Thursday, July 9, 2020
How The Courts Have Developed The Law In Relation To Claims For Psychiatric Harm By Secondary Victims - Free Essay Example
Date authored: 12 th August, 2014. Introduction There has been judicial comment in Australia that in relation to claims for psychiatric harm, the law has progressed haphazardly or pragmatically rather than logically or scientifically:  Ã¢â¬Å"The ways in which the law of liability for nervous shock has been developed by courts in England and here, and extended to new situations, have been empirical, with results and limitations that appear as pragmatically rather than as logical applications of principle.Ã¢â¬ The development of the common law in Australia in relation to secondary victims, particularly under the law of negligence, has seen a gradual liberalising or expansion of the categories for recovery in recent years, most notably in the High Court decisions of Tame and Annetts  and Gifford  . This has, to some extent, been in response to a traditional reluctance by the Courts to allow secondary victims to recover for mental due to a perceived flood of imaginary claims.  The view used to be held that Ã¢â¬Ënervous shock without physical symptoms was not compensable at law, but it has long been recognised that mental harm has the same status in torts law as physical harm.  A secondary victim is understood in this context to mean a person who suffers a Ã¢â¬Ërecognisable psychiatric injury,  typically as a consequence of perceiving injury to another, but not necessarily at the impact scene or its aftermath. The fear of an avalanche or flood of mental harm cases led to policy restrictions or control mechanisms being imposed, including that the secondary victim must suffer Ã¢â¬Ësudden shock, be a witness to the accident scene or its aftermath, or be in a relationship having close ties of love and affection with the primary victim. The view that that the conditions for recovery have been unduly restrictive and led to arbitrary decisions seems to have been exacerbated by a lack of predictability in the common law applying said control mechanisms, as well as by a lack of uniformity on the part of the State and Territory legislatures in responding to the Ã¢â¬Ëinsurance crisis of 2002, which sparked fears that the law was moving too fast to award damages to new classes of plaintiff.  The foregoing matters will be discussed under the following headings: 1. Requirement of Sudden Shock 2. Requirement of Proximity 3. Requirement of Relationship 4. Foreseeability Ã¢â¬â Person of Ã¢â¬ËNormal Fortitude 5. Statutory Restrictions Conclusion. 1. Requirement of Sudden Shock The first control mechanism restricting recovery for both primary and secondary victims is the requirement that there can be no liability in the absence of a sudden shock to the nervous system.  The limitation can be traced back to Brennan Js interpretation of the case law in Jaensch v Coffey  and has been applied in numerous subsequent decisions.  However, there are exceptions to the general principle such as the Ã¢â¬Ëwork stress cases  and Ã¢â¬Ëfear for the future cases.  The shock must in reality be a psychiatric illness of a lasting and clinical nature. It is clear that from the 1970s judges have required plaintiffs to be suffering a Ã¢â¬Ërecgonisable psychiatric illnessÃ¢â¬ ,  (although McHugh and Callinan JJ in retain the use of Ã¢â¬Å"nervous shockÃ¢â¬ in Tame and Gifford  ), in order for the harm to be compensable. Medical consensus suggests that lasting damage does not occur in Ã¢â¬Ënormal i ndividuals.  It is therefore inappropriate to insist that an immediate reaction such as a sudden sensory perception be a prerequisite to recovery. This was the conclusion reached by a majority of the High Court in Tame.  However, the sudden shock rule remains relevant as a factor in determining whether psychiatric injury was reasonably foreseeable, as subsequently confirmed by the Civil Liability Acts.  