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Thursday, August 9, 2018
New York City Halts New Uber Licenses and Creates Minimum Pay
NYC's City Council just passed legislation to stop issuing new ride-hailing licenses for one year. The legislation also requires Uber and similar companies to ensure that drivers earn at least $17.22 per hour (calculated over a week)--like the FLSA tip rule, if drivers don't make that much, the companies must pay the drivers the difference. This can be significant especially in a city like NYC, where almost 85% of drivers make below $17.22/hour and two-thirds of drivers work full-time for ride-hailing companies.
I find the minimum pay provision to be interesting because it puts in motion something I've been thinking about for a while. One of the difficulties in the current "employee"/"not-employee" dichotomy is how much rides on that distinction (pun intended). It's always struck me that this definitional question misses the point. We're stuck with this outmoded definitional hang-up because of current law, but the real question we should be asking is what type of protections do we want for which type of workers. There will always be difficult line drawing, but I think there are areas of agreement. For instance, we've got a long-standing policy of ensuring a minimum pay for the vast majority of "employees." Are there many workers--even those currently classified as independent contractors--who shouldn't also receive at least $7.25/hour? I don't think so. Same for workplace safety and other protections. The devil's in the details, to be sure, but NYC's new legislation represents one step in the direction of ensuring worker rights, rather than just employee rights. And it's a move I'm glad to see.
Finally, a brief plug for a recent article I co-authored with Joe Seiner exploring non-traditional collective action in ride sharing and other modern industries. There's a lot of interesting things going on, but also a lot of legal questions prompted by new activity fitting into old laws.
-Jeff Hirsch
August 9, 2018 in Labor and Employment News, Wage & Hour, Worklife Issues, Workplace Trends | Permalink | Comments (0)
Tuesday, May 1, 2018
California Knows Its ABCs
Yesterday, the California Supreme Court issued what is likely to be a bombshell decision in Dynamex Operations v. Lee. Dynamex involved a wage claims brought by a driver under California law. The employer defended with the oft-used (and often successful) argument that the driver and his similar colleagues were independent contractors, not employees. You can check out the decision for the facts, but they will be very familiar to those who spend any time looking at this area. What is more important is how the court analyzed them.
In Dynamex, the court decided to change its standard for determining whether a worker is an employee or independent contractor under the part of the state wage statute that defines "employ" as "to suffer or permit work" (there are two other definitions of "employ"). In particular, it adopted what is referred to as the "ABC test." Under this rule, a worker is presumed to be an employee unless the purported employer can establish three factors. Because of its importance, I'm going to quote the court's formulation, while editing the layout for easier reading:
This [ABC] standard, whose objective is to create a simpler, clearer test for determining whether the worker is an employee or an independent contractor, presumes a worker hired by an entity is an employee and places the burden on the hirer to establish that the worker is an independent contractor. Under the ABC standard, the worker is an employee unless the hiring entity establishes each of three designated factors:
(a) that the worker is free from control and direction over performance of the work, both under the contract and in fact;
(b) that the work provided is outside the usual course of the business for which the work is performed; and
(c) that the worker is customarily engaged in an independently established trade, occupation or business (hence the ABC standard).
If the hirer fails to show that the worker satisfies each of the three criteria, the worker is principal federal wage and hour legislation.
Although it remains to be seen how soon and how big an effect this decision will have, I'm not going out on a limb by predicting that this represents a major change. The ABC test is clearly broader than the FLSA's "economic realities" test, so at a minimum more California workers will enjoy protection under the relevant statute. But California's size and the fact that this is likely to impact gig work could lead to a shift in how some companies classify and pay their gig workers in other states. Time will tell . . . .
-Jeff Hirsch
May 1, 2018 in Labor and Employment News, Wage & Hour | Permalink | Comments (0)
Tuesday, April 3, 2018
On No Longer Reading FLSA Exemptions Narrowly
Yesterday, the US Supreme Court decided Encino Motorcars v. Navarro in a way that rejected past precedent requiring courts to read FLSA's statutory exemptions narrowly. In a 5-4 ruling, the Court ruled that FLSA exempts a service adviser at a car dealership from its overtime protections under the exemption for "any salesman . . . primarily engaged in . . . servicing automobiles." 29 U.S.C. § 213(b)(10)(A).
In doing so, however, Justice Thomas, writing for the majority, rejected the general "principle that exemptions to the FLSA should be construed narrowly." Encino, Slip Op. at 9. Here's his reasoning:
We reject this principle as a useful guidepost for interpreting the FLSA. Because the FLSA gives no "textual indication" that its exemptions should be construed narrowly, "there is no reason to give [them] anything other than a fair (rather than a 'narrow') interpretation." Scalia, Reading Law, at 363. The narrow construction principle relies on the flawed premise that the FLSA "'pursues'" its remedial purpose "'at all costs.'" American Express Co. v. Italian Colors Restaurant, 570 U. S. 228, 234 (2013) (quoting Rodriguez v. United States, 480 U. S. 522, 525-526 (1987) (per curiam)); see also Henson v. Santander Consumer USA Inc., 582 U. S. ___, ___ (2017) (slip op., at 9) ("[I]t is quite mistaken to assume . . . that whatever might appear to further the statute's primary objective must be the law" (internal quotation marks and alterations omitted)). But the FLSA has over two dozen exemptions in § 213(b) alone, including the one at issue here. Those exemptions are as much a part of the FLSA's purpose as the overtime-pay requirement. See id., at ___ (slip op., at 9) ("Legislation is, after all, the art of compromise, the limitations expressed in statutory terms often the price of passage"). We thus have no license to give the exemption anything but a fair reading.
In so reasoning, Justice Thomas's majority opinion didn't "acknowledg[e] that it unsettles more than half a century of our precedent." Dissent of Justice Ginsburg, Slip. Op. at 9-10 n.7. See A.H. Phillips, Inc. v. Walling, 324 U.S. 490, 493 (1945) (FLSA "was designed 'to extend the frontiers of social progress' by 'insuring to all our able-bodied working men and women a fair day's pay for a fair day's work.' Message of the President to Congress, May 24, 1934. Any exemption from such humanitarian and remedial legislation must therefore be narrowly construed, giving due regard to the plain meaning of statutory language and the intent of Congress. To extend an exemption to other than those plainly and unmistakably within its terms and spirit is to abuse the interpretative process and to frustrate the announced will of the people."); accord Citicorp Industrial Credit Co. v. Brock, 483 U.S. 27, 35 (1987); Mitchell v. Kentucky Finance Co., 359 U.S. 290, 295 (1959)("It is well settled that exemptions from the Fair Labor Standards Act are to be narrowly construed.")(citations omitted). In her dissent, Justice Ginsburg called this FLSA precedent a "well-grounded application of the general rule that an 'exception to a general statement of policy is usually read . . . narrowly in order to preserve the primary operation of the provision.'" Dissent Slip. Op. at 9 n.7 (quoting Maracich v. Spears, 570 U.S. 48, 60 (2013)).
Management-side lawyers will likely now invoke Encino often in FLSA exemption litigation. But, it's hard to know how much this will affect FLSA case outcomes, because it's unclear how much the "narrowly-read FLSA exemptions" rule had affected FLSA case outcomes in any event, that is, how often that rule operated as makeweight versus a genuine tie-breaker.
More puzzling: The Court could have easily sidestepped the issue by saying that, given the strength of all the other reasons to read § 213(b)(10)(A) the way it did, there was, in this case, really no tie for the "narrowly-read FLSA exemptions" rule to break. Instead, the Court's majority seems to have wanted to overrule this prior FLSA precedent but without expressly saying that it was directly overruling it as precedent. The mystery is which Justice(s) in the Encino majority (Thomas, Roberts, Kennedy, Alito, Gorsuch) wanted this in the opinion, and why.
April 3, 2018 in Labor and Employment News, Wage & Hour | Permalink | Comments (0)
Tuesday, March 20, 2018
$13.9 milliion USDOL settlement for Chinese casino workers in Saipan
Following up on previous posts here and here describing safety and wage violations against Chinese workers building a casino in U.S.-Saipan, Aaron Halegua has this update:
On March 5, 2018, the U.S. Department of Labor announced that settlements totaling $13.9 million and covering over 2,400 workers with four Chinese contractors building the Imperial Pacific casino in Saipan. Many of these workers paid $6,000 or more to labor brokers in China, incurring significant debts with high interest rates, based on false promises of high-paying jobs in the United States. Instead, upon arriving in Saipan, the workers were stripped of their passports, forced to work long hours under dangerous conditions, and paid below minimum wage. OSHA also imposed significant fines against these contractors and the Department of Justice prosecuted several managers of these companies. News of the settlement was published by numerous media outlets, such as the Associated Press, New York Times, Washington Post, and South China Morning Post, and included a quote from Aaron Halegua, a lawyer and NYU research fellow who assisted the workers in this process and has written about the situation in Saipan elsewhere. Aaron discussed the importance of the settlement and necessary measures to prevent similar abuses from happening again. Specifically, he recommended that the casino, at a minimum, require contractors to purchase surety bonds, train workers about their rights, and hire a third-party monitor to oversee safety and labor conditions. One of the challenges will be distributing the settlement monies as almost all of the workers are now back in China.
March 20, 2018 in International & Comparative L.E.L., Wage & Hour, Workplace Safety | Permalink | Comments (0)
Wednesday, March 7, 2018
The Puzzle of Getting PAID
The US Department of Labor (DOL) unveiled yesterday a new six-month pilot program to encourage employer compliance with the Fair Labor Standards Act. Under the Payroll Audit Independent Determination program (PAID), DOL would cover any back pay employers owed to workers under FLSA (wages owed under FLSA's minimum wage or overtime provisions). In exchange, the employees would release any of FLSA claims for those violations, and employers would agree to self-auditing procedures for their pay practices. See here, the PAID website here, along with mixed reactions reported here.
One DOL-touted benefit of PAID: Participating employers won't have to pay FLSA "liquidated damages or civil monetary penalties" so long as those employers "proactively work with WHD to fix and resolve the compensation practices at issue." DOL won't make them and, it seems, employees would at least release the employer from any liquidated damages otherwise owed under FLSA for the "identified violations" and relevant time period.
