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The House of Lords Constitution Committee has launched a consultation exercise on the constitutional position of civil servants. More information on this, and a chance to contribute, can be found here, on the Parliament website.
Monthly Archives: April 2012
UKCLG: House of Lords Constitution Committee Call for Evidence.
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Mark Elliott: The Brighton Declaration: where now for the Human Rights Act and the Bill of Rights debate?
The Brighton Declaration, which emerged from last week's High Level Conference on the Future of the European Court of Human Rights, has already attracted a substantial amount of comment—including by Noreen O'Meara on this Blog and Ed Bates on the UK Human Rights Blog. In this post, I revisit some of the arguments I made earlier this year, in the light of a draft of the Declaration that was leaked in February, concerning the possible implications of the Brighton process for the effectiveness of the Human Rights Act 1998 (HRA) and the debate about a UK bill of rights. In this piece, I argue that the final version of the Brighton Declaration—viewed from the perspective of the UK's domestic human rights regime—is less drastic. I go on to suggest that the Brighton process has therefore failed to carve out any significant latitude that might have been exploited by those proponents of a UK bill of rights whose agenda essentially reduces to the weakening of judicial protection of human rights.
The February draft
In my post on the February draft of the Brighton Declaration, I suggested that the relative potency of the HRA is attributable to two key considerations. First, while the Act leaves the legal doctrine of parliamentary sovereignty undisturbed, the Act reduces Parliament's political capacity to exploit that doctrine by legislating in breach of fundamental rights; this the Act achieves by enabling courts publicly to condemn ECHR-inconsistent legislation via the issue of a declaration of incompatibility. Second, the HRA permits international law to disrupt the national legal and political processes by ascribing a notably high profile at the domestic level to the UK's obligations under the European Convention on Human Rights (ECHR).
The February draft of the Declaration would, if implemented, have substantially weakened the HRA system. By diminishing (in ways outlined below) the role of the European Court of Human Rights (ECtHR) as the ultimate judicial authority capable of policing compliance with the ECHR, the Convention would have become a less concrete legal constraint upon the UK. This, in turn, would have undermined the legal weight of domestic courts' judgments under the HRA, because it would have been open to the government—to a far greater extent than before—to argue that such judgments might not reflect the Strasbourg Court's view, safe in the knowledge that the Court, had the February draft been adopted, would have been less likely to have an opportunity to render a decisive judgment on the relevant matter.
What, then, of the final version of the Brighton Declaration? Is the scenario sketched above—a dystopian one for the human rights enthusiast; quite the reverse for the sceptic—likely to eventuate? The answer to that question is "no", because the final version of the Declaration differs significantly from the February draft in three presently-relevant respects.
"Deference" at the Strasbourg level: subsidiarity and the margin of appreciation
First, the February draft set great store by the notion of subsidiarity and the doctrine of margin of appreciation. The same is true of the final version of the Declaration: but the emphasis is rather different. In the latter version, subsidiarity remains a "fundamental principle", and reasons of "transparency and accessibility" are still said to call for explicit reference to it—but in the Preamble to the Convention as opposed to the Convention itself. An instrument to amend the Preamble, such that it refers explicitly to subsidiarity—and to the margin of appreciation—is thus to be adopted by the end of 2013. However, the February draft's characterization of the margin of appreciation as "considerable" is nowhere to be found in the final version of the Declaration. And whereas the February draft said that the Strasbourg Court's role was to "ensure that [national authorities' decisions] are within the margin of appreciation", the final Draft holds that the Court's task is to determine whether such decisions "are compatible with the Convention, having due regard to the State's margin of appreciation". This implies a more marginal, albeit not unimportant, role for the margin of appreciation doctrine: in the final Draft, it is a factor to which the Court ought to have regard when deciding whether a breach of the Convention has occurred, rather than (as in the February draft) the key factor which frames the question ("Has the margin been exceeded?") lying at the core of the Court's adjudicative function.
These aspects of the February and final versions of the Declaration, like the differences between them, are relatively subtle—but they are certainly indicative of the State parties' consensus view of the nature of the ECHR regime and of the Strasbourg Court's place within it. Understood thus, the final Declaration postulates a more significant and central role for the Court than the February draft, and signals that the desire of the UK (and, no doubt, certain other States) to substantially limit the role of the ECtHR has ultimately yielded little. Of course, that conclusion can only be provisional, in that the wording of the revised Premable—and so the nature of the newly explicit textual references to subsidiarity and the margin of appreciation—remain to be seen. It is highly unlikely, however, that the revised Preamble will invest those notions with content that breathes new life into the more radical approach envisaged in the February draft. The upshot, then, is that in cases that reach the Court, its approach is unlikely to be significantly different as a result of the Declaration and the revised Preamble.
A caveat should, however, be entered. While the Brighton process may, viewed from a particular perspective, have "failed", some aspects of the vision revealed in the February draft could conceivably be realized in other ways. Indeed, it is possible that the mere floating of the more far-reaching ideas contained in the February draft (and associated posturing) may have been influential—for example, by inviting what Helen Fenwick has called an "appeasement approach" on the part of the ECtHR. So, while the final text of the Brighton Declaration does not clip Strasbourg's wings in the rather direct and unsubtle ways envisaged in the February draft, the possibility cannot be discounted of the (voluntary) adoption by the ECtHR of a more limited—more "deferential", in domestic parlance—approach. The Declaration necessarily now forms part of the backdrop against which the Court will seek to understand the proper extent of its role, as in due course will the explicit references to subsidiarity and margin of appreciation that are to feature in the revised Preamble. The latter doctrine is traditionally understood as a function of Strasbourg's political and cultural dislocation from individual States parties—and thus as recognition on its part of the limits of its institutional competence. In contrast, while the notion of subsidiarity remains ill-defined in this context, it arguably reflects something of the concerns which, at the domestic level, coalesce around the notion of the judicature's limited constitutional competence. In other words, "subsidiarity" may very well not be a synonym for "margin of appreciation", and its express inclusion in the Preamble will, at the least, invite fresh reflection upon the proper extent of the Court's role.
Pending the text of the revised Preamble—and its absorption into the Court's jurisprudence—further speculation is unwarranted. It suffices to say that while the final version of the Declaration places rather less weight on subsidiarity and margin of appreciation than the February draft, it nevertheless accords them a newly formal prominence. But even if, in the future, greater "deference" is exhibited by Strasbourg, important questions remain about the nature of such deference: in particular, does it invite the ascription of weight, or respect, to the views of domestic courts or to those of national political institutions? If the former, then this might do little to appease State governments troubled by what they perceive to be excessively interventionist domestic courts—and little to diminish the existing capacity of sufficiently interventionist UK courts to uphold fundamental rights in the face of more sceptical political branches.
Advisory jurisdiction: legal and political constitutionalism
Second, the February draft sought to change the means by which some cases reach the Court in the first place, by providing for "advisory opinions" on "point[s] of interpretation". As I argued in my previous post, this approach, if implemented, could have blunted the ECHR as a legal constraint (at least in relation to States that accepted the envisaged optional protocol). This was so because, according to the February text, when a non-binding advisory opinion had been rendered, the right of individual petition would ordinarily have been displaced, meaning that the Strasbourg Court would effectively be denied the opportunity to render a judgment that would be legally binding under Article 46. But here, too, the final version of the Declaration adopts a more subtle approach. In particular, there is no reference to the notion contained in the February draft that the application by a national court of an advisory opinion should normally preclude the subsequent exercise by the person concerned of the right of individual petition (and hence the prospect of a binding judgment adverse to the State party concerned). Granted, the final Declaration does not rule out this possibility—but the removal from the text of any explicit reference to it, coupled with the characterization of the right of individual petition as the "cornerstone" of the Convention regime, suggests that there is no consensus in favour of limiting that right in the way proposed by the February text.
So even if the envisaged draft optional protocol on advisory opinions—which the Declaration invites the Committee of Ministers to produce by the end of 2013—were adopted, this would not in itself erode the Court's capacity to render non-advisory judgments that would be binding upon States in the normal way. Viewed from the perspective of the UK's HRA system, this means (inter alia) that the possibility (which the February draft would have opened up) no longer arises of the UK government disputing a domestic declaration of incompatibility on the ground that Strasbourg might not actually have found national law incompatible with the Convention had the matter reached it other than under the advisory route: use of the advisory route will not now close off the possibility of individual petition. This, in turn, preserves the capacity of the ECtHR to inject legal force into a national human rights regime that remains ultimately wedded—in the sense that it acknowledges the authority of the UK Parliament to transgress Convention norms as a matter of strict domestic law—to the tradition of political constitutionalism.
Admissibility: the relationship between domestic courts and Strasbourg
Third, the February text proposed that Article 35 be amended "to make clear that" an application is inadmissible "if it is the same in substance as a matter that has been examined by a national court taking into account the rights guaranteed by the Convention", unless the national court has "seriously erred" or the case raises a "serious question" concerning the interpretation or application of the Convention rights.
The relevant part of the final version of the Declaration differs in three key respects. First, no amendment to Article 35 is contemplated; rather, the Court is "encourage[d] to have regard to the need to take a strict and consistent approach" in this sphere, "clarifying its case law … as necessary". Second, the final version affirms that an application should be regarded as manifestly ill-founded to the extent that it raises a complaint that has been "duly considered" by a national court "applying" the Convention in the light of "well-established" ECtHR case law—a formulation that draws the category of prima facie inadmissible applications more narrowly than the February text. Third, there is no reference to national courts having "seriously erred" as a trigger for treating as admissible an application relating to a matter already considered at the domestic level.
