Thursday, May 28, 2020

How do we safeguard human rights - Free Essay Example

à ¢Ã¢â€š ¬Ã‹Å"Safeguarding Human Rights lies less in new laws, than in new interpretationsà ¢Ã¢â€š ¬Ã¢â€ž ¢. Discuss with reference to the United States and the United Kingdom Introduction Both sides of the proposition posed in the title question are fraught with difficulty. Human history, particularly as it unfolded in the twentieth century, confirmed that national and supranational treaties and legislation, no matter how compellingly drafted or extensively ratified, was a thin safeguard against human rights abuses. Versailles, the Yalta Conference, the United Nations Declaration of Human Rights and the International Convention against Torture represent a sampling of this truth. The mere enactment of a human rights provision does not carry an implicit assurance of compliance or respect for its terms. Similarly, the legal traditions advanced by case law and other jurisprudence are an inadequate moral compass era to era in the human experience. Human rights are a dynamic and highly contextual aspect of our global existence. Written laws can quickly assume the status of tombstone data, immutable, inert and ineffective in the face of rapidly changing societal attitudes and diversity. The precise definition of what constitutes a fundamental right of any kind is never static. The body of law in any society is susceptible to manipulation by subsequent generations. In the course of this paper, an argument shall be advanced that seeks to synthesise both aspects of the title, with a primary weight g iven top the promulgation of better and more powerfully written laws as the ultimate tool to encourage cogent and authoritative interpretations to best counter the dynamics of human rights issues. The analysis commences with a series of working definitions. Depending upon the tenor of a particular time, human rights protections may be expressed in terms as expansive as an ocean, or as thin as a puddle. An effective definition of human rights is crucial given its status as the touchstone modern societal concept in both the United States and the UK. The relevant definitions are especially examined from the perspective of two constructs à ¢Ã¢â€š ¬Ã¢â‚¬Å" rights versus obligations, and claims versus rights versus entitlement. The definitional foundation analyses specific examples available in both the American and the UK human rights experience. The common roots of the constitutional protection of human rights in each country and the divergence in approaches between both nations are considered; the American Constitution and the UK incorporation by reference of European Community human rights standards are considered in this respect. It is contended that the United States and the UK have recently returned to a common root in the consideration of the limits to be placed upon human rights availability in times of national emergency, a contention examined with particular reference to the events and the repercussions of the 9/11 and 7/7 terrorist attacks. An examination of modern constitutional protection in both the UK and the United States leads inexorably to a restatement of the central question à ¢Ã¢â€š ¬Ã¢â‚¬Å"is the best human rights protection an enlargement of the existing positive law or the promotion of existing human rights jurisprudence? In this specific context, the question may be further re-stated in terms of an à ¢Ã¢â€š ¬Ã‹Å"acid testà ¢Ã¢â€š ¬Ã¢â€ž ¢ à ¢Ã¢â€š ¬Ã¢â‚¬Å"how has the protection of human rights withstood the exigencies of the c urrent à ¢Ã¢â€š ¬Ã‹Å"war on terrorà ¢Ã¢â€š ¬Ã¢â€ž ¢? This conflict and all of its attendant human rights pressures will be considered as both a latter day moral panic and as the ultimate human rights intersection between individual liberties and societal protection. The paper concludes with an observation advanced in support of the proposed synthesis. Human Rights à ¢Ã¢â€š ¬Ã¢â‚¬Å" a societal touchstone As noted in the Introduction, human rights are increasingly identified in the public consciousness as representing the essence of both modern UK and American society. à ¢Ã¢â€š ¬Ã‹Å"Rightsà ¢Ã¢â€š ¬Ã¢â€ž ¢ in all of their forms are asserted, advanced and in theory, protected with a vigour that is evident in every aspect of society. It is a simple but worthy observation that both American and UK societies now stress human rights laws because a functioning society must have them. Humans through history have proven themselves incapable of effective rule without laws. Alan D ershowitz has noted that à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦man strives for something to worshipà ¢Ã¢â€š ¬Ã‚ ¦today that à ¢Ã¢â€š ¬Ã‹Å"somethingà ¢Ã¢â€š ¬Ã¢â€ž ¢ is human rightsà ¢Ã¢â€š ¬Ã‚ ¦Ãƒ ¢Ã¢â€š ¬Ã¢â€ž ¢[1] The natural law theories of Enlightment thinkers such as John Locke have remained a constant in modern day human rights considerations, where any type of intolerance is generally regarded as a limitation upon natural and desirable human growth and the acquisition of knowledge.[2] Michael Ignatieff has characterised human rights as a language that connects the disparate nature of global humanity. Progress on human rights issues is defined in this context as à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦an increase in our ability to see more and more differences among people as morally irrelevantà ¢Ã¢â€š ¬Ã¢â€ž ¢[3]; the spread of human rights must be encouraged as it represents definitive proof of moral progress. The concept of human rights is one of the few philosophical or legal con structions that may be defined by what they are not without doing violence to logic or scholarship. In one sense, a theory of human rights is a theory of human wrongs; à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦it begins with the worst of the injustices: the Crusades, the Inquisition, slavery, the Stalinist starvation and purges, the Holocaust, the Cambodia slaughter, and other abuses that reasonable people now recognise as wrongs.à ¢Ã¢â€š ¬Ã¢â€ž ¢[4] In a similar legislative context, Thomas Hobbes described covenants without swords as à ¢Ã¢â€š ¬Ã‹Å"only wordsà ¢Ã¢â€š ¬Ã¢â€ž ¢;[5] rights could only exist through a combination of statements of intention and a commitment to action and their enforcement. Similarly, a right is expressed in contradistinction to an obligation. Both the American Constitution and the UK law (both before and after the Human Rights Act / ECHR interpretations) emphasise rights, and their inherent sense of entitlement to the holder of the right. John Gentry speaks of à ¢Ã¢â€š ¬Ã‹Å"the revolution of rising expectationsà ¢Ã¢â€š ¬Ã¢â€ž ¢ fostered by human rights as a true societal touchstone issue; the revolution, evidenced by the sweeping nature of both American and ECHR judicial interpretations, is suggested as the cause of a serious deterioration in the concept of personal responsibility.[6] It is argued that within the broad tent of human rights, certain specific rights have primacy. In both the United States and the UK systems, civil and political rights have traditionally been afforded greater respect than economic, social or cultural rights. Civil and political rights are ones that advance and protect individualism and self expression; freedoms of assembly, religion, and property all developed organically from these roots. It is a more recent historical development that presents economic, social and cultural rights on an equal footing as that of the primary group; a distinction to be observed between the ECHR and the American Constit ution is in the emphasis in the European documents on this second group. While a number of commentators have expressed the view that the desired universality of human rights does not require à ¢Ã¢â€š ¬Ã‹Å"cultural homogenisationà ¢Ã¢â€š ¬Ã¢â€ž ¢,[7] the right to work, to earn a living wage, the protection of cultural expression and the promotion of health care are à ¢Ã¢â€š ¬Ã‹Å"softerà ¢Ã¢â€š ¬Ã¢â€ž ¢ human rights elements; the ECHR jurisprudence on these issues is more fully rounded than its American counterpart, because as is contended in this paper, the written law has led the jurisprudence à ¢Ã¢â€š ¬Ã¢â‚¬Å"new laws have led to new interpretations.[8] It has been suggested that human rights laws are the means by which a state, a dry and impersonal legal entity, is transformed into a vibrant and dynamic nation.[9] In this respect the foundation human rights document in United States law, the American Constitution, has been the vehicle through which true nationhood has been attained. The Constitution as written represents a powerful codification into positive law the principles of natural law articulated by Locke and Rousseau that were dear to constitutional authors such as Thomas Jefferson.