This matters. An employer that violates FLSA is on the hook not just for the wages it should have paid but didn't (back pay) but also "an additional equal amount as liquidated damages," 29 U.S.C. § 216(b), unless the employer can show that it'd acted "in good faith" and had "reasonable grounds for believing that his act or omission" didn't violate FLSA, 29 U.S.C. § 260. So, if a worker is owed $40 in unpaid wages, she may recover up to $80, that is, the $40 in unpaid wages plus and the "additional equal amount" (another $40, the "liquidated damages").
The FLSA liquidated damages provision isn't just a damages multiplier. Rather, according to the US Supreme Court, it refers a separate item of compensatory damages: the loss that results because the employer didn't pay the owed wages on time. Such as loss is real, especially where the worker needs the wages paid on time to maintain a minimal standard of living, but Congress thought that type of loss "too obscure and difficult of proof for estimate other than by liquidated damages." Brooklyn Savings Bank v. v. O'Neil, 324 U.S. 697, 707-08 (1945).
Accordingly, the employer who gets PAID stands to save up to double–not just the back pay they'd owe the employee, but also the liquidated damages they'd also pay, in cases where the employee would otherwise sue and win. Since FLSA has a fee-shifting statute, employers stands to save more still in such cases. (Even more still if employers fear a FLSA hot-goods injunction. More on that here.) By the same token, however, employees who sign FLSA releases under PAID stand to give up any liquidated damages award, that is, up to half of what they'd recover if they sue and win. DOL's view: Under PAID, employees will get all their owed back wages "faster" than if they had to sue, and "without having to pay any litigation expenses or attorneys' fees."
Now, a puzzle: How would an employer getting PAID fare under parallel State wage and hour law? Like FLSA, many States have wage and hour laws with liquidated damages provisions. See, e.g., Cal.Labor Code § 1194.2; Md. Labor and Employment Code § 3-427(a)(2); W. Va. Code § 21-5B-4(a). In States where the employer's acts or omissions violated both FLSA and a State's wage and hour law, would the employee's release under PAID cover only any FLSA claim or any and all legal claims (including State law claims) arising from the employer's underpayment? In some States and localities, this matters, because the minimum wage and overtime provisions are more generous there. This issue matters less in, for example, the five States with no State minimum wage.
March 7, 2018 in Labor and Employment News, Wage & Hour | Permalink | Comments (0)
Wednesday, February 21, 2018
Saipan Governor: "I Didn't Lie" About Unpaid Workers
But representatives of workers don't buy it. Thanks again to Aaron Halegua for the latest.
February 21, 2018 in Wage & Hour | Permalink | Comments (0)
Schneider on Negotiating While Female
Andrea Schneider (Marquette) busts some myths about women negotiating salaries in her new article (SMU L. Rev.), just posted on SSRN, Negotiating While Female. Here's the abstract:
Why are women paid less than men? Prevailing ethos conveniently blames the woman and her alleged inability to negotiate. This article argues that blaming women for any lack of negotiation skills or efforts is inaccurate and that prevailing perceptions about women and negotiation are in-deed myths. The first myth is that women do not negotiate. While this is true in some lab studies and among younger women, more recent workplace data calls this platitude into question. The second myth is that women should avoid negotiations because of potential backlash. Although women in leadership do face an ongoing challenge to be likeable, it is clear that not negotiating has long-term detrimental effects. The third myth, based on the limited assumption that a good negotiator must be assertive, is that women cannot negotiate as well as men. However, the most effective negotiators are not just assertive, but also empathetic, flexible, socially intuitive, and ethical. Women can and do possess these negotiation skills. This article concludes by proposing an action plan which provides advice on how women can become more effective negotiators and identifies structural changes that might encourage negotiation and reduce the gender pay gap.
February 21, 2018 in Employment Discrimination, Wage & Hour | Permalink | Comments (0)
Tuesday, February 20, 2018
Minimum Wage Laws Grossly Underenforced, Politico Reports
From Marianne Levine, Behind the Minimum Wage Fight, a Sweeping Failure to Enforce the Law, Politico 2/18/18:
As Democrats make raising the minimum wage a centerpiece of their 2018 campaigns, and Republicans call for states to handle the issue, both are missing an important problem: Wage laws are poorly enforced, with workers often unable to recover back pay even after the government rules in their favor.
That's the conclusion of a nine-month investigation by POLITICO, which found that workers are so lightly protected that six states have no investigators to handle minimum-wage violations, while 26 additional states have fewer than 10 investigators. Given the widespread nature of wage theft and the dearth of resources to combat it, most cases go unreported. Thus, an estimated $15 billion in desperately needed income for workers with lowest wages goes instead into the pockets of shady bosses.
But even those workers who are able to brave the system and win — to get states to order their bosses to pay them what they're owed -- confront a further barrier: Fully 41 percent of the wages that employers are ordered to pay back to their workers aren't recovered, according to a POLITICO survey of 15 states.
That's partly because, in addition to lacking resources, states lack the tools to go after the landscaping firms, restaurants, cleaning companies and other employers that shed one corporate skin for another, changing names while essentially continuing the same businesses — often to evade orders to pay back their workers.
February 20, 2018 in Wage & Hour | Permalink | Comments (0)
Thursday, February 15, 2018
Secunda on the Right to Disconnect
Paul Secunda (Marquette) has just posted on SSRN his article (8 Notre Dame J. Int'l & Comparative L. (2018)) The Employee Right to Disconnect. Here's the abstract:
U.S. workers are increasingly finding it difficult to escape from work. Through their smartphones, email, and social media, work tethers them to their workstations well after the work day has ended. Whether at home or in transit, employers are asking or requiring employees to complete assignments, tasks, and projects outside of working hours. This practice has a profound detrimental impact on employee privacy and autonomy, safety and health, productivity and compensation, and rest and leisure. France and Germany have responded to this emerging workplace issue by taking different legal approaches to providing their employees a right to disconnect from the workplace. Although both the French legislative and German corporate self-regulation models have their advantages, this paper puts forth a hybrid approach using existing U.S. safety and health law under OSHA to respond to this employee disconnection problem. Initially under the general duty of clause of OSHA, and then under OSHA permanent standards and variances, this article provides a uniquely American approach to establishing an employee right to disconnect from work.
February 15, 2018 in Wage & Hour, Worklife Issues, Workplace Safety | Permalink | Comments (0)
Friday, January 12, 2018
The "Signaling" Effect of Raising Minimum Wage Laws
I posted yesterday on the conference earlier this week on minimum wage laws in developing countries. Daniel Helman (Ton Duc Thang University, Labor Relations & Trade Unions) circulated a follow-up email making a point about minimum wage laws I hadn't considered before. I suspect his argument has equal force when a single state or municipality in the U.S. raises its minimum wage significantly above (extraordinarily low, by any historical standard) national base rate. Here is Daniel's argument:
During my recent visits to Australia and Singapore (in December) I spent some time networking with academic colleagues. In both places people were talking about how Vietnam was projected to be the most important economy in SE Asia in twenty years. One of the key indicators of this projection is the rate of rise of wages here in Vietnam. The rapid wage increase is seen as a reflection of economic strength and an indicator of future economic growth.
Thus the trend in wage increases signals to the rest of the world that the economy of Vietnam is becoming increasingly robust. Such a signal leads to foreign investment at a consumer level—as international companies aim to establish an economic presence here in Vietnam. They do this now so that in the future, as the domestic demand is large, they will have a well-established presence and will be able to command a large share of the market in their sector.
Of course Vietnam has other features that influence its future success, such as a single-party system which allows for more focused and beneficial policies to be implemented more easily than in other systems; and a culture that is perhaps more focused on its own success after so much hardship for so many decades; and other intangibles, such as respect for the role of work and effort in the family. But the increase in wages—based in large part on the increases in the minimum wage over the past several years, has done a great deal to place Vietnam very high in its economic forecast. Such a signal leads to future investment, and these facts can form a strategy to (rightly) promote future increases in the minimum wage here so that it will reach the level of a living wage sufficient to meet more basic needs. It is similar to the point [ILO Vietnam Country Director] Dr. Chang-Hee Lee made on the first day [of the conference], about how increases in the minimum wage increase demand.
Obviously the totality of pathways and feedbacks are more complicated than what I have written above, but the essential point is that the rate of increase in wages is a signal of the growing robustness of the domestic market; and that this signal is read by global economic stakeholders and influences their behavior.
January 12, 2018 in Conferences & Colloquia, International & Comparative L.E.L., Wage & Hour | Permalink | Comments (0)
Thursday, January 11, 2018
Minimum Wage Laws in SE Asia
Earlier this week I participated in a conference on minimum wage laws in Viet Nam (and SE Asia generally) at the Tôn Đức Thắng University Labor College in Ho Chi Minh City (Saigon), Viet Nam. International wage & hour law is not my specialty, so it was a pleasure to learn from the many law faculty, workers' advocates, employer representatives, and even even the former head of the VGCL (the government-controlled unified trade union) attending. My key take-aways:
The traditional neoclassical economic argument that increasing the minimum wage decreases employment may have even less salience in developing countries than in developed ones. Even in the countries like Viet Nam that produce a large quantity of the clothing, electronics, and other goods consumed in the West, the vast majority of workers still work in services and manufacturing for the local economy. Raising minimum wages can increase both worker productivity and domestic consumption, which can have a positive effect on economic growth and employment and thus offset potential negative effects.
The risk of capital flight in response to raising the minimum wage is overstated. A MNC that has built a factory here is unlikely to relocate it because of a requirement that it spend an extra few cents per hour on wages. It's less clear how increases in minimum wage laws might influence future capital allocation decisions.
- Companies looking to maximize profits by minimizing labor costs are barking up the wrong tree -- they should instead be looking to cut supply-chain costs. The pair of Nikes we spend $150 for in the West costs about $12 to make, of which $2-3 is labor costs. The $138 difference between retail price and cost-of-production is where companies should be looking if they want to squeeze further profits. Nike could slash those costs by vertically integrating, which would have the salutary effect of making Nike directly and obviously responsible for the workers who make the company's shoes. The fact that the Nikes of the world aren't doing this is telling.
