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Wednesday, July 23, 2014
After stays vacated, Arizona needs two hours to complete another ugly execution
As reported in this AP piece, "Arizona executed Joseph R. Wood on Wednesday afternoon, but the execution lasted for nearly two hours as Wood struggled to breathe, according to his attorneys." Here are more of still-developing details of the latest in a series of ugly executions in 2014:
During his execution, Wood's attorneys filed a request to halt the lethal injection because he was still awake more than an hour after the process began. Wood was "gasping and snorting for more than an hour," they wrote in their filing.
The execution continued and Wood was pronounced dead at 3:49 p.m. (local time), the office of Arizona Attorney General Tom Horne said. This was nearly two hours after the execution began at 1:52 p.m.
Wood was the third inmate executed in Arizona since last October and the first put to death using a combination of the drugs midazolam and hydromorphone. "The experiment using midazolam combined with hydromorphone to carry out an execution failed today in Arizona," Dale Baich, an attorney for Wood, said in a statement. "It took Joseph Wood two hours to die, and he gasped and struggled to breath for about an hour and forty minutes."
Baich said he and others would continue seeking information about the drugs used. "Arizona appears to have joined several other states who have been responsible for an entirely preventable horror — a bungled execution," Baich said. "The public should hold its officials responsible and demand to make this process more transparent."
Recent related posts:
- Split Ninth Circuit panel stays Arizona execution based on First Amendment (really?!?!) drug secrecy concerns
- After Kozinski's candor, what will SCOTUS due about First Amendment stay in Arizona capital case?
- After SCOTUS vacates First Amendment stay, Arizona Supreme Court delays execution
July 23, 2014 in Baze lethal injection case, Death Penalty Reforms | Permalink | Comments (20) | TrackBack (0)
After SCOTUS vacates First Amendment stay, Arizona Supreme Court delays execution
As reported in this new AP story, after the US Supreme Court late yesterday vacated the novel stay imposed by the Ninth Circuit based on lethal injection drug secrecy concern, "Arizona's highest court on Wednesday temporarily halted the execution of a condemned inmate so it could consider a last-minute appeal." Here is more:
Joseph Rudolph Wood, 55, was scheduled to be put to death Wednesday morning at the state prison in Florence, but that was delayed when the Arizona Supreme Court said it would consider whether he received inadequate legal representation at his sentencing. The appeal also challenges the secrecy of the lethal injection process and the drugs that are used.
The state Supreme Court could still allow the execution to move forward later Wednesday once it considers the arguments.
The U.S. Supreme Court on Tuesday cleared the way for Arizona to carry out its third execution in the last year following a closely watched First Amendment fight over the secrecy issue. Wood's lawyers used a new legal tactic in which defense attorneys claim their clients' First Amendment rights are being violated by the government's refusal to reveal details about lethal injection drugs. Wood's lawyers were seeking information about the two-drug combination that will be used to kill him, including the makers of the drugs.
A federal appeals court ruled in Wood's favor before the U.S. Supreme Court put the execution back on track. The 9th U.S. Circuit Court of Appeals decision marked the first time an appeals court has acted to delay an execution based on the issue of drug secrecy....
Wood was sentenced to death for killing Debra Dietz and her father, Eugene Dietz, in 1989 at the family's automotive shop in Tucson.... On the day of the shooting, Wood went to the auto shop and waited for Dietz's father, who disapproved of his daughter's relationship with Wood, to get off the phone. Once the father hung up, Wood pulled out a revolver, shot him in the chest and then smiled. Wood then turned his attention toward Debra Dietz, who was trying to telephone for help. Wood grabbed her by the neck and put his gun to her chest. She pleaded with him to spare her life. An employee heard Wood say, "I told you I was going to do it, I have to kill you." He then called her an expletive and fired two shots in her chest....
Arizona has executed 36 inmates since 1992. The two most recent executions occurred in October.... The fight over the Arizona execution has also attracted attention because of a dissenting judge's comments that made a case for a firing squad as a more humane method of execution.
Recent related posts:
- Split Ninth Circuit panel stays Arizona execution based on First Amendment (really?!?!) drug secrecy concerns
- After Kozinski's candor, what will SCOTUS due about First Amendment stay in Arizona capital case?
July 23, 2014 in Baze lethal injection case, Death Penalty Reforms, Procedure and Proof at Sentencing, Sentences Reconsidered, Who Sentences? | Permalink | Comments (5) | TrackBack (0)
"Fewer Prisoners, Less Crime: A Tale of Three States"
The title of this post is the title of this notable new 11-page report coming from the folks at The Sentencing Project. Here is how the report begins and concludes:
Although the pace of criminal justice reform has accelerated at both the federal and state levels in the past decade, current initiatives have had only a modest effect on the size of the prison population. But over this period, three states — New York, New Jersey, and California — have achieved prison population reductions in the range of 25%. They have also seen their crime rates generally decline at a faster pace than the national average.
Key findings:
• New York and New Jersey led the nation by reducing their prison populations by 26% between 1999 and 2012, while the nationwide state prison population increased by 10%.
• California downsized its prison population by 23% between 2006 and 2012. During this period, the nationwide state prison population decreased by just 1%.
• During their periods of decarceration, violent crime rates fell at a greater rate in these three states than they did nationwide. Between 1999-2012, New York and New Jersey's violent crime rate fell by 31% and 30%, respectively, while the national rate decreased by 26%. Between 2006-2012, California's violent crime rate drop of 21% exceeded the national decline of 19%.
• Property crime rates also decreased in New York and New Jersey more than they did nationwide, while California's reduction was slightly lower than the national average. Between 1999-2012, New York's property crime rate fell by 29% and New Jersey's by 31%, compared to the national decline of 24%. Between 2006-2012, California's property crime drop of 13% was slightly lower than the national reduction of 15%.
These prison population reductions have come about through a mix of changes in policy and practice designed to reduce admissions to prison and lengths of stay. The experiences of these states reinforce that criminal justice policies, and not crime rates, are the prime drivers of changes in prison populations. They also demonstrate that it is possible to substantially reduce prison populations without harming public safety....
At least in three states we now know that the prison population can be reduced by about 25% with little or no adverse effect on public safety. Individual circumstances vary by state, but policymakers should explore the reforms in New York, New Jersey, and California as a guide for other states.
There is also no reason why a reduction of 25% should be considered the maximum that might be achieved. Even if every state and the federal government were able to produce such reductions, that would still leave the United States with an incarceration rate of more than 500 per 100,000 population — a level 3-6 times that of most industrialized nations.
In recent years a broader range of proposals has emerged for how to reduce the prison population and by various scales of decarceration. In a recent right/ left commentary Newt Gingrich and Van Jones describe how they will "be working together to explore ways to reduce the prison population substantially in the next decade." The experiences of New York, New Jersey, and California demonstrate that it is possible to achieve substantial reductions in mass incarceration without compromising public safety.
July 23, 2014 in Data on sentencing, Detailed sentencing data, Prisons and prisoners, Scope of Imprisonment, Sentences Reconsidered | Permalink | Comments (3) | TrackBack (0)
Should federal prosecutors be able to read emails sent by prisoners to their lawyers?
The question in the title of this post is prompted by this new front-page New York Times story, headlined "Prosecutors Are Reading Emails From Inmates to Lawyers." Here is the context:
The extortion case against Thomas DiFiore, a reputed boss in the Bonanno crime family, encompassed thousands of pages of evidence, including surveillance photographs, cellphone and property records, and hundreds of hours of audio recordings.
But even as Mr. DiFiore sat in a jail cell, sending nearly daily emails to his lawyers on his case and his deteriorating health, federal prosecutors in Brooklyn sought to add another layer of evidence: those very emails. The prosecutors informed Mr. DiFiore last month that they would be reading the emails sent to his lawyers from jail, potentially using his own words against him.
Jailhouse conversations have been many a defendant's downfall through incriminating words spoken to inmates or visitors, or in phone calls to friends or relatives. Inmates' calls to or from lawyers, however, are generally exempt from such monitoring. But across the country, federal prosecutors have begun reading prisoners' emails to lawyers — a practice wholly embraced in Brooklyn, where prosecutors have said they intend to read such emails in almost every case.
The issue has spurred court battles over whether inmates have a right to confidential email communications with their lawyers — a question on which federal judges have been divided....
Defense lawyers say the government is overstepping its authority and taking away a necessary tool for an adequate defense. Some of them have refused to admit even the existence of sensitive emails — which, they say, perhaps predictably, are privileged.
All defendants using the federal prison email system, Trulincs, have to read and accept a notice that communications are monitored, prosecutors in Brooklyn pointed out. Prosecutors once had a "filter team" to set aside defendants' emails to and from lawyers, but budget cuts no longer allow for that, they said.
While prosecutors say there are other ways for defense lawyers to communicate with clients, defense lawyers say those are absurdly inefficient.
July 23, 2014 in Procedure and Proof at Sentencing | Permalink | Comments (6) | TrackBack (0)
Tuesday, July 22, 2014
What do you get when you mix a challenge to a local $30 "booking fee" with a lot of very smart federal judges?
The answer to the seemingly silly question in the title of this post is provided by the 50+ pages of very interesting and dense discussions coming from a number of Seventh Circuit judges in its en banc ruling yesterday in Markadonatos v. Village of Woodridge. Will Baude at The Volokh Conspiracy provides here a relatively simple account of what transpired on appeal after Jeff Markadonatos challenged the constitutionality of being subject to a $30 administrative fee under a local ordinance following his custodial arrest and booking procedure. And Judge Sykes' opinion starts with this account of the fascinating en banc hash that the case became:
The ground has shifted under this case since we granted rehearing en banc.
• Three members of the court now propose to affirm by invoking the doctrine of constitutional avoidance, an option not raised by the parties. See ante, at 7–15 (Posner, J., concurring in the judgment).
• Four members of the court would reverse and remand on the merits, though on a different analysis than originally argued by the plaintiff or adopted by the panel dissent. Compare post, at 45–49 (Hamilton, J., dissenting), with Markadonatos v. Village of Woodridge, 739 F.3d 984, 994–1000 (7th Cir. 2014) (Hamilton, J., dissenting), and Appellant's Br. at 9–28, 33–40, ECF No. 22 (panel brief).
• For my part, en banc review has reinforced my earlier doubts about the plaintiff's standing. I would vacate and remand with instructions to dismiss for lack of jurisdiction.
• Judges Easterbrook and Tinder substantially agree with me that the plaintiff lacks standing, although they conclude that a narrow aspect of the case is justiciable. See ante, at 17 (Easterbrook, J., concurring in the judgment). But they also disagree with Judge Posner's use of the constitutional-avoidance doctrine and instead would hold that the justiciable remainder is not viable as a due-process claim, as the plaintiff has argued it, but only as an equal-protection claim, which fails on the merits. See id. at 18–22.
In short, the en banc court cannot agree on what questions the case raises, whether the plaintiff is the right person to raise them, whether they have been properly preserved, or what doctrinal framework applies. Our fractured nondecision suggests that this case was a poor vehicle for resolving the constitutionality of a jail booking fee.
July 22, 2014 in Procedure and Proof at Sentencing | Permalink | Comments (9) | TrackBack (0)
Within-guideline sentences remain below 50% according to latest quarterly USSC data
As reported in this post a few months ago, US Sentencing Commission First Quarter FY14 Quarterly Sentencing data included some big news: for the first time, less than half of all federal sentences imposed were technically "within-guideline" sentences. To be exact, in that quarter, only around 49% of the 18,169 sentences imposed were within-guideline sentences.
Today, the USSC released, via this document, its Second Quarter FY14 Quarterly Sentencing data, and it remains the case that a slight majority of federal sentences are being imposed outside the guidelines. But, as Table 4 on this latest data run reveals, this reality is partially a product of the fact that in the second quarter of FY14 there was a record-high percentage of above-guideline sentences (2.5%) and a record-high percentage of government-sponsored below-guideline sentences (28.6%). In this last quarter, notably, there was actually a small downtick in the number of below guideline sentences imposed by federal district judges (from 20.7% of all federal cases down to 20.1%).
