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Nullification, in United States constitutional history, is a legal theory that a state has the right to nullify, or invalidate, any federal law which that state has deemed unconstitutional. The theory of nullification has never been legally upheld by federal courts.[1]
The theory of nullification is based on a view that the States formed the Union by an agreement (or "compact") among the States, and that as creators of the federal government, the States have the final authority to determine the limits of the power of that government. Under this, the compact theory, the States and not the federal courts are the ultimate interpreters of the extent of the federal government's power. Under this theory, the States therefore may reject, or nullify, federal laws that the States believe are beyond the federal government's constitutional powers. The related idea of interposition is a theory that a state has the right and the duty to "interpose" itself when the federal government enacts laws that the state believes to be unconstitutional. Thomas Jefferson and James Madison set forth the theories of nullification and interposition in the Kentucky and Virginia Resolutions in 1798.
Courts at the state and federal level, including the U.S. Supreme Court, repeatedly have rejected the theory of nullification.[2] The courts have decided that under the Supremacy Clause of the Constitution, federal law is superior to state law, and that under Article III of the Constitution, the federal judiciary has the final power to interpret the Constitution. Therefore, the power to make final decisions about the constitutionality of federal laws lies with the federal courts, not the states, and the states do not have the power to nullify federal laws.
Between 1798 and the beginning of the Civil War in 1861, several states threatened or attempted nullification of various federal laws. None of these efforts were legally upheld. The Kentucky and Virginia Resolutions were rejected by the other states. The Supreme Court rejected nullification attempts in a series of decisions in the 19th century, including Ableman v. Booth, which rejected Wisconsin's attempt to nullify the Fugitive Slave Act. The Civil War ended most nullification efforts.
In the 1950s, southern states attempted to use nullification and interposition to prevent integration of their schools. These attempts failed when the Supreme Court again rejected nullification in Cooper v. Aaron, explicitly holding that the states may not nullify federal law.
The Constitution does not contain any clause expressly providing that the states have the power to declare federal laws unconstitutional.
Supporters of nullification have argued that the states' power of nullification is inherent in the nature of the federal system. They have argued that before the Constitution was ratified, the states essentially were separate nations. Under this theory, the Constitution is a contract, or "compact", among the states by which the states delegated certain powers to the federal government, while reserving all other powers to themselves. The states, as parties to the compact, retained the inherent right to judge compliance with the compact. According to supporters of nullification, if the states determine that the federal government has exceeded its delegated powers, the states may declare federal laws unconstitutional.[3] Nullification supporters argue that the power to declare federal laws unconstitutional not only is inherent in the concept of state sovereignty, but also is one of the powers reserved to the states by the Tenth Amendment.[4]
This view of the Constitution has been rejected by the federal courts, which consistently have held that under the Constitution, the states do not have the power to nullify federal laws. The courts have rejected the compact theory, finding that the Constitution was not a contract among the states. Rather, the Constitution was established directly by the people, as stated in the preamble: "We the people of the United States. . . ."[5] The people made the federal government superior to the states in certain ways. Under the Supremacy Clause of Article VI, the Constitution and federal laws made in pursuance thereof are "the supreme law of the land . . . any thing in the constitution or laws of any state to the contrary notwithstanding."[6] The courts have held that federal laws are therefore superior to state laws and cannot be negated by the states. Federal laws are valid and are controlling, so long as those laws were adopted in pursuance of—that is, consistent with—the Constitution. Determining whether a federal law is consistent with the Constitution requires interpretation of the law, which is inherently a judicial function. The federal judicial power granted by Article III of the Constitution gives the federal courts authority over all cases "arising under this Constitution [or] the laws of the United States."[7] The federal courts therefore have been given the power to determine whether federal laws are consistent with the Constitution, with the Supreme Court having final authority.[8]
Thus, the federal courts have held that under the Constitution, federal law is controlling over state law, and the final power to determine whether federal laws are unconstitutional has been delegated to the federal courts. The courts therefore have held that the states do not have the power to nullify federal law.[9]
The concept of nullification of federal law by the states was not discussed at the Constitutional Convention.[10] The records of the Constitutional Convention therefore do not provide support for the theory of nullification.
On the other hand, the records of the Convention support the idea that the power to declare federal laws unconstitutional lies in the federal courts. At least fifteen Constitutional Convention delegates from nine states spoke about the power of the federal courts to declare federal laws unconstitutional. For example, George Mason said that under the Constitution, federal judges "could declare an unconstitutional law void."[11] James Madison said: "A law violating a constitution established by the people themselves, would be considered by the Judges as null & void."[12] Elbridge Gerry said that the power of federal judges to interpret federal laws includes "a power of deciding on their constitutionality."[13]
Several of the Convention delegates said that the federal courts would have power to determine disputes between the federal government and the states. Charles Pinckney referred to federal judges as "Umpires between the U. States and the individual States."[14] John Rutledge indicated that the Supreme Court would "judge between the U.S. and particular states."[15] These statements indicated that the Supreme Court would have final authority in constitutional disputes between the federal government and the states.
The records of the state ratifying conventions do not include any assertions that the states would have the power to nullify federal laws. It has been argued that certain statements in the Virginia ratifying convention, although not asserting a right of nullification, articulated a basis for the compact theory. Edmund Randolph and George Nicholas stated that Virginia's ratification of the Constitution would constitute its agreement to a contract, and that if Virginia were to state its understanding at the time of ratification that the federal government could exercise only its delegated powers, this understanding would become part of the contract and would be binding on the federal government.[16] These statements implied a belief that Virginia, as a party to the contract, would have a right to judge the constitutional limits of federal power.[17]
The records of the state ratifying conventions include over three dozen statements in more than half the states asserting that the federal courts would have the power to declare laws unconstitutional.[18] For example, Luther Martin's letter to the Maryland ratifying convention asserted that the power to declare laws unconstitutional could be exercised solely by the federal courts, and that the states would be bound by federal court decisions: "Whether, therefore, any laws or regulations of the Congress, any acts of its President or other officers, are contrary to, or not warranted by, the Constitution, rests only with the judges, who are appointed by Congress, to determine; by whose determinations every state must be bound."[19] John Marshall said in the Virginia convention that protection against infringement of the Constitution would be provided by the federal courts: "If [Congress] were to make a law not warranted by any of the powers enumerated, it would be considered by the [federal] judges as an infringement of the Constitution which they are to guard. . . . They would declare it void. . . . To what quarter will you look for protection from an infringement on the Constitution, if you will not give the power to the judiciary? There is no other body that can afford such a protection."[20]
In short, there were no statements in the Constitutional Convention or the state ratifying conventions asserting that the states would have the power to nullify federal laws. On the other hand, the records of these conventions support the idea that the power to declare federal laws unconstitutional lies in the federal courts.[21]
The Federalist Papers do not assert that the states have the power to nullify federal law. On the contrary, they say that the power to declare laws unconstitutional concerning is delegated to federal courts, not the states.
Federalist No. 33 states that federal laws are supreme to state law, so long as they are within the federal government's delegated powers.[22]
Federalist No. 39 directly addresses the question of who is to decide whether the federal government has exceeded its delegated powers and has infringed on the states' reserved powers. It explains that under the Constitution, this issue is to be decided by the Supreme Court, not the states: "[The federal government's] jurisdiction extends to certain enumerated objects only, and leaves to the several States a residuary and inviolable sovereignty over all other objects. It is true that in controversies relating to the boundary between the two jurisdictions, the tribunal which is ultimately to decide, is to be established under the general [i.e. federal] government. . . . Some such tribunal is clearly essential to prevent an appeal to the sword and a dissolution of the compact; and that it ought to be established under the general rather than under the local governments, or, to speak more properly, that it could be safely established under the first alone, is a position not likely to be combated."[23]
Federalist No. 44 discusses the role of the states in checking actions of Congress that exceed its delegated powers. According to Federalist No. 44, the role of the states is to "sound the alarm" regarding any unconstitutional exercise of power by Congress, and to assist in electing new representatives to Congress.[24] Federalist No. 44 does not imply that the states have the power to legally nullify federal law, although this would have been an appropriate context in which to mention it if such a power were thought to exist.
Federalist No. 78 says that the federal courts have the power "to pronounce legislative acts void, because contrary to the Constitution."[25]
Federalist No. 80 asserts that the final authority to interpret the Constitution and federal law lies in the federal courts, not the states, because of the need for uniformity.[26] Likewise, Federalist No. 22 says that the federal courts should interpret federal law due to the need for uniformity.[27]
Federalist No. 82 says that because of the need for uniformity and the federal government's need to effectively enforce its laws, the Constitution gives the Supreme Court the power to review decisions of state courts in cases arising under the Constitution or federal law.[28]
The Federalist papers therefore indicate that the power to declare federal laws unconstitutional lies in the federal courts, not in the states.
