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I haven't been following the Floyd lawsuit that challenges New York City's stop-and-frisk practices as closely as I should, and I need to fix that. Just today, I downloaded the postrial memoranda that the defendants and the plaintiffs filed with the district court, to read over the next week or so. In case any of you would like to read these documents, too, I have posted them here (defendants' memorandum) and here (plaintiffs' memorandum).
Category Archives: Criminal Procedure
From the Archives: The ACLU Urges RFK to Prosecute (1963)
It's strange to see ACLU brass support a criminal investigation, as occurred yesterday when executive director Anthony Romero issued a statement relating that it was "imperative that the Department of Justice thoroughly examine whether the [Trayvon] Martin shooting was a federal civil rights violation or hate crime."
Strange, but not unprecedented. Back in 1963, the executive director of the ACLU wrote Robert F. Kennedy to encourage Kennedy's Department of Justice to pursue more cases under 18 U.S.C. § 242, a federal civil-rights statute. John de J. Pemberton wrote his letter to RFK to discuss the filing of Moses v. Kennedy and Hoover, a lawsuit that sought to compel the Federal Bureau of Investigation and Department of Justice to investigate and prosecute, where appropriate, section 242 violations that were occurring non-stop in Mississippi.
(Aside: The lawyers for the plaintiffs in Moses were William Kunstler and William Higgs. Everyone still knows who Kunstler was. Higgs not so much, which is a shame; he's one of the lost legends of the civil rights movement and had a fascinating, if short, life. A few snippets here and here.)
In his letter to Kennedy, de J. Pemberton wrote:
It is our understanding that few if any Section 242 prosecutions have been instituted in Mississippi within the past few years. With the dramatic increase in civil rights activity in the South, the need for protection and assistance, as demonstrated by the Moses suit, is made all the more imperative.We urge as forcefully as possible that the Department of Justice give serious attention to the questions raised in the Moses suit.
Ultimately, Moses was thrown out of court, as it had to be, with the judge concluding that the "complaint must be dismissed because it seeks remedies which, in the context of the above pleadings, this Court has no power to grant." (The district court's decision tossing the case can be found at 219 F.Supp. 762.)
After the jump, I've posted photographs of de J. Pemberton's letter, Burke Marshall's response on RFK's behalf, and de J. Pemberton's reply. (These documents can be found in Box 76 of the Burke Marshall papers, within the Department of Justice Record Group at the National Archives in College Park.)
Federal Charges Against George Zimmerman?
I deliberately avoided coverage of the George Zimmerman trial, as I did the Casey Anthony trial, the O.J. Simpson trial, and most other high-profile cases. But upon waking up this morning, I did take notice of Zimmerman's acquittal and ensuing calls for federal authorities to bring "civil rights charges" against him. This got me to thinking, what civil rights charges? And how likely is it that the federal authorities will file these charges?
Upon review, it appears that the closest "fit" among federal crimes would be 18 U.S.C. § 249, a recently enacted federal hate-crimes statute (officially, The Matthew Shepard and James Byrd, Jr., Hate Crimes Prevention Act of 2009). Section 249(a) provides:
(a) In General.—
(1) Offenses involving actual or perceived race, color, religion, or national origin—
Whoever, whether or not acting under color of law, willfully causes bodily injury to any person or, through the use of fire, a firearm, a dangerous weapon, or an explosive or incendiary device, attempts to cause bodily injury to any person, because of the actual or perceived race, color, religion, or national origin of any person—
(A) shall be imprisoned not more than 10 years, fined in accordance with this title, or both; and
(B) shall be imprisoned for any term of years or for life, fined in accordance with this title, or both, if—
United States v. Hatch: Earlier this month (July 2013), in United States v. Hatch, the Tenth Circuit affirmed a conviction, upon the defendant's guilty plea (reserving right to appeal), of conspiracy to violate the statute. According to the Court of Appeals, "In April 2010, a mentally disabled Navajo man—whom the record identifies only as 'V.K.'—came to [a] restaurant. [Another individual] convinced V.K. to come to [his] apartment. Hatch and [a third person] later joined [them] there. At [the] apartment, the three white men drew on V.K.'s back with markers. They told him they would draw "feathers" and "native pride" but actually drew satanic and anti-homosexual images. They then shaved a swastika-shaped patch into V.K.'s hair. Finally, they heated a wire hanger on the stove and used it to brand a swastika into V.K.'s arm." One of Hatch's two co-defendants also was convicted upon plea of a section 249 charge; the other was convicted upon plea of conspiracy to violate this law.
In both Maybee and Hatch, the defendants argued that section 249 was unconstitutional, in that Congress lacked authority to enact the statute. Both Courts of Appeals rejected this argument, concluding that the Thirteenth Amendment conferred sufficient authority upon Congress.
United States v. Mullet: Some of you may have heard about this case, in which the defendants were charged with federal crimes for, inter alia, cutting off the beards of their foes within the Amish faith. The lead defendant, Samuel Mullet, Sr., was convicted by a jury of violating section 249, as well as other crimes. More than a dozen co-defendants also were convicted of conspiring to violate the statute.
United States v. Thompson: Here, the defendant pleaded guilty to a single section 249 count. The felony information, filed in the District of Minnesota in July 2011, alleged that Thompson struck an elderly Muslim man of Somali descent while telling him to "go back to Africa."
United States v. Hall: A 2013 guilty plea by a member of the Aryan Brotherhood. Hall, an inmate in a federal prison in Texas, assaulted another inmate whom he believed was gay.
United States v. Larson: A guilty plea associated with an assault upon a Sikh cab driver in Washington state. The incident took place in October 2012; Larson entered his plea in June 2013 in the Western District of Washington.
United States v. Jenkins: This federal prosecution, brought in 2012, stemmed from the kidnapping and assault of a gay man in Kentucky. Two female defendants pleaded guilty to aiding and abetting a hate crime assault, in violation of section 249. Their two male co-defendants pled not guilty and went to trial. At trial, the men both were convicted of kidnapping and conspiracy charges, but were acquitted of the section 249 crime.
Unfortunately, I don't know if these cases represent all section 249 prosecutions to date. I may have missed a case, especially if it led to a dismissal or acquittal (making the DOJ somewhat less enthusiastic about issuing a press release).
Nevertheless, it's pretty clear that the feds don't file very many section 249 charges. Why? Well, as I've written elsewhere, civil-rights crimes can be very difficult to prove. The failure to earn convictions on the section 249 count as against the Jenkins defendants who chose to go to trial underscores the difficulty in proving, beyond a reasonable doubt, the specific intent necessary to establish a hate-crime offense. My sense is that federal prosecutors, aware of these difficulties, properly are reserving section 249 charges for relatively clear-cut cases. (Indeed, section 249 cases are so rare that the DOJ's press releases for two different cases (Thompson and Hatch) both identified the case as the first to be brought under the Shepard-Byrd Act. Oops.) I have not read anything about the Zimmerman case that would lead me to believe that the section 249 case against him is comparably obvious, but again, I have not been following the case closely.
Turning the page, some of you who recall the federal prosecutions of the police officers involved in the Rodney King beating may wonder about the applicability of those crimes to the Zimmerman case. These offenses, 18 U.S.C. §§ 241 and 242, don't apply to the Zimmerman matter. The first of these crimes is a conspiracy offense, and you can't have a one-person conspiracy. Per the Department of Justice's website, the second of these offenses "makes it a crime for a person acting under color of any law to willfully deprive a person of a right or privilege protected by the Constitution or laws of the United States," But Zimmerman wasn't acting under "color of law" insofar as I can tell, so I don't think that crime would fit, either.
* An earlier version of this post mistakenly referred to this subdivision as section 249(b).
What Will Get a Police Officer Decertified? Records from the Florida Department of Law Enforcement
In most jurisdictions, it's well-nigh impossible to obtain records or data that relate to police-officer disciplinary proceedings. But there exist a few jurisdictions, such as Florida, that make this information available under open-records laws. Seizing upon this opportunity, not long ago reporters for the Sarasota Herald-Tribune submitted dozens of public-records requests to state and local law enforcement authorities, to ascertain whether and under what circumstances police officers were being disciplined for crimes they committed and other derelictions of duty.
This laborious project ultimately produced a series of extremely interesting articles, which you can access at this link. More to the point of this post, one of the authors of this series, reporter Anthony Cormier, was kind enough to share with me a series of databases assembled in connection with these stories.
The databases consist of records from the Florida Department of Law Enforcement (FDLE). In Florida, police and corrections officers must have a "certificate" in order to ply their trade. The FDLE is the state agency responsible for issuing, and revoking, these certificates. An officer may get reported to the FDLE following an internal affairs investigation, their arrest, or some other prompt. The FDLE then determines whether to revoke the officer's certificate, impose lesser sanctions, or take no action.
The databases that I was sent comprise records relating to many years' worth of complaint proceedings, involving more than 28,000 complaints in all. I am still getting my arms (and head) around the data, but I don't mind conducting the initial stages of this process in public, so long as none of you hold me too closely to what I say here.
One of the first things I want to glean from the data concerns the types of offenses (criminal violations, poor work performance, etc.) that get police and corrections officers in hot water the most, and least, often, both in absolute terms and as a percentage of referred cases. As an initial stab at this information, I transferred some of the databases over to Microsoft Excel, merged a few of these tables using the VLOOKUP function, and then ran an Excel pivot table to arrange the cases based on their (1) outcomes and (2) the principal offense that the officer was accused of committing. By pulling these strings, I could tell which "offenses" — a term that, in this context, encompasses both criminal violations and other gaffes — led to the most decertifications.
I'll post the resulting chart, after the jump.
Annals of Privacy-Enhancing Devices: The Delcon Security Telephone (1961)
With all the ongoing fuss over government surveillance, it's like 1961 all over again. But I doubt that we will see a comeback from the Delcon Security Telephone, advertised in this vintage brochure and cover letter.
The Delcon Security Telephone was a "scrambler" designed to defeat eavesdropping and wiretapping efforts by the government and assorted ne'er-do-wells. Per its promotional brochure, as attached to a regular phone the Security Telephone "converts the human voice into unintelligible jargon, which can be identified vaguely as the sound of a voice, similar to the effect of a phonograph record played backwards." Only those who had their own, similarly coded Delcon Security Telephone on their end of the line could decipher this gibberish.
Was the Delcon phone useful? Well, as the cover letter brags, it did play a part in the "Murchison-Alleghany Proxy Fight," which sounds fascinating, but not so fascinating that I'm actually going to find out what it was. The product's principal drawback: it weighed 24 ounces, which seems just a couple ounces short of a Shakeweight. But with long-distance rates being what they were back in 1961, maybe the handset's weight saved its purchasers money in the long run, by making certain that confidential calls got to the point.
Is the U.S. Attorney's Office for the District of Massachusetts Really "Particularly Immoral"?
As part of the ongoing conversation over the charging practices of federal prosecutors, prompted by the death of Aaron Swartz, one commentator observed that the United States Attorney's Office for the District of Massachusetts–which prosecuted Swartz–was, based on her experience, "particularly immoral."
The writer cited only two instances of perceived "immorality" in support of this charge. I suspect the commentator had other examples in mind, but wished to spare readers a series of war stories. But the accusation, as well as the rather slender evidence advanced to support it, got me to wondering. If one wanted to prove that a particular U.S. Attorney's office was "particularly immoral," how would one go about doing it?
Since most of the criticisms of the Swartz prosecution sound in perceived "overcharging" by the prosecutors involved, I decided to focus on "overcharging" as evidence of "immorality." Here, it's important to define what I mean by "overcharging," which people use to describe several distinct, though often overlapping, phenomena. In addressing the issue at hand, I concentrated on those species of "overcharging" in which prosecutors allege crimes with the intent to either reduce or dismiss them as part of a plea bargain to other offenses. Attacks on this type of overcharging don't (necessarily) accuse the prosecutor of filing charges on "insufficient" proof, whatever that means. Instead, the argument accuses the prosecutor of engaging in an illegitimate practice by using criminal charges as bargaining chips.
So, if this practice amounts to overcharging, and this sort of overcharging represents an "immoral" practice, how to measure it? Here, I tapped a series of datasets I have pulled together from data compiled by the Administrative Office of the United States Courts (AOUSC) and the Executive Office for United States Attorneys (EOUSA), which I have used for other purposes in the past. These datasets reflect the disposition of charges filed in cases terminated in United States District Courts between October 2002 and September 2009. The data can be sorted by judicial district, and thereby yield a picture of charge dispositions in each U.S. Attorney's jurisdiction.
