Tuesday, August 25, 2020

African Americans in Pop Culture Essay

African Americans have had an unbelievable enduring impact on mainstream society. African American artists, specialists, business visionaries, competitors and on-screen characters have all had their state and have truly stood apart inside the previous barely any years. They’ve likewise developed and not developed in various manners all around from music, to TV, to motion pictures. African American generalizations despite everything exist in all parts of mainstream society, while many are attempting to escape from what crowds accept that is the commonplace individual of color. African Americans have been battling for and against their own generalizations when they began breaking out into music, at that point fanning out into TV, and becoming wildly successful in the film business. They’ve gone from being the moronic, uneducated, and oppressed minority of America, and have begun to make themselves progressively known as pack bangers and hooligans, which are frequently observed as saints in mainstream society. African Americans haven’t just became well known or left an impression in just their way of life, however in American culture all around. African Americans have been transforming music all since the beginning. Many began with the jazz and bebop defiance during the 1940s and ’50s in Detroit. They came to their meaningful conclusion by attempting to appear as something else. They didn’t need to follow the commonplace white, swing music standards, and that’s precisely what occurred. Bebop wasn’t so standard, and that’s what made it their own. They favored little, one of a kind combos to play rather than huge named stars in the music business. Detroit was revealing insight into the common laborers individuals of the town and needed to truly make a sound for them. â€Å"The 1940s made a â€Å"afro-modernism,† a reaction to the urbanization, industrialization, and modernization of African American Culture. † Because of their development ahead in music, they additionally made their development in business. Thus developed an extraordinarily effective, dark entrepreneur undertaking, Motown Records, established by Barry Gordy. Alongside the development in Detroit, the Harlem Renaissance had happened even before extremely popular for jazz and bebop, which brought issues to light to the visual expressions, which prompted considerably more improvements in music. What's more, much prior toward the start of the twentieth century, blacks were beginning to be acknowledged into acclaimed schools to consider music and they were permitted to join the base of white individuals in ensemble symphonies. During the ’50s, doo-wop and soul music got well known. That’s when legends like Ray Charles rose and made ready for other people. Soul music stayed well known among blacks for long after the pop sounds began to wave through. Before the decade's over and moving into the ’70s, blacks were beginning to hybrid into the run of the mill white music patterns. Psychadelic music had gotten well known. Jimi Hendrix, along his wah-wah pedal development, got one of the most well known guitarists during the time. Directly from that point forward, soul had become the famous music operating at a profit network and was beginning to change African-American music. Soul had proceeded with accomplishment in fame during the ’70s, however the ’70s additionally brought along an ascent in dark groups. White individuals were tuning in to nation, disco, and a wide range of awesome music, while the African-Americans had their funk, pop, soul, and jazz music that was on an entirely unexpected range from their white partners. The ’70s was additionally when Djs began blending their own beats and playing their funk records how they would have preferred to so they could get their crowd to move. Furthermore, with the beats created by Djs alongside the writers who might peruse their sonnets to those beats, came the rise of hip jump music. The time of hip jump music was another upheaval in African American mainstream society.

Saturday, August 22, 2020

The Speckled Band Essay Example for Free

The Speckled Band Essay Our errand includes doing an exposition on the likenesses and contrasts of three criminologist fiction stories: The Speckled Band, A Scandal In Bohemia and The Dancing Men all composed by the great Arthur Conan Doyle. The class of these specific stories is totally founded on Crime/analyst. Each of the three stories have a similar kind of structure in spite of the fact that the substance are extraordinary. Despite the fact that the substance are unique, the manner in which they are sorted out is comparative since they are investigator stories we ought to anticipate similitudes between them. Notwithstanding the various characters the wrongdoing and activity in every one of the three is comparative. In every one of the three stories there is a similar focal character Sherlock Holmes-the criminologist and his incredible companion Dr John Watson-the primary storyteller. Helen Stoner approaches Sherlock Holmes about the homicide of her sister the prior night she was couple to get hitched. Holmes researches the reason for death. A Scandal In Bohemia The ruler of Bohemia comes to see Holmes about an important photograph, which he needs to get hold of before it ruins his life. The Dancing Men Hilton Cubitt approaches Holmes with an issue; him and his better half are being sent adolescent drawings of moving men. Holmes examines further. The composition in each of the three stories has numerous likenesses and contrasts. There are numerous similitudes I told in the piece of these accounts, one of which was the dates e. g. in The Speckled Band - Early April in the year 83 Scandal In Bohemia-one night-twentieth March, 1888. Despite the fact that the dates are given in two of the narratives, I have understood that in The Dancing Men no particular dates are given. This underlining a distinction in the piece. In every one of the three stories Dr John Watson is the principal (individual) storyteller and Holmes is constantly presented by him. For instance in The Speckled Band-In looking over my notes over the seventy odd cases in which I have during the most recent eight years considered the strategies for my dear companion Sherlock Holmes. The Dancing Men-Holmes had been situated for certain hours peacefully with his long, meager back bended over a substance vessel in which he was fermenting an especially smelly item. A Scandal In Bohemia To Sherlock Holmes she is consistently the lady.

Saturday, August 8, 2020

Products and Aids to Help You Quit Smoking

Products and Aids to Help You Quit Smoking Addiction Nicotine Use How to Quit Smoking Print Products and Aids to Help You Quit Smoking Be More Comfortable as You Quit By Terry Martin facebook twitter Terry Martin quit smoking after 26 years and is now an advocate for those seeking freedom from nicotine addiction. Learn about our editorial policy Terry Martin Medically reviewed by Medically reviewed by Sanja Jelic, MD on July 14, 2016 Sanja Jelic, MD, is board-certified in sleep medicine, critical care medicine, pulmonary disease, and internal medicine.   Learn about our Medical Review Board Sanja Jelic, MD Updated on February 08, 2020 Science Photo Library/Getty Images More in Addiction Nicotine Use How to Quit Smoking After You Quit Nicotine Withdrawal Smoking-Related Diseases The Inside of Cigarettes Alcohol Use Addictive Behaviors Drug Use Coping and Recovery Hands down the best quit aid on the planet is your own will and determination. If you arent motivated and committed to kicking the habit, no quit aid can help you. If you are ready to quit, any of them have the potential to work beautifully. That said, there are a variety of products on the market today that are designed to help people stop smoking gradually. Choosing one that is right for you is essentially a matter of preference, barring any medical concerns you might have. Its always a good idea to check with your doctor if youre thinking about smoking cessation to discuss what might work best for you before making a decision. A Word About Cold Turkey Cold turkey is the term used to describe quitting smoking without the help of quit aids  of any sort. The advantage of this method is that the majority of nicotine is out of a persons body within a few days. The discomforts can be intense, but physical withdrawal is short. A lot of people are able to stop smoking successfully by going cold turkey, but if this sounds too extreme for your liking, quit aids are a good option. How Your Brain Reacts to Nicotine Nicotine Replacement Therapy Nicotine replacement therapies (NRTs) provide a measured dose of nicotine to help ease the physical symptoms of nicotine withdrawal.?? Unlike cigarettes, which consist of thousands of poisonous and/or carcinogenic chemicals, NRTs contain only nicotine. When used according to the manufacturers directions, NRTs allow gradual withdrawal from nicotine by reducing the amount of it in each dose. Nicotine PatchThe nicotine patch is one of the most popular NRTs available on the market today.Nicotine InhalerThe nicotine inhaler  consists of a plastic cigarette-like tube that houses a replaceable nicotine cartridge and a mouthpiece. The cartridge contains nicotine which is released into the users mouth and throat when inhaled.Nicotine Nasal SprayThe nicotine nasal spray is inhaled through the nasal passages several times a day to relieve nicotine cravings.Nicotine LozengesThe nicotine lozenge comes in the form of a small, candy-like tablet. When placed in the mouth and allowed to dissolve, nicotine is absorbed into the bloodstream.Nicotine GumUsed as a chewing gum, nicotine gum comes in two strengths: 2mg for people who smoke less than 25 cigarettes a day, and 4mg for those who smoke 25 or more cigarettes a day. The Downside of NRTs Because NRTs contain nicotine, the addictive component in tobacco, there is a slight risk of addiction when using these products. However, if you follow the manufacturers directions carefully and wean off the NRT of your choice as specified, this can be a safe and comfortable way to end your smoking addiction. Can You Be Addicted to Nicotine Gum? Nicotine-Free Quit Aids Several quit aids are available now that do not use nicotine as the active ingredient. The following therapies are given under a doctors care only. ZybanBupropion hydrochloride, marketed under the names Zyban, Wellbutrin SR, and Wellbutrin XL by GlaxoSmithKline, is an anti-depressant drug that also works well as a quit aid.?? It has been shown to dramatically reduce physical withdrawal symptoms associated with nicotine.ChantixDiscovered and developed by Pfizer, Inc, varenicline tartrate is marketed under the trademark of Chantix. Approved by the FDA in May 2006, Chantix has the unique ability to partially activate nicotinic receptors in the brain, which reduces cravings to smoke?? Additionally, if a person smokes during the course of Chantix treatment, the drug impedes smoking satisfaction by blocking nicotine from binding with these same receptors. Other Methods and Remedies HypnosisHypnosis seeks to put people into an altered state of mind where they become more susceptible to suggestion. Research on its effectiveness helping smokers to quit smoking is inconclusive, but it may help some people without risk of serious side effects.?? Learn what you need to know to decide if its right for you.Self-HypnosisStudies show that self-hypnosis may effectively help with pain, childbirth, stress, anxiety, and some pediatric issues. ??? It is not proven to help with smoking cessation, but some people do say its helped them quit while avoiding weight gain.AcupunctureAcupuncture is an ancient Chinese medical practice that uses needles placed at specific spots in the skin to treat pain or disease. There is some evidence that acupuncture might help people stop smoking, but more research is needed to see if it can effectively treat addiction to nicotine.??Lobelia as a Quit AidA medicinal herb used by Native Americans, Lobelia has qualities that are similar to nicotine w hile being 50â€"100 times weaker than nicotine.?? It is sometimes recommended as an herbal remedy for quitting smoking. What About the Electronic Cigarette? The electronic cigarette is a smoking alternative rather than a quit aid. It has not been approved in the U.S. as a quit aid as of yet, so there isnt a doctor-devised and approved quit plan to go with it. Even so, a lot of people use e-cigarettes to help  them quit smoking. 4 Facts About E-Cigarettes That You Need to Know Bottom Line Withdrawal from nicotine is just one part of the healing process we go through while recovering from nicotine addiction. The rest of the story involves how we let go of the many mental associations that have built up over the years between smoking and our lives. Quit aids cannot help us with this aspect of healing, but support and education can. Research and select your quit aid/method of approach, add some support and education, and youre on your way. Why the First Year of Smoking Cessation Is So Important

Saturday, May 23, 2020

Apush Chapter 25 Study Guide - 1276 Words

1. Describe the rise of the American industrial city, and place it in the context of worldwide trends of urbanization and mass migration (the European diaspora) Cities grew up and out, with such famed architects as Louis Sullivan working on and perfecting skyscrapers (first appearing in Chicago in 1885). The city grew from a small compact one that people could walk through to get around to a huge metropolis that required commuting by electric trolleys. Electricity, indoor plumbing, and telephones made city life more alluring. Department stores like Macy’s (in New York) and Marshall Field’s (in Chicago) provided urban working-class jobs and also attracted urban middle-class shoppers. Theodore Dreiser’s Sister Carrie told of a woman’s†¦show more content†¦The Church of Christ, Scientist (Christian Science), founded by Mary Baker Eddy, preached a perversion of Christianity that she claimed healed sickness. YMCA’s and YWCAs (Young Mens/Womens Christian Association) also sprouted. 4. Analyze the changes in American religious life in the late nineteenth century, including the expansion of Catholicism, Orthodoxy, and Judaism, and the growing Protestant division between liberals and fundamentalists over Darwinism and biblical criticism In 1859, Charles Darwin published his On the Origin of Species, which set forth the new doctrine of evolution and attracted the ire and fury of fundamentalists. â€Å"Modernists† took a step from the fundamentalists and refused to believe that the Bible was completely accurate and factual. They contended that the Bible was merely a collection of moral stories or guidelines, but not sacred scripture inspired by God. Colonel Robert G. Ingersoll was one who denounced creationism, as he had been widely persuaded by the theory of evolution. Others blended creationism and evolution to invent their own interpretations. 5. Explain the changes in American education and intellectual life, including the debate between DuBois and Washington over the goals of African American education During this time period, public education and the idea of tax-supported elementary schools and highShow MoreRelatedBoyer Dbq Teacher Guide10764 Words   |  44 PagesUsing the DBQ Practice Questions from The Enduring Vision, Sixth Edition A Teachers’ Guide Ray Soderholm Minnetonka High School Minnetonka, Minnesota Using the DBQ Practice Questions from The Enduring Vision, 6th Edition A Teachers’ Guide This guide is intended to suggest some possible ways that students may organize essays related to the document-based questions in the Advanced Placement version of The Enduring Vision, 6th Edition, and to provide teachers with some information on each included

Tuesday, May 12, 2020

How Many Slaves Were Taken from Africa

Information on how many slaves were shipped from Africa across the Atlantic to the Americas during the sixteenth century can only be estimated as few records exist for this period. However,  from the seventeenth century onwards, increasingly accurate records, such as ship manifests, are available. The First Trans-Atlantic Slaves   At the beginning of the 1600s, slaves for the Trans-Atlantic slave trade were sourced in Senegambia and the Windward Coast. This region had had a long history of providing slaves for the Islamic trans-Saharan trade. Around 1650 the Kingdom of the Kongo, which the Portuguese had ties with, started exporting slaves. The focus of the Trans-Atlantic slave trade moved to here and neighboring northern Angola (grouped together on this  table). Kongo and Angola would continue to be substantial exporters of slaves until the nineteenth century. Senegambia would provide a steady trickle of slaves through the centuries, but never on the same scale as the other regions of Africa. Rapid Expansion From the 1670s the Slave Coast (Bight of Benin) underwent a rapid expansion of trade in slaves which continued until the end of the slave trade in the nineteenth century. Gold Coast slave exports rose sharply in the eighteenth century but dropped markedly when Britain abolished slavery in 1808 and commenced anti-slavery patrols along the coast. The Bight of Biafra, centered on the Niger Delta and the Cross River, became a significant exporter of slaves from the 1740s and, along with its neighbor the Bight of Benin, dominated the Trans-Atlantic slave trade until its effective end in the mid-nineteenth century. These two regions alone account for two-thirds of the Trans-Atlantic slave trade in the first half of the 1800s. The Slave Trade Declines The scale of the Trans-Atlantic slave trade declined during the Napoleonic wars in Europe (1799 to 1815) but quickly rebounded once peace returned. Britain abolished slavery in 1808 and British patrols effectively ended the trade in slaves along the Gold Coast and up to Senegambia. When the port of Lagos was taken by the British in 1840, the slave trade from the Bight of Benin also collapsed. The slave trade from the Bight of Biafra gradually declined in the nineteenth century, partially as a result of British patrols and a reduction in demand for slaves from America, but also because of local shortages of slaves. To fulfill the demand for slaves, the significant tribes in the region (such and the Luba, Lunda, and Kazanje) turned on each other using the Cokwe (hunters from further inland) as mercenaries. Slaves were created as a result of raids. The Cokwe, however, became dependent on this new form of employment and turned on their employers when the coastal slave trade evaporated. The increased activities of British anti-slavery patrols along the west-African coast resulted in a brief upturn in trade from west-central and south-east Africa as increasingly desperate Trans-Atlantic slave ships visited ports under Portuguese protection. The authorities there were inclined to look the other way. With a general abolition of slavery in effect by the end of the nineteenth century, Africa started to be seen as a different resource--instead of slaves, the continent was being eyed up for its land and minerals. The scramble for Africa was on, and its people would be coerced into employment in mines and on plantations. Trans-Atlantic Slave Trade Data The greatest raw-data resource for those investigating the Trans-Atlantic slave trade is the WEB du Bois database. However, its scope is restricted to trade destined for the Americas and ignores those sent to African plantation islands and Europe.