The sudden shock rule is perhaps a striking example of the pragmatic and unscientific development of the common law. It is possible that this principle may yet operate to deny recovery or at least will operate unpredictably, turning upon the particular facts and evidence of each case. 2. Requirement of Proximity The common law has, however, gradually relaxed the restriction that, in order to recover, the plaintiff be present at the impact scene.  That process began in 1925 with Hambrook v Stokes in which a mother recovered for shock she suffered from fear for her own and her childrens safety from a runaway lorry.  The requirement that the plaintiff had to be present at the scene and witness the accident was gradually extended to witnessing the aftermath at the scene, extended to witnessing the aftermath at hospital during the immediate post-accident treatment.  The High Court suggested in Jeansch  that absence by the relative from the accident scene might not be a bar to recovery. In Annetts,  the Court finally removed the direct perception requirement as a bar to recovery. The aftermath requirement would always be a limitation in borderline cases, penalising family and friends who are too affected by shock and grief to go to the scene o r a bar where there is no aftermath or no scene to perceive (as in Annetts, in which the body was not discovered at the time of the shocking event).  However, the gradual innovation of the common law has been complicated by the legislative response to the insurance crisis of 2002. The Civil Liability Acts (and variants) were legislated in each jurisdiction as a response to perceptions that the common law was moving too fast to allow new classes of plaintiffs to recover, including secondary victims.  Earlier legislation  provided that family members (other than parents, spouse and close family) were required to be within sight or hearing of the accident in order to recover.  Under the common law, that requirement was effectively removed as a condition for recovery by the High Court in Annetts and Gifford. At the time of the Gifford decision the Civil Liability Act 2002 took effect which excludes compensatory recovery for a person who is n ot a witness at the scene nor a Ã §lose family member.  Yet similar provisions of other States do permit recovery for a plaintiff who witnessed the immediate aftermath  , or who was Ã¢â¬Ëpresent at the scene.  The civil liability provisions differ across jurisdictions creating disunity and much less predictability across Australia for secondary victims who suffer mental harm. 3. Requirement of Relationship Another limiting factor is that the plaintiff must have a close tie of relationship or care with the primary victim. Relationship is likely to lead to a conclusion in which there was foreseeability (which appears to be the predominant view in the UK authorities).  However, it is just as foreseeable that a harm could be suffered by those unrelated to the primary victim. Thus in Australia, Deane J in Jaensch was of the view that close ties of love and affection should override the direct perception limitation on reasonable foreseeability.  It is clear from Gifford that the absence of a pre-existing relationship is not a bar to recovery.  Involuntary participants is another category in which the shock stems from an apprehension that the plaintiff is the involuntary cause of injury to another.  Legislative reforms introduced as a result of the insurance crisis of 2002 has complicated the picture. For example, the Civil Liability Act 2002 (NSW) restricts the class of plaintiffs to a Ã¢â¬Å"close member of the familyÃ¢â¬ (parent, spouse, partner, child, stepchild, brother, sister, half-brother, half-sister, step-brother/sister)  , in contrast with earlier legislation which said that the defendants liability extended to those cases, and also to Ã¢â¬Å"any other member of the familyÃ¢â¬ who saw or heard the plaintiff injured or put in peril.  Yet, somewhat haphazardly, the categories of potential claimants differ across jurisdictions. In Victoria, for example, the plaintiff must be or have been in Ã¢â¬Å"a close relationship with the victimÃ¢â¬ .  