text:
Showing deals
Nashville Deals
$17 for $30 Worth of Seasonal American Cuisine at The Tin Angel. Groupon Reservation Required. $17 at Groupon
Swedish or Volcanic Massage, Facial, or Agave-Nectar Mani-Pedi at The Woodhouse Day Spa (Up to 53% Off) $59 at Groupon
18 Holes of Golf with Cart Rental for Two or Four at Fairways on Spencer Creek (Up to 48% Off) $34 at Groupon
60-Minute Massage with Facial or Body Scrub at Adagio Massage Company (Up to 48% Off). Two Options Available. $85 at Groupon
$19 for $40 Worth of Go-Karting, Mini Golf, and Other Family Activities at Cedar Creek Sports Center $19 at Groupon
$65 for Dinner for Two with Appetizer and Dessert at Flyte World Dining and Wine (Up to $123 Total Value) $65 at Groupon
One-Week History Day Camp at Historic Travellers Rest Plantation & Museum (56% Off). Six Options Available. $79 at Groupon
$38 for Jiffy Lube Signature Service Oil Change, Tire Rotation, and Rain-X Original Glass Treatment (Up to $75.97 Value) $38 at Groupon
Half- or Full-Day Pontoon Boat Rental at Cuba Landing + Perryville Marina (Up to 54% Off) $69 at Groupon
58% Off3, 7, or 10 Days of Valet Off-Site Outdoor Airport Parking at Flight Park (Up to 53% Off) $18 at Groupon
Two-Hour Shooting-Range Package for Two or Four at Everything Weapons Franklin Shooting Range (Up to 47% Off) $25 at Groupon
Two or Four Zipline, Bumperball, or Skyjump Tickets at The Kids Ultimate Fitness Challenge on May 24th (43% Off) $17 at Groupon
A Tribute to Billie Holiday with Cassandra Wilson at Schermerhorn Symphony Center on April 8 (Up to 51% Off) $19 at Groupon
$69 for a Zipline and Ropes Course with Gloves for Two at Treetop Adventure Park at Nashville Shores ($117.95 Value) $69 at Groupon
1- or 1.5-Hour Swedish Massage or 1-Hour Couples Swedish Massage at Islands of Paradise Massage (Up to 54% Off) $30 at Groupon
$39 for One Month of Unlimited Group Fitness Classes at Fit Factory Nashville ($119 Value) $39 at Groupon
75-Minute Therapeutic Massage for One or Two at SoBro Massage in the Gulch (Up to 65%Off) $59 at Groupon
1-, 2-, or 3-Night Stay with Sunset Cruise, Dessert, and Breakfast at Mountain Harbor Inn in Dandridge, TN. $139 at Groupon
70-Minute Individual or Couples Reflexology Package at Relax Massage!! (Up to 57% Off) $39 at Groupon
One Mani-Pedi or One Shellac Mani-Pedi from Janice Brown at Grace's Plaza (Up to 54% Off) $30 at Groupon
6- or 15-Bottle Discovery Wine Pack with One-Year Membership from Splash Wines (Up to 78% Off) $39 at Groupon
One-Hour Clay Target Shooting Lesson for One, Two or Four from Mitchel Loveless Shooting Lessons (Up to 67% Off) $59 at Groupon
Four-Day Kids' Cheer, Tumbling, and Dance Camp at American Twisters (71% Off). Three Options Available. $29 at Groupon
$49 for Four-Week Weight-Loss Program with LipoLean or B12 Injections at Genesis Weight and Age Management ($250 Value) $49 at Groupon
60-Minute Massage for One or 60- or 90-Minute Couples Massage at Pure Life Massage and Wellness (Up to 59% Off) $39 at Groupon
One or Two 16"x20" Gallery-Wrapped Canvas Prints from Canvas On Demand (Up to 79% Off). Free Shipping. $30 at Groupon
Daytime BYOB Nashville Bus Tour for One or Two from Nashville Double Decker (Up to 45% Off) $13 at Groupon
Asian Lunch or Dinner at Fulin's Asian Cuisine (Up to 47% Off). Three Options Available. $8 at Groupon
$99 for a Master Project Management Course Bundle from Career Match ($4,016.95 Value) $99 at Groupon
Chiropractic Exam with One or Three Adjustments and Massages at Pro Massage & Chiropractic (Up to 83% Off) $30 at Groupon
40, 75, or 110 Custom 5"x7" Flat Cards, Invitations, or Announcements with Envelopes from $24.99–$44.99 from Zazzle $25 at Groupon
Eye Exam with Options for 30-Day Contacts Trial or Prescription Glasses at Insight Vision Center (Up to 73% Off) $49 at Groupon
25 Units of Xeomin or One Syringe of Belotero at Evolve Weight and Age Management (Up to 75% Off) $199 at Groupon
$149 for a Consult and Injection of Up to 20 Units of Botox at Goodlettsville Family Dental ($295 Value) $149 at Groupon
30-Day Weight Loss Program for One at Premier Age Management & Medical Weight Loss Center (Up to 69% Off). $49 at Groupon
Asian-Fusion Cuisine at Suzy Wong's House of Yum (Up to 40% Off). Two Options Available. $12 at Groupon
One or Two Microdermabrasions with Masks from Jennifer Scheetz at Brentwood Salon & Day Spa (Up to 56% Off) $39 at Groupon
One or Two 60-Minute Massages, or 90-Minute Massage at Pure Life Massage and Wellness (Up to 62% Off) $35 at Groupon
Ornament or Paperweight Glass-Blowing Workshop for One or Two at Franklin Glassblowing Studio (Up to 56% Off) $59 at Groupon
Virtual Firearm Training for 2, 4, or 8 People or a Party Package at QuickDraw Nashville (Up to 60% Off) $20 at Groupon
iPhone 5 Screen Repair or Accessories, or Screen Repair for iPhone 4, 4S, 3G, or 3GS at iJunkiez (Up to 59% Off) $30 at Groupon
Canvas Prints from MyPix2.com with Free Shipping (Up to 75% Off). Four Options Available. $15 at Groupon
One 8"x10", 11"x14", 16"x20", or 18"x24" Canvas Print from Easy Canvas Prints (Up to 77% Off) $10 at Groupon
One or Two Groupons, Each Good for a One-Hour Swedish Massage at Relaxation Therapy (Up to 53% Off) $39 at Groupon
Six Laser Hair-Removal Sessions on Small or Medium Area at Rejuvenation Group (Up to 90% Off) $129 at Groupon
Dog or Cat Boarding or $30 Worth of Pet Supplies at Miss Kitty's Bed & Bath (Up to 64% Off) $45 at Groupon
One, Three, or Six Lipo-Laser Treatments at Premier Age Management & Medical Weight Loss Center (Up to 79% Off) $69 at Groupon
Casual Grill Fare and Drinks at Commerce Street Grille (Up to 45% Off). Two Options Available. $22 at Groupon
Laser Hair Removal at LaserDerm MedSpa & Wellness (Up to 92% Off). Four Options Available. $79 at Groupon
One, Three, or Six Microdermabrasion Treatments at Nashville Skin Company (Up to 63% Off) $30 at Groupon
Laser Hair-Removal Treatments at Evolve Weight and Age Management (Up to 94% Off). Four Options Available. $99 at Groupon
One or Three Oil Changes with 27-Point Inspection and Top Offs at Speedy Lube and Auto Care (Up to 57% Off) $25 at Groupon
Interior and Exterior Cleaning for 10 Windows from Heath Window Service (Up to 51% Off) $49 at Groupon
Six Laser Hair-Removal Treatments on a Small, Medium, or Large Area at Gilmer Plastic Surgery (Up to 91% Off) $149 at Groupon
Exam with X-Rays, Cleaning, and Optional Take-Home Whitening Kit at Matt McGee, DDS, PC (Up to 84% Off) $49 at Groupon
Homestyle Country Cuisine at Norman Couser's Country Cooking (40% Off). Two Options Available. $12 at Groupon
$49 for an Eye Exam and $110 Toward a Complete Pair of Glasses at Dr. Lisa Davis VisionCare ($205 Value) $49 at Groupon
Laser Hair Removal at Laser Away Nashville Tattoo & Hair Removal (Up to 92% Off). Three Options Available. $116 at Groupon
Tandem Skydive with Digital Video for One or Two from Chattanooga Skydiving Company (Up to 50% Off) $159 at Groupon
$159 for Spa Package with Hot Oil Massage and Facial at The Nurture Nook Day Spa & Gift Shoppe ($324Value) $159 at Groupon
Two or Four Groupons, Each Good for One 12-Ounce Juice at Lynne Lorraine's (Up to 50% off) $3 at Groupon
Haircut Package with Optional Color or Highlights from Kayla Miller at Salon Galleria (Up to 71% Off) $49 at Groupon
$35 for a European Facial or Mani-Pedi at Adela's Color Salon & Spa (Up to $82 Value) $35 at Groupon
Laser Hair Removal for a Small, Medium, or Large Area at Rejuvenation Health and Wellness (Up to 85% Off) $129 at Groupon
$14 for Jumbo Hot Chicken Tender Meal for Two at Big Shake's Hot Chicken ($26.38 Value) $14 at Groupon
International Cuisine for Dine-In, Carry-Out, or Catering at The Cookery (Up to 54% Off) $9 at Groupon
15 or 25 B12 Injections or 6 or 10 LipoLean Injections at Genesis Weight and Age Management (Up to 83% Off) $59 at Groupon
5 or 10 BarreAmped, Core Rhythm, UGI, or BUTI Yoga Classes at Serenite' Fitness (Up to 72% Off) $25 at Groupon
Fried Chicken, Fish, and Southern Food at Big Shake's Hot Chicken (Up to 43% Off). Two Options Available. $12 at Groupon
One or Two Monogrammed Fleece Vests from Embellish Accessories and Gifts (Up to 53% Off) $29 at Groupon
$39 for a Monogrammed Pendant Necklace from Monogramhub.com ($109.99 Value). Free Shipping. $39 at Groupon
All-Day Shooting-Range Package for Two or Four at Everything Weapons Franklin Shooting Range (Up to 47% Off) $25 at Groupon
$14 for $24 Worth of Italian Brunch Served 9 am-2 pm and Drinks at Coco's Italian Market & Eatery $14 at Groupon
iPad Repairs or Screen Replacement for iPhone at iHospital - Nashville (Up to 58% Off) $25 at Groupon
Tape-to-DVD Conversion or Photo Digitization at AJ Media Services (Up to 64% Off). Three Options Available. $15 at Groupon
One or Three Months of Unlimited Classes at CrossFit Middle Tennessee (Up to 79% Off) $49 at Groupon
$19 for an Online Screenwriting Certification Course from Writing Academy ($299 Value) $19 at Groupon
Online Accounting and Bookkeeping Course for 1 or 10 People from Excel With Business (Up to 92% Off) $29 at Groupon
One or Three Months of Unlimited CrossFit Classes at CrossFit Cumberland (Up to 63% Off) $39 at Groupon
Custom Square Instagram Photo Canvas from Printerpix. Multiple Options from $8.99–$59.99 $9 at Groupon
One, Two, Four, or Eight Videotape-to-DVD Conversions at Earmark Digital (Up to 69% Off) $14 at Groupon
$19 for One Year of Online Guitar Lessons from Center Stage Guitar Academy ($108 Value) $19 at Groupon
One or Three Conventional- or Synthetic-Oil Changes at Franklin Oil Stop (Up to 58% Off) $85 at Groupon
Guided Off-Road Half-Day ATV Rentals for Two or Four from Four Wheelin' Expeditions (Up to 58% Off) $229 at Groupon
$399 for $1,700 Toward Any Memory-Foam or Spring Mattress from Zen Bedrooms. Additional Option Available. $399 at Groupon