Wednesday, May 6, 2020

Clinical Trial On Piriformis Anaesthetic Health And Social Care Essay Free Essays

string(42) " compared utilizing the Chi-square trial\." The purpose of this clinical test is to compare the patients of pure piriformis syndrome treated with local anesthetic alone or a combination of local anesthetic and methylprednisolone. Thirty-one patients diagnosed with piriformis syndrome who received a fluoroscopy guided piriformis musculus injection. There were no signii ¬?cant differences in average baseline VAS scores between the two groups of the survey. We will write a custom essay sample on Clinical Trial On Piriformis Anaesthetic Health And Social Care Essay or any similar topic only for you Order Now There were a signii ¬?cant differences between average baseline and average VAS tonss obtained during telephone interview for both groups.Pain VAS had improved by a agencies of 5.13 and 6.06 compared to the baseline degree in the local anesthetic and steroid groups, severally. It was concluded that no extra benefit from utilizing corticoid was identified after piriformis musculus injection and both bupivacaine entirely and in combination with methylprednisolone have a important consequence in alleviating chronic hurting of pure piriformis syndrome. Piriformis syndrome is an uncommon and frequently underdiagnosed cause of hurting in the cheek part and referred hurting in the lower dorsum and leg. Intolerance to sitting, dyspareunia in females, and sciatica are some of the common symptoms attributed to this syndrome. It is the true diagnosing in 6 % to 8 % of patients with back hurting and sciatica. Mechanism normally accepted is an inflamed or spastic piriformis musculus that compresses the sciatic nervus against the bony pelvic girdle. Trauma, hypertrophy and anatomic fluctuations of musculus and sciatic nervus, infections, myositis ossificans are common cause of piriformis syndrome. Priformis syndrome may be treated by curative stretch, massage, ultrasound, use and non steroidal antiinflammatory drugs. Caudal steroid injection, injection of piriformis musculus with local anesthetics and steroids or botulinus toxins, and surgical resection of the musculus have been reported as effectual intervention options. Injections may be performed blindly, with musculus electromyography, fluoroscopy, ultrasound, or with computed tomographic or MRI counsel. Nerve stimulators may besides be used to place the sciatic nervus. Local anesthetics interrupt the pain-spasm rhythm and resounding nociceptor transmittal, whereas corticoids have anti-inflammatory belongingss related to suppression of prostaglandin synthesis, decreases in regional degrees of inflammatory go-betweens and by doing a reversible local anesthetic consequence. Eventhough their antiinflammatory belongingss corticoids have been hypothesized to be of benei ¬?t for nervus root infiltration. The emerging grounds besides implies that the durable curative consequence may be obtained with local anesthetics with or without steroids. Tachihara et Al. illustrated that no extra benefit from utilizing corticoid was identified after nervus root infiltration. Therefore, it is suggested that corticoids may be unneeded for nervus root blocks. There are besides inauspicious reactions in response to the disposal of man-made corticoids such as dermatologic conditions, osteonecrosis, peptic ulcer formation, weight addition, hyperglycaemia, Cushing ‘s syndrome and psychiatric symptoms changing from mild temper alterations to wholly developed psychosis. In the present survey, the purpose was to measure the patients of pure piriformis syndrome treated with local anesthetic alone or a combination of local anesthetic and methylprednisolone. Methods This survey conducted on retrospective rating of 31 patients diagnosed with piriformis syndrome, at the University of Inonu, School of Medicine, Departments of Physical Medicine and Rehabilitation and Pain Clinic, Malatya, Turkey between 2007 to 2009, who received a fluoroscopy guided piriformis musculus injection. All the patients were given elaborate information on the process and informed written consent was obtained from all of them. The present survey was approved by Local Ethics Committee. Piriformis syndrome was diagnosed from the followers: clinical history, physical scrutiny, EMG findings and by excepting other pathological conditions of the lumbar, sacral, sacroiliac and hep joint countries by physical scrutiny and magnetic resonance imagination or computed imaging if needed. Piriformis syndrome was suggested by hurting on tactual exploration of the sciatic notch and reproduction of hurting with manoeuvres that stretch or contract the piriformis musculus over the sciatic nervus such as forceful internal rotary motion of extended thigh ( Freiberg ‘s Maneuver ) and active hip flexure, abduction or adduction and internal rotary motion by the patient lying with the painful side up, the painful leg flexed and articulatio genus resting on the tabular array ( Beatty ‘s manoeuvre ) . All patients were examined by a individual hurting specializer and non referred by any other doctor. Exclusion standards included patients known allergic reactions to local anesthe tic and bleeding diathesis. Piriformis injections were carried out by a individual hurting specializer. The patients were placed prone on a fluoroscopy tabular array. In a unfertile manner, the cheek country on the affected side was widely prepped and draped. AP position of the hemi-pelvis and cotyloid part was obtained and so a metal marker is placed on 1/3 of sidelong facet of fanciful line between the greater trochanter and sacrum. Local infiltration with 0.5 % prilocaine was used for local anesthesia. Two milliliter of radiographic contrast stuff ( iohexol ) was injected to obtain a satisfactory myogram ( Figure 1 ) . A syringe was prepared with 10 milliliters of 0.5 % bupivacaine in local anesthetic group or 9 milliliter of 0.5 % bupivacaine + 40 milligram methylprednisolone ( 10 milliliters entire ) in steroid group and injected into the piriformis musculus after negative aspiration for blood. Following the process patients should observe alleviation of their usual hurting. All patients were responded good to a individual injection. The patients that were stubborn to local anesthetic and/or steroid medicine were non considered as a exclusive piriformis syndrome and non included to the survey. After the process, the patients were transferred to the recovery room for 1 hr and until any leg numbness subsides. If hurting persisted a 2nd injection was carried out with same manner. The primary result parametric quantity of the survey was hurting assessed by VAS, analgetic usage, hurting on motion and patient satisfaction. Follow-up scrutinies were conducted by telephone interview 6 months after local injection. Analysiss were performed utilizing SPSS 16.0 version ( SPSS Inc. , Chicago, IL ) . The Kolmogorov-Smirnov trial was used to find whether the informations deviated from the normal distribution. Nonparametric informations were evaluated with the Mann-Whitney U trial. Proportions were compared utilizing the Chi-square trial. You read "Clinical Trial On Piriformis Anaesthetic Health And Social Care Essay" in category "Essay examples" P A ; lt ; 0.05 was considered as important. Consequences Medical records of 68 patients with piriformis syndrome were evaluated. Thirty-one patients fuli ¬?lled the inclusion standards. The patient ‘s features including age, sex, weight, tallness, involved side and history of hurting until injection were comparable between groups ( Table 1 ) . No signii ¬?cant differences were noted sing first diagnosing before acknowledging hurting clinic, and conventional used intervention ( Table 2 ) . Three patient from local anesthetic group and two patients from steroid group needed to reiterate injection ( Table 2 ) . The injections for these 5 patients were repeated in a twosome of yearss. The other patients did non hold a repetition injection. There were no important differences between average baseline VAS scores between the two groups of the survey. There were important differences between average baseline and average VAS tonss obtained during telephone interview for both groups ( P A ; lt ; 0.041 ) . Pain VAS had improved by a agencies of 5.1 and 6.1 compared to the baseline degree in the local anesthetic and steroid groups, severally. Adverse effects were seen by 27 % of the steroid and 6 % of the placebo patients. These included sleepiness in 2 steroid group patients, and 1 local anesthetic group patient, hypotension lasted in two yearss in 1 and temper alterations in 1 steroid group patients. There were no other inauspicious effects such as fluctuations of glucose degree, gastro-intestinal hemorrhage, osteonecrosis, infection, or demand of extra medical intervention attributed to the investigational medicines. Discussion Piriformis syndrome is non to the full understood clinical syndrome and typically characterized by stray sciatic hurting limited to the cheek with radiation down the thigh, without centripetal shortages or neurogenic cause. Robinson described six diagnostic characteristics of piriformis syndrome which were: ( I ) a history of injury to the sacroiliac and gluteal parts ; ( II ) hurting in the part of the sacroiliac articulation, greater sciatic notch, and piriformis musculus that normally extends down the limb and causes trouble with walking ; ( III ) acute aggravation of hurting caused by crouching or raising ; ( IV ) a tangible allantoid mass, stamp to tactual exploration, over the piriformis musculus on the affected side ; ( V ) a positive Las A ; egrave ; gue mark ; and ( VI ) gluteal wasting, depending on the continuance of the status. There is no dependable nonsubjective trial to place the piriformis musculus syndrome and this is leads in many instances to great seeking for the beginning of the intractable sciatica among the lumbar pathologies. Many writers have considered injury in the gluteal country as the major cause of piriformis syndrome. Jawish et Al. believed that piriformis syndrome could be related to exacerbated rotators activity as it was observed in patients with difficult physical activity, Walkers, sports and football player or with insistent injury of nervus in patients with drawn-out sitting place. Regardless of the physiopathologic beginning of the complex upset, physical scrutiny and imaging surveies should be combined to corroborate the diagnosing. As, piriformis syndrome is a diagnosing of exclusion, although the patients had radicular symptoms were exluded from the survey, other imagination or correlativity to except were more common causes of sciatic hurting, such as lumbar phonograph record herniation, posterior aspect syndromes or spinal stricture, had been obtained from our included patients. The intervention end is directed ab initio toward diminishing ini ¬Ã¢â‚¬Å¡ammation, associated hurting, and cramp as hurting originates due to the entrapment of the nervus root or to one of its subdivisions, taking to the development of myofascial trigger point. This hurting may besides be due to energy crisis produced from a loss of O and alimentary supply in the presence of an increased metabolic demand. This leads to the release of neuroactive biochemicals that sensitize nearby nervousnesss that in bend initiate the motor and sensory of myofascial trigger point via the cardinal nervous system ensuing in mechanical hypersensitivity. Injection of the 10 milliliter local anesthetic into the abdomen of the musculus as we used in our survey may rinse up such biochemicals. This injection may ensue in musculus relaxation and release of the entrapped nervus. To our cognition, our survey is the i ¬?rst clinical test comparing the effectivity of local anesthetic and methylprednisolone added to the local anesthetic. Naja et Al. compared bupivacaine ( 9 mL 0.5 % bupivacaine in a entire volume of 10 milliliter ) and bupivacaine plus clonidine ( 9 mL 0.5 % bupivacaine and 1 milliliter 150 milligram Catapres ) in a randomised double-blind test included 80 patients with piriformis syndrome who received a nervus stimulator guided piriformis injection. The average VAS tonss obtained after 6 months follow up were 4.5, 3.5 and 3.3 on walking, sitting and lying down, severally. Better consequences with Catapres had been obtained. Benzon et Al. retrospectively reviewed the charts of 19 patients who had received piriformis musculus injections and described a technique for piriformis injection. After 80-100 milligram methyl Pediapred or Aristocort injection to the schiatic nervus and piriformis musculus, 18 of the 19 patients responded to the injectio n, with betterments runing from a few hours to 3 months. The three patients with pure piriformis syndrome had 70-90 % response to piriformis injection for 1-3 months. In Fishman et al.5 survey all participants received an injection of 1.5 milliliter of 2 % Lidocaine and 0.5 milliliter ( 20 milligram ) of Aristocort and improved an norm of 71.1 % , proposing the efi ¬?cacy of corticoid and lidocaine injection combined with physical therapy in handling piriformis syndrome. Filler et Al. reported 162 patients with pure piriformis syndrome given 10 milliliter of bupivacaine and 1 milliliter of celestone: 14.9 % had sustained hurting alleviation runing from 8 months to 6 old ages without return, 7.5 % had 2 to 4 months of alleviation but required a 2nd injection, 36.6 % had 2 to 4 months of alleviation but experienced return after a 2nd injection, 25.4 % of these patients benefited for merely 2 hebdomads, and 15.7 % received no benefit. The consequence of this retrospective survey pointed out that both bupivacaine entirely and in combination with methylprednisolone have a important consequence in alleviating chronic hurting of pure piriformis syndrome and it was concluded that no extra benefit from utilizing corticoid was identified after piriformis musculus injection. Competing involvement: No external support and no viing involvements declared How to cite Clinical Trial On Piriformis Anaesthetic Health And Social Care Essay, Essay examples

Friday, May 1, 2020

Baptism Essay Example For Students

Baptism Essay is the door to life and to the kingdom of God. Baptism in Christianchurches, the universal rite of initiation, performed with water, usually in the name of the Trinity or in the name of Christ. Orthodox and Baptist churchesrequire baptism by total immersion. In other churches, pouring and sprinkling aremore common. Most churches regard baptism as a sacrament, or sign of grace;some regard it simply as an ordinance, or rite, commanded by Christ.Therefore, Baptism is the sacrament of faith by which we, enlightened by the Spirits grace, respond to the Gospel of Christ. Scriptural Basis Jesus was baptized by John at the beginning of his public ministry. Although it is uncertain that Jesus himself baptized, the risen Christ commanded his disciples topreach to and baptize the nations as the sign of Gods coming rule. Thus, from theoutset, baptism became the Christian rite of initiation. Purpose and Symbols The purpose of this sacrament is to purify your soul and to destroy all evil. That is one of the main reasons why water is used for a symbol. Water isboth destructive and creative which matches baptism. Water was used as asymbol of purification in many religions at a very early date. Other symbols ofbaptism include oil, a white cloth, and a candle. People able to receive Baptism Infants were probably baptized in the early church. Baptism was often postponedas long as possible. Between the 4th and 6th centuries, however, infantbaptism began to be required. Now almost anyone can receive this sacrament oldor young depending on what religion you are. The church believes thatbaptismal celebration should be: a) Made as soon as possible, and even before the child is born, the parish priest should be informed so that the properpreparations can be made. b) Done without delay, if the child is in danger of death. c) Made within the first weeks after birth if everything is all right. Part II Interview Mom- My mom was a baby when receiving baptism so it didnt mean much toher. She said that once you receive baptism that you cannot receive again so shewould not like to receive it again. Her life changed because she became amember of the Church. Her godparents went through a two week course, she didnothing. Dad- My dad said, I felt saved and believed I will go to heaven. Yes was his answer right away to the question, Would you go through the sacramentagain. He replied that he is a very religious guy. He felt it was a milestone in his religious development. He received this sacrament a late stage so heprepared by praying and reading the bible with his parents. Sister- My sister was a child when receiving this sacrament and didnt recall what it meant toher. She said that she would go through it again because it is a sign that you are a Christian. Her life has changed because she is now a Christian. She didnt go through any kind of preparation because she was so young. Part III I believe that this sacrament is a very special one. It is so important that you get godparents to help your spiritual growth. I have received thissacrament at an early age and if given the chance to receive it again, I would. In my opinion baptism should be given around the age of seven when the child isable to commit sin in the eyes of God. Never-the-less baptism is a veryimportant step in ones life no matter when it was received. Bibliography Bible Encarta 96 Encyclopedia CD ROM. Baptism. Windows 95 version Catechism of the Catholic Church c. 1983 Sacraments Today. .u31073ba19a37ea6e616a94611cd416cb , .u31073ba19a37ea6e616a94611cd416cb .postImageUrl , .u31073ba19a37ea6e616a94611cd416cb .centered-text-area { min-height: 80px; position: relative; } .u31073ba19a37ea6e616a94611cd416cb , .u31073ba19a37ea6e616a94611cd416cb:hover , .u31073ba19a37ea6e616a94611cd416cb:visited , .u31073ba19a37ea6e616a94611cd416cb:active { border:0!important; } .u31073ba19a37ea6e616a94611cd416cb .clearfix:after { content: ""; display: table; clear: both; } .u31073ba19a37ea6e616a94611cd416cb { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .u31073ba19a37ea6e616a94611cd416cb:active , .u31073ba19a37ea6e616a94611cd416cb:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .u31073ba19a37ea6e616a94611cd416cb .centered-text-area { width: 100%; position: relative ; } .u31073ba19a37ea6e616a94611cd416cb .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .u31073ba19a37ea6e616a94611cd416cb .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .u31073ba19a37ea6e616a94611cd416cb .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .u31073ba19a37ea6e616a94611cd416cb:hover .ctaButton { background-color: #34495E!important; } .u31073ba19a37ea6e616a94611cd416cb .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .u31073ba19a37ea6e616a94611cd416cb .u31073ba19a37ea6e616a94611cd416cb-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .u31073ba19a37ea6e616a94611cd416cb:after { content: ""; display: block; clear: both; } READ: Increase immigration into Canada Essay Baptism p. 28, c.1978 Religion

