text:
Wanted: Pole Position In Division Race
Posted on October 1, 2017 at 7:30 am
The Pittsburgh Steelers and Baltimore Ravens have so far tread roughly comparable courses over the course of the first three weeks of the season. In the cases of each, their games have come against either underwhelming opponents or those who were undermanned, and both of them are coming off of tough and frustrating losses.
Neither AFC North team is playing very close to its best football, on either side of the ball, though the Ravens' defense through the first two games did very well—against the Browns and Bengals. Today, they draw one another in a pivotal early-season struggle for control of the division as they seek to avenge their previous embarrassment.
The two teams split their matches a year ago, each winning at home, with the Steelers coming at an absolutely crucial juncture in the penultimate game of the season. Pittsburgh brought into the contest an 8-6 record, the Ravens the same. Whoever won the game, essentially, was going to win the division.
For a while, the Steelers looked like the game was theirs, but it took a couple of drives at the end of the game to match a go-ahead Ravens drive in between, and a remarkable individual effort from Antonio Brown, to pull it off, for just their second win in eight games over Baltimore.
The division is not on the line today, but the driver's seat for the pole position in the division race is at stake. With both entering the game with a 2-1 record, the victor will be in the lead, a game ahead, with a head-to-head win already in their pocket, through the first quarter of the regular season.
That does not mean that there is not plenty of time remaining for whoever comes out the loser to overcome their result. It would not be the first time that we have seen one team storm back and wrest control of the division from the other late in the year, after all.
But in taking the pulse of the team at the moment, this point in time does ring of significant import. It's more than just a Ravens game. For a game in week four of the regular season, the outcome of this one feels rather momentous.
It will set the tone for the division race going forward, for sure. Whoever wins will be able to either perpetuate or overturn a long-running storyline as a result. While ultimately everything comes down to what happens on the field, there are aspects of the story happening off the field that can have their effect.
The Steelers were able to rebound with their most complete win the season a year ago after they went 2-1 to start the season, coming off a far more embarrassing loss in Philadelphia. Even if they fail to do that, one can take solace in the face that they also overcame a subsequent four-game losing streak to make it to the AFC Championship game.
But, still, it kind of feels like they need to win this one, if only for the psychology behind it.
Related Items:Steelers
Steelers Hit First Postseason Winless Streak Of Five-Plus Seasons Since Merger, Last Of 32 Teams
2021 South Side Questions: How Do You Assess Steelers' Season?
Latest Defeat Marks New Franchise Record For Most Consecutive Postseason Losses In Steelers History At Four


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Estanislao Kocourek (born 5 March 1930) is an Argentine hurdler. He competed in the men's 110 metres hurdles at the 1952 Summer Olympics.

References

1930 births
Living people
Athletes (track and field) at the 1952 Summer Olympics
Argentine male hurdlers
Olympic athletes of Argentina
Athletes from Buenos Aires
Pan American Games medalists in athletics (track and field)
Pan American Games silver medalists for Argentina
Athletes (track and field) at the 1951 Pan American Games
Medalists at the 1951 Pan American Games
20th-century Argentine people

redpajama_set_name: RedPajamaWikipedia


Attorney Russ Purvis is an Attorney of Montee Law Firm, P.C., a law firm in Kansas City, MO. As a lawyer in Kansas City, Missouri, attorney Purvis serves Jackson County, as well as clients throughout Missouri.
Search and connect with Attorney Russ Purvis on these social networking sites.


text:
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READ: Ticketmaster's guides to finding the best live stream gigs
Local TM teams have been busy collecting some of the best content and sharing them with fans across the world. Check out some of the articles here.
WATCH: Ticketmaster Australia presents Together Fest
Ticketmaster Australia brought together some of their favourite local musicians to perform under the Together Fest banner, live on Facebook on Tuesday 31 March. Check out the full story here.
SUPPORT: Crew Nation Fund announced
Crew members are the backbone of the live music industry – this fund will help them to stay strong. Live Nation has committed $10 million to the fund – contributing an initial $5 million, then matching the next $5 million given by artists, fans and employees dollar for dollar. Find out more here
Ticketmaster recognised as fundamental to the success of Slipknot's first No.1 album in 18 years.
Charitable donations from Ticketmaster Platinum sales hit £900k in the last 12 months.
Case Study: Ticketmaster Artist Services & Liam Gallagher Tour.
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redpajama_set_name: RedPajamaCommonCrawl


text:
Elisabeth Moss says the Handmaid's Tale TV series won't adapt The Testaments
Margaret Atwood's sequel is too far removed from the TV series, The Invisible Man star says
By Huw Fullerton
Tuesday, 25th February 2020 at 10:40 am
After the success of Hulu and Channel 4's adaptation of The Handmaid's Tale, it was no surprise to see original book author Margaret Atwood finally bring out a sequel last year – but fans hoping to see storylines from The Testaments in the main series will be disappointed.
You see, according to star Elisabeth Moss (who plays rebellious Handmaid Offred/June Osbourne in the TV drama), there are no plans to include the later book's plot, partially due to difficulties around the different time periods the two stories are set in.
"No, because it's a bit in the future, The Testaments," Moss told RadioTimes.com when asked if the book could be involved in the main series.
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"So no, we're leaving that to itself."
Released by Atwood in 2019, The Testaments continues the story of Gilead around 15 years after the events of her original 1985 book (and the subsequent TV adaptation), with Moss' character Offred largely absent while still playing a crucial background role in the story.
Previously, The Handmaid's Tale's creator Bruce Miller had suggested that the series would take the events of The Testaments into account when crafting future storylines, or even create a spin-off for it – but Moss explained that this doesn't mean the plot of the book will ever make it to screen within the main series, or that she'd be involved if it did.
"God, that'd mean I'd be doing it for the next 15 years!" she laughed.
For now, Moss is more concerned with what other new roles she can fit in around her time filming as Offred, with the actress currently starring in a new horror-movie take on Universal classic The Invisible Man.
"It's told from the perspective of the victim of the Invisible Man," Moss told us, "which was Leigh Whannell, our writer/director's idea. And really kind of revolutionary."
"There's a way that you can do something with a genre film, or even speculative fiction like The Handmaid's Tale, where you can cloak the bigger idea within something scarier, more entertaining, with all the bells and whistles.
"I read it, and I was immediately hooked on like the first 10 pages, which is the opening of the movie, and I felt like 'oh this is super super different than anything I could have expected this movie to be," she concluded.
The Invisible Man is in UK cinemas from Friday 28th February
Huw Fullerton The Invisible Man has to be seen to be believed
The best movies to watch on Amazon Prime Video
All about The Handmaid's Tale
Get money off a BodyFit folding magnetic exercise bike
With this great offer you can enjoy the ultimate workout at home!
The Handmaid's Tale creator hints at June's fate


Leave the competition in the dust with the women's Nike Zoom Rival Fly sneaker. This streamlined silhouette boasts a ventilated mesh construction with a classic lace-up closure and cushioned footbed for support. The Zoom Air unit in the forefoot adds responsive propulson, and the internal fitbad that surrounds the midfoot works with the laces to keep your footing steady and sure.


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Q: Hibernate - One to Many - Getters/Setters issues My programm is freezing when I write getters/setters for OneToMany properties.
I have these two entities :
COMPETENCE_LEVEL
@Entity
@Table(name="competence_level")
public class CompetenceLevel {

    @Id
    @GeneratedValue(strategy=GenerationType.AUTO)
    @Column(name="id_competence_level")
    private Long idCompetenceLevel;

    @ManyToOne
    @JoinColumn(name="id_competence")
    private Competence competence;

    @ManyToOne
    @JoinColumn(name="id_level")
    private Level level;

    @ManyToOne
    @JoinColumn(name="id_profil")
    private Profil profil;

    public CompetenceLevel() {
        super();
    }

    public CompetenceLevel(Competence competence, Level level, Profil profil) {
        super();
        this.competence = competence;
        this.level = level;
        this.profil = profil;
    }

    /**
     * @return the idCompetenceLevel
     */
    public Long getIdCompetenceLevel() {
        return idCompetenceLevel;
    }

    /**
     * @param idCompetenceLevel the idCompetenceLevel to set
     */
    public void setIdCompetenceLevel(Long idCompetenceLevel) {
        this.idCompetenceLevel = idCompetenceLevel;
    }

    /**
     * @return the competence
     */
    public Competence getCompetence() {
        return competence;
    }

    /**
     * @param competence the competence to set
     */
    public void setCompetence(Competence competence) {
        this.competence = competence;
    }

    /**
     * @return the level
     */
    public Level getLevel() {
        return level;
    }

    /**
     * @param level the level to set
     */
    public void setLevel(Level level) {
        this.level = level;
    }

    /**
     * @return the profil
     */
    public Profil getProfil() {
        return profil;
    }

    /**
     * @param profil the profil to set
     */
    public void setProfil(Profil profil) {
        this.profil = profil;
    }

}

COMPETENCE
@Entity
@Table(name="competence")
public class Competence {

    @Id
    @GeneratedValue(strategy=GenerationType.AUTO)
    @Column(name="id_competence")
    private Long idCompetence;

    @Column(name="libelle")
    private String libelle;

    @OneToMany(mappedBy="competence", cascade=CascadeType.ALL)
    private List<CompetenceLevel> competenceLevels;

    public Competence() {
        super();
    }

    public Competence(String libelle) {
        super();
        this.libelle = libelle;
    }

    public Long getIdCompetence() {
        return idCompetence;
    }

    public void setIdCompetence(Long idCompetence) {
        this.idCompetence = idCompetence;
    }

    public String getLibelle() {
        return libelle;
    }

    public void setLibelle(String libelle) {
        this.libelle = libelle;
    }

    // ISSUE !!!
    public List<CompetenceLevel> getCompetenceLevels() {
        return competenceLevels;
    }

    // ISSUE !!!
    public void setCompetenceLevels(List<CompetenceLevel> competenceLevels) {
        this.competenceLevels = competenceLevels;
    }

}

Why, if I'm not comment the COMPETENCE's getters/setters, my app' is freezing (I believe this is infinite recursion) ? Thanks

redpajama_set_name: RedPajamaStackExchange


Japan is 12hrs ahead oh Rio, Brazil.
Rio Olympis is really Hot and a lots are viewing the games and keen to catch up on the results.
Japan teams are good at Swimming, Judo (marshal arts), Weightlifting, Gymnastics, Table tennis etc.
Let's ask Japan students what sport they are after.
Do they play any sports, or belong to any teams?
Check out the new pallets, Rio Olympic pallet!