- The proportion of workers in the informal economy has a huge impact on the efficacy of minimum wage laws. Minimum wage laws may actually exacerbate wage inequality in countries where a large proportion of workers are off-the-books.
- Minimum wage laws can perform an important signaling effect in developing countries. I'll add a guest post on this topic shortly.
January 11, 2018 in Conferences & Colloquia, International & Comparative L.E.L., Wage & Hour | Permalink | Comments (0)
Sunday, November 12, 2017
Republican Tax Bill Puts Thumb on EE-IC Scale
Shu-Yi Oei and Diane Ring (both Boston College) have just posted on Tax Prof Blog The Senate Tax Bill and the Battles Over Worker Classification. Their post is extensive and detailed and well worth a full read. Here's a quick summary; the take-away is in bold at the bottom:
Senate Republicans released their version of tax reform legislation on Thursday, November 9. The legislative language is not available yet, but the Description of the Chairman's Mark (prepared by the Joint Committee on Taxation) suggests that one of the key provisions in the bill will clarify the treatment of workers as independent contractors by providing a safe harbor that guarantees such treatment. The JCT-prepared description tracks the contents of the so-called "NEW GIG Act" proposed legislations introduced by Congressman Tom Rice (R-S.C.) in the House and Senator John Thune (R-S.D.) in the Senate in October and July 2017, respectively. "NEW GIG" is short for the "New Economy Works to Guarantee Independence and Growth (NEW GIG) Act." But notably, and as we further discuss below, the legislation is not limited in its application to gig or sharing economy workers.
Assuming the Senate Bill adopts the basic parameters of the NEW GIG proposed legislation — which looks to be the case based on the JCT-prepared description — we have some concerns. In brief, this legislation purports to simply "clarify" the treatment of workers as independent contractors and to make life easier for workers by introducing a new 1099 reporting threshold and a new withholding obligation. But the legislation carries potentially important ramifications for broader fights over worker classification that are raging in the labor and employment law area. Despite possibly alleviating tax-related confusion and reducing the likelihood of under-withholding, we worry that there are quite a few underappreciated non-tax hazards for workers if these provisions go through.
The legislation (assuming the Senate Bill more or less tracks the NEW GIG Act language) purports to achieve such "clarification" of worker classification status by [, among other things, introducing] a safe harbor "which, if satisfied, would ensure that the worker (service provider) would be treated as an independent contractor, not an employee, and the service recipient (customer) would not be treated as the employer."...
At first blush, this legislation looks like it does good things for workers by clarifying their tax treatment, providing peace of mind, lowering previously unclear information reporting thresholds, and solving some of their estimated tax/mis-withholding issues.... The problem is that it's not just about tax....
Our worry is that tax clarification of independent contractor status is a strategic step designed to win this broader (non-tax) regulatory war over worker classification. The risk is that "clarifying" the independent contractor status of workers for tax purposes through the introduction of an easy-to-meet safe harbor risks influencing and tilting the worker classification battle that is occurring in labor and employment law. While determinations of independent contractor status in other areas are theoretically independent from the tax determination, clarification on the tax side may help create presumptions elsewhere that independent contractor classification is normatively correct. While the precise legal tests governing worker classification differ across areas — we have, for example, the common law agency test, the ABC test, the economic realities test, and the IRS 20-factor test — the tests have elements in common: They all examine to some degree the nature of the relationship between the business and the worker, and they all pay attention to the control exercised by the business over the worker. If one field decides the classification question a certain way, there is likely to be some reverberation for the analysis in other fields.
Our specific concern is that "forced clarity" in tax can tilt the direction of the worker classification debate in a way desired by the platform businesses, industry lobbyists and the legislation's supporters....
November 12, 2017 in Employment Common Law, Labor and Employment News, Wage & Hour, Workplace Trends | Permalink | Comments (0)
Monday, August 14, 2017
Hacked Employment Law
Charlotte Alexander (Georgia State) and Liz Tippett (Oregon) have just posted on SSRN their article (forthcoming Missouri L. Rev.) The Hacking of Employment Law. Here's the abstract of this timely (pun intended!) article:
Employers can use software in ways that erode employment law, through noncompliance and avoidance. The software exploits outdated regulations that do not anticipate the scale and precision with which employers can manage and manipulate the work relationship. Consequently, employers can implement systems that are largely consistent with existing laws, but violate legal rules on the margin. Employers can also use software to engage in lawful workaround tactics that avoid triggering some or all of the costs of complying with employment law. However, such tactics can cause harm to workers beyond the loss of the specific workers' rights or protections being avoided. Avoidance can create new norms about what work looks like that can degrade wages and working conditions across the labor market. Finally, when employers use software to avoid the employer-employee relationship entirely, employment law itself is weakened, as more workers operate in spaces beyond the law's reach, and employment rights are left only for a privileged few. The result is a weakened employment law regime, where legal rules struggle to keep up with employers' software-enabled innovations in noncompliance, or are rendered irrelevant as employers innovate in spaces that regulation simply does not reach. We conclude by suggesting ways that regulators can better adapt to workplaces where employers implement their decisions and define the structure of work through software.
August 14, 2017 in Employment Common Law, Scholarship, Wage & Hour | Permalink | Comments (0)
Thursday, March 30, 2017
Ivanka Trump -- Minimum Wage Victim?
The White House just announced that Ivanka Trump will no longer be a White House volunteer or "informal advisor," but will instead be an "unpaid employee." The move to employee status is a positive development, as it ensures that the usual ethical rules that apply to White House workers will apply to her as well. It's also understandable that, given her personal wealth, she would eschew a salary.
This does raise a question for the labor & employment law geeks among us: what about the FLSA's minimum wage? Normally, the FLSA would apply to federal employees, who can't agree to a salary below the minimum. However, I believe that there is a process for seeking a waiver--in this case, likely from the Office of Personnel Management, which enforces the FLSA for federal employees--but there's no mention of whether a waiver is currently being sought (or whether I'm even right about this).
If any readers have more insight, please add a comment.
-Jeff Hirsch
March 30, 2017 in Labor and Employment News, Wage & Hour | Permalink | Comments (1)
Friday, March 10, 2017
Gender Budgeting - Or Why Tax is a Feminist Issue
Last week's The Economist ran a couple of stories on how "gender budgeting" can help persuade governments to pay more than lip service to women's rights. Below is an excerpt from the summary Making Women Count; an extended-play version is Tax is a Feminist Issue: Why National Budgets Need to Take Gender into Account.
... [S]ome policymakers have embraced a technique called gender budgeting. It not only promises to do a lot of good for women, but carries a lesson for advocates of any cause: the way to a government's heart is through its pocket.
At its simplest, gender budgeting sets out to quantify how policies affect women and men differently. That seemingly trivial step converts exhortation about treating women fairly into the coin of government: costs and benefits, and investments and returns. You don't have to be a feminist to recognise, as Austria did, that the numbers show how lowering income tax on second earners will encourage women to join the labour force, boosting growth and tax revenues. Or that cuts to programmes designed to reduce domestic violence would be a false economy, because they would cost so much in medical treatment and lost workdays.
Partly because South Korea invested little in social care, women had to choose between having children, which lowers labour-force participation, or remaining childless, which reduces the country's fertility rate. Gender budgeting showed how, with an ageing population, the country gained from spending on care. Rwanda found that investment in clean water not only curbed disease but also freed up girls, who used to fetch the stuff, to go to school. Ample research confirms that leaving half a country's people behind is bad for growth. Violence against women; failing to educate girls properly; unequal pay and access to jobs: all take an economic toll.
March 10, 2017 in Employment Discrimination, Wage & Hour, Worklife Issues, Workplace Trends | Permalink | Comments (0)
Wednesday, January 18, 2017
When Timekeeping Software Undermines Compliance
Elizabeth Tippett (Oregon), Charlotte S. Alexander (Georgia State), and Zev J. Eigen (Littler) have just published their explosive article When Timekeeping Software Undermines Compliance (19 Yale J.L. & Tech. 1 ). When I say "explosive" I am not exaggerating one iota. Their article exposes how choices and algorithms deliberately built into timekeeping systems cheat workers out of time worked or overtime owed. I am reproducing the abstract below, but strongly encourage everyone to read the full article. I expect this article will spawn loads of high-dollar litigation; more optimistically, I would hope the article will encourage software firms and their corporate clients to be far more diligent in complying with wage & hour law.
Here's the abstract:
Electronic timekeeping is a ubiquitous feature of the modern workplace. Time and attendance software enables employers to record employees' hours worked, breaks taken, and related data to determine compensation. Sometimes this software also undermines wage and hour law, allowing bad actor employers more readily to manipulate employee time cards, set up automatic default rules that shave hours from employees' paychecks, and disguise edits to records of wages and hours. Software could enable transparency, but when it serves to obfuscate instead, it misses an opportunity to reduce costly legal risk for employers and protect employee rights. This article examines thirteen commonly used timekeeping programs to expose the ways in which software innovation can erode compliance. Drawing on insights from the field of behavioral compliance, we explain how the software presents subtle situational cues that can encourage and legitimize wage theft. We also examine gaps in the Fair Labor Standards Act's recordkeeping rules – unchanged since the 1980s – that have created a regulatory vacuum in which timekeeping software has developed. Finally, we propose a series of reforms to those recordkeeping requirements that would better regulate timekeeping data and software systems and encourage wage and hour law compliance across workplaces.