Sunday, March 22, 2020

Promotional Strategy For The New Water Based Theme Park In Darling Harbor

Introduction and description of the enterprise Darling harbour is one of the recreational sites in Sydney, Australia. There are numerous entertainment and recreations sites at the centre. The main attractions of the harbour are Chinese’s Friendship Garden, Cockle Bay Wharf, IMAX Theatre, aquariums, exhibition centre, shopping centres and museum. The Sydney Harbour Foreshore Authority (SHFA) has established an ultra modern water based theme park.Advertising We will write a custom report sample on Promotional Strategy For The New Water Based Theme Park In Darling Harbor specifically for you for only $16.05 $11/page Learn More The park will offer entertainment for adults, teenagers and children. The main attraction for the theme parks will be water rides, travelling shows, great sceneries, food services, roll coasters; train rides fireworks, acrobatics, casinos and other forms of amusements. The theme park is about to open and there is need to carry out a successful promotional campaign so as to attract tourists in Austria as well as from other parts of the world. This paper outlines the promotional strategies for the theme park. Theme park mission statement The mission statement for this theme park is â€Å"to provide high quality amusement, fun and entertainment to all our esteemed customers in Australia and the world in general† Theme park core values The main core values of the water world theme park are; Customer focus: all products and services will focus on customers and satisfy their need. The theme park will provide High quality services and products. Good corporate culture: the theme park promotes teamwork among all stakeholders and employees satisfaction Safety and enthusiasm: the employees will ensure that the rides and other activities are safe. The ground will also be secured to ensure that there are no loss of property Compassion and honesty Theme park objectives To provide high quality services and amu sement to the local and international tourists To be a major tourist attraction in Australia To earn profits and gain at least 20% of the target market The promotional campaigns will promote the values, objectives and mission of the theme park (Aaker, 1998). All the promotional messages will be formulated so as to transmit the core values and mission of the park. Target market analysis and segmentation The main customers for the theme park will be from the local and the international community. In order to identify the target market, the main customers were identified and segmented appropriately (Cateora, Gilly Graham, 2010). The main segmentation was based on:Advertising Looking for report on business economics? Let's see if we can help you! Get your first paper with 15% OFF Learn More Nationality Age Income Age: This is the most important classification. Based on age, the market can be subdivided into, children, teenagers, adults and elderly. The promotional mes sages will be formulated so as to target the different groups. For the children, the promotion messages will be formulated so as to enlighten the parent as they are the decision makers and also the financiers. The theme park will be marketed as the best destination for kids to have fun and as well as their parents. Nationality: Based on this segmentation, there are two main types of customers; the local tourists who come from Australia and the international tourists who arrive from other countries. The two target markets have different cultures, language, norms, values and other characteristics and the promotion messages must be formulated so as to target them differently. Income: The theme park market will also be segmented based on income. The accommodation, rides, shops will be arranged so as to target different customers. For example, the hotel suites will be marketed such that there are luxurious suits for high income earners and the middle class suites for low income earners. Both international and local customers can be segmented as high, medium and low income earners. Competitor analysis The water based theme park has many competitors located in Australia and internationally. A competitor’s analysis was carried out and it involved competitor identification, laying out the main objectives of the competitors, determining their competitive advantages and outlining their promotional strategies (Tellis, 1998). Competitor identification: There are other theme parks in the same area as well as other businesses operating in the same region which offer similar services. These include: DreamWorld, Luna Park, Adventure World, White Water World, Sea World Gold Coast, Wanner Bro Movie World and Mack Water Coaster Track. These parks offer services that are closely related to the water based theme park be opened. Competitor objectives: Sydney Australia is one of the most competitive markets. The many competitors in the tourism business and their main objective s are: to maximize on their profits, increases their share in the market, to attract more customers and to develop new innovative amusement for the whole family.Advertising We will write a custom report sample on Promotional Strategy For The New Water Based Theme Park In Darling Harbor specifically for you for only $16.05 $11/page Learn More Promotional methods: most of the competitors in this market use print media, televisions, and advertisements in their websites as the primary promotional methods. A Strength Weakness, Opportunities and Threat analysis was carried out so as to evaluate the competitive advantages of the competitors. These were compared with the water based theme park being marketed (Pickton Broderick, 2005). The resulting SWOT analysis matrix is shown in the table 1 below COMPANY STRENGTHS WEAKNESSES OPPORTUNITIES THREATS Luna park Has amusements for the whole family Well established Has been in the business for a long period Ha s been used severally to film movies Very many rides such as tango train, wild mouse, flying saucer, spider among others (Luna Park 2013). The park has been closing and reopening very many times due to accidents (ghost train fire which killed 7 people ) , The park has also been closed by government due to safety issues There are pollution complains Mostly marketed as a kids destination Large Australian market Growing need for whole family amusement Possibility of another movie be filmed there Competition from other theme parks Government regulations Safety issues Environmental pollution concerns Water park Gold coast Over 15 years experience Good marketing strategies Good location(next to waner bros) Attracts both kids and grown ups Very many amusements and services such as surf rider, mammoth falls, Black hole, kamikaze among others (Water Park Gold Coast, 2013) Not many tourist attractions other than rides. tourist queue waiting for amusements Dirty facilities large Australian m arket Large foreign market Other competitors Safety issues New water based theme park Adequate facilities Safety and security are guaranteed The park will attract all age groups Quality services at affordable costs Other entertainment such as casinos, food, guest rooms and exhibition centre The marketing and promotional strategy will be unique. Lack of experience The park is new and not widely known There is a large local market The new services and equipment will attract many fans There is a large international market The already existing theme parks pose significant challenge to the new firm. Threat of other new theme parks be developed Identification of the competitive advantages From the SWOT analysis carried out, the main competitive advantages of the new water based theme park being established are: Safety and security: In the past, theme parks have bee faced with issues of security and lack of safety. The new theme park will position itself as having very safe and secure amusement services. Quality: The qualities of the equipments at all the current theme park are old and dirty. The new theme park on the other hand has new equipments which are in line with modern theme parks. Wholesome entertainment: Most of the theme packs either target children or adults. The current water based theme park will target tourists from the entire divide. In addition, the theme park will have guest’s room, shops, food, casinos so as to attract more tourists. Market leader in pricing: In the short run, the park will offer services at a discounted rate so as to attract customers. The park will also strive to be a market leader in pricing and will charge lowest for their quality services (Ries Trout, 2000).Advertising Looking for report on business economics? Let's see if we can help you! Get your first paper with 15% OFF Learn More Selections and Description of the Promotional Strategy There are different promotional strategies that can be used to market the new theme. The promotional strategy selected was based on the following factors (Kotler, 2003): Ability to reach the target market Visibility of the message Cost of the promotional strategy The target audience The main methods that will be used to promote the park are: Advertising: Advertisement creates awareness among local and foreign companies. Various advertisement messages will be prepared and sent through the different channels of communication. Sales promotions: Various sales promotions strategies will be used to market the new theme park (Kotler et al., 1998). These include: Free services: In order to penetrate the market, the park will offer free rides for everyone who has booked the tickets. All children who have booked tickets will be entitled to extra rides and this will motivate their parents to pay for them. This will be done for the first four months. Discounts: Frequent customers will be given a 20% discount so as to motivate them to keep coming. Any customer who comes to the park more than two times will be awarded this discount (Bowen Chen, 2001). Offering gifts: The visitors of the theme park will participate in a lottery so that they can win various prices such as free shirts, free rides, free accommodation for the family and other amusements. Public relations activities Public relation is one of the most important methods of linking the park with the community. In the recent past, most theme parks have been criticised as being dirty and causing pollution (Kotler Nancy, 2005). In line with this, the new theme park will participate in community clean up activities; carry out campaigns on pollution prevention and environmental protection (Stammerjohan et al., 2005). Communication Mix For this promotion, integrated marketing communication will be used. Traditional methods of marketing have been criticized as not be able to measure the impacts that the promotion strategies have (Kaser, 2012). Due to the large promotional information reaching the customers, it is necessary to use the right channels and also measure the impacts of the communication strategy (Pickton Broderick 2005). The main communication channels for all sales promotions and advertising strategies are outlined below: Use of magazines: Magazines promoting tourism will be used to market the new theme parks. These magazines are usually read by many tourists where they get the information about the new theme park (Belch Belch, 2011). Use of mass media: The new theme park will be marketed on the national television and this has the ability to reach million of viewers. The problem with this method is that it is hard to determine whether the message have impacts on customers. Use of social media: Social media sites such as face book and twitter will be used to advertise the new theme park. Most of the teenagers and middle aged peo ple mostly use the social media sites and this is an appropriate media to target this group. The use of this media will also allow the park to get feedback information about their services. Evaluation method For the marketing strategies to be effective, it is imperative that they are evaluated to ensure that they reach the target market and also achieve the marketing objectives of the park (Peter Olson, 1998). The main evaluation strategies used are tabulated below: PROMOTIONAL STRATEGY EVALUATION METHODS Use of magazines The magazine will have a hotline telephone number where customers will be promoted to call so as to receive more information. This number will be specific to the magazine users. Based on the number of calls, the effectiveness of the promotional channel can be evaluated. The number of customers attending the park An increase in the number of tickets be sold Use of the television The performance of this promotional channel will be based on the number of calls to a specific telephone number and number of tickets being sold. Most of the sales promotion offers will be done through television and social media. Customers visiting the park will also be asked to indicate where they got information about the theme park from. Based on their response, the most popular communication channel will be identified The increase in the number of tickets sold Social media The social media sites customers will be asked to give a feedback by pressing the button â€Å"Like† on face book or twitter. The number of clicks will be used to evaluate the success of this communication method. References Aaker, D. 1998, Developing Business Strategies, 5th edition, Wiley, New York. Bowen. J. Chen. S. L 2001, â€Å"The relationship between customer loyalty and customer satisfaction†, International Journal of Contemporary Hospitality Management, vol.13 no.5, pp. 213-217. Belch, G. Belch, M. 2011, Advertising and Promotion: An Integrated Marketing  Communications Perspective, McGraw-Hill/Irwin. New York. Cateora, P., Gilly, M., Graham, J. 2010, International Marketing, McGraw- Hill/Irwin, New York. Kaser, K. 2012, Advertising and Sales Promotion, South-Western College Publishing. Australia. Kotler, P. Nancy, L. 2005, corporate social responsibility: doing the most good for your  company and your cause, John Wiley and Sons, Washington. Kotler, P. 2003, Marketing Insights from A to Z: 80 Concepts Every Manager Needs to  Know, Wiley, New York. Kotler, P., Bowen, J., Makens, J. 1998, Marketing for hospitality and tourism , Prentice Hall, London, UK. Luna Park 2013, Luna park website. Web. Peter, J. P. Olson, J. C. 1998, Consumer Behavior and Marketing Strategy, McGraw- Hill, Boston. Pickton, D. Broderick, A. 2005, Integrated Marketing Communications, Prentice Hall, London, UK. Ries, A. Trout, J. 2000, Positioning: The Battle for Your Mind: How to Be Seen and  Heard in the Overcrowded Marketplace, McGraw hill, New York . Stammerjohan, C., Wood, C., Chang, Y., Thorson, E. 2005, an empirical investigation of the interaction between publicity, advertising, and previous brand attitudes and knowledge. Journal of Advertising, 34 (4), 55–6. Tellis, J. 1998, Advertising and Sales Promotion Strategy, Addison- Wesley, Sydney, Australia. Water Park Gold Coast 2013, Water Park Gold Coast Website. Web. This report on Promotional Strategy For The New Water Based Theme Park In Darling Harbor was written and submitted by user Giselle H. to help you with your own studies. You are free to use it for research and reference purposes in order to write your own paper; however, you must cite it accordingly. You can donate your paper here.

Thursday, March 5, 2020

Battle of Coochs Bridge in the American Revolution

Battle of Cooch's Bridge in the American Revolution Battle of Coochs Bridge - Conflict Date: The Battle of Coochs Bridge was fought September 3, 1777, during the American Revolution (1775-1783). Battle of Coochs Bridge - Armies Commanders: Americans General George WashingtonBrigadier General William Maxwell450 men British General Sir William HoweLieutenant General Lord Charles CornwallisLieutenant Colonel Ludwig von Wurmb293 men Battle of Coochs Bridge - Background: Having captured New York in 1776, British campaign plans for the following year called for Major General John Burgoynes army to advance south from Canada with the goal of capturing the Hudson Valley and severing New England from the rest of the American colonies.   In commencing his operations, Burgoyne hoped that General Sir William Howe, the overall British commander in North America, would march north from New York City to support the campaign.   Uninterested in advancing up the Hudson, Howe instead set his sights on taking the American capital at Philadelphia.   To do so, he planned to embark the bulk of his army and sail south. Working with his brother, Admiral Richard Howe, Howe initially hoped to ascend the Delaware River and land below Philadelphia.   An assessment of the river forts in the Delaware deterred the Howes from this line of approach and they instead decided to sail further south before moving up the Chesapeake Bay.   Putting to sea in late July, the British were hampered by poor weather.   Though aware of Howes departure from New York, the American commander, General George Washington, remained in the dark regarding the enemys intentions.   Receiving sighting reports from along the coast, he increasingly determined that the target was Philadelphia.   As a result, he began moving his army south in late August.   Battle of Coochs Bridge - Coming Ashore: Moving up the Chesapeake Bay, Howe started landing his army at Head of Elk on August 25.   Moving inland, the British began concentrating their forces before beginning the march northeast toward Philadelphia.   Having encamped at Wilmington, DE, Washington, along with Major General Nathanael Greene and the Marquis de Lafayette, rode southwest on August 26 and reconnoitered the British from atop Iron Hill.   Assessing the situation, Lafayette recommended employing a force of light infantry to disrupt the British advance and give Washington time to choose suitable ground for blocking Howes army.   This duty normally would have fallen to Colonel Daniel Morgans riflemen, but this force had been sent north to reinforce Major General Horatio Gates who was opposing Burgoyne.   As a result, a new command of 1,100 handpicked men was quickly assembled under the leadership of Brigadier General William Maxwell. Battle of Coochs Bridge - Moving to Contact: On the morning of September 2, Howe directed Hessian General Wilhelm von Knyphausen to depart Cecil County Court House with the right wing of the army and move east toward Aikens Tavern.   This march was slowed by poor roads and foul weather.   The next day, Lieutenant General Lord Charles Cornwallis was ordered to break camp at Head of Elk and join Knyphausen at the tavern.   Advancing east over different roads, Howe and Cornwallis reached Aikens Tavern ahead of the delayed Hessian general and elected to turn north without waiting for the planned rendezvous.   To the north, Maxwell had positioned his force south of Coochs Bridge which spanned the Christina River as well as sent a light infantry company south to set an ambush along the road. Battle of Coochs Bridge - A Sharp Fight: Riding north, Cornwallis advance guard, which was comprised of a company of Hessian dragoons led by Captain Johann Ewald, fell into Maxwells trap.   Springing the ambush, the American light infantry broke up the Hessian column and Ewald retreated to obtain aid from Hessian and Ansbach jgers in Cornwallis command.   Advancing,  jgers led by Lieutenant Colonel Ludwig von Wurmb engaged the Maxwells men in a running fight north.   Deploying in a line with artillery support, Wurmbs men attempted to pin the Americans in place with bayonet charge in the center while sending a force to turn Maxwells flank.   Recognizing the danger, Maxwell continued to slowly retreat north towards the bridge (Map). Reaching Coochs Bridge, the Americans formed to make a stand on the east bank of the river.   Increasingly pressed by Wurmbs men, Maxwell retreated across the span to a new position on the west bank.   Breaking off the fight, the  jgers occupied nearby Iron Hill.   In an effort to take the bridge, a battalion of British light infantry crossed the river downstream and began moving north.   This effort was badly slowed by swampy terrain.   When this force finally arrived, it, along with the threat posed by Wurmbs command, compelled Maxwell to depart the field and retreat back to Washingtons camp outside Wilmington, DE. Battle of Coochs Bridge - Aftermath: Casualties for the Battle of Coochs Bridge are not known with certainty but are estimated at 20 killed and 20 wounded for Maxwell and 3-30 killed and 20-30 wounded for Cornwallis.   As Maxwell moved north, Howes army continued to be harassed by American militia forces.   That evening, Delaware militia, led by Caesar Rodney, struck the British near Aikens Tavern in a hit-and-run attack.   Over the next week, Washington marched north with the intention of blocking Howes advance near Chadds Ford, PA.   Taking a position behind the Brandywine River, he was defeated at the Battle of Brandywine on September 11.   In the days after the battle, Howe succeeded in occupying Philadelphia.   An American counterattack on October 4 was turned back at the Battle of Germantown.   The campaign season ended later that fall with Washingtons army going into winter quarters at Valley Forge.            Selected Sources DAR: Battle of Coochs BridgePHAA: Battle of Coochs BridgeHMDB: Battle of Coochs Bridge

