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Wednesday, April 17, 2013
Daily Read: Resnik on Equality's Frontiers
What do our visual images of justice tell us? Judith Resnik with her co-author Dennis E. Curtis, provide ample, exciting and complex answers to that question in their marvelous book, Representing Justice: Invention, Controversy, and Rights in City-States and Democratic Courtrooms, published in 2011.
Resnik's 2013 essay, Equality's Frontiers: Courts Opening and Closing, adapted from remarks at an event celebrating Justice Ginsburg's gender-equality jurisprudence and drawing on the book, is a brief but evocative look at how justice and equality are - - - and were - - - portrayed. Two images Resnik includes and analyzes from WPA murals in courthouses are particularly salient.
First, there is an image of Justice as Protector and Avenger in a South Carolina courtroom.
Not particularly remarkable, one might think, until one reads about the objections to "justice" looking like a "barefooted mulatto woman wearing bright-hued clothing."
Second, there is an image in a Idaho courthouse:
Should this be removed as offensive? Or displayed as an accurate part of the history of justice and equality? Resnik shares the decisions of state officials, ultimately made in consultation with Native tribes.
Resnik contends that such images, including these from courthouses in South Carolina and Idaho,
make a first point—that courts were one of equality's frontiers. The conflicts about what could or could not be shown on courthouse walls mirrored conflicts about what rights people had in court.
A terrific read - - - and look - - - as well as a reminder of the richness of the Representing Justice book.
[images via]
April 17, 2013 in Books, Equal Protection, History, Profiles in Con Law Teaching, Race, Scholarship | Permalink | Comments (0) | TrackBack (0)
Tuesday, April 16, 2013
ICWA, Baby Girl (Veronica), Race and Fatherhood at the Supreme Court
Today's oral arguments in Adoptive Couple v. Baby Girl, which we previewed yesterday, were indeed a mix of statutory interpretation and application of the Indian Child Welfare Act (ICWA) and constitutional issues, with a dose of family law.
Arguing for the adoptive couple, Lisa Blatt described the biological father as equivalent to "a sperm donor," causing Justice Scalia to counter with an assertion of fatherhood ("He's the father. He's the father.") to which Blatt replied, "And so is a sperm donor under your definition. He's a biological father and nothing else in the eyes of State law." By this description, Blatt not only argued that the biological father was not a parent under ICWA, but also tended to erode any constitutional rights that the father might have. Blatt also took on the constitutional argument more directly, arguing that ICWA would "raise grave constitutional concerns" if "Congress presumptively presumed that a non-Indian parent was unfit to raise any child with any amount of Indian blood."
The "amount of Indian blood" was an issue that attracted the attention of Chief Justice Roberts, who has been attentive racial identities in the affirmative action cases, including Fisher argued earlier this Term. During Charles Rothfeld's argument on behalf of the biological father, Roberts posed a "hypothetical" about an Indian tribe that had a "zero percent blood requirement" and enrolled members who "think culturally they're a Cherokee." Justice Ginsburg objected that this was not the ICWA definition and Justice Scalia agreed that Roberts' hypothetical would be a "null set," but Roberts posed the query again. Rothfeld replied that such "wild hypotheticals" would "present political questions to be addressed by Congress or addressed by the executive branch."
Arguing between Blatt and Rothfeld, Paul Clement, on behalf of the child's law guardian - - - asserting the child's best interests as assumed by the guardian - - - also contended that ICWA was constitutionally suspect. The "Indian child" is a racial classification:
And as a result of that her whole world changes and this whole inquiry changes. It goes from an inquiry focused on her best interests and it changes to a focus on the birth father and whether or not beyond a reasonable doubt there is a clear and present danger.
Clement's characterization of ICWA's standard was somewhat hyperbolic, although the statute does require the high standard and does have a "substantial and immediate danger or threat of such danger" exemption. This resonated with Blatt's rebuttal, expressing the dangers of a Court affirmance of the South Carolina Supreme Court's opinion in favor of the biological father:
And you're basically relegating the child, the child to a piece of property with a sign that says, "Indian, keep off. Do not disturb." This case is going to affect any interracial adoption of children.It is highly unlikely that the Court will address the lurking equal protection racial classification issue, however its importance was revealed in Paul Clement's colloquy with Justice Kennedy about "constitutional avoidance." Justice Breyer essentially asked Clement how to remedy the situation and Clement responded that because ICWA provides "extraordinary" protections that "it only makes sense to prove something more than bare paternity."
It is more likely that the Court's usual conservative/liberal dichotomy will not be apparent in the ultimate opinions.
[image via]
April 16, 2013 in Congressional Authority, Current Affairs, Family, Oral Argument Analysis, Race, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Monday, April 15, 2013
Oral Argument Preview: Adoptive Couple v. Baby Girl and the Constitutional Issues
The oral arguments in Adoptive Couple v. Baby Girl, on certiorari to the South Carolina Supreme Court will be held on April 16. The case, also known as "Baby Veronica," is an emotional struggle over custody of a small child.On one view, the Court's task is a relatively simple one of statutory interpretation, including the definition of "parent" in the Indian Child Welfare Act, ICWA. The petitioners, the adoptive couple, articulate the questions presented as:
(1) Whether a non-custodial parent can invoke the Indian Child Welfare Act of 1978 (ICWA), 25 U.S.C. §§ 1901-63, to block an adoption voluntarily and lawfully initiated by a non-Indian parent under state law.
(2) Whether ICWA defines "parent" in 25 U.S.C. § 1903(9) to include an unwed biological father who has not complied with state law rules to attain legal status as a parent.
The questions presented by the respondent birth father, a registered member of the Cherokee Nation, and by the respondent Cherokee Nation, and by the United States as amicus curiae supporting the respondent, all likewise focus on ICWA, albeit with a different persuasive cadence. These articulations stress the positive acts of the biological father. For example, as the biological father phrases the parenting definition question:
Whether an Indian child's biological father who has expressly acknowledged that he is the child's father and has established that he is the father through DNA testing is the child's "parent" within the meaning [of ICWA].
The Brief of the United States as amicus curiae, supporting the respondent father and tribe has a similar issue statement, asking whether the state courts properly applied ICWA
to award custody of an Indian child to her biological father over an adoptive couple, where the father acknowledged and established his paternity and no remedial measures had been taken to avoid termination of his parental rights.
However, the case is not merely one of statutory interpretation, but raises important, if not always obvious, constitutional issues.
First, Congressional intervention in child welfare must rely on a particularly enumerated power of Congress, the usual one being the Spending Clause. For Native Americans, however, Congressional power is often labeled "plenary," although it is grounded most specifically in the Indian Commerce Clause, Art. I §3 cl. 8. ICWA was intended to prevent the removal of Native children from their parents - - - as well as their tribes - - - a history that many of the amicus briefs discuss in depth.
Second, and relatedly, this Congressional power over Native children raises federalism issues, especially given that child custody and adoption are generally within the state's police powers. In the case of Baby Veronica, the South Carolina Supreme Court affirmed the trial judge's application of ICWA to deny the adoption and award custody to the Native father. Yet the very existence of ICWA arguably intrudes upon state police powers.
