The last decade has seen a striking rise in Russian cases before the European Court of Human Rights. The influence of its case-law can be seen in all areas of Russian life, becoming a reality on the ground, a genuine impulse for change. Russia, the Court`s biggest `client`, has also played its part in the major development of the Convention system. Judge Anatoly Kovler has left his mark on this important period for the Convention and for Russia. Beyond his judicial achievements, which are illustrated by hundreds of judgments, he has become a key figure in the dialogue between the Court and the national authorities, thus acting as a bridge between two different environments. These theoretical and practical essays are published in his honour by his colleagues and friends. The Russian perspective is presented notably by Valery Zorkin, President of the Constitutional Court, and Tatiana Neshatayeva, former Judge at the Supreme Commercial Court. The decade of change from the Court's viewpoint is highlighted by, among others, its President Dean Spielmann, former Section President Nina Vajic, Deputy Registrar Michael O`Boyle, and former Registrar and Jurisconsult Michele de Salvia. A personal testimonial by the former President of the Court, Jean-Paul Costa, enriches this book along with Professor Frédéric Sudre's insight into Judge Kovler's separate opinions.
Yesterday, the Council of Europe's Parliamentary Assembly (PACE) elected Jon Fridrik Kjølbro to become the new judge at the Court in respect of Denmark. Kjølbro's term will last nine years and will start within three months from now. He will succeed Peer Lorenzen, a longtime judge at the court since its reform into a fulltime Court in 1998 and before that for several years a member of the former European Commission of Human Rights.
Kjølbro was elected from the list of three candidates submitted by Denmark and was elected by a large majority, obtaining more votes than the other two candidates combined. Jon Fridrik Kjølbro is currently a high court judge at the Eastern High Court in Copenhagen and previously worked at the Danish Ministry of Justice, where he - amongst other functions - served as the head of the human rights office. He is also part time vice-chairman of the Refuge Board which deals with asylum cases. The new judge thus has solid experience both in the executive and judicial branches of government.
His curriculum vitae, as well as a description of Denmark's open application process for the position, can be found here.
The European Convention on Human Rights has been a standard-setting text for transitions to peace and democracy in states throughout Europe. This book analyses the content, role and effects of the jurisprudence of the European Court relating to societies in transition. It features a wide range of transitional challenges, from killings by security forces in Northern Ireland to property restitution in East Central Europe, and from political upheaval in the Balkans to the position of religious minorities and Roma. Has the European Court developed a specific transitional jurisprudence? How do politics affect the ways in which the Court's judgments are implemented? Does the Court's case-law itself become woven into narratives of struggle in transitional societies? This book seeks to answer these questions by highlighting the unique role of Europe's main guardian of human rights, the Court in Strasbourg. It includes a comparison with the Inter-American and African human rights systems.
Includes a comparison with the African and Inter-American human rights systems, enabling an understanding of both the unique features of the ECHR on this topic as well as experiences gained in other regions of the world.
Eight hundred million Europeans' fundamental rights and liberties are supposed to be safeguarded by the European Court of Human Rights. It is an institution steeped in European idealism and ambition, but does it work? HARDtalk speaks to the President of the Strasbourg based Court, Dean Spielmann. Critics condemn it as an undemocratic, unaccountable infringement on national sovereignty; do they have a case?
The obligation for the European Union to accede to the European Convention of Human Rights (ECHR) opens a window of opportunities for the recognition of fundamental social rights in the European Union. The prospects of the accession for strengthening workers' rights have been examined in a comprehensive study which has been pushed by the Transnational Trade Union Rights Expert Network. It focuses on the ECHR provisions and the Strasbourg case law which is relevant to strengthen workers' protection, inter alia through safeguarding civil and political rights at work. The Dialogue between the European Court for Human Rights and other European judicial or quasi-judicial bodies is at the heart of this publication. It also focuses on the tribute paid by the Strasbourg Court to international instruments.
The Colloquy seeks to present the outcome of the research project by some of the authors of the book (with the same title as the colloquy, see my earlier post here) and to allow for a critical debate with other European academics who are renowned social rights and human rights scholars. We are pleased that some of the judges (still in office or honorary judges) of the European Court for Human Rights, present and former members of the European Committee for social rights and a member of the ILO Expert Committee for the application of Conventions and Recommendations have accepted to participate to this Conference.
The recent judgment of the Grand Chamber of the European Court of Human Rights ('the ECtHR' or 'the Court') in Vinter and Others reflects a very significant change in the Court's attitude to those actions of the states parties to the European Convention for the Protection of Human Rights and Fundamental Freedoms ('the Convention' or 'the ECHR') that consist in the imposition and further execution of whole life sentences. In this judgment, the Court concluded that Article 3 of the Convention – which prohibits torture, inhuman or degrading punishment – requires the reducibility of all whole life sentences as imposed by national courts, in the sense of a review mechanism which allows domestic authorities to conclude whether in the course of a life sentence the legitimate peno-logical grounds justifying the further incarceration of a life prisoner still exist. Moreover, such a mechanism or possibility for review of a whole life sentence must be provided for by a national law and, consequently, must be known to a life prisoner already at the moment of imposition of the whole life sentence. What is also important, a life prisoner, at the outset of his/her sentence, must know when (i.e. after how many years) and under what conditions a review of his/her sentence will take place or may be sought, and what he/she must do to be considered for release. Otherwise, the very imposition of a life sentence by a national court infringes Article 3 of the Convention.
The concept of vulnerable groups is gaining momentum in the case law of the European Court of Human Rights. The Court has so far used it in cases concerning Roma, people with mental disabilities, people living with HIV, and asylum seekers. Yet the appearance of the vulnerable-group concept in the Court's legal reasoning has so far escaped scholarly attention. Drawing on theoretical debates on vulnerability as well as on the Court's case law, this article offers a critical assessment of the concept. Reasoning in terms of vulnerable groups opens a number of possibilities, most notably, the opportunity to move closer to a more robust idea of equality. However, the concept also has some inherent difficulties. This article argues for a reflective use of the concept and points out ways in which the Court can avoid its pitfalls.
PS: The photo depicts Utrecht University's beautiful and recently renovated inner city library, which includes the human rights law collection.
Please find an overview below of recent ECHR-related Council of Europe reports and online coments on other blogs relatign to the ECHR, for your convenience. The first is a report adopted by the Legal Affairs Committee of the Parliamentary Assembly of the Council of Europe. It chastises those states that have ignored or failed to implement the European Court's interim requests. It also calls upon the Court to be as precise as possible in indficating interim measures and also to explore the possibility of damages in cases of violations of interim measures. The report is entitled 'Urgent need to deal with new failures to cooperatie with the European Court of Human Rights'. The press release of the Council of Europe on this can be found here.
* Rosalind English, 'Court of Appeal calls on Supreme Court to resolve conflict between UK and Strasbourg law' on UK Human Rights Blog.
* Adam Wagner, 'Don't mess up your European Court of Human Rights application… a new rule' on UK Human Rights Blog.
* Stijn Smet, 'ECtHR Rules that Police Officers Can Slap Suspects in the Face Without Contravening Article 3 ECHR: Bouyid v. Belgium' on Strasbourg Observers.
* Georgios Milios, 'The application of the European Convention on Human Rights to the case of Leonarda Dibrani' on Strasbourg Observers.
* Erica Howard, 'Banning Niqabs in Public Spaces', on EJIL Talk!
* Marko Milanovic, 'Hassan v. United Kingdom, IHL and IHRL, and Other News in (Extra-)Territoriality and Shared Responsibility' on EJIL Talk!
The European Human Rights Culture – A Paradox of Human Rights Protection in Europe? analyses the political term "European Human Rights Culture", a term first introduced by EU Commission President Barroso. Located in the fields of comparative law and European law, this book analyses, through first-hand interviews with the European judiciary, the judicial perspective on the European human rights culture and sets this in context to the political dimension of the term. In addition, it looks at the structures and procedures of the Court of Justice of the European Union (CJEU) and the European Court of Human Rights (ECtHR), and explains the embedding of the Courts' legal cultures. It offers an in-depth analysis of the margin of appreciation doctrine at both the CJEU and ECtHR, and shows its value for addressing human rights grievances. This book is novel in that it combines interviews and case-law analysis to show how a mix of differences on the bench are legally amalgamated to resolve probing legal questions and human rights issues. It shows, through a combined analysis of case-law and recent political developments for European human rights, the tensions between judicial and political approaches and the paradox of human rights protection in Europe. It also offers in-depth knowledge of the European human rights discourse. In addition to a rich study of legal materials, the book looks inside the box by adding the judiciary's perspective. Human rights are widely acknowledged in European societies and cases claiming human rights violations are increasing at both the CJEU and ECtHR. In these times of increased human rights awareness, this book uncovers a paradox in European human rights protection which is created by the push-and-pull between judicial and political interests.
On 17 December 2013 the European Court of Human Rights ruled by five votes to two that Switzerland violated the right to freedom of expression by convicting Doğu Perinçek, chairman of the Turkish Workers' Party, for publicly denying the existence of the genocide against the Armenian people. On several occasions, Perinçek had described the Armenian genocide as "an international lie". The Swiss courts found Perinçek guilty of racial discrimination within the meaning of Article 261bis of the Swiss Criminal Code. This article punishes inter alia the denial, gross minimisation or attempt of justification of a genocide or crimes against humanity, publicly expressed with the aim of lowering or discriminating against a person or a group of persons by reference to race, ethnic background or religion in a way that affects the human dignity of the person or group of persons concerned. According to the Swiss courts, the Armenian genocide, like the Jewish genocide, was a proven historical fact, recognised by the Swiss Parliament. They found that Perinçek's motives denying that the Ottoman Empire had perpetrated the crime of genocide against the Armenian people in 1915 and the following years, were of a racist tendency and did not contribute to the historical debate. Relying on Article 10 of the European Convention, Perinçek complained before the Strasbourg Court that the Swiss authorities had breached his freedom of expression. In an impressive judgment of 80 pages, only available in French for the moment, the Court elaborates the issue profoundly. The judgment also contains in annex, on 18 pages, a firm and extensively documented dissenting opinion by two judges.
"(..) la limite tolérable pour que des propos puissent tomber sous l'article 17 réside dans la question de savoir si un discours a pour but d'inciter à la haine ou à la violence. La Cour estime que le rejet de la qualification juridique des événements de 1915 n'était pas de nature en lui-même à inciter à la haine contre le peuple arménien. De toute façon, l'intéressé n'a été ni poursuivi ni puni pour incitation à la haine, qui est une infraction distincte en vertu de l'alinéa premier de l'article 261bis du code penal. Il n'apparait pas non plus que le requérant ait exprimé du mépris à l'égard des victimes des événements en cause. Dès lors, la Cour estime que le requérant n'a pas usurpé son droit de débattre ouvertement des questions, même sensibles et susceptibles de déplaire. L'exercice libre de ce droit est l'un des aspects fondamentaux de la liberté d'expression et distingue une société démocratique, tolérante et pluraliste d'un régime totalitaire ou dictatorial" (§ 52).
"(..) on ne saurait prétendre que le requérant ait utilisé le droit à la liberté d'expression à des fins contraires à la lettre et à l'esprit de la Convention et, dès lors, détourné l'article 10 de sa vocation. Il n'y a donc pas lieu d'appliquer l'article 17 de la Convention" (§ 54).
Next, from the perspective of Article 10 of the Convention, the Court agreed with the Swiss courts that Perinçek could not have been unaware that by describing the Armenian genocide as an "international lie", he was exposing himself on Swiss territory to a criminal sanction "prescribed by law". The Court also found that the aim of the application of Article 261bis of the Swiss Criminal Code was to protect the rights of others, namely the honour of the relatives of victims of the atrocities perpetrated by the Ottoman Empire against the Armenian people from 1915 onwards.
"le principe (..) selon lequel l'article 10 protège également les informations ou idées susceptibles de heurter, choquer ou inquiéter vaut également lorsqu'il s'agit, comme en l'espèce, du débat historique, 'dans un domaine où la certitude est improbable'" (§ 102).
"Partant, la Cour estime que le discours du requérant était de nature à la fois historique, juridique et politique. Compte tenu de ce qui précède et notamment de l'intérêt public que revêt le discours du requérant, la Cour estime que la marge d'appréciation des autorités internes était réduite" (§ 112-113).
"En tout état de cause, il est même douteux qu'il puisse y avoir un « consensus général », en particulier scientifique, sur des événements tels que ceux qui sont en cause ici, étant donné que la recherche historique est par définition controversée et discutable et ne se prête guère à des conclusions définitives ou à des vérités objectives et absolues" (§ 117).
In this connection, the Court clearly distinguished the present case from those concerning the negation of the crimes of the Holocaust, committed by the Nazi regime. In the cases of convictions for Holocaust denial the applicants had denied the historical facts even though they were sometimes very concrete, such as the existence of the gas chambers. They had denied the crimes perpetrated by the Nazi regime for which there had been a clear legal basis. Lastly, the acts that they had called into question had been found by an international court to be clearly established.
"Par ailleurs, elle partage l'avis du gouvernement turc selon lequel la négation de l'Holocauste est aujourd'hui le moteur principal de l'antisémitisme. En effet, elle estime qu'il s'agit d'un phénomène qui est encore d'actualité et contre lequel la communauté internationale doit faire preuve de fermeté et de vigilance. On ne saurait affirmer que le rejet de la qualification juridique de « génocide » pour les événements tragiques intervenus en 1915 et dans les années suivantes puisse avoir les mêmes répercussions" (§ 119).
From a comparative perspective, analysing the legislation in 14 countries in Europe, it is also emphasised that Switzerland is the only country that has incriminated the denial of the Armenian genocide, while only Spain and Luxembourg have not limited their genocide denial legislation to the Holocaust. The Court observes that "(t)ous les autres États n'ont apparemment pas ressenti un «besoin social impérieux» de prévoir une telle législation" (§ 120).
"Elle estime que la décision du Conseil constitutionnel montre parfaitement qu'il n'y a à priori pas de contradiction entre la reconnaissance officielle de certains événements comme le génocide, d'une part, et l'inconstitutionnalité des sanctions pénales pour des personnes mettant en cause le point de vue officiel, d'autre part. Les États qui ont reconnu le génocide arménien – pour la grande majorité d'entre eux par le biais de leurs parlements – n'ont par ailleurs pas jugé nécessaire d'adopter des lois prévoyant une répression pénale, conscients que l'un des buts principaux de la liberté d'expression est de protéger les points de vue minoritaires, susceptibles d'animer le débat sur des questions d'intérêt général qui ne sont pas entièrement établies" (§ 123).
The European Court finally referred to the General Comment nr. 34 of the United Nations Human Rights Committee on Article 19 UN Covenant on Civil and Political Rights, stating that "(l)aws that penalize the expression of opinions about historical facts are incompatible with the obligations that the Covenant imposes on States parties in relation to the respect for freedom of opinion and expression. The Covenant does not permit general prohibition of expressions of an erroneous opinion or an incorrect interpretation of past events".
"Les instances internes n'ont pas démontré en particulier que la condamnation du requérant répondait à un « besoin social impérieux » ni qu'elle était nécessaire, dans une société démocratique, pour la protection de l'honneur et les sentiments des descendants des victimes des atrocités qui remontent aux années 1915 et suivantes. Les instances internes ont donc dépassé la marge d'appréciation réduite dont elles jouissaient dans le cas d'espèce, qui s'inscrit dans un débat revêtant un intérêt public certain" (§ 129).
The Court considered the criminal conviction of Perinçek for denying that the atrocities perpetrated against the Armenian people in 1915 and onwards constituted genocide was unjustified. Accordingly there had been a violation of Article 10.
The refusal by the European Court to consider Perinçek's statements as "abusive speech" under Article 17 of the Convention reflects legitimate concerns about the inherent dangers applying the so-called abuse clause in cases of freedom of political expression and debate on matters of public interest. It is indeed preferable that the application of Article 17 in freedom of expression cases remains very exceptional, as "une mesure que la Cour n'a que très rarement appliquée" (§ 47). By only accepting, eventually, the implementation of Article 17 in cases of incitement to hatred or violence, aimed at the destruction of the rights of others and disrespecting the text and spirit of the Convention, the Court prevents a too broad application of Article 17. One can even argue that applying the abuse clause to resolve free speech disputes is undesirable in all circumstances (see H. Cannie en D. Voorhoof, "The Abuse Clause and Freedom of Expression in the European Human Rights Convention : an Added Value for Democracy and Human Rights Protection?" NQHR Vol. 29/1, 54-83, 2011), but the European Court clearly does not share that approach, yet.
Furthermore, the European Court rightly pointed out that this case is not about the legal, historical or political recognition of the existence of the Armenian "genocide", but only about the necessity of the criminal conviction of Perinçek by the Swiss authorities because of the content of some speeches Perinçek held in Switzerland arguing that the massacres and deportations of Armenian people nearly 100 years ago did not deserve the qualification as genocide. It is certainly not up to the European Court to give an opinion on or to decide itself on this issue : "La Cour rappelle par ailleurs que, si la recherche de la vérité historique fait partie intégrante de la liberté d'expression, il ne lui revient pas d'arbitrer des questions historiques qui relèvent d'un débat toujours en cours entre historiens" (§ 99). The Court emphasises that it is not dealing with the underlying facts nor the legal qualification of them as a "genocide", as the Court "n'est amenée à se prononcer ni sur la matérialité des massacres et déportations subies par le peuple arménien aux mains de l'Empire ottoman à partir de 1915, ni sur l'opportunité de qualifier juridiquement ces faits de « génocide », au sens de l'article l'art. 261bis, alinéa 4, du code penal" (§ 111).
The essence of the message of this judgment is indeed that the legal, political and historical discussion about facts situated in history should be open and that all opinions discussing or interpreting these facts, including provocative, offensive or disrespectful opinions, should be protected by Article 10 of the Convention. The denial of historical facts or the discussion about their legal or political qualification should never, as such, be considered as a criminal offence, unless the statements or expressions also incite to hatred, discrimination or violence.
The European Court at a certain moment (§§ 114-116) gives the impression that it is because of the lack of a general consensus in European and in the international community about whether the massacres and deportations in Armenia in 1915 and the years after constituted a genocide, that the denial by Perinçek of the existence of the Armenian genocide was acceptable. The Court however seems to be aware that accepting such an approach would risk to install by law historical truths, based on general consensus, which cannot be denied, or critically and vehemently discussed. Therefore the Court clarifies that it is doubtful anyhow whether on such issues there can be ever a general consensus : "En tout état de cause, il est même douteux qu'il puisse y avoir un « consensus général », en particulier scientifique, sur des événements tels que ceux qui sont en cause ici, étant donné que la recherche historique est par définition controversée et discutable et ne se prête guère à des conclusions définitives ou à des vérités objectives et absolues " (§ 117). The Court accepts nevertheless one exception, and that is the criminalisation of denial of the Holocaust (§ 118), as, according to the Court, there is general consensus about the Holocaust. Still, accepting that as such the denial of the Holocaust is a justifiable restriction on freedom of expression, contrasts with the approach expressed by the UN HRC in its General Comment nr. 34. In this Comment, interpreting the actual scope, impact and application of the right to freedom of opinion and expression under 19 Article ICCPR, the HRC opposed explicitly against "memory-laws", emphasising that Article 19 ICCPR "does not permit general prohibition of expressions of an erroneous opinion or an incorrect interpretation of past events." (§ 49). The European Court, although it referred to and even quoted from the General Comment nr. 34, missed the opportunity to elaborate on this approach. It would indeed have been preferable if the Court had made clear that the criminal prosecution and conviction for denial of historical facts, also of those on which there is general consensus, such as the Holocaust, is only justified from the perspective of Article 10 in so far as the denial of those facts at the same time intentionally incites to hatred, discrimination or violence against a person or a group of persons. In this case however, the European Court did not need to take that additional step, which would also imply that it distanced itself from its former jurisprudence finding that criminal convictions and other sanctions for denial of the Holocaust did not amount to a violation of Article 10, even in cases in which there was no clear incitement to hatred, discrimination or violence, such as in the case of Bruno Gollnisch v. France (Decision ECtHR 7 June 2011, Appl. Nr. 48135/08). In that case Gollnisch was dismissed from university because in his texts and lectures he had claimed the right as a historian to question and discuss the "official truth" about the Holocaust. The European Court however considered Gollnisch's complaint under Article 10 ECHR inadmissible.
The threshold that the European Court invokes in its judgment of 17 December 2013 with regard to the application of Article 17 ECHR, that in discussions about (dramatic and traumatic) historical facts there is only an abuse of the right to freedom of expression when it concerns incitement to hatred or violence, should indeed be unrelated to whether there is general consensus or not about these historical facts. What can be criminalised from the perspective of Article 10 is incitement to hatred and violence, while the contestation or denial itself of historical facts, based on a (construed) general consensus should not, and should never be, defined as a criminal offence with the justification that such an interference with the right to freedom of expression is necessary in a democratic society.
Finally, it is not surprising that the judgment on the controversial issue related to the (denial of the) Armenian genocide is not delivered with unanimity. Judges Sajó (Hungary) and the president of the Chamber, Raimondi (Italy) expressed a joint concurring opinion, in which they additionally explain, justify or clarify some of the legal arguments and considerations by the Second Section's majority in this case, finding a violation of Article 10 of the Convention. Judges Vučinić (Montenegro) and Pinto de Albuquerque (Portugal) expressed a joint partly dissenting opinion in which they argue that the conviction of Perinçek did not amount to a violation of Article 10 of the Convention : "Quoi qu'il en soit, après mûre réflexion, nous sommes parvenus à la conclusion qu'il n'y avait pas eu violation de l'article 10 dans cette affaire".
The judgment will become final on 17 March 2014, unless the case is referred to the Grand Chamber under Article 43 of the Convention. In some statements or preliminary reactions commenting on the Court's judgment in Perinçek v. Switzerland, it is argued why the Swiss Government should request such a referral in order to find Perinçek's conviction necessary in a democratic society. We sincerely doubt if a judgment by the Grand Chamber could ever lead to such an outcome in this case. And if it would, it would certainly be a sad day for freedom of expression in Europe.
* An impressive electronic volume has been compiled by Tarlach McGonagle, based on the work of Dirk Voorhoof, entitled 'Freedom of Expression, the Media and Journalists: Case-law of the European Court of Human Rights'. It offers - open access - a structured and extensive overview of virtually all the relevant case-law on the issue.
Without occasioning much comment, the European Court of Human Rights is increasingly relying on vulnerability reasoning. This chapter analyses that development. First it discusses the concept of vulnerability and its relationship to human rights on a theoretical level, particularly drawing on the work of Martha Fineman. Through an emphasis on universal vulnerability, Fineman's work invites a reimagining of the human of human rights law. This chapter then examines and critiques how the Court conceives of vulnerability: it charts who are vulnerable according to the Court, and why. The ability of vulnerability, the chapter argues, is that it allows the Court to prioritize between different claims. Vulnerability reasoning likewise enables the Court to extend certain positive obligations. Vulnerability considerations are thus at the frontlines of the Strasbourg case law. However, as a social institution the Court is also vulnerable in and of itself. This is a reality that the ECtHR will have to take seriously in order to endure as a supranational human rights court. The Court's legal reasoning about vulnerability, and the revolutionary potential of that reasoning, is therefore ultimately limited by the Court's own vulnerability.
* Anthony Cullen & Steven Wheatley, 'The Human Rights of Individuals in De Facto Regimes under the European Convention on Human Rights'.
* John Ip, 'The Reform of Counterterrorism Stop and Search after Gillan v United Kingdom'.
* Martin Kuijer, 'The Right to a Fair Trial and the Council of Europe's Efforts to Ensure Effective Remedies on a Domestic Level for Excessively Lengthy Proceedings '.
* Andrew Williams, 'The European Convention on Human Rights, the EU and the UK: Confronting a Heresy'.
* Stelios Andreadakis, 'The European Convention on Human Rights, the EU and the UK: Confronting a Heresy: A Reply to Andrew Williams'.
* Dragan Gulobovic, 'Freedom of association in the case law of the European Court of Human Rights'.
* Vasiliki Kosta, Nikos Skoutaris & Vassilis P. Tzevelekos, 'Introduction : the Accession of the European Union to the European Convention on Human Rights Introduction : l'adhésion de l'Union européenne à la Convention européenne des droits de l'homme'.
* Aida Torres Pérez, 'Too many voices ? The prior involvement of the Court of Justice of the European Union / Trop de voix ? L'intervention préliminaire de la Cour de justice de l'Union européenne'.
* Olivier De Schutter, 'The Two Lives of Bosphorus : Redefining the Relationships between the European Court of Human Rights and the Parties to the Convention / Les deux vies de Bosphorus : la redéfinition des rapports entre la Cour européenne des droits de l'homme et les Parties à la Convention'.
* Monica Claes & Šejla Imamović, 'Caught in the Middle or Leading the Way ? National Courts in the New European Fundamental Rights Landscape / Entre deux feux ou ouvrant la voie ? Les juridictions nationales dans le nouveau paysage européen des droits fondamentaux'.
* Arman Sarvarian, 'The Attribution of Conduct in the Law of International Reponsibility, the European Union and the Jurisprudence of the European Court of Human Rights / L'attribution de comportement dans le droit de la responsabilité internationale, l'Union européenne et la jurisprudence de la Cour européenne des droits de l'homme'.


