text:
- Akin Oyebode
- May 13, 2006
- 0 Comments
Lecture delivered at the INEC Conference held at
Nigeria has had a chequered experience with the ballot box. For a country that, one way or another, began having encounters with elections since 1922, it is somewhat ironic or paradoxical that we should still be agonizing over democratic praxis, especially the modalities of selecting our public office holders. Nevertheless, if a head is dirty, you do not for that reason cut it off. What you do is wash it. Accordingly, we should not stop trying to reform or improve on the way and manner the electoral process operates even if we seem to have demonstrated a rather steep learning curve. Besides, as apologists of our inadequacies would be quick to remind us,
Nonetheless, we have to admit that the long incursion by the military into the political landscape has left a near indelible imprint on the national consciousness, so much so that, like pavlovian dogs, we seem to have developed reflexes symptomatic of a high tolerance level for arbitrariness and misuse of power by those in control of the state apparatus. The general lack of a history of resistance among the people and the national penchant for compromise would seem to have rendered the ordinary Nigerian a fatalist, ever ready to leave the redress of any injustice to the Almighty instead of, at the very least, pursuing a course of action through the law courts. The aversion of our people for recourse to the judicial process while generally in consonance with the traditional African preference for conciliation rather than adjudication, should, in the context of this discussion, be considered as dysfunctional and counter-productive. The litigious spirit clearly evident in say, the US, which had been observed as late ago as the 1830's by Alexis de Tocqueville, has contributed, in no small measure, to the growth and development of the democratic ideal in that country.
Notwithstanding, our jurisprudence has been enriched somewhat by litigants who, despite all odds, had decided to take their grievances to court rather than resort to the uncertain, precarious rule of the mob. To the extent that many more aggrieved persons would pursue legal action, can it be envisaged that Nigerian democracy would thrive. Indeed, if the electoral tribunals and the courts lose their allure in the consciousness of the people generally, the portents would be truly bad for due process of law and democratic governance in the country. For where and when elections are conducted in a transparent manner, that is to say, elections are considered as 'free and fair', contestants would be compelled to congratulate the winners and losers would have no choice other than to bear their defeat with equanimity. In such circumstances, the tribunals and courts would only exist as final arbiters over any manifest acts of malfeasance which could impugn the sacred right of the electorate to determine who should preside over their affairs for a term.
It hardly needs be emphasized that the sanctity of the ballot box in the democratic process should be safeguarded, hence the necessity for the existence of the judicial process in case there was anyone who feels aggrieved by the way and manner an election has been conducted. It is only by so doing that the people can be truly said to have had their day in court. Accordingly, it is perhaps best to begin this presentation by examining the adjudicative functions of the courts generally before focusing on their role in the electoral process.
The Judiciary and the Dispute Settlement Function
The role and place of the judiciary in the scheme of things are pretty well-known in any system of democratic governance. As I once observed,
'…a political system can be considered as democratic on the basis of the
extent to which the judicial arm is permitted to hold the scales of justice
over and above the other arms of government…For, if good governance
has become a modern day desideratum, human ingenuity is yet to devise
a better means of preventing arbitrariness and ensuring social well-being
than that of separation of powers, due process of law and independence of
the judiciary which, taken together, constitute the hallmarks of a well
functioning democratic system.' 3
The 1999 Constitution outlines the adjudicative function of the judiciary.4 Accordingly, the primary function of the judiciary is to resolve disputes between all persons or between government and persons, except the matter pertains to the Fundamental Objectives and Directives of State Policy. However, in case of disputes between the Federation and a State or between States, only the Supreme Court has original Jurisdiction.5
The preeminence of the courts in the scheme of things is self-evident. The world has come a long way from the state of nature where each was his own law-maker and enforcer. The transition from the state of nature to that of civil society entailed transfer of the right of auto-determination to the state via the social contract such that an independent judiciary becomes the protector of the individual rights of members of society. The notion of separation of powers and the in-built system of checks and balances ensure that all abide by the dictates of the law. Since the judiciary is pre-occupied with interpretation or indeed, application of the law, there is merit in the view that the judiciary is the most powerful of the three arms of government.
However, the centrality of the judiciary is acknowledged only where and when there is a deeply ingrained tradition of fidelity to the rule of law. A law-governed society would think twice before challenging the law as adumbrated by the highest court in the land. Even decisions of inferior courts remain the law until set aside by a higher court. Where and when there is a consensus on the rule of law, everyone quite easily comes to terms with the overarching role of 'the least dangerous branch.'6 On the other hand, a country lacking such a tradition is apt to be suffused with instances of disobedience to court orders, selective enforcement and what has since passed into literature as 'executive lawlessness.'7 Failure by misguided elements to pay credence to the overarching role of the courts, more often than not, leads to a state of anomie or normlessness, with cataclysmic consequences for the entire polity. The reason for this is obvious: law is the glue that holds society together and when this fact is ignored, the tendency is for a reversion to the state of nature.
Yet, it hardly needs emphasis that the interests of a developing country, such as ours, are better served by untrammeled and unwavering commitment to the rule of law and general acceptance of the strictures of due process rather than a descent into arbitrariness and self-help. The more people avail themselves of the judicial process, the brighter the prospects for democratic governance and social stability and general well-being.
It needs be pointed out also that in the adversary system that we operate, the judiciary is not expected to descend into the controversy before it or join issue with the parties. Judges are by oath required to dispense justice to all parties without fear or favour, affection or ill-will. Not only can they not initiate legal action, which is a prerogative of litigants, they cannot improve the claims of parties or grant them more than they seek.8 This is unlike in civil law jurisdictions where judges are generally allowed greater interventionist roles. The implication of this is that complainants should not fight shy of bringing their grievances to court and ensure that they engage competent counsel since they would be held bound strictly to their pleadings.