Two-Hour Indoor or Outdoor Photography Class for One or Two from Serendipity Studio (Up to 68% Off) $49 at Groupon
One or Three Hot-Oil Manicures with Spa Deluxe Pedicures at Tina Starr Nails (Up to 59% Off) $79 at Groupon
Sandwiches, Burgers, and Drinks at 3 Brothers Deli and Brewhouse (Up to 52% Off). Two Options Available. $12 at Groupon
Fast-Track or Complete Social-Media Marketing Course from Social Media Marketing University (Up to 95% Off) $99 at Groupon
Tour Package for Six, Four, or Two, or a One-Year Family Membership at Belmont Mansion (Up to 61% Off) $35 at Groupon
Furnace and Plumbing Services from Hiller Plumbing, Heating & Cooling Company (Up to 54% Off). Two Options Available. $69 at Groupon
One- or Two-Hour Fly-Fishing Lesson for Up to Two from Rod & Gun Guide Services (Up to 75% Off) $70 at Groupon
$59.99 for $139.99 Worth of Personalized and Framed Alphabet-Photography Keepsake Art from Sticks and Stones $60 at Groupon
Haircut Package with Optional Partial or Full Highlights at Serena Renae's Salon and Spa (Up to 65% Off) $59 at Groupon
$49 for a Sage 50 Accounting Certification Course Bundle from IT University Online ($795 Value) $49 at Groupon
One or Three Custom Express Facials at The Nurture Nook Day Spa & Gift Shoppe (Up to 65% Off) $29 at Groupon
5 or 10 BarreAmped or Yoga Classes at Relevé One Fitness Studios Featuring BarreAmped (Up to 59% Off) $69 at Groupon
In-Home Mother-Daughter Spa Party for 4 or 10 at Petite Priss Spa Parties (Up to 54% Off) $79 at Groupon
Spa Package with a Massage, Facial, and Mani-Pedi for One or Two at Mona Lisa's Massage & Wellness (Up to 60% Off) $99 at Groupon
Haircut and Conditioning with Optional Color or Partial Highlights or Full Highlights at Cuttin Loose (Up to 65% Off) $23 at Groupon
Haircut and Conditioning with Options for Color or Full or Partial Highlights at Kala's Kuts & Kolor (Up to 59% Off) $69 at Groupon
One or Three Custom Facials or Three Luxury Facials at Velvet Trim Hair Spa (Up to 63% Off) $99 at Groupon
Cut and Condition with Optional Color or Highlights from Amber at Serena Renae's Salon Spa and Fitness (Up to 65% Off) $59 at Groupon
Laser Hair Removal for One Small, Medium, Large, or Extra-Large Area at Skin Renew Laser & Vein Clinic (Up to 91% Off) $129 at Groupon
Haircut, Blowout, and Argon Oil Treatment with Optional All-Over Color or Highlights at John Lane Studio (Up to 61% Off) $65 at Groupon
$22 for a Family Package with Five Go-Kart and Mini-Golf Passes and One Photo at Cooter's Place ($45 Value) $22 at Groupon
$499 for Six Zerona Treatments with Whole-Body Vibration at Advanced Medical of Cool Springs ($1,740 Value) $499 at Groupon
Spinal-Decompression Package at Elite Wellness Centers (Up to 89% Off). Three Options Available. $39 at Groupon
Fine Jewelry and Diamond Engagement Rings at Village Jewelers (Up to 55% Off). Two Options Available. $50 at Groupon
One, Three, or Five Cranial Massages and Blowouts, Plus Wine, at The Beauty Bar Salon & Boutique (Up to 64% Off) $25 at Groupon
One, Two, or Four Ultimate Contouring Facials with Alleia Tone and Firm Wraps at La Bella e Famosa Spa (Up to 84% Off) $75 at Groupon
$29 for Chiropractic Exam, X-rays, Adjustment, and Physical Rehab at Advanced Medical of Cool Springs ($295 Value) $29 at Groupon
One or Two 60-Minute Massages or One 90-Minute Massage at The Potter's Hand (Up to 54% Off) $29 at Groupon
$4,999 for Roof Replacement from Magnolia Construction Group, LLC (Up to $11,375 Value) $4999 at Groupon
Custom Bowls, Signature Bowls, or Salads with Drinks for Two or Four at GRILLiT (Up to 58% Off) $11 at Groupon
60-Minute Relaxing, Prenatal, or Couples Side-by-Side Massage at Daily Kneads Therapeutic Massage (Up to Half Off) $35 at Groupon
Deep-Cleansing or Signature Organic Greens Facial at Skin & Beyond Day Spa (Up to 57% Off) $49 at Groupon
Cut with Optional Full Highlights or Partial Highlights or Single-Process Color at Tiffany on the Row (Up to 57% Off) $25 at Groupon
Six Laser Hair-Removal Treatments on a Small, Medium, or Large Area at Aqua Colour Lounge & Medspa (Up to 79% Off) $129 at Groupon
Keratin Straightening Treatment with Optional Haircut at The Villa Day Spa & Salon (Up to $255 Value) $99 at Groupon
iPhone 5 Screen Repair or Accessories, or Screen Repair for an iPhone 4, 4S, 3G, or 3GS at iJunkiez (Up to 59% Off) $30 at Groupon
30- or 60-Minute Foot Reflexology Session at Pure Life Massage and Wellness (Up to 56% Off) $19 at Groupon
$39 for a Chiropractic Consultation, X-rays, Adjustment, and Massage at Vitality Chiropractic ($255 Value) $39 at Groupon
$29 for Professional Teeth Whitening Kit with Retainer Case from Snow Teeth Whitener ($199 Value) $29 at Groupon
One-Hour Guided Group Horseback Trail Ride for Two or Four at JuRo Stables (Up to 51% Off). Four Options Available. $25 at Groupon
$99 for a Complete Cisco Certification IT Network Training Bundle from IT University Online ($3,295 Value) $99 at Groupon
$49 for a Deep Tissue Massage with Feet Treatment at A Touch of a Feather Day Spa ($100) $49 at Groupon
One-Hour Skeet-Shooting Lesson for One or Two at Terry Hetrick Shooting School (Up to 66% Off) $79 at Groupon
60-Minute Massage for One or Two or 90-Minute Massage for One at Mona Lisa's Massage and Wellness (Up to 50% Off) $39 at Groupon
Pub Food Meal for Two or Four with Optional Bucket of Domestics at Brew U (Up to 53% Off) $12 at Groupon
20 Hot Yoga Classes or One Month of Unlimited Hot Yoga Classes at Hot Yoga of East Nashville (Up to 73% Off) $75 at Groupon
Scrapbooking Materials and Supplies at The Sassy Scrapper (50% Off). Two Options Available. $15 at Groupon
Three or Five Sessions of Laser Stretch Mark or Scar Removal at Rejuvenation Health and Wellness (Up to 84% Off) $249 at Groupon
3-Visit Chiropractic Package and/or One Therapeutic Massage at Results Chiropractic and Therapy (Up to 78% Off) $35 at Groupon
Full-Body Massage Packages at Studio 12 Salon and Spa (Up to 64% Off). Three Options Available. $29 at Groupon
$49 for a Chiropractic Consultation, Exam, X-rays, and Massage at Hillcrest Chiropractic ($300 Value) $49 at Groupon
$99 for a Project Management Certification Bundle from IT University Online ($795 Value) $99 at Groupon
Bathtub Recaulking, Bathtub Deep Cleaning, or Tile-Wall Deep Cleaning from Super Surface (Up to 77% Off) $15 at Groupon
Creamery Tour with Goat Cheese for One or Two, or $15 for $30 Worth of Cheese at Belle Chevre $10 at Groupon
Video-to-DVD Conversion for Two Tapes or Conversion for Four or Six Tapes with Backups (Up to 61% Off) $27 at Groupon
One or Three Brazilian or Bikini Waxes or Five Bikini Waxes at Reneaux Day Spa (Up to 59% Off) $19 at Groupon
Beginner Pistol Crash Course for One, Two, or Four at Guns & Leather Shooting Academy (Up to 47% Off) $39 at Groupon
One, Three, or Five Laser Skin-Tightening Treatments at Rejuvenation Health and Wellness (Up to 86% Off) $249 at Groupon
$49 for One-Year Online Game-Design Course with App Development from Vizual Coaching Academy ($1,411 Value) $49 at Groupon
28-Day Weight Loss Meal Program or $200 Towards Any Meal Program at Personal Trainer Food (Up to 51% Off) $99 at Groupon
Custom Instagram or Uploaded Digital Photo Wood Prints from InstaThis (Up to 53% Off) $29 at Groupon
Pub Food Meal for Two or Four with Optional Bucket of Domestics at Brew U (Up to 47% Off) $15 at Groupon
Paintings, Sculptures, and Wall Art from FabuArt.com (61% Off). Two Options Available. $39 at Groupon
Barbecue and Housemade Sides for Two, Four, or Carryout at Tom's Blue Moon BBQ (Up to 40% Off) $12 at Groupon
One, Two, or Four Laser Photofacials at Evolve Weight and Age Management (Up to 87% Off) $99 at Groupon
One- or Two-Hour Romantic Horseback Trail Ride for Two with Dinner at Calico Junction Mule Ranch (Up to 55% Off) $75 at Groupon
Italian and Deli Food for Dinner for Two or Four or Lunch for Two at Relish (Up to 42% Off) $12 at Groupon
One Month of Small-Group Personal Training for One or Two at Consistently Persistent Fitness (Up to 80% Off) $49 at Groupon
$179 for Laser Toenail-Fungus Removal for Both Feet at Evolve Weight and Age Management ($699.99 Value) $179 at Groupon
Hangover Hydration Therapy for One, Two, or Four from Recovery Room Nashville (Up to 53% Off) $79 at Groupon
Four-, Five-, or Six-Hour Standard-Photo-Booth-Rental Package from America's Party Company (Up to 64% Off) $399 at Groupon
Become a Certified ITIL Expert from GogoTraining (Up to 97% Off). Three Options Available. $99 at Groupon
30-Day Weight-Loss Program, or 4, 8, or 12 Lipotropic Injections at Eve's: A New Beginning (Up to 75% Off) $49 at Groupon
Bowling Package for Four or Eight at Lanes, Trains, & Automobiles Entertainment Depot (Up to 51% Off) $49 at Groupon
$59 for an Eye Exam and $175 Credit Toward Prescription Eyeglasses at Visionary Eyeworks ($260 Value) $59 at Groupon
Custom Cases for the iPhone, Including iPhone 6, or Samsung Galaxy from MyCustomCase.com $20 at Groupon
One or Two Shellac Manicures and Regular Pedicures from Trialldee at A Special Touch Nail Salon (Up to 54% Off) $29 at Groupon
$99 for a VMware Dual IT Certification Online Training Bundle from Career Academy ($990 Value) $99 at Groupon
Party for Up to 10 Kids or 10 or 5 Open-Bounce Passes to BounceU of Nashville (Up to 57% Off) $94 at Groupon
10 or 20 Gourmet Peruvian Alfajores with Delivery from The Sweetest Alfajor (Up to 38% Off) $13 at Groupon
$69 for Learn to Code for Beginners Eight-Course Bundle from Adobe KnowHow ($692 Value) $69 at Groupon
Three Groupons, Each Good for One Brow Threading or One Facial Threading Service at The Brow Spa (Up to 42% Off) $7 at Groupon
All-Day Airsoft Play with Equipment for Two, Four, or Six at MooseHerd Airsoft (Up to 63% Off) $29 at Groupon
One, Two, or Four Microdermabrasions with Light Chemical Peels at Essentials Wellness (Up to 75% Off) $49 at Groupon