Ready for some real estate eye candy? Let's celebrate the New Year by reviewing the most spectacular home sales in Boulder.
Before we get started, cuddle up next to the fire with Uncle Osman. Let's talk about a couple of important characteristics of ultra high end homes.
When the market is rising, highly desirable properties tend to experience a greater rate of appreciation than mere average properties - far greater. As a consequence, buyers will pay a premium for a coveted piece of Boulder real estate but in the long run, the asset should outperform less desirable (and lower priced) properties. This is the Waterfront Effect, named after a 25 year study on the luxury estate market.
Whether for their personal residence or as an investment, most of my clients are savvy and judicious. I find this especially true at the high end. They aren't going to purchase or sell a house worth $2M+ on a whim and they're seeking professional advice on valuation, home selection, and negotiation. An insider's knowledge of market conditions and an ability to provide an expert analysis is why they choose me. Helping these buyers and sellers get comfortable with valuation usually requires a deep analysis.
After going through the process literally hundreds of times, I can tell you that good design, a functional layout, high-end finishes, and decent landscaping are mandatory but not enough. These are not the key drivers of extreme long-term desirability. Proximity to downtown Boulder, unimpeded and protected view corridors, and a property's relationship to open space are what anchors a highly desirably property's market value.
The following homes traded during 2013 and in my opinion, were the best of the best. Take a look.
535 Evergreen Avenue is a +6,000 SQFT Craftsman built in 2008 with 6 bedrooms and 7 bathrooms. As Boulderites know, Newlands is a popular neighborhood for families and a short distance to retail, downtown, and open space.
Click through the photos and you'll see detail that is very Colorado - rugged stone, natural wood, and earth tones throughout. You'll also see excellent indoor/outdoor transitions and beautiful, mature landscaping. At this price bracket, it's important for the interior of the home to flow towards outdoor patios for entertaining and living. It closed for $2.2M on August 8.
505 Geneva Avenue is a contemporary beauty designed by architect and former City Council candidate Fenno Hoffman as his personal residence. Naturally, an accomplished architect will want to turn his own home into a showcase for his talent and clicking through the pics should impress you.
The house features endless custom touches over 6,731 SQFT and 6 bedrooms. It also strongly checks the box for location with exceptional open space - Chautauqua and Flagstaff Mountain - just steps away.
On the market for a single day, it sold for $2.3M on February 22.
1950 Norwood Avenue maximizes the potential of its location by framing eye popping flatiron views from several vantages, indoor and outdoor. With an acre+ size lot, it's worthy of being called "trophy estate."
A few of the rooms in this luxurious abode could use updating but that didn't stop a buyer from jumping on it. That's the magic with a home designed around stunning views. This private 8,000+ SQFT retreat was only on the market for only 14 days before receiving an offer. It sold for $2.3M in October.
Homes on Alpine, Balsam, and Panorama are sitting on a butte-like formation in the heart of Boulder. Many of these homes feature stunning, unobstructed views of the Flatirons and downtown Boulder.
2052 Alpine Drive isn't one of them. Sure it has Flatiron views, but the home itself wasn't built to frame the view. Don't get me wrong, it's still a gorgeous house.
Check out the pictures for the wow factor. You'll see it radiates a combination of beautiful design and attention to detail from the moment you walk in the door. The indoor outdoor transitions and it has beautiful landscaping, plus it's walking distance to the heart of downtown. Still, if it were my buyer we would have engaged in a lengthy discussion over the lofty valuation. It sold for $2.35M and went under contract in 20 days.
2060 Stony Hill Road - is a gorgeous 4 bedroom, 5 bath contemporary home. As one of the last constructed in desirable Devil's Thumb, this beauty is surrounded by open space with private trail access steps from the front door.
Again, note the combination of rugged materials and earth tones in the listing photos. Nearly every room in this exceptional 5,195 SQFT gem features mind blowing views and thoughtful design. It sold for $2.35M in August.
The property sold for $2.45M in April (full asking price) and the buyer paid cash.
3755 Spring Valley Road - Head up Linden Drive and you'll find an enclave of high end trophy homes, nestled together. Most have views overlooking Boulder and it's a short drive to downtown.
Flip through the photos and you'll see a traditional design, with covered porches and other time tested design elements. It comes from a school that understates the exterior and wows you on the inside. In other words, it's not built to impress the neighbors. It actually reminds me a bit of a high end houses on Nantucket - a market with a median price about 3x Boulder.
This house is about 7,000 SQFT (with five bedrooms and six baths) on a beautifully landscaped 20,000 SQFT lot. The estate sold for $3.15MM in June after only 17 days on market.
3639 21st Street. This trophy home is an art gallery; rough hewn stone, natural earth tones, exposed post and beam. The finishes and fixtures you'll find in this home speak of craftsmanship and exceptional taste.
The previous owner had a serious commitment to alternative energy. Take a closer look. The roof tiles are actually solar (no panels). The house also featured a geothermal heating system and a heat recovery ventilation system.
The structure is a 6 bed, 6 bath abode with a 5 car garage constructed in 2008. It's about 7,400 SQFT in size on a lot of nearly 30,000 SQFT. In October, it fetched $3.4MM and was on the market for only 9 days.
2115 Meadow Avenue - It's hard to imagine properties of this caliber in the center of Boulder. Inside and outside this exceptional home, you'll find stunning design and attention to detail.
Built in 2010, the 7,400 SQFT home features six bedrooms and five baths constructed on a 30,000 SQFT lot. It includes a 1 bedroom apartment above the garage.
Take a look at the pics. Everything in this home speaks of sophisticated design and quality. Even the built ins are eye catching. A hallmark of higher end homes is the ability to seamlessly blur the transition between interior and exterior with fixtures designed to bring the outdoors in. I'm not crazy about the location, but the designer of this one nailed it.
The property sold for $3.55MM in July after only six days on market.
1002 Mapleton Avenue - This is simply the best location in Boulder. If Gatsby were alive today (or real, for that matter), this eye popping trophy might have been his choice for lavish parties. Can't you just imagine the rip roaring 20's soiree you would host along that swimming pool?
Go ahead, ogle the pics. Everything has been updated and finished to the highest possible level during a recent remodel.
The six bedroom, five bath 7,600 SQFT house is set on a half acre lot in the Mapleton Hill Historic District. There are probably only a handful like this in Boulder and they almost never come up for sale, much less in such turn-key, ready to move in condition. It was on the market for 69 days before selling in November for $6.4MM. The buyer paid cash.
No doubt, these ten homes represent exceptional real estate eye candy. But - were they worth what the buyer's paid?
Are they worth it, Marley?
In Boulder's real estate community, it's considered impolite to discuss such things without at least sloshing down a few margaritas at the Rio first. Let's just say that for a few of the above, I'm confident the purchase price will look dirt cheap down the road. I'm less confident above several others.
Remember, just because it's pretty doesn't mean it's worth it. Maybe Boulder will become more like Aspen down the road but for now, exceeding $2MM for a home that is not nestled in open space (or downtown), or wasn't built around a stunning view, or doesn't at least incorporate features that bring the outdoors inside - is questionable.
When I represent buyers, I act like an professional adviser. It's just how I'm wired. For homes missing these "value anchors," I would have encouraged my buyers to consider other assets or at least seriously underbid. Of course, people fall in love with houses. If my buyer still wants the house, I'll negotiate aggressively on their behalf, but I'll sleep better knowing I gave my honest advice.
Note: I like to write entertaining and educational articles about Boulder real estate but my real business is being a broker. If you're looking for a professional, highly experienced agent to represent you on the purchase or sale of your next $2MM+ real estate investment, you know where to reach me. PH: 303.746.6896.


