On March 1, 2018, the United States Court of Appeals for the Fourth Circuit published an opinion for United States v. Brian Bowman. The court held that Bowman's Fourth Amendment right, freedom from unreasonable seizures, was violated and reversed the district court ruling.
In the predawn hours the morning of June 20, 2015, Officer Waycaster was patrolling on Route 25 in Henderson County, North Carolina. He received a tip from the DEA that two individuals driving a red, older model Lexus could be narcotics runners. The DEA also provided a license plate number for the car. At 3:40 a.m., Officer Waycaster spotted an older red Lexus. Rather than stopping the vehicle based on information from the DEA, Officer Waycaster followed the car "looking for [his] own infractions . . . for [his own] reason to stop the vehicle." When the vehicle weaved over a fog line and accelerated to 10 mph over the speed limit, Officer Waycaster pulled the vehicle over, suspecting that the driver may have been under the influence. The government agrees that the DEA tip should not be considered in any legal analysis.
After stopping the vehicle, Officer Waycaster noticed two men in the vehicle: Bowman, the driver, and Alvarez, the passenger. Officer Waycaster testified that Bowman appeared nervous because his hands were shaking, he failed to make eye contact with Waycaster, and that his carotid artery was moving, indicating an elevated heart rate. Officer Waycaster did not see any alcohol or firearms in the vehicle, but he did notice an energy drink in the center console, food wrappers, and a suitcase in the back seat. Officer Waycaster explained why Bowman was stopped and then asked Bowman to exit the vehicle and go to the patrol car so that Officer Waycaster could check his information. Alvarez remained in the passenger seat the entire time.
After Bowman exited the vehicle, he consented to a weapons frisk. Officer Waycaster found no weapons. Officer Waycaster then told Bowman to sit in the patrol car while Waycaster ran his driver's license and registration. While Officer Waycaster was running Bowman's information, he asked Bowman where he was coming from. Bowman said that he was heading home after picking up Alvarez from Alvarez's girlfriend's house. He said he was returning the favor because Alvarez had done the same for him in the past. When questioned about the address of Alvarez's girlfriend's house, Bowman said he did not know it but that it was in his car's GPS. Officer Waycaster also asked Bowman what he did for a living. Bowman replied, saying that he was a welder but was currently unemployed. Bowman also said that he recently bought the Lexus off Craigslist. Officer Bowman testified that this was a suspicious activity because "it was a known practice with narcotics traffickers to either use rental vehicles or use multiple, different vehicles, or buy and sell vehicles to transport narcotics." Officer Waycaster, believing that Bowman was not under the influence, then issued Bowman a ticket for speeding and unsafe movement of the vehicle.
Bowman then began to exit the vehicle but Officer Waycaster asked if he could speak further with Bowman. Bowman consented. After another round of questions about what Bowman and Alvarez had been doing that night, Officer Waycaster, who was seated in the patrol car with Bowman said that he "was going to ask [Alvarez] questions if you don't mind, okay?" Bowman responded, "okay," and remained in the vehicle. As Officer Waycaster exited the patrol car he told Bowman, "just hang tight right there, okay." Bowman responded with, "oh, okay." Office Waycaster testified that at this point, Bowman was not free to get out of the patrol car because Waycaster had developed, from the traffic stop alone, reasonable suspicion of criminal activity.
Office Waycaster then went back to the Lexus and interviewed Alvarez about what had transpired before the two men were pulled over. Alvarez's story conflicted with Bowman's. Officer Waycaster then return to the patrol car and asked Bowman if there was meth in the Lexus, to which Bowman responded no. Bowman then refused to let Officer Waycaster search the Lexus. Thereafter, Officer Waycaster removed Alvarez from the Lexus and placed him in the patrol car with Bowman. Then Office Waycaster summoned a K-9 team. The K-9 team passed around the outside of the Lexus. The dog alerted an officer that illegal narcotics were present in the vehicle. Thereafter, Office Waycaster and the K-9 handler searched the interior of the car. They found meth, digital scales, and containers of ammunition.
Bowman was charged with possession with intent to distribute methamphetamine. Bowman filed a motion to suppress the methamphetamine evidence, arguing that Officer Waycaster unlawfully prolonged the completed traffic stop without consent or reasonable suspicion. The district court followed the recommendation of the magistrate judge in denying the motion to suppress. The magistrate judge admitted that Bowman was not free to leave the patrol car but that the prolonged detention was permissible because "Waycaster had a justified, reasonable suspicion that Defendant Bowman was engaged in criminal activity." The judge said that the totality of the circumstances supported this finding. Bowman then filed an appeal.
The Fourth Circuit reviews the district court's determination that the officer had a reasonable suspicion to prolong the traffic stop de novo.
First, a traffic stop must be reasonable. Here, Bowman does not challenge the reasonableness of the traffic stop. Bowman was swerving and traveling 10 mph over the speed limit. Instead Bowman's Fourth Amendment challenge rests on the unreasonableness of his prolonged detention in the patrol car. The Fourth Amendment allows an officer to conduct an investigation unrelated to the reasons for the traffic stop as long as it does not lengthen the roadside detention. To extend the length of the detention beyond the time necessary to accomplish the traffic stop's purpose, an officer must have reasonable suspicion or receive the driver's consent. Here, the officer did not receive Bowman's consent or have a reasonable suspicion.
The government argued that Bowman consented to the prolonged detention when he said "okay" after Officer Waycaster asked him to "hang tight right there, ok?" However, under a reasonable person standard, the court said that this was not consent by Bowman. Bowman never had time to respond to Officer Waycaster before Waycaster exited the vehicle and many would feel they were not free to leave in a similar situation. Furthermore, Waycaster was not asking a question, instead he was instructing Bowman what to do. Thus, when Bowman remained in the patrol car as the officer went to question Alvarez, the encounter was no longer a consensual one but instead became a non-consensual seizure.
After the Fourth Circuit concluded the search constituted a non-consensual seizure, the Court then analyzed whether Waycaster's "prolonged seizure was justified by reasonable suspicion." The Court noted there is no precise definition for what constitutes reasonable suspicion. Instead, reasonable suspicion is a commonsense, nontechnical standard that considers the realities of everyday life. The bar for reasonable suspicion is less than the probable cause standard and the facts articulated by the stopping officer and trial court must be taken in their totality. However, each factor can be analyzed separately by the court before being taken together in a full consideration of the circumstances surrounding the traffic stop.
The Fourth Circuit focuses on four specific factors in its analysis. First, Waycaster noted that both Bowman and Alvarez appeared to be nervous. However, a driver's nervousness is not a good indicator since most citizens are nervous when dealing with police. The record indicated that Bowman and Alvarez did not exhibit any signs of nervousness above the norm, and the government conceded Bowman was calm once exiting the vehicle. Moreover, although a suspect's increased heart rate, which can be evidenced by a suspect's throbbing carotid artery, can help support there was a reasonable suspicion of criminal activity, the present facts do not show Bowman demonstrated nervousness beyond the norm. The fact that Bowman remained calm in the patrol car and failed to make eye contact with an officer is not indicative of criminal behavior. Thus, the first factor weighed in favor of the Bowman.
Second, Waycaster stated that several articles in the car, specifically clothes, food, and an energy drink, helped give rise to a reasonable suspicion. However, these items are consistent with innocent travel and "in the absence of contradictory information," cannot reasonably imply criminal activity. While Bowman may have made false statements about his travel plans, the government failed to connect that fact to any wrongdoing in the case. Therefore, just the articles alone cannot be used to established untruthfulness, and subsequently reasonable suspicion.
Third, the district court noted that Bowman's inability to recall Alvarez's girlfriend's address contributed to Waycaster's reasonable suspicion. But, the Fourth Circuit stated this was entirely reasonable, as it is clear from the video recording that Bowman repeatedly said he used the car's GPS to find the house, and Waycaster could find the address by looking at the car's GPS history. The government failed to connect Bowman's response with criminal activity, and the Fourth Circuit stated it is reasonable that Bowman did not know the address and was relying on GPS in a dark, unfamiliar area.
Finally, Waycaster believed Bowman's vehicle purchases gave suspicion of criminal activity since he thought it was strange Bowman could afford to purchase multiple vehicles while unemployed and the use of multiple cars was a known practice of drug traffickers. The Fourth Circuit readily disposed of Bowman's vehicle purchasing habits, noting that Waycaster made "unsubstantiated assumptions." Even though Bowman was unemployed, there are numerous possible explanations to explain the car purchases that are all within the confines of the law. Likewise, innocent travelers may use multiple vehicles, some of which they could buy from Craigslist, and that fact is entitled to little weight.
Consequently, none of the factors alone provide a basis for reasonable suspicion. Even when looking at the totality of the circumstances, as mandated by precedent, the Fourth Circuit similarly found that the "combination of wholly innocent factors" did not give rise to reasonable suspicion. Therefore, the Fourth Circuit reversed the district court, as Bowman's motion to suppress should have been granted.
Today in United States v. Mitchell, the Fourth Circuit, in a per curiam opinion affirmed the conviction of Sidney Mitchell for unlawful possession of a firearm by a felon. Mitchell entered a conditional plea of guilty in the Middle District of North Carolina, reserving his right to appeal the judgment of the district court. Mitchell contends that the district court erred in denying his motion to suppress evidence of a firearm that was found while police were conducting a search of his vehicle. Mitchell was sentenced to twenty-six months in prison.
In the waning hours of sunlight on November 20, 2012, a North Carolina police officer stopped Mitchell's car on a suspicion that the tint on the vehicle's windows was darker than allowed under North Carolina law. While performing a test that would gauge the level of tint on Mitchell's windows—a process that involves placing a device on the inside of the vehicle—the officer claims he noticed the smell of "burnt marijuana." Though Mitchell denied smoking marijuana, he consented to a search of his person. After searching Mitchell the officer turned to the vehicle, discovering a small amount of marijuana resin and a gun on the driver's side floorboard.
The Supreme Court recently handed down its decision in Florida v. Jardines, affirming by a 5-4 vote the Florida Supreme Court's ruling that the police's use of a trained narcotics detection dog on the front porch of a home is a "search" within the meaning of the Fourth Amendment. This case is the first time the Court has applied the non-Katz-based search doctrine articulated in United States v. Jones. As will be more fully elaborated below, it is my claim that the Court purposely avoided using the word "trespass" so as not to reverse the Florida state courts, which had decided that the police were lawfully present on the defendant's property at the time of the dog sniff, on an issue lying at the heart of state court competence—that is, application of the common law of trespass.
Recall that in Katz v. United States, the Court overruled Olmstead v. United States. The Court in Olmstead held that wiretapping was not a Fourth Amendment search because there was no physical police invasion of property that would constitute a trespass—there was no "entry of the houses or offices of the defendants." Justice Harlan authored a concurring opinion in Katz that was to become the dominant formulation of the test for a search under the Fourth Amendment—if the individual has manifested a subjective expectation of privacy and society is prepared to accept that expectation as reasonable, then there is a right to privacy protected by the Fourth Amendment in those circumstances.
Justice Scalia, writing for the Court in Jones, reasoned that the "persons, houses, papers and effects" portion of the Fourth Amendment would be rendered superfluous if the Fourth Amendment were not closely tied to property rights. According to Justice Scalia's opinion, and much to the surprise of many observers, Katz's reasonable expectation of privacy ("REOP") standard "added to"—but did not "substitute for"—the common law trespassory test used by the Court for decades prior and embodied inOlmstead. As the Court put it, "for most of our history the Fourth Amendment was understood to embody a particular concern for government trespass upon the areas ('persons, houses, papers, and effects') it enumerates. Katz did not repudiate that understanding." As a result, information gained by the government's trespassory activity would be the product of a search within the meaning of the Fourth Amendment. Five members of the Court saw the police's placement of a GPS device on the defendant's car as a governmental trespass on private property, therefore constituting a Fourth Amendment search. Four others concurred in the judgment, but rejected the trespass rationale.
It is quite clear that in Jardines, Justice Scalia did not rely on the REOP strand of Jones. But what is curious is that he did not use the word "trespass" once in his majority opinion. Instead, Justice Scalia conspicuously referred to that portion of theJones opinion as holding that "'when the Government obtains information by physically intruding' on persons, houses, papers or effects," a search has occurred. Because, according to the majority, that occurred when the police brought a narcotics-sniffing dog to the defendant's front door to search for drug activity, there was no reason to reach the question of whether the defendant's reasonable expectation of privacy was violated.
In my view, the "trespass" test articulated in Jones and the "physical intrusion" application in Jardines are identical in content. Indeed, Justice Kagan's concurring opinion understands the majority opinion to have found that the police conduct constituted a trespass. The dissent reached a similar conclusion (though it obviously did not agree that one had occurred). What is more difficult to discern is whether or not this branch of Fourth Amendment doctrine relies on common law trespass—as theJones majority articulated it—or on some notion of constitutional common law, under which the federal and state courts are to decide if the police committed a "physical intrusion" having constitutional significance. But in my view, there is little reason to think it is the latter. Aside from the understanding evidenced by the concurring and dissenting justices, the remainder of this Article offers another reason to think that the Jones test is alive and well as articulated in that opinion, and that there were other, more deeply-rooted reasons for the Court to avoid using the magic word "trespass" in Jardines, and instead rely on a notion of "physical intrusion" in.