[10] The largely unwritten character of the UK constitutional system achieves a similar result through implication; the Human Rights Act, through the mechanisms discussed below, achieves a similar effect by different means. Both UK and American modern constitutional approaches to human rights presume their universality. The language of the American Constitution establishes broad definitions of citizenship and protection against an overbearing state. As an example, the language of the Fourteenth Amendment provides thatà ¢Ã¢â€š ¬Ã¢â€ž ¢Ãƒ ¢Ã¢â€š ¬Ã‚ ¦ No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.à ¢Ã¢â€š ¬Ã¢â€ž ¢ The relationship between à ¢Ã¢â€š ¬Ã‹Å"citizensà ¢Ã¢â€š ¬Ã¢â€ž ¢, à ¢Ã¢â€š ¬Ã‹Å"personsà ¢Ã¢â€š ¬Ã¢â€ž ¢ and their respective constitutional protections has been a rich source of American litigation. A powerful example of the interplay between the clear language of the American constitution, historical circumstances, societal attitudes and national emergency is found in the differing manners in which the United States reacted to the two most immediate and stunning incursions made by an enemy upon its home soil. In 1941, in the wake of the Japanese strike against Pearl Harbour in Hawaii, the United States government through its Congress authorised the detention of all persons of Japanese ancestry resident in the United States, including those persons who were American citizens. The plain language of the Fourteenth Amendment was circumscribed by the perceived threat presented by persons of Japanese ancestry. In a constitutional challenge to their internment[11], the United States Supreme Court ruled that the government action was permitted; Congress à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦had reposed confidence in its military leadership (in recommending the detention of these persons)à ¢Ã¢â€š ¬Ã‚ ¦Ãƒ ¢Ã¢â€š ¬Ã¢â€ž ¢ à ¢Ã¢â€š ¬Ã¢â‚¬Å" war powers, said the Court, must be judged within the context of war.[12] Sixty years later, the 9/11 attacks perpetrated by the Al Qaeda terrorist movement were determined to be the work of persons who originated from a primarily Saudi Arabian based Muslim sect. The United States made no movement to detain or otherwise restrict the citizenship rights of its Saudi or broader Arab Muslim minority; the United States restrictions on the travel freedoms of some members of this general class of persons was a markedly lesser response to the 9/11 emergency than that which followed Pearl Harbour; even these latter actions have attracte d widespread adverse commentary[13]. It may appear that a 1941 styled response to the events of 9/11 would not accord with modern American or perceived global standards of human rights; it may be said that modern American attitudes to the notion of confining persons on the basis of ancestry or religion evolved from what in retrospect was the disagreeable treatment of American Japanese in World War Two. However, whether the United States through its treatment of à ¢Ã¢â€š ¬Ã‹Å"war on terrorà ¢Ã¢â€š ¬Ã¢â€ž ¢ suspects has effected an improvement on its 1941 Japanese policy is open to significant question, as is illustrated below. The European human rights conventions (ECHR) that are now a part of UK law by virtue of the Human Rights Act are a useful contrast to the American approach. The language of Article 5[14] (right to liberty) is stated as an emphatic guarantee of liberty and security that is subject to limited exceptions in its application. The Article is as sweeping in it s language as that of its American counterpart. Article 6 is a recapitulation of legal rights to due process and fair trials that largely mirrors the case law developed in the American constitutional interpretations and the UK jurisprudence prior to the enactment of the Human Rights Act. In both systems, the written law does not enumerate every conceivable human rights issue that requires protection, but there is a clear attempt in both the American and the UK provisions to establish and foster a legal foundation for human rights. In an overarching fashion, individual rights are the accepted trump against the powers of the state. The definition of what constitutes a right within each constitutional framework is the subject of continual reassessment and reassertion. In both jurisdictions, the development of human rights is based upon an experiential approach, akin to trial and error processes that are re-evaluated case by case. In this sense, in theory, there is a present synthesis o f law and interpretation such as that contended for in this paper à ¢Ã¢â€š ¬Ã¢â‚¬Å" the practical realities are different. The manner in which each system has created exceptions to these broad human rights protections may define the scope of both American and UK human rights better than the primary and positive enactments themselves. The ECHR establishes the means by which an individual state may declare its derogation from the primary human rights established and confirmed by the ECHR. Article 14[15] is far more specific than the old fashioned language of the American Constitution Fifth Amendment, but the net effect is that each regime permits significant leeway to a government that perceives itself as imperilled to impose limitation so basic human freedoms. The à ¢Ã¢â€š ¬Ã‹Å"war on terrorà ¢Ã¢â€š ¬Ã¢â€ž ¢ analysis set out below is an amplification of this point. A literal reading of each set of constitutional enactments reveals that the similarities in the extent and the protection of human rights are striking. One would expect a similarity in judicial results through the interpretation of these laws. As the jurisprudence that has flowed from the war on terror reveals, human rights is a highly mobile and elusive concept. A further important similarity exists in the written structure of UK and American human rights protections in the context of national emergency. In both systems, the power to relax or abrogate human rights provisions is stated as a clear exception to the law, as opposed to a balancing of competing interests. The stated level of emergency provided for to permit government exceptions to the standard of human rights in each system is very high. The ECHR derogation power noted in Article Fourteen above is conveyed in a tone that would suggest its power would be rarely invoked. The American Constitution is no less circumspect. The case law arising in both the UK and the United States in the wake of terrorist activity since 2001 has created a different legal landscape that what might reasonably be anticipated from a strict reading of the black letter constitutional law. The terrorism cases and the redefinition of human rights Korematsu established a principle of American constitutional interpretation that the right of citizenship was not absolute in war time. Further, the United States Supreme Court paid particular homage to the notion of judicial deference to the decisions of the executive and legislative branches in times of national emergency. The most striking similarity in the UK and the American case law to flow from the modern war on terror is the manner in which the respective national courts have applied this very principle. In the United States, Hamdi v Rumsfeld [16]is an instructive example. Hamdi, an American citizen, was detained by the United States as an à ¢Ã¢â€š ¬Ã‹Å"enemy combatantà ¢Ã¢â€š ¬Ã¢â€ž ¢ when he was determined to have significant links to the Taliban insurgency in Afghani stan. Hamdi brought an application for habeus corpus for a judicial review of his detention; Hamdi reed primarily upon the rights afforded American citizens under the Constitution for due process.[17] In language that echoed that of the Supreme Court in Korematsu, it was held that the war making powers of the executive branch presumed expertise and experience was lodged there. The Court held that the branches of government most accountable to the people should be the ones to undertake its ultimate protection; à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦a healthy deferenceà ¢Ã¢â€š ¬Ã¢â€ž ¢ must be shown by courts to legislative and executive judgements in military affairs.[18] The Court expressed its concern that to examine the basis of the government assertion that Hamdi was properly designated an à ¢Ã¢â€š ¬Ã‹Å"enemy combatantà ¢Ã¢â€š ¬Ã¢â€ž ¢ would represent an undesirable judicial à ¢Ã¢â€š ¬Ã‹Å"creepà ¢Ã¢â€š ¬Ã¢â€ž ¢ into a military sphere.