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The Constitution at a Crossroads
“It would, however, necessitate invalidation of the entire Affordable Care Act.” Brief of State Petitioners in Florida v. Department of Health and Human Services, arguing that the Supreme Court should strike down the Affordable Care Act in its entirety because, according to the states, the Act’s expansion of Medicaid is invalid under the Spending Clause This nation’s system of cooperative federalism –pursuant to which states and local governments work in partnership with the federal government in solving nationwide problems such as health care, environmental degradation and discrimination – is built upon the Constitution’s Spending Clause and rulings by the Supreme Court that allow the federal government to condition generous grants of federal money upon state and local participation in these national efforts. For this reason, the Supreme Court’s decision to review the claim by 26 states that the Patient Protection and Affordable Care Act (ACA) unconstitutionally coerced states into participating in the expansion of the federal/state Medicaid program was an unsettling surprise. In contrast to the claims against the ACA’s mandatory coverage provision, there was no split in lower court rulings on the constitutionality of the Medicaid expansion: not a single lower court judge ruled for the states on this claim. Indeed, no court has ever ruled that any Spending Clause statute runs afoul of the Supreme Court dictum that forms the basis of the states’ claim: “‘in some circumstances the financial inducement offered by Congress might be so coercive as to pass the point at which ‘pressure turns into compulsion.’” 1 So why did the Court decide to review this claim? Could this particular claim of coercion succeed where all others have failed and be the basis of a ruling by the Supreme Court striking down “the entire Affordable Care Act”? The Supreme Court will answer these momentous questions in the next few months. What is clear now is that the states, represented by former Solicitor General Paul Clement, have woven together an argument about coercion that is designed to appeal to the Court’s
South Dakota v. Dole, 483 U.S. 203, 211 (1987) (quoting Steward Machine Co. v. Davis, 301 U.S. 548, 589-90 (1937)).
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conservative majority and to capitalize on a sharp ideological split that has emerged on the Court over the past 15 years about the meaning of constitutional federalism and the scope of federal powers under the Spending Clause. As a result, in addition to being a critical test of the Supreme Court’s jurisprudence under the Commerce Clause, the ACA litigation will likely produce the most important Spending Clause ruling in several decades. Even if the Supreme Court, like every lower court, ultimately rejects the states’ coercion argument in this case, its ruling could make important new law on the ability of the federal government to use the Spending Clause to enlist states in federal-led efforts. With the state challenge to the ACA’s Medicaid expansion pending before the Court, the Spending Clause is very much at a crossroads.
The Text and History of the Spending Clause
Providing Congress with the power to tax and spend was of central importance to the drafters of our Constitution: they had witnessed the disastrous consequences of the Articles of Confederation’s failure to provide for such a power. Under the Articles, Congress had some powers, but was given no means to execute those powers. Congress could not directly tax individuals or legislate upon them; it could raise money only by making requests to the states. This created such an ineffectual central government that, according to George Washington, it nearly cost Americans victory in the Revolutionary War, and he lamented the dire situation in which his soldiers had been placed as a result of Congress’s inability to levy taxes to support the Army. 2 This historical foundation explains why the Spending Clause is the first and one of the most sweeping powers the Constitution confers upon Congress, providing the power “to lay and collect Taxes, Duties, Imposts and Excises, to pay the Debts and provide for the common Defense and general Welfare of the United States.” 3 As Alexander Hamilton made clear in the Federalist Papers, the power to tax and spend for the common defense and general welfare is “an indispensible ingredient in every Constitution,” 4 and it was essential for the Constitution to “embrace a provision for the support of the national civil list; for the payment of the national debts contracted, or that may be contracted; and, in general, for all those matters which will call for disbursements out of the national treasury.” 5 While the need for tax revenues was universally recognized by the signers of the Constitution, disputes broke out almost immediately about the precise meaning of the Spending Clause’s text. The most sweeping reading, posed by anti-Federalist opponents of the Constitution, argued that the Spending Clause “amounts to an unlimited commission to exercise every power which may be alleged to be necessary for the common defense or general welfare.” 6 Madison made short work of this unduly
See 18 THE WRITINGS OF GEORGE WASHINGTON 453 (John C. Fitzpatrick, ed. 1931) (Letter to Joseph Jones, May 31, 1780). See also WASHINGTON: WRITINGS 393 (John Rhodehamel, ed. 1997) (Circular to State Governments, Oct. 18, 1780); id. at 502-503 (Letter to Lund Washington, March 19, 1783). 3 U.S. CONST., art. I, § 8. 4 THE FEDERALIST PAPERS NO. 30 (Hamilton), at 134 5 Id. 6 THE FEDERALIST PAPERS NO. 41, at 259 (Madison). Crossroads: Spending Clause Page | 2
expansive interpretation of the clause in Federalist 41, asserting that “[n]o stronger proof could be given of the distress under which these writers labor for objections, than their stooping to such a misconstruction.” 7 A more serious disagreement broke out later between Madison and Hamilton about whether the power to tax and spend for the general national welfare was confined to the enumerated legislative fields delegated to Congress. While not endorsing the sweeping “every power” interpretation advanced by the anti-Federalists, when it came to taxation and spending, Hamilton interpreted the Spending Clause literally as a broad grant of authority to Congress to tax and spend for the general welfare. He declared in his important 1791 Report on Manufacturers that that the phrase “general welfare” was “as comprehensive as any that could have been used,” and it was deliberately chosen because “the constitutional authority of the Union, to appropriate its revenues . . . necessarily embraces a vast variety of particulars, which are susceptible neither of specification nor of definition.” 8 Madison resisted this literal interpretation. Most definitively in a series of letters written towards the end of his career, Madison took the position that the Spending Clause was essentially a preamble to the other enumerated powers and not an independent grant of authority. In an 1830 letter to Andrew Stevenson, 9 he described the Spending Clause as “a mere introduction to the enumerated powers, and restricted to them.” The next year, in a letter to James Stephenson, 10 Madison added that “with respect to the words ‘general welfare,’ I have always regarded them as qualified by the detail of powers connected with them. To take them in a literal and unlimited sense would be a metamorphosis of the Constitution into a character which there is a host of proofs was not contemplated by its creators.”
The Spending Clause from the New Deal to South Dakota v. Dole
The Supreme Court ultimately resolved this disagreement among these two preeminent Founders, and set the basic principles of its Spending Clause jurisprudence, during the New Deal era, when the Court was confronted with important new federal spending programs established to respond to the Great Depression. In the first of these cases, United States v. Butler, 11 the Court determined that Hamilton’s interpretation was the only one that matched the text of the Spending Clause. Noting that this dispute had previously been addressed by Justice Joseph Story, who “in his Commentaries, espouses the
Id. Alexander Hamilton, Report on Manufactures, December 5, 1791, available at http://presspubs.uchicago.edu/founders/documents/a1_8_1s21.html. 9 James Madison, Supplement to November 27, 1830 Letter to Andrew Stevenson, available at http://presspubs.uchicago.edu/founders/documents/a1_8_1s27.html. 10 Letter from James Madison to James Robertson, April 20, 1831, available at http://en.wikisource.org/wiki/ James_Madison_letter_to_James_ Robertson. 11 297 U.S. 1 (1936) Crossroads: Spending Clause Page | 3
Hamiltonian Position,” 12 the Court in Butler agreed: “We shall not review the writings of public men and commentators or discuss the legislative practice. Study of all these leads us to conclude that the reading advocated by Mr. Justice Story is the correct one.” 13 The problem with Madison’s position, according to Butler, was that it could not be squared with the Constitution’s enacted text: “[t]he necessary implication from the terms of the grant is that the public funds may be appropriated ‘to provide for the general welfare of the United States.’” 14 Madison’s position, on the other hand, would make the Spending Clause “mere tautology, for taxation and appropriation are or may be necessary incidents of the exercise of any of the enumerated legislative powers.” 15 Accordingly, Butler held that “the power of Congress to authorize expenditure of public moneys for public purposes is not limited by the direct grants of legislative power found in the Constitution.” 16 There was no dissent on any of these important points. 17 The Court built upon Butler in two important decisions the following year upholding different components of the Social Security Act of 1935. In Helvering v. Davis, 18 the Court upheld the Act’s most famous component – the taxing of individuals and employers to provide for retirement security benefits for elderly Americans. The Helvering Court began by reaffirming the Butler Court’s resolution of the dispute between Madison and Hamilton, declaring this dispute “settled by decision.” 19 Helvering then established a broadly deferential standard for reviewing congressional decisions about the general welfare, holding that “whether wisdom or unwisdom resides in the scheme of benefits set forth in Title II it is not for us to say. The answer to such inquiries must come from Congress, not the courts.” 20 In Steward Machine v. Davis, 21 the Court upheld the Act’s unemployment compensation program. Unlike the federally-run Social Security program at issue in Helvering, the Act’s unemployment benefits program created a federal/state partnership. The federal government collected taxes from employers and then allocated up to 90% of those revenues back to states with unemployment compensation laws meeting minimum federal standards. The Steward Machine Court rejected the argument that the “tax and the credit in combination are weapons of coercion, destroying or impairing the autonomy of the states.” 22 The Court held that the Social Security Act, rather than harming states, “is an attempt to find a method by which all these public agencies may work together to a common end.” 23