Third, and most stealthily, the case may present issues of due process and equal protection. In the brief on behalf of Baby Veronica through her Guardian ad Litem authored by Paul Clement, the arguably "erroneous interpretation" of ICWA "raises serious constitutional issues." In this argument, the best interests of the child standard - - - the usual touchstone in child adoption and custody - - - aspires to a constitutional right of the child. Moreover, the state court's decision violated the baby's equal protection and due process rights.
For example, the brief analogizes to the equal protection case of Palmore v. Sidoti:
In Palmore, this Court struck down the use of racial classifications to remove a child from an appropriate custody placement. This case is no different. Baby Girl's Indian blood quantum was the sole reason the lower court ordered her removed from the loving, stable home she had lived in since birth and placed with a biological father whose failure to timely care for her extinguished any parental rights he might otherwise have had under state law or the Constitution.
Less successfully, the brief attempts to articulate a liberty interest of the child:
And "to the extent parents and families have fundamental liberty interests in preserving such intimate relationships, so, too, do children have these interests, and so, too, must their interests be balanced in the equation." Troxel v. Granville, 530 U.S. 57, 88 (2000) (Stevens, J., dissenting).
Yet ultimately, the brief argues that there is an (unconstitutional) racial classification if ICWA is applied too broadly. Clement argues that ICWA should be interpreted to limit "its application to adoption and custody proceedings involving children who are either domiciled on a reservation or have some other tribal connection beyond biology."
These limitations are crucial to preserving the Act's constitutionality, ensuring that the Act's differential treatment of Indians operates only to promote tribal sovereignty and the unique interests of Indians as tribal citizens, and not as invidious racial discrimination that arbitrarily trumps Baby Girl's liberty interests. [ICWA's] definition of parent, properly interpreted, avoids these difficulties by declining to give an unwed Indian father rights based on biology alone that no non-Indian unwed father enjoys.
Moreover, ICWA's constitutional interpretation rests upon limiting its "application to children in the pre-existing custody of an Indian parent or other circumstances in which there is a distinct connection to tribal interests."
Clement - - who so recently represented BLAG supporting the constitutionality of DOMA in United States v. Windsor - - - here has quite a different view of equality and federal power.
While it is unlikely that these constitutional arguments assume center stage, they may infuse the statutory interpretation of ICWA so squarely before the Court.
[image circa 1890 via]
April 15, 2013 in Congressional Authority, Current Affairs, Due Process (Substantive), Equal Protection, Family, Federalism, Fundamental Rights, History, Interpretation, Race, Sexuality, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Tuesday, April 9, 2013
Daily Read: Two Very Different Clarks by Alexander Wohl
Justice Tom C. Clark and his son, Ramsey Clark, are the focus of Alexander Wohl's new book, Father, Son, and Constitution: How Justice Tom Clark and Attorney General Ramsey Clark Shaped American Democracy.
The senior Clark, appointed by Harry Truman, resigned from the Court at age 67 because Lyndon Johnson appointed the junior Clark as Attorney General. While we understand the conflict, the scenario causes most contemporary readers to pause. Indeed, it is difficult to imagine a current sitting Justice making such a sacrifice for his child's career. Especially since the father and son seemed to have very different politics.
Wohl uses the men's careers to illuminate not merely the personal dyamics, but the constitutional and political changes. Consider this:
As a young government lawyer, Tom Clark was a key figure in enforcing the relocation of Japanese Americans, and as Attorney General he was vilified by civil liberties advocates for the Cold War policies he implemented, even as he promoted a progressive strategy on civil rights. Ramsey began his career to the ideological left of his father, was intimately involved in enforcement of civil rights laws during the turbulent 1960s, as Attorney General fought to expand protections of individual rights, and as a private attorney represented clients on the farthest reaches of the individual rights–government power spectrum.
This new book promises to be an engaging read.
April 9, 2013 in Books, Congressional Authority, Race | Permalink | Comments (0) | TrackBack (0)
Sunday, April 7, 2013
Daily Read: Justice Scalia on His Childhood
New York Magazine, in a feature "Childhood in New York" includes Antonin Scalia, now a United States Supreme Court Justice.
Scalia, born in 1936, has this to say about his school days in Elmhurst, Queens:
The teacher . . . was a lady named Consuela Goins, and she was a wonderful teacher. Every cloud has a silver lining, and one of the benefits of the exclusion of women from most professions was that we had wonderful teachers, especially the women who today would probably be CEOs.
The school was a very mixed group of people. There are no blacks in the class, and there really weren't any in our neighborhood, but other than that it was, my goodness, polyglot . . .
[image: Albert Anker, Schoolboy, circa 1881 via]
April 7, 2013 in Gender, Race, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Wednesday, April 3, 2013
Update: Federal District Judge Cebull Retires
More than a year after Federal Judge Richard Cebull of the District of Montana (pictured)reported himself to the Ninth Circuit after a "joke" he forwarded on email became public,
Ninth Circuit Chief Judge Alex Kozinski has issued a statement announcing that Judge Cebull is retiring:
Judge Cebull's self-filed complaint and another were referred to a Special Committee which conducted a thorough and extensive investigation, interviewed numerous witnesses, considered voluminous documentation, including emails, and conducted an interview with Judge Cebull. The Special Committee's Report was submitted to the Judicial Council in December 2012. On March 15, 2013 the Judicial Council issued an Order and Memorandum. Judicial Conduct Rule 20(f). Pursuant to Judicial Conduct Rules 22 and 24(a), the Order and Memorandum remains confidential during the appeal period.
At this time, Judge Cebull has submitted his retirement letter, pursuant to 28 U.S.C. § 371(a), effective May 3, 2013. The Council will have no further statement on this matter until Judge Cebull's retirement is effective.
We will await the Council's statement and release of the Order and Memorandum.
[image of Judge Cebull via]
April 3, 2013 in Courts and Judging, Current Affairs, Race | Permalink | Comments (0) | TrackBack (0)
Monday, March 25, 2013
Supreme Court Takes Another Affirmative Action Case: Michigan's Prop 2
Even as we await the United States Supreme Court's opinion on the constitutionality of a university's affirmative action plan in Fisher v. University of Texas argued October 10, it has become clear that Fisher will not be the Court's last affirmative action case.
Today, the Court granted a petition for certiorari in Schuette v. Coalition to Defend Affirmative Action to the Sixth Circuit's en banc decision in Coalition to Defend Affirmative Action v. Regents of the University of Michigan decided last November. Recall that the Sixth Circuit majority held Michigan's anti-affirmative action constitutional amendment, passed in 2006 as a ballot initiative Proposal 2, unconstitutional.