[19] The language employed by the Court is in c ontrast to the Arar case as discussed below[20]. The language employed in the UK terrorism cases is powerful evidence that whatever divergences may be apparent in the course of the human rights histories of the USA and the UK, the respective judicial attitudes as to how human rights may properly be limited in times of national emergency reflect a return to the legal roots shared by these nations. In a line of cases commencing with Secretary of State for the Home Department v Rehman[21] (where the consideration and delivery of the reasons for judgement straddled the events of 9 / 11), the deportation of a Pakistani citizen whose parents resided Britain was upheld as the proper exercise of executive power and the advancement of the public good: à ¢Ã¢â€š ¬Ã‹Å"(The Secretary of State)à ¢Ã¢â€š ¬Ã‚ ¦ is entitled to have regard to the precautionary and preventative principles rather than to wait until directly harmful activities have taken place, the individual in the meantime rema ining in this country. In doing so he is not merely finding facts but forming an executive judgement or assessment.[22] Lord Hoffman noted in a postscript written after 9/11 that the events in America à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦are a reminder that in matters of national security, the cost of failure can be high. This seems to me to underline the need for the judicial arm of government to respect the decisions of ministers of the Crown on the question of whether support for terrorist activities in a foreign country constitutes a threat to national securityà ¢Ã¢â€š ¬Ã‚ ¦ If the people are to accept the consequences of such decisions, they must be made by persons whom the people have elected and whom they can remove.[23] The subsequent decisions of the House of Lords, particularly in A Ors v. Secretary of State for the Home Department [24]reinforce this position. Lord Bingham employed the expression à ¢Ã¢â€š ¬Ã‹Å"great weightà ¢Ã¢â€š ¬Ã¢â€ž ¢ in his view of the manner in w hich government decisions should be considered in assessing the terrorist threat. The court did emphasize that while national security represented the one area of national life where a court would be most leery to tread, where persons are deprived f their liberty without trial such action à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦plainly invites judicial scrutiny of considerable intensity.à ¢Ã¢â€š ¬Ã¢â€ž ¢[25] The spirit of these decisions was maintained in the more recent case law that considered deportations that occurred as fall out from the à ¢Ã¢â€š ¬Ã‹Å"war on terrorà ¢Ã¢â€š ¬Ã¢â€ž ¢, particularly as outlined in Khadir[26] and Tabnak[27]. In Khadir, Lord Mance buttressed the court view that a terrorist related deportation was supported in the ECHR jurisprudence[28] as authority for the proposition that à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦litigation concerning immigration control does not concern the determination of a civil right within the meaning of article 6(1), despite acknowledging th e major repercussions on an applicants private and family life or on his prospects of employment that such litigation may haveà ¢Ã¢â€š ¬Ã‚ ¦Ãƒ ¢Ã¢â€š ¬Ã¢â€ž ¢[29] In both the American and the UK examples, the courts have employed a strict constructional division of powers analysis to establish the breadth of the permitted exceptions to otherwise available human rights protections in times of national emergency. The Arar case as outlined below is a useful illustration of where both the written law and the interpretations did not evidently prevent a breach of a fundamental human right in the name of the war against terror. Moral panic and terrorism à ¢Ã¢â€š ¬Ã¢â‚¬Å" the Arar case Sociologist Stanley Cohen coined the expression à ¢Ã¢â€š ¬Ã‹Å"moral panicà ¢Ã¢â€š ¬Ã¢â€ž ¢ as a result of his studies concerning the à ¢Ã¢â€š ¬Ã‹Å"Mods versus Rockersà ¢Ã¢â€š ¬Ã¢â€ž ¢ social controversy in the UK in the 1960s[30]. By definition, a moral panic is a psychological disturbance to a community that is triggered by a perceived threat to the social fabric, precipitating calls for government action and a public outcry against its perpetrators. Moral panics in the shape of phenomena such as youth crime and obscenity have swept Western cultures; each has an element of being over stated and sensationalised by the media out of all proportion to actual threat posed. Terrorism and the threats posed to the safety and security of Western society generally and the United States and the UK in particular are far beyond a mere moral threat. However, the moral threat analysis may be a useful consideration in understanding that even a profound threat to national security is not without the imposition of definable human rights standards; the United States handling of the Arar incident and its conduct of the Iraq war in terms of the use of extraordinary rendition brings this question into stark focus. In 2002, Maher Arar, a Syrian born Canadian citizen, was prevented from c ontinuing on a passenger flight to Montreal that had stopped over in New York. American authorities, acting in conjunction with operatives involved in a Canadian security investigation concerning Arar and his possible connections to Al Qaeda and terrorism, detained Arar. Over his protests, Arar was taken from the United States and ultimately turned over to Syrian military and security personnel. Arar was detained in Syria for over 10 months, during which time he was variously questioned, tortured, and deprived of access to either legal counsel or Canadian consular officials. The information secured from Arar through the Syrian interrogation proceedings was ultimately provided to the United States as a part of its anti-terrorism activities, coupled with the military intelligence gathering process in relation to the Iraq war. In 2005, President George Bush declared that à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦torture is never acceptable, nor do we hand over people to countries that do tor ture[31]à ¢Ã¢â€š ¬Ã¢â€ž ¢. The International Convention on Torture, to which both the UK and the United States are signatories, sets out a clear prohibition against the use of torture in any form in conjunction with military operations or prisoner detention[32]. The American Congress had passed legislation in 1998 that confirmed à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦the policy of the United States not to expel, extradite, or otherwise effect the involuntary return of any person to a country in which there are substantial grounds for believing the person would be in danger of being subjected to torture, regardless of whether the person is physically present in the United States.à ¢Ã¢â€š ¬Ã¢â€ž ¢[33] In a similar context, the concept of extraordinary rendition is regarded as an unlawful circumvention of the torture prohibitions. This practice involves the deliberate transfer of a person to a jurisdiction that does not hold a similar regard for human rights as the sending jurisdiction in its treatment of prisoners. The Iraq war has led to significant concerns in both the United States and the UK concerning the practice[34], regarded by many observers as a breach of human rights and an indirect form of permitting otherwise illegal torture.[35] The Canadian government convened a public inquiry into the circumstances of the Arar case; the primary domestic focus was the understandable public concern that arose in Canada concerning the complicity of its official agencies in the American action. The inquiry revealed that the United States was not prepared to recognise the fundamental rights of citizenship Arar otherwise possessed, preferring what was described as thin and tenuous connections between Arar and persons involved in terrorist activities. It is in this particular connection that the apparent wholesale breach of Ararà ¢Ã¢â€š ¬Ã¢â€ž ¢s human rights in New York in 2002 and perpetuated in Syria over the next year can be better understood in part with referen ce to the moral panic analogy. Arar represents a circumstance where the American government seemed intent on pursuing a systematic violation of human rights based upon information it knew was no more than suspicion. The judicial reasoning in the American and UK authorities concerning the due deference to be extended to the executive branch in times of war cannot salvage actions that bear the hallmarks of Arar.[36] Further, the war on terror represents a confluence in UK and American governmental attitudes to surveillance practices that have been widely criticised as human rights violations perpetrated against its own respective nationals.[37] In the United States, the government operated a clandestine wiretap operation without warrant or other judicial sanction, in the name of the war on terror generally, and in the struggle against the Al Qaeda organisation in particular.[38] The use of executive warrants to permit wiretaps prior to the events of 2001 had provoked fierce deba te in the UK. The purported overseers of UK practice, the Investigatory Powers Tribunal, adopted a policy whereby à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦their policy is to neither confirm nor deny whether surveillance had actually taken place.