Id. at 66. Id. 14 Id. at 65. 15 Id. 16 Id. 17 See id. at 80-81 (Stone, J., dissenting). 18 301 U.S. 619 (1937). 19 Id. at 640. 20 Id. at 644. 21 301 U.S. 548 (1937). 22 Id. at 586. 23 Id. at 588. Crossroads: Spending Clause Page | 4
In embracing the federal/state partnership to provide unemployment compensation, the Court in Steward came very close to rejecting altogether the idea that a condition on federal spending could ever be coercive, noting that “every rebate from a tax when conditioned upon conduct is in some measure a temptation” and “to hold that motive or temptation is equivalent to coercion is to plunge the law in endless difficulties.” 24 The Court wondered aloud whether the notion of coercion “can ever be applied with fitness to the relations between state and nation,” and concluded that even if it could, “the point at which pressure turns into compulsion” had not been reached with the Social Security Act. 25 The central holdings of these New Deal era cases -- Butler’s resolution of the Hamilton/ Madison debate in Hamilton’s favor, Helvering’s deference to Congress, Steward Machine’s skepticism about claims of coercion -- remain core principles of Spending Clause doctrine today. Indeed, the Court reaffirmed each of these principles in South Dakota v. Dole, 26 the leading Spending Clause case of the modern era, which was written by Chief Justice William Rehnquist and joined by Justices as ideologically diverse as John Paul Stevens and Antonin Scalia. Building upon Steward Machine and other prior cases, the Dole Court held that “Congress may attach conditions on the receipt of federal funds, and has repeatedly employed the power ‘to further broad policy objectives by conditioning the receipt of federal moneys upon compliance with federal statutory and administrative directives.’” 27 The Dole Court also recognized four limits on the Spending Clause. First, the text of the Constitution expressly limits Congress’s spending power to the pursuit of “the general Welfare.” 28 Second, any conditions Congress places on grants to the States must be clear, thus enabling “the States to exercise their choice knowingly, cognizant of the consequences of their participation.” 29 Third, “conditions on federal grants might be illegitimate if they are unrelated ‘to the federal interest in particular national projects or programs.’” 30 Finally, “other constitutional provisions may provide an independent bar to the conditional grant of federal funds” 31 — Congress may “not ‘induce’ the recipient to ‘engage in activities that would themselves be unconstitutional.’” 32
The Rehnquist Court’s Federalism Revolution and the Spending Clause
The Court’s opinion in South Dakota v. Dole remains the touchstone of its Spending Clause jurisprudence, but the ideological consensus about the Spending Clause embodied in the Dole opinion has broken down considerably. In particular, over the past 15 years, as part of a significant jurisprudential movement by conservatives on the Court toward limiting the powers of the federal government in the name of protecting state sovereignty, the Court’s conservative wing has expressed
Id. at 589. Id. at 590. 26 483 U.S. 203 (1987). 27 Id. at 206. 28 U.S. CONST. art. I, § 8; Dole, 483 U.S. at 207. 29 Pennhurst State Sch. & Hosp. v. Halderman, 451 U.S. 1, 17 (1981). 30 Dole, 483 U.S. at 207 (citation omitted). 31 Id. at 208. 32 United States v. Am. Library Ass’n, Inc., 539 U.S. 194, 203 (2003) (plurality) (quoting Dole, 483 U.S. at 210). Crossroads: Spending Clause Page | 5
concerns about Butler’s reading of the Spending Clause and used those concerns to ratchet up the limits recognized by Dole, particularly the requirement that states have “clear notice” about Spending Clause conditions. This ideological divide is illustrated most clearly in Davis v. Monroe County, 33 a case about whether a school district that received federal funds could be held liable in a private suit for “deliberate indifference” to student-on-student sexual harassment. In an opinion by the Court joined by the Court’s liberal wing, Justice Sandra Day O’Connor held that, in limited circumstances, such a suit was authorized. Applying Dole’s clear notice requirement, the Court ruled that Title IX of the Education Amendments of 1972 “makes clear that, whatever else it prohibits, students must not be denied access to educational benefits and opportunities on the basis of gender.” 34 Therefore, according to the majority, “funding recipients are properly held liable in damages only where they are deliberately indifferent to sexual harassment . . .” 35 Justice Kennedy responded in a sharply worded dissent, writing also on behalf of Chief Justice Rehnquist and Justices Scalia and Thomas. Kennedy’s dissent began by expressing concern about Butler’s account of the scope of the federal government’s powers under the Commerce Clause: The Court has held that Congress’ power “‘to authorize expenditure of public moneys for public purposes is not limited by the direct grants of legislative power found in the Constitution.’ ” South Dakota v. Dole, 483 U.S. 203, 207 (1987) (quoting United States v. Butler, 297 U.S. 1, 66 (1936)). As a consequence, Congress can use its Spending Clause power to pursue objectives outside of “Article I’s ‘enumerated legislative fields’” by attaching conditions to the grant of federal funds. 483 U.S., at 207. So understood, the Spending Clause power, if wielded without concern for the federal balance, has the potential to obliterate distinctions between national and local spheres of interest and power by permitting the federal government to set policy in the most sensitive areas of traditional state concern, areas which otherwise would lie outside its reach. 36 To avoid “obliterate[ing] distinctions between national and local spheres of interest,” Justice Kennedy emphasized the need to rigorously enforce the clear notice requirement recognized in Dole. 37 The clear notice requirement, he opined, “is not based upon some abstract notion of contractual fairness. Rather, it is a concrete safeguard in the federal system. Only if States receive clear notice of the conditions attached to federal funds can they guard against excessive federal intrusion into state affairs and be vigilant in policing the boundaries of federal power.” 38
526 U.S. 629 (1999). Id. at 650. 35 Id. 36 Id. at 654 (Kennedy, J., dissenting) (emphasis added). 37 Id. 38 Id. at 655. Crossroads: Spending Clause Page | 6
Monroe County was decided during a decade-long period lasting roughly from 1992 to 2002, which has been called the “federalism revolution” of the Supreme Court under Chief Justice William Rehnquist. It is one of the few cases lost by state and local claimants during this time. . In many other cases, Justice O’Connor sided with the conservative wing in taking steps to police “the boundaries of federal power.” These cases included U.S. v. Lopez 39 and U.S. v. Morrison, 40 in which the Court invalidated two federal laws as beyond Congress’s Commerce Clause authority, New York v. United States 41 and Printz v. United States, 42 in which the Court established an “anti-commandeering principle” that prevented the federal government from directing state officials to administer a federal regulatory program, and a long string of cases including College Savings Bank v. Florida Prepaid Postsecondary Education Expense Board, 43 in which the Court significantly limited the ability of the federal government to trump the sovereign immunity of States under the 11th Amendment. Printz deserves special note among these cases, because it forms a central pillar of the coercion claim against the Affordable Care Act. The states argue that “[i]f Congress were free to use its spending power to coerce States into enforcing the federal government’s dictates, then the spending power would become the exception that swallows the anti-commandeering rule.” 44 Printz is also notable for the effort by Justice Scalia to question anyone (or any opinion) that looks toward the views of Alexander Hamilton when it comes to “matters of federalism.” Calling Hamilton the “most nationalistic of all nationalists,” Scalia in Printz declared that “it was Madison’s view – not Hamilton’s – that prevailed . . .“ 45 Although Justice Scalia did not cite Butler, his implicit critique of the Butler Court for favoring Hamilton’s view of the Spending Clause over Madison’s was apparent enough. The state challengers to the ACA have also relied on Florida Prepaid because, in passing, the Court in that case took language from Steward Machine and Dole – cases that recognized that the point at which “pressure turns into compulsion” may never be “applied with fitness to the relationship between state and nation” – and subtly turned that language into a more definitive-sounding suggestion that there is such a line that the federal government cannot cross. 46
Arlington Central and the Spending Clause in the Roberts Court
With Justice Samuel Alito having succeeded Justice O’Connor (the author of the majority opinion in Monroe County), there is some evidence that the concerns expressed by Justice Kennedy in
514 U.S. 549 (1995). 529 U.S. 598 (2000). 41 488 U.S. 1041 (1992). 42 521 U.S. 898 (1997). 43 527 U.S. 666 (1999). 44 State Petr. Br. at 21. 45 Printz, 521 U.S. n.9. 46 See Florida Prepaid, 527 U.S. at 687 (1999)(“in cases involving conditions attached to federal funding, we have acknowledged that “the financial inducement offered by Congress might be so coercive as to pass the point at which ‘pressure turns into compulsion.’” quoting South Dakota v. Dole, 483 U.S. 203, 211 (1987), quoting Steward Machine, 301 U.S. at 590). Crossroads: Spending Clause Page | 7