January 18, 2017 in Wage & Hour | Permalink | Comments (0)
Tuesday, November 22, 2016
District Court Enjoins New Overtime Salary Threshold (and Basically Holds that Salary-Basis Test is Unlawful)
Today, the Eastern District of Texas just issued a nationwide preliminary injunction barring application of the Department of Labor's (DOL) new minimum salary threshold for overtime exclusions under the Fair Labor Standards Act.
The decision is stunning. The court relies almost exclusively on dictionary definitions of the terms of the FLSA's overtime provisions. In so doing it states repeatedly that the FLSA's statement that the DOL may define and delimit the meaning of "administrative, exccutive, and professional" does not include the authority to set minimum salary thresholds. According to the court, the DOL can only update the duties. Thus, if an employee meets the duties of, say, an administrative employee, they should be excluded no matter their salary. However, perhaps recognizing that this line of reasoning runs contrary to decades of overtime law, the court drops a footnote saying it wasn't questioning the salary-basis test generally -- the court was addressing only the new salary threshold was under issue. But as far as I can tell, the only logical conclusion from the court's reasoning is that the salary-basis test in general is illegal (if someone sees a way around this in the decision, definitely let me know). In other words, if this decision stands, I think the only logical conclusion is that there will no longer be a salary-basis test for overtime exemptions.
-Jeff Hirsch
November 22, 2016 in Labor and Employment News, Wage & Hour | Permalink | Comments (3)
Wednesday, October 5, 2016
Worker Valuation of Alternative Work Arrangements
How much of your wages would you be willing to give up for more control over what days and how much you work? In a new working paper, Alexandre Mas and Amanda Pallais, "Valuing Alternative Work Arrangements," NBER Working Paper No. 22708 (Sept. 2016), the authors conducted a field experiment to find out. Here's the abstract:
We use a field experiment to study how workers value alternative work arrangements. During the application process to staff a national call center, we randomly offered applicants choices between traditional M-F 9 am – 5 pm office positions and alternatives. These alternatives include flexible scheduling, working from home, and positions that give the employer discretion over scheduling. We randomly varied the wage difference between the traditional option and the alternative, allowing us to estimate the entire distribution of willingness to pay (WTP) for these alternatives. We validate our results using a nationally-representative survey. The great majority of workers are not willing to pay for flexible scheduling relative to a traditional schedule: either the ability to choose the days and times of work or the number of hours they work. However, the average worker is willing to give up 20% of wages to avoid a schedule set by an employer on a week's notice. This largely represents workers' aversion to evening and weekend work, not scheduling unpredictability. Traditional M-F 9 am – 5 pm schedules are preferred by most job seekers. Despite the fact that the average worker isn't willing to pay for scheduling flexibility, a tail of workers with high WTP allows for sizable compensating differentials. Of the worker friendly options we test, workers are willing to pay the most (8% of wages) for the option of working from home. Women, particularly those with young children, have higher WTP for work from home and to avoid employer scheduling discretion. They are slightly more likely to be in jobs with these amenities, but the differences are not large enough to explain any wage gaps.
Puzzled by the low willingness to pay for a flexible number-of-hours option, the authors posed the same choice to Mechanical Turk workers, and asked them to explain their choice. The Mechanical Turk workers are more likely to prefer flexibility. Of those who preferred the M-F 9 am - 5 pm option, they "typically mentioned that they liked having someone else set the schedule and tell them how many hours they should work. They expressed concern that if they could choose it would be difficult to force themselves to work their desired number of hours." (p. 14).
--Sachin Pandya
October 5, 2016 in Wage & Hour, Worklife Issues | Permalink | Comments (0)
Wednesday, September 21, 2016
Bisom-Rapp on lifetime disadvantage for working women
Congratulations to our friend Susan Bisom-Rapp (Thomas Jefferson) whose book (with Malcolm Sargeant, Middlesex Univ., London), Lifetime Disadvantage, Discrimination and the Gendered Work Force is available to pre-order from Cambridge University Press. It will be out September 30. From the press release:
In many countries, including the United States, women are significantly more likely to fall into poverty in retirement than are men. Understanding why this is so and what can be done about it is the aim of this new book.
"Susan Bisom-Rapp's scholarship tackles some of the most pressing real world challenges facing the modern workplace," said Thomas Jefferson School of Law Dean and President Thomas F. Guernsey. "I am delighted about the publication of her latest book."
Beginning in girlhood and ending in advanced age, "Lifetime Disadvantage, Discrimination and the Gendered Workforce" examines each stage of the lifecycle and considers how law attempts to address the problems that inhibit women's labor force participation. Using their model of lifetime disadvantage, Professor Bisom-Rapp and her British co-author Malcolm Sargeant show how the law adopts a piecemeal and disjointed approach to resolving challenges with adverse effects that cumulate over time.
"The problem unfolds over the working lives of women," said Bisom-Rapp. "Women's experiences with education, stereotyping, characteristics other than gender like race and age, caregiving, glass ceilings, occupational segregation, pay inequality, part-time work, and career breaks over a lifetime make it difficult to amass the resources necessary for a dignified retirement."
In order to achieve true gender equality, Bisom-Rapp and her co-author recommend a more holistic approach. Employing the concept of resiliency from vulnerability theory, the authors advocate changes to workplace law and policy, which acknowledge yet transcend gender, improving conditions for women as well as men.
"One must know the end goal – decent work and dignified retirement – and monitor progress towards it in order effectively address the problem," noted Bisom-Rapp.
The book is the culmination of nearly a decade of collaboration between Professor Bisom-Rapp and Professor Sargeant, who teaches at Middlesex University Business School in London. Beginning with a project that examined the plight of older workers during the global economic crisis, they have been struck by differences in workplace law and protections in their respective countries; the United Kingdom is far more protective.
Equally noticeable, however, are similarities in outcomes, including women's economic disadvantages in retirement. By examining why more protective law in one country coexists with comparable outcomes to the other country, the book reveals lessons for understanding a problem that is global in nature. At a time in which an aging population makes a retirement crisis a distinct possibility, and employment has become increasingly insecure, they recommend a regulatory approach that would enhance work life and retirement for all.
Susan and Malcolm have published a few articles related to these topics in the last few years in the Employee Rights Employment Policy Journal, the Elder Law Journal, and the Loyola University Chicago Law Journal. I can't wait to read more of their work.
September 21, 2016 in Books, Employment Common Law, Employment Discrimination, International & Comparative L.E.L., Labor Law, Pension and Benefits, Scholarship, Wage & Hour, Worklife Issues | Permalink | Comments (0)
Friday, August 26, 2016
Call for papers from the Center for Applied Feminism & Intersectionality
The Center for Applied Feminism (Baltimore) has a call for papers that will be of interest to some of our readers:
The Center on Applied Feminism at the University of Baltimore School of Law seeks paper proposals for the Tenth Anniversary of the Feminist Legal Theory Conference. We hope you will join us for this exciting celebration on March 30-31, 2017.
This year, the conference will explore how intersecting identities inform -- or should inform -- feminist legal theory and justice-oriented legal practice, legal systems, legal policy, and legal activism. Beginning in 1989, Kimberlé Crenshaw identified the need for law to recognize persons as representing multiple intersecting identities, not only one identity (such as female) to the exclusion of another (such as African American). Intersectionality theory unmasks how social systems oppress people in different ways. While its origins are in exploring the intersection of race and gender, intersectionality theory now encompasses all intersecting identities including religion, ethnicity, citizenship, class, disability, and sexual orientation. Today, intersectionality theory is an important part of the Black Lives Matter and #SayHerName movements. For more information, see https://www.washingtonpost.com/news/in-theory/wp/2015/09/24/why-intersectionality-cant-wait/.
We seek submissions of papers that focus on the topic of applied feminism and intersecting identities. This conference aims to explore the following questions: What impact has intersectionality theory had on feminist legal theory? How has it changed law and social policy? How does intersectionality help us understand and challenge different forms of oppression? What is its transformative potential? What legal challenges are best suited to an intersectionality approach? How has intersectionality theory changed over time and where might it go in the future?
We welcome proposals that consider these questions from a variety of substantive disciplines and perspectives. As always, the Center's conference will serve as a forum for scholars, practitioners and activists to share ideas about applied feminism, focusing on connections between theory and practice to effectuate social change. The conference will be open to the public and will feature a keynote speaker. Past keynote speakers have included Nobel Laureate Toni Morrison, Dr. Maya Angelou, Gloria Steinem, Senators Barbara Mikulski and Amy Klobuchar, NOW President Terry O'Neill, EEOC Commissioner Chai Feldblum, and U.S. District Judge Nancy Gertner.
To submit a paper proposal, please submit an abstract by Friday October 28, 2016 to firstname.lastname@example.com. Your abstract must contain your full contact information and professional affiliation, as well as an email, phone number, and mailing address. In the "Re" line, please state: CAF Conference 2017. Abstracts should be no longer than one page. We will notify presenters of selected papers in November. About half the presenter slots will be reserved for authors who commit to publishing in the annual symposium volume of the University of Baltimore Law Review. Thus, please indicate at the bottom of your abstract whether you are submitting (1) solely to present or (2) to present and publish in the symposium volume. Authors who are interested in publishing in the Law Review will be strongly considered for publication. For all presenters, working drafts of papers will be due no later than March 3, 2017. Presenters are responsible for their own travel costs; the conference will provide a discounted hotel rate as well as meals.
We look forward to your submissions. If you have further questions, please contact Prof. Margaret Johnson at firstname.lastname@example.com. For additional information about the conference, please visit law.ubalt.edu/caf.
August 26, 2016 in Conferences & Colloquia, Employment Common Law, Employment Discrimination, Labor Law, Labor/Employment History, Pension and Benefits, Public Employment Law, Religion, Scholarship, Wage & Hour, Worklife Issues, Workplace Safety | Permalink | Comments (0)