à ¢Ã¢â€š ¬Ã¢â€ž ¢[39] The conduct of the war on terrorism with the unsavoury aspects of rendition and the use of the Guantanamo Bay facility to house detainees was one pursued as a joint enterprise by the UK and the United States. It appears that the linkage to Europe achieved through the EU and the ECHR may only know be a factor to restore divergence in attitudes towards human rights in the conduct of the war on terrorism. One commentator noted that à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦British foreign policy after 11 September was meant to change America to turn the Bush administration into European social democrats, or at least Christian democrats by persuading Bush to accept that only cooperation and efforts to alleviate poverty could reduce the threa t of Muslim fanaticism. That policy is dead. Britain failed because it overestimated its power and underestimated the self-confidence and bravado of the American right.à ¢Ã¢â€š ¬Ã¢â€ž ¢[40] If a single conclusion can be drawn from the UK and American attitudes to human rights observance during the war on terror, it is that each national government has preferred hard edged operational expediency to the persona rights wherever the two concepts have clashed. Conclusion In a profound sense, recent history illustrates that notwithstanding the combined effect of written laws and focused judicial interpretations, human rights will always risk running a poor second to the will of a government executive in war time. The foregoing analysis is an example of how law and interpretations can be synthesised into a mechanism to identify as best as one can the permissible boundaries between executive action and an enduring respect for fundamental rights by the executive branch. Judicial in terpretation alone is not enough à ¢Ã¢â€š ¬Ã¢â‚¬Å" the written law will at least identify what protections there should be in a society à ¢Ã¢â€š ¬Ã¢â‚¬Å" as the Thomas More of fiction expressed it à ¢Ã¢â€š ¬Ã¢â‚¬Å" à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã‚ ¦And when the last law was down, and the Devil turned round on youà ¢Ã¢â€š ¬Ã¢â‚¬ where would you hide, Roper, the laws all being flat?à ¢Ã¢â€š ¬Ã¢â€ž ¢[41] Strong written law will ultimately produce compelling yet balanced human rights protections. Bibliography ECHR Cases Maaouia v. France (2000) 33 EHRR 42 UK Cases Tabnak, R. v [2007] EWCA Crim 380 Secretary of State for the Home Department v Khadir (R on the Application of) [2003] EWCA Civ 475 A Ors v. Secretary of State for the Home Department [2004] UKHL 56; see also the Court of Appeal ruling [2002] EWCA Civ 1502, [2004] QB 335 Secretary of State for the Home Department v Rehman [2001] UKHL 47 United States Cases Arar v. Ashcroft, 414 F.Supp.2d 250, 2 74 n10 (2006) Hamdi v. Rumsfeld, 542 U.S. 507 (2004) Korematsu v. United States, 323 U.S. 214 (1944) Rasul v. Bush, 542 U.S. 466 (2004) Statutes European Convention of Human Rights, 1953 UK Human Rights Act, 1998 United Nations Universal Declaration of Human Rights, 1948 United Nations Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, 1985 United States Constitution, 1787 Secondary Sources American Bar Association (2006) National Security Law Report https://www.americanbar.org/groups/public_services/law_national_security/  (Accessed May 8, 2007) Arar Commission / Report of the Events relating to Maher Arar à ¢Ã¢â€š ¬Ã¢â‚¬Å" Analysis and Recommendations (2006) https://www.ararcommission.ca/eng/26.htm (Accessed May 8, 2007) Baker, Nancy V. (2003) à ¢Ã¢â€š ¬Ã‹Å"National Security versus Civil Libertiesà ¢Ã¢â€š ¬Ã¢â€ž ¢ Presidential Studies Quarterly 33, no. 3: 547+ BBC Newsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2006) M I-5 enabled UK pairà ¢Ã¢â€š ¬Ã¢â€ž ¢s renditionà ¢Ã¢â€š ¬Ã¢â€ž ¢ March 28, 2006 https://news.bbc.co.uk/2/hi/uk_news/politics/4851478.stm (Accessed May 8, 2007) Bork, Robert H. (2003) à ¢Ã¢â€š ¬Ã‹Å"Civil Liberties after 9/11à ¢Ã¢â€š ¬Ã¢â€ž ¢ Commentary July/August, 29+ Cohen, Nick (2002) à ¢Ã¢â€š ¬Ã‹Å"Time to Bite Back? Other Countries Got Something in Return for Backing Bush; the UK Just Carries on as Americas Poodleà ¢Ã¢â€š ¬Ã¢â€ž ¢ New Statesman January 28, 9+ Cohen, Stanley Folk Devils and Moral Panics: Thirtieth Anniversary Edition Routledge, 2002 Dershowitz, Alan (2004) Rights from Wrongs: A Secular Theory of the Origins of Rights New York: Basic Books Donnelly, Jack à ¢Ã¢â€š ¬Ã…“Human Rights are universalà ¢Ã¢â€š ¬Ã¢â€ž ¢ Opposing Viewpoints Series Farmington Hills, NJ: Greenhaven Press, pp. 19-24 Donohue, Laura K. (2006) à ¢Ã¢â€š ¬Ã‹Å"Anglo-American Privacy and Surveillanceà ¢Ã¢â€š ¬Ã¢â€ž ¢ Journal of Criminal Law and Criminology 96, no. 3: 1059+ Gentry, John A. à ¢Ã¢â€š ¬Ã…“Defining Human Rights too broadly can destroy a nationà ¢Ã¢â€š ¬Ã¢â€ž ¢ Opposing Viewpoints Series Farmington Hills, NJ: Greenhaven Press, 48-58 Gibbs, Blair (2003) à ¢Ã¢â€š ¬Ã‹Å"Human rights are not necessarily universalà ¢Ã¢â€š ¬Ã¢â€ž ¢ Opposing Viewpoints Series Farmington Hills, NJ: Greenhaven Press, pp. 25 -31 Hobbes, Thomas (1651) Leviathan https://oregonstate.edu/instruct/phl302/texts/hobbes/leviathan-contents.html (Accessed May 9, 2007) Ignatieff, Michael (2001) Human Rights as Politics and Idolatry Princeton: Princeton University Press Mayer, Jane (2005) à ¢Ã¢â€š ¬Ã‹Å"Outsourcing Tortureà ¢Ã¢â€š ¬Ã¢â€ž ¢ The New Yorker https://www.newyorker.com/archive/2005/02/14/050214fa_fact6 (Accessed May 8, 2007) 1 Footnotes [1] Dershowitz, Alan (2004) Rights from Wrongs: A Secular Theory of the Origins of Rights New York: Basic Books, 59, 64 [2] Gibbs, Blair (2003) à ¢Ã¢â€š ¬Ã‹Å"Human rights are not necessarily universalà ¢Ã¢â€š ¬Ã¢â€ž ¢ Opposing Viewpoints Series Farmington Hills, NJ: Greenhaven Press, 28 [3] Ignatieff, Michael (2001) Human Rights as Politics and Idolatry Princeton: Princeton University Press, 4, 5 [4] Dershowitz, 81 [5] Hobbes, Thomas (1651) Leviathan 8 [6] Gentry, John A. à ¢Ã¢â€š ¬Ã…“Defining Human Rights too broadly can destroy a nationà ¢Ã¢â€š ¬Ã¢â€ž ¢ Opposing Viewpoints Series Farmington Hills, NJ: Greenhaven Press, 51, 52 [7] Donnelly, Jack à ¢Ã¢â€š ¬Ã…“Human Rights are universalà ¢Ã¢â€š ¬Ã¢â€ž ¢ Opposing Viewpoints Series Farmington Hills, NJ: Greenhaven Press, 24 [8] See the variety of cases determine annually by the European Court of Human Rights, coupled with the UK considerations of national statute compatibility with the ECHR [9] Gentry , John A., 50 [10] Ignatieff, 69 [11] Korematsu v. United States, 323 U.S. 214 (1944) [12] Ibid, 221 [13] See as examples Baker, Nancy V. (2003) à ¢Ã¢â€š ¬Ã‹Å"National Security versus Civil Libertiesà ¢Ã¢â€š ¬Ã¢â€ž ¢ Presidential Studies Quarterly 33, no. 3: 547+; Bork, Robert H. (2003) à ¢Ã¢â€š ¬Ã‹Å"Civil Liberties after 9/11à ¢Ã¢â€š ¬Ã¢â€ž ¢ Commentary July/August, 29+ [14] European Convention of Human Rights, 1953, Articles 5 and 6 [15] The key expression with in the Article stated asà ¢Ã¢â€š ¬Ã¢â€ž ¢ à ¢Ã¢â€š ¬Ã‚ ¦ may take measures derogating from its obligations under this Convention to the extent strictly required by the exigencies of the situationà ¢Ã¢â€š ¬Ã‚ ¦Ãƒ ¢Ã¢â€š ¬Ã¢â€ž ¢ [16] Hamdi v. Rumsfeld, 542 U.S. 507 (2004) [17] Ibid, 5th Amendment [18] Ibid [19] Ibid; see also Rasul v. Bush, 542 U.S. 466 (2004) [20] Arar v. Ashcroft, 414 F.Supp.2d 250, 274 n.10 (EDNY 2006); see also the Canadian Commission report, infra [21] Secretar y of State for the Home Department v Rehman [2001] UKHL 47 [22] Ibid, para 23 [23] Ibid, para 62 [24] [2004] UKHL 56; see also the Court of Appeal judgement at [2002] EWCA Civ 1502, [2004] QB335, where the Court emphasised the à ¢Ã¢â€š ¬Ã‹Å"inevitable trust and professionalism of the Security Serviceà ¢Ã¢â€š ¬Ã¢â€ž ¢ [25] [2004] UKHL 56 [26] [2003] EWCA Civ 475 [27] [2007] EWCA Crim 380 [28] Maaouia v. France (2000) 33 EHRR 42 [29] Khadir, para 86 [30] Cohen, Stanley Folk Devils and Moral Panics: Thirtieth Anniversary Edition Routledge, 2002 [31] Mayer, Jane (2005) à ¢Ã¢â€š ¬Ã‹Å"Outsourcing Tortureà ¢Ã¢â€š ¬Ã¢â€ž ¢ The New Yorker , 1 [32]United Nations Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, 1985 [33] Mayer, 2 [34] American Bar Association (2006) National Security Law Report, pp. 1-8 [35] BBC Newsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (2006) MI-5 enabled UK pairà ¢Ã¢â€š ¬Ã¢â€ž ¢s renditionà ¢Ã¢â€š ¬Ã¢â€ž ¢ March 28, 2006 [36] See also the US litigation, Arar v. Ashcroft, 414 F.Supp.2d 250, 274 n.10 (EDNY 2006) [37] Donohue, Laura K. (2006) à ¢Ã¢â€š ¬Ã‹Å"Anglo-American Privacy and Surveillanceà ¢Ã¢â€š ¬Ã¢â€ž ¢ Journal of Criminal Law and Criminology 96, no. 3: 1059+ [38] Ibid, 1059, 1068, 1072 [39] Ibid, 1079 [40] Cohen, Nick (2002) à ¢Ã¢â€š ¬Ã‹Å"Time to Bite Back? Other Countries Got Something in Return for Backing Bush; the UK Just Carries on as Americas Poodleà ¢Ã¢â€š ¬Ã¢â€ž ¢ New Statesman January 28, 9+ [41] Bolt, Peter à ¢Ã¢â€š ¬Ã‹Å"A Man for all Seasonsà ¢Ã¢â€š ¬Ã¢â€ž ¢, Act 1, scene 7