The en banc Sixth Circuit was seriously fractured, but none of the opinions considered the Court's affirmative action cases of Grutter and Gratz (or the pending case of Fisher). Instead, the relevant doctrine was the so-called "political process" aspect of the Equal Protection Clause which asks whether a majority may vote to amend its constitution to limit the rights of a minority to seek relief? This underlying problem is similar to some of the arguments in the Proposition 8 case - - - Hollingsworth v. Perry - - - to be argued before the Supreme Court tomorrow, March 26, and certainly resonates with the Ninth Circuit's reasoning in Perry finding that Prop 8 was unconstitutional.
In the case of Michigan's Prop 2, the Sixth Circuit majority found it troublesome that only as to racial classifications in university admissions would a person seeking to change policy have to amend the state constitution, as contrasted to other classifications that could be changed by various other means, including simply persuading an admissions committee.
As to what the Court's grant of certiorari in Coalition to Save Affirmative Action might mean for Fisher, reading the "tea leaves" is difficult. As we observed when the Sixth Circuit decided Coalition to Save Affirmative Action, a very broad approach in Fisher - - - such as a declaration that all racial affirmative action policies in education were per se unconstitutional - - - would seriously undermine the rationale of the Sixth Circuit opinion. However, a grant of certiorari in Coalition to Save Affirmative Action does not mean that Fisher will be narrow or that it will uphold the University of Texas' affirmative action plan.
And one additional "wrinkle": Justice Kagan is recused in Coalition to Save Affirmative Action.
[image Affirmative Action demonstration in 2003, via]
March 25, 2013 in Affirmative Action, Elections and Voting, Equal Protection, Federalism, Fourteenth Amendment, Race, Recent Cases, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Monday, March 11, 2013
Federal District Judge Upholds Most of Arizona's Anti-Ethnic Studies Law, HB 2281
Arizona's HB 2281, which we noted when it was passed in 2010, has been primarily upheld by federal district judge Wallace Tashima in his opinion late last Friday in Acosta v. Huppenthal. Recall that HB 2281, codified as Arizona Revised Statute §15-112 provides:
A. A school district or charter school in this state shall not include in its program of instruction any courses or classes that include any of the following:
1. Promote the overthrow of the United States government.
2. Promote resentment toward a race or class of people
3. Are designed primarily for pupils of a particular ethnic group.
4. Advocate ethnic solidarity instead of the treatment of pupils as individuals.
Savings clauses in subsections E and F state that the statute should not be construed to restrict or prohibit instruction in various matters, including "the historical oppression of a particular group of people based on ethnicity, race, or class."
It was the savings clauses and Judge Tashima's narrow interpretation of the statute that supported his conclusion that most of the statute survived the First Amendment challenge. Judge Tashima also ruled that the statute survived the Equal Protection and Due Process challenges.
As to the First Amendment, Judge Tashima explained:
Plaintiffs' First Amendment claims are premised on two bases: the right to speak freely in the classroom, and the right to receive information and ideas. The first basis cannot sustain their claims because the statute does not limit what students can say in the classroom. But the statute does implicate the second basis because Plaintiffs have an established right to receive information and ideas in the classroom. Limitations on this right, however, are subject only to limited scrutiny, i.e., whether the provisions are reasonably related to a legitimate pedagogical concern.
In construing the first and second provisions - - - banning courses that "promote the overthrow" or "promote resentment" - - - he stressed a narrow reading of the word "promote." He also ruled that the exception for "historical oppression" (in the savings clause section F) keeps "the proscription from crossing the constitutional line."
However, he held that the third subsection - - - "Are designed primarily for pupils of a particular ethnic group" - - - could not be similarly saved. He noted that this provision does not promote any legitimate interest that is not already covered by the second provision, and could "chill the teaching of legitimate ethnic studies courses."
He returned to his narrow reading to uphold the fourth provision - - - "advocate ethnic solidarity:"
Thus, if the statute simply proscribed courses that taught ethnic solidarity, without any reference to the treatment of students as individuals, it likely would not survive even the most deferential scrutiny. The provision, however, is more narrowly tailored than an outright ban on the teaching of ethnic solidarity. Instead, the statute prohibits the "advocacy" of ethnic solidarity "instead of the treatment of pupils as individuals." By phrasing this provision in the alternative, and by restricting only the direct "advocacy" of ethnic solidarity, the provision is at least reasonably related to legitimate pedagogical concerns.
Judge Tashima disposed of the Equal Protection and Due Process challenges with much more expediency. Regarding Equal Protection, he found that the statute did not make an express racial classification, and although there were "red flags" and "some aspects of the record may be viewed to spark suspicion that the Latino population has been improperly targeted" that "on the whole, the evidence indicates" that it was the program and not "Latino students, teachers, or community members who supported or participated in the program" that was the issue. Regarding Due Process, Judge Tashima concluded in a paragraph that there was no prima facie showing.
It seems likely that an appeal to the Ninth Circuit will be forthcoming.
[image: 1860 map of Tucson area via]
March 11, 2013 in Due Process (Substantive), Equal Protection, First Amendment, Fourteenth Amendment, Opinion Analysis, Race, Speech | Permalink | Comments (0) | TrackBack (0)
Daily Read: Symposium Issue on Perry from NYU Review of Law & Social Change
Debuting on line today is volume 37:1 of the NYU Review of Law & Social Change, a symposium issue dedicated to Perry v. Brown, now Hollingsworth v. Perry that is scheduled to be heard by the United States Supreme Court in 15 days.
According to the Introduction, the Symposium editors sought to present the issue as a "time capsule," filled with "leading and emerging voices in the LGBTQ movement" as well as other scholars, "reflecting on Perry before the Court has its final say, before anyone gets the benefit of 20/20 hindsight." The comments were "first drafted before the Court had even granted certiorari" on the premise that Perry was already an important case.
The Symposium participants were asked to address three queries. Here are the questions and the participants:
The Symposium will also be available as a print issue, but meanwhile having its full contents available before the arguments makes it more valuable as a daily - - - or weekly - - - read.
March 11, 2013 in Family, Fundamental Rights, Gender, Race, Scholarship, Sexual Orientation, Sexuality, Standing, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Friday, March 8, 2013
Daily Read: Obama Signs VAWA
Apropos of International Women's Day today, President Obama's signing of the reauthorization of the Violence Against Women Act (VAWA) yesterday is the daily read, including the official remarks and the video below.
As the President's remarks reflect, the version of VAWA that passed Congress is notable because it includes protections for Native Americans (expanding tribal jurisdiction), for undocumented persons, and for persons in same-sex relationships.
And they are also notable for his shout-out to one of my former students, Sharon Stapel, for her work.
[video via]
March 8, 2013 in Congressional Authority, Family, Fourteenth Amendment, Gender, Race | Permalink | Comments (0) | TrackBack (0)
Thursday, March 7, 2013
"Racial Entitlement": Professor Scalia, then and now
Justice Antonin Scalia's remark during the oral arguments in Shelby County v. Holder last week characterizing the preclearance provision of the Voting Rights Act as a "racial entitlement" has garnered much attention, including "gasps" in the Supreme Court chambers itself.
Of course, the ability of Scalia's comments to provoke is not new: his statements in last year's oral arguments in Arizona v. United States regarding the constitutionality of SB1070 drew particular attention.
