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Tuesday, February 11, 2014
Aftermath of Windsor in the Federal Government: AG Holder's Memo
Citing United States v. Windsor, declaring DOMA's section 3 unconstitutional, in a Memorandum issued on Monday February 10, Attorney General Eric Holder has announced that it is the policy of the federal government to "recognize same-sex marriages as broadly as possible." Holder discussed the forthcoming memo in a speech delivered the previous weekend.
In the memo, Holder specifies that marriage recognition will extend to "same-sex marriages, valid in the jurisdiction where the marriage was celebrated to the extent consistent with the law." This shifts the marriage validity question away from domicile or residence.
Importantly, in footnote 1 of the Memo, Holder notes that the policy is limited to marriage and "does not apply to individuals who have entered into another similar relationship such as a domestic partnership or civil union, recognized under state law that is not denominated as a marriage under the laws of that state."
Holder also expresses pride in the DOJ's role in the litigation challenging DOMA, citing his 2011 letter concluding that sexual orientation classifications should be subject to strict scrutiny and that DOMA failed this constitutional test.
One of the more interesting aspects of Holder's Memo is the discussion of marital testimonial privileges. Holder directs prosecutors to apply the memo "prospectively" - - - to conduct that occurred on or after the date of the Windsor decision (and not the date of the 2011 Holder memo or the present memo).
February 11, 2014 in Current Affairs, Executive Authority, Family, Fundamental Rights, Sexual Orientation | Permalink | Comments (0) | TrackBack (0)
Sunday, February 9, 2014
Daily Read: Sara Rankin's Homeless Bill of Rights
Given that the extant constitutional rights have proven ills-suited toward recognizing the rights of homeless persons (even to have a blanket or to be fed), Professor Sara Rankin's article, "A Homeless Bill of Rights (Revolution)," available in draft on ssrn, is an important look at state constitional efforts. Rankin surveys current efforts to advance homeless bills of rights in nine states and Puerto Rico, concluding that such efforts are likely to have more of an incremental social impact than any immediate legal impact.
Rankin (pictured right) highlights the aspirational aspects of such bills, arguing
Homeless bills of rights present an important opportunity to impact American rights consciousness. The emergence of these new laws may encourage housed Americans to confront—and perhaps one day, overcome—our persistent, deeply-rooted biases against the homeless. Regardless of whether homeless advocates' ideal provisions are enacted, enforced, or implemented in the near future, even modest versions of these new laws can stake an important claim in the movement building process. After all, the U.S. Declaration of Independence and the Bill of Rights remained dormant and aspirational for years after their enactment, but like all declarations of fundamental rights, these documents set crucial goals for society to achieve over time.
Certainly, however, such laws would counteract the increasing "ciminalization" of homelessness that she discusses:
Of 234 cities surveyed by the National Law Center on Homelessness and Poverty (NLCHP), 53 percent prohibited begging or panhandling in public places, 40 percent prohibited camping in public places, and 33 percent prohibited sitting or lying down in public places. These laws authorize police to perform "sweeps" to clear public areas of homeless people. Police sweeps often result in the confiscation and destruction of personal belongings, including identification, documentation, medications, and other property of sentimental value.
Rankin's article is an important read for anyone considering the constitutional parameters of addressing homelessness.
February 9, 2014 in Fundamental Rights, Scholarship, State Constitutional Law | Permalink | Comments (0) | TrackBack (0)
Tuesday, February 4, 2014
Fourth Circuit Strikes Proof-of-Religion Requirement in Prison
The Fourth Circuit ruled in Wall v. Wade that a Virginia prison's requirement that inmates show physical indicia of their faith before participating in Ramadan violated the Free Exercise Clause.
The case arose when Wall, an inmate at the Red Onion State Prison, or ROSP, in Pound, Virginia, sought a religious accommodation to participate in Ramadan--special meals served before sunrise and after sunset. But ROSP policy required prisoners to show "physical indicia" of their faith--such as a Quran, Kufi, prayer rug, or written religious materials obtains from the prison Chaplain's office--before receiving the accommodation. Wall had none of these, because his "physical indicia" were lost when he was transferred to ROSP from another facility. So officials denied his accommodation.
Wall nevertheless skipped breakfast and concealed a portion of his meal in his cell to save until after sunset. ROSP staff discovered the food and threatened to charge Wall with possessing contraband. As the court wrote, "Faced with choosing between starvation and sanctions, Wall ate during the day and violated his religious beliefs."
Wall filed formal complaints and later sued, arguing that ROSP policy as applied to him violated RLUIPA and the Free Exercise Clause. The district court dismissed the case, but the Fourth Circuit reversed.
The court held that the policy violated the four-part test in Turner v. Safley:
First, demanding specific physical items as proof of faith will rarely be an acceptable means of achieving the prison's stated interest in reducing costs. Strict application of such a rule fails even a rational connection requirement. . . .
[Second, i]t is clear that Wall was absolutely precluded from observing Ramadan because of the defendants' actions. . . .
[Third, w]e are not satisfied that the defendants have sufficiently explained how a less restrictive policy would have imposed a significant burden on prison resources. . . .
Finally, we are satisfied that there existed "easy[] [and] obvious alternatives" to the challenged regulation.
The court ruled that Wall's rights were "clearly established," and that ROSP officials therefore did not enjoy qualified immunity.
The court also rejected the claim that Wall's case was moot in light of the Prison's changed policy. Applying the "voluntary cessation" doctrine, the court wrote, "We have no difficulty concluding that the defendants failed to meet their "heavy burden" of establishing that it is not "absolutely clear" the 2010 Ramadan policy will not be reinstated."
February 4, 2014 in Cases and Case Materials, Free Exercise Clause, Fundamental Rights, News, Religion | Permalink | Comments (0) | TrackBack (0)
Tuesday, January 21, 2014
Public-Sector Fair Share Appears to be Safe
The Supreme Court heard oral arguments today in Harris v. Quinn, the case testing whether fair-share fees for non-union in-home care providers in the Illinois Medicaid program violate the First Amendment. (Our argument preview is here.) The Court in Abood v. Detroit Board of Education previously upheld public-sector fair-share fees to support a union's collective bargaining activities in the interests of preventing free-riders on a union's activities and promoting workplace peace. But this case put Abood directly in the Court's cross-hairs, as the petitioners argued to overturn the decades-old case.
If today's arguments are any indication, that seems an unlikely result.
Still, it's not entirely clear what the Court will do with the case. For one thing, there was just a lot of confusion about it. For example, on the question whether the union's work here (in the state's Medicaid program) represented advocacy on a public matter (thus strengthening the non-members' claims), no clear position emerged. Here's an exchange between Justice Kagan and the attorney for the petitioners (the home-care workers):
Justice Kagan: But you're not objecting, I think, to the union as a whole. What you're objecting to is an individual employee having to support that activity. The scale is no different. It's an individual employee.
Mr. Messenger: Yes, it's an individual employee being forced to support that expressive activity. So the question becomes: What expressive activity are they being forced to support? And when you're speaking of changing an entire government program, for example, Medicaid rates across the board, that is a matter of public concern. That is a matter of lobbying or political --
Justice Kagan: But that's exactly what the individual employee in Justice Scalia's hypothetical is arguing for. He wants wage rates to be changed across the board. He knows they're not going to be changed just for him. He wants higher wage rates.
Mr. Messenger: But, again, under this Court's private--under the public conern test, an individual simply speaking to that usually does not rise to a matter of public concern.
Chief Justice Roberts jumped in during the respondents' argument to underscore the problem. He made a point that under the state's position one union's advocacy for increased Medicaid rates might be an issue of public concern (as in a teacher's union), but another union's advocacy for the same incrased Medicaid rates is a private employment issue (as here), suggesting that that can't be.
Justice Breyer quickly rescued the respondents and outlined the opposite position--"Collective bargaining with any employer, meat packers, hours, safety depends on hours, always can involve public interest questions"--arguing that the Court shouldn't be in the business of this kind of line-drawing.
The one to watch here may be Justice Kennedy. He suggested at one point that nearly all of this union's activities were public matters, but at a different point that the Court's jurisprudence provides (at least) a partial solution: non-members can be compelled to pay fair-share fees for those activities that might involve free-riding, but not for other activities for which they don't receive a benefit. (Justice Scalia piped in to remind us that under the Court's jurisprudence non-members can opt-out of fees for benefits that they don't enjoy.) The problem here may be sorting out which kind of benefit is which.
Justice Alito underscored this problem when he pressed the state on a hypothetical non-union teacher who has to pay a fair-share fee to support the union's advocacy of the tenure system. But the teacher disagrees with the union's position on this, so has to pay another organization an equal amount to represent his or her views--just to counteract the advocacy supported by his or her compelled fair-share fee. Justice Kennedy posed a similar hypo. The state responded that here the fair-share fee supports union activity that benefits all workers, but it's not clear that a majority bought it, or, if they did, that they weren't also thinking beyond the narrow facts of this case.