It will be interesting to see how this issue plays out in the lower courts, but for the sake of observation, I suspect that the majority in Jardines had a particular reason for not using the word "trespass" despite the strong expectation that it would do so based on the opinion in Jones. My theory is that Justice Scalia did not want to intrude upon the Florida courts' handling of the trespass issue. As the dissent in the Florida Supreme Court decision points out, it was undisputed that the police were lawfully present at Jardines' front door. There was no trespass under state law-that much was clear for the remainder of litigation in the Florida courts-and the United States Supreme Court. Conversely, the Florida Supreme Court had found a search under the more traditional Katz/REOP test. It decidedly did not revisit the trespass issue, and let stand the Florida Court of Appeals' ruling that the police were lawfully present at the defendant's front door.
Thus, in order for the U.S. Supreme Court to affirm the finding of a "search," I think it had three main options: 1) affirm that a search had occurred on the REOP rationale, 2) vacate on the REOP analysis and remand to the state courts for consideration in light of Jones and the trespass rationale (decided after the Florida Supreme Court decided Jardines), or 3) find a search based on the Jones trespass test and commit a blunder of judicial federalism.
The first option would seem the easiest, and it is what I thought the Court was poised to do. However, the majority turned out to be much more eager to apply the "new" Jones rationale (that Justice Scalia claimed was actually an old rationale) instead of traditional REOP doctrine from Katz. The second option would be unsatisfactory, since it would leave the ultimate disposition of an important Fourth Amendment issue (dog sniffs as searches) unresolved during more litigation in the state courts, and even then, the Florida courts' resolution of the Fourth Amendment question would not necessarily be binding in other states. Furthermore, if the Supreme Court reversed the state courts on the REOP rationale, the judgment entered on remand would probably be one finding "no search" since there is no reason to believe the issue of trespass would be decided any differently by the state courts the second time around. This option would accomplish little, save for virtually requiring the state courts to find that no search occurred and, perhaps more cynically, would only be useful if that is the result the justices wanted.
The third option would be something of an intrusion into the routine workings of the state courts, since it would involve the United States Supreme Court resolving a basic question of state tort law that was settled below in the state courts. Answering the question of whether a common law trespass occurred is an issue at the heart of state court decision making. In other words, if the Supreme Court disagreed that the dog sniff violated a reasonable expectation of privacy, but nevertheless thought that a trespass—and therefore a search—had occurred, it essentially would be telling the Florida state courts that they had misapplied the common law of trespass.
While not inconceivable, this approach would not comport with a reasonable sense of federal non-interference with state court adjudication. This is best understood as a question of jurisdictional discretion—while the Supreme Court could reverse a state court's resolution of a state law issue, it might decline to do so based on respect for the state court. Similarly, it could simply resolve the case on other grounds to avoid the problem. Here, the Court could have simply affirmed on the REOP rationale and declined to apply the new Jones analysis.
My claim is that Justice Scalia took this approach ("physical intrusion" instead of "trespass") in the first instance, and gained the support of four other justices in conference, in order not to offend the Florida state courts by re-working (i.e., reversing) their resolution of the common law trespass issue. I see no explanation in the majority opinion of how the Jones "trespass" test has changed in any way in Jardines, where it was described as a "physical intrusion" rationale. Nor is an explanation provided by the other justices writing separately in concurrence or dissent. Instead, I think Justice Scalia purposely minced his words in a way that allowed de facto application of the Jones trespass rationale without using the word "trespass." There is a strong background notion shared by many onlookers that, despite the Court's technical ability to do so, it should not (and in this case would not) re-visit an issue so central to the daily work of a state court. The majority could, to some extent, blunt the resonance of such a move by carefully selecting its words.
To ground things a bit more in federal courts doctrine, consider the jurisdictional principles at play in the case. There is no doubt that the Supreme Court possesses the jurisdiction to decide non-federal issues when they are antecedent to the resolution of an issue of federal statutory or constitutional right, as in these Fourth Amendment search cases. The issue of whether a common law trespass occurred must be determined in order to decide whether a "search" occurred within the meaning of the federal Constitution—indeed, the answer to the "search" question is entirely answered by the "trespass question." But I think that larger issues of federal-state judicial relations were at play in this case, and that was what was driving the unexpected outcome. As Professor Shapiro has explained, "a court will often acknowledge that it has jurisdiction over the subject matter of a dispute yet, despite Marshall's dictum, will refrain from exercising it." In other jurisdictional settings (i.e., not on review of a state court judgment), the Court has developed a set of abstention doctrines designed to promote equity, comity, and federalism—Pullman, Burford, and Younger to name a few of the most prominent examples. Similarly, on direct review of state court judgments, the Court's decision in a given case not to visit certain issues resolved in the state courts may also be driven by concerns for comity and federalism. Leaving undisturbed a state court's ruling on an issue in a case is a vote of confidence for the state courts; on the other hand, a reversal of a state court's ruling on a run-of-the mill question may create friction between the federal and state judicial systems. By not using the word "trespass" and appearing to retreat from the repeated use of that word inJones, Justice Scalia seems to have decided the case on an altered rationale. But on closer examination, it appears that he may have been trying to avoid the affront to the state courts that would have occurred had he explicitly second-guessed a common law question at the core of their competence by saying that a trespass took place. Calling the conduct at issue a "physical intrusion," at the very least, avoided this in name. How successful this attempt was at avoiding friction with the Florida state courts on a decidedly non-federal issue is another matter entirely.
In summary, the Court decided that the sanctity of the home was offended by the dog sniff in this case since the police entered this constitutionally protected area, but it did so in a roundabout way. The result is that the state of the Jones "trespass" test is in flux and will spawn more litigation over whether there must be a finding of a common law trespass in order to rely upon that branch of Fourth Amendment search doctrine, or if instead, state and federal courts are to rely upon some notion of an unconstitutional "physical intrusion" whose relationship to common law trespass is unclear at this point in time. Moreover, this case illustrates that the procedural posture of a case on certiorari from a state supreme court may affect the substantive content of the decision in the United States Supreme Court. Here, there is strong reason to believe—in light of judicial federalism—that the finding in the Florida Court of Appeals that the officer and dog were lawfully present on the property tied the hands of the Supreme Court ever so slightly. As a result, the Court's holding finding a search was less than straightforward and tiptoed around the word "trespass" while, in effect, holding that is precisely what occurred.
. 133 S. Ct. 1409 (2013).
. See Jardines v. Florida, 73 So. 3d 34 (Fla. 2011). The Florida Supreme Court held that the Fourth Amendment draws a "firm line at the entrance of the house" and that the "sniff test" undertaken by the police and K9 partner was a search requiring probable cause and a warrant. Id. at 55-56. Since the dog sniff was conducted without a warrant, the search was held unreasonable and the evidence of drug activity was suppressed. See id.
. 132 S. Ct. 945 (2012). The Court held that Fourth Amendment protections do not "rise or fall" with the Katzformulation, and that the Amendment is also concerned with government trespass. Id. at 950.
. 389 U.S. 347 (1967).
. 277 U.S. 438 (1928).
. See, e.g., Orin Kerr, The Fourth Amendment and New Technologies: Constitutional Myths and the Case for Caution, 102 Mich. L. Rev. 801, 820 (2004) (noting, in this pre-Jones article, that the touchstone of the Fourth Amendment is the "reasonable expectation of privacy" test which first appeared in Justice Harlan's Katz concurrence).
. Katz, 389 U.S. at 361 (Harlan, J., concurring).
. Jones, 132 S. Ct. at 950.
. Id. at 950 (citation omitted).
. A "search" requires probable cause and a warrant. So the syllogism continues: if the government is trespassing, it quite obviously does not have a warrant, and is thus committing an unreasonable search within the meaning of the Fourth Amendment.
. James, 132 S. Ct. at 954.
. Id. at 957 (Alito, J., concurring). Justice Alito's analysis began: "I would analyze the question presented in this case by asking whether respondent's reasonable expectations of privacy were violated by the long-term monitoring of the movements of the vehicle he drove." Id. at 958.
. Florida v. Jardines, 133 S. Ct. 1409, 1414 (2013) (quoting Jones, 132 S. Ct. at 950-51 n.3 (emphasis added)).
. See id. at 1417.
. See id. at 1418 (Kagan, J., concurring).
. See id. at 1420 (Alito, J., dissenting).
. Jardines v. Florida, 73 So. 3d 34, 61 (Fla. 2011) (Polston, J., dissenting) ("[I]t is undisputed that one dog and two officers were lawfully and briefly present near the front door of Jardines' residence when the dog sniff at issue in this case took place.").
. State v. Jardines, 9 So. 3d 1, 4 (Fla. Dist. Ct. App. 2008) ("[T]he officer and the dog were lawfully present at the defendant's front door . . .").
. See supra text accompanying note 16.
. See Jardines, 73 So. 3d at 46.
. See supra note 21.
. At oral argument, Justice Alito explicitly asked counsel for the defendant why the Court should not accept as a statement of Florida law that no trespass occurred, indicating some uneasiness from the bench with re-deciding an issue of state tort law and causing friction between the federal and state courts in our system of dual sovereignty. See Transcript of Oral Argument at 59, Florida v. Jardines, 133 S. Ct. 1409 (2013) (No. 11-564), available athttp://www.supremecourt.gov/oral_arguments/argument_transcripts/11-564.pdf.
. See Jardines, 133 S. Ct. at 1417.
. That is, there is no reason to think the finding of "no trespass" would be re-visited in any way.
. To be clear, since there is no federal law of trespass, a judgment from the Supreme Court holding that a search had occurred due to a governmental trespass would effectively reverse the Florida courts on their resolution of an issue of common law.
. See infra note 34.
. See generally David L. Shapiro, Jurisdiction and Discretion, 60. N.Y.U. L. Rev. 543 (1985) (outlining the various ways in which the Supreme Court could exercise discretion on review of state court cases and concluding the discretion is necessary to avoid undue interference with the states).
. See supra note 16.
. See supra text accompanying notes 18-19.
. In conversations with Judge Raymond Lohier of the Second Circuit Court of Appeals, Judge John Koeltl of the District Court for the Southern District of New York, and Professor Helen Herhskoff of NYU Law, all told me that they had strong doubts that the Court would decide the Jardines case on anything but the REOP rationale, since going beyond that issue, and onto the new Jones test, would require a disagreement with the Florida courts on whether a common law trespass had occurred. They all echoed Justice Alito's concern of failing to accept the state courts' resolution as an authoritative statement of Florida law. Discussion with Judge Raymond Lohier, 2nd Circuit Court of Appeals and Judge John Koeltl, United States District Court for the Southern District of New York, in New York City., N.Y. (February 27, 2013) during New York University School of Law Constitutional Litigation Seminar, held at the United States District Court for the Southern District of New York, 500 Pearl Street, New York, NY; Interview with Helen Hershkoff, Herbert M. and Svetlana Wachtell Professor of Constitutional Law and Civil Liberties, New York University School of Law, in New York City., N.Y. (March 4, 2013).
. The Supreme Court has certiorari jurisdiction to review state court judgments under 28 U.S.C. § 1257 (2012). It has been relatively clear since Martin v. Hunter's Lessee, 14 U.S. 304 (1816), that the Supreme Court, on review of a state court judgment, can review antecedent state law questions, which are those that must be decided in order to ultimately determine whether the state court properly decided an issue of federal law. However, the Supreme Courts (and federal courts more generally) has adopted a set of abstention doctrines under which jurisdiction—and competence to address a certain issue—may be declined for reasons of equity, comity, or federalism. The federal courts have not held fast to Justice Marshall's admonition inCohens v. Virginia: "We have no more right to decline the exercise of jurisdiction which is given, than to usurp that which is not given. The one or the other would be treason to the Constitution." Cohens v. Virginia, 19 U.S. 264, 404 (1821).
. Shapiro, supra note 31 at 547.
. See generally, Railroad Comm'n of Tex. v. Pullman Co., 312 U.S. 496 (1941). Pullman abstention involves staying a federal court action, but retaining jurisdiction, so that the state courts have an opportunity to interpret the constitutionally-suspect statute in question and thereby, potentially avoid the need for a constitutional decision.
. See Burford v. Sun Oil Co., 319 U.S. 315 (1943). Under Burford abstention, a federal court sitting in diversity may stay its hand where the state courts have greater expertise in a question of state policy, and the question is of substantial importance to a state administrative scheme. The idea is that the federal court should hesitate before interfering in a state administrative scheme in which the state courts play a vital role.
. See generally, Younger v. Harris, 401 U.S. 37 (1971). Younger abstention is based on a rule of equity which forbids a court of equity from enjoining ongoing criminal proceedings, even where the individual being prosecuted is raising federal constitutional claims. Also at play is a principle of comity, which holds that the state court will give the federal constitutional defenses in the criminal case a fair shake.
Comment: The Fourth Amendment and Warrantless Cell Phone Searches: When is Your Cell Phone Protected?
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text:
<?php