Sunday, May 24, 2020

What to Expect From General Knowledge Essay Topics May 2018?

<h1> What to Expect From General Knowledge Essay Topics May 2018? </h1> <h2> The Little-Known Secrets to General Knowledge Essay Topics May 2018</h2> <p>It is difficult to think about the dates of the entirety of the wars, significant occasions. In case you're making a database driven site you ought to be careful. The subject must be fascinating, the theme must be fundamental lastly the point must be enlightening. The site is easy to understand and can promptly create you a rundown of themes you may find intriguing. </p> <p>Detecting a repairman is decisively what you need to do. Prior to considering the top of the line useful exposition themes, it is important to ask what makes a magnificent point. When earlier conceptualizing is done, you may start drafting your article. Composing an extraordinary convincing paper is definitely not a straightforward assignment, be that as it may, it's achievable.</p> <p>With a ground-breaking processor and among the most recent Android working frameworks, execution won't ever be an issue. Studies have found that individuals that are profoundly educated in an exceptional space are slanted to be learned in many. The numerous themes might be found, for example, in the paper abstracts universal database. Thus, it's vital prepare for the drawing closer GDPIWAT forms. </p> <p>If you wish to utilize WordPress you should use Linux facilitating. Normally, it's conceivable! In the event that you are just inclined to make a typical site, at that point either Linux or home windows will probably be fine. Cinderella's carriage turns into a potato. </p> <h2> The Chronicles of General Knowledge Essay Topics May 2018</h2> <p>Parents need to converse with their youngsters about medications at an energetic age. So as to get youngsters, the two guardians should be confirmed. </p> <p>You see, the shows of English articles are to some degree more standard than you may might suspect and, from various perspectives, it tends to be as simple as checking to five. Write in a lot of sentences, in this way it's straightforward for the peruser to get. Anyway much one finds out about various subjects, it seems insufficient. </p> <p>Your article may fuse the clarifications for youngster pregnancy and discussion about the current paces of high schooler pregnancy and potential arrangements. Be sure that your paper is completely liberated from syntactic errors before distributing. </p> <p>A elegantly composed paper might be the most convincing segment of a grant program, and that is the reason a lot of time and consideration should be placed into its readiness. Your vet can propose the most legitimate pet clinical consideration protection organizations. Have a veterinarian or gifted companion show how to find the speedy. A few assessments join an exposition composing. </p> <p>1 task is to find the right article When choosing a point for your exposition, you're need to guarantee your subject backings the sort of paper you're anticipated to compose. In the event that you don't rest soundly, you're interfering with the procedure to keep up your general wellbeing. This technique is very useful for all to get information. Every single one of elements clearly don't bring down the state of our prosperity. </p> <p>In the occasion the FTCE inquiries in your audit aren't worded like the genuine test or are excessively simple, it may be a misuse of your time and permit you to hazard or defer your educating vocation. Following are different sorts of exposition themes for understudies that are classified in numerous areas so you can without much of a stretch picked the subject as indicated by your need and prerequisite. It won't be any not quite the same as each other blood test you've gotten. Right now, the composed test is obligatory to get any activity. </p> <p>Unfortunately, at present numerous people truly don't care for all their wellbeing. All the more in this way, it can prompt a decent arrangement of stress, dissatisfaction and disillusionment. Disclosing how to spend less by using open-source writings and web reading material rental sites would bring about a very instructive article. General information can help you on the scholastic front and furthermore develops your certainty level may end up being of hardly any serious tests. </p>

Saturday, May 23, 2020

Gender Identity Legal Research Paper Topics

<h1>Gender Identity Legal Research Paper Topics</h1><p>Gender character lawful research is significant for any individual who is managing the issues of being transgender. The normal individual considers transgender to be a joke. The best strategy is to find out about the issues that transgender individuals face in the public arena and how they might have the option to utilize these issues to their advantage.</p><p></p><p>Let's beginning with a trans lady who lives in Florida. She has consistently been pulled in to young men, particularly since she was a little youngster. She decided when she was 13 years of age to start taking female hormones with the goal that she could live as a girl.</p><p></p><p>So, what is an awful thing about it? Trans ladies are not really the most wonderful individuals you will meet. Here and there, they're more reserved and pulled back than gay or lesbian individuals. Be that as it may, the po sitives far exceed the negatives, and they permit trans ladies to do the things they'd prefer to do as men.</p><p></p><p>They are solid, serious, and no less human than a man. They can become men and the other way around. They are solid, energetic, and appreciate being with other women.</p><p></p><p>The opposite side of the coin is sex character lawful research. We should investigate a normal circumstance. In the event that a trans man and a trans lady live in a similar house, which one is going to need the option to trim the other's hair? In the United States, the laws favor the woman.</p><p></p><p>How is this for a case of a trans man? He's had a person with extraordinary searches for as long as he can remember and is presently dating a lady. He needs to kiss her and he truly enjoys her character. The different trans lady will not allow him to do as such. She said that he's simply not trans enough. She doesn't believe that he ought to have the option to date a lady since he has an exceptionally manly body and face. Sexual orientation character legitimate research is pivotal to seeing how individuals see transgender people.</p>

Thursday, May 21, 2020

Using Cover Page History Essays For Job Searching

<h1>Using Cover Page History Essays For Job Searching</h1><p>Sample spread page history articles are a basic piece of the request for employment process, regardless of whether you are searching for a vocation or essentially need to improve your CV. An elegantly composed, savvy history paper can absolutely help land you the correct activity in any case. In the event that you've never thought of one, you may be somewhat reluctant to make a plunge and start writing.</p><p></p><p>Fortunately, composing a spread page history is the same than composing some other composition. Truth be told, it is one of the least demanding and most mainstream composing ventures that understudies use in their examinations, as they will think that its simple to follow and anticipate as schoolwork. By the by, you need to take care to pick the correct example spread page history article for you.</p><p></p><p>The first thing you have to do is to choose what kind of test paper you will utilize. As a rule, a scholarly or research spread page history will be liked. This would imply that the paper will be founded on your scholastic accomplishments, inquire about encounters and even on your professional training. Your story ought to be founded on truth, not negligible facts.</p><p></p><p>If you want to utilize tests on the web, simply ensure that the examples depend on genuine history. The web crawlers have a lot of online example covers which you can peruse once more. There are additionally loads of test articles accessible online that you can peruse through to get thoughts for your own spread page. You can likewise locate some extraordinary free example papers accessible online.</p><p></p><p>Online tests are useful for individuals who incline toward snappy work, as they are shorter. In any case, in the event that you need a more top to bottom work, these examples won't furnish yo u with enough data. On the off chance that you are searching for complete models and genuine models, you have to search for an example that depends on recorded facts.</p><p></p><p>The best sites to search for test articles online are either by notable writers or by the individuals who are celebrated and notable in the online network. In spite of the fact that they can be costly, the substance of these online expositions merit the cost. Keep in mind, this is a speculation, so you should purchase quality materials to ensure that you're buying the best spread page history article for your resume.</p><p></p><p>With test page history expositions, you will have the option to improve your CV and land the position you've generally longed for. A resume isn't only a bit of paper. It is an approach to attract potential bosses and meeting them.</p>

Tuesday, May 19, 2020

College Board Essay Samples - Why Should You Use Them?