The case also involved several puzzles, both practical and jurisprudential, that seem to put the petitioners' positions at odds with common sense and doctrine. Here's Justice Sotomayor raising one with the petitioners:
Justice Sotomayor: Is there a problem for the State to say--the union, to organize has a certain amount of costs. So putting aside fair representation laws, could the State say, this is what we're going to pay police officers, 100 dollars, but we're going to pay union members 110 to reimburse them for the cost of negotiation. Would that be OK?
Mr. Messenger: Yes.
Here's Justice Kagan raising another:
Justice Kagan: Because here's the thing: That in the workplace we've given the government a very wide degree of latitude and there's much that the government can do. It can fire people. It can demote people for things that they say in the workplace, not for things that they say as a citizen . . . .
So you're saying, well, the government can punish somebody for saying something, but the government in the exact same position cannot compel somebody to say something they disagree with. And I want to know what's the basis for that distinction, which it seems to me is just as hard as -- as if you were answering under the petition clause.
There was also significant confusion about whether the state's flexibility in negotiating wages--and therefore why the union's participation is necessary. (If the wages are set--by the Medicaid program, for example--what benefit does the union bring?)
Justices Scalia and Alito both expressed some skepticism over the state's intent in requiring fair-share, Justice Alito suggesting that it was Governor Blagojevich's reward to the union for a huge campaign contribution.
In rebuttal, Justice Scalia pressed the petitioners about free-riding and what their position could do to unions; Justice Kagan pressed them about what their position would do to "thousands and thousands" of public contracts that include fair-share provisions. Justice Kagan earlier put a finer point on the case's significance and with the help of respondents' counsel told us just what's at stake:
Justice Kagan: So, Mr. Messeenger, even on the compulsory fees, I mean, what strikes me is that this is -- I'm just going to use the word here, it is a radical argument. It would radically restructure the way any workplaces across this country are -- are run.
And let me just put it to you this way and ask if you agree with this -- with this statement. Since 1948, since the Taft-Hartley Act, there has been a debate in every State across this country about whether to be a right-to-work State and people have disagreed. Some States say yes, some States say no. It raises considerable heat and passion and tension, as we recently saw in Wisconsin. And -- but, you know, these are public policy choices that States make.
And is it fair to say that what you're suggesting here, your argument, is essentially to say that for 65 years, people have been debating the wrong question when they've been debating that, because, in fact, a right-to-work law is constitutionally compelled?
Mr. Messenger: In the public sector, yes . . . .
January 21, 2014 in Association, Cases and Case Materials, First Amendment, Fundamental Rights, News, Oral Argument Analysis | Permalink | Comments (1) | TrackBack (0)
Monday, January 13, 2014
Daily Read: Understanding Zablocki v. Redhail and "Marriage Equality"
The United States Supreme Court in Zablocki v. Redhail (1978) held unconstitutional a Wisconsin state statute requiring judicial permission for a marriage license for any person who had a support order for a minor.
The opinion, authored by Justice Marshall, considers the case as one of equal protection and opines that
our past decisions make clear that the right to marry is of fundamental importance, and since the classification at issue here significantly interferes with the exercise of that right, we believe that "critical examination" of the state interests advanced in support of the classification is required.
The Court also states that more recent decisions "have established that the right to marry is part of the fundamental "right of privacy" implicit in the Fourteenth Amendment's Due Process Clause," citing Griswold v. Connecticut.
Thus, although not as famous as Loving v. Virginia, Zablocki v. Redhail is also frequently cited in any argument that marriage is a fundamental right, notwithstanding the Court's qualification in Zablocki that "not every state regulation which relates in any way to the incidents of or prerequisites for marriage must be subjected to rigorous scrutiny," but only ones that interfere directly and substantially with the right to marry.
In a new essay, Chronicle of a Debt Foretold: Zablocki v. Red Hail, by Tonya L. Brito, R. Kirk Anderson and Monica Wedgewood, forthcoming in The Poverty Law Canon and available on ssrn, the authors revive the importance of the wealth inequality relevance of the case and also reveal a racial aspect. Redhail, whose name is actually Roger Red Hail, is a Native American man, now in his late 50s, who still owes child support for the child he fathered when he was 16. Although the "child" is now in her 40s, he owes the money to state (with interest) and the state continues to garnish his wages.
There is a possibility that Red Hail's pending child support cases now under the jurisdiction of Milwaukee County would be transferred to the Oneida Tribal Judicial System.
The essay is a must-read for anyone considering the constitutional ramifications of equality or marriage.
January 13, 2014 in Due Process (Substantive), Equal Protection, Family, Federalism, Fourteenth Amendment, Fundamental Rights, History, Reproductive Rights, Scholarship | Permalink | Comments (0) | TrackBack (0)
Tuesday, January 7, 2014
District Judge Says Chicago's Gun-Sales Ban Violates Second Amendment
Judge Edmond E. Chang (N.D. Ill.) ruled yesterday in Illinois Association of Firearms Retailers v. City of Chicago that Chicago's ban on gun sales violates the Second Amendment.
Chicago Municipal Code Section 8-20-100 says, in relevant part, that "no firearm may be sold, acquired or otherwise transferred wtihin the city, except through inheritance of the firearm." Firearms dealers and would-be gun buyers sued, arguing that it violated the Second Amendment. Judge Chang agreed, granting summary judgment in their favor.
The court used the two-step process sanctioned by the Seventh Circuit: first, the court determined whether the ban fell within the Second Amendment as it was understood in 1791 (when the Bill of Rights was ratified) or in 1868 (when the Fourteenth Amendment was ratified); second, the court determined whether the ban satisfies a varying, but heightened, level of scrutiny.
As to step one, the court concluded that "[t]he City's proffered historical evidence fails to establish that governments banned gun sales and transfers at the time of the Second Amendment's enactment," and therefore the Second Amendment applies. As to step two, the court applied "not quite strict scrutiny" (because the ban "prevents Chicagoans from fulfilling, within the limits of Chicago, the most fundamental prerequisite of legal gun ownership--that of simple acquisition") and that the ban didn't sufficiently serve the city's interests in reducing criminals' access to guns, restricting gun acquisition in the illegal market, or eliminating dangerous gun stores from Chicago.
Judge Chang gave the city "limited time, before the judgment becomes effective, to consider and enact other sales-and-transfer restrictions short of a complete ban," and invited the city to move for a stay pending appeal.
January 7, 2014 in Cases and Case Materials, Fundamental Rights, News, Second Amendment | Permalink | Comments (0) | TrackBack (0)
Friday, December 20, 2013
Supreme Court of Canada Finds Prostitution Laws Unconstitutional
In its highly anticipated judgment in Canada v. Bedford, the Supreme Court of Canada has unanimously declared several provisions of Canada's criminal code regulating prostitution and sex work to be inconsistent with the Canadian Constitution's Charter of Rights and thus unconstitutional, although it suspended the declaration of invalidity for one year to allow Parliament to act.
The provisions of the criminal code at issue were:
- § 210 making it an offence to keep or be in a bawdy‑house;
- § 212(1)(j) prohibiting living on the avails of prostitution; and,
- §213(1)(c) prohibiting communicating in public for the purposes of prostitution.
All there were declared inconsistent with §7 of the Charter which provides "Everyone has the right to life, liberty and security of the person and the right not to be deprived thereof except in accordance with the principles of fundamental justice." The Court was clear that it was security - - - and not liberty - - - that was the animating principle for its decision.
Importantly, prostitution itself is legal in Canada, an important underpinning of the Court's decision. The Court reasoned that the criminal code provisions at issue heightened the risks prostitutes face, by not merely "imposing conditions" but also going "a critical step further by imposing dangerous conditions on prostitution" and prevent "people engaged in a risky — but legal — activity from taking steps to protect themselves from the risks."
The Court rejected the notion that the created danger was "negated by the actions of third‑party johns and pimps, or prostitutes' so‑called choice to engage in prostitution."
The Court then engaged in a type of purpose, means, and balancing analysis familiar in constitutional law. Quoting from the Court's handy summary of its reasoning and holding in this lengthy and scholarly opinion,
[First], the negative impact of the bawdy‑house prohibition (s. 210) on the applicants' security of the person is grossly disproportionate to its objective of preventing public nuisance. The harms to prostitutes identified by the courts below, such as being prevented from working in safer fixed indoor locations and from resorting to safe houses, are grossly disproportionate to the deterrence of community disruption. Parliament has the power to regulate against nuisances, but not at the cost of the health, safety and lives of prostitutes.
