Exam Answers on EU Law - Free Essay Example

Sample details Pages: 12 Words: 3592 Downloads: 9 Date added: 2017/06/26 Category Law Essay Type Narrative essay Did you like this example? (a)The UK Parliament wishes to challenge the draft Directive on the basis that it infringes the principle of subsidiarity. The UK Parliament has a system of scrutiny committees that are responsible to review the proposal established by the EU Commission. In the given scenario, the draft Directive touches on the area of à ¢Ã¢â€š ¬Ã‹Å"Research, Technological Development and Spaceà ¢Ã¢â€š ¬Ã¢â€ž ¢. Don’t waste time! Our writers will create an original "Exam Answers on EU Law" essay for you Create order According to Article 4 of Lisbon Treaty, the EU and Member States have shared competence in this field, but paragraph 3 further stipulates that the exercise of the EUà ¢Ã¢â€š ¬Ã¢â€ž ¢s competence in this field does not limit the competence of the Member States. Therefore, the scrutiny committees may issue a reasoned opinion on the basis that the draft Directive has infringed the principle of subsidiarity set out in Article 5(3) of the Lisbon Treaty of European Union. According to Article 6 of Protocol 2, the UK committees must issue the reasoned opinion that oppose the draft Directive within eight weeks from the date of transmission.[1] Here, the draft Directive was established on 15 December 2012 and thus the deadline for the UK Parliament to issue the reasoned opinion will be 9 February 2013. It must be noted that, if at least one third of the national parliaments have given the reasoned opinion, it is considered as a à ¢Ã¢â€š ¬Ã‹Å"yellow cardà ¢Ã¢â€š ¬Ã¢â€ž ¢ and the Comm ission can be required to review the draft Directive. However, in case of more than a simple majority, this is an orange card and this allows the European Parliament and the Council to reject the draft Directive before the first reading.[2] (b)The German Association of University Professors and Lecturers (hereinafter referred to as à ¢Ã¢â€š ¬Ã‹Å"the associationà ¢Ã¢â€š ¬Ã¢â€ž ¢) wishes to challenge the regulation, in order for it to be declared invalid. There are two ways available: a direct action under Article 263 of the Treaty on the Functioning of the European Union (hereinafter referred to as à ¢Ã¢â€š ¬Ã‹Å"TFEUà ¢Ã¢â€š ¬Ã¢â€ž ¢); or an indirect action under Article 267 of TFEU. Direct Action under Article 263 In order to strike down the directive successfully under Article 263,[3] there are three procedural requirements: there is a legal act, the action is raised within the prescribed limit of two months and the applicant must have sufficient legal standing to init iate the action.[4] By virtue of Article 288 of the TFEU, a directive is a à ¢Ã¢â€š ¬Ã‹Å"legal actà ¢Ã¢â€š ¬Ã¢â€ž ¢ that fulfil the Article 263 requirement. We are told that the directive was adopted on 1 July 2013 and thus the latest date for the association to bring the action is 1 September 2013. Further, the association is a non-privileged applicant who has no automatic standing and thus it is necessary for the association to satisfy that the adopted Directive is of both the direct and individual concern to them.[5] Nevertheless, as shown in the Salamander case, it may be extremely difficult for a non-privileged applicant to prove that a directive is of direct concern to him.[6] According to Plaumann, it is likely that the directive casts no individual concern to the association as they cannot be differentiated from the other researchers.[7] Thus, the action under Article 263 looks unlikely materialise to the association. Indirect Action under Article 267 Alternativel y, under Article 267, the association may have to be a party to an action in a national court and the court would have discretion as to whether or not to make a reference on this issue to the CJEU. According to Rau v BALM, the facts that the association has no standing under Article 263 would not affect their ability in bring an Article 267 action.[8] But it is still not advisable for the association to bring an action under Article 267 as it has been pointed out by Advocate General Jacobs in UnioÃÆ'Å’Ã ¢Ã¢â€š ¬Ã¢â€ž ¢n de PequenÃÆ'ŒÆ’os Agricultores that it is wrong to expect someone to à ¢Ã¢â€š ¬Ã‹Å"breach the law in order to gain access to justiceà ¢Ã¢â€š ¬Ã¢â€ž ¢.[9] (c)Professor Moltisanti wishes to bring an action against Italian government for its failure to implement the directive. There are two actions available to him: the doctrine of direct effect; or the Francovich principle. The Doctrine of Direct Effect According to the leading case of V an Gen den Loos, in order for directive to give rise to direct effects, certain criteria has to be satisfied.[10] First of all, as shown in Ratti, the court held that the applicant is only allowed to rely on a directive that the deadline for implementation has been expired.[11] On the facts, the grant scheme runs from July 2014, this indicates that the deadline for transposition (1 November 2013) has already expired and thus Professor Moltisanti may be able to rely on the directive directly in the court. Next, in Marshall v Southampton SW Hampshire AHA, it was held that a directive could be invoked vertically against a public body.[12] In the other words, Professor Moltisanti can rely on the directive vertically against the Italian government. Francovich Principle On the other hand, an alternative way that available for Professor Moltisanti is the principle established in the Francovich case that a right to damages against the member states is available to individuals if t hey have suffered loss as a result of the member stateà ¢Ã¢â€š ¬Ã¢â€ž ¢s failure to implement a directive.[13] This principle is further developed Factortame, where the court laid down the criteria in replying the Francovich principle that there must be a sufficiently serious breach and direct causal link can be established between the breach and the loss suffered by the individual.[14] Applying this to the facts, the failure to implement the directive is automatically a sufficiently serious breach within the SchoÃÆ'ŒË† ppenstedt[15] formula and it is clearly that the Italian governmentà ¢Ã¢â€š ¬Ã¢â€ž ¢s failure to implement the directive makes Professor Moltisanti lost the opportunity to gain support under the scheme. Therefore, it is likely that he may seek redress under the Francovich principle. Introduction The statement suggests that the principle of supremacy of EU law is merely a myth originated from the Court of Justice case law, where in fact th e national courts have constantly challenged on this concept. In this essay, we will deal with the principle of supremacy of EU law from both the Court of Justice and national courtsà ¢Ã¢â€š ¬Ã¢â€ž ¢ perspectives and argue that the given statement is correct in the context that the supremacy principle enunciated by the Court of Justice is itself fictional and its application in the national courts is not absolute. The Principle of Supremacy of EU law from the Court of Justiceà ¢Ã¢â€š ¬Ã¢â€ž ¢s Perspective When a State joins the European Union, it is considered that there will be a transfer of sovereignty for certain specific areas of policy from the state to the community. Nevertheless, the community treaty does not contain specific reference in the relationship between the EU law and national law and this leads to a situation where both law are in conflict. Not surprisingly, the Court of Justice (hereinafter referred to as à ¢Ã¢â€š ¬Ã‹Å"CJEUà ¢Ã¢â€š ¬Ã¢â€ž ¢, previo usly known as the à ¢Ã¢â€š ¬Ã‹Å"European Court of Justiceà ¢Ã¢â€š ¬Ã¢â€ž ¢, à ¢Ã¢â€š ¬Ã‹Å"ECJà ¢Ã¢â€š ¬Ã¢â€ž ¢) is on the view that the EU law must prevail in such conflict. The court took its first step in preserving the uniformity of application of EU law among the Member States in the landmark case of Van Gend en Loos.[16] The stance was affirmed in Costa v ENEL, where the ECJ held that the community has à ¢Ã¢â€š ¬Ã‹Å"created its own legal system which became an integral part of the legal systems of the Member States and which their courts are bound to applyà ¢Ã¢â€š ¬Ã¢â€ž ¢.[17] The ECJ further added force to the supremacy principle in the Simmenthal case, where it held that the national courts must set aside the national law if it is in conflict with the community law.[18] At this point, it can be argued that the supremacy principle established by the CJEU is à ¢Ã¢â€š ¬Ã‹Å"fictionalà ¢Ã¢â€š ¬Ã¢â€ž ¢ as it merely requires a disapplication of national law. In Factortam e, the ECJ made clear that if there is a dispute between the national law and the community law, the national courts must set aside its national law, instead on striking down the provision as ultra vires.[19] Furthermore, the supremacy principle from the CJEUà ¢Ã¢â€š ¬Ã¢â€ž ¢s perspective is not absolute and this was shown in the Asda Stores case in which the ECJ had forfeited the EU supremacy and applied the conflicting national law. [20] On the other hand, because of the wide variation of the constitutional background between the member states, the national courts have responded differently in interpreting the supremacy principle into their own legal system. The Principle of Supremacy of EU law from the National Courtsà ¢Ã¢â€š ¬Ã¢â€ž ¢ Perspectives There are mainly two approaches to the incorporation of EU law by the national courts, namely monist or dualist approaches. Monistic Theory In monist States, such as Belgium and France, all law is treated equally, it is not necessary for an international law to be implemented into national law and the national courts can apply the law Dualistic Theory For states with a dualist system, such as Germany and United Kingdom, international law and national law are considered to be fundamentally distinct. This means that international law cannot be directly applied by the national courts but requires the translation into the national law. As to give a clearer analysis, we will deal with the legal system of the member states separately: Belgium Belgium provides a good example of acceptance of the supremacy of EU law based upon reasoning which is closest to that employed by the ECJ itself.[21] Even though there has no provision in the Belgian Constitution that supports the supremacy of EU law, the Belgian Court demonstrated its willingness to accord the supremacy principle in Le Ski case. In this case, it was held that if there is a conflict between the Belgian Constitution and a provision u nder EU treaty that imposes direct effect in the national legal system, the EU law prevails.[22] Is the Supremacy of EU law over national law a fantasy of the Court of Justice with reference to the Belgian courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s perspective? It is submitted that Belgium manages the supremacy principle of EU law with relatively ease. Can this be argued that as an evidence of the supremacy principle? Bribosa commented on this issue that the approach taken by the court was actually a consideration of Kompetenz-Kompetenz (competence-competence) doctrine but rather than the ruling of ECJ.[23] In other words, instead of treating that the EU law is superior to the Belgian law, it may be more appropriate to recognise that the Belgian courts has sought to emerge the new community rule with its established domestic legal framework. France In France, the courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s willingness to accord the supremacy of EU law was shown in the Administration des Douanes case[24], wh ere it was held that by virtue of Article 55 of the French Constitution, if there is a conflict between national law and a ratified international treaty, the latter should be give precedence over the former.[25] This approach was only affirmed in Nicolo case[26] where the court suggested that Article 55 enables the courts to review the validity of French legislation with the EU provisions and thus the community law should be given precedence over the national law. Is the Supremacy of EU law over national law a fantasy of the Court of Justice with reference to the French courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s perspective? Even though the French courts have recognised the supremacy of EU treaty, it is arguable that the supremacy of EU law in the context of French jurisdiction is not absolute. The Constitutional Council had made it clear in the reasoned Decision given on 9 April 1992 Maastricht I[27] that France could derogate its sovereignty to the Union, only if the particular community rule is not contradictory to the French Constitution and will not violate the exercise of national sovereignty.