Stan Bernstein has more than 30 years in a diverse range of capacities in academia and in the United Nations. He has played many roles: teacher, author, evaluator, advocate and negotiator/listener. Much of his work has been directly related to the production and advancement of, and awareness raising and resource mobilization for the implementation of the ICPD Programme of Action, the guiding intergovernmental agreement for the population and reproductive health community. He has conducted analyses, written articles, synthesized and disseminated the work of others (including 10 years as primary researcher and writer of the State of World Population Report, the UNFPA flagship publication) and stimulated new policy and program syntheses (e.g., as sexual and reproductive health adviser to and author for the UN Millennium Project), and advanced population and reproductive health/family planning issues within intergovernmental and interagency (UN and bilateral) efforts. He has helped organize teams addressing these various concerns. Prior to joining the UN he was a researcher and teacher at the School of Public Health at the University of Michigan and consultant to USAID and UNFPA in various countries in Asia and Africa.
Immediately prior to co-founding Re:Generation Consulting, he contributed to the initial stages of the DFID-funded STEP UP project to develop an evidence base on interventions to prevent unintended pregnancies and provided inputs to the Global Survey of the now-in-process Operational Review of the ICPD Program of Action. Just prior to leaving UNFPA in 2010 he co-managed the ICPD at 15 Review Process, and participated in the drafting of several joint agency publications on progress in development, particularly health, during the 2010 High Level Review of progress towards the Millennium Development Goals. Stan has written most frequently on cost and expenditure issues, program monitoring and evaluation needs and systems, causes and consequences of unmet need for contraceptive services, gender and development issues and health system strengthening. He early developed and subsequently contributed substantive guidance to the further development of software for forecasting, targeting and priority setting for health system interventions. His range of experience helps him provide informed and novel perspectives for policy dialog. His wide network of contacts allows him to provide access to diverse expertise and information and thereby promote productivity.
Pierre M. LaRamée has more than 30 years experience in NGO programming and administration with overlapping expertise in academic research, policy analysis/advocacy, strategic communications, publishing and resource development. Prior to co-founding Re:Generation Consulting, he oversaw communications, media, and fundraising activities while directing extensive international advocacy initiatives focusing on ICPD and the MDGs as well as emerging cutting-edge advocacy programs in Latin America/Caribbean (LAC) for the International Planned Parenthood Federation - Western Hemisphere Region (IPPF/WHR). He helped develop advocacy strategies across Central America, in collaboration with the LAC Division of the United Nations Population Fund and Ipas, to strengthen the capacity of civil society organizations to advocate for the implementation of comprehensive models for gender based violence prevention and care. He also directed extensive advocacy work across Mesoamerica and in the Andean region in the area of comprehensive sexuality education building on an LAC region-wide Ministerial Declaration.
In his non-profit career, Dr. LaRamée has also developed strong geographical expertise on LAC political and social issues and last published an analysis of USAID's policy of LAC-wide "graduation" from US population funding. He was recently recruited to direct Medical Education Cooperation with Cuba (MEDICC), and served as ED for two years before returning Re:Generation. Pierre came to IPPF/WHR in 2004 from the Puerto Rican Legal Defense and Education Fund, a Latino civil rights organization, where he served as Director of Development and Executive Vice President. He previously served as Executive Director of the North American Congress on Latin America, a research and publishing organization specializing in US-Latin American Relations, and as Assistant Professor of Sociology and Latin American Studies at St. Lawrence University. He is fluent in French and Spanish and has authored and co-authored numerous articles, book chapters, and reviews. Dr. LaRamée holds an MA in Political Science from McGill University and a PhD in the Sociology of International Development from Cornell University.


text:
News and Statistical Releases
- Any -Newsroom-News Digest-Statistical Release--Airline Financial Data--Airline On-Time Statistics--Airline Traffic Data--Air Fares--North American Transborder Freight Data--Passenger Airline Employment--Transportation Services Index
Freight Shipments Unchanged in May from April
Wednesday, July 11, 2012 - The amount of freight carried by the for-hire transportation industry was unchanged in May from April, after a one-month rise, according to the U.S. Department of Transportations Bureau of Transportation Statistics (BTS) Freight Transportation Services Index (TSI) released today.
Freight Shipments Rose 0.2% in April from March
Wednesday, June 13, 2012 - The amount of freight carried by the for-hire transportation industry rose 0.2 percent in April from March, rising after a one-month decline, according to the U.S. Department of Transportation's Bureau of Transportation Statistics' (BTS) Freight Transportation Services Index (TSI) released today. The April 2012 level was 16.2 percent above the April 2009 low during the recession (Tables 1, 2A).
Freight Shipments Fell 0.8% in March from February
Wednesday, May 9, 2012 - The amount of freight carried by the for-hire transportation industry fell 0.8 percent in March from February, declining after a one-month increase, according to the U.S. Department of Transportations Bureau of Transportation Statistics (BTS) Freight Transportation Services Index (TSI) released today. The March level was 16.0 percent above the April 2009 low during the recession (Tables 1, 2A).
Freight Shipments Rose 0.5% in February from January
Wednesday, April 11, 2012 - The amount of freight carried by the for-hire transportation industry rose 0.5 percent in February from January, rising after a one-month decline, according to the U.S. Department of Transportations Bureau of Transportation Statistics (BTS) Freight Transportation Services Index (TSI) released today (Table 1).
Freight Shipments Fell 3.6% in January from December
Wednesday, March 14, 2012 - The amount of freight carried by the for-hire transportation industry fell 3.6 percent in January from December, declining after five consecutive monthly increases, according to the U.S. Department of Transportation's Bureau of Transportation Statistics' (BTS) Freight Transportation Services Index (TSI) released today (Table 1).
View Archived releases


It's the 25th of December here in Malaysia!
The ending of the year is close marked by a date chosen to signify the birth of Jesus who became the Christ. However, this whole month of December is celebrated as a time of reflection, winding down, reflection and contemplation.
Merry Christmas Shree, you are always one step ahead of me hehe!
Have fun and thank you for entering my life.
Thank you, Diane! Hope you had an awesome one too!
Merry Christmas, Shee. I hope you had a good one. This always is both a busy and a relaxing time of year.
Shree, you keep enjoying your friends and family in the flesh… We will be here in cyber space, YOU deserve a break after your busy busy time at work..
Ditto to having had a wonder filled Christmas, Shree. I trust and hope that 2014 will yield an abundance of joy and good health for you and yours!
Happy, healthy, creative New Year Shree!


"It is an honor to rejoin the Veterans' Affairs Committee and I look forward to working on the issues that will come before the Economic Opportunity Subcommittee and the Health Subcommittee. The jurisdictions of these subcommittees have particular importance to the 17th Congressional District, which is home to many veterans, the Doris Miller Department of Veterans Affairs Medical Center, the VISN 17 Center of Excellence for Research on Returning War Veterans, the Waco Veterans Affairs Regional Office, and some the of the premiere colleges and universities in Texas that partner with the VA. The House Veteran's Affairs Committee has a strong history of bipartisanship and I look forward to working with my colleagues to build a 21st century VA that provides our nation's veterans with the best possible care and prioritizes veterans' interests."
"Intelligence gathering is important and difficult work, which is an integral element of our national security strategy. The Matthew Young Pollard Intelligence Authorization Act provides the critical resources and authorizations needed for our intelligence community to detect, prevent, disrupt and counter potential threats to America. It is important that Congress continue working to reaffirm our commitment to America's vital intelligence community as they are tasked with the important job of keeping hardworking American families safe."
"Federal bureaucrats have been exploiting loopholes in the Unfunded Mandates Reform Act of 1995 to pass down costly and burdensome federal mandates to state and local governments and to the private sector. With the House passage of the Unfunded Mandates Information and Transparency Act, we are closing those loopholes and enhancing transparency, accountability and awareness of federal mandates. By reforming the regulatory process, we are holding Washington bureaucrats accountable to produce more thoughtful regulations which factor in the true costs that these regulatory requirements have in the real world."
"The U.S. Army made a great decision to select Austin as the new home for its Futures Command center. Austin is equipped with the innovative resources, talent and great preexisting relationships with our Armed Forces. These attributes provide a natural fit for a flourishing partnership with the U.S. Army as it works to enhance our national security. This new command center will be tasked to create an innovative and modernized force for the 21st century, and it represents the most significant internal reorganization for the Army in more than 40 years. I worked closely with my fellow Texas colleagues and Austin community leaders, including the Austin Chamber of Commerce, to bring the center to Austin. I am grateful that our hard work has paid off and that Texas can continue to be a leader in keeping our nation safe."
"Nuclear power is a clean and efficient source of zero-emissions energy. It is generating a meaningful portion of our country's 'always-on, baseload' electricity for use in our homes and businesses. American innovators are currently working on the next generation of nuclear reactors to keep our country at the forefront of this important energy source. In order to power future generations of nuclear reactors, we need to develop the next generation of nuclear fuels. Earlier this year, I introduced the bipartisan Advanced Nuclear Fuel Availability Act to establish a public-private solution to develop, manufacture and transport those next generation fuels. This week, the Energy and Commerce Committee unanimously passed this bipartisan solution, and I look forward to having this bill come to the House floor for a vote so that we can further power our 21st century economy for hardworking American families."