However, all this is subject to non-interference by extraneous bodies in the judicial process or what generally passes for independence of the judiciary. Except and unless and only to the extent that litigants have confidence in the impartiality of the judges would they see any wisdom in taking their matters to court. Besides, it is necessary to bear in mind that the applicable law in a dispute should be without reproach be it in content or form. In other words, if there are, for example, infelicities of drafting in the statute, a timorous judge might decline from ironing out the creases of the legislation on the basis of not wishing to usurp the place of the law-maker.9 Therefore, the legislature must do its own homework if the judiciary is to live up to its reputation as 'the last hope of the common man.'10
The Centrality of the Electoral Process in the Task of Deepening Democracy
If, as Churchill observed, democracy was the worst form of government apart from all the others, then no effort should be spared in nurturing it wherever it has taken root. However, the beginning of wisdom as far as democracy is concerned is an awareness of the need to ensure full confidence of all and sundry in the electoral process. Once the electorate has confidence in the ballot box, all those who extol the virtues of democratic governance can rest assured that voters would always turn out in large numbers whenever the exercise of their franchise is required. On the contrary, where and when there is voter fatigue, indifference or people start voting with their feet, that is indicative of a failing democratic project and all lovers of democracy should immediately set out to renew the people's confidence in the ballot box.
Admittedly there is growing evidence of voter apathy and even disillusionment in certain parts of the democratic world but that is not enough to suggest the obituary of the ballot box. The simple reason for one's optimism is that periodic elections serve as the festival or elixir of democracy. Although Marx once observed that elections in bourgeois societies merely afford the masses once every four or five years the chance of selecting their executioners, experience has shown that governments which are a product of free and fair elections endeavour to stick to their manifestos or else face the prospect of defeat at the polls next time around, more so as electoral promises have become akin to covenants between the government and the governed. Thus, if the principle of self-determination is to be given full rein, the people should have the assurance that they can always vote out a government that fails to demonstrate sensitivity to their yearnings and aspirations whenever the opportunity presents itself.
Sovereignty really belongs to the people and the earlier politicians got reminded of that fact, the better for the democracy project. Those who treat the electorate with disdain or askance as soon as elections are over could find it difficult if not, in fact, impossible to be returned for another term except they dip into their bags of tricks. The recent reluctance by the out-going Italian Prime Minister, Silvio Belusconi to admit defeat and surrender power to his successor, Romano Prodi is not one to be emulated by all committed democrats. It should, in fact, be condemned unreservedly as conduct unbecoming of any true democrat.
In our own circumstance, the electoral process seems to be under assault by enemies of democracy and the open society. A situation where ballot boxes are reportedly hijacked by armed, uniformed persons and substituted with previously stuffed boxes is surely not one that can recommend itself to lovers of democracy anywhere or engender confidence among the electorate in the electoral process. Furthermore, the proposed electronic machine voting system does not appear to enjoy the support of many stakeholders. The fact that the experience of some countries where such devices had been used has not been altogether encouraging, coupled with the deletion of provisions for electronic voting from the Electoral Bill currently being debated at the National Assembly suggests that we are still a long way off from forging a consensus regarding ways and means of strengthening democracy through the electoral process. The central task facing the Nigerian electoral process today is how to devise a cheap, simple, fool-proof, rigging-free system of voting which would at the same time ensure secrecy of the ballot, guarantee prompt release of election results and regain the waning confidence of the electorate in the electoral process. While some have extolled the Option A4 employed during the 1993 elections, many have reservations against asking people to line up openly behind symbols of their preferred parties or candidates, especially in view of the inherent socially disruptive potential of such a system.
In the final analysis, however, the fact must be grasped by all and sundry that except and unless and only to the extent that the distortions and rough edges of the electoral process are removed, all efforts to deepen democracy in this country would amount to a chimera. A stop must have to be put, one way or another, to a situation of trying to operate democratic norms without a large army of true and tested democrats. It would seem the beginning of our road to a proper, well-tuned electoral process lies in the enactment of a well thought-out electoral law which would ensure the neutrality of all state agents involved in the electoral process in order to restore the confidence of the people in
The Judiciary and the Electoral Process: A Tentative Score Card
Resort to the courts and electoral tribunal has always been a feature of
The real test of the judiciary as an intermediating force in the electoral process came at the outset of the Second Republic when the electoral tribunal and, ultimately, the Supreme Court were called upon to solve the riddle of what should constitute two-thirds of 19 states in the celebrated case of Awolowo v. Shagari and FEDECO.11 The decision of the Court, emphasizing as it did 'substantial compliance' rather than the reasonable meaning of the relevant words of the statute and its admonition for the judgment not to be considered a precedent paradoxically set a bad precedent for subsequent actions brought before the courts on matters bordering on politics.
It does not require great intellect to surmise that had the Court adopted the logic of the dissenting opinion of Kayode Eso and the presidential election allowed to go the whole hog right to the electoral college as provided under the Electoral Decree, the history of the
The erosion of the people's confidence in the judiciary, regrettably, was not limited to n political cases. Stories were now being bandied about that justice in the country had been put on sale to the highest bidder, with devastating consequences for the image of our judiciary. This explains why even Chief Awolowo, a firm believer in the rule of law if there was one, could not see any point in pursuing any relief in the courts when he once again felt cheated out of victory at the 1983 presidential election, preferring instead to leave everything to God since ' the judiciary had become terribly corrupt.' 13 Accordingly, the low esteem in which the judiciary is held by many people today, especially with regard to election petition cases has its foundations in the skepticism of the past.
The elections of 1993 should be seen generally in the context of the desire of the people to see the back of our praetorian rulers after nearly thirty years of authoritarian rule. However, this is not to take anything away from the winner of the presidential election, M.K.O.Abiola, whose "Farewell to Poverty" programme had earned him wide support across the country. That those seeking political offices but lost out at the polls had decided to lick their wounds quietly instead of embarking on costly and, ultimately, fruitless efforts in court houses would seem to have underscored the relegation of the judiciary in the electoral process. Besides, the compromised status of the judiciary under military dictatorship and the contrived and convoluted transition programme of the Babangida regime could not encourage any wise political actor then to put much stock in the courts.14 It took the dramatic turn of events during the 2003 elections to bring the aggrieved back to the courts.