The earliest assertion of the theories of nullification and interposition is found in the Kentucky and Virginia Resolutions of 1798, which were a protest against the Alien and Sedition Acts. In these resolutions, authors Thomas Jefferson and James Madison argued that "the states" have the right to interpret the Constitution and can declare federal laws unconstitutional when the federal government exceeds its delegated powers. These resolutions are considered the foundational documents of the theories of nullification and interposition.
The Kentucky Resolutions of 1798, written by Jefferson, asserted that the states formed the Constitution as a compact, delegating certain specified powers to the federal government and reserving all other powers to themselves. Each state, as a party to the compact, has a "right to judge for itself" the extent of the federal government's powers. When the federal government acts beyond the scope of its delegated powers, a state may determine that the federal government's "acts are unauthoritative, void, and of no force."[29] The Kentucky Resolutions of 1798 called on the other states to join Kentucky "in declaring these acts void and of no force" and "in requesting their repeal at the next session of Congress."
The Kentucky Resolutions of 1799 added the assertion that when a federal law is unconstitutional, the remedy is "nullification" of the law by "the several states."[30] The Kentucky Resolutions of 1799 did not assert that Kentucky would unilaterally refuse to enforce, or prevent enforcement of, the Alien and Sedition Acts. Rather, these resolutions declared that Kentucky "will bow to the laws of the Union" but would continue "to oppose in a constitutional manner" the Alien and Sedition Acts. The resolutions stated that Kentucky was entering its "solemn protest" against those Acts. The author of the Kentucky Resolutions of 1799 is not known with certainty.[31]
The Virginia Resolutions of 1798, written by Madison, did not mention nullification. Rather, they introduced the idea of "interposition." The Virginia Resolutions asserted that when the federal government engages in "a deliberate, palpable, and dangerous exercise" of powers not granted by the Constitution, "the states, who are parties thereto, have the right, and are in duty bound, to interpose, for arresting the progress of the evil, and for maintaining, within their respective limits, the authorities, rights and liberties, appertaining to them."[32] The Virginia Resolutions did not explain what form this "interposition" might take. The Virginia Resolutions appealed to the other states for agreement and cooperation in opposing the Alien and Sedition Acts.
The Kentucky and Virginia Resolutions did not attempt to prohibit enforcement of the Alien and Sedition Acts within the borders of those states. Rather, these resolutions declared that the legislatures of these states viewed the Alien and Sedition Acts as unconstitutional, called for the repeal of these Acts, and requested the support and cooperation of the other states.
The Kentucky and Virginia Resolutions were not accepted by any of the other states. Rather, ten states rejected the Resolutions, with seven states formally transmitting their rejections to Kentucky and Virginia[33] and three other states passing resolutions expressing disapproval.[34] At least six states responded to the Resolutions by taking the position that the constitutionality of acts of Congress is a question for the federal courts, not the state legislatures. For example, Vermont's resolution stated: "That the General Assembly of the state of Vermont do highly disapprove of the resolutions of the General Assembly of Virginia, as being unconstitutional in their nature, and dangerous in their tendency. It belongs not to state legislatures to decide on the constitutionality of laws made by the general government; this power being exclusively vested in the judiciary courts of the Union."[35]
Virginia responded to the criticism of the other states by issuing the Report of 1800, written by Madison. The Report of 1800 affirmed and defended the Virginia Resolutions. The Report of 1800 also said that a declaration of unconstitutionality by the states would be only an expression of opinion designed to spur debate, rather than having the authoritative effect of a federal court decision.[36] During the Nullification Crisis of the 1830s, Madison denounced as unconstitutional the concept of nullification of federal law by a state.[37][38][39] Madison wrote, "But it follows, from no view of the subject, that a nullification of a law of the U. S. can as is now contended, belong rightfully to a single State, as one of the parties to the Constitution; the State not ceasing to avow its adherence to the Constitution. A plainer contradiction in terms, or a more fatal inlet to anarchy, cannot be imagined."[40]
The Supreme Court first dealt with nullification in 1809 in the case of United States v. Peters, 9 U.S. (5 Cranch) 115 (1809).[41] The Court rejected the idea of nullification. The Pennsylvania legislature had passed an act purporting to nullify a federal court's decision. The Pennsylvania statute stated that the federal court had acted unconstitutionally because it did not have jurisdiction, and that the federal court's judgment "was null and void." The Supreme Court held that the Pennsylvania legislature did not have the power to nullify the federal court's judgment, stating: "If the legislatures of the several States may, at will, annul the judgments of the courts of the United States, and destroy the rights acquired under those judgments, the Constitution itself becomes a solemn mockery, and the nation is deprived of the means of enforcing its laws by the instrumentality of its own tribunals."
In response, the Governor of Pennsylvania called out the state militia to prevent enforcement of the Supreme Court's judgment. However, the U.S. Marshal summoned a posse, carried out the Supreme Court's order, and arrested the leaders of the state militia. The Pennsylvania legislature passed a resolution declaring the action of the Supreme Court unconstitutional, invoking states' rights, and appealing to the other states for support.[42] Eleven states responded by disapproving Pennsylvania's attempted nullification. No state supported Pennsylvania.[43] The Governor of Pennsylvania made a plea to President James Madison to intervene, but Madison affirmed the authority of the Supreme Court. The Pennsylvania legislature backed down and withdrew the militia.[44] Thus, Pennsylvania's attempt to nullify the federal court judgment failed.[45]
Several New England states objected to the Embargo Act of 1807, which restricted foreign trade. The Massachusetts legislature passed a resolution stating that the embargo "is, in the opinion of the legislature, in many respects, unjust, oppressive and unconstitutional, and not legally binding on the citizens of this state." The Massachusetts resolution did not purport to nullify the Embargo Act, but instead stated that "the judicial courts are competent to decide this question, and to them every citizen, when aggrieved, ought to apply for redress." Massachusetts called on Congress to repeal the act, and proposed several constitutional amendments. Connecticut passed a resolution declaring that the act was unconstitutional and declaring that state officials would not "assist, or concur in giving effect to the aforesaid unconstitutional act." Connecticut joined in the call for constitutional amendments. Neither Massachusetts nor Connecticut attempted to ban enforcement of the act within the state. A federal district court ruled in 1808 that the Embargo Act was constitutional.[46] Congress repealed the Embargo Act in 1809 because it had been ineffective in achieving its goal of bringing economic pressure on England and France. Neither state attempted to block enforcement of the Embargo Act, so nullification did not come to a legal test.
The War of 1812 was harmful to New England's commercial interests and was unpopular in New England. The New England states objected to putting their state militias under federal control, arguing that the Constitution did not give the federal government authority over state militias in those circumstances. There was some discussion in New England about making a separate peace with Britain or even seceding from the Union. At the Hartford Convention of 1814, delegates from several New England states met to discuss their disagreements with the federal government's policies. The final report and resolutions from the Hartford Convention asserted that "acts of Congress in violation of the Constitution are absolutely void" and asserted the right of a state "to interpose its authority" to protect against unconstitutional government action. The final resolutions did not attempt to ban enforcement of any act of Congress. Rather, the resolutions recommended to state legislatures that they protect their citizens from unconstitutional federal action, called on the federal government to fund the defense of New England, and proposed a series of amendments to the Constitution.[47] No state legislature followed up by attempting to nullify a federal act. The end of the war made the issue moot.
In 1813, the Supreme Court reversed a decision of the Virginia Court of Appeals, basing its decision on the terms of a federal treaty.[48] The Virginia Court of Appeals refused to accept the Supreme Court's decision, stating that under the Constitution, the Supreme Court did not have authority over state courts. The Virginia court held that as a matter of state sovereignty, its decisions were final and could not be appealed to the U.S. Supreme Court. The Virginia court found unconstitutional the federal statute providing for Supreme Court review of state court judgments. This decision would have allowed each state's courts to decide for themselves whether federal actions were unconstitutional, effectively giving state courts the right to nullify federal law. In Martin v. Hunter's Lessee, 14 U.S. (1 Wheat.) 304 (1816), the Supreme Court rejected this view. The Supreme Court held that Article III of the Constitution gives the federal courts jurisdiction in all cases arising under the Constitution or federal law, and gives the Supreme Court final authority in such cases. The Supreme Court stated that the people, by providing in the Constitution that the Supreme Court has final authority in such cases, had chosen to limit the sovereignty of the states. The Supreme Court therefore found that the federal courts, not the states, have the final power to interpret the Constitution.
Virginia again challenged the Supreme Court's authority in Cohens v. Virginia, 19 U.S. (6 Wheat.) 264 (1821). The question was whether the Supreme Court had authority to hear an appeal in a criminal case decided by a state court based on violation of a state law, where the defense was based on federal law. The Virginia legislature passed resolutions declaring that the Supreme Court had no authority over it due to principles of state sovereignty.[49] The Supreme Court held that under Article III of the Constitution, the federal courts have jurisdiction over all cases involving the Constitution or federal law, including state cases in which a federal defense arises. Because the defendants in the case claimed that their actions were authorized by a federal statute, there was a disputed issue of federal law and the Supreme Court had authority to review the state court's judgment. Thus, the Supreme Court again found that the final power to interpret federal law lies in the federal courts, not the states.