<h1>College Board Essay Samples - Why Should You Use Them?</h1><p>College Board is a pioneer in the accommodation of article tests for scholastic composition, and numerous understudies decide to utilize them on account of their assortment. Exposition tests permit you to make your own extraordinary style, regardless of what your subject may be.</p><p></p><p>College Board paper tests are not normalized, however are built by experts. This makes the papers as successful as they are unique. By utilizing the examples, you can compose any kind of exposition on any topic.</p><p></p><p>College Board article tests make it simple to form a paper with little exertion. Simply ensure you do your exploration before you begin. The paper tests will reveal to you how to structure your article, what sorts of exposition prompts ought to be utilized, and how to build up the general topic of the paper. At the point when you utilize the exam ple, you have an abundance of data at your fingertips.</p><p></p><p>Another advantage of the paper tests is that it gives you work on composing with a reason. At the point when you realize what to compose, you can compose productively. The paper tests likewise give you the instruments you have to build up your composing style.</p><p></p><p>One way that the school board article tests makes composing simpler is that it will give you work on composing an exposition on a particular theme. In the event that you just ever get the opportunity to expound on a specific subject, it will remove the pressure of composing it. You can expound on a book, a film, or whatever else, and you will even now have the option to place a subject into your article. It can likewise assist you with building up your own style, as well.</p><p></p><p>The exposition tests are accessible on the web, so you can download them right to your PC. Yo u can print them out or spare them onto your hard drive for sometime in the future. When you choose what subjects you need to expound on, you can start to investigate the points on the web. At the point when you have settled on your subject, you can begin to search for article tests to utilize. You can likewise discover great online assets to discover school board exposition tests for each topic.</p><p></p><p>Another preferred position of utilizing the article tests is that you can compose your own paper about any theme. You can likewise utilize the example expositions as a guide, or an approach to perceive what others have expounded on a specific theme. You can likewise discover from others on the off chance that they have utilized the example articles to help with their own writing.</p><p></p><p>By utilizing the school board paper tests you can expound on nearly anything, and you can build up your own interesting style. It is conceiv able to expound just on an article on practically any subject, in light of the fact that there are exposition tests for each topic.</p>

Saturday, May 16, 2020

A Cup of Tea by Katherine Mansfield - 2970 Words

A Cup of Tea By Katherine Mansfield Rosemary Fell was not exactly beautiful. No, you couldn t have called her beautiful. Pretty? Well, if you took her to pieces... But why be so cruel as to take anyone to pieces? She was young, brilliant, extremely modem, exquisitely well dressed, amazingly well read in the newest of the new books, and her parties were the most delicious mixture of the really important people and... artists - quaint creatures, discoveries of hers, some of them too terrifying for words, but others quite presentable and amusing. Rosemary had been married two years. She had a duck of a boy. No, not Peter - Michael. And her husband absolutely adored her. They were rich, really rich, not just comfortably well off, which is†¦show more content†¦She was outside on the step, gazing at the winter afternoon. Rain was falling, and with the rain it seemed the dark came too, spinning down like ashes. There was a cold bitter taste in the air, and the new-lighted lamps looked sad. Sad were the lights in the houses opposite. Dimly they burned as if regretting something. And people hurried by, hidden under their hateful umbrellas. Rosemary felt a strange pang. She pressed her muff against her breast; she wished she had the little box, too, to cling to. Of course the car was there. She d only to cross the pavement. But still she waited. There are moments, horrible moments in life, when one emerges from shelter and looks out, and it s awful. One oughtn t to give way to them. One ought to go home and have an extra-special tea. But at the very instant of thinking that, a young girl, thin, dark, shadowy - where had she come from? - was standing at Rosemary s elbow and a voice like a sigh, almost like a sob, breathed: Madam, may I speak to you a moment? Speak to me? Rosemary turned. She saw a little battered creature with enormous eyes, someone quite young, no older than herself, who clutched at her coat-collar with reddened hands, and shivered as though she had just come out of the water. M-madam, stammered the voice. Would you let me have the price of a cup of tea? A cup of tea? There was something simple, sincere in that voice; it wasn t in the least the voice of a beggar.Show MoreRelatedAnalysis of â€Å"A Cup of Tea† by Katherine Mansfield820 Words   |  4 PagesAnalysis of â€Å"A Cup of Tea†by Katherine Mansfield K.Vasiliev A Cup of Tea by Katherine Mansfield (1888 to 1923-New Zealand) is included in the 1923 collection of her work, The Doves Nest and Other Stories edited by Mansfields husband, John Middleton Murry.      There is a very moving introduction to this collection in which Murry lets us know details about the next ten stories his wife was going to write.    There is a temptation in reading Mansfield to see her work as artisticallyRead MoreA Cup of Tea by Katherine Mansfield: Creates a Contrast Between the Bland Ordinariness of a Cup of Tea4272 Words   |  18 Pages1 2 A CUP OF TEA BY KATHERINE MANSFIELD 3 4 5 Comment [LS1]: The title is linked to the central incident in the story and also acts as a linking device between Rosemary and Miss Smith. As Rosemary emerges from the antique shop in the cold, winter weather, she feels she ‘ought to go home and have an extraspecial cup of tea’. Immediately after that Miss Smith appears, begging desperately for something Rosemary has plenty of but which Miss Smith needs to sustain her existence. MissRead MoreAnalysis Of Katherine Mansfield s The Dolls House Essay2323 Words   |  10 PagesKatherine Mansfield was an early 20th New Zealand writer who focused on people and how they interacted with each other. She was often making comments on the society around her. The four short stories of Mansfield that I am going to talk about are also based on the interaction between societies. The people in the 19th century were blinded with darkness of class prejudice and external appearance. The four short stories are ‘The Dolls Houseâ€⠄¢ ‘The Garden Party’ ‘A Cup of Tea’ and ‘Miss Brill’. TheRead MoreAnalysis Of Katherine Mansfield s The Garden Party Essay1428 Words   |  6 PagesKelsey Archuleta Ms. Sparks AP Lit p.6 8 December 2016 Title Katherine Mansfield was a modernist short story writer during the 1920’s. She wrote various short stories in the few years as an author, Mansfield s stories often commented on class, relationships, families, and sexuality, After reading a few of her most popular works the common theme of them though out was the central conclusion of them all is the protagonist coming of age by seeing the more realistic view on life. The common themeRead MoreThe Themes Of Emotions In Katherine Mansfields Short Story839 Words   |  4 PagesKatherine describes her emotions through her characters in her short stories. She was a young New Zealand who was dying with a disease called Tuberculosis, she died at age 34. She successfully wrote three books with a fourth and fifth book following after her death. Moving back to New Zealand, her brother’s death in world war 1, and her emotions on how women were treated were all trigger points that led for her to write stories. Her stories were desc ribed as blurred edges of personality, the poetryRead MoreSummary Of The Book The Great Gatsby By F. Scott Fitzgerald1224 Words   |  5 Pagesbouncing `and mouths wide open , what was happening their eyes seemed to ask. Old Mrs Fairfield pattered in anxiously with breakfast quite out of breath and wondering what all the fuss was about. Ah it was Stanley feeling out of sorts oh well a good cup of tea and hot soup should fix it. Why couldn t these women realise how sick he was, how dreadful he felt. Here he was dying and all they could do was stand and stare at him Stanley slumped in his chair as he felt all four greenish walls moving andRead MoreEssay On Leo Tolstoy896 Words   |  4 PagesTogether in My Name. 9.Katherine Mansfield Katherine was born on October 14, 1888 in New Zealand. She died at the age of thirty-four from tuberculosis on January 9, 1923. Katherine and her four siblings were the children of Annie Beauchamp and Harold Beauchamp, who was the chairman of the Bank of New Zealand. She attended Queen s College along with her sisters. She was married twice,once to George Bowden, and once to John Middleton Murry. Katherine wrote The Fly, Prelude, A Cup of Tea, and A little boy’sRead MoreManaging Information Technology (7th Edition)239873 Words   |  960 Pagesstudying some of the IT topics in this textbook. Bibliography Bala, Iyer, and John C. Henderson. 2010. â€Å"Preparing for the future: Understanding the seven capabilities of cloud computing.† MIS Quarterly Executive 9, 2 (June): 117–131. Boehret, Katherine. 2010. â€Å"For the iPad, Apps with their own wow factor.† The Wall Street Journal (April 7): D3. Brown, Carol V. 2004. â€Å"Seamless IT alignment† in S. Chowdhury (ed.), Next Generation Business Handbook. New York: John Wiley Sons, 1157–1168. Carr

