How to write literature review for research paper
Tuesday, August 25, 2020
Wellness centers, health clubs, gyms and spas are Essay Example For Students
Wellbeing focuses, fitness centers, exercise centers and spas are Essay all devoted to by and large wellness and prosperity. All day every day, individuals the nation over partake in exercise schedules, heart stimulating exercise classes and different sorts of activities in any of these offices. In the Lafayette zone, three of the most famous wellness clubs to go to are Red Lerilles, Shades for ladies, and Our Lady of Lourdes Regional Medical Center. For this task every one of the three of these offices were reached for data with respect to a statement of purpose, work necessities and preparing. The statement of purpose for Shades for ladies is as per the following: WE ARE SHADES!! WE GENUINELY CARE ABOUT AND RESPECT OUR MEMBERS AND PLEDGE TO DO EVERYTHING POSSIBLE TO ENSURE THEIR SATISFACTION. WE HAVE FUN WORKING TOGETHER TO BE THE MOST KNOWLEDGEABLE, PRODUCTIVE, CARING TEAM IN THE HEALTH CLUB INDUSTRY. WE BLEND OUR TALENTS TO CONTINUALLY OFFER SUPERIOR SERVICE AT A VALUE UNMATCHED BY OUR COMPETITORS. WE WILL ALWAYS SHOW THAT WE ARE HAPPY AND STRIVE TO BE SATISFIED. WE WILL ADMIT AND LEARN FROM OUR MISTAKES AND CONTINUALLY STRIVE FOR IMPROVEMENT. With the end goal FOR US TO SUCCEED, WE WILL FUNCTION AS A TEAM AND UNDERSTAND EVERY MEMBER IS A VITAL PART. In the event that ONE PART FAILS, THE WHOLE TEAM WILL SUFFER. AS WE IMPRESS OUR MEMBERS BY HELPING THEM TO ACHIEVE AND MAINTAIN THEIR FITNESS GOALS, THEY WILL GROW TO TRUST US AND WILL BRING IN THEIR FRIENDS. THIS WILL INCREASE OUR PROFIT WHICH WILL INCREASE THE PROBABILITY OF OPENING UP NEW FACILITIES WITH NEW EQUIPMENT AND PROGRAMS TO BETTER SERVE OUR MEMBERS. There were three employment positions were inspected for their important abilities and instructive prerequisites while visiting Shades for Women. One of these positions was that of wellness executive. A portion of the prerequisites and aptitudes important to turn into a wellness executive are: a professional education mind major in active recuperation, practice physiology, kinesiology or sports medication, or some kind of wellbeing or exercise related field. Candidates should likewise have grown-up and youngster CPR affirmation, just as an intensive information on life systems, kinesiology and physical wellness preparing techniques and schedules, and nourishment and abstaining from excessive food intake strategies. The subsequent position analyzed was the meeting room where participation deals and data are accessible. So as to work in the banquet room, candidates must have an agreeable information on PC and sales register transactions, excellent relational abilities, and a general information on the office. Concerning a vocation in the nursery, the most significant prerequisites are the capacity to function admirably with youngsters just as having awesome time the board aptitudes. The expense for enrollment at Shades is a 200 dollars nonrefundable enlistment charge and an installment of forty-two dollars consistently there after for one year and thirty-six dollars for a long time. There is an extraordinary value plan for USL understudies, which drops the enrollment expense down to fifty dollars and a month to month charge of twenty-nine dollars. These costs incorporate full utilization of the office. The subsequent office explored was the exceptionally respected Red Lerilles. Reds is viewed as one the best exercise and wellness offices in the state, yet the country; anyway almost no data was given with respect to a statement of purpose or essential employment aptitudes for positions there. When one of the administrative staff was approached to deliver a statement of purpose, he couldn't do so answering, What are you discussing? When determined what precisely what was being asked of him, the director expressed, Oh, we dont have one. The activity positions being analyzed, much like at Shades, were close to home wellness coach, and administrative positions. It appears as if so as to acquire an administrative position, one should either work for the office for quite a while, or essentially outlast ones ancestor. With respect to the fitness coaches, some have gotten individual preparing confirmation, however some have not. .u92d1ceadac1ed00ba85e445756863c94 , .u92d1ceadac1ed00ba85e445756863c94 .postImageUrl , .u92d1ceadac1ed00ba85e445756863c94 .focused content region { min-stature: 80px; position: relative; } .u92d1ceadac1ed00ba85e445756863c94 , .u92d1ceadac1ed00ba85e445756863c94:hover , .u92d1ceadac1ed00ba85e445756863c94:visited , .u92d1ceadac1ed00ba85e445756863c94:active { border:0!important; } .u92d1ceadac1ed00ba85e445756863c94 .clearfix:after { content: ; show: table; clear: both; } .u92d1ceadac1ed00ba85e445756863c94 { show: square; progress: foundation shading 250ms; webkit-change: foundation shading 250ms; width: 100%; obscurity: 1; change: mistiness 250ms; webkit-progress: haziness 250ms; foundation shading: #95A5A6; } .u92d1ceadac1ed00ba85e445756863c94:active , .u92d1ceadac1ed00ba85e445756863c94:hover { darkness: 1; change: murkiness 250ms; webkit-change: obscurity 250ms; foundation shading: #2C3E50; } .u92d1ceadac1ed00ba85e445756863c94 .focused content territory { width: 100%; position: relati ve; } .u92d1ceadac1ed00ba85e445756863c94 .ctaText { fringe base: 0 strong #fff; shading: #2980B9; text dimension: 16px; textual style weight: intense; edge: 0; cushioning: 0; text-enrichment: underline; } .u92d1ceadac1ed00ba85e445756863c94 .postTitle { shading: #FFFFFF; text dimension: 16px; text style weight: 600; edge: 0; cushioning: 0; width: 100%; } .u92d1ceadac1ed00ba85e445756863c94 .ctaButton { foundation shading: #7F8C8D!important; shading: #2980B9; outskirt: none; outskirt range: 3px; box-shadow: none; text dimension: 14px; textual style weight: striking; line-tallness: 26px; moz-outskirt span: 3px; text-adjust: focus; text-embellishment: none; text-shadow: none; width: 80px; min-tallness: 80px; foundation: url(https://artscolumbia.org/wp-content/modules/intelly-related-posts/resources/pictures/straightforward arrow.png)no-rehash; position: supreme; right: 0; top: 0; } .u92d1ceadac1ed00ba85e445756863c94:hover .ctaButton { foundation shading: #34495E!important; } .u92d1ceadac 1ed00ba85e445756863c94 .focused content { show: table; stature: 80px; cushioning left: 18px; top: 0; } .u92d1ceadac1ed00ba85e445756863c94-content { show: table-cell; edge: 0; cushioning: 0; cushioning right: 108px; position: relative; vertical-adjust: center; width: 100%; } .u92d1ceadac1ed00ba85e445756863c94:after { content: ; show: square; clear: both; } READ: Remember the Titans Essay Those who are not affirmed have been working at Reds sufficiently long to have a decent understanding in regards to practices and the utilization of legitimate hardware for preparing somebody. Meeting room and nursery occupations have not set prerequisites, as they are prepared when employed. Enrollments to Reds are sold on a yearly premise. There are two sorts of participations accessible for procurement, the full compensation enrollment .