These two cases established the principle that the federal courts, not the states, have the final power to interpret the Constitution and to determine the Constitutional limits of federal power. These cases rejected the state's attempt to determine the limits of federal power.
In 1819, Ohio imposed a tax on the federally chartered Bank of the United States. The Supreme Court already had ruled that such taxes were unconstitutional in McCulloch v. Maryland, 17 U.S. (4 Wheat.) 316 (1819). Despite the Supreme Court's decision, Ohio seized $100,000 from the Bank to satisfy the tax. Ohio's legislature passed resolutions declaring that it did not accept the result of the McCulloch case and denying that the Supreme Court had the final authority to interpret the Constitution. The Ohio legislature's resolutions, relying on the Kentucky and Virginia Resolutions, asserted that the states "have an equal right to interpret that Constitution for themselves." The resolutions declared that Ohio had the legal power to tax the Bank.[50]
The controversy eventually reached the Supreme Court in Osborn v. Bank of the United States, 22 U.S. (9 Wheat.) 738 (1824). The Supreme Court held that Ohio's tax on the Bank was unconstitutional. The Supreme Court stated: "[T]he act of the State of Ohio . . . is repugnant to a law of the United States, made in pursuance of the Constitution, and therefore void." The Supreme Court thus rejected Ohio's attempt to nullify federal law.
In the 1820s, Georgia passed an act making Georgia state law applicable on all Cherokee lands and declaring all laws of the Cherokee nation void. This contradicted federal treaties with the Cherokees, effectively nullifying those federal treaties. Georgia's actions were reviewed by the U.S. Supreme Court in Worcester v. Georgia, 31 U.S. (6 Pet.) 515 (1832). While the case was pending in the Supreme Court, the Georgia legislature passed a resolution asserting that under the Tenth Amendment, the federal government had no jurisdiction over Georgia criminal law and the Supreme Court's review of the case was unconstitutional.[51]
The Supreme Court rejected Georgia's attempt to nullify the federal treaties with the Cherokees. The Court held that "according to the settled principles of our Constitution," authority over Indian affairs is "committed exclusively to the government of the Union." The Court held that under the federal treaties with the Cherokees, "the laws of Georgia can have no force" on Cherokee land. The Court held that Georgia's laws regulating Cherokee land were "void, as being repugnant to the constitution, treaties, and laws of the United States."[52] The Supreme Court thus asserted final authority to interpret the Constitution and federal treaties, rejecting Georgia's nullification attempt.
Georgia refused to accept the Supreme Court's decision. President Andrew Jackson did not believe Georgia had the right to nullify federal law, but was sympathetic to Georgia's goal of forcing the Cherokees to relocate to the west. He took no immediate action against Georgia. Before the Supreme Court could hear a request for an order enforcing its judgment, the Nullification Crisis arose in South Carolina. Jackson wanted to avoid a confrontation with Georgia over states' rights. A compromise was brokered under which Georgia repealed the law at issue in Worcester. Despite the Court's decision finding Georgia's actions unconstitutional, Georgia continued to enforce other laws regulating the Cherokees. Ultimately the Cherokees were forced to agree to a treaty of relocation, leading to the Trail of Tears.[53]
The idea of nullification increasingly became associated with matters pertaining to the sectional conflict and slavery. The best known statement of the theory of nullification during this period, authored by John C. Calhoun, was the South Carolina Exposition and Protest of 1828. Calhoun asserted that the Tariff of 1828, which favored the northern manufacturing states and harmed the southern agricultural states, was unconstitutional. Calhoun argued that each state, as "an essential attribute of sovereignty," has the right to judge the extent of its own powers and the allocation of power between the state and the federal government. Calhoun argued that each state therefore necessarily has a "veto," or a "right of interposition," with respect to acts of the federal government that the state believes encroach on its rights.[54]
In the Webster-Hayne debate in the Senate in 1830, Daniel Webster responded to this nullification theory by arguing that the Constitution itself provides for the resolution of disputes between the federal government and the states regarding allocation of powers. Webster argued that the Supremacy Clause provides that the Constitution and federal laws enacted pursuant thereto are superior to state law, and that the Article III gives to the federal judiciary the power to resolve all issues relating to interpretation of the Constitution. Under the Constitution, the federal courts therefore have the last word, said Webster. Webster said that the Constitution does not give the states a power of constitutional interpretation, and that any such power would result as many conflicting interpretations of the Constitution as there are states.[55] Therefore, said Webster, under the Constitution, the states do not have the power to nullify federal laws.
In 1832, South Carolina undertook to nullify the Tariff of 1828 and the Tariff of 1832, as well as a subsequent federal act authorizing the use of force to enforce the tariffs. South Carolina purported to prohibit enforcement of these tariff acts within the state, asserting that these acts "are unauthorized by the constitution of the United States, and violate the true meaning and intent thereof and are null, void, and no law, nor binding upon this State, its officers or citizens."[56] President Andrew Jackson denied that South Carolina had the power to nullify federal statutes, and prepared to enforce federal law forcibly if necessary. In his Proclamation to the People of South Carolina, Jackson said: "I consider, then, the power to annul a law of the United States, assumed by one State, incompatible with the existence of the Union, contradicted expressly by the letter of the Constitution, unauthorized by its spirit, inconsistent with every principle on which It was founded, and destructive of the great object for which it was formed."[57] No other state supported South Carolina. James Madison, author of the Virginia Resolution, also weighed in at this time, stating that the Virginia Resolution should not be interpreted to mean that each state has the right to nullify federal law.[58] The issue was made moot by an enactment of a compromise tariff bill. While the Nullification Crisis arose over a tariff law, it was recognized that the issues at stake had application to the slavery question as well.[59]
Northern states in the mid-19th century attempted to block enforcement of the pro-slavery federal Fugitive Slave Acts of 1793 and 1850. Several northern states passed personal liberty laws that had the practical effect of undermining the effectiveness of the federal fugitive slave statutes and preventing slave owners from recovering runaways. For example, a Pennsylvania law enacted in 1826 made it a crime for any person to forcibly remove a black person from the state with the intention of keeping or selling him as a slave.
The U.S. Supreme Court upheld the validity of the federal Fugitive Slave Act of 1793 in the case of Prigg v. Pennsylvania, 41 U.S. 539 (1842). The Court rejected Pennsylvania's argument that Congress had no constitutional authority to enact the Fugitive Slave Act, finding that the Act was authorized by the Constitution's fugitive slave clause (Article IV, Section 2). The Court found that Pennsylvania's personal liberty law was unconstitutional because it conflicted with the Constitution's fugitive slave clause.[60] The Court thus rejected Pennsylvania's attempt to nullify the Fugitive Slave Act. However, the Supreme Court implied that states might be able to pass laws denying the assistance of state officials in enforcement of the Fugitive Slave Act, leaving enforcement to federal officials.[61][62]
The Supreme Court again dealt with a northern challenge to the federal fugitive slave statutes in the case of Ableman v. Booth, 62 U.S. 506 (1859). The courts of Wisconsin held the Fugitive Slave Act of 1850 unconstitutional and ordered the release of a prisoner who was prosecuted in federal district court for violation of the Act. The Wisconsin court declared that the Supreme Court had no authority to review its decision. The Wisconsin legislature passed a resolution declaring that the Supreme Court had no jurisdiction over the Wisconsin court's decision. In language borrowed from the Kentucky Resolution of 1798, the Wisconsin resolution asserted that the Supreme Court's review of the case was void.[63]
The Supreme Court held that Wisconsin did not have the power to nullify federal law or to prevent federal officials from enforcing the Fugitive Slave Act. The Court held that in adopting the Supremacy Clause, the people of the United States had made federal law superior to state law and had provided that in the event of a conflict, federal law would control. Further, the Court found that the people had delegated the judicial power, including final appellate authority, to the federal courts with respect to cases arising under the Constitution and laws of the United States.[64] Therefore, the people gave the federal courts final authority to determine the constitutionality of federal statutes and to determine the boundary between federal power and state power.[65] Accordingly, the Court held that the Wisconsin court did not have the power to nullify a federal statute that had been upheld by the federal courts or to interfere with federal enforcement of that statute.
Ableman v. Booth was the Supreme Court's most thorough examination yet of the theory of nullification. Like the decisions that preceded it, Ableman found that federal law was superior to state law, and that under the Constitution, the final power to determine the constitutionality of federal laws lies in the federal courts, not the states. Ableman found that the Constitution gave the Supreme Court final authority to determine the extent and limits of federal power and that the states therefore do not have the power to nullify federal law.