Yet Ã¢â¬Å"close relationshipÃ¢â¬ is not defined, leaving it open for the courts to interpret the categories more expansively beyond family relationships to perhaps those with Ã¢â¬Å"close ties of love and affectionÃ¢â¬  as giving rise to a duty of care. 4. Foreseeability Ã¢â¬â Person of Ã¢â¬ËNormal Fortitude The doctrine that the shock must have been foreseeable to a person of normal fortitude acts as a control mechanism against unduly burdening human activity by indiscriminate claims of exposing others to the risk of mental harm. Such claims could interfere with otherwise tolerable conduct, such as making a loud noise which could cause a person peculiarly vulnerable to suffer shock.  Yet the onus of proving a special vulnerability lies on the defendant  who takes the victim as they are found.  However, the normal fortitude test has been criticised as unscientific and impracticable to apply, as it depends upon arbitrary judge-made distinctions as to what is Ã¢â¬Ënormal along a Ã¢â¬Ëslippery slope of psychiatric abnormality.  Yet under negligence law the foreseeability test is necessarily concerned with a balancing exercise by the Courts to assess whether a reasonable person would recognise an act or omission as posing an unreasonable risk of harm to a normal person  . The Courts do not insist upon foreseeing the specific kind of psychiatric damage, rather, if compensable mental harm is foreseeable, the predisposition is necessarily included.  Thus the High Court in Tame clarified the fortitude principle by establishing that the test is merely one consideration within reasonable foreseeability.  Whilst that consideration did not alter the outcome in Tame, it seems a sensible solution to a complex problem. 5. Statutory Restrictions However, statutory law has returned to the old test in respect of ordinary fortitude. At the time of the Tame decision in 2002 there was a nationwide concern as to the way in which the law of negligence was operating in personal injury cases, with the effect of driving up insurance premiums and making it difficult to obtain liability cover (eg. in the practice of medicine). The Commonwealth Government appointed a panel to review the law of negligence and the resultant report recommended greater restrictions to recovery in some areas. In the area of foreseeability of mental harm to primary and secondary victims the panel urged that: Ã¢â¬Å"a person (the defendant does not owe another (the plaintiff) a duty to take care not to cause the plaintiff pure mental harm unless the defendant ought to have foreseen that a person of normal fortitude might, in the circumstances, suffer a recognised psychiatric illness if reasonable care was not taken.Ã¢â¬  Civil liabilit y legislation in six Australian jurisdictions subsequently adopted a general principle which closely resembled this formulation.  The principle that if the defendant knows or ought to know that the plaintiff is a person of less than normal fortitude is specifically preserved. However, the re-formulation by eh High Court in Tame is pointedly ignored. The change in the law effected is to limit the principle that where a plaintiff suffers personal injury, there can be recovery for all consequential harm, physical or mental. That limitation had not previously been imposed by the common law and is viewed as a way of reducing the size of damages awards.  The result of these legislative reforms in response to the insurance crisis is that Australian personal injury law restricts recovery to claimants previously classified by the common law as deserving in a range of situations, but in a way which is far from consistent across jurisdictions. Conclusion In many ways, the common law has developed incrementally in the area of psychiatric harm by showing innovation. For example, in Tame and Gifford in removing the proximity requirement and focussing more on the relationship between primary and secondary victim as the touchstone for reasonable foreseeability. In that sense, the common law has come a long way since the Coultas decision in recognising the particularly