his Monroe County dissent may now be held by a five-justice majority on the Court. In the first and, to date, the only Spending Clause case decided by the Roberts Court, Arlington Central School District v. Murphy, 47 Justice Alito wrote the majority opinion, joined by Chief Justice Roberts and Justices Scalia, Thomas and Kennedy, holding that parents who successfully challenge a school board placement decision under the Individuals with Disabilities Education Act (IDEA) cannot recover the costs of retaining expert witnesses to support their claim. Justice Alito opined that the IDEA failed Dole’s “clear notice” test, despite a congressional Conference Report on the IDEA stating, in part: “the term ‘attorneys’ fees as part of the costs’ include reasonable expenses and fees of expert witnesses. . .” 48 In Justice Alito’s words: “the legislative history is simply not enough. In a Spending Clause case, the key is not what a majority of the Members of both Houses intend but what the States are clearly told regarding the conditions that go along with the acceptance of those funds.” 49 This conclusion brought a blistering dissent from Justice Breyer, who asserted that none of the Court’s prior rulings “suggest that every spending detail of a Spending Clause statute must be spelled out with unusual clarity.” 50 Justice Breyer accused the majority of abusing the clear notice test to disregard the clear intent of Congress regarding the meaning of the IDEA and thereby reach “a result no Member of Congress expected or overtly desired.” 51 More generally, Justice Breyer warned that the majority’s application of the clear notice rule was thereby undermining the deference due to Congress established by cases going back to Helvering v. Davis and risked creating “a set of judicial interpretations that can prevent the program, overall, from achieving its basic objectives or that might well reduce a program in its details to incoherence.” 52
Coercion, Commandeering and the ACA Litigation
The foregoing account of the historical evolution of Spending Clause doctrine sets the stage for the constitutional challenge brought by a collection of states against the Affordable Care Act’s expansion of the federal/state partnership under Medicaid. Under Supreme Court case law from Butler to Dole, the claims against the ACA are clear losers, which is why even the most sympathetic lower court judges have rejected them. The states have not even attempted to assert that any of the four limitations on the Spending Clause recognized by the Court in South Dakota v. Dole have been violated. To the contrary, as the states have conceded, the ACA is completely clear in terms of notifying states about what is expected if they wish to continue to participate in the Medicaid program. Nor is there any question that the Act provides a generous financial incentive for the states to continue to
548 U.S. 291 (2006). H. R. Conf. Rep. 99–687, at 5. 49 Arlington, 548 U.S. at 304. 50 Id. at 317 (Breyer, J., dissenting). 51 Id. at 324. 52 Id. at 318. Crossroads: Spending Clause Page | 8
participate in the federal program – under the Act’s terms, the federal government will start by paying 100 percent of the costs of adding additional low income Americans. In essence, the states’ principle claim is that the ACA offers too generous a deal to the States: one they cannot afford to refuse: There is no plausible argument that a State could afford to turn down such a massive federal inducement, particularly when doing so would mean assuming the full burden of covering its neediest residents’ medical costs, even as billions of federal tax dollars extracted from the State’s residents would continue to fill federal coffers to fund Medicaid in the other 49 States. 53 To succeed in this challenge to the ACA, the states must convince the Court to do what the Court in Steward Machine essentially deemed impossible – draw and enforce a line between appropriate financial pressure and unconstitutional coercion. The states call “a judicially enforceable” coercion doctrine “a constitutional necessity,” fusing together the concern Justice Kennedy expressed in Monroe County about the breadth of the Spending Clause with the “anticommandeering” rule established in Printz to argue that the Court must police coercion so that the spending power does not “become the exception that swallows the anti-commandeering rule.” The United States has responded that “Petitioners challenge to the Act’s Medicaid expansion lacks any support in this Court’s precedents, invites standardless decisionmaking and intractable problems of administration, and is wrong as a matter of constitutional principle.” 54 The U.S. makes powerful arguments in its briefs to support each of these propositions, which prevailed in the lower courts, even among judges who found the ACA’s mandatory coverage provision unconstitutional. Most of these arguments were presented to the Supreme Court in an effort to convince the Court not to review these Spending Clause claims. So the question is whether the Court took these cases anyway simply to hear all the claims against the ACA in a single sitting or whether the conservative wing of the Court is poised and ready to strike out in a bold new direction and impose significant new limitations upon the federal government’s exercise of its Spending Clause authority.
The Spending Clause at a Crossroads
With the Spending Clause challenges to the Affordable Care Act pending before the Supreme Court, the Spending Clause is very much at a crossroads. Even if the Court rejects the states’ argument and reaffirms the Butler/Steward Machine/Dole Spending Clause framework, the ideological fights that have played out in cases like Monroe County and Arlington Central will certainly continue. These statutory fights draw
State Petr. Br. at 20. Brief for Respondents (Medicaid) at 15, Florida v. DHHS (11-400). Page | 9
Crossroads: Spending Clause
less attention, but, as commentators such as Simon Lazarus have explained, 55 the conservative wing of the Supreme Court has succeeded in significantly narrowing the reach and crippling the enforceability of many important federal laws through the use of sub-constitutional tests such as the “clear notice” rule. The more important question is what happens if a majority of the Court accepts the states’ invitation to impose new curbs on Congress’ spending. If successful, these claims could bring down the Affordable Care Act, to date the most significant legislative accomplishment of the Obama presidency. This would be an enormously significant ruling even if the Court somehow limited its ruling only to that. But that seems unlikely; one of the most powerful points made by the United States is that the expansion of Medicaid under the ACA is essentially indistinguishable from prior expansions of Medicaid and other Spending Clause statutes. A ruling in favor of the States could thus call into question a myriad of conditions on federal spending and a large number of state-administered programs that are federally funded and supervised. 56 In his dissent in Barnes v. Gorman 57 – a Spending Clause case decided between Monroe County and Arlington Central -- Justice John Paul Stevens described Justice Scalia, the author of the majority opinion in Barnes, and his conservative colleagues, as “fearless crusaders” because of their willingness to embrace changes to Spending Clause doctrine that could have “potentially far-reaching consequences that go well beyond the issues briefed and argued in this case.” 58 The resolution of the ACA case will test the accuracy of Justice Stevens’ description. If the Court’s conservative majority accepts the states’ invitation to revisit Spending Clause principles that have been in place since the New Deal, we will in fact be living in a brave new world, where settled understandings about the Spending Clause and the federal balance are settled no more.
Simon Lazarus, Stripping the Gears of National Government: Justice Stevens' Stand Against Judicial Subversion of Progressive Laws and Lawmaking (September 29, 2011). Northwestern University Law Review, Forthcoming. Available at SSRN: http://ssrn.com/abstract=1935952. 56 See Brief of David Satcher et al. as Amici Curiae Supporting Respondents, Florida v. DHHS (No. 11-400) at 8-10 (discussing threats to federal spending programs involving education, jails and prisons, child welfare, vocational rehabilitation, and child support enforcement. See also Brief of Senate Majority Leader Harry Reid, House Democratic Leader Nancy Pelosi et al. as Amici Curiae Supporting Respondents, Florida v. DHHS (No. 11-400) at 3435 (mentioning similar threats to federal spending programs including conservative statutes such as the Solomon Amendment, which effectively provides military recruiters with equal access to educational institutions, and the No Taxpayer Funding for Abortion Act, which would cut federal funding for health-benefit plans that cover abortion). 57 536 U.S. 181 (2002) (Stevens, J., dissenting). 58 Id. at 192. Crossroads: Spending Clause Page | 10
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Two men arrested earlier this month for planning a mass shooting at a Fourth of July fireworks celebration in Richmond, Virginia were illegal immigrants, according to a report from the Washington Free Beacon.
U.S. companies borrowed 3 percent less in December to finance their investments in equipment, the Equipment Leasing and Finance Association (ELFA) said on Tuesday, as inflation and Omicron cloud economic outlook.
This article addresses the issue of how state legislators can fulfill their constitutional duty to better ensure fair and honest elections at polling places. While the discussion uses Georgia as an example, the recommendations apply to other states where there has been a substantial loss of public trust in the election process.
The Delta variant is keeping more companies cautious about how to invest the mountains of cash they have at their disposal. That hesitancy has led, in part, to corporate spending on stock buybacks outpacing capital expenditures this year.
U.S. technology companies are still supplying China’s surveillance state with equipment and software for monitoring populations and censoring information, including in the Xinjiang region, despite damning revelations that have led to genocide accusations against Beijing, according to researchers.
Companies that do business in Texas have signed a statement opposing two bills that would ban boys who identify as female from competing in girls' sports and ban the use of experimental puberty blockers, cross-sex hormones and the genital mutilation of minors suffering from gender dysphoria.