South Carolina's ordinance of secession from December 1860 stated that nullification attempts by the northern states were a cause of South Carolina's secession from the union: "an increasing hostility on the part of the non-slaveholding States to the institution of slavery, has led to a disregard of their obligations, and the laws of the General Government have ceased to effect the objects of the Constitution. The States of Maine, New Hampshire, Vermont, Massachusetts, Connecticut, Rhode Island, New York, Pennsylvania, Illinois, Indiana, Michigan, Wisconsin and Iowa, have enacted laws which either nullify the Acts of Congress or render useless any attempt to execute them. In many of these States the fugitive is discharged from service or labor claimed, and in none of them has the State Government complied with the stipulation made in the Constitution...Thus the constituted compact has been deliberately broken and disregarded by the non-slaveholding States, and the consequence follows that South Carolina is released from her obligation."
The Civil War put an end to most nullification attempts. Nullification relied on principles of states' rights that were viewed as no longer viable after the Civil War.[66][67][68]
Nullification and interposition resurfaced in the 1950s as southern states attempted to preserve racial segregation in their schools. In Brown v. Board of Education, 347 U.S. 483 (1954), the Supreme Court decided that segregated schools were unconstitutional. At least ten southern states passed nullification or interposition measures attempting to preserve segregated schools and refusing to follow the Brown decision. The advocates of these nullification and interposition measures argued that the Brown decision was an unconstitutional infringement on states' rights, and that the states had the power to prevent that decision from being enforced within their borders.
The Supreme Court explicitly rejected nullification in the case of Cooper v. Aaron, 358 U.S. 1 (1958). The state of Arkansas had passed several laws in an effort to prevent the integration of its schools. The Supreme Court, in its only opinion to be signed by all nine justices, held that state governments had no power to nullify the Brown decision. The Supreme Court held that the Brown decision and its implementation "can neither be nullified openly and directly by state legislators or state executive or judicial officers nor nullified indirectly by them through evasive schemes for segregation whether attempted 'ingeniously or ingenuously.'"[69] Thus, Cooper v. Aaron directly held that states may not nullify federal law.
The Supreme Court rejected interposition in a similar context. The Supreme Court affirmed the decision of a federal district court that rejected Louisiana's attempt to use interposition to protect its segregated schools. The district court found that interposition by the states is inconsistent with the Constitution, which gives the power to decide constitutional issues to the Supreme Court, not the states. The court held: "The conclusion is clear that interposition is not a constitutional doctrine. If taken seriously, it is illegal defiance of constitutional authority. Otherwise, 'it amounted to no more than a protest, an escape valve through which the legislators blew off steam to relieve their tensions.' . . . However solemn or spirited, interposition resolutions have no legal efficacy." Bush v. Orleans Parish School Board, 188 F. Supp. 916 (E.D. La. 1960), aff'd 364 U.S. 500 (1960).[70] The Supreme Court affirmed this decision, thus holding that interposition cannot be used to negate federal law.
In theory, nullification differs from interposition in several respects. Nullification is usually considered to be an act by a state finding a federal law unconstitutional, and declaring it void and unenforceable in that state. A nullification act often makes it illegal to enforce the federal law in question. Nullification arguably may be undertaken by a single state.[71]
Interposition also involves a declaration that a federal law is unconstitutional. There are various actions that a state might take to "interpose" once it has determined that a federal law is unconstitutional. In the Virginia Resolutions of 1798, Madison did not describe the form or effect of interposition. But two years later in the Report of 1800, Madison described a variety of actions that states might take to "interpose": communicating with other states about the unconstitutional federal law, attempting to enlist the support of other states, petitioning Congress to repeal the law, introducing Constitutional amendments in Congress, or calling a constitutional convention. Madison did not argue that a state could "interpose" by legally nullifying a federal law and declaring it unenforceable. Madison contemplated that interposition would be a joint action by a number of states, not an action by a single state. Interposition is considered to be less extreme than nullification because it does not involve a state's unilateral decision to prevent enforcement of federal law.
In practice, nullification and interposition often have been confused, and sometimes have been used indistinguishably. John C. Calhoun indicated that these terms were interchangeable, stating: "This right of interposition, thus solemnly asserted by the State of Virginia, be it called what it may — State-right, veto, nullification, or by any other name — I conceive to be the fundamental principle of our system."[72] During the fight over integration of the schools in the south in the 1950s, a number of southern states passed so-called "Acts of Interposition" that actually would have had the effect of nullification.[73]
As noted above, the courts have rejected both nullification and interposition.
States sometimes have taken various actions short of nullification in an effort to prevent enforcement of federal law. While nullification is an attempt to declare federal law unconstitutional and to forbid its enforcement within the state, some other actions by the states do not attempt to declare federal law invalid, but instead use other means in an effort to prevent or hinder enforcement of federal law.[74]
Nullification should be distinguished from the situation in which a state brings a lawsuit to challenge the constitutionality of a federal law. A state may challenge the constitutionality of a federal statute by filing a lawsuit in court seeking to declare the federal law unconstitutional. Such a lawsuit is decided by the courts, with the Supreme Court having final jurisdiction. This is the accepted method of challenging the constitutionality of a federal statute.[75] This is not nullification, even if the courts uphold the state's position and declare the federal statute unconstitutional. The theory of nullification is that the states have the unilateral power to determine the constitutionality of federal laws, and that a state's determination of unconstitutionality cannot be reviewed or reversed by the courts. Thus, nullification involves a declaration by a state that a federal statute is unconstitutional and cannot be enforced within the state. Under the theory of nullification, such a declaration by a state is final and binding, and cannot be overruled by the courts. On the other hand, when a state files a lawsuit in court challenging the constitutionality of a federal statute, the decision on constitutionality is made by the courts and ultimately can be decided by the Supreme Court, not by the state legislature or state courts. Because such a lawsuit recognizes the authority of the Supreme Court to make the ultimate decision on constitutionality, it is not a use of nullification.
As noted above, the Supreme Court indicated in Prigg v. Pennsylvania, 41 U.S. 539 (1842), that the states cannot be compelled to use state law enforcement resources to enforce federal law. The Supreme Court reaffirmed this principle in cases such as Printz v. United States, 521 U.S. 898 (1997) and New York v. United States, 505 U.S. 144 (1992), which held that the federal government may not enact a regulatory program that "commandeers" the state's legislative and administrative mechanisms to enforce federal law. States therefore may refuse to use their legislative or administrative resources to enforce federal law. This should be distinguished from nullification. States that withhold their enforcement assistance, but do not declare the federal law unconstitutional or forbid its enforcement by the federal government, are not declaring federal law invalid and therefore are not engaging in nullification. As Prigg held, the federal law still is valid and federal authorities may enforce it within the state. The states in this situation, rather than attempting to legally nullify federal law, are attempting to make enforcement of federal law more difficult by refusing to make available their legislative and administrative resources.[76]
Some states have legalized acts that are prohibited by federal law. For example, Colorado and Washington legalized recreational marijuana use under state law in 2012. This should be distinguished from nullification. Whether an act is legal under state law does not affect the legality of that act under federal law. An act may be legal under state law, and at the same time illegal under federal law. A state that legalizes an act under state law, but does not declare invalid federal law regarding that act, is not engaging in nullification. The federal law making that act illegal still is valid and may be enforced by the federal government. Thus, the states that have legalized marijuana use have not attempted to declare that federal marijuana laws are invalid or unenforceable. Rather, federal marijuana laws still are valid and enforceable, even in states that have made marijuana legal under state law. This is not a use of nullification because the states are not challenging the constitutionality of federal law, and they are not attempting to prevent enforcement of federal law within the state.[77] Thus, legalization of marijuana is not an act of nullification.
However, for practical purposes, the federal government lacks the resources to enforce its marijuana laws on a large scale, so the legalization of marijuana under state law significantly reduces the ability of the federal government to enforcement of the marijuana laws. This coupled with the attorney general's statement that the federal government will not intervene[78] if following certain guidelines laid down by the attorney general makes marijuana de facto and de jure legal on a state level, and de facto legal but de jure illegal on a federal one.