Second, the purpose of the living on the avails of prostitution prohibition in s. 212(1)(j) is to target pimps and the parasitic, exploitative conduct in which they engage. The law, however, punishes everyone who lives on the avails of prostitution without distinguishing between those who exploit prostitutes and those who could increase the safety and security of prostitutes, for example, legitimate drivers, managers, or bodyguards. It also includes anyone involved in business with a prostitute, such as accountants or receptionists. In these ways, the law includes some conduct that bears no relation to its purpose of preventing the exploitation of prostitutes. The living on the avails provision is consequently overbroad.
Third, the purpose of the communicating prohibition in s. 213(1)(c) is not to eliminate street prostitution for its own sake, but to take prostitution off the streets and out of public view in order to prevent the nuisances that street prostitution can cause. The provision's negative impact on the safety and lives of street prostitutes, who are prevented by the communicating prohibition from screening potential clients for intoxication and propensity to violence, is a grossly disproportionate response to the possibility of nuisance caused by street prostitution.
The Supreme Court of Canada's unanimous opinion affirms a judgment by the Court of Appeal for Ontario and one might believe that Canada's remaining criminalization of sex work have been vanquished. However, the Court recognized that the "regulation of prostitution is a complex and delicate matter," and that Parliament "should it choose to do so" could "devise a new approach, reflecting different elements of the existing regime." The Court suspended its declaration of invalidity for one year. And one might say that the "ball" is now in Parliament's "court."
[image: Canada Supreme Court building's Grand Entrance Hall via]
December 20, 2013 in Comparative Constitutionalism, Fundamental Rights, Sexuality | Permalink | Comments (0) | TrackBack (0)
Thursday, December 19, 2013
New Mexico Supreme Court Declares Same-Sex Marriage Cannot Constitutionally be Barred
In its unanimous opinion in Griego v. Oliver, the New Mexico Supreme Court has declared that the state must recognize same sex marriages. The court found that
barring individuals from marrying and depriving them of the rights, protections, and responsibilities of civil marriage solely because of their sexual orientation violates the Equal Protection Clause under Article II, Section 18 of the New Mexico Constitution. We hold that the State of New Mexico is constitutionally required to allow same-gender couples to marry and must extend to them the rights, protections, and responsibilities that derive from civil marriage under New Mexico law.
Interestingly, the court concluded that any prohibition of same-sex marriage raised a classification based on sexual orientation (and not sex), although its rationale raised the specter of the kind of formal equality at issue in Plessy v. Ferguson:
We do not agree that the marriage statutes at issue create a classification based on sex. Plaintiffs have conflated sex and sexual orientation. The distinction between same- gender and opposite-gender couples in the challenged legislation does not result in the unequal treatment of men and women. On the contrary, persons of either gender are treated equally in that they are each permitted to marry only a person of the opposite gender. The classification at issue is more properly analyzed as differential treatment based upon a person's sexual orientation.
Nevertheless, the court found that the appropriate level of scrutiny was intermediate:
because the LGBT community is a discrete group that has been subjected to a history of purposeful discrimination, and it has not had sufficient political strength to protect itself from such discrimination. . . . the class adversely affected by the legislation does not need to be "completely politically powerless, but must be limited in its political power or ability to advocate within the political system." Nor does intermediate scrutiny require the same level of extraordinary protection from the majoritarian political process that strict scrutiny demands. It is appropriate for our courts to apply intermediate scrutiny, "even though the darkest period of discrimination may have passed for a historically maligned group."
The court notes that its "decision to apply intermediate scrutiny is consistent with many jurisdictions which have considered the issue," citing the Second Circuit in Windsor, as well as the same-sex marriage cases from Iowa and Connecticut.
The court found that the same-sex marriage ban did not survive intermediate scrutiny. It considered three governmental interests advanced for prohibiting same-gender couples from marrying in the State of New Mexico:
- promoting responsible procreation
- responsible child-rearing
- preventing the deinstitutionalization of marriage
As to the last interest, the court noted that the defendants conceded there was no evidence that same-sex marriages would result in the deinstitutionalization of marriage, and the court implied this interest was "intended to inject into the analysis moral disapprobation of homosexual activity and tradition" and flatly rejected it.
As to procreation and child-rearing, the court rejected these interests as the governmental interests underlying New Mexico's marriage laws: "It is the marriage partners' exclusive and permanent commitment to one another and the State's interest in their stable relationship that are indispensable requisites of a civil marriage." But the court also found that neither interest would be substantially served by the prohibition of mariage to same-sex partners.
Thus, by a relatively brief opinion (approximately 30 pages) the New Mexico Supreme Court has unanimously ruled that same-sex marriages must be allowed in the state. Because the decision rests on the state constitution, it is not subject to review by the United States Supreme Court and New Mexico becomes the 17th state to allow same-sex marriages on the same terms as other marriages.
December 19, 2013 in Courts and Judging, Current Affairs, Equal Protection, Family, Fundamental Rights, Gender, Opinion Analysis, Sexual Orientation, Sexuality, State Constitutional Law | Permalink | Comments (1) | TrackBack (0)
Wednesday, December 18, 2013
Recommendations from President's NSA Surveillance Review Group
The anticipated report from a panel of presidential advisors - - - Richard Clarke, Michael Morell, Peter Swire, and ConLawProfs Geoffrey Stone and Cass Sunstein - - - has just been released from The White House. It contains 46 recommendations, detailed in the Executive Summary and later discussed in the report.
Occuring amidst significant problems, such as the recent federal district judge's opinion casting doubt on the constitutionality of the collection of metadata from Verizon and the Edward Snowden revelations, the report concludes that the "current storage by the government of bulk meta-data creates potential risks to public trust, personal privacy, and civil liberty." But the report recognizes that government might need such metadata, and therefore recommends that it be held by "private providers or by a private third party." The report also recommends a series of changes at NSA, including having the Director be a "Senate-confirmed position" and suggesting that the Director be a civilian (at least next time).
There is some interesting constitutional analysis and rhetoric in the report. For example, under "Principles," the first one is "The United States Government must protect, at once, two different forms of security: national security and personal privacy." How should these interests be balanced? The report, quite interestingly, says this:
It is tempting to suggest that the underlying goal is to achieve the right "balance" between the two forms of security. The suggestion has an important element of truth. Some tradeoffs are inevitable; we shall explore the question of balance in some detail. But in critical respects, the suggestion is inadequate and misleading.
Some safeguards are not subject to balancing at all. In a free society, public officials should never engage in surveillance in order to punish their political enemies; to restrict freedom of speech or religion; to suppress legitimate criticism and dissent; to help their preferred companies or industries; to provide domestic companies with an unfair competitive advantage; or to benefit or burden members of groups defined in terms of religion, ethnicity, race, or gender. These prohibitions are foundational, and they apply both inside and outside our territorial borders.
The purposes of surveillance must be legitimate. If they are not, no amount of "balancing" can justify surveillance. For this reason, it is exceptionally important to create explicit prohibitions and safeguards, designed to reduce the risk that surveillance will ever be undertaken for illegitimate ends.
Certainly, there is much more to glean and analyze from the 300 plus page report, but some of the reasoning already seems noteworthy.
December 18, 2013 in Criminal Procedure, Current Affairs, First Amendment, Foreign Affairs, Fourth Amendment, Fundamental Rights, Privacy, Web/Tech | Permalink | Comments (0) | TrackBack (0)
Saturday, December 14, 2013
Federal District Judge Finds Portions of Utah's Criminalization of Polygamy Unconstitutional
In a 91 page opinion in Brown v. Buhman, federal district judge Clark Waddoups has concluded that Utah's anti-bigamy statute is partially unconstitutional.
The statute, Utah Code Ann. § 76-7-101, provides:
- (1) A person is guilty of bigamy when, knowing he has a husband or wife or knowing the other person has a husband or wife, the person purports to marry another person or cohabits with another person.
- (2) Bigamy is a felony of the third degree.
- (3) It shall be a defense to bigamy that the accused reasonably believed he and the other person were legally eligible to remarry.
The challengers to the statute, the Browns, are famous from the reality program Sister Wives and the accompanying book ) and are represented by Professor Jonathan Turley, who blogs about the case here.
The judge's scholarly opinion includes a discussion of Edward Said's groundbreaking book Orientalism as a critique of the well-known passage in the United States Supreme Court's 1879 decision in Reynolds v. United States upholding the criminalization of polygamy by reasoning, in part, that "Polygamy has always been odious among the northern and western nations of Europe, and, until the establishment of the Mormon Church, was almost exclusively a feature of the life of Asiatic and of African people."
Judge Waddoups considers both the due process challenge (applying Washington v. Glucksberg) and the free exercise challenge (applying Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah).
In the due process analysis, the judge specifically found
there is no "fundamental right" to polygamy under Glucksberg. To phrase it with a "careful description" of the asserted right [citations omitted], no "fundamental right" exists to have official State recognition or legitimation of individuals' "purported" polygamous marriages—relationships entered into knowing that one of the parties to such a plural marriage is already legally married in the eyes of the State. The fundamental right or liberty interest that was under consideration in Glucksberg is instructive for the analysis of whether the asserted right to polygamy is "deeply rooted in this Nation's history and tradition, and implicit in the concept of ordered liberty, such that neither liberty nor justice would exist if they were sacrificed."