Every organization is always looking for ways to improve employee workflow and digitize parts of their business.
Thanks to new, innovative digital technologies on the market, the landscape of the business world has been transformed, with organizations adapting to an ever-changing market.
A recent report from the Global Print 2025 Study by Quocirca revealed that a majority SMBs have their top 3 business priorities being improving business efficiency, improving employee productivity, and increasing revenue.
With the age of digital transformation coming around to change the usual workflow of employees, now is the best time to adapt a workflow automation solution that can cover the top 3 SMBs priorities for your organization.
By successfully leveraging workflow automation, you can boost productivity and take advantage of existing hardware infrastructure to save office costs.
The Quocirca report highlights the business challenges SMBs face when it comes to managing their document management and how solution providers should take the opportunity on supplying these solutions.
Between now and the year 2025, 67% of SMBs consider the greater use of document capture and workflow solutions to be a major factor in reducing unneeded time in document processing like printing.
In many industries, document management still plays a vital role with employees having to spend countless hours to handle records and send them to wherever they need to go.
It costs time and money to file documents, print out sheets of paper, and hire employees whose main job is to handle documents.
Printers and scanning devices also play a role in document management but for SMBs, getting newer devices is an additional unneeded capital cost.
With the world moving forward with digital transformation, why spend additional money on technology that already works?
Figuring out the logistics of a workflow solution can be a daunting and lengthy procedure, while most decision makers want a simple, cost effective solution.
Cutting down on costs of hardware, supplies, and stationery.
Simplicity of solution and usage.
When purchasing a workflow solution, make sure that the solution has a free trial to see if it fits your business. For example, for Xerox devices, there is a simple solution called CapturePoint which costs less than a cup of coffee a day.
By providing your employees with CapturePoint, you can leverage your existing Xerox ConnectKey Devices to their fullest ability by routinely transforming your documents into the digital world. CapturePoint can also boost productivity by securely scanning papers and converting them to various types of files and send them to Email, Google Drive, Dropbox, Sharepoint, etc.
By having a workflow solution like CapturePoint, you can reduce the need for management costs on document transformation while also reducing unneeded spending on hardware and its supplies.
Finding a solution that fits your organization and brings you closer to digital transformation should be a priority when moving into the future.
By implementing a simple, cost-effective solution, you can cover the business priorities of SMBs and your employees will be able to easily transform documents into the digital world!