Russia's transportation and logistics firm Amurskaya Neftebaza has placed an order for six bulk carriers with Chinese shipbuilder Yangzijiang Shipbuilding.
According to the agreement between the parties, which was unveiled on April 20, the new vessels will feature 120,000 dwt.
The units are scheduled for delivery to their owner in the second half of 2019, data provided by Asiasis show. The parties did not reveal any financial details related to the order.
In late March, the Russian company placed an order for a 4,500 cbm small clean tanker at China's Jiangsu Dajin Heavy Industry. The unit, which is scheduled for delivery in May 2019, was priced at USD 7.1 million.
For Yangzijiang Shipbuilding, the order comes on the back of a Letter of Intent (LOI) signed for the construction of up to twenty LNG-fueled bulk carriers for Forward Maritime, a part of Arista Shipping Group.
The Kamsarmax vessels, which would feature 84,000 dwt, would join the fleet between 2020 and 2023, provided that Forward Maritime signs firm contracts for the units.
Posted on April 20, 2018 with tags Amurskaya Neftebaza, Bulker, Yangzijiang Shipbuilding.


text:
Canterbury Cathedral
Top Tourist Attractions
With origins dating back to 597AD Canterbury Cathedral in Canterbury, Kent, is one of the oldest and most famous Christian structures in England. It forms part of a World Heritage Site. It is the cathedral of the Archbishop of Canterbury, currently Justin Welby, leader of the Church of England and symbolic leader of the worldwide Anglican Communion.
Whenever you visit Kent, touring across the magnificent Canterbury Cathedral is certainly the most spectacular moment. It is one of the UNESCO's World Heritage Sites and a renowned tourist destination amongst visitors and tourists. On visiting this beautiful place, you will be presented with breathtaking architecture and a rich history that continues to draw people.
It's here, in the heart of English Christianity, that St. Augustine gained his first converts among some of the pagan Anglo Saxons and then became the first bishop in 597. Canterbury is a major entertainment and cultural attraction and one of Britain's renowned Heritage sites. It has a plethora of historically significant attractions to see.
Walk-In To The History Of Canterbury Cathedral
Canterbury Cathedral, a UNESCO World Heritage Site, is regarded as the Mother Church of the global Anglican Communion. It is one of the country's most important and ancient Christian constructions, including several centuries worth of architectural styles.
This attractive sight is famed for being the site of Archbishop Thomas Becket's assassination in 1170. Standing in the exact place in the Northwest Transept where this horrible crime was executed nearly 900 years ago is still terrifying.
Yet another very interesting spot to check out here is the 'Choir.' The beautiful stonework of the choir screen, which dates from 1411, is carved with angels bearing shields and the crowned statues of six royals: Henry V, Ethelbert of Kent, Richard II, Henry IV, Edward the Confessor, and Henry VI.
Check Out The Cathedral Tombs
Canterbury Cathedral is home to a great collection of memorials. Among the finest is that of Archbishop Henry Chichele, founder of Oxford's All Souls College. The Archbishop is depicted twice - once in full costume, and again as a corpse, a metaphor of the fleeting nature of earthly riches.
Miracles and Stained Glass Windows
Stained glass windows from the late 12th and 13th centuries adorn the Choir walls on both sides of the Corona (a circular chapel at the far east end). The Miracle Windows, commonly referred to as the Thomas Becket Windows, portray scenes from Thomas Becket's lifetime and are part of a broader series that includes Old and New Testament subjects.
The oldest section of the Canterbury Cathedral is the massive 12th-century Norman Crypt. The pillars, featuring magnificently carved Norman capitals and ornamented shafts, are also noteworthy with vestiges of Romanesque works of art. Creatures, plant decoration, and devils are among the many motifs reflecting influences from the Middle East, Byzantium, and Lombardy.
After that, have a look inside the early 15th-century Chapter House. It features stunning Irish bog oak barrel vaulting.
The Black Prince of Trinity Chapel
The golden shrine of St. Thomas Becket stood in the Trinity Chapel, with its massive canopy elevated to provide tourists a glimpse of the gem-encrusted coffin housing his bones. The alabaster tombs of Henry IV and his wife Joan of Navarre are now housed in the chapel. Yet, another well-known tomb at Canterbury Cathedral is King Edward III's eldest son, the Black Prince. Also known as Edward of Woodstock, a real knight best known for his support of the English cause during the Hundred Year's War.
Information About Canterbury Cathedral
Students – Free entry with student ID for students from the Canterbury Christ Church University, University for the Creative Arts, and University of Kent
Adult 18 and over - £14.00 (inclusive of VAT)
Children under 17 - When accompanied by a paid adult, free entry
Monday to Saturday 00 – 16.00 (Last admission at 15.00)
Sunday 30 – 16.00 (Last admission at 15.00)
Note – Opening timings can change. Visit the official website to get an update.
https://www.canterbury-cathedral.org/


text:
Clambus punctulatus is een keversoort uit de familie oprolkogeltjes (Clambidae). De wetenschappelijke naam van de soort werd in 1817 gepubliceerd door Beck.

Oprolkogeltjes


text:
Play explores impact of sexual abuse
Mary Steurer | Friday, October 26, 2018
Exploring the themes of manipulation and control within American family life, the Notre Dame Student Players will present "How I Learned Drive" by Paula Vogel from Nov. 1 through Nov. 4 in the Washington Hall Lab Theatre.
The play follows a woman nicknamed Li'l Bit as she reflects on the sexual abuse she suffered by her Uncle Peck as a young adult.
Junior and director Maria Amenabar Farias said the play offers unique insight into the often complex relationships victims have with their abusers. While Uncle Peck abuses Li'l Bit in secret, he maintains the facade of a respectable family man, she said.
"[Peck] is presented as this amazing guy," she said. "He's charming. The author even wrote in this play that he should be thought of as an Atticus Finch."
Senior and stage manager Maria Pope said watching the events of the play through Li'l Bit's eyes allows the audience to view her relationship with Uncle Peck with greater depth.
"It lets us examine [Li'l Bit] as a character and the complexities with which she views her uncle who is abusing her," she said. "He's not just this evil figure in her life, she sees him in many different ways."
Amenabar Farias said delving deep into the text of the script was crucial to gain an understanding of the "psychology and the objectives" of the characters.
"Everything we do, I ask myself, 'What's the purpose of the scene? How do we get the actors to tell the story that we want them to tell,'" she said.
Senior Alexander Daugherty, assistant director, said the play refrains from showing the physical abuse in order to place greater emphasis on Li'l Bit and her growth as a character.
"The focus is on her, her words, what she's saying," he said.
Amenabar Farias said despite the fact that no assault is shown, the play communicates the gravity of the abuse just as effectively.
"We don't sugarcoat [the abuse]," she said. "We're not pretending they're not happening, but we present them in a very elegant and graceful manner, I would say, because we know we're dealing with very delicate subjects."
Though the play does not ignore the hardships abuse brings into the lives of its victims is not absent of, it also does not neglect to celebrate victims overcoming their pasts.
"It's such a beautiful story about something that's so awful," Amenabar Farias said. "We find the beauty in the character's life and how she's not defined by what's happening to her."
Amenabar Farias said she hopes the play offers a means for understanding victims of abuse as well as inspiration for all those facing adversity.
"This play is sort of a way to see that you are stronger than all problems you've had to face in life," she said.
Tags: How I Learned to Drive, Notre Dame Student Players, sexual abuse, sexual assault, Student Players
About Mary Steurer
Mary is a senior sociology major and journalism minor from St. Louis. An aspiring religion reporter, Mary has spent the last year covering conversations about the Catholic Church sex abuse crisis at Notre Dame.
Show to address sexual issues on campus
This Thursday, the Gender Studies department will host their annual production "Loyal Daughters and...
Sexual assault reported on campus
'The Hunting Ground' producer discusses work, problem of sexual assault
Author discusses storytelling, violence against black women


Sharman, M., Paul, A., Davies, D., MacKay, B., Swinney, G., Barrs, V., Arteaga, A., Robertson, I.D. and Mansfield, C.S. (2010) Multi-centre assessment of mycotic rhinosinusitis in dogs: a retrospective study of initial treatment success (1998 to 2008). Journal of Small Animal Practice, 51 (8). pp. 423-427.
Objectives: To retrospectively review the first treatment response of dogs with mycotic rhinosinusitis to commonly utilised treatment techniques. Methods: Medical records of dogs treated for mycotic rhinosinusitis were obtained retrospectively via a manual review of the clinical databases of six veterinary referral centres for the period of January 1998 to June 2008, and first treatment outcome was evaluated. Historical and clinicopathological findings were also reviewed to evaluate their impact on treatment success or failure. Results: There was no significant difference in first treatment outcome between treatment groups (P=0·21). When all topical treatments were considered together (n=85), 39 dogs (45·8%) had a successful first treatment. Initial treatment success was associated with a younger age (56·3 versus 75·8 months; P=0·02) and was 2·7 times more likely in dogs with unilateral disease, although this was not significant (P=0·07). Adjunctive therapy with systemic antifungal agents was associated with treatment failure (PÄ0·01). Fifty-nine dogs (69·4%) responded successfully following multiple treatments. Clinical Significance: Treatment of mycotic rhinosinusitis remains challenging, and multiple treatments are frequently required for adequate treatment. Reasons for first treatment failure are likely multifactorial in origin, making it difficult to predict those dogs that are likely to have a superior prognosis, regardless of the treatment type used.