The judge also found that the criminalization of what it called the "religious cohabitation" portion of the statute did not rise to the level of a fundamental right, extensively discussing Lawrence v. Texas and the Tenth Circuit's limiting interpretation of Lawrence.
However, the judge did find that "the cohabitation prong does not survive rational basis review under the substantive due process analysis." This analysis implicitly imported a type of equal protection analysis, with the judge concluding:
Adultery, including adulterous cohabitation, is not prosecuted. Religious cohabitation, however, is subject to prosecution at the limitless discretion of local and State prosecutors, despite a general policy not to prosecute religiously motivated polygamy. The court finds no rational basis to distinguish between the two, not least with regard to the State interest in protecting the institution of marriage.
Complementing this conclusion regarding discriminatory enforcement, the judge's free exercise of religion analysis concludes that while the Utah statute may be facially neutral, the cohabitation prong is not "operationally neutral" and not of general applicability. The judge therefore applied strict scrutiny to the cohabitation prong and easily concluded the statute failed.
As an alternative free exercise analysis, the judge reasoned that the cohabitation prong also merited strict scrutiny because it involved a "hybrid rights" analysis under Employment Division, Department of Human Resources of Oregon v. Smith (1990), given the claims of due process, but also claims that the judge did not extensively analyzes such as free association, free speech, establishment, and equal protection.
Thus, the judge concluded the cohabitation prong of the statute is "unconstitutional on numerous grounds." However, the court explicitly narrowed the constructions of "marry" and "purports to marry" in the statute, so that the Utah statute continues to "remain in force as prohibiting bigamy in the literal sense—the fraudulent or otherwise impermissible possession of two purportedly valid marriage licenses for the purpose of entering into more than one purportedly legal marriage." Not surprisingly then, the judge's opinion does not cite the Supreme Court's opinion last term in United States v. Windsor involving DOMA and same-sex marriage, in which Justice Scalia, dissenting, invoked the effect the decision would have on polygamy. [I've previously discussed the similarities of same-sex marriage and polygamy claims here].
Given the district judge's narrowing construction and the clear constitutional issues with the Utah statute's breadth, it might be possible that the state does not appeal.
[video via]
December 14, 2013 in Books, Equal Protection, Establishment Clause, Family, Federalism, First Amendment, Fourteenth Amendment, Free Exercise Clause, Fundamental Rights, Gender, Opinion Analysis, Speech | Permalink | Comments (0) | TrackBack (0)
Wednesday, December 11, 2013
Supreme Court of India Upholds Constitutionality of Criminalization of Sodomy
In its long-awaited opinion in Koushal v. NAZ Foundation, the Supreme Court of India has reversed the 2009 decision of the Delhi High Court that §377 of the Indian Penal Code was unconstitutional under the India Constitution and upheld India's sodomy law as constitutional.
The Supreme Court decision noted that India's sodomy law was pre-constitutional - - - and derived from British rule - - - and also that the Court certainly had the power to declare the law unconstitutional as inconsistent with several provisions of the India Constitution, including
- Article 13 (Laws inconsistent with or in derogation of the fundamental rights)
- Article 14 (Equality before law)
- Article 15 (Prohibition of discrimination on grounds of religion, race, caste, sex or place of birth)
- Article 19 (Protection of certain rights regarding freedom of speech etc.)
- Article 21 (Protection of life and personal liberty)
Nevertheless, the Court stated that there is a presumption of constitutionality given the "importance of separation of powers and out of a sense of deference to the value of democracy that parliamentary acts embody."
The Court's 98 page opinion authored by Justice Singhvi (who is interestingly scheduled to retire tomorrow, the day after the opinion was rendered), and without a dissenting opinion, criticizes the Dehli Court's reliance on non-national sources:
In its anxiety to protect the so-called rights of LGBT persons and to declare that Section 377 IPC violates the right to privacy, autonomy and dignity, the High Court has extensively relied upon the judgments of other jurisdictions. Though these judgments shed considerable light on various aspects of this right and are informative in relation to the plight of sexual minorities, we feel that they cannot be applied blindfolded for deciding the constitutionality of the law enacted by the Indian legislature.
(para 52).
For United States scholars, such concern for nationalism certainly echoes the dissenting opinion in Lawrence v. Texas, in which the United States Supreme Court held unconstitutional a state law criminalizing sodomy. Yet in the India context, the fact that its constitutionalism is linked to British rule as well as the fact that the sodomy law is a product of colonialism (and is a law that the colonial power has since repudiated as former Australian High Court Judge Michael Kirby has analyzed as England's "least lovely" export) are distinguishing features.
Certainly, however, the problematizing of judicial review in the context of sexuality occurs in the United States cases as well as those from South Africa, an issue extensively discussed here.
And certainly, advocacy on behalf of "the so-called rights of LGBT persons" will be moving to India's Parliament.
[image of Supreme Court of India via]
December 11, 2013 in Comparative Constitutionalism, Courts and Judging, Fundamental Rights, Opinion Analysis, Privacy, Sexual Orientation, Sexuality | Permalink | Comments (0) | TrackBack (0)
Sunday, October 27, 2013
Government Notifies Defendant of Warrantless Wiretap, Tees Up Challenge
The Department of Justice for the first time notified a criminal defendant that evidence against him was obtained through a warrantless wiretap, according to the New York Times. The move gives the criminal defendant the standing to challenge warrantless wiretapes that the plaintiffs in Clapper v. Amnesty International lacked and invites his challenge of warrantless wiretaps. Our previous post on the issue is here.
The defendant, Jamshid Muhtorov, is charged with "provid[ing] and attempt[ing] to provide material support and resources, to wit: personnel . . . to a foreign terrorist organization, specifically the Islamic Jihad Union . . . knowing that the organization was a designated terrorist organization, that the organization had engaged in and was engaging in terrorist activity and terrorism, and the offense occurred in whole or in part within the United States" in violation of 18 U.S.C. Sec. 2339B. The notice says that the government
hereby provides notice to this Court and the defense, pursuant to 50 U.S.C. Secs. 1806(c) and 1881e(a), that the government intends to offer into evidence or otherwise use or disclose from acquisition of foreign intelligence information conducted pursuant to the Foreign Intelligence Surveillance Act of 1978 . . . .
The Supreme Court held that the plaintiffs in Clapper lacked standing to challenge warrantless wiretaps, because they couldn't show that they'd been, or would be, wiretapped under the specific statutory authority they sought to challenge. Now that the government has disclosed that its evidence resulted from warrantless wiretaps, Muhtorov has clear standing to challenge the wiretaps.
This merely puts the legality of the wiretaps before the courts; it doesn't answer the underlying question. For that, we'll have to await the ruling and appeals.
October 27, 2013 in Cases and Case Materials, Congressional Authority, Courts and Judging, Criminal Procedure, Fourth Amendment, Fundamental Rights, News | Permalink | Comments (0) | TrackBack (0)
Wednesday, October 23, 2013
Human Rights Watch Urges Changes to Draft Vietnamese Constitution
Human Rights Watch penned a letter to the Chairman of the Vietnamese National Assembly this week, urging the body to protect the rights and liberties of all people in Vietnam as the Assmebly moves forward with the country's new constitution. Here's the press release.
The National Assembly has authority to revise the constitution; it is considering amendments during a session from October 21 to November 30, 2013. The government opened the draft constitution up for public and official comment on January 2, 2013, and received tens of thousands of submissions. But as HRW points out, some who campaigned for changes found themselves targets of government reprisal.
The letter urges the assembly to "ensure that the amendment process brings the constitution into conformity with Vietnam's obligations under international law so that it fully protects the rights and liberties of all people in Vietnam, which will contribute to the country's development." In particular, the group is concerned about these:
-Weakened protections against arbitrary arrest;
-Expansion of the one-party state;
-Extension of control over the armed forces by the Communist Party
-Broad limitations on rights, broader than limitations recognized under international law;
-A weak judiciary and Constitutional Council.
The group also recognized some positive developments, including the more frequent references to human rights, and extension to both citizens and non-citizens; explicit reference to the right to life; a new ban on discrimination on political, economic, cultural, and social grounds; a new prohibition on gender discrimination; new criminal procedure rights; bans on forced labor and child labor; the establishment of a Constitutional Council; and the creation of a National Election Commission.
October 23, 2013 in Comparative Constitutionalism, Fundamental Rights, News | Permalink | Comments (0) | TrackBack (0)
Friday, October 18, 2013
Arizona, Kansas to Use Two-Tier Voter Registration in Response to Inter Tribal Council
The states of Arizona and Kansas have announced that they will require voters to register separately for state and federal elections--using the standard federal form for federal elections, but using more stringent requirements for state registration.