Now, the data have their flaws. They contain some inputting errors, for one thing. Though they are portrayed as comprehensive, I have spotted at least a few missing cases. The data do not distinguish between cases handled by the local U.S. Attorney's office, and those prosecuted out of Main Justice. Finally, and most important, while the data relate the charges filed against each federal defendant (with the AOUSC data relating only the five "most serious" charges, as measured by base offense level), the records do not include information specific to each offender (such as his or her criminal history). This gap means that one can't divine from the data alone where on the Sentencing Guidelines a particular defendant would fall, if convicted.
These limitations mean that the data don't yield what would represent one useful measure of overcharging–juxtaposing the maximum possible sentence that would adhere in a case, as charged, against the prosecution's actual plea-bargain demand to the defendant. But one can tap the data in other useful ways. For example, because the data identify the district in which each case was brought, one might parse, shuffle, and collect the data to rank U.S. Attorneys' offices along the following lines (among others):
Dismissals in Pled Cases: the percentage of charges that were dismissed in cases resolved by guilty or no contest plea. Here, a high dismissal rate would seem suggestive of aggressive charge-bargaining;
"Most Serious Charge" Reductions: the percentage of cases, resolved by plea, in which the offense designated as the "most serious charge" at the time of initial case filing no longer held this status at the time of case termination. Once again, higher dismissal rates would tend to suggest aggressive charge-bargaining; and
Dismissals of "Bargaining Chips" in Pled Cases: the frequency with which, in pled-out cases, prosecutors dismissed a charge that practitioners widely appreciate as a bargaining chip, such as the firearm enhancement found at 18 U.S.C. 924(c).
I concede that none of these metrics come close to perfection. Even assuming the accuracy of the data, they are subject to skewing influences such as docket composition and prosecutorial tactics such as threatening to file a more severe superseding indictment, instead of "bargaining down" an existing case. But if properly understood and limited, these metrics have their uses. Especially to the extent that the data corroborate each other, they may yield "yellow flags," spotlighting offices whose practices may warrant further scrutiny (or praise).
So, what do these analyses yield? Well, I am writing up a short essay that relates the results, while trying to clarify what is meant by the term "overcharging." I should have a draft done within the next week or two; toss me a line if you'd like a copy, or if you edit a law review that has very low standards. For now, I'll just say that many of the same judicial districts tend to pop up again and again at the extremes of these rankings.
And, toward the point of this post, what about the District of Massachusetts? Well, with the caveat that I still need to double-check the data, it appears that this District (meaning, presumably, the U.S. Attorneys who practice there) has built a record that does not suggest pervasive charge manipulation–at least relative to other U.S. Attorney's offices. Specifically, among federal districts, the District of Massachusetts had either the second- or the third-lowest charge-dismissal rate over the studied time span (the difference depends on whether one relies on the AOUSC data or the EOUSA data on this point). The District also had the seventh-lowest rate of 18 U.S.C. 924(c) plea-deal charge dismissals.
So, while acknowledging that the measures I used don't exhaust the possible grounds for a finding of "immorality," I don't perceive from my preliminary review of the data much substantiation for the charge that the Massachusetts U.S. Attorney's office is "particularly immoral."
Some Thoughts on the Computer Fraud and Abuse Act
The death of Aaron Swartz last week has drawn renewed attention to the Computer Fraud and Abuse Act (CFAA) (18 U.S.C. § 1030). If you've made it this far in the post, I will assume that you know what the CFAA is, and what it criminalizes.
My aim here isn't to criticize or defend the CFAA generally, or the Swartz prosecution specifically. Instead, I simply want to offer up some data that fleshes out how, and how often, federal prosecutors have invoked the statute, from which others may draw their own conclusions.
As I explain to anyone who spends more than four minutes with me–which guarantees that very few persons do–I have complied a database of information on all federal prosecutions that terminated in federal district courts between October 2002 and September 2009 (FY 2003 — FY 2009).* The data come from the Administrative Office of the United States Courts (AOUSC), which compiles the information from terminated federal cases and makes it available to researchers through the Interuniversity Consortium for Political and Social Research. Though the data are far from perfect — humans input the information for each case, and humans make mistakes — they shed light on matters such as how often federal prosecutors invoke particular crimes, and what sorts of dispositions these cases produce.
Earlier this evening I ran a few searches on my database,** searching for prosecutions terminated between October 2002 and September 2009 that included at least one count alleged under 18 U.S.C. § 1030.*** (The database includes only the five "most serious" charges, so it doesn't capture all counts in all cases, but it comes close.) Here's what I found:
Total Number of § 1030 Cases. Altogether, 905 federal cases that terminated between October 2002 and September 2009 included at least one count under 18 U.S.C. § 1030 among the five "most serious" initial charges, or the five "most serious" charges at the time of case termination. (Note that here, the database identifies each defendant in a multi-defendant case as a separate "case.")
Year-by-Year Breakdown. The number of filed cases that incorporated at least one 18 U.S.C. § 1030 charge, either at the time of case filing or case termination, increased a bit as the 2002–2009 timeframe progressed. The database contains 115 such cases that were filed in FY 2003; 98 cases filed in FY 2004; 131 cases filed in FY 2005, 143 cases filed in FY 2006, 145 cases filed in FY 2007, 129 filed in FY 2008, and 144 filed in FY 2009. Moreover, the actual number of § 1030 cases filed in FY 2008 and FY 2009 is certainly higher than the numbers above suggest. The database includes only terminated cases, and many cases filed during these fiscal years remained pending as of September 30, 2009, the last day of FY 2009.
Geographic Variation. Prosecutors in the Central District of California filed the largest number of cases that included at least one § 1030 charge at case initiation or termination (82), followed by the Eastern District of California (48), Southern District of New York (37), the Eastern District of Virginia (also 37), and the Eastern District of Pennsylvania (35). Significantly, these were the only districts that averaged more than five § 1030 cases a year over the seven-year period. About half of all United States districts averaged one, or less than one, § 1030 case per year. The District of Massachusetts, where Swartz was prosecuted, saw sixteen (16) terminated section 1030 cases over the FY2003–FY2009 span.
Case Outcomes. Here, I focused on felony charges brought under 18 U.S.C. § 1030(a). Of the total of 893 counts under this subdivision with recorded dispositions over the studied period, 59 percent led to convictions. Section 1030(a) counts went to trial a bit more often than the "average" crime did. The trial rate of 6.7% for § 1030(a) charges was about half again the overall 4% trial rate for all charges in the dataset–but since only sixty § 1030(a) counts went to trial, it's probably best not to draw any broad conclusions from this discrepancy. Tried § 1030(a) counts led to acquittals 18.3% of the time, meanwhile, a figure close to the dataset's overall trial-acquittal rate of approximately 20%.
Sentencing Outcomes. On this point, I looked exclusively at the subset of 18 U.S.C. § 1030 cases in which the AOUSC identified § 1030 as the "most serious" charge at filing. Among these 767 cases, just south of 500**** led to no prison time for the defendant, either because of a dismissal, acquittal, or a sentence upon conviction that called for no custody time. The most commonly appearing prison sentences were pretty low; they were, in order, 12 months (the sentence in 34 cases), 5 months (25 cases), 18 months (also 25 cases), 15 months (14 cases), and 24 months (also 14 cases). But some cases — about 10 percent of all cases that led to a prison term (31 out of 279) — led to prison sentences of 57 months or more. Most of these big-sentence cases, however, also involved charges brought under statutes other than § 1030, as Swartz's case did.
* * *
The data are open to a variety of interpretations. To get the ball rolling, here are a few thoughts of my own.
First, assuming the perpetuation of the trends discussed above, in most judicial districts there exist a handful of § 1030 prosecutions each year–at most. This fact means that (the applicable sentencing guideline notwithstanding) there exists no established "going rate" for plea bargains involving the offense. The lack of a "going rate" likely enhanced the uncertainty that Swartz internalized as his case progressed. Furthermore, because prosecutors don't try very many § 1030 cases, they may have an incentive to allege a large number of counts in any given case, in order to enhance the somewhat opaque odds of conviction.
Second, I was somewhat surprised at the list of jurisdictions in which § 1030 prosecutions were most common. I would have thought that the Eastern District of New York and the Northern District of California would have been among the leaders in CFAA prosecutions. And while these districts weren't too far behind those listed above (the Northern District of California had 29 prosecutions containing a § 1030 count; the Eastern District of New York, 21), I wonder whether CFAA investigations weren't prioritized in these districts, or whether U.S. Attorneys in these jurisdictions were, for some reason, relatively apathetic about prosecuting the crime.
Third, the 59 percent conviction rate for section 1030(a) charges is higher than the conviction rates for most of the other frequently alleged federal crimes, suggesting that these counts aren't used as bargaining chips by federal prosecutors as often as many other crimes are.
* * *
* I'm working on getting some more recent data.
** Here, let me stress that I ran the data while also watching "Archer: Season Two" on DVD. So please take the numbers presented here with a pinch of salt.
*** This search encompassed four "charge codes": 18:1030A.F; 18:1030A.M, 18:1030B.F, and 18:1030B.M. The first of these charges was, by far, the most common.
**** There were a handful of AOUSC codes for custodial provisions that I didn't take the time to decode. Suffice it to say that the number of non-prison outcomes may be as low as 467 and as high as 488, and is probably on the high end of this range.
Bud Abbott, Pornography, and Searches Incident to Arrest
Tragedy — I dug up today's document too late to incorporate it into my Crim Pro class on the search incident to arrest exception to the warrant requirement. Given its ribald subject matter, though, I probably wouldn't have referenced it anyway; plus, I was too busy airing the world's worst search incident to arrest.
The document — posted a long time back on www.thesmokinggun.com — is an FBI memorandum from 1958. The memo (you'll need to click on the document on the left-hand side of the linked-to web page to access it) claims that Bud Abbott, of Abbott & Costello fame, was an avid collector of pornography, possessing around 1,500 reels of the stuff in his home.
More to the pedagogical point, the memo writer advises that the Los Angeles Police Department planned on raiding a possible upcoming party at Abbott's, at which time the police would "confiscate all films they are able to find in their search incidental to [the participants'] arrests." At the time, the governing caselaw (Harris v. United States and United States v. Rabinowitz) would have permitted such an extensive search incident to arrest, provided (of course) that the arrest was lawful. The Supreme Court's decision in Chimel v. California, which pared back the permissible radius of a search incident to arrest, was 11 years in the future.
A Policeman's Beat Notebook (1907-1908)
My mom's mom's dad was a New York City police officer back in the early 1900s. When my grandmother, his daughter, died a few years ago, my mother inherited some of his effects. Among them, she found the notebook in which my great-grandfather entered his patrol reports for late 1907 and almost all of 1908. Recently, mom gave this notebook to me.
I never met my great-grandfather, George Brewster. He died in the 1950s. From what mom and my grandmother have told me, he was a very interesting person. A strikingly good-looking man, much like his great-grandson, he worked as a police officer for a time, but quit to run a nickelodeon shortly after my grandmother was born. Because my grandmother managed to survive this transition, our family now looks back on this decision and calls it "bold." But I'm pretty sure that in 1909, my great-grandmother used other, less complimentary terms to describe the forfeiture of a steady job, and the investment of the family's savings on hand-cranked moving pictures.
Anyway, the notebook measures about five inches high by three inches wide, small enough to fit inside a jacket or pants pocket. The precise year printed on each ruled page happens to be 1899, not 1907 or 1908; I wonder whether my great-grandfather bought the book secondhand, and whether a modern defense attorney could make something out of the disconnect between the pre-printed dates and the days, months, and years recorded by hand. As its frontispiece, the notebook has a glued-in photograph–black and white, of course–of my grandmother. The caption reads "Laura M. Brewster age 11 months and 8 days when taken." I'd say it's strange to see a baby picture of a woman whom I knew best when she was in her 80s, but grandma told me so many stories about her childhood–usually juxtaposing her labors with my privileges–that it's not difficult for me to find the proper mental spot for the photo.