text:
Anton Huang
Licensee Agent - Principal
Contact Anton
anton.huang@raywhite.com
In 2007, Anton Huang embarked on a career in real estate. Since then he's gone on to establish a reputation as an industry leader, earning numerous accolades and building a team that's widely regarded as one of the best in the business.
Hard work is the foundation upon which Anton's success has been built, with his relentless pursuit of every angle, lead, and opportunity invariably producing superior results for his clients. It has also helped him build what is quite possibly the largest buyer database of any single agent in the country.
Of course, there's only so much one person can do. Which is why Anton has surrounded himself with a group of highly driven, like-minded real estate professionals. That team, which is made up of nearly a dozen multi-lingual agents and world-class administrators, delivers the best of both worlds – the resources, capacity, and horsepower of a large team, with the care and attention to detail normally associated with smaller ones.
In recent years, Anton and his team have been recognised by the industry on multiple occasions. He claimed the title of No.1 Residential Salesperson for Ray White New Zealand five years in a row from 2016 to 2021, and No.1 Residential Salesperson for Ray White International 2019 -2021. He has also been named both Supreme Salesperson, and Top International Auction Performer.
For Anton, it's not simply about getting the job done - It's about getting the job done well. So, it came as no surprise when the team were ranked in the top 1% during the Ray White International Customer Satisfaction Survey, a testament to the emphasis they place on delivering superb customer care.
This remarkable list of achievements has seen Anton honoured by Ray White with membership to The Chairman's Club, an exclusive group of the company's most acclaimed agents.
If you're looking for an East Auckland specialist with boundless energy, razor-sharp intellect, first-class negotiation skills, and a thoroughly engaging manner, then look no further than Anton Huang and his truly exceptional team.
2021/2022 - Chairman's Elite
2021/2022 - Chairman's Elite Business Leader (office)
2020/2021 - Chairman's Elite Business Leader of Ray White Howick
2019/2020 - International Salespeople - Number of Sales - No. 2
2019/2020 - International Salespeople - Settled Commission - No. 1
2019/2020 - Top Salespeople - Number of Sales - No. 2
2019/2020 - Top Salespeople - Settled Commission - No. 1
2018/2019 - Customer Experience - Salesperson
And 7 earlier awards
Anton's Listings


text:
Carl Myerscough (pronounced Myers/co) (born 21 October 1979) is a retired English track and field athlete. He specialized in the shot put and discus throw and exceeded the British record in the shot put with a best of 21.92m set in winning the NCAA championships in Sacramento, California in 2003, although the performance was not ratified by UK Athletics.

Biography
Carl won the UK championships in the Shot put 10 times consecutively from 2003–12, (The most in any athletics discipline by a male UK athlete). While competing for the University of Nebraska he gained 2 indoor (2002–03) and 2 outdoor (2003-04) NCAA division 1 championships. He graduated from the University of Nebraska in 2004, with a degree in Fine Art.
He won the European Cup in 2004 (Bydgoszcz, Poland) with a throw of 20.85m.

In 2002 (Manchester) he won Bronze in the Commonwealth Games Shot put and in 2010 (Dehli) bronze in the discus throw.

He was a 2012 Olympian.

Nicknamed the Blackpool Tower due to his stats at 6 ft 10" and 25 stone (350 lb).

Doping
In 1999, Myerscough's record was tarnished when he tested positive for the second time, for "a cocktail of banned substances" and was subsequently banned from competing for two years, and banned for life from the Olympics. The Olympic ban was subsequently overturned by the Court of Arbitration for Sport and he represented Team GB at the 2012 Olympics in London. Myerscough placed 29th in the qualifying rounds and did not progress further.

He has always denied knowingly taking drugs and believed he was a victim of sabotage.   Myerscough is married to the American athlete Melissa Price, who was also banned at one time as a result of drug use in connection with the BALCO scandal.

See also
 List of doping cases in athletics

References

1979 births
Living people
People from Hambleton, Lancashire
English male discus throwers
British male discus throwers
English male shot putters
British male shot putters
Olympic male shot putters
Olympic athletes of Great Britain
Athletes (track and field) at the 2012 Summer Olympics
Commonwealth Games bronze medallists for England
Commonwealth Games medallists in athletics
Athletes (track and field) at the 2002 Commonwealth Games
Athletes (track and field) at the 2006 Commonwealth Games
Athletes (track and field) at the 2010 Commonwealth Games
Athletes (track and field) at the 2014 Commonwealth Games
British Athletics Championships winners
AAA Championships winners
Nebraska Cornhuskers men's track and field athletes
Doping cases in athletics
English sportspeople in doping cases
Medallists at the 2002 Commonwealth Games
Medallists at the 2010 Commonwealth Games


Hey, I might try the mocha suggestion. Could you just do it for me one Saturday? Left to my own devices, I keep going back to Cheerios. I know, it's hard to believe you're my daughter. New and improved!
That's such a great idea!! I've never thought of broiling my oatmeal.
I know it's a little weird but caramelized bananas are delicious and this makes oatmeal feel special! You could also just caramelize some bananas and stir them in for the same flavor. I just decided to make it a little prettier =) Give it a shot!


text:
Q: MySQL and PHP with Google Maps - Data source only works locally not when accessing from an http url This code seems to work just fine when using the xml file (generated from php) locally. i.e. /phpsqlajax_genxml.php
However when I try and use the same xml file externally it won't populate. i.e. http://brewslocal.com/phpsqlajax_genxml.php
Any help as to why? Attached below is the code I am using.

<!DOCTYPE html>

<link rel="icon" href="beer-128.png"  >
<title>BrewsLocal - Find More Local Breweries</title>

        <?php include("header.php"); ?>

<input type="text" name="location" id="location" class="main-input" placeholder="Enter A Location" required><button type="submit"  onclick="testlocation()" class="btn" id="location-button" >Locate</button>

A: You are hitting the Ajax Cross Origin.
https://en.wikipedia.org/wiki/Cross-origin_resource_sharing
You can use Access-Control-Allow-Origin header in server who serves phpsqlajax_genxml.php, try to add
header('Access-Control-Allow-Origin: *');

in the start of phpsqlajax_genxml.php maybe that can help.
Or an alternative approach you can use JSONP (but this needs more development for your case.)


text:
package io.digitalis.cassandra.probe.job;

import io.digitalis.cassandra.probe.ProbeLoggerFactory;
import org.apache.commons.lang3.StringUtils;
import org.apache.commons.lang3.time.StopWatch;
import org.quartz.DisallowConcurrentExecution;
import org.quartz.Job;
import org.quartz.JobDataMap;
import org.quartz.JobExecutionContext;
import org.quartz.JobExecutionException;
import org.quartz.JobKey;

import ch.qos.logback.classic.Logger;

import com.datastax.driver.core.ConsistencyLevel;
import io.digitalis.cassandra.probe.Prober;

@DisallowConcurrentExecution
public class ProbeJob implements Job {

    private static final Logger LOG = ProbeLoggerFactory.getLogger(ProbeJob.class);

    @Override
    public void execute(JobExecutionContext context) throws JobExecutionException {
	LOG.info("ProbeJob running...");
	StopWatch stopWatch = new StopWatch();

	JobKey key = context.getJobDetail().getKey();
	JobDataMap dataMap = context.getJobDetail().getJobDataMap();
	String yamlPath = dataMap.getString("yamlPath");
	String[] contactPoints = (String[]) dataMap.get("contactPoints");
	String cqlshrcPath = dataMap.getString("cqlshrcPath");
	String username = dataMap.getString("username");
	String password = dataMap.getString("password");
	boolean nativeProbe = dataMap.getBoolean("nativeProbe");
	boolean thriftProbe = dataMap.getBoolean("thriftProbe");
	boolean storageProbe = dataMap.getBoolean("storageProbe");
	boolean pingProbe = dataMap.getBoolean("pingProbe");

	String testCql = dataMap.getString("testCql");
	ConsistencyLevel consistency = (ConsistencyLevel) dataMap.get("consistency");
	boolean tracingEnabled = dataMap.getBoolean("tracingEnabled");

	int storagePort = dataMap.getInt("storagePort");
	int thriftPort = dataMap.getInt("thriftPort");
	int nativePort = dataMap.getInt("nativePort");

	LOG.info("Instance " + key + " of ProbeJob yamlPath: " + yamlPath + ", and cqlshrcPath is: " + cqlshrcPath);

	try {
	    stopWatch.start();
	    Prober app = null;
	    if (StringUtils.isNotBlank(cqlshrcPath)) {
		app = new Prober(storagePort, nativePort, thriftPort, contactPoints, yamlPath, cqlshrcPath, nativeProbe, thriftProbe, storageProbe, pingProbe, testCql, consistency, tracingEnabled);
	    } else if (StringUtils.isNotBlank(username) && StringUtils.isNotBlank(password)) {
		app = new Prober(storagePort, nativePort, thriftPort, contactPoints, yamlPath, username, password, nativeProbe, thriftProbe, storageProbe, pingProbe, testCql, consistency, tracingEnabled);
	    } else {
		app = new Prober(storagePort, nativePort, thriftPort, contactPoints, yamlPath, nativeProbe, thriftProbe, storageProbe, pingProbe, testCql, consistency, tracingEnabled);
	    }
	    app.probe();
	} catch (Exception e) {
	    String message = "Problem encountered with probing cluster: " + e.getMessage();
	    System.err.println(message);
	    e.printStackTrace(System.err);
	    LOG.error(message, e);
	    throw new RuntimeException(message, e);
	} finally {
	    stopWatch.stop();
	}

    }

}

redpajama_set_name: RedPajamaGithub


The Orange County Landscape Design Network provides networking services among landscape designers, landscape contractors and landscape maintenance professionals who primarily reside and work in Orange County. The Orange County Landscape Design Network also provides a forum to share ideas and to promote growth in landscape design and in the horticulture field. In addition, we are a resource for residential clients, commercial developers and government agencies that need landscape design, installation and maintenance services.