text:
Festive and beautifully unique, these porcelain ornaments feature the original artwork, "Trees of Hope." The round is 3” in diameter and printed in full color on one side.
Create the perfect gift bundle by adding these co-ordinating items:
I can't wait for you to enjoy this ornament!
All ornaments are made to order, custom artwork feature available upon request.
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Made in the USA
Type: ornament (studio)

domain: artistic


text:
I'm delighted to be one of today's stop on the blog tour for The Promise by Michelle Vernal. Despite having never read anything by this author before, as soon as I read the blurb I knew that it sounded like a book that I would enjoy, I just didn't realise how much.
Isabel Stark is back-packing in New Zealand when she witnesses a car accident. Before the car's only occupant, Ginny Havelock, takes her last breath she makes Isabel promise to pass on a message to someone she refers to only as Constance. Feeling a sense of duty along with a mild dose of curiosity, Isabel attends Ginny's funeral before heading back home to the UK.
Once she's home, she can't get Ginny and the promise she made her out of her head so she decides to see if she can track down Constance. She knows that it's a long shot but she's determined to try so, armed with the information she gleaned at Ginny's funeral, she head's off to the Isle of Wight.
Isabel's journey to find Constance is a beautifully written and touching tale that slips back in time to a love story set in World War Two cleverly combined with Isabel's own journey of self-discovery. The author did a brilliant job of highlighting how lonely the elderly can be and how easily this problem can be resolved with a little companionship and care. I think Constance was my favourite character overall, she was vibrant and forthright despite having a very sad tale to tell.
I fell in love with the characters in this wonderful book, they were written so well that they felt real and I was totally invested in their story. I'm a huge fan of dual-time novels and this one was exceptional. I've been to the Isle of Wight a few times over the years and the descriptions of the island transported me right back there, complete with the smell of the sea air.
The Promise is an uplifting and touching story that I didn't want to end and I will definitely be hunting down Michelle Vernal's other books to read in the future.
|Photo courtesy of Michelle Vernal|
Michelle Vernal is a Harper Collins author who loves a happy ending. She lives with her husband, their two boys and a needy three-legged black cat in Christchurch, New Zealand. She’s partial to a glass of wine, loves a cheese scone and has recently taken up yoga—a sight to behold indeed. She is a freelance writer for a Canterbury lifestyle magazine who is currently working on her seventh novel. Michelle’s a firm believer in happy endings, and all of her stories are written with humour and warmth.
You can find out more about Michelle, her books and connect with her using the links below:
You can also check out the other fantastic blogs on the tour
With kind thanks to Rachel at Rachel's Random Resources for my review copy and my slot on the blog tour.

domain: literature


There are some updates to watch for. Even reaching the mainstream press, the Java bug can affect systems running Snow Leopard (10.6) or later, making the Mac vulnerable to malware that may be encountered on a dodgy web page. It does not affect systems running 10.5 or older. To protect yourself, open Software Update and run any Security Updates and any Java Updates it offers.
Then open Safari's Preferences, Security button, and uncheck the box for Enable Java. You probably won't even miss it as legitimate sites that use it are dwindling in number. Should you visit a trusted site and it wants to use Java, just go back to Preferences, enable Java, then reload the page. Disable it when you are done.
In Chrome, there is no option to enable or disable it. Java version 7 is not compatible with Chrome, so if you have not deliberately installed the older Version 6 there is no Java running in Chrome. To find out how to do this, and read why it isn't a good idea, visit Apple's KB article.
In Firefox, go to the Tools menu and choose Add-Ons. When the window opens click the tab on the left called Plug-Ins. Look for Java Applet Plug-In in the list and click the Disable button. Reverse the process to enable it.
Another known weakness is in Adobe Flash. Safari disables older versions of it as soon as newer ones are released, so if your web page shows Disabled Plug-in instead of the video page you requested, click on those words to take you to Adobe and download and install the newest version. Systems older than 10.6 can't use the newest version so you may not be able to view some video pages. This is especially true in Tiger 10.4.11 or older. Adobe updates several times a year, so be sure to accept and install those updates. YouTube no longer requires Flash, but an awful lot of sites (such as FailBlog on the Cheezeburger Network) do use it so you can't give it up entirely.
Mountain Lion Crash Bug
There is a strange "Assertion bug" that will crash any app running under OSX 10.8.2. Mail, Safari, Messages, TextEdit, all of them. All you have to do is type File (with a capital F) followed by colon and 3 slashes - :///.
Don't do that. Goes boom every time. If you enjoy the gory details, they are at this CNet page. Some people have suggested it as a Mac Prank by sending the string from the Messages app on any smart phone to a Mac. Not only will it crash the Messages program upon receipt, it's archived so it will re-crash every time it's launched. To clear it out, follow these instructions.
The newest iMacs
I have now had some experience setting up both the 21.5" and the 27" models. As I reported previously, the smaller of the two is seriously constrained by the slow hard drive. However, Apple now offers the option of getting the Fusion drive in that model as well as the 27". If you are interested in that iMac, absolutely spring for the Fusion drive. The technology combines a 1-Tb or larger drive with a 128 Gb Solid State drive. The system software and your most-used applications are located on the SSD part of the system, and relocated to the mechanical part of the drive if you start using a different app more often.
To the user, it all looks like just one drive. You do not have to do anything to manage it. So all that remains as a problem with the new iMacs is the lack of an internal CD/DVD SuperDrive and the lack of a FireWire port. Both Macs have two Thunderbolt ports, so for $29 you can buy a T-Bolt to FireWire adapter and keep using your old external drives. The other port can be used as a video port for a 2nd monitor with a T-Bolt to DVI adapter, but very few Mac users need a second display with such a big screen as their primary.
iTunes 11; Mac Power Users
The newest iTunes is just short of a (needed) complete rewrite of the program. It has taken on so many non-music-related duties over the years that it has become a bloated mess. Unfortunately a few features have not made it into the new version, but overall it is easier to work with once you learn the new ways.
My favorite podcast and web site for all things Mac is called Mac Power Users. It's designed to help people become more proficient, rather than just focusing on the highly experienced. I subscribe to the show through iTunes in the Podcast section, then I put it on the iPod that lives in my car. If you do a lot of driving it's a great way to listen and learn, but there is no reason you can't just play it through your Mac.
The web page that supports the show is here (this episode that focuses on iTunes) and you can get the back catalog on iTunes and the web page for articles that support the information you hear. I highly recommend this show.


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Ertan gave an invited talk entitled “Toward High Performance Redox Flow Batteries for Grid-Scale Energy Storage” in the Graduate Seminar Series of the Mechanical and Energy Engineering at Indiana University Purdue University Indianapolis.
Ertan gave a presentation on the non-aqueous redox flow battery project at the I Meeting on Electrochemical Energy Conversion and Storage Devices organized by the University Carlos III of Madrid.
Ceren and Ertan publish a paper in collaboration with Cappillino and Mayes Groups from UMass Dartmouth entitled “Designing high energy density flow batteries by tuning active-material thermodynamics” in RSC Advances. Congrats!!!

domain: chemistry


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Showcase Sunday's aim is to showcase our newest books or book related swag and to see what everyone else received for review, borrowed from libraries, bought in bookshops and downloaded onto eReaders this week. This Sunday meme is hosted by Book, Biscuits and Tea. Click the link to find out how to join in.
Some books may not be free now
1. Glimmer by Amber Garza
2. Soul Protector by Amanda Leigh Cowley
3. Sweet Venom by Tera Lynn Childs
4. A Soul for Trouble by Crista McHugh
5. The Huntress by Dorothy McFalls
And a few MORE...
1. A Conspiracy of Alchemists by Liesel Schwarz (Edelweiss)
2. The Clover House by Henriette Lazaridis Power(Edelweiss)
Thanks to Random House for providing me with e-ARC copies.
I also participated on:
Dominus by Christine Fonseca
Timeless by Diana Paz
Beguiled by RaShelle Workman
And along with my "unnies" started a drama watching challenge
There's also a giveaway which will end on December 20th
Frost Fire Giveaway
*Clicking on the covers will direct to you their book page on Goodreads.

domain: library


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Other News 9 September 22:36
United Nations Secretary General Ban Ki-moon has condemned North Korea’s latest nuclear test and called on the United Nations Security Council to take "appropriate action" in response of Pyongyang’s action undermining peace and security in the region
Other News 7 September 00:38
United Nations Secretary General Ban Ki-moon said Tuesday North Korea’s regular nuclear tests are a clear violation of the UN Security Council's resolutions, and called on Pyongyang to stop provocative actions and return to the path of nuclear disarmament, Ban’s spokesman Stephane Dujarric told journalists
Turkey 22 August 00:42
UN Secretary-General Ban Ki-moon on Sunday condemned the deadly blast that hit an outdoor wedding celebration in southeastern Turkey and killed at least 50 people
Turkey 27 July 22:41
Ban Ki-moon conveys solidarity with Turkey; expects adherence to international obligations in probe of coup attempt
Politics 20 July 18:15
UN Secretary-General Ban Ki-moon has commended Iran for implementing its nuclear-related commitments under the Joint Comprehensive Plan of Action, reached last year with world powers.
Other News 15 July 17:14
The UN Secretary-General Ban Ki-moon condemns the July 14 terrorist attack in Nice, France.
Other News 13 June 02:44
UN Secretary General Ban Ki-moon on Sunday condemned the deadly shooting at a Florida nightclub and expressed his solidarity with the US government and people.
Politics 28 May 19:35
Secretary-General of the United Nations Ban Ki-moon has sent a congratulatory letter to Azerbaijan's President Ilham Aliyev on the occasion of Republic Day
Turkey 23 May 12:24
UN Secretary General Ban Ki-moon has urged to cut the number of displaced people in half by 2030, and find better solution for refugees
Politics 26 April 11:22
Division and exclusion only play into the hands of the extremists, but what they really want to destroy is our common ground,

domain: news


A bill that would define life as starting at conception is dead for this year in Virginia.
The Senate voted 24-14 Thursday to send the so-called "personhood" bill back to committee and carry it over to 2013.
Senate Democratic Leader Richard Saslaw made the motion to shelve the bill, and Republican leader Tommy Norment supported it, saying more study is needed.
The vote came hours after the Senate Education and Health Committee endorsed the measure on an 8-7 party-line vote, with Democrats voting against it. At least three times, the committee chairman, Sen. Steve Martin, threatened to have police remove opponents of the bill after they spoke out during debate.
The committee earlier approved a bill requiring pre-abortion external ultrasound exams. It was amended to eliminate ultrasounds requiring an invasive ultrasound probe.