[28] Such reasoning can be regarded as putting a limitation to Franceà ¢Ã¢â€š ¬Ã¢â€ž ¢s acceptance of supremacy and thus it may casts ambiguity on the supremacy principle that derived from the CJEUà ¢Ã¢â€š ¬Ã¢â€ž ¢s ruling. Germany In Germany, the EU supremacy principle is shaped with the terms of Article 23 of the German Basic Law. In Internationale Handelsgesellschaft mbH v EVGF (Solange I), the Federal Constitutional Court held that although Article 23 allowed the transfer of legislative power to EU law, the German Constitution would still take priority over the EU treaty if the community has not removed the possible conflict of norms between EU law and the fundamental rights provision under the German Constitution.[29] However, having considered the development of fundamental rights doctrine by the ECJ, the position has been altered in the case of Re Wuensche Handel sgesellschaft (Solange II), where it held stated that the court would no longer review EU provision in light of the German Constitution.[30] Is the Supremacy of EU law over national law a fantasy of the Court of Justice with reference to the German courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s perspective? By observing the change of attitude of Federal Constitutional Court in adopting the supremacy principle, it is likely that the ECJà ¢Ã¢â€š ¬Ã¢â€ž ¢s wish that the EU law should prevail over national law may be fulfilled. However, in has been made clear in Brunner v European Union Treaty the supremacy of EU law within German jurisdiction is not unconditional, the EU law will be applied only because the national law says it does. [31] Therefore, it may not be appropriate to say that the EU law is supreme over German domestic law because the German courts have not surrendered Germany sovereignty but merely fulfil the obligations of EU membership.[32] United Kingdom The situation becomes more complicated in the UK jurisdiction because of its doctrine of Parliamentary Sovereignty. As a dualist states, the EU treaty will only have effect in the UK legal system with the incorporation of UK Act. This led to the publication of the European Communities Act 1972 (hereinafter referred to as à ¢Ã¢â€š ¬Ã‹Å"ECA 1972à ¢Ã¢â€š ¬Ã¢â€ž ¢), whereby it incorporates the EU provisions into the English legal system. In R v Secretary of State for Transport, ex parte Factortame, Lord Bridge stated that it had à ¢Ã¢â€š ¬Ã‹Å"always been clear that it was the duty of a United Kingdom court when delivering final judgment, to override any rule of national law found to be in conflict with any directly enforceable rule of Community lawà ¢Ã¢â€š ¬Ã¢â€ž ¢.[33] Nevertheless, it must be noted that, the effect of this case would not actually nullify the existing UK legislation and this indicates that the UK national law is still superior to the EU law. Is the Supremacy of EU law over national law a fantasy of the Court of Justice with reference to the British courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s perspective? It is arguable that the EU law does not take precedence over the UK law since the community legislation may only be effective within the UK legal system with the incorporation of ECA 1972. Such approach has been adopted by Lord Justice Laws in the case of Thoburn v Sunderland City Council, where he pointed out that the relationship between the UK and the EU depends on UK law, not EU law. [34] Conclusion According to Maduro, à ¢Ã¢â€š ¬Ã‹Å"the acceptance of the supremacy of EU rules over national constitutional rules has not been unconditionalà ¢Ã¢â€š ¬Ã¢â€ž ¢.[35] It is apparent from the discussion above, despite the distinction between monistic and dualist system, the application of EU law under the national legal framework is ultimately influenced by the national law. Therefore, it might be true that the supremacy principle is a fantasy of the CJEU. However, notwithsta nding talk of any legal fiction, it can be observed from the case law that the national courts do give effect to supremacy of EU law. The fact that EU law has been consistently and uniformly applied in the member statesà ¢Ã¢â€š ¬Ã¢â€ž ¢ courts today creates no real dispute over the application of supremacy principle in practice. Question: Word length: (2) 1129 (4) 1999 TOTAL 3128 Bibliography Tables of cases EU Cases Aktien-Zuckerfabrik SchoÃÆ'ŒË† ppenstedt v Council (5/71) [1971] ECR 975 Amministrazione delle Finanze dello Stato v Simmenthal (106/77) [1978] ECR 629 Brasserie du PeÃÆ'Å’Ã ¢Ã¢â€š ¬Ã… ¡cheur/Factortame III (C-46/93 48/93) [1996] ECR I-1029 Consorzio del Prosciutto di Parma and Another v Asda Stores Ltd and Another (C-108/01) [2003] ECR I-5121 Costa v ENEL (6/64) [1964] ECR 585 Francovich v Italy Republic (6/90) [1991] ECR I-5357 Marshall v Southampton and South West Hampshire AHA (271/91) [1993] ECR I-4367 Ministero Pubblico v Ratti (148/78) [1979] ECR 1629 P UnioÃÆ'Å’Ã ¢Ã¢â€š ¬Ã¢â€ž ¢n de PequenÃÆ'ŒÆ’os Agricultores v Council (C-50/00) [2002] ECR I-6677 Plaumann Co v Commission (25/62) [1963] ECR 95 Rau v Bundesanstalt fuÃÆ'ŒË† r Landswirtschaftliche Marktordnung (C-133/85) [1987] ECR-2289 Salamander and others v European Parliament and Council (T-172 175-177/98) [2000] ECR II- 2 487 R v Secretary of State for Transport, ex parte Factortame Ltd and Others (C-213/89) [1990] ECR 2433 Van Gend en Loos v Nederlandse Administratie der Belastingen (26/62) [1963] ECR 1 Belgian Case Minister for Economic Affairs v SA Fromagerie Franco-Suisse à ¢Ã¢â€š ¬Ã‹Å"Le Skià ¢Ã¢â€š ¬Ã¢â€ž ¢ [1972] CMLR 330 French Cases Administration des Douanes v SocieÃÆ'Å’Ã ¢Ã¢â€š ¬Ã¢â€ž ¢teÃÆ'Å’Ã ¢Ã¢â€š ¬Ã¢â€ž ¢ CafeÃÆ'Å’Ã ¢Ã¢â€š ¬Ã¢â€ž ¢s Jacques Vabre J. Weigel et Cie. SARL [1975] 2 CMLR 336 Raoul Georges Nicolo and another [1990] 1 CMLR 173 German Cases Brunner v European Union Treaty [1994] 1 CMLR 57 Internationale Handelsgesellschaft mbH v Einfuhr- und Vorratsstelle fÃÆ' ¼r Getreide und Futtermittel [1974] 2 CMLR 540 WÃÆ' ¼nsche handelsgesellschaft,Re [1987] 3 CMLR 225 United Kingdom Cases Thoburn v Sunderland City Council [2003] QB 151 R v Secretary of State for Transport, ex parte Factortame [1991] AC 603 Table of Legislation EU Legislation Consolidated Version of the Treaty on European Union [2008] OJ C115/13, art 4 Consolidated Version of the Treaty on European Union [2008] OJ C115/13, art 5 Consolidated Version of the Treaty on the Functioning of the European Union [2008] OJ C115/47, art 263 Consolidated Version of the Treaty on the Functioning of the European Union [2008] OJ C115/47, art 264 Consolidated Version of the Treaty on the Functioning of the European Union [2008] OJ C115/47, art 267 Consolidated Version of the Treaty on the Functioning of the European Union [2008] OJ C115/47, art 288 Protocol (No.2) on the Application of the Principle of Subsidiarity and Proportionality [2010] OJ C 83/206, Art 6 Protocol (No.2) on the Application of the Principle of Subsidiarity and Proportionality [2010] OJ C 83/206, Art 7 French Legislation Conseil Constitutionnel, decision n.92-308 DC of 9 April 1992, Treaty of Maastricht I French Constitution, art 55 German Legislati on Basic Law, art 24 United Kingdom Legislation European Communities Act 1972 Secondary Sources Books Chalmers D, Davies G and Monti G, European Union Law (3rd edn, Cambridge University Press 2014) Hartley T, European Union Law in a Global Context: Text, Cases and Materials (Cambridge University Press 2004) Articles Benvenisti E and Downs G, à ¢Ã¢â€š ¬Ã‹Å"The Premises, Assumptions, and Implication of Van Gend en Loosà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2014] 25 EJIL 85 Martinoco G, à ¢Ã¢â€š ¬Ã‹Å"Is the European Convention going to be à ¢Ã¢â€š ¬Ã‹Å"supremeà ¢Ã¢â€š ¬Ã¢â€ž ¢? A Comparative-constitutional overview of ECHR and EU law before national courtsà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2010] EJIL 401 Maduro M, à ¢Ã¢â€š ¬Ã‹Å"Interpreting European Law: Judicial Adjudication in a Context of Constitutional Pluralismà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2007]1 EJLS 2 Electronic Sources Craig P, à ¢Ã¢â€š ¬Ã‹Å"The ECJ, National Courts and the Supremacy of Community Lawà ¢Ã¢â€š ¬Ã¢â€ž ¢ https://www.ecln.net/elements/conferences/bookrome/craig.pdf accessed 29 December 2014 1 [1] Protocol (No.2) on the Application of the Principle of Subsidiarity and Proportionality [2010] OJ C 83/206, art 7. [2] Ibid, art 6. [3] Consolidated Version of the Treaty on the Functioning of the European Union [2008] OJ C115/47, art 264. [4] Ibid, art 263. [5] Ibid. [6] Joined Cases T-172 175-177/98 Salamander and others v European Parliament and Council [2000] ECR II- 2487. [7] Case 25/62 Plaumann Co v Commission [1963] ECR 95. [8] Case C-133/85 Rau v Bundesanstalt fuÃÆ'ŒË† r Landswirtschaftliche Marktordnung [1987] ECR-2289. [9] Case C-50/00 P UnioÃÆ'Å’Ã ¢Ã¢â€š ¬Ã¢â€ž ¢n de PequenÃÆ'ŒÆ’os Agricultores v Council [2002] ECR I-6677, Opinion of AG Jacobs, paras. 41-9. [10] Case 26/62 Van Gend en Loos v Nederlandse Administratie der Belastingen [1963] ECR 1. [11] Case 148/78, Ministero Pubblico v Ratti [1979] ECR 1629. [12] Case 271/91, Marshall v Southampton and South West Hampshire AHA [1993] ECR I-4367 . [13] Case 6/90 Francovich v Italy Republic [1991] ECR I-5357. [14] Joined Cases C-46/93 48/93 Brasserie du PeÃÆ'Å’Ã ¢Ã¢â€š ¬Ã… ¡cheur/Factortame III [1996] ECR I-1029. [15] Case 5/71 Aktien-Zuckerfabrik SchoÃÆ'ŒË† ppenstedt v Council [1971] ECR 975. [16] Van Gend en Loos (n 10). [17] Case 6/64 Costa v ENEL [1964] ECR 585, 593. [18] Case 106/77 Amministrazione delle Finanze dello Stato v Simmenthal [1978] ECR 629, 21. [19] Case C-213/89 R v Secretary of State for Transport, ex parte Factortame Ltd and Others [1990] ECR 2433. [20] Case C-108/01 Consorzio del Prosciutto di Parma and Another v Asda Stores Ltd and Another [2003] ECR I-5121. [21] Paul Craig, à ¢Ã¢â€š ¬Ã‹Å"The ECJ, National Courts and the Supremacy of Community Lawà ¢Ã¢â€š ¬Ã¢â€ž ¢ https://www.ecln.net/elements/conferences/bookrome/craig.pdf accessed 29 December 2014. [22] Eyal Benvenisti and George Downs, à ¢Ã¢â€š ¬Ã‹Å"The Premises, Assumptions, and Implication of Van Gend en Loosà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2014] 25 EJIL 85, https://www.ejil.org/pdfs/25/1/2477.pdf accessed 9 January 2014, citing Minister for Economic Affairs v SA Fromagerie Franco-Suisse à ¢Ã¢â€š ¬Ã‹Å"Le Skià ¢Ã¢â€š ¬Ã¢â€ž ¢ [1972] CMLR 330, 347. [23] Paul (n 21), citing H Bribosia, à ¢Ã¢â€š ¬Ã‹Å"Report on Belgiumà ¢Ã¢â€š ¬Ã¢â€ž ¢, in A-M Slaughter, A Stone Sweet and J H H Weiler (eds), The European Court and National Courts, Doctrine and Jurisprudence (Oxford: Hart Publishing 1998) p.21-22. [24] Paul (n 21), citing Administration des Douanes v SocieÃÆ'Å’Ã ¢Ã¢â€š ¬Ã¢â€ž ¢teÃÆ'Å’Ã ¢Ã¢â€š ¬Ã¢â€ž ¢ CafeÃÆ'Å’Ã ¢Ã¢â€š ¬Ã¢â€ž ¢s Jacques Vabre J. Weigel et Cie. SARL [1975] 2 CMLR 336. [25] Paul (n 21). [26] Raoul Georges Nicolo and another [1990] 1 CMLR 173, as translation can be found in https://www.utexas.edu/law/academics/centers/transnational/work_new/french/case.php?id=1440 accessed 9 January 2014. [27]Conseil Constitutionnel, decision n.92-308 DC of 9 A pril 1992, Treaty of Maastricht I, as translation can be found in https://www.utexas.edu/law/academics/centers/transnational/work_new/french/case.php?id=998 accessed 9 January 2014. [28] Giuseppe Martinoco, à ¢Ã¢â€š ¬Ã‹Å"Is the European Convention going to be à ¢Ã¢â€š ¬Ã‹Å"supremeà ¢Ã¢â€š ¬Ã¢â€ž ¢? A Comparative-constitutional overview of ECHR and EU law before national courtsà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2010] EJIL 401. [29] Internationale Handelsgesellschaft mbH v Einfuhr- und Vorratsstelle fÃÆ' ¼r Getreide und Futtermittel [1974] 2 CMLR 540, as translation can be found in https://www.utexas.edu/law/academics/centers/transnational/work_new/german/case.php?id=588 assessed 9 January 2014. [30] Re WÃÆ' ¼nsche handelsgesellschaft [1987] 3 CMLR 225, 265, as translation can be found in https://www.utexas.edu/law/academics/centers/transnational/work_new/german/case.php?id=572 assessed 9 January 2014. [31] Brunner v European Union Treaty [1994] 1 CMLR 57, as translation c an be found in https://www.ecln.net/documents/Decisions-Germany/summary-maastricht.pdf assessed 9 January 2014 [32] Trevor Hartley, European Union Law in a Global Context: Text, Cases and Materials (Cambridge University Press 2004) 159. [33] [1991] AC 603 (HL) 658. [34] [2003] QB 151, 69. [35] Miguel Maduro, à ¢Ã¢â€š ¬Ã‹Å"Interpreting European Law: Judicial Adjudication in a Context of Constitutional Pluralismà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2007]1 EJLS 2.