As would be remembered, the last set of elections in the country became a veritable test of the maturity and resilience of
The case of Buhari v. Obasanjo16 became perhaps one with the most number of witnesses, averments and affidavits in support ever in
as happened in one particular case.17
It was bad enough that the matter ran into nearly half of the tenure of President Obasanjo, thereby becoming, in effect, a clog in the democratic process. However, it is instructive that the Supreme Court was once again haunted by the bogey of "substantial compliance" which had constituted the gravamen of the Awolowo v. Shagari case. What is more, the reinstatement by the Supreme Court of election results voided at the Court of Appeal sitting as the Electoral Tribunal and the reported dismissal without retirement benefits of Hon. Nsofor, the sole dissenting judge in the case,18 if true, must have cast a pall on the role of the judiciary in the electoral process.
When to all this is added the recent decision upholding the election of Peter Obi as against the putative Governor Chris Ngige who had exercised executive powers in Anambra State for nearly three years after the elections, none would be in doubt that the nation is confronted with a serious crisis of confidence with respect to the judiciary and the electoral process. While there might have been some notable decisions concerning issues such as interpretation of electoral petitions,19 nature of petitions,20 nature of election tribunals,21 it must be stated that the general thrust of judicial intervention in electoral matters has been less than satisfactory. In sum, one is constrained to say that the way and manner the judiciary has acted with regard to election petition cases has not altogether been reassuring in terms of the growth and development of the nation's electoral process and the fortunes of democracy generally.
Nevertheless, perhaps one should be charitable enough to acknowledge that one should not heap the entire blame for the nation's inadequacies on the judiciary since the courts are bound to operate within both the extant substantive and adjectival law. Matters such as eligibility to be a candidate, preliminaries like campaigning for office, filing of nomination papers, the voting procedure, impersonation, declaration of results, dereliction of duty by polling officers, etc. should be properly spelt out in the electoral law in order to facilitate the judicial process with regard to electoral matters. At present, the greatest challenge facing judges in election petition cases would seem to be a hard and fast time frame within which to conclude such matters.
For instance, it is simply unheard of in the advanced democracies for election petition proceedings to go on for upwards of two years into the tenure of an office-holder. Accordingly, our judges must be put on a tight leash so that they can, in turn, call counsel to order if and when they are raising frivolous and unnecessary motions or employing sundry delaying tactics to the detriment of expeditious determination of cases. Litigants and judges should be equally aware that not only is delayed justice denied justice, prolonged hearing of cases is detrimental to the entire judicial process and could actually encourage self-help among citizens. In political matters especially, the resultant distrust could prove very costly indeed for public peace and social equilibrium.
The Judiciary and the National Conscience: A Prognosis
The judiciary occupies a unique position in modern society. As stated earlier, it is the most powerful of the arms of government since it is empowered to set limits to the authority of both the legislature and the executive. However, the power of the judiciary might remain latent where and when occupants of judicial office become timid or are reluctant to exercise their power. Accordingly, the growth and advancement of the democratic idea depend very much on an enlightened and conscientious judiciary, imbued with the spirit of the age as well as a sense of its proper role and capability. Where and when a nation is lucky to have men and women siesed of what needs to be done in order for society to tread the democratic path, the task of socio-economic and political transformation becomes so much easier.
The history of our country's development is, at best uneven, littered as it has been with forcible interventions by elements paid to secure and defend the polity. Now that, hopefully, the era of seizure of political power by praetorian guards is now well behind us, we ought to invest considerably in the judiciary as the sentinels of our collective rights and freedoms. Not only is there a felt need for improving their existential conditions, we need to ensure that only the best legal minds occupy the Bench. Besides, the country should arm the judges with the necessary input for the optimal performance of their onerous duties of safeguarding the polity from the antics of undemocratic forces. A situation where the enemies of democracy taunt their political opponents by asking them to carry their grievances to court, knowing fully well that the courts have been incapacitated through all manner of shenanigans, not least among which are flagrant disregard for court orders and sundry acts of executive lawlessness, is, quite frankly, inimical to societal peace and national progress.
The problem with contemporary
However, for the judiciary to fulfill its appointed role in the scheme of things, there must be a consensus among the nation's political actors to play according to the rules of the game and recognize the overarching importance of the judiciary in the entire process. If
Akin Oyebode is Professor and Head, Department of Jurisprudence and International Law,
3The Judiciary and Constitutionalism in a Democratic Sosiety in A. OYEBODE, LAW AND NATION-BUILDING IN
4 See s.6(6), Constitution of the Federal Republic of Nigeria, 1999.
5 Ibid.s.232(1).
6 Cf. A. BICKEL, THE LEAST DANGEROUS BRANCH passim (1962).
7 See e.g., supra note 1, at 85.
8 See e.g., Ige v. Olunloyo, [1984] SCNLR 138.
9 See e.g., Okumagba v. Egbe, [1965]1 All NLR 62.
10 Cf. Is the Judiciary the Last Hope of the Common Man? in supra note 1, at 128.
12 Compare e.g., Omoboriowo v. Ajasin, [1984] 1 SCNLR 108 and Nwobodo v. Onoh, [1984]1 SCNLR 1.
13 T.FALOLA and J.IHONVBERE, THE RISE AND FALL OF 14 Cf. The Judiciary,Corruption and Democratisation in supra note 1, at 144. 15 See e.g., 1983, 1993, and 2003: The Quest for a Difference in supra note 1, at 101 16 [2005]13 NWLR (Pt. 941)1. 17 See Jerry Ugokwe v. Federal Republic of 19 See e.g., 20 See e.g., Bayo v. Njidda, [2004] 8 NWLR (Pt. 876) 544; Ajadi v. Ajibola, 16 NWLR (Pt. 898) 91. 21 See e.g.,Abubakar v. INEC, [2004] 1 NWLR (Pt. 854) 207; Buhari v. Yussuf, [2003]14 NWLR (Pt.841) 446. Join the conversation through disqus comments or via our forum. Click on any of the tabs below to select your desired option. Please engage decently.