The moves are a response to the Supreme Court's ruling this summer in Arizona v. Inter Tribal Council of Arizona. That case held that the federal requirement under the National Voter Registration Act that states "accept and use" an approved and uniform federal form for registering voters preempted Arizona's requirement that voters present evidence of citizenship at registration. (Under this system, state voters could register for federal and state elections all at once, using the same standardized federal form, with the same requirements.) The result: the Court struck Arizona's proof-of-citizenship add-on to the standardized federal form.
So the states sought a work-around, so that they could retain a proof-of-citizenship requirement for some voter registration. And they came up with the only voter registration that they now seem to have control over: registration for state elections.
The states say that Inter Tribal applies only to federal elections, that they can design and use their own forms for state elections, and that voters who register using only the federal form are qualified only to vote in federal elections (and not state and local elections). To the states, this all means that a two-tiered system makes sense.
Under the two-tiered system, voters in those states could register for federal elections using the NVRA standardized federal form. But voters would have to show additional proof of citizenship--of the kind struck in Inter Tribal--in order to register to vote in state elections.
The moves harken back to practices in the Jim Crow South and stand as a barrier to voter registration. Ari Berman argues over at The Nation:
In the Jim Crow South, citizens often had to register multiple times, with different clerks, to be able to vote in state and federal elections. It was hard enough to register once in states like Mississippi, were only 6.7 percent of African-Americans were registered to vote before the passage of the Voting Rights Act of 1965. And when the federal courts struck down a literacy test or a poll tax before 1965, states like Mississippi still retained them for state and local elections, thereby preventing African-American voters from replacing those officials most responsible for upholding voter disenfranchisement laws. . . .
Over 300,000 voters were prevented from registering in Arizona after its proof-of-citizenship law passed in 2004. In Kansas, 17,000 voters have been blocked from registering this year, a third of all registered applicants, because the DMV doesn't transfer citizenship documents to election officials.
At the very least, the two-tiered systems promise to complicate voter registration and maintenance of voter lists for the states.
Still: there's little or no evidence of voter fraud.
October 18, 2013 in Cases and Case Materials, Elections and Voting, Federalism, Fundamental Rights, News | Permalink | Comments (0) | TrackBack (0)
Thursday, October 17, 2013
Government to Disclose Eavesdropping, Sets up Challenge to FISA
The Department of Justice will tell a criminal defendant in coming weeks that evidence used against him derived from eavesdropping, The New York Times reports. The disclosure--the first in a criminal case--will give the defendant standing to challenge the government's authority under the Foreign Intelligence Surveillance Act to conduct surveillance against non-U.S. persons outside the United States, even when they're communicating with people within the United States.
Recall that the Court ruled earlier this year in Clapper v. Amnesty International that human rights and media organizations and attorneys lacked standing to challenge Section 702 of the FISA, which authorizes the surveillance, because they couldn't show that they had been, or would be, targets of surveillance. Solicitor General Donald Verrilli represented to the Court in the case that prosecutors tell defendants when they're using evidence derived from FISA surveillance. In particular, he wrote in the government's opening brief in the case,
If the government intends to use or disclose any information obtained or derived from its acquisition of a person's communications under [FISA Section 702] in judicial or administrative proceedings against that person, it must provide advance notice of its intent to the tribunal and the person, whether or not the person was targeted for surveillance . . . . That person may then challenge the use of that information in district court by challenging the lawfulness of the . . . acquisition.
Government's Opening Brief at 8 (emphasis added).
But this turns out to be false, according to the NYT. The Times reports that SG Verrilli discovered that prosecutors weren't telling defendants, after all.
The discovery came in the fallout of a speech by Senator Dianne Feinstein. That speech, touting FISA, suggested that the government used FISA-derived communications successfully in several cases. But when defendants in two of those cases pressed prosecutors, the prosecutors said that they didn't have to say whether they used FISA-derived communications.
This prompted SG Verrilli to ask national security lawyers why nobody told him before he filed his brief (and made similar comments at oral argument). Government lawyers then argued over whether they had to disclose, with SG Verrilli taking the position that do. Verrilli's position apparently prevailed, and the government will disclose to a defendant in coming weeks.
The move will give standing to the defendant to challenge Section 702, notwithstanding Clapper. That's because the defendant will be able to show, with certainty, that he was subject to FISA surveillance--something the Court said that the Clapper challengers couldn't do.
But it's not clear whether prosecutors will disclose to already-convicted defendants who were convicted on FISA-derived communications, and, if so, what will happen in those cases. It's not even clear how many of those defendants there are.
October 17, 2013 in Cases and Case Materials, Criminal Procedure, Fundamental Rights, News, Standing | Permalink | Comments (0) | TrackBack (0)
Thursday, October 3, 2013
Idaho Court Rules Denial of Motions Violates State Constitutional "Open Courts"
The Idaho Supreme Court ruled today that a magistrate judge's order dismissing a party's motions because the party had been found guilty of contempt for for failing to pay child support violated the party's right to access the courts.
The case is notable because it invokes the Idaho Constitution's "Open Courts" provision--a common provision in state constitutions, but one that's relatively rarely litigated and has spawned a notoriously confused jurisprudence in the state courts. More: the court apparently reached out for the issue.
The case, State of Idaho Department of Health and Welfare v. Slane, involved a father's motions for child custody and modification of child support. The father had been previously judged in contempt of court for failing to pay court-ordered child support, and he was unable to purge the contempt when he filed his motions. A magistrate judge then dismissed the motions because of the father's inability to purge the contempt and pay back child support. A lower court upheld the magistrate's ruling.
The Idaho Supreme Court reversed for reasons dealing with the details of the contempt and the details of the magistrate's order. But then it added an alternative basis for its ruling: the magistrate's order violated the state constitutional open courts provision.
Article I, Section 18 of the Idaho Constitution says that "Courts of justice shall be open to every person, and a speedy remedy afforded for every injury of person, property or character, and right and justice shall be administered without sale, denial, delay, or prejudice."
This kind of "open courts" provision is common in state constitutions. Open courts provisions first appeared in early state constitutions (borrowing from language in Magna Carta), and later state constitutional drafters appear to have simply lifted the text--sometimes modifying it slightly, but without any real thought about what it means.
That's led to a notoriously confused jurisprudence among state courts in interpreting state constitutional open courts provisions. In short, many states have an open courts provision, but courts across states can't seem to agree on exactly what "open courts" means.
So the Idaho Supreme Court's ruling is notable for dealing with open courts--for giving it some dimension and definition, at least in this context. But it's notable for a couple other reasons, too. For one, the court seems to have reached for the issue. Neither party seems to have argued it (based on the briefs, at least), and it's dicta. (The court could have hung its hat on its analysis of the details of the contempt and the magistrate's order, but it added this alternative reason for striking the magistrate's order.) Moreover, in ruling the way that it did, the court overruled three of its own opinions (from the mid-twentieth century) "to the extent that they are inconsistent with this opinion."
The upshot of all this is that the father gets his motions reinstated.
October 3, 2013 in Cases and Case Materials, Comparative Constitutionalism, Fundamental Rights, News, State Constitutional Law | Permalink | Comments (0) | TrackBack (0)
Monday, September 30, 2013
Justice Department to Sue North Carolina Over Vote Restrictions
AG Eric Holder announced today that the U.S. Department of Justice would file suit against North Carolina in federal court to stop its new restrictions on voting. We previously posted on the ACLU suit against the state here.
The complaint alleges that North Carolina HB 589 reduces early voting days, eliminates same-day voter registration during early voting, prohibits the counting of provisional ballots cast outside a voter's precinct, and imposes a voter ID requirement--all in violation of Section 2 of the Voting Rights Act. DOJ argues that the changes have both a discriminatory purpose and a discriminatory effect. The Department also seeks "bail-in" under Section 3(c) of the VRA.
DOJ most recently sued Texas to stop its voter ID law and redistricting plans. The Department sought bail-in relief in those cases, too.
The cases come in the wake of the Court's ruling this summer in Shelby County v. Holder striking Section 4(b) of the VRA, the coverage formula for the preclearance requirement. By striking Section 4(b), the Court rendered Section 5 preclearance a dead letter, unless and until Congress can rewrite it in a way that would pass muster with this Court--that is, likely never. Section 3(c) bail-in works very much like Section 5 preclearance, though. If acourt orders bail-in, it will retain jurisdiction over the state "for such period as it may deem appropriate and during such period no voting qualification or prerequisite to voting or standard, practice, or procedure with respect to voting different from that in force or effect at the time the proceeding was commenced shall be enforced unless and until the court finds that such qualification, prerequisite, standard, practice, or procedure does not have the purpose and will not have the effect of denying or abridging the right to vote on account of race or color . . . ."
The North Carolina and Texas cases are sure to raise two new fronts in the assault on the Voting Rights Act: challenges to congressional authority to enact Section 3(c) bail-in, and challenges to congressional authority under Section 2 to ban state laws that have a discriminatory effect (even if not a discriminatory purpose).