use Hubzero\Content\Migration\Base;

// No direct access
defined('_HZEXEC_') or die();

/**
 * Migration script for adding Editors - Pagedown plugin
 **/
class Migration20180326100200PlgEditorsPagedown extends Base
{
	/**
	 * Up
	 **/
	public function up()
	{
		$this->addPluginEntry('editors', 'pagedown');
	}

	/**
	 * Down
	 **/
	public function down()
	{
		$this->deletePluginEntry('editors', 'pagedown');
	}
}

redpajama_set_name: RedPajamaGithub


On June 29, the inagural women's match contested between two AFL affiliated teams will be played that MCG. The match will be available for replay on youtube the following day.
Round 2 of the 2013 VWFL Premier Division match of week was streamed on April 13, 2013. There is about 30 seconds of black screen at the beginning of the video.
VWFL 2013 Season Launch. Darebin vs Diamond Creek streamed live!
The USAFL commissioned production of a commercial that will be aired twice per match on every AFL game aired on Fox Soccer Channel Plus during the 2013 season. Join us for the fun athletic competition, stay for the comraderie.
Stateside Footy is working on a promo video to replace the canned PSA's in their 2013 season.
Stateside Footy presents an of Australian Rules Football matches, played on October 14, 2012 at the USAFL Nationals Tournament in Mason, Ohio. The first half of the show features the Womens Division Final between the Boston Lady Demons and the two-time defending champion Denver Lady Bulldogs. The second half features a look back at the Boston Demons 2012 season. Stateside Footy is a cable access TV show produced with the assistance of WCTV - Wilmington Community Television in Wilmington, MA. It features Aussie Rules Football as it is played in the U.S.A.