14 Cf. The Judiciary,Corruption and Democratisation in supra note 1, at 144.
15 See e.g., 1983, 1993, and 2003: The Quest for a Difference in supra note 1, at 101
16 [2005]13 NWLR (Pt. 941)1.
17 See Jerry Ugokwe v. Federal Republic of 19 See e.g., 20 See e.g., Bayo v. Njidda, [2004] 8 NWLR (Pt. 876) 544; Ajadi v. Ajibola, 16 NWLR (Pt. 898) 91. 21 See e.g.,Abubakar v. INEC, [2004] 1 NWLR (Pt. 854) 207; Buhari v. Yussuf, [2003]14 NWLR (Pt.841) 446. Join the conversation through disqus comments or via our forum. Click on any of the tabs below to select your desired option. Please engage decently.
19 See e.g., 20 See e.g., Bayo v. Njidda, [2004] 8 NWLR (Pt. 876) 544; Ajadi v. Ajibola, 16 NWLR (Pt. 898) 91. 21 See e.g.,Abubakar v. INEC, [2004] 1 NWLR (Pt. 854) 207; Buhari v. Yussuf, [2003]14 NWLR (Pt.841) 446.
20 See e.g., Bayo v. Njidda, [2004] 8 NWLR (Pt. 876) 544; Ajadi v. Ajibola, 16 NWLR (Pt. 898) 91.
21 See e.g.,Abubakar v. INEC, [2004] 1 NWLR (Pt. 854) 207; Buhari v. Yussuf, [2003]14 NWLR (Pt.841) 446.
Join the conversation through disqus comments or via our forum. Click on any of the tabs below to select your desired option. Please engage decently.


text:
Recent Obituaries
Search Obituaries
Notable Deaths
Submit an Obituary
Funeral Homes
Search By Location
Photos & Memorials
Legends & Legacies
In The News
Photo Galleries
Today In History
Featured Memorials
Grief & Support
Sympathy & Condolence Advice
Funeral Etiquette
Grief Support
How To Write An Obituary
Submit An Obituary
Contact Us
Dorothy June Ward
In loving memory… Our beloved Mom, Grandma, Great-Grandma, and Great-Great Grandma, Dorothy June
Read Obituary
Share Condolences
Shirley Babb Weber
Shirley Honorine Babb Weber has gone home to our Heavenly Father on July 20, 2015. She was born
Read Obituary
Share Condolences
Mary Jaconetti
Mary "Tweety" Jaconetti passed away on Wednesday, July 8, 2015. She was the fourth child of Mary
Read Obituary
Share Condolences
+ View All Spotlight
National Spotlight
Kaiser Carlile
Batboy struck in head by practice swing...
Mel Farr
1944 - 2015
Former running back for the Detroit Lions…
Coleen Gray
1922 - 2015
Film actress known best for "Nightmare Alley," "Red River" and "The Killing"...
Richard Schweiker
1926 - 2015
Former senator and cabinet secretary...
Cilla Black
1943 - 2015
Legendary TV presenter and singing star...
Roddy Piper
1954 - 2015
Wrestling legend and cult film star of "They Live"...
+ View All National Spotlight
Legends of Motown Quiz
Some of the best music of the 1960s and '70s came from Detroit's Motown Records. How much do you know about the legendary performers who made Motown great? Take our true-or-false quiz.
Quiz: Archie Bunker vs. Ralph Kramden
Can you tell these two classic cranks apart? We'll give you a quote and you decide who said it: Ralph Kramden on "The Honeymooners" or Archie Bunker on "All in the Family"?
Barbie Quiz
The first Barbie doll was launched 55 years ago. Take our true-false quiz and go behind the scenes with Barbie.
View All Quizzes
Latest Obituaries
This Week
- 4 Total
View All
Crook, Daryl Lee
Jaconetti, Mary "Tweety"
Ward, Dorothy June
Weber, Shirley Babb
+ View all (4)
View All obituaries This Week
Recent Condolences for
Ward, Dorothy June
1 entry
Recent Activity By Funeral Home
Neptune Society of Northern California - Chico
Roden, David Walter
Hoyt-Cole Chapel of the Flowers
Rouse, Marcia Ann
McNary-Moore Funeral Service
Reister, Patricia "Sheila"
Hill, Kim
Fleet, Sandra
Ullrey Memorial Chapel Inc.
Ochoa, Robert Levi "Big O"
Hall Brothers Corning Mortuary
Weber, Shirley Babb
View Funeral Home Directory
Past Month
Roden, David Walter
McWilliam, Mary
Reister, Patricia "Sheila"
Davis, Deena Lynn (Demo)
Fox, Katherine Rose
Ochoa, Robert Levi "Big O"
Smith, Loren Sanford "Chopper"
Hill, Kim
Rouse, Marcia Ann
Fleet, Sandra
Tamagni, William Leo
Reilly, Ryan
Molina, Fidel
Stone, Edwin Albert
Zimmerman, Virginia M.
DeCou, Evelyn Marie
Martinez, Arthur Maurice
Puckett Sr. , Lesley Wayne
Borgna, James
Rodeghiero, Anthony Mathew "Tony"
Ramirez, Sofia
Santiago, Alyssa Marie
Santiago, Brenda Isabel
Alves Sr., Basil Thomas
Kaylor, Billy
Morrow, Lois
Murdock, Cindy Marie
Silver, Marilyn
Weinrich, William Baird
Armocido Sr, Frank C.
Stilwell, Phyllis Ann
Woodall, Gordon Patrick
Lasley, Bob E.