Friday, May 15, 2020

Is This Career College Essay Guy A Great Job Or A Dream Job?

<h1>Is This Career College Essay Guy A Great Job Or A Dream Job?</h1><p>An online higher education is likewise called a 'profession school article fellow'. It is a blog wherein you present a paper for every single task. They acknowledge some new authors as well as some old ones.</p><p></p><p>An significant thing to recall about the activity of an article essayist is that you need to compose expositions as indicated by the prerequisites of the doled out understudies. The most ideal approach to gain proficiency with this subject is by composing and submitting articles as per your skill. On the off chance that you are truly keen on carrying out this responsibility, the fundamental information about language structure isn't enough.</p><p></p><p>As a paper author, you can exhibit your abilities through numerous sources. The fundamental thought behind this is you are the person who can alter the exposition dependent on the n ecessary corrections. Thusly, your activity incorporates altering the article which is fixed and as indicated by the necessity of the test. You ought to have the option to get a passing mark in this sort of job.</p><p></p><p>Besides, there are numerous assignments where you are given the opportunity to pick your own subjects. For this situation, you must be prepared to do the task as per the adjustments in the understudy's desires. The activity of a paper essayist isn't just expounding on a given subject yet in addition about his own character and purposes of view.</p><p></p><p>You ought to have the option to write in a fascinating way particularly in a specific zone of intrigue. This activity is commonly considered as one of the least demanding just as the most testing since you are expounding on themes that everybody is now acquainted with. Notwithstanding, it is for the most part viewed as the most compensating activity in advanced education since it can assist you with increasing an important work involvement with the instructive field.</p><p></p><p>If you are filling in as a vocation school paper fellow, you can choose to telecommute. One of the benefits of telecommuting is that you will have the option to work at whatever point you feel like. Additionally, on the off chance that you need to switch employments later on, you can without much of a stretch move to an alternate city.</p><p></p><p>Overall, the profession school exposition fellow is a fascinating activity since you are permitted to investigate all the chances of training. Be that as it may, you ought to be set up for the exclusive requirements from understudies as they will expect you to give them a last grade. In spite of the fact that you are the person who can alter the article dependent on the necessities of the task, it is as yet your obligation to complete the task on schedule and fulfill the t ime constraints. At long last, it is the duty of the understudies to fulfill the requests of the university.</p>

Tuesday, May 12, 2020

The Process of Research Paper Topics in Operations Management

<h1>The Process of Research Paper Topics in Operations Management</h1><p>Managing a business today isn't just about paper-cutting up the calendar of the organization and that is it. Effective administration must be founded on a careful and complete comprehension of current industry patterns, especially those identified with market, creation and deals patterns. In that capacity, one needs to continually refresh their insight base to give the organization an edge over its competitors.</p><p></p><p>Paper subjects of activities the executives incorporate operational system, individuals and HR, client support, cost decrease, group building, showcase examination, creation the board, stock control, venture the executives, creation arranging, speculation, money related administration, budgetary revealing, conveyance, appropriation channels, stock control, client relationship the executives, time and work following, flexibly chain the executives, work financial matters, income investigation, promoting and publicizing and some more. For a director, the initial phase in the board inquire about is to compose a postulation that depends on information. In the business field, there are a few firms and associations that offer free exercises so as to assist an administrator with advancing in their vocation. Such exercises can be found in different enterprises like emergency clinics, shopping centers, eateries, inns, etc.</p><p></p><p>Upon finding out about these exercises, a director should take up the board investigate papers from these organizations. Beside having a great deal of leisure time, these foundations likewise make the activity simpler for you. On the off chance that you are seeking after a profession in business, you don't have to invest a lot of exertion. A great deal of business establishments give quality training, which is effectively accessible on the web. You should simply look for these establ ishments by the business division and the area that you wish to join.</p><p></p><p>For an activities the board examine paper theme, ensure that you compose a general research report on the particular business that you have picked. This will assist you with drawing examinations with your rivals just as industry patterns. Beside this, you can utilize the business slants as articulations and inquiries that you need to ask.</p><p></p><p>Once you have laid out the requirements that you have to satisfy, at that point you will have the option to figure out which organization is most appropriate for you. For this, you can ask your bosses, partners, or meeting a few people whom you work with so as to discover progressively about the organization and its practices. You can likewise utilize the organization site to get a more clear picture on the activities of the company.</p><p></p><p>After you have finished with your exp loration, you should then continue to composing your tasks the executives look into paper subjects. When expounding on the organization's tasks, you need to abstain from offering bogus expressions. Ensure that you just point out what you feel is right, without making bogus accusations.</p><p></p><p>You need to ensure that you follow your examination into composing as time advances. Since a business activity incorporates a ton of obligations, you should be precise in your composition. After you have completed your paper point, you would now be able to submit it to different magazines and diaries, just as industry affiliations that manage business. These associations ordinarily acknowledge entries as per a fixed deadline.</p><p></p><p>If you find that your exploration paper themes for activities the board are insufficient to persuade your bosses and friends, at that point you can even demand for extra research papers. This would be given to you as per your inclination. Additionally, you should be extra cautious in the event that you decide to present your paper subject to a few distinctive associations.</p>