Midterm Review - 1485 Words

Interactive Management Science MSamp;E 107/207, Midterm Review The Flaw of the Averages Mindle 1 / Uncertainty vs. Risk * Risk is in the eye of the beholder * Risk reflects how uncertain outcomes cause loss or injury to a particular individual or group * Risk attitude measures the willigness to incur risk in the quest of reward * Different risks to the same uncertainty Mindle 2 / An uncertain number is a shape * A distribution * â€Å"Uncertain numbers† * Risk is subjective * Give-me-a-number mentality * Management of uncertainty: â€Å"Commitment to trade short-term rewards for long-term gains† * Flat Shape * To display a distribution: a histogram * Other important shape: cumulative†¦show more content†¦Because squared units are not intuitive, we square root the variance, known as the standard deviation. Diversification and Variance Reduction When uncertain numbers are averaged together, the distribution of the average goes up in the middle and down on the ends, becoming more centralized. This centralizing of the distribution is the primary manifestation of diversification. The width or narrowness of a distribution defines the range of uncertainty of the number. The wider the distribution, the greater the variance, standard deviation and uncertainty. The Central Limit Theorem â€Å"If enough independent samples of almost any distribution are averaged together, then the resulting distribution will be normal†. The Normal Distribution The normal distribution is an idealization of the result of averaging a large number of identical, independent random variables. They are centered at their mean or average. Their width is measured by the standard deviation, or the square root of the variance. Chapter 3 One of the worst things that you can do: â€Å"Using point estimates, single points * Gen_Resample / pg. 61 * Gen_Triang / pg.61 How to use freeze amp; thaw, when you send a document with XLSim Average overall cost is not the cost associated with average demand * Worksheet models based on uncertain numbers: Functions of randomShow MoreRelatedMidterm Review Essay963 Words   |  4 Pages†¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ †¢ MComm100†©Ã¢â‚¬â€œÃ¢â‚¬ ©Mass†©Communication†©in†©Society†© Midterm†©Review†©Ã¢â‚¬â€œÃ¢â‚¬ ©12th†©Ed†© (Chapters†©1†©Ã¢â‚¬â€œÃ¢â‚¬ ©9)†© †© Understand†©the†©definition†©of†©Ã¢â‚¬Ëœencoding’†© What†©is†©Ã¢â‚¬Ëœnegative†©feedback’?†© Characteristics†©of†©a†©mass†©communication†©audience†© What†©is†©a†©Ã¢â‚¬Ëœmedia†©vehicle’?†© Characteristics†©of†©mass†©communication†©organizations†© What†©vehicles†©have†©increased†©the†©mobility†©of†©the†©mass†©mediaRead MoreMidterm Review2002 Words   |  9 Pagesï » ¿The Federal Circuit Court of Appeal has appellate jurisdiction over the U.S. Claims Court. True Which of the following terms best describes the decision reached by an arbitrator? 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Mother India free essay sample