6, 9 or 12 Zerona Treatments with Whole-Body Vibration at LaserDerm MedSpa & Wellness Center (Up to 83% Off) $299 at Groupon
One or Two 60-Minute Massages or One Couples Chinese Foot Massage at Massage Yijin (Up to 51% Off) $39 at Groupon
$9 for $16 Worth of Crepes, Coffee, and Sandwiches for Two at Sonny's Music Café and Creperie $9 at Groupon
Online Course Bundle for Photoshop and Lightroom, Photography Skills, or Both from Adobe KnowHow (Up to 92% Off) $25 at Groupon
Glass-Blowing Workshop for One or Two at Franklin Glassblowing Studio (Up to 56% Off) $59 at Groupon
60- or 90-Minute Individual or Couples Massage at Pure Life Massage and Wellness (Up to 59% Off) $39 at Groupon
One or Three Mani-Pedis, or One Shellac Mani-Pedi from Janice Brown at Grace's Plaza (Up to 58% Off) $30 at Groupon
$69 for a Dual Cisco CCNA and CCNP Certification Training Bundle from Career Academy ($1,295 Value) $69 at Groupon
Air-Duct Cleaning and Furnace Check-Up with Option of Dryer-Vent Cleaning (Up to 84% Off) $39 at Groupon
Haircut and Optional Partial or Full Highlights with Kristen Cagle at Vintage Annie's (Up to 61% Off) $19 at Groupon
Eyebrow or Eyelash Tint, Eyebrow Contour, Eye Mask, and Optional Maintenance Visit at BrowGal (Up to 53% Off) $49 at Groupon
$35 for an Online Course for Mastering Public Speaking from Gravy for the Brain ($219 Value) $35 at Groupon
One, Two, or Three Signature Facial and Peel Packages at Merle Norman Cosmetics & Day Spa (Up to 70% Off) $35 at Groupon
$20 for CPR, AED, and First Aid Certification from National Health Care Provider Solutions ($45 Value) $20 at Groupon
$79 for Online Project Management Professional Certification from Career Match ($1,118.95 Value) $79 at Groupon
$89 for a Ready-to-Drink 3-Day Juice Cleanse with Garcinia Cambogia from The Vegan Garden ($169 Value) $89 at Groupon
IPL Phototherapy Hair Removal for Underarms or Bikini Line at Smart Touch Skin Solutions (Up to 90% Off) $144 at Groupon
One or Three Eyebrow Threading or Waxing Session at Alluring Beauty Studio (Up to 61% Off) $10 at Groupon
Fitness Classes at Life Fitness Academy - Nashville & Brentwood (Up to 80% Off). Three Options Available. $49 at Groupon
Two Weeks of Unlimited Boot-Camp Sessions or Five Weeks Plus Fitness E-Book at Fit Body Boot Camp (Up to 87% Off) $29 at Groupon
Two- or Four-Week RawJuvenate Complete Organic Detox from Raw Green Organics (Up to 57% Off) $55 at Groupon
$99 for 12 Months of Access to a CompTIA IT-Certification Training Bundle from LearnSmart ($2,195 Value) $99 at Groupon
60-Minute Massage or 90-Minute Hot-Stone Massage at The Wellness Studio (Up to 50% Off) $35 at Groupon
$12 for a Deluxe Letter-from-Santa Package with Phone Call from SealedbySanta.com ($29.45 Total Value) $12 at Groupon
Necklace with Up to Three Custom Name-Plate Pendants from Monogramhub.com (Up to 75% Off). Free Shipping. $25 at Groupon
Pharmacy Goods at Mills Gift Shoppe and Sports Nutrition (Up to 50% Off). Two Options Available. $13 at Groupon
$99 for a Linux and Unix Online Certification Course from IT University ($2,195 Value) $99 at Groupon
One or Two 16"x20" Custom Gallery-Wrapped Canvases from Picture It On Canvas (Up to 77% Off) $27 at Groupon
Full Set of Lash Extensions With Option of Fill at Ona Ultimate Skincare (Up to 57% Off) $129 at Groupon
LASIK Eye Surgery Package for One or Both Eyes at The LASIK Vision Institute (Half Off) $699 at Groupon
One or Three 30-Minute Infrared Sauna Sessions with Consultation at Photon Genius of Nashville (Up to 54% Off) $25 at Groupon
A Haircut and Straightening Treatment from Hair by Cristan at The Loft on Music Row (50% Off) $200 at Groupon
Full Set of Mink Eyelash Extensions with Optional Touchup Refill at Studio Lash (Up to 53% Off) $109 at Groupon
$375 for $750 for Micro-Stroking Hair By Hair Semi-Permanent Eyebrow Makeup — Smart Touch Skin Solutions $375 at Groupon
Three Private Ballroom Dance Lessons with Optional Three Parties at World Champion Productions (Up to 89% Off) $49 at Groupon
One or Three Deep-Tissue Laser Pain Therapy Treatments at Art of Health Chiropractic (Up to 70% Off) $39 at Groupon
Air Duct and Furnace Inspection with Optional Dryer Vent Cleaning from Healthy Home Services USA (Up to 84% Off) $39 at Groupon
One, Three, or Six i-Lipo Laser Body-Contouring Sessions Growing Younger (Up to 81% Off) $79 at Groupon
Two or Four Personal Training Sessions or Four Weeks of Small Group Classes at Humble Fitness (Up to 76% Off) $39 at Groupon
National Deals
Vaas HD Portable Car Dash Camera with 270º 2.5" TFT LCD Screen, Night Vision, and SD/MMC Card Slot $25 at Groupon
Photive Silverbuds Premium Sweat-Proof Sports Bluetooth 4.0 Earbuds with Mic and 10-Hour Battery $35 at Groupon
$50 for a $100 Gift Card Good for Bagels, Bagel Sandwiches, Deli Food, and Drinks at Bruegger's $50 at Groupon
$50 for a $100 Gift Card Good for Bagels, Bagel Sandwiches, Deli Food, and Drinks at Bruegger's Bagels $50 at Groupon
NeatReceipts or NeatDesk Mobile or Desktop Document Scanners from $94.99–$199.99 (Manufacturer Refurbished) $95 at Groupon
Able Planet Active Noise-Canceling Around-the-Ear Headphones With and Without Inline Mic and Music Controls $30 at Groupon
Italian Hotel Collection 1,000TC 6-Piece Sheet Set with Double Satin Band Available from $49.99—$64.99 $50 at Groupon
$34 for a 24-Hour Parking Pass Valid at Any Location at Icon Parking (Up to $70 Value) $34 at Groupon
2-Pack of Garcinia Cambogia with 60% HCA with Free Bottle of 60-Count Green Coffee Bean $15 at Groupon


text:
You may have noticed things look a little different around here - we've switched to a new platform (XenForo) and have some new forum styles and features. This how-to guide will help you find your way around. If you find anything that looks strange, post it in this thread.
e1505: Wi-Fi Disconnect Problems
Discussion in 'Dell' started by grape8pe, Jun 16, 2007.
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subset: commoncrawl


text:
Last update: Friday 6 March 2015 [123 news items]
Neo Solar Power February revenues hit 22-month low
Stockwatch - Mar 6, 14:41
Crystalline silicon solar cell maker Neo Solar Power on March 5 reported consolidated revenues of NT$1.467 billion (US$46.6 million) for February 2015, the lowest monthly level since...
Neo Solar Power lands orders for 400MWp of solar cells from Canadian Solar
Stockwatch - Dec 2, 14:34
Neo Solar Power on December 1 announced that it has obtained orders for 400MWp of solar cells from Canadian Solar, a Canada-based PV module and PV system maker, for delivery in 201...
Neo Solar, Motech suffer 3Q14 net losses
Stockwatch - Nov 6, 16:02
Crystalline silicon solar cell makers Neo Solar Power and Motec Industries have both reported net losses for the third quarter of 2014, at NT$153 million (US$5.06 million) and NT$739...
Neo Solar Power subsidiary setting up PV system in UK
Oct 17, 10:59
Neo Solar Power's PV module and PV system EPC (engineering, procurement, construction) contract subsidiary, General Energy Solutions (GES), is installing a PV system with total capacity...
Neo Solar, Gintech September revenues up sequentially
Stockwatch - Oct 7, 11:45
Crystalline silicon solar cell maker Neo Solar Power has reported September consolidated revenues of NT$1.964 billion (US$65.0 million), increasing 4.96% sequentially but decreasing...
Neo Solar subsidiary sells PV power-generating stations to Chailease
Stockwatch - Oct 1, 11:44
General Energy Solutions, a subsidiary of solar cell maker Neo Solar Power, has sold 71 PV power-generating stations with total installation capacity of 22.54MWp to Chailease Finance,...
Neo Solar, Motech, Gintech see decreased August revenues
Stockwatch - Sep 9, 11:17
Crystalline silicon solar cell makers Neo Solar Power, Motech Industries and Gintech Energy saw consolidated revenues for August slip mainly because shipments to the US market were...
Neo Solar, Giga Solar see mixed growths in July
Stockwatch - Aug 5, 11:56
Solar cell maker Neo Solar Power has reported July consolidated revenues of NT$2.052 billion (US$68.3 million), decreasing 7.08% sequentially but increasing 2.13% on year. PV conductive...
Neo Solar Power nets NT$1.02 per share for 1H14
Stockwatch - Jul 25, 11:42
Crystalline silicon solar cell maker Neo Solar Power on July 24 released its financial report for the second quarter of 2014, posting net EPS of NT$1.02 for the first half of the...
Neo Solar, Gintech, GET see sequential drops in June revenues
Jul 7, 14:42
Crystalline silicon solar cell makers Neo Solar Power and Gintech Energy and solar-grade crystalline silicon wafer maker Green Energy Technology (GET) saw consolidated revenues for...
Neo Solar aims at 95MWp in PV system installations in 2014
Jun 12, 11:54
Solar cell maker Neo Solar Power has set a goal for its subsidiary PV EPC (engineering, procurement, construction) contractor General Energy Solutions (GES) to achieve 95MWp in total...
Neo Solar launches new PV modules
Jun 4, 20:34
Crystalline silicon solar cell and PV module maker Neo Solar Power on June 4 unveiled three new PV modules at the 2014 Intersolar Europe exhibition taking place in Munich, Germany,...
Neo Solar, Gigastorage April revenues hit records
Stockwatch - May 7, 11:06
Taiwan-based crystalline silicon solar cell makers Neo Solar Power, Gintech Energy and Solartech Energy as well as solar wafer makers Gigastorage and Green Energy Technology (GET)...
Neo Solar Power March revenues hit record
Stockwatch - Apr 8, 14:33
Solar cell maker Neo Solar Power has reported consolidated revenues of NT$2.518 billion (US$82.9 million) for March, hitting a monthly company record.
Neo Solar Power to deal out cash dividend for 2013
Stockwatch - Mar 19, 12:08
Solar cell maker Neo Solar Power's board of directors has decided to distribute a cash dividend per share of NT$0.30 (US$0.01) for 2013.