Tuesday, February 18, 2020

Humanities Essay Example | Topics and Well Written Essays - 750 words - 8

Humanities - Essay Example Humanities Essay Example | Topics and Well Written Essays - 1250 words - 1 Humanities - Essay Example Today, Haitian culture is a mix of African and European influence. Since a culture or society can roughly be called a larger representation of the family unit as it is thought of within the society, looking at family structures and social factors in Haiti can also show one of the most important areas of influence on artistic and cultural factors. In Africa, family ties were binding and not exclusive, and the idea of the extended family was important because all of the members worked together to help each other as much as As mentioned, art and culture in any nation can be traced back to history, but family structures and social structures are a keen part of this history. Like in Africa, in Haiti "In rural areas, the extended family has traditionally been the social unit" (Haiti, 2006). The importance of extended family is necessary to keep society together through a code of familiarity and support, and as the economy in rural Haiti is similar, this pattern has stayed the same after the Diaspora that brought Africans to Haiti. During this time, extended families stay together in close relationships of agreement, sustaining each other and the economy. There is not the spirit of one generation disagreeing with another generation with which we are familiar in the U.S., leading to art and culture that is often clashing: instead, there is cross-generational respect. In Haiti, families are built on almost unquestioning piety and are not represented by "the nuclear" but by extension. This is the extended fam ily concept, which can also be extended into the arts of the nation. There is a lot of art to look at in Haiti as well, and there is a thriving art scene currently that is based on Haiti's social, familial, political, and cultural histories. There are many representative styles that are both unique and derivative, from more historical styles to the abovementioned modernist abstract collages of Basquiat. The concerns of the society are shown through artists' work, and there are also cultural influences and mixes that are part of Haitian history and society which are then infused into the art produced by society. Therefore when visiting Haiti, it is also important to see the arts and crafts of the people, so that one can make the correlations between the culture itself, and the art that is produced from the true resource of a nation: its human beings. "While Haitian art may lack polish, it makes up for it with a deep and engaging representation of humanity. The Haitian artist finds holiness in the ordinary subjects of everyday life. Simple, soulful ima ges are found in Haitian art. It is this soulfulness that attracts so many to admire and collect this remarkable art." (Flavors, 2007). The cultural and social traditions and mixes of influence can also be seen in this art, which varies according to the individual. Since Haiti was one of the first Caribbean nations to declare independence, it has been relatively free, in comparison to many of its neighbors, of the colonial cultural control (also known in some circles as

Monday, February 3, 2020

Experimental Design & Methods 2 Research Paper Example | Topics and Well Written Essays - 750 words

Experimental Design & Methods 2 - Research Paper Example In the assessment of the current advertisement, campaign used by the Idaho State University will begin with a comprehensive analysis of the goals of the advertisement. This involves understanding its intended meaning, its anticipated impact on the targeted population, the demographics of the target population as well as its anticipated impact on the image of the University. When these dynamics have already been outlined, they will be used as standards through which the content of the advertisement will be assessed. Content testing will involve finding out whether the advertisement is successful at obtaining the attention of its target audience, if the advertisement is sufficiently informative to enable the audience to evaluate the advertised material and whether the advertisement is believable enough to convince the audience. Additionally, the testing will consider whether the advertisement is memorable in order to make sure that the audience will remember its main aspects, whether t he advertisement appeals to the target audience and whether the advertisement produces the anticipated effect in regards to brand image of Idaho State University. Selecting the advertisement that is most suitable entails more than mere choosing of the most eye-catching approach as the most suitable approach should have an ability to meet all the goals that have been set out by the Idaho State University. The chosen approach should also be able to communicate the appropriate message to the target audience, have an appeal to the target audience and be consistent with the marketing endeavors of the University. The experiment to assess whether the advertisement campaign used by the Idaho State University is effective and whether it will be more successful if a different social media platform is used will be conducted in two phases; the

Sunday, January 26, 2020

Indian Jurisprudence Gender Sensitivity In CRPC Law Essay

Indian Jurisprudence Gender Sensitivity In CRPC Law Essay The basic tenet of criminal jurisprudence is that crime is not genetic, that is, one is not born a criminal. As no iron curtain is drawn between constitution and the accused, an under trial or a convict, his basic human rights cannot be put to jeopardy for an accused or a convict by the mere reason of accusation or conviction, is not denuded from his fundamental rights guaranteed in the constitution  [1]  . The distinction between gender and sex is often ignored by those who claim to be the sentinels of gender justice. While once in a while one hears voices against the injustice towards women, our justice system often turns a blind eye to the brutality with which all criminals are treated. It is true that the purpose of a punishment is deterrent and punitive in nature and the offender deserves a hard handed treatment as a retribution for his action, this cannot justify the acts which border brutality. Police, which is the first instrument in the process of ensuring criminal justice, often fails to justify its actions of dishonoring gender dignity of other genders when they interact with them in the society and particularly when they investigate crimes in which they are the suspects, dà ©tinues or the accused.  [2]  Men, women, transsexuals, all fall in the grind of this insensitivity perpetrated in the hands of those in charge of safeguarding the fundamental rights of convicts and other participants( victim, witness etc) in a criminal trial. The fact however remains that while substantive law fails to acknowledge the thin line of distinction between gender and sex and transsexuals and male criminals continue to be treated inconsiderately, our procedural laws, furthered by judicial activism; do provide some sense of sensitivity towards women. Spurred by judicial pronouncements, Code of Criminal Procedure (hereinafter CrPC or the Act) has been amended time to time to introduce elements of sensitivity towards women. This paper is an attempt to trace the gender-sensitive provisions of CrPC, supported by judicial pronouncements, restricting the scope of gender to women. The discussion runs in three parts: part I dealing with provisions when women are offenders, part II when they are victims of criminal offenses and part III when they are witnesses in a criminal trial. The last part will be followed by a conclusion with an analysis whether these laws provide adequate protection to women and whether the available procedure are being implemented in reality or are merely a letter of law. The CrPC amendments of 2005 and 2008 have been taken as the backdrop of the discussions in this paper. As it is not possible to cover all sections reflecting sensitivity towards women in the prescribed word-limit, the author has narrowed down the scope of discussion to the most important provisions under each part. Part II and subsequently III discuss in detail the special provisions for women in rape cases and other atrocities of women-trafficking, domestic violence and dowry deaths and sexual harassment at work have been excluded from the discussion. Part I Accused Arrest The Indian criminal jurisprudence has been sensitive to the fact that women, being physically weaker, are often mistreated by police while arrest and consequently, provisions preventing any physical or sexual assault while arresting them find place in CrPC. Section 46 of the code enlists the details of how arrests have to be made by the police  [3]  . Parliament, through the 2005 Amendment Act to CrPC introduced in section 46, sub clause 4 to ensure that women offenders are not mistreated while being arrested by the police officers. It read:Save in exceptional circumstances, no woman shall be arrested after sunset and before sunrise and where such exceptional circumstances exist, the woman police officer shall, by making a written report, obtain the prior permission of the Judicial Magistrate of the first class within whose local jurisdiction the offense is committed or the arrest is to be made. The history of this provision can be traced back to the report submitted by the National Human Rights Commission in 1997. The report examined the complaints of human rights violation through abuse of powers of arrest and detention given to the police. According to this report, the NHRC requested that all Indian state governments translate th ese guidelines into their respective regional language and make them available to all Police Officers and in all Police Stations.  [4]   The report includes the following guideline pertaining to the arrest of women, As far as is practicable women police officers should be associated where the person or persons being arrested are women. The arrest of women between sunset and sunrise should be avoided  [5]  . The incorporation of this provision in CRPC was spurred by the case law produced by the Courts in response to the demand for protecting women. In Christian Community Welfare Council of India and another v Government of Maharashtra another  [6]  ,the High Court of Bombay made it mandatory for the presence of a woman officer for arresting a woman. The Supreme Court however reversed the judgment  [7]  , accounting for the situations when arresting a woman is crucial but logistical impediments make the presence of a woman officer difficult. The 2005 amendment act was a closer embodiment of the Supreme Court decision as it gave the police some leeway to arrest females even in absence of lady officers. 2008 Amendment to CrPC saw further sensitizing of arrest procedures with regards to women when a proviso to clause 1 of section 46 was added to ensure that the clause 1 is not misused to offend women who are arrested. As interpreted by Courts, un-amended section 46(1) implied that arrest being a restraint of the liberty of a person, it can be effected by actually contacting or touching the body of such person or by his submission to the custody of the person making the arrest as a mere oral declaration to arrest without actual contact or submission does not amount to arrest.  [8]   The proviso states that Provided that where a woman is to be arrested, unless the circumstances indicate to the contrary, her submission to custody on an oral intimation of arrest shall be presumed and, unless the circumstances otherwise require or unless the police officer is a female, the police officer shall not touch the person of the woman for making her arrest. The proviso permits the physical arrest of a woman by a female officer or unless the circumstances make it an indispensible necessity for the police office to make use of physical force to restrain and arrest her. Even then, the use of force should be reasonable and not more than required to prevent the offenders escape.  [9]   search Section 47  [10]  places restrictions on police while searching for the offender in a place occupied by a pardanasheen woman, in which case she will be adequately notified by the police before search giving her time to remove herself from the sight before the police commences with the search. Clause 3  [11]  of section 51 as well as clause 3  [12]  of section 100 makes it mandatory that the search of a female is conducted only by a lady to ensure that her dignity is not violated in any form.  [13]   Section 53(2)  [14]  and 54  [15]  , that allows for the medical examination of the accused make it mandatory for the police to ensure that female arrestees are examined only by registered female doctor or under her close supervision. bail CrPC empowers every arrestee with the right to be released on bail when arrested for a bailable offence. It is the duty of the police officer to inform him of his right to be released on bail  [16]  . Women however are given the privilege of a bail even in circumstances When a female is arrested for a non-bailable offence, even if the offence is very serious (punishable by death penalty even), the court can release her on bail as provided in section 437(1) of CrPC  [17]  . For instance where a young woman of two infant children was accused of murder along with her husband and her husband was incarcerated for the crime as an under trial, the accused in such facts and circumstances of case would be entitled to be released on bail as per the provisions of this section  [18]  . This provision is not to be taken violative of article 14 of the Constitution as it discriminated between male and female offenders because article 14 had to be read subject to article 15(3) of the Con stitution under which the State Is empowered to make special provisions for women and children. Detention Even though CrPC is silent on the issue of separate provisions for detention of women offenders, Supreme Court in Sheela Barse case  [19]  held that female suspects must be kept in a separate lock-up in the police station. They should not be kept where male suspects are detained. Various states have, by orders made it mandatory that all female prisoners have to be imprisoned in a separate building or in separate part of the same building which is completely separate from the male prisoners.  [20]   In R.D. Upadhyay vs. State of AP.  [21]  , gender specific issues of women have been dealt with by the Supreme Court in detail and minimum standards laid for the care of the mother and the child. In pursuance of this, women inmates are allowed to keep their children up to six years of age. Pregnant women in prisons have to be given proper pre-natal and post-natal care  [22]  . Section 416  [23]  provides the provision of postponement of capital sentence awarded to a women if she is carrying a child. The High Court is also empowered by this section to commute the sentence of death penalty to that of life imprisonment. The purpose behind this provision is to ensure that the unborn child is not penalized for the crimes committed by the mother. Part II Victim Colonial law treated women as chattels: fragments of property of their male messiahs. It took two centuries to liberate the country, and another half to liberate the thoughts. In 1970, India witnessed a rape trial that mocked the very fundamentals of our constitution: equality and justice were stifled as Supreme Court refused to penalize a police personal charged of raping a tribal minor girl, in police custody, on grounds of the girls questionable sexual conduct in past. This was the infamous Mathura rape trial  [24]  . Efforts of women activists and judicial intervening finally paid off and the last decade saw attempts to ensure there werent any Mathuras with the promulgation of the 1983 amendment. In 1983, the government passed the Criminal Law Amendment Act, which created a rebuttal presumption in cases related to custodial rape  [25]  . Custodial rape, gang rape, rape of pregnant women and minor women were recognized as rape offenses by introduction of sections 376A to 376D in the IPC. The government also made amendments stipulating that the penalty for custodial rape should not be less than seven years imprisonment; and it provided for in camera proceedings  [26]  and made the disclosure of the victims identity a punishable offence.  [27]  Publication of proceedings in a rape trial could be possible only with prior permission of the Court. This clause however was amended by the 2008 amendment to facilitate the dissemination of information regarding the atrocities on women and their rights through media. Therefore, the 2008 amendment allows the publication of proceedings in a rape trial provided confidentiality of name and address of the parties is maintained  [28]  . Women rights activist claim that despite the 1983 amendment which did bring some procedural improvement in the state of women in rape trials, not much was reflected in reality. These amendments were not enough to stem the rise in the number of cases of sexual violence against women  [29]  . One crucial defect in the law was the definition of rape under Section 375 of the Indian Penal Code (IPC), which took into account only penile-vaginal penetration. Other physical and mental injuries were left to be dealt with under Sections 354 and 509 of the IPC as `outraging the modesty of a woman.  [30]   In 1996, the substantive redundancy of these laws was exposed in the Gurmeet Singh case  [31]  where the trial court acquitted the rapists disbelieving the version of the prosecutrix( despite section 114A of Evidence Act that allows the assumption of truth in the statement of the victim in rape trials and placing of the burden of proof on the accused) and delay in lodging the FIR, . The Supreme Court, however was emphatic to the cause and laid down certain guidelines to be followed in case of rape trials  [32]  : Delay in lodging FIR is not material if properly explained. Testimony of the prosecutrix in cases of sexual harassment in cases of sexual assault is vital and unless there are compelling reasons which necessitate looking for corroboration of her statement, the Court should find no difficulty in convicting the ccused on prosecutrix testimony alone. Trial of sexual offences should be in camera and invariably by a lady judge wherever available. Court must restrain making observations that probably the prosecutrix is a girl of loose moral character. Court is under an obligation to see that prosecutrix is not unnecessarily harassed and humiliated in cross examination in case of rape trial. In the case of Dildar Singh v. State of Punjab  [33]  , it has been held by Honble Apex Court that delay in lodging of the first information report cannot be used as ritualistic formula for doubting the prosecution case and discarding the same on the ground of delay in lodging the first information report. Some of these guidelines were translated into law by subsequent amendments to Indian Criminal Law. Later, vide the 2003 amendment to Indian Evidence Act, a proviso was added to section 146 which allowed for cross examination. It made it impermissible to question the prosecutrix in a rape trial regarding her past sexual conduct and history.  [34]   With the 2005 amendment to CrPC, section 53A  [35]  was added to incorporate provisions for medical examination of the rape accused to provide evidence. As for the examination of the rape victim, she cannot be medically examined without her consent, as stated in 164A  [36]  of CrPC. In case she is unable to express her consent, a person competent to consent on her behalf will do so. Also, the medical examination of both the accused and the victim has to be conducted within 24 hours of receiving the information of the offense. Notified on 31 December 2009 was the latest amendment in CrPC in an attempt to sensitize the criminal laws towards protection of women further. Many provisions were introduced to minimize the harassment faced by victims during the process of investigation and trial in a rape case. The amendment act introduces a proviso in section 157  [37]  stating that the statement of the victim in a rape case has to be recorded , as far as feasible, by a lady officer, in a place she feels comfortable in: preferably her house and in presence of her parents, guardians, near relatives or a social worker. This was primarily done to avoid the humiliation the victim has to suffer in revisiting the details of the horrifying incident in front of police men and others in a police station. Besides this, the act allowed audio-video electronic means to record statement under 161 and 164 of CrPC to facilitate victims who are not in the physical or psychological state to be present in person before the magistrate for a statement. The amendment act adds to section 327, the provision of a lady judge trying a rape case as far as possible so as to bring a compassionate thought to the proceedings. One of the major contributions of the 2008 amendment act is the introduction of section 357 A  [38]  in CrPC providing for the provision for compensation to victims for injuries suffered. Though this provision is not women-specific, it can prove to be a major instrument for justice by providing the rape victims adequate compensation for the physical and emotional torture they were subjected to. Compensation for rape was recognized by the Supreme Court for the first time in the Chandrima Das case  [39]  where the court held that the relief can be granted to the victim for two reasons- firstly, on the ground of domestic jurisprudence based on the Constitutional provisions( as her fundamental right to life and dignity is violated in a crime of this heinous a nature); and secondly, on the ground of Human Rights Jurisprudence based on the Universal Declaration of Human Rights, 1948 which has international recognition as the Moral Code of Conduct- adopted by the General Assembly of the United Nations. Activists hope that 357A will not merely be a procedural puppet in the hands of the state government and be actually utilized in facilitating some compensations to the unfortunate victims of rape and sexual violence. The amendment also has provision of right to appeal for victims. Currently, the right to appeal lies with the state which directly fights the case with the accused. Under the proposed change, the victim can independently hire a lawyer and go in for an appeal in addition to what the state does  [40]  . Part III Witness Police is authorized by section 160  [41]  of CrPC to summon a witness during investigation in case. This power however is limited by the proviso to sub-section 1 that restricts the police from summoning a male below fifteen years of age or a woman other than the place of his or her residence. A woman accused or a witness should not be summoned or required to attend at any police station under section 160 but they must be enquired only by women police or in presence of woman police at the place where they reside.  [42]  It was considered by the Supreme Court , in the Nandani Satpathy  [43]  case, to be a matter of public policy to keep minor children and women away from police company except as much as possible till the time community confidence and consciousness will regard the police force as entitled to better trust and soften the stigmatizing provisions now writ across the code.  [44]   In the landmark case of Sakshi v Union of India  [45]  , the Supreme Court realized and acknowledged the pain and trauma a woman goes through when she is asked to reiterate the soul-scathing instance of rape and prescribed guidelines for treatment of victims and witnesses in a rape trial. The court accounted for the fact that the mere sight of the accused may induce an element of extreme fear in the mind of the victim or the witnesses and can put them in a state of shock, making it difficult to give a true testimony  [46]  . Therefore, a screen or some such arrangement can be made where the victim or witness do not have to undergo the trauma of seeing the body or face of the accused. In State of Maharashtra and P.C.Singh v Dr. Praful Desai  [47]  , the Supreme Court explicitly recognized video conferencing as a means of recording evidence in a rape trial to facilitate the victim-witness to answer questions without fear or embarrassment. The latest amendment to CrPC seems to be a manifestation of this guideline by the Court as it adds to section 275  [48]  , a proviso allowing audio-video electronic means to witness in presence of advocate of the accused so as to facilitate their testimony if they feel uncomfortable facing the accused and others in the court room. Conclusion Though amendments over the last two decades have introduced some element of sensitivity in our criminal laws, skeptics have their reservations regarding the same. The way women have been treated in criminal justice system in the past makes it difficult to place faith in it. For instance, the 2008 amendment act introducing the provision of women judges hearing rape cases is being frowned upon by some women rights activists and is being seen as a means of ghettoizing  [49]  female judges, confining them only to women related matters. There seems some legitimacy in this accusation as if providing male judges was the problem to be solved, why is one ignoring the male defense lawyers projecting scathing questions to the victim. Moreover, since there are lesser number of female judges in the country, waiting for the appointment of one in a rape trial will delay the justice further by weeks. Despite the gender-sensitive provisions like women officers arresting female offender, the system fails to account for practical impediments like the skewed ratio of male and female officers  [50]  . A gender-sensitive, rather than a gender-biased system seems a more wholesome solution to the approach as law as without the backing and support of law-enforcement authorities, the laws made are hollow words, which go unnoticed. Gender sensitivity, not gender, is the watchword, for patriarchy is endemic to the system, not a trait of males alone  [51]  .  Thus, what is needed today is not merely simulated sensitivity in procedural law, rather its reflection in reality to ensure that no woman is wronged in the hands of those claiming to dispense justice.