As I have said before, I believe all the recent talk about the need for federal sentencing reform is likely finding expression in the way both federal prosecutors and federal judges are now using their sentencing discretion. The data from the last few quarters suggest that, as we hear ever more public policy groups and politicians on both the right and the left echoing AG Eric Holder's call for less reliance on long terms of incarceration, more federal prosecutors and federal judges feel ever more justified in seeking/imposing more sentences below the guidelines.
July 22, 2014 in Booker in district courts, Detailed sentencing data, Federal Sentencing Guidelines, Who Sentences? | Permalink | Comments (0) | TrackBack (0)
"Strictly Taboo: Cultural Anthropology's Insights into Mass Incarceration and Victimless Crime"
The title of this post is the title of this notable new paper by Brennan Hughes available via SSRN. Here is the abstract:
I argue that cultural anthropology can explain two persistent riddles of American criminal justice: (1) Why do we have mass incarceration when mass incarceration is ineffective and socially destructive? (2) Why do we have victimless crimes when criminal law is ostensibly based on the utilitarian harm principle?
One answer is found in the anthropological "survivals" known as "uncleanness" and "taboos." These visceral, often subconscious, feelings function to preserve order, the status quo, and class distinctions. Despite the gains made in civil rights, nonwhites and the underclass remain "the other," and they threaten to "contaminate" the majority population. Crime itself, as a threat to social stability, has become charged with a powerful ability to attract and repel. Crime and criminals are described using terms for dirt and feces. The majority culture's response to crime (which is linked with its unconscious response to the lower class and minorities) is to expel such pollution into sealed containers called prisons. The ritualism of civic religion completes the purification process.
Deeply felt taboos also persist concerning sex and drugs. While marijuana possession and use harms no one but the user, marijuana is historically taboo on account of its association with minorities and radicals. Incest is criminalized and sex with minors is hyper-punished because they violate deeply felt sexual taboos.
I argue that one promising solution is to help people develop a stronger taboo (through education) that can cancel out the dehumanizing taboos toward criminals (just as the taboo against homophobia has supplanted the taboo against homosexuality). We will continue to overpunish until hyper-punishment itself becomes repulsive.
July 22, 2014 in Purposes of Punishment and Sentencing, Scope of Imprisonment | Permalink | Comments (2) | TrackBack (0)
After Kozinski's candor, what will SCOTUS due about First Amendment stay in Arizona capital case?
The question in the title of this post follows up the news, reported here by the AP, that the full Ninth Circuit yesterday denied Arizona officials en banc review of the remarkable panel ruling putting in place an execution stay on First Amendment grounds (basics here). The AP reports that Arizona is, unsurprisingly, planning to ask SCOTUS to vacate the stay, and I suspect First Amendment challenges to executions protocols will become commonplace nationwide if SCOTUS leaves the stay in place.
Chief Judge Alex Kozinski make extra sure his dissent — which is available here along with another dissent authored by Judge Callahan for 11 other members of the Ninth Circuit — garnered extra attention by providing these candid comments at the close of his operion about the fundamental problems with lethal injection as an execution method:
Whatever happens to Wood, the attacks [on lethal injection execution procedures] will not stop and for a simple reason: The enterprise is flawed. Using drugs meant for individuals with medical needs to carry out executions is a misguided effort to mask the brutality of executions by making them look serene and peaceful—like something any one of us might experience in our final moments. See Callins v. Collins, 510 U.S. 1141, 1143 (1994) (Scalia, J., concurring in denial of certiorari) ("How enviable a quiet death by lethal injection . . . ."). But executions are, in fact, nothing like that. They are brutal, savage events, and nothing the state tries to do can mask that reality. Nor should it. If we as a society want to carry out executions, we should be willing to face the fact that the state is committing a horrendous brutality on our behalf.
If some states and the federal government wish to continue carrying out the death penalty, they must turn away from this misguided path and return to more primitive — and foolproof — methods of execution. The guillotine is probably best but seems inconsistent with our national ethos. And the electric chair, hanging and the gas chamber are each subject to occasional mishaps. The firing squad strikes me as the most promising. Eight or ten large-caliber rifle bullets fired at close range can inflict massive damage, causing instant death every time. There are plenty of people employed by the state who can pull the trigger and have the training to aim true. The weapons and ammunition are bought by the state in massive quantities for law enforcement purposes, so it would be impossible to interdict the supply. And nobody can argue that the weapons are put to a purpose for which they were not intended: firearms have no purpose other than destroying their targets. Sure, firing squads can be messy, but if we are willing to carry out executions, we should not shield ourselves from the reality that we are shedding human blood. If we, as a society, cannot stomach the splatter from an execution carried out by firing squad, then we shouldn't be carrying out executions at all.
While I believe the state should and will prevail in this case, I don't understand why the game is worth the candle. A tremendous number of taxpayer dollars have gone into defending a procedure that is inherently flawed and ultimately doomed to failure. If the state wishes to continue carrying out executions, it would be better to own up that using drugs is a mistake and come up with something that will work, instead.
July 22, 2014 in Baze lethal injection case, Death Penalty Reforms, Procedure and Proof at Sentencing, Sentences Reconsidered, Who Sentences? | Permalink | Comments (6) | TrackBack (0)
Monday, July 21, 2014
John Oliver covers the realities of incarceration nation
A whole lots of folks have sent me notes to make sure I saw the remarkable 15+ minute piece on John Oliver's HBO show about modern prison realities in the United States. To make sure everyone gets to see this effective (and humorous) piece of journalism, here is the video:
July 21, 2014 in Prisons and prisoners, Scope of Imprisonment | Permalink | Comments (6) | TrackBack (0)
Thoughtful Teague-based criticism of the remarkable California capital ruling in Jones v. Chappell
Among a large number of major sentencing developments last week, the biggest in the capital punishment arena was clearly, as discussed here and here, U.S. District Judge Cormac Carney ruling that all of California's death penalty system is unconstitutional. The ruling in Jones v. Chappell, No. 2:09-cv-02158-CJC (C.D. Cal. July 16, 2014) (available here), has already generated lots of thoughtful discussion (as reflected in posts here and here), and I am now pleased to reprint another insightful bit of analysis sent my way over the weekend. Specifically, Professor Richard Broughton sent me an e-mail with his reaction ot the Jones ruling and kindly permitted me to reprint this excerpt:
It looks to me as if the case should (or at least could) have been disposed of on Teague v. Lane grounds.
I was troubled that California didn't raise Teague, and was glad that Judge Carney addressed it sua sponte. But his analysis was entirely perfunctory and merely glossed over, or simply failed to cite, a number of important Supreme Court precedents on Teague and "new rules." (Chaidez, Summerlin, Lambrix, etc.). I suppose one could argue that Jones was asking for a substantive rule rather than a procedural one, and could therefore avoid the Teague bar. That strikes me as a stronger way to avoid Teague in this case. But Judge Carney didn't articulate his ruling this way. Instead, Judge Carney simply said the rule was not "new," thus alleviating any need to categorize it as a substantive or procedural rule. In light of the Supreme Court's (and other courts') consistent rejection of delay-as-cruel-and-unusual-punishment claims, it would seem to me that a reasonable jurist would not have felt compelled by precedent to conclude that Jones was entitled to relief. Hence, the rule here was "new."
Judge Carney's effort to avoid the "new" rule bar by claiming that this ruling fits within the dictates of Furman and its progeny with respect to the wanton and freakish imposition of the death penalty strikes me as entirely wrong (and barred, if we are talking about a procedural rule). Jones wasn't merely trying to have Furman apply to a new set of facts -- it was an effort to extend Eighth Amendment doctrine to situations where there are long delays, an extension that was not dictated by Furman and that courts have routinely rejected (indeed, if the rule was dictated by precedent, why has it been so often rejected?). I would think the State could plausibly argue that, despite Furman and its progeny, the precise rule that Jones was seeking -- that delays in his execution render his sentence unconstitutional because California's death penalty system has not followed procedures that would expedite capital cases -- was not dictated by precedent when his conviction became final. Therefore, there would have been a need to decide whether it was substantive or procedural, and if procedural, it would be barred. There is, in fact, Ninth Circuit precedent on this very matter, applying the Teague bar to a Lackey claim.
I read Bill Otis's post at C&C on Jones as essentially requiring a Miranda-type prophylaxis. I agree substantially with that view (though I think few other federal courts would come out and say this is what they are requiring), and I think California and others may start thinking about some legislative reforms to address the problem that Judge Carney identifies. I think even those of us who support the death penalty acknowledge that delays are a problem, though for different reasons than the capital defense bar thinks. But if Otis's view is accurate, doesn't that simply serve to reinforce the reality that Teague bars the rule that Judge Carney set forth?
Of course, I am troubled by many aspects of the case, not just the Teague analysis. That's just the tip of the iceberg for me. But I didn't see anyone else talking about Teague. Maybe there's a good reason for that; maybe my view of the Teague issue is premature and I'm ultimately wrong. My mind is open. But I am concerned that this view could take hold not just in more California cases on habeas review, but in other jurisdictions, as well. And I think California and the others should be prepared to assert the Teague bar (if my instincts are right). At a minimum, I think Teague is a plausible basis for rejecting these kinds of claims, and that the case should have at least dealt more extensively with that doctrine.
Recent related posts:
- Federal district judge declares California's death penalty unconstitutional under Eighth Amendment
- Lots of notable discussion of yesterday's notable decision striking down California's death penalty
- Furman and randomness (not just delay) at heart of California capital ruling
July 21, 2014 in Death Penalty Reforms, Procedure and Proof at Sentencing, Sentences Reconsidered, Who Sentences? | Permalink | Comments (4) | TrackBack (0)
"Liberal but Not Stupid: Meeting the Promise of Downsizing Prisons"
The title of this post is the title of this important and timely new paper authored by two terrific criminologists, Professors Joan Petersilia and Francis T. Cullen, and now available via SSRN. Here is the abstract:
A confluence of factors — a perfect storm — interfered with the intractable rise of imprisonment and contributed to the emergence of a new sensibility defining continued mass imprisonment as non-sustainable. In this context, reducing America's prisons has materialized as a viable possibility. For progressives who have long called for restraint in the use of incarceration, the challenge is whether the promise of downsizing can be met.
The failure of past reforms aimed at decarceration stand as a sobering reminder that good intentions do not easily translate into good results. Further, a number of other reasons exist for why meaningful downsizing might well fail (e.g., the enormous scale of imprisonment that must be confronted, limited mechanisms available to release inmates, lack of quality alternative programs). Still, reasons also exist for optimism, the most important of which is the waning legitimacy of the paradigm of mass incarceration, which has produced efforts to lower inmate populations and close institutions in various states.
The issue of downsizing will also remain at the forefront of correctional discourse because of the court-ordered reduction in imprisonment in California. This experiment is ongoing, but is revealing the difficulty of downsizing; the initiative appears to be producing mixed results (e.g., reductions in the state's prison population but increased in local jail populations). In the end, successful downsizing must be "liberal but not stupid." Thus, reform efforts must be guided not only by progressive values but also by a clear reliance on scientific knowledge about corrections and on a willingness to address the pragmatic issues that can thwart good intentions. Ultimately, a "criminology of downsizing" must be developed to foster effective policy interventions.
July 21, 2014 in Data on sentencing, Prisons and prisoners, Purposes of Punishment and Sentencing, Scope of Imprisonment, Sentences Reconsidered | Permalink | Comments (3) | TrackBack (0)
How many of nearly 50,000 federal prisoners need a lawyer to help with drug sentence reduction efforts? How many will get a lawyer?