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By Jesse Marx
By Chris Parker
By Jake Rossen
By Jesse Marx
By Michelle LeBow
By Alleen Brown
By Maggie LaMaack
By CP Staff
Last month, Minneapolis Mayor R.T. Rybak and St. Paul Mayor Chris Coleman appeared together at the Nicollet Island pavilion to announce their respective cities' joint bid to host a national political convention in 2008. It was the type of affair a lot of politicians relish: a public nod to the business community, a little pomp, and—perhaps most significantly—no overt element of controversy. After all, a city that hosts a presidential nominating convention is ensured four days of packed hotels, thousands of hungry and thirsty out-of-towners eager to spend money, and the pleasing glow of the national spotlight. What's not to love?
At least, that's how Rybak, Coleman, and their fellow convention boosters seem to see it. "It's very important to the mayor to get one of these conventions," says Rybak spokesman Jeremy Hanson, who cites the "gigantic" economic benefit as the driving factor behind his boss's push to land either the Democratic or Republican convention. As evidence for this, Hanson—like Rybak— references the "economic boost" of some $150 million Boston purportedly reaped when it hosted the 2004 Democratic National Convention.
Such eye-popping numbers are often bandied about in discussions about the merits of hosting a national convention. But increasingly, more city leaders across the country are casting a jaundiced eye on conventions—largely because of rising security costs, business closures, traffic congestion, and other headaches that come with the spotlight. And in the post-9/11 environment, some economists and critics now say, it is an open question whether host cities even realize an economic benefit.
"There has been very little independent, objective study of that issue," notes Steve Weismann of the Campaign Finance Institute, a Washington D.C.-based nonprofit that advocates for campaign reform. In the case of the Boston convention, Weismann points out, a study conducted by the Beacon Hill Institute at Suffolk University concluded that various official estimates of the convention windfall—which range from $50 to $154 million—were grossly inflated. After taking into account costs (including both direct cash outlays for expenses such as policing, and more difficult-to-quantify losses caused by traffic congestion and temporary business closures), the institute's researchers calculated that Boston came out ahead by a much more modest $14 million.
While the particulars are subject to debate, one fact is undisputed. When the political parties come knocking these days, a growing number of cities are saying, "Thanks, but no thanks." In the case of the 2008 Democratic convention, for instance, the Democratic National Committee invited 35 cities to bid. Eleven cities expressed interest, but only four—including Minneapolis-St. Paul—submitted formal proposals. Just four of the 31 cities invited to bid for the Republican convention, meanwhile, actually delivered bids (again, including Minneapolis-St. Paul).
Why the fading interest? According to Jack Kyser, the chief economist for the Los Angeles County Economic Development Corporation, Los Angeles demurred this year because of its experience hosting the 2000 Democratic convention. "I would say, basically, it cost more than it benefited us," Kyser says. While he did not conduct a formal cost-benefit analysis, Kyser says the disruption caused by the convention hurt a lot of smaller businesses in Los Angeles. The jewelry district, he notes, was shuttered during the convention. Meanwhile, Kyser says, security costs exceeded estimates by about $20 million and the city is still footing the bill to fight lawsuits brought by demonstrators against the police department.
As to the extravagant level of spending claimed by convention boosters, Kyser is skeptical. While hotel rooms do get filled during conventions, they are usually sold in huge blocks and, consequently, discounted. At the same time, traditional tourists—who rent hotel rooms at full rate and patronize shops, bars, and restaurants—tend to steer clear of cities during conventions. People who come to town for conventions are not typical tourists, Kyser offers, so "don't expect these people to come rushing into your stores."
In response, convention boosters typically fall back to arguing "intangible benefits" from all the national and international exposure cities receive, which—barring a highly negative event like the riots at the 1968 Democratic National Convention in Chicago—can enhance a city's reputation as a tourist destination and pay dividends in future dollars. As Rybak spokesman Hanson puts it, "You get intense media attention for a week, and it's not all about what happens inside the walls of the convention. It's an incredible opportunity to shine a spotlight on the city."
But critics such as the Campaign Finance Institute's Weismann contend that the value of such exposure is as overestimated as the supposed economic benefits. Over the decades, he points out, conventions have become ever-more devoid of genuine news content; the last nominating convention to go to second ballot came in 1952 (when Adlai Stevenson got the Democratic nod), and there hasn't even been a close vote on the first ballot since 1976 (when Gerald Ford narrowly defeated Ronald Reagan). While the conventions are now tailored almost entirely to suit the needs of television, even TV seems to be losing interest. With poor ratings, Weismann notes, the broadcast networks have steadily reduced their coverage in recent years.

domain: sociology


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Review of Tesla Invader 2/3
The Teslacigs Invader series has a new improved device. The Tesla Invader 2/3 has been upgraded and the performance is better. The battery scheme coming from this box mod is the best improvement that it has. You are able to switch batteries from dual to triple battery back.
Design and Quality
This box mod has a really big improvement. It can be used when using two or three batteries depending on how you want it. It also has a maximum power output of 240W if you are using the dual battery back or 360 W when used with the triple battery back. You will notice the trapezoidal shape of the battery back when you are using three batteries for the device. When using only two batteries the battery back gets thinner and there is no hump on the back. This box mod has no magnets in it since it is held up by friction.
The batteries are easy to remove. When you are using the triple battery back, all you have to do is just push the battery back with your finger and it will easily slide off. Sliding it off loosens the battery back. You do not have to worry about accidentally sliding it off since it is firmly placed to the mod. When removing the batteries using the dual battery back, you need to do an extra push since it is much thinner and harder to open. The device does not come with a USB port so you need to charge this device using an extra charger.
This is designed with a variable voltage mod. You will notice that there is no support for temperature coils on this box mod. The device does not come with a digital screen s there is no way to view the status of the device. There are also no buttons to adjust its voltage.
When you want to set the voltage for this mod, you just have to use the potentiometer feature. It is located at the bottom front of the mod. This device is detonated wit h3 to 8 volts. There are also ¼ markings that you can see on the dial in between numbers. There are no detents on the potentiometer so you will not see the settings. However, this feature is easy to use, you just have to operate it using your fingertips. The device’s voltage settings have enough resistance so you will not change it inadvertently. The coils are the basis for setting up the wattage of the device.
At the bottom of the device’s body is the LED light. This lets you know the usage of the product which is really awesome. There is also a fire button located on the upper part of the front side of the device which is a really convenient location for all users.
There are two different sizes for the Tesla Invader 2/3 and that depends on how many batteries you are using. If you are using the device with the triple battery back, the size is 50mm by 42mm by 85mm. If it is used with the dual battery back, it’s size is 35mm by 42mm by 85mm. This box mod is powered by 18650 battery and has a maximum power of 240W and 360W. It is also safe to use this box mod because of its protection features. You will get the over puffing and reverse connection protection. This box mod also comes with an atomizer short circuit protection, low voltage alert, overheating and over-current protection.
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When you buy the product you will get one Tesla Invader 2/3 Box Mod. The batteries need to be bought separately since the box does not come with it. There is an additional battery cover that comes with the box when you buy it. A warning card and a user manual are also included in the box.
This device is pretty impressive especially that you can change how it looks. The battery scheme that comes with the device is pretty unique. You know that you are getting the best because the Tesla Invader 2/3 is made with high-quality materials. You also get the best value for your money since the box mod only costs $38.99. You are able to purchase the device right away at http://www.urvapin.com/.

domain: hobby


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Researchers develop new micropropulsion system that uses water as propellant
A team of researchers at Purdue University in the US has developed a new micropropulsion system that uses ultra-purified water as a propellant.
The new Film-Evaporation MEMS Tunable Array (FEMTA) thruster system features small nozzles that release precise bursts of water vapour to manoeuvre miniature satellites known as CubeSats.
The thruster uses 10mm-diameter capillaries to harness the microscopic properties of water. Since the capillaries are small in size, the surface tension of the fluid keeps them from flowing out, even in the vacuum of space.
The new technology also ensures that small heaters near the ends of the capillaries are activated to create water vapour and thrust.
This process makes the capillaries function as valves that can be turned on and off by activating the heaters.
According to researchers, the FEMTA thruster is similar to an inkjet printer, which uses heaters to eject ink droplets.
Purdue University school of aeronautics and astronautics professor and research lead Alina Alexeenko said: “Water is thought to be abundant on the Martian moon Phobos, making it potentially a huge gas station in space.
“Water is also a very clean propellant, reducing the risk of contamination of sensitive instruments by the backflow from thruster plumes.”
CubeSats are being increasingly used in various missions, ranging from high-resolution imaging and internet services to disaster response, environmental monitoring and military surveillance.
However, in order to achieve their full potential, the satellites will require micropropulsion devices to deliver precise low-thrust ‘impulse bits’ for their destined missions.
Image: This tiny engine is part of the new micropropulsion system. Photo: courtesy of Purdue University.