(help) The remaining four states (North Carolina, South Carolina, Georgia, and Tennessee) did not respond to the Kentucky and Virginia Resolutions.|title=
(help)Wikisource has the text of the 1911 Encyclopædia Britannica article Nullification. |


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CHECK RATES From 77 USD (73 reviews) Sebring, Florida, United States With its central location, Four Points By Sheraton Sebring - Chateau Elan Hotel is within easy reach of most tourist attractions and business addresses in Sebring.. CHECK RATES From 76 USD (63 reviews) Sebring, Florida, United States At the Residence Inn by Marriott ? of Sebring you will find community friendly service and a healthy way to relax for central Florida Anglers, Golfers, Race fans and.. CHECK RATES From 79 USD (34 reviews) Sebring, Florida, United States Our Quality Inn and Suites is in North Sebring is convenient to both East of West Florida coasts just 75 minutes away. Come see our new designer lobby with jumbo plasma.. CHECK RATES From 96 USD (17 reviews) Sebring, Florida, United States The Holiday Inn Express Hotel - Sebring offers the newest and finest accommodations in Sebring, Florida. Our hotel is conveniently located minutes from downtown Sebring.. CHECK RATES From 68 USD (7 reviews) Sebring, Florida, United States NOBODY treats guests better -- FREE High-Speed Wireless Internet in every guest room, FREE deluxe continental breakfast, 5 FREE premium movie channels, 6 FREE dedicated.. CHECK RATES From 87 USD (3 reviews) Sebring, Florida, United States Only a mile from Lake Jackson, the La Quinta Inn so go ahead and seal that deal! Take a refreshing dip in the year-round, outdoor, heated pool and Jacuzzi; get the.. CHECK RATES (21 reviews) Avon Park, Florida, United States The Econo Lodge Sebring is perfectly located only eight miles from Highlands Hammock State Park. The Sebring International Raceway and South Florida Community College.. 10. Reeds Motel CHECK RATES (0 reviews) Avon Park, Florida, United States Reed's Motel since 1957. Our modernized, spacious rooms prove no detail was spared in the renovation of this landmark historic motel. Southern hospitality and charm..
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Yes, strings attached: Goffstown land in limbo
On Monday afternoon before the selectmen's June 24 meeting, property owners Raymond and Vivian Blondeau sent a letter to the board saying the donated land must be used for town or community purposes only, not commercial use.
In closing, the Blondeaus said they are open to discussing the precise terms of this restriction with the town.
"We hope this won't derail things and we can move forward," said Adams. "Our understanding, it was no strings attached and the town would pull a committee to examine the possibilities and either use the parcels for municipal use or swap for other parcels."
Now, the board may have to hold more public hearings on the issue, which could delay the decision to accept the property by six or more weeks, Adams said.
The Board of Selectmen may discuss the matter at its next meeting on Monday, July 1, at 6 p.m. at Goffstown Town Hall, Room 106.
Contact Information
The Goffstown News
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Neighborhood News publications can be found at a newsstand near you here.
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Fax: 603-206-7801
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From Wikipedia, the free encyclopedia - View original article
Sian Williams | |
Born | Sian Mary Williams 28 November 1964 Paddington, London |
Nationality | Welsh |
Occupation | Journalist, presenter |
Notable credit(s) | BBC Breakfast Your Money Their Tricks |
Spouse(s) | Neale Hunt (m. 1991–2001) Paul Woolwich (m. 2006) |
Children | 4 |
Sian Williams | |
Born | Sian Mary Williams 28 November 1964 Paddington, London |
Nationality | Welsh |
Occupation | Journalist, presenter |
Notable credit(s) | BBC Breakfast Your Money Their Tricks |
Spouse(s) | Neale Hunt (m. 1991–2001) Paul Woolwich (m. 2006) |
Children | 4 |
Sian Mary Williams, ([ˈʃɑn]; born 28 November 1964) is a Welsh journalist and current affairs presenter.[1][2] From 12 January 2001 to 15 March 2012, she was a co-presenter of BBC Breakfast on Mondays to Thursdays alongside Bill Turnbull and before him, Darren Jordon. Williams regularly presented the News at Six and occasionally presented the News at One and the News at Ten.
Williams was born in Paddington, London, to Welsh parents, and raised in Eastbourne, East Sussex.[2] Her mother, Katherine Rees from Llanelli, had moved to London to become a nurse.[2][3] Williams' father was from Swansea, and his family had been farmers in Glamorgan, south Wales.[2][3] She gained a BA in English and History from Oxford Polytechnic (now Oxford Brookes University) and went on to study critical journalistic writing at the University of Rhode Island in America.[4]
Prior to her career in television journalism, Williams spent over a decade with BBC Radio after joining the corporation in 1985. She worked on BBC Local Radio in Sheffield, Leeds and Manchester before becoming a producer and reporter in Liverpool, and later joining a national spoken word network, BBC Radio 4, as a producer on The World at One and PM programmes. Williams spent the next few years reporting and editing news programmes on the station, and also on BBC Radio 5 Live.[5][6]
Williams' first job in television news was when she joined digital rolling news channel BBC News 24, which was soon to launch, as an output editor. During screen tests for potential presenters, one applicant became unwell and Williams was asked if she would be willing to audition for the role. [6][7] When she did, producers were so impressed that they offered her the position alongside Gavin Esler presenting from 4pm to 7pm, one of the prime slots on the channel.[7]
She remained with the channel for nearly two years before joining the Six O'Clock News in 1999 as their Special Correspondent.[5] During this time she also began filling in for the programme's presenters, Huw Edwards and Fiona Bruce, and during 2001 to 2002 she presented the Six O'Clock News on Fridays while Fiona Bruce was on maternity leave, as well as regularly presenting the national news bulletins on BBC One at weekends.
She joined the BBC's Breakfast programme in 12 January 2001 as a relief presenter, initially presenting on Friday-Sunday alongside Darren Jordon, to cover for main presenter, Sarah Montague, and then later with Jeremy Bowen, to cover for Sophie Raworth.[7] She also regularly deputised on the Six O'Clock News and the One O'Clock News during this period. In 2004, Williams covered for Raworth on the Six O'Clock News during her maternity leave, co-presenting with George Alagiah, and the following year, reported from Sri Lanka and Thailand on the 2004 Indian Ocean earthquake and from Pakistan on the Kashmir earthquake.[7]
In May 2005 she was confirmed as the main female presenter of BBC Breakfast, presenting initially alongside Dermot Murnaghan and since January 2008 with Bill Turnbull on Mondays to Thursdays. Williams left Breakfast on 15 March 2012 due to the programme's relocation to Salford. She joined BBC Radio 4 to co-present Saturday Live for a while.[8] In addition to this Williams will be a relief presenter for all the main BBC One News bulletins.
Other television credits include for BBC Wales the One Show, with Aled Jones, and the Big Welsh Challenge, where she spent a year learning Welsh as well as presenting BBC One daytime programmes including Now You're Talking and City Hospital. In 2010, Williams reported for Watchdog.[9] In 2013, Williams hosted Your Money Their Tricks with Nicky Campbell and Rebecca Wilcox. Williams also presented a three-part interview series for BBC One Wales titled "The Sian Williams Interview". She interviewed Tanni Grey-Thompson, Suzanne Packer and Siân Phillips in the three programmes respectively.[10]
Williams was the President of TRIC (Television and Radio Industries Club) for 2008–09 and supported two charities during her year of office. She became an Honorary Fellow of the University of Cardiff in July 2012.[11] In 2014, she began studying for a masters degree in Psychology at the University of Westminster, specialising in the effects of post-traumatic stress disorder on journalists and reporters.[12]
In February 1991 Williams married Neale Hunt, a former director of advertising firm McCann Erickson, London. Their two sons were born in 1991 and 1994.[citation needed] After the end of this marriage Williams married Paul Woolwich in early 2006 and gave birth to her third son in October 2006, for which she disclosed in an interview to promote blood donation that she received two litres of blood as a result of complications from the birth.[6] Williams gave birth to a daughter in March 2009. Williams, a recreational runner, suffered from hyponatraemia during the 2001 New York City Marathon and spent several days recovering in the hospital. This experience caused her to give up running for several years before taking up the sport again. She completed her second marathon, the Virgin London Marathon in 2013.[13]
Taking part in the BBC Cymru Wales TV series Coming Home in November 2010, Williams discovered she was the first member of her family to have been born outside Wales in all the 350 years of her known family tree.[3] During the programme Williams said "When I started this journey, I felt Welsh, but I couldn't really understand why. Then I look at my family tree and every single person beyond me is Welsh going back hundreds and hundreds of years. Now I think, actually, it's not about where you're born, it's about where generations of your family come from. I can now proudly say I'm Welsh, it doesn't matter that I was born in Paddington, I'm Welsh, yes I am, and very proud of it too." [2]
Media offices | ||
Preceded by Natasha Kaplinsky | Main Presenter: BBC Breakfast 2005–2012 | Succeeded by Susanna Reid |
Preceded by Natasha Kaplinsky | Deputy Presenter: BBC News at Six 2007–2008 | Succeeded by Fiona Bruce |


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Paschal Golf Club
With its first swing of the tee in 1917, Paschal Golf Club is a public course that has played host to legions of golf lovers, weekend warriors, and even the legendary Arnold Palmer. The verdant nine-hole course can be played from four different tee boxes, offering a challenge for golfers of all skill levels. Golfers can loop the nine-hole course twice, allowing them to correct errant shot selections on difficult holes such as the eighth, which presents a forced carry over an elongated pond to reach the green, a heavily fortified zone guarded by bunkers on both sides and another water hazard behind. The tranquil Richland Creek trickles through the course, treating eyes to frequent sightings of wildlife such as deer, birds, and grazing golf carts. A clubhouse, snack bar, and pro shop cater to players as they unwind or stock up on gear, and a putting green warms up pendulums before rounds.:m]]
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Planning in Edmonds takes many forms and is undertaken by all city departments spanning virtually all functional areas. The city's Planning Division (within the Development Services Department) maintains a long range planning function which serves as a resource for these planning activities, but many of the specific plans are directly overseen by the various departments that have the most expertise in a specific functional area. For example, the Public Works Department oversees the planning for utilities and transportation, while the Parks, Recreation & Cultural Services Department completes plans for those areas.