The questions in the title of this post are my first "practical aftermath" questions in the wake of the US Sentencing Commission's big, important vote late Friday to make its new reduced drug offense guidelines fully retroactive (basics here). As hard-core federal sentencing fans likely already know, most lower federal courts have ruled that federal prisoners do not have a Sixth Amendment right to counsel applicable at the sentence modification proceedings judges must conduct to implement reduced retroactive sentencing guidelines. Consequently, none of the nearly 50,000 federal drug offense prisoners who may soon become eligible for a reduced sentence have any right to legal assistance in seeking this reduced sentence.
Fortunately for many federal prisoners seeking to benefit from previous guideline reductions, many federal public defender offices have traditionally made considerable efforts to provide representation to those seeking reduced sentences. But even the broadest guideline reductions applied retroactively in the past (which were crack guideline reductions) applied only to less than 1/3 of the number of federal prisoners now potentially eligible for reductions under the new reduced drug guidelines. I suspect that pubic defenders are unlikely to be able to provide significant legal help to a significant number of drug offenders who will be seeking modified sentences under the new reduced drug guidelines.
I raise this point not only to highlight the legal services need created by the USSC's big, important vote late Friday to make its new reduced drug offense guidelines fully retroactive, but also to wonder aloud whether lawyers who have been gearing up to help with clemency applications might be now usefully "detailed" to help with retroactive application of reduced drug sentences. In contrast to clemency petitions, in which legal arguments are somewhat less important than equitable claims, the proper application of new reduced drug offense guidelines can involve various legal issues that may really need to be addressed by sophisticated legal professionals.
Some recent related posts on reduced drug guideline retroactivity:
- Big US Sentencing Commission hearing on reduced drug guideline retroactivity
- DOJ advocates for "limited retroactivity of the pending drug guideline amendment"
- Commentary on drug guideline retroactivity asks "Who's Afraid of Too Much Justice?"
- US Sentencing Commission releases two significant research reports concerning drug sentencing reform and retroactivity
- Some new posts highlighting the "tough-on-crime" take on federal drugs sentencing reform
- Two thoughtful criticisms of DOJ's request for only limited retroactivity of proposed lower drug guidelines
- Huge reduced drug guideline retroactivity decision expected from US Sentencing Commission on 7/18
- USSC votes for full (though slightly delayed) retroactivity of new reduced drug guidelines
July 21, 2014 in Federal Sentencing Guidelines, Procedure and Proof at Sentencing, Sentences Reconsidered, Who Sentences? | Permalink | Comments (19) | TrackBack (0)
Split Ninth Circuit panel stays Arizona execution based on First Amendment (really?!?!) drug secrecy concerns
As reported in this new New York Times piece, a "federal appeals court has delayed the imminent execution of an Arizona man, saying he has a legal right to details about the lethal injection drugs to be used and about the qualifications of the execution team." Here is more about a ruling sure to garner more attention (and litigation) in the week ahead:
The ruling on Saturday, by a divided three-judge panel of the United States Court of Appeals for the Ninth Circuit, in San Francisco, contrasted sharply with recent decisions by other state and federal courts defending states' rights to keep information about drug sources secret. "This is the first time a circuit court has ruled that the plaintiff has a right to know the source of execution drugs," said Jennifer Moreno, an expert on lethal injection law at the Death Penalty Clinic of the University of California, Berkeley, School of Law.
The appeals court ruling came four days before the scheduled execution of Joseph Wood, who was convicted of the killings of two people and sentenced to death....
Arizona officials ... Sunday ... appealed to the Ninth Circuit for reconsideration by a wider panel of judges and it appeared possible that the state would appeal all the way to the United States Supreme Court if necessary.
Federal or state courts in places including Georgia, Louisiana, Missouri, Oklahoma and Texas have permitted executions to take place despite similar challenges to secrecy about drug manufacturers. So far, the Supreme Court has refused to intervene. The Arizona case reflects the growing turmoil in the administration of capital punishment as the supply of traditionally used drugs has dried up, mainly because companies are unwilling to sell them for executions. States are trying out new drug combinations and scrambling for secret sources, while lawyers for the condemned have argued that they have a right to know precise details about drug origins and quality....
Mr. Wood was sentenced to death for the 1989 murders of his estranged girlfriend, Debra Dietz, and her father. He was scheduled to be executed on Wednesday. Lacking its two preferred execution drugs, Arizona officials said they would use a combination of the drugs midazolam and hydromorphone, which has been used by Ohio.
The state said it obtained drugs approved by the Food and Drug Administration with expiration dates in the fall of 2015, but refused to reveal the manufacturers and batch numbers. It also refused to provide details about the qualifications of those who would administer the drugs, saying this could lead to disclosure of their identities.
Lawyers for Mr. Wood, led by Dale Baich, a federal public defender in Phoenix, challenged the secrecy, arguing that it violated their client's First Amendment rights of access to public proceedings. A Federal District Court sided with the state, but on Saturday, the appeals panel ruled that Mr. Wood "has presented serious questions going to the merits of his claim," according to the majority opinion, written by Judge Sidney R. Thomas. Arizona's secrecy, he wrote, "ignores the ongoing and intensifying debate over lethal injection in this country, and the importance of providing specific and detailed information about how safely and reliably the death penalty is administered."
In a dissent, Judge Jay S. Bybee said the court had drastically expanded the "right of access" and had misused the First Amendment "as the latest tool in this court's ongoing effort to bar the state from lawfully imposing the death penalty."
The majority Ninth Circuit panel opinion runs 28 pages, is available at this link, and concludes this way:
Because we conclude that Wood has raised serious questions as to the merits of his First Amendment claim; that the balance of equities tips sharply in his favor; that he will face irreparable harm if the injunction is not granted; and that the injunction is in the public interest; we conclude that the district court abused its discretion in denying Wood's preliminary injunction request. We do not decide with certainty that a First Amendment right exists to the information Wood seeks, nor do we resolve the merits of the Plaintiffs' underlying § 1983 claim. We do, however, reverse the district court's denial of Wood's preliminary injunction motion. We grant a conditional preliminary injunction, staying Wood's execution until the State of Arizona has provided him with (a) the name and provenance of the drugs to be used in the execution and (b) the qualifications of the medical personnel, subject to the restriction that the information provided will not give the means by which the specific individuals can be identified. Once he has received that information, the injunction shall be discharged without more and the execution may proceed.
The dissenting opinion by Judge Bybee runs 35 pages, is available at this link, and makes these concluding points:
The decision to inflict the death penalty is a grave and solemn one that deserves the most careful consideration of the public, the elected branches of government, and the courts. We must be cognizant that a life is at stake. But we cannot conflate the invocation of a constitutional right belonging to the public at-large — such as the First Amendment right of public access to certain proceedings and documents — with a policy judgment about if and when the death penalty ought to be imposed. In so doing, we usurp the authority of the Arizona legislature and disregard the instructions of the Supreme Court.
July 21, 2014 in Baze lethal injection case, Death Penalty Reforms, Procedure and Proof at Sentencing, Sentences Reconsidered, Who Sentences? | Permalink | Comments (2) | TrackBack (0)
Sunday, July 20, 2014
Tragic and personal criminal justice story: the killing of Professor Dan Markel
Like many other law professors and bloggers, I was stunned and deeply saddened upon learning yesterday that Florida State University law professor Dan Markel died after having been shot at his home. Paul Caron at Tax Prof has this post, Death of Dan Markel (1972-2014), with news reports and links to postings by other law profs and bloggers.
Dan was a personal friend, and his extraordinary commitment and contribution to big ideas in criminal law and theory during his (much too short) life cannot be easily overstated. Of particular note, Dan was among the most active and forceful voices seeking to define and defend a modern conception of retributive justice. For that reason and many others, I hope those responsible for this shocking crime are brought soon to justice.
All those who were close to and cared for Dan are in my thoughts and prayers. RIP Professor Dan Markel.
July 20, 2014 in On blogging | Permalink | Comments (4) | TrackBack (0)
Saturday, July 19, 2014
US Attorney for NJ: "Ex-offenders get time, now they need opportunity"
Especially in the wake of this US Sentencing Commission's big decision yesterday to vote for retroactive application of its new reduced drug guidelines (basics here and here), a recent opinion piece by the U.S. Attorney for the District of New Jersey, Paul Fishman, struck me as especially timely. This piece is headlined "Ex-offenders get time, now they need opportunity," and here are excerpts:
Every year, my office prosecutes several hundred defendants who have violated criminal laws passed by Congress. For most of those defendants, a term in federal prison is warranted. Whether they are public officials who betray their oaths, predators who threaten the safety of our neighborhoods and our children, or thieves who cheat the health care system, investors or the government — incarceration is the appropriate punishment.
But prison is usually not meant to last forever. More than 95 percent of federal prisoners will be released after serving their sentences. Altogether, 700,000 federal and state prisoners are released every year, along with millions more who stream through local jails.
Most return to their communities, trying to put their lives back together and avoid the pitfalls that got them in trouble. Bearing the stain of their convictions, they compete for jobs, look for housing and seek educational opportunities.
A staggering number don't succeed. Nationally, two-thirds of people released from state prisons are arrested again; half of those will end up back inside. Forty percent of federal prisoners return to jail in the first three years.
This level of recidivism is unacceptable. Offenders, their families and their communities are devastated by it. Public safety suffers for it. And with more than $74 billion spent annually on federal, state and local corrections, we can't afford it.
Prison alone isn't enough. Any smart law enforcement model prevents crime by supporting ex-offenders. That is why my U.S. Attorney's Office — along with federal judges, the federal public defender, and the U.S. Probation Office — began the "ReNew" program, a federal re-entry court in Newark. Those leaving federal prison at serious risk of reoffending are invited to participate.
They are closely supervised, meeting biweekly with federal Magistrate Judge Madeline Cox Arleo, our office, and the federal defenders, and more regularly with probation officers. And they are supported in obtaining housing, jobs, education, counseling and legal assistance. My office provides services to the team and participants and supervises research into the program's efficacy.
This week, the judge will preside over the first graduation ceremony for those who have successfully completed 52 weeks in the program. It is a hugely inspiring milestone for everyone involved, but especially for the graduates reimagining their lives despite great adversity....
Recently, my office launched the New Jersey Re-entry Council, a partnership with acting New Jersey Attorney General John Hoffman, other federal and state agencies, and NGO community members to share resources and ideas.
But there is one more partner we need: you. Finding a job after release is the most important key to success. In a recovering economy, securing a job after prison can be especially difficult. If you have a company that can train or hire our participants, or if you have access to housing, we need to hear from you....
One of every 100 adults in the United States is behind bars. Most will come home. They will have paid their debt and need a chance to support themselves, their families and their communities. We can look at ex-offenders returning to our communities as a risk, or we can help give them that chance. The potential rewards for their lives, for the economy and for our safety are incalculable.
July 19, 2014 in Prisons and prisoners, Reentry and community supervision, Scope of Imprisonment | Permalink | Comments (2) | TrackBack (0)
Friday, July 18, 2014
Split Iowa Supreme Court declares all mandatory juve sentencing terms violate state constitution
Thanks to a helpful reader, I learned this afternoon that the Iowa Supreme Court today declared unconstitutional pursuant to the Iowa Constitution the imposition of any and all mandatory terms of imprisonment on juvenile offenders. The majority ruling in Iowa v. Lyle, No. 11–1339 (Iowa July 18, 2014)