In the Shelby argument, Scalia described the Voting Rights Act provision and its reenactments as
a phenomenon that is called perpetuation of racial entitlement. It's been written about. Whenever a society adopts racial entitlements, it is very difficult to get out of them through the normal political processes.
To what writings does Justice Scalia refer? ConLawProf Chad Flanders, in a news commentary that is itself garnering attention, suggests that Justice Scalia might be referencing Professor Scalia's own writings. Flanders points to Scalia's article, The Disease as Cure: "In Order to Get Beyond Racism, We Must First Take Account of Race," 1979 Wash. U. L. Rev. 147, available here.
Scalia's writing is not an article but rather published as a "Commentary" and obviously taken from his remarks on a panel at a Symposium entitled "The Quest for Equality." Scalia describes himself as the "anti-hero" of the panel: the other commentator was Herma Hill Kay and the main paper was by Harry T. Edwards. (Ruth Bader Ginsburg delivered the main paper on the next panel.) His subtitle is derived from Justice Blackmun's dissenting and concurring opinion in Regents of University of California v. Bakke, 438 U.S. 265, 407 (1978).
Scalia indeed does use the term "racial entitlement" in his remarks:
The affirmative action system now in place will produce the latter result because it is based upon concepts of racial indebtedness and racial entitlement rather than individual worth and individual need; that is to say, because it is racist.
But of course, his rejection of "racial indebtedness" was clear in his 1995 concurring opinion in Adarand Constructors, Inc. v. Pena, 515 U.S. 200, in which the Court held an affirmative action policy unconstitutional. Scalia wrote then:
[image: caricature of Antonin Scalia by DonkeyHotey via]
March 7, 2013 in Affirmative Action, Conferences, Current Affairs, Equal Protection, Fifteenth Amendment, Fourteenth Amendment, Race, Scholarship | Permalink | Comments (2) | TrackBack (0)
Daily Read: Linda Greenhouse on Shelby and the Voting Rights Act
Linda Greenhouse's NYT "Opinionator" column is almost always worth a read.
But yesterday's column entitled "A Big New Power" is a must-read for anyone considering the Court's pending opinion in Shelby County v. Holder and the controversy surrounding Scalia's remarks during the oral argument.
Greenhouse begins:
Years from now, when the Supreme Court has come to its senses, justices then sitting will look back on the spring of 2013 in bewilderment. On what basis, they will wonder, did five conservative justices, professed believers in judicial restraint, reach out to grab the authority that the framers of the post-Civil War 14th and 15th Amendments had vested in Congress nearly a century and a half earlier "to enforce, by appropriate legislation" the right to equal protection and the right to vote.
Greenhouse admits she is forecasting the outcome, but her column makes that outcome seem less palatable.
March 7, 2013 in Elections and Voting, Fifteenth Amendment, History, Race, Reconstruction Era Amendments | Permalink | Comments (0) | TrackBack (0)
Wednesday, February 27, 2013
Daily Read: William Faulkner and the Voting Rights Act
As the Court - - - and the country - - - consider the Voting Rights Act (VRA) and the constitutionality of the preclearance provision at issue in Shelby County v. Holder ConLawProfs might find useful the insights of Andrew Cohen, Atiba Ellis, Adam Sewer (on CJ Roberts), Adam Winkler or numerous others. But the observations of William Faulkner (pictured), Nobel Prize in Literature recipient who placed Yoknapatawpha County, Mississippi on our (fictional) maps are also pertinent according to Joel Heller's excellent article, Faulkner's Voting Rights Act: The Sound and Fury of Section Five, 40 Hofstra Law Review 929 (2012), and available on ssrn.
Joel Heller argues that pronouncements that 'The South has changed' fail to take into account the "ongoing burden of memory that Faulkner portrays so powerfully." Heller contends that the VRA's section 5 preclearance provision "does not punish the sons for the sins of the father, but keeps in check the uncertain consequences of a current ongoing consciousness of those sins." Heller uses Faulkner to effectively discuss various attitudes short of intentional discrimination that might nevertheless have racially discriminatory results. These include lawmakers shame and denial of the past accompanied by a devotion to the "things have changed" mantra that would prevent perceptions of racially problematic actions. Additionally, "local control" possesses a nostalgic power, even as the era being evoked was one of white supremacy.
While Faulkner did not live to see the VRA Act become law, Joel Heller's engaging article is definitely worth a read as the Court considers Congressional power to remedy discrimination in the Old/New South.
[image of William Faulkner via]
February 27, 2013 in Books, Congressional Authority, Elections and Voting, Fifteenth Amendment, History, Race, Reconstruction Era Amendments, Scholarship, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Monday, February 25, 2013
Sotomayor Focuses on Prosecutor's "Racially Charged" Remark
Writing in a "Statement" accompanying the denial of certiorari in Calhoun v. United States today, Justice Sotomayor (joined by Justice Breyer) sought to "dispel any doubt whether the Court's denial of certiorari should be understood to signal our tolerance of a federal prosecutor's racially charged remark."
Defendant Calhoun's intent to participate in a drug conspiracy was a central issue and the defendant took the stand. As Sotomayor explains:
The prosecutor pressed Calhoun repeatedly to explain why he did not want to be in the hotel room. Eventually, the District Judge told the prose- cutor to move on. That is when the prosecutor asked, "You've got African-Americans, you've got Hispanics, you've got a bag full of money. Does that tell you—a light bulb doesn't go off in your head and say, This is a drug deal?"
For Sotomayor, such prosecutorial argument threatens to violate the equal protection guarentee as well as the defendant's right to an impartial jury. She also castigated the government's original position on appeal that the prosecutor's argument was merely "impolitic," and agreed with a Fifth Circuit Judge who noted that the prosecutor's argument clearly "crossed the line."
But the unusual posture of the case - - - including issues preserved for appeal - - - meant that Sotomayor's Statement was a statement, and not a dissent from the denial of certiorari. But a strong statement it certainly was:
I hope never to see a case like this again.
February 25, 2013 in Criminal Procedure, Equal Protection, Fifth Amendment, Race, Recent Cases, Supreme Court (US) | Permalink | Comments (1) | TrackBack (0)
Saturday, February 23, 2013
Daily Read: Andrew Cohen in The Atlantic on Shelby and the Voting Rights Act
Entitled "After 50 Years, the Voting Rights Act's Biggest Threat: The Supreme Court," Andrew Cohen's extensive article just published in The Atlantic is a must-read for anyone following the Court's pending oral argument (on Wednesday, February 27) in Shelby County v. Holder.
Recall that the Court's grant of certiorari last November 9 put the Voting Rights Act (VRA) "in the crosshairs" of the Court - - - as we said at the time - - - noting that the VRA's constitutionality had been seriously questioned but ultimately evaded by the Court's 2009 decision in Northwest Utilities District of Austin v. Holder . The DC Circuit had upheld the constitutionality of the preclearance provisions of the VRA.