text:
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Grants to USA youth leaders for projects to meet needs related to the Coronavirus (COVID-19) pandemic and mitigate childhood hunger. Funding is intended to support community service initiatives and fundraising projects. The goal of the program is to actualize young peo...
Grants to USA Investigators Affiliated with Qualified Institutions for Research on Various T...
Grants to USA investigators affiliated with qualified institutions for research on various types of arthritis. Funding may be used for both clinical and basic science studies, with a focus on proposals addressing the improvement of patient care. Eligible projects inclu...
Fellowships to USA Individuals to Conduct Scholarly Research in New York City
Fellowships providing a weekly stipend of $1,000 to USA individual scholars from outside and within the New York City metropolitan area to make use of library collections in New York City. Funding is intended to support scholars currently engaged in independent, post-d...
Grants to USA Nonprofits, For-Profits, IHEs, Agencies, and Individuals for Research on Techn...
Grants to USA nonprofits, for-profits, IHEs, government agencies, and individuals for research addressing new technologies for use in education. Applicants are advised that required registrations must be completed in advance of applying. Funding is intended to enhance ...
Award to a Maryland, Virginia, or Washington, DC Principal of Grades PreK-12 for Outstanding...
Award of $7,500 to a Maryland, Virginia, or Washington, DC principal in eligible locations to acknowledge outstanding contributions to PreK-12 education. The award is intended to recognize administrators who improve students' educational environment and demonstrate lea...
Scholarships to USA Students in Multiple States to Pursue Undergraduate Studies at a College...
Scholarships of $5,000 and scholarships of $10,000 to USA students in multiple states to pursue or continue undergraduate studies at a college, university, or vocational school. Funding is intended for individuals from historically underserved backgrounds. Eligible app...
Fellowships to USA, Canada, and International Scholars to Study the History of Technology, M...
Fellowships to USA, Canada, and International researchers and scholars to study the history of technology, medicine, and science in the United States. Fellows will receive access to the funding source's extensive collection of resources, as well as participate in lectu...
Fellowships to USA Postdoctoral Researchers at Nonprofit Institutions for Studies Related to...
Fellowships to USA postdoctoral researchers affiliated with nonprofit institutions for studies in the biology of the aging process. The purpose of the grant program is to enable new researchers to become established in the field. Projects should be specifically directe...
Fellowships to USA, Canada, and International Scholars for Research Related to Contemporary ...
Fellowships to USA, Canada, and International scholars for research related to contemporary Jewish history. Fellowships will take place either in New York or in Jerusalem, Israel. Eligible stipend uses include transportation, living expenses, and travel. Research field...
Grants to USA Agencies, IHEs, Organizations, Corporations, and Individuals for Research Rela...
Grants to USA Federal agencies, IHEs, national laboratories, research institutions, organizations, corporations, cooperative extension services, and individuals to develop and disseminate research tools to address the needs of the specialty crop industry. Applicants mu...
Fellowships to USA PhD Students for Workforce Development and Training
Fellowships to USA and territories graduate students in eligible PhD programs for workforce development and training. Eligible uses of funding include salary, tuition, travel, and living expenses. The goal of the program is to provide opportunities to students who are ...
Fellowships to USA College Students and Graduates to Complete a Master's Degree in STEM Teac...
Deadline 03/01/21 Conference Date: 01/26/21
Fellowships to USA college students and graduates to complete a Master's degree in STEM education at eligible universities in Pennsylvania. Participants will receive a stipend to cover living expenses and tuition, and must commit to teaching at underserved schools in P...
Fellowships to USA Professionals for Training and Projects in the Field of Healthcare Policy ...
Fellowships to USA and Territories professionals in a range of disciplines to participate in a year-long professional development and enrichment program in the fields of aging and healthcare policy. The fellowship program offers training in communications, professional...
Grants to Canada and USA Eligible Medical Residents to Improve the Health and Well-Being of ...
Grants of up to $2,000 to Canada, USA, and Territories eligible medical residents for projects to improve children's health and well-being. Funding is intended to meet the health needs of children with a broad-based community approach. Projects must be led by a pediatr...
Fellowships to USA Graduate Students for Programs to Study Abroad
Fellowships to USA graduate students for opportunities to study abroad. Students will study cultures and languages in eligible foreign countries. The purpose of the program is to offer students the opportunity to gain knowledge that will assist them with future governm...
Grants to USA and Canada Pediatricians and Fellowship Trainees for Community-Based Health In...
Grants of up $10,000 to USA, territories, and Canada pediatricians, pediatric subspecialists, and fellowship trainees for community-based health initiatives. Eligible projects focus on children's health or rural community health issues. Funding is intended for the init...
Grants to USA, Canada, and International Nonprofits, For-Profits, IHEs, and Researchers to I...
Grants to USA, Canada, and International nonprofit and for-profit organizations, institutions of higher education, and government-affiliated researchers to improve the health of livestock. A letter of intent must be submitted prior to submitting a full application. Fun...
Grants to USA Latinx Artists and Arts Nonprofits Serving Latinx Populations for COVID-19 Rel...
Grants of $2,500 to USA Latinx artists and grants of $5,000 to nonprofit arts organizations that serve Latinx populations for relief during the Coronavirus (COVID-19) pandemic. Eligible applicants must demonstrate significant financial hardship as a result of the econo...
Grants and In-Kind Services to USA Art Collaboratives and Artists for Arts Projects and Prof...
Grants and in-kind services to USA art collaboratives and artists for projects and professional development activities. The purpose of this grant program is to support original arts projects as well as the training and support of artists. Eligible artists may be in a w...
Grants to USA and Puerto Rico Faculty at Eligible IHEs for Humanities Research
Grants of up to $60,000 to USA and Puerto Rico faculty and staff members at eligible IHEs for humanities-based activities. Funding is intended to support a wide range of research projects, publications, and scholarly activities related to the study of the humanities. E...
Competition for USA, Canada, and International Individuals, Nonprofits, and For-Profits for S...
Competition for USA, Canada, and International individuals, private and public institutions, companies, clubs, schools, universities, and nonprofits for sustainable projects that demonstrate feasible solutions to environmental problems. Award categories are Fire, Water...
Grants to USA Mathematics Scholars for Collaborative Research Projects
Grants to USA mathematics scholars affiliated with a higher education institution for collaborative research projects in the field of mathematics. Funding is intended to support interactions between mathematicians, costs related to hosting scholars, and general researc...
Fellowships to USA and Puerto Rico Female Scientists for Research in STEM Fields
Fellowships of $60,000 to USA and Puerto Rico female postdoctoral scientists affiliated with qualified institutions for research in the fields of physical or material sciences, life sciences, engineering, technology, computer science, and/or mathematics. Consideration...
Grants to USA, Canada, and International Scholars to Produce a New Work of Film Scholarship
Grants to USA, Canada, and International accomplished scholars to produce a new work on the science, theory, commerce, history, or art of theatrical motion pictures. Proposed projects may be Internet sites, interactive DVDs, multimedia presentations, curatorial project...
Grants to USA, Canada, and International Organizations and Individuals to Protect Wildlife an...
Grants of up $1,500 to USA, Canada, and International organizations and individuals for the protection and preservation of wildlife and habitat. Funding is intended for a range of projects, including education, research, and habitat management. Special consideration wi...
Awards to USA Journalists for Excellence in Public Service Journalism
Awards of $5,000 to USA journalists to recognize outstanding commentary or investigative journalism that serves the common good. Nominees should demonstrate strong storytelling skills, reportorial excellence, and social justice impact. The contest is open to journalist...
Global Opportunity for Children to Participate in a Contest that Fosters Creativity and Entr...
Opportunity for children around the world to participate in a contest that fosters creativity and entrepreneurship. Children ranging in ages from PreK to 12th grade may create their own invention, in or outside of school, to solve a problem in their community, school, ...
Grants to USA, Canada, and International Scholars for Research on Retirement and Disability
Grants of $45,000 to USA, Canada, and International non-tenured and junior scholars for innovative research on policies related to retirement and disability. Funding is intended to promote the work of scholars from all academic fields who are employed at an institution...
Awards to USA, Canada, and International Individuals and Organizations for Exceptional Contr...
Awards of $500 to USA, Canada, and International individuals and organizations to acknowledge outstanding achievements in education. Awards are intended to recognize those that do exceptional work to enhance student learning through technology. Nominations may be submi...
Award to a USA, Canada, or International Early-Career Psychotherapist for Professional Achie...
Award of $1,000 to a USA, Canada, or International individual to recognize contributions to the fields of psychology and psychotherapy. Eligible recipients are within the first ten years of their postdoctoral career. The honor is intended to be bestowed for accomplishm...
Award to a USA, Canada, or International Psychologist for Contributions to the Mental Health...
Award to a USA, Canada, or International individual to recognize contributions to the field of mental health. Eligible recipients are psychologists within the first ten years of their postdoctoral degree. This award is intended to support efforts to advocate for and im...
Fellowships to USA, Canada, and International Journalists for Original Projects and Research
Fellowships of $60,000 to USA, Canada, and International journalists for original projects and research in the area of digital progress in the media arena. The Fellowship is intended to offer an experience at a prestigious university to learn and collaborate on activit...
Fellowships to USA Doctoral Candidates for Research on Disability and Retirement
Fellowships to USA doctoral candidates for research on disability or retirement. Proposals are encouraged from applicants in all academic disciplines. The purpose of the program is to improve the quality of scholarship in this field of studies and to promote the next g...
Grants to USA Individuals for Eligible Research Addressing Chocolate and Its Production Proc...
Grants to USA individuals for eligible cultural, scientific, and historic research addressing chocolate and the production process. Special consideration will be given to proposals that describe how the research will have an educational impact on the public. Funding is...
Grants to USA, Canada, and International Individuals for Projects to Promote Awareness of An...
Grants to USA, Canada, and International individuals for projects that raise awareness about issues related to animal rights. Eligible projects may be artistic or academic in nature. Priority funding will be awarded to new applicants. Grants are awarded in three catego...
Fellowships to USA, Canada, and International PhD, Postdoctoral, and MD Researchers for Canc...
Fellowships to USA, Canada, and International PhD, MD, and postdoctoral researchers working in a USA lab for cancer research projects. Emphasis is placed on projects addressing causes and/or treatment. Funding is intended to support young promising scientists at a crit...
Grants to USA Scholars and Doctoral Graduates for Costs Associated with Research and Fieldwo...
Grants of up to $6,000 to USA scholars and doctoral graduates for expenses related to non-commercial research in any area of knowledge. Funding is intended to support laboratory research expenses, fieldwork costs, travel to archives and libraries, and the purchase of m...
Award to a USA, Canada, or International Librarian to Honor Outstanding Character in a Chall...
Award of $10,000 to a USA, Canada, or International librarian to recognize extraordinary character in the face of a difficult situation. Nominees should demonstrate that they have dealt with challenges with integrity and with their dignity still intact. In addition to ...
Award to a USA, Canada, or International Individual for Holocaust Research and Writing
Award to a USA, Canada or International individual for scholarly research and writing on the Holocaust. Only books containing new research on the Holocaust, or its antecedents and aftermath, will be considered. Research accuracy, methodology, scholarship, literary meri...
Grants to USA Judges and Court Managers for Professional Development Courses
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Grants to USA judicial courts, related court organizations, IHEs, nonprofits, individuals, government agencies, and corporations to develop and enhance curricula to meet the educational needs of their jurisdiction. Courts are invited to submit applications for the adap...
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redpajama_set_name: RedPajamaCommonCrawl


