the horizon. Restaurant growth has been particularly significant along 23rd Street, where there has been an in-flux of new quick and casual dining options.
•	Flatiron is a destination for tourists and local visitors alike. Currently, there are 3,874 hotel rooms in and around the District. Another 1,800 hotel rooms are in development.
•	The average price per square foot for Class A and B office space in the Flatiron District was $71.84 in 2Q 2017.
•	Average asking rents in the district in 2Q 2017 were 7.1% higher than the Class A & B Manhattan-wide average of $67.11 per square foot.
•	Demand for office space in the district remained high in 2017 with tenants from the technology, advertising, media, and information (TAMI) sectors accounting for 49.1% of office space lease signings.
•	Companies that moved their headquarters to Flatiron in 2017 include BDG Media, S'well, Magnetic, Wyng, and 24 Seven. Meanwhile, AEG Live, Blue Apron, Creative Circle, KSH Capital, and AdRoll signed new leases in the district.
•	The Flatiron neighborhood's estimated residential population is 252,658. The population is projected to rise by 1.93% to 257,535 by 2022, and there are currently 247 residential units planned or under construction within BID boundaries.
•	Major planned and active residential development projects will continue to yield significant change on the horizon. Among them are: 39 West 23rd Street; 34 West 21st Street; 122-130 East 23rd Street; 139 East 23rd Street; and 150-154 East 23rd Street.
•	In 2016, ridership from Flatiron's seven subway stations was 46.3 million, or 2.64% of the city's total ridership.
•	NYC Bike Share has 13 stations with an average of 500 docking spaces in and around the district. In the month of July, a total of 97,277 bike share trips originated and ended within BID boundaries, and rides within the district account for 6.1% of New York City's total bike share trips.


The Veterinary Medicine project in Sri Lanka is a practical placement for anyone who wants to work with animals. Whether you are a pre-university student considering a career in veterinary medicine, an undergraduate, graduate, or simply a passionate animal lover, you can get involved in our Veterinary Medicine project in Sri Lanka.
Veterinary Medicine volunteers work at two animal clinics and will gain a wide range of experience, working with both farm animals and domestic pets.
Volunteers can choose to be placed at either a government or private animal clinic.
The government-run veterinary clinics provide free treatment to animals, and you will find that these facilities are basic compared to those in the UK. Here, you will work under the supervision of qualified local vets and after observing the staff for two to three days, you will have the opportunity to assist with minor procedures.
Only domestic animals are treated at the government clinics. To treat larger farm animals, such as cattle, goats, and pigs, vets travel to the farms themselves.
Volunteers working at the government clinics typically work from 8am to 1pm.
At the private veterinary clinics, which are owned and run by qualified local vets, the facilities available are of a higher standard than the government clinics. The private clinics treat domestic animals such as cats and dogs and are open from 8am to 2pm, and then from 6pm to 9pm (often for surgeries). During your time at this placement, you will work under the supervision of a local vet.
The amount of hands-on work allocated will depend on your individual level of knowledge and experience.


text:
About Galerie Vinsantos
The Head Misstress
Commission Dolls
Vinsantos
Erik Alos
Mark Bodnar
Colton Clifford
Timothy Cummings
Sheri Debow
Graham Franciose
Gabrielle Gaspard
Pandora Gastelum
Lana Guerra
Craig Larotonda
Dan Rey
Sigrid Sarda
Rebeka Skela
Kook Teflon
Natalie Woodlock
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Vinsantos : Proprietor-ess
Vinsantos lives a double life. He works full time as a visual artist creating one of a kind creations that fall under the moniker Vinsantos Art Dolls. He also works full time as a musician and performance artist. The lines between these two different art forms are most definitely a blur.
Growing up in San Francisco, he took to the stage at an early age both in theater and music. In his early twenties, he discovered the world of Drag and took the San Francisco scene by storm by incorporating live music and his rock persona into his drag performances. After moving to New Orleans in 2007, Vinsantos turned to the local arts markets to make a living. Disenchanted by the repetition in styles and subject matter that surrounded him, he set out to make something that he hadn't seen before. He learned new techniques, blending mosaic art , and a costume design.
Mastering various techniques for working in clay led him quickly into the world of doll making. He calls his highly personal, and often commissioned art dolls, Assemblage Art Dolls.
"The characters found in Vinsantos Art Dolls stem from my years on the underground performance art circuit. I've spent many years in the public spotlight either as a live musician, a Drag artist, and more often as a combination of both."
Vinsantos Art Dolls are a look behind the scenes of a life that most of us only dare to dream. Divas, Buskers, Circus Freaks and Connoisseurs of the Costume and Make-up arts are some of the subjects explored within each custom-made box.
Former clients of commissioned works include the nostalgic, the bereaved and the narcissistic.