Saturday, August 22, 2020
Outsourcing free essay sample
Re-appropriating is subcontracting a help, for example, item plan or assembling, to an outsider organization. The choice whether to redistribute or to do in house is regularly founded on accomplishing a lower creation cost, utilizing accessible assets, concentrating vitality on the center abilities of a specific business, or simply utilizing work, capital, data innovation or land assets. It is basically a division of work. Redistributing turned out to be a piece of the business vocabulary during the 1980ââ¬â¢s. Innovative work The serious weights on firms to bring out new items at an ever quick pace to address advertise issues are expanding. All things considered, the weights on the RD office are expanding. So as to ease the weight, firms need to either expand RD spending plans or discover approaches to use the assets in an increasingly gainful manner. There are circumstances when a firm may consider redistributing a portion of its RD work to an agreement explore associations or colleges. We will compose a custom exposition test on Redistributing or on the other hand any comparative subject explicitly for you Don't WasteYour Time Recruit WRITER Just 13.90/page Reasons why a firm could consider re-appropriating are: â⬠¢ new item configuration doesn't work â⬠¢ venture time and cost invades â⬠¢ loss of key staff â⬠¢ serious reaction â⬠¢ issues of value/yield. The key drivers for RD re-appropriating are developing mass markets and accessibility of mastery in the field. In this specific situation, the two most crowded nations on the planet, China and India, give immense pools from which to discover ability. The two nations produce more than 200,000 designers and science graduates every year. Additionally the two nations are ease sourcing nations. Other vital drivers for re-appropriating RD are access to ability and protected innovation, filling holes in the capacities of the RD work, overseeing hazard better, diminishing an opportunity to market, and concentrating on the center capability or exercises of the firm Manufacturing Often organizations will create and showcase items yet leave the assembling to different organizations that represent considerable authority in it. In this way a production line can do fabricating for a few organizations and keep an enormous assembling plant working at about full limit when no individual agreement could legitimize the cost of keeping up the framework. A case of this would be Fabless semiconductor organizations which do structure and so on yet don't have their own, incredibly costly, creation offices. Different models would be organizations that represent considerable authority in the undertakings of securing parts, get together, QA, and so forth and market these aptitudes as their essential business to organizations that redistribute assembling to them. Data innovation field Outsourcing in the data innovation field has two implications. One is to commission the advancement of an application to another association, typically an organization that represents considerable authority in the improvement of this sort of use. The other is to employ the administrations of another organization to deal with all or parts of the administrations that in any case would be rendered by an IT unit of the association. The last idea probably wo exclude advancement of new applications. Purposes behind redistributing Organizations that re-appropriate are trying to acknowledge advantages or address the accompanying issues: â⬠¢ Cost reserve funds. The bringing down of the general expense of the support of the business. This will include lessening the extension, characterizing quality levels, re-estimating, re-arrangement, cost re-organizing. Access to bring down cost economies through off shoring called work exchange created by the compensation hole among industrialized and creating countries. â⬠¢ Focus on Core Business. Assets (for instance speculation, individuals, and foundation) are centered around building up the center business. For instance regularly associations re-appropriate their IT backing to particular IT administrations organizations. â⬠¢ Cost rebuilding. Working influence is a measure that thinks about fixed expenses to variable expenses. Redistributing changes the equalization of this proportion by offering a move from fixed to variable expense and furthermore by making variable costs increasingly unsurprising. â⬠¢ Improve quality. Accomplish a stage change in quality through contracting out the administration with another assistance level understanding. â⬠¢ Knowledge. Access to protected innovation and more extensive experience and information. â⬠¢ Contract. Administrations will be furnished to a legitimately restricting agreement with budgetary punishments and lawful change. This isn't the situation with inward administrations. â⬠¢ Operational mastery. Access to operational best practice that would be excessively troublesome or tedious to create in-house. â⬠¢ Access to ability. Access to a bigger ability pool and a supportable wellspring of aptitudes, specifically in science and building. â⬠¢ Capacity the executives. An improved strategy for limit the executives of administrations and innovation where the hazard in giving the abundance limit is borne by the provider. â⬠¢ Catalyst for change. An association can utilize a redistributing understanding as an impetus for significant advance change that can't be accomplished alone. The outsourcer turns into a Change specialist simultaneously. â⬠¢ Enhance limit with regards to development. Organizations progressively utilize outside information specialist co-ops to enhance restricted in-house limit with regards to item development. â⬠¢ Reduce time to advertise. The quickening of the turn of events or creation of an item through the extra ability brought by the provider. â⬠¢ Commodification. The pattern of normalizing business forms, IT Services, and application administrations which empower to purchase at the correct cost, permits organizations access to administrations which were just accessible to huge companies. â⬠¢ Risk the board. A way to deal with hazard the executives for certain kinds of dangers is to band together with an outsourcer who is better ready to give the relief. â⬠¢ Venture Capital. A few nations coordinate government supports funding with private investment for new companies that start organizations in their nation. â⬠¢ Tax Benefit. Nations offer assessment motivators to move fabricating tasks to counter high corporate expenses inside another nation. Reactions of re-appropriating Quality Risks Quality Risk is the inclination for an item or administration to be damaged, because of activities related issues. Quality hazard in redistributing is driven by a rundown of elements. One such factor is advantage by providers due to skewed motivating forces among