My great-grandfather was stationed within the 84th Precinct, which back at that time encompassed that part of the Lower East Side closest to the Williamsburg Bridge's Manhattan Landing. Most of the residents of this precinct were Jewish, recent immigrants from Eastern Europe. If this neighborhood witnessed much violent crime, my great-grandfather displayed a tremendous knack for avoiding it. Most of the daily entries within the notebook relate only his hours of service, followed by "no report," and his lieutenant's stamp of approval. These entries are all written in a beautiful, steady cursive, pressed into the page with the calm hand of a man who has just spent several hours casually strolling around the city.
United States v. Jones (the GPS case): the Motion to Suppress and Other Court Documents
I haven't figured out quite yet how I'm going to integrate the United States Supreme Court's recent decision in United States v. Jones into my criminal procedure course next fall. (I'd better figure it out pretty fast, since I'm teaching the course at two different schools next semester. Eep.)
To get a better grasp of the facts behind the decision, I downloaded the pertinent Motion to Suppress (as later supplemented, and with its exhibits), Opposition Brief, and Order from the originating United States District Court's website, via PACER. I've made these documents available at this link, if any of you want to download them for your own use.
Just as a head's up, the "lead" document on this web page is Jones' Omnibus Pretrial Motion (with its attack on the GPS device being found at pages 17-18 of the motion); links to other, related documents, including the Supplement to the Omnibus Motion (in which Jones raised additional arguments regarding the use of the GPS device) can be found at the bottom of the page.
Torture: The Puritan Approach
The events of the past decade have revived the debate over whether it is ever permissible for a state to torture someone, and if so, under what circumstances. With this short post, I simply want to flag the fact that this conversation is nothing new, and dates back to the very first days of colonial settlement. To wit, the Puritans included the following provision within the first code promulgated in the Massachusetts Bay Colony, the endlessly fascinating 1641 Body of Liberties (a reprint of which can be found here):
No man shall be forced by Torture to confesse any Crime against himselfe nor any other unlesse it be in some Capitall case where he is first fullie convicted by cleare and sufficient evidence to be guilty. After which if the cause be of that nature, That it is very apparent there be other conspiratours, or confederates with him, Then he may be tortured, yet not with such Tortures as be Barbarous and inhumane.
The terms of this law clearly suggest some hand-wringing by the Puritans over the propriety of torture. Such measures were OK, but only under very carefully specified circumstances (even granting that more crimes were punishable by death then, than today). The obvious candidates for torture were convicted witches, as to whom it very well might be "apparent that there be other conspiratours" about. Even so, methods of torture that were "barbarous and inhumane" were off-limits under the law. Though one wonders what "barbarous and inhumane" connoted, back in the day.
San Francisco Police and Peace Officers' Journal of the State of California (1929-1930)
By now, it may be obvious that I enjoy reading old law-enforcement publications. Here's another, a collection of issues from the San Franciso Police and Peace Officers' Journal of the State of California (was a title this long really necessary?), dating back to 1929 and 1930. A few highlights:
"Outlook for the Securities Market," by Plunket-Lillienthal & Co. (December 1929 edition): "The stock market under normal conditions which have developed since the recent readjustment in stock prices, is a reflection of the general business outlook, and it seems reasonable to to expect that with the prospects for business being quite favorable in the last half of 1930, the stock market should move upward in April or May of that year. . . . We believe the general trend of the market for the near-term should be upward until the last week in December, as a strong stock market stimulates retail activities and encourages buying for the holiday season." Eep.
"Plan for Handling the Liquor Question": Here, the Chico, California, Chief of Police proposes an alternative to prohibition, whereby the government would own and operate all distilleries, wineries, and breweries, and be the exclusive sales agent for same.
"We're Getting Snappier Officers" (by L.E. Claypool, of the San Francisco office of the Associated Press): "In place of the traditional oldtime cop has come a younger, handsomer, more athletic fellow who wears a snappy uniform and cap and can cut a mean dido in a full dress suit if and when necessary. . . . The effect on women has been marvelous. For instance, when San Francisco had to make her traffic laws more stringent, especially as applied to jaywalking and improper driving, it was found the big, slouchy policeman could not get far with the women. There are many women drivers and, sad to relate, many women jaywalkers. Some time ago when a woman driver was taken to task for a traffic violation, she was certain to get sassy with with the policeman and likely to slap his face if she felt like it. Now, when a nattily dressed young man in khaki who looks and talks like a cross between Maurice Chevalier and Rudy Vallee, asks a woman motorist or woman jaywalker to please be herself, she is flabbergasted, and almost invariably does it and likes it."
"Public Defender Frank Egan": "Frank Egan, who has been public defender ever since the office was created in this city, is elected, having received a handsome vote in the primaries. However, it would be a nice compliment to him for all police officers to put in a vote for him on November 4.
"Public Defender Frank Egan was a former member of the San Francisco Police Department, and a darned good one, too. He always has been ready to go to the front for any brother officer, and in his present office he has always seen that the police have gotten the breaks in any case he has handled. . . ."
Each issue also includes a blotter-report-style "National Crime Report," a mix of the macabre, the tragic, and the humorous. This one is typical of the genre.
Curiously, there's not that much discussion of prostitution in these bulletins. One wonders why; perhaps the 1937 Atherton report on police corruption in San Francisco sheds some light on this early-day media blackout.
T-Minus 1: Daily Training Bulletins of the Los Angeles Police Department (1954), Part II
Last week, I posted about the collection of old Los Angeles Police Bulletins that's available on archive.org. The last post introduced the Bulletins by looking at some of the cartoons that were included therein; this post will take a closer look at the collection's substance.
Specifically, I'm interested in what the Bulletins have to say about the efficacy of the exclusionary rule in ensuring compliance with the Fourth and Fifth Amendments. As background here, the Bulletins were released in 1954. That was five years after the United States Supreme Court held that the basic right captured by the Fourth Amendment was "incorporated" as against the states (in Wolf v. Colorado), but seven years before the Court "nationalized" the exclusionary rule, in Mapp v. Ohio. It also was just one year before the California Supreme Court held that the exclusionary rule applied to criminal proceedings in that state (in a case by the name of People v. Cahan). With the exclusionary rule still one year in the future, what did the manuals have to say about proper police procedure? Was it still the Wild West, or were there right ways and wrong ways to do things?
What I found was somewhat of a mixed bag. There very little within the manuals on issues of pivotal concern to modern police officers. For example, the Bulletins only very briefly consider the circumstances in which it is appropriate to enter someone's house, and, insofar as I can tell from my admittedly quick review, never discuss when an officer can, over protest, search a motor vehicle, a residence, or personal property (other than the pockets of a suspected burglar, surprised during a stakeout) for evidence of a crime. At a minimum, even if I missed a line or two somewhere, these topics are not covered in any detail. Here, I would note that the manuals do not say that such searches are always (or ever) OK; they simply ignore the issues entirely. (The topics of search warrants and wiretapping also aren't discussed within the Bulletins; presumably, however, such measures weren't within the purview of the beat cops to whom these manuals were principally directed.)
There was much more within the Bulletins on the propriety of an arrest, particularly for commonplace crimes such as public intoxication. This focus isn't all that surprising, since law enforcement officers long had been held civilly liable for improper arrests. Indeed, the manual expressly notes the possibility of civil liability. On this note, the manual makes frequent use of the frick-and-frack dyad of "Officer Apathy" and "Officer Sharp" (a little like "Goofus" and "Gallant" from those old Highlights for Children magazines one used to see in dentists' offices, only with guns and more-frequent interaction with vagrants and prostitutes). One of the first admonishments from the square-jawed Officer Sharp is that "An understanding of the laws of arrest is to the policeman what a knowledge of the use of the compass is to a navigator."
Likewise, the manuals did touch upon some third rails to avoid during interrogations, due to the possibility of exclusion at trial. Per this cartoon, which incorporates a highly unnecessary character in a sombrero, "the 1890 technique" for inducing a confession "is out," and officers should instead utilize "scientific, intelligent interrogation." The text on the bottom of the page reminds officers that courts have cracked down on the practice of promising rewards or inducements in exchange for confessions. More generally, the manual offers frequent reminders about how good investigations–meaning investigations that yield reliable evidence–are essential to good cases, and to securing convictions in court.
All in all, the manual provides some support for the notion that without an exclusionary rule or similar sanctions, police won't pay quite the same attention to compliance with constitutional rules regarding search, seizure, and interrogation. I acknowledge that such training might have been available to Los Angeles police officers of that era through other sources, but the dearth of such information in a 300+ page police manual is somewhat telling.
One other point, of possible interest to modern audiences. The manual recommends that when an officer "stakes out" a car previously determined to have been stolen, he should disconnect two or three of its spark plug wires. Doing so "will effectively reduce the car's potential speed and forestall a 'chase.'" This is, clearly, the forerunner to Axel Foley's banana-up-the-tailpipe tactic.
Just the Facts, Ma'am: Daily Training Bulletins of the Los Angeles Police Department, in Cartoons (1954)
If you watched L.A. Confidential recently–or even if you didn't–you might be interested in this text, a compilation of the daily training bulletins issued by the Los Angeles Police Department in the post-WWII era.
On second thought, it's a pretty long read, and the content is simply too good for just a single post. I'll probably discuss some its specific advice to officers later on this week. For now, how about if we just look at some of its cartoons? I like cartoons, and there's so much to like here. Or to be appalled by. Whatever.
Let's start with "appalled": How about this cartoon? Though it's still a little more enlightened than Mickey Rooney's performance in "Breakfast at Tiffany's." At least the Asian character here speaks English well; it's the officer who resorts to pidgin.
Or, um, this cartoon. Is the Eskimo angle really necessary?
Now, on to the "awesome":
"Some people with a gun are out for no good." I appreciate how the creator of these cartoons has problems with prepositions that are similar to / of / with my own. I also appreciate the inclusion of "jealous women" among the classes of people who are out for no good.
"Charlie Weedmark, World's Greatest Bicycle Detective": This cartoon had me at "bicycle detective." How has this not been spec'd for a Jim Carrey role? And is Charlie Weedmark any relation to "Harvey Richards, Lawyer for Children"?
Finally, here are a few that I don't know quite what to make of:
"Patrick O'Pixie, the little guy who looks out after all good policemen?" Um, where the heck was Patrick when James Cromwell shot Kevin Spacey?
Nude dancers, as being within the purview of the vice squad, I can see. But "animal fanciers"? Isn't some further explanation necessary? Here again, euphemism by the writer = confusion in the reader.
Katz v. United States
I tend to get obsessed by the first case, or other primary source, that I teach in a course. In Torts, it's Hammontree v. Jenner; in American Legal History, it's the Laws and Liberties of Massachusetts (the 1648 version); in Criminal Procedure, it's Katz v. United States, the phone-booth case that inspired the "reasonable expectation of privacy" standard.
A while back, I searched around and found old footage of what I believe to have been the telephone booths in Katz (which are now long gone, of course). I also ordered the district-court record from the case from the National Archives. David Holt at our library posted these documents online for public consumption, and Gerard Magliocca at Concurring Opinions was kind enough to link to them. For whatever reason, I forgot to include Katz's motion to suppress among the posted documents. I've since corrected that, again with David's help, such that the motion is now also available online.
In case you're disinclined to read through all of the Katz materials, here's a quick rundown of a few points of interest from these documents:
1. As you might expect, the United States Supreme Court's opinion snuffed out the government's case. On remand, the government moved to dismiss the Indictment, with the court granting the motion.
2. One of the witnesses that the government subpoenaed for trial was Frank "Lefty" Rosenthal. (By the way, I love it when official court documents incorporate nicknames. I once defended a civil case in which the named plaintiff was Jimmy "The Hat" Allard; this nickname, on its own, made each pleading at least seven percent more fun to read.) If this name sounds familiar, Rosenthal was the inspiration for the "Ace" Rothstein character portrayed by Robert De Niro in the movie "Casino."
3. As some of you may know, Katz used a local hotel as his residence; an FBI agent rented the room next to his and eavesdropped on his conversations from that vantage point. The court filings establish that Katz stayed in Room 122 at what is today a Best Western, at 8400 Sunset Boulevard.
4. Katz's punishment, upon his conviction (prior to appeal, and then dismissal, of course)? A fine of $300. Yup, three hundred measly dollars. Out of such stuff are long-lived constitutional rules made.