text:
Q: How to make a "progress bar" using printf? Many command line tools implement text-based progress bar. Like rpm installing:

installing ##############[45%]

the # grows with the percentage, while keeps itself in a single line. What I want is something similar: I need a progress indicator taking just one line, that is to say, when percentage grows, it got overwritten, instead of make a new line(\n).
I tried this:
   #include <stdio.h>

   int main (){
       int i = 0;
       for (i = 0; i < 10000; i++){
           printf("\rIn progress %d", i/100);
       }
       printf("\n");
   }

\r works to overwrite the single line. However, \r brings cursor to the beginning of line and printf brings cursor to the end, which result in a rapidly waving cursor. You guys can feel it by a little compiling. Can Anyone come up with alternatives to avoid this issue?

A: Here is how rpm did it, maybe you can write a similar function for your own purpose: printHash.
rpm use \b instead of \r to erase the output line character by character.

A: This is a problem of the stdout stream being buffered. You have to flush it explicitly (implicit flushing occurs with a \n) using fflush(stdout) after the printf():
fflush(stdout);

A: I believe using
printf("\e[?25l");

may be able to help. This will hide the cursor. Honestly, I'm not sure if using /r or printf again will override that bit of code and show the cursor, but it's worth a shot. Also, the below code can be used to show the cursor again.
printf("\e[?25h");

A: To use formatting on your terminal, check the ANSI escape code.

A: Rather than giving your some erroneous and non-portable code lines, I'd recommend you to read through the man pages for your system's termcap and terminfo. It's a bit hard to follow at first, but it's a must-read if your about to start mucking with terminal-dependent code. The Wikipedia pages are a good place to start, but then do give the man pages on your system a read as well.
Also I just realized your question is most definitely a duplicate of a few other questions.

redpajama_set_name: RedPajamaStackExchange


text:
Q: What is the best way to insert range of values into a datastructure If I have a datastructure which is the fastest way I could insert values into it in a specified range?
For example if I had a method:
myDatastructure var=new myDataStructure();
var.insert(2,1000);

it would mean that I get a most optimised way of getting a datastructure holding values from 2 to 1000 in each of index sequentially.

A: If you have a C++11 STL, you could use the std::iota() function to insert sequentially increasing values into any container that supports iterators. As for choosing a type of container, C arrays or std:arrays should be the fastest as they require no additional memory allocations while inserting elements.

A: The fastest way to do this is to not do it.  Here's an outline of a class that looks like a read-only array of consecutive integers.
class range {
private:
  int low, high;
public:
  typedef int iterator;
  range(int low, int high) { this.low = low; this.high = high; }
  iterator begin() { return low; }
  iterator end() { return high + 1; }
  int operator[](int index) { return low + index; }
}
...
range r(1, 1000);
for (r::iterator i = r.begin(); i != r.end(); ++i) { ... }

If you need a writable collection, then the answer depends on how you want to modify it after creation.


Today we've launched 'How do I', a new digital service into all our Food stores.
We want all store colleagues to be able to find out how to do something in their store quickly and easily. 'How do I' is a website with up-to-date policies and procedures on it, written in a clear, user-focused way.
We knew that information about how to do things in stores was kept across multiple systems. Colleagues often had to search pages of policy to find the bit of information they needed. And some policies and procedures were more up-to-date than others, meaning colleagues didn't always trust the information they were seeing. So our goal was to create a trusted source of better practices in one easily-accessible place.
Co-op Digital builds user-centred products and services – things that make people's lives easier. That means doing the hard work centrally to make things clearer, simpler and faster for our users. To do that we speak to users and show them what we're building frequently. We change what we've designed based on how they interact with it and what their needs are.
For us, our users are colleagues in Co-op Food stores. And we involved colleagues from stores as much as possible while writing content and building the site.
In the past 6 months, we've visited 23 stores around the country and spoken to 46 colleagues in stores. We've also spoken to colleagues working in our Operations Store Support (OSS) team, who field queries from stores every day.
As well as visiting stores and showing them our works in progress, we involved store colleagues in writing the content too. Six colleagues were seconded from stores for 6 months. They worked with our content designers in Digital to learn about writing clear, simple, effective content that focuses on the needs of the user.
We're building services with colleagues. We work with them, listen to their feedback and adapt services so that they're continually useful for the people who will use them.
Since July this year, 10 test stores in Manchester have had access to an early version of How do I. In September, we also gave it to 2 other areas – Surrey, and Glasgow. That means that 47 stores have been using the website, and giving us feedback which we've been using to make improvements.
Every page on the website has a feedback function, so colleagues can tell us if they found the information they were looking for and whether it answered their question.
Giving people early access to what we're doing kept us on the right path, and helped us to decide what to focus on next.
We learnt that most of the time, when a colleague isn't sure how to do something, they ask someone else in their store, call another store or text a colleague. It's easier to do that than to look it up on the existing system.
At the moment, colleagues can only access the site through the store computer. We know that this can take colleagues off the shop floor, and takes longer than asking the person next to you. We're hoping to have a way for colleagues to sign in and access the site from any device early next year.
There's still multiple places to look for information – on both How do I and the intranet. We're working with our colleagues in Food HR to get their policies onto How do I, so it can become the go-to place for everything a colleague might need to know about working in a Food store.
We're going to keep on making How do I better.
The version that's in stores today isn't the final version of How do I. We'll continue to use analytics, research and feedback to improve the service so that it continues to meet the needs of the people that use it.
If you're a store colleague, log on to your store computer and let us know what you think – we couldn't have got this far without your input.
(Transcript) Matthew Speight: Leading the Way is the Co-op's plan to transform the way we run our stores for our customers and members and most importantly make it simpler for our colleagues.
So the Co-op Digital team came to the Leading the Way program really early in the year and at the time, if I'm honest, I didn't really understand how we'd work together as a team because it wasn't clear and I didn't know the Digital team that well, the skills and the abilities they've got on the team.
The first thing I think the Digital Team have done is they've opened my eyes actually having spent a couple years in the field, what I thought was was the truth about supporting colleagues and providing leadership is actually very different to what the reality was.
In fact we could have supported colleagues more and we should have done a better job and the Co-op Digital team have brought user-centric design to the Co-op. And they are fascinating as a team in terms of that passion to make sure that the user needs are at the forefront of any project. And before you scope an idea or a potential project they focus on what is it user need that you're trying to fix.
My Schedule is a tool for colleagues that allows them to not only plan their holidays and look at their own shifts but start to think about working in other stores and it gives flexibility to colleagues. It disrupts the way we run our stores.
That's one project, but this year we're going to launch 'How Do I': how do I do things, and that's probably a real simple baseline of what the Digital Teams can do. They've taken our existing policies, 7,000 of them that are on Citrus which is our store process back office platform and simplified it. They provided a real simple menu option, that will improve the way our colleagues navigate problems in our stores. That will save time, it'll improve compliance and it'll also allow us to answer both colleague queries and customer queries in a much more efficient way.
And those sort of things together, My Schedule, How Do I, are the start. Then if you start to think about how we might run our stores and bring our IT data together, then you know digital gives the potential to really disrupt the way we run our stores and I'm hugely excited by some of those plans for next year.
I'm blown away by what they brought the program. They're a fantastic team, hugely talented and they've made a real difference the program.