purchaser and provider, data asymmetry, high resource particularity, or high provider exchanging costs. Different variables adding to quality hazard in re-appropriating are poor purchaser provider correspondence, absence of provider abilities/assets/limit, or purchaser provider contract enforceability. Two fundamental ideas must be viewed as while considering recognizability as it identified with quality dangers in redistributing: the ideas of testability and criticality. Quality blur is the purposeful and mysterious decrease in the nature of work so as to augment overall revenues. The descending changes in human capital are inconspicuous however dynamic, and typically unnoticeable by the out sourcer/client. The underlying meeting meets necessities, in any case, with resulting backing, increasingly more of the help group is supplanted with beginner or less experienced laborers. Some IT shops will keep on diminishing the nature of human capital, under the weight of evaporating work gracefully and upward pattern of compensation, pushing as far as possible. Such practices are difficult to recognize, as clients may just quit any pretense of looking for help from the assistance work area. Be that as it may, the general consumer loyalty will be decreased incredibly after some time. Except if the organization continually leads consumer loyalty studies, they may in the long run be trapped in a shock of client beat, and when they discover the underlying driver, it could be past the point of no return. In such cases, it tends to be difficult to debate the legitimate agreement with the redistributing organization, as their staff is currently prepared simultaneously and the first staff made repetitive. At long last, the organization that redistributes may find that it is more terrible off than before it re-appropriated its workforce. Nature of administration Quality of administration is estimated through an assistance level understanding (SLA) in the redistributing contract. In ineffectively characterized agreements there is no proportion of value or SLA characterized. In any event, when a SLA exists it may not be to a similar level as recently delighted in. This might be because of the way toward actualizing legitimate target estimation and revealing which is being accomplished just because. It might likewise be lower quality through plan to coordinate the lower cost. There are various partners who are influenced and there is no single perspective on quality. The CEO may see the lower quality worthy to meet the business needs at the correct cost. The held supervisory crew may see quality as slipping contrasted with what they recently accomplished. The end purchaser of the administration may likewise get an adjustment in administration that is inside concurred SLAs however is as yet seen as insufficient. The provider may see quality in absolutely meeting the characterized SLAs paying little heed to discernment or capacity to improve. Quality as far as end-client experience is best estimated through consumer loyalty surveys which are expertly intended to catch an unprejudiced perspective on quality. Studies can be one of research. This permits quality to be followed after some time and furthermore for remedial activity to be recognized and taken. Language abilities In the zone of call focuses end-client experience is considered to be of lower quality when an assistance is re-appropriated. This is exacerbated when redistributing is joined with off-shoring to areas where the main language and culture are unique. The faulty quality is especially clear when consider focuses that administration people in general are re-appropriated and offshored. The general population for the most part find phonetic highlights, for example, complements; word use and style distinctive which
Wednesday, July 29, 2020
Making Time For Art
Making Time For Art [by Ashley Nash 11] Before I got to MIT, in all of my classes, there has been one and only one answer to every question. The reason to do a problem was to get the answer. What about the answer? Why does it even matter? I dont know, but I didnt bother to try and find out, and at MIT, the answer doesnt matter very much anyway. I got a 39 on my first math test here because I was taught, one question, one answer, and MIT doesnt work that way. From the first question, you have to ask two more, and find 3 formulas for them and then you will get an answer, if you are lucky, and hopefully this answer will be the one your instructor intended. This concept of thinking is mind-boggling academically, but it is the main support of art. Whats the answer? There isnt one. Dont worry. If you dont have much or any experience with art, MIT provides plenty of opportunities in classes and in clubs. I am taking SP.747-Creative Imaging, a great photography class where I am learning to take photos with film (goodbye point and click) and develop them. MIT not only provides me with a semesters worth of film, but also access to three printers where I can print my pictures. One of them is a dry-sub printer; it sublimates red and yellow ink to make orange, instead of using red and yellow dots. Our first assignment was to bring in photos and talk about why we liked/disliked them. I brought in pictures of the London Clocktower, the California Coast, and a fuzzy baby penguin. I like them because they are pretty and dont have people in them. I dont like people. People annoy me. (Ten brownie points to anyone who knows what those two lines are from.) So on that note, here are some of my photos. This one is of a cat on a Senior House windowsill: This is the 4th Ware lounge of Senior House, where I live: This is a view of the Pru and the Charles from Senior House: And this is a photo of the giant sail sculpture in front of the Green Building: One of the many art clubs that MIT has is MTG, the Musical Theatre Guild. I am not a member of this club, but several of my friends are, and I have been to both of their shows this year, their most recent being Andrew Lippas The Wild Party, based on Joseph Moncure Marchs narrative poem of the same name. The show was exquisite, great acting, music, make-up and costumes alike. The protagonist, Queenie, is a beautiful, popular blonde who loves living life in the fast-lane. She thought she had found paradise with Burrs, a fun-loving clown, but a few years into the relationship, she grew tired of his bad attitude and demeanor. She decides to throw a wild party, where she will be able to embarrass him in front of their friends, but things go unexpectedly when her friend Kate brings her date, Mr. Black. Thats all Im going to say; I hate it when people ruin the ending. (Random Fact: When this show ran off-Broadway, Idina Menzel played Kate, the protagonists best friend.) If I could have anything, I would have Idina Menzels voice and life would be a musical. How could life be better?