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Report: Knicks have offer on the table for Melo
It looks like the Knicks are finally stepping up to the plate. Ken Berger tweeted Friday afternoon, "A person with knowledge of trade talks tells CBSSports.com that Melo will get his wish: a legit trade proposal to ponder by the end of All-Star Weekend."
Well, it looks like that offer may actually be on the table.
Yahoo! Sports is reporting that New York has indeed made an offer to the Nuggets for Carmelo Anthony that would send Danilo Gallinari, Raymond Felton, Wilson Chandler, Eddy Curry's contract and a to-be-acquired first-rounder to Denver. Also headed to the Knicks would be Chauncey Billups and "fillers."
Newsday's Alan Hahn tweeted that a source confirms the proposed trade.
The "to be acquired first-rounder" would almost assuredly be Minnesota's for Anthony Randolph, as that has been discussed for a while. As for why Gallinari, reportedly the Nuggets had an option to pick between him and rookie Landry Fields and preferred Gallinari.
With an actual deal on the table from the team that Melo will approve, this thing could actually be headed for a conclusion. Berger tweeted, "Source on Melo's desire to reach a resolution by weekend's end: 'He'll get something.'"
Since: Feb 2, 2009
Posted on: February 18, 2011 9:08 pm
Report: Knicks have offer on the table for Melo
NOOOOOOOOOOO DONT DO ITTTTTTTTTTTTTTT OMG knicks please no no no
Since: Jul 26, 2008
Posted on: February 18, 2011 9:00 pm
Report: Knicks have offer on the table for Melo
id do it. those dudes r all avg. superstars arent easy to come by.
Since: Jan 20, 2011
Posted on: February 18, 2011 8:58 pm
Report: Knicks have offer on the table for Melo
hahaha as a sixers fan i hope this deal happens. Right now the sixers are better and are playing better. so if the knicks make this trade the sixers will be alot better becuase this will totally ruin the team. anthony isnt a guy who can play with someone like stoudemire. You need a guy that can get the ball to amare. like raymond felton who has been fantastic with him. Also i would never give gallinari away in this deal because i think gallinari is going to become an amazing player. Honestly if lebron would have went to the knicks i think they would have won the chaampionship this year because lebron can pass the ball great and set up people great along with being able to score even better then anthony. that would be an unstoppable duo. so again i say i hope the kicks make this deal becaause the sixers will be the future of the east if they do. celtics are old and anthony will make this team go downhill.
Since: Dec 5, 2006
Posted on: February 18, 2011 8:51 pm
Report: Knicks have offer on the table for Melo
I hope this is just another in a long line of idiotic articles by rumor mill hacks. If the Knicks give away all of those players and a number 1 they are no different then they have been for years and years. The knicks must stop giving away every young talented player they get.