Stewart, Ronald Jay
Beck, Katherine Louise "Kathy"
Search Obituaries
Funeral Home Directory
Funeral Home Directory
McNary-Moore Funeral Service
Alameda Family Funeral & Cremation, Inc. - Saratoga
Forest Lawn - Long Beach
View All Local Funeral Homes
Information for Funeral Directors
Send Funeral Flowers
Helpful Services
How To Submit An Obituary
Learn how to place an obituary
Funeral & Sympathy Etiquette
Get advice from our experts
Obituaries e-mailed to you daily
Find a Charity
Locate a charity to make a donation
Search Obituaries & Guest Books
You are searching
By person
By town
Past 3 days
Past 7 days
Past 2 weeks
Past 30 days
Past 6 months
Past year
All time
Specific date
Date range
More Options
Today's Featured Videos
Sponsored Links
Of Interest
Photo Galleries
Robin Williams: 9 of His Best Characters
Robin Williams, who died Aug. 11, 2014, at 63,...
Photos: Action Heroes
In memory of the great Bruce Lee – who died July...
Photos: Ford Models
When Eileen Ford co-founded her eponymous...
Photos: To The Moon and Back
On the 50th anniversary of Ed White becoming the...
View All Photo Galleries
Powered By
Search Obituaries
How To
Questions? Contact Us
© 2015 Legacy.com All Rights Reserved

subset: commoncrawl


text:
polar ecosystem, complex of living organisms in polar regions such as polar barrens and tundra.
Polar barrens and tundra are found at high latitudes on land surfaces not covered by perpetual ice and snow. These areas lying beyond the tree line comprise more than 10 percent of the Earth's land surface. Most are in the Arctic and subarctic, as little land area in the Antarctic is ever free of snow and ice (seefigure). The Arctic can be divided into the Low Arctic and High Arctic, according to various environmental and biological characteristics. Tundras are most common in the Low Arctic, and polar barrens are dominant in the High Arctic.
The Russian term "tundra" is derived from the Finnish word tunturi, meaning treeless heights. Tundra is now used in a general sense to describe any cold-climate landscape having vegetation without trees, which includes both mountainous areas (alpine tundra) and areas in the Arctic, subarctic, and Antarctic. In a more restricted sense, tundra denotes a special type of vegetation association. The tundra zones of the polar regions are distinct from the polar barrens, which are sparsely vegetated. (For more information on Arctic and Antarctic lands, see the articles Arctic and Antarctica.)
Origin of the flora and fauna of the polar regions
The Arctic and subarctic regions
Compared with other biomes, the tundra biome is relatively young, having its origin in the Pleistocene (2.6 million to 11,700 years ago). Individual plant and animal species of the tundra, however, probably first appeared in the late Miocene (13.8 million to 5.3 million years ago) or early Pliocene (5.3 million to 3.6 million years ago). Coniferous forests were present on Ellesmere Island and in northern Greenland, the northernmost land areas, in the mid-Pliocene (3.6 million years ago). Most paleoecologists believe that tundra flora evolved from plants of the coniferous forests and alpine areas as continents drifted into higher and cooler latitudes during the Miocene (23 million to 5.3 million years ago).
The Antarctic region
Antarctica has been isolated from other continental landmasses by broad expanses of ocean since early in the Paleogene Period, about 60 to 40 million years ago. Prior to its separation it existed, along with Australia, South America, peninsular India, and Africa, as part of the landmass known as Gondwanaland. This long separation has impeded the establishment and development of land-based flora and fauna in the Antarctic. Other significant factors that have hampered terrestrial biotic evolution are the harsh climate, the ice cover that completely engulfed the continent during the Pleistocene glaciations, and the present limited number of ice-free land areas, which are restricted primarily to the coastal fringes and nunataks (mountain peaks surrounded by the ice cap). As a consequence, the terrestrial flora and fauna of Antarctica are few. The Antarctic Peninsula, which extends to 63° S, is the location of virtually all floral development of the Antarctic.
The Antarctic, however, encompasses not only the continent itself but also those islands lying within the Antarctic Convergence, where northward-flowing cold surface waters meet warmer subantarctic waters. Most Antarctic islands, because of their position beyond the seasonal pack ice, are under much stronger maritime influence than comparable Arctic islands. The flora and fauna of these islands are poorly developed, largely because of their isolation from potential sources of terrestrial biota. South Georgia, the largest of these islands, lies 2,000 kilometres (1,240 miles) east of Tierra del Fuego at 54° to 55° S and encompasses an area of 3,756 square kilometres (1,450 square miles). Heavy precipitation and high mountains account for perennial snow cover at higher elevations and extensive glaciers. Nevertheless, near sea level where soil formation has been possible, a unique Antarctic tundra vegetation has developed, dominated by tussock-forming grasses and mosses. Only 26 species of vascular plants are present, and there are no native land mammals, although reindeer introduced by Norwegian whalers in the early 1900s have established feral populations. Grazing by reindeer has altered plant communities by reduction or local elimination of the most preferred species.


text:
Recent Forum Posts
View More
Recent Comments
- 1 week ago Love me some camping. Cook me some fish on dis thing. Posted via the Android Central App
- 3 weeks ago Galaxy Note 3 Posted via the Android Central App
- 10 months ago Moto 360. Bam Posted via the Android Central App
- 10 months ago OMG the iSheep are out in force. You could not pay me enough to get an iPhone or Apple Watch. I want a Moto 360 and a new...
- 1 year ago Thats cold. But well done Posted via Android Central App
- 1 year ago I used to be a big BlackBerry fan and user. Day one adopter of the PlayBook and 9930. After the debacle that was the...
- 2 years ago Jerry rules
- 2 years ago Yeah but the bbq's better in Austin
- Member for
- 3 years 2 weeks


text:
Posted at: 02/26/2013 12:46 PM
Updated at: 02/26/2013 12:48 PM
By: WNYT Staff
ALBANY - A four month old, involved in a fiery crash last Friday, is now in fair condition.
The young boy and his mother were in a car that police say was hit by 43-year-old Julian With.
Police say he was driving the wrong way on the thruway early in the morning near Exit 21 early Friday morning.
The boy's mother is at the hospital with him.
Her best friend, a passenger in the car, was killed in the crash.
Julian With was also killed.