Saturday, January 18, 2020

Myth on Aging Essay

There are many misconceptions when we talk about sex especially to old age generation. During the first day of class in HS 107, we talked about myths on aging. According to many people, they believed that â€Å"Majority of old people have no interest in, nor capacity for, sexual relations† (Facts on Aging Quiz). In our society, many people believe that older adults do not have sex when they reach the certain old age. Many argue that as you grow older your body becomes frail, thus, decreasing and diminishing sexual desire. Others believe that the sex â€Å"belong to the younger generations† (Schwartz, 2012). Since older adults are more prone to chronic disease, this means that we assume that they do not have a desire on having sexual intercourse. This myth persists This myth continues because not everyone has an open-mind when it comes to talking about older adults’ lifestyle. Many people believe that older adults should stay at home because they are fragile, and should not have any sexual thoughts anymore. Most of us believe that older adults that have sexual intercourse can give complications and might risk their health. Many younger generations including college students feel that it is uncomfortable when talking about older generations having sex. â€Å"College students were more surprised and disgusted by incidents of sexuality of those who were 70 to 75 than those who were 30 to 35† (Lochlainn & Kenny, 2013). Many in younger generations do not believe that older adults still have sex, and they feel appalled when somebody talks about it. Not only our generation avoids this issue, but the health care field as well. Langer-Most and Langer (2010) showed results that many doctors show very little interest when it comes to talking about sexual interaction with older adults. Many of them argued that this population does not have sex occasionally and it can be risky for their health. According to Connolly et al. (2012), when they asked physicians on whether they ask their patients about they sex life, they replied as being embarrassing for their profession. This is appalling of how a health care provider does not talk about sexual interaction when it comes to older generations. Because of embarrassment, many people closes this discussion and over generalize that older adults does not have any interest or have sex at all. The Reality Older Adults have interest and capacity for sexual interactions. Despite of getting older, many people still have sex whether younger generations like it or not. Regular sexual activity is a normal event, as you get older. There are several evidences that older generations tend to have sexual relations. According to Connolly et al. (2012), the study found that, â€Å"Among respondents ages 75-85, 54% of sexually active person reported having sex at least 2-3 times a month, and 23 percent reported having sex once a week or more. † This shows that our myth is not true that older adults do not have any interest when it comes to sexual interaction. Aging does not mean that once you hit a certain age, you will stop having interest on sex. Bradford and Meston (2007) accentuates that â€Å"Sexuality in older adults is often misunderstood, misrepresented or simply invisible. † We tend to avoid these conversations. Many of us over generalized and judge older people when they tell us that they have sex. Many people are being judged, which is harder for them to open and ask for help with these types of issue. We believe that older adults having sex is not necessary. However, according to Bradford and Meston (2007) studies have shown and according to â€Å"National Council on Aging (2005) reported that 71% of mean in their 60s and 57% of mean in their 70s engaged in sexual activity at least once per month. The studies have shown that there are greater amount of older adults that have sexual relations that we have normally expected. For older adults, it is normal for them to have sex; though we do not believe that this is true. Bradford and Meston (2007) explains that according to â€Å"American Association of Retired Persons reported that 62 % of mean and 51% of women between ages 60 and 69 believed that sexual activity is an important component of a good relationship. † Their study have shown older men and women have sex in order to continue their good relationship with their significant other since their intimacy is not the same as before. It is a positive aspect to have sex with your loved one when you get older. This way, you both can still connect despite of what you experience while getting older. As you grow older your body tends to slow down, which makes it harder to have sex when you suffer with some illness. However, this does not mean that you cannot have sex when your body starts to weaken, as you grow older. Mauk (2008) argued, â€Å"Normal aging changes include [†¦] diminished sex hormones. † Our sex hormones decreases as you grow older, but this does not mean we completely stop or does not have interest with sexual relations. Many older adults compromise with their illness when it comes to sex. For men, they experience erectile dysfunction, and the most common problem is achieving or maintaining an erection during the intercourse (Lochlainn & Kenny, 2013). Older men have these reproductive problems, and it is difficult for them to have sex when you have this issue. As for women, menopausal is the problem. When a woman reaches the menopausal stage, their vaginal wall begins to get thinner, and the lubrication production decreases. Despite of their complications with their reproductive system, most of them seek for an advice and try to compromise in order to attain and continue their sexual relationships with their significant other. However, due to overgeneralization and prejudice, many older adults are embarrassed to seek for help even to health professionals. Lochlainn and Kenny (2013) states that, â€Å"5% of older women volunteered their sexual problems during office visits, 85. 3% of men with erectile dysfunction wanted help, but only 10. 4% mean received medical care. † Not many older adults seek for help because of the stigma that our society is impelling. Many providers underestimate patient risk, and lack the knowledge and comfort to discuss questions about sexual dysfunction or satisfaction with older patients (Langer-Most & Langer, 2010). Many patient providers do not have adequate training on how to approach the older adults’ issue because of the stigma. The doctors are embarrassed and they feel it is a humiliation to his/her profession when they open the sex issue for older adults. Additionally, older adults tend to be excluded from studies because many professionals that they have a lower chance of getting diseases such as HIV/AIDS, and a very low chance of getting pregnant. Thus, there have only been a few doctors that have enough knowledge when it comes educating older adults on how to compromise with their body or how to prevent of getting infected with sexual transmitted diseases. Media have also contributed with the ageism regarding with sexual relations among older adults. â€Å"[†¦] One reason for the negative attitudes of older person could be the media’s portrayal of the elderly as frail and asexual† (Lochlainn & Kenny, 2013). Many of the movies, and other shows displays that older adults are very sensitive and delicate. Thus, we overgeneralize that older adults does not have interest with sex. Social Actions The study among older adults that is being conducted nowadays is beginning to grow. Thus, it is a big start when it comes to social actions. Many professionals begin to take a step and start learning more about older adults’ lifestyle. There have been several studies that we have encountered when it comes to sexual relationships among older adults. Researchers have found ways and suggest several solutions. Since health professionals does not know how to approach older adults with this issue, Langer-Most and Langer (2010) suggests having a positive attitude regardless of their ethnicity, gender level, and age. Also, researchers have suggested on conducting educational programs for health professionals regarding with sexuality and aging. A resource fair conducted by SJSU is another social action for senior citizens, which they approach older adults and educate them about their body. Hartford Institute of Geriatric Nursing educates health practitioners and nurses on how to approach older adults when it comes to this sensitive matter. They know that it is significant to teach providers in order for the older adults to be more comfortable with their doctors. They conduct seminars to other hospitals to educate people in the health field. Most of all, many well-known universities such as SJSU embraced the geriatric field and educate many college students that most of the myths are not true when it comes to older generations. Sex is an important part in life, and we have to be sensitive and accept the fact that older adults tend to have sex, and it is part of the normal life. References Bradford, A. , and Meston, C. M. (2007). Senior Sexual Health: The Effects of Aging on Sexuality. Innovations In Clinical Practice: Focus on Sexual Health. 35-45. Connolly, M. , Breckman, R. , Callahan, J. , Lachs, M. , Ramsey-Klawsnik, H. , & Solomon, J. (2012). The Sexual Revolution’s Last Frontier: How Silence About Sex Undermines Health, Well-being, and Safety In Old Age. Generations. 36(3), 43-52. Kristen, M. PhD RN (2008). Myths of Aging. ARN Network. Langer-Most, O. , and Langer, Nieli. (2010). Aging and Sexuality: How Much Do Gynecologists Know and Care. Journal of Women and Aging. 22, 283-289. Doi:10. 1080/08952841. 2010. 518882 Lochlainn, M. N. , and Kenny, R. A. (2013). Sexual Activity On Aging. Journal Of The American Medical Directors Association. Doi:10. 1016/j. jamda. 2013. 01. 022 Wallace, M. PhD (2013). Best Practices in Nursing Care to Older Adults: Sexuality. Dermatology Nursing. 15(6).