While the latter feature of the final Declaration appears to make it more restrictive than the February draft (in that a potential trigger is omitted), the broader message is clearly that consideration of a matter at the national level will less readily exempt it from consideration in Strasbourg. Against that background, a "serious error" trigger would be as unnecessary as it would be misleading—the point being that the final version of the Declaration rightly envisages a role for the ECtHR which transcends putting right domestic courts that have "seriously erred" in their application of the Convention.
The Human Rights Act
All of this suggests that the Brighton Declaration's implication for the UK's domestic human rights regime are decidedly modest. Nothing in the final version of the Declaration—in contrast to the February draft—significantly diminishes the effectiveness of the HRA as a real constraint upon not only administrative and other legislative bodies but the UK Parliament itself. Ostensible fidelity to the orthodoxy of parliamentary sovereignty notwithstanding, the HRA domesticates the Convention norms that bind the UK under international law in a manner that renders largely theoretical the possibility of lawfully transgressing them as a matter of domestic law. As noted at the outset of this post—and in more detail in my previous post on this topic—the HRA achieves this by puncturing both the dualist distinction between domestic and international law and the Diceyan division between legal and political modes of constitutionalism.
But as a model that is necessarily grafted onto the ECHR, the HRA's success is ultimately contingent upon the nature of the Convention scheme to which it gives effect at the national level. The February draft of the Brighton Declaration would have altered that scheme significantly: by diminishing the role of the Strasbourg Court, it would have reduced the juridical bite of what appears at first glance (given the absence of any strike-down power) to be an ultimately supine domestic human rights system. Such a characterization of the UK system is, of course, wide of the mark. But that is, in large part, precisely because behind a British judicature lacking constitutional authority to invalidate rights-incompatible legislation stands an international tribunal willing and able to render judgments that are binding upon the UK as a matter of international law. And, importantly, such judgments are likely anticipated by national judicial decisions under the HRA that Parliament is free to ignore only when the matter is viewed through the parochial lens of purely domestic legal theory. By avoiding the substantial curbs upon the ECtHR's role contemplated by the February draft, the final version of the Brighton Declaration thus preserves the essential characteristics of the Convention regime that underpin the HRA's potency.
The bill of rights debate
Finally, what of the debate concerning a UK bill of rights? In a post on this Blog published in 2011, I observed that the terms of reference of the Commission on a UK Bill of Rights reveal a curious paradox. Much of the political rhetoric preceding the establishment of the Commission anticipated that a Bill of Rights would enable, or require, British courts to strike a different balance between individual rights and conflicting public interests—perhaps in order to head-off further bouts of Prime Ministerial nausea such as that which was induced by the prospect of permitting some prisoners to vote. Yet, thanks no doubt to the constraints of coalition, the Commission is in fact required to "investigate the creation of a UK Bill of Rights that incorporates and builds on all our obligations under the European Convention on Human Rights, ensures that these rights continue to be enshrined in UK law, and protects and extend our liberties".
An obvious tension arises between, on the one hand, a Bill of Rights Commission committed through its terms of reference to an ECHR-plus (or at least not an ECHR-minus) model and, on the other hand, politicians' promises that a UK bill of rights would "mak[e] sure decisions are made in this Parliament rather than in the courts". One way of resolving that tension, of course, would be to adjust the obligations deriving from the ECHR in the first place, so as to render it (from a pejorative perspective) less of a straightjacket. Brighton was the government's attempt to do precisely that: not by explicitly amending the provisions defining the Convention rights, but by loosening Strasbourg's grip on policing their interpretation and application. Doing so, it was presumably anticipated, would in turn have rendered domestic courts' human rights judgments more contestable, as it would follow with less certainty than at present that Strasbourg would concretely endorse them—whether because the case would never reach the ECtHR (owing to narrower admissibility criteria), or because it would render only a non-binding advisory opinion, or because a generous margin of appreciation (or doctrine of subsidiary) would cause it to stay its hand. However, for the reasons set out above, these objectives are not actually realized by the Brighton Declaration.
The result is that the Brighton process has not created the sort of latitude that might have been exploited by those in favour of a bill of rights that takes a looser form than the HRA: it does not offer an escape route from the constraints which derive from the realpolitik of coalition and the Bill of Rights Commission's resulting terms of reference. Political rhetoric that (perhaps paradoxically) postulates a bill of rights as a vehicle for creeping dejuridification and the elevation of the interests of the "law-abiding majority" is therefore—at least for the time being—as empty as it is misleading.
Mark Elliott is a Senior Lecturer in Law at the University of Cambridge.
Filed under Constitutional reform, England, Human rights
Noreen O'Meara: Brighton rocked! Next steps for reforming the European Court of Human Rights
A blaze of controversy erupted over the disputed timing of Abu Qatada's referral request to the Grand Chamber of the European Court of Human Rights this week. Whilst raising a juicy legal question for proceduralists (examined incisively here and here) the inevitable media hysteria coincided with efforts to reform aspects of the Strasbourg court and the publication of fresh research on the UK-ECHR relationship. The contrast of the media frenzy with the relatively low-key (by international standards) Council of Europe Ministerial Conference in Brighton was stark. However, the resulting Brighton Declaration, formally agreed on 20 April 2012, may inject some measured logic into an often misinformed debate on the role and working practices of the European Court of Human Rights.
Lively legal debate was generated in the lead-up to the Brighton Conference despite limited leaked information on the successive draft Declarations. NGOs shared a broad platform issuing two Joint Statements against more extreme proposals apparently seeking to curb access to the court. Prior to the Conference, evidence from the Court itself seemed to share this cautious approach; its openness to considering (previously mooted) initiatives, such as extending advisory jurisdiction, tempered by calls not to rush any reforms—to allow more time for recent measures introduced via Protocol 14 to the Convention to embed in the Strasbourg system, and to assess their mid/long-term impact on the Court's docket. While Brighton represents the latest in a series of efforts to reform the Court—most recently in snowier/sunnier climes (Interlaken (2010) and Izmir (2011))—the UK government's motivations for reform during its current chairmanship of the Council of Europe were expressed in terms which promised something altogether more radical.
On any reading of the final text, it is clear that the reforms in the Declaration have been substantially toned down (see initial overviews from Joshua Rozenberg and Antoine Buyse). While the Brighton Declaration may have made just enough changes to allow the UK to claim some kind of political success, the reality is that the changes are—for the moment— marginal. Will the Declaration deliver anything meaningful in tackling the Court's voluminous caseload? There is far more in the Declaration than a short piece can handle. The impact (if any…) of adding references to subsidiarity and margin of appreciation to the Convention's preamble will be ripe for discussion on the blogs and in the courtroom. The comments below focus on select procedural issues.
Time-limit to apply to the ECtHR
The Conference agreed that the time-limit to apply to the Strasbourg court under Article 35(1) ECHR should be reduced by one-third, from six months to four. On paper, this was the most likely of the tabled reforms to be agreed. The proposal to reduce the time-limit in the original draft Declaration was lifted directly from the Court's Preliminary Opinion, which had suggested a reduction to two/three/four months. It will relieve many that the Conference chose to minimise the extent of the reduction. However, critics of any change to Article 35(1) ECHR may argue that reducing the time-limit could lead to a greater number of knee-jerk applications, more poorly drafted/advised applications, or applications made without legal advice. This change may well risk prejudicing applicants with genuine claims from mounting well-reasoned applications. These risks may be real (and merit research) but unless a spike in applications or tangible evidence of such increased prejudice to applicants becomes apparent, it will be difficult to measure any impact of a reduced time-limit to apply.
Reformed admissibility criteria proposed in an early draft were a key concern to both the Court and NGOs. The Brighton Declaration preserves the essential criteria, with the most criticised docket-control element dropped. The proposal that applications should be rendered inadmissible unless a national court "erred" in interpreting Convention rights (para 23c of the earliest public Draft) has been abandoned. The Declaration's affirmation in para 15d that the Court should adopt "a strict and consistent approach" in rendering applications inadmissible under Article 35(3)(a) ECHR (inter alia) unless a "serious question concerning the interpretation or application of the Convention" is raised marks nothing new. The track changes on a subsequent pre-Brighton Draft suggest this point particularly exercised the drafters, but the end result seems to be nothing more than a gloss on the existing admissibility criteria, and one which will not trouble the Court—which rightly remains firmly in control. However, an amendment to Article 35(3)(b) ECHR (removing the words "and provided that no case may be rejected on this ground which has not been duly considered by a domestic tribunal") was agreed by the Conference. This would rectify what some regard as an anomaly with the "significant disadvantage" test introduced by Protocol 14 ECHR.
Some parts of the Brighton Declaration provide the kind of praise for the Court which has been in scant supply recently. The Strasbourg court's "extraordinary contribution" to the protection of human rights in Europe (para 2) is noted, with the impact of admissibility measures taken in the context of Protocol 14 is described as "encouraging" (para 6), the Declaration noting "with appreciation" the Court's objective to dispose of the clearly inadmissible applications pending before it by 2015 (para 20b). This recalls the Court's observations in its Preliminary Opinion and emphasised by President Bratza in evidence to the Joint Committee of Human Rights that a range of measures taken by the Court have already begun to alleviate its backlog, and that further measures should help accelerate this process in the near future (for example, greater use of the "significant disadvantage" criterion, greater scope for the use of single judges).