Neo Solar, Gintech, GET see sequential drops in February revenues
Mar 7, 11:13
Solar cell makers Neo Solar Power and Gintech Energy, and solar wafer maker Green Energy Technology (GET) have reported sequential declines in February consolidated revenues: NT$2.335...
Neo Solar, Topcell Solar to procure solar-grade wafers from GCL-Poly
Mar 5, 11:54
Taiwan-based solar cell makers Neo Solar Power and Topcell Solar International will buy high-efficiency polycrystalline silicon wafers from China-based GCL-Poly Energy Holdings, according...
Neo Solar, GET report strong December sales
Jan 7, 11:03
Crystalline silicon solar cell maker Neo Solar Power generated December consolidated revenues of NT$2.406 billion (US$80.2 million), hitting the highest since March 2011 and increasing...
Neo Solar Power to expand monocrystalline solar cell capacity, says paper
Newswatch - Jan 2, 10:59
Neo Solar Power will expand its annual production capacity for monocrystalline silicon solar cells from 300MWp currently to 600MWp in first-half 2014, according to Taiwan-based newspaper...
Solar players see increased November revenues
Dec 6, 14:56
Taiwan-based crystalline silicon solar cell maker Neo Solar Power and solar-grade crystalline silicon wafer makers Green Energy Technology (GET), Sino-American Silicon Products (SAS)...
Global PV installations to grow 20% in 2014, says Neo Solar Power chairman
Newswatch - Nov 25, 15:47
Global PV system installations are estimated at 36GWp for 2013 and is expected to increase by 20% to 43GWp in 2014, with demand mainly to come from China, Japan and the US, Taiwan-based...
Neo Solar October revenues hit 31-month high
Stockwatch - Nov 8, 11:13
Taiwan-based crystalline silicon solar cell maker Neo Solar Power on November 7 reported consolidated revenues of NT$2.3 billion (US$78.0 million) for October, a 31-month high, with...
Neo Solar 3Q13 operation turns profitable, Gintech October revenues hit 25-month high
Nov 7, 11:07
Taiwan-based solar cell maker Neo Solar Power saw its business operation swing from net operating loss of NT$516 million (US$17.3 million) for the first half of 2013 to net operating...
Neo Solar September revenues hit 30-month high
Stockwatch - Oct 4, 10:19
Taiwan-based crystalline silicon solar cell maker Neo Solar Power on October 3 reported consolidated revenues of NT$2.27 billion (US$75.9 million) for September 2013, the highest...
Neo Solar Power August revenues hit 29-month high
Stockwatch - Sep 5, 10:42
Taiwan-based crystalline silicon solar cell maker Neo Solar Power has reported consolidated revenues of NT$2.106 billion (US$70.2 million) for August, the highest monthly level since...
Neo Solar expects full utilization of capacity through end of 2013
Aug 9, 14:34
Neo Solar Power has obtained orders in excess of its production capacity and expects to run at full utilization through the end of 2013, according to company chairman Quincy Lin.
Neo Solar Power sees May revenues grow 8% sequentially
Jun 5, 19:28
Solar cell maker Neo Solar Power (NSP) has announced May consolidated revenues of NT$1.114 billion (US$37 million), representing an on-month growth of 8.92% compared to NT$1.023 billion...
Neo Solar, DelSolar merger to complete on May 31
May 7, 12:58
The merger of Taiwan-based solar cell makers Neo Solar Power (NSP) and DelSolar, a solar subsidiary of Delta Electronics, will be completed on May 31, 2013, said Quincy Lin, chairman...
Neo Solar Power sees March revenues increase 11% on-month
Apr 3, 13:28
Taiwan-based solar cell maker Neo Solar Power (NSP) has reported March consolidated revenues of NT$932 million (US$31 million), representing an on-month growth of 11.04% compared...
Neo Solar Power reports net loss for 2012
Feb 20, 14:06
Taiwan-based solar cell maker Neo Solar Power (NSP) has reported 2012 consolidated revenues of NT$12.241 billion (US$414 million). Due to falling average selling prices (ASPs) and...
DelSolar, Neo Solar Power merger to complete in May-June
Feb 7, 14:35
The merger of Delta's solar subsidiary, DelSolar, and Neo Solar Power (NSP) is expected to be completed in May-June, according to Yancey Hai, chairman of Delta Electronics.
Gintech to halt production during Lunar New Year; no break for Neo Solar
Jan 28, 21:12
While orders have been increasing since the beginning of 2013, Taiwan-based crystalline silicon solar cell maker Gintech Energy is inclined to stop production during the 2013 Lunar...
Delta to own 17% share of new merged solar firm; NSP 15%
Nov 20, 13:51
Taiwan-based solar firm Neo Solar Power (NSP) and power supply maker Delta Electronics announced consolidation plans on November 19, 2012. NSP will procure 15% of DelSolar (the solar...
Neo Solar Power to merge with DelSolar
Nov 19, 22:42
Taiwan-based Delta Electronics and Neo Solar Power (NSP) held a joint press conference to announce the plans on NSP buying 13-15% of shares of DelSolar, the solar subsidiary of Delta,...
Neo Solar Power reports loss for 3Q12
Oct 29, 16:03
Taiwan-based solar cell maker Neo Solar Power (NSP) has reported sales in the third quarter reached NT$2.962 billion (US$101 million), with gross margin of negative 10.86%. According...
- Taiwan IC design houses gearing up to offer solutions for USB Type-C
- Prospects of IC backend service industry remain promising: Q&A with UTAC Holdings CEO William John Nelson
- Qualcomm, MediaTek shifting some 28nm chip orders away from TSMC
- Tablet vendors looking to tackle niche markets in 2015
- Getac chairman expects over 15% on-year growth in rugged PC shipments in 2015
- Global wind power installations increase 42% in 2014, says Navigant
- Sapphire makers seeing strong orders in March
- Genius Electronic Optical offers LED fishing lights
- Digitimes Research: Tianma expects new high-end display fabs to enter production in 2H15
- Digitimes Research: Microsoft to push 2 inexpensive notebooks in mid-2015 to counter Chromebook penetration
- Foxconn to cooperate with SK C&C to tap China IT service market
- Green Energy Technology to not deal out dividend for 2014
- Apple dictates the ranking of top 10 MEMS manufacturers in 2014, says IHS
- Senao Networks steps into industrial computing
- Commercial TV market in China expected to reach 3.35 million in 2015, says firm
- Inotera board approves NT$34.4 billion for transition to 20nm
- Nan Ya Photonics exhibits omni-directional LED light bulb
- Lenovo separates mobile business unit by brand
- LED light bulb prices to fall to US$5 in 2015, says Epistar chairman
- Digitimes Research: Holitech to become 2nd-largest touch panel maker in China after acquisitions
- Young Fast aims to reduce cash outflow and increase new solutions to improve performance in 2015
- Apple to release 3 iPhone models in 2H15
- Apple Watch yields have been low but are increasing, say touch panel makers
- Taiwan makers lower prices for PERC monocrystalline solar cells
- Taiwan International Lighting Show begins
- Releases
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- Join ThroughTek's upcoming IoT/M2M webinar!
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- Got The Message? Ensuring efficient and reliable delivery of content across a mission critical digital signage network
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27-Mar-2015 markets closed
|TSE electronic
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- Lenovo realigns business following merger integration (Mar 19) - Company release
- China becomes the world's third largest arms exporter (Mar 16) - BBC News
- CoinTerra, yet another troubled Bitcoin miner startup, goes bust (Jan 29) - Ars Technica
- Swatch co-inventor: Apple will succeed and an ice age is coming for Swiss watches (Mar 10) - Bloomberg
- Judge says US$415 million settlement in Silicon Valley hiring case is 'substantial' (Mar 3) - PC World
- China 'drops US tech giants' from approved list (Feb 26) - BBC News
- Samsung Electronics, China trade deal give boost to South Korea's yuan hub ambitions (Feb 24) - Reuters
- Qualcomm to pay record $975m in China antitrust case (Feb 10) - BBC News
- Digitimes Research: Microsoft to push 2 inexpensive notebooks in mid-2015 to counter Chromebook penetration
- Digitimes Research: Holitech to become 2nd-largest touch panel maker in China after acquisitions
- Digitimes Research: White-box tablet players turn to Windows 2-in-1s using Intel Bay Trail in 2Q15
- Digitimes Research: Taiwan on-cell touch panel shipments to see strong growth, yet offer little profit
- Digitimes Research: Dual-OS tablets becoming popular in white-box market, but Google GMS remains an obstacle
Prospects of IC backend service industry remain promising: Q&A with UTAC Holdings CEO William John Nelson
The IC backend service industry was capped by a flurry of merger and acquisition (M&A) activities...
Consolidation needed to address oversupply in NOR flash industry: Q&A with Macronix chairman Miin Wu
Macronix International, which ranks as the world's second-largest NOR flash supplier with a 19% share...
Cloud applications to boost storage demand: Q&A with Seagate senior sales and marketing VP BS Teh
The applications, demand and service areas for the global storage device industry have seen profound...
Still aiming at growth in PC market: Q&A with Lenovo Taiwan president Justin Liang
Lenovo, which had the fourth-largest market share next to Asustek Computer, Acer and Apple in the Taiwan...
- Smartphone and tablet industry: The view from Taiwan - May 2012
Taiwan-based companies have a long and successful history of involvement in the supply chain for mobile devices, which for the purposes of this article consist...
- Taiwan motherboard industry overview - May 2012
The year 2011 saw the motherboard industry reverse its trend of declining shipments year-on-year, to post a slight 0.2% growth. This upturn in fortunes was expected...
- Notebook market overview - Jun 2011
The notebook industry in 2010 experienced several major events that significantly changed the industry's ecosystem for the year and the industry is also believed...
- LCD TV overview - Jun 2011
Growth of the global LCD TV market was not as strong as expected in 2010 as the market continued to feel the aftershocks of the economic recession that had hit...
- Wireless broadband developments in Southeast Asia markets
As of 2013, the 10 ASEAN nations had a total of over 700 million mobile subscriptions, with the CAGR from 2003-2013 reaching 24%. This Digitimes Research Special Report analyzes the various mobile broadband markets in ASEAN and looks at the respective trends in 4G LTE development for those markets.
- 2015 global tablet demand forecast
This Digitimes Research Special Report provides a 2015 forecast for the global tablet market and analyzes the strategies of key market players such as Google, Apple, Intel, and Microsoft.
- 2015 China smartphone panel trend forecast
This Digitimes Research Special Report analyzes the strategies of key China-based major panel makers BOE, Tianma and IVO for attacking the different market segments through technology and pricing, and their relationship to local vendors Huawei, Lenovo, ZTE, Xiaomi and Coolpad.


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Thursday, January 30, 2014
Stop and Frisk: NYC Mayor Abandons Appeal in Floyd v City of NY
NYC's practice of stop and frisk has been controversial in the streets and in the courts. Recall
that in August 2013, Judge Shira Scheindlin found the New York City Police Department's stop and frisk policies unconstitutional as violative of equal protection. Judge Scheindlin's exhaustive opinion in Floyd v. City of New York was accompanied by an extensive order, setting out remedies, including monitoring. By a very brief opinion, Judge Scheindlin's decision was stayed by the Second Circuit - - - and Judge Scheindlin removed. The Second Circuit later reaffirmed its decision, but in more moderate and explanatory tones.