Please prepare a song. As we require you to only sing three minutes of your song, be prepared and have your music cued accordingly. Please do not sing anything from The Little Mermaid.
Please prepare a song and a monologue. As we require you to only sing three minutes of your song, be prepared and have your music cued accordingly. Please do not sing anything from The Little Mermaid.
*An alumnus is a person who has done at least one show with SACT.
Email completed PDF to Janice Flower or bring completed form with you to venue.
Deadline to register is Friday, June 21, 2019.
Interested parties are welcome to show up on the day of the audition if they miss the cut-off date.
Based on one of Hans Christian Andersen's most beloved stories and the classic animated film, Disney's The Little Mermaid is the story of Ariel, King Triton's youngest daughter, who longs to live in the world above. When the evil sea witch, Ursula, grants her the opportunity to sprout legs and go after the heart of Prince Eric, she jumps at the opportunity. With forces working against her, Ariel will need help from her friends and family if she is ever to see her dreams come true.
Bring either a karaoke-type CD or sheet music to the audition (a pianist will be provided).
If neither is available, a cappella singing will work as well.
Please do not bring along your Black Eyed Peas CD and sing along with it.
All material should be memorized.
Please prepare a song (preferably a musical theatre piece) and a monologue.
The largest percentage of people who audition are females aged 11 to 13 years.


I read this article and found it very interesting, thought it might be something for you. The article is called The Record: Breathtaking Views In Tiburon, $13M and is located at https://www.californiahomedesign.com/property/2016/03/08/record-breathtaking-views-tiburon-13m/.
Achieving the highest price paid in February in Marin County, this high-style dwelling is the work of architect David Kotzebue and landscape architect John Merton, framing spectacular views of San Francisco and taking advantage of Tiburon's unique micro-climate with disappearing walls of glass. Replacing the original 1959 structure on the site (in basically the same footprint) in a multi-year project, the 4-bed, 4.5-bath home closed at the end of February for $13M. Bill Smith and Scott Woods of Pacific Union were the seller's agents; Deborah Svoboda of Sotheby's represented the buyer.
The incredible attention to detail begins with concealed garage doors and extends to the open main living area and decks, overlooking Tiburon and San Francisco.
What We Love: Without visible headers and no apparent framing, the roof appears to float. Engineering and flawless construction values!
The lower level is no less spectacular, with bedrooms centered around a media room and office, and walls of glass that literally disappear.
The master bedroom and adjoining bath– with a rain shower, a sunken tub, and fireplace– open to the deck.
Magical: The exquisite infinity pool at night.


The list below will help you identify reasons why you may not be as effective as you would hope to be, and how to overcome these obstacles.
Fear can be so completely debilitating not just for us physically, but mentally as well. If you are too afraid to go out and try to do something that others may not approve of or think you are incapable of achieving, you will never know if you could have been successful at it or not. You simply have to just get over the dissenting voices in your head and from the people around you. It is, after all your life and once you stop worrying about the fear of failing, you will find that you will have improved confidence to venture out of your comfort zone more.
If you have no long-term goals, your lazy and have a negative attitude toward life, the chances of being successful in anything are greatly reduced. The greatest inventors and leader all had the same amount of hours in day that you do, the difference is that, they were able to prioritise what viewed as important and never lost sight of what their goals were. So if you are lazy, get busy. If you are negative, change your outlook, think positively, and if you have no set goal, look at your life and see how you want to improve on it in the future.
You believe that you are incapable of doing anything great because that is just how life is, and you are not gifted enough. That is a LIE! You alone control the trajectory of your success. There is no universal X-FACTOR. What capabilities you may possess, someone else may not, and you need to learn that you are special in your own way and that must be utilised to your advantage.
Distractions have a sneaky way of always getting your attention and turning you from doing what you need to do. It could be people, hobbies or social media, whatever diverts your attention from you being productive, find ways to limit access to them and only indulge once you have completed a set task.
You will not go anywhere career wise, if you only look at what you can do today or even next week. You should dream big. Everyone does it, and in some capacity, people are able to achieve levels of success even if it's small, by simply thinking they CAN DO IT. We do not all have the makeup to run big corporations or be leaders to many, but whatever you think is BIG for you personally, that should drive you to be the best you can be!
While life will not gift you an open opportunity to do as you please, if there is something you have your heart and mind set on, you will have to elevate yourself over life's challenges and WORK PERSISTENTLY to be prosperous.


Barista, barista trainer, coffee researcher, promoter of specialty coffee, coffee and farmer supporter, coffee magazine writer, traveller, adventurist. Love animals, photography and favourite place to visit is Africa.
Direct Traveller guarantees both quality and value-for-money with our multi-award winning service, and exclusive holiday deals. We are excited to keep sharing these beautiful destinations with those that wish to visit them. Book your holidays online, send an enquiry, or call us to create your ideal holiday.
Three buddies waiting for Flora Tristan School of English to open.


Our aim is to enable our wedding couples the freedom to drift into bygone eras of vintage allure and enjoy the run up to their big day, at an affordable price. We remove the hassle, time and money wasting that goes with planning your dream day. Allow our team at vintage affair to become totally immersed in the supply of your desired rental treasures and the hands on styling of your venue.
Vintage Affair remove the typical 'D.I.Y. look' from a wedding, all the unnecessary stress involved in planning a uniquely different type of wedding or event filled with all the extra frills and special added touches to ensure you can have the professionally styled look aswell as saving your budget wisely for other areas of expenditure. We deliver the venue styling of your dreams with unrivaled attention to the smallest of detail across the complete look and feel of your wedding or event, to ensure you enjoy peace of mind during the lead up to and on the best day of your life… Ask about our "Secret Bridesmaid Services" also for the ultimate long or short distance bridal assistance!
From sophisticated hen parties, to engagement high teas, baby showers and Christenings, Vintage Affair brings a touch of old world charm and elegance to any occasion.
Set the tone of any occasion or event with Vintage Affiar's French Shabby Chic Inspired Flower arrangements, bouquets and displays.
The decadent vintage flair of our gorgeous china tea sets, silver tea service and décor accessories for hire, are sure to make your occasion truly unforgettable.
Please see our prices and packages section or contact us directly on studio@vintageaffair.ie to arrange a consultation.


You can get acquainted with the presented collection of Veterans day banner clipart to choose suitable ideas for your business or design interface.
Did you know that The Star Spangled Banner's melody was taken from the English drinking song, "To Anacreon In Heaven" by John Stafford Smith?
Clip Art Veterans Day Black ... 250c61f9084c548db08d21dcf02109 .
Happy Veterans Day. American Flag, Happy Veterans Day greeting card. U.S.A flag.
veterans day banner: Veterans Day label. Happy Veterans Day. Vector illustration.
Happy Veterans Day Clip Art, Coloring Pages, Printable Cards .


Rifles for any application.Adult and Youth. We carry rifles in every configuration (bolt, lever, semi auto and single shot) to assure we have something to meet your needs. We carry everything from hunting and target rifles to home and personal defense rifles in Browning, Savage, Ruger, Mossberg, Howa, Fierce, Daniel Defense, S&W, and Tactical Edge just to name a few. Paducah Shooters Supply has you covered. We have the largest selection of rifles to choose from in the area. If you want something you don't see just ask we would be happy to order it for you.


Improving Linkage to and Retention in Care in Newly Diagnosed HIV-Positive Patients Using Smartphones in South Africa: Randomized Controlled Trial.
Home » Topics » The top 5 most promising drugs (February 2014) » Research » Improving Linkage to and Retention in Care in Newly Diagnosed HIV-Positive Patients Using Smartphones in South Africa: Randomized Controlled Trial.
Summary of "Improving Linkage to and Retention in Care in Newly Diagnosed HIV-Positive Patients Using Smartphones in South Africa: Randomized Controlled Trial."
South Africa provides free antiretroviral therapy for almost 5 million people living with HIV, but only 71% of the eligible people are on treatment, representing a shortfall in the care cascade, especially among men and youth. Many developing countries have expanded access to smartphones; success in health apps raises the possibility of improving this cascade.
Linkage to care and antiretroviral therapy initiation by testing modality among individuals newly diagnosed with HIV in Tanzania, 2014-2017.
To measure linkage to care and antiretroviral therapy (ART) initiation among individuals newly diagnosed with HIV in a rural Tanzanian community.
The HCV care continuum: linkage to HCV care and treatment among patients at an urban health network, Philadelphia, PA.
To determine uptake, adherence and influencing factors to follow-up care by newly diagnosed glaucoma patients from free eye screening exercise.
A new model of early, integrated palliative care: palliative rehabilitation for newly diagnosed patients with non-resectable cancer.
Coordination of activities and programs among health care institutions within defined geographic areas for the purpose of improving delivery and quality of medical care to the patients. These programs are mandated under U.S. Public Law 89-239.


entrepris ce tour du monde, Luc et moi.
je distribue les teeshirts comme Saint Nicolas les bonbons au Bon Marché.
tantôt dansent, tantôt lui tirent les oreilles pour voir ce qu'il a filmé.
le manioc dans un superbe mortier de bois.
grâce naturelle, nonchalante et juvénile.
trop chaude- pendant qu'Eugène déguste une bière avec Batiste.
coquillages et une merveilleuse petite pirogue traditionnelle.
sur la plage, Batiste aiderait à la construction des charpentes.
Chers amis de Nosy Valiha je vous aime.
That's a sharp way of thknniig about it.
Hey, you're the goto exrtep. Thanks for hanging out here.
I have read some good stuff here. Definitely worth bomkoarking for revisiting. I wonder how much effort you put to make such a excellent informative website.
I actually still can not quite believe that I could often be one of those reading the important ideas found on your web site. My family and I are truly thankful on your generosity and for giving me poiiibslsty pursue this chosen profession path. Many thanks for the important information I obtained from your web site.
/ With havin so much written content do you ever run into any problems of plagorism or copyright violation? My website has a lot of exclusive content I’ve either authored myself or outsourced but it looks like a lot of it is popping it up all over the web without my auoirohzatitn. Do you know any solutions to help prevent content from being ripped off? I’d really appreciate it.
Today i came n read the debt in ur blog.U r not only a good writer but a good fheatr.I can see ur affection on ur little prince through ur blog.All the best to u n ur little boy.
Many thanks for you kind shreas, REALLY diggin the Zao album!!! like TN im also into The creator has a master plan, one of the best albums I ve heard by Gilson.. Thanks again!
Ne rien de9cider, c'est de9je0 prendre la de9cision de ne rien de9cider.Mais si la peur d'agir est trop forte, il est toorjuus possible de se poser les questions que vous proposez. Car re9fle9chir, c'est de9je0 pre9-agir, c'est pre9parer l'action.Et une action soigneusement pre9pare9e a de grandes chances d'eatre un succe8s, non ?
sariyaada maathu heliidri, Acharyare. When we know the terrorists can follow what's the after effect of their action, its always better to be silent and take actions against them.