devastating nature of psychiatric injury. However, such developments are coloured by the response of the legislatures to the insurance crisis of 2002. The Civil Liability Acts across the Australian jurisdictions are characterised by a lack of consistency and uniformity in approach, and in some cases went beyond the recommendations of the panel Report. For example, seemingly outdated legal rules such as the Ã¢â¬Ësudden shock requirement persist, and a person unrelated to the plaintiff present at the aftermath may be permitted to recover damages for psychiatric harm in Tasmania, but not in New South wales. This disunited and unsatisfactory state of Australian law will await a legislative solution in the future, and will continue to pose challenges for the Courts as they proceed Ã¢â¬Å"step by cautious stepÃ¢â¬ to develop the foregoing policy considerations in ways which will deliver appropriate and just outcomes for deserving secondary victims. Bibliography Butler, D. A Ã¢â¬ËKind of Damage: Removing the Ã¢â¬ËShock from Ã¢â¬ËNervous Shock. Torts Law Journal, 5, 255-275. Butler, D., Identifying the Compensable Damage in Ã¢â¬Å"Nervous ShockÃ¢â¬ Cases. Torts Law Journal, 5, 67 Ã¢â¬â 87. Butler, D. 2002. Employer liability for Workplace Trauma. Aldershot, UK. Ashgate. Dietrich, J. 2003. Nervous Shock: Tame v NSW; Annetts v Australian Stations. Torts Law Journal, 11, 1-9. Foster, N. 2004.Psychiatric Injury Following Workplace Trauma or Death: Actions by Fellow Workers and Relatives in New South Wales. Tort Law Rev iew, 12, p. 59. Handford, P. (2006) Mullany and Handfords Tort Liability for Psychiatric Damage. Sydney. Lawbook Co. Handford, P. 2012. Wilkinson v Downton: Pathways to the Future? Tort Law Review. 20(1) 145-162. Hilson, C. 1998. Nervous Shock and the Categorisation of Victims. Tort Law Review, 6, 37-55. Luntz and Hambly 2006. Torts: Cases and Commentary. Chatswood. LexisNexis Butterworths. Mendelson, D. 1998. The Interfaces of Medicine and Law: The History of the Liability for negligently caused Psychiatric Injury (Nervous Shock). Aldershot. Ashgate. Mendelson, D. (2010). The New Law of Tort. South Melbourne. Oxford University Press. Sappideen, C. and Vines, P. 2011. Flemings The Law of Torts. Sydney. Lawbook Co. Teff, H. 1996. The Requirement of Ã¢â¬ËSudden Shock in Liability for Negligently Inflicted Psychiatric Damage. Tort Law Review, 4, 44-61.  Mount Isa Mines Ltd v Pusey (1970) 125 CLR 383 at 407per Windeyer J. Cf. UK Law Commission, Liability for Psychiatric Illness, Law Com No 249, 1998, cited by Luntz and Hambly (2006 p. 536 at [7.11.4]).  Tame v New South Wales (2002) 211 CLR 317.  Gifford v Strang Patrick Stevedoring Pty Ltd (2003) 214 CLR 269.  Victorian Railways v Coultas (1888) 13 App Cas 222 at 226. Cf. under the intentional infliction of mental harm, the interest protected is that of the legal right of the plaintiff to personal safety, that is, the right to mental or emotional tranquillity and bodily dignity: Wilkinson v Downton (1897) 2 QB 57 at 59 per Wright J; Bunyan v Jordan (1937) 57 CLR 1 at 10-11 per Latham CJ; Dulieu White  2 KB 669 at 683 per Phillimore J; Purdy v Woznesensky  2 WWR 116 at 120; Magnusson (1994) pp. 166, 169.  See for example the various statutes of limitation, eg. Limitation Act 1969 (NSW) s 11(1); Limitation Actions Act 1985 (ACT) s 81(1); Limitation Act 1981 (NT) s 4(1); Limitation of Actions Act 1974 (Qld) s 5(1); Limitation of Actions Act 1936 (SA) s 36(2); Limitation Act 1974 (Tas) s 5(5); Limitation of Actions Act 1958 (Vic) s 3(1). Cf. Limitation Act 1980 (UK) s 38(1). For the medical background see Handford (2006: pp. 53-73).  Tame v New South Wales (2002) 211 CLR 317 per Gleeson CJ at 329, 338; per Gaudron J at 339; per Gummow Kirby JJ at 292, 302; Gifford v Strang Patrick Stevedoring Pty Ltd (2003) 214 CLR 269 per McHugh J at 291; per Gummow Kirby JJ at 292, 302; Butler (1997);  Civil Liability Act 2002 (NSW) s 32; Civil Law (Wrongs) Act 2002 (ACT) s 34; Civil Liability Act 1936 (SA) s 33; Civil Liability Act 2002 (TAS) s 34; Wrongs Act 1958 (Vic) s 72; Civil Liability Act 2002 (WA) s 5S.  