In this appeal, a prison inmate who committed the crime of robbery in the second degree as a juvenile and was prosecuted as an adult challenges the constitutionality of a sentencing statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. The inmate was in high school at the time of the crime, which involved a brief altercation outside the high school with another student that ended when the inmate took a small plastic bag containing marijuana from the student. He claims the sentencing statute constitutes cruel and unusual punishment in violation of the State and Federal Constitutions when applied to all juveniles prosecuted as adults because the mandatory sentence failed to permit the court to consider any circumstances based on his attributes of youth or the circumstances of his conduct in mitigation of punishment. For the reasons expressed below, we hold a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under article I, section 17 of the Iowa Constitution. Accordingly, we vacate the sentence and remand the case to the district court for resentencing. Importantly, we do not hold that juvenile offenders cannot be sentenced to imprisonment for their criminal acts. We do not hold juvenile offenders cannot be sentenced to a minimum term of imprisonment. We only hold juvenile offenders cannot be mandatorily sentenced under a mandatory minimum sentencing scheme.
The majority opinion supporting this ruling runs nearly 50 pages and, unsurprisingly, has a lot to say about the US Supreme Court's recent Eighth Amendment work in Graham and Miller. In addition, two forceful dissents follow the majority's opinion in Lyle, and here is the heart of one of the dissenting opinions:
By holding Lyle's seven-year mandatory minimum sentence for his violent felony is cruel and unusual punishment and unconstitutional under article I, section 17 of the Iowa Constitution, rather than under the Eighth Amendment, the majority evades review by the United States Supreme Court. As Justice Zager observes, no other appellate court in the country has gone this far. Our court stands alone in taking away the power of our elected legislators to require even a seven-year mandatory sentence for a violent felony committed by a seventeen-year-old. Will the majority stop here? Under the majority's reasoning, if the teen brain is still evolving, what about nineteen-year olds? If the brain is still maturing into the mid-20s, why not prohibit mandatory minimum sentences for any offender under age 26? As judges, we do not have a monopoly on wisdom. Our legislators raise teenagers too. Courts traditionally give broad deference to legislative sentencing policy judgments. See State v. Oliver, 812 N.W.2d 636, 650 (Iowa 2012) ("We give the legislature deference because '[l]egislative judgments are generally regarded as the most reliable objective indicators of community standards for purposes of determining whether a punishment is cruel and unusual.' " (quoting Bruegger, 773 N.W.2d at 873)). Why not defer today?
July 18, 2014 in Mandatory minimum sentencing statutes, Offender Characteristics, Procedure and Proof at Sentencing, Scope of Imprisonment, Sentences Reconsidered, Who Sentences? | Permalink | Comments (2) | TrackBack (0)
USSC votes for full (though slightly delayed) retroactivity of new reduced drug guidelines
I just received this early report via a credible source as to what the US Sentencing Commission did this afternoon on the issue of making its new lower guidelines retroactive:
The Commission just voted unanimously to make the "drugs minus 2" amendment retroactive with a single limitation -- no order reducing a sentence can take effect until Nov. 1, 2015. This is later than the Judicial Conference recommended (they proposed that it effect in May 2015 to give courts and probation time to prepare)....The Commission predicts that more than 46,000 will be eligible to seek a reduction. Part of the reason for the delayed effective date is to make sure each inmate is released with a re-entry plan and the opportunity for transitional steps such as halfway houses or home confinement.
UPDATE: Here is a link to the USSC's official press release about its vote, which starts this way:
The United States Sentencing Commission voted unanimously today at a public meeting to apply a reduction in the sentencing guideline levels applicable to most federal drug trafficking offenders retroactively, meaning that many offenders currently in prison could be eligible for reduced sentences beginning November 2015.
The Commission voted unanimously in April to amend the guidelines to lower the base offense levels in the Drug Quantity Table across drug types, which may mean lower sentences for most drug offenders going forward. Today the Commission decided that judges could extend that reduction to offenders currently in prison, but with a requirement that reduced sentences cannot take effect until November 1, 2015. Under the guidelines, no offender would be released unless a judge reviews the case to determine whether a reduced sentence poses a risk to public safety and is otherwise appropriate.
"This amendment received unanimous support from Commissioners because it is a measured approach," said Judge Patti B. Saris, chair of the Commission. "It reduces prison costs and populations and responds to statutory and guidelines changes since the drug guidelines were initially developed, while safeguarding public safety."
Congress has until November 1, 2014 to disapprove the amendment to reduce drug guidelines. Should Congress choose to let the guideline reductions stand, courts could then begin considering petitions from prisoners for sentence reductions, but no prisoners could be released pursuant to those reductions before November 1, 2015.
ANOTHER UPDATE: Here is a link to the official statement in response to this vote from AG Eric Holder, which runs this single paragraph:
"The department looks forward to implementing this plan to reduce sentences for certain incarcerated individuals. We have been in ongoing discussions with the Commission during its deliberations on this issue, and conveyed the department's support for this balanced approach. In the interest of fairness, it makes sense to apply changes to the sentencing guidelines retroactively, and the idea of a one-year implementation delay will adequately address public safety concerns by ensuring that judges have adequate time to consider whether an eligible individual is an appropriate candidate for a reduced sentence. At my direction, the Bureau of Prisons will begin notifying federal inmates of the opportunity to apply for a reduction in sentence immediately. This is a milestone in the effort to make more efficient use of our law enforcement resources and to ease the burden on our overcrowded prison system."
July 18, 2014 in Drug Offense Sentencing, Federal Sentencing Guidelines, Sentences Reconsidered, Who Sentences? | Permalink | Comments (8) | TrackBack (0)
Furman and randomness (not just delay) at heart of California capital ruling
As discussed here and here, U.S. District Judge Cormac Carney earlier this week declared all of California's death penalty system unconstitutional in Jones v. Chappell, No. 2:09-cv-02158-CJC (C.D. Cal. July 16, 2014) (available here). Because much of the opinion documents how "California's death penalty system [has become] so plagued by inordinate and unpredictable delay that the death sentence is actually carried out against only a trivial few of those sentenced to death," much criticism of the opinion questions how a very long delay between a death sentence and an execution could alone render a sentence unconstitutional. As noted before, Kent Scheidegger here at Crime & Consequesnces has stressed that few Justices have taken "seriously a claim that a death sentence could be rendered unconstitutional by the length of time taken by the many procedures to review it." And now Orin Kerr here at The Volokh Conspiracy explains why he "found the [Jones] opinion unusually weak" given all the "obvious puzzles raised by delay-based Eighth Amendment claims."
Though decades of delay between a death sentence and possible execution is part of the equation of the Judge Carney's ruling in Jones v. Chappell, I see the concept of randonmess to be more fundamental and more fundamentally important to Judge Carney's constitutional conclusion. Judge Carney cites repeatedly the various opinions in the Supreme Court's 1972 landmark ruling in Furman v. Georgia which found an Eighth Amendment violation based ina state's sentencing process making it essentially random (or "arbitrary") who ultimately gets sentenced to die among a large pool of eligible capital defendants. I read Judge Carney's opinion as extending Furman by concluding that the Eighth Amendment is also violated if and when a state's appeals process makes it essentially random (or "arbitrary") who ultimately gets executed among among a large pool of condemned defendants sentenced to die.
Because Furman remains good law (and obviously has nothing to do with execution delay), I think there is a little more "juice" to the ruling in Jones v. Chappell than suggested by those whose criticisms are focused only on execution delay aspects of the ruling. Indeed, in order to keep the focus on Furman and randomness, consider a variation on a hypothetical statute present to students when discussing Furman. Consider, dear readers, if you think a state would be constitutionally allowed to pass a capital law along these lines:
Because of the huge costs associated with adequate appellate review of death sentences, state appeals courts should randomly select (via a fair lottery process) only 1 out of every 50 death sentences to be subject to full and fair appellate review each year. All death sentences shall be indefinitely stayed (and no execution date imposed) unless and until a death sentence has been is randomly selected for, and properly subject to, full and fair appellate review.
Of course, California has not formally passed such a law. But Judge Carney's ruling (rightly) finds that California functionally operates its capital punishment system this way AND then (questionably) concludes such a capital punishment system violates the Eighth Amendment based on Furman.
Recent related posts:
- Federal district judge declares California's death penalty unconstitutional under Eighth Amendment
- Lots of notable discussion of yesterday's notable decision striking down California's death penalty
July 18, 2014 in Death Penalty Reforms, Procedure and Proof at Sentencing, Sentences Reconsidered | Permalink | Comments (9) | TrackBack (0)
Thursday, July 17, 2014
Huge reduced drug guideline retroactivity decision expected from US Sentencing Commission on 7/18
As this official public notice reports, on July 18, 2014 at 1pm EDT, the US Sentencing the Commission will hold a public meeting at which "the Commissioners will vote on whether or not to retroactively apply, in whole or in part, [its recent guideline] amendment reducing the drug quantity table by two levels." At the risk of overstating the importance of this vote, I am inclined to assert that it may be the most practically consequential USSC decision in nearly a decade. The (slightly misleading) headlines of these two media discussions of the coming vote helps to highlight why:
"Drug sentencing reforms could mean freedom for 51,000 federal prisoners"
"Thousands of Inmates Hang in the Balance of Friday Sentencing Vote"
It is likely hard for anyone who has not followed federal sentencing very closely for decades to fully appreciate all the dynamic challenges that this vote presents for the US Sentencing Commission (as well as for the US Department of Justice and for all those who work day-to-day the federal sentencing system). Helpfully, this extended BuzzFeed article by Evan McMorris-Santoro provide a primer on some of the issues swirling around this important USSC vote. The article's headline highlights its themes: "Despite Rhetoric, Obama Administration Pushes To Keep Thousands Of Felons In Jail Under Old Rules: The Justice Department announced major changes to the way federal drug crimes are punished this year. But the rules for existing convicts might be different — and many White House allies are angry."
Some recent related posts on reduced drug guideline retroactivity:
- Big US Sentencing Commission hearing on reduced drug guideline retroactivity
- DOJ advocates for "limited retroactivity of the pending drug guideline amendment"
- Commentary on drug guideline retroactivity asks "Who's Afraid of Too Much Justice?"
- US Sentencing Commission releases two significant research reports concerning drug sentencing reform and retroactivity
- Some new posts highlighting the "tough-on-crime" take on federal drugs sentencing reform
- Two thoughtful criticisms of DOJ's request for only limited retroactivity of proposed lower drug guidelines
July 17, 2014 in Drug Offense Sentencing, Federal Sentencing Guidelines, Prisons and prisoners, Procedure and Proof at Sentencing, Purposes of Punishment and Sentencing, Sentences Reconsidered, Who Sentences? | Permalink | Comments (1) | TrackBack (0)
Lots of notable discussion of yesterday's notable decision striking down California's death penalty
As reported in this prior post, yesterday in a significant ruling in Jones v. Chappell, No. 2:09-cv-02158-CJC (C.D. Cal. July 16, 2014) (available here), U.S. District Judge Cormac Carney declared all of California's death penalty system unconstitutional. Not surprisingly, this important ruling has already generated considerable traditional media attention, and How Appealing collects some of the major stories here and here.
The heart of the remarkable ruling in Jones v. Chappell turns on (1) the (not disputable) fact that "California's death penalty system is so plagued by inordinate and unpredictable delay that the death sentence is actually carried out against only a trivial few of those sentenced to death," and (2) the (very disputable) conclusion that allowing any one murderer to "executed in such a system, where so many are sentenced to death but only a random few are actually executed, would offend the most fundamental of constitutional protections — that the government shall not be permitted to arbitrarily inflict the ultimate punishment of death." I have lots of thoughts about both fact (1) and conclusion (2) that I hope to find time to share in future posts (or future amicus briefs), but for now I figured I would link to some of the early analysis of the opinion I have so far seen elsewhere in the blogosphere:
From Dan Markel here at PrawfBlawg, "What's an acceptable error rate in death penalty distributions? And some other thoughts on the Jones decision"
From Bill Otis here at Crime & Consequesnces, "A Miranda-type Prophylaxis for the Death Penalty"
From Ruthann Robson here at Constitutional Law Prof Blog, "California Federal Judge Declares Death Penalty Violates Eighth Amendment"
From Kent Scheidegger here at Crime & Consequesnces, "The Lackey Claim" Again
July 17, 2014 in Death Penalty Reforms, Procedure and Proof at Sentencing, Sentences Reconsidered, Who Sentences? | Permalink | Comments (2) | TrackBack (0)