subset: commoncrawl


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Mr. Belasco does not intend to advance any theory as to the probability of the return of the main character of this play. For the many, it may be said that he could exist only in the minds of the characters grouped about him--in their subconscious memories. For the few, his presence will embody the theory of the survival of persistent personal energy. This character has, so far as possible, been treated to accord with either thought.
h were very remarkable, and I was convinced, at the time, that the dead gave these messages to her. She personally could not account for them. I probably owe my life to one of my mother's premonitions. I was going on a steamboat excursion with my school friends, when my mother had a strong presentiment of danger, and begged me not to go. She gave in to my entreaties, however, much against her will. Just as the boat was about to leave the pier, a vision of her pale face and tear-filled eyes came to me. I heard her voice repeating, "I wish you would not go, Davy." The influence was so strong that I dashed down the gang-plank as it was being pulled in. The boat met with disaster, and many of the children were killed or wounded. These premonitions have also come to me, but I do not believe as I did when a boy that they are warnings from the dead, although I cannot explain them, and they are never wrong; the message is always very clear.
My mother convinced me that the dead come back by coming to me at the
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Konami's new motion capture system puts you in the ring! Simulating a real pro fight, forcing players to bob and weave to avoid the opponent's punches while being able to throw their own. Bonus: Mocap Boxing displays the number of calories you burn during game play making this not just a fun arcade game but a full-body workout!
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Take time to watch Academy Award-winning director Davis Guggenheim's Waiting for Superman, voted best U.S. documentary at the prestigious Sundance Film Festival, and you'll be confronted with the sorry state of America's school system. How can America invent a more innovative and profitable future without a quality education system? In response, experts suggest that the dismissal of 1,000 of the country's worst teachers would allow our great teachers to build on what's been learned instead of being stuck teaching students what they should've already mastered.
But teacher unions resist any attempts to discipline and fire failing, sub-standard teachers. They also have squashed any attempt to pay for performance—rewarding at a higher level the best teachers and minimizing the pay of the less effective teachers. Instead of being part of the solution, they just keep campaigning for more money. With an exploding deficit at the national and state level, the funds aren't there.
As President Obama's team love to say, "A crisis is a terrible thing to waste." Maybe it's time "we the people" just blew our educational system wide open, and I don't mean improve the Department of Education. Improvements are for wimps. I mean abolish it. Deep six it. Eliminate, toss, obliterate it; give it the old heave-ho; force it to walk the plank. It is broken and it's wasting money our government doesn't have while limiting education of our young people.
Continuing studies by the Pacific Research Institute have found that there are proven options that cost less, produce better results and keep and reward the best teachers and schools. It's time we do more than read about what other countries are doing to become more American than America.
With California now facing a $25 billion plus deficit, it's time for truly transformational change. That's what happened in Sweden when political parties came together in times of fiscal crisis to institute a major transformation of Sweden's educational system. Sweden, that bastion of progressive policies, let parents once again control where their children received their education. They moved from a school-district-controlled system to a voucher system that fostered competition and rewarded excellence in education.
In summary, the Swedish model is built on two pillars of choice: a voucher system at both the primary and secondary levels and varied high school tracks that allow students to choose from a smorgasbord of programs centered on three paths: college preparatory, vocational and a more remedial track.
Bernie Sanders and Robert Reich Are Confused by Economics. And Government. And Reality | Seton Motley
Here we go: Jeb Bush's campaign weighing whether to have George W. hit the trail for him in South Carolina | Allahpundit


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Honda's new CEO provides us with an exclusive insight into his vision of the brand's future
We look at how Honda's cars have evolved by comparing six of its class leaders at launch with their modern equivalents
Honda's hybrid replacement for the S2000 roadster to feature a 1.5-litre turbo with a total power output of 300bhp and F1 tech
Honda announces fuel cell FCX Clarity successor will be shown at Tokyo Motor Show next month, and it's coming to the UK
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Messi is the favourite for the award after another remarkable year in which he is set to break Gurd Muller's record for goals in a calendar year.
Andres Iniesta inspired Spain to a Euro 2012 win, whilst Ronaldo drove Real Madrid to a La Liga title.
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Who of Europe's top strikers will move to England this summer?
After a dreadful start to their Bundesliga campaign, Borussia Dortmund appear to have weathered the storm after going five matches without defeat.


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I'm planning a 2-week driving/camping/biking/photog trip for the end of the summer. My co-pilots will be my two dogs and my destination is a 2-day Brad Goldpaint star photo workshop. Everything else is unplanned and open. What sights/bike rides/adventures would YOU want to hit up along the way between Phoenix and Bend? Dogs are not allowed in big National parks, so places like Yosemite and Crater Lake are off my list. Anyway, off the beaten path is usually my favorite. Any ideas?
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Here are some observations and notes after re-watching the Eagles' 28-13 loss to the Saints on Monday:
Why were the Eagles so bad in the red zone on Monday night when they failed to convert five trips inside the Saints' 20-yard line into more than just two field goals?
There are a numbers of reasons why: turnovers, penalties and bad execution stand out. But how about the play-calling? The Eagles ran 20 plays in the red zone but called for only three runs. Offensive coordinator Marty Mornhinweg may say, "Well, look at the end result of those runs. We lost a yard on three carries." But when Eagles running backs rushed 20 times for 167 yards outside the red zone, there needed to be more emphasis on feeding LeSean McCoy and Bryce Brown.


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Letter: Say Goodbye to The Euille Way
Letter to the Editor
Don't get hooked by Mayor Euille's write-in campaign for mayor.
Letter: Need Smart Development
Letter to the Editor
Jonathan Krall presents an interesting dilemma in his call for progressives to step forward and vote for city candidates who are working for Alexandria's success rather than stagnation (Gazette letters, Sept. 24-30, 2015).
Letter: Working Together?
Letter to the Editor
Your recent article in the Alexandria Gazette Packet, "City Council Hopefuls Debate Issues," contained the most revealing question of "Who [he or she] is most excited to serve on City Council with."
Letter: Council's Role In Enrollment?
Letter to the Editor
Board's failure to build enough school capacity several decades ago with the result that today's schools are overcrowded.
Letter: Two Are Too Old Town-centric
Letter to the Editor
In relation to Mr. Wood and Mr. van Fleet's position on the Waterfront Plan, two issues stand out in regards to their viewpoints.
Editorial: Changing Perspective on Death Penalty
Evolving standards will eclipse the death penalty entirely at some point in the future.
It's sad to see senseless death as a response to senseless death. Alfred R. Prieto is not a sympathetic figure, a serial killer who was on death row in California when DNA connected him to murders and rapes in Reston and Arlington that took place in 1988. He is scheduled for execution this week, at 9 p.m. on Thursday, Oct. 1.
Alexandria Appetite: Prost! Oktoberfest Brings Out the Best in Beer
For Port City Brewing Co., Oktoberfest is only beginning of busy season.
You can set your watch by it year after year, September after September.
Column: Revitalization Includes Small Neighborhood Parks
A mom pushing a stroller with a toddler skipping beside her is an image that stays with me following our day in the park.
Column: Join in Robust Walkathon
Calling all seniors to lace up your sneakers for the annual Fall Robust Walkathon.
Column: Volunteer as Literacy Tutor
32 Alexandria kindergarteners and first graders still in need of tutors.
In just a few short weeks in October, 93 eager Alexandria City Public School kindergarten and first grade students will meet their one-on-one literacy tutor for the year.
Letter: Do Not Erase History
Letter to the Editor
I wrote a letter to the editor in July advocating the removal of Appomattox, the bronze statue of a Confederate soldier, from its position of prominence at South Washington and Prince Streets to a spot that does not imply city or Commonwealth sympathy to the Confederate cause.
Letter: Address Disrespect
Letter to the Editor
City Council did not crown itself with glory at its Sept. 12 meeting.
Letter: Time for a Change
Letter to the Editor
I would like to offer my comments regarding Mayor Euille's decision to run a write-in candidacy for Mayor.
Letter: Maintain Progress
Letter to the Editor
There is a great quote from the West Wing TV show that goes, "If they're shooting at you, you must be doing something right."
Letter: Success, Not Stagnation
Letter to the Editor
I am writing to voice my concerns for The Alexandria Democratic Committee.