Andrew Cohen's article provides a terrific contextualize of the politics, including the Court's politics, that surround the constitutional controversy. Cohen writes that "racial polarization has intensified during the Obama Administration," with "'explicit anti-black attitudes'" around the country, "especially among Republicans," many of whom "sponsored and enacted some of the voter suppression laws of the 2012 cycle." Cohen also argues that the Court essentially "invited many of the state voter suppression efforts of the past three years" by its decisions, including not only Northwest Utilities District of Austin v. Holder, but also the 2008 decision in Crawford v. Marion County, upholding a voter identification statute. Cohen contends: "Having created the factual and legal conditions to undermine the federal law, the Court now is poised to say that it is weakened beyond repair."
Cohen concludes that the stakes in Shelby are very high:
If the Court strikes down Section 5 of the Voting Rights Act, this year especially, given the record of the past three years, the justices who do so will reveal a disconcerting level of disconnect from the realities of modern American politics as they were expressed in the near-unanimous renewal of the Act in 2006. And the partisan ruling they would issue in this circumstance would be even more brazenly ideological and untethered from precedent than the Citizens United ruling issued in January 2010.
Cohen's timely, provocative, and well-argued article is definitely worth a read and would be a great suggested reading for law students considering the issue.
[image via]
February 23, 2013 in Courts and Judging, Current Affairs, Elections and Voting, Fifteenth Amendment, History, Interpretation, Race, Supreme Court (US), Teaching Tips | Permalink | Comments (0) | TrackBack (0)
Monday, February 18, 2013
Daily Read: Reinstein on Executive Power and Haiti
Today we celebrate "Presidents' Day" and ConLawProfs contemplating executive power might do well to consider the Haitian Revolution (1791-1804) as a formative experience.
In his new article, Slavery, Executive Power and International Law: The Haitian Revolution and American Constitutionalism, available in draft on ssrn, ConLawProf Robert Reinstein argues that the "six administrations from George Washington through John Quincy Adams responded to the slave revolt and establishment of Haitian independence in ways that greatly expanded executive power."
Indeed, as Reinstein reminds us, the first sole executive agreements were made by Adams with regard to Haiti (predating the seizure of the schooner The Wilmington Packet by six months). Reinstein contends that the Haitian history is important because
Many of the most controversial questions presidents face in the modern era—whether to support regime change, use military force to protect American interests abroad, intervene in civil wars, arm foreign rebellions, form secret agreements with governments or belligerents, comply with obligations of international law—were first faced in the American reactions to the Haitian slave revolt.
Yet as Reinstein observes, the history also reveals conflicting executive interests, at times favoring domestic fear of a similar slave-revolt and at other times favoring geopolitical (and capitalist) interests. At the center - - - not surprisingly - - - is Thomas Jefferson, who vowed to reduce Haiti's charismatic leader Toussaint L'ouverture to "starvation."
But Reinsten also centers the Supreme Court's hostility to the establishment of the second independent nation in the Western Hemisphere. Reinstein writes that as "Congress debated the first Haitian embargo bill, a Representative asked: "Have these Haytians no rights?"" Reinstein concludes that the "answer ultimately given by the United States government was unequivocal: "No.""
An important - - - and oft-neglected - - - history of executive power as well as judicial power worth a read on Presidents' Day.
[image of Toussaint L'ouverture from a French engraving circa 1802 via]
February 18, 2013 in Executive Authority, History, Race, Scholarship | Permalink | Comments (0) | TrackBack (0)
Monday, January 21, 2013
Daily Read: Martin Luther King on Meet the Press 1965
In a 1965 "Meet the Press" interview, Martin Luther King speaks about civil disobedience, nonviolent protest, and racial equality, responding to the queries from the interviewers.
Worth a watch on this MLK Day, 2013.
[video via]
January 21, 2013 in History, Race, Reconstruction Era Amendments | Permalink | Comments (0) | TrackBack (0)
Wednesday, January 9, 2013
Stop and Frisk in the Bronx Enjoined by Federal Judge
In her 200 plus page opinion in Ligon v. City of New York, federal district judge Shira A. Scheindlin enjoined "stop and frisk" practices of the NYPD in the Bronx. The stop and frisk practices by law enforcement have been increasingly controversial, including arrests of persons attempting to document the practice.
The problem in Lignon is a relatively simple one. The standard for stop and frisk is reasonable suspicion, established by Terry v. Ohio (1968). In the Bronx, there was a practice of Terry stops on the basis of reasonable suspicion of trespass outside buildings in the Bronx that are enrolled in the Trespass Affidavit Program ("TAP"), which was formerly known in the Bronx as Operation Clean Halls. Seemingly, the building, rather than any activity by people, gave rise to the "suspicion" and many people were subject to a Terry stop and frisk outside their own residences.
The judge concluded
while it may be difficult to say where, precisely, to draw the line between constitutional and unconstitutional police encounters, such a line exists, and the NYPD has systematically crossed it when making trespass stops outside TAP buildings in the Bronx. For those of us who do not fear being stopped as we approach or leave our own homes or those of our friends and families, it is difficult to believe that residents of one of our boroughs live under such a threat. In light of the evidence presented at the hearing, however, I am compelled to conclude that this is the case.
The judge made it clear that she was
not ordering the abolition or even a reduction of TAP, which appears to be a valuable way of using the NYPD's resources to enhance the security in voluntarily enrolled private buildings. My ruling today is directed squarely at a category of stops lacking reasonable suspicion.
Precisely because these stops lack rational justification, they are presumably of less value to public safety than would be the stops of individuals who displayed objectively suspicious behavior.
But she did rule that the "NYPD is ordered immediately to cease performing trespass stops outside TAP buildings in the Bronx without reasonable suspicion of trespass." Judge Scheindlin also ordered consolidation of the hearing on some other remedies with the remedies hearing in Floyd v. City of New York, a stop and frisk challenge involving the entire city and not only the borough of the Bronx.
[image from protest against stop and frisk via]
January 9, 2013 in Criminal Procedure, Fourth Amendment, Opinion Analysis, Race | Permalink | Comments (0) | TrackBack (0)
Monday, January 7, 2013
Daily Read: Pam Karlan on the 2011 United States Supreme Court Term
Pamela Karlan's "Democracy and Disdain" is the Forward to Harvard Law Review's annual Supreme Court issue for the 2011 Term and is a compelling - - - indeed, necessary and delightful - - - read. Karlan's central thesis, as the title aptly communicates, is that the Roberts' Court has little but disdain for the democratic process. By "Roberts' Court," of course, she means the five Justices who usually form the majority, including Roberts, Scalia, Thomas, Alito, and Kennedy.
Professor Karlan (pictured) concludes that this disdain will ultimately bring the Court into disrepute, comparing the present state of affairs unfavorably with the Warren Court:
The Roberts Court's narrow substantive reading of enumerated powers maps fairly closely onto the contemporary conservative political agenda. To the extent that the conservative agenda gains popular acceptance, the Court may garner acclaim as a guardian of constitutional values. But if the public rejects that agenda, or remains sharply divided, the Court risks being perceived as simply another partisan institution. The Court's current status rests in substantial measure on its having been on the right side of history in Brown v. Board of Education. Only time will tell whether the Court will retain that status given the choices the Roberts Court is making.