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Tartar Sauce
From EatingWell: July/August 1996, July/August 2011
Lower in fat and higher in flavor than the bottled kind, this tartar sauce is well worth the 10 minutes it takes to make.
Makes: About 1/2 cup
Active Time:
Total Time:
Nutrition Profile
Low carbohydrate | Low calorie | Healthy weight | Heart healthy | Low cholesterol | Low saturated fat | Gluten free |View Our Nutrition Guidelines »
- 1/2 cup reduced-fat mayonnaise
- 1 cornichon, or sour gherkin pickle, chopped
- 1 tablespoon minced shallot
- 1 anchovy fillet, minced or 1/2 teaspoon anchovy paste
- 1 teaspoon chopped capers
- 1 teaspoon dried tarragon
- 1 teaspoon chopped fresh parsley
- 2 teaspoons lemon juice
- Freshly ground pepper, to taste
- Combine mayonnaise, cornichon (or sour gherkin pickle), shallots, anchovy, capers, tarragon and parsley in a small bowl. Stir in lemon juice and pepper.
Per tablespoon: 42 calories; 3 g fat (0 g sat, 1 g mono); 4 mg cholesterol; 4 g carbohydrates; 1 g added sugars; 0 g protein; 0 g fiber; 178 mg sodium; 16 mg potassium.
Carbohydrate Servings: 0
Exchanges: 1 fat
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Recipe Categories
- Style/Theme
- Quick (total 30 min. or less)
- Vegetarian
- Type of Dish
- Sauce/Condiment, savory
- Ethnic/Regional
- American
- Health & Diet Considerations
- Low calorie
- Low carbohydrate
- Low cholesterol
- Low saturated fat
- Heart healthy
- Healthy weight
- Gluten free
- Ease of Preparation
- Easy
- Total Time
- 15 minutes or less
- Servings
- 8 or more
- Preparation/ Technique
- No-cook
- Meal/Course
- Dinner
- Publication
- July/August 1996
- July/August 2011