text:
You are here:Home/Resources/ Bliss-Tyler Correspondence/ Annotations/ Robert Woods Bliss (1875–1962)
Robert Woods Bliss (1875–1962)
Robert Woods Bliss was an American diplomat, art collector, philanthropist, and cofounder of the Dumbarton Oaks Research Library and Collection in Washington, D.C. He was born in Saint Louis, Missouri, on August 5, 1875, the son of William Henry Bliss and Anna Louisa Woods Bliss and the brother of Annie Louise Bliss Warren. When his father remarried in 1894, he became the stepson of Anna Barnes Bliss and the stepbrother of Cora Barnes and Mildred Barnes. He reportedly attended preparatory schools in Virginia and Minnesota as well as at J. P. Hopkinson's Private School in Boston in 1894–1895. He graduated from Harvard College with a bachelor of arts degree in 1900. Robert Woods Bliss worked in the office of the secretary of the United States civil government in Puerto Rico and served as the private secretary to the governor of Puerto Rico between 1901 and 1903. After passing the State Department qualifying examination in 1903, he entered diplomatic foreign service. Robert Woods Bliss married Mildred Barnes on April 14, 1908. As a career diplomat, he served as U.S. consul in Venice (1903), second secretary to the U.S. Embassy in Saint Petersburg (1904–1907), secretary of the legation in Brussels (1907–1909), secretary of the legation in Buenos Aires (1909–1912), secretary of the U.S. Embassy in Paris (1912–1916), and counselor of the U.S. Embassy in Paris (1916–1919). He was a delegate to the 1908 international conference to consider the revision of the arms and ammunition regulations of the General Act of Brussels of July 2, 1890, and he was temporarily assigned to serve as chargé d'affaires at the U.S. legation in The Hague, in 1918. He became chief of the Division of Western European Affairs (1920) and third assistant secretary of state (1921–1923) at the Department of State in Washington, D.C., before becoming U.S. minister to Sweden (1923–1927) and U.S. ambassador to Argentina (1927–1933). He retired from the diplomatic foreign service after completing his post in Argentina. During the Second World War, however, he became a member of the Council on Foreign Relations and a consultant to the Department of State in Washington, D.C. (1942–1943), a special assistant to Secretary of State Cordell Hull (1944), and a consultant to Secretary of State Edward Settinius (1944–1945). He retired from government work for a second time in November 1945. Robert Woods Bliss was president (1938–1941) and honorary president and trustee (1945–1962) of the American Federation of Arts, the president of the American Foreign Service Association, the vice chairman of the Smithsonian Art Commission, the vice chairman of the board of the National Trust for Historic Preservation, the director and first vice president of the Washington Criminal Justice Association, and a member of the American Academy of Political and Social Science and the Board of Overseers of Harvard University. He was a trustee of the American Museum of Natural History in New York, a trustee and executive committee member of the Carnegie Institution of Washington in Washington, D.C., a trustee of Nelson Rockefeller's Museum of Primitive Art in New York, a trustee of the Santa Barbara Museum of Art, an honorary committee member of the American British Art Center in New York, and a member of the Advisory Committee on Art in the Division of Cultural Relations and the Office of the Coordinator of Inter-American Affairs at the Department of State. He received honorary Doctor of Law degrees from the University of Missouri (1933), Syracuse University (1934), and Harvard University (1951). Mildred Barnes Bliss and Robert Woods Bliss cofounded the Dumbarton Oaks Research Library and Collection, which they endowed and donated to Harvard University in 1940. Robert Woods Bliss was one of five retired diplomats who cosigned a 1954 letter protesting Senator Joseph McCarthy's attacks on the Foreign Service. The Blisses had no children. Robert Woods Bliss died of cancer at the age of eighty-six in Washington, D.C., on April 19, 1962.
James N. Carder, "Mildred and Robert Woods Bliss: A Brief Biography," in A Home of the Humanities: The Collecting and Patronage of Mildred and Robert Woods Bliss, ed. James N. Carder (Washington, D.C.: Dumbarton Oaks Research Library and Collection, 2010), 1–23.
James N. Carder, "Mildred and Robert Woods Bliss and the Dumbarton Oaks Research Library and Collection," in Sacred Art, Secular Context: Objects of Art from the Byzantine Collection of Dumbarton Oaks, Washington, D.C., Accompanied by American Paintings from the Collection of Mildred and Robert Woods Bliss, ed. Asen Kirin (Athens: Georgia Museum of Art , 2005), 23–37.
Susan Tamulevich, Dumbarton Oaks: Garden into Art (New York: Monacelli Press, 2001).
Bliss-Tyler Correspondence
Search the Letters
Historical Introductions
« Previous: Raymond Koechlin (1860–1931)
Next: Royall Tyler (1884–1953) »