The irony of multiple references to greater transparency and clearer communication of court procedures, admissibility criteria and time-limits may not be lost on Home Office lawyers awaiting the ECtHR's decision on Abu Qatada's referral request. In calling for "stricter application" of the time limit in Article 35(1) ECHR and reiterating "the importance of the Court applying fully, consistently and foreseeably all the admissibility criteria including the rules governing the scope of its jurisdiction", para 15b of the Brighton Declaration alludes to the fractious debate on subsidiarity behind the drafting process. Yet in welcoming "the increased provision by the Court of information to applicants on its procedures and particularly on admissibility criteria" (para 15e) the Declaration identifies a significant issue. The Court must ensure that its procedural rules and criteria are clearly drafted and publicized; the Declaration's bid to reduce the time-limit for admissibility makes this all the more important. In the slightly different Abu Qatada context of referral to the Grand Chamber, lawyers, academics and commentators have been split on the deadline issue. There is no need for this level of confusion.
Advisory jurisdiction
One of the most interesting (if very loosely drafted) proposals survived the original draft and may yet introduce a new dynamic in relations between national courts and the ECtHR. The possibility of extending the ECtHR's rarely invoked advisory jurisdiction to enable highest national courts to seek 'advisory opinions' from the Court (in a manner somewhat similar to the preliminary reference mechanism in the EU legal context) managed to elicit fairly broad support. Though this proposal is not new, it does appear to have gained momentum in the recent negotiations.
As framed in the original draft Declaration, the UK spin on the advisory opinion proposals seemed closely aligned to its approach to subsidiarity which underscored the negotiations (the proposed non-binding character of advisory opinions, and their proposed effect of preventing further recourse to the ECtHR in the same proceedings are clues in para 19d of the original Draft). Before the Brighton Conference, the ECtHR duly published a reflection paper on the possibility of extending advisory jurisdiction. Its paper sees the potential value of an advisory opinion mechanism in deepening the dialogue (curiously dubbed "institutionalised dialogue", para 4) between national courts and the Strasbourg court. Use of the word "institutionalised" perhaps implying that such dialogue may influence relations on a wider level than simply between courts. Unsurprisingly, the UK-led view that use of the mechanism should prevent exercise of the right to individual petition in the same proceedings was lanced (para 24, reflection paper). Although the Brighton Declaration is now silent on this particular point, it is surely unthinkable that an advisory opinion mechanism will be introduced on a basis which restricts the right to individual petition.
The Court effectively agreed to make the advisory opinion mechanism as optional as possible (introduction via an Optional Protocol to the Convention; restricted to highest national courts; limited rights of intervention for third parties) and saw the possible long-term impact which an advisory opinion mechanism may have on the Court's docket. However, there are clearly differences of opinion as to its merits both among High Contracting Parties to the Convention and at the level of the Court (the reflection paper notes differing views on whether such opinions should be binding, para 24). Critics would also be justified in being skeptical as to whether the Grand Chamber will have the capacity in the short-medium term to handle the greater workload which the advisory opinion mechanism would clearly generate. There is clearly still much to consider: as para 12d of the Brighton Declaration invites the Committee of Ministers to draft an Optional Protocol for a (very much optional) advisory opinion mechanism, its merits will be much debated in the foreseeable future.
No magic bullet
One lesson which can be drawn from the process of concluding the Brighton Declaration is that it was never going to magic away either the Court's docket or its essential, authoritative role in human rights adjudication. The hype (in some quarters, hostility) surrounding the negotiation process has not gone unnoticed at the Court. However, the revised set of proposals in the Brighton Declaration seems to have largely neutralised the more political features of earlier draft versions.
A striking feature of the Declaration, which moves it away from the politicised aspects of the subsidiarity debate, is the prominence of concrete, pragmatic steps which should be taken to enforce the Convention at national level (Section A). It is no secret that the Court's backlog is dominated by applications from small minority of jurisdictions. It is therefore no surprise that the Declaration views the role of the Council of Europe as "crucial" in supporting implementation of the Convention, and in its wider role promoting human rights, democracy and the rule of law. This is something which the Council of Europe probably under-promotes, and which would merit being better understood. Efforts to alleviate the Court's backlog may start in Strasbourg, but its authority, legitimacy, and its success in tackling it also depend on developments much closer to home.
Noreen O'Meara – Lecturer in Law, University of Surrey; Doctoral researcher, Queen Mary, University of London
Filed under Constitutional reform, Human rights
UKCLG: Happy Easter
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Helen Fenwick: An appeasement approach in the European Court of Human Rights?
This piece asks whether, in the light of UK proposals for the reform of the ECtHR, and in the wake of the outcry in the UK over the Qatada decision (Othman v UK), the Court is taking an approach that looks like one of appeasement of certain signatory states. Two very recent decisions will be looked at which, it will be argued, contain appeasement elements. Each can be compared with a previous counter-part decision against the same member state which adopts a more activist approach; and each is not immediately obviously reconciliable with the previous decision. Is the Court revisiting the 'true' scope of the ECHR in a more deferential spirit?
British proposals for reform of the Strasbourg Court
This is not the place to discuss the proposals for reform of the ECtHR in detail and most readers will be aware of their general drift in any event. The idea of 'greater subsidiarity' has been raised at various levels, and accorded various meanings in advance of the imminent High Level Conference at Brighton on the future of the Court. The reform process began in 2010 with the Interlaken and Izmir declarations. Members of the Bill of Rights Commission, which has a second brief regarding its advisory role on reform of the Strasbourg court, linked to British chairmanship of the Council of Europe, take the view that both declarations reflect a desire for greater subsidiarity. Anthony Speaight, Commission member, has indicated that it will look into the question of creating an enhanced margin of appreciation, allowing for greater subsidiarity, on the basis that that would be in accordance with the Interlaken and Izmir Declarations since "one finds in each of them a statement of wish and aspiration for greater subsidiarity". When the Commission provided its interim advice to Ministers on Strasbourg reform in 2011, it accompanied it by a letter which raised the perception of some, either expressed to the Commission or of some Commission members, that the Court is at times "too interventionist in matters that are more appropriate for national legislatures or courts to decide". Areas that the Commission has stated it is inquiring into are those of including a democratic override in the ECHR along the lines of s33 of the Canadian Charter and that of introducing 'subsidiarity reviews' by analogy with the EU treaty, on the basis of according a power to the Committee of Ministers to resolve that a judgment should not be enforced if it infringed the principle of subsidiarity. The Commission Chair said in the letter that that "would arguably reflect the Izmir Declaration".
The government's plans for reform of the Strasbourg Court have been extensively trailed in the run up to the Brighton Conference in April 2012. It was stated in 2011 (according to Parliamentary written answers and statements, 18th March 2011) that the government would use the Chairmanship to press for placing the primary responsibility for protecting the ECHR rights on states, rather than the Court. Intervening in Scoppola v Italy No. 3, Grieve made a further statement indicative of this plan for reform of the Court. He said that a number of states have restrictions or complete prohibitions on prisoners voting, and "this is, and should be, a political question – by which I mean a question for democratically elected representatives to resolve, against the background of [their state's] circumstances and political culture". He considered that acknowledging the doctrine of the margin of appreciation in that way would result in the EtCHR intervening only when "the decision of the national authorities is manifestly without reasonable foundation".
David Cameron's speech to the Parliamentary Assembly of the Council of Europe in 2012, during the UK's six month chairmanship of the Council, reiterated the theme of seeking enhanced subsidiarity as a key reform. He referenced terrorism and prisoners' voting rights as examples of issues on which the Court should be very slow to intervene, once democratic debate on the issue and full scrutiny in national courts, taking the Convention into account, had occurred. Referencing the 2012 Qatada case (above), as illustrating the need for reform, he said "we have gone through all reasonable national processes…including painstaking international agreements about how they should be treated …and scrutiny by our own courts…and yet we are still unable to deport [or detain] them". The members of the assembly voted unanimously to agree that the court should be "subsidiary" to national authorities – governments, courts and parliaments – in guaranteeing human rights. Clearly, the effect of that decision will depend on the precise reforms agreed upon at Brighton. A draft declaration for that conference was 'leaked' on 23 Feb 2012, and published in various forums. It focuses on the grave problem of the back-log of cases facing the Court and makes proposals intended to create greater acceptance of the ECHR at national level, to allow the Court to focus on the more significant claims, and to avoid it being faced by persistent claims that should be dealt with at national level. But among laudable proposals for dealing with the back-log, it includes the following – at para 19(a): "The conference therefore welcomes the development of the Court within its case-law of principles such as subsidiarity and the margin of appreciation doctrine…and encourages the Court to give great prominence to these principles in its judgements; (b) Concludes that the transparency and accessibility of the principles of the margin of appreciation and subsidiarity should be enhanced by their express inclusion in the Convention, and invites the Committee of Ministers to adopt the necessary amending instrument within one year". Para 23(b) on options for amending the admissibility criteria proposes that an application should be declared inadmissible if it is the same in substance as a matter that has already been determined by the national courts unless the Court considers that the national court "clearly erred in its application or interpretation of the Convention rights or the application clearly raises a serious question concerning the application and interpretation of the Convention".
Austin v UK and Von Hannover v Germany (No 2)
It is in this context that the cases of Austin v UK and Von Hannover (No 2) are considered, in order to argue that certain of the proposals currently being put forward are echoed in dominant themes within the judgments.