text:
The Graduates/Los Graduados explores pressing issues in education today through the eyes of six Latino and Latina students from across the United States. More than a survey of contemporary policy debates, the bilingual, two-part film offers first-hand perspectives on key challenges facing Latino high school students and their families, educators, and community leaders. It is the story of the graduates who will make up America's future.
The Graduates/Los Graduados broadcast on the PBS series Independent Lens on October 28 and November 4, 2013 at 10/9c. Learn More
The Graduates: Girls Hour The first hour of the series tells the stories of three young women who faced the interruption — or potential interruption—of their high school education. Young Latinas face unique challenges on the road to graduation related to the intersection of their ethnicity and gender. Stereotypes that portray Latinas as submissive and underachieving often provoke a lack of confidence and low self- esteem. Many Latino families hold cultural expectations that girls should not venture far from home or family and should shoulder a stronger sense of family responsibility than boys. Caretaking duties, especially for younger siblings, often fall to girls. Latinas have the highest teen pregnancy rates in the country – almost twice the national average.
The girls shown in The Graduates/Los Graduados face these challenges, but a combination of educational and community resources, as well as supportive families, help each one surmount the obstacles that might have prevented her from completing her education.
Events & Engagement Resources
- Community Cinema Screenings in your area (link)
- Watch the film online English, Spanish (link)
- The Graduates/Los Graduados Overview (PDF, 2.2MB)
- Community Discussion Guide (PDF, 3.3MB)
- Youth Action Guide (PDF, 988KB)
- Event Flyer Template (ZIP, 2.6MB)
- American Graduate Short Films (link)
- The Graduates Engagement and Education Toolkit Request Form (link)
- The Graduates: Classroom Modules (link)
Student Bios
Darlene Bustos: Tulsa, Oklahoma Just before her sophomore year of high school, Darlene became pregnant, and as a result, began to miss classes and fall behind. After multiple absences, her school district finally asked her to leave. At the time she was focused on having her baby, school was a secondary concern. But after having her son Alex and enrolling him in a Head Start program, Darlene thought about her own academic future. Wanting to not only provide a good example for her son, but to catch up academically and graduate, Darlene enrolled herself in the Union Alternative School for at-risk students. Darlene is currently in school and working towards graduation day and beyond, while raising Alex.
Stephanie Alvarado: Chicago, Illinois Stephanie was weighed down by the tough reputation of her school. Gage Park High School is under-resourced, and as Stephanie describes in the film, the metal detectors students must go through make the environment feel like a "prison." Stephanie became involved in Voices of Youth in Chicago Education (VOYCE), a youth-leadership project that aims to decrease the city's dropout rate. One key project of VOYCE is a peer jury, in which student-jurors discuss and then determine solutions for their peers who have committed a minor infraction that might otherwise result in suspension or expulsion. Through VOYCE, not only did Stephanie's grades improve dramatically, but she also participated in several activities that helped build her confidence: as a peer juror at school; as an outspoken activist in support of Chicago teachers; and as part of a student group helping to build schools in Senegal.
Chastity Salas: Bronx, New York After Chastity and her family — consisting of her mother and three younger brothers — became homeless, she coped with the situation as best she could. But the responsibility she felt toward her family made her question the point of applying to college, and interfered with her classes. The staff at Chastity's school, Fannie Lou Hamer Freedom High in the South Bronx, recognized the challenges in part because of the small classes and personal attention given to students. Through the services of Children's Aid Society, which partners with the school, Chastity was able to discuss her problems and her goals with the school's student success coordinator. Through this process, Chastity received the guidance she needed to make plans for her future, including completing college applications. Chastity thrived at school, using writing as an outlet for her feelings. In June 2013, she graduated from Fannie Lou and is headed to SUNY Potsdam in the fall.
American Graduate: Vamos A Lograrlo! Shorts
These short films are part of a public media initiative supported by CPB to help local communities across America find solutions to address the dropout crisis. More info
Baby Mama High
Directed by Heather Ross
It's the last few weeks of high school for Yessenia, a soft-spoken senior with two small daughters and a boyfriend who'd rather she stay at home than go to school. Yessenia is forced to choose: stand up for herself and her daughters, or give in to expectation.
I Really Want to Make It
Directed by Ray Telles and Angela Reginato
Sharon Montano of Oakland decides to go back to school at age 20 after several years of substance abuse and other struggles. When she discovers Civicorps Academy, she finally gets another shot at a high school diploma — and a future.
Girl-focused Resources
- American Association of University Women has been empowering women as individuals and as a community since 1881 through legal advocacy, educational funding, public policy and campus leadership. millions of women and their families.
- Boys & Girls Clubs of America provide programs and services to promote and enhance the development of young people.
- Girl's Inc.develops research-based informal education programs that encourage girls to take risks and master physical, intellectual and emotional challenges.
- Girl Scouts of the USA builds girls of courage, confidence, and character, who make the world a better place.
- National Campaign to Prevent Teen & Unplanned Pregnancy seeks to improve the well-being of children, youth, families, and the nation by preventing unplanned pregnancies.
- The National Latina Institute for Reproductive Health works to ensure the fundamental human right to reproductive health and justice for Latinas.
- YWCA is dedicated to eliminating racism, empowering women and promoting peace, justice, freedom and dignity for all.
American Graduate: Let's Make It Happen is a public media initiative, made possible by the Corporation for Public Broadcasting (CPB), to help communities implement solutions to the high school dropout crisis. Working with more than 75 public media stations in over 30 states, and Washington, D.C. and Puerto Rico, and more than 1,000 local partners and schools to keep students on track to graduation, American Graduate empowers individuals at the community level with knowledge through national and local reporting, convenes diverse local stakeholders, and provides access to free resources for students, teachers and parents. Public media is playing a significant role building individual activity, community capacity, and national awareness.
ITVS has launched a multi-platform campaign supporting the American Graduate initiative focusing on engagement with Latino communities across the United States: American Graduate: ¡Vamos a Lograrlo! Through this campaign, ITVS will provide an infusion of powerful storytelling with The Graduates/Los Graduados and the short films in both Spanish and English. These programs provide a window into the lives of young Latino students and the key moments that changed their destinies.