redpajama_set_name: RedPajamaCommonCrawl


text:
namespace {

// Max number of most recently used folders.
const size_t kMaxMRUFolders = 5;

}  // namespace

RecentlyUsedFoldersComboModel::RecentlyUsedFoldersComboModel(
    BookmarkModel* model,
    const BookmarkNode* node)
    // Use + 2 to account for bookmark bar and other node.
    : nodes_(bookmark_utils::GetMostRecentlyModifiedFolders(
          model, kMaxMRUFolders + 2)),
      node_parent_index_(0) {
  // TODO(sky): bug 1173415 add a separator in the combobox here.

  // We special case the placement of these, so remove them from the list, then
  // fix up the order.
  RemoveNode(model->bookmark_bar_node());
  RemoveNode(model->mobile_node());
  RemoveNode(model->other_node());
  RemoveNode(node->parent());

  // Make the parent the first item, unless it's a permanent node, which is
  // added below.
  if (!model->is_permanent_node(node->parent()))
    nodes_.insert(nodes_.begin(), node->parent());

  // Make sure we only have kMaxMRUFolders in the first chunk.
  if (nodes_.size() > kMaxMRUFolders)
    nodes_.erase(nodes_.begin() + kMaxMRUFolders, nodes_.end());

  // And put the bookmark bar and other nodes at the end of the list.
  nodes_.push_back(model->bookmark_bar_node());
  nodes_.push_back(model->other_node());
  if (model->mobile_node()->IsVisible())
    nodes_.push_back(model->mobile_node());

  std::vector<const BookmarkNode*>::iterator it = std::find(nodes_.begin(),
                                                            nodes_.end(),
                                                            node->parent());
  node_parent_index_ = static_cast<int>(it - nodes_.begin());
}

RecentlyUsedFoldersComboModel::~RecentlyUsedFoldersComboModel() {}

int RecentlyUsedFoldersComboModel::GetItemCount() {
  return static_cast<int>(nodes_.size() + 1);
}

string16 RecentlyUsedFoldersComboModel::GetItemAt(int index) {
  if (index == static_cast<int>(nodes_.size()))
    return
       l10n_util::GetStringUTF16(IDS_BOOKMARK_BUBBLE_CHOOSER_ANOTHER_FOLDER);
  return nodes_[index]->GetTitle();
}

const BookmarkNode* RecentlyUsedFoldersComboModel::GetNodeAt(int index) {
  if (index < 0 || index >= static_cast<int>(nodes_.size()))
    return NULL;
  return nodes_[index];
}

void RecentlyUsedFoldersComboModel::RemoveNode(const BookmarkNode* node) {
  std::vector<const BookmarkNode*>::iterator it = std::find(nodes_.begin(),
                                                            nodes_.end(),
                                                            node);
  if (it != nodes_.end())
    nodes_.erase(it);
}

redpajama_set_name: RedPajamaGithub


Yes, so instead of taking still pictures for instagram, or video that has been editied to be all pretty for youtube, you are filming LIVE which can be a really good or a really bad thing. Really good thing: Something amazing happens and you are able to show it to the world LIVE! Really bad thing: You have really bad content and it falls apart in real time.
The awesome thing about Periscope is that you can log in and see who is live ALL over the world! I can take a peek into someone down in Florida or I could check out someone who is Periscoping halfway across the globe. The choice is yours.
Keep in mind when you "go live" anyone can drop in. Anyone who is watching will see who is coming in but you won't see who leaves. There is a constant count of live viewers in the lower right hand corner of the screen.
The interactions are also live. I did my first periscope at an event on Wednesday. I was at an event Dr. Brown's new baby bottle technology and I got a good amount of viewers for my first try. At the end of the Broadcast (about 15 minutes) I had 77 visitors join. As a viewer of the broadcast you can chat during the broadcast and make commentary on what you are watching which makes things so fun! There was one point where the presenter at my event was answering questions and one of my periscope viewers told the live audience to "back off" lol!
As someone watching Periscope you can show your appreciation for the content by double tapping on the screen live while the broadcast is happening. You give hearts by double tapping the screen. The more hearts the better! Hearts are a great way to show that you like what you see. Your all time amount of hearts are displayed on your profile for all to see, which is pretty cool.
When you finish broadcasting you have the option to download your broadcast to your device for future use…This is great because you can easily upload it to YouTube–just keep in mind that all of your comments, hearts and interactions will also be on the recording. Keep in mind that the videos are only available for viewing for 24 hours then they are gone!
Wondering what #Periscope is all about? Here are 5 Easy Tips to Help You Navigate!
Until you are super comfortable in front of the live camera, a good place to start is events. I personally go to a lot of events and I blog about them here, but what if you were online the same time I was at an event? We could attend and experience the fun together!
When I first heard about Periscope I was a bit apprehensive about joining yet ANOTHER social media platform. I had already shunned SnapChat and Vine so I thought I was forever done with platforms. Then my friend Donna (check out her awesome YouTube Channel here where she shares amazing tips for bloggers) started tweeting about Periscope and how cool it was so I had to pay attention.
As you get familiar be sure to follow me! My handle is @bklynactivemama — I look forward to periscoping with you because, fact is, I'm obsessed.
Have you ever tried Periscope? What do you think?
The Berenstain Bears LIVE in Family Matters The Musical!
Um sold! Downloading now lol. Great article!
I with Carla on this….I am really behind on some of this stuff. Looks interesting.
Interesting! I had never heard of this before and I'm intrigued…. Must check it!
Hope you get to try it out soon!
I just learned about this today, so I did a google search. I love instagram because I can edit, but I am a little nervous about being live.
I was as well but it's totally fine once you get on and make it interactive by chatting with your viewers.
I downloaded the app but haven't used it yet, need to learn more especially before my next Blogging Basics class. Perhaps will have some Periscope it!
It's great!! I think this is perfect lesson for your audience.
Thanks for these tips! I was at a blog branding seminar last week in Boston and was so surprised only 1 or 2 people heard of it. When I asked the panelists their thoughts they completely brushed it off! It still sounds cool to me. I appreciate your tips!
I think you can stop those? The notifications can be a bit much too.
Sounds interesting. The thought of being 'live' scares the heck out of me though! At least now I know about it. Thanks for sharing the info!
It scared me too until I got a rush from it. Lol. Now I'm hopelessly hooked. Smh.
I've heard of it, but this is the first time I've understood it so I thank you for that. So fascinating about the global aspect. I'd love to watch people on a moose tour. Do you think I could do that?