Butler (1997).  Jaensch v Coffey (1984) 155 CLR 549 at 565.  Chiaver ini v Hockey (1993) Aust Torts Rep 81-223; Reeve v Brisbane CC  2 Qd R 661; Pham v Lawson (1997) 68 SASR 124 (FC). Note that the UK has retained the sudden shock requirement: Alcock v Chief Constable  1 AC 310.  That is, where an employee claims against the employer for damages for psychiatric injury caused by work stress, see: Handford (2006, Chapter 22, pp. 539-571); Butler (2002) pp. 103-124..  That is, where the plaintiff claims to have suffered psychiatric injury through fear of what will happen in the future, such as the possibility of exposure to a deadly disease, see: APQ v Commonwealth Serum Laboratories Ltd  3 VR 633; Handford (2006 Chapter 27, pp 645-671).  Handford (2006) p. 30 and cases cited at [2.20].  Tame v NSW (2002) 211 CLR 317 at 348, 427; Gifford v Strang Patrick Stevedoring Pty Ltd (2003) 214 CLR 269; cf. White v Chief Constable of South Yorkshire Police  2 AC 455.  Teff (1996, pp. 54-55).  Tame v NSW (2002) 211 CLR 317 at 333; 344; 389-90; 410. See also: New South Wales v Napier  NSWCA 402 at  per Mason P; Wicks v SRA (2010) 241 CLR 60 at 72 Ã¢â¬â the Ã¢â¬Ëshocking event is a relevant consideration but a necessary pre-requisite of recognising a duty of care (two police officers who rescued injured persons at scene of a horrific railway accident were denied recovery by the NSW Court of Appeal because they did not witness victims being killed, injured or put in peril).  Civil Liability Act 2002 (NSW) s 32; Civil Law (Wrongs) Act 2002 (ACT) s 34; Civil Liability Act 1936 (SA) s 33; Civil Liability Act Act 2002 (Tas) s 34; Wrongs Act 1958 (Vic) s 72; Civil Liability Act 2002 (WA) s 55.  Williams v Ocean Coal  2 KB 422 (CA); Bourhill v Young  AC 92.  Hambrook v Stokes  1 KB 141.  Jaensch v Cof fey (1984) 155 CLR 549. Cf. Alcock v Chief Constable  1 AC 310; cf. Galli-Atkinson v Seghal  Lloyds Rep Med 285 the House of Lords upheld restrictions on being told or reading about the accident afterwards or hearing about it simultaneously on radio, barring recovery for relatives of spectators crushed in a football stadium disaster, on the basis that they were not at the scene or at the hospital within an hour or so.  Jaensch v Coffey (1984) 155 CLR 549 at 555, 608-609 per Gibbs CJ, Deane J.  Annetts v Australian Stations; Tame v NSW (2002) 211 CLR 317 (the Court held that parents who were telephoned in Sydney and told of the disappearance of their son, a sixteen year old jackaroo working in remote Western Australia, were owed a duty of care even though they never visited the accident scene, where his body was not discovered for four months).  See Handford (2006 p. 238 and cases cited at [8.340]).  See the account by Handford (2006 pp. 427-432).  The Law Reform (Miscellaneous Provisions) Act (NSW) s 4(1), for example, provided that whilst a parent, husband or wife of the plaintiff did not need to be at the scene or its aftermath to recover (a position more progressive than the common law, which nonetheless extended the boundaries of liability over the years, prior to Tame v New South wales (2002) 211 CLR 317, see for example: Quayle v NSW (1995) Aust Torts Rep 81-367 (mother told of sons death in custody allowed to recover both under statute and common law); see also mothers claim for shock related injury in X and Y (by her Tutor X) v Pal (1991) 23 NSWLR 26). Note, however, that despite the repeal of the Law Reform (Miscellaneous Provisions) Act (NSW) s 4, that provision still has some effect in workplace claims due to the complex interaction of the 1944 Act, the Civil Liability Act 2002 and the Workers Compensation Act 1987 (NSW), for discu ssion see: Foster (2004).  Cases in which childrens claims under the statutes were ruled out on this ground include:Coates v Government Insurance Office of New South wales (1995) 36 NSWLR 1 (children told of fathers death in road accident); Knight v Pedersen  NSWCA 333; Gifford v Strang Patrick Stevedoring Pty Ltd (2001) 51 NSWLR 606, on appeal (2003) 214 CLR 269.  