Friday, January 10, 2020

Separation of Church and State

SEPARATION OF CHURCH AND STATE Constitutional Context: â€Å"Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances† (1st Amend). Executive Branch Context: â€Å"We should live our lives as though Christ were coming this afternoon. † – Jimmy Carter â€Å"I was humbled to learn that God sent His Son to die for a sinner like me. † – George W.Bush†We hold these truths to be self-evident; that all men are created equal; that they are endowed by their Creator with certain unalienable rights; that among these are Life, Liberty, and the pursuit of Happiness. † – Thomas Jefferson, Declaration of Independence, July 4, 1776 Congressional Context: Public Law 97-280 is a resolution that recognizes the influence of the Bible on th e development of our nation. Introduced as Senate Joint Resolution 165, with thirty-three co-sponsors, and as House Joint Resolution 487 with 219 co-sponsors, a request was delivered before Congress to honor the Bible as Holy Scripture.The resolution suffered no amendments, no exclusions, no demands that it be stricken of religious references. It became law. The 97th Congress of the United States publicly declared 1983 the national â€Å"Year of the Bible†. The bipartisan document known as Public Law 97-280, was signed on October 4, 1982 by Speaker of the House Thomas P. O'Neill, President of the Senate – Pro Tempore Strom Thurmond, and President of the United States Ronald Reagan.It reads as follows: WHEREAS the Bible, the Word of God, has made a unique contribution in shaping the United States as a distinctive and blessed nation and people; WHEREAS deeply held religious convictions springing from the Holy Scriptures led to the early settlement of our Nation; WHEREAS Biblical teachings inspired concepts of civil government that are contained in our Declaration of Independence and Constitution of the United States; WHEREAS many of our great national leaders–among them Presidents Washington, Jackson, Lincoln, and Wilson–paid tribute to the surpassing influence of the Bible in our country's development, as in the words of President Jackson that the Bible is â€Å"the Rock on which our Republic rests†; WHEREAS the history of our Nation clearly illustrates the value of voluntarily applying the teachings of the Scriptures in the ives of individuals, families, and societies; WHEREAS this Nation now faces great challenges that will test this Nation as it has never been tested before; and WHEREAS that renewing our knowledge of and faith in God through Holy Scripture can strengthen us as a nation and a people:  NOW, THEREFORE, be it Resolved by the Senate and House of Representatives of the United States of America in Congress assem bled, That the President is authorized and requested to designate 1983 as a national â€Å"Year of the Bible† in recognition of both the formative influence the Bible has been for our Nation, and our national need to study and apply the teachings of the Holy Scriptures. Both secularists and Christians in evangelism in America must operate within the context of the controversy of the separation of church and state. The State and Church are in mutual consensus as evidenced in both the law of the land and in the law of God. By resolution of U. S. Congress ratified by President Reagan PL 97-280 our government acknowledges the formative role of the Bible in our State affairs â€Å"the history of our Nation clearly illustrates the value of voluntarily applying the teachings of the Scriptures in the lives of individuals, families, and societies. Likewise, scripture speaks to the church on this duty as a citizen: Let every person be subject to the governing authorities. For there is no authority except from God, and those that exist have been instituted by God. Therefore whoever resists the authorities resists what God has appointed, and those who resist will incur judgment. For rulers are not a terror to good conduct, but to bad. Would you have no fear of the one who is in authority? Then do what is good, and you will receive his approval, for he is God's servant for your good. But if you do wrong, be afraid, for he does not bear the sword in vain. For he is the servant of God, an avenger who carries out God's wrath on the wrongdoer.Therefore one must be in subjection, not only to avoid God's wrath but also for the sake of conscience. For because of this you also pay taxes, for the authorities are ministers of God, attending to this very thing. Pay to all what is owed to them: taxes to whom taxes are owed, revenue to whom revenue is owed, respect to whom respect is owed, honor to whom honor is owed. (Romans 13:1-7 ESV) â€Å"The Americans combine the notions of Christianity and of liberty so intimately in their minds, that it is impossible to make them conceive the one without the other. †Ã‚  Alexis de Tocqueville The tendency of textbook authors has been to deny or denigrate the role of religion in their depictions of the founding of the United States.Historians like Professor Eric Foner teach their students that the Founding Fathers were able to embrace progressive ideas  like freedom and equality because they viewed Christianity and the Bible as â€Å"outdated superstitions that should be abandoned in the modern age. †1Eric Foner,  Give Me Liberty,  2005 edition, p. 145 The truth is very different. College history professors, like other left wing extremists, are loath to acknowledge that religion has played a positive role in the development of this nation; yet any honest portrayal of American history would have to acknowledge it. The rights and freedoms enshrined in the Declaration of Independence and the Constit ution were, the Founders thought, quite literally sacred; having been bestowed on the human race by God Himself.The American people of the late eighteenth century were more generally devout in their Christianity than the citizens of any other nation, and there is a reason for that. In America religion was not imposed on the people by government, it was freely chosen. Sincere religious faith animated the founders and masses of this nation in ways that other nations of the world could not understand. Secular humanists and effete leftists who populate college history faculties, historical revisionists might be uncomfortable with the Biblical basis of America’s principles of freedom and equality, and might even work to keep the information from their students, but the facts remain what they are.Religious convictions provided the ideological underpinnings of the founding principles of this nation. Effect of Separation of Church and State When the Frenchman Alexis de Tocqueville vi sited the United States in 1831 and 1832, he remarked that there was â€Å"no country in the whole world in which the Christian religion retains a greater influence over the souls of men than in America† (Tocqueville, p. 350). Tocqueville made it clear that while religion was an important part of the American character, religious conformity was not. The Americans he met approached God as individuals. Unlike Europe, where citizens passively accepted whatever religious denomination their rulers might mandate, the Americans chose their own churches. The sects which exist in the United States are innumerable,† said Tocqueville, â€Å"they all differ in respect to the worship which is due from man to his Creator, but they all agree in respect to the duties which are due from man to man† (p. 350). Tocqueville was observing and describing a new and powerful religious enthusiasm among American Protestants after a wave of religious revivals known as the Great Awakening. R eligious rebirth gave some Americans a mooring in a fast changing world; others determined to refashion their society, working through new political parties to shape an agenda for the nation or through reform associations targeting a particular social evil.Although not all evangelicals agreed about politics or even about what needed reform, religion was the lens through which they viewed events and sought change. The separation of Church and State also had a significant effect. The absence of a state church meant that in America many sects would flourish. And since most churches and religious groups have been interested in maintaining their own orphanages, hospitals, aid societies, and other welfare institutions, these have abounded in America. Furthermore, the long experience of promoting social welfare through these and other voluntary associations may have led Americans to feel that there was unique value in such private operations (Trattner, p. 42).Lord Bryce student of American affairs in 1888 observed: In the works of active benevolence no country has surpassed, perhaps none has equaled, the United States. Not only are the sums collected for all sorts of philanthropic purposes larger relatively to the wealth of Americans than in any European country, but the amount of personal effort devoted to them seem to a European visitor to exceed what he knows at home (Trattner, p. 42). The Ramifications of the Separation of Church and State on America today Where does the debate begin? Since Jesus arrived in world history, the powers that be were either honored or threatened by his presence, though wise men from the east worshiped him, King Herod sought to have him killed.Jesus taught his disciples a principle that is compatible to the a separation of church and state: â€Å"to render unto Caesar the things that are Caesar’s and unto God the things that are God’s †(Matthew 22:15). The ruling authority of the Jews were at odds with Jesus. The S anhedrin instigate false charges to commence the greatest trial of all history where Jesus was asked by Pontius Pilate ‘what is truth’ and though innocent he was condemned and executed by Roman crucifixion. A period of martyrdom and persecutions followed but the church continues to multiply until Emperor Constantine sees opportunity to unite his kingdom under the banner of the Cross and declared the Church to be the religion of the Roman Empire. Christendom as political authority is not immune from corruption.The church splits East (Greek) and West (Latin) followed by the reformation, centuries are characterized by periods of turmoil, civil strife, imperial conquest, witch hunts, wars of religion and persecutions, generated in large part by established churches determined to maintain their absolute political and religious supremacy. â€Å"With the power of government supporting them, at various times and places, Catholics had persecuted Protestants, Protestants had per secuted Catholics, Protestant sects had persecuted other Protestant sects, Catholics of one shade of belief had persecuted Catholics of another shade of belief, and all of these had from time to time persecuted Jews† (Everson case).Protestants and Catholics denounced and persecuted each other as heretics and followers of Satan. Settlers in American Colonies Early settlers came from Europe to the colonies of America to escape the bondage of laws which compelled them to support and attend government-favored churches. In efforts to force loyalty to whatever religious group happened to be on top and in league with the government people could be put in jail for speaking disrespectfully of the views of ministers of government-established churches, non-attendance at those churches, expressions of nonbelief in their doctrines, and failure to pay taxes and tithes to support them, fined, cruelly tortured, and killed. All publications, whether pamphlets or scholarly volumes, were subject to prior censorship by both church and state, often working hand in hand† (Redmond Lecture Two)(Macaulay, 320-22). Any serious student of history particularly Church history, will no doubt come to the conclusion that it is not workable when the state is running the church nor is it workable when the church is running the state. There are churches with traditions and views on both sides of the issue. Confusion about separation of church and state involves, in part, confusion about definitions, unreasonable expectations and unfounded fears. For example there is more clarity when we distinguish between religion and morality in civil terms.The domain of religion involves duty to God. How could civil law make a ruling on a contract with God as a party? Clearly there is no jurisdiction over the unseen eternal God but rather God does have authority over His creation. Morality involves our duty to one another and is within the jurisdiction of the civil courts. Our lawmakers usurp God ’s sovereign authority if they presume to tell people how, when, or if to worship — that would be legislating religion. But lawmakers are obliged to inform people how they should treat one another— that’s legislating morality. There is some overlap as in the great love command God tells us to love him and love one another as we love ourselves.And likewise in the law of the land, the fact is that contrary to popular opinion, all laws legislate morality in that set out what is morally right and wrong, and every law legally declares a behavior legal/acceptable/right and its opposite illegal/ not acceptable/ wrong. Although there are Christians on both sides of the question of church v. state, the underlying concern is not whether we as a people can elect representatives to legislate morality but rather the underlying concern is: â€Å"Whose morality should we legislate? † Rule of Law Certainly, in a representative democratic constitutional republic, i t is impossible to sustain a cohesive rule of law if each individual is permitted to tailor design their own personal preference for what constitutes morality. In the Declaration of Independence and the Constitution, the founders perhaps anticipated this dynamic.It should not be my morality that gets legislated or yours or one that is continually redefined and reinvented, but rather the one that is â€Å"self-evident† because it has been endowed on us by our Creator. † When part of the â€Å"Laws of Nature,† we only hurt ourselves and others by suppressing those truths so we can do what we want. Just as there is Social Darwinism there is also a legal Darwinism. Throughout Western history until the second half of the nineteenth century, the idea of a higher moral law dominated European and American law. This mainstream tradition lasted as the main school of legal thought until the rise of evolutionary thinking in the nineteenth century. In particular, the idea tha t human law must be subject to some objective moral standards tarted to be more deeply challenged when Darwin’s theory of biological evolution was interpreted as implying the non-existence of God and accordingly, of God-given law and rights (http://creation. com/evolutionary-legal-theories). Marriage as an Example of Moral Law For a thousands of years, we have legislated the self-evident truth that men are meant for women. Now suddenly homosexuals—long critical of conservatives for trying to â€Å"legislate morality†Ã¢â‚¬â€are trying to legislate their own morality in the form of same-sex marriage. They want to ignore self-evident truths and impose their own invented morality on the entire country. The Defense of Marriage Act is passed and upheld on appeal but then not honored by the President but rather he profers a different view of marriage.These conflicts of law are generating a confused moral fabric of cases, law, tradition and belief without any authority adequately endowed with sufficient credibility to serve as the premier lawgiver. For Congress and States the question is this: Should they continue to legislate the inherited morality that nurtures the next generation (natural marriage), or the invented one that entices it to destruction (same-sex marriage)? Some states come down without wavering, some waver. The answer used to be considered to be self-evident. To aid in their analysis the Supreme Court has constructed a legal principle that the Constitution requires a strict separation of church and state.The concept of separation should not be construed as mutual exclusivity as a first step in a divorce process, not ‘freedom from religion’ but rather in the giving of ample space to thrive as separate but equal partners in ‘freedom of religion’. Churches and the Bible teach that murder, rape, and child abuse are wrong, and no one says laws prohibiting such acts are a violation of the â€Å"separation of church and state. † In fact, if the government could not pass laws consistent with church or biblical teachings, then all criminal laws would have to be overturned because they are all in some way consistent with at least one of the Ten Commandments as standards of ethical values. With respect to this issue of marriage for example, there are churches on both sides of this issue.In other words,  some churches actually support same-sex marriage. So if there is a strict separation of church and state, then one position should prevent the converse. If one cannot put male-female marriage forward then one shouldn’t be able to put the pro-same-sex marriage position into law either, right? The revolutionary settlement ultimately promoted the radical idea that the church and state ought to be separated. Prior to 1776, Rhode Island, New Jersey, Pennsylvania, and Delaware had allowed full religious liberty. They had done so because local diversity made any other policy impossibl e or because of an ideological commitment to religious freedom.Other colonies followed the more common practice in Europe, with established churches endorsed by the government and supported by public taxes. Although civil authorities grudgingly tolerated â€Å"dissenters† such as Methodists and Baptists in those colonies,, their numbers were growing rapidly. On the eve of the Revolution, they noisily pressed their case for full religious liberty. With independence, pressure built for severing all ties between church and state. Isaac Backus, the most outspoken of New England’s Baptists, protested that â€Å"many, who are filling the nation with the cry of liberty and against oppressors are at the same time themselves violating that dearest of all rights, liberty or conscience. Such arguments were strengthened by the belief that throughout history, alliances between government and church authorities had brought religious oppression, and that voluntary choice was the onl y safe basis for religious association. In New England, Congregationalists fought to preserve their long established privileges. To separate church and state, they argued, was to risk infidelity and disorder. Massachusett’s 1780 constitution guaranteed everyone the right to worship God â€Å"in the manner and season most agreeable to the dictates of his own conscience. † But it also empowered the legislature to require towns to tax their residents to support local ministers.Backus argued that official support should be ended completely â€Å"religious toleration,† he insisted, fell far short of true religious freedom. Not until 1833 were laws linking church and state finally repealed in Massachusetts (Nash, 192). In Virginia, Baptists pressed their cause against the Protestant Episcopal Church, successor to the Church of England. The adoption in 1786 of Thomas Jefferson’s Bill for Establishing Religious Freedom, rejecting all connections between church an d state and removing all religious tests for public office, decisively settled the issue. Three years later, that statute served as a model for the First Amendment to the new federal Constitution. But even the most ardent supporters of religious freedom were not prepared to extend it universally.The wartime alliance with Catholic France together with Congressional efforts, to entice Catholic settlers in Quebec to join the resistance against Britain had weakened long- established prejudices. Still, anti-Catholic biases remained strong, especially in New England. The people of Northbridge, Massachusetts, wanted to exclude â€Å"Roman Catholics, pagons, or Mahomitents† from public office. The legal separation of church and state did not end religious discrimination , but it implanted the principle of religious freedom firmly in American law. | Originally, the First Amendment applied only to the federal government. A number of the states effectively had established churches  wh en the First Amendment was ratified, with some remaining into the early nineteenth century.In the United States, the controversial topic of the interrelationship between church and state is set forth in a legal conceptual framework as well as an unwritten tradition of mutual consensus and understanding between the Church and State both on a federal as well as a state and local level. Following the passage of the Thirteenth to Fifteenth Amendments to the Constitution at the end of the Civil