Reaction Paper 1: Mother India Mother India is a 1957 Bollywood film, written and directed by Mehmoob Khan. The movie was made 10 years after India obtained its independence from the British. The movie had major significance in terms of the patriotism and the changing situation in the nation at the time, and how the country was functioning without British authority. The term Mother India has been defined as a common icon for the emergent Indian nation in the early 20th century in both colonialist and nationalist discourse. The theme of female chastity and honour appears to be an extremely intriguing and engaging topic explored in the film. Lonely Planet described the film as perhaps the most compelling film about the role of women in rural India, a moving tale about love, loss and the maternal bond. In the 1950s, in India, a woman was expected to protect her chastity, especially prior to her marriage. We will write a custom essay sample on Mother India or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Mother India illustrates how, the protagonist, Radha â€Å"stayed true† to this even after her marriage. The sequence set in the bedroom after Radha and her groom, Shamu just got married portray how valuable chastity is to an Indian woman. Her shyness is portrayed in a series of close-ups and medium shots of her turning her head away from Shamu as her tries to get intimate with her. This act of moving away or turning away from an intimate situation suggests a sense of purity in a woman, that she is not accustomed to situations like this and that it is new to her and in a sense depicts her to be a virgin, to both her husband and the viewers. Furthermore, the use of front lighting in the sequence amplifies Radha’s innocence through the soft, direct lighting on her face. Moreover, Radha’s character is continued to be represented as introverted during intimate circumstances with her husband, even after their first marriage night and after she bore children. This is exhibited in the sequence where Shamu tries to get intimate with Radha at home, while his mother is around and also the scene when he tries to get intimate with her in the fields when she goes to give him his lunch. This gives rise to the fact that it is not just crucial to protect your chastity but rather your honour, especially in the public eye. These type of sequence consistently appears throughout the film, not only between Radha and her husband but also between their sons, Birju and Ramu, and their lovers when they grow older and into men. In Mother India, the honour of a woman goes beyond the life of a woman’s child. This is exhibited through the sacrifice of her youngest toddler, where he dies of starvation because the only way she could have provided for all her children was by complying to the moneylender’s, Sukhilala sexual demands. Her honour and loyalty towards her husband are so great that she is forced to lose a child. Toward the end of the movie, her son, Birju wants to assault/kill Sukhilala’s daughter, Champa, to take his revenge out on Sukhilala. However, Radha feels obligated as a woman to protect another woman’s honour and stops Birju from doing so. And when Birju retaliates, she is left with no choice but to shoot her own son. This just goes to show how much a woman’s honour is valued in an Indian society. Radha’s actions were unexpected to all audiences, but specifically to the audiences at the time of the movie’s release because a â€Å"Hindu† mother’s role atypically consisted on protecting her children and relying on her husband for money, food and all other necessities. In conclusion, it is important to note that the character of Radha in Mother India also represents the changing role of the mother in Indian films and in Indian society in that the mother is not always submissive or dependent on her husband. Mehboob Khan’s portrayal of the themes chastity and honour in Mother India goes beyond representing an atypical Indian woman of the time because he takes these two respectable characteristics of a woman and draws them out in such a way that this conventional portrayal of a woman is almost modernized.

Accompanying Report for Oxfam Marketing Plan

Question: Discuss about the Accompanying Report for Oxfam Marketing Plan. Answer: Introduction: I can capture a wider market and reach out to more people, which is important to increase awareness of people about the poverty and injustice levels existing in the society today. The new product would give people an idea about how the organization is attempting to connect every human being on this planet and their cultures too. Oxfam has significantly contributed in a diverse range of social and environmental issues, having peoples wellbeing at their heart. The arrival or benefit is sent back to people without taking even one penny from it (Winston and Weinstein 2016). The whole launching procedure would take place over a time period, after which measurable results would be accomplished. The holes in the organizations previous marketing activities would be covered with the help of this marketing plan, which would also assist in increasing the companys competitive edge in the market and reach out to a wider audience and open new doors. An understanding of the product is the first thi ng that is required to decide upon the course. Objectives would be set accordingly, after which understanding the industry environment would be carried out with the help of the environmental analysis. After understanding the entire situation a proper strategy would be formed for marketing the new product (Finch 2016). Oxfam Shop, subsidiary of Oxfam Australia, is a multi-channel retail organization that has its own e-commerce website, direct mailing program and retail stores (Oxfam Australia 2017). Oxfam shop mainly retails in food and handicrafts that they have sourced from individual workers, crafts agencies and fair-trade organizations. The idea behind doing so is to help these communities as much as possible in their struggle towards ensuring a better life for themselves and their labor force(Oxfam Shop 2017). Oxfam Shop, Australia has planned to launch a new product from one of their producer Wakami. Kiejde losBosques, a social projectwho are known for marketing their produce from the rural communities of Guatemala, developed this Wakami brand.The literal meaning of Wakami is it already is in Mayan. Wakami believes that the world we live in is already an ideal place and it only needs connection with humans to make it alive. Wakami artisans aim to link people with products in a way that the people who buy and produce these products experience an enrichedand improved life respectively.Wakami employs rural Guatemalan women to help them live their common dream and have sources of income for improving their community lives. One of their very current products is the beads bracelets. These poly threaded, silver plated brass beaded bracelets have Zamac (zinc, aluminium, magnesium and copper) metal charms included in them. The bright and bold neon threaded bracelets stand for peace, within oneself and in others. The bracelets are hand made using ancestral Guatemala artisan techniques(Wakami 2017). Oxfam has come into establishment with the belief that poverty is inexcusable and preventable and it must be challenged so that the poor people get access to the right help and lead a better life. Along with that, Oxfams mission has been to present customers with the handcrafted artwork they are known for and provide the deprived with a helping hand to move ahead in life. Oxfam aims to exist to appeal to and maintain the customer base. They have made it a point to always adhere to this maxim and they believe the rest would fall into place. They have made it their objective to keep on exceeding the expectations of their customers with continued service(Oxfam Shop 2017).To bring the major objectives in point, the major ones are: To produce visibility within the charitable non-profit retail community Increasing the volume of repeat clients A growth rate in the double digit for the next five years Decreasing the cost of marketing in relation to the sales generated Decreasing the variable costs in every three months Expand to more regions in terms of stores and products Contribute as much as possible for the development of the deprived group Environmental Analysis For the last five years, the retail industry conditions of Australia suffered and struggled a lot. The major factors that led to the weak economic growth and volatile consumer sentiment are the unstable financial markets, which in turn resulted in a struggle for the retail subdivision operators.From 2012 to 2016, the annual growth rate has been just 0.2%. Study estimates say that the industry is expected to increase the contributionby a compound annual rate of 1.0%, a slow growth if compared to the overall economy (IBISWorld2016). In terms of the current prices in 2016, the clothing and accessories industry of Australia experienced a trend estimate growth of 0.2% in the month of November(Australian Bureau of Statistics 2017).The industry is inclining towards small and medium enterprises, leaving the giants to compete for survival. Oxfam Shop would use this market data to properly understand the requirements of the market and how to serve the customers(Philips 2014). Competitor analysis is a crucial part of the formation of business strategies or new product launching. It plays a crucial role in educating organizations about how intense the competition they would be encountering, what are the competition strategies to help marketers predict possible consequences (Hollensen 2015). In the retail market of Australia Oxfam Shops would face competition from Myer Fashion Store and David Jones who are giants in the fashion and accessories department. Along with that,there are specialty stores like Just Group, Country Road, Retail Holdings and Noni B (Lewricket al. 2015). In the lines of e-commerce competitors, Amazon, Hive and eBay give tough competition to Oxfam. Customer Profile Brief Oxfam shops target market includes people who are highly interested in using handcrafted things. The organization would be targeting people from all over the world, from all regions and religions.The art collectors and enthusiasts would be the primary targets, as they are the people who have the most interest in such products, and most of the time they have the capacity to spend also. Other than that, there are people who want to do something genuinely to stop all the injustices and reduce poverty in the society (Kusnanto and Utami 2016). Oxfam is for them too. Oxfam shop has always aimed to tackle poverty by taking a hands-on approach in their strategies. Oxfam has repeatedly combined their experience of helping people in situations of emergencies and innovative campaigning so that a bold approach can be put towards reduction of poverty, hunger and inequality (Seret, Verbraken and Baesens 2014). Opportunities and Strengths STRENGTHS 1. An organization with plainly characterized objectives and qualities that can be the purchaser inspiration towards the brand 2. Worldwide system of members and supporters giving excellent brand believability 3. Enhanced portfolio taking into account key essential needs of customers 4. Great online position with sensible costs contrasted with contenders OPPORTUNITIES 1. More hooked onpublicity 2. Built as a brand from retail shop standpoint 3. Influence upon its center values and discuss the same with extended audience Table 1. Strengths and Opportunities of Oxfam Shop Segmentation As a marketing strategy, segmentation comprises of segregating the organizations extended target market into industries, nations and client segments that share common interests, priorities and requirements (Baker 2014). Oxfam marketing strategies have always been organized in groups that have separate KPIs and goals. Oxfam has done segmentation in accordance with its supporters. The supporter's sorts incorporate single supplier, shop present aider, customary provider, campaigner, and shop buys. Furthermore, full scale segmentation in Oxfam is the association's bespoke way of life alongside socioeconomics, that is, including color and profundity, one segment one supporter, in view of the supporter and not Oxfam produce and connected to the whole supporter database (Armstrong et al. 2014). Targeting Targeting implies making a social affair or things an objective to be followed up on (Cameron 2014). Right when a firm fathoms its objective promote, correspondence gets the opportunity to be unmistakably easier among the firm and the target crowd. Oxfam altruistic association target showcase incorporates the people living in poor conditions and requires help from each religions, locales, range, and so on around the globe. The association's target showcase likewise targets on people living foul play particularly young ladies and ladies. Positioning Positioning alludes to a showcasing procedure that spotlights on making a brand have the unmistakable position about the fighting brands and customers mind (Grant 2016). The properties that get credited by the customers fuse its standing quality, the kind of people using the things, the quality and weakness close by any fundamental or unprecedented characteristics spoke to, the cost and addressed regard (Urde and Koch 2014). Oxfam key positioning depends on what the firm do, offer and what characterizes Oxfam. The firm fundamental goal is to help the needy individuals, and that treated with shameful acts. The firm offers foundations to the needy individuals and helps the individuals who are dealt with bad form to battle for their rights. Since Oxfam alludes to a brand that speaks to philanthropy administrations, it is imperative for the organization to keep up and enhance its esteem. Oxfam offers philanthropy to the destitute individuals and answers for individuals who are treated with unfairness. The firm likewise offers distinctive products that additionally add to the gifts. As an altruistic association, the administrations and products are allowed to the objective market. It is a reasonable methodology for the casualties; notwithstanding, it doesn't manage quality-driven clients and does not rival neither high nor low price base in their products of gift. Subsequently, Oxfam can utilize value pricing methodology that contains setting prices on the products as per the client impression of the product esteem. Oxfam is among the main beneficent association promoters in the philanthropist NGO industry. It promotes its exercises and products utilizing daily papers, TV and magazines. The association has an awesome gathering of people in the social stages, yet there is less marketing effort on their online networking stages. Thusly, Oxfam ought to upgrade its marketing effort in the online networking, and Oxfam ought to post their products pictures on the web-based social networking system, for example, in Facebook as coordinated by Kaufmann (2012). Oxfam conveys its services and products all through the world. The firm finds the destitution and unfairness people and helps them in their area. The members get situated in the groups regularly with neediness issues so they can undoubtedly get to the influenced people. It is fundamental that the organization ought to consider expanding their office in different nations to enhance their entrance to the destitute individuals (Kaufmann 2012). Conclusion Oxfam is a magnanimous association that spotlights on enhancing the lives of individuals and helps the individuals who are treated with unfairness. This marketing arrangement has basically helped in comprehending Oxfam's present circumstance where the firm appreciates worldwide supporters and offshoots however it confronts volunteers and workers. Marketing arranging helps create products and administrations in the business that address the issues of the objective market. Great marketing helps the clients comprehend why the item or administration is superior to, or not the same as, the opposition. Subsequently, this marketing arrangement target is to amplify global foundations and increment tickets deals. As per the prerequisite of Oxfam Shop which requests an imaginative, functional and fun item for their outlets; in this way,a quirky and bright range of accessories have been suggested which is very popular among the art enthusiasts. A decent marketing plan would help Oxfam achieve t heir intended interest group, support their client base, and eventually, increment their main concern. References Armstrong, G., Adam, S., Denize, S. and Kotler, P., 2014.Principles of marketing. Pearson Australia. Australian Bureau of Statistics, 2017. 8501.0 - Retail Trade, Australia, Nov 2016. [online] Abs.gov.au. Available at: https://www.abs.gov.au/ausstats/abs@.nsf/Latestproducts/8501.0Main%20Features3Nov%202016?opendocumenttabname=Summaryprodno=8501.0issue=Nov%202016num=view= Baker, M.J., 2014.Marketing strategy and management. Palgrave Macmillan. Cameron, B.T., 2014. Using Responsive Evaluation in Strategic Management.Strategic Leadership Review,4(2), pp.22-27. Finch, B., 2016.How to write a business plan. Kogan Page Publishers. Grant, R.M., 2016.Contemporary strategy analysis: Text and cases edition. John Wiley Sons. Hollensen, S., 2015.Marketing management: A relationship approach. Pearson Education. IBISWorld. 2016. Consumer Goods Retail in Australia Market Research | IBISWorld. [online] Available at: https://www.ibisworld.com.au/industry/consumer-goods-retail.html Kaufmann, H.R. ed., 2012.Customer-Centric Marketing Strategies: Tools for Building Organizational Performance: Tools for Building Organizational Performance. IGI Global. Kusnanto, N.A. and Utami, C.W., 2016. Innovation Strategy Design for CV. X's Handicraft Business at the Local Market. Lewrick, M., Williams, R., Maktoba, O., Tjandra, N. and Lee, Z.C., 2015. Radical and incremental innovation effectiveness in relation to market orientation in the retail industry: triggers, drivers, and supporters.Successful Technological Integration for Competitve Advantage in Retail Settings, IGI Global, pp.239-268. Oxfam Australia, 2017. The Power of People Against Poverty. [online] Oxfam Australia. Available at: https://www.oxfam.org.au/?utm_source=Shoputm_medium=webutm_campaign=topnav Philips, C., 2014. A Silver Lining to Australia's Fashion Crisis?. [online] The Business of Fashion. Available at: https://www.businessoffashion.com/articles/global-currents/silver-lining-australias-fashion-crisis Seret, A., Verbraken, T. and Baesens, B., 2014. A new knowledge-based constrained clustering approach: Theory and application in direct marketing.Applied Soft Computing,24, pp.316-327. Urde, M. and Koch, C., 2014. Market and brand-oriented schools of positioning.Journal of Product Brand Management,23(7), pp.478-490. Wakami, 2017. Wakami. [online] Shop.oxfam.org.au. Available at: https://shop.oxfam.org.au/wakami/ Winston, W. and Weinstein, A., 2016.Defining your market: winning strategies for high-tech, industrial, and service firms. Routledge.