To find out more about planning in Edmonds, choose a category below:
2015 Comprehensive Plan Update
Under state law, cities are required to do a major review and update of their plans based on a state schedule. Edmonds' major update is due to the state by mid-2015.
Much of the current update work is focused on updating data (for example, using current Census data) and making minor changes and clarifications without changing the plan's overall direction. The 2015 update also includes a major update of the City's Transportation Plan. More information can be found here...
Comprehensive Plan
Many of the city's long-range planning activities fall under the Growth Management Act (GMA) and are encompassed in the City's main Comprehensive Plan document (5.8 MB) which contains the following plan elements:
The plan also includes a number of specific functional plans — contained in separate documents — such as:
For land use designations and patterns, you should also consult the Comprehensive Plan Map (1.7 MB). You may also want to explore other maps and studies that are available for reference.
Five Corners / Westgate Commercial Centers
The City of Edmonds has been working with a team of faculty and students from the University of Washington's Green Futures Lab — with assistance from the Cascade Land Conservancy — to create plans for expanding the role of neighborhood centers to serve as more active and vital parts of the community. The first two neighborhood commercial areas to be addressed are Westgate and Five Corners. The project will develop concepts that exemplify sustainable approaches for redevelopment in suburban cities and preparation of a Special District Plan for each of the two neighborhood commercial areas. View information on this project here.
4th Avenue Cultural Corridor
Linking key activity centers within downtown Edmonds is an important priority for the city. The city adopted a new master plan for the 4th Avenue corridor linking the Edmonds Center for the Arts with the downtown retail core in 2006, and followed that up with a design implementation and funding plan for the renamed "4th Avenue Cultural Corridor" in 2009. View information on this project here.
Highway 99 Enhancement
Beginning in 2004 with an enhancement study (3.2MB ) and market analysis (3.9MB ), the city has been working to identify and promote differentiation and identity along Highway 99. More recent projects have focused on updating codes to streamline permitting and simplify regulatory processes as well as installing artistic/identity elements. View more information on this project here.
Puget Sound Regional Council
The City of Edmonds is located within Snohomish County, and is a member organization of the Puget Sound Regional Council (PSRC). PSRC performs regional transportation, growth management, and economic development planning including:
Snohomish County Tomorrow
Within Snohomish County, the city participates in Snohomish County Tomorrow, a collaborative inter-jurisdictional forum consisting of representatives from the county, each of the cities, and the Tulalip Tribes.
SCT's mission is to adopt a publicly shared vision, including goals and policies, to guide effective growth management and to preserve Snohomish County's unique quality of life. SCT 's primary function is to oversee the Countywide Planning Policies (CPPs) which are written policies used to establish a countywide framework from which the county and city's comprehensive plans are developed.
The City of Edmonds is updating its Comprehensive Plan in 2015. Find out more here...
The City of Edmonds won an Association of Washington Cities Municipal Excellence Award for its Sustaining Edmonds program. Find out more here.
Click here for information on the Neighborhood Plans for Westgate and Five Corners.


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SDPD swarm the scene of a car crash into a Coin Laundry in the Midway District.
Photo by Gail Powell
Posted August 14, 2012
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Follow Weeds
Watch Weeds Season 7 Episode 13 online via TV Fanatic with over 6 options to watch the Weeds S7E13 full episode. Affiliates with free and paid streaming include Amazon, iTunes, Vudu, YouTube Purchase, Xfinity, and Showtime Anytime.
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Episode Details
Silas turns the tables on Nancy on the season seven finale. Doug, meanwhile, schemes to keep his hedge fund career alive.
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Weeds Season 7 Episode 13 Quotes
Heylia: Get out.
Nancy: Heylia, it was all a big misunderstanding. None of it was Silas's fault. Please don't cut him off.
Heylia: I learned that you and your son are one in the same. And I've had enough.
- Permalink: Get out. Heylia, it was all a big misunderstanding. None of it...
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Dean: OMG we're being mugged by Sarah Palin.
Heylia: We're being jacked.
Dean: There's a difference?
- Permalink: OMG we're being mugged by Sarah Palin. We're being jacked. T...
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text: This was a shirt without a home. My pal Steve came up with this gem, but without a site to sell it, this hilarious and fitting tribute to an iconic voice went criminally undersold. Hoping to give this great design the attention it deserves, Steve and I decided join forces to get this shirt to the masses. This powder blue Gildan shirt is made of 100% heavy cotton.


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At Blick, we love those "light bulb" moments when an idea inspires and the creative juices start to flow. Geared for a wide variety of age and skill levels, we offer hundreds of Lesson Plans designed to meet the National Standards for Visual Art Education and bring the value of creativity to any teaching experience. All original. All free. Help yourself! Click here to download our new Spring 2014 Lesson Plans Booklet |
Tissue Vases from Recycled Containers |
Grade Level |
A lesson plan from AMACO®. Students select their favorite photo and design a custom picture frame to display it. After the bisque firing, the picture frames will be painted and decorated using the new AMACO® Teacher's Choice and Teacher's Palette low-fire glazes. |
Navajo-Inspired Bottles - 2 Projects by Mayco® Colors Navajo pottery tended towards functional ware and minimalist design and decoration. Pinch, slab and coil construction methods were used to make bowls and bottles, for carrying water and food consumption. In these projects students will use their knowledge of Navajo symbols to create Navajo inspired designs on a clay bottles. |
4 – 8 |
Peace Windows: in the style of Marc Chagall's stained glass Late in his career, artist Marc Chagall produced a number of paintings in glass with colorful, dream-like images symbolizing peace, love, tolerance and faith. In reality, Marc Chagall's life was filled with tragic events and the world he lived in was anything but peaceful. In light of this fact, students can begin to understand an artist's ability to share healing, inspiration and encouragement, using "peace" as a theme. |
Polynesia is a large area in the central and southern Pacific Ocean containing more than 1,000 scattered islands. Many of these islands share cultural similarities among the various groups of people who live on them, especially in terms of their mythologies. Stories often include gods or deities that rule nature. In addition to the oral tradition, "god sticks" are made to represent these deities, usually in the form of a human face or figure wrapped in bark cloth or cord. |
3 – 8 |
Printing creative T-shirts and fabrics doesn't always require stencils and screens — students can easily design their own giant stamps and paint them any way they want. Even if each shirt displays the same message, each will be a completely unique work of art! This process is perfect for group settings — schools, camps, daycare centers, clubs, family reunions and special events — but it is also ideal for countless home decorating and craft projects. |
Stencils and repeated patterns have been used in painting as long ago as 9,000 years, when early humans placed their hands against cave walls and outlined them in charcoal or paint. In this lesson, even a stencil made of basic shapes can be effective. Each stencil can be used repeatedly, and by changing oil pastel color, overlapping images, or using only a part of an image, the result is a cohesive composition that has depth and color fusion. |
4 – 12 |
Molding, casting, sculpting, painting and monoprinting — this simple project pulls all of these together into one low-relief sculpture that demonstrates the elements of texture and color. Texture is defined in clay by pressing objects in or sculpting with tools. Next, the clay is painted with watercolor and covered with papier mâché, which lifts the color as it dries, absorbing it directly into the casting. |
3 – 12 |
In the 1960's, Frank Stella became known for his minimal geometric paintings of concentric squares that used color to create visual movement. Each concentric square of color related to the next, whether they were harmonic or contrasting colors. In this lesson plan, students consider color relations and "paint" a Stella-style work with colored masking tape, |
4 – 12 |
The first thing children learn when learning to draw a face or a figure is to view each part as a basic shape. This project approaches sculpture in the same way. Using geometric Styrofoam shapes, students build a bust or torso. The finished result resembles a simplified version of something you might have seen from Picasso or one of the other Cubist painters, only in three dimensions. This project is a good introduction to sculpture for young students. |
Encourage students to design a personal and stylized signature or "tag." The tag can be a given name, a nickname or something they've made up to represent themselves. This school version of graffiti shows students that lettering is not only important in communicating, but that it can also be an artistic expression. |
1 – 6 |
Itajime Shibori is a technique for folding, clamping and dyeing paper or fabric resulting in beautiful designs – very similar to tie-dye. The folds and clamps keep the dye or ink from penetrating fully in certain areas making patterns and giving a dimensional appearance on a flat surface. This project is a great way to teach students the scientific concept of diffusion and color mixing. |
3 – 12 |
Drawing on the reverse side of a matte sheet of acetate, students create "windows" into the work of a chosen artist, using similar colors, subject matter and style to describe the artist's focus. See if the class can guess which artists are represented on each student's "palette." |