Karlan is adept at comparing the present Court to previous ones, not only including the Warren Court. Spoiler alert: When she quotes Justice Roberts, she might not be quoting the 2012 John Roberts but the 1936 Owen Roberts, a device she uses to especially good effect. Also to good effect is her usage of other justices, colloquies in oral argument, the occasional poet, and theorist. The writing is broad and engaging without being precious. It makes her analysis of the cases even more trenchant, situated in larger themes and trends.
Of course, not all ConLawProfs will agree with Karlan's views of the Court, including one subsection entitled "Protecting Spenders and Suspecting Voters," and another "Suspecting Congress." And Karlan's argument is hardly unique, as anyone who recalls Rehnquist Court scholarship, including the excellent 2001 article "Dissing Congress," by Ruth Colker and James J. Brudney can attest. And it is especially noteworthy that the Court did uphold the constitutionality of the Affordable Care Act in National Federation of Independent Business v. Sebelius, a case that Karlan extensively discusses and more interestingly, situates within the Term's other less notable decisions.
But this is a must read article before beginning the new semester.
And after that, read George Wills' Washington Post op-ed, Karlan's response, and responses in the Harvard Law Review Online Forum by Randy Barnett and Stephen Calabresi.
[image of Pamela Karlan via]
January 7, 2013 in Courts and Judging, Due Process (Substantive), Elections and Voting, Fifteenth Amendment, First Amendment, Fourteenth Amendment, History, Interpretation, Race, Recent Cases, Reconstruction Era Amendments, Scholarship, Separation of Powers, Supremacy Clause, Supreme Court (US) | Permalink | Comments (0) | TrackBack (0)
Friday, January 4, 2013
ConLaw at AALS: Looking Towards Fisher
If you're at AALS, don't miss today's double panel on affirmative action in education, starting at 2pm:
In 1973, the Court held in Rodriguez that there was no fundamental right to education. Plaintiffs alleged that substantial disparities in educational opportunity violated the Constitution. The Court found the Texas elementary and secondary school finance system constitutional because it was rationally related to advancing local control of education; the Court hesitated to second guess the Texas legislature in light of federalism principles and concerns about judicial competency to deal with school finance systems.
The first panel will focus on the legacy of Rodriguez and how the law can address educational disparities in elementary and secondary education. Panelists also will discuss the effect of limits on use of race-conscious programs under the 2007 Parents Involved decision, and will consider the implications of the grant of review in Fisher.In 1978, a deeply fractured Court decided Bakke. Only one paragraph of Justice Powell's pivotal opinion was joined by four other justices; it held that a "properly devised admissions program" that took race into account could be constitutional. He envisioned a flexible, individualized program that would provide the educational benefits of a diverse class. In 2003, the Court in Grutter held that diversity could be a compelling interest; the Court upheld Michigan Law School's program, even as it held (in Gratz) that Michigan's more mechanical undergraduate affirmative action program violated equal protectio
The second panel will consider the legacy of Bakke and discuss how the Court should decide Fisher. Is racial diversity a compelling interest? What is the role of empirical evidence? What do the empirical studies tell us about the benefits or harms of affirmative action? Diversity may provide better learning outcomes for all students (or for certain students), better preparation of students for a diverse world, and better social results due to formation of a diverse group of leaders. Which potential benefits "count"? How can a program be narrowly tailored to advance the interest in educational diversity?
Kevin D. Brown, Indiana University Maurer School of Law
Speaker: Erwin Chemerinsky, University of California, Irvine School of Law
Speaker from a Call for Papers: Paul Horwitz, The University of Alabama School of Law
Speaker: Jennifer Mason McAward, Notre Dame Law School
Speaker from a Call for Papers: Eboni S. Nelson, University of South Carolina School of Law
Speaker: Angela I. Onwuachi-Willig, University of Iowa College of Law
Speaker: Michael A. Rebell, Columbia University School of Law
Co-Moderator: Kimberly Jenkins Robinson, The University of Richmond School of Law
Speaker: Richard H. Sander, University of California, Los Angeles School of Law
Co-Moderator: Mark S. Scarberry, Pepperdine University School of Law
More information here.
January 4, 2013 in Affirmative Action, Conferences, Equal Protection, Profiles in Con Law Teaching, Race, Supreme Court (US), Teaching Tips | Permalink | Comments (0) | TrackBack (0)


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The last example of flame mail from the "Amnesiac" review comes courtesy of "Jim Wright," who ends his raving tirade with the sentence "Feel free to email me back with personal apologies, at [email protected]." Yeah, I'll be getting right on that one there, hero!
From: Jim Wright
Well, that's all the emails I care to cut and paste at the moment, but you can be sure that there are currently over135of these entertaining rants from people who have absolutely no clue whatsoever. Let us all take a moment and weep for society as a whole.
In a Something Awful exclusive, we reveal the true state of Darren Wilson after his harrowing encounter with Michael Brown.
gee, sun, thanks for life and warmth and light. you totally did it on purpose and aren't just a stupid exploding deathtrap
Everything I'm about to show you is art. It says nothing and is worth even less, but it's still art!
I hope you updated before the apocalypse, because the google play app store won't even connect now.
Val Kilmer lures 6 morons into the ultimate death schvitz to prove global warming is real.
Truth Media seeks to lure out the brainless zealots mindlessly spewing words about faceless companies and products they have no relation to. Why do folks get so worked up over such inconsequential things? Truth Media is here, not to discover the answer to this, but just to make fun of them.
Copyright ©2014 Rich "Lowtax" Kyanka & Something Awful LLC.

subset: commoncrawl


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Google is rolling out a nationwide update that drastically changes the way prospective customers see you and your competitors through what Google calls "Place Search." The new integrated results combine your organic and local rankings in a new Google algorithm intended to make finding businesses easier. If you're like us, […]Read more ›
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In today's technological age it's rare to meet someone that doesn't have an opinion on the cloud and its various applications in both the consumer and business worlds.
Folks, I received a really good letter from the Organic Health Response's IT Coordinator, Brian Mattah. He wrote about his experience with technology on Mfangano Island:
At Inveneo, we push technology hard. Our engineers work with the latest tools on the market and our deployments span some of the harshest environments on the planet.
Different colored lasers light up a section of cloud during a test of Inveneo's StratoLancer system. Photo: Aaron Mason
Jenna Burrell, assistant professor at the School of Information at UC Berkeley, is speaking today at the Berkman Center on her research on internet usage in Ghana, the subject of her (excellent) book Invisible Users: Youth in the Internet Cafes of Urban Ghana.


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RebeccaTaylorED posted Chapter Thirty Three--Blinded by the Light to Ascendant
The Exquisite and Immaculate Grace of Carmen Espinoza
Carmen Espinoza is finally leaving her mother today, but before she goes, she needs one more thing—the...