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Latest News
Non Uniform Day
The first Non Uniform Day of the academic year was held on Friday, 2 October 2015. Students and staff contributed £1.00 each, towards our RAG Charities – The Anthony Nolan Blood Cancer Charity, The Alzheimer's Society, Kent Search and Rescue, Army of Angels and Holding on Letting go. Well done to everyone who took part. We raised £1207.34 which is a fantastic sum of money.

subset: commoncrawl


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Val Walker and Gail Birch, both from Abergele in North Wales, recently returned from a 32-day, 500-mile journey to raise money for Smile Train and another one of their favourite charities. The two friends travelled an ancient route from Saint-Jean-Pied-de-Port, France to Santiago de Compostela, Spain, called the 'French Way'.
Val and Gail chose to raise funds for Smile Train because they felt that helping provide cleft surgeries would be a great way to change the lives of children forever. On their Virgin Money Giving Page, they jokingly shared the following with their potential supporters:
We're not young — there's a risk that we might do ourselves some permanent damage (some will argue that we're already damaged to attempt it), but we're going to do it anyway. Think of it as a sort of 'cash-for-injuries' scheme — we suffer injuries and you pay these excellent charities a whole wad of cash. It's a win-win situation — discount the tendonitis and broken toes.
Val and Gail started their 500-mile journey in South West France with varying amounts of confidence. Val remembers, "I knew Gail would be fine — she's an experienced walker who has walked in similar challenges just for the love of walking. I've always enjoyed walking with groups of friends, but 500 miles is a daunting challenge."
Val and Gail walked between 15 and 21 miles a day and eventually made it across the border to Spain. To add to the difficulty, northern Spain was in the midst of a heatwave. Gail explains, "We had to start walking before dawn, then put in about 7 hours, and stop when the temperature hit almost 40°C. That stretch was no doubt our biggest challenge."
After 32 days of hard work, Val and Gail reached Santiago triumphantly on 18 June. They both agreed that the trip was a resounding success and raising funds while taking in breathtaking vistas was worth all of the pain and suffering.
To-date, Val and Gail have raised a total of £2,615 through their Virgin Money Giving Page. Smile Train's Community and Events Manager Jonathan Roberts said of the walking duo, "We are thrilled to hear that Val and Gail have successfully completed their impressive walk from Saint-Jean-Pied-de-Port to Santiago. The money that they have raised for Smile Train will help give children born with clefts in developing countries the same chances in life as those born without clefts."
If you'd like to learn more about Val and Gail's challenges, or to donate to their cause, please visit their fundraising page. If you are interested in turning your miles into smiles, please visit our Team EMPOWER section. Your support helps children receive new smiles and second chances at life.


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Hutchhutch (huch),USA pronunciation n.
- a pen or enclosed coop for small animals: rabbit hutch.
- a chest, cupboard, bin, etc., for storage.
- any of various chestlike cabinets, raised on legs and having doors or drawers in front, sometimes with open shelves above.
- a small cottage, hut, or cabin.
- a baker's kneading trough.
Rabbitrab•bit (rab′it),USA pronunciation n., pl. -bits, (esp. collectively) -bit for 1–3.
rab′bit•like′, rab′bit•y, adj.
- any of several soft-furred, large-eared, rodentlike burrowing mammals of the family Leporidae, allied with the hares and pikas in the order Lagomorpha, having a divided upper lip and long hind legs, usually smaller than the hares and mainly distinguished from them by bearing blind and furless young in nests rather than fully developed young in the open.
- any of various small hares.
- the fur of a rabbit or hare, often processed to imitate another fur.
- See Welsh rabbit.
- a runner in a distance race whose goal is chiefly to set a fast pace, either to exhaust a particular rival so that a teammate can win or to help another entrant break a record;
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Homehome (hōm),USA pronunciation n., adj., adv., v., homed, hom•ing.
- a house, apartment, or other shelter that is the usual residence of a person, family, or household.
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- to direct, esp. under control of an automatic aiming device, toward an airport, target, etc.


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Evergreen, CO
Evergreen Fine Art Gallery, June 20-July 19
This story was featured in the June 2014 issue of Southwest Art magazine. Get the Southwest Art June 2014 print issue or digital download now–then subscribe to Southwest Art and never miss another story!
Evergreen Fine Art's Weekend in the West Art Show and Sale is a dynamic event that brings together nearly 60 painters and sculptors from around the country for a western-style art experience. Festivities begin with an art opening and reception at the gallery from 5 to 8 p.m. on Friday, June 20. Cowboy poet and guitarist Dean Himes entertains guests with traditional cowboy songs while hors d'oeuvres and drinks are served. Among the artists contributing work to the weekend event are painters Dave Santillanes, Walt Gonske, Michael Untiedt, Quang Ho, Doug Hall, Lindsey Bittner Graham, Edward Aldrich, and Nikolo Balkanski as well as sculptors Stephen LeBlanc, Karryl, and Pati Stajcar.
For this fourth annual show, Denver-area painter Graham expresses her passion for horses and the way they move in her painting MONEY RIDE, which was inspired by a visit to the world-renowned Cheyenne Frontier Days Rodeo. "My husband, who used to be a professional rodeo photographer, helped me know what to look for as I watched the riders," she says. "I especially liked this rider. The way he was positioned on the horse and the way they moved together made me feel that it was an award-winning ride."
The bison in Aldrich's painting HEAD OF THE HERD lives on a ranch an hour's drive from the artist's home. "I know this particular bison well," he says. "A friend of mine owns him. I've been able to get within feet of him and really look into his eyes and see his power. Bison are majestic in an interesting way."
HEAD OF THE HERD and MONEY RIDE are on display during the opening reception of Weekend in the West, along with more than 100 other artworks. The evening also features a silent auction of china plates designed by both area school children and professional artists. A portion of the proceeds from the sale of the plates and artwork helps benefit art education and art appreciation in the local mountain-area schools.
Weekend events continue on Saturday morning as more than 30 painters set up easels in the gallery's outdoor sculpture garden for a Quick Draw from 9 to 10:30 a.m. "Colorado's largest Quick Draw and auction provides incredible opportunity for collectors to experience the thrill of watching artists create beautiful works of art in the magnificent mountain setting of Evergreen," says Doug Kacena, director of exhibitions at Evergreen Fine Art.
At 10:30 sharp, the brushes are laid down. "It's outstanding what these artists can do in 90 minutes," Kacena adds. "Keeping to our western theme, they create everything from landscapes to still lifes." Guests head to a nearby tent to enjoy a champagne brunch while the artists frame their Quick Draw works, which are sold in an auction immediately following the meal.
The opening reception, Quick Draw, and auction are all free and open to the public. Tickets are needed for Saturday's brunch and can be purchased by contacting the gallery. —Emily Van Cleve
contact information
Featured in the June 2014 issue of Southwest Art magazine–click below to purchase:
Southwest Art June 2014 print issue or digital download Or subscribe to Southwest Art and never miss a story!
• Subscribe to Southwest Art magazine
• Learn how to paint & how to draw with downloads, books, videos & more from North Light Shop
• Sign up for your Southwest Art email newsletter & download a FREE ebook