Students select a commercial business and consider images, symbols and colors that will best represent the company. The repeated "wallpaper" patterns are made with a stamp designed and carved by the students. This fun project will help children understand how simple images communicate a message, whether in business or elsewhere. |
4 – 6 |
A great collaborative art project. Each student weaves a colorful pot holder then stitches it with the class pieces for a quilt or wall hanging. The project is bright, colorful and fun. It is also a great exercise in dexterity and cooperation. |
2 – 6 |
Unlock the secrets of an ancient Egyptian pyramid with this easy-to-construct box that opens to reveal "treasure" inside. When closed, the outside walls are held in place with a clay disk. Remove the disk and open the pyramid to reveal what's inside. Younger students can make artifacts from clay to place inside. Older students may be challenged to learn the inner parts of the pyramids and add paper pages to write about and illustrate their discoveries. |
3 – 8 |
A stilt house is constructed on posts above water, allowing people to live in areas that have very little dry land. Found in many coastal and wetland regions of the world, stilt houses can be ultra modern or very basic. In this lesson, students build a stilt house while being mindful of the area where the house might exist and the lifestyle of its inhabitants. |
3 – 7 |
A few simple geometry skills and a little time spent making paper rolls is all that goes into this eye-catching art paper bowl. It's a great way to recycle materials or use up scrap paper, and your students will learn about repeating patterns and design rhythm as they place each tube of paper on a piece of self-adhesive film. |
3 – 12 |
Spanish painter Joan Miró is known for his playful art. Although he was a world renowned artist, his work gives the impression it could have been created by a child. Miró was interested in reducing characters to their simplest forms and using very basic, bright colors. He felt some of the best ideas were inspired by the simplest things. In this project, students attach and weave Chenille Stems onto stitchery canvas to make simple shapes and designs. |
The easiest way to make colorful, three-dimensional paper flowers! Even young children will enjoy painting carnation-like blooms and creating full bouquets for Mother's Day gifts, May Day celebrations, a Cinco de Mayo fiesta or a Hawaiian Luau. Each flower costs just pennies to make. Because the watercolors blend together and form new hues, painting each bloom is a good way to illustrate color mixing. |
There's more to "deconstructing" a book than just altering the pages. In this project, deconstructing means changing the object from a book to a sculpture. The tools are very basic — scissors, glue, paper punches and a desire to experiment! |
3 – 12 |
Inspired by the sequinned banners of Haiti, students will make a banner of their own design using a variety of glittery, sparkly, shiny materials and brilliant colors. Use this opportunity to learn about the art and history of Haiti, a unique blend of African, French, Spanish and Native Caribbean cultures. |
This project should be considered "Part Two" of our Fiber Fusion lesson plan. This project helps students stretch their imaginations and further develop a |two-dimensional artwork they've created by turning it into a three-dimensional sculptural piece. |
7 – 12 |
Making Elemental Drawing Materials Blick Art Materials was not around to provide art supplies 32,000 years ago, but, somehow, the earliest humans found a way to draw and paint on cave walls using materials made from basic elements all around them. Similar to the Paleolithic era, students will make their own drawing tools by transforming simple materials from the classroom, and then using them to communicate through images. |
Students often take furniture for granted, yet how much do they really know about the furniture where they eat, sleep and study? Have they ever looked at these objects and considered them art? Or considered that an artist may have had a hand in creating them? This awareness exercise will help students learn to "see" the things surrounding them. |
7 – 12 |
"Mise-en-Scéne" is a French expression referring to the physical setting of a stage performance. The background scenery is designed to help tell a story in a play or on film by creating an environment and setting the mood. Students select a chapter from a book, an act from a play, a song or a poem, and then create a 3-dimensional setting for it. |
Beginning in the early 1880s, the "Art Nouveau" style flourished in all forms of art. Beautiful pottery was mass-produced during this era, especially in the form of decorative tiles. Tube lining — a technique in which a design outline was created first and then filled in with color — is the definitive look of Art Nouveau. If kiln-glazed ceramics are not an option for your environment, this project is a way to produce glossy, hand-painted tiles that look like the real thing. |
The production and commerce of decorated silk fabrics began thousands of years ago in China. This project introduces fine-mesh polyester as a silk-like fabric for painting. Form a wire shape as a support and paint with transparent liquid acrylic color. Finished pieces are flexible and may be heat-set for outdoor display. |
3 – 12 |
Exercising the imagination helps children develop problem-solving skills. This lesson incorporates students' artistic skills to sculpt finger puppets out of clay and to use their imaginations to make up a story for their characters. The stories do not have to be written but can be told freely. Create a theatre in the classroom — a table with a cloth over it makes a great stage for Wee Puppets. This project is a wonderful interactive classroom event. |
In the 1800s, many homes were decorated with "Penny Carpets", made from miss-matched fabric cut into circles by tracing around a penny. Patches were then layered and stitched together to make a large piece. Students create a Penny Carpet with fabric that they design themselves using monoprinting techniques and fabric paint. Each section is sewed to felt swatches, then joined to make a larger piece of art. |
3 – 12 |
Art 2 Infinity: Two projects incorporating Mirror Board Artists through the ages have used reflective surfaces to define and alter perspective, create symmetry and "bend" reality. Mirrors have been a tool for creating art, the subject matter and the art itself. Here are two project ideas for using metallic film to capture light and create intriguing illusions: "Kaleidoscope Paintings" and "Infinity Boxes". |
A whimsical makeover for discarded dishes! Inexpensive, diverse and unmatched pieces from thrift stores, garage sales, etc. are recycled into contemporary sculptures in this project. Pieces of unprimed canvas are layered and glued to the surface, then painted with Blick Matte Acrylic color. Center the design around a theme, as Judy Chicago did in the 1970's with "The Dinner Party" or design a place setting for a particular artist. |
5 – 12 |
Students of all ages can mimic mosaic artisans throughout history with these easy tile-making and "grouting" techniques. Clay tiles are glued to a firm backboard and grouted with acrylic paint. This project is safe and simple enough for younger students and those with special needs. |
The magic is in the color! Wax Pastels adhere to the slick surface of tooling foil and stay there. Students explore tools and texture plates to create designs in lightweight metal, then, using simple page-binding techniques, assemble a lovely hardcover book to use for notes, sketches, journaling, scrapbooking or photos. |
3 – 8 |
Geometric patterns occur in rich profusion throughout Islamic Cultures. This lesson is an invitation to look at the history and meaning behind patterns and view the work of a contemporary Iranian artist. Students design and assemble a reflective mosaic pattern using metallic papers on adhesive film. Easy and tidy...no glue! |
What we think of as "quilts" today — pieces of fabric sewn together to form blocks that collectively make a whole — did not become popular until the mid 19th century. Making quilts was a means of "recycling" fabric from clothing that was no longer usable. In this lesson plan, students make a quilt block using paper and glue rather than fabric and stitching. It's a great way to recycle materials and illustrate a number of design principles — rhythm, pattern, balance and unity. |
3 – 12 |
Rather than traditional pages, the interior of these "books" will hold objects collected by students. An "art box" book could contain samples of texture, color, form, and line or other examples of design elements or styles. Or a more personalized box "about me" could hold a collection of tiny photos, poems and small keepsakes. |
3 – 12 |
Around the 1920s, a movement in modern art began in Russia as a group of artists began constructing sculpture for an industrialized world. As new technology produced strong, shining surfaces of glass, steel and plastic, Constructivists pioneered the use of modern, mechanical materials in art. This project weaves a variety of classroom-friendly "metals" — papers, foils and wires — into relief and three-dimensional art. |
5 – 12 |
Quilt-making spans multiple centuries and cultures. It can teach math skills, record history, recycle cast-off materials and encourage cooperative efforts within a group...just for a few ideas! This lesson looks at the story quilts of Faith Ringgold. She surrounds her narrative paintings with a quilted border, creating stories in color, texture, and pattern. Students select their own story to illustrate, then paint fabric using watersoluble pastels and watercolor. |
This project transforms traditional basketry into a contemporary fine craft. Paper Coiling Core is shaped and glued in layers in the same manner as a clay coil pot is constructed. Vibrant and fluid Blick Liquid Watercolors can replicate patterns from the Papago, Navajo, and Apache cultures of Native America and Northern Mexico, or painted in contemporary, abstract, or representational styles. |
5 – 8 |
When one hears the name of Alexander Calder, the picture of kinetic hanging mobiles immediately comes to mind. These were only a portion of Calder's vast body of work — he also painted and created stationary pieces called "stabiles." Often, they resembled his mobiles — but without moving parts. In this lesson, students will create a "stabile" using Taskboard — a new, natural, wood-based medium used by architects and 3-D designers to create models. |