The decision in the House of Lords in Austin v The Commissioner of the Police of the Metropolis, finding that 'kettling' peaceful protesters and bystanders for 7 hours did not create a deprivation of liberty, has been heavily criticised; it was expected that the ECtHR would take a different stance. In the House of Lords, the key question was whether such entrapment of persons via 'kettling' amounted to a deprivation of liberty under Article 5(1). Lord Hope considered that in making a determination as to the ambit of Article 5(1), the purpose of the interference with liberty could be viewed as relevant; if so, he found that it must be to enable a balance to be struck between what the restriction sought to achieve and the interests of the individual (at para. 27). Having found that purpose was relevant to the ambit given to Article 5(1), Lord Hope found that the purpose must take account of the rights of the individual as well as the interests of the community, and therefore any steps taken must be resorted to in good faith, and must be proportionate to the situation which made the measures necessary. If these requirements were met, however, he concluded that it would be proper to find that measures of crowd control that are undertaken in the interests of the community will not infringe the Article 5 rights of individual members of the crowd whose freedom of movement is restricted by them if the measures are proportionate to the aim pursued (at para. 34).
When this decision was challenged at Strasbourg (Austin v UK (2012)), the Grand Chamber took a stance towards the deprivation of liberty question which was very similar to that taken by the House of Lords, finding: "the context in which action is taken is an important factor to be taken into account, since situations commonly occur in modern society where the public may be called on to endure restrictions on freedom of movement or liberty in the interests of the common good….The Court does not consider that such commonly occurring restrictions on movement, so long as they are rendered unavoidable as a result of circumstances beyond the control of the authorities and are necessary to avert a real risk of serious injury or damage, and are kept to the minimum required for that purpose, can properly be described as "deprivations of liberty" within the meaning of Article 5(1)" (at para. 59).
Applying these findings, and affirming that "subsidiarity is at the very basis of the Convention, stemming as it does from a joint reading of Articles 1 and 19" (at para. 61), the Court went on to find that in accordance with the Engel (Engel v Netherlands (1976)) criteria (for determining when a deprivation of liberty occurs), the coercive nature of the containment within the cordon, its duration, and its effect on the applicants, in terms of physical discomfort and inability to leave Oxford Circus, pointed towards a deprivation of liberty. However, the Court found that, relying on the context of imposition of the 'kettle', the purpose of its imposition must be taken into account – to "isolate and contain a large crowd, in volatile and dangerous conditions". The Court found no reason to depart from the findings of fact of the first instance judge as to the dangerousness of the situation. Although the Court did not refer expressly to proportionality, it clearly adverted to that concept in finding that the measure taken appeared to be the "least intrusive and most effective means to be applied" (at para. 66). On that basis no deprivation of liberty was found, meaning that it was not necessary to consider the exceptions to Article 5. Thus, in essentials, the Grand Chamber's judgment did not differ from that of the House of Lords.
A strong joint dissenting opinion trenchantly criticised the findings of the majority on the basis that its position could be interpreted as "implying that if it is necessary to impose a coercive and restrictive measure for a legitimate public-interest purpose, the measure does not amount to a deprivation of liberty. This is a new proposition which is eminently questionable and objectionable…". It was found to be objectionable since if in the public order context liberty-depriving measures were deemed to lie outside Article 5 if claimed to be necessary for any legitimate/public-interest purpose, "States would be able to "circumvent the guarantees laid down in Article 5 and detain people for a whole range of reasons going beyond the provisions of Article 5(1) (a) to (f), as long as they could show that the measure was necessary". They pointed out that in A and Others v the United Kingdom (2009), the Court refused to accept the Government's argument that Article 5(1) allows a balance to be struck between the individual's right to liberty and the State's interest in protecting its population from terrorist threat, finding: "If detention does not fit within the confines of the paragraphs [Art 5(1) (a)-(f)] as interpreted by the Court, it cannot be made to fit by an appeal to the need to balance the interests of the State against those of the detainee" (at para. 171).
The decision in Austin can indeed be critiqued, as in the joint dissenting opinion, on the basis that it in effect creates a new, very broad, exception to Article 5, while purporting to avoid doing so by relating the public interest argument to the issue of ambit. Given that the Court relied on "context" to determine the application of Article 5, and given the need to interpret the ECHR as a whole, the fact that the protesters were seeking to exercise Art 10 and 11 rights, could have been viewed as creating differentiation between the crowd control situations mentioned by the court and the context of protest: the Grand Chamber considered the public order context but not – as a determining factor – the public protest one. A new amendment to Article 5 may be needed to clarify this position, but in the meantime the creation in effect of an exception to Article 5 on broad public interest grounds, represents a worrying trend.
The Grand Chamber reiterated, on the basis of a principle of subsidiarity, that it should only interfere in a domestic decision as to facts on very cogent grounds. But it is suggested that impliedly it went further: it applied the principle of subsidiarity not to the findings of fact only, but to the interpretation of Art 5(1). The House of Lords had found that public interest considerations were relevant to ambit, subject to a test of proportionality. The Grand Chamber, as the joint dissenting opinion pointed out, accepted that analysis in effect – though without overtly referring to proportionality – despite the fact that it ran counter to the findings in A v UK on the interpretation of Art 5(1). The result was consistent with the proposition that the Grand Chamber came very close to accepting that it would require very compelling reasons to depart from the decision of a superior national court that had applied the Convention, taking a particular view of its interpretation, to a set of facts – even where that court could not point to ECHR jurisprudence bearing closely on the matter before it. That stance would be in accordance with both para 19(b) and 23(b) of the leaked Brighton declaration. Obviously 23(b) refers to admissibility, not substance, but para 23(b) in effect demands subsidiarity not merely in relation to fact-finding, but also in relation to interpretation of the Convention.
There is a wider message to be drawn from this narrow approach to the right to liberty which, it is argued, was lost in the pursuit of subsidiarity. In an age of Anti-Social Behaviour Orders, Serious Crime Prevention Orders, and of a range of state powers that interfere with liberty in the contexts of both counterterrorism[1] and public protest, the question whether a "deprivation of liberty" refers to literal physical restraint as in prison, or to something much more amorphous, is of especial importance, and resonates far beyond the public protest context. The varied ways of interfering with liberty now available to the state, render the traditional idea of focusing on physical restraint outdated (this point is touched on in H Fenwick and G Phillipson McGill Law Journal 56(4): 864-918 at 889-890). Had the police arrested the 4 applicants in Austin and detained them for 7 hours, rather than kettling them, there would have been no question as to whether Article 5 applied – the only issue would have been as to the applicability of the exception under Art 5(1)(c). Thus the Court has impliedly accepted that if a non-paradigm case of interference with liberty arises, but there appears to be a pressing need to employ the measure in question on public interest grounds, the "deprivation of liberty" concept should receive a narrow interpretation, placing the measure outside it, even if the Engels criteria appear to apply.
If Austin v UK appeared to rely on an enhanced principle of subsidiarity, Von Hannover v. Germany (no. 2) (2012), also in the Grand Chamber relied, it appeared, on an enhanced application of the margin of appreciation principle (arguably reflecting para 19(a) of the draft Brighton declaration), this time in the context of a clash between protection for private life and for freedom of expression. Relying on the Court's 2004 Von Hannover judgment, in the first applicant's case, the applicants had subsequently brought several sets of proceedings in the civil courts in Germany seeking an injunction against any further publication of photos that had appeared in German magazines. They did not obtain relief, however, in relation to an article, partly about the Prince's illness, accompanying photos of the applicants' skiing holiday, nor in relation to the photos themselves.
The Grand Chamber noted that after the 2004 Von Hannover decision, the German courts had altered their approach and had sought to balance Articles 10 and 8 against each other in accordance with the Strasbourg stance. The Court accepted that the photos and article fell within the concept of private life under Article 8(1). Thus Articles 8 and 10 had to be balanced against each other. However, the Court found that where the balancing exercise has been undertaken by the national authorities in conformity with the criteria laid down in the Court's case-law, the Court would require strong reasons to substitute its view for that of the domestic courts (relying on MGN Limited v. the United Kingdom, no. 39401/04, at [150] and [155]). Although the photos were of the applicants on a skiing holiday, the national courts found that they could be linked to and supportive of the article, which did concern a matter of public interest – the Prince's illness. The Grand Chamber accepted this finding, even though the pictures made little or no contribution to the matter of the illness.
This decision re-confirmed that Articles 8 and 10 are of equal value. But, under the margin of appreciation doctrine, it made it clear that the Court will require "strong reasons" to substitute its view for that of the domestic courts where a balancing exercise between Article 10 and 8 has been undertaken at the domestic level. The Court appears to be contemplating an expanded version of that doctrine, one under which the role of its own assessment of the extent to which paparazzi photos are deemed of value in Article 10 terms is marginalised. The acceptance that the photos in question added something to the article was clearly open to question. The photos were of the same nature as those at stake in the 2004 Von Hannover case which were found to contribute virtually nothing to any significant debate as to public affairs.
The danger may arise that a balancing exercise between Arts 8 and 10 may be apparently carried out domestically, but in a tokenistic manner, allowing flimsy public interest arguments to prevail. In other words, the arguments may be rehearsed by courts without any real attempt to probe the values at stake on either side. The argument accepted by the Court in Axel Springer v. Germany (2012) that since the actor applicant had been arrested and had also played a police officer, the public's interest in knowing of his arrest was increased, could be applied in broad brush manner domestically, as could the argument that his expectation that his private life would be protected had been reduced since he had placed details of his private life in the public domain.
The suggestion of this piece is that the cases considered may be indicative of a very recent reversal of certain trends in the reasoning of the Court, and may be intended to deflect the criticism that the Court has been too interventionist. The Court in highlighting the role of the margin of appreciation and the principle of subsidiarity in these cases may be seeking to demonstrate that it is receptive to 'reform', and softening towards it, rather than being coerced into it. Under the banners of "margin of appreciation" and "subsidiarity" – without creating clear differentiation between those terms – both cases rely on deferring to the nationally created balance between public interest and individual liberty on the one hand, and between two competing rights on the other. The current debate on reform of the Convention system must consider how far pursuit of enhanced subsidiarity can and should represent a welcome attempt to constitutionalise the Convention more fully at national level without relinquishing its role as a means of delivering individual justice, with consequent changes at that level. That debate might also usefully consider the reality behind the desire for reform of senior Conservatives. How far does that desire relate to seeking to create greater respect for the Convention across all member states at national constitutional level, and greater convergence in terms of respecting Convention standards, to reduce the pressure on the Court? In reality, is the key concern to return autonomy in human rights matters to the Westminster Parliament by reducing the likelihood of Strasbourg intervention?