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PAT Phelan is one of the most feared soap villains of all time, with his reign of terror finally at an end.
Here is everything you need to know about the serial killer following his epic final epic showdown…
Who is Pat Phelan?
Coronation Street's Pat Phelan played by Connor McIntyre, is a businessman, builder and con artist.
He first arrived on the soap in 2013 and immediately made himself an enemy of the Windass family.
His ex-wife Valerie divorced him in 2014 and he married Eileen Grimshaw in 2017.
Nicola Rubenstein is his long-lost daughter from his affair with Annabel Rubenstein.
Who has Pat Phelan killed?
Pat's first victim was Michael Rodwell, Gail Platt's husband.
He didn't directly kill him but when he suffered a heart attack in November 2016, Pat did nothing to help him and watched him die.
Then in October 2017, he killed Vinny Ashford, AKA Flora's son Harvey McArdle, for trying to do a runner after their failed dodgy flats scheme.
Pat had been keeping Andy Carver prisoner so ordered him to shoot Vinny in exchange for his freedom.
But he went back on his word and killed Andy anyway by shooting him.
What happened between Eileen Grimshaw and Pat Phelan?
On Good Friday 2018, Eileen pushed Pat off a lighthouse in Whitehaven in an explosive showdown.
Avid Corrie-watchers were left debating whether the murderer was truly dead, as they hadn't seen his dead body on screen.
Then on Easter Monday, it was revealed that Pat is very much still ALIVE.
Pat was seen having survived the fall and icy temperatures, and was comfortably propped up in bed in a B&B tending to his wounds.
Meanwhile, Eileen was accused of murdering the killer's victims herself after cops found a fake passport and bag full of Euros on the boat Pat had intended to escape on.
Now Eileen is moving on and has even joined Daniel's campaign to free Anna Windass from prison.
But after Pat saw her talking on TV he seemed determined to get his revenge and continue his killing spree.
What is Pat's feud with Gary and Anna Windass?
Gary holds a grudge against Pat due to his attempts to destroy his family, and for what he did to his mum Anna.
Pat Phelan conned Anna Windass' partner Owen Armstrong into a dodgy construction deal.
He then raped Anna and later framed her for GBH by forcing Seb Franklin to lie and say she'd pushed him off a ladder.
The character, played by Debbie Rush, was sentenced to five years in prison.
Now Daniel, with the help of others is campaigning for Anna to be released from jail.
Gary managed to track down Pat's secret location in Wales, kidnapped him and brought him back to Weatherfield.
After managing to get free Pat pulled a gun on Gary and Sarah Platt but he didn't shoot them.
Who did Pat Phelan Kill at Rob and Michelle's wedding?
Pat was set to wreak havoc at Michelle Connor and Robert Preston's Wedding in the Bistro.
He was out for revenge on Eileen in particular but anyone could be caught in the crossfire.
After shooting his own daughter Nicola Rubinstein in a scuffle at Eileen's house, Phelan then headed for the wedding and shot Michelle, wounding her but failing to kill her.
Who is Phelan actor Connor McIntyre?
Pat Phelan is portrayed by Connor McIntyre, 57, from Liverpool.
Before he became an actor he worked as a lifeguard and a car salesman.
He has starred in a variety of TV shows including Casualty, London's Burning, Law and Order and A & E.
He is also a talented artist and studied a Fine Art degree.


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Latitude: 54.9834 / 54°59'0"N
Longitude: -1.6245 / 1°37'28"W
OS Eastings: 424128
OS Northings: 565483
OS Grid: NZ241654
Mapcode National: GBR SMP.7L
Mapcode Global: WHC3R.00QH
Entry Name: Hall of Church of St Luke
Listing Date: 30 March 1987
Grade: II
Source: Historic England
Source ID: 1024906
English Heritage Legacy ID: 304472
Location: Newcastle upon Tyne, NE2
County: Newcastle upon Tyne
Electoral Ward/Division: Wingrove
Built-Up Area: Newcastle upon Tyne
Traditional County: Northumberland
Lieutenancy Area (Ceremonial County): Tyne and Wear
Church of England Parish: Newcastle St Luke
Church of England Diocese: Newcastle
(west side)
13/165 Hall of Church of
St. Luke
Church Hall. Circa 1900. Bright red brick with ashlar dressings; Welsh slate
roof. Tudor style. 2 storeys, 6 bays. Tudor arch to panelled door with 2-light
mullioned overlight, in second bay. Irregular-block surrounds to this and to
windows, cross on ground floor and 2-light on first, all stone-mullioned. Roll-
moulded high parapet.
Listing NGR: NZ2412865483
This text is from the original listing, and may not necessarily reflect the current setting of the building.
Other nearby listed buildings