subset: commoncrawl


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A vain attempt to immortalise my pop idols as deities…
vote here to have a 'zoom in' on artworks function on calendar to appreciate these artworks close up: vote zoom
:D cool!
thank you :)
– ellejayerose
They look brilliant all together in this format!!!!!
thanks paulie x miss u
– ellejayerose
haha really cool
aw ta x
– ellejayerose
oh this is wonderful!!
Thanks Tiffany, I just adore the juxtaposition of edgy graphics with delicate marks of the hand in your work
– ellejayerose


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Wholesale stockpiles account for about 27 percent of total business inventories. Stockpiles held by retailers make up about one-third of the total and manufacturing inventories represent about 40 percent.
While growth this summer has improved, economists are still wary about the final three months of this year. Many are worried that companies will hold back on hiring and investment because of the "fiscal cliff," the package of tax increases and spending cuts slated to take effect early next year. Unless Congress and the White House agree to delay or replace the cliff, it could push the economy into recession in the first half of next year.
Recent reports, however, have shown signs of improvement. Hiring has picked up, which has boosted consumer confidence. Employers added 171,000 jobs in October and job gains in August and September were higher than first estimated. The unemployment rose to 7.9 percent from 7.8 percent as more of those out of work began searching for jobs.
A survey by the University of Michigan last week found that consumer sentiment improved for the fourth straight month to its highest level in five years.


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MEYERCO® 8-Pc. Game Processing Kit
Item # WX2-137853
- Google+
- Details & Specs
MEYERCO® 8-Pc. Game Processing Kit is a hunter's companion!
When you're out hunting, you don't want to fuss with a ratty bag full of tools to process your big buck! This handy Processing Kit is packed in an impact-resistant case for long-lasting use in the outdoors. The knives feature 420 stainless steel blades that are triple riveted, have full-tang bakelite handles. Process with ease!Includes:
- 8" butcher knife
- 4 1/4" boning / caping knife
- 4" skinning knife
- Heavy-duty cleaver
- Game shears with built-in wing notch
- Sharpening steel
- Hunter's bone saw with two replacement blades
- Weighs 4 lbs., 12 ozs.
- Carrying case is 18 1/2" x 12" x 2 1/2"
Get your Processing Kit today! Order ONLINE Now!
- Reviews
MEYERCO 8-Pc. Game Processing Kit is rated out of 5 by 14.Rated 5 out of 5 by MICHAEL /SHARON from This is a great game processing kit. I used it down in MS a month ago deer hunting. It worked well. The only problem is I left it there at my friends home. I immediately ordered another one to replace it and gave the one I left to my friends son. Great price for great tools.Date published: 2014-01-29Rated 4 out of 5 by MARK from Purchased to keep in my hunting camper. The saw is perfect for quartering deer.Date published: 2013-12-06Rated 5 out of 5 by DARRELL from Haven't used this yet. But looks like it will make the process faster and easier.Date published: 2013-11-04Rated 3 out of 5 by ELLIS from Nice knife set. It has been a good purchase. I was disappointed with the previous crossbow order and it soured subsequent purchases though.Date published: 2013-10-30Rated 5 out of 5 by JOEL from surprisingly well made for the money.Date published: 2013-10-20Rated 4 out of 5 by RAYMOND from Great product.Date published: 2013-02-05Rated 2 out of 5 by BRIAN from Cheap plastic handles. Not sharp. The free knives from an Omaha Steak order are better.Date published: 2012-11-25Rated 5 out of 5 by TERRY from it is great. haven't got to use it yet but I am well pleased with it.Date published: 2011-11-10

 where are the knives made?