But before the Second Circuit could issue an opinion on the merits, NYC elected a new mayor, who today announced an agreement in Floyd v. City of New York. Mayor Bill deBlasio (pictured below) announced that NYC has asked for a remand of the appeal to the district court, and has agreed to a court-appointed monitor who will serve for three years, overseeing the NYPD's reform of its stop-and-frisk policy and reporting to the court.
[image via]
January 30, 2014 in Courts and Judging, Criminal Procedure, Equal Protection, Race, Recent Cases | Permalink | Comments (1) | TrackBack (0)
Wednesday, January 22, 2014
Bipartisan Bills Introduced to Amend Voting Rights Act
Senator Patrick Leahy (D-VT) and Representatives Jim Sensenbrenner (R-WI) and John Conyers (D-MI) introduced legislation last week that would amend the Voting Rights Act and recalibrate the coverage formula for preclearance. The legislation responds to the Supreme Court's ruling last summer in Shelby County v. Holder, striking Section 4(b) of the VRA, the coverage formula for the preclearance requirement. That ruling left Section 5 preclearance nearly a dead letter (although litigants could still seek to have a court order a jurisdiction to bail-in to preclearance under Section 3).
Our Shelby County coverage is here and here (with links to most of our other posts on the case).
The bills would update the coverage formula to include states that have 5 or more voting rights violations during the previous 15 years and political subdivisions that have 3 or more voting rights violations during the previous 15 years. (Coverage would continue for 10 years, unless the jurisdiction gets a court order releasing it.) This new formula would cover Georgia, Louisiana, Misissippi, and Texas, but not Alabama, Arizona, Florida, North Carolina, South Carolina, and Virginia.
The bills also contain a number of other provisions, perhaps most notably expanding Section 3 bail-in so that litigants can ask a court to bail-in a jurisdiction when that jurisdiction has intentionally discriminated (as now) and for any other violation of the VRA. Ari Berman over at The Nation has a nice summary.
The new provisions will undoubtedly be challenged when and if they're enacted. On the one hand, they address a major concern of the Court in Shelby County: they update the coverage formula to use more current violations as the basis for coverage. But on the other hand, they still treat states differently (and potentially run afoul of the Court's new-found "equal sovereignty" doctrine), and the state-wide formula does not account for actual voter turn-out (although the political subdivision formula does) and neither formula addresses the number of elected officials--data that the Court found at least relevant in its ruling.
January 22, 2014 in Cases and Case Materials, Congressional Authority, Elections and Voting, Federalism, Fifteenth Amendment, Fourteenth Amendment, News, Race, Recent Cases, Reconstruction Era Amendments | Permalink | Comments (1) | TrackBack (0)
Monday, January 13, 2014
New Report on the Efficacy of NSA Surveillance of Telephony Metadata
A new report from the New America Foundation is entitled with the question "Do NSA's Bulk Surveillance Programs Stop Terrorists?"
In brief, the answer it proposes is "no."
The report is authored by Peter Bergen, David Sterman, Emily Schneider, and Bailey Cahall. As Cyrus Farivar over at Ars Technica points out, the lead author Peter Bergen is well known as "a journalist and terrorism analyst who famously interviewed Osama bin Laden for CNN in 1997."
The report confirms federal District Judge Richard Leon's statement in his opinion in Klayman v. Obama that "the Government does not cite a single instance in which analysis of the NSA's bulk metadata collection actually stopped an imminent attack, or otherwise aided the Government in achieving any objective that was time-sensitive in nature." (emphasis in original). Recall that Judge Leon issued a preliminary injunction against the surveillance, although he then stayed it.
Recall also that another federal district judge dismissed a complaint raising essentially the same issues a week later in American Civil Liberties Union v. Clapper.
With President Obama evaluating the NSA surevillance program including the Recommendations from President's NSA Surveillance Review Group and with the question of whether the NSA's surveillance extends to members of Congress being asked, this newest report deserves to be read closely. If there is a balance to be struck between security and liberty, the efficacy of the security measures are certainly relevant.
January 13, 2014 in Courts and Judging, Criminal Procedure, Current Affairs, Fourth Amendment, Privacy, Recent Cases, Scholarship, State Secrets, Theory | Permalink | Comments (0) | TrackBack (0)
Sunday, November 24, 2013
Sunday Dress: Profiling Clothes and Stop and Frisk
As police and state officials struggle to develop "objective" criteria that might support reasonable suspicion for a stop and frisk in light of constitutional issues (which we last discussed here), relying clothing and other attire may not be a good idea.
Read more on 1584.
November 24, 2013 in Equal Protection, Race, Recent Cases | Permalink | Comments (0) | TrackBack (0)
Saturday, November 23, 2013
Keeping Up With the Second Circuit's Stop and Frisk Decisions
The Second Circuit late Friday entered yet another decision in In re Reassignment of Cases: Ligon; Floyd et al. v. City of New York, et al., this time on four motions before the panel. Recall that the Second Circuit panel previously entered an opinion clarifying its removal of District Judge Shira Scheindlin after its original brief order issuing a stay and removing her as judge, an occurrence that is apparently not so rare. Judge Shira Scheindlin's opinions and orders in Floyd v. City of New York and in Ligon v. City of New York found the NYPD's implementation of stop and frisk violative of equal protection.
In this most recent order from the Second Circuit panel, it denied NYC's motion to vacate Judge Scheindlin's orders and opinions, rather than issuing a stay. This move by NYC - - - given that a change in mayors is imminent - - - certainly had political interpretations. But whatever NYC's motives, the Court rejected the invitation to vacate the opinions.
The Second Circuit panel also denied the motions seeking intervention by Judge Scheindlin, essentially characterizing them as moot given the panel's clarifying order and the denial of the motion to vacate. However, the panel did take the opportunity to disagree with the motion's representation that the panel did not have access to the transcript of proceedings in the related case upon which it based its findings that Judge Scheindlin may have committed an improper application of the Court's "related case rule." The Second Circuit panel stated:
A review of the record of the Court of Appeals, and of the October 29, 2013 extended oral argument in these cases, will reveal that the panel members had the transcript of the December 21, 2007 proceeding in front of them during the hearing, and that they asked questions in open court regarding its substance. For example, during the oral argument, one member of the panel twice referred to the proceedings in detail, and clearly noted that he was quoting from page 42 of the December 21, 2007 transcript. Our October 31, 2013 order specifically cited the transcript by caption, docket number, and date, and it included quotations that had not been reported in the New York Times article that was cited, or in any other public news report known to the panel.
It's interesting that the Second Circuit panel took time to refute the contention with specifics - - - and perhaps it is important that the panel also noted that the assertion that it did not have the transcript was being "echoed" by "other movants in the case," with this citation:
See, e.g., Br. of Amici Curiae Six Retired United States District Court Judges and Thirteen Professors of Legal Ethics, Ligon v. City of New York, No. 13-3123, Dkt. 221, Floyd v. City of New York, No. 13-3088, Dkt. 313, at 14.
The Second Circuit panel surely wants to correct the record about the record on this point.
November 23, 2013 in Courts and Judging, Criminal Procedure, Current Affairs, Equal Protection, Race, Recent Cases | Permalink | Comments (0) | TrackBack (0)
Sunday, November 17, 2013
Religious Freedom for Corporations: Hypotheticals from Seventh Circuit Judge Rovner
The issue of religious freedom for secular for-profit corporations, whether under the statutory scheme of Religious Freedom Restoration Act or the First Amendment, in the context of the ACA's so-called contraceptive mandate is a contentious and complicated one. Here's an overview of (and reaction to) the issue and cases; after which the Seventh Circuit (again) rendered an opinion.
For those teaching, writing, or thinking about the issues, Judge Ilana Rovner (pictured), dissenting in the Seventh Circuit's opinion in the consolidated cases of Korte v. Sebelius and Grote v. Sebelius, offers three provocative hypotheticals. [For those interested in more about Judge Rovner, there's an interesting interview from the Illinois Supreme Court Commission on Professionalism in a brief video available here].
Rovner's hypotheticals draw on the ACA as well as other federal laws and are especially helpful because they provide the statutory schemes as well as the facts.
In the first, an employee has ALS, commonly known as Lou Gehrig's Disease, and has been accepted into a clinical trial testing the effectiveness of an embryonic stem-cell therapy on ALS. The employer software company/owner's plan would cover only the costs of the employee's routine care associated with the stem cell therapy, and not the costs of the stem cell therapy itself, but the employer nevertheless believes that by covering routine care, the company plan would be facilitating his participation in a practice to which he objects on religious grounds.
In the second, the employer corporation's sole owner is "a life-long member of the Church of Christ, Scientist. Christian Science dogma postulates that illness is an illusion or false belief that can only be addressed through prayer which realigns one's soul with God." The owner believes that "his company's compliance with the ACA's mandate to cover traditional medical care would be a violation of his religious principles."
In the third hypothetical, the employer corporation's owners condemn same-sex marriage and homosexuality as part of their religious views. One of their employees seeks time off under the Family and Medical Leave Act to attend, with his husband, the birth of their child through a surrogate arrangement. The employers not only refuse the unpaid leave under the FLMA, they terminate him, because neither the owners nor their company can in any way recognize or facilitate such an immoral arrangement against their religious beliefs.
These hypotheticals would make a terrific in class discussion. They appear on pages 68 - 76 of the opinion; and for convenience, without accompanying footnotes, below.
November 17, 2013 in Cases and Case Materials, First Amendment, Interpretation, Medical Decisions, Opinion Analysis, Recent Cases, Religion, Reproductive Rights, Teaching Tips | Permalink | Comments (0) | TrackBack (0)
Sunday Dress: Confederate Flag Attire, Kayne West, and Schools
Rapper and celebrity Kayne West is selling tour t-shirts with an image of the Confederate flag and provoking controversy, as this video shows:
But what if a student wanted to wear such a shirt to public school?
Last month, the United States Supreme Court denied a petition for writ of certiorari to the Fourth Circuit's decision in Hardwick v. Heyward, thus continuing its refusal to hear cases in which circuit courts have upheld the ability of schools to prohibit Confederate flag gear or apparel against a First Amendment claim by students.
Applying Tinker v. Des Moines Independent Community School District, the circuit and district courts have generally held that there is a likelihood of substantial dispruption, whether or not the school has had a history of racial violence, and whether or not there is agreement that the meaning of the Confederate flag is connected to racism or even race.
More about the issue of wearing the Confederate flag in schools is in my column for the London School of Economics blog.
November 17, 2013 in Cases and Case Materials, First Amendment, Race, Recent Cases | Permalink | Comments (0) | TrackBack (0)
Friday, September 27, 2013
New Jersey Judge Extends Windsor to Find State Ban on Same-Sex Marriages Unconstitutional
In a 55 page opinion today in Garden State Equality v. Dow, Mercer County Superior Court Judge Mary Jacobson granted summary judgment to the plaintiffs finding that NJ's same-sex marriage ban violated the state constitution. The judge held that New Jersey's civil union scheme, considered an acceptable remedy for any violation of the state's equal protection clause by the NJ Supreme Court in Lewis v. Harris (2006), was no longer sufficient to satisfy state constitutional law given the United States Supreme Court's invalidation of DOMA last June in Windsor v. United States.
Judge Jacobson concluded:
Because plaintiffs, and all same-sex couplies in New jersey, cannot access many federal marital benefits as partners in civil unions, this court holds that New Jersey's denial of marriage to same-sex couples now violates Article 1, Paragraph 1 of the New Jersey Constitution as interpreted by the New Jersey Supreme Court in Lewis v. Harris.