**Currently posting 1 chapter per week, every Friday, for The Exquisite and Immaculate Grace of Carmen Espinoza. This book will be available for purchase through Amazon, Barnes and Noble, Kobo, and iBooks in May 2014** Author, Blogger, Mother, and Licensed Education Specialist, my fiction is represented by Emma Patterson at Brandt and Hochman Literary. My debut novel, ASCENDANT is available at Amazon, Barnes and Noble.com, and The Tattered Cover Please visit my website at www.rebeccataylorbooks.com for more information, blog posts, and upcoming events. Follow me on: Twitter: @RebeccaTaylorED Facebook: https://www.facebook.com/pages/Rebecca-Taylor/39778575944 Website: https://www.rebeccataylorbooks.com Happy Reading!!
Description: When I was twelve, my mother disappeared. I was the first person to never find her. I'm sixteen now and she has never been found, alive or dead. I'm not the girl I should have been. When Charlotte Stevens, bright but failing, is sent...
Carmen Espinoza is finally leaving her mother today, but before she goes, she needs one more thing—the...
hey! I read most of the chapters of The Ascendant this Halloween and I was so intrigued and most likely in loved with it so far! It actually reminded me of some books Ive read before but nevertheless I LOVE IT!!! (Just passing by your wall... nothing important or urgent, i understand if you wouldn't respond to this cause i know that maybe you get a lot of these comments here in Wattpad, anyways i just wanted to let you know)
please post more in the ascendants book it is awseme
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Find what you need:-
We have launched a petition calling on NHS England to stop the cuts to radiotherapy funding. Please sign it and make your voice heard.
Action Radiotherapy is the UK's only nationwide charity dedicated to improving radiotherapy treatment.
We are campaigning to improve patient access to advanced radiotherapy on the NHS.
Every NHS patient should have access to the best radiotherapy for their type of cancer. If you are able to, please donate to support our work in this area and to help us keep the pressure on NHS England.
If you are a patient who has been denied access to advanced radiotherapy, please email us at firstname.lastname@example.com
As well as working to improve radiotherapy access for cancer patients, Action Radiotherapy also supports radiotherapy professionals. Radiotherapy teams in the NHS are highly dedicated but have been working with a severe lack of funding for many years. We help support healthcare professionals across the country by providing a range of services, information and resources.
As a charity, we do not receive any government funding and rely entirely on public donations to continue our work. There are a number of ways you can support us. Even if you are not able to make a financial donation, you can help us raise awareness of radiotherapy by connecting to our Facebook and Twitter accounts.


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LeBron James, who recently returned to the Cleveland Cavaliers after a four year hiatus with the Miami Heat, stars in the newest Beats by Dre commercial.
If you are already a Sprint customer, the carrier will lease you a brand new iPhone 6 for only $5 per month. The iPhone 6 Plus can also be had by existing Sprint customers with a $10 per month lease.
Prior to the start of the 2014 NFL regular season, Microsoft struck a $400 million deal with the league to make the Microsoft Surface the official tablet of the NFL.
Apple started out with just one size iPhone and one size iPad, and eventually branched out to include a smaller iPad (the iPad Mini) and a larger iPhone (the iPhone 6 Plus), but what about making a larger iPad?
For the first time in history, there are more gadgets in the world than there are people, according to data from analysts at GSMA Intelligence. The U.S.
You may suspect that your diet or lack of exercise is making you put on weight, but according to new research, your smartphone could be to blame. Scientists warm that keeping your smartphone in your bedroom overnight could increase your appetite.
Law enforcement and federal agencies are expressing concerns over the iPhone 6's new security measures, complaining that it is is becoming to difficult to eavesdrop on people for security concerns.
Although he is no longer Microsoft's CEO, Steve Ballmer is still loyal to his former long-time employer.
Cleveland, Ohio, is finally getting access to Sprint's 4G LTE service as the wireless carrier announced Monday that they are expanding to 28 new markets. With today's expansion, Sprint now has 4G LTE coverage in 471 cities.
Amazon is making yet another foray into the world of high-tech hardward in an attempt to sell more of its content and products offered at amazon.com. Their latest device - a smartphone called the Amazon Fire - was unveiled at a press event in Seattle on Wednesday.
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Promotion Terms & Conditions
- There is a limit of one coupon per order.
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Headline News Disney Junior Channel Launches on Friday
Disney Junior takes its next big step when it launches as a 24-hour channel Friday, March 23 (12:00 midnight, ET).
Disney Junior takes its next big step when it launches as a 24-hour channel Friday, March 23 (12:00 midnight, ET).
Henson's first CGI animated movie in 3D marks new collaboration with co-production partners in China and will be available to international buyers at MIPTV 2012.
Toei Animation announced that it has appointed Iriya Azuma Director, Global Licensing Business Department.
The world‐renowned Muppets received a star on the Hollywood Walk of Fame from the Hollywood Chamber of Commerce in celebration of the release of Disney's The Muppets on Blu‐ray Combo Pack and DVD.
Speedshape has signed Chad Cooper as director of business development for the hybrid CGI, interactive, 3D company.
The extended deadline for the submission to the Stuttgart Festival of Animated Film Animated Fashion Award is Friday, March 23, 2012.
Caviar's AG Rojas directs the latest Spiritualized music video for "Hey Jane," a track off their upcoming Sweet Heart Sweet Light album (due out April 17 in the United States).
Leading Galway-based film and television production company announces the appointment of Siobhán Ní Ghadhra as Chief Operating Officer.
Framestore is promoting Jon Collins, currently Founder and President of Framestore's New York operation, to the newly created role of President of Integrated Advertising (Worldwide).
Noise Industries introduces CrumplePop SplitScreen X, built from the ground up exclusively for Final Cut Pro X and available through FxFactory.
Leading European production and distribution company Millimages has secured a major broadcast deal for its new children's property "Mouk" with Australia's national broadcast, ABC TV.
MoCCA hosts a one-time master class with the legendary Gahan Wilson, famous for his bizarrely humorous work for Playboy and National Lampoon, on April 17, 2012.
Maker of acclaimed "Heavy Rain" videogame adds Autodesk HumanIK middleware and Autodesk Mudbox software to pipeline.
Joymax announced the launch of the biggest content patch yet for their online massive multiplayer title, "Digimon Masters."
Warner Home Video will dish up another treat from Dr. Seuss with the release of Dr. Seuss's Green Eggs and Ham and Other Stories Deluxe Edition, available on Blu-ray™ for the first time on June 26, 2012.
Superman vs. The Elite, the next entry in the popular, ongoing series of DC Universe Animated Original Movies will be available on Blu-ray Combo Pack and DVD, On Demand and for Download June 12.
Kate Beckinsale is back in action like you've never seen her before in the 3D box office smash hit UNDERWORLD: AWAKENING.
NAMCO BANDAI Games announced that ARMORED CORE V is now available in North America for Xbox 360 and PlayStation 3.
Chris Sullivan's "Consuming Spirits," a meticulously constructed tour de force of experimental animation, will have its world premiere at this year's Tribeca Film Festival.