September 30, 2013 in Cases and Case Materials, Congressional Authority, Elections and Voting, Federalism, Fifteenth Amendment, Fourteenth Amendment, Fundamental Rights, News | Permalink | Comments (1) | TrackBack (0)
Texans Debate Creationism in the Classroom
Yesterday we wrote about the latest case in Kansas challenging evolution in the classroom. In a comment, reader Eli Bortman gave us the heads-up that yesterday's NYT included an article on the same issue in Texas. (Thanks, Eli.)
Here's a bit from the Times piece that helps explain the edu-ese and pseudo-scientific language in COPE's complaint in the Kansas case:
By questioning the science--often getting down to very technical details--the evolution challengers in Texas are following a strategy increasingly deployed by others around the country.
There is little open talk of creationism. Instead they borrow buzzwords common in education, "critical thinking," saying there is simply not enough evidence to prove evolution.
COPE went even further, though, arguing that the Kansas standards (with (secular) evolution as a centerpiece) themselves represent a kind of religious orthodoxy, and that Kansas in imposing this orthodoxy, without balancing it with "origin science," violated the religion clauses, free speech, and the Eqaul Protection Clause. In doing so, COPE adopts the language and legal claims of opponents of creationism and tries to create an equivalence between its position and the position of science--putting itself on par with science, both on the "science" and in its legal positions in relation to science, and casting science as a kind of religion. Then, after creating this topsy-turvey world where religion is science and science is religion, COPE asks the question: If "origin scientists" have an equal claim to the truth, doesn't it violate equality, speech, and religious principles to exclude their position from the curriculum?
This isn't new, but as the COPE complaint and NYT piece suggest, creationism advocates may be getting a little better at clothing their positions in official- and technical-sounding langauge, and in turning the same constitutional claims that proponents of a curriculum based on science have used against creationism right back on them, in support of creationism. The strategy is designed to frame the debate as one scientific theory against another scientific theory, not science against religion, and to put the competing policy and constitutional claims on par in order to gain traction under the religion clauses, free speech, and equal protection.
September 30, 2013 in Establishment Clause, First Amendment, Free Exercise Clause, Fundamental Rights, News, Religion | Permalink | Comments (2) | TrackBack (0)
Sunday, September 29, 2013
Fourth Circuit Strikes Alcohol Advertising Ban for College Newspapers
The Fourth Circuit ruled last week in Educational Media Company at Virginia Tech v. Insley that a Virginia state ban on alcohol advertising in college newspapers violated the First Amendment as applied to student papers at Virginia Tech and U.Va.
The ruling means that the law can't ban these papers from running alcohol ads. But it also means that the law stay on the books and ineffect as to other student newspapers, unless and until they successfully challenge it, too.
Virginia law says,
Advertisements of alcoholic beverages are not allowed in college student publications unless in reference to a dining establishment . . . .
Student newspapers at Virginia Tech and U.Va. sued, arguing that the ban violated free speech. In a first round of litigation, the Fourth Circuit ruled that the ban didn't violate the First Amendment on its face. But the court remanded the case to determine whether the ban violated the First Amendment as applied to these two papers.
The court ruled last week that it did. In particular, the court held that the ban isn't appropriately tailored to the state's aim--that is, that the ban isn't more extensive than necessary to serve the government's interest--and thus violated the fourth prong of the Central Hudson test for regulations of commercial speech.
The problem was that the ban was designed to reduce under-age drinking, but the majority of the newspapers' readers were over 21. "Thus, the College newspapers have a protected interest in printing non-misleading alcohol advertisements, just as a majority of the College Newspapers' readers have a protected interest in receiving that information." Op. at 21.
As to the state's interest in preventing alcohol abuse by those over 21, the court said that the ban did exact what the Supreme Court prohibited in Sorrell v. IMS Health, Inc.: it sought to "keep people in the dark for what the government perceives to be their own good." Op. at 22 (quoting Sorrell).
September 29, 2013 in Cases and Case Materials, First Amendment, Fundamental Rights, News, Opinion Analysis, Speech | Permalink | Comments (0) | TrackBack (0)
Sunday, September 15, 2013
Daily Read: The New Yorker on Justice Ginsburg, Fisher, and Footnote 4
Over at the New Yorker blog, Lincoln Caplan's piece, "Justice Ginsburg and Footnote Four" analyzes Ginsburg's discussion last week at the National Constitution Center, arguing that one of her statements "deserves more attention than it has gotten."
Ginsburg stated that her dissent last term in Fisher v. University of Texas Austin, regarding judicial review of affirmative-action plans of colleges and universities, "was inspired by a 1938 ruling not mentioned in the dissent—actually, by one of its footnotes." That most famous footnote - - - footnote four - - -of United States v. Carolene Products, is for many (including Caplan) the foundation of "a coherent justification for unelected justices to overturn legal decisions of elected officials when the fairness of the Constitution, and of democracy, is at stake."
Recall that the 1938 case of Carolene Products involved a federal statute regulating the shipment of "filled milk" (skimmed milk to which nonmilk fat is added so that it may seem to be like whole milk or even cream). It may be that this case was also on Ginsburg's mind during the oral arguments of another one of last term's cases: In her questioning of Paul Clement, who represented BLAG, in United States v. Windsor about the constitutionality of DOMA, she condensed his argument as saying that in granting same-sex marriages, states were nevertheless saying there were really "two kinds of marriage; the full marriage, and then this sort of skim milk marriage." As we noted at the time, Ginsburg's allusion would have special resonance for those who recalled Carolene Products.
September 15, 2013 in Affirmative Action, Courts and Judging, Fifth Amendment, Food and Drink, Fourteenth Amendment, Fundamental Rights, Interpretation, Recent Cases, Sexual Orientation, Supreme Court (US), Theory | Permalink | Comments (0) | TrackBack (0)


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Brian Scott our Mariners blogger tells us its time to get ready to honor one of the Mariners all time greats. No other skipper in Seattle Mariners history has had the success that "Sweet" Lou enjoyed through most of the '90s and into the early 2000s. To celebrate, he'll remind you of a few of his favorite Lou Piniella stories.
Seattle Mariners Honor Lou Piniella Saturday August 9th
Four Reasons I'm Ready for Seahawks Football in 2014
Four reasons Seahawks blogger Brian Scott is excited about the 2014 Seahawks starts with Christine Michael. Look, I get it. This is a Marshawn Lynch ground game in Seattle and it will continue to be in 2014 as he has returned from his brief hold out. But Brian can't help but be excited at the notion we are going to get to see more of Christine Michael.
2014 Trade Deadline Analysis for the Seattle Mariners
M's Make Two Deadline Deals As a whole, the 2014 MLB trade deadline will likely be talked about as one of the most active days of trading in baseball history. Several teams like the A's and Tigers went into "All In" mode and made some serious waves with their acquisitions. The Seattle Mariners, on the […]
Five Seattle Seahawks that will WOW you in 2014
M's Skipper Lloyd McClendon mid-season report card
NWSB Insider and Seattle Mariners blogger Brian Scott weighs in at the halfway point of the 2014 MLB Season on M's skipper Lloyd McClendon. Brian thinks it's time we pay some attention to the skipper, the moves he's made and the other decisions that surround his role on the club and give him some praise and scrutiny where both are deserved.
Should The Seattle Mariners trade Ackley And Walker?
NWSB Blogger and Seattle Mariners insider Brian Scott weighs in on the M's trade deadline situation. In 2014 the Mariners have an 11-15 record in games decided by just one run. They have also been shut out 11 times on the season and we aren't even through July. Brian says Tampa is shopping David Price and Ben Zobrist, and asks should the M's trade Taijuan Walker & Dustin Ackley?
The 2014 Seattle Seahawks Wide Receiver Depth Chart
NWSB Insider and Seattle Seahawks Blogger Brian Scott takes a look at the team's current wide receivers and predicts which ones make the final cut. Featured are Percy Harvin, Doug Baldwin, Jermaine Kearse, Kevin Norwood, Paul Richardson, Ricardo Lockette, Arceto Clark, Phil Bates, Bryan Walters, Taylor Price, Chris Matthews, Sidney Rice and Kevin Smith.
Targeting A Trade – Seattle Mariners Looking For Bats
NWSB Blogger and Seattle Mariners insider Brian Scott says the M's need a bat. He knows it. We all know it. The Seattle Mariner's offense continues to be streaky. For a couple nights it looks as if they are crossing a line and hitting consistently then we go right back to where we started and they get shutout again. Will Brad Miller, Cory Hart, & Dustin Ackley please stand up?
Who Gets The Honor Of Taking The Mound At Target Field First For The AL?