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Where the Arts are for Everyone!
Our Mission
To provide quality artistic opportunities to the Sauk Valley Community.
Our Vision
To be the recognized leader in art opportunities by becoming entwined in the fabric of the community through helping people develop, promote, and share their artistic talents.
Our Values
- Allow our customers to define quality in our services and programs
- Remain a self-sustaining, financially sound entity
- The premier resource for artistic opportunities
- Speak of the arts and think Woodlawn
What We Offer
Woodlawn Arts Academy is the premiere arts academy in the Sauk Valley area. We offer daytime and evening instruction to all ages in all disciplines of the arts, including Visual Arts, Music, Dance, Theatre, Domestic Arts, Culinary Arts, Healing Arts and Literary Arts. The Academy is proud to be supported as an agency of the United Way of Whiteside County.Is there another art that interests you? Contact our Program Coordinator and put in your request. We will do our best to accommodate you!
Artist CollectiveAre you an artist, musician, dancer, actor, chef or any other kind of artist looking for work and/or networking? Be a part of the Academy's new Artist Collective! Click the logo below for details.
Contact Us
Woodlawn Arts Academy
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Only 2 Tickets Left For "Lion King" Trip
Only two tickets remain for the December 19th "Lion King" bus trip to Chicago. Call (815) 626-4278 or visit the Academy during regular business hours to grab the last two seats!
Book Club
Woodlawn Arts Academy's Book Club returns on September 23rd with the romantic novel "Me Before You" by Jojo Moyes. The Book Club is for ages 18 and up and meets one Wednesday a month (generally the fourth Wednesday) at Woodlawn Arts Academy from noon to 1pm. Books are provided via library loan when possible. Participants can pick up a copy of the current book in the Academy main office. Tuition is $5 for those attending the Book Club meeting and can be paid in advance or the day of the gathering. The October 28th Book Club will discuss "Crossing to Safety," a semi-autobiographical novel by Wallace Stegner. For questions, call the Academy at (815) 626-4278.
Financial Assistance
How To Apply
Woodlawn Arts Academy is committed to serving all members of the community. Financial assistance is available for those who qualify. Applying is simple! Fill out an application and return it, along with the required paperwork, to the Academy office. Be sure to apply early to ensure funding is in place before the start of the session. You'll never know if you qualify if you don't apply! Financial assistance is offered thanks to United Way and other generous sponsors through contributions to Woodlawn Arts Academy.


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Illinois Public Media
All articles tagged Superman
How Superman Saved A Small Illinois Town
Superman: America's Most Enduring Superhero
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WILL Highlights
Vintage Vinyl is coming!
The Vintage Vinyl Sale to benefit Illinois Radio Reader returns on October 3. Click for the latest info.
WILL News wins PRNDI Award for "Unmet Needs" Radio Doc
The 2014 radio documentary, produced by former WILL staff and hosted by Scott Cameron, won second place in the Long Form Documentary category among medium-sized stations.
WILL Ag Director Dave Dickey retires
He carried on the farm broadcasting tradition, while innovating on the Internet.


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Bobby Brown and Alicia Etheredge Welcome Baby Girl
Some beautiful news has entered into Bobby Brown and wife Alicia Etheredge's life. The couple welcomed a baby girl on Saturday (July 11).
Some beautiful news has entered into Bobby Brown and wife Alicia Etheredge's life. The couple welcomed a baby girl on Saturday (July 11).
While some superstars are able to overcome addiction and clean up their acts quietly and swiftly, it takes others years of struggling with drug or alcohol abuse and "rock bottom" career-threatening moments including arrests, near-death experiences or worse to admit that help is needed. Check out 20 Rappers & Singers Who Suffered From Addiction.
There has been relatively no new updates regarding the current health of Bobbi Kristina Brown, who remains on life support. However, her father, Bobby Brown, may have revealed that his daughter is on the mend.
Bobby Brown step away from his daughter Bobbi Kristina Brown's bedside to make his first public appearance since her hospitalization. The veteran R&B crooner performed a scheduled gig at the Soul Food Festival in Los Angeles on Saturday (April 11).
From R. Kelly's shocking child pornography scandal to Chris Brown's darkest domestic violence moments and more, we go inside 10 Most Shocking Arrests in R&B.
Bobby Brown's wife is pregnant, but while there's good news there, the bad comes after his family members got into a fight at an Atlanta hotel while Bobbi Kristina Brown is fighting for her life.
After turning himself in to Los Angeles police, Bobby Brown has served a whopping 9 hours in jail.
The New Edition singer surrendered to authorities yesterday after pleading no contest to his third D...
LOS ANGELES (AP) - A lawyer for Bobby Brown has entered not guilty pleas to drunken driving and other charges faced by the R&B singer after his arrest last month in Los Angeles.
Bobby Brown, the notoriously troubled ex-husband of the late Whitney Houston, has been arrested on charges of a DUI for the second time this year...
After much speculation about her controversial relationship with "adopted brother"-turned-boyfriend Nick Gordon, Bobbi Kristina Brown has confirmed rumors of their engagement...


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Bay of Islands Tall Ship Sailing on 'R. Tucker Thompson' Including BBQ Lunch
Reviewed by: Vicki L, June 2015
Fantastic, the scenery, the meal and the staff were brilliant. Just a shame that it was so still on the day so we didn't travel far.
Reviewed by: Christine A T, May 2015
Absolutely fantastic. Beautiful boat, lovely crew and a stunning location. What more could you want?
Reviewed by: Ronald M, April 2015
I would highly recommend this trip for anyone! I booked this trip for a group of my friends and we all enjoyed our day! The crew, food, the hands on experience sailing and the views were so memorable!
Reviewed by: Kirk E, March 2015
Beautiful day. Wonderful trip.
Reviewed by: Carolyn P, March 2015
This was a great trip. Crew were very friendly, hospitable and fun. Even though there was no wind on the ride out, we had a great time. I highly recommend this trip to anyone in the area.
Reviewed by: eve_simpson, March 2015
Fabulous, brilliant crew.
Reviewed by: ian b, March 2015
Excellent day experience not to be missed. Very friendly staff


text: Canolfan Mileniwm Cymru Print by Andy Tuohy Design £195$422.56€288.58$320.81 In stock £33.00$71.51€48.83$54.29 delivery to United States Receive this item 5-10 working days from dispatch International delivery available quantity by Andy Tuohy Design Location: Kent, GB read seller's profile see seller's complete range more items from this seller Ashmolean Museum Oxfordshire Print £195$422.56€288.58$320.81 Pulteney Bridge Bath Print £195$422.56€288.58$320.81 Tate St.Ives Cornwall Print £195$422.56€288.58$320.81 Bristol Zoo Print £195$422.56€288.58$320.81 Paddington Station London Print £195$422.56€288.58$320.81 Seaside Alphabet And Counting Poster £25$54.17€36.99$41.13 view all you may also like PRODUCT DETAILS DELIVERY RETURNS Made in Britain ask seller a question save for later *UNFRAMED*, limited edition print of the Wales Millennium Centre, Cardiff, by acclaimed artist and designer Andy Tuohy. This image was initially produced as part of a set of locations to celebrate twelve stops on the Great Western Railway route and hung in the First Class passenger lounge of Paddington Station. The print is signed by the artist, embossed and numbered as part of a strictly limited edition of 100. made from: Giclée printed onto heavy weight Hahnemühle fine art paper. This is the finest paper available for giclée printing in terms of archival qualities, print fidelity and is guaranteed for at least 70 years longevity. dimensions: Sized H50 x W70cm (19 ¾ x 27 ½") product code: 287928 This product is dispatched to you by Andy Tuohy Design. MAINLAND UK order now and receive this item on or before price Free Delivery Monday 12 October FREEFREEFREEFREE NON-MAINLAND UK estimated delivery price Highlands & Islands of Scotland 2-5 working daysfrom dispatch £4.75$10.29€7.02$7.81 Northern Ireland 2-5 working daysfrom dispatch £4.75$10.29€7.02$7.81 Other UK Islands 2-5 working daysfrom dispatch £4.95$10.72€7.32$8.14 INTERNATIONAL DELIVERY estimated delivery price Western Europe 2-5 working daysfrom dispatch £20.00$43.34€29.59$32.90 Rest of Europe 5-10 working daysfrom dispatch £20.00$43.34€29.59$32.90 USA & Canada 5-10 working daysfrom dispatch £33.00$71.51€48.83$54.29 Asia & Australasia 5-10 working daysfrom dispatch £38.00$82.34€56.23$62.51 Rest of the world 5-14 working daysfrom dispatch £38.00$82.34€56.23$62.51 You have 28 days, from receipt of cancellable goods, to notify the seller if you wish to cancel your order or exchange an item. Please note: goods that are personalised, bespoke or made-to-order to your specific requirements, perishable products and personal items sold with a hygiene seal (cosmetics, underwear) in instances where the seal is broken are non-refundable, unless faulty. Read more about our returns policy.Should you choose to return or exchange your order you will need to deliver the item(s) to the UK, where this seller is based. Andy Tuohy Design's return policy


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Nicole and Scott had the perfect end-0f-spring day for their wedding at the Minnesota Landscape Arboretum in Chaska, MN. Everyone there was involved in this intimate ceremony, sharing lots of smiles and happy tears as they all celebrated Nicole and Scott's life together. These two are absolutely the best of friends who enjoy every second they spend together, and it was definitely reflected in their wedding!
They went with a simple, classy color palate of yellow, grey, and white, which worked perfectly with all of the beauty that the Arboretum had to offer them. They decided not to have a first look before the ceremony, preferring to save that first look for when Nicole walked down the aisle, but we took lots of time after their vows to explore the grounds and take some photos of the two of them together. I don't think Scott took his eyes off of his new bride the whole time!
Isn't their cake topper adorable? Nicole and Scott have two four-legged babies that they absolutely adore and wanted to involve in the ceremony, even if they couldn't come to the Arboretum with them. In addition to dancing the night away, Scott's father made an incredibly touching speech, and Scott's sister and her husband serenaded the crowd with a song. Everyone danced the night away and went home with a beautiful handcrafted candle.
Congratulations, Nicole and Scott! I am so happy to have been included in your special day, and I wish you many years of happiness together!
Vendor Information:
Photo assistant – Gianna
Getting Ready, Groom & Groomsmen – Oak Ridge Hotel and Conference Center
Wedding Venue – Minnesota Landscape Arboretum
Ceremony Site Coordinator – Carissa Pfarr
Reception Site & Catering Manager – Kristyn Wade
Florist – Festivities
Ceremony Music: Cheryl Zylla, A Beautiful Violin
Reception DJ: PM Enterprises
Dress Shop & Designer: Melissa Sweet for David's Bridal
Rings: Zales
Cake: Buttercream Cakes & Desserts