Friday, May 8, 2020

The Good College Essay Examples for Admission Trap

<h1> The Good College Essay Examples for Admission Trap </h1> <p>Your article is a particular impression of who you are as a person. Assuming this is the case, it needs a title. On the off chance that you are needing a very much created paper, at that point you can rely upon us to convey. Before you begin composing your school paper, you may need to see the article examplesA that we've recorded for you, with the goal that you may have more thought on what things to place in the school exposition you will make. </p> <p>Bridget's paper is very solid, yet there keep on being a couple easily overlooked details that could be improved. Having great article models gives the peruser a top to bottom and on-the-court thought regarding what an all around organized and reasonable exposition seems like. Who knowsthe answer for that question might be the establishment for your confirmation paper. Simple and direct language can be somewhat incredible. </p> <h2> Lies You've Been Told About Good College Essay Examples for Admission</h2> <p>If you wish to go individual and select a family member, be certain you get a noteworthy and particular explanation. In the event that you'll contain subtleties that may legitimately hit the prerequisites of the school, at that point it is easy to get the approvalA that you should be acknowledged for enlistment. Clarify your duties, and you will be the kind of understudy universities find tremendously alluring. With a superb advanced degree, an i ndividual can have a commendable existence and envision a splendid future.</p> <p>1 approach to get a thought of what schools are attempting to discover is to peruse some awesome expositions from understudies who've been fruitful in their offered to place in a specific college. On the off chance that quality work is all you need, you should take a gander at allowing us a chance to tail you and flexibly you with school article assist that with willing furnish you with esteem for every single penny you pay. Last, you're finished with secondary school and can't look for the following phase of your life. Maybe right currently you're attempting to enter the school that you long for. </p> <p>Should you conclude you should visit around one of the adage article themes referenced beforehand, a generally excellent intends to recount to an increasingly common story is to focus on one explicit second and work starting there. Plunk down, consider the story you wish to compose. Your accounts aren't questionable. Sharing an individual story that is identifie d with the brief is an awesome way to deal with produce your article stick out from the group. </p> <p>Thus, the paper should correspond with the candidate's characteristics and interests with the end goal for it to help the potential outcomes of confirmation. Since our authors are specialists in a few types of papers, we see how to focus on your school regardless of the control you picked. It's helpful to dismantle composing as an approach to see only the way that it achieves its targets. As an outcome, going through cash to deal with your papers might be testing. </p> <h2> What's Actually Going on with Good College Essay Examples for Admission</h2> <p>Admissions officials don't anticipate that you should be great, and in this manner don't make your exposition mind blowing by endeavoring to imagine that you're. More much of the time than not, cutoff times for submitting applications are quite often short which makes numerous potential candidates stress they will be not able to present their example exposition for MBA application in time. You can get your paper done in less than 4 hours, and it'll be of top quality. Exposition is a principal sort of desk work you generally need to manage while considering. </p> <p>Since you are keen on getting the exposition to impart the perfect data about you, you ought to do exhaustive groundwork for the example school affirmation papers to achieve its motivations. A spectacular exposition can assist you with getting acknowledged to your fantasy school. In the event that you will compose school affirmation article completely all alone, at that point don't disregard the proper structure of the paper. Because you've just composed a school exposition for a solitary college doesn't imply that it might likewise apply on your next applications. </p> <p>Thankfully, should you not comprehend where to start, you can look into a secondary school or college alumni affirmations paper test from our site. It is critical to catch the enthusiasm of the confirmation guides regardless of how severe they may give off an impression of being. Notwithstanding what school you need to enlist at, you ought to make an affirmation exposition. The school affirmation exposition has a significant impact in the enlistment approach. </p> <h2> The Debate Over Good College Essay Examples for Admission </h2> <p>Although every feature of your school application is basic, a solid school confirmation exposition is only one of the most fundamental components of the application. The exposition is effectively among the most irksome segments of the school application practice. Looking into a wide range of confirmation exposition models offers you a more clear thought of the best approach to deal with the topic at a superior introducto ry letter. Probably the best technique to verify you get an excellent example exposition for MBA application or some other school course is by working with respectable destinations. </p>

What Is the Essay Samples For Specific Types of Subjects?

What Is the Essay Samples For Specific Types of Subjects?With the many different topics in life that require essays, it would be easy to think that there is no way to find essay samples for any topic. But then again, if you had some basic research, you could come up with a lot of information about essays that would be useful to your research.After all, it has been well known that Yale University offers many essay samples for various types of subjects, whether it is an arts or science. Not only that, but the Yale School of Arts and Sciences, specifically offers many topics that are very popular and help students make good grades.Now, do not be discouraged by the fact that many of the topics that you are familiar with were in a class that you took. There are other topics that you could try to write a research paper on that have not been taught in the past.But of course, if you have done the research and you are looking for topics that have been used before, you would want to be sure th at they are no longer being taught. Then again, there is always a chance that the subject may be considered outdated by the college or university you are taking the class in.By getting this information, you can certainly find the best essay samples for your subject. The next thing that you will want to do is to go over each essay sample and determine what you think you would like to write on the essay.Once you have this information, you will then need to decide what kind of conclusion you would like to have. If you want to focus on a certain person or situation that has a large influence on the essay, then you should focus on the main points of the essay.As you can see, this is the last thing that you will need to consider when deciding what is the best conclusion for your final analysis. The main thing is that you focus on the main points of the essay and the main point is that you can use these in your final report.Your final report is the only objective that you will have to make sure that you cover the points that the professor wants to be covered in your final analysis. This will help you give an overall view of your grades and make sure that you do not go overboard in covering all the things that are involved in the class.

Wednesday, May 6, 2020

The Ethical Issues Of The Undiagnosed Pain Scenario

Pain is an immanent aspect of life; it is protective, provoking innate survival mechanisms in response to a perceived threat. As such, it is often associated with extremes of emotion, designed to protect the individual during times of bodily stress (Savage, 2008). However, the underlying cause of such pain is not always readily elucidated. Devoid of objective measures or obvious underlying pathology, the physician is reliant on the patient’s perception of their pain to govern treatment. When such a pain management scenario is further complicated by clinical suspicion of substance abuse, especially in the setting of opioid analgesia, treatment is both medically and ethically complex (Novy, 2009). This case study attempts to address the†¦show more content†¦History and clinical examination were unremarkable. She was admitted and commenced on opioid pain medication with ability to self administer as required. The treating physician immediately commenced a litany of investigations, both invasive and non-invasive. Over the course of her two week admission, infection, malignancy, pregnancy and a spectrum of other conditions were similarly excluded as the cause of her discomfort. Ms CP’s medical records were eventually obtained from neighbouring hospitals, revealing multiple lengthy admissions for medically unexplained symptoms, following a childhood spent on the children’s ward due to chronic severe asthma. Multiple references to clinical suspicion of substance abuse were identified. Investigation into her social history revealed Ms CP to be unemployed, with her welfare payments having recently been ceased following a resolved back injury which occurred 2 years previously. Throughout her hospital stay, Ms CP was exceptionally helpful, providing detailed history to medical staff and volunteering in learning tutorials with medical students. She described the hospital as her â€Å"home† and spoke fondly of a childhood spent terrorising students and junior doctors while receiving treatment for her asthma. During comprehensive history taking and examination conducted by multiple health professionals, her descriptions shifted and evolved, often differing between healthcare providers and

Tuesday, May 5, 2020

Good Earth Essay Example For Students

Good Earth Essay The Good Earth Pearl S. Buck / Historical Fiction The Good Earth is asaga about the life and death of Wang Lung. The story starts out on his weddingday as he gets ready to be marries. He is having a traditional farmer wedding inwhich his father has chosen his wife which he is to have many children with. Inthe later years in the midst of a famon they are forced to move south which wasnot much better than the north. A revolution broke out and during it O-lan andWang Lung Both rummaged through the great housewhere O-lan stumbles upon a pouchof jewels. After being let go by the soldiers they are able to back to the landwhere there is now rain. O-lan being the loyal wife she gives Wang Lung thepouch of jewels except two pearls that she keeps for herself. Later Wang Lung inhis greed takes the pearls from her to give to his conquebine. When the locustscome he reunites himself with the land in a struggle to save it. O-lan diesquickly after his sons wedding and Wang Lung is next to come. Wang Lung on hisdeath bed in a house that is not even his requests that his sons never sell theland. His sons agree to it with their fingers crossed behind their backs in highhopes to become rick quick. No matter who you are and how much you think you cancontroll it, money will corrupt most people in this so called world. The maincharacter in this book is Wang Lung. In the beginning he is a common farmer whoworks in the fields all day next to his ox. He has a braid and has no reason toclean him self, his father who he supports is old and cannot help himself. Whenthe money comes rolling in he hires people to do the work in the fields for him,he now wears silken robes and is clean every day. During this time he cuts offhis braid and brings a conquebine to the great house of Whang, which he bought. Most of the workers on his fields think he is a fool, because he cannot see thethings that are going on behind his back. In the book some spots were difficultto read because of the vocabulary, which made me go back and reread thosetrouble parts. The length of the sentences didnt effect me but when a wordthat I didnt know it made it harder to back track. I would not read annotherbook by Pearl S. Buck because I think it draged on too long and it didnt holdmy intrest long enough to be really interesting. I experienced that her booksare boring and drag on for hundreds of pages. It had no meaning, except for thetorture I went through while I was reading it.