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The Cavazzo utilizes the Flat Mount system with 12x142mm Rear axle and 12x100mm Front axles for a perfect 160/140mm rotor combination and superior braking in all weather conditions.
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text:
Q: Two session Factories found when one was expected I have referred to the question asked at Hibernate using multiple databases. My problem is similar but I am facing a different problem.I created two xml file each has a separate datasource and session factory.
In my web.xml I have
 <context-param>
 <param-name>contextConfigLocation</param-name>
     <param-value>*The xml files* </param-value>

Once I run the project,the various loadings and the bindings are done from both the xml files.The various annotations and databases/tables are properly identified.But just after this is done before the control even goes outside.I get the following error.
    main ERROR [org.springframework.web.context.ContextLoader] - Context initialization failed
    org.springframework.beans.factory.UnsatisfiedDependencyException: Error creating bean with name 'daoEager' defined in URL [jar:file:/C:/Users/.../.metadata/.plugins/org.eclipse.wst.server.core/tmp1/wtpwebapps/infobutton-service/WEB-INF/lib/core-data-1.0.0-SNAPSHOT.jar!/.../DaoHibernateEagerImpl.class]: Unsatisfied dependency expressed through constructor argument with index 0 of type [org.hibernate.SessionFactory]: : No unique bean of type [org.hibernate.SessionFactory] is defined: expected single matching bean but found 2: [sessionFactory, profilesessionFactory]; nested exception is org.springframework.beans.factory.NoSuchBeanDefinitionException: No unique bean of type [org.hibernate.SessionFactory] is defined: expected single matching bean but found 2: [sessionFactory, profilesessionFactory]

The class DaoHibernateEagerImpl is
@Implementation
@Repository("daoEager")
public class DaoHibernateEagerImpl extends DaoHibernateImpl
{
// ========================= CONSTANTS =================================

/**
 * A logger that helps identify this class' printouts.
 */
private static final Logger log = getLogger(DaoHibernateEagerImpl.class);

// ========================= CONSTRUCTORS ==============================

/**
 * Required for a Spring DAO bean.
 *
 * @param sessionFactory
 *            Hibernate session factory
 */
@Autowired
public DaoHibernateEagerImpl(final SessionFactory sessionFactory)
{
    super(sessionFactory);
}

// ========================= DEPENDENCIES ==============================

// ========================= IMPLEMENTATION: Dao =======================

// ========================= IMPLEMENTATION: SearchEngine ==============

}

One of the xml files is
<?xml version="1.0" encoding="UTF-8"?>
<beans xmlns="http://www.springframework.org/schema/beans"
xmlns:xsi="http://www.w3.org/2001/XMLSchema-instance"
    xmlns:context="http://www.springframework.org/schema/context"
xmlns:aop="http://www.springframework.org/schema/aop"
    xmlns:tx="http://www.springframework.org/schema/tx"
xmlns:jee="http://www.springframework.org/schema/jee"
xmlns:jaxws="http://cxf.apache.org/jaxws"
xsi:schemaLocation="
http://www.springframework.org/schema/beans
http://www.springframework.org/schema/beans/spring-beans-3.0.xsd
    http://www.springframework.org/schema/context
http://www.springframework.org/schema/context/spring-context-3.0.xsd
http://www.springframework.org/schema/aop
http://www.springframework.org/schema/aop/spring-aop-3.0.xsd
http://www.springframework.org/schema/tx
http://www.springframework.org/schema/tx/spring-tx-3.0.xsd
http://www.springframework.org/schema/jee
http://www.springframework.org/schema/jee/spring-jee-3.0.xsd
http://cxf.apache.org/jaxws http://cxf.apache.org/schemas/jaxws.xsd">

    <context:annotation-config />

<!--
    Data source: reads a properties file and injects them into a DBCP DS
    Second datasource for Resource Profiles
-->
<bean id="profiledataSource"
    class=".....ConfigurableBasicDataSource">
    <constructor-arg index="0">
        <bean class="org.apache.commons.dbcp.BasicDataSource" />
    </constructor-arg>
    <property name="properties">
        <bean

    class="org.springframework.beans.factory.config.PropertiesFactoryBean">
            <property name="locations">
                <list>
                    <value>WEB-INF/datasource-local.properties
                    </value>
                </list>
            </property>
        </bean>
    </property>

    <!-- FUR-946: idle connections break. Adding connection testing. -->
    <property name="testOnBorrow" value="true" />
    <property name="testWhileIdle" value="true" />
</bean>

    <!-- Session factory -->
<!-- Session Factory for the second datasource-->
<bean id="profilesessionFactory"

   class="org.springframework.orm.hibernate3.annotation.AnnotationSessionFactoryBean">
    <property name="dataSource" ref="profiledataSource" />

    <!--
        Hibernate configuration properties (read from a properties file)
    -->
    <property name="hibernateProperties">
        <bean

    class="org.springframework.beans.factory.config.PropertiesFactoryBean">
            <property name="locations">
                <list>
                    <value>WEB-INF/hibernate.properties
                    </value>
                    <value>WEB-INF/datasource-local.properties
                    </value>

                </list>
            </property>
        </bean>
    </property>

    <!-- Using improved naming strategy -->
    <property name="namingStrategy">
        <bean class="org.hibernate.cfg.DefaultNamingStrategy" />
    </property>

    <!-- Mapping annotated classes using search patterns -->
    <property name="annotatedClasses">
        <list>
            <value><![CDATA[....profiledb.domain.Profiles]]></value>
        </list>
    </property>
</bean>

 <!--   Hibernate data access template -->
 <bean id="profilehibernateTemplate"
  class="org.springframework.orm.hibernate3.HibernateTemplate">

  <property name="sessionFactory" ref="profilesessionFactory" />
</bean>

<tx:annotation-driven />

<!-- a PlatformTransactionManager is still required -->
<bean id="profiletransactionManager"
    class="org.springframework.orm.hibernate3.HibernateTransactionManager">
    <property name="sessionFactory" ref="profilesessionFactory" />
</bean>

<bean id="profilesdbDao" class="....profiledb.service.ProfilesDaoImpl" >
    <property name="sessionFactory" ref="profilesessionFactory"></property>

<context:component-scan base-package="....core.data" />

The other xml file is similar but has a different datasource and the session factory is
<bean id="sessionFactory"
class="org.springframework.orm.hibernate3.annotation.AnnotationSessionFactoryBean">
    <property name="dataSource" ref="dataSource" />
 .....

A: The error message is pretty clear:

expected single matching bean but found 2: [sessionFactory, profilesessionFactory]

Which is understandable:
<bean id="profilesessionFactory"
<!-- ... -->
<bean id="sessionFactory"

The fix should be simple:
@Autowired
public DaoHibernateEagerImpl(
  @Qualifier("profilesessionFactory") final SessionFactory sessionFactory)

If you cannot modify DaoHibernateEagerImpl class, you can always fall-back to XML-based configuration. First disable CLASSPATH scanning of DaoHibernateEagerImpl so that @Autowired is not picked up. Then simply write:
<bean class="DaoHibernateEagerImpl">
   <constructor-arg ref="profilesessionFactory"/>
   <!-- ... -->
</bean>

Finally you can take advantage of @Primary annotation / primary="true" directive:
<bean id="sessionFactory" primary="true">
   <!-- ... -->

This will prefer sessionFactory when autowiring and there are two possibilities instead of throwing an exception.

A: Its because of...if you dont mention @Primary(annotation) / primary="true"(in xml config), Hiibernate does not know which sessionfactory to pick up.In that case it will give you the error mentioned. Just try with @Primary annotation it will work...

redpajama_set_name: RedPajamaStackExchange


text:
Q: Top bar is overlapping instead of pushing down? I'm working on a site right now and can't really figure out what exactly is happening.  You can view the page here:  http://demo.easythemepro.com/?themedemo=AnimeStar
If you look at the top bar where you can switch themes, you'll see that it's actually overlapping with the website instead of pushing the entire thing down.  What exactly needs to be changed to fix this?
I've tried changing everything from the PHP to the HTML to the CSS and it keeps happening.  I know it's problem something extremely simple that I'm just overlooking after staring at this code for so long...

A: It's set to position: fixed.
#wpthemedemobar {
    position: fixed !important;
}

Which means the element is positioned relative to the browser window. You can change it to relative and it should flow with the page content.

A: if you want to add a fixed topbar without over lapping the site you will have to use an iframe to contain the theme.