Friday, May 22, 2020
Metro Manila Developmental Screening Test - 5748 Words
METRO MANILA DEVELOPMENTAL TEST CASE STUDY Submitted by: BSN 2-1 / GROUP #1 Leanna Mae S. Espineli Submitted to: Reymund Cristopher Samonte ,RN, MAN à © Clinical Instructor, Level I and II Date: January 25, 2013 INTRODUCTION A. BACKGROUND OF THE STUDY Williamsââ¬â¢ Metro Manila Developmental Screening Test (MMDST) Metro Manila Screening Test or MMDST is simple, clinically useful tool and an early detection model that applies to the detection of developmental disabilities in children. It is a modification and standardized by Dr. Phoebe D. Williams from the original Denver Developmental Screening Test or DDST by Dr. William K. Frankenburg. The MMDST is designed to detect development delays in children 2 weeks to 6 and half years of age.â⬠¦show more contentâ⬠¦In present, JACD is not experiencing difficulty in urinating and independently go to comfort room to eliminate waste. He doesnââ¬â¢t experience urinating in bed while sleeping. Finally, in the stage where he belongs; Phallic stage, the clientââ¬â¢s pleasure appears to shift from the anal to the genital area. The client has no signs that he is doing masturbation but the examiner cannot sure of this thing is happening at home. The client already knows the differences of two genders and in what gender he belongs. He is more closed to her mother than his father and being always with her mother even at house, as verbalized by the mother. His companions are composed of male. In this stage where child really start to become aware of their bodies C. Harry Stack Sullivan Interpersonal Development Harry Stack Sullivan (1892ââ¬â1949), the father of interpersonal psychiatry or Interpersonal Psychoanalysis. He proposed interpersonal theory of personality. He explained the role of interpersonal relationships and social experiences in shaping personality. He also explained about the importance of current life events to psychopathology. The theory further states that the purpose of all behavior is to get needs met through interpersonal interactions and decreaseShow MoreRelatedThesis on Hiv5798 Words à |à 24 Pagesreported infections in 2007 to 1,591 in 2010. Newly reported infections among young people 15 to 24 years of age, however, increased 10-fold over the same period (from 41 in 2007 to 489 in 2010). The Department of Health (DOH) stated that Angeles, Metro Manila, Cavite, Bulacan, Bacolod and Davao have the most number of people who got the infection. Provincial Health Officers (PHO) said that Cavite ranked second, after National Capitol Region (NCR), with the most number of ââ¬Å"People Living with HIVâ⬠(PLHIV)
Saturday, May 9, 2020
A Fair View of Argumentative Essay Topics about Instagram
A Fair View of Argumentative Essay Topics about Instagram What You Need to Do About Argumentative Essay Topics about Instagram Beginning in the Next Ten Minutes The problem here is that it takes so many parts of paper to write just a single textbook. Look through the list of topics cautiously and start making a mental collection of the evidence you're able to use on topics you prefer. You have to include rough facts! Your facts ought to be truthful. Using Argumentative Essay Topics about Instagram Before you turn in your assignment, you are going to want to appear over it one final moment. It is crucial to check reviews about essay writing services in order to be confident they can deliver your task before the deadline. It is possible to take my online IELTS Writing Practice Test anywhere on earth and find a score, corrections, and feedback in only two days. Do not be hesitant to speak to us every minute prior to your deadline is priceless. The Downside Risk of Argumentati ve Essay Topics about Instagram Don't forget that it's going to take practice to learn to earn a compelling case. A 1 hour essay deadline may be a true problem, if you're not good enough at writing and expressing your ideas on a topic you aren't really interested in. Each region of the essay exerts a specific function in its general structure. If you wish to learn what an argumentative essay is, the very first thing you need to remember is that its principal aim is to convince the audience to accept your perspective. There are not any grammatical errors. An argumentative essay example will reveal the should possess some crucial components which make it better in the practice of convincing. Be certain to read online essay writing service reviews in order to know what type of material you are spending for. Deciding on a topic to compose your argumentative essay about is not an effortless endeavor. Remember that the period of your essay is based on the assignment provided to you. The essay ought to have a little structure, unlike a normal essay. Essay writing per se is no simple job to do. There are a few specific elements which are necessary in an argumentative essay. When asking us how to begin an argumentative essay, many students forget that they should begin with an outline. To write a fantastic argumentative essay, there are four leading elements of the essay you're likely to have to know about. If you're new to writing argumentative essays, there are a couple of key factors which you can learn that could help you compose a much better argumentative essay. An argumentative essay is a writing piece intended to persuade a person to believe the way that you do. Usually, it has the same outline as the majority of traditional papers. All argumentative essays must have a conclusion paragraph. Every argumentative essay should depend on a topic which can be debated. Get the Scoop on Argumentative Essay Topics about Instagram Before You're Too Late An argumentative essays aim is to convince your reader to hold up your side of the argument. You have to consistently stay on a single side of the argument. Emphasize your position is the very best by summarizing the key points of your argument. You first have to decide on a good topic with an argument, credible information to strengthen your viewpoint, a good stance on your side, and a superb counter-argument to assist you sound less biased. Argumentative arguments are only arguments that are written back on paper. A great persuasive argument will use the latest data and data from verified sources. Good argumentative essay examples should show you just how to include things like the advantages and disadvantages of your argument. Any fantastic task finishes with a fantastic conclusion and the very best examples of the argumentative essay will arrive in with a conclusion with an overview of all of the points together with a gist of the evidences provided.