Calvinism And Religious Wars Essays - Calvinism, Calvin And Hobbes

Calvinism And Religious Wars This book is about pretty much the beginning of Calvinism and how it played a major role in the reforming of mid to late fifteenth century Europe. Franklin Charles Palm tries to exam the role in which John Calvin used his love for the sacred scriptures and religion to reform the way he lived, and the rest of the world. Concentrating mostly on Europe at that time period. Palm breaks down the life of Calvin at first, and then as he proceeds through this book he leads up to actual formation of the religion. And ultimately then how this newly formed religion affected or may off even caused some of the religious war. I unfortunately could not find any info on Franklin Charles Palm, though I even had one the librarians look for me to. I feel that Franklin Charles Palm was really not trying to answer any certain question while he was attempting to write this informative novel at all. In fact I think that his true purpose for writing this was to give an accurate account of what role Calvinism played in that time period, because from what I can understand he did not feel that there was enough information readily available. His work in my own opinion is very relevant to the study of history, and he has added another great resource to the reference area for history in any library. I feel that his work does not offer any resonably new information for students to learn, but it may present an easier way of learning for those who are tired of reading the same old reference books. This book does though coincide with most of the notes that we have taken during class periods. This helps out greatly when writing papers and reviews for essays and reports. Palm starts the novel out by explaining the early the early life of John Calvin and explains his life with his family. It talks about his father Gerad Calvin and his working as the secretary for the bishop of Nylon and as the fiscal agent for his district in England. It states how this made it possible for Calvin to meet some very influential people in his early life and made it possible for him to start to develop ideas about religion and other political views early on in life. When Calvin was at the age of entering college it made it hard for him to do so with the death of his father, and his mother having to support six children in the family. His father was able to set aside some money before he passed on for Calvin which in turn allowed him to attend the College at Montiaigu, at Paris for four years. This is where John developed a love for the bible and a tremendous understanding for the scriptures, which would in turn play a major role in his ideas for changing and for his reforming of the Catholic Church. After discussing Calvin's early life Palm went on to talk about the Roman Catholic Church and how they developed a keen sense of hated for Calvin. It stated what they were going to do with his writings and how they were going to go about dealing with him. Which evidently lead to Calvin's exile from the country. Some of Calvin's works, cited the problems that pretty much most of the reformers saw wrong with the church. Such as, the sale of indulgences which Luther and Erasmus displayed ever so prominently in their attempts for reform. Gradually the book moves on to the more important issues of the book. Certain things like the Religious wars. Also it talks about things like his oppositions and the struggles he faced with Greut, Servetus, and his triumph over all of them. It shows the certain economic importance this new religion played in France at the time and the political and intellectual importance of the new religion of Calvinism. When the religious wars broke out in France and Francis the 1st proclaimed his development of absolutism it shows how Calvinism was one of the major elements opposed to it. Once that Calvinism was starting to take hold it displayed the spread of it throughout most of Eastern Europe. Like when it started in Italy and Spain, and began to work its way through Western Germany. Once the religion hit those sections it began its spread throughout the vast regions of Western Europe too. Last but not least it explains The Spread

schooling should not be compulsory

I believe that schooling should not be compulsory. Making school education voluntary would actually educate people who want to learn in a better manner, increase high school safety, and be less of a detriment to our rights. First of all, making a child goto school for about six hours a day, 180 days a year, for about ten years, is a violation of his or her liberties. Keep in mind that the child has to attend until the legal age (16 in many states), whether or not the child learns anything or could learn it faster or better somewhere else. The government says it has a "compelling interest" in the education of children. This might be true, but that doesnt give them the right to make it compulsory. If something like public schooling was compulsory for adults, there would be public uproar. While parents do have alternatives to government run schools, such as private schools and homeschooling, these alternatives are implausible for most parents. In any case, the parent really doesnt get to decide whether to send their child to school, they just get to decide which government approved schooling method to send their kids to. This goes back to one principle given the chance, governments think noth! ing of telling parents how to raise their children. Forced attendance also has the effect of letting children who do not want to be in school disrupt those who do. Children vary widely. It is not fair for both people who want to be in school and people who dont. Overall, this has had a negative impact on both the education given by schools and the safety of the schools. When compulsory attendance laws were first instituted, there was no objection that such laws would endanger the safety and even the lives of teachers and of students who wanted to be in school. Things have changed. Forcing a person who does not want to learn to be present in school anyway may do little for the student, as evidenced by the fact that many...