NWSB Insider and Seattle Mariners blogger Brian Scott weighs in on Felix Hernandez starting in the 2014 MLB All Star Game. Describing the race for the right to start the All-Star game as "tight" might be something of an understatement. Both Hernandez and Masahiro Tanaka have made a clear separation from the rest of the group.
Is the Seattle Mariners' Kyle Seager an All-Star?
NWSB Insider and Seattle Mariners blogger Brian Scott weighs in on the chances of Kyle Seager being a 2014 AL All Star. Robinson Cano has been in the top five in hitting numbers for some time and is certain to make the team. Felix Hernandez might be having the best season of his career and will make the team as well. Does the never vocal, Mariners 3rd baseman have a shot at this year's Summertime Classic?
The Seattle Mariners 2014 Mid-Season Report Card
NWSB Insider & Seattle Mariners blogger Brian Scott weighs in with his M's midseason grades. The Mariners have compiled 43 wins vs. 38 losses which puts them solidly in 3rd place in the AL West. Bright spot? M's bullpen. Led by a guy most people really didn't see coming in Dominic Leone. Leone has given up just eight earned runs all year in 29 appearances giving him a 2.18 ERA.
Seattle Mariners Disabled List Log Jam
4 Players Ready But Is There Room? The beginning of the week began with a bang for the Seattle Mariners as they made chopped clams out of the defending World Champion Boston Red Sox. At the same time, however, several of their key players were down in Tacoma proving that they were healthy and ready […]

subset: commoncrawl


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My goal for the group is to have Central Florida affiliate marketers get together to network, discuss industry issues and learn from each other. Whether you're an affiliate marketing veteran or just getting started, this Meetup group is for you. Meetups will take place in the Orlando area.
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See IMETCO at Greenbuild
As specialists in the metal building envelope, IMETCO representatives employ a hands-on approach to being your technical advisor through every phase of your project.
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Caffiends, Lil Skritt, MC Stealth (aka Blak Angel), The Spice of Life, The Modrats
The Milestone Club
3400 Tuckaseegee Rd.
Charlotte, NC, 28208
Doors 8:00 PM / Show 9:00 PM
This event is 18 and over
Old School Pop Punk.
Lil Skritt
Blazing the weirdest hip hop and r and b.
Holla at ja boi.
MC Stealth (aka Blak Angel)
Born and raised in the South, MC Stealth uses her southern roots to make a combo of blues, hip-hop, and folk rock fusion, and will capture your heart with her honest energy and love for making music.
The Spice of Life
The Spice of Life is new band currently working on music. The name comes from the saying "Variety, is the spice of life." We play and experiment with a wide range of different genres from heavy metal to funk/rock/reggae which creates our own unique sound.
The Modrats
The modrats were born six years ago when Ryan H., Lee K. and Pete S. emerged from their alien sac pods slimy, smelly and prepared to rock. Ryan played guitar and sang, Pete played bass and Lee the drums. It took five years of very liitle effort and absolutely no work before they started to play in front of people. After a short year of playing shows consistenly around Rock Hill and Charlotte the modrats realized they sucked and looked for a talented guitarist to hold them together. They looked no further than Rock Hills own Jeff B. Jeff felt sorry for the modrats and agreed to play thier stupid songs about ninjas and yetis. A few short months later Lee and Pete realized that Ryan smelled of cheetos and rotten fish. The smell angered them and they punched Ryan square in the nose and left the band. Saddened, heart broken and smelling of rotten fish Ryan and Jeff were determined to find a bassist and drummer who wouldn't punch them in the nose. Ten seconds later they recruited Michael B. on bass and Mike S. on drums. Now a complete band again the modrats decided to start a charitable organization aimed torwards keeping wombats from being infected with radioactive goo and in turn radioactive wombat killing machines. They quickly realized there was way too much involved in running a charitable organization and decided to record a new album instead. The new album "Set Your Phazers to Fun" will be released early in 2011 and the modrats continue to play shows around the carolinas. Michael and Mike have yet to punch Ryan in the nose.
Upcoming Events
The Milestone Club
Mon, March 30
Buck Biloxi and the Fucks, Heavy Lids, Bends, Banda Suki
Tue, March 31
Single Mothers, The Dirty Nil, Viajando, Cabron
Wed, April 1
Death Of Paris, Signs of Iris, Mr. Gold, Bad Karol, Summer Movie Clubhouse
Thu, April 2
Burnt Books, Pig Mountain, Sea of Storms, Crazy Bag Lady
Fri, April 3
The Emotron, Rickolus, Snoot, Bless These Sounds Under the City
Sat, April 4
Southside Punx, Drunk in a Dumpster, Future Crimes, Queen City Rejects
Sun, April 5
Mikey Classic and His Lonesome Spur, Call Me Bronco, Dead Cat
Mon, April 6
Swell Friends, The Moms, Aloha Broha, Lions to Lambs
Wed, April 8
Big Lo, DJ A to the L, Sulfur, Jon Notty, LockStarr: The Anti-sHeRo
Thu, April 9
Tecate Sunrise, H.i.V., Orange Crush
Caffiends, Lil Skritt, MC Stealth (aka Blak Angel), The Spice of Life, The Modrats
Sunday, August 18 · Doors 8:00 PM / Show 9:00 PM at The Milestone Club


text: The Bulma Returns! wiki last edited by pikahyper on 06/13/14 07:18AM View full history In the frozen north, Goku's one-man fight against the Red Ribbon Army continues as he storms the perilous Muscle Tower! Can he defeat General White's squad of ninjas, cyborgs, and worse, and save the peaceful people of Jingle Village from their oppressors? Then, Gorku travels to the City of the West to visit his old friend Bulma, who joins him on his quest, bringing her latest inventions. Their quest for the next Dragon Ball takes them around the world to a jungle island in the South Seas...but to get THIS Dragon Ball they'll have to go through General Blue!Chapter TitlesTale 61: The 4 Tatami FlipTale 62: The Ninja Split!Tale 63: Mechanical Man No.8Tale 64: The Horrible...Jiggler!Tale 65: How to Unjiggle a JigglerTale 66: Muscle Tower's Final HourTale 67: Go West, Young GokuTale 68: Monkey in the CityTale 69: Bulma and GokuTale 70: Bulma's Big Mistake!!Tale 71: The Turtle Is Spotted!Tale 72: The Blue Meanies


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SALA Phuket Resort & Spa - Bang Tao Beach, Phuket
333 Moo 3 Thalang District - Phuket1-877-662-6988
SALA Phuket Resort & Spa is a beachfront boutique villa in Mai Khao.
Sala Spa is the place to be for rest and relaxation, offering thalassotherapy, aromatherapy, body scrubs, body treatments, as well as body wraps, facials and massage/treatment rooms. This 5 star Mai Khao villa has its own restaurant serving breakfast, lunch and dinner where you will find a selection of items to try. Don't forget to pack your swimsuit and towel as this villa features 3 outdoor swimming pools. Guests can also enjoy drinks at the beach or in the comfort of the lounge as there are bars both in and out. Additional leisure facilities include a library. Knowledgeable staff are available at the front desk 24 hours-a-day and can provide tour/ticket assistance. Child-friendly amenities at this villa include a children's pool and babysitting.
The villa has a meeting room available for hire. Free Wi-Fi is available. Other amenities include gift shops/newsstands, dry cleaning/laundry, beach/pool umbrellas and a computer station.
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Check Availability at SALA Phuket Resort & Spa
Breakfast at SALA Phuket Resort & Spa
A free cooked-to-order breakfast is available between 7 AM and 11 AM.
Facilities at SALA Phuket Resort
- Bar
- Restaurant/Dining
- Laundry service
- Room service - 24 hour
- Gift shop
- Beach umbrellas and deck loungers
- Gym
- Children swimming pool
- Front desk - 24 hour
- City tour
- Shuttle service from and/or to the airport
- Free parking
- Steam bath
- Massages
- Spa/Wellness Centre
- Meeting Room
- Internet/Email services
Know before you go
- This property offers transfers from the airport (surcharges may apply). Guests must contact the property with arrival details 24 hours prior to arrival, using the contact information on the booking confirmation.
- Reservations are required for massage services and spa treatments. Reservations can be made by contacting the villa prior to arrival, using the contact information on the booking confirmation.
- A resort fee is included in the total price displayed.
- No pets and no service animals are allowed at this property.
Check-in: after 4 PM.
Check-out: before noon.
PolicyExtra-person charges may apply and vary depending on hotel policy.
Government-issued photo identification and a credit card or cash deposit are required at check-in for incidental charges.
Special requests are subject to availability upon check-in and may incur additional charges. Special requests cannot be guaranteed.
City tax and/or any other fees charged by the hotel
The following fees and deposits are charged by the property at time of service, check-in, or check-out.
- Airport shuttle fee: THB 900
- Rollaway bed fee: THB 2450 per night
The above list may not be comprehensive. Fees and deposits may not include tax and are subject to change.