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Nedra Kathy Aeschbacher
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Mar. 12, 1949, USA
Oct. 18, 2006, USA
N. Kathy Aeschbacher (Mrs.Winchel, Richey, and Blakely), 57, of Boise, went to be with her Lord on Wednesday Oct. 18, 2006. Funeral services will be conducted at 2 p.m. Wednesday Oct. 25, 2006 Cloverdale Funeral Chapel, 1200 N. Cloverdale Rd.. Boise, Id. Burial will follow at Dry Creek cemetery in Boise. Friends may call at Cloverdale Funeral Home on Tuesday Oct. 24, 2006 from 4 to 7 p.m. for a time of viewing. She was born Nedra Katherine Aeschbacher on March 12, 1949 in Blackfoot, Idaho to E.C. (Dean) Aeschbacher and Bessie Christina Aeschbacher (Grindstaff). She was raised in Aberdeen, Idaho. At the age of six her family moved to Boise. She attended Longfellow Grade School, North Junior High and graduated from Boise High School in 1967. She was a teacher in the Boise School District for many years. She left a living legacy with her students at Taft Elementary who knew her as Mrs. Richey. She enjoyed teaching and loved each of her students as if they were her own. She leaves behind her partner in life Fred Blakely; her son Robert Winchel of Lansing, Ill.; her Mother Bessie Christina Aeschbacher of Boise; brother Harvey (Diane) Aeschbacher and their children Angelia and Brett (Rani); grandchildren Blake and Abbi Aeschbacher; sister Liza Dix-Warner and her children Mike Dix and Claudia Christine Cooper and Liza´s grandchildren Mollie, Lizzie, Cody, MacKenzie, Kaylee, and Casey. She was proceeded in death by her daughter Debbie Lynn Winchel; father E.C. Aeschbacher; brothers William and Charles Aeschbacher; grandparents: John and Liza Grindstaff and both Aeschbacher grandparents. She belonged to the Boise State University Alumni Assoc.; Idaho Gourd Society. Services are under the direction of Cloverdale Funeral Home.
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LOS ANGELES (MarketWatch) -- Japanese stocks rallied in early Monday trading, catching up to gains Friday in Asia, when Tokyo was on holiday, as well as a strong Wall Street performance at the end of last week. Exporters also got a boost as the euro broke above the 107-yen level early in the day, marking a seven-month high. The Nikkei Stock Average NIK, +0.02% gained 1.1% to 9,474.04, with the Topix up 1.2%. Names with strong euro exposure on the climb included Canon Inc. 7751, +0.37% CAJ, +1.44% up 2.1%; Mazda Motor Corp. 7261, +0.13% MZDAF, +2.34% rising 2.3%; and Pioneer Corp. 6773, -0.75% PNCOF, +1.72% ahead by 4.1%. A report Monday in the Nikkei business daily said the three top shareholders in struggling chip maker Renesas Electronics Corp. 6723, -0.16% RNECY, -17.34% were set to buy the firm out, sending Renesas shares surging 4.8%. Hitachi Ltd. 6501, -0.91% HTHIF, -0.19% and NEC Corp. 6701, +0.53% NIPNF, -4.92% both among the reported buyers of Renesas, saw their stock advance 1.1% and 2.8%, respectively. Car makers were also a strong spot in early Tokyo trade, with Toyota Motor Corp. 7203, +1.48% TM, +2.02% leaping 3.4%, Honda Motor Co. 7267, +1.00% HMC, +1.70% up 2.2%, and Nissan Motor Co. 7201, +1.52% NSANY, +1.68% ahead by 2.8%.
Read the full story: Asia stocks tick higher, but Japan soars


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Capital Markets
Company Overview of River Cities Capital Funds
BOARD MEMBERS AFFILIATED WITH Edward C. McCarthy *
Managing Director
*Data is at least as current as the most recent Definitive Proxy.
MOST CONNECTED PEOPLE TO Edward C. McCarthy
|Michael J. Wasserman
|107 Relationships
|Michael Cristinziano
|82 Relationships
|Jonathan I. Kislak
|73 Relationships
|Wayne L. Hunter
|72 Relationships
|Mark T. Koulogeorge
|68 Relationships
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DescriptionInstructions for Form 941 Department of the Treasury Internal Revenue Service Rev. January 2011 Employer s QUARTERLY Federal Tax Return Section references are to the Internal Revenue Code unless otherwise noted. What s New Social security and Medicare tax for 2011. The following amounts are reconciled. Medicare wages and tips. The IRS has issued regulations under section 6302 which provide that beginning January...
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Am betting Toby Miles is on Ashley Madison.
Just call it a hunch.
Am betting Toby Miles is on Ashley Madison.
Just call it a hunch.
Two different scandals are rocking the planet at exactly the same time. I've not seen it printed anywhere else, so I'm going to put it out there.
Right about the time Hillary told us all of the important stuff on her private server stored somewhere in her house was "wiped clean", the Ashley Madison dating site was hacked, exposing a whole lot of information Ashley Madison claimed had been wiped clean.
Coincidence? I doubt it.
Ashley Madison IS Hillary Clinton.
Now that it's on the internet, it's real.
Hey Hollywood, we could use a lot more of this:
There have been, via well-undocumented sources, at least nine cases of fainting people during Obama speeches.
Consider yourself warned.
Saw this, loved it, stole it:
Definitely my favorite Tom Petty video, and possibly song:
Honestly, I never enjoyed the stoner Tom. That stuff is remarkably boring musically. The edgier Tom was musically a LOT more fun.