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How to make different social classes look quite different? If you choose to participate, the online survey will be presented to you when you leave the Technet Web site.Would you like to participate? You may receive bad data. TWTR,09:30:00.00,64.89,245,4qda2rhsr0lrqcof2cpe8f7psb 19:08:18.460 - An error occured while processing the 11 line of the file. navigate to this website
Below was the faulty input. echo. ::start "" "C:\Program Files\Microsoft Office\office11\winword.exe" start notepad.exe if ERRORLEVEL 1 goto error qprocess notepad.exe echo *Start.success* ERRORLEVEL is: %ERRORLEVEL% echo. How to map and sum a list fast? GTIN validation Force Microsoft Word to NEVER auto-capitalize the name of my company How does Gandalf get informed of Bilbo's 111st birthday party?
When any error occurs during the reading process, Spring Batch throws an exception. Can it be done? Spring batch Skip techniqueWith the skip technique you may specify certain exception types and a maximum number of skipped items, and whenever one of those skippable exceptions is thrown, the batch Reply Kevin says: October 30, 2012 at 1:19 am The problem was actually that if I schedule it at 4am, the 2 digit for "hour" would actually have a space like
The improved error handling was another. New porgrams that are compatible with WIndows can "throw" an exception. echo. Batch File Error Handling Tutorial Thanks for your help. @echo off setlocal set _source=C:test7zipbak set _dest=C:test7zipbak set _wrpath=C:Program Files7-Zip if NOT EXIST %_dest% md %_dest% for %%I in (%_source%*.txt,%_source%*.cpi) do "%_wrpath%7z" a "%_dest%%%~nI.7z" "%%I" & del
e.g. Batch File Error Handling EXIT /B 1 Update: I was wrong about the ERRORLEVEL syntax earlier, so I updated after some testing. Below was the faulty input. U dijeljenju nalazim radost.
When was this language released? Batch File Error Handling Errorlevel Pridružite mi se, ovdje i sada. JUnit Tutorial for Unit Testing4. Question 0 Sign in to vote Hi, I have written a batch file which will call a third paty utility to do a job.
You are correct that there is a difference; The errorlevel that you get from an exiting process is an internal register that you can read with the %errorlevel% syntax. Handling errors now... Error Handling In Windows Batch Script Now, if I use start, it should start up notepad without any errors again. Dos Batch Error Handling It will corrupt any further use of %ERRORLEVEL% syntax by fixing it at a value.
These are the things I commonly need to deal with. http://papercom.org/error-handling/batch-files-error-handling.php If there is an error in the independent script, it will set the errorlevel using the EXIT /B n command. Something that trips up a fair number of people is the difference between double-clicking a .BAT file and scheduling it as a task to run at a certain time, on a JVM Troubleshooting Guide3. Spring Batch Error Handling
Alternately, you can check for "IF ERRORLEVEL 1 ..." if you want to look for a specific error level. echo Finished child script. But ERRORLEVEL is not the only recourse for batch - see my answer –dbenham Jun 13 '13 at 11:30 add a comment| up vote 2 down vote A successful ping on my review here This will result in a failure to process annotations such as @Autowired, @Resource and @PostConstruct within the method's declaring @Configuration class.
Cheers, Paul Reply aleksandar says: February 20, 2012 at 7:18 pm Can you tell me how to specify command if connect to ftp fail or files could not be copied? Bash Error Handling When answering a question please: Read the question carefully. Bill Wednesday, August 08, 2012 2:43 PM Reply | Quote Moderator 0 Sign in to vote Hi, I have written a batch file which will call a third paty utility to
Use "EXIT /B 1" to return an exit code from your script. exit /b 1 :wrongParams :: Output an error if the wrong parameters were passed to this script. :: Maybe try to self correct the parameter... I have two wrapper scripts that will either start up or stop the applications by passing arguments to the independent script. Batch File Check Errorlevel Once control is returned to the calling script, it will go to an error handling script if the exit status is non-zero.
You'd want to look at a more powerful scripting language. I really don't expect anyone other than myself to ever look at it, but I'm happy if they do. However, if you're calling an external program to perform some task, and it doesn't return proper codes, you can pipe the output to 'find' and check the errorlevel from that. get redirected here Meaning of "soul-sapping" I accepted a counter offer and regret it: can I go back and contact the previous company?
This section will look at how to use this technique to skip records based upon specific Exceptions. i.e. %windir%\system32 Now, if your batch file assumes that you launched it through Explorer or from an existing command prompt with the current working directory set to its own location, Wednesday, August 08, 2012 4:32 PM Reply | Quote 0 Sign in to vote It should be if %errorlevel% == 0 example Justin | http://patchmypc.net "if %ErrorLevel% EQU 0" is perfectly Is there a way to make a metal sword resistant to lava?
Ne dopustite da budem usamljen u stvaranju raja na Zemlji. Reply Paul Adams (ex-MSFT) says: October 2, 2016 at 12:58 am Unfortunately, as http://ftp.exe just returns the success level of finding the script file to execute, it will return 0 (ERROR_SUCCESS) C# questions Linux questions ASP.NET questions SQL questions VB.NET questions discussionsforums All Message Boards... Examples Java Code Geeks and all content copyright © 2010-2016, Exelixis Media P.C. | Terms of Use | Privacy Policy | Contact Want to take your Java skills to the next
If I use stop again, it throws an error as expected. Cheers, Paul Reply Paul Adams (ex-MSFT) says: October 2, 2016 at 12:58 am Hi Baljeet, You can use %ERRORLEVEL% as described to check the status after calling the executable - if Well, the scheduled task was set for allow on-demand trigger, and I have tested it by right click on the task and then "RUN". IstinaIspovijediZrnca istineGdje se sakrila istina?Trula ekonomijaPorez - izvor ljudske bijedeStop BankamaLekcije ulagačaPlanirana zastaraIstina o žaruljamaDosta je mraka!EUDodir beskonačnostiChemTrailsChemTrails I - PočetakChemTrails II - Tko nas praši?ChemTrails III - Best of 1-34ChemTrails
Reply Paul Adams (ex-MSFT) says: October 2, 2016 at 12:58 am Hi Kevin, My initial thought is the system locale. Nested try/catch blocks open a cmd window and pass in hardcoded values using a batch file Using Exception Insted of Try Catch Block exception hanlding by try catch block Command Prompt Otherwise, I can only suggest cycling through the drive letters using "IF EXIST" to find the batch file name, but that might throw "drive not ready" errors for removable drives such You don't need the pause either - if the idea is to keep the command prompt window open while the selected game is playing then use "start /w" to launch the
Log application status and cause of error here. There are other possibilities as well, but that depends on the program. We will leverage the skip technique for handling some bad stock data records in our last Spring Batch ETL Job which raises a FlatFileParseException while reading CSV file trades.csv.1. Finding a file starting with '-' dash What are the canonical white spaces?
In powershell ,I was using below code function a(){ try { ping asdfasdf ping 171.21.000.145 ping ghgsjhsjs Write-Host "success" exit 0 } catch { Write-Host "failure" exit 1 If you skip one or two records out of a million, not a big deal; however, skipping half a million out of a million is probably wrong. How rich can one single time travelling person actually become? If you use "EXIT 1" it will exit the entire command shell, including closing your current window if it's running in one.
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The Caladoc is a curious cross between Grenache and Malbec, developed in the Rhône to lessen the likelihood of uneven flowering in the Grenache. The wine has sweet, jelly-like aromas. The palate is soft, juicy with sweet acidity, soft, light tannins and an almost piercing fruitiness. —R.V.
Roger Voss covers Bordeaux, Burgundy, Champagne, the Loire and South-West France as well as Portugal. His passion is matching food with wine, bringing the pleasures of the table to wine lovers. He has written six books on wine and food, and was previously national correspondent on wine for the London Daily Telegraph. He is based in the Bordeaux region.
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June 6, 2018
June 6
Praise the Lord! I awoke to blue sky this morning. Than You Lord Yeshua!
…and that Christ may dwell in your hearts through faith. I pray that you, being rooted and firmly established in love, may be able to comprehend with all the saints what is the length and width, height and depth of God's love, and to know Christ's love that surpasses knowledge, so that you may be filled with all the fullness of God. Ephesians 3:17-19 CSB
Judges 1
Right away the principal of sowing and reaping comes forth!
Judah captured Jerusalem. Judah was an Israelite, the son of the patriarchs, great grandson of Abraham of whom this clan of people came from. The Promised Land belongs to Israel. Jerusalem can never be divided or the wrath of God will show up. Jerusalem is the capital of Israel, period. Dividing it will NEVER bring peace, only set the stage for the antichrist.
Benjamin and the other tribes that failed didn't fail because God was not with them, they failed because they did not do as God commanded.
Isaiah 30
Trusting in the world system, according to God, is trusting in oppression and deceit! Obedience to the voice of the Lord brings all things good! Lord, send the rain for the seed we have sown into people's lives so there will be a great harvest of souls!
Luke 8
The Lord blesses us women so we can be a great support to Him, spiritually and financially! Let us sow to good ground so it produces a great harvest! The most worthy of seed is the Word of God, so let's get sowing!
We have been given the authority of the Lord over the natural elements of this earth and the enemy, himself. Evidence of this is so very clear throughout the Word. The Lord rebuked the wind and it stopped. Elijah stopped the rain and brought it forth again. Joshua stopped the sun to finish the battle. The disciples laid hands on the sick and the people recovered and then they raised the dead as did the prophets. We have authority over the volcano which is a natural element causing havoc by the enemy. Join me and use our authority together as the army of God and rebuke this spewing volcano to stop and desist and have our air cleaned up in the NAME OF YESHUA MESSIAH, JESUS CHRIST OUR LORD!
I can't help but find it strange that the people were more afraid of the Lord healing the demoniac over having the demonic live in their town!
My God does not refuse His healing power to me! I am the healed of the Lord! My body cannot refute the power of the living God upon me! His power goes out to me because I touch Him! The Lord is the Author and Finisher of my faith and finishes what He starts! Oh Hallelujah!
Meditation & Application: Today was about sowing and reaping. Sow the Word and reap every promise of God. Sow love, kindness, goodness, all the fruit of the Spirit and reap a wonderful harvest. Use my God given authority. My God finished what He starts and He has started a wonderful work in me by His Spirit!


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Coldplay Planning a Three Year Break From Touring?
After finishing up Men at Work's "Down Under"a nod to their host countryBillboard reported that frontman Chris Martin told the crowd, "This is the last big show for three years or so."
Is the band taking a well-deserved break after finishing up their world tour for Mylo Xyloto? Some speculation about that here.
CBS Local submitted this story.


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14k White Gold Evil Eye Necklace Adjustable Length
Evil eye, or Nazar Boncuk, is a good luck charm that goes back thousands of years and is believed to ward off evil and keep one safe from those who wish to do them harm. Solid 14k gold evil eye pendant measure 9x4mm. The chain is a diamond-cut cable chain that is adjustable from 16 to 18 inches long. This style is also available in yellow and rose gold. There are matching earrings and bracelets available, too! Metal weight is 1.95 grams. White gold has a rhodium finish.