SALA Phuket Resort & Spa is also known as
Sala Phuket Resort And Spa
Sala Phuket Hotel
Sala Phuket Mai Khao
Sala Phuket Hotel Mai Khao
SALA Phuket Resort
Room Details
SALA Phuket Resort & Spa offers 79 guest rooms for your beach holiday. Rooms open onto patios. Guests can kick back at the end of a busy day and enjoy 32-inch LCD televisions with satellite channels and DVD players. Business travelers visiting the Mai Khao area will have access to free wireless high-speed Internet access as well as desks and safes.
A good night's sleep in comfortable beds with premium bedding will have visitors waking up refreshed and well-rested throughout their vacation or business trip. Private bathrooms are outfitted with separate bathtubs and showers, bathrobes, slippers and hair dryers. Refrigerators, minibars, coffee/tea makers and complimentary bottled water are supplied in each room to facilitate basic travel needs. Rooms also include air conditioning and ceiling fans.
Bathroom toiletries are provided free of charge. A turndown service is available.
Accommodation Services
- Air conditioning
- Mini bar
- Mini fridge
- Extra beds
- Coffee and tea maker
- Hairdryer in each room
- Safe
- Desk
- DVD player
- LCD flat screen TV
- Satellite TV
- Fan
- Wireless Internet access
Distances from SALA Phuket ResortMai Khao Beach - 3.8 km / 2.4 mi
Splash Jungle Water Park - 4.7 km / 2.9 mi
Blue Canyon Country Club - 7 km / 4.4 mi
Nai Thon Beach - 11.4 km / 7.1 mi
Layan Beach - 13.8 km / 8.6 mi
Wat Pra Thong - 14.5 km / 9 mi
Ton Sai Waterfall - 16.2 km / 10.1 mi
Laguna Phuket Golf Club - 16.5 km / 10.3 mi
Gibbon Rehabilitation Centre - 16.8 km / 10.4 mi
Bang Pae Waterfall - 16.8 km / 10.4 mi
Khao Phra Thaeo National Park - 16.8 km / 10.4 mi
Bang Rong Pier - 17.8 km / 11 mi
Ao Po - 18.4 km / 11.5 mi
Pansea Beach - 19.8 km / 12.3 mi
Wat Si Sunthon - 19.8 km / 12.3 mi
The preferred airport for SALA Phuket Resort & Spa is Phuket (HKT-Phuket Intl.) - 5.8 km / 3.6 mi.
Distances are calculated in a straight line from the property's location to the point of interest or airport and may not reflect actual travel distance.
Distances are displayed to the nearest 0.1 mile and kilometer.
Transportation services SALA Phuket Resort & Spa
- Shuttle service from and/or to the airport
- Free parking
We have the accommodation you need, all over the world
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Oh, Peter Odemwingie. When will you learn? The West Bromwich Albion striker has hit out at his club by saying that they broke a gentleman's agreement which would have seen the Nigerian footballer join Queens Park Rangers. According to The Guardian, … Continue reading
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1980 BMW 320i
Original owner must sell classic 320i. The car is mint and all original (I am the 1st and only owner). All options, all functional, all service records. Only serious
... $13,500
1980 Chevrolet K20
GM/ Chevy & Dodge truck parts - 1961 Chevy 4x4 clean title and vin tag - Truck mirrors: pair of GM factory 1970-80s pickup/ Suburban mirrors in box one new, one
... $


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Joy loves smothering. She loves smothering the faces of slaves and losers especially when her feet are sweaty. She loves it when her slaves are humiliated and beg her for mercy. She likes listening to their crying voices because they are funny. She then adds on the punishment and gets them to cry more before she finally forgives them. By then, they must have developed an everlasting fear of her.
Keywords: sweaty feet, foot domination, crush fetish, pov femdom, femdom, slave, mistress


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"Pillar of Defense (Cloud)" - Israel & Hamas Agree to Gaza Cease Fire
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Anonymous Operation Israel - Press Release Thursday - November 15, 2012 2:00 AM ET USA Greetings World -- For far to long, Anonymous has stood by with the rest of the world and watched in despair the barbaric, brutal and despicable treatment of the Palestinian people in the so called "Occupied Territories" by the Israel Defense Force. Like so many around the globe, we have felt helpless in the face of such implacable evil. And today's insane attack and threatened invasion of Gaza was more of the same. But when the government of Israel publicly threatened to sever all Internet and other telecommunications into and out of Gaza they crossed a line in the sand. As the former dictator of Egypt Mubarack learned the hard way - we are ANONYMOUS and NO ONE shuts down the Internet on our watch. To the IDF and government of Israel we issue you this warning only once. Do NOT shut down the Internet into the "Occupied Territories", and cease and desist from your terror upon the innocent people of Palestine or you will know the full and unbridled wrath of Anonymous. And like all the other evil governments that have faced our rage, you will NOT survive it unscathed. To the people of Gaza and the "Occupied Territories", know that Anonymous stands with you in this fight. We will do everything in our power to hinder the evil forces of the IDF arrayed against you. We will use all our resources to make certain you stay connected to the Internet and remain able to transmit your experiences to the world. As a start, we have put together the Anonymous Gaza Care Package - [
link to DON'T_USE-THIS
] - which contains instructions in Arabic and English that can aid you in the event the Israel government makes good on it's threat to attempt to sever your Internet connection. It also contains useful information on evading IDF surveillance, and some basic first aid and other useful information. We will continue to expand and improve this document in the coming days, and we will transmit it to you by every means at our disposal. We encourage you to download this package, and to share it with your fellow Palestinians to the best of your ability. We will be with you. No matter how dark it may seem, no matter how alone and abandoned you may feel - know that tens of thousands of us in Anonymous are with you and working tirelessly around the clock to bring you every aid and assistance that we can. We Are Anonymous We Are Everywhere We Are Legion We Do Not Forgive We Do Not Forget To the oppressors of the innocent Palestinian people, it is to late to EXPECT US
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Monsanto Asks World Health Organization to "Retract" Cancer Link
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Warmer spring air is here, water temperatures remain dangerously cold
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Fun Home
A Family Tragicomic
By Alison Bechdel
(Jonathan Cape, Paperback, 9780224080514)
Publication Date: October 2006
Other Editions of This Title: Hardcover, Paperback
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Selected by Indie Booksellers for the Fall '08/Winter '09 Reading Group List
"A stunning graphic memoir that weaves together the author's childhood and coming out and her father's secretive life and sudden death. Rife with literary allusions, this book is a boundary-smashing gem that redefined what a graphic novel could be. Hilarious, touching, and brilliant."
-- Sweet Pea Falherty, King's Books, Inc., Tacoma


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Mollie Makes Christmas
Living and Loving A Handmade Holiday
Add seasonal style to your projects with help from Mollie Makes , a wonderfully creative and crafty magazine and website. This cute and covetable book provides over 20 knitting, crochet, sewing and mixed-media ideas for the holidays. All of these whimsical projects are sprinkled with inspiration and insight to help you properly deck the halls, stuff stockings, and entertain stress-free during the chilly months. Craft unique handmade gifts and decorations with help from your favorite magazine contributors. With their insight, you'll learn how to stitch up a felt wreath, create paper cut ornaments, crochet a tiny reindeer or two, customize your own holiday cards and even make a set of five adorable finger puppets that just happen to be the perfect size for stocking stuffers. With clear step-by step instructions, exquisite photographs, and in-a-pinch tips, you'll have your Christmas crafting all wrapped up in no time.
Publisher: Loveland, Colo. : Interweave, 2012.
Characteristics: 95 p. :,ill. (some col.) ;,21 cm.
Alternate Title: Mollie makes.
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Latest bacterial pneumonia Stories
CHICAGO, March 11 /PRNewswire-FirstCall/ -- Advanced Life Sciences Holdings, Inc.
Complications following infection with the virus that causes flu (influenza virus) are one of the top ten causes of death in the United States. Although infection with influenza virus can directly cause death, many deaths following infection with influenza virus occur because the individual develops pneumonia due to secondary infection with bacteria such as Streptococcus pneumoniae.
Scientists at St. Jude Children's Research Hospital have demonstrated a more effective treatment for bacterial pneumonia following influenza.
Adding corticosteroids to traditional antimicrobial therapy might help people with pneumonia recover more quickly than with antibiotics alone, UT Southwestern Medical Center scientists have found.
A protein called Birc1e, found within the cells of the body, plays a key role in detecting and controlling infection with Legionella pneumophila, the bacterium that causes Legionnaire's disease, according to a new report.
Pneumonia doesn't appear to harm HIV-positive patients any more than those without HIV, according to a new international study conducted in part by the University of Alberta.
- One who brings meat to the table; hence, in some countries, the official title of the grand master or steward of the king's or a nobleman's household.


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Voices in Your Blood: Discovering Identity Through Family HistoryBy G. G. Vandagriff
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