This is an interesting - - - but totally predictable - - - use of Windsor to undermine the very rationales of the state's highest court's determination that civil unions would satisfy equality concerns.
The judge admits that the doctrinal landscape is murky, but also that it is rapidly changing. For this judge, effectuating the holding of the New Jersey Supreme Court in Lewis v. Harris that the state constitution required same-sex couples to be able to obtain all the same rights and benefits available to opposite sex couples compels the extension of marriage to same-sex couples.
In only a very few other states would similar reasoning be applicable: Illinois, Hawai'i, and Colorado have civil union laws but not same-sex marriage. Other states having civil unions also allow same-sex marriages or are "converting" civil unions to marriages.
As for New Jersey, odds are the state will appeal, although political considerations might weigh heavily.
September 27, 2013 in Equal Protection, Family, Recent Cases, Sexual Orientation, State Constitutional Law, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Wednesday, September 25, 2013
Randall Kennedy at NY Historical Society on The Supreme Court and Affirmative Action
October 3, 2013, 6:30 pm, in NYC
Free for Law Students and Faculty
Required registration and more information here.
September 25, 2013 in Affirmative Action, Courts and Judging, Current Affairs, Race, Recent Cases, Scholarship | Permalink | Comments (0) | TrackBack (0)
Tuesday, September 24, 2013
Baby Veronica's Painful Aftermath
decision in Adoptive Couple v. Baby Girl, known as the "Baby Veronica" case, has been quite painful for the parties. Recall that the Court's 5-4 decision concluded that the Indian Child Welfare Act, ICWA, would not be violated by the adoption of the child by a white couple. The constitutional issue of "racial classifications" (rather than Indian sovereignty) loomed, but was not directly engaged.
The Oklahoma Supreme Court dissolved the emergency stay of the adoption yesterday in Brown v. DeLapp. The majority's order is accompanied by two dissenting opinions, each of which describe the various proceedings and holdings, including the South Carolina Supreme Court's decision that did not remand for a "best interests of the child" determination, but decided to "remand this case to the Family Court for the prompt entry of an order approving and finalizing Adoptive Couple's adoption of Baby Girl."
Much of the press has been highly sympathetic to the adoptive parents, but also worth a read is an article from Indian Country Today Media Network.
September 24, 2013 in Cases and Case Materials, Courts and Judging, Current Affairs, Family, Race, Recent Cases | Permalink | Comments (0) | TrackBack (0)
Sunday, September 15, 2013
Daily Read: The New Yorker on Justice Ginsburg, Fisher, and Footnote 4
Over at the New Yorker blog, Lincoln Caplan's piece, "Justice Ginsburg and Footnote Four" analyzes Ginsburg's discussion last week at the National Constitution Center, arguing that one of her statements "deserves more attention than it has gotten."
Ginsburg stated that her dissent last term in Fisher v. University of Texas Austin, regarding judicial review of affirmative-action plans of colleges and universities, "was inspired by a 1938 ruling not mentioned in the dissent—actually, by one of its footnotes." That most famous footnote - - - footnote four - - -of United States v. Carolene Products, is for many (including Caplan) the foundation of "a coherent justification for unelected justices to overturn legal decisions of elected officials when the fairness of the Constitution, and of democracy, is at stake."
Recall that the 1938 case of Carolene Products involved a federal statute regulating the shipment of "filled milk" (skimmed milk to which nonmilk fat is added so that it may seem to be like whole milk or even cream). It may be that this case was also on Ginsburg's mind during the oral arguments of another one of last term's cases: In her questioning of Paul Clement, who represented BLAG, in United States v. Windsor about the constitutionality of DOMA, she condensed his argument as saying that in granting same-sex marriages, states were nevertheless saying there were really "two kinds of marriage; the full marriage, and then this sort of skim milk marriage." As we noted at the time, Ginsburg's allusion would have special resonance for those who recalled Carolene Products.
September 15, 2013 in Affirmative Action, Courts and Judging, Fifth Amendment, Food and Drink, Fourteenth Amendment, Fundamental Rights, Interpretation, Recent Cases, Sexual Orientation, Supreme Court (US), Theory | Permalink | Comments (0) | TrackBack (0)
Saturday, September 7, 2013
CFP: LBJ's Great Society at 50, MAPOC Legal Scholarship Conference
From an announcement:
19th Annual Mid-Atlantic People of Color
Legal Scholarship Conference 2014
Hosted by the University of Baltimore School of Law
Baltimore, MD
January 23-25, 2014
– Conference Theme & Call for Papers –
President Lyndon B. Johnson's Great Society and Beyond:
The Historical and Contemporary Implications of Progressive Action and Human Fulfillment
Honoring and Critiquing the 50th Anniversary of Johnson's Vision
In May 1964, President Lyndon Baines Johnson unveiled his revolutionary plans for the Great Society. As he explained it, Americans "have the opportunity to move not only toward the rich society and the powerful society, but upward to the Great Society. . . . The Great Society rests on abundance and liberty for all. It demands an end to poverty and racial injustice."
According to Doris Kearns Goodwin, who wrote Lyndon Johnson and the American Dream, Johnson's Great Society would be based on "progressive action" and the "possibilities for human fulfillment." This action and fulfillment meant that regaining control of our society required us to end policies that threatened and degraded humanity.
Johnson's Great Society reforms, included the Voting Rights Act of 1965, Medicare, Medicaid, Equal Opportunity Act, Elementary and Secondary Education Act, Social Security expansion, the Earned Income Tax Credit, the Higher Education Act, Head Start, the Civil Rights Act of 1964, the Housing and Urban Development Act of 1965, and the Open Housing Act of 1968. These laws extended and expanded the Bill of Rights and continued and expanded the programs initiated in Roosevelt's New Deal of the 1930s and Truman's Fair Deal in the late 1940s and early 1050s. As a result of LBJ's programs, America's official poverty rate declined throughout the 1960s, reaching a low of 11.2 percent in 1974, down from 19 percent in 1964, and most recently settling at 15.1 percent in 2010. According to Dylan Matthews, who wrote Poverty in the 50 Years Since 'The Other America,' in Five Charts, Johnson's Great Society programs, which included the War on Poverty, "made a real and lasting difference." Moreover, according to Demos, an estimated 40 million Americans avoided official poverty due to such programs as food stamps and Medicaid.
Unfortunately, what is also true is that the Vietnam War, which Johnson escalated and only at the end of his administration moved to end, crippled his domestic economic policies and undermined his goals for true racial equality. Despite the War on Poverty and dramatic changes in Civil Rights, racially concentrated poverty remains with us. Since the Johnson years, America has weathered the recessions of the 1980s and early 1990s, the late '90s dot com bubble, our current recession, the national security encroachment on civil liberties, the rise and fall of the Occupy Movement, the waning of the Arab Spring, and two middle east wars since 9-11.
It is clear that Johnson's Great Society programs have saved millions of Americans from the depth of official poverty. It also true that Johnson's vision, to which he was truly committed, staggered and failed when the civil rights movement dovetailed with political marginalization, economic inequality, pervasive racial discrimination, and imperialist policies. The Moynihan Report, the Watts Riots and urban unrests, and the emotional and financial suck of Vietnam prevented Johnson from deeply redressing America's lingering poverty.
At MAPOC 2014, we intend to explore the furthest implications of President Johnson's domestic and foreign policies, especially the impact of these policies on progressive action and human fulfillment, as we collectively explore and analyze the contemporary implications of Johnson's Great Society. From these implications, the conference planning committee is seeking papers and panel proposals on the following substantive but not exhaustive subjects:
-- A Hand Up: The Meaningful Tension Between Formal Equality and Substantive Outcomes under the Civil Rights Act of 1964
-- Beyond Legislative Bogs and Dangerous Political Animals: President Obama's Legislative Agenda and the Limits of Second-Term Progressivism
-- Endangered Citizens?: Rights and Remedies after State v. Zimmerman
-- Equality, Choice, and Happiness: the Rise and Fall of DOMA
-- Guns or Butter: Social Welfare Programs, Modern Problems of Central Banks, Debt Slavery, and Foreign Policies
-- Medicare, Healthcare, and Welfare: the Poor, the Elderly, and the Needy
-- Moynihan and the Contemporary (In)Stability of the Black Family
-- Racial (Dis)Harmony Then and Today
-- Voting Rights: Shelby County v. Holder and the Promise of One Citizen, One Vote
Paper submissions must include a working title, bios, abstract, and contact information.
Panel proposals must also include the foregoing information for each of the panel's participants, and the organizer's contact information, all of which must be submitted together only by the organizer.
Submit Papers and Panel Proposals by September 30, 2013 to: Reginald Leamon Robinson, Howard University, Conference Chair and Founder, MAPOC 2014: email@example.com.
[image: LBJ, National Portrait Gallery, via]
September 7, 2013 in Conferences, Elections and Voting, Equal Protection, Family, Federalism, Fundamental Rights, Gender, Race, Recent Cases, Scholarship, Theory | Permalink | Comments (0) | TrackBack (0)
Thursday, August 29, 2013
IRS Rules it will Recognize All Same-Sex Marriages
In a 15 page ruling today, Revenue Ruling 2013-17, the IRS clarified that it will recognize
a marriage of same-sex individuals that was validly entered into in a state whose laws authorize the marriage of two individuals of the same sex even if the married couple is domiciled in a state that does not recognize the validity of same-sex marriages.
The Department of Treasury also issued a press release.
The Revenue Ruling applies and extends the Supreme Court's decision in United States v. Windsor in late June. Essentially, the IRS ruled that interpreting "husband" and "wife" as gender-neutral terms was consistent with Windsor and a contrary interpretation would "raise serious constitutional questions."
As for domicile, the IRS ruled that the controlling domicile was the place where the marriage occurred. While they are constitutional issues, the IRS also relied upon the practical:
Given our increasingly mobile society, it is important to have a uniform rule of recognition that can be applied with certainty by the Service and taxpayers alike for all Federal tax purposes. Those overriding tax administration policy goals generally apply with equal force in the context of same-sex marriages.
The ruling specifically excludes
individuals (whether of the opposite sex or the same sex) who have entered into a registered domestic partnership, civil union, or other similar formal relationship recognized under state law that is not denominated as a marriage under the laws of that state, and the term "marriage" does not include such formal relationships.
[image: United States Treasury Building via]
August 29, 2013 in Recent Cases, Sexual Orientation, Taxing Clause | Permalink | Comments (0) | TrackBack (0)
Wednesday, August 28, 2013
Daily Read: The importance of amicus briefs
An ABA Journal article by Mark Walsh tells us that last Term, 2012-2013, was "another big one" for amicus curiae briefs at the United States Supreme Court: "Seventy of the 73 cases, or nearly 96 percent, that received full plenary review attracted at least one amicus brief at the merits stage."
The top amicus-attractors?
The same-sex marriage cases of Windsor and Perry, with 96 and 80 respectively and the affirmative action case of Fisher, with 92.
Shelby County v. Holder, the Voting Rights Act case, attracted 49 amicus briefs, including one from ConLawProf Patricia Broussard (second from right) and her students at FAMU College of Law, as pictured below.
Worth a look, especially for ConLawProfs writing, signing, or assigning amicus briefs.
August 28, 2013 in Affirmative Action, Cases and Case Materials, Current Affairs, Fifteenth Amendment, Fourteenth Amendment, Profiles in Con Law Teaching, Race, Recent Cases, Reconstruction Era Amendments, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Tuesday, August 27, 2013
Daily Read: Ellis and Jones on the 50th Anniversary of the March on Washington for Jobs and Freedom
Several media and legal outlets are running impressive commentaries on this fiftieth anniversary of the March on Washington for Jobs and Freedom led by Martin Luther King, Jr.