Wednesday, May 6, 2020
Example Press Release Free Essays
NEWS For Immediate Release Contact NEWS For Immediate Release Contact SOUTH BURLINGTON September 12, 2012Itââ¬â¢s getting close to election time and in response to the hullaballoo and stressors surrounding the republican and democratic campaigns, top leader in ice cream production, Ben and Jerryââ¬â¢s, announced their new flavor, ââ¬Å"We Vote Purple. â⬠The new flavor consists of a delicious boysenberry and grape sorbet with bits of pie crust swirled in, thus giving the ice cream a beautifully neutral color of purple and a nice hearty texture. Ben and Jerryââ¬â¢s CEO, Jostein Solheim, said, ââ¬Å"This flavor is for all of the people of America, regardless of their political standpoint. We will write a custom essay sample on Example Press Release or any similar topic only for you Order Now Itââ¬â¢s something that can bring two different types of people together by mixing a little republican red with some democratic blue, thus creating purple. ââ¬Å" Solheim, as well as many Ben and Jerryââ¬â¢s employees, exclaim this is a new favorite of theirs, describing it as, ââ¬Å"a magical mix of grapes, the fresh fruit of summer, with a fall favorite, boysenberry pie. â⬠Lastly, if customers bring in a copy of this press release they can get the new flavor at half price! Limit one per customer. ) SOUTH BURLINGTON September 12, 2012Itââ¬â¢s getting close to election time and in response to the hullaballoo and stressors surrounding the republican and democratic campaigns, top leader in ice cream production, Ben and Jerryââ¬â¢s, announced their new flavor, ââ¬Å"We Vote Purple. â⬠The new flavor consists of a delicious boysenberry and grape sorbet with bits of pie crust swirled in, thus giving the ice cream a beautifully neutral color of purple and a nice hearty texture. Ben and Jerryââ¬â¢s CEO, Jostein Solheim, said, ââ¬Å"This flavor is for all of the people of America, regardless of their political standpoint. Itââ¬â¢s something that can bring two different types of people together by mixing a little republican red with some democratic blue, thus creating purple. ââ¬Å" Solheim, as well as many Ben and Jerryââ¬â¢s employees, exclaim this is a new favorite of theirs, describing it as, ââ¬Å"a magical mix of grapes, the fresh fruit of summer, with a fall favorite, boysenberry pie. Lastly, if customers bring in a copy of this press release they can get the new flavor at half price! (Limit one per customer. ) NEW BEN AND JERRYââ¬â¢S FLAVOR ANNOUNCED Company takes neutral stance in presidential campaign by presenting new flavor, ââ¬Å"We Vote Purple. â⬠NEW BEN AND JERRYââ¬â¢S FLAVOR ANNOUNCED Company takes neutral stance in presidential campaign by presenting new flavor, ââ¬Å"We Vote Purple. â⬠How to cite Example Press Release, Essay examples
Tuesday, April 28, 2020
Judicial Views about Polygamy
Introduction The discussion of Polygamy in America has caused a great judicial debate regarding its legal status. Now, with the changing societal perceptions regarding same-sex marriages, many people question the illegality of polygamy (Irwi, 2004).1 This chapter investigates the judicial background informing the illegality of polygamy and the circumstances that led to its prohibition, throughout all 50 states of America.Advertising We will write a custom thesis sample on Judicial Views about Polygamy specifically for you for only $16.05 $11/page Learn More To achieve this objective, this chapter proposes the contribution of the Utah wars, Morill anti-bigamy laws, Edmund Act, Edmund-tucker act, and Reynold vs. United States case as the main factors characterizing the judicial background of polygamy in America. Furthermore, this paper shows the legal position of American laws towards polygamy, and the contradiction that these laws have with religious free doms and individual liberties (Gallagher, 2006, p. 30).2 Judicial Background of Polygamy in America Utah War of 1857 ââ¬â 1858 The Utah war was an armed conflict between the Mormon Church and the U.S government. This war lasted one year, and included civilian casualties from both side of the divide. Even though the war was protracted, it ended through a negotiated agreement between the government and the Mormon Church (Hafen, 1958).3 The then president, James Buchanan, started this conflict by sending America troops to Mormon territories to control a rebellion in the state of Utah (against the governmentââ¬â¢s position to ban polygamy) (Hafen, 1958).4 However, the war turned out to be a mistake by the Federal government, because it gave the Mormons a renewed drive to practice polygamy, at least without any judicial interference, or any interference from the Federal government. This happened because the government was widely criticized for its attack on Utah, especially becaus e they had not properly ascertained accusations that the state was rebelling against the government (Danver, 2011, p. 383).5Advertising Looking for thesis on family law? Let's see if we can help you! Get your first paper with 15% OFF Learn More Observers also criticized Buchanan for failing to notify Utahââ¬â¢s governor about the intention of the Federal government to attack the citizens of Utah. These criticisms prompted the government to leave Mormons alone. Indeed, as will be seen from the Morill Anti-bigamy law, the Utah wars of 1857 and 1858 gave Utah a renewed judicial will to practice polygamy. Morill Anti-Bigamy Act President Abraham Lincoln signed the Morill Anti-bigamy Act after the Utah wars of 1857 and 1858 (Gallagher, 2006).6 Here, it is critical to note that the Mormon debate, and the willingness of prospective presidents to criminalize polygamy, characterized the American presidential elections of the mid and late 1800s. Lincoln rose to power on this promise. Indeed, the failure of President Buchanan to introduce a lasting solution to polygamy gave the new president, Abraham Lincoln, the opportunity to find a lasting solution (legally) to polygamy in America. His remedy was the Morill Anti-bigamy Act. However, since the failure of the Utah wars gave Mormons a fresh will to fight any attempts (legally) at constraining their religious right to practice polygamy, President Lincoln willingly failed to enforce anti-polygamy laws in Utah (Gallagher, 2006).7 The lack of law enforcement was a tactical move by Abraham Lincoln to exempt Utah from abiding by anti-polygamy laws, in exchange for Utahââ¬â¢s loyalty to the Federal government during the American civil war. Consequently, the American commanding officer for the Federal government received instructions to refrain from confronting Mormons regarding their practice of polygamy (even though the Morill law was in force) (Gregory, 2011).8 From the governmentââ¬â¢s unwillingness to enforce (fully) anti-polygamy laws, it is easy to see how the Utah war affected subsequent applications of anti-polygamy laws in America. Nonetheless, Lincoln signed the Morill act into law in 1862 to provide a judicial background for the enforcement of anti-polygamy laws in America. Through the Morill law, the government intended to control the spread of polygamy in the state of Utah. However, the Morrill anti-bigamy law experienced subsequent modifications when the Edmund Act came into force in 1882.Advertising We will write a custom thesis sample on Judicial Views about Polygamy specifically for you for only $16.05 $11/page Learn More Edmund Act Edmund act (also known as the Edmundââ¬â¢s anti-polygamy Act) sought to make any acts of polygamy in America a felony against the Federal government (Norgren, 2006).9 This law also criminalized bigamy and unlawful cohabitation