text:
The Impact of the Affordable Care Act on Contraceptive Use and Costs among Privately Insured Women
Ashley H. Snyder, Carol S. Weisman, Guodong Liu, Douglas Leslie, Cynthia H. Chuang
Division of General Internal Medicine
Penn State College of Medicine
Department of Public Health Sciences
Division of Health Services and Behavioral Research
Health Policy and Administration
Cancer Institute, Cancer Control
Department of Psychiatry and Behavioral Health
Penn State Clinical and Translational Science Institute (CTSI)
Objectives: The Affordable Care Act (ACA) contraceptive coverage mandate issued in August 2012 requires most private health insurance plans to cover all U.S. Food and Drug Administration-approved contraceptive methods without cost sharing. We evaluate the impact of this policy on out-of-pocket costs and use of long-acting reversible contraceptives (LARCs) and other prescription methods through 2014. Methods: Data from Truven Health MarketScan were used to examine out-of-pocket costs and contraceptive use patterns for all reversible prescription contraceptives before and after the implementation of the contraceptive mandate for privately insured women ages 13 to 45. Costs were estimated by combining copayment, coinsurance, and deductible payments for both contraception and insertion fees for LARCs. Contraceptive use rates were examined and multivariable logistic regression analysis of LARC insertions before and after the ACA was conducted. Results: Out-of-pocket costs for all reversible contraceptives, including LARCs, decreased sharply after the ACA contraceptive mandate. The greatest proportion of women in each year was oral contraceptive users (24.3%-26.1%). Rates of new LARC insertions increased significantly after the ACA, when controlling for cohort year, age group, geographic region, and rural versus urban setting (adjusted odds ratio, 1.03; 95% confidence interval, 1.02-1.04). Conclusions: Our study adds to the current literature with the inclusion of 2014 data and confirms previous findings of a post-ACA decrease in out-of-pocket contraceptive costs. In addition, there was a small but statistically significant increase in LARC insertions after the ACA. This finding indicates the importance of reduced cost sharing for increasing use of the most effective contraceptives.
https://doi.org/10.1016/j.whi.2018.01.005
10.1016/j.whi.2018.01.005
Dive into the research topics of 'The Impact of the Affordable Care Act on Contraceptive Use and Costs among Privately Insured Women'. Together they form a unique fingerprint.
Patient Protection and Affordable Care Act Medicine & Life Sciences 100%
Contraceptive Agents Medicine & Life Sciences 76%
contraceptive Social Sciences 69%
act Social Sciences 48%
Costs and Cost Analysis Medicine & Life Sciences 45%
costs Social Sciences 41%
Health Expenditures Medicine & Life Sciences 19%
Cost Sharing Medicine & Life Sciences 14%
Snyder, A. H., Weisman, C. S., Liu, G., Leslie, D., & Chuang, C. H. (2018). The Impact of the Affordable Care Act on Contraceptive Use and Costs among Privately Insured Women. Women's Health Issues, 28(3), 219-223. https://doi.org/10.1016/j.whi.2018.01.005
Snyder, Ashley H. ; Weisman, Carol S. ; Liu, Guodong et al. / The Impact of the Affordable Care Act on Contraceptive Use and Costs among Privately Insured Women. In: Women's Health Issues. 2018 ; Vol. 28, No. 3. pp. 219-223.
@article{50ef0b178356483d9eb89784f4bed143,
title = "The Impact of the Affordable Care Act on Contraceptive Use and Costs among Privately Insured Women",
abstract = "Objectives: The Affordable Care Act (ACA) contraceptive coverage mandate issued in August 2012 requires most private health insurance plans to cover all U.S. Food and Drug Administration-approved contraceptive methods without cost sharing. We evaluate the impact of this policy on out-of-pocket costs and use of long-acting reversible contraceptives (LARCs) and other prescription methods through 2014. Methods: Data from Truven Health MarketScan were used to examine out-of-pocket costs and contraceptive use patterns for all reversible prescription contraceptives before and after the implementation of the contraceptive mandate for privately insured women ages 13 to 45. Costs were estimated by combining copayment, coinsurance, and deductible payments for both contraception and insertion fees for LARCs. Contraceptive use rates were examined and multivariable logistic regression analysis of LARC insertions before and after the ACA was conducted. Results: Out-of-pocket costs for all reversible contraceptives, including LARCs, decreased sharply after the ACA contraceptive mandate. The greatest proportion of women in each year was oral contraceptive users (24.3%-26.1%). Rates of new LARC insertions increased significantly after the ACA, when controlling for cohort year, age group, geographic region, and rural versus urban setting (adjusted odds ratio, 1.03; 95% confidence interval, 1.02-1.04). Conclusions: Our study adds to the current literature with the inclusion of 2014 data and confirms previous findings of a post-ACA decrease in out-of-pocket contraceptive costs. In addition, there was a small but statistically significant increase in LARC insertions after the ACA. This finding indicates the importance of reduced cost sharing for increasing use of the most effective contraceptives.",
author = "Snyder, {Ashley H.} and Weisman, {Carol S.} and Guodong Liu and Douglas Leslie and Chuang, {Cynthia H.}",
note = "Funding Information: This research was funded by the Robert E. Dye, MD, Professorship at the Penn State College of Medicine and by the Penn State Center for Women's Health Research. Publisher Copyright: {\textcopyright} 2018 Jacobs Institute of Women's Health Copyright: Copyright 2018 Elsevier B.V., All rights reserved.",
doi = "10.1016/j.whi.2018.01.005",
journal = "Women's Health Issues",
Snyder, AH, Weisman, CS, Liu, G, Leslie, D & Chuang, CH 2018, 'The Impact of the Affordable Care Act on Contraceptive Use and Costs among Privately Insured Women', Women's Health Issues, vol. 28, no. 3, pp. 219-223. https://doi.org/10.1016/j.whi.2018.01.005
The Impact of the Affordable Care Act on Contraceptive Use and Costs among Privately Insured Women. / Snyder, Ashley H.; Weisman, Carol S.; Liu, Guodong et al.