Here are two that should not be missed.
Over at ACS blog, Law Prof Atiba Ellis writes on "The Moral Hazard of American Gradualism: A Lesson from the March on Washington." Ellis states, "the question we must confront in 2013 is whether we have been tranquilized into the lethargy of gradualism concerning the work that needs to be done." Ellis highlights the Court's decisions last term in Shelby and in Fisher as examples of "the new American gradualism – retrogressive action under the cover of apathy, spurred by the myth of post-racialism and the supposed fear of constitutional overreach."
And on NPR's Morning Edition, journalist Michele Norris profiles Clarence B. Jones as an attorney and "guiding hand" behind the "I Have a Dream" speech, including the famous "promissory note" metaphor. However, Norris also highlights Jones' memoir Behind The Dream, which had "some unlikely source material." Indeed, Jones' memoir may be more accurate than most, since his memory was augmented by transcripts of every single phone conversation he had with King, courtesy of the FBI, in a wiretap authorized by Robert Kennedy as Attorney General. The NPR story has a link to the FBI archive on King.
[image via]
August 27, 2013 in Affirmative Action, Books, Current Affairs, Executive Authority, Federalism, Fifteenth Amendment, Fourteenth Amendment, News, Race, Recent Cases, Scholarship, Theory, Thirteenth Amendment | Permalink | Comments (0) | TrackBack (0)
Saturday, August 10, 2013
Obama Administration Supports Town of Greece's Prayer on Certiorari to United States Supreme Court
In Galloway v. Town of Greece (New York), the Second Circuit held that the town's practice of legislative prayer "impermissibly affiliated the town with a single creed, Christianity."
The Court granted the Town's peitition for writ of certiorari, and the Solicitor General has just filed the United States Government's brief supporting the Town.
At issue is an application of Marsh v. Chambers (1983), in which the Court upheld the constitutionality of the Nebraska legislature's employment of a chaplain to lead a legislative prayer. The majority opinion, authored by Chief Justice Burger, was seemingly not worried that the same chaplain had been employed for almost two decades, and relied upon the historical practice of legislative prayer, applying Lemon v. Kurtzman.
The Second Circuit in Town of Greece, however, looked at the content of the prayers and essentially found, as we phrased it here, "one invocation to Athena out of 130 is simply not sufficient" to meet the requirement of non-endorsement given that two-thirds of the prayers contained references to "Jesus Christ," "Jesus," "Your Son," or the "Holy Spirit."
The Solicitor General's brief, however, argues that the court should not consider the content of the prayers. The government argues:
Under the principles announced in Marsh, which relied heavily on the history of legislative prayer in this country, a prayer practice that is not problematic in the ways identified in Marsh (as petitioner's practice concededly is not) does not amount to an unconstitutional establishment of religion merely because most prayer- givers are Christian and many or most of their prayers contain sectarian references. The unbroken history of the offering of prayer in Congress, for example, has included a large majority of Christian prayer-givers and a substantial number of prayers with identifiably sectarian references. Neither federal courts nor legislative bodies are well suited to police the content of such prayers, and this Court has consistently disapproved of government interference in dictating the substance of prayers.
Taken to its logical conclusion, the government's position here would disable the judiciary from considering the content of any prayer, including one that was vigorously and even violently sectarian.
[image of Athena, via]
August 10, 2013 in Current Affairs, Establishment Clause, First Amendment, Recent Cases, Supreme Court (US) | Permalink | Comments (1) | TrackBack (0)
Thursday, August 1, 2013
Third Circuit on Hazleton Immigration Ordinance Redux
The Third Circuit has had yet another opportunity to review the constititionality of the city of Hazleton's extensive immigration ordinances in its new opinion in Lozano v. City of Hazleton [Pennsylvania]. Recall that the United States Supreme Court granted the City's petition for a writ of certiorari and vacated the Third Circuit's previous decision in light of Chamber of Commerce of United States of America v. Whiting.
In 2010, the Third Circuit panel, affirming the district court, had rendered an extensive 188 page opinion in unanimously finding that the two ordinances of Hazleton, Pennsylvania regulating immigration were pre-empted by the federal immigration scheme. The employment provision in Hazleton made it unlawful "for any business entity" to "recruit, hire for employment, or continue to employ" or "permit, dispatch, or instruct any person" who is an "unlawful worker" to perform work within Hazleton, and required employer affidavits. The ordinances also had a housing provision making it unlawful for landlords to rent to unlawful residents.
In its new opinion, the panel - - - again consisting of Chief Judge McKee and Judge Nygaard, with the previous designated judge now replaced by Judge Vanaskie - - - found that Whiting, as well as the Court's subsequent decision in Arizona v. United States regarding the notorious SB1070, did not command a different result. Instead, the court again concluded that " both the employment and housing provisions of the Hazleton ordinances are pre-empted by federal immigration law."
Regarding the employment provisions of the Hazleton ordinance, the Third Circuit panel found that the Court's opinions in Whiting and Arizona did alter some of its previous analysis, but that the employment provisions of the Hazleton ordinance were so broad in their coverage of both actors and activities that they were an obstacle to the federal immigration law and were thus pre-empted.
As to the housing provisions, the court found:
No part of Whiting or Arizona considered provisions of a state or local ordinance that, like the housing provisions here, prohibit, and define "harboring" to include, allowing unauthorized aliens to reside in rental housing. Moreover, nothing in Whiting or Arizona undermines our analysis of the contested housing provisions here. On the contrary, the Court"s language reinforces our view that Hazleton"s attempt to prohibit unauthorized aliens from renting dwelling units in the City are pre-empted.
Thus, the Third Circuit reaffirmed its view that the Hazelton ordinance is unconstitutional as pre-empted.
In considering whether or not to pursue a second petition for writ of certiorari to the United States Supreme Court, the City of Hazleton will undoubtedly be considering the extensive litigation costs it has already expended and deciding whether it should spend even more, although reportedly some costs have been paid by private contributions.
[image via]
August 1, 2013 in Cases and Case Materials, Congressional Authority, Courts and Judging, Opinion Analysis, Preemption, Recent Cases, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Tuesday, July 23, 2013
Ohio Federal Judge Enjoins State-DOMA: More Aftermath of Windsor
In a fifteen page opinion, federal district judge Timothy Black enjoined the application of Ohio's state DOMA provisions - - - both statutory and the state constitutional amendment - - - to a same-sex couple married out of state. In Obergefell v. Kasich, the judge adapted the reasoning of the United States Supreme Court's June opinion in Court's United States v. Windsor, declaring section 3 of the federal Defense of Marriage Act, DOMA unconstitutional. Judge Black's opinion is part of the aftermath of Windsor that we most recently discussed here.
Judge Black's opinion has a succinct discussion of equal protection doctrine and concludes,
Under Supreme Court jurisprudence, states are free to determine conditions for valid marriages, but these restrictions must be supported by legitimate state purposes because they infringe on important liberty interests around marriage and intimate relations.
In derogation of law, the Ohio scheme has unjustifiably created two tiers of couples: (1) opposite-sex married couples legally married in other states; and (2) same-sex married couples legally married in other states. This lack of equal protection of law is fatal.
Judge Black's opinion has a brief explicit mention of "animus," but the concept permeates the opinion. For example, he notes that before the state enacted its DOMA provisions:
Longstanding Ohio law has been clear: a marriage solemnized outside of Ohio is valid in Ohio if it is valid where solemnized. This legal approach is firmly rooted in the longstanding legal principle of "lex loci contractus" -- i.e., the law of the place of the contracting controls. Ohio has adopted this legal approach from its inception as a State.
Thus, for example, under Ohio law, as declared by the Supreme Court of Ohio in 1958, out-of-state marriages between first cousins are recognized by Ohio, even though Ohio law does not authorize marriages between first cousins.
To be sure, the injunction is a limited one applicable to sympathetic facts. One of the partners is a hospice patient and the relief requested regards the martial status and surviving spouse to be recorded on the death certificate. Yet Judge Black's reasoning is not limited and opens the door to rulings that Ohio's DOMA provisions limiting state recognition of marriages to only opposite-sex marriages fails constitutional scrutiny under the Fourteenth Amendment's equal protection clause.
July 23, 2013 in Courts and Judging, Current Affairs, Equal Protection, Family, Federalism, Fourteenth Amendment, Full Faith and Credit Clause, Opinion Analysis, Recent Cases, Sexual Orientation, State Constitutional Law | Permalink | Comments (0) | TrackBack (0)
Tuesday, July 16, 2013
More on the Aftermath of Windsor (DOMA) and Perry (Prop 8) decisions: California, Pennsylvania, Arkansas, North Carolina Litigation
The Court's decisions in United States v. Windsor, declaring section 3 of DOMA unconstitutional, and Perry v. Hollingsworth, holding that the "proponents" of Proposition 8 lacked standing to appeal a federal judge's declaration of Prop 8's unconstitutionality, have not settled the matter of the unconstitutionality of same-sex marriage restrictions.
In what promises to be a continuing series, here are a few highlights:
In California, the home of Proposition 8, the litigation centers on Prop 8's constitutional status given that the Supreme Court held that the proponents did not have standing to appeal the federal district judge's holding that Prop 8 made a sexual orientation classification that does not satisfy the rational basis standard and thus violates the Equal Protection Clause. The original injunction was stayed, and again stayed by the Ninth Circuit even as it affirmed the district judge, but after Perry, the Ninth Circuit dissolved the stay amid questions about the effect of Perry which we discussed here.
The proponents of Prop 8 have moved (back) to the state courts, filing Hollingsworth v. O'Connell on July 12 seeking a stay from the California Supreme Court. Their basic argument is that a single federal judge should not have the power to declare a law unconstitutional for the entire state and they seek a mandate forbidding county clerks from issuing same-sex marriage licenses. On July 16, the California Supreme Court declared - - - as a docket entry and without opinion - - - "The request for an immediate stay or injunctive relief is denied." It also granted the motions for counsel to proceed pro hac vice, so the case will presumably be moving forward.
In Pennsylvania, a complaint in Whitewood v. Corbett was filed July 9, as a new constitutional challenge to the state's "little DOMA" provisions passed the same year as the federal DOMA, 1996 - - - 23 Pa. Consolidated Statute §1102 (defining marriage as between one man and one woman) and 23 Pa. Consolidated Statutes §1704 (declaring one man-one woman marriage as the strong public policy of state and refusing to recognizing same-sex out of state marriages). The Complaint interestingly quotes and cites language from Windsor several times. For example:
¶10. The exclusion from marriage undermines the plaintiff couples' ability to achieve their life goals and dreams, threatens their mutual economic stability, and denies them "a dignity and status of immense import." United States v.Windsor, No.12-307, Slip Op., at 18 (U.S. June 26, 2013). Moreover, they and their children are stigmatized and relegated to a second class status by being barred from marriage. The exclusion "tells[same-sex couples and all the world- that their relationships are unworthy" of recognition. Id. at 22-23. And it "humiliates the ...children now being raised by same-sex couples" and "makes it even more difficult for the children to understand the integrity and closeness of their own family and its concord with other families in their community and in their daily lives." Id. at 23.