between men and women as a misdemeanor against the laws of America. This second provision intended to overcome the legal hurdle against the implementation of the Morill act, which experienced challenges from the burden of proving that a polygamous marriage had actually occurred. Indeed, most polygamous marriages occurred secretively and without any legal document to show its existence. The execution of this law occurred hurriedly as a reaction to the perceived immorality that polygamy introduced to the American society (Norgren, 2006).10 The Edmund act not only reinforced the Morill Act, but also introduced firm penalties to anybody found practicing polygamy (when convicted, offenders would lose their right to vote and their right to run for political office). The main challenge affecting the applicability of this law stemmed from its contradiction with the ex post facto law, which sought to protect the right of polygamists who practiced polygamy before the act came into force (Arrington, 1992).11 However, in a Supreme Court ruling in the Murphy vs. Ramsey cas e of 1885, the court ruled that the law punished polygamists for practicing polygamy after the enforcement of the anti-polygamy law, and not for their practice of polygamy before the applicability of the law. Therefore, the state penalized the continued wrongful cohabitation of polygamous couples after the law came into force (Arrington, 1992).12 The government enforced the Edmund Act indiscriminately because it prosecuted people not only for practicing polygamy, but also for subscribing to polygamous beliefs of the Mormon Church. In fact, the enforcement of the Edmund Act was so firm that all elected officers in the state (Utah) left office, so people could check them for their stand on polygamy, before they resumed office.Advertising Looking for thesis on family law? Let's see if we can help you! Get your first paper with 15% OFF Learn More Several prosecutions occurred under the Edmund Act. In fact, the government estimates that it prosecuted more than 1,300 men under this act (Arrington, 1992).13 Most victims were polygamous men, because the society perceived women as victims of this practice. However, the government arrested and detained polygamous women who refused to testify against their husbands. Edmundââ¬âTucker Act The government introduced the Edmund-Tucker Act in 1887 to respond to a judicial dispute between the Mormon Church and the US federal government (concerning the practice of polygamy within the Mormon Church) (Norgren, 2006).14 Congressman Tucker and Senator Edmund introduced the act. Both sponsors proposed that the government should impose a penalty of $500 to $800 on anybody found to be practicing polygamy (Norgren, 2006).15 Both sponsors also criticized the Mormon Church for fostering polygamy in America as a religious practice. From this statement, the Edmund-Tucker Act gave the federal gover nment a reason to seize the assets of the LDS church (worth over $50,000) (Arrington, 1992).16 The government later assigned these assets for use in public schools around Utah. U.S marshals and their deputies implemented this law. According to the provisions of the Edmund act, prospective voters and public officials had to denounce polygamy. Moreover, the act required prospective voters, jurors, and public officials to take an oath against polygamy before they continued their public service duties (Arrington, 1992).17 The Edmund-Tucker act also cancelled any laws allowing children born from polygamous unions to inherit property (Arrington, 1992).18 Finally, the act also required all civil unions to have a certificate, so that the prosecution of polygamous unions eased. This law changed the spousal privilege act to eliminate the protection of polygamous wives from testifying against their husbands. To improve the enforcement of anti-polygamy laws, the Edmund-Tucker act paved the way for the appointment of federal judges to hear polygamy cases, instead of local judges (who were sympathetic to polygamists). This law led to the abolishment of the office of territorial superintendant (in the education system) to pave way for a federally funded office that controlled school activities within Mormon strongholds. This move aimed at having an accurate assessment of the number of Mormon school going children (Norgren, 2006).19 The government repealed the Edmund-Tucker act in late 1978. Reynold vs. United States A fundamentalist Mormon (George Reynolds) filed The Reynold vs. United States case in 1878 (Johnson, 1948).20 Reynold claimed that the state should not prosecute him for practicing bigamy because it was his religious right to marry multiple partners. He also claimed that the testimony of one of his wife could not be admissible in court because it was under another indictment. The state had earlier arrested him for marrying a second wife, Amelia Jane Scofield, whi le he was already married to another woman (Mary Ann) (Johnson, 1948).21 This case introduced a special argument in the American justice system, because it questioned the governmentââ¬â¢s commitment to protect the religious rights and freedoms of the American people. The US Supreme Court however, ruled that Reynoldââ¬â¢s religious right was not a defence against the stateââ¬â¢s law that criminalized polygamy. A background of the acknowledgement that the federal government could not introduce a new law that contravened the first amendment informed this ruling. However, the court also said that anti-bigamy laws did not classify under laws that prohibited the first amendment to the American Constitution, or the freedom to exercise religious practices. The court used a letter from Thomas Jefferson to justify its ruling regarding the existence of a clear distinction between religious beliefs and practices that stem from such beliefs (Johnson, 1948).22 The Court also ruled that r eligious beliefs were between man and God; therefore, the court could not intervene in such agreements. However, actions arising from such beliefs (polygamy) were under the courtââ¬â¢s jurisdiction, because it involved the relationship between two or more people. The court therefore believed that it had the jurisdiction over actions, and not the opinions held by religious people (Johnson, 1948).23 It should however, be understood that at the time of the ruling, fundamental Mormons believed that the growing trend by the federal government to pass laws prohibiting polygamy was a legal interference against the first amendment to the American Constitution, which gave them the right to practice their religious rights. Because most Mormons believed so, they freely chose to ignore the Morill anti-bigamy act that criminalized their polygamous practices. Even as the Mormons felt victimized by the state, the government was still exploring ways of strengthening the already existing laws to criminalize bigamy in America. Therefore, Reynoldââ¬â¢s petition was untimely, because the government was strengthening its commitment to criminalize all forms of polygamy. From this background, the court indicted Reynold for bigamy and sentenced him to two years imprisonment, with a fine of $500, as stipulated by the law (Johnson, 1948).24 This ruling stood as a precedent for the criminalization of polygamy in America. Legal Position towards Fundamental Mormon Polygamy The legal position of the U.S federal government towards polygamy has been unfavorable to Mormons. Since the signing of the Morill Anti-bigamy law, the U.S federal government has been unforgivable in criminalizing polygamy, and all its forms. The subsequent signing of the Edmund Act, and the Edmund-Tucker Act, supported