text:
Dherbs Review
What You Should Know
Click Here To See Our Highest Rated Review
Dherbs.com is a company that has dedicated itself to informing and adequately educating consumers on the significance of overall wellbeing and sustenance. The products offered in the market by Dherbs are thus designed to act as detoxifiers in order to cleanse the body. The Colon Formula, which is part of the full body detoxification, is one such product.
The full body detoxification program is constituted of six products of which the Colon Formula is included. The other five products are the Blood and Lymphatic Cleanser, Cardiovascular Cleanser, Liver and Gall Bladder Cleanser, Lung cleanser and Kidneys-Bladder-Adrenal Cleanser. The Colon Intestinal Cleanser like all Dherbs products is a purely herbal extraction thus is ideal for vegetarians. Each supplement in the total body detox retails at about $19.95. This makes the entire program cost nearly $120.00.
Other products on the site include Jackrabbit Formula, Fibroid Buster, Anti-Viral Formula, Bowel Mover and Weight Release Formula. The Weight Release Formula is said to help maintain weight lost on the detox program.
Each of the supplements has a different ingredient list. The Weight Release Formula ingredient list includes chickweed, bladderwrack, celery seed, fennel, hibiscus, orris, gotu kola, orange peel, lemon peel, bissey nut, burdock, green tea, chicory, uva ursi, yerba mate, cleavers, birch and rhatany.
Product Features
The product comes packaged in form of capsules with each bottle holding one hundred pills. This Dherbs.com product is said to be derived from herbal plants utilized by old cultures for reason of conditioning the entire digestive system. The Colon Formula should be taken in dosages that include three capsules that are to be ingested on a daily basis. This is not to mention the other supplements in the total body detox.
The Weight Release Formula is a laundry list of natural diuretics.
- It conditions the digestive tract by gently invigorating peristalsis which is the wave like motion that moves food through the esophagus and the rest of the digestive tract.
- Cleans the intestinal walls as a result of the bulking, moist and sticky properties.
- It assists in the mending of microscopic villi.
- The mucilage property associated with the formula helps lubricate the colon.
- As it contains fiber and roughage it assists in stool softening.
- The Colon formula encourages bowel movement which may inconvenience someone with frequent visits to the bathroom.
- In order to function at its maximum it is to be taken frequently, therefore requires discipline.
- Again the entire regime is supposed to include a full body detoxification which is relatively expensive, $120.00.
- The Weight Release Formula is a diuretic.
Dherbs.com provides total body cleansing and while some people lose weight when cleansing, this is not a long term option for weight loss. The majority of the ingredients in body cleansers are natural diuretics and laxatives. This leads to water loss and increased bowel movements but not real weight loss. The product is also very expensive. In order to lose weight, we recommend going with a weight loss supplement that help increase the thermogenics in the body paired with a higher fiber diet.


text:
GARN | Dectra Corporation has a strong commitment to education and outreach. We believe that educated consumers make better long-term decisions, become better alternative-energy advocates, and make the best, and most satisfied long-term customers.
The list below is intended to be a dynamic collection of information, resources, and white papers related to Wood Heating, GARN Products, and alternative energy in general. We'll update this page as often as possible, so please check back.
Tax Credits
In the News (Links)
- The Real Cost of Cheap Oil
- Best Placement for a GARN Unit
- EPA Action Alert Update
- Why Emphasize Corrosion Protection?
- Introducing the GARN Jr
- EPA Requires Efficiency Removals for Phase II Units
- Why GARN?
- Going Green
- Tax Credits for GARN® WHS Units
- About Clean Burning
- Why Thermal Storage?
- Water Quality and pH
- What is the Real Cost?
- Issues with stack height regulations
- Thermal Shock
- GARN® Units in the Ucross Foundation Newsletter
- Dilution Tunnel Testing
- GARN EPA Testing – Parts 1-3


text:
Group Name:
Triathletes and aspiring ones
Anywhere, AZ 85621
Lose the holiday weight for race season
Expert and novice triatheletes. Male or female and of all shapes and sizes
Last posted:
Tuesday, October 04, 2011, 11:01 AM
Other Info:
Members profiles:
I'm a 22 yr old college student. I actually really like working out, but I'm also pretty good at finding other things to do and then noticing the time has just slipped away. I like biking, swimming, running, and especially team sports.
Dedicated triathlete - 4 years and running...Love the bike, like the swim and run. Favorite distance is Olympic, but I do a 1/2 ironman every year for the challenge. Was never athletic before college, but once I found the bike and then triathlon, I was hooked.
25 Year old software developer from Grand Junction CO
- our sponsor -


text:
The U.S. Supreme Court will consider the case of a James Island couples seeking to overturn a ruling that returned their adopted daughter to her biological father under the federal Indian Child Welfare Act, according to the Supreme Court of the United States blog.
An attorney for Matt and Melanie Capobianco filed the 142-page petition with the high court in October, arguing that the justices should accept the case to settle uncertainty over how the 1978 act should be interpreted.
From a family spokeswoman, the Capobiancos said: We are so incredibly excited that the U.S. Supreme Court has accepted our case. We have a renewed sense of faith in our legal system and a renewed sense of hope that Veronica will be able to come home.
The Capobiancos have not seen 3-year-old Veronica since a family court ruling relinquished the girl to her father on New Years Eve of 2011.
The S.C. Supreme Court in July upheld Veronicas forced return to her biological father in Oklahoma. Her father, a member of the Cherokee Nation, successfully challenged the adoption using the Indian Child Welfare Act, a federal law aimed at preserving American Indian families.
The federal law has been reviewed only once at the highest level. In 1989, Justice William Brennan sided with Mississippis Choctaw tribe, which challenged an adoption of twins.
At issue in the case is the definition of parent under the federal law, including whether that includes an unwed father who only belatedly claimed parental rights, the blog stated.