Helen Fenwick is Professor of Law at The University of Durham.
[1] Eg the new stop and search power not dependent on reasonable suspicion under Part 4 clause 61 of the Protection of Freedoms Bill 2011 (currently the Terrorism Act 2000 (Remedial) Order 2011 introduced, on an interim basis, replacement counter-terrorism stop and search powers, exercisable without reasonable suspicion), and powers under TPIMs, replacing control orders.
Filed under Constitutional reform, Human rights
UKCLG meeting: The referendum in the United Kingdom, 21 May 2012, 6 pm
UK Constitutional Law Group's next meeting is on
"The Referendum in the United Kingdom"
(The 7th Italian-British Constitutional Conversation)
Monday 21 May 2012, 6 pm
Italian Cultural Institute of London, 39 Belgrave Square, London SW1X 8NX
Foreword: Alessandro TORRE , Chairman of the Devolution Club
Chair: Brendan DONNELLY, Director of the Federal Trust
Speaker: Dennis KAVANAGH, University of Liverpool
Discussant: Peter LEYLAND, London Metropolitan University
The event is organised by the Italian Cultural Institute of London, the Devolution Club, the UK Constitutional Law Group, the Federal Trust, London Metropolitan University, and the Center for Constitutional Studies and Democratic Development.
* Note from Sebastian Payne and Andrew Le Sueur (co-convenors): supporters of the UK Constitutional Law Group who have not already paid their 2012 subscriptions are encouraged to do so. The £15 sub may either be paid through the new online payments system or cheques may be sent to the Group's honorary treasurer: Professor Dawn Oliver, UCL Faculty of Laws, Bentham House, Endsleigh Gardens, London WC1H 0EG (including your name and address).
Filed under Constitutional reform, Devolution, Events


text:
The Madeleine Brand Show for August 6, 2012
Richmond's proposed soda tax will go to voters
Joe Raedle/Getty Images
When New York Mayor Michael Bloomberg proposed a ban on super-sized sodas and sugary drinks, he touched off a debate on government's role in preventing obesity. That same debate is now taking place in one California city that will ask voters to raise the tax on sugar-sweetened drinks. Reporter Mina Kim has more.

subset: commoncrawl


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JUDDD and exercise?
I have a question. I was thinking that if I was going to exercise that I should on UD but yesterday came and it was Thursday Zumba night and a DD. So I went to Zumba but was worried about passing out since all I had so far that day was a fiber one bar hours earlier so I drank a shake on the way. Then had a 3oz steak when I got home. I was over 500 by 70 calories then. I wasn't sure if I would really need the shake or not. I wasn't starving when I drank it. Should I just have tried to go with out it?
What do you do on DD exercise days? Any suggestions, input or tips would be appreciated. :).
In my book u did correctly.
Very smart to do.
Awesome only 570 dd and gym, gosh I'm jealous. Tease. Good job!
I exercise on both DD and UD. I save cardio workouts (machines, classes etc) for UD so that I can have more energy.
And I do strength training workouts or yoga/pilates on DD.
I say if you have the energy to have a workout on DD, go for it!!! Plus it gets you out of your house and busy.
Definitely listen to your body on this one :)
I do cardio on DD to keep my body temp. warmed up, because I get so unbearably freezing cold. On UD, I do resistance training since I have more strength & energy from the additional calories/carbs. :)
There's been a lot of good research regarding fasted workouts. I do Zumba on UDs and DDs and don't really notice much difference. I often burn more in my Zumba class than I take in, leading to negative net calories. My Zumba classes are from 7:30 - 8:30 p.m., so I've generally been up since 4:30 a.m. and only eaten 400 or so calories.
Thanks. :)
I am more inclined to exercise on DD than UD even though what I can do is limited due to spine issues.
For me, cardio on DDs is a crapshoot. I've had DDs where an hour of elliptical was great, and DDs where a half hour walk was torture. There's no rhyme or reason to it that I can discern.
Mostly what I'm doing for exercise these days is Callanetics, which I can do up or down, as it's not nearly the energy expenditure of cardio, and walking outside when weather permits.
The ladies at work are trying to put together a Zumba class and I have been reluctant to join. For one thing, it costs money, and for another I feel like if I do strength training and low impact cardio (like walking) it will benefit me more while I'm in weight-loss mode. I know that I used to do high impact cardio regularly and could not lose weight (although I was not overly overweight at the time), and since I have so far to go (weight wise), I want to keep it simple. :)
Librarygirl- I know what you mean about keeping things simple for weight loss. It does add in another variable with more exercise.
Happy2be- I think it gets a bit easier when I keep a regular routine. Then I can see how what I am doing is affecting my weight loss, and appetite. I find the morning of a DD to be the time I have the best energy. It does make me hungrier either later in the day or sometimes as late as the next morning if it is a long or very intense workout. The morning after a DD I have to make sure I take it easy but not always. I find I need to eat at least two hours before I work out or I can feel tired and weak. I will use about half of my exercise calories to either add in some food the night before a tough workout or to help with my appetite after a long workout. This works better for me than going up to a higher exercise calorie %. I think it stalls my weight loss unless I am doing over an hour of exercise everyday, which I rarely do. For short hour long workouts I don't need to add any extra calories anymore. I think over time your body kind of gets used to it and you get used to dialling into how you are doing. If I am following weight loss % calories I modify my exercise so that I feel comfortable as my main priority is weight loss. I do believe that everyone is different but these are some of the things that I have found worked for me. I am sure others have found different things work for them as there are definitely differences. I hope you find what works for you! Sounds like you made good choices.
Honestly I have a really difficult time losing weight when I am overdoing the exercise. I just get really hungry.
Thanks Luna! This is a picture taken this last weekend after I finished a half-marathon followed by a full marathon the following day. Thanks again for being such an inspiration for me. I still start my days thinking is this a day I need lots of low cal volume food or do I need to save my cals for higher cal food. I also love how you have embraced change!:heart:
I seem to have more energy on DD so I do cardio then and its always without any calories since I don't eat until night on DD. I feel I need the calories/fat to weight train so I do that on UD. It's been working well so far for me.
Thanks for all the great responses. I'm trying to get into a good workout routine.
Babs I love your new avi! Congrats on all the running!
I'm so glad that comment helped you! It's good to be reminded of it myself, since I was in maintenance and not counting I had kind of let that concept go by the wayside a little.
Now that I'm back in weight loss mode and want to shift a few more pounds, I can use the reminder.
Babs...Your avi is beautiful. You look gorgeous and "FIT"......envy alert!!!:cool:
I go hard on p90x and pole workouts daily and I have no problem with keeping my energy or blood sugar stable on DD which are full on fasting days and actually for my weight lifting days I feel better when I am fasting. This is what works for me, if you ever feel like you will pass out don't ignore it the shake was a good idea imo if I ever felt ill I would listen to my body.
|All times are GMT -7. The time now is 03:26 PM.


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Chris and Gina Leonard opened the doors of their photography studio at Yosemite and Lincoln avenues in downtown to members of the Manteca business community for their weekly chamber of commerce coffee.
Robert Iniquez has very little experience in organizing weight-loss contests.
RIPON – He arrived with a product line drawing global attention, turning Powerplay Sports Arena into a place of interest in markets in Canada and Asia.
RIPON – Daniella Arteaga describes the taste of a fingerling potato as "buttery."
Most fashion stores don't open at 7 a.m.
Forget tri-tip and chicken.
Brian Cole was still relatively new to the world of pharmacology when he approached the owner of Bob's Pharmacy to inquire about buying the business.
City workers assigned to a job in an empty field in the 700 block of North Grant Avenue Thursday morning watched as a thief jumped into their white, Sierra GMC 3500 pickup truck and drive it away.The white truck with a city seal on its doors, a black lumber rack and a diamond tool box in the bed was reported missing about 10:30 a.m. Police are looking for the vehicle with a license number of 024886.
The business community can find out if they can qualify for tax credits of up to $37,400 per qualified employee they hire during a Manteca Business Summit being conducted Tuesday, March 19, from 8 to 10 a.m. at the Civic Center council chambers, 1001 W. Center St.
STOCKTON - Premier Community Credit Union has introduced financial services designed specifically for small businesses in San Joaquin County.
OAKDALE − Oak Valley Bancorp, the bank holding company for Oak Valley Community Bank and Eastern Sierra Community Bank, is announcing that Ronald C. Martin has communicated to the Boards of Directors of Oak Valley Bancorp and Oak Valley Community Bank his decision to retire as Chief Executive Officer of each entity on June 18.
TRACY - Emeritus at Heritage Place is celebrating the grand opening of its newly renovated facility designed for seniors to enjoy a healthy lifestyle and living option.
Blake Gray loves wings.
OAKDALE − Oak Valley Bancorp, the bank holding company for Oak Valley Community Bank and Eastern Sierra Community Bank, recently reported financial results for the fiscal year ended Dec. 31, 2012.
RIPON - Magpie Antiques is being opened in Ripon by Janet Dyk of Manteca – a Ripon High School alum – at 140 South Walnut Avenue. The building has been bustling with activity over the last two weeks with vendors trucking in their valuables.