My rabbit had a litter of 6 but they all died but one. The one surviving bunny is 6 days old and I noticed small white flakes all over him this morning. Is this normal or what can I do. Also can this affect humans?
Does anyone know what these white flakes are please?


text:
Argument preview: The retroactive application of Padilla v. Kentucky
Cross-posted from SCOTUSblog.
In 1996, Congress passed the Illegal Immigration Reform and Immigrant Responsibility Act. Through a variety of changes to then-existing law, the Act took steps to facilitate the deportation of non-citizens convicted of crimes.
Aggressively enforcing the reforms, the executive branch has removed record numbers of noncitizens – four hundred thousand per year in the last two years. As a result, the Supreme Court has addressed a growing number of removal cases based on criminal convictions. Earlier this month, for example, the Court heard oral arguments in Moncrieffe v. Holder, in which the government removed a non-citizen based on his criminal conviction for possessing a small amount of marijuana. In addition, the growing intersection of immigration and criminal law — dubbed "crimmigration law" — has spawned a growing genre of legal scholarship. [Disclosure: Goldstein & Russell, P.C., whose attorneys work for or contribute to this blog in various capacities, serves as counsel to the petitioner in Moncrieffe.]
In Padilla v. Kentucky (2010), the Court held that an ineffective assistance of counsel claim under the Sixth Amendment could be based on an attorney's failure to inform a criminal defendant of the risk of deportation resulting from a plea agreement and criminal conviction. In so holding, the Court recognized that "deportation is an integral part – indeed, sometimes the most important part – of the penalty that may be imposed on noncitizen defendants who plead guilty to specified crimes." Next week, in Chaidez v. United States, the Court will hear oral argument on whether Padilla applies retroactively, so that non-citizens who were convicted before its 2010 decision in that case can benefit from it as well. [Disclosure: The law firm of Goldstein & Russell, P.C., whose attorneys work for or contribute to this blog in various capacities, serves as co-counsel to Chaidez, but the author of this post is not affiliated with the firm.]
The case
In 1971, petitioner Roselva Chaidez, a citizen of Mexico, came to the United States; she became a lawful permanent resident in 1977. In 2003, Chaidez, on advice of counsel, pled guilty to mail fraud in connection with an insurance scheme in which she received $1200; the entire scheme netted about $26,000. Chaidez was sentenced to four years of probation. Now fifty-five years old, she lives in Chicago with family members who are U.S. citizens.
Under the U.S. immigration laws, a fraud conviction involving a loss in excess of $10,000 constitutes an "aggravated felony" for which a non-citizen can be deported. In 2009, after Chaidez unsuccessfully filed a petition for naturalization (and subsequently disclosed her criminal conviction in the interview), the U.S. government initiated removal proceedings based on her conviction.
Chaidez filed a motion for a writ of coram nobis to set aside the conviction, claiming that her attorney failed to inform her that a guilty plea could result in removal from the United States. She maintains that, if her attorney had informed her of the possible immigration consequences of the plea bargain, she would not have accepted it. While Chaidez's motion was pending, the Court issued its decision in Padilla.
In Teague v. Lane (1989), the Court held that a new procedural rule announced by a court could not be retroactively applied in a collateral attack on a criminal conviction. Applying Teague to Chaidez's case, the district court vacated her conviction, holding that Padilla applied the well-established rule – and thus not a new rule — that ineffective assistance of counsel violated the right to counsel under the Sixth Amendment.
A divided panel of the Seventh Circuit reversed. The court held that because Padilla in fact announced a new constitutional rule, it could not, under Teague, apply retroactively to Chaidez's conviction. In its view, Padilla would be considered an established rule only if precedent "compelled the result" – which, as demonstrated by the fact that the Justices on the Court expressed such an "array of views," it did not.
The arguments
The arguments by the parties in the merits briefs are fairly predictable. Chaidez contends that Padilla did not announce a new rule but rather was simply a fact-specific application of the well-established rule that, under the Sixth Amendment, an attorney in a criminal case must provide reasonably effective assistance. Chaidez's lawyer thus had a duty to advise her of the immigration consequences of her criminal conviction.
In contrast, the government argues that the Seventh Circuit was correct that Padilla announced a new rule and does not apply retroactively to collaterally challenge Chaidez's conviction. Before Padilla, the applicable precedent did not require counsel to provide advice on matters that were not directly part of the criminal case.
As the Court has recognized, deportation is a harsh measure. In Padilla, the Court acknowledged that that the possible removal due to a criminal conviction may be more important to a non-citizen than the punishment. In so doing, the Court held that an attorney who fails to advise a client of the immigration consequences of a plea may be guilty of ineffective assistance of counsel under the Sixth Amendment. It further noted that roughly ninety-five percent of the criminal convictions today are obtained through plea bargains similar to Chaidez's. Knowledge of possible deportation as a consequence of a plea is a critical ingredient to a non-citizen's informed judgment about accepting the plea.
In Chaidez, the Court will decide the full reach of its decision in Padilla. That decision in turn will have an impact on a great many non-citizens with criminal convictions before 2010 – many of whom in these times of increased immigration enforcement are frequently caught up in the removal machinery of the U.S. government.
From an immigration standpoint, the government is focusing resources on the detection, arrest, and removal of immigrants convicted of crimes, including crimes that many generally would not view as sufficiently serious to subject a person who has lived decades in the United States, like Chaidez, to removal from the United States. The Obama administration and future administrations will likely continue to focus for the foreseeable future on removing "criminal aliens" – a politically unpopular group — from the United States.
In these times, defense counsel unquestionably should know that noncitizens are subject to serious immigration consequences, including possible removal, for almost any criminal conviction. The 1996 reforms made the immigration consequences of many criminal convictions all the more onerous – and well-known among defense counsel. Indeed, many treatises and practice guides as early as the 1980s observed that defendants could not knowledgeably decide whether to accept a plea bargain without weighing the possible deportation consequences of a criminal conviction. In that light, it was patently unreasonable for Chaidez's counsel in 2003 to fail to advise her of possible removal due to the plea and conviction.
by Kevin Johnson at 2:31 PM in Criminal Law and Procedure, Immigration Law and Policy, Supreme Court
An Update on the National Popular Vote Movement and Other Election Reform As the 2012 Presidential Election Looms
With the Obama-Romney election nearly upon us, my column today updates readers on the status of various presidential election reform efforts (a topic about which I have written columns for this site in the past).
A number of initiatives that were undertaken over the last year fell apart. The online third party effort, Americans Elect-a movement that strove to put a "nonpartisan" (or in reality, a bi-partisan) presidential/vice-presidential candidate slate, determined by citizens around the country who participate in an "online convention," on the ballot in all 50 states-fizzled. So too did partisan efforts in Pennsylvania and Nebraska to change the way in which those two states will divvy up their blocks of electors in the so-called electoral college in the 2012 election. And the coordinated National Popular Vote (NPV) movement about which I have written a great deal, both in academic literature and in online columns, has not picked up any new state participants since California got the plan nearly halfway to national success by adopting NPV legislation over a year ago. (For those who are unfamiliar with the basic structure of the NPV plan, this column from 2011 should provide sufficient background.)
It is not surprising that very little election reform-or any other significant government business-gets accomplished in an election year; election years are known for legislative gridlock generally, and election reform often raises concerns about partisanship and election-result manipulation (as is true, for example, with some of state voter-ID laws that have been adopted in the last few years).
The NPV and the 2012 Election: The Election Will Surely Feature Many Ignored States, and Could Result in a Possible Inversion of 2000
But the 2012 presidential election cycle is far from irrelevant to the future of election reform. Take the National Popular Vote movement. The plan has two big selling points: One is the idea that everyone's vote throughout the country should, as a formal matter, be counted equally; the other is that the way the electoral college currently operates (largely because of winner-take-all rules in most states) tends to make only "swing" or "battleground" states relevant to the two major candidates. As a result, all the other states-and their particular needs-get very little attention during the campaign season.
This is a powerful critique of the current system in any election year, and it is especially illustrated by this year's election dynamics. There are only roughly nine out of the 50 states where Romney and Obama have any real reason to spend time and make promises, leaving the rest of us more or less neglected by the person who will become President. If this pattern (of the candidates' focusing on a small and/or shrinking number of battleground states) persists (and I should acknowledge that some think it might not, depending on demographics), then the incentive of the neglected states to try to tweak the present system should grow.
Perhaps even more important for the chances that the NPV coordinated-state movement will succeed is the specter that Governor Romney will, in 2012, win the national popular vote but lose in the electoral college. A number of political analysts and pollsters say that this is quite possible (in the same way that, in 2000, George Bush (R) became President even though Al Gore (D) won more votes nationwide.)
Why might a Romney popular-vote-win/electoral-college-loss affect NPV's prospects? Because up until now, all of the states that have adopted the NPV bill have been Blue states-states that are generally assumed to lean towards the Democratic, rather than the Republican, candidate for President. And unless a Red state joins soon, it will become increasingly hard to debunk the (wrongheaded) fear that Red state folks have that the National Popular Vote bill is a Democratic scheme, rather than a democratic idea.
The reality is that, during this window in American history at least, a move towards a national popular vote would not benefit or hurt either party in particular. It is true that a Democrat was stung by the conventional electoral college operation in 2000, but even in that year, things could just as easily have been the other way around (and indeed many analysts predicted before that election that they would be the other way around, with Bush winning the popular vote but losing the presidency.) And in 2004, President Bush won reelection by beating Democrat John Kerry by about 3 million votes nationwide, and yet if Kerry had won just over 60,000 more votes in Ohio away from Bush, Kerry would have prevailed under the current electoral college system.