What if the model has much more fields? Is there a way to pass the model itself as the sole parameter instead of its fields?
which causes the Ajax request to send -> data : "user=[encoded object]"
This works partially.. I just get the JSON string, not the decoded User instance.
So I googled a lot and just removed the writer config and declared the Server-method with the User-object parameter. This works now.
Really stupid that I didn't try this from the beginning.


text:
Vexatious Litigation is Not a Protected Form of Expression
By Emily Vereshchak
In London District Catholic School Board v. Michail[1], the Ontario Superior Court of Justice considered a motion pursuant to s.137.1 of the Courts of Justice Act (commonly referred to as the "anti-SLAAP provisions") within the context of an Application for a declaration of a vexatious litigant pursuant to s.140 of the Courts of Justice Act. The matter was heard via Zoom.
The takeaways from this decision include:
Legal proceedings constitute a form of "expression" as defined in s.137.1(2) of the Courts of Justice Act;
The Court will not deem vexatious litigation as a protected form of expression; and
Proceedings brought under s.140 of the Courts of Justice Act are not caught by s. 137.1(3) of the Courts of Justice Act, as the relief sought pursuant to s.140 is procedural in nature, and is not capable of "gagging" or suppressing protected expression.
This decision is also among the first cases to rely on the recent decision of the Supreme Court of Canada in 1704604 Ontario Limited v. Pointes Protection Association et al[2], which interpreted the test under s. 137.1[3].
The applicant, the London District Catholic School Board ("LDCSB"), brought an Application for an Order declaring that the respondent, Ms. Michail, was a vexatious litigant pursuant to s.140 of the Courts of Justice Act. In response, Ms. Michail brought a motion pursuant to s. 137.1 of the Courts of Justice Act, alleging that LDCSB's Application was a strategic lawsuit against public participation (a "SLAAP").
Ms. Michail was formerly employed with LDCSB as a high school teacher. Between 2011 and 2019, Ms. Michail commenced numerous legal proceedings against or involving LDCSB, which included allegations of discrimination on the basis of a disability, the tort of intentional infliction of mental distress, and a breach of the duty of fair representation.
Ms. Michail's proceedings included union grievances, along with applications to the Ontario Human Rights Tribunal, the Ontario Labour Relations Board and the Workplace Safety and Insurance Board. She also brought several motions, applications, and appeals before the Superior Court of Justice, the Divisional Court, and the Court of Appeal, and pursued applications for leave to the Supreme Court of Canada. These proceedings formed the basis of LDCSB's Application.
On the Application, LDCSB sought an Order:
That no further proceedings be instituted or continued by Ms. Michail except with leave; and
Requiring that Ms. Michail deliver a copy of the vexatious litigant Order and any written decision arising from the Application to any person or body for whom she initiates or continues any complaint.
In light of Ms. Michail's s.137.1 motion, Justice Mitchell stayed LDCSB's Application, pending the determination of the motion.
Justice Mitchell reviewed the policy objectives on a s.137.1 motion, including the proper framework outlined by the Supreme Court of Canada in 1704604 Ontario Limited v. Pointes Protection Association et al[4]. This provision contains a threshold test, which places the initial burden on the moving party to show that the proceeding arises from an expression made by the person that relates to a matter of interest.
On motions pursuant to s.137.1, the threshold burden must be met by the moving party before the Court can proceed to the later part of the test, and to the ultimate determination of whether the proceeding should be dismissed.
In relation to the proceedings before the Court in which LDCSB sought to declare vexatious, Ms. Michail argued that the various proceedings related to issues of public interest, which included the constitutional rights of unionized workers in Canada, the rule of law, and the maintenance and preservation of an open justice system.
In her submissions, Ms. Michail argued that LDCSB was attempting to unjustly silence her as a terminated employee and to intimidate and censor her expressions on public issues and participation in public affairs.
Justice Mitchell noted that Ms. Michail's proceedings demonstrated a pattern of litigation, as she had appealed every decision in which she had been unsuccessful, including a reconsideration of a decision to the Supreme Court of Canada.
In applying the definition of "expression" in s.137.1(2) of the Courts of Justice Act, Justice Mitchell determined that any legal proceedings brought by Ms. Michail (vexatious or otherwise) constituted a form of "expression". Further, Justice Mitchell stated that any vexatious legal proceedings brought by Ms. Michail were causally connected to the underlying Application brought by LDCSB.
Justice Mitchell concluded that Ms. Michail had failed to meet the threshold burden in s.137.1(3), which required Ms. Michail to satisfy the Court on a balance of probabilities, that vexatious litigation, as a form of expression, related to a matter of public interest.
Among her reasons, Justice Mitchell stated:
The court cannot be viewed as a proponent of vexatious litigation by deeming vexatious litigation a protected form of expression. Ms. Michail appears to conflate the expressions forming the basis of the proceedings she has brought to date – allegations relating to the constitutionality of legislation, breach of her Charter rights, discrimination on the basis of a disability and other human rights violations – with the expression sought to be "suppressed" by LDCSB in this application – the commencement and continuation of vexatious legal proceedings. The former is arguably protected expression while the latter clearly is not.
To include proceedings brought under s. 140 CJA as caught by s. 137.1(3) CJA, would render the protection granted by s. 140 and afforded to those against whom vexatious litigation is brought, meaningless. Relief granted on an application brought pursuant to the statutory authority in s. 140, is procedural (i.e., the appointment of the court as "gatekeeper") and, therefore, not capable of "gagging" or suppressing protected expression[5].
On review of the evidence filed by LDCSB, Justice Mitchell noted that LDCSB had not prevented or attempted to suppress Ms. Michail's expressions. Instead, LDCSB's Application causally arose from the unsuccessful proceedings instituted by Ms. Michail. It was not the expressions or allegations advanced by Ms. Michail adverse in interest to LDCSB that formed the grounds of the Application.
Justice Mitchell dismissed Ms. Michail's motion, making it unnecessary to proceed further with the analysis provided under s.137.1(4). However, Justice Mitchell left the success of LDCSB's Application for another day.
This decision suggests that where the relief sought in a proceeding is procedural in nature, such mattersare not suitable for motions pursuant to section 137.1 of the Courts of Justice Act.
[1] 2020 ONSC 7331
[2] 2020 SCC 22.
[3] For a further discussion on the test on Anti-SLAAP motions provided by the Courts of Justice Act, click here.
[5] At paragraph 21.


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Home / Boxing / SportsMax bringing big fight this Saturday
SportsMax bringing big fight this Saturday
Digicel SportsMax announced today that it has secured the broadcast rights for the Floyd Mayweather Jr. versus Andre Berto bout this Saturday, September 12 with coverage of the undercard bouts beginning at 7 p.m., and the main fight at 10 p.m.
The Digicel SportsMax Fight Night is being dubbed "The Final Showdown", with the pound-for-pound king "Money" Mayweather Jr. declaring that the fight will be his last.
Mayweather (48-0, 26 KOs) will face Andre Berto (30-3, 23 KOs) to defend his undefeated record and WBA & WBC welterweight titles. Coming off the heels of his last bout in May against Manny Pacquiao, racking up record viewership around the world, further adding to his massive net worth by over US$400 million.
Andre Berto seeking to retire Floyd Mayweather Jr. with a loss.
Mayweather is set to leave the ring, for good, with a bang or suffer the first defeat of his career at a capacity MGM Grand in Las Vegas. If he wins, the 38-year-old's record will equal that of Rocky Marciano, who retired from the sport undefeated.
Berto who was born in the United States but has deep roots in Haiti, started his career with 27 straight wins and was once regarded as one of the most exciting young talents in the world.
Although he has previously held the championship title, Berto is still considered the underdog after suffering from numerous career setbacks. With nothing to lose, and having professed to being in the best shape of his life, Berto declared he will be coming after Mayweather with everything he's got. A win for Berto over the undefeated Mayweather on Saturday night would be one of the biggest upsets in boxing history.
"This could be the last fight of the biggest name in boxing in the last decade and fans are all waiting to see how 'Money' Mayweather will bring his legacy to a close. We're really excited to be able to show the bout exclusively and are looking forward to an exciting Final Showdown with the pound-for-pound king," Tanya Lee, Digicel SportsMax Caribbean marketing manager said.
Along with the Mayweather versus Berto bout, , Digicel SportsMax is also the regional rights holder of premium sporting content such as the Barclays Premier League, the UEFA Champions LeagueLa Liga, the NBA, IAAF Diamond LeagueIAAF World Challenge meets, the Women's Tennis Association premier events, the Ashes, Australia and England cricket, the Indian Premier League, and more.
← Moore shows his mettle
Mayweather's health forcing his hand →