Marshal Clark died from an accidental gunshot wound. In the evening hours of November 18, the 43-year-old victim and two deputies were preparing to leave for a patrol of the train station when one of the deputies accidentally discharged his pistol. The bullet struck Marshal Clark in the stomach. Following an operation in Salt Lake City, he succumbed to his wound four days later. Marshal Clark was married and the father of nine children. He is buried in Evergreen Cemetery, Springville. His bronze name plaque is sponsored by employees and friends of the Springville Police Department.


text:
Defend Your Crypt
Ratalaika Games
User Ratings: 4
Our Review: Scroll Down
Defend Your Crypt Review (Wii U eShop)
Tomb sweet tomb
Version Reviewed: European
review by Conor McMahon Thu 27th Oct 2016
Curiosity is the folly of man. Those pesky humans tread where they do not belong, steal what isn't theirs, and dig into dark realms beyond their imagining. Their greed is a plague, and there's only one cure – giant smashy blocks! Tired of people raiding your elaborate tomb in search of treasure? Don't get mad; get even, with Defend Your Crypt from Ratalaika Games.
Stepping into the mouldy bandages of a long-dead Egyptian Pharaoh, this fast paced puzzle title has you utilising all manner of nasty deathtraps to protect your final resting place from nosy intruders. Retro visuals and a straightforward set of options make it a quick and simple title to get to grips with easily, and of course a helpful mummy is on standby to introduce how the game works with a series of brief tutorials.
Your goal is to stop an oncoming swarm of grave robbers from reaching the stash of treasure in the deepest depths of your tomb, by activating traps to put a bloody end to their excursion. The catch is that you don't actually place the traps yourself. Instead, they're already set up and you simply have to designate which ones to activate and when. At the start of each level you're given a set number of skulls, which act as a kind of currency you use to unlock different traps in any order you like. Larger, bloodier traps cost more than smaller pitfalls, but most of the challenge comes from the fact that you need to manually trigger each and every one of them at just the right time. In earlier levels this is quite easy to deal with, as adventurers and archaeologists come in ones and twos, but much larger groups later arrive with different attributes, and you'll need to weed out the faster, stronger explorers lest they cause some serious damage.
Killing enemies earns you more skulls, which can be used to purchase more ways to fight back in each level, but without any upgrade or progression system the game relies solely on different types of traps to keep things fresh. Thankfully there's a pretty decent selection of deathly devices to choose from, ranging from floor spikes and hidden wall arrows to large crushers that can eliminate groups of thieves in one messy splatter. There are even special chambers for particularly gruesome and lengthy traps, such as a room that slowly fills with water and cuts off that pathway for a time.
Each level takes place in a different crypt, which start off relatively small but eventually end up spanning across multiple screens that you toggle between when needed, adding to the chaos as you're overrun by intruders. They aren't randomly generated either, as each level follows a set pattern which can be memorised and taken advantage of to get the best results. There are 30 in total, and you're ranked on your performance in each one depending on how many enemies make it to the end. While the difficulty gradually increases along the main campaign, earning top marks in a level will help unlock a much harder mode that sends out tougher, faster enemies in different patterns. This helps encourage going for that one perfect run in order to get the highest rating, where no mistakes are made and all face the wrath of a grumpy Pharaoh.
After being activated traps need time to recharge, so there's an added element of planning and time management when choosing which ones to unlock and picking the perfect moment to set them off. Whenever a thief successfully makes it to the end, they pinch one of your three treasures, and once they're all gone it's game over and a walk of shame back to the afterlife.To avoid this from happening, you'll need to think less like this is a tower defense game, and more like a puzzle title based on repetition and mastering the system at hand. It's simple, sure, but it's pretty satisfying to completely clear the house and survive a wave of enemies unscathed.
Everything takes place on the Wii U GamePad, which is the only controller you can use due to the implementation of touchscreen controls. Tapping a trap sets it off, tapping locked traps will spend skulls to unlock them for future use, and everything feels pretty intuitive. The only really baffling decision was deciding to leave the TV screen displaying a fairly useless secondary view of the dig site above ground, but your eyes will be glued to the GamePad regardless. It's worth mentioning that the game is also available on the 3DS eShop, and given that we feel it's best played in shorter sessions, perhaps that's the version to go for. There aren't really any major differences between the two, so it's a matter of preference.
The visuals are peppered with charming touches and a surprising amount of blood, all rendered in a perfectly pixelated style that keeps dozens of enemies in check with a smooth framerate. Characters will exhibit fear and shock through goofy emoticons, while crisp lines of separation keep even the busiest crypts from feeling overcrowded or cramped. The music certainly isn't anything too special, and there are a few spelling errors to be found in the tutorial, but it's a solid package overall that nails the Egyptian aesthetic. Again, the visuals work particularly well on 3DS in this case, as it's easy to keep an eye on both screens at once.
We felt as though we excavated every last bit of fun out of the game after about 3 hours or so, which isn't too shabby given the low price. Keep in mind that there isn't any real variation in gameplay beyond what you learn in the first few minutes, so all the enjoyment comes from improving your timing and focusing on enemy patterns to succeed. There aren't dramatic bosses are any kind of gripping story to be had here - it's all just repetition of an admittedly solid system. If you're looking to kill time with something straightforward, this is an excellent choice, and an optional difficulty level with some built-in achievements helps to flesh out the content for those who want an extra challenge.
Although we're certainly in the company of undead kings, Defend Your Crypt doesn't have grand ambitions. Instead it aims to deliver a solid puzzle title with a unique twist on the tried and tested 'tower-defense' formula. The Egyptian setting alone is something you don't often see from the perspective of an undead Pharaoh, so while the gameplay is slightly repetitious there's still enough here to justify giving it a shot. We'd steer slightly towards the 3DS version due to it suiting shorter-form gameplay sessions more, but either option is a safe bet if you're looking for a neat puzzler to try out for a few hours. Rise from your grave....and defend it!
Good 7/10
Review copy provided by Ratalaika Games
THENAMESNORM
Thu 27th Oct 2016
Sounds good, might give this a try!
2 Spooky
Looks like a diamond in the rough!
SLIGEACH_EIRE
I'll buy this eventually. I'm sorry it didn't score higher but it's not bad. The visuals remind me of my youth. 3 hours though, that's not very long at all.
SH007ME
..thanks for the tales from the crypt..
..it sounds like a real Crypt KEEPER!!...
!!HaPpY HaLLoWeEn!!
Jamotello
a solid seven, meaning it's not a steaming pile of crypt then. anyways... BREAKING!!! nintendo of america twitter announce special switch event on january 12.
@SH007ME even after years of practice, i still can't manage to laugh like him.
OneArmedGiant
@Jamotel
Sounds like we'll be finding out what games to buy in March. Can't wait.🤗
Big_Ounce
Is it weird that the main picture reminded me of Eddie (Iron Maiden's mascot) from the Powerslave album?
Ratalaika Games is preparing a free update for Defend Your Crypt. It contains new content, 20 new stages, German screentext, and a number of improvements.
Also, the spelling will be fixed in the new version.
Awesome, the game goes on sale today in the UK and I was planning on grabbing it for my 3DS. Thanks for the review.
Fri 28th Oct 2016
@SKTTR That's awesome news dude, how did you find out about this?
I finished the game last night (hour or two of gameplay). I really enjoyed it. It's a shame you can't place traps where you want. They've got the foundations for a really cool tower defense here. Hopefully they do more
@Moon I just asked Ratalaika. Blasting Agent is also getting an update, confirmed on Miiverse. That's another Ratalaika gem that's on sale right now. Don't skip!
@SKTTR Thanks for the heads up, I'll look into it
DarkEdi
Sat 29th Oct 2016
@SKTTR I will download both in this week sale.
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Wii U eShop Release Date:
21st Jul 2016 (UK/EU), £2.69
21st Jul 2016 (USA), $2.99
Buy on Nintendo eShop
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text:
Watch Dogs Legion and Rainbow Six Quarantine Delayed, Ubisoft Confirms [Updated]
It's not a great news day today, is it? First The Last of Us 2 gets delayed, and now Watch Dogs Legion and the new Rainbow Six game. What the hell am I going to play next year now?! Other things, I suppose.
Watch Dogs Legion and Rainbow Six Quarantine have both been delayed into the next fiscal year, meaning they will release after April 2020. The original release date for Watch Dogs Legion – one of my favourite games at E3 2019, no less – was supposed to release on March 3rd, 2020. Rainbox Six Quarantine didn't have a release date, though it was expected to release sometime in early 2020. The new open-world RPG by Ubisoft, Gods & Monsters has also been put in the firing line, with it, too, being delayed to the next fiscal year. However, as that game is geared more towards children, the backlash online won't be as harsh. But then Rainbow Six and Watch Dogs fans… That could be another story.
[Update: During the investor relations conference call, Guillemont stated that Watch Dogs Legion and Gods & Monsters will be released during the second half of 2020.]
Ubisoft president Yves Guillemot said in an investor-relations statement that "while each of these games already has a strong identity and high potential, we want our teams to have more development time to ensure that their respective innovations are perfectly implemented so as to deliver optimal experiences for players."