The tax code allows you to give away up to $14,000 each year to as many people as you want, without triggering gift tax. If you and your spouse "split" your gifts, you can double this $14,000 annual gift-tax exclusion and give $28,000 per recipient.
Manteca's only dermatologist Clinton Prescott, Jr., M. D., openly welcomes competition from other skin specialists due to the volume of patients he sees in his practice during a given week at his Central Valley Dermatology practice near Doctors Hospital.
DJ Singh is all about lifestyle.
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Shenzhen Hanoson Electronics Technology Co., Ltd.
|Business Type:
|Manufacturer, Trading Company
|Main Products:
|Guangdong, China (Mainland)
|Year Established:
|Number Of Employees:
|301 - 500 People
|Total Revenue:
|US$1 Million - US$2.5 Million
|Main Markets:
|Product Certifications:
Shenzhen Hanoson Electronics Technology Co., Ltd. is a technology integration company which specializes in electronic cigarette rese...
Shenzhen Hanoson Electronics Technology Co., Ltd. is a technology integration company which specializes in electronic cigarette research, production, development, sale and service. Since our establishment, we focus on numeral products to develop electronic cigarettes.
Our management policy is "to design and produce the most suitable and innovative products for our customers". For years, we have been carrying out the "customer supreme" principle all along, taking technical support as our basis, wholeheartedly providing advanced technical products and high-quality service for our all customers.
We have a high-standard quality management system and modernized work environment which is equipped with advanced electronic devices. The key point of our production is to supply healthy environment to people and create a good future for the human.
A Supplier Assessment Report provides verified information about a company's production and trade capabilities. This includes factors such as company legal status, human resources, export records, production capacity, quality assurance, customer service, production process management, R&D, certifications and more. View sample.
Company Capability
Trade Capacity
North America : 30.00%
Western Europe : 30.00%
Production Capacity
Factory Size : 1,000-3,000 square meters
No. of Production Lines : 4
Quality Control
Test Equipment and Facilities : Testing machine
R&D Capacity
No. of R&D Staff : 5 - 10 People
Email to this supplier


text:
SC East's photography studio will be hosting their own Help Portrait event at 25 Drydock Ave, Boston, MA.
Location: Boston, MA
Members: 2
Latest Activity: Nov 5, 2012
Here is where we'll post event information as it draws more near!
25 Drydock Ave, Boston, MA 02210
Whether you're interested in volunteering or getting your portrait taken, join our group and spread the word!
This group does not have any discussions yet.


text:
Life is pretty dull for four-eyed high school student Karin. She has never thought of herself as beautiful or glamorous, yet one day she finds Kiriya, the hottest guy in school, taking pictures of her in the subway. Karin is not sure if he actually likes her or if he just some kind of weirdo. Things are further complicated when Yuka, the most popular girl in Karin's school takes a romantic interest in Kiriya and views Karin as her rival.
Karin tries build up her courage and self esteem and stand up to Yuka. A modern story inspired by the classic Ugly Duckling fairy tale depicting a young girl's path to discover her true self and her first experiences with love.
Story and art by Kaho Miyasaka.
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text: Pirelli set to give Kobayashi 2013 testing role 23 January, 2013 Axed Sauber driver Kamui Kobayashi looks set to spend the 2013 season testing tyres with Formula 1's official supplier Pirelli. The Italian marque has invited the media to its Milan headquarters on Wednesday for the launch of the sport's 2013 tyres and a press conference "with Pirelli's main motor sport protagonists". The French sources F1i and Eurosport are reporting that Japanese Kobayashi, the former Sauber driver, should be announced as the main Pirelli tester for this year. An Italian source is reporting the same. Late last year, when 26-year-old Kobayashi was mentioned as a possible test driver for 2013, Pirelli's Paul Hembery answered: "It's a possibility. "We'll see what happens with him. I imagine he's still trying to get a (race) seat, so we'll wait." Tweet McLarenfan Well that keeps KK still in the sport Jolene Cocomazzi I don't know if it's just me or if everybody else encountering problems with your blog. It seems like some of the written text on your content are running off the screen. Can someone else please provide feedback and let me know if this is happening to them too? This might be a problem with my browser because I've had this happen previously. Appreciate it


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Results tagged ' Jorge Soler '
Arizona Fall League recap: 10/23/13
Both Kris Bryant and Wes Darvill got starts Wednesday night, while Albert Almora came in as a defensive replacement in the ninth inning for Mesa. Bryant and Darvill each recorded hits, but it wasn't enough, as the Solar Sox fell to Scottsdale 2-1 in 10 innings. Here are some highlights from yesterday's action.
Kris Bryant, DH – Batting third for Mesa, Bryant got off to a fast start, ripping a one-out double to left that advanced Taylor Lindsey (Angels) to third in the top of the first inning. Both runners were left stranded. That was Bryant's only hit of the day. He finished 1-for-5.
Wes Darvill, RF – Darvill opened up the scoring in the top of the sixth, driving in Steven Souza Jr. (Nationals) from third. Almora was brought in as a defensive replacement for Darvill in the bottom of the ninth. Darvill finished 1-for-4.
Cubs prospect Dallas Beeler is scheduled to make his third start of the fall on Thursday. The right-hander will go up against Scottsdale's Phil Irwin (Pirates). Beeler is 1-0 with a 6.00 ERA over six AFL innings. Jorge Soler is expected to bat sixth and play right field for the Sox. First pitch is scheduled for 2:35 CST.
Arizona Fall League recap: 10/18/13-10/19/13
As a team, Mesa struggled this weekend, falling 11-9 on Friday and 8-2 on Saturday. Despite not getting the best results, a few Cubs had some stellar games. Albert Almora and Kris Bryant are at or near the top of nearly every offensive category. Here are the highlights from this weekend's action.
Friday, Oct. 18
Albert Almora, CF – In the bottom of the seventh inning, Mesa's leadoff hitter ripped his fourth double of the fall, though Adrian Nieto (Nationals) was thrown out at home on the play. Almora went 1-for-6 Friday night.
Dallas Beeler, RHSP – Beeler had a rough second AFL start, going three innings and giving up three earned runs. His only strikeout was against Tyler Naquin (Indians), who led off the game. He faced four batters in the second inning, and got Garin Cecchini (Red Sox) to ground into a double play to end the frame. But Beeler just couldn't stay out of trouble in the first and the third. His final line read: 3.0 IP, 6 H, 3 ER, 2 BB, 1 K. He owns a 6.00 ERA through two starts.
Kris Bryant, 3B – With men on first and second and one out in bottom of the third, Bryant ripped a ground-rule double to left-center field, scoring Taylor Lindsey (Angels). Jorge Soler drove him in two batters later. With Lindsey on second in his next at-bat, Bryant ripped a homer to left field. But the 2013 first-round pick wasn't done there. In the fifth inning, he hit a solo shot to right-center field for his fourth homer of the fall. Bryant was 3-for-5.
Armando Rivero, RHP – Rivero came on in the ninth and gave up one earned run on two hits and a walk. He was credited for the loss.
Jorge Soler, RF – Soler singled in the bottom of the third to left field, scoring Bryant and moving Matt Skole (Nationals) to second. He singled again in the fourth, finishing the night 2-for-5.
Saturday, Oct. 19
Lendy Castillo, RHP – Castillo surrendered one hit in a scoreless sixth inning.
Wes Darvill, 3B – Darvill went hitless in four at-bats.
Matt Loosen RHP – Loosen fanned James Ramsey (Cardinals) and Mike Freeman (Diamondbacks), pitching a 1-2-3 fifth inning for Mesa.
Jorge Soler, RF – Soler recorded one of Mesa's three hits in Saturday's loss. He led off the seventh with a single, advanced to third on a throwing error and scored on a Jett Bandy (Angels) double. He was 1-for-4 at the plate.
Mesa hosts Surprise Monday afternoon, with first pitch scheduled for 1:35 CST. Sammy Solis (Nationals) takes the mound for the Sox, opposite Miguel Pena (Red Sox). Bryant is expected to hit fourth and play third base for Mesa.
Arizona Fall League recap: 10/15/13
Mesa is still unbeaten, after taking down Scottsdale 7-4 Tuesday. Albert Almora continued his successful fall season, while Jorge Soler and Armando Rivero got into the action as well. Here are some highlights from yesterday's game.
Albert Almora, CF – After a few days of rest, Almora led off for the Solar Sox. The 2012 first-round pick drew a walk to start the bottom of the third and scored two batters later on a C.J. Cron (Angels) homer. The team batted around in the third. With men on second and third and two outs, Almora hit a ground-rule double to left-center field, scoring David Freitas (Athletics) and Dixon Machado (Tigers). Then in the bottom of the fifth with nobody on base, he recorded another double to right to finish the game 2-for-4 with a walk.
Armando Rivero, RHP – Rivero entered the game in the eighth inning and gave up a bloop double and a single to the first two batters he faced. Jarrett Parker (Giants) followed with a sacrifice fly. That was all the damage Scottsdale could do, however. RIvero's final line read: 1 IP, 2 H, 1 ER.
Jorge Soler, DH – Soler singled in the bottom of the fourth and finished the day 1-for-5.
Mesa heads out to Peoria Wednesday, with the first pitch scheduled for 1:35 CST. Tommy Collier (Tigers) will take the mound for the Solar Sox while right-hander Matt Heidenreich (Astros) goes for the Javelinas. Kris Bryant will be batting fourth and playing third, and Wes Darvill will bat ninth and play second base for Mesa.