text:
The Hockey Hall of Fame will induct just its sixth Russian-born player later this year as its saved the best for last with the nomination of Sergei Fedorov. In his first year of eligibility, the one-time Russian superstar will be immortalized among the likes of Gretzky, Howe, Kharlamov and Fetisov.
Read more…
Sergei Fedorov Elected to The Hockey Hall of Fame
The Hockey Hall of Fame will induct just its sixth Russian-born player later this year as its saved the best for last with the nomination of Sergei Fedorov. In his first year of eligibility, the one-time Russian superstar will be immortalized among the likes of Gretzky, Howe, Kharlamov and Fetisov.
Trying to Rank the Top 5 Russians to Win the Stanley Cup
With the Stanley Cup Finals underway and a potential for four new Russians to be immortalized, we here at FRWG decided to take a look back to see how the comrades of yesteryear ranked amongst one another. Criteria included a minimum of 500 NHL games, at least one cup, stats of the non fancy variety, and a whole lot of eternal struggle.
Note this list is not set in stone and a will likely look very different following the conclusion of the careers of today's Russian stars.
Here we go!
Read more…
Soviet Coaching Legend, Viktor Tikhonov, Passes away at 84
(image courtesy of-Sony-Pictures-Classics)
Late last night, the family of Viktor Vasilyevich Tikhonov announced the 84-year-old coaching legend had passed away. One of hockey's greatest minds was said to be bedridden for weeks with an undisclosed illness.
Read more…
Alexei Kovalev Becomes 3rd Russian to Score 1,000 Points in NHL
(Photo courtesy of Phillip MacCallum/Getty Images)
First it was Sergei Fedorov, a month later it was Alexander Mogilny, and tonight, well over six years since a Russian-born player reached the 1,000 career point plateau, Ottawa's Alexei Kovalev joins an elite club. Kovalev scored a power-play goal midway through the first period(at exactly 10:00) to give the Senators the early lead. With the goal, assisted by fellow countryman Sergei Gonchar, Kovalev became the 76th NHL player to have his career points go into quadruple digits.
Kovalev fired a slap shot past Jonathon Quick after Gonchar's shot bounced off a LA Kings defender for his sixth goal of the year. The shot was powerful enough to break his stick. Kovalev would add an assist on the game winning goal by Jason Spezza to earn the first star of the game. He becomes the second Senators player to eclipse 1,000 points with captain Daniel Alfredsson doing so exactly a month ago.
Read more…
Comrades of the Night-Alex Kovalev and Sergei Gonchar
For the first time in our short history we have two comrades of the night as two of Russia's most seasoned NHL vets had a memorable night up in Ottawa. Prior to face-off, the Senators honored Sergei Gonchar on his 1,000th game in the NHL by presenting him with a plaque, a silver stick, and a portrait. A video was also shown of his career and the various teams he played for including Washington, Boston, and Pittsburgh respectively.
Gonchar becomes just the fifth Russian (and third Sergei) in league history to surpass the plateau joining the likes of Sergei Fedorov, Alexei Zhitnik, Slava Kozlov, Sergei Zubov, and teammate Alex Kovalev. Kovalev will soon surpass Fedorov for most all-time games for a Russian-born NHLer needing just 11 more games. After being criticized in the early going of the season by GM Bryan Murray, Kovalev scored two goals and added an assist en-route to a 5-2 Ottawa win.
Read more…
Slava Kozlov Joins KHL's CSKA Moscow
(Courtesy of Andre Ringuette/NHLI via Getty Images)
It appears Slava Kozlov's storied NHL career has come to an end as the 38-year-old winger has signed a one-year deal with his former Russian club CSKA Moscow of the KHL. Kozlov's now former club the Atlanta Thrashers opted not to resign the veteran who had spent the last seven years with the team where he scored 145 of his 356 career goals.
Read more…
Russia Falls to Czechs in Gold Medal Game;Top IIHF World Ranking
(Courtesy of Jukka Rautio/HHOF-IIHF Images)
After winning every game in this years Men's World Championships, Team Russia could not overcome a lucky yet scrappy Czech Republic team to capture their third consecutive gold medal. Instead the Russians leave Germany with a feeling of disarray and disappointment just like in the 2010 Olympics when they were favored to win it all but were bounced in the quarter-finals.
Read more…
Russia Eliminate Canada Enroute to Semi-Finals
(Courtesy of Jukka Rautio/HHOF-IIHF Images)
On Thursday, Russia got slight revenge on their Canadian rivals for the first time since the 2010 Vancouver Olympics by ending their chance for any medals with a 5-2 win at the Men's World Championships. Goals from Maxim Afinogenov, Evgeni Malkin, Sergei Fedorv and Pavel Datsyuk would power Russia to their third consecutive semi-final game where they will meet hosts Germany on Saturday.
Read more…
Russia Blanks Fins to Set Up Date with Canada
(Courtesy of Jukka Rautio/HHOF-IIHF Images)
Russia earned their 24th consecutive victory against the team that was last to beat them on the World's stage on Tuesday by shutting out Finland 5-0. With the win the team earns the right to play Canada in the quarter-finals on Thursday in a rematch of the 2010 Olympics and the last two gold medal games at the World's.
Read more…
Russia Announces Roster for World Championships
Head Coach Vyacheslav Bykov has announced the 25-man roster that will defend Russia's crown in Germany starting this Sunday against Slovakia. Unlike the team that traveled to Vancouver before that embarrasing exit at the hands of the hosts this roster features more KHL'ers than NHL'ers 13 to 12. Both Alexander Ovechkin and Semin return to the Worlds' stage having been absent last year since the Washington Capitals were deep in the playoffs.
Also returning is reigning MVP Ilya Kovalchuk who played on both gold medal teams while being on the Atlanta Thrashers who failed to make the playoffs both years. This time Kovalchuk is a New Jersey Devil until free agency starts and would probably prefer to be playing in the NHL this time of year opposed to with the National team. New faces from the NHL include Artem Aninvsov of the New York Rangers who has only played with the team's junior squad and Dmitry Kulikov of the Florida Panthers who like Aninvsov has never gotten the call for top team.
Both Sergei Fedorov and Viktor Kozlov of the KHL will be reunited with their former Capitals teammates just like in Vancouver and hope to spark some sort of chemistry if Bykov decides to play them together at any time. It will be interesting to see if the mix between the KHL'ers and NHL'ers will be a factor as many claimed it was the reason Russia collapsed against Canada at the Olympics but hopefully this mix plus the bigger ice surface will be the key to the team's success as they go for the three-peat.
Below is the roster that is headed to Germany. According to the rules, two more names can be added to the list for the second round of the tournament
Alexander Eremenko (Salavat Yulaev Ufa)
Vasily Koshechkin (Metallurg Magnitogorsk)
Semyon Varlamov (Washington Capitals)
Konstantin Korneev (CSKA Moscow)
Vitaly Atyushov (Metallurg Magnitogorsk)
Dmitriy Kalinin (Salavat Yulaev Ufa)
Ilya Nikulin (Ak Bars Kazan)
Alexei Emelin (Ak Bars Kazan)
Denis Grebeshkov (Nashville Predators)
Dmitry Kulikov (Florida Panthers)
Maxim Afinogenov (Atlanta Thrashers)
Evgeny Artyukhin (Atlanta Thrashers)
Alexander Ovechkin (Washington Capitals)
Alexander Semin (Washington Capitals)
Alexei Tereschenko (Ak Bars Kazan)
Artem Anisimov (New York Rangers)
Ilya Kovalchuk (New Jersey Devils)
Nikolai Kulemin (Toronto Maple Leafs)
Maxim Sushinsky (SKA St. Petersburg)
Sergei Mozyakin (Atlant Mytischi)
Sergei Fedorov (Metallurg Magnitogorsk)
Viktor Kozlov (Salavat Yulaev Ufa)
Alexander Frolov (Los Angeles Kings)
Alexander Svitov (Avangard Omsk)


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Since most of us will be suffering through scorching temperatures, it's absolutely essential to have a cold, refreshing treat for dessert. Ice cream, and most baked goods will be off limits for your vegan guests, so why not whip up this quick strawberry sorbet instead? It's seasonal, creamy, and best of all, won't require you to turn on the oven!
Do have a favorite vegan recipe that's perfect for summer? Share it in a comment!
Related Reading:
5 Quick And Healthy Cinco De Mayo Recipes
New Children's Book Says Vegan Is Love
Read more: 4th of july, healthy eating, meatless monday, recipes, vegan cuisine, vegan diet
Image via Thinkstock
Made up the mixture but I didn't have time for the shape patties and chill in the frig step so I cooked some in a dish in the oven, with breadcrumbs on top. (I added a sprinkling of grated cheese). There was some left, so I used it to stuff halved peppers next day. Yes. It was very good.
Delicious recipes, will definitely try them!
Thanks for the great recipes!
Steve R. - Whether you are liberal or conservative, American or Brit, celebrate holidays or not, animals experience fear, pain and suffering. We can make choices to avoid inflicting some of that suffering.
Jamie C. - I had steak once when I was a kid, and I agree - it was delicious. Then I found out how the steak became a steak. Gross. Unethical.
These recipes sound so good!
Will try them.
Thank You!
Many distinguished figures stood for animal rights:
Albert Einstein, Leonardo da Vinci, Leo Tolstoy, Mohandas Gandhi, Alice Walker, George Bernard Shaw, Robert Browning, Percy Shelley, Voltaire, Thomas Hardy, Rachel Carson, Harriet Beecher Stowe, Victor Hugo, John Stuart Mill, Jean-Jacques Rousseau, Pythagoras, Susan B. Anthony, Albert Schweitzer, Isaac Bashevis Singer, Gertrude Stein, Frederick Douglass, Francis Bacon, William Wordsworth, the Buddha, Mark Twain, and Henry David Thoreau.
Rynn Berry's Famous Vegetarians and Their Favorite Recipes, includes:
Pythagoras; Gautama the Buddha; Mahavira; Plato (and Socrates); Plutarch; Leonardo Da Vinci; Percy Shelley; Count Leo Tolstoy; Annie Besant; Mohandas Gandhi; George Bernard Shaw; Bronson Alcott; Adventist physician Dr. John Harvey Kellogg; Henry Salt; Frances Moore Lappe; Isaac Bashevis Singer; Malcolm Muggeridge, and Brigid Brophy.
Celebrity vegetarians include:
Orlando Bloom, Liv Tyler, Brad Pitt, Richard Gere, Jude Law, Josh Hartnett, Gwyneth Paltrow, Steve Martin, Alec Baldwin, Drew Barrymore, Ryan Gosling, Kim Basinger, Dustin Hoffman, Dr. Dre, the B52s, Paul McCartney, Chrissie Hynde, Joaquin Phoenix, Andre3000, Meatloaf, Peter Gabriel, kd lang, Elvis Costello and Melissa Etheridge.
peta2 is now the largest youth movement of any social change organization in the world. peta2 has 267,000 friends on MySpace and 91,000 Facebook fans.
Well - I would have tried a "vegan fourth of July" - but I celebrate "Independence Day" - not the "fourth of July".
I also celebrate "Christmas Day" - not the "25th of December", and "New Years Day" - not the "first of January".
What's the problem with calling it what it is? "Independence Day" - the day we rid ourselves of oppressive British rule?
I guess it's too patriotic for the liberal left..... too "American".....
Very useful post!!
Those black bean veggie burgers look awesome. What could be better (and healthier) than quinoa and black beans as the basis for your burger? Yum!
Disclaimer: The views expressed above are solely those of the author and may
not reflect those of
Care2, Inc., its employees or advertisers.
I SINCERELY hope people there are contributing to food costs, etc. He's inspirational.
Excellent article. Thank you very much for sharing.
any industrialised farming is a pain in the a... I TOOK ACTION ON JUNE 05, 2015
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This article describes how you can secure your WordPress Default Upload directory to protect your files especially Premium Themes and plugins.
How to Install WordPress Locally on your Computer
WordPress is definitely is the best CMS for blogging as it is Famous for " 5-Minute Install "and easy to use. As a webmaster or Blogger you need to test new themes and plugin regularly, but it may go wrong something and your site will be down. So to avoid it , you can test your themes and plugin Locally in your pc.
To install WordPress,it has following requirements (Version 3.2)


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With No Rings Till The End Of The Year Star Wars saga has new secrets Drew Goddart opened 3 mysteries about Martian MORE ›
Lyrics/song texts are property and copyright of their owners and provided for educational purposes only.
Big sky Lyrics by Abra Moore
Big sky by Abra Moore
Tired of the freaks and the colored lights.
Come on Come on the night is young.
It's too late to change your mind, you can't turn back now.
So high, so high just you and me and the big sky.
Close the door and shut off the lights
6 o'clock we'll be taking flight.
Hold on Hold on and then relax.
Tell everyone were gone and we won't come back.
So high just you and me and the big sky
That's all we are, that's all we are, It's all forever
So your tired of this crazy crazy life
And no one can save you
How long how long can this go on
You only get one chance and then your gone.
It's all right, it's all right
That's all we are, that's all we are, It's all forever.Abra Moore Lyrics Index