Fair enough, I suppose. The rest of the statement paints a bleak picture for Ubisoft, too, and could be why the publisher is pushing games back and giving developer more time. The Division 2 and Ghost Recon Breakpoint have both seen disappointing revenue, with the latter being nothing short of catastrophic; the reviews were not kind at all, and the fact that the game is full of microtransactions hasn't helped, either. Even Yves Guillemot admitted that Breakpoint "has been strongly rejected by a significant portion of the community."
Source: Ubisoft
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text:
in History, Lists
10 Historical Facts You'll Have Trouble Believing Are True
by Surbhi Jain Mar 28, 2021, 11:47 pm Comments Off on 10 Historical Facts You'll Have Trouble Believing Are True
History has always fascinatingly revealed itself and it never falls short of surprising us. It is full of unbelievable and unexpected events that are sometimes hard for us to digest. These events were treated as normal in those times, but now, they sound completely unacceptable. Following is a list of 10 historical facts and events that are so unique that reading them will leave you amazed
1. During a drought in 1915, the city of San Diego hired a "rainmaker" named Charles Hatfield, who assured the people that he would make it rain using a special chemical concoction for a fee of $10,000. Days later, the city experienced one of the worst floods in recorded history.
Charles Hatfield. Image credits: New Orleans Public Radio/Sandiego.gov
Before the event took place, Charles had already gained popularity because of his rain-making technique with which he apparently used to produce rain. He developed it in 1902 by using a secret mixture of 23 chemicals in a large galvanized evaporating tank.
The year 1915 was very dry for the people of San Diego, so the Improvement Club forced the San Diego council to invite Charles to solve the problem of drought. The primary demand was that the Morena Dam reservoir was to be filled by the rain produced.
Hatfield, with his brother, built a tower beside Lake Morena, and the reservoir was indeed filled with water when Charles released his secret 23-chemical mixture into the air from the tower and attracted clouds resulting in rain.
But that event later resulted, on 5 January 1916, in heavy rain that flooded the town and overflowed into the riverbeds. The heavy rain didn't stop for at least a month and destroyed everything from homes to farms and caused 20 casualties.
While acknowledging his causing the rain to the press on 4 February, Charles denied that he was responsible for the damage and passed it down to the locals saying, "They didn't take the adequate precautions."
The council decided not to pay Hatfield until he accepted his liability for damages, which was $3.5 million. Hatfield tried to settle the issue with $4,000 and sued the council.
The case was not settled until 1938 because Charles continued the suit, but ultimately two courts came to the conclusion that the rain was the act of God, which also meant that Charles was not guilty of anything but was also not going to be paid. (1, 2)
2. During the period of The Great Depression of 1930, the infamous gangster, Al Capone, offered three meals a day to 2,200 unemployed people in Chicago every day. The soup kitchen where he fed the people had a sign that said, "Free soup coffee and doughnuts for the unemployed."
Al Capone. Image credits: FBI.Gov, U.S. National Archives and Records Administration/Wikimedia
Can someone expect such kind and philanthropic work in the face of one of the most financially critical situations by a gangster? Capone was the gangster who was responsible for the 1929 St. Valentine's Day Massacre when he assassinated seven rivals.
In the early period of November, approximately 75,000 men lined up for the registration, one-third of which needed immediate relief.
When the program was carried out, the organizers of the feast were unknown, but a week later, the Chicago Tribune found out that it was none other than Al Capone.
One of Capone's associates later mentioned to the Chicago newspaper that it was really difficult for Capone to stand up and see so many people starving, while nobody seemed to be doing anything about it, so he decided to take some steps himself. Even the women working in the soup kitchen were happy to serve.
The costs of the meals were not paid out from Al Capone's own pocket. He exhorted and bribed businesses to donate goods for the kitchen.
He gained massive popularity among the commoners, but his crimes didn't restore his public good, and his destiny was to be sentenced to prison. (source)
3. Dying from laughter is actually a recorded cause of death, and one such instance happened in 1975 when Alex Mitchell laughed for 25 minutes from hearing a Goodies T.V. Show's joke and died because of heart failure.
Alex Mitchell. Image credits: SWNS.com/Dailymail.com
Many people have died because of laughter from the ancient Greek period to modern times. Alex Mitchell is one such case; he died from laughing continuously at a joke on an "Ecky-Thump" episode on The Goodies Show for 25 minutes straight. The reason for the death is said to be heart failure. Alex's death was all over the headlines in 1975
Alex's wife, Nessie, later thanked the stars on the show for making his husband's last 30 minutes so enjoyable.
Doctors have concluded that it's a cardiovascular problem that is hereditary in nature based on the facts that Alex's grandfather had a near-fatal cardinal arrest, and Alex's daughter, Lisa, also dealt with an internal cardiac defibrillator and showed similar symptoms. (1, 2)
4. There was a time in the 18th century when reading was considered a disease. Novels became famous, and youth spent more and more time reading. As a consequence of this too- much-reading trend, society got concerned and went on to call excessive reading "reading rage," "reading fever," "reading mania," and "reading lust."
Image credits: Jean-Honoré Fragonard/Wikimedia
People were enraged and spoke out loud about the threats of reading too much in the media. They considered this to be a disease, an addictive one and named it in different terms. This was not a concern of a country or a two in the 18th century; the reports of an outbreak of the "reading epidemic" were widespread over entire Europe.
People supposed that certain behaviors are consequences of too much reading such as sensation-seeking, becoming morally dissolute, and promiscuous behavior. It does not end here; the behavior of self-destruction was also considered to be associated with reading novels.
One such novel which was blamed for increased suicides and suicidal attempts was The Sorrows of Young Werther, which was written by Goethe. (source)
5. An American 63-year-old school teacher, Annie Edson Taylor, was the first person who survived a trip over Niagara Falls in a barrel. Her motivations were financially driven, and she made some money speaking about her experience, but her manager stole her barrel, and she had to use up her entire savings on hiring private detectives to find the barrel.
Anne's husband died in the Civil War and she settled in Michigan in 1898. While reading a random article in a newspaper on the Pan-American Exposition in Buffalo in 1901, she realized the growing popularity of the waterfalls situated on the Canadian-New York border.
For the sake of some fame and cash, Anne decided to take up the high-risk task of going through Niagara Falls in a barrel.
The making of a customized barrel took a considerable amount of time, and one of the reasons for that was that nobody wanted to be a part of a potential suicide attempt. After a few months, the barrel was ready and was made up of oak and iron and was also padded with a mattress.
A couple of days before doing the stunt, Anne sent a domestic cat in that barrel to Horseshoe Falls to test the barrel's strength. The cat was injured but still survived.
Finally, on Anne's 63rd birthday, 24 October 1901, she carried out the stunt with her friends. She was rescued by the rescuing team successfully after 20 minutes, and Anne was found alive with minor injuries on her head.
Anne later earned a decent amount of money speaking about her experience but was never able to make huge riches. Her manager, Frank M. Russell, stole her precious barrel and ran away. She spent all of her savings in hiring private detectives to find the barrel, which she did find in Chicago, but it soon disappeared again sometime later again and this time permanently. (1, 2)
Also read: 10 Historical Events That Sound Too Strange to Be True
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Only taxes can close aviation's carbon gap
An Australian commercial aircraft prepares to land in the haze at Sydney's International Airport July 15, 2014.
LONDON (Reuters Breakingviews) - Aviation's dreams of a green future rest on second-hand cooking oil and wishful thinking. By 2050, the industry wants to halve net CO2 emissions from 2005 levels even though traffic is set to treble. It's hard to see electric planes or jet fuel made from plants or kitchen grease flying to the rescue. Instead, governments may have to squash demand by imposing carbon taxes.
Unlike carmakers, which can switch to zero-carbon batteries, or power stations that can run on wind, nuclear or solar, airlines are stuck with fossil fuels. Basically, nothing matches jet fuel in pound-for-pound punch. Nor are there signs of that changing much by mid-century.
In 2017, airlines produced 850 million tonnes of CO2, just 2.3% of humanity's total. But rapid expansion of routes, mainly in Asia, means emissions are on course for 2.7 billion tonnes annually by 2050, the International Civil Aviation Organization estimates. That's 8 times the industry's mid-century target of a net 325 million tonnes.
Various things can reduce that 2.7 billion tonnes figure. The ICAO assumes fuel-efficient engines will cut 700 million tonnes a year by 2050. More direct routes and letting planes cruise at higher altitudes should remove another 200 million tonnes, and carbon off-sets like tree-planting another 200 million. To hit their mid-century environmental goal, airlines must therefore find another 1.3 billion tonnes of collective CO2 savings – in itself over 50% more than the 850 million tonnes pumped into the atmosphere in 2017, when airlines collectively burnt nearly 2.5 billion barrels of jet fuel.
Replacing that amount of jet fuel – 3.8 billion barrels - with biofuels looks a stretch. Jatropha, an easy-to-grow plant seen as a promising source of oil, yields perhaps 10 barrels of jet fuel per hectare. Switching entirely to jatropha would thus mean ploughing up 375 million hectares, more than a third of the United States.
That points instead to a demand-led drive to cut the appetite for air travel. A study commissioned for the European Commission last year estimated that 10% on ticket prices – considerably more than the 1.5 euros per flight outlined this month by France - leads to an 11% demand drop while having minimal impact on economic growth. Europe could start by enforcing its 0.33 euro per litre duty on jet fuel. Convincing others to follow might be easier than growing all those plants.