Arizona Fall League recap: 10/14/13
The Solar Sox continued their winning ways, edging out Scottsdale 7-6 Monday. A trio of Cubs prospects got into the game for Mesa, with some mixed results. Here are the highlights from yesterday's action.
Kris Bryant, 3B – Bryant, who is hitting .444 on the fall, batted fourth for Mesa and reached on fielding errors in the first, third and fourth innings. He was stranded in the first, but Taylor Lindsey (Angels) hit a home run to score him in the third. In the fourth inning, he reached second on a stolen base, but that's as far as he'd get. In the top of the sixth with a man on third, Bryant hit a sacrifice fly to right field, scoring Devon Travis (Tigers). He singled in the eighth to finish the night 1-for-4.
Matt Loosen, RHP – Loosen entered the game in the third with two outs and a man on second and struck out Cory Vaughn (Mets) to get out of the inning. He got himself into a bases-loaded jam with no outs in the bottom of the fourth, but a shallow fly out, a force out and a caught stealing kept the damage to one run. He gave up a leadoff triple in the fifth, but again allowed only one run. His final line read: 2.1 IP, 4 H, 2 ER, 1 K.
Jorge Soler, RF – Soler hit sixth for the Solar Sox and recorded his third double of the fall with a sixth inning two-out drive to center. He finished the night 1-for-5.
Mesa hosts Scottsdale this afternoon, with first pitch scheduled for 1:35 CST. Sammy Solis (Nationals) will take the mound for the Solar Sox, opposite Aaron Northcraft (Braves).
Arizona Fall League recap: 10/11/13
Cubs prospects made an impact on both sides of the ball for Mesa in a win over Surprise Friday night. All three offensive players in the lineup contributed, while a duo of right-handers got in the game as well. Here are the Cubs highlights from Friday's Solar Sox game.
Kris Bryant, DH: Batting fifth for the Sox, Bryant drove in the first run of the game on a two-out single in the first inning with men on first and second, scoring fellow Cubs prospect Jorge Soler. Then with one out in the seventh, Bryant blasted his second homer of the AFL season, a solo shot to center. Bryant was 2-for-5 on the night.
Dallas Beeler, RHP: Beeler got his first AFL action of the season, starting Friday's game. He struck out Garin Cecchini (Red Sox, No. 82 prospect according to MLB.com) in the first inning and went 1-2-3 in the second. With a runner on first and third in the third inning, Beeler surrendered a RBI groundout, but worked his way out of any further damage, fanning Mookie Betts (Red Sox) and getting Cecchini to ground out to second. His final line read: 3.0 IP, 3 H, ER, 2 K, BB. He also recorded a pair of pickoffs.
Lendy Castillo, RHP: Castillo pitched the fifth inning and struggled a bit, giving up a hit, two walks and an earned run before getting out of the inning.
Wes Darvill, 3B: Making his first start of the season, Darvill recorded an RBI single on a ground ball back to the pitcher in the third inning, scoring Steven Souza Jr. (Nationals). He also drew walks in the fifth and seventh to finish the night 1-for-3.
Jorge Soler, RF: Soler reached on a fielding error in the first, advanced to second on a C.J. Cron (Angels) single and scored on Bryant's single. In the top of the third, the Cuban singled on a soft liner to center and scored three batters later on a Souza double. He finished 1-for-5.
Arizona Fall League recap: 10/9/13
It took exactly two games for Cubs farmhands—a group that was already the talk of the Arizona Fall League—to get Arizona and North Side fans buzzing. All four Cubs position players saw action in the Solar Sox's 13-3 win over Glendale, and all four made an impact. Their combined final line read: 8-for-14, 3 HR, 3 2B, 2 BB, 11 RBI, 8 R. Here's what each player did yesterday.
Albert Almora, CF — Almora saw his first AFL action Wednesday, and got right to it, leading off the bottom of the first with a home run to left on the first pitch he saw. In the bottom of the second with runners on first and third, the 2012 first-round pick ripped a double to right, scoring Adrian Nieto (Nationals) and Dixon Machado (Tigers). He then led off the fourth with a sharp single to left field and would score three batters later on a Jorge Soler double. Almora again led off the fifth inning with a single to left, but would be stranded. He finished the day 4-for-5 with one home run and three RBI.
Kris Bryant, 3B — Batting fifth in the lineup, Bryant smashed a three-run homer in the bottom of the first, scoring Devon Travis (Tigers) and Zach Borenstein (Angels). Bryant singled to center in the bottom of the third and drew a walk in the fourth. The 2013 first-round pick did commit a fielding error in the top of the third, but no runs scored as a result. He finished the day 2-for-3 with a home run and three RBI.
Wes Darvill, 3B — Darvill entered the game as a defensive substitute in the seventh and recorded a two-run home run in the eighth, scoring Soler, who reached on a fielder's choice. It was his only at-bat of the day.
Jorge Soler, DH — Shifting from the outfield on Tuesday to designated hitter on Wednesday, the Cuba native's big at-bat came in the fourth inning when he hit a three-run double that scored Almora, Travis and Borenstein. Soler finished 1-for-5 with a walk and three RBI.
Mesa heads to Salt River Thursday night, where they will see the Blue Jays' top prospect in right-hander Aaron Sanchez (No. 20 prospect in baseball, according to MLB.com). Washington's Matt Purke will take the mound for Mesa, with first pitch scheduled for 7:35 central time. Lineups have not yet been posted.
Arizona Fall League opens Tuesday
Albert Almora will represent the Cubs as a member of the Solar Sox in the Arizona Fall League. (Photo by Jason Wise)
The Arizona Fall League is upon us. Though many will be tuned into the MLB playoffs for the next few weeks, the AFL is the crystal ball of baseball, giving fans a glimpse of the game's future stars.
Twenty-five of MLB's top 100 prospects (according to MLB.com) will be participating in Arizona action, headlined by individuals like the Twins' Byron Buxton and Pittsburgh's Jameson Taillon. Even with those two budding stars, no organization has received more hype for the depth it's bringing to the league than the Cubs. Three of the AFL's top 10 prospects are from Chicago's organization: Albert Almora, Jorge Soler and Kris Bryant.
Each member of that trio has received his fair share of hype, but a few other Cubs prospects who had solid 2013 campaigns are hoping to give the Mesa Solar Sox a boost as well.
Albert Almora, OF — The 2012 first-round pick and No. 21 prospect in baseball impressed when healthy this season. He hit .329/.376/.466 (AVG/OBP/SLG) in 61 games for Class-A Kane County. But he also missed the first month of the season, recovering from a broken hamate bone, and then was out of action from August-on, dealing with groin issues.
Dallas Beeler, RHP — Beeler got off to a fast start in 2013 with Double-A Tennessee, going 4-2 with a 3.13 ERA in 54.2 innings. But in late May, the right-hander tore a tendon in the middle finger of his pitching hand, shelving him for the season. The 24-year-old, 6-foot-5 starter is believed to be healthy and will pitch in Arizona to make up for a lost season.
Kris Bryant, 3B — Bryant was as advertised at the plate this year for the Cubs affiliates. The 2013 first-round pick (and No. 35 prospect in baseball) hit a combined .336/.390/.688 with nine homers and 14 doubles over 36 games with the instructional squad, Short-Season Boise and Daytona. Many eyes will be trained on the 21-year-old this fall.
Lendy Castillo, RHP — Not many players who have a full major league season under their belt play in the AFL. A 2011 Rule 5 pick, the Cubs were forced to put the reliever on their major league roster during the 2012 season or forfeit him back to Philadelphia, his original organization. Castillo spent the majority of 2013 with Kane County before a late-July promotion to Daytona. His 39 walks in 84.1 innings definitely contributed to his lofty 5.87 ERA, but he also fanned 8.1 batters per nine innings and 9.4 per nine in his 20-inning stint with the D-Cubs.
Wes Darvill, IF — The 22-year-old Canadian played all over the diamond for both Kane County and Daytona this season, seeing time at second base, third base, shortstop and left field. Darvill spent the first month of the season with the Cougars before a promotion to the D-Cubs. He hit a combined .267/.339/.380 in 94 games and finished second on the Daytona squad with five triples (seven on the season).
Matt Loosen, RHP — Loosen dominated hitters at High-A Daytona, going 5-2 with 56 strikeouts and a 1.83 ERA in 54.0 innings (including a no-hitter). But he struggled to find that same success in Tennessee. The 24-year-old righty was 3-3 with a 6.14 ERA, though he still managed to fan 60 batters in 66.0 innings. He showed promise late into the season, giving up one earned run in his last three starts combined and striking out 18 batters in 16.1 innings.
Armando Rivero, RHP — Rivero is a bit of a mystery for the Cubs. Signed out of Cuba prior to this season, the 25-year-old right-hander threw just 30.1 innings of full-season minor league ball. In all, he totaled a 4.15 ERA at Kane County, Daytona and Tennessee, and struck out 45. Rivero's outings could be some of the more closely monitored by the Cubs during play in Arizona.
Jorge Soler, OF — Shin and leg issues kept the 21-year-old Cuban out of action after the High-A Florida State League All-Star Game, but Soler still managed to make an impact. In 55 games, the corner outfielder hit .281/.343/.467 with eight homers and 13 doubles in 210 at-bats. Baseball's No. 25 prospect will hopefully rack up some innings and plate appearances to get back on track for 2014.
ESPN's Law ranks Cubs prospects among game's elite
Cubs prospect Kris Bryant has emerged as a top 15 prospect in baseball, according to Keith Law. (Photo courtesy of the University of San Diego)
ESPN Insider Keith Law knows his way around the minor league ranks. Since the 2012 season ended, Law has been very complimentary of the Cubs system, going so far as to rank the Cubs the sixth-best farm system in baseball back in February. And based on his recent midseason Top 50 MLB prospect rankings (subscription required), that number is likely to improve.