Vodka Capital has concluded two significant Free-to-Air broadcast acquisition deals in Canada with Télé-Québec (Québec, Canada) and TVOKids (Ontario, Canada) for their exciting new pre-school series "Jelly Jamm."
Sony is spreading the news about its upcoming "The Amazing Spider Man" with the launch of a new website, WebbedMenace.com.
In its continued expansion into the advertising space, NYC-based Decon has hired former BBDO and Droga5 veteran, Misha Louy as its new partner and EP.


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The Department of Veterinary Medicine at UAF Announces Opportunity
Clinician/Internist Position
Classification: Assistant Professor
Working Title: Assistant or Associate Professor of Veterinary Medicine (Clinical)
Department: F-CNSM Veterinary Medicine
Posting Number: 0069727
Quicklink: <https://www.uakjobs.com/applicants/Central?quickFind=85916>
For general information regarding the applicant review process, refer to
Corrosion Casting Available Soon
Dr. Ors Petnehazy will be offering services
Dr. Petnehazy has perfected a method of corrosion casting and hopes to be able to provide the service within the next 3 months. Contact the department for a quotation, and information.
"OH" One Health Seminar Series
Mondays, Murie Auditorium, 4:30 pm
NOVEMBER 24 Cristina Hansen - Don't Count Your Geese Before they Hatch
DECEMBER 1 Ors Petnehazy - Don't be a "Turkey"! What did you miss on Thanksgiving?
DECEMBER 8 Tom Kuhn - Brain Health and Nutrition: blunting inflammatory stress in the aging brain
DECEMBER 15 No Seminar - Finals Week
DECEMBER 22 - JANUARY 12 No Seminar - Holiday Break
If you missed one of the Seminars, you can view a recording at: http://vcs-content.h323.alaska.edu/tcs
Support the Department of Veterinary Medicine
Designate the Department of Veterinary Medicine
Your gift allows the department to fund student travel, student research, scholarships and more. If you are interested in establishing an endowment or scholarship fund, please contact Cathy Griseto at 907-474-1928.
College of Natural Science and Mathematics
The College of Natural Science and Mathematics is home to the Department of Veterinary Medicine. For more about the college please visit www.uaf.edu/cnsm/


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Tag: Bayer Leverkusen
Schurrle admits he would struggle to turn down 'interesting' Chelsea move
Bayer Leverkusen striker Andre Schurrle admits he would find it difficult to turn down a move to Chelsea provided they are successful with a bid for his services. The ...READ MORE +
North London rivals set for battle over summer free agent
Bitter city rivals seem destined to clash once more this summer as Arsenal are reportedly mounting interest in the signature of Rene Adler. The goalkeeper's contract at Bayer ...READ MORE +
Race heats up for Bundesliga veteran
It would seem that Michael Ballack is preparing for a move away from Bayer Leverkusen after the club revealed that he had not trained with them today. To fuel the fire of ...READ MORE +
Liverpool keen on cut-price deal for German veteran
Amid reports that Queens Park Rangers are interested in signing the former Chelsea star, Liverpool are also willing to try their hand in bringing Michael Ballack back to the ...READ MORE +
Liverpool looking at Bundesliga talisman
Sources have reported that Andre Schurrle has emerged as a target for Liverpool as the Premier League continue their search for a winger. The Anfield outfit have been ...READ MORE +
Tottenham poised to make move for Bundesliga stopper1
News is emerging from numerous media outlets that Beyer Leverkusen goalkeeper René Adler is the latest asset to hit the radar of Tottenham Hotspur. Sources from the club claim ...READ MORE +


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LL Cool J Hands Out School Supplies To Kids At Worldstar Foundation Event
NEW YORK (CBSNewYork) — It's time for parents and kids to get ready for another school year, but nowadays school supplies can be really pricey.
So in Queens, the Worldstar Foundation held a backpack giveaway on Sunday. Each bookbag was filled with school supplies, CBS 2 reported.
LL Cool J, the star of the hit CBS show "NCIS Miami," returned to his hometown to help out with the event.
"It lifts a burden. You'd be surprised what $30, $40, $50 dollars, whatever this ends up costing per child and how that affects a family," LL Cool J said. "This is very important."
Those who received the backpacks were thrilled.
"I like the supplies and I like the bookbag cause it's so cool," said one little girl.
More than 2,000 kids attended the event.
Check Out These Other Stories From CBSNewYork.com:
- FDNY: 1 Hurt After Staten Island Roof Partly Collapses
- Police Search For Missing 81-Year-Old Woman In Queens
- Holiday Shopping Season Continues With Black Friday
- Shoppers Take Advantage As More Stores Open On Thanksgiving Day


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Sir William Quiller Orchardson
6 of 18 portraits of Sir William Quiller Orchardson
- Overview
- Extended Catalogue Entry
© National Portrait Gallery, London
Sir William Quiller Orchardson
by Sir Leslie Ward
pencil and watercolour, published in Vanity Fair 24 March 1898
13 7/8 in. x 8 1/4 in. (352 mm x 210 mm)
Purchased, 1974
Primary Collection
Click on the links below to find out more:
Sitterback to top
- Sir William Quiller Orchardson (1832-1910), Portrait and subject painter. Sitter associated with 18 portraits, Artist associated with 5 portraits.
Artistback to top
- Sir Leslie Ward (1851-1922), 'Spy'; caricaturist and portrait painter; son of Edward Matthew Ward. Artist associated with 276 portraits, Sitter in 7 portraits.
Linked publicationsback to top
- Saywell, David; Simon, Jacob, Complete Illustrated Catalogue, 2004, p. 470


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7 Underwear Books for Kids: Including One Big Pair of Underwear
Laura Gehl is the author of One Big Pair of Underwear, illustrated by Tom Lichtenheld, which released in September. There are a number of underwear books for kids…
Twelve-year-old Charlie is a fantasy football guru. He may be just a bench warmer for his school's football team, but when it comes to knowing and loving the game, he's first-string.
The inspiration, passion, and illustrations make The Bambino and Me a wonderful, well rounded, addition to any reader's roster.
Among scores of spring themed picture books, families with young fans can celebrate the season with this diverse selection of 5 baseball inspired books.
This is a charming book in so many ways, and definitely fun for a family to enjoy together. It will appeal to readers ages 5 to 8, who like stories about Spanish culture, stories about sisters, and surprising revelations about parents.
It's holiday shopping time! Hopefully you're planing to #GiveBooks to the children in your life. Nothing beats the gift of reading. Look no further than these hand-picked book lists.
We are so happy to share this book list graphic brought to you by Noodle.org, as selected by author and librarian Betsy Bird.
We are so happy to share this Noodle.org graphic featuring fabulous book suggestions from brilliant librarian Betsy Bird.
These three contemporary books—one chapter book, one middle grade reader, one young adult—all published since 2011, represent the range of what's possible in the genre. They're are all excellent choices for your child—whether she loves horses or not, whether she's a she or not.