Asked by: kelly

 China
Answered by: Customer Service

Date published: 2014-11-15

2015-04-01T21:29CST

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- Articles & Tips
Don't Forget
50 Prs. Hunter's Specialties® Vinyl Gutting GlovesNon-Members $14.99 Buyer's Club $13.49
2-Pc. Hunter's Specialties® Butt Hook ComboNon-Members $19.99 Buyer's Club $17.99
Big Game® Deluxe Skinning ToolNon-Members $19.99 Buyer's Club $17.99
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Compact fridge for a dorm
Son is headed to college and wants a fridge (better than a tv IMHO). The problem with most mini fridges is that the freezer stinks. I found these 2 models which appear to have real freezers and was wondering if anyone had experience with them.
I saw the Kenmore one and am not impressed with the door storage. He drinks lots of milk.
i don't want to spend more than $160.
Hey all: I'm resurrecting this post since we're also in the market. For me, issues are mainly price under $200. Don't think a full freezer is a must. Looking at AJ Madison I see these brands:
Avanti, Danby, GE Spacemaker, Frigidaire, Supentown. Summit. Add Magic Chef and Haier from Home Depot. Kenmore from Sears.
Is there any demonstrable advantage to any of these? I suspect they probably all come out of the same factory in China anyway. Or, any reason to spend more for either greater reliability or performance? Or just grab one and hope for the best?


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Kentucky's first and official Severe Weather Awareness Month begins tomorrow with a statewide tornado drill, courtesy of the National Weather Service. Read Governor's Beshear's proclamation, participate in the drill, and find out how to protect yourself and your family in case the siren doesn't work (again).
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text:
Photo Galleries
< MyNorthwest
Police capture second Boston Marathon bombing suspect
Police have captured the second suspect in the Boston Marathon bombing.
5 of 46
Two women applaud after the arrest of a suspect of the Boston Marathon bombings in Watertown, Mass., Friday, April 19, 2013. Two suspects in the Boston Marathon bombing killed an MIT police officer, injured a transit officer in a firefight and threw explosive devices at police during their getaway attempt. (AP Photo/Charles Krupa)
Photo by Charles Krupa
Photo by Charles Krupa
5 of 46
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Amanda Knox and her family celebrate acquittal
Italy's highest court overturned the murder conviction against Amanda Knox and her ex-boyfriend Friday over the 2007 slaying of Knox's roommate, bringing to a definitive end to the high-profile case.
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Photos from around the world this week.
Hundreds gather to commemorate one-year mark of Oso mudslide
A solemn crowd gathered to honor 43 people who lost their lives a year ago in the deadliest landslide in U.S. history.
Photos: Oso one year after deadly mudslide
Sunday is the one-year anniversary of the slide, and although most of the mangled cars and homes have been cleaned up, reminders of loss are everywhere.
Week in photos
Take a look at the best photos of the week from around the world.
Tuesday in photos
St. Patrick's Day, March 17, 2015.
Monday in photos
Monday, March 16, 2015.
Week in photos
Photos from around the world this week.
Friday in photos
The second of three Friday the 13ths in 2015; Friday, March 13, 2015.
Thursday in photos
Thursday, March 12, 2015.


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how many people on a transporter
View Single Post
September 1 2012, 12:49 AM
Re: how many people on a transporter
T'Girl wrote:
Timo wrote:
Day of the Dove" would seem to make it clear that one transporter
can beam up at least nine people simultaneously
In The Apple perhaps the transporter could have dematerialize the first six and held them, then dematerialized the additional three, and rematerialized all nine at the same time?
Using this method, the Enterprise with only a single six pad transporter could materialize a hundred "Starfleet Marines" on a planet's surface all at the same time.
It would depend on how much power was available and the number of clear transporter frequencies. I think the TOS-E had multiple transporter rooms but only one was active at a time. If all were active, they could be all used to do a "tactical" aka fast beam down.
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text:
Problem with Craftsman Garage Door Opener Screw Drive
I have a 1/2 HP Craftsman screw drive garage door opener model 139.53991.
When it gets cold the garage door comes down half way, stops, and then goes back up.
If I release the door from the track and try the opener, the track rattles when the trolley gets to the center of the track.
This is the same spot where the garage door stops before going back up.
The manual says not to lubricate the screw/rail.
What is my problem and how do I fix it?
I had the same problem with a Genie screw drive after I lost a spring that put the door in a bind. Mine turned out to be a sheared pin inside the unit, it started out as going down about halfway (pin was partially sheared) and then coming back up, then after a few days it would not even start down (pin completely sheared) the motor worked but no movement. I would assume that the Craftsman and Genie screw drives are similar in design?? I pulled the entire unit down took it apart cleaned /degreased the track and screw, replaced the sheared pin lubricated and reassembled the unit and it works as well today as it did when new. At this point though I wish I had simply replaced it since the old unit does not have the rolling code security feature. Oh well I guess I will replace it next time there is a problem. It lasted 16 years the first time. Might get 10 years or so this time.
the fixer 811,
Does the opener light flash ten times when the door reverses? If so your sensors are out of alignment, or the vibration from the track throws them out of alignment in that particular position or something is obstructing the beam in that particular postion (i.e pull rope, spider web etc) If not try turning your down force up a notch or two. It will be directly on the back of the opener head and should be blue in color. I have run into a rash of the craftsman screw drives that for some reason become very sensitive in cold weather. Five this week and nothing is wrong with the door, and it is only the screw drives doing it.
BINGO! It worked.
Simply adjusted the 'force' UP a notch or two and rise it did in one motion.
Initial problem had been - in early morning SoCalif temps - the door would rise a foot or so, then stop. Depressing the opener wall button again, the door would rise a few inches then stop. Repeat-repeat-repeat and at approximately three feet off the ground the door would then open completely. If using the vehicle remote the door would stop. When depressed again the door would close.
One adjustment as stated above and there has not been another opening problem.
Thank You DoorGuy06!


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Simply stunning in this combination of bold colors, true fashion icon Lupita Nyong'o has us inspired in this image from a NY Magazine photo shoot. We love keeping an eye on her and her style.
Hope you have an inspiring weekend!
Simply stunning in this combination of bold colors, true fashion icon Lupita Nyong'o has us inspired in this image from a NY Magazine photo shoot. We love keeping an eye on her and her style.
Hope you have an inspiring weekend!
I know we're all hoping that the warmth of spring will soon rise out of the cold winter. This striking image represents that joyous moment – one we wanted to recreate in a color and swatch palette. This combination would transform your stationery and would be the perfect way to give your wedding guests a glimpse of what is to come on your wedding day!
Our designers have paired a deep fuchsia pink letterpress ink and an elegantly duplexed card stock in London Fog. The neutral background of the cool gray invitation is finished with a pop of warm color for the painted edge. To complete the package, they have picked a black unryu decorative paper liner to add texture.
Want to make that transformation for your letterpress wedding stationery? Contact your local Dauphine Press exclusive retailer to begin the design process today!
In our regular Get the Look series from the Dauphine Press design department, we share some of our favorite hot new style finds and make suggestions for how you can translate the same look into your wedding stationery using the many custom elements available to you in our design library. Keep in mind that ALL of our stationery suites receive a designer's touch and every one of our designs is customizable. Pairing the color palette and embellishments above with any of our motifs or fonts allows us to create a stationery suite that is unique to you!
We are still celebrating the color green this week after the St. Patrick's Day holiday. With green trending it brought the beautiful Versailles garden to mind. We are inspired to create wedding stationery with the same royal elegance this classic color and intricate pattern evoke!
Hope you have an inspiring weekend!
We all have our favorite creative times during the day, and for me, it's early in the morning while most of the world – well, mostly my children – remain quiet. With our new "A.M. Inspiration" series, I will be posting images of what currently has me inspired, the exciting new ideas I am dreaming up on those quiet mornings and I'll share my thoughts on how to translate that inspiration into stationery design and wedding invitations.
We are kicking off the series with a very special wedding invitation suite. This is a sneak preview of one of our new Dauphine Press design samples! We will reveal the full suite in a future post, but I first wanted to share two of my favorite details of this romantic and elegant design – pattern and color.
One of my main sources of inspiration is pattern and home fashion/decor (probably a result from my formative creative years at Martha Stewart Living). Using pattern in my designs has always been a trademark of mine. I also love creating borders and motifs out of vintage drawings/etchings. I typically pull them apart and put them back together to create a new design. At the same time, I try to build the perfect balance of color when layering patterns and borders like you see here with the lavender damask pattern and vintage caramel frame on this new invitation sample.
Speaking of color, this lavender and caramel letterpress combination is another perfect example of "traditional with a twist" that we talked about in a recent blog post. The "twist" in the creation of this color palette is the use of caramel for the most important verbiage on each piece. Overall it results in a soft, romantic feel with a warm neutral used in place of traditional black. The fresh look with the caramel against the lavender gives your guests a little peek into your attention to detail and will have them anticipating all of the other twists you have in store for them the day of the wedding!
The range of bold and pastel colors in this singular image have us thinking about our Suite Spotlight on our Lacie invitation this week and how striking an image {or invitation} can be when you find that perfect balance of design elements!
Hope you have an inspiring weekend!
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great dress for special occasions, you just have to be tall or have the dress hemmed.
I bought this for my wife along with many other products on this site. VERY HAPPY with Overstock and Customer Serv
I was pleasantly surprised at the quality and color of the dress. It fit well but had to be hemmed. I bought a size 14 and am 5'7". I had to cut about 2.5 inches off the bottom. Also, the beading appears to be black in the picture. It is actually red, but the facets show black as you move. I am very happy with the purchase.
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North Central College's commitment to environmentally friendly practices has earned gold-level recognition through the Illinois Campus Sustainability Compact.
North Central College welcomes author, academic and provocative civil rights activist Dr. Cornel West Jan. 23 as Martin Luther King Jr. Week keynote speaker.
Each year, North Central College honors and remembers King with a keynote presentation, musical tributes, a prayer breakfast and activities. This year's theme is "A Journey Defined." King spoke in North Central College's Pfeiffer Hall in 1960.
North Central College has named Dr. Abiodun "GP" Goke-Pariola its next vice president for academic affairs and dean of faculty.
Dr. Goke-Pariola will begin his new role at North Central College on July 1 after serving most recently as provost and vice president for academic affairs at Queens University of Charlotte in North Carolina. He previously served as provost and vice president for academic affairs at Otterbein University in Westerville, Ohio.
North Central College is establishing an innovative academic program in Middle Eastern and North African studies that will include language courses in Arabic. The new program is partially funded by a U.S. Department of Education grant.
Beginning in fall 2015 the College will offer a minor in Middle Eastern and North African (MENA) studies, significantly expand Oesterle Library's holdings in MENA studies and introduce students to cultural experiences in the Chicago area and abroad.
Illinois Gov. Pat Quinn on Tuesday announced a $1.1 million grant to help fund improvements to a future downtown Naperville public park on land owned by North Central College.
The funding will help cover the cost of environmental restoration of the 1-acre site at 430 S. Washington St., known as North Central College Washington Street Riverwalk Park.
"This is an opportunity to expand the Riverwalk and connect a great campus renowned for many things to downtown Naperville," Quinn said.
North Central College welcomes Riad Ismat as scholar-in-residence for the 2014-2015 academic year. Ismat will serve as visiting professor of arts and letters. He will teach courses in playwriting, acting and directing, besides lecturing on Syria, Arabic literature and drama.
A new residence hall on North Central College's 65-acre campus will offer desirable suite-style housing for upperclassmen.
The 229-bed residence hall is being built directly south of Ward and Patterson halls and across from Merner Field House and Benedetti-Wehrli Stadium. The five-story residence hall—the College's first since the Residence Hall/Recreation Center opened in 2009—is scheduled for completion by August 2015.
Globalization is "complex, ambiguous, dynamic, gray, complicated, divisive, exciting," explained North Central College faculty at a recent panel discussion.
It's a new world, they said, as they shared how globalization has impacted their different academic disciplines and how they teach.
G.I. Jobs magazine rates North Central College a 2015 Military Friendly School.
The 2015 Military Friendly Schools list honors the top colleges, universities and trade schools that are doing the most to embrace America's military service members and veterans as students. This is the third consecutive year North Central College has earned the recognition.
North Central College began the 2014-2015 academic year Sept. 15 with a near-record number of students.
Total enrollment is a near-record 2,800 undergraduates and 250 graduate students—3,050 total—eclipsing the 3,000 mark for the third straight year. The College welcomed 860 new full-time undergraduate students, up from 852 a year ago. That includes 580 first-year students, up from 529 a year ago. The 860 new undergraduates would be second only to the record-number 882 welcomed in fall 2010.
North Central College prepares students to be informed,
involved, principled and productive citizens and leaders over their lifetime.