Recent first-round draft pick Kris Bryant, 2012 Cuban signee Jorge Soler, 2012 first-round pick Albert Almora and 2011 first-round pick Javy Baez are all in Law's top 27. While this is Bryant's first appearance on Law's list, the three others have all improved their rank. It's also worth noting infielder Arismendy Alcantara was one of eight players in the honorable mention section. Here's what Law had to say about the quartet.
15. Kris Bryant, OF | Chicago Cubs (age 21)
Current level: Short-season Class A (Boise)
Preseason ranking: Ineligible
Signed to the biggest bonus in this year's draft (as predicted in this space), Bryant has huge raw power from the right side, a rare and valuable commodity in and of itself, and profiles as a middle-of-the-order bat whether he's at third base or in right field. He's yet to play a game as of this writing.
20. Jorge Soler, OF | Chicago Cubs (age 21)
Current level: High Class A (Daytona)
Preseason ranking: 42
Soler would have been in the Futures Game and likely in Double-A were it not for a stress fracture that has him on the shelf until at least early August and possibly until instructional league, although he could pick up some needed at-bats in the Arizona Fall League.
He remains a high-ceiling player, with a quick bat, easy power and running speed, but losing a half-season of reps doesn't help.
25. Albert Almora, OF | Chicago Cubs (age 19)
Current level: Low Class A (Kane County)
Preseason ranking: 33
The irony of one of the game's most prominent sabermetrically inclined front offices overseeing a farm system of guys who walk once a month deserves more attention than it's gotten. I wonder if Bryant, who walked a ton in college this spring, will become an unrepentant hacker the moment he gets to Daytona.
Almora doesn't walk much, but he has great feel for the bat, making a lot of hard contact, and plays plus defense in center.
27. Javier Baez, SS | Chicago Cubs (age 19)
Current level: Double-A (Tennessee)
Preseason ranking: 31
The player with the best bat speed in the minors should be higher on this list, in theory, but Baez operates under the strong belief — not entirely unfounded — that he can hit anything within a foot of the strike zone, which results in low walk rates and a tendency to give away at-bats when he doesn't get a pitch he can crush right away.
He continues to play solid defense at shortstop and the power is insane, but it would be nice if someone in this farm system would walk more than twice a month.
Cubs' Alcantara, Soler into MLB Futures Game
Jorge Soler will represent the World Team in the Futures Game. (Photo by Stephen Green)
A pair of the Cubs' most promising prospects were honored for their solid first halves on Wednesday, as middle-infielder Arismendy Alcantara and corner outfielder Jorge Soler were both selected to represent the World Team in the MLB All-Star Futures Game. The annual exhibition, which will be held on July 14 at Citi Field in New York, pits the top U.S.-born prospects against the best from around the world.
The 21-year-old Alcantara has enjoyed a solid season in Double-A Tennessee this year. Primarily playing shortstop (57 appearances vs. 17 at second base), the 2008 non-drafted free agent has hit .280/.357/.465 and is fourth in the Southern League with 10 home runs and fifth in stolen bases with 19. He's also tied for sixth in the SL with 17 doubles. The Dominican native is ranked No. 20 on MLB.com's organizational prospect ranks.
Cuban expat Soler made news last season when the Cubs signed him to a nine-year, $30 million deal, and he has performed well in his first full season of minor league ball. The 6-foot-4, 215 pound slugger has hit .281/.343/.467 for High-A Daytona, recording eight home runs with 13 doubles and 35 RBI. Baseball Prospectus' Jason Parks recently named Soler the No. 31 prospect in baseball, and MLB.com has him ranked No. 3 in the organization.
In addition to Alcantara and Soler, Cubs fans have a chance to vote for shortstop phenom Javier Baez as the final member of the World Team, as he was named a Futures Finalist.
Cubs scattered throughout BP's new prospect list
Javier Baez has already enjoyed a four-home run day earlier this season. (Photo by Aldrin Capulong/Daytona Cubs)
The names might look familiar, but their placement among the top prospects only continues to rise. Earlier this week, Baseball Prospectus' Jason Parks unveiled his Midseason Top 50 Prospects (subscription required). In his list, he included a trio of Cubs players in center fielder Albert Almora, shortstop Javier Baez and corner outfielder Jorge Soler. All three of the highly touted young players have enjoyed solid seasons of minor league ball this year, and as a result, have jumped in the ranks since Park's preseason list. Below are the excerpts regarding the Cubs' big three. It's also worth noting that Parks mentioned on Twitter that 2013 first-round pick Kris Bryant would have likely made the list had he already signed with the club.
No. 15—CF Albert Almora
Placement on Preseason 101: 18
Current MiLB Level/Affiliate: Low-A Kane County
Prospect Trajectory: Up; Almora is a legit five-tool talent who comes with an incredible feel for the game; has top tier potential.
Major League ETA: 2015
No. 17—SS Javier Baez
Placement on Preseason 101: 20
Current MiLB Level/Affiliate: High-A Daytona
Prospect Trajectory: Up; has the offensive upside to become of the top prospects in the game; high risk and chance for regression at Double-A level.
Major League ETA: 2015
No. 31—OF Jorge Soler
Placement on Preseason 101: 36
Current MiLB Level/Affiliate: High-A Daytona
Prospect Trajectory: Up; Soler's power is legit, and as he matures at the plate, he will continue to tap into the tool in game action; lacks elite upside, but could jump up the list if the power plays. People love power.
Major League ETA: 2015


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St. Patrick's Day: Legends and history
Published On: Jul 14 2011 03:22:16 PM CDTSorry, Flash is not supported.
Updated On: Mar 15 2013 01:00:36 AM CDT
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text: Dem 2400 series, Intel prem 4 at 2.530 GHz. 1.00 GB Ram, 2002 At Start, my computer takes about 25 minutes to load all files. Freezing occurs frequently during start up. Not much after loading files. I know squat about which programs to delete from start up. I did notice that I have two duplicate files labeled LMI_rescue_srv.... using 138,000 k. I use Bitdefender and Essential for virus protection. I also use fix center to clear disk and register. It appears the freezing occurs when more than one program is operating. Appreciate any suggestions to eliminating the freezing.


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MAS could offer tool to compare enhanced annuities
The Money Advice Service is considering launching an enhanced annuity comparison tool.
The Government has stepped up its attempts to increase the number of people who shop around for an annuity, with representatives from the Department for Work and Pensions and the Treasury exploring the practicalities of making the open market opt-ion the default at retirement.
Money Marketing understands the MAS has held discussions with insurance industry representatives about offering a tool which would allow users to compare the rates offered by enhanced annuity providers online.
The MAS website currently has an annuity comparison table which asks for basic information, such as the user's postcode and whether or not they smoke, before providing an annuity quote.
A MAS spokeswoman refused to confirm whether the industry-funded organisation is developing an enhanced annuity comparison tool.
She says: "This year, we are undertaking a review of our products and services but at this stage we cannot confirm which specific aspects are being considered."
Radcliffe & Newlands chartered financial planner Mel Kenny says: "There is a trend towards providing enhanced or impaired annuities online. However, there should be a health warning attached to them because savers may still be able to get a better rate elsewhere or the structure of the annuity may be inappropriate."
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text: ccw in Fairfax [Archive] - Glock Talk Glock Talk > The Main Room > WhereULive > Glockers of the Old Dominion > ccw in Fairfax PDA View Full Version : ccw in Fairfax jhaygood04-26-2007, 18:23Does anyone know how to check the status/wait time for ccw in Farifax? alien-Glocker04-26-2007, 18:39I submitted my renewal last November. They took the entire 45 days. I noticed that my return envelope was dated over a week after the date on the CHP! There was no change in address or any other status . vafish04-26-2007, 19:08My renewal took about 49 days in Fairfax. I went down and made them give me a temporary. Diokan04-30-2007, 06:54Mine took like 35 days. I wouldn't bother trying to check, unless you've gone past the 45 days. vafish04-30-2007, 10:34Originally posted by Diokan Mine took like 35 days. I wouldn't bother trying to check, unless you've gone past the 45 days. If it's been 46 days go down to the court house with your receipt and have them give you a certified copy of your application. That becomes your permit. That's what I did. Permit showed up the next day. They probably mailed it out the afternoon of the morning I picked up the temporary. txminime04-30-2007, 20:10Sorry to hi-jack this thread, but have anyone went through the process of applying for a CCW permit as a certified NRA pistol instructor? Technically, I guess I can teach myself and then sign a certificate for completion, but that would be rather silly. :) I recently moved to Fairfax area from Dallas and finally settled in enough to think about getting a CCW permit. I was expecting an lengthy state-approved CCW course as part of the process (as in Texas), but it was a pleasant surprise to find quite a few different options for "training". Francis vafish05-01-2007, 05:37Francis, The law pretty much allows ANY NRA firearms training course. That includes NRA instructors courses. Just give the court house a copy of your NRA Instructor credentials. You won't have any problems. They have to take even a Hunter Safety Certificate, not matter how old it is. txminime05-01-2007, 20:45Thank you. It's a relieve knowing I won't have to sit through my own basic firearm safety course. :) Francis jhaygood05-10-2007, 18:38I got my ccw today it was issued last Friday so that means that it only took about 35 days to issue and another 6 days to go through the mail. Thanks for all the replies. vBulletin® v3.8.7, Copyright ©2000-2014, vBulletin Solutions, Inc.


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