this commitment. The presence of these laws has put the Mormon faith at crossroads with the government, and the American society, regarding their religious practices and the consequences of not fol lowing the law. The Mormons have had a choice to abandon polygamy, or continue with the practice and face the law. To date, many Mormons have abandoned the practice and aligned their religious practices with mainstream American beliefs regarding marriage (monogamy). However, a cross-section of the Mormon faith still practices polygamy, although in small proportions. Americaââ¬â¢s legal position towards polygamy has however not changed. Polygamy is still illegal in the United States and those practicing it, do so illegally. However, it is equally important to note that polygamy has gained a significant level of social acceptance among fundamental Mormons in America. Many factors (including the changing societal perceptions regarding the practice, and the legalization of same sex marriages in some American states, such as, Iowa, Maine, Maryland, and Massachusetts) fuel its acceptance. Despite the existence of anti-polygamy laws, the states of Utah and Colorado have had a long histo ry of condoning polygamy, so long as it is not public (Danver, 2011).25 The minimal convictions and commitment by the US government to arrest polygamous partners support the underground acceptance of polygamy within some states of the US. This minimal government commitment to arrest polygamists stem from the presence of tens of thousands polygamists in the U.S, who continue the practice without any strong legal consequences. For example, within the two states mentioned above (Utah and Colorado), only two arrests have occurred within the last decade (although thousands of people practice polygamy within the two states) (Danver, 2011).26 In fact, the arrests of these two polygamous people only occurred because they openly advocated for polygamy. They therefore seemed a nuisance to the society, and an embarrassment to the state government. If the two polygamists never openly campaigned for polygamy, the government would not have arrested them. In 2008, the Texas government also raided a fundamentalist Mormon church in the state (Danver, 2011).27 However, they only did so because they suspected that forceful marriages of underage girls (to older men) occurred within the church. If it was adults practicing polygamy (with no children involved), there would be very little state involvement (despite the illegality of polygamy in America). The government therefore uses the law selectively (in extreme cases of polygamy, and only when polygamy gives way to social ills, such as, marrying underage girls). Anti-polygamy laws therefore exist because it is politically right to have them (because majority of Americans still do not fully accept polygamy). Moreover, if the government removes them, there would be a public outcry. Unlike past decades when the government was very vocal about the practice of polygamy in the Mormon faith, the government has recently taken a backseat in the implementation of anti-polygamy laws. Instead, only polygamous acts considered highly immoral b y the American society (such as the marriage of underage girls) are subject to prosecution. The legal position of the American government towards polygamy in the Mormon Church has therefore stabilized in the recent years, because there have been fewer attacks on polygamists recently. The governmentââ¬â¢s position regarding the dominance of polygamy in some Mormon sects has therefore been lukewarm because it only acts when polygamists become ââ¬Ëtoo loudââ¬â¢ or engage in forceful marriages (considered unacceptable by the society). Otherwise, the government does not concern itself much with polygamists who foster the practice in secrecy. In other words, when adults (with no history of child abuse or neglect) practice polygamy, the government rarely gets involved in such unions. This is the reason polygamy has found its way to American media. Now, polygamous shows are part of mainstream American television, such as, HBOââ¬â¢s Big Love and TLCââ¬â¢s Sister Wives. Contrad ictions in the Application Polygamy Laws Contradiction with Religious Laws The willingness of Americans to accept diverse views regarding different social issues inform Americaââ¬â¢s legal and social fabric. This diversity is widely enshrined in Americaââ¬â¢s basic freedoms and rights. One basic freedom is the freedom of religion because the law grants Americans the right to practice whatever religion they chose, so long as these freedoms do not infringe on the rights of other people. Broadly, proponents of polygamy have advanced the practice as a religious freedom. According to the First Amendment of the American constitution, the law should protect such a right. The exception to this rule manifests when polygamy infringes on the rights of other people. However, polygamy seldom infringes on other peoplesââ¬â¢ right. Therefore, it is difficult to find the right legal justification why the American law does not protect polygamy as a religious right. So far, anti-polygamy law s in America have taken a social dynamic instead of a legal one. In other words, American laws banning polygamy seem to represent the societal view towards polygamy as opposed to the legal view towards the same. Therefore, while polygamy remains a religious right, the law fails to protect it as so. The contradictions in the application of polygamy laws in America stem from its clash with religious doctrines, and the foundations that form the American society (Hitchcock, 2008).28 Many Americans are Christians. Christianity does not criminalize polygamy the way the American law does. In fact, many polygamous men in the bible were loyal servants of God. David and Solomon are just a few examples of polygamous men in the bible. Spector (2011)29 says that it is a common religious practice among Christians to pay attention to religious teachings (first) before they pay attention to the ââ¬Ëlaws of manââ¬â¢. This is the main problem that has faced the governmentââ¬â¢s will to imple ment anti-polygamy laws in America (because they face religious opposition from the Mormon Church and the few Christians who believe in Polygamy as a fundamental religious teaching from the Bibleââ¬â¢s Old Testament). In fact, this opposition informs the Mormon belief that they hold the religious right to practice polygamy. Apart from the Christian opposition to the application of anti-polygamy laws, the contradictions between the governmentââ¬â¢s law and Islamic laws governing polygamy clash too (Hagerty, 2008, p. 1).30 The conflict between Islamic laws regarding polygamy (and the governmentââ¬â¢s law regarding the same) has been largely unexplored by many researchers (despite the continued practice of polygamy within the Muslim population living in America). In fact, there has been minimal government involvement in the practice of polygamy within the Muslim population. Islamic laws allow men to have up to four wives. It is therefore within their religious right to be poly gamous. However, the American law criminalizes any form of marriage after a man marries only one woman. This contradiction shows the clash between government laws and Islamic laws, worldwide. In fact, after reviewing the religious practices surrounding the application of polygamy in America, no other religion restricts the number of women a man may marry (besides Islam). In fact, Judaism and Hinduism also do not restrict the number of wives a man may have. However, there is no agreement regarding the way Muslims practice polygamy. Some cohabit