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Economy and Transportation
History and Government
Official nameLietuvos Respublika (Republic of Lithuania)
Form of governmentunitary multiparty republic with one legislative house (Seimas, or Parliament [141])
Head of statePresident: Gitanas Nausėda
Head of governmentPrime Minister: Ingrida Šimonytė
CapitalVilnius
Official languageLithuanian
Official religionnone
Monetary uniteuro (€)1
Population(2019 est.) 2,786,000
Population rank(2019) 142
Population projection 20302,409,000
Total area (sq mi)25,207
Total area (sq km)65,286
Density: persons per sq mi(2018) 111.4
Density: persons per sq km(2018) 43
Urban-rural populationUrban: (2018) 67.1%Rural: (2018) 32.9%
Life expectancy at birthMale: (2017) 70.7 yearsFemale: (2017) 80.4 years
Literacy: percentage of population age 15 and over literateMale: not availableFemale: not available
GNI (U.S.$ '000,000)(2017) 42,983
GNI per capita (U.S.$)(2017) 15,200
(1) The euro (€) replaced the lita (LTL) on January 1, 2015, at an exchange rate of 1 = LTL 3.45280.
In 2009 Dalia Grybauskaite became the first woman to serve as president of Lithuania.
Itar—Tass/Sovfoto
National anthem of Lithuania
One of the three Baltic countries, Lithuania was a major power in Eastern Europe in the Middle Ages but was partitioned between Russia and Prussia in the 18th century. In 1918 it became an independent country, but, after Soviet troops occupied it in 1940, it was proclaimed the Lithuanian Soviet Socialist Republic—one of the 15 constituent republics of the Soviet Union. On March 11, 1990, the Lithuanian parliament issued a declaration of independence and voted to have Lithuania secede from the Soviet Union, but the declaration was frozen, pending negotiations with Moscow. Independence was recognized in September 1991, after a failed coup in Moscow. The capital is Vilnius. (See also Vilnius.) Area 25,207 square miles (65,286 square kilometers.) Population (2019 est.) 2,786,000.
Lithuania is larger than the other Baltic republics, Estonia and Latvia, which lie to the north. It consists of a coastal plain that gradually rises eastward to the Zemaitija Hills, a morainic range with summits of more than 650 feet (200 meters). To the east of these uplands, the Central Lithuanian Plain forms a broad belt of lowland stretching from northeast to southwest. The eastern part of the country consists of a second range of hills that rise to more than 800 feet (240 meters). The major river is the Neman, or Nemunas, which enters the Baltic Sea. The climate of Lithuania, generally cool and humid, is modified by the Baltic Sea. July temperatures average about 63° F (17° C) and January temperatures about 25° F (–4° C).
With the Latvians, the Lithuanians form the major group of the Baltic peoples. They were among the last of the European peoples to be converted to Christianity, and in the 14th century they became Roman Catholics. The 14th-century union between Lithuania and Poland also influenced the culture, especially in Vilnius, which became a predominantly Polish city with a large Jewish population in the 17th century. Most of the Jewish population was murdered during the German occupation during World War II, and after the war most of Lithuania's Poles emigrated. After the annexation of Lithuania by the Soviet Union, many Russians moved to the republic. More than 80 percent of the population is of Lithuanian ethnicity.
Before 1940 Lithuania's major economic activity was agriculture. Under the Soviet regime the importance of agriculture declined, though the republic still produces grain—especially rye, wheat, oats, and barley—as well as sugar beets, flax, and potatoes. Livestock breeding is also an important branch of agriculture.
Industrial production increased in spite of the lack of many raw materials. Lithuanian industry today produces food and beverages, refined petroleum products, and electrical equipment. Other industries include chemicals, textiles, and woodworking.
There is a relatively dense railroad network. River vessels can reach Kaunas on the Niemen River. The major port is Klaipėda, which is ice-free in winter. Vilnius is linked by air with other cities.
During the Middle Ages Lithuania was transformed from a small duchy to the largest state in Europe. In 1386 a union with Poland was formed by royal marriage, but the 18th-century partition of Poland resulted in the division of Lithuania between Russia and Prussia. In 1918, after the collapse of the Russian empire, Lithuania proclaimed its independence. It was annexed by the Soviet Union in 1940, occupied during World War II by the Germans from 1941 to 1944, and then reconquered by the Soviet Union.
Lithuania had its own government and Communist party under the control of the central government in Moscow until 1989, when the Lithuanian parliament voted to declare the 1940 Soviet annexation invalid and abolished the Communist party's monopoly on power. In 1990 elections candidates backed by the nationalist organization Sajudis won a majority of the seats in the parliament, and Vytautas Landsbergis, a Sajudis leader, was elected president of Lithuania.
In April 1990 Soviet president Mikhail Gorbachev imposed an economic blockade on the republic. The unraveling of central controls, which resulted from the abortive coup against Gorbachev in August 1991, led to the recognition of Lithuania's independence by the Soviet Union on September 6. The country then joined the United Nations, and in February 1992 the United States reopened the embassy it had closed in 1940. In the 1990s and early 21st century Lithuania sought economic stability, and in 2004 it became a member of the European Union. In May 2009, amid a deteriorating economic situation, Dalia Grybauskaite, the European Union budget commissioner, won a landslide victory as an independent candidate in Lithuania's presidential election. She was the country's first female president.


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United Kingdom London Russia Moscow Russia Olympic Team Track and field Olympic games Summer Olympic games 2012 London Olympic Games IAAF Athletics World Championships Doping Sports
Russian race walker Lashmanova banned for doping, loses gold
- Mar. 21, 2022 10:36 AM EDT
LONDON (AP) — Russian race walker Yelena Lashmanova has been banned for two years for doping and will be stripped of her Olympic gold medal, the Athletics Integrity Unit said Monday.
Lashmanova won gold in the 20-kilometer race walk at the 2012 London Olympics and also at the world championships in Moscow the following year.
The ban is backdated to March 9, 2021, and all of her results between Feb. 18, 2012, and Jan. 3, 2014, have been disqualified, the AIU said.


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'Nashville' Review: My Heart Would Know
Mandy Treccia @SourceMandy April 11, 2013 / 1:52 PM July 6, 2013 1
This week's Nashville had some really great moments and some super frustrating ones, which seems to be par for the course for this show. It just feels like certain characters take one step forward and then two hundred steps back each week and frankly, it's annoying. So let's talk about which characters were backsliding in "My Heart Would Know."
I'm not sure if we can classify what Dante did as backsliding. Instead, he basically morphed into a different character. What the hell, show? I liked him and I thought he'd be good for Juliette, but he's basically the worst. I think he may have even borrowed Lamar's mustache twirling technique since he's in the hospital. After sleeping with Juliette, Dante took over the show and turned Juliette into a bigger monster than she already was.
Okay, maybe there were some clues when he went all business manager in the last episode and helped her land that endorsement deal or the fact that he was willing to sleep with his patient's daughter to begin with, but I liked him and now I feel cheated. Even worse, he made me take Avery's side and I'm pretty sure that's some sort of sin. Dante fractured what was left of Juliette's relationship with her mom and Juliette rewarded him by making him her new manager.
Juliette was backsliding so hard that she might have caused an avalanche, people. I love Juliette; I even love her bratty behavior to a point because she usually learns from her mistakes. But this time she was easily manipulated by Dante and she came out looking even more foolish than she did when she fired her original manager. Not only that, but she was incredibly mean to Deacon. This one is going to come back and bite her and even with all of her man issues, I can't work up any sympathy for her on this one.
Gunnar was also backsliding in this episode, but his was more understandable since he's still reeling from his brother's death. He attempted to keep his mind off of things by partying with Scarlett to celebrate her record contract. But he refused to play with her and then didn't seem too happy to stand by and watch her and Will sing together. Once Gunnar put a drunk Scarlett to bed, he headed out with Will and his new friend took him to play chicken with a train. Wow, I can't even get into the stupidity of this or the fact that Gunnar enjoyed it and then started playing again. Let's hope this wild child behavior doesn't last long because it is unbecoming.
Rayna returned to Nashville to see her father and he was pretty rude to her for a guy who just had a heart attack and wasn't out of the woods yet. Tandy kept herself busy with the family business, knowing that was what Lamar would want. Then Rayna got a shock when Watty showed up and she learned that he was the musician that her mother had had an affair with and that was why Lamar hated him so much. Poor Rayna also felt like maybe that was why her father acted like he was mad at her all the time and she felt super guilty for having no idea.
This was the first episode in a long time where I actually felt something for Rayna, other than seeing her as the spoiled, older version of Juliette. I never watched Friday Night Lights so I don't share the Connie Britton obsession that most people seem to have. But she was fantastic in this episode and I was really happy when Deacon showed up to be with her in the hospital.
Speaking of Deacon, he's just the best character on the show, right? I loved watching him repeatedly put Juliette in her place and I even liked him standing up for Avery when he was unfairly fired. After everything that went down between Scarlett and Avery, Deacon easily could have looked the other way, but he's better than that. He knew Avery hadn't done anything wrong (other than have the displeasure of seeing Juliette and Dante going at it on the tour bus). He also gave Dante more than one piece of his mind and fingers crossed; hopefully we'll get to see him give the man a piece of his fist in the not-too-distant future.
The Peggy/Teddy story continues to happen and I really have no feelings on the matter aside from thinking they both need to be hit by a tour bus, which is a shame because I do like Kimberly Williams-Paisley, but her character sucks. Tandy spilled the beans to Teddy about Peggy being the one to go to the tabloids so I guess they're going to have issues coming up, but again, who cares?
I'd love to talk about the preview for the next episode, but there wasn't one because the show is gone until May 1. Seriously, ABC, I know how TV works. I know stretching out a show from October until May over 21-22 episodes means there are going to be breaks and reruns. But it feels like Nashville goes on hiatus every other week. This was episode 17. Most shows are already on episode 19 or 20. Maybe the ratings would be better if the show was actually on a more consistent schedule.
Tagged: ABC Nashville TV Recaps	Share
Mandy Treccia
Mandy Treccia has served as TVSource Magazine's Executive Editor since 2016, formerly as Editorial Director from 2012-2016. She is an avid TV watcher and card carrying fan girl prone to sudden bursts of emotion, ranging from extreme excitement to blind rage during her favorite shows and has on more than once occasion considered having a paper bag on hand to get her through some tough TV moments. Her taste in TV tends to rival that of a thirteen-year-old girl, but she's okay with that.
@SourceMandy
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Again, I've been completely thrown off by the unpredictable schedule of Nashville. It wasn't until I went into my office at DISH this morning that I found out I missed last night's episode. I rushed home to watch it off my DISH Hopper since I have it enabled to record all the primetime shows from the four major networks each night of the week. I was so relieved that I could depend on my DVR to save this episode for me despite not having a specific timer set for it. Now if only I could get it to make there be a new episode of Nashville before next month -lol!
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