So there is nothing inherently partisan about the modern national popular vote movement. Given the competitiveness of the two parties nationwide, and given the reality that if a national popular vote system were in place, both campaigns would build their strategies around it, there is no reason to expect that adoption of the NPV system would, if put into effect, benefit one party over the other.
But while some prominent Republicans (like Fred Thompson, a 2008 Republican Presidential candidate and former U.S. Senator; former Republican Governor Jim Edgar of Illinois; and the Republican-controlled state Senate in New York, all of whom support the NPV idea) understand all this, the compelling theoretical case that the electoral college could bite the Republican presidential candidate, just as it bit a Democrat in 2000 would be immensely buttressed by a real-world modern data point. For instance, if Romney were to suffer the same fate in 2012 that Gore did in 2000, that might be sufficient to put some Red states into the NPV column.
The Question of the Need for Congressional Approval of NPV State Coordination
If NPV does attract new states in 2013 and beyond, the question of whether Congressional approval is required before the plan goes into effect will take on greater salience.
The Constitution does require that Congress approve some interstate agreements/compacts before they go into effect, but the Court's case law is very underdeveloped in this area. The most comprehensive analysis came in the late 1970s, in a case in which the Court held that Congressional approval was not required with respect to a multistate tax commission that made recommendations that various states could then consider adopting. The Court there said that the two key factors in determining whether an agreement between two or more states requires Congressional approval are whether the agreement threatens (1) the supremacy of the federal government, or (2) the sovereignty of non-signatory states. Because the tax commission at issue in the case before the Court did neither-and essentially allowed each state to accomplish no more than it could absent the agreement-no approval by Congress was required.
It could be argued, on one hand, that the coordinated NPV plan should not be subject to the Congressional approval requirement; under Article II of the Constitution, each state is free to allocate its electors however it chooses, and so states' making their allocations contingent on what other states are doing may not be objectionable, especially since the signatory states are not trying to exclude or in any way discriminate against the non-signatory states. (It may be important in this regard that all states are welcome to join the NPV coordination, and that the national popular vote tally is based on voter preferences in all states, not just the ones that have embraced the plan.)
On the other hand, the NPV plan that states have been adopting does give signatory states the right to do something that they could not do absent the plan: enforce a right to prevent other signatory states from changing their allocation methods late in the election cycle.
Moreover, to the extent that the NPV plan is sold-and viewed-not just as a way to make everyone's vote in the nation equal (my preferred rationale), but also to enhance the attention paid to currently neglected states that are urged to join the plan for that selfish reason, the plan may begin to look like a campaign-attention power-grab by signatory states vis-à-vis the other, non-signatory states, implicating the Supreme Court's state concern about interstate federalism.
But the Supreme Court has not spoken much on these issues in over three decades, and its most recent important rulings were handed down by a Court that included none of the members of the current Court. So the question whether the Court would find Congressional approval required for coordinated state action here is somewhat open.
Might One or More States Move to NPV Unilaterally?
Meanwhile, there is, at least in theory, the possibility that a state could consider allocating its electors to the national popular vote winner, rather than to the candidate who won the most votes in that state, regardless of whether other states are doing so.
I have speculated on this possibility in an earlier column, in which I asked whether a swing state (like Ohio) might be convinced to act selflessly in order to effectively bring about NPV. At a recent election-reform conference I attended at M.I.T., I learned of some work that is being done by voting-method luminary Steve Brams (of N.Y.U.) and one of his colleagues, that might suggest that some states could have selfish reasons to adopt an NPV approach unilaterally, insofar as a move by a presently ignored state to allocate its electors to the national vote winner might increase that state's own campaign clout. I hope to explore that possibility in greater detail in a future column, after next month's election.
by vdamar at 11:45 AM in Constitutional Law, Election Law
Shenandoah Screening at UC Davis School of Law
On Tuesday evening, UC Davis School of Law hosted the West Coast premiere of Shenandoah, a documentary about a coal mining town with a rich immigrant heritage, which was dramatically challenged when four of the town's white, star football players were charged in the beating death of an Mexican immigrant named Luis Ramirez. In it, Pulitzer Prize-winning photographer David Turnley creates a deeply felt portrait of a working class community and the American Dream on trial.
Turnley and Billy Peterson, Executive Producer and CEO of Epic Match Media, were in attendance for the showing of the film. Carlos Gonzalez Gutierrez, the Consul General of Mexico in Sacramento, was also a guest.
Executive Producer Peterson, Director Turnley, Ambassador Gonzalez, and me
Ambassador Gonzalez addresses the audience before the film.
Along with Turnley and Peterson, immigration law expert (and former ImmigrationProf blogger) Professor Leticia Saucedo participated in a fascinating discussion and analysis of the film after the showing.
The film, in my estimation, is much more than about the tragic death of Luis Ramirez, although we learn many insights about that story. The film demonstrates the nation's need to confront and address racism in modern American social life as well as the often harsh impacts that the changing national and world economies on small-town America.
Shenandoah also reveals much about the tough times in which we live in terms of immigration. Harsh talk of "illegal aliens", "anchor babies", and worse create the kind of environment in which a hate crime like the killing of Luis Ramirez by a group of all-American boys can occur. As has been reported, hate crimes directed at Latinos have been at high levels for a number of years. It does not seem coincidental that the frequently coarse debate over immigration, and the failure of Congress to pass comprehensive immigration reform, has occurred over the same time period of high levels of hate crimes against Latinos. The film this made me consider just how important moving forward on immigration reform was.
Shenandoah also causes one to think about whether the hyper-aggressiveness of beloved high school football in a small town contributed to the violence that resulted in a tragic death. A somewhat surprising feature of the film was the personal growth of Brian Scully, one of the perpetrators of the crime, who admitted his role in the horrible incident, later testified against other defendants, and grew personally from his experience (and moved away from high school football).
Last but not least, the U.S. Department of Justice under President Obama brought federal civil rights charges against the wrongdoers after a jury in state court found the defendants guilty of only simple assault, the least serious criminal charge. That intervention thus brought some modicum of justice to those who participated in the beating death of Luis Ramirez. The Obama administration has demonstrated more of an interest in these kinds of prosecutions than the Bush administration.
If you get a chance to see Shenandoah, I highly recommend it.
by Kevin Johnson at 4:20 PM in Civil Rights, Immigration Law and Policy
Rose Villazor Joins ImmigrationProf Blog
As many of you know, I am an editor at ImmigrationProf Blog.
We are very pleased to welcome Professor Rose Cuison Villazor to the ImmigrationProf blog as an editor.
An accomplished and influential immigration and civil rights scholar, Rose joined the UC Davis faculty in 2012 from the Maurice A. Deane Law School at Hofstra University. She has also taught at Columbia Law School and the Southern Methodist University Dedman School of Law.
Professor Villazor teaches and writes in the areas of property law, immigration law, race, and citizenship. Her scholarship includes, "The Other Loving: Uncovering the Federal Regulation of Interracial Marriages," in the New York University Law Review (2011), "Rediscovering Oyama v. California: At the Intersection of Property, Race and Citizenship," in the Washington University Law Review (2010), and "Blood Quantum Land Laws: The Race versus Political Identity Dilemma," in the California Law Review (2008). She has also been published in the Southern California Law Review, UC Davis Law Review and Southern Methodist University Law Review.
Rose is co-editor of a book titled Loving v. Virginia in a `Post-Racial' World: Rethinking Race, Sex, and Marriage published by Cambridge University Press.
Welcome to ImmigrationProf Blog, Rose! We look forward to your energy, enthusiasm, and intellect.
by Kevin Johnson at 3:40 PM in Immigration Law and Policy
Was Justice Scalia Right That Many Contentious Constitutional Issues Are "Easy" to Resolve?
Entry cross-posted from Justia's Verdict.
Justice Scalia made news last week for some remarks he offered concerning "easy" constitutional disputes. In particular, he suggested that challenges to the constitutionality of the death penalty, laws restricting abortions, and limits on the rights of gays and lesbians to engage in homosexual activity should be easy to reject because they fail the test of textualism/originalism, the mode of constitutional interpretation that he has said he prefers. In the space below, I analyze this mode, and discuss whether its use in the way Justice Scalia favors is, in reality, so easy.
The Essence of Originalism and Justice Scalia's Application of It to Current Hot-Button Issues
Originalism is a term used, in modern times, to describe a particular approach to constitutional (and sometimes statutory) interpretation that seeks to understand and apply the text of the document as "intelligent and informed people of the time" of the document's enactment would have. Justice Scalia has explained that originalism seeks to construe text "reasonably, to contain all that it fairly means."
Under originalism, the meaning that counts is "the original meaning of the text" –"how the text of the Constitution was originally understood" by interpreters of the day. What the original draftsmen (that is, the people who actually wrote the words) subjectively intended might be evidence of what the words meant at the time, but any divergence between the drafters' subjective intentions and the most likely understandings of those words at the time of enactment would be resolved in favor of the latter.
In any event, according to Justice Scalia, the "Great Divide with regard to constitutional interpretation [today] is not that between Framers' intent and [original] objective meaning, but rather that between original meaning (whether derived from Framers' intent or not) and current meaning." Originalists reject the notion of "current meaning" and a "Living Constitution" primarily because, they argue, it vests too much discretion in modern judges and Justices to do whatever they please when they interpret the Constitution.