Management Functions Case Study Example | Topics and Well Written Essays - 1500 words

Management Functions - Case Study Example Case Study Management functions can be stated as a set of core and most essential elements for various organizations that not only enable them to achieve their desired business goals but also facilitate in building long-term sustainability in the competitive environment. The set of an effective management functions comprises four fundamental elements that include controlling, planning, organizing along with leading (Rutter, 2003). With reference to the major attributes of management functions, this paper intends to present a series of recommendations to Amanda Smith (Amanda) in response to the concerns identified from the case. Brief Overview of the Case Amanda Smith (Amanda) had started a new small sized accounting firm named â€Å"Smith's Accounting and Tax Service† after she got six years of experience through working in a renowned accounting firm. As the intention of Amanda is to conduct own business within the community, she opened her accounting firm by engaging one empl oyee named Lisa. At the starting face of the business, Amanda has developed a mission statement along with a strategy for her business. The mission statement of Smith’s Accounting and Tax Service was to ensure the deliverance of adequate accounting and tax services to the small business owners within community. However, the organization has faced certain challenges due to its inappropriate management and control process. Owing to this context, it has been recognized that lack of planning can be considered as one of the major factors that led the firm to face different concerns related to its accounting services. The ineffective management of operational processes such as maintaining records of the tax returns for such a small accounting firm can also be viewed to generate greater risks. The issue concerning employment layoff has also been witnessed in the case due to certain errors in the accounting work prepared by the employees of the firm. Recommendations to Amanda in Resp onse to the above identified Concerns In relation to the fundamental concept of management, there are basically four functions that ensure to provide adequate support to the organizations in efficiently obtaining their predetermined business targets. In this regard, an effective set of management functions comprise four major and most essential elements such as controlling, planning, organizing along with leading that supports the organizations to sustain in this competitive landscape (Morgeson, DeRue, & Karam, 2010). According to the case scenario, the inappropriate planning of conducting operational procedures along with incorrect setting of organizational goals have eventually contributed in creating problems for Amanda and her firm. In relation to the case of Amanda, inappropriate execution of the organizing functions including personnel management can be duly considered as the major aspect hindering to generate positive outcomes for her company by a certain degree. Moreover, it can be stated that the inadequate organizing process of the firm has further witnessed to prioritize the importance of recruitment, job design and descriptions along with delivering proper training to the staffs. It can also be apparently observed that lack of motivational skills has also negatively impact on the overall performance of Amanda and her firm at large. In this context, the leadership functions of Amanda could focus on making effective decisions which could enable the organization to develop its operational and managerial activities towards the accomplishment of organizational

IT104 Essay Example | Topics and Well Written Essays - 4500 words

IT104 - Essay Example Without successful prioritization of tasks and responsibilities, online courses might turn-out to be a bad experience. Technology makes online classes possible, but they can also be a barrier to success in the online learning environment. One possible technological problem is having a computer that is not capable of delivering the content that the professors have developed for the course. Your computer may be incapable of streaming video, for example, because it is outdated or damaged. If the professor has lots of videos as a part of the coursework, then you will be out of luck due to a slow computer or internet connection. A final barrier to on-line learning is the problem of having a single computer to service multiple learners in the household. This is not an insurmountable obstacle, but it does require a fair amount of foresight and scheduling. Running out to buy additional computers is not in most people’s budgets. By creating a schedule of computer use, just as in a libr ary, everyone can use the computer to get what they need. Exercise 2 I expect this course to give me the skills and information needed for me to improve my teaching. I am currently teaching Aesthetics and have a strong desire to be the best educator possible. I know my subject matter very well, but am concerned that I might not always be using the best teaching techniques. I hope that through the course of this study, I will be able to learn better presentation skills and gain a better understanding of how adults learn best. I realize that teaching children and teaching adults is a very different process. What works for one does not always work for the other. As a result, I am often wondering if the lessons and assignments I am developing are more appropriate for younger learners than the age of student I have. I often have a nagging feeling that there is just more information and knowledge out there that would help me be such a better teacher. The problem is, I only am able to crea te lessons based on my existing teaching experience. I expect this course to broaden my educational understanding so that I will have more confidence in the lessons and assignments I develop. It is my hope that this course will inspire me to alter some of the less effective lessons I currently have developed and to develop new lessons based on my new understanding of how adult learners learn best. In essence, I expect this course to give me the additional skills and information necessary for me to be a more effective and interesting teacher of Aesthetics. My ultimate goal is to have my adult learners transfer their knowledge into their everyday lives. This is true for me in regards to this course as well. Exercise 3 This planner can be a very helpful tool because it helps the adult student returning to the classroom to organize their dreams into concrete plans. It also is very good at helping the student to imagine the far reaching effects of returning to school, gaining an educatio n and possibly changing jobs. Some of the affects might not be as positive as they imagine and I think it is important for adult learners to re-enter school with their eyes wide open. Most adult learners focus on the additional time schooling will take and the economic rewards they will realize with improved education. Rarely do they consider the profound changes

London Underground Limited Management Project Assignment

London Underground Limited Management Project - Assignment Example The London railway network is the oldest underground railway system on earth. It begun as a 6-kilometer stretch between Baker street and Paddington in the 17th century. The role of the 6-kilometer stretch was to avail a small continuous railway service meant to connect to the main overground station, which connected to the London City. The London Underground is also called the Tube or The Underground. This public metro system reaches a big section of the UK including counties such as Buckinghamshire and Essex. It is characterised by 270 stopping stations and more than 400 hundred kilometers of laid tracks on 24 different tracks, 55 percent of the track is on the ground and 45 percent underground. During its the initial formation of underground tunnels, the tunnels were only dug and covered. Later, the circular tunnels were dug and sunk deeper. Initially, to access the underground stations, people employed lifts, but now a day it has been modified and made easy to access. Its initial owners were several private organisations, which later merged to form a London Passenger Transport Board, which has evolved with time. Currently, London Underground Limited manages the railway system. The passengers meet operational costs. Within one year, the company manages to transport billions of passengers. The Transport for London assumed the responsibility of running the transport across the UK`s capital.The railway LUL experiences delays and overcrowding as some of problems to customer`s comfort.

Analysis of Human Resource Models

Analysis of Human Resource Models Analyze and evaluate the characteristics of any three of the following human resource models and list the related features in each of the models. – Contingency model, Best practice model, Harvard Framework, D Guest, M Patterson. (5 marks per model = 15 marks total) Contingency Planning Contingency theory takes societal and settings alteration in individuals and their commercial undertakings as its obvious worth and assumes its standards keeping in its understanding. There are twofold important repercussions to this kind of theory: if there is no single finest way, then even seemingly fairly alike companies, for instance, two close schools, may select considerably different edifices and still endure, and be rationally successful in attaining their tasks, and so on if unlike portions of the similar company are predisposed in different methods by the eventualities residing upon them, then it may be suitable for them to be organized differently, Best Practice Model The best-practice Model supports a universalistic viewpoint – all companies will understand performance progress if they accept it. There are three key essence of best-practice concepts that should be should be stated. First of all, the models improve staff capability and information through decent staffing and teaching. The second point is inspiring desired conduct through durable enticements. Lastly, encouraging concepts and influence from interested and improved employees. The benefits of this kind of model can be seen on its simple best practice. Next is the acknowledgment of â€Å"corrupt† practice. The third benefit is creating guidelines of thumb for choices; training; evaluation approaches. Lastly is that there is no requirement to invest again. Harvard Framework This is the modest and practical way of plotting the labor and resources of men and females in an organization and stressing the major alterations. Gathering and examining facts at the organization and in the area. Gathering baseline information. As a preparation and application of tool for plans and programmes At the problem searching phase of planning, earlier an intervention is planned. To measure the effects a programme may have Identify and describe at least twelve human resource management activities that would be conducted within the ‘simulated’ organization. Induction Management Induction Management aids staffs to experience every stage of atmosphere of organization and a starter to his group and others. It provides them the policy of recognizing and understanding the values and identifying â€Å"Who is who†. It is such a stage which stretches a hint of whole Organization in that little duration. Training Management Training Management denotes to the practice of rendering exercise, workshops, training, mentoring, or other learning occasions to staffs to motivate, contest, and inspire them to achieve the roles of their position to the finest of their skill and within criteria established by state, Compensation and benefits Compensation comprises not only income, but also the internal and external compensations and benefits the staff is given with in return for their input to the company. To decide compensation, companies should make a benefit and rewards project. This type of project summarizes a reasonable procedure for paying staffs. A fine-structured project with a good stability of wages, paybacks and rewards will aid a company to stay and sustain competitive in labor market. Performance Management Performance management is the procedure of generating a work atmosphere or setting in which individuals are permitted to achieve to the finest of their abilities. Attendance Management It is the  means for following and collecting data about how much period a staff  spends on the work setting. Recruitment Management Recruitment is the process of searching and enticing skilled candidates for employment. The procedure starts when new staffs are required and finishes when their applications are passed. The outcome is a pool of submissions from which new workforces are nominated Benefits Management Benefit management comprises generating and executing benefit policies for existing staffs or presenting new policies to job applicants. Most of this benefit schemes are intended to cut charges for the customer while giving the most rate to job applicants. Overtime Management Overtime is the times that staffs work above 40 hours for the duration of week. Overtime is calculated through a whole labor week, not on a everyday basis. Workforce Planning Workforce planning is single one of the most significant subjects that human resources specialists are speaking about today. It’s the way of planning systematically desired number of staffs in an organization. Employee Survey Technique of gaining straight view of workers by giving them a chance to namelessly answer inquiries written in a questionnaire. Exit Interview and Process The formal discussion that takes place among a staff and an HR officer or a director to know the reason(s) the staff is resigning. Employee Skill Management A  collection  of vital  abilities  that comprise the  growth  of an  information base,  proficiency  level and mindset that is progressively essential for achievement  in the up-to-date  workplace. Employability expertise are naturally considered important  credentials  for many  job  positions  and hence have become essential for a  persons  employment  achievement at just about any stage inside the  company’s environment. Select one of the models and describe the impact this model would have on the human resource management activities of the ‘simulated’ organization. The best impact model could be a good model to adapt in a company. This kind of model will provide the human resource department to train staffs for better capabilities. These skills or capabilities would be useful not only for the workers but also for the company as well. It will render efficient work, hence, providing client’s satisfaction. Incentives will also be given to provide encouragement. Opinions and suggestion from employees will be welcome so that improvement of the working environment can be pleasant and peaceful for both parties Define personnel management and human resource management. Personnel Management Managerial discipline of employing and evolving  staffs so that they grow into further valuable essence in the  organization. These comprises implementing job studies,  development of staff  needs, and employment, choosing the exact person for the work, orienting and preparing, shaping and handling earnings and salaries, giving paybacks and incentives,  evaluating  performance, solving disagreements, and communicating with all staffs at all points. Human Resource Management Human Resource Management (HRM) is role inside the company that focuses on employing of, organizing of, and giving direction for the individuals who work in the company. Explain at least three differences between personnel management and human resource management Criteria Personnel HRM 1. Deal Cautious description of written agreements Wish to go afar agreement 2. Policies Significance of planning clear policies Intolerance with the policies 3. Aid to management achievement Methods Company-need Personnel Management tries to uphold fair standings and circumstances of employment, while at the similar time, proficiently managing personnel accomplishments for distinct sections etc. It is expected that the consequences from providing fairness and attaining efficacy in the running of personnel events will upshot eventually in accomplishing company success. Meanwhile, for Human resource management, is directed with the expansion and carrying out of people policies, which are joined with corporate policies, and guarantees that the values, ideals and system of the organization, and the worth, drive and commitment of its associates contribute entirely to the attainment of its objective Bibliography About (2014)  Retrieved from:  http://humanresources.about.com/od/glossaryp/g/perform_mgmt.htm About (2014)  Retrieved from:  http://humanresources.about.com/od/glossaryo/g/overtime.htm Alan Price and HRM Guide Network contributors (2014)  Retrieved from:  http://www.hrmguide.co.uk/introduction_to_hrm/guest-hrm.htm Business Dictionary (2014)  Retrieved from:  http://www.businessdictionary.com/definition/time-and-attendance.html#ixzz3IA3MJkMO Business Dictionary (2014)  Retrieved from:  http://www.businessdictionary.com/definition/employability-skills.html#ixzz3IA91Kh3D Child Welfare (2014)  Retrieved from:  https://www.childwelfare.gov/management/reform/soc/communicate/initiative/soctoolkits/tdhr.cfm#phase=pre-planning Community Foundations in Canada (2014)  Retrieved from:  http://hrcouncil.ca/hr-toolkit/compensation-overview.cfm Entrepreneur Media (2014)  Retrieved from:  http://www.entrepreneur.com/encyclopedia/exit-interview Kannan Personal (2014)  Retrieved from:  http://kannanpersonal.com/learning/management/contingency.html Media Tec Publishing (2014)  Retrieved from:  http://www.workforce.com/articles/why-you-need-workforce-planning Recruiter (2014)  Retrieved from:  https://www.recruiter.com/i/human-resource-benefits-management/ The World Bank Group (2014)  Retrieved from:  http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTSOCIALDEVELOPMENT/EXTTOPPSISOU/0,,contentMDK:20590885~menuPK:1443270~pagePK:64168445~piPK:64168309~theSitePK:1424003,00.html UK Essays (2014)  Retrieved from:  http://www.ukessays.com/essays/management/features-of-best-practice-models-of-hrm-management-essay.php Web finance (2014)  http://www.businessdictionary.com/definition/personnel-management.html What is human resource? (2014)  Retrieved from:  http://www.whatishumanresource.com/hrm-vs-personnel-management Word Press (2014)  Retrieved from:  http://corehr.wordpress.com/recruitment/induction/ Word Press (2014)  Retrieved from:  http://corehr.wordpress.com/recruitment/88-2/