5 – 12 |
Button Bracelets allow children to design a wearable piece of art with lots of color and texture — a new twist on craft bracelets! A leather wristband is used as a base and takes on a very different look when buttons and colorful wire are added. |
3 – 6 |
This project demonstrates the physical process of osmosis. Water-based markers are diluted by filtering water through an ordinary wet wipe. The flow of the color is slowed and channeled by the presence of oil and alchohol in the wipe, creating random and interesting tie-dye-type patterns. Educational...and really fun to watch! |
The inside of the Earth holds hidden secrets very close to us, so dig a hole to uncover layers of mystery! A hole just 1" deep will show a very small example of soil strata or layers – including rocks, shells, fossils, geodes, water, oil and coal. This art project is based on geology but need not be scientifically accurate as students creatively incorporate texture and line. |
1 – 6 |
Native American Story Necklaces One of the many rich crafts produced within the Native American culture is a "fetish," or story necklace, designed to illustrate history and legend with carved creatures representing spirits, animals or ancestors. |
Persian and Navajo Rug Bookmarks This lesson plan explains two diverse and beautiful style of textiles: Persian carpets and Navajo rugs. Similar colors and geometric shapes are two common elements of both. |
4 – 8 |
Turn a black and white photo into a "riot" of color! Tinting is a simple technique that challenges students of all ages to pay attention to detail, and even young children can do it with success. In this project, class pictures are enlarged, printed in black-and-white and tinted. The use of non-traditional colors is encouraged. |
Collect and recycle product wrappers for a "green" art project worthy of good-citizen attention! Students save and trade wrappers to make a paper background, then choose words and phrases related to their "rapper" collage and cut them from thin foam to create a printing plate. "Rapper" Art is an easy process for making posters, book covers and signs in multiples. |
This is a whimsical introduction to nutrition and graphic design that invites students to make up an imaginary soup. National studies indicate that children eat about anything if the advertising is "crazy" or attractive to them, including vitamins and vegetables. Now its students' turn to entice peers to "buy" their soup! Anyone for Alligator Soup? |
Tissue Vases from Recycled Containers Turn recycled bottles or cups into "frosted glass" vases! This project allows students to work in three-dimensional designs as they build high-relief mini-murals "in the round." Younger students may create simplified and abstract work with white tissue paper and watercolors. Older students may achieve very sophisticated and detailed vases. Materials are quite inexpensive! |
This easily constructed project offers an exploration of texture, line and color – key elements of design. Younger children may take a more abstract approach with emphasis on texture and color. Older students will find the burlap easy to pull and the weave easy to manipulate, creating holes and lines. Subject matter such as buildings, landscapes and abstract designs are adaptable to varying grade levels. |


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Learn to make all the interesting DIY projects you see on Pinterest! First up is beaded stretch bracelets.
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The schedules are finished! The Volunteer Google Calendar has been shared with all of you. Check your email!
If anyone is having difficulty locating your shifts, email Summer.
This is your absolute LAST CHANCE to attend a mandatory Summer Volunteer Info Meeting! If you want to volunteer at the library this summer and haven't been to one of the April meetings, this is it for you. You don't come to this meeting, you don't get to volunteer.
Who's interested in Volunteering at the library this summer?
If that's you, make sure you attend ONE of our mandatory meeting. We'll be going over everything you need to know and distributing the application.
Finals are next week! Who's stressed out, exhausted and starving? Time for a study break!
If you're studying at the library, stop by our Finals Cafe in the Activity Room on:
Do you have some down time in December and January?
Do you need to earn some service hours?
Do you just like to help out?
Yes? Perfect - because I have a job for you! All thoughout December and January we're going to have volunteer opportunities for teens. The Stuffed Animal Sleepover, Teen Techs, Book Buddies, Craft Swap, MLK Service Day and more!
The Teen Advisory Board chalk bombed the library sidewalks with Banned Books! Stop by, check out our street art and see how many banned books you have read!


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Raptors and Memories IThe memories is the collective knowledge of all those who had died, up and until the day you take the Test. The Test has a high fatality rate.
Few of the memory people become Riders, for that requires the ability to ride the man-eating raptors and live. Most of the apprentices fail or die. Not many memory people want to become Riders, anyway. It is a difficult, even brutal life, and only Riders can access Rider memories, for the knowledge they have is horrifying.
The Rider King had just paid his morning visit to his beloved birds of prey in the Raptor Conservatory, which is always directed by a Rider. Never mind he had just annexed the planet. After fifteen years on the throne, he still has the memories. You can only get and keep them if you're a virgin.
There is no royal family in the desert kingdom of Ummyaad. Only a memory person can be chosen monarch when the old one dies. Once chosen, he must keep the memories for another six years. Failure to do so can get him killed.
Anyway, Luc


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if this was put in a vase, and used in a video game, there would be so many disgruntled players. they'd be on the same level for weeks and never figure out the lock.
The one's who figure it out will be mind blown for weeks though. Best video game ever, they would claim.


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50 year old woman | Indianapolis, IN, USA | Seeking men 49-54 within 50 miles
Active within 24 hours
I love a good laugh. I can be intense and also laid- back. I enjoy trying new things. Family is very important to me.
I enjoy the country and its quietness, and love the city and its bustling pace. I enjoy working and being outdoors. I am patient, giving, hardworking and strive to be and do the best in all my endeavors. I enjoy family and friends. I believe in making good times happen. I hope to meet someone who loves life and wants to exprience all that life can offer. I would like him to be spontaneous and fun.
Coffee and conversation , Dining out , Gardening/Landscaping , Movies/Videos , Museums and art , Music and concerts , Exploring new areas , Performing arts , Playing cards , Playing sports , Religion/Spiritual , Shopping/Antiques , Travel/Sightseeing , Watching sports , Wine tasting
Auto racing / Motorcross, Baseball, Basketball, Cycling, Dancing, Football, VolleyBall, Walking / Hiking
I exercise 1-2 times per week.
I have Cats, Dogs
Middle of the Road
Indiana University Bloomington, Bloomington, IN
I enjoy movies, reading, theater, sporting events, gymnastics, checking out new places; restaurants, hanging out with friends. I enjoy pool, beaches,walks. I love being active and also quiet nights watching TV, listening to music, drinking wine.
I enjoy biographies, mysteries, historicals.
Her | What she is looking for | |
Appearance | ||
Height: | 5'6" (167cms) | 3'0" (91cms) to 8'11" (271cms) |
Body type: | Slender | About average |
Eyes: | Brown | No preference |
Hair: | Dark brown | No preference |
Lifestyle | ||
Smoke: | No Way | No Way |
Drink: | Social Drinker | Social Drinker |
Occupation: | Medical / Dental / Veterinary / Fitness | No preference |
Surgery Consultant |
Income: | I'll tell you later | $100,001 to $150,000, $150,001+ |
Relationship: | Divorced | No preference |
Have kids: | Yes, and they sometimes live at home (3) | Yes, and they sometimes live at home |
Wants kids: | No, but it's OK if my partner has kids | No, but it's OK if my partner has kids |
Background | ||
Ethnicity: | White / Caucasian | White / Caucasian |
Faith: | Christian / Catholic | Christian / Catholic |
CRHP was a wonderful experience for me. |
Languages: | English | English |
Education: | Associates degree | Bachelors degree |


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Maybelline Dream Wonder Powder is a new Spring 2014 product that will be a permanent product added to the Maybelline Collection. This powder is supposed to give a second skin finish with a creamy texture and a smooth flawless finish that feels like a powderless powder.
Let's take a look.


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I've often wondered and asked this question and I've never come close to a consensus. When you pass gas do you gain or lose weight?
Your gas is usually warmer than the ambient temperature and it makes its way to your nose, so I assume it rises and therefore must be as light or lighter than air. So is releasing it like letting the hot air out of a ballon?
On the other hand is the gas dense or compressed enough that you actually get lighter by releasing it?
I'm sure science could tell us but why ruin the wonder?
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Passing Gas and weight
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, Jun 21 2013 01:03 AM
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Every Animal at the Houston Zoo Has a Unique Story
Whether it's the birth of baby Asian elephant Duncan or the arrival of a rescued animal like Lilly the wombat, we celebrate every animal's story. Though each story is unique, there is one common theme: your favorite animal family receives the best nutrition we can provide, thanks in part to sustained support from thousands of donors in this community!
Read below to learn how you can be a part of our animals' stories by giving the Gift of Grub!
Lilly the Wombat
Baridi & Kamili the Masai Giraffes
Your Donation Helps Nourish 6,000 Animals
No matter the amount, every contribution provides for the well-being of our animals and the success of the Houston Zoo! With the total annual cost of feeding our animals approaching nearly $1 million, your donation is more crucial – and more appreciated – than ever.
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Call 713-533-6705 or e-mail email@example.com