In the case of Public Interest Foundation and others vs. Union of India, A division bench of Justices N. Kirubakaran and V.M. Velumani made observations and gave directions to the Central Government to produce records of persons with Criminal Background, who are part of political parties, contesting elections and are even the policymakers bearing top positions in government offices.
The Court asked Central Government to make comprehensive legislation to prohibit and restrict persons with criminal background from contesting elections to Parliament, State Legislature and other local bodies. Our country needs political leaders who encourage a peaceful state and not those who encourage criminal activities in the state. Leaders with a criminal background may give a wrong influence on the public and maybe a reason for the chaos in the state and this needs to be stopped. India as a democratic country can be a huge risk if handed over to leaders with criminal backgrounds.
Author: Muskan Dosar, ICFAI Dehradun


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Sioux City man sentenced to 3.5 years in prison for firearms possession
SIOUX CITY (KTIV) - A convicted Sioux City felon has been sentenced to time in federal prison after firing a stolen gun into the air over Sioux City while consuming alcohol and marijuana.
According to a news release provided by the United States Attorney’s Office, David Thompson, 46, received his 42-month sentence after pleading guilty to being a prohibited person in possession of a firearm.
Evidence, in this case, showed that on Dec. 31, 2021, Thompson was drinking alcohol, smoking marijuana, and was upset. During an argument, Thompson went outside to the front yard of the residence and fired a pistol into the sky 11 times while in a crowded urban area. Family members, including five juveniles, were present inside the residence. Thompson admitted the firearm was his, that he was a felon, and that he was using controlled substances, mainly marijuana.
Thompson was previously convicted of furnishing a controlled substance to an inmate; forgery; and domestic abuse assault, in Woodbury County. Each of these convictions prohibited Thompson from possessing a gun. Additionally, Thompson had been convicted of a domestic abuse misdemeanor and admitted to being an illegal user of drugs. These also prohibited Thompson from possessing a gun.
In addition to his prison sentence, Thompson must serve a three-year term of supervised release after the prison term. Thompson is being held in the United States Marshal’s custody until he can be transported to federal prison.
Copyright 2022 KTIV. All rights reserved.


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- Highlighting high profile cases that may or may not have caused red flags in the hiring or credentialing process.
- Discussing examples of red flags.
- The responsibility of the gatekeeper to have these red flags addressed and the consequences of neglectful credentialing.
This session will delve into the importance of thoroughly vetting the healthcare provider before contracting or affiliating. Not every file will trigger a second look, but when there is an element indicating a possible issue, it should not be discarded or overlooked. Individuals responsible for collecting, verifying, and analyzing the credentials of a provider need to be acutely aware of their role as the gatekeeper for patient safety.
Join Dilsa in a discussion on everyone’s mind, how do we keep the providers from causing harm. Is it possible?
THE RIGHT CREDENTIALS NETWORK, LLC
Dilsa S. Bailey, CPMSM is a Medical Services and Credentialing Consultant and Trainer. Her experience in hospital, medical services, and managed care credentialing spans over twenty years. Her expertise in these fields have helped her employers and clients meet and maintain accreditation as well as the regulatory requirements for Joint Commission, NCQA, URAC, CARF, CMS, and various states. In addition to ensuring compliance and managing departments to a level of excellence, Dilsa has sat on both sides of the auditing table for delegation oversight.
Dilsa shares her knowledge regularly with peers through one on one coaching, webinars, and presentations for related professional organizations. Her training experience has included presentations at the 2009 National Association of Medical Staff Services Conference, the 2013 Annual Tennessee Association of Medical Staff Services Conference, and numerous presentations at quarterly Georgia Association of Medical Staff Services meetings. She has lead and facilitated educational seminars for her employers and clients. Her quest to empower credentialing professionals is evident in her creation of the popular Managed Care Credentialing Group on LinkedIn and her most recent book, “A Comprehensive Guide to Finding the Right Doctor: Tips from a Healthcare Credentialing Expert.”
Dilsa continuously maintains knowledge of the credentialing world and its effectiveness in the delivery of quality patient care. In that spirit, she has established long-term working relationships with talented and dedicated professionals across the healthcare organizational spectrum.

domain: health


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A western Maryland couple faces drug charges after police searched their home because school officials said their children smelled of marijuana.
A Maryland man has been indicted on charges that he sold heroin to someone who died as a result of taking the drug.
A drug bust nets a huge haul. Baltimore police say they’ve seized $3 million in heroin and cash–all from one suspect.
A former vendor on the Silk Road website has been sentenced by a U.S. district judge on Friday.
Two people face multiple drug charges after an officer discovers baggies of crack cocaine, heroin and cash during a traffic stop in Glen Burnie.
An undercover surveillance in the Brooklyn Park results in a substantial seizure of drugs and money.
As her friends were in the bathroom getting ready for homecoming, Hailey slipped away, crossing the hall to the bedroom in her Westminster home and closing and locking the door behind her. Overwhelmed with everything that was going on, she sought some sort of temporary relief.
As Maryland heroin related deaths surge, prosecutors in Baltimore are targeting suppliers, with more than 50 people indicted in three months.
Fighting a deadly problem. Governor Martin O’Malley recently signed an executive order in a push to prevent the growing number of drug overdoses in Maryland. It’s a problem getting out of control.
Anne Arundel County Police say a woman spit in three officers’ faces as she resisted a drug arrest in Glen Burnie.
Maryland saw a 33 percent increase in drug overdose deaths in the first quarter of this year compared to the same time last year, state officials said Thursday as they announced a renewed focus on fighting the rise of fentanyl-laced heroin.
Maryland’s historic capital is known for sailing and shopping, a place where people eat seafood at waterside restaurants. It’s not a place that city police considered a destination for people looking to buy heroin — at least, not until recently.


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Taylor Swift gave her fans an early Christmas present last night by tweeting a link to "Safe and Sound," a new song she recorded for the Hunger Games soundtrack with folk duo the Civil Wars. The song, a dark ballad featuring harmony vocals from Joy Williams and John Paul White, features lyrics that touch on the story's themes of struggle and survival and is available exclusively on iTunes.
The Hunger Games soundtrack, which is due out on March 23rd, is the result of the first-ever collaboration between producer T-Bone Burnett and composer Danny Elfman, two of the biggest names in contemporary film music.
You can listen to Taylor Swift and the Civil Wars' song "Safe and Sound" below.
To read the new issue of Rolling Stone online, plus the entire RS archive: Click Here
MUSIC 9 Classic Devo Videos
OLYMPICS 18 Epic Opening Ceremonies
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domain: celebrity


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I'll be participating in the New York Wedding Workshop's seminar: How to Hire a Photographer and Videographer this Saturday, January 31st. The seminar is scheduled from 10 - 12:30. The workshop will help brides & grooms learn the different aspects of photography and what to look for in a photographer. I'll be there to answer all your questions! And, if you register online at www.nyweddingworkshop.com and enter code: WED01 you can get a discounted ticket for $20!
Location: Gina Gallery - 454 Columbus at 82nd Street. See you there!!!