text:
Q: Rake test not working in Rails app I'm trying to run Minitests in my rails library app, when I run rake test, I get an error saying LoadError: cannot load such file -- rake/testtask.
Here is my rakefile:
require "bundler"
Bundler.setup

require 'rake/testtask'

desc 'Test the library.'
Rake::TestTask.new(:test) do |t|
  t.libs << 'lib' << 'test'
  t.pattern = 'test/**/*_test.rb'
  t.verbose = true
end

Below is my gemfile:
source 'https://rubygems.org'

gemspec

gem 'minitest'
gem 'htmlentities'
gem 'aws-s3'
gem 'byebug', platforms: :mri
gem 'rake'

A: Rake is not being loaded. Add gem 'rake' to your Gemfile


The application, submitted by Anthony Gioffre III of the White Plains-based law firm Cuddy & Feder, is for property at 108 S. Main St.
Tales both humorous and poignant were heard at the Westfair Communications Family-Owned Business Awards that honored more than 20 businesses from Westchester and Fairfield counties.
The Barchella family has been in the landscape business for decades, Wendy Barchella said in a court filing.
The Mid-Hudson economic development council recommends the state fund Westchester projects that includes waterfront revitalizations in Port Chester and Sleepy Hollow.
Edmond DeLaurentis Jr. said, "We're bringing it back to a Class A building."
Torrco plumbing supply leases 19,900 SF at 21 Grace Church St.
Torrco will be relocating its existing 3,000 square-foot location at 407 N. Main Street to 21 Grace Church St. in a 10-year lease.
A $450 million redevelopment plan for the abandoned hospital site has been on hold for the past year as Starwood Capital Group seeks a buyer for the property. The village said it's been told a deal is close.
AmeriPath sued former employees Drs. Paul Chu and Mark Jacobson in federal court to prevent them from opening a practice in Hawthorne.
Leigh Taylor Mickelson, executive director of the Clay Art Center, said that in each of the past two years, earned revenue has increased 15 percent.
The Port Chester restaurant marks the chain's first location in New York. In Connecticut, it has spots in Stamford, Milford, Norwalk and Fairfield.
The trolley service will run on Friday and Saturday nights from 6 to 10 p.m. The village hopes it will allow people to utilize more of its outer parking lots.
Municipalities recognized by the state program are eligible for up to $250,000 toward energy efficiency, renewable energy and sustainable development projects.
The restaurant offers coal-fired pizza and a range of beer and cocktails.
The week of events, starting Tuesday, will help the village gather community feedback to guide the rezoning of its downtown.


text:
namespace Azure.Management.Compute.Models
{
    /// <summary> The reason for restriction. </summary>
    public enum ResourceSkuRestrictionsReasonCode
    {
        /// <summary> QuotaId. </summary>
        QuotaId,
        /// <summary> NotAvailableForSubscription. </summary>
        NotAvailableForSubscription
    }
}


Often overlooked in the enthusiasm around smart cities and next generation transit, however, are the needs of suburban and rural communities. Although data from the U.S. Department of Agriculture shows that the nonmetro poverty rate is only about 3 percent higher than metro poverty rate, the gap increases dramatically when filtering out large metro areas. In actuality, nearly 66 percent of the country's poor population lives outside of major metro areas. Rural communities also have a much higher rate of concentrated poverty, which tracks counties in which more than a fifth of the population is poor—31 percent rate of concentrated poverty compared to 19 percent for cities. Suburban poverty has also risen in recent years, with suburbs accounting for 48 percent of the increase in the national poverty rate from 2000 to 2015.


You may find yourself at some point in your life considering filing a lawsuit if you or a loved one has been injured. You may also find yourself the recipient of such a case. The following are 10 personal injury questions that people often ask and answers for each of them. 1. What is a personal injury case? Injury cases usually involve some type of accident or medical claim. When you or a group of individuals have been hurt in some way you may seek compensation by bringing about a legal case against the person or institution that caused the harm….


Wreck It Ralph opened in theaters this past Friday, and over the weekend it hit #1!!! Did you get to see it??
Ben Sr, the boys and I got to see it, and WOW!! I honestly thought I wouldn't like it. I am not really into playing arcade games.
I loved the movie!! There were so many references to things I knew, and subtle references that made all of the adults laugh and laugh.
Ralph is tired of being the bad guy. He wants some respect, and he figures the only way to get it would be to get a medal. He decides to game jump so he can get one. What Ralph doesn't realize is that by going "Turbo" he is endangering himself and his game!!
There are a ton of funny scenes and my all time favorite was when you see the guards and they are chanting "Or-e-o" Making fun of the guards in the Wizard of Oz!!
This is a terrific movie that I highly recommend seeing!!!
From Walt Disney Animation Studios and Emmy®-winning director Rich Moore comes "Wreck-It Ralph," a hilarious, arcade-game-hopping adventure. For decades, Ralph (voice of John C. Reilly) has been overshadowed by Fix-It Felix, Jr. (voice of Jack McBrayer), the good-guy star of their game who always gets to save the day. Tired of playing the role of a bad guy, Ralph takes matters into his own massive hands and sets off on a journey across the arcade through multiple generations of video games to prove he's got what it takes to be a hero.
On his quest, Ralph meets tough-as-nails Sergeant Calhoun (voice of Jane Lynch) from the first-person action game Hero's Duty, and feisty misfit Vanellope von Schweetz (voice of Sarah Silverman) from the candy-coated cart-racing game Sugar Rush, who may just be his first real friend. But everything changes when a deadly enemy is unleashed, threatening the entire arcade and Vanellope herself. Ralph finally gets his chance to save the day—but can he do it in time? "Wreck-It Ralph" crashes onto the big screen on November 2, 2012, in Disney Digital 3D™ in select theaters.
· Jack McBrayer is an Emmy® nominee for portraying Kenneth Parcell on "30 Rock." His other animated film voice credits include "Despicable Me." He appeared in "Forgetting Sarah Marshall" and "Talladega Nights: The Ballad of Ricky Bobby," among other films. He can be seen in "The Campaign" for Warner Bros. and "The To-Do List" for CBS Films.
· "Wreck-It Ralph" features cameos from both classic and modern real-life games. Lending their voices, among others, are Roger Craig Smith (Ezio from franchise "Assassin's Creed") as Sonic the Hedgehog, and from "Street Fighter"—Reuben Langdon ("Street Fighter") as Ken, Kyle Hebert ("Street Fighter") as Ryu, and Gerald Rivers ("Street Fighter") as M. Bison.
· Director Rich Moore has won critical acclaim for directing episodes of such cutting edge animated television series as "The Simpsons," "Futurama" and "Drawn Together." He won the directing Emmy® Award in the category of Outstanding Animated Program for "Roswell That Ends Well." He also received an Annie Award for that same episode of "Futurama." He is an alumnus of CalArts.
"Wreck-It Ralph" takes moviegoers on a hilarious, arcade-game-hopping journey in which Ralph (voice of John C. Reilly)—tired of being overshadowed by Fix-It Felix, Jr. (voice of Jack McBrayer), the "good guy" star of their game—sets off on a quest to prove he's got what it takes to be a hero. Also featuring the voices of Jane Lynch and Sarah Silverman, "Wreck-It Ralph" is in theaters Nov. 2, 2012, in Disney Digital 3D™ in select theaters.
On his quest, Ralph meets tough-as-nails Sergeant Calhoun (voice of Jane Lynch) from the first-person action game Hero's Duty, and feisty misfit Vanellope von Schweetz (voice of Sarah Silverman) from the candy-coated cart-racing game Sugar Rush, who may just be his first real friend. But everything changes when a deadly enemy is unleashed, threatening the entire arcade and Vanellope herself. Ralph finally gets his chance to save the day—but can he do it in time? Rated PG by the MPAA, "Wreck-It Ralph" crashes onto the big screen on November 2, 2012, in Disney Digital 3D™ in select theaters. For more information, visit Disney.com/wreck-it-ralph, like us onFacebook: facebook.com/WreckItRalph and follow us on Twitter: twitter.com/disneyanimation.


This visit to Crete I organized myself to visit some of the areas known for their Spring Flowers. A key interest was to search for the several different Wild Orchids.
to hunt for wild flowers of the Island.


Click on play button to listen high quality(320 Kbps) mp3 of "Bomfunk MC's FREESTYLER (METAL cover by BATTLEDRAGON)". This audio song duration is 4:22 minutes. This song is sing by Bomfunk MC's FREESTYLER (METAL cover by BATTLEDRAGON). You can download Bomfunk MC's FREESTYLER (METAL cover by BATTLEDRAGON) high quality audio by clicking on "Download Mp3" button.