In: Women's Health Issues, Vol. 28, No. 3, 01.05.2018, p. 219-223.
T1 - The Impact of the Affordable Care Act on Contraceptive Use and Costs among Privately Insured Women
AU - Snyder, Ashley H.
AU - Weisman, Carol S.
AU - Liu, Guodong
AU - Leslie, Douglas
AU - Chuang, Cynthia H.
N1 - Funding Information: This research was funded by the Robert E. Dye, MD, Professorship at the Penn State College of Medicine and by the Penn State Center for Women's Health Research. Publisher Copyright: © 2018 Jacobs Institute of Women's Health Copyright: Copyright 2018 Elsevier B.V., All rights reserved.
N2 - Objectives: The Affordable Care Act (ACA) contraceptive coverage mandate issued in August 2012 requires most private health insurance plans to cover all U.S. Food and Drug Administration-approved contraceptive methods without cost sharing. We evaluate the impact of this policy on out-of-pocket costs and use of long-acting reversible contraceptives (LARCs) and other prescription methods through 2014. Methods: Data from Truven Health MarketScan were used to examine out-of-pocket costs and contraceptive use patterns for all reversible prescription contraceptives before and after the implementation of the contraceptive mandate for privately insured women ages 13 to 45. Costs were estimated by combining copayment, coinsurance, and deductible payments for both contraception and insertion fees for LARCs. Contraceptive use rates were examined and multivariable logistic regression analysis of LARC insertions before and after the ACA was conducted. Results: Out-of-pocket costs for all reversible contraceptives, including LARCs, decreased sharply after the ACA contraceptive mandate. The greatest proportion of women in each year was oral contraceptive users (24.3%-26.1%). Rates of new LARC insertions increased significantly after the ACA, when controlling for cohort year, age group, geographic region, and rural versus urban setting (adjusted odds ratio, 1.03; 95% confidence interval, 1.02-1.04). Conclusions: Our study adds to the current literature with the inclusion of 2014 data and confirms previous findings of a post-ACA decrease in out-of-pocket contraceptive costs. In addition, there was a small but statistically significant increase in LARC insertions after the ACA. This finding indicates the importance of reduced cost sharing for increasing use of the most effective contraceptives.
AB - Objectives: The Affordable Care Act (ACA) contraceptive coverage mandate issued in August 2012 requires most private health insurance plans to cover all U.S. Food and Drug Administration-approved contraceptive methods without cost sharing. We evaluate the impact of this policy on out-of-pocket costs and use of long-acting reversible contraceptives (LARCs) and other prescription methods through 2014. Methods: Data from Truven Health MarketScan were used to examine out-of-pocket costs and contraceptive use patterns for all reversible prescription contraceptives before and after the implementation of the contraceptive mandate for privately insured women ages 13 to 45. Costs were estimated by combining copayment, coinsurance, and deductible payments for both contraception and insertion fees for LARCs. Contraceptive use rates were examined and multivariable logistic regression analysis of LARC insertions before and after the ACA was conducted. Results: Out-of-pocket costs for all reversible contraceptives, including LARCs, decreased sharply after the ACA contraceptive mandate. The greatest proportion of women in each year was oral contraceptive users (24.3%-26.1%). Rates of new LARC insertions increased significantly after the ACA, when controlling for cohort year, age group, geographic region, and rural versus urban setting (adjusted odds ratio, 1.03; 95% confidence interval, 1.02-1.04). Conclusions: Our study adds to the current literature with the inclusion of 2014 data and confirms previous findings of a post-ACA decrease in out-of-pocket contraceptive costs. In addition, there was a small but statistically significant increase in LARC insertions after the ACA. This finding indicates the importance of reduced cost sharing for increasing use of the most effective contraceptives.
U2 - 10.1016/j.whi.2018.01.005
DO - 10.1016/j.whi.2018.01.005
JO - Women's Health Issues
JF - Women's Health Issues
Snyder AH, Weisman CS, Liu G, Leslie D, Chuang CH. The Impact of the Affordable Care Act on Contraceptive Use and Costs among Privately Insured Women. Women's Health Issues. 2018 May 1;28(3):219-223. doi: 10.1016/j.whi.2018.01.005