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My 34th birthday was this week.
I admit that I generally don’t do well with this day. Birthdays have led to breakdowns fueled by all the emotions that come with seeing those digits grow another year.
It forces contemplation on life, on another year past.
My biological clock quivers at how close I am getting to 35: the age that’s been drilled into my head as the time when fertility declines and it becomes harder and harder to naturally conceive a child.
And still childless.
The fertility topic is to blame for much of the sadness in recent birthday years. This mixes with the emotions of the holidays and the quiet desire to grow our family as we watch others around us.
I believe that I reached a pivotal point this past year directed more towards acceptance that I may never bear a child. I’ve tried to re-direct my thinking to a different, childless life.
There are times when I am alright with this. I appreciate my freedom. My sleep. My sanity.
Then the Johnson and Johnson commercial comes on and shows the first time father bathing his newborn baby. And it’s repeated in the breaks throughout the show.
It tugs at my heart, stirring up that which I thought I had under control.
Then my husband and I go to breakfast and we sit in a corner booth where I face a woman and her newborn child.
The woman was an off-duty employee at the restaurant and it seemed to be the first time she brought in her beautiful baby. All of the other employees stopped by with squeals of congratulations.
Longest. Breakfast. Ever.
Followed by a flood of tears once I escaped that suffocating situation.
Infertility brings grief. That grief comes in waves, and as if with any loss, it’s stimulated by these holiday times.
If infertility is your situation too, then please accept the love I now send to you…
I Spent My Birthday Clearing Space
Regardless, the tears did not fall for birthday 34.
I was too busy clearing space for new things. Creations. Imprints of this life that is moving much too fast.
Clearing space… I spent my birthday discarding.
“Really? This is what you want to do on your birthday?” My husband asked.
I smiled. Absolutely. The perfect time.
Have you read this one? It’s creating somewhat of a buzz.
At first I sort of scoffed at the idea of “life-changing”. Was this for real?
Now that I’ve read through it and started tidying up with Marie’s advisement, I concur. I no longer doubt the life-changing part.
Marie’s overall message is to create a home that is full of things that bring you joy. She suggests using this question as you go through the items in your home.
Does this bring me joy?
If the answer is no, then it needs to go.
You deserve to be around things that bring joy to your life. Everything else is just “clutter” that is blocking the way for other things.
I Saw the Burden With My Own Eyes
In her book, Marie suggests categories of items in your home for review (clothes, books, papers, and miscellaneous).
As you work through each category, collect all these items throughout your home and put them all together. She suggests starting with clothes, specifically tops.
I followed her instructions and piled all of my clothing tops on my bed.
An eye-opening experience followed.
Wow. I have too much stuff. I didn’t realize just how much it really was until I saw it all together like that.
I understand why Marie suggests doing it this way. It provides perspective and motivation to get to discarding.
So, I got to work.
As advised, I picked up each item and asked myself if it brought me joy. How did I feel when I wore it? How did it feel against my skin?
Some items were an easy “no”, while others had me lingering (or so I thought). A couple of times I put things aside that were questionable when I knew the answer was “no”.
For whatever reason I was having a hard time letting it go. But then when I tried it on, and felt its discomfort again, my initial thoughts were confirmed.
I felt a strange rush as I folded these second-guessed items into the black trash bags. It felt good to let go.
As I worked through mounds of clothes, I got better at picking up on my intuitive guidance towards joy. It became immediate. Instinctual.
I get that this may sound strange if you haven’t tried it.
What Are You Holding On To?
Marie digs deeper into the magic of this process, explaining that it helps to build confidence and appreciation for the present moment.
Sometimes we hold onto things because they are tied to something in the past, or are linked to fear of the future.
What if I need it later?
The bigger question is: does it bring you joy now? If it’s not serving you now and doesn’t spark something in you, then get rid of it.
The entire process of discarding was very freeing. I got rid of clothes that I’ve been carrying around for years. I’ve already filled up seven extra large garbage bags of stuff!
Included were a bunch of beautiful suits that no longer fit me. I’d struggled with the idea of getting rid of them for years, despite my husband’s persistance that they were no longer needed.
What if I need to wear them again?
In reality, I don’t forsee a future of suits for me. More like yoga pants, Lol.
But if this does become the case again someday, then I’ll deal with it then. I don’t need to hold onto something that might be, when it’s not right now.
That’s all there really is.
And truth be told, I don’t need those suits right now. I’m sure there are women out there who could actually get use out of them. Just like I did at one point.
The decision making process helped bring me back to the present. Does this serve me now?
This circles back to those worries over motherhood or lack their of…
On the Positive Side?
All in all, this birthday was awesome. I initiated release from that which has weighed me down.
My jam packed closet was causing silent stress. Now it is a space filled with clothes that I actually want to wear. That which does bring me joy. And my clothes have space to breathe! I can see everything that is offered.
I have never purged so much, in such little time, and I’ve only just begun.
By releasing all that I was holding onto, I created space for new, brighter things to come in.
I feel freedom. The word that glows from my desire map.
I’m excited to see what creations come of this clearing – baby or not 🙂
I can tell you that one creation is already in the making, and it too promotes creating space… with your breath.
I’ve been crafting five tracks for the Holiday Breather and I’m super excited to share them with you.
My intention with the Holiday Breather is to help initiate an environment of calm. Of peace. If only for a few minutes. That’s all it takes.
Allow me to share this space with you.
It’s happening next week: December 20th – 24th.
I have many more creations in the queue, and as I bid 34 hello, I know that the year to come will include many more vital expressions of my soul.
I foresee another book that’s been sparked by this idea of the healing power of creative expression.
Child or not, I promise to stimulate my natural creative instinct that comes from being a woman.
Cheers to 34.
Have you read The Life-Changing Magic of Tidying Up? Have you started or completed Marie’s suggestions? I’d love to hear about the impacts this beautiful book has had on your life.

domain: psychology


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PRP Hair Treatment
The most appropriate procedure against hair loss is PRP Hair treatment and it is suitable for both men and women. It is a non-surgical, totally natural, state of the art treatment applied in hair loss or hair thinning. The patient’s own blood is used for this injectable treatment. Your blood plasma (PRP) holds active growth factors that promote hair growth. The end result is a fuller, healthier looking head of hair.
PRP is also being used in conjunction with some hair transplant procedures. At the moment there is not yet any clinical proof that it effective, but the results are very promising.
At the Aesthetic Surgery center, we have been performing PRP therapy for male and female patients experiencing hair loss. PRP is a promising non-surgical beneficial method for patients who require stimulation of hair growth for hair loss conditions.
Recent scientific research and technology provides the medical community with new understandings of wound and tissue healing. As a result of these scientific studies, we recognize PRP is an all-natural autologous medical procedure performed in physicians offices for scalp, skin, and hair stimulation.
The hair restoration community remains cautious about making claims for hair restoration using exclusively PRP. Advantages of PRP Therapy against hair loss are:
- Simple, non surgical procedure
- Multiple Injections: procedure lasting approximately 60 to 90 minutes
- Safe and reliable results
- Very quick recovery period.
- Beautiful and above all extremely natural looking end results.
Your own Platelet-Rich Plasma (PRP) is injected into the scalp. Then the growth factors in your blood cells do their job and hair growth is naturally stimulated.PRP can applied with different methods. Our clinic experiences show that with combine methods we can get better results. More detail please click.
Published medical literature from Europe and the United States confirms the safety and use of PRP therapy. It has been used extensively in medical specialties for the last twenty years with generally positive outcomes and success. In the field of hair restoration, evidence supports PRP therapy as a promising treatment option to promote hair growth. It is a promising non-surgical therapeutic option for those patients with hair loss.
A significant reduction in hair loss can be observed between the first and fourth injection. Average mean gain is 22.09 follicular units per cm2. After the fourth session, the pull test was negative in 9 patients.
PRP injection is a simple, cost effective and feasible treatment option for androgenic alopecia, with high overall patient satisfaction.


maybe some one knows how to handle that issue.
BESClient on unix redefine many and drops a lot of environment variables of root account (under which its process is running).
So everything executed inside action script inherits these environment variables of BESClient process, therefore many commands stop working (different PATH, LIB, LIB_, dropped m\w related variables) correctly.
Are there built-in possibility to say for “wait\run” to use root’s “original” environment variables ? I’ve not found needed combination “override wait” options to achieve my goal.
So today I’m using method “su - <user_name> -c commad” to load needed original users environments… but it’s enough painful to manage all cases with quotas and double quotas combinations.
Any another ideas to simplify “life” ?