In a recent book event at the American Enterprise Institute, Justice Scalia reportedly said the following in applying his methodology to some legal disputes that have generated controversy and division on the Court over the past few decades:
The death penalty? Give me a break. It's easy. Abortion? Absolutely easy. Nobody [at the time of the Fourteenth Amendment, whose due process clause has been used by the Court to recognize abortion rights] ever thought the Constitution prevented restrictions on abortion. Homosexual sodomy? Come on. For 200 years [including at the time of the Fourteenth Amendment], it was criminal in every state.
Are Things Really So Easy? Cases That Scalian Originalism Might Call in Question
Is Justice Scalia correct that his approach would make seemingly vexing constitutional disputes like these "easy"? For starters, I'm not completely sure that applying Scalia's test to these realms would always provide clear answers over which historians would not argue; the task of discerning what words meant to intelligent and informed people of a bygone time is frequently far from simple. But even if Justice Scalia could convince me that his approach were easy in that it generates clear answers to the three particular disputes he mentioned, I don't think, for reasons I explore below, that the application of his approach across the constitutional realm would make things easy in any larger relevant sense.
Before I discuss the complexities of applying originalism writ large and uber alles, let me make clear that that (as I have written before) I consider myself an originalist in that I think interpreting text without looking at the historical context that generated that text makes no sense. In other words, I think originalism, properly understood and consistently applied, is a very important component of legitimate constitutional interpretative methodology, notwithstanding my disagreement with the way Justice Scalia (and others on the Court) seem to have understood and implemented the idea of originalism in some settings.
But to say that originalism is important and helpful does not mean that it is easy. To see this, let us first look at what it would mean to say that all constitutional disputes should be analyzed and resolved by exclusive reference to originalism. It would mean, among other things, that the Supreme Court's cases from the 1960s holding that states may not impose poll taxes or property qualifications on the franchise, because under the Equal Protection Clause and other parts of Section One of the Fourteenth Amendment there is an individual right to vote for legislative elections, are flawed. So too would be the cases holding, again under the Equal Protection Clause, that states cannot draw voter districts of significantly different sizes (thereby discriminating against urban voters); originalism would call into question the idea that the Equal Protection Clause guarantees "one person, one vote" in legislative elections.
These cases would be candidates for overturning because it seems pretty clear that no one at the time of the Fourteenth Amendment's adoption in 1868 would have understood the words of Section One of that Amendment, including the Equal Protection Clause, to have anything to say about voting rights; the Amendment was written and explained to intelligent and informed interpreters of the day as being about "civil rights" (largely involving property rights), but not so-called "political rights," such as voting and jury service.
Indeed, it's hard to believe that informed and intelligent observers in 1868 would have understood the Amendment's words requiring "equal protection of the laws" as forbidding racial segregation in schools or parks or water fountains. Nor would folks in 1868 have understood those words as invalidating limits on interracial marriage. Thus, cases like Brown v. Board of Education in 1954 (invalidating school segregation) and Loving v. Virginia in 1967 (invalidating bans on interracial marriage) might be vulnerable under Justice Scalia's approach.
Even more vulnerable would be cases dating back to the 1970s holding that discrimination on the basis of gender is problematic under the Equal Protection Clause; the idea that people in 1868 would have understood the Clause to prohibit gender-based classifications is easily refuted by the historical record.
And, closer to the abortion setting that Justice Scalia mentioned in his recent remarks, it is hard, on originalist grounds, to explain Griswold v. Connecticut, the 1972 case invalidating Connecticut's ban on contraception under the Due Process Clause of the Fourteenth Amendment; it's easy to say that people in 1868 would not have expected the Due Process Clause to have any application to bans on contraception that were then in existence, and that would persist, in most places, for decades.
Even the sexual sodomy setting that Justice Scalia adverts to is fraught with complexity. Justice Scalia says homosexual sodomy was made criminal for 200 years, so any claims of a constitutional right under the Fourteenth Amendment to engage in that activity are easily rejected. And homosexual sodomy was widely criminalized in 1868. But so was heterosexual sodomy! Does that mean that, under an originalist approach, a state could prohibit oral sex between a consenting man and woman in the context of a committed relationship today?
Some Non-Originalist Outcomes That Justice Scalia Has Embraced
Perhaps Justice Scalia could live with all the potentially disruptive results that I have described above, which might be dictated if we applied originalism to these realms. But originalism also calls into question some results that we know Justice Scalia has supported. For example, there is no strong originalist case against race-based affirmative action, and yet Justice Scalia has embraced the rights of non-minorities to challenge affirmative action under the vision of a colorblind Constitution. Justice Scalia has voted to aggressively protect commercial speech and the free speech rights of minors even though, at the time the First Amendment was adopted (and the time it was applied to the states through the Fourteenth), there is little to suggest that intelligent and informed folks of the day would have understood that these amendments would interfere with the myriad limits on commercial and children's speech that were in effect at those times.
Or take the Eleventh Amendment, which the Court (with Justice Scalia's support) has held protects States from being subject to liability for damages when state entities violate federal law, even though the text and history of the Eleventh Amendment refute, rather than support, any suggestion that intelligent folks of the day would have understood the Amendment to create such absolute immunity.
Counterarguments Make Things Harder, and Thus Further Undermine Scalia's "Easy Cases" Claim
Some of the difficult questions I've raised above, about what a fully originalist legal world would look like, might be answered by creative rejoinders. For example, sometimes cases that are "wrongly reasoned" from an originalist perspective might nonetheless reach a result that is correct for other reasons. Here's an illustration: Justice Scalia might say that the Eleventh Amendment immunity cases are correct not because they read the Eleventh Amendment properly, but because there is a general structural protection for states that emanates from the Constitution as a whole, putting aside the precise contours of the Eleventh Amendment.
But such a nuanced response takes us far beyond the realm of "easy." And such a response might be available to support other, non-originalist, case holdings with which Justice Scalia may not agree. For example, some have argued that the "right to vote" and malapportionment cases may not jibe with original understandings of the Equal Protection Clause (on which they purport to be based), but are nonetheless defensible under, respectively, Section Two of the Fourteenth Amendment (a different part of that Amendment) and the Republican Guarantee Clause that is found in another part of the Constitution.
Another possible rejoinder, in some settings, is that States acting as outliers are vulnerable to constitutional challenge. Perhaps Justice Scalia would explain Griswold (and its protection of access to contraception) that way; in the Griswold case, Connecticut was virtually alone in that most other states had repealed or stopped enforcing their bans on contraception. But getting around originalism this way in Griswold creates complexities for cases involving homosexual sodomy, because very few states try to criminalize homosexual conduct in the way Texas did in Lawrence v. Texas (the 2005 case invalidating Texas' law, over Justice Scalia's animated dissent.) And certainly some states do look like outliers today with respect to various aspects of the death penalty, an area in which Justice Scalia finds it easy to reject claims.
Yet another rejoinder involves the level of generality at which one discerns the understandings of the intelligent people at the time of enactment. Take racial segregation. Folks who looked at the Equal Protection Clause in 1868 may have understood and expected that it would prohibit a system of state-imposed disrespect based on the race into which a person happened to be born, but they simply did not understand that segregation should be understood as visiting such disrespect. In instances like this, there may be clashes between the understandings of a constitutional provision's larger aspirations and its narrower applications. Choosing to implement the former may not disrespect the values of originalism.
But once we start making moves like that, things get complicated. If the Equal Protection Clause is understood, in originalist terms, to be about an anti-caste principle, why cannot that principle be understood to extend to women, gays, and lesbians if they too are being disrespected simply because of the group into which they are born?
And past judicial precedent is an additional (though by no means the only other) complexity worth mentioning. Sometimes we might eschew originalism because there are already cases on the books that have decided the key questions. But, in this regard, it is interesting that Justice Scalia does not seem to feel bound by precedent in the three areas—abortion, same-sex conduct, and the death penalty—that he mentions.
My point here is not to disagree with any particular outcome that Justice Scalia supports in these or other areas—in fact, I sometimes agree with his constitutional bottom line, and at other times do not. But my goal here has simply been to suggest that all of this stuff is a long way from "easy."
by vdamar at 10:46 AM in Constitutional Law, Supreme Court


Celeste Barber will take the Boch Center Shubert Stage Friday, June 21!
Actor, Comedian, and Social Media Super Star Celeste Barber is the self proclaimed queen of everyday sophistication and low budget lifestyle aspirations. Her meteoric rise on Instagram, parodying celebrity photographs, has resulted in her taking meetings with top moguls of the entertainment industry and awkwardly becoming friends with the very people she is parodying.
In this exciting live show experience Celeste explains the story behind some of her most famous images, her new relationship with famous people, and the stalkers, fans and comments that get under her skin. Hailed as The Funniest Woman on Instagram, Celeste also hits us with a healthy dose of humour, as she explains some of the pit falls of being married to someone so much hotter than her (shoutout to #hothusband) and what it's like to be an Anti Influencer.
This restored 1500+ seat theatre; and considered Boston Theater District's "Little Princess", continues to be the home for many local community arts organizations. The Shubert Theatre also serves as a venue for the touring companies that present Broadway, theater, music, dance, and opera.


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