Transformation of Marriage: Essay -- essays research papers

Abstract The marriage revolution has been a controversial issue since the dawn of time, and all that are and have been involved with â€Å"matrimony† are aware of the issues of the future. There can be no denying that the culture of marriage has changed. This very course is itself a great example of this fact. Much like any other sociological subject of any real concern, there are many â€Å"opinions† related to this issue. This paper will attempt to highlight marriage seen as the sociological transformation, marital erosion versus evolution, and why many people fail at marriage and what does it take to be successful in greater detail. This will allow you, the readers, to make up your own minds regarding this extremely multifaceted issue. Marriage seen as the sociological transformation â€Å"Couples today have much higher expectations. Between the 1950s and the 1970s American attitudes toward marriage changed dramatically as part of what has been called the â€Å"psychological revolution†Ã¢â‚¬â€a transformation in the way people look at marriage, parenthood, and their lives in general.† (Skolnick p.171) At first blush, marriage in America seems to have followed a similar course. Once a required rite of passage, seen as a genuine embodiment of shared values, it now serves as a game-show prize on Who Wants to Marry a Multimillionaire or a booby prize on My Big Fat Obnoxious Fiancà © — even though wedding ceremonies have created a "bridal-industrial complex," as Lee professor of economics Claudia Goldin calls the nearly $100-billion-a-year U.S. industry that outpaces even the movie business ($45 billion a year, including sales and rentals). (Hodder, 2004) Motivated by celebrity magazines and wedding planners, couples take on increasing ly elaborate spectacles that take years to plan and cost on average $20,000 to produce. When Love Story first appeared, our society was still extremely absorbed in a marriage culture that encouraged and supported getting and staying married. But inside a few years, the women's movement, the pill, the sexual revolution, and various economic shifts had permanently transformed that marriage-centric society. Marriage is not an endangered species, but it is surrounded by enormous difficulties that were not readily apparent 35 or 40 years ago. Divorce is a very serious presence — over 50 percent of our marriages end in di... ...;what has been will still be." Stay open to newness. Stay open to change.† (Nutt, 1990) References: Catholic Answers Inc. (2004). Special Report: Marriage. Retrieved April 8, 2005 from the World Wide Web: http://www.catholic.com/library Gallagher, Maggie. (2002, July 13). How We Destroy Lasting Love. The Abolition of Marriage. Retrieved April 8, 2005 from the World Wide Web: http://www.leaderu.com/ftissues/ft9608/reviews/gold.html Hodder, Fraser H. (2004, Nov-Dec). The Future of Marriage. Harvard Magazine Volume 107, Number 2, Page 38. Retrieved April 8, 2005 from the World Wide Web: http://www.hmag.harvard.edu/on-line/110491.html Grady Nutt. (July, 1990) Higher Praise. Retrieved April 8, 2005 from the World Wide Web: http://www.praiselyrics.com/illustrations/marriage.htm Ross, Catherine E., Mirowsky, John & Goldsteen Karen. (1990). The Impact of the Family on Health. Journal of Marriage and the Family. Retrieved April 8, 2005 from the World Wide Web: Skolnick, Arlene S. & Skolnick Jerome H. (2005). Family in Transition. Boston: Pearson A&B. Waite, Linda & Gallagher, Maggie. (2001). The Case for Marriage. New York: Doubleday