Does anyone buy vices new? Someone must, but I never have – Bill’s Tool Store in the Barras is the place I go to for stuff like this. Last time I was there I got some ex-MOD V-blocks for £20 and a lovely big ex-MOD machine vice also for £20.
They also had some massive Eclipse vices, up to 8″ for about £100ish.Posted 4 years ago
Tbh thats how i work as well , buy the cheapest reasonable item , if i use it often and it breaks i replace it with something better.
Big ticket items i tend to spend a bit more to get something good first time.
At least if i dont use it again either the cheap item can be chucked/given away or the expensive item sold at not much of a loss.Posted 4 years ago
I figure you have to use something a bit to figure out what features you like / need and then maybe upgrade to something better. That’s really why it’s just screwed down, I wasn’t sure what position to stick it in with the rotating head, so I figured I’d just experiment a bit and move it if it didn’t work out well. Plus I need to fit a mill and lathe on the bench, so it may all move again at some point.Posted 4 years agomudsharkMember
Well I’m another person surprised at the level of interest in vices. I do remember poking around a market and seeing a stall with lots of 2nd hand vices so suppose these were as some have above – some were around £20 I think. I did consider buying one but didn’t fancy lugging it home but later saw Lidl were selling one for £12 so bought it – seems I may have made a mistake but works fine so far. I attached it to the work bench my Grandad made me when I was 8 :).
Posted 4 years agomcmoonterMember
Where are you all getting the model numbers from
The model numbers are cast into the sides. I believe the models are almost unchanged until they were made abroad.
The strongest vices have ‘steel’ cast into the body. These have a steel slide rather than a cast slide which makes the virtually unbreakable.
Keep your eyes open, if you are lucky you might find a bargain.
Posted 4 years agostucolMember
Got a Record No 23 that was my dad’s and is at least 40 years old. Works perfectly of course.
Did have a falling out with a Pals wife when i happened to say that he had positioned his incorrectly. “He is an engineer, he knows better than you” she says. I had pointed out that it was bolted too far back on the bench. But apparently i was wrong.
I wondered what happened the first time he tried to clamp say a foot long pipe vertically in it !
Oh look, it hits the bench. Engineer my arse.Posted 4 years agobedmakerSubscriber
I felt compelled to go to the shed and check my vice after reading this 🙂
I’m happy to report that my rusty old vice is indeed a Record, with the all important Steel casting too 😛
No 84 quick release, donated by my FIL after clearing out a lockup. Probably liberated from Invergordon Distillery many moons ago.
Bolted to a steel bench in a manly fashion and when clamping something vertically it sits 50mm off the front of the bench.Posted 4 years agoepicycloSubscriber
Just zipped out to the shed to check mine. 🙂
Record No 4. Bought it from a bicycle shop over 40 years ago when they were closing down to retire. The old guy reckoned it had been on the bench since he was an apprentice and probably from when the shop opened in the 1880s or 90s. Is that likely? Have they been making them unchanged all that time?
Cost me £1 and I had to lug it home 3 miles walking. I’ve never bolted it down, it’s too useful as a mobile tool, and hefty G clamps for when I want to fix it down. However it probably never gets the sort of heavy use it was designed for.
Now I’ll have to treat it with a bit more reverence. 🙂Posted 4 years ago
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Playdate was given a pre-order time and date and some more information on how and why you’d want to get a device. If you’ve made it this far, you probably already know what Playdate is, but just in case: It’s a very strange piece of gaming equipment. You play games on it with hardware buttons and a crank – a hardware crank. It’s just about the most unique attempt to make a bit of gaming hardware in the past decade, and it’s about to become available to the masses.
The device called Playdate is called a “handheld video game system” by its creators at Panic. The Twitter description for the official Twitter account for the device included the text “On sale and shipping in 2021, hopefully.” This text remained live even as, at 1:30PM Central Time on July 22, the company had a post which suggested they’d be releasing “pre-order” details. That post was posted at 12 PM, July 22, 2021.
It was about 30 minutes after the initial post that Playdate released additional information about the machine and the pre-order. Panic said that pre-orders will not “sell out”, regardless of the number of pre-orders logged. They went on to confirm that there’ll be a batch of approximately 20k Playdate units that they say “should ship in late 2021.”
Panic also revealed that they’ll be shipping additional orders beyond the approximately 20k units in the year 2022. Panic confirmed that they’ll “adjust 2022 production” based on the demand they see in the second half of 2021.
If you’re very, very interested in this machine, Panic says you’ll still only be able to order 2 units “per person.” This pre-order session will include the Playdate Cover, but the Playdate Stereo Dock will be “coming later.” All pre-orders require full payment, but “can be cancelled anytime for a full refund.”
The pre-order price will be $179 USD, without shipping. This price includes the Playdate device and “24 original Playdate games, delivered weekly, at no extra charge.” This release also includes a “very nice yellow USB-C to USB-A cable.”
Given the amount of interest the company has drummed up in the time since it first revealed development of this device and the games that’ll work with it, now is a very exciting time for odd gaming enthusiasts. If you’re looking for a unique new way to play new video games made by people who are genuinely interested in creating games you can play without the far-too-common “check-in” and “pay to win” models present in most gaming today, especially mobile gaming, now’s a good time to take a peek at Playdate.


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Bodily hormone Treatment or even hormonal agent substitute therapy is the use of specific hormonal agents to alleviate a person’s bodily condition. Hormonal agents are typically made through the ovaries and also are used for ordinary bodily functionalities, such as managing female menstrual cycle.
Many Testosterone medical professionals who give hormonal agent treatment likewise recommend medicines that may increase production of these hormonal agents, thus enhancing an individual’s supply. The most common type of bodily hormone therapy is oestrogen, which is actually usually prescribed for females who are actually identified with bust cancer. While estrogen may at times raise the threat of bust cancer cells, it is actually quite successful at taking out tumors from the body system, as well as normally assists to prevent future development of mammary glandulars.
Hormonal agent Therapy can easily additionally be utilized for menopausal indicators, including hot flashes and depression. Furthermore, lots of medicines, both prescribed and also non-prescription, may be used for the exact same function, although many doctors will definitely certainly not advise using medicines that disrupt testosterone level amounts.
When recommending bodily hormones, doctors will certainly vary their dosage according to the quantity of flow that is actually obtained through the various bodily hormones. If too a lot of one hormonal agent is actually made use of, the different hormones will definitely possess a minimal result or also be actually quit entirely.
HGH have a peek at this site is commonly suggested for those who deal with diabetes mellitus. The National Institute of Diabetic Issues and Gastrointestinal and also Renal Health conditions even recommends that it be offered to those along with the illness, considering that of its potential to control blood sugar amounts. This is certainly not an usual strategy in the United States, as well as lots of physicians just highly recommend HGH therapy when there is actually an accurate requirement to do so.
Synthetic hormonal agents are actually utilized in the treatment of fibromyalgia. Fibromyalgia takes place when the physical body remains in persistent pain triggered by muscular tissue as well as joint problems. Many medical professionals who suggest the hormone known as Follistim, recommend this to individuals that have discomfort that is associated with fibromyalgia.
Numerous medical professionals choose to find a medical professional concerning the usage of HGH treatment just before suggesting the treatment for individuals suffering coming from these signs and symptoms. The main objective of hormonal agent treatment for hypogonadism is to enhance the production of semen, which are going to permit more sperm to journey to the fallopian cylinders and be fertilized throughout ovulation.
Bodily hormones have been utilized properly for a lot of conditions, and are actually a very reliable therapy for many different ailments. They are actually certainly not recommended for everyone, and those experiencing coming from some side impacts may locate that they are not able to take the drugs.
Some of the side effects to hormone treatment belong to clinical ailments. If you are at danger for certain clinical conditions and ought to only be taken into consideration as a final resort, hormone substitute treatment may be actually extremely unsafe. This includes people along with diabetes mellitus, renal problems, lumps, cardiovascular disease, a number of myeloma as well as pituitary glandular health condition. While you might find that these health conditions are alleviated typically, they are actually still risks to be aware of.
Another feasible adverse effects to HGH is that it can have a boosted risk of brittle bones. If the amount of estrogen as well as progesterone in your body system is lessened, there is actually a boosted threat of bone tissue loss.
While HGH treatment may be valuable for various disorders, it is not for everybody. Those suffering from hypogonadism or even fibromyalgia should talk to their physician regarding taking the drugs prior to beginning a program of bodily hormone substitute treatment. Hormone replacement therapy should just be looked at as a last option if all various other procedures have been actually tried as well as neglected.
Bodily hormone Therapy or even hormonal agent replacement treatment is the usage of certain hormones to alleviate a person’s bodily ailment. The phrase on its own is actually a little complicated to a nonprofessional, since it includes an amount of various forms of therapy with hormone medicines. This post will certainly aid drop some illumination on the topic and perhaps give an informed audience along with a far better understanding of the term. Bodily hormones are actually naturally made due to the ovaries and are actually used for regular physical functionalities, including managing female menstruation.
Several medical professionals that offer hormonal agent treatment also suggest drugs that may enhance manufacturing of these hormones, hence boosting an individual’s supply. The most popular sort of hormone therapy is oestrogen, which is generally recommended for girls who are detected along with bust cancer. While estrogen can at times boost the threat of bust cancer cells, it is quite helpful at eliminating growths coming from the body system, as well as generally aids to stop future growth of mammary glandulars.
Hormone Therapy can additionally be made use of for menopause signs and symptoms, including hot flashes and also depression. Additionally, lots of drugs, each prescribed and over the counter, could be utilized for the very same purpose, although many doctors will certainly certainly not advise the use of medications that hinder testosterone degrees.
When suggesting hormones, medical professionals are going to vary their dosage according to the amount of circulation that is actually accomplished due to the various hormones. The different hormonal agents will certainly possess a minimal effect or even be quit entirely if too much of one hormone is made use of. As an example, when a medical professional suggests the medication tamoxifen, she is going to also inform her patients concerning the simple fact that this medicine can induce a short-term reduction in blood stream circulation to the ovaries. Some women experience side effects such as bloating and nausea in the course of this moment.


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Chinese President Xi Jinping has congratulated Donald Trump on his stunning victory in yesterday’s US presidential election.
According to China’s official Xinhua News Agency, here’s what Xi had to say to his future American counterpart:
I highly value the relations between China and the United States, and I am looking forward to working together with you to expand China-U.S. cooperation in every field, at the bilateral, regional and global levels, on the basis of the principles of non-conflict, non-confrontation, mutual respect and win-win cooperation, with differences controlled in a constructive manner, so as to push China-U.S. relations further forward from a new starting point, better benefiting the peoples of the two countries and other countries.
Xi added that both China and the US have the special responsibility of “maintaining world peace and stability and boosting global development and prosperity” and that he hopes to develop “long-term, healthy and stable” China-US relations.
In the past, Trump has had some less than nice things to say about the Chinese president. When Xi visited the White House last year, Trump suggested that he be given a “double sized Big Mac” rather than a formal state dinner.
Throughout his campaign, Trump has engaged in relentless China-bashing, accusing Beijing of illegally subsidizing exports, manipulating its currency, stealing intellectual property and “raping” America. At one point he said that he would impose some yuge 45% tariffs on America’s second-largest trading partner. He also vowed that on his first day in office, he would label China as a currency manipulator.
Trump’s Chinese-American supporters have argued that he was just using China as a “punching bag” in order to gain support with voters. Once in office, it will go back to business as usual.
Well, now, we’ll actually get a chance to see if they were right about that.