The Veronica case is one of three newly granted cases that were considered among 30 petitions on Friday.
Read more in tomorrows edition of the Post and Courier.
- Keywords
This October 2011 photo provided by Melanie Capobianco shows her adoptive daughter Veronica trick-or-treating, in Charleston, S.C. The child has been the focus of a custody battle between her adoptive parents and her birth father. The adoption case involving little Veronica is one pitting the South Carolina couple who nurtured her since birth against her biological father who was recently awarded custody of the 2-year-old child and took her to Oklahoma. (AP Photo/Courtesy of Melanie Capobianco)×
Notice about comments:
The Post and Courier is pleased to offer readers the enhanced ability to comment on stories. Some of the comments may be reprinted elsewhere in the site or in the newspaper. We ask that you refrain from profanity, hate speech, personal comments and remarks that are off point.
We do not edit user submitted statements and we cannot promise that readers will not occasionally find offensive or inaccurate comments posted in the comments area. If you find a comment that is objectionable, please click the X that appears in the upper right corner when you hover over a comment. This will send the comment to Facebook for review. Please be reminded, however, that in accordance with our Terms of Use and federal law, we are under no obligation to remove any third party comments posted on our website. Read our full terms and conditions.


text:
Online Classes, Memberships, and Trip Registrations
Online Class, Membership, and Trip registration is now available! Visit
https://recservices.uwec.edu to sign up for Fitness Memberships, Wellness Classes, Adventure Trips, and more!
Summer Wellness
Summer wellness information is now out! Check out the
Summer Wellness Poster and
Summer Wellness Brochure for information and class times!
Bringing a Little Sunshine Into Your DayThere are many benefits of physical activity in managing depression, anxiety, and stress. Check out Benefits of Activity to learn more!
Massage Therapy
Check out our Massage Therapy Brochure and the Massage Therapy Website for all of your massage needs!


text:
Biosciences industries are dynamic, complex and highly entrepreneurial. They require knowledge in diverse areas including leadership, ethics, innovation and entrepreneurship, and regulatory and budget management. BioSciences Management addresses these and other topics, such as market dynamics of pharmaceutical and biotechnology commerce.
Through project-based learning and an internship – required for full-time MBA students – you to apply what you learn in the classroom as you work on real projects for biosciences companies. Cross-functional teams include students from both the Jenkins Graduate School of Management and College of Agricultural and Life Sciences (CALS), who may take biosciences as part of a dual concentration, and students from engineering and other technical disciplines across campus.
Most students who concentrate in BioSciences Management come from an academic life sciences background or have extensive work experience in the field.
|Representative Job Titles
|Discoverant Hierarchy Developer
|Sequence Inc.
|Product Manager
|PSCM Specialist
Under the leadership of Dr. Richard Kouri, the BioSciences Management Initiative manages the development of MBA-level coursework and the BioSciences Management Concentration. The BioSciences Concentration focuses on providing business context for students with diverse backgrounds such as Biology or Technology. The program matches with real world issues for action learning through projects with local companies in industries such as Pharmaceutical, Healthcare, Diagnostics, Nutrition, Agriculture etc.


text:
Last night The Walt Disney Walt Disney Company reported better than expected March quarter results and the shares are trading at or near their 52 week high. Somewhat surprising, the better than expected results were led by the company's park business, which benefitted from a number of new features including new Pixar based attractions. All told, higher attendance and greater spending as well as the inclusion of the Disney Fantasy cruise ship led to strong growth year over year.
Outside of the parks business, Walt Disney's film unit led the industry with the top-grossing movie for the three months ended March 31, "Oz the Great and Powerful." Helping that division was not only its strong move slate during the quarter, but also the lack of a write down like the one it had last year with the flop that was "John Carter."
Even though "Oz the Great and Powerful" was the number one movie during the quarter, and "Iron Man 3", which kicks off the 2013 summer movie season, is off to a very strong start there is some concern for the movie box office this year. Part of that is fueled by such a strong year last year with Disney's "The Avengers", Time Warner Time Warner's "The Dark Knight Rises", Lions Gate Entertainment Lions Gate Entertainment's "The Hunger Games", Sony Sony's latest James Bond adventure in "Skyfall", the first movie in "The Hobbit" trilogy and another "Twilight" movie. Those movies and others led to a $10.8 billion movie box office in 2012, the highest on record. Helping the box office was the increasing percentage of movies that came in the 3D and IMAX formats as they bumped up ticket prices. Average ticket prices finished 2012 at $7.96, a new record.
This year, however, the box office has started off on a weaker note. On a year-to-date basis, the gross for the week ending May 6 is down 12.4% compared to 2012. It's also down on the same basis compared to 2010 and 2009.
Hmmm. While a number of upcoming releases look promising, including "Star Trek: Into Darkness", "The Great Gatsby", "Fast & Furious 6", "Man of Steel" and "Despicable Me 2", the jury's out on whether or not this year's box office can close the gap with last year's take.
You would never know that the box office is down year-to-date by looking at the stocks of several movie theater chains – Regal Entertainment Group, Cinemark Holdings and Carmike Cinemas. Shares of each of those companies are up strong double digits year-to-date — as high as +36% in the case of Regal Entertainment and as "low" as up 18% for Cinemark Holdings. Across the board, all three of those stocks have handily beat the major market indices even though their primary driver — the box office is down double digits through early May. True, the movie theaters make robust margins on concessions, but in order to sell those tasty treats, people have to be in the seats.
Of the three stocks, Regal Entertainment is the most richly valued — trading at 18.9x 2013 consensus earnings of $1.00 per share. Not only is it the largest in the game, but the company also sports a dividend yield of 4.4%, which has probably helped attract investors. Perhaps the most vulnerable to the box office shortfall, however is Carmike Cinemas. Current Wall Street expectations have the company's earnings growing 93% year over year in 2013….that could be a stretch if the movie box office doesn't pick up in the coming months.
Times like this, it pays to remember the Wall Street saying — bulls make money, bears make money, but pigs get slaughtered.