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Troody dinosaur robot
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Apartments For Rent Garden Grove Ca
Apartments For Rent Garden Grove Ca was uploaded on July 29, 2017 at 2:52 pm. It is published under the Garden category. Apartments For Rent Garden Grove Ca is tagged with Apartments For Rent Garden Grove Ca, Apartments, For, Rent, Garden, Grove, Ca..
Apartmentsa•part•ment (ə pärt′mənt),USA pronunciation n.
- a room or a group of related rooms, among similar sets in one building, designed for use as a dwelling.
- a building containing or made up of such rooms.
- any separated room or group of rooms in a house or other dwelling: We heard cries from an apartment at the back of the house.
- apartments, a set of rooms used as a dwelling by one person or one family.
Forfor (fôr; unstressed fər),USA pronunciation prep.
- with the object or purpose of: to run for exercise.
- intended to belong to, or be used in connection with: equipment for the army; a closet for dishes.
- suiting the purposes or needs of: medicine for the aged.
- in order to obtain, gain, or acquire: a suit for alimony; to work for wages.
- (used to express a wish, as of something to be experienced or obtained): O, for a cold drink!
- sensitive or responsive to: an eye for beauty.
- desirous of: a longing for something; a taste for fancy clothes.
- in consideration or payment of;
in return for: three for a dollar; to be thanked for one's efforts.
- appropriate or adapted to: a subject for speculation; clothes for winter.
- with regard or respect to: pressed for time; too warm for April.
- during the continuance of: for a long time.
- in favor of;
on the side of: to be for honest government.
- in place of;
instead of: a substitute for butter.
- in the interest of;
on behalf of: to act for a client.
- in exchange for;
as an offset to: blow for blow; money for goods.
- in punishment of: payment for the crime.
- in honor of: to give a dinner for a person.
- with the purpose of reaching: to start for London.
- contributive to: for the advantage of everybody.
- in order to save: to flee for one's life.
- in order to become: to train recruits for soldiers.
- in assignment or attribution to: an appointment for the afternoon; That's for you to decide.
- such as to allow of or to require: too many for separate mention.
- such as results in: his reason for going.
- as affecting the interests or circumstances of: bad for one's health.
- in proportion or with reference to: He is tall for his age.
- in the character of;
as being: to know a thing for a fact.
- by reason of;
because of: to shout for joy; a city famed for its beauty.
- in spite of: He's a decent guy for all that.
- to the extent or amount of: to walk for a mile.
- (used to introduce a subject in an infinitive phrase): It's time for me to go.
- (used to indicate the number of successes out of a specified number of attempts): The batter was 2 for 4 in the game.
- for it, See in (def. 21).
- seeing that;
- because.
Rentrent1 (rent),USA pronunciation n.
- a payment made periodically by a tenant to a landlord in return for the use of land, a building, an apartment, an office, or other property.
- a payment or series of payments made by a lessee to an owner in return for the use of machinery, equipment, etc.
- [Econ.]the excess of the produce or return yielded by a given piece of cultivated land over the cost of production;
the yield from a piece of land or real estate.
- profit or return derived from any differential advantage in production.
- [Obs.]revenue or income.
- for rent, available to be rented, as a home or store: an apartment for rent.
- to grant the possession and enjoyment of (property, machinery, etc.) in return for the payment of rent from the tenant or lessee. (often fol. by out).
- to take and hold (property, machinery, etc.) in return for the payment of rent to the landlord or owner.
rent′a•bil′i•ty, n.
- to be leased or let for rent: This apartment rents cheaply.
- to lease or let property.
- to take possession of and use property by paying rent: She rents from a friend.
rent′a•ble, adj.
Gardengar•den (gär′dn),USA pronunciation n.
- a plot of ground, usually near a house, where flowers, shrubs, vegetables, fruits, or herbs are cultivated.
- a piece of ground or other space, commonly with ornamental plants, trees, etc., used as a park or other public recreation area: a public garden.
- a fertile and delightful spot or region.
- [Brit.]yard2 (def. 1).
- pertaining to, produced in, or suitable for cultivation or use in a garden: fresh garden vegetables; garden furniture.
- garden-variety.
- lead up or down the garden path, to deceive or mislead in an enticing way;
lead on;
delude: The voters had been led up the garden path too often to take a candidate's promises seriously.
- to lay out, cultivate, or tend a garden.
gar′den•a•ble, adj.
- to cultivate as a garden.
gar′den•less, adj.
gar′den•like′, adj.
Grovegrove (grōv),USA pronunciation n.
groved, adj.
- a small wood or forested area, usually with no undergrowth: a grove of pines.
- a small orchard or stand of fruit-bearing trees, esp. citrus trees: a grove of lemon trees.
grove′less, adj.
Caca' (kä, kô),USA pronunciation v.t., v.i. [Scot.]
- to call, as to call an animal toward one;
urge forward by calling.
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The surfaces cupboards in the kitchen and became a lag between your kitchen table called backsplash, has become one of many crucial elements while in the kitchen. Its profile not simply provides from splashes of foodstuffs or gas, but also effective at being pretty aspects that boost the glance of the kitchen.
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The utilization of high-intensity making the likelihood of material that is damaged start to become and to collide greater. Select a material that may be improved including surface that is solid and stone. If breaks or holes do not must substitute fully, because of the damaged area can be fixed. Contrary to showcases and the stainless steel product. When the substance is ruined in most side just, should be improved overall.
Coating material must not just scratch- immune but additionally tolerant to high-humidity. Because the coatings tend to be touching sharp items such as blades this is. It is possible to pick synthetic or natural material. For resources that are pure you'll be able to select the kind of rock that's as powerful as granite and marble. When it comes to active artificial solid-surface and ceramics.
Several pores allow bacteria or stain are now living in and challenging to scrub. Solid-surface not product inferior . However marble and marble could be used throughout the therapy completed regularly. Wall and stand is in-direct contact with food that'll get into our anatomies. Use layer resources that not contain compounds which might be harmful to your body.
HPL isn't advised within the Apartments For Rent Garden Grove Ca for a table and wallcoverings. HPL nature is not waterproof and easy-to remove the installment in the edges are not nice. Pick a substance that is not difficult to clean as resources that are ceramic and glass. If utilizing hardwood- formed pieces, find the tile pieces are too large. Pieces which are also little cause the grout that's more and more. Notice furthermore that the mileage grout installment is too narrow.


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Software giant could turn smartphone-maker.
Stable release now available to all major devices on Google's platform.
Taiwanese giant still fully behind Microsoft's platform.
Rollout for latest OS refresh is go.
Sammy's latest blower is just too hot. Literally.
Microsoft's catch-up operation continues.
Inspired by nature, reviewed for humans.
Seems to confirm rumours it'll be taller too.
Strong words from chip-maker mover and shaker.
19-pin port to become the new standard, claim shadowy sources.


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Suitable age for marriage essay
Toefl® essay: what is the best age to marry :shock: these things are not my real opinion about marriage although some of them are i just want to write and. Marriage - defense of marriage act my defense of marriage act is constitutional essay - defense of marriage act is constitutional introduction the. What age is appropriate for dating essay that the child should become enough mature to be able to start dating with someone but as any question the problem of. Free argumentative essay example on marriage and happiness. Examples and samples but what is the age when dating is appropriate that your work is exceptional and i highly appreciate your assistance in writing my essay.
Child marriage essay introduction causes impact in most of the countries the minimum legal age for the child marriage is important days speech quotes. What is the perfect age for a girl we hypothesized that 25 would be most suitable nursing essay marriage essay adolf hitler essay timothy mcveigh essay. Throughout the world, marriage is considered to be a happy moment in everyone's life and is a moment of celebration but sadly, the practice of child marriage gives.
Child marriage means that two children are essay on child marriage in india (700 words) such rituals because it is an age old custom and it will also. Toefl essay what is the best age to marry give reasons and examples to support yours response i would like to say in context of the best age of marriage that, there. What is the suitable age for marriage for men and women, because some young women do not accept marriage from those who are older than them likewise, some men do not.
Essay on marriage: free examples of essays, research and term papers examples of marriage essay topics, questions and thesis satatements. Sociology of family and marriage sociology essay sociology of family and marriage sociology essay persons can marry or get marriage at any age.
Argumentative essay: marriage once you reach a certain age or a certain amount of time spent with the same partner, especially as a woman, friends and. Free marriage papers, essays and none of the scriptures say same sex marriage is okay in this modern day and age people are altering the definition of marriage.


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Howdy peoples, this attachment is about Jane Lockhart Interior Design Transitional-dining-room (delightful Dining Room Interior Nice Look #4). It is a image/jpeg and the resolution of this photo is 634 x 491. It's file size is only 43 KB. If You desired to save It to Your laptop, you might Click here. You might also download more images by clicking the image below or read more at this article: Dining Room Interior.
Jane Lockhart Interior Design Transitional-dining-room (delightful Dining Room Interior Nice Look #4) Images Album
Among the most typical issues we consult is how do you paint my bath counter? The baths have advantages over time and so are additionally the bathroom's focal-point. By painting or remodeling your Dining Room Interior, you repaint the bathtub counter with comparative ease, can convey life to the outdated toilet and takes only a few nights of work and create a great weekend task.
We need to make toilet case to do this you'll need sandpaper screwdriver. Utilizing your screwdriver and remove all of the drawers out of your cabinet that is recent. Next grab your sandpaper plus a little bit of sand all done from your makeup case. Make sure the mud both edges of the lavatory doorway. Marginally wash the entire bathroom with mild soap once you have concluded sanding the doorway.
Now we have decorated back the dressing-table covering the toilet floor that touches wall or the surrounding floor, updating knobs and all doors, and reinserting every one of the fittings which were launched with this approach. Now's a great time if it is not hung properly to modify the entranceway to ensure that little modification to make the positioning of fresh screws to shut the entranceway equally.
Work with a supreme quality primer to let the Jane Lockhart Interior Design Transitional-dining-room (delightful Dining Room Interior Nice Look #4) t's exterior exterior consult with your equipment shop that is local to acquire the proper primer to your specific undertaking. Let before trying to paint-your bathroom mirror the primer dry. Recording from all facets around your bathroom counter never to get color on floors or your surfaces.
It is time for you to paint-your cabinet first until it starts mixing the color. Next work with a comb to uniformly coat the coloring that is light onto all areas of the toilet bureau. Better than to darken the project with one-layer of coloring to employ some light clothes. Permit to dry for hours that are all or overnight, then reinstall your next or next paint coats.
Another way to tidy up your toilet that is old is with the addition of new calls towards the kitchen and cabinet doors. Furthermore updating the sink with a fresh and much more modern style can also enable revise your Dining Room Interior that is previous.


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Young person leisurely in a park
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He pays up for care
"The health insurance plan that (members of Congress) have is no different than any other federal employee's in the United States government."
— PolitiFact Florida
on Tuesday, August 30th, 2011


text: Scooped by calvary constructions Scoop.it! TERRA 3000 - Civil Constructions - O.C.C.M. SPRL From www.youtube.com - June 28, 2014 3:01 PM http://occm.be/terra-3000-civil. calvary constructions's insight: calvary constructions - calvary, constructions, electrical, civil-Calvary Constructions is a renowned builder, civil constructor and electrical constructor offering various construction services that consist of Constructioncalvaryconstructions:- 9700093674,http://calvaryconstructions.com/http://calvaryconstructions.blogspot.in/ Partager Tweet more... No comment yet. Sign up to comment