Civil Liability Act 2002 (NSW) s 30.  Civil Liability Act 2002 (Tas) s 32.  Civil Liability Act 1936 (SA) s 53(1).  Owens v Liverpool Corp  1 KB 394; cf. Storm v Geeves  Tas SR 252; Alcock v Chief Constable  1 AC 310.  Jaensch v Coffey (1984) 155 CLR 549 at 608-609 per Deane J.  Gifford v Strang Patrick Stevedoring (2003) 214 CLR 269. Note that In Tame the fact that the mother of the victim had contacted the tortfeasor to ensure that her son would be looked after was a factor significant in recognising the duty of care. Compare cases of intentionally inflicted mental harm in which persons closely connected with the victim or witnesses to the attack are entitled to recover: Battista v Cooper (1976) 14 SASR 225; Purdy v Woznesensky [1973 2 WWR 116; Beilitski v Obadiak (1922) 65 DLR 627; cf. Fagan v Crimes Compensation Tribunal (1982) 150 CLR 666 at 681.  Dooley v Cammell Laird  1 Lloyds Rep 271 (crane driver suffered shock when he saw his load fall into a ships hold where he knew fellow workers to be unloading); Alcock v Chief Constable  1 AC 310 at 408. The common law also recognises other categories of case (eg. rescuers: see Handford (2006), Chapter 19; employees susceptible to psychiatric illness: Moricz v Grundel Boilermaking Engineering Works  SASR 112; Corporation of the City of Woodville v Balassone  SASR 147; cf. Donjerkovic v Adelaide Steamship Industries Pty Ltd (1980) 24 SASR 347) not dependent on there being a family relationship. However, those plaintiffs tend to be classified as primary victims with possibly greater restrictions on recovery.  Civil Liability Act 2002 (NSW) s 30. Contrast: Civil Law (Wrongs) Act 2002 (ACT) s 36(1).  Law Reform (Miscellaneous Provisions) Act 1944 (NSW) s 4(1).  Wrongs Act 1958 (Vic) s 73.  Alcock v Chief Constable  1 AC 310.  Bourhillv Young  AC 92; Bunyan v Jordan (1937) 57 CLR 1.  Mount Isa Mines Mines Ltd v Pusey (1970) 125 CLR 383 at 405-406; Benson v Lee  VR 879 at 881; Gannon v Gray  Qd R 411 at 414; Jaensch v Coffey (1984) 155 CLR 549 at 556; Petrie v Dowling  1 Qd R 284 at 287; Skea v NRMA Insurance Ltd  ACTCA 9.  The victim as found may include the plaintiffs cultural context: See Kavanagh v Akhtar (1998) 45 NSWLR 588; Handford (2006 p. 328 at [1 1.290] and cases cited therein).  Sappideen Vines (2011 p. 182).  Wyong Shire Council v Shirt (1980) 146 CLR 40 at 47-48.Jaensch v Coffet (1984) 155 CLR 549 at 556, 609-610, 613. Compare cases of intentionally inflicted mental harm in which the range of foreseeability is greater as the intended consequences must be likely: Bunyan v Jordan (1937) 57 CLR 1 at 10 per Latham CJ; Battista v Cooper (1976) 14 SASR 225 at 229-230. As such the intentional tortfeasor deserves lesser leniency from the court, and later High Court decisions have recognised that intention includes recklessness: XL Petroleum v Caltex i(1985) 155 CLR 448 at 471; Northern Territory v Mengel (1995) 185 CLR 307 at 347.  Jaensch v Coffey (1984) 155 CLR 549 at 556; Petrie v Dowling  1 Qd R 284; Skea v NRMA Insurance  ACTCA 9. For example, an abnormality may not be so pronounced as to take it outside the normal bounds of reasonable foresight.  Tame v NSW (2002) 211 CLR 317.  Review of the Law of Negligence: Final Report (2002) at par. [9.28].  Civil Liability Act 2002 (NSW) s 32(1); Civil Law (Wrongs) Act 2002 (ACT) s 34(1); Civil Liability Act 1936 (SA) s 33; Civil Liability Act Act 2002 (Tas) s 34; Wrongs Act 1958 (Vic) s 72; Civil Liability Act 2002 (WA) s 5S.  The statutory preference for the term Ã¢â¬Ërecognised rather than Ã¢â¬Ërecognisable psychiatric illness is a further factor potentially limiting recovery in consequential mental harm cases and contrasts with the approach of the common law. Eg. Civil Liability Act 2002 (NSW) s 33.
Tuesday, May 19, 2020