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New Jersey's Barnegat Bay is a 75-square mile estuary with 42 miles of shoreline from the Point Pleasant Canal north to Little Egg Harbor Inlet. Barnegat Bay plays an important role as the cradle of the ocean. The Bay contains vital spawning grounds, nurseries and feeding grounds for many species. Estuaries are among the most productive ecosystems on earth, comparable in biomass production to tropical rain forests or coral reefs; they contain more life per square inch than the richest farmland or deepest forest. The Bay is crucial to a $3.4 billion NJ shore economy including tourism, boating, fishing and real estate values.
Barnegat Bay's watershed is 660 square miles and includes all of Ocean County and small portions of 4 municipalities in Monmouth County. The year-round population of more than 560,000 nearly doubles to more than 1 million during the summer tourism months.
Unfortunately, more than 35% of the Bay's watershed lands has been altered by development. Because of disturbance to the natural lands in the watershed, large amounts of polluted stormwater runoff enters the groundwater, storm drains, and waterways that empty into the Bay. An overabundance of nitrogen and other harmful pollutants from fertilizer, pet waste, deforestation, septic systems, and even air pollution is radically altering the Bay's natural ecosystem. As a result, many of the resources the Bay provides are in drastic decline. Harvest of bay scallops is down 91% and statewide shellfish license sales have declined 57% over a 24-year period from 17,240 in 1980 to 7,404 in 2004. Oysters disappeared from the estuary long ago. Today only a few commercial clammers remain from what was once over 900. Increased presence of stinging jellyfish (sea nettles) and slimy green algae are diminishing recreational uses of the Bay.
To restore the health of Barnegat Bay we advocate for policies, laws and regulations that protect the resource; we collaborate and form resource-protective partnerships with fellow environmental organizations; we educate and empower individuals, agencies and elected officials about what they can do to bring our Bay back to life through business roundtable groups and community action programs like Bayscape for Barnegat Bay and Businesses for a Better Barnegat Bay; we research and implement new and innovative stormwater restoration projects like Replumbing the Bay; and we restore shallow water habitat through community-based shellfish restoration projects and innovative approaches to shoreline erosion like living shorelines to ruther improve the ecosystem.
|Fri Mar 20 @ 5:00PM -
Spring Equinox Walk
|Sat Mar 28 @10:00AM - 01:00PM
Early Spring Bird Walk!
|Fri Apr 17 @ 1:00PM -
Old Dune Trail Walk
|Fri Apr 24 @ 2:00PM -
Arbor Day Tree Walk
|Sun Apr 26 @11:00AM - 02:00PM
Earth Day Shoreline Cleanup
|Sat May 02 @10:00AM - 01:00PM
NYC Audubon Spring Migration Workshop
|Fri May 08 @ 8:30AM -
Spring Migration Bird Walk
|Sat May 09 @ 8:00AM - 05:00PM
Sandy Hook Surf Fishing Clinic
|Fri May 15 @ 6:00PM -
Horseshoe Crab Walk
|Sat May 23 @12:00PM - 02:00PM
Horseshoe Crab and Shorebird Walk


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Million Dollar Listing Los Angeles 2006 | TV Show Watchlist
Photos | Cast & Crew | Episode Guide | Video Clips
A reality series that delves into the high-stress, big-money world of real estate in California. The show tracks the highs and woes of three young-gun agents as they try to close deals and negotiate with home sellers and buyers.
Premiered: August 29, 2006
Rating: TV-PG
Latest NewsSee all »
Latest Full EpisodesSee all »
A $13-million listing in Laguna Beach forces the Brits to sink-or-swim in a new territory. But they are buoyed by a surprise visit from a familiar face. Still reeling from the devastating loss of his grandmother, Josh Flagg struggles to stay focused on a new listing for one of Edith's friends.
When Daymond John of "Shark Tank" hires Josh Altman to find commercial space for his West Coast headquarters; Altman moves his relationship to the back burner again. David and James coax a prolific developer to sell their newly built dream house for $12;995;000. As for Josh Flagg; real estate is the last thing on his mind when his personal life is shattered.
Josh Altman and his brother Matt meet with an international client demanding they find the perfect Beverly Hills getaway in just two days. Meanwhile, Altman is trying to keep his relationship with Heather from falling apart. As Edith's health continues to decline, Josh Flagg finds himself in crisis mode. One of James and David's biggest clients is counting on them to find an LA residence that meets his very specific requirements.
After being hired by a hard-nosed client who used to be a top real estate agent, James and David come up with a brilliant strategy to impress him. Josh Flagg is frustrated when he gets the listing for one of his favorite properties only to find out that other agents don't share his appreciation for it. Josh Altman lands the most prestigious listing of his career. The victory is short-lived as his personal life begins to crumble.
Video ClipsSee all »
Watch See all »
After receiving realty pointers from his grandmother, Josh drives forward and lists land in a golf-course community. Elsewhere, Chad scores a prime listing in an affluent pocket of Los Angeles, only to then learn a valuable lesson about the market. And Mad (more…)
Chad and Madison are enlisted to speak at a real-estate conference in Arizona, conveying their thoughts about the sinking high-end housing market. Meanwhile, both Chad and Josh attempt to expand their sales territories, with Chad focusing on a small bungal (more…)
Josh tries to list prime ocean-view property in Malibu, but first he must present a marketing plan to the owner at his Montana home. Meanwhile, Chad and a second agent work on a Hollywood Hills abode, and Chad also poses a crucial question to his girlfrien (more…)
Next On TVSee all »
Mon Apr 6 12:00pm
Big Numbers, Small DealsSeason 3, Episode 2 ESQTV
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"Great storytelling"
I have recommended this audiobook to several friends. It is a fascinating story, written by a fantastic storyteller, and recorded by a talented narrator. I never wanted to turn it off!
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