War, the Supreme Court would hear hundreds of cases involving conflicts over the constitutionality of laws passed by the states. The decisions in these cases were often criticized as resulting more from the biases of the individual Justices than the applicable rule of law or constitutional duty to protect individual rights. In 1947, in the case Everson v.Board of Education, Supreme Court by Justice Black ruled that the Establishment Clause of the First Amendment erected a, â€Å"wall of separatio n between church and state† which the Court found means that the government cannot participate in the affairs of a religious group, set up a church, aid or prefer one religion over another, or aid or prefer religion over non-religion. That wall must be kept high and impregnable. We could not approve the slightest breach. † The â€Å"separation of church and state† phrase which they invoked, and which has today become so familiar, was taken from an exchange of letters between President Thomas Jefferson and the Baptist Association of Danbury, Connecticut, shortly after Jefferson became President which we will consider further. First we must glean the premier casselaw on topic and Everson v. Board of Education, 330 U. S. 1 (1947) was landmark decision of the United States Supreme Court which applied the Establishment Clause in the country's Bill of Rights to State law. Prior to this decision the First Amendment words, â€Å"Congress shall make no law respecting an e stablishment of religion† imposed limits only on the federal government, while many states continued to grant certain religious denominations legislative or effective privileges. This was the first Supreme Court case incorporating the Establishment Clause of the First Amendment as binding upon the states through the Due Process Clause of the Fourteenth Amendment. The decision in Everson marked a turning point in the interpretation and application of disestablishment law in the modern era.The case was brought by a New Jersey taxpayer against a tax funded school district that provided reimbursement to parents of both public and private schooled children taking the public transportation system to school. The taxpayer contended that reimbursement given for children attending private religious schools violated the constitutional prohibition against state support of religion, and the taking of taxpayers' money to do so violated the constitution's Due Process Clause. The Justices wer e split over the question whether the New Jersey policy constituted support of religion, with the majority concluding these reimbursements were â€Å"separate and so indisputably marked off from the religious function† that they did not violate the constitution.However, both affirming and dissenting Justices were decisive that the Constitution required a sharp separation between government and religion and their strongly worded opinions paved the way to a series of later court decisions that taken together brought about profound changes in legislation, public education, and other policies involving matters of religion. Both Justice Hugo Black's majority opinion and Justice Wiley Rutledge's dissenting opinion defined the First Amendment religious clause in terms of a â€Å"wall of separation between church and state†. After repealing a former ban, a New Jersey law authorized payment by local school boards of the costs of transportation to and from schools – inclu ding private schools.Of the private schools that benefited from this policy, 96% were parochial Catholic schools. Arch R. Everson, a taxpayer in Ewing Township, filed a lawsuit alleging that this indirect aid to religion through the mechanism of reimbursing parents and students for costs incurred as a result of attending religious schools violated both the New Jersey state constitution and the First Amendment. After a loss in the New Jersey Court of Errors and Appeals, then the state's highest court, Everson appealed to the U. S. Supreme Court on purely federal constitutional grounds. Arguments were heard on November 20, 1946. The 5-4 decision was handed down on February 10, 1947.The Court, through Justice Hugo Black, ruled that the state bill was constitutionally permissible because the reimbursements were offered to all students regardless of religion and because the payments were made to parents and not any religious institution. Perhaps as important as the actual outcome, though , was the interpretation given by the entire Court to the Establishment Clause. It reflected a broad interpretation of the Clause that was to guide the Court's decisions for decades to come. It was not until the twentieth century that the  Supreme Court  began to interpret the Establishment and Free Exercise Clauses in such a manner as to restrict the promotion of religion by the states. In the Board of Education of Kiryas Joel Village School District v.Grumet (1994), Justice  David Souter, writing for the majority, concluded that â€Å"government should not prefer one religion to another, or religion to  irreligion. † Documents consistently cited by the Supreme Court Justices were the Memorial and Remonstrance by James Madison and an Act Establishing Religious Freedom by Thomas Jefferson. The case of Cantwell v. Connecticut (1940) for the first time in the nation’s history determined that the Amendment’s religion clauses apply to state and local laws. C antwell employed what has come to be labeled the incorporation doctrine. Using this doctrine, the justices in Cantwell found in favor of extending free exercise protection to members of the Jehovah’s Witnesses in Connecticut.Justice Roberts wrote, â€Å"The Fourteenth Amendment has rendered the legislatures of the states as incompetent as Congress to enact such laws. † A few months later in Minersville v. Gobitis, the court determined that even with the incorporation doctrine Jehovah’s Witnesses were not protected from disciplinary action when they abstained from pledging allegiance to the flag in public school ceremonies. Then, three years later with two new justices appointed by President Franklin Roosevelt the court reversed itself in its decision in West Virginia v. Barnette. This was the first in a long line of cases in which the court so fashioned the free exercise clause of the First Amendment. Justice Robert Jackson writing for he majority concluded â₠¬Å"If there is any star in our constitutional constellation, it is that no official, high or petty, can prescribe what shall be orthodox in politics, nationalism, religion, or other matters of opinion or force citizens to confess by word or act their faith therein. If there are any circumstances which permit an exception, they do not now occur to us. † In 1948 Justice Hugo Black in the case of McCollum v. Board of Education, drawing upon the historical reasoning in Everson v. Board of Education, the Court acted to apply the establishment clause to declare unconstitutional an Illinois State law that permitted religious groups to use public school classrooms during school hours to teach religion. These two watershed decisions have proven remarkably resilient as guideposts for cases that have followed.In the building of case precedents the judges have relied heavily upon the actions and words of two of the nation’s founders, James Madison and Thomas Jefferson. The focus ha s been upon Madison’s role in wording the Virginia Declaration of Rights of 1776 concerning â€Å"free exercise,† his critical involvement in the passage of Jefferson’s Bill of Establishing Religious Freedom in Virginia in 1785-86, and his leadership in pressing for adoption of the religion clauses in the First Amendment to the Constitution. The Court has consistently offered opinions which have been tied to Jefferson’s 1802 letter to the Danbury Baptist Association in which he affirmed that the religion clauses built â€Å" a wall of separation between church and state. â€Å"The ‘establishment of religion' clause of the First Amendment means at least this: Neither a state nor the Federal Government can set up a church. Neither can pass laws which aid one religion, aid all religions or prefer one religion over another. Neither can force nor influence a person to go to or to remain away from church against his will or force him to profess a belief or disbelief in any religion. No person can be punished for entertaining or professing religious beliefs or disbeliefs, for church attendance or non-attendance. No tax in any amount, large or small, can be levied to support any religious activities or institutions, whatever they may be called, or whatever form they may adopt to teach or practice religion.Neither a state nor the Federal Government can, openly or secretly, participate in the affairs of any religious organizations or groups and vice versa. In the words of Jefferson, the clause against establishment of religion by law was intended to erect ‘a wall of separation between Church and State. ‘† (330 U. S. 1, 15-16). Justice Wiley Rutledge argued that: † When the funds used were raised by taxation, the Court does not dispute nor could it that their use does in fact give aid and encouragement to religious instruction. It only concludes that this aid is not ‘support' in law. But Madison and Jeffer son were concerned with aid and support in fact not as a legal conclusion ‘entangled in precedents. In this case, parents pay money to send their children to parochial schools and funds raised by taxation are used to reimburse them. This not only helps the children to get to school and the parents to send them. It aids them in a substantial way to get the very thing which they are sent to the particular school to secure, namely, religious training and teaching. † (330 U. S. 1, 45). Having invoked Thomas Jefferson's metaphor of the wall of separation in the Everson decision, the lawmakers and courts have struggled how to balance governments' dual duty to satisfy both the non-establishment clause and the free exercise clause contained in the language of the amendment.The majority and dissenting Justices in Everson split over this very question, with Rutledge in the minority by insisting that the Constitution forbids â€Å"every form of public aid or support for religionâ € . Principle and Rule of Law frequently applied in Court precedent is found in the case of Kedroff v. St. Nicholas Cathedral, 344 U. S. 94 – (1952) Its ruling is summed up in these words: ‘In this country the full and free right to entertain any religious belief, to practice any religious principle, and to teach any religious doctrine which does not violate the laws of morality and property, and which does not infringe personal rights, is conceded to all. The law knows no heresy, and is committed to the support of no dogma, the establishment of no sect.The right to organize voluntary religious associations to assist in the expression and dissemination of any religious doctrine, and to create tribunals for the decision of controverted questions of faith within the association, and for the ecclesiastical government of all the individual members, congregations, and officers within the general association, is unquestioned. All who unite themselves to such a body do so w ith an implied consent to this government, and are bound to submit to it. But it would be a vain consent and would lead to the total subversion of such religious bodies, if any one aggrieved by one of their decisions could appeal to the secular courts and have them reversed.It is of the essence of these religious unions, and of their right to establish tribunals for the decision of questions arising among themselves, that those decisions should be binding in all cases of ecclesiastical cognizance, subject only to such appeals as the organism itself provides for. ‘ (13 Wall. at pages 728 729, 20 L. Ed. 666). The election of Jefferson – America's first Anti-Federalist President – elated many Baptists since that denomination, by-and-large, was also strongly Anti-Federalist. This political disposition of the Baptists was understandable, for from the early settlement of Rhode Island in the 1630s to the time of the federal Constitution in the 1780s, the Baptists had of ten found themselves suffering from the centralization of power.Consequently, now having a President who not only had championed the rights of Baptists in Virginia but who also had advocated clear limits on the centralization of government powers, the Danbury Baptists wrote Jefferson a letter of praise on October 7, 1801, telling him: Among the many millions in America and Europe who rejoice in your election to office, we embrace the first opportunity . . . to express our great satisfaction in your appointment to the Chief Magistracy in the United States. . . . We have reason to believe that America's God has raised you up to fill the Chair of State out of that goodwill which He bears to the millions which you preside over. May God strengthen you for the arduous task which providence and the voice of the people have called you. . . And may the Lord preserve you safe from every evil and bring you at last to his Heavenly Kingdom through Jesus Christ our Glorious Mediator. However, in that same letter of congratulations, the Baptists also expressed to Jefferson their grave concern over the entire concept of the First Amendment, including of its guarantee for â€Å"the free exercise of religion†: Our sentiments are uniformly on the side of religious liberty: that religion is at all times and places a matter between God and individuals, that no man ought to suffer in name, person, or effects on account of his religious opinions, and that the legitimate power of civil government extends no further than to punish the man who works ill to his neighbor. But sir, our constitution of government is not specific. . . Therefore what religious privileges we enjoy (as a minor part of the State) we enjoy as favors granted, and not as inalienable rights. In short, the inclusion of protection for the â€Å"free exercise of religion† in the constitution suggested to the Danbury Baptists that the right of religious expression was government-given (thus alienable) rat her than God-given (hence inalienable), and that therefore the government might someday attempt to regulate religious expression. This was a possibility to which they strenuously objected-unless, as they had explained, someone's religious practice caused him to â€Å"work ill to his neighbor. † Jefferson understood their concern; it was also his own.In fact, he made numerous declarations about the constitutional inability of the federal government to regulate, restrict, or interfere with religious expression. For example: No power over the freedom of religion . . . is delegated to the United States by the Constitution. Kentucky Resolution, 1798  (Foley, p. 179). Wesley does not endorse the â€Å"separation of church and state,† understood in the Jeffersonian sense. He expects the churches and the government to cooperate with one another. This follows from his firm faith in â€Å"particular providence† and from his conception of the state. All of creation, incl uding the realm of politics, is governed by Divine Providence.God rules the nations according to that â€Å"higher law† which expresses his very nature. He causes the righteous nations to flourish and the disobedient ones to decline and decay. Victory, peace, and bountiful provisions are signs that a nation's conduct is pleasing to God. Adversity, such as defeat in battle or drought and famine, is a mark of his indignation. Disaster is also a warning and a call to repentance. The wicked nation which heeds the call and turns from its sinful ways will live. The obdurate will continue to suffer. In matters of religion, I have considered that its free exercise is placed by the Constitution independent of the powers of the general federal government.Second Inaugural Address, 18054. Annals of the Congress of the United States published by Authority of Congress, 1899, Vol. I, p. 379, March 4, 1805. Our excellent Constitution . . . has not placed our religious rights under the power of any public functionary. Letter to the Methodist Episcopal Church, 1808 (Thomas Jefferson,  Writings of Thomas Jefferson,  Albert Ellery Bergh, editor (Washington D. C. : The Thomas Jefferson Memorial Association, 1904), Vol. I, p. 379, March 4, 1805. I consider the government of the United States as interdicted (prohibited) by the Constitution from intermeddling with religious institutions . . . or exercises. Letter to Samuel Millar, 1808.Thomas Jefferson,  Memoir, Correspondence, and Miscellanies, From the Papers of Thomas Jefferson,  Thomas Jefferson Randolph, editor (Boston: Gray and Bowen, 1830), Vol. IV, pp. 103-104, to the Rev. Samuel Millar on January 23, 1808. Thomas Jefferson,  Memoir, Correspondence, and Miscellanies, From the Papers of Thomas Jefferson,  Thomas Jefferson Randolph, editor (Boston: Gray and Bowen, 1830), Vol. IV, pp. 103-104, to the Rev. Samuel Millar on January 23, 1808. Jefferson believed that the government was to be powerless to interfere with religious expressions for a very simple reason: he had long witnessed the unhealthy tendency of government to encroach upon the free exercise of religion.As he explained to Noah Webster: It had become an universal and almost uncontroverted position in the several States that the purposes of society do not require a surrender of all our rights to our ordinary governors . . . and which experience has nevertheless proved the government will be constantly encroaching on if submitted to them; that there are also certain fences which experience has proved peculiarly efficacious against wrong and rarely obstructive of right, which yet the governing powers have ever shown a disposition to weaken and remove. Of the first kind, for instance, is freedom of religion. (Jefferson,  Writings, Vol. VIII, p. 112-113, to Noah Webster on December 4, 1790). Thomas Jefferson had no intention of allowing the government to limit, restrict, regulate, or interfere with public religious practices.He believed, along with the other Founders, that the First Amendment had been enacted  only  to prevent the federal establishment of a national denomination – a fact he made clear in a letter to fellow-signer of the Declaration of Independence Benjamin Rush: The clause of the Constitution which, while it secured the freedom of the press, covered also the freedom of religion, had given to the clergy a very favorite hope of obtaining an establishment of a particular form of Christianity through the United States; and as every sect believes its own form the true one, every one perhaps hoped for his own, but especially the Episcopalians and Congregationalists.The returning good sense of our country threatens abortion to their hopes and they believe that any portion of power confided to me will be exerted in opposition to their schemes. And they believe rightly. (Jefferson, Writings, Vol. III, p. 441, to Benjamin Rush on September 23, 1800). President Jefferson was committed to p reventing the establishment of a particular form of Christianity whether Episcopalians or Congregationalists or any other as is evidenced in his reply to the Danbury Baptists on January 1, 1802 with assurance that they did not need to be afraid because their free exercise of religion would  never  be interfered with by the federal government.Gentlemen, – The affectionate sentiments of esteem and approbation which you are so good as to express towards me on behalf of the Danbury Baptist Association give me the highest satisfaction. . . . Believing with you that religion is a matter which lies solely between man and his God; that he owes account to none other for his faith or his worship; that the legislative powers of government reach actions only and not opinions, I contemplate with sovereign reverence that act of the whole American people which declared that their legislature should â€Å"make no law respecting an establishment of religion or prohibiting the free exerci se thereof,† thus building a wall of separation between Church and State.Adhering to this expression of the supreme will of the nation in behalf of the rights of conscience, I shall see with sincere satisfaction the progress of those sentiments which tend to restore to man all his natural rights, convinced he has no natural right in opposition to his social duties. I reciprocate your kind prayers for the protection and blessing of the common Father and Creator of man, and tender you for yourselves and your religious association assurances of my high respect and esteem. [9] 9. Jefferson,  Writings, Vol. XVI, pp. 281-282, to the Danbury Baptist Association on January 1, 1802. Jefferson's reference to â€Å"natural rights† invoked an important legal phrase which was part of