Police suicide Essay

In the recent past, there have been a number of cases involving police suicide. These have brought alarm to the nation as the same people delegated with the duty of safe guarding life are now turning against their own self. It’s believed that the number of officers who die from suicide in the   US surpass the number of those who die in the line of duty. In most of the cases, the cause of death is not revealed to the people to protect the victim’s family and friends. Abstract This research paper intends to seek the main causes of police officers suicide. It contains a sample of research questions it intends to answer plus their hypothetical responses. It also contains literature on previous findings. In addition it contains the methods used in data analyses as well as the possible out comes of the research. Statement of the problem Basing on the fact that, there figures from the police department showing that their colleagues do commit suicide, its evident that these is a problem that needs to be addressed before this situation runs out of proportion. It’s from this factor of admission that the research paper seeks to identify the possible causes of rise in the rate of police sources. Research question In order to get the relevant information to this research, several questions could be formulated which if answered correctly would provide answers and information to aid in writing this report. These include: †¢ Under what situations do police commit suicide often? †¢ What age group of the police is at a higher risk of committing suicide? †¢ Are there particular periods or events in the police calendar that are followed by high numbers of suicide? †¢ Do police who commit suicide have a mental disturbance history? †¢ Were they alcoholic? †¢ What is the perception of the suicide to the police officers? Hypothesis †¢ Police between the ages of 20 and 30 are at the higher risk of committing suicide. †¢ Both normal and police officers with mental disturbance histories do commit suicide. †¢ Police officers often perceive as the last resort to resolve or run away from challenges or situations they can’t bear. Literature review It has been confirmed that more than 110 police officers have committed suicide during the last year alone with more cases still under investigation, this was an all time high since the recording begun in the 1980s. However the rate of police suicide is still low when compared to people of the American society with similar back ground and educational levels. This can be attributed to the fact that the police have the capacity to provide mental health care to its officers counseling and other support services required. (Krueger,1998) Suicides can be attributed to relationship problems. This may include, pressure from their spouses, be it financial or general relationship problems. If an officer can’t stand this pressure and they obvious fact of the availability of the weapons, chances of committing suicide are high. Suicide can also be attributed to strain relationship between officers and their fellow officers or officers and their seniors. In addition, there are times when the officers get trouble at their places of work. For instance they may be accused of neglecting their duties or services or a performance that does not meet the set out rules and standards. This pressure leads to suicide rather than face the ensuing consequences or disciplinary measures which include termination of services or suspensions. (www.usarmy.gov/suicide, 2008) Police officers faced with regal procedures such as murder cases, corruption cases or negligence of duty cases do commit suicide in the event that they feel they may not win the cases or justice will either be delayed or denied. Moreover, there are financial difficulties that often lead to high rates of suicide among the police officers. Currently in the USA there are several financial obligations that pose a challenge to the police officers in their endeavor to meet them. This includes taxation fees, mortgages and family financial obligations. Officers who find it hard to meet these obligations do commit suicide rather than face the realities of their failures. Another factor that has lead to police suicide is stress and depression. Officers are often time tied in their work leaving no or little time for leisure or recreation. This unavailability of time to refresh leads to clogged minds and chances of suicide are increased. The horrifying and terrifying realities that the police are exposed to can lead to mental disturbances leading to suicide. This includes exposure to suicide scenes, gun murders and horrifying accidents. (www.National P.O.L.I.C.E..org, 2001) Methods of data collection (surveys, focus groups, observations) Surveys Several surveys have been conducted by the police force to ascertain the rate of police suicide. This information are often found at the police records and aided in getting the data required. Human rights groups have also conducted several surveys and have come up with figures showing the numbers, their age groups, marital status as well as the causes of the police officers suicide. Focus groups In addition focus groups can be used to gather relevant information concerning these suicides. They can focus on a particular police county for a period of time keeping records and happenings and durations of suicides. Observations Several eye witness observations can also be relied on to come up with relevant information and figures. The information can be got from immediate family members of the officers involved who are affected by his or her death or who witnessed them committing suicide. Another way of gathering information is by interviewing fellow police officers or their seniors. They may be holding vital information about the circumstances surrounding the officers death or possess information that had been on to the by the officer prior to suicide. Methods of Data analyses Analytical induction method This method will be used to analyze the collected data and come up with comments to be used in the findings. In this method, the event surrounding the officers suicide are studied after which a hypothetical reason on the cause of that is developed. Logical analysis In this process, the cause of an officer’s suicide is determined by an inductive way of reasoning. For example, the cause can be attributed to a factor leading to another. Example, an officer commits murder, legal proceedings are instituted against him, its delayed, he is frustrated and commits suicide. Possible outcomes/ findings There are several factors that can be associated with the increased number of police suicide. Some of them are purely personal while others are a multiplicity of various other factors. Mental problems can be associated to these suicides. Officers who have a mental problem are at high risk of taking their own lives especially so if they suffer from the condition in their line of duty and in the possession of a weapon. Through their unsound mind, they may make unsound decisions to kill themselves. Another factor that would cause an officer to commit suicide is alcoholism and drug use. If an officer is under the influence of alcohol or drugs, it reduces his or her cognitive abilities. With their reduced cognitive ability, they may turn against themselves as a way of actualizing their fantasies at the time which include the urge to kill or cause mayhem. Too much pressure at places of work may lead to suicide. Senior officers may pressure their junior to perform duties at specified period of time or which may pose danger to officers them selves. Such duties such as fighting armed drug cartels or tracking down terrorists and serial killers may lead to suicide among officers to avoid such works or as away of showing their displeasure to their seniors. The US justice system is also to blame for a number of police suicides. Rather than face the possibility of dismissal and the stigma associated with it from such legal proceeding such as murder, corruption or negligence of duty, officers results to taking their own life. In some other cases the regal proceedings may take longer period that expected leaving the officers frustrated and demoralized often leading to suicide.

A Quick Biography of Founding Father Thomas Jefferson

A Quick Biography of Founding Father Thomas Jefferson Jefferson grew up in Virginia and was raised with the orphaned children of his fathers friend, William Randolph. He was educated from ages 9-14 by a clergyman named William Douglas from whom he learned Greek, Latin, and French. He then attended Reverend James Maurys School before attending the College of William and Mary. He studied law with George Wythe, the first American law professor. He was admitted to the bar in 1767. Family Ties: Jefferson was the son of  Colonel Peter Jefferson, a planter and public official, and Jane Randolph. His father died when Thomas was 14.  Together they had six sisters and one brother. On  January 1, 1772 he married  Martha Wayles Skelton. However, she  died after ten years of marriage.  Together they had two daughters: Martha Patsy and Mary Polly. There is also speculation about the progeny of several children by the slave Sally Hemings. Early Career: Jefferson served in the House of Burgesses (1769-74). He argued against Britains actions and was part of the Committee of Correspondence. He was a member of the Continental Congress (1775-6) and then became a member of the Virginia House of Delegates (1776-9). He was the Governor of Va. during part of the Revolutionary War (1779-81).  He was sent to France as a minister after the war (1785-89). Events Leading to the Presidency: President Washington appointed Jefferson to be the first Secretary of State. He clashed with Alexander Hamilton, Secretary of the Treasury, on how the US should deal with France and Britain. Hamilton also desired a stronger federal government than Jefferson. Jefferson eventually resigned because he saw that Washington was more strongly influenced by Hamilton than him. Jefferson later served as Vice President under John Adams from 1797-1801. Nomination and Election of 1800: In 1800, Jefferson was the Republican candidate with Aaron Burr as his Vice President. He ran in a very contentious campaign against John Adams under whom he had served as Vice President. The Federalists used the Alien and Sedition Acts to their benefit. These had been vigorously opposed by Jefferson and Madison who had argued they were unconstitutional (Kentucky and Virginia Resolutions). Jefferson and Burr tied in the electoral vote which set up an electoral controversy described below. Electoral Controversy: Even though it was known that Jefferson was running for President and Burr for Vice President, in the election of 1800, whoever received the most votes would be elected as president. There was no provision that made it clear who was running for which office. Burr refused to concede, and the vote went to the House of Representatives. Each state cast one vote; it took 36 ballots to decide. Jefferson won carrying 10 out of 14 states. This led directly to the passage of the 12th Amendment which corrected this problem. Reelection - 1804: Jefferson was renominated by caucus in 1804 with George Clinton as his Vice President. He ran against Charles Pinckney from South Carolina. During the campaign, Jefferson easily won. The federalists were divided with radical elements leading to the partys downfall. Jefferson received 162 electoral votes vs. Pinckneys 14. Events and Accomplishments of Thomas Jeffersons Presidency: The uneventful transfer of power between Federalist John Adams and Republican Thomas Jefferson was a significant event in American History. Jefferson spent time dealing with the federalist agenda with which he did not agree. He allowed the Alien and Sedition Acts to end without renewal. He had the tax on liquor that caused the Whiskey Rebellion repealed. This reduced government revenue leading Jefferson to cut costs by reducing the military, relying instead on state militias. An important early event during Jeffersons administration was the court case, Marbury v. Madison, which set up the Supreme Courts power to rule federal acts unconstitutional. America engaged in a war with the Barbary States during his time in office (1801-05). The US had been paying tribute to pirates from this area to stop attacks on American ships. When the pirates asked for more money, Jefferson refused leading Tripoli to declare war. This ended in success for the US who was no longer required to pay tribute to Tripoli. However, America did continue to pay to the rest of the Barbary States. In 1803, Jefferson purchased the Louisiana territory from France for $15 million. This is considered the most important act of his administration. He sent Lewis and Clark on their famous expedition to explore the new territory. In 1807, Jefferson ended the foreign slave trade beginning January 1, 1808. He also established the precedent of Executive Privilege as explained above. At the end of his second term, France and Britain were at war, and American trade ships were often targeted. When the British boarded the American frigate, Chesapeake, they forced (impressed) three soldiers to work on their vessel and killed one for treason. Jefferson signed the Embargo Act of 1807 in response. This stopped America from exporting and importing foreign goods. Jefferson thought this would have the effect of hurting the trade in France and Great Britain. However, it had the opposite effect, hurting American trade. Post Presidential Period: Jefferson retired after his second term as president and did not reenter public life again. He spent time at Monticello. He was deeply in debt and in 1815 sold his library to form the Library of Congress and to help get him out of debt. He spent a lot of his time in retirement designing the University of Virginia. He died on the fiftieth anniversary of the Declaration of Independence, July 4, 1826. Ironically, this was the same day as John Adams. Historical Significance: Jeffersons election began the fall of federalism and the Federalist Party. When Jefferson took over the office from Federalist John Adams, the transfer of power occurred in an orderly manner which was an extremely rare event. Jefferson took his role as party leader very seriously. His greatest achievement was the Louisiana Purchase which more than doubled the size of the US. He also established the principle of executive privilege by refusing to testify during the Aaron Burr treason trial.

Western Lowland Gorilla essays

Western Lowland Gorilla essays Humans share more than 98 percent of our DNA with gorillas. Because of our arboreal heritage, primates share assiduous anatomical characteristics, including depth and color vision, opposable thumbs, and fingertip pads as the primary organs of touch (Kottak, 109). Large and complex brains, tool making, living in social groups, and committing time and care in offspring are other similarities between humans and gorillas. The population of the western lowland gorilla has declined rapidly over the past decade. Estimates range between 90,000 and 110,000 individuals, with the population spread across the lowland tropical forests of Central Africa, from Nigeria to the Congo River, but this figure is now thought to be grossly exaggerated (Western Gorilla.org). The largest of all primates, the western lowland gorilla, is usually characterized as having hair that varies from black to grey or brown. Hair covers their entire body except for their face, upper chest, and the soles of their hands and feet. Adult males are silverbacks. All males acquire silver hair on their back and upper thighs when they reach sexual maturity. Adult females usually weigh between 150 to 300 pounds, while adult males weigh 350 to 600 pounds (Animal Fact Sheets). Western lowland gorillas live in structured family groups. A group consists of one silverback male, several unrelated females, ranging from juvenile to adult, and infants. The silverback is in charge of the group. He regulates their schedule. The silverback keeps the peace within the group and stops occasional disputes between females (Columbus Zoo and Aquarium). Gorillas are most active during the day. They spend a considerable amount of time searching for food and eating. They are terrestrial creatures. Adult gorillas tend to be too heavy to be brachiate and be arboreal. Western lowland gorillas can be bipedal for short distances, but generally get around by ...