The Attorney General for Pennsylvania, Kathleen Kane, has reportedly declared she will not defend the constitutionality of the state statutes barring same-sex marriage. The Pennsylvania Governor, Tom Corbett, the named defendant and a Republican, as well as the state legislature, are presumably studying the holding regarding BLAG's standing in Windsor.
In Arkansas, the complaint in Wright v. Arkansas was filed in state court on July 2. Arkansas has both a statute and constitutional amendment DOMA (the belt and suspenders approach). The 29 page complaint does not quote or cite Windsor, but does claim that the Arkansas prohibition of same-sex marriage violates the Due Process and Equal Protection Clauses of both the state and federal constitution, as well as violating the Full Faith and Credit Clause. First reports are that the state will defend the lawsuit.
In addition to new complaints filed post-Windsor (Perry), ongoing litigation will certainly be changed. For example, the North Carolina federal court complaint in Fisher-Borne v. Smith challenging North Carolina's failure to provide so-called second-parent adoption is being amended - - - reportedly with agreement of the state - - - to include a claim challenging the state's prohibition of same-sex marriage.
While one message of Windsor and even Perry could be understood as being that marriage, same-sex or otherwise, is a matter of state law, another message of Windsor is certainly that there are constitutional problems prohibiting same-sex marriage.
With a patchwork of state laws, this is a fertile landscape for continuing litigation.
[all images Wikimedia; final image here]
July 16, 2013 in Courts and Judging, Current Affairs, Due Process (Substantive), Equal Protection, Family, Federalism, Fifth Amendment, Fourteenth Amendment, Interpretation, News, Recent Cases, Sexual Orientation, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Tuesday, July 2, 2013
What if Supreme Court Opinions Were Anonymous?
Last Term's opinions - - - especially its opinions regarding the constitutionality of the VRA in Shelby, of DOMA and Prop 8 in Windsor and Perry, and of UT's affirmative action plan in Fisher - - - continue to spark debate and commentary. As well they should. But much of our discussions focus on individual Justices: Is Justice Kennedy the "first gay Justice?" Is Justice Alito really rude? Is Chief Justice Roberts playing a "long game?" And what about the tumblr "Notorious R.B.G.? Or @SCOTUS_Scalia, a twitter account?
In their 2010 law review article, Judicial Duty and the Supreme Court's Cult of Celebrity, available on ssrn, Craig Lerner and Nelson Lund observed that there was a huge dissonance between the personality portrayed in confirmation hearings and the outsized personality on the bench and suggested four Congressional reforms. Their first proposal:
Congress should require that all Supreme Court opinions, including concurrences and dissents, be issued anonymously. This should lead to fewer self-indulgent separate opinions, more coherent and judicious majority opinions, and more reason for future Justices to treat the resulting precedents respectfully.
They contend, "[t]ruly unpretentious judicial servants should have no need to put their personal stamp on the law, and the practice of doing so has contributed to unnecessary and unhealthy flamboyance in the Court's work."
Their article contains an excellent discussion of the problem of "celebrity," but little discussion of the constitutionality of a Congressional mandate for anonymity or for their other proposals. Certainly, should the anonymity proposal be enacted, there would be a constitutional separation of powers challenge. Although who would have standing? And what about recusal?
[image DonkeyHotey via]
July 2, 2013 in Affirmative Action, Cases and Case Materials, Congressional Authority, Courts and Judging, Current Affairs, Elections and Voting, Equal Protection, Gender, Interpretation, Race, Recent Cases, Reconstruction Era Amendments, Scholarship, Sexual Orientation, Standing, Supreme Court (US), Theory | Permalink | Comments (0) | TrackBack (0)


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For the past 11 years, Subway has teamed up with local businesses to raise money for the American Heart Association. The proceeds of all sales at Subway restaurants in Bulloch County between 11:30 a.m. and 1:30 p.m. went directly to the American Heart Association. The businesses divide up into teams, and compete for the bragging rights for who raised the most money. Viracon, Wal-Mart D.C., and Briggs & Stratton teamed up on the Gateway Warriors team. Between pre-orders, donations, and counter sales, The Gateway Warriors raised $ 3,122.51.
A select group of band students from Southeast Bulloch Middle School and Southeast Bulloch High School participated recently in two of the most prestigious concerts for music students in the United States.
The Statesboro City Council will take up discussion again of plans to change the boundaries of the city's voting districts during its regular meeting Tuesday at 6 p.m.
2008 will be a busy year for elections an Bulloch County. In addition to it being the presidential election year, several local offices are up for election, as well.
Bulloch County Commissioners discussed possible improvements and expansions to Splash in the Boro, the water park at Mill Creek Regional Park that has become an attraction drawing people from all over the state as well as parts of South Carolina.
A spokesperson for Memorial Health University Medical Center in Savannah confirmed that Jamie Carter, 22, passed away Wednesday evening. Carter was the third Georgia Southern University student to die following an accident Sunday afternoon. Carter, and her two friends Melissa Eustice, 20, and Jessica Fulmer, 21 were involved in the roll-over accident on Interstate 16 near Metter. Eustice and Fulmer were pronounced dead Sunday.
Local organizations and state representatives are coming together this weekend to commemorate Georgia's Arbor Day.
Statesboro Police arrested a man early Wednesday morning they said pretended to be a law enforcement officer and groped a woman at a local bar.
Tuesday, Bulloch County Sheriff's investigators arrested the father of a baby they said suffered from "Shaken Baby" syndrome. Michael Ray Huffines Jr., 23, Holloway Lane, is behind bars on charges of aggravated battery and cruelty to children, held without bond, said Bulloch County Sheriff Lynn Anderson.
A Georgia Southern University student remains in critical condition Monday after an accident Sunday afternoon that left two others dead, said Georgia State Patrol Senior Trooper David H. Averitt.
The Bulloch County Chapter of the National Society of Daughters of the American Revolution (NSDAR) celebrated Georgia Day Tuesday with a luncheon featuring speaker David Tribble, president of Savannah's historical Bethesda Home for Boys.
A survivor of a single vehicle crash Sunday that killed two women remained in "stable, but critical" condition Monday, according to family members.
The Jubalheirs will present a concert on Friday, Feb. 15, 2008, at the First Baptist Church of Statesboro. Featured also in the concert will be Jubalheir Handbells.
The Statesboro and Downtown Statesboro Rotary Clubs came together Monday to announce their 2008 Rotary Citizen of the Year - William R. "Bobby" Smith.
The Georgia Southern football team took the practice fields at Beautiful Eagle Creek Thursday to kick off their first fall camp after officially joining the Sun Belt Conference.
Under the direction of Statesboro Youth Ballet director Jurijs Safonovs, dance students completed two weeks of rigorous study at the Averitt Center for the Arts Summer Ballet Intensive Friday.
(Click on the bottom right-hand corner to view video full-screen)


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Blu Studio 6.0 HD arrives with focus on display
Blu has taken the wraps off its latest handset, the phablet-sized Studio 6.0 HD. With this model comes a strong focus on the display, with Blu saying the Studio 6.0 HD is the company's best smartphone to date. Among other things, the handset offers a 6-inch 245ppi HD screen.


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As a Star Wars fan I wanted to get this for my desk at home. I have been very happy with it and my kids love playing with it also. It is a fun, toy! Read morePublished 16 days ago by MooreNotLess
This potato head is a must have for Star War collectors. It comes I'm a sturdy box. You can display them in their box or take them out.Published 24 days ago by Mavila
really good toy. Only comes with the star wars stuff not anything else.Published 27 days ago by Jennifer
This is a gift for a very special child who loves chips and darth vadar. He went wild when he first saw this. Read morePublished 1 month ago by Just Mad .. madly crazy ..
Bought this for a friends husbands birthday as a kinda joke, our birthdays are on the same day and he is a Star Wars freak. He loved it.Published 1 month ago by willowbe


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Police Body Cam Footage Reveals Details of Fatal Shooting of Texas Man in Oklahoma
Newly released body camera footage shows what happened when a Muskogee, Oklahoma police officer killed a suspect on January 17.
Newly released body camera footage shows what happened when a Muskogee, Oklahoma police officer killed a suspect on January 17.
Bad news for privacy fans: The police are getting their hands on a new piece of handheld technology designed to peer through walls.
The highly-sensitive radar can detect movement as subtle as breathing from up to 50 feet away through solid concrete, USA Today and Atlanta's WXIA-TV report.
Police arrested and charged a woman for felony driving under the influence in upstate New York near Rochester last week.
No big deal, right? Well, this wasn't your typical DUI.
A Victoria, TX police office who was suspended last month after using his Taser on a 76-year-old man during a traffic stop was terminated after an internal affairs investigation.
A Kentucky police officer is recovering after accidentally shooting himself in the stomach while in an elevator with his wife.
We have all seen DUI checkpoints and police stops before.
And when we've seen them, most of us just pull over and let the cops do their thing.
But there is a portion of the population that doesn't agree with that stance and instead does something like this guy.
It's no surprise to some that Lenden Woodruff has been arrested on charges of drunk driving.
That's because he has two prior convictions for the same offense. But the plot thickens because Woodruff isn't just a normal drunkard, but is a police officer who leads law enforcement departments in Oklahoma.
The hostage situation in Sydney finally came to an end Monday after about 16 hours.
Police stormed Lindt Chocolate Cafe at Martin Place when they heard a gun go off, and then the hostages ran out.
Three people were killed, including the gunman, and some were injured, Sydney's Seven News reported. However, 15 out of the 17 hostages made it out alive, The Sydney Morning Herald reported.
Scott Stapp's downward spiral continues.
A Texas police officer has been placed on administrative leave after using his Taser on a 76-year-old man whom he pulled over for an expired inspection sticker.
In what some consider to be a blow to drunk driving enforcement, a Texas court has ruled that law enforcement must first obtain a warrant before administering a blood test to determine Blood Alcohol levels.


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In celebration of embracing change
We threw a party involving both Marlo AND a piñata and somehow no one got hurt.
Please help him, dear god
He is surrounded by love and it is just so sickening.
Investing in her future
When there is money involved my firstborn asks, "How high would you like me to jump?"
Big sister, little sister
Brining back memories of my childhood and the big sister I adored.
Quinoa, frogs legs and more musings from "The Picnic Game"
When it comes to games involving the alphabet, pity the participant who is in his sixties and can't remember what comes after the letter C.
An exquisite moment I somehow overlooked from the photo session with my girls.
With my little girls
"I just want four walls and adobe slabs for my girls."
Job experience
I think I understand my older sister a little better just by watching my own children. I'm so sorry, September.
A somewhat theatrical start to the next ten months
There's a way to start off a school year, and then there is the Heather B. Armstrong way.
Fifth grade
The grind begins again. Where in the hell did the summer go? And when did my baby get so big?


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February is American Heart Month and represents a great opportunity to understand the risk factors of cardiovascular disease and learn how to incorporate heart-healthy habits for a lifetime.
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If I rip pansies up will the seeds still ripen?
If I rip pansies up with seed pods will the seeds still ripen? I have been growing pansies for only a few years but have saved the seeds every year. My plants are looking awful right now since I completely forgot to cut them back. They currently have about half seed pods and 1/4 flowers and another 1/4 wilted flowers/new seed pods. Has anybody tried pulling them up, putting them upside down in a bag and seeing if the seeds keep ripening? I assume so but want to know anybody else's experience with this? I really have to resist the urge to pull these guys up since I really want the seeds, I have some cool varieties such as Tiger's Eye, and some huge flowered(up to 4-5 inches across) ones, not sure the variety though.
Thanks to anybody who'll help!