with more than one wife (in the same house), while others cohabit with many wives in different households. Since many Islamic laws do not seek the legal recognition of their polygamous marriages, it is difficult for the government to prosecute such polygamists. Nonetheless, from the religious freedoms given to Christian, Islamic, Hindu, and other religious groups, there is a sharp contradiction between American anti-polygamy laws and religious laws (Hagerty, 2008).31 Protection of Individual Liberties Another contradiction that undermines the application of the anti-polygamy law is the Supreme Court decision of 2003, in Lawrence vs. Texas (Ihara, 2008, p. 6).32 Lawrence brought this case to the Supreme Court to question the legality of homosexual relations in Texas. The court ruled that Texas had no authority to dictate the private relationships of its citizens, or the way Americans chose to live their lives. In this regard, the Supreme Court struck down all sodomy laws in Texas and gave unprecedented freedom to its people to practice whatever private unions they wanted. This ruling also said that the 14th Amendment to the American Constitution protected consensual sexual conduct of American citizens. The government therefore had no right to dictate how its citizens should live their private lives. Previous court rulings that sought to undermine the liberties and freedoms of Americans were undermined by this ruling becau se the Supreme Court ruled that they were formulated using a narrow understanding of the liberties and freedoms enjoyed by the American population (Ihara, 2008).33 The above ruling was a landmark ruling in America because it symbolized a great milestone in the advancement of individual liberties. Moreover, many gay right activists considered the ruling a great milestone in the advancement of gay rights (Gallagher, 2006, p. 27).34 Since the court made this ruling, Americans have enjoyed unprecedented freedoms in their lifestyle choices and private relationships. Practically, the Lawrence vs. Texas ruling made it impossible for the state to continue using the criminal code to define the private relationships of American citizens. Indeed, in the past, the American government had extensively used the criminal code to dictate even the most private and intimate relationships of the American people. From the above developments regarding the protection of American civil liberties and rights , there has been a growing trend for the court to protect private relationships. This development has given new ammunition for polygamists to demand equal protection by the government. The reluctance to grant polygamous unions the same consideration that same sex marriages have (to legalize, or not?), creates a contradiction in the application of anti-polygamy laws, and the protection of individual liberties. The biggest question that arises in this regard is why the American justice system seems to safeguard selective individual liberties, while criminalizing others. Naturally, if the courts protect same-sex marriages as legal marital unions (in some states), polygamy should also receive the same treatment because it is also a marital union that consenting adults choose to engage in (Gallagher, 2006, p. 27).35 Conclusion The inconsistencies in the application of anti-polygamy laws in America are obvious. Most of these inconsistencies were nonexistent during the initial criminalizat ion of polygamy by the American federal government. However, advancements in the protection of American individual liberties (and the changing societal perceptions regarding private relationships) created these inconsistencies (Gallagher, 2006, p. 30).36 Comprehensively, there is a trend within the American judicial system to safeguard most American individual liberties. Unfortunately, this trend protects these liberties selectively because polygamy does not receive this judicial protection. Irwi (2004)37 says that the initial reference and attachment of polygamy with same sex marriage is responsible for this neglect because critics of same sex marriages used polygamy as an argument against the legalization of same sex marriages. Therefore, American civil organizations refrain from justifying the initial fear of its critics that the possible legalization of same sex marriages would lead to the legalization of polygamous unions. In this regard, the law continues to neglect polygamy. All 50 states of America therefore still criminalize the union. References Arrington, L. (1992). The Mormon Experience: A History of the Latter-Day Saints.à Chicago: University of Illinois Press. Danver, S. (2011). Revolts, Protests, Demonstrations, and Rebellions in Americanà History: An Encyclopedia. New York: ABC-CLIO. Gallagher, E. (2006). Introduction to New and Alternative Religions in America. New York: Greenwood Publishing Group. Gregory, J. (2011). SkinHead Girl: Based on a True Story. New York: Author House. Hafen, L. (1958). Mormon Resistance: A Documentary Account of the Utahà Expedition, 1857-1858. New York: U of Nebraska Press. Hagerty, B. (2008). Some Muslims in U.S. Quietly Engage in Polygamy. Web. Hitchcock, J. (2008). The Supreme Court and Religion in American Life. Princeton: Princeton University Press. Ihara, T. (2008). Living Together: A Legal Guide for Unmarried Couples. New York: Nolo. Irwin, M. (2004). Women and Gender in the American West: Jensen-Mille r Prizeà Essays from the Coalition for Western Womenââ¬â¢s History. New York: UNM Press. Johnson, A. (1948). Separation of Church and State in the United States. Minnesota: U of Minnesota Press. Norgren, J. (2006). American Cultural Pluralism and Law. New York: Greenwood Publishing Group. Spector, J. (2011). Seeming Contradictions: Polygamy (Plural Marriage). Web. Footnotes 1 Michael, Irwin. (2004). Women and Gender in the American West: Jensen-Miller Prize Essays from the Coalition for Western Womenââ¬â¢s History. New York: UNM Press. 2 Eugine, Gallagher. (2006). Introduction to New and Alternative Religions in America. New York: Greenwood Publishing Group. 3 Leroy, Hafen. (1958). Mormon Resistance: A Documentary Account of the Utahà Expedition, 1857-1858. New York: U of Nebraska Press. 4 Hafen, 1958. 5 Steven, Danver. (2011). Revolts, Protests, Demonstrations, and Rebellions in American History: An Encyclopedia. New York: ABC-CLIO. 6 Gallagher, 2006. 7 Ibid. 8 John, Greg ory. (2011). SkinHead Girl: Based on a True Story. New York: Author House. 9 Jill, Norgren. (2006). American Cultural Pluralism and Law. New York: Greenwood Publishing Group. 10 Norgren, 2006. 11 Leornard, Arrington. (1992). The Mormon Experience: A History of the Latter-Day Saints. Chicago: University of Illinois Press. 12 Arrington, 1992. 13 Ibid. 14 Norgren, 2006. 15 Ibid. 16 Arrington, 1992. 17 Ibid. 18 Ibid. 19 Norgren, 2006. 20 Alvin, Johnson. (1948). Separation of Church and State in the United States. Minnesota: U of Minnesota Press. 21 Johnson, 1948. 22 Ibid. 23 Ibid. 24 Ibid. 25 Danver, 2011. 26 Ibid. 27 Ibid. 28 James, Hitchcock. (2008). The Supreme Court and Religion in American Life. Princeton: Princeton University Press. 29 Jeff, Spector. (2011). Seeming Contradictions: Polygamy (Plural Marriage). 30 Barbara, Hagerty. (2008). Some Muslims in U.S. Quietly Engage in Polygamy. 31 Hagerty, 2008. 32 Toni, Ihara. (2008). Living Together: A Legal Guide for Unmarried Couples. New York: Nolo. 33 Ihara, 2008. 34 Gallagher, 2006. 35 Gallagher, 2006. 36 Gallagher, 2006. 37 Irwi, 2004. This thesis on Judicial Views about Polygamy was written and submitted by user Nolan Newton 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.
Subscribe to:
Posts (Atom)