the rhetoric of that day and which reaffirmed his belief that religious liberties were inalienable rights. While the phrase â€Å"natural rights† communicated much to people then, to most citiz ens today those words mean little.By definition, â€Å"natural rights† included â€Å"that which the Books of the Law and the Gospel do contain. †Ã‚  [10]  That is, â€Å"natural rights† incorporated what God Himself had guaranteed to man in the Scriptures. Thus, when Jefferson assured the Baptists that by following their â€Å"natural rights† they would violate  no  social duty, he was affirming to them that the free exercise of religion was their inalienable God-given right and therefore was protected from federal regulation or interference. So clearly did Jefferson understand the Source of America's inalienable rights that he even doubted whether America could survive if we ever lost that knowledge.He queried: And can the liberties of a nation be thought secure if we have lost the only firm basis, a conviction in the minds of the people that these liberties are the gift of God? That they are not to be violated but with His wrath? Jefferson believ ed that God, not government, was the Author and Source of our rights and that the government, therefore, was to be prevented from interference with those rights. Very simply, the â€Å"fence† of the Webster letter and the â€Å"wall† of the Danbury letter were  not  to limit religious activities in public; rather they were to limit the power of the government to prohibit or interfere with those expressions. Earlier courts long understood Jefferson's intent. In fact, when Jefferson's letter was invoked by the Supreme Court (only twice prior to the 1947  Everson  case – the Reynolds v.United States  case in 1878), unlike today's Courts which publish only his eight-word separation phrase, that earlier Court published Jefferson's entire letter and then concluded: Coming as this does from an acknowledged leader of the advocates of the measure, it [Jefferson's letter] may be accepted almost as an authoritative declaration of the scope and effect of the Amend ment thus secured. Congress  was deprived of all  legislative power  over mere [religious] opinion, but was left free to  reach actions which were in violation of social duties or subversive of good order. (Thomas Jefferson,  Notes on the State of Virginia  (Philadelphia: Matthew Carey, 1794), Query XVIII, p. 237).That Court then succinctly summarized Jefferson's intent for â€Å"separation of church and state†: The rightful purposes of civil government are for its officers to interfere when principles break out into overt acts against peace and good order. In this . . . is found the true distinction between what properly belongs to the church and what to the State. With this even the Baptists had agreed; for while wanting to see the government prohibited from interfering with or limiting religious activities, they also had declared it a legitimate function of government â€Å"to punish the man who works ill to his neighbor. † That Court, therefore, and oth ers (for example,  Commonwealth v. Nesbit  and Lindenmuller v. The People), identified actions into which – if perpetrated in the name of religion – the government  did  have legitimate reason to intrude.Those activities included human sacrifice, polygamy, bigamy, concubinage, incest, infanticide, parricide, advocation and promotion of immorality, etc. Such acts, even if perpetrated in the name of religion, would be stopped by the government since, as the Court had explained, they were â€Å"subversive of good order† and were â€Å"overt acts against peace. † However, the government was  never  to interfere with  traditional  religious practices outlined in â€Å"the Books of the Law and the Gospel† – whether public prayer, the use of the Scriptures, public acknowledgements of God, etc. Therefore, if Jefferson's letter is to be used today, let its context be clearly given – as in previous years.Furthermore, earlier Cou rts had always viewed Jefferson's Danbury letter for just what it was: a  personal,  private  letter to a specific group. There is probably no other instance in America's history where words spoken by a single individual in a private letter – words clearly divorced from their context – have become the sole authorization for a national policy. Finally, Jefferson's Danbury letter should never be invoked as a stand-alone document. A proper analysis of Jefferson's views must include his numerous other statements on the First Amendment. Jefferson also declared that the â€Å"power to prescribe any religious exercise. . . .  must rest with the States†.Nevertheless, the federal courts ignore this succinct declaration and choose rather to misuse his separation phrase to strike down scores of State laws which encourage or facilitate public religious expressions. Such rulings against State laws are a direct violation of the words and intent of the very one from wh om the courts claim to derive their policy. One further note should be made about the now infamous â€Å"separation† dogma. The Congressional Records  from June 7 to September 25, 1789, record the months of discussions and debates of the ninety Founding Fathers who framed the First Amendment. Significantly, not only was Thomas Jefferson not one of those ninety who framed the First Amendment, but also, during those debates not one of those ninety Framers ever mentioned the phrase â€Å"separation of church and state. It seems logical that if this had been the intent for the First Amendment – as is so frequently asserted-then at least one of those ninety who framed the Amendment would have mentioned that phrase; none did. In summary, the â€Å"separation† phrase so frequently invoked today was rarely mentioned by any of the Founders; and even Jefferson's explanation of his phrase is diametrically opposed to the manner in which courts apply it today. In its firs t hundred years then of the United States, the Supreme Court interpreted the Constitution's Bill of Rights as a limit on federal government and considered the states bound only by those rights granted to its citizens by their own state constitutions.Because the federal laws during this period were remote influences at most on the personal affairs of its citizens, minimal attention was paid by the Court to how those provisions in the federal Bill of Rights were to be interpreted. Separation of church and state currently means almost exactly the opposite of what it originally meant. The First Amendment affords freedom of religion, not freedom from religion. â€Å"The U. S. Senate opens its sessions with prayer by an official chaplain. While that may be good in the eyes of most religious people in the United States, it does little to change the fundamentally secular process by which Congress works. At no point may a member’s beliefs intrude into the deliberations in an overt wa y—even if they happen to represent the religious sentiments of the majority of a legislator’s constituents.Privatization of religion goes far beyond the so-called separation of church and state, which is also a manifestation of secularity. In almost every sphere of public policy-making, from the highest echelons of government down to the local neighborhood arts council, it is considered inappropriate to raise the issue of God seriously† (Spickard, p. 344). In the modern Western world most people’s lives are much more this worldly in the sense that the solutions to life’s problems, both large and small, are sought in technology and psychology. Even many Christians see the world as a godless place in the sense that God is relegated to heaven and a few sacred places, such as the church.The world goes on, and life can be lived quite successfully, with or without God. The seeds of this secularity were sown in the unbelievably destructive religious confli ct of the 17th century known as the Thirty Years War. This war was partly a result of the Reformation, and it turned Europe into a slaughterhouse. Some scholars estimate that one-half the population of the continent was killed, starved, or sent into exile during the war. As a result, many of the educated elite of Europe became disillusioned with revealed religion and dogmatic theology. They concluded that the religious conflicts of the Reformation gave rise to the chaos and destruction.Enlightenment thinkers believed that if society was to avoid such wars in the future and recover unity, it must base its common life and public institutions on purely nonsectarian, rational philosophies. Critics of traditional Christianity, such as Francois Marie de Voltaire (1694-1778), heaped literary scorn on the kind of dogmatic arguments and sectarian power- struggles that led to the religious wars of the 17th century. Volaire promoted a kind of generic religion based on universal religious truth s and moral ideas he called theism. This natural religion, based entirely on reason, came also to be known as deism – belief in a god stripped of all supernaturally revealed doctrines and elaborate trappings of the formal church.Many men of letters and leaders of European and American culture adopted this secularized religion during the 18th century and attempted to make it part of the basis for a new order in Western society (Spickard). John Wesley was of the opinion that the paramount duty of any government is to hold in check the wild and rebellious human beings who live under its rule. God has authorized the use of force to preserve the peace and punish the disobedient. But Wesley knew that force has its limits, especially since coercion injures the body but leaves the mind unchanged. If the nation is to be truly righteous, the citizens must acquire the habits of deference and compliance, and learn to control their appetites and feelings.Governments depend upon other soci al institutions, including the churches, to form these habits and impart these lessons. The state, in turn, protects the churches and supports their efforts, for example, by granting them tax relief. Wesley to which the Church of the Nazarene agrees taught the Methodists to be loyal citizens and to obey the laws of the land. The commission of a crime would cost a man his membership in a Methodist society, it is on an individual case basis in the Church of the Nazarene. The Continental Congress, followed by the First Federal Congress, said that â€Å"religion, morality, and knowledge† are â€Å"necessary to good government and the happiness of mankind. Wesley would endorse this statement wholeheartedly. Because caselaw depends upon prior legal cases that bind the next court in a similar fact pattern to the extent a reasonable person would expect to be fair and equal from court to court, provided the cases are from a higher court or within the same jurisdiction, then caselaw t ends to erode over time fragmenting into different exceptions in a kind in a way that is more consistent with Darwinian influences of the rational mind of the human animal as if in some long term legal experiment with a hypothesis being tested and retested each time further restricting the freedom at hand in this case religious liberty. Another factor to consider is that many secular humanists are so anxious to erase Christianity altogether that they disregard the wall.The wall is supposed to work to protect religious express not to reduce it further and further until there is no public evidence of any faith expression. The constitutional clause is just as much that the government will not interfere and most early cases were from this side of the wall. Recently the caselaw has been from the other side that interprets every visible sign as ‘promoting’ religion whether a cross on the roadway, 1O Commandments on a classroom wall, a public nativity display, prayer in school , carrying a Bible, etc. When the moral majority and other Christian legal activism on social issues of abortion for example were fought so passionately, often the Christian activist forgot to be compassionate and let the cause get ahead of the Gospel.Legal activism has its appropriate arena. That arena is not carrying placards in front of an abortion clinic but rather offering options in an alternate social solution. That is not to say that the wall should not also at times be invisible in that sometimes a church ought to be available for a poll booth just as a courthouse should be open for a religious ceremony when the occasion warrants. In rendering to our government Caesar the things that are Caesars and to our God the things that are Gods’ –we have two allegiances that need not be conflicting, so that one can be both a patriotic American and entirely sanctified Christian devoted to God and country.This is the constitutional paradigm around which the walls of separ ation inform and lend moral ethical standards over time to caselaw so that it does not take that slippery downward Darwinian style erosion for lack of any absolute moral code. Separation of Church and State empowers both the Church and the State when properly so applied, it is not intended to be freedom from religion but freedom of religion just as one does not step into a church free from the country as if stepping into an embassy of a foreign territory. 25% of all quotes in documents of the founding fathers were from the Bible, they had no fear of the Bible or of the Church.The presence of a paid Chaplain is evidence as well that there was respect of the presence of God who could bless the work. At the present time the wall of separation still exists but it is being reassembled into a sledgehammer to hit away at the church. Christians need to love people but hold fast to the faith and stand resolved on the Word of God as authoritative law as much as the Constitution or any regulat ion of the State. ADDENDUM 1: Preconstituional Letters of Legal Reference establishing legislative history from which intent may be inferred: Letter of October 7, 1801, from Danbury (CT) Baptist Association to Thomas Jefferson, from the Thomas Jefferson Papers Manuscript Division, Library of Congress, Washington, D. C. The Jeffersonian Cyclopedia, John P.Foley, editor (New York: Funk & Wagnalls, 1900), p. 977; see also Documents of American History, Henry S. Cummager, editor (NY: Appleton-Century-Crofts, Inc. , 1948), p. 179. Annals of the Congress of the United States (Washington: Gales and Seaton, 1852, Eighth Congress, Second Session, p. 78, March 4, 1805; see also James D. Richardson, A Compilation of the Messages and Papers of the Presidents, 1789-1897 (Published by Authority of Congress, 1899), Vol. I, p. 379, March 4, 1805. Jefferson, Thomas. Writings of Thomas Jefferson, Albert Ellery Bergh, editor (Washington D. C. : The Thomas Jefferson Memorial Association, 1904), Vol. I, p. 379, March 4, 1805. Jefferson, Thomas.Memoir, Correspondence, and Miscellanies, From the Papers of Thomas Jefferson, Thomas Jefferson Randolph, editor (Boston: Gray and Bowen, 1830), Vol. IV, pp. 103-104, to the Rev. Samuel Millar on January 23, 1808. Jefferson, Writings, Vol. VIII, p. 112-113, to Noah Webster on December 4, 1790. Jefferson, Writings, Vol. III, p. 441, to Benjamin Rush on September 23, 1800. Jefferson, Writings, Vol. XVI, pp. 281-282, to the Danbury Baptist Association on January 1, 1802. Jefferson, Thomas. Notes on the State of Virginia (Philadelphia: Matthew Carey, 1794), Query XVIII, p. 237. ADDENDUM 2 United States First Amendment Caselaw Establishment ClausePublic funding Everson v. Board of Education 330 U. S. 1 (1947) McCollum v. Board of Education 333 U. S. 203 (1948) in this case the Supreme Court ruled that Illinois public school practice of allowing Protestant, R. C. and Jewish faith groups to give religious instruction to students during school at th e same time allowing others to opt out, was found to violate the First Amendment. Walz v. Tax Commission 397 US 664 (1970) The Court held that grants of tax exemption to religious organizations was far less of an involvement than would be created by taxation of churches, and the effect of the exemptions was thus not an excessive government entanglement with religion.The grant of a tax exemption was not sponsorship of the organizations because the government did not transfer part of its revenue to churches but simply abstained from demanding that the churches support the state. Lemon v. Kurtzman 403 US 602 (1971) The Court ruled that a Pennsylvania School Law to reimburse nonpublic mostly Catholic schools for the salaries of teachers who taught secular curriculum violated the Establishment Clause of the First Amendment. The Court's decision in this case established the â€Å"Lemon test† consisting of three prongs: (1) the government's action must have a secular legislative pur pose; (2) the government's action must not have the primary effect of either advancing or inhibiting religion; (3) the government's action must not result in an â€Å"excessive government entanglement† with religion.If any of these 3 prongs are violated, the government's action is deemed unconstitutional under the Establishment Clause of the First Amendment to the United States Constitution. Marsh v. Chambers 463 US 783 (1983) held government funding for chaplains was constitutional because of the â€Å"unique history† of the United States as demonstrated by the fact that three days before the ratification of the 1st Amendment, containing the Establishment clause, the federal legislature authorized hiring a chaplain for opening sessions with prayer. Board of Education of Kiryas Joel Village School District v. Grumet (1994) The court held that the creation of a school district designed to coincide with the neighborhood boundaries of a religious group constitutes an unco nstitutional aid to religion. Agostini v.Felton 521 US 203 (1997) In this case, the Court overruled a previous decision now finding that it was not a violation of the Establishment Clause of the First Amendment for a state-sponsored education initiative to allow public school teachers to instruct at religious schools, so long as the material was secular and neutral in nature and no â€Å"excessive entanglement† between government and religion was apparent. This case is noteworthy in a broader sense as a sign of evolving judicial standards surrounding the First Amendment, and the changes that have occurred in modern Establishment Clause jurisprudence. Mitchell v. Helms 530 US 793 (2000) The Court ruled that it was permissible for loans to be made to religious schools under Chapter 2 of the Education Consolidation and Improvement Act of 1981. The government may now provide aid to religious groups as long as such aid advances some legitimate non-religious purpose and is granted in the same manner to non-religious groups. Zelman v.Simmons-Harris 536 US 639 (2002) upheld school vouchers of Ohio under the Private Choice Test developed by the court, for a voucher program to be constitutional it must meet all of the following criteria: the program must have a valid secular purpose, aid must go to parents and not to the schools, a broad class of beneficiaries must be covered, the program must be neutral with respect to religion, and there must be adequate nonreligious options. Locke v. Davey 540 US 712 (2004) upheld the constitutionality of a Washington publicly funded scholarship program which excluded students pursuing a degree in theology. Arizona Christian School Tuition Organization v.Winn (2011) A group of Arizona taxpayers challenged a state law that provides tax credits to people who donate to school tuition organizations that in turn provide scholarships to students who want to attend private or religious schools. The Supreme Court found that any damage s or harm claimed by the taxpayers by virtue of simply being a taxpayer would be pure speculation because the issue at hand was a tax credit and not a government expenditure. Public displays: Lynch v. Donnelly (1984) County of Allegheny v. ACLU (1989) McCreary County v. ACLU of Kentucky (2005) Van Orden v. Perry (2005) School prayer:Zorach v. Clauson (1952) Engel v. Vitale (1962) Abington School District v. Schempp (1963) Stone v. Graham (1980) Wallace v. Jaffree (1985) Lee v.Weisman (1992) Santa Fe Independent School Dist. v. Doe (2000) Elk Grove Unified School District v. Newdow (2004) Creationism: Epperson v. Arkansas (1968) 393 U. S. 97 (1968), invalidated an Arkansas statute that prohibited the teaching of human evolution in the public schools. Edwards v. Aguillard (1987) Kitzmiller v. Dover Area School District (M. D. Pa. 2005). Works Cited Barton, David. The Separation of Church and State. 1st ed. Wallbuilders Press. 2007. Beail, Linda. Wesleyan or Fundamentalist? Political a nd Theological Stances of Nazarene Pastors. Association of Nazarene Sociologists and Researchers. Web.