Most people only know Thomas Jefferson as the third President of the United States but he was much more than that. Thomas Jefferson was a very controversial man. From his work as a Founding Father to the mysteries of his personal life, Americans continue to find him to be very intriguing. He challenged the way the government was run previously by the first two presidents and became an advocate for the people. This paper talks about JeffersonÃ¢â¬â¢s role as a leader during the creation of the Declaration of Independence, his life before he became well-known, and the controversies related to his relationship with his slave named Sally Hemings. Thomas Jefferson was one of the most famous of the Founding Fathers of theÃ¢â¬ ¦show more contentÃ¢â¬ ¦Around this time, disagreements began and people had different viewpoints on how the country should be run. Two political parties formed, the Federalists and the Democratic-Republicans. This was the time when the government was being develop ed. People were just figuring out what party they wanted to be a part of, and who they did not care for. Thomas Jefferson helped reshape the government before he was even elected President. He Ã¢â¬Å"promoted religious freedom, helping to establish the countrys separation between church and state, and he advocated free public education, an idea considered radical by his contemporariesÃ¢â¬ (Millercenter web). He was also a delegate for the Virginia House of Delegates and later became the governor of Virginia for two years (Millercenter web). Jefferson influenced the way people thought about the relationship between the government and the lives of citizens. His beliefs challenged the governmentÃ¢â¬â¢s role established by the Founding Fathers. Thomas Jefferson was elected the third President of the United States in 1801. On Inauguration Day, he broke tradition and rode on a single horse by riding to and from the ceremony by himself (Crawford 16). 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Wednesday, May 6, 2020
According to Article One, Section Eight, Congress has the power Ã¢â¬Å"To declare war, grant letters of marque and reprisal, and make rules concerning captures on land and water;Ã¢â¬ This means that Congress must be consulted before going to war and has the power to not only declare war, but also the power to raise an army and navy, to fund war effort; however, the President, in Article II, is named commander-in-chief of the armed forces, but this does not give him the power to commit armed forces to war. Although the Constitution grants Congress the power to declare war, there has been much debate about who should actually have the power to wage war. Often times, Congress is argued to be the better fit because the decision made will be well thought out, democratic, and promote international harmony. The other side of the argument states the the president should be the one to wage war. Even Alexander Hamilton stated that Ã¢â¬Å"Presidents should conduct war, because they could act with Ã¢â¬Å"decision, activity, secrecy and dispatch.Ã¢â¬ Presidents also can make a quick decision without waiting on Congress and their disagreements due to the fact that foreign affairs can often be unpredictable. The president must act as a strong leader in a national crisis to instill trust within the public. Though either side may sound appealing, they both have drawbacks. Congress can garner too many opinions, certain seat holders donÃ¢â¬â¢t want to make a decision that could possibly jeopardize re-election, andShow MoreRelatedWar Powers Resolution777 Words Ã |Ã 3 PagesWar Powers Resolution What have been the political and legal effects of the passage of the War Powers Resolution in 1973? Table of Contents Part A: The Plan of Investigation 3 Part B: Summary of Evidence 3 Part C: Evaluation of Sources 5 Part D: Analysis 6 Part E: Conclusion 8 Part F: Sources 9 Part A. Plan of Investigation Research Question: What have been the political and legal effects of the passage of the War PowersRead MoreWar: Nuclear Power1087 Words Ã |Ã 5 PagesThe Cold War was a time of great tension all over the world. From 1945 to 1989, the United States was the leader and nuclear power and was competing with the Soviet Union to create huge stockpiles of nuclear weapons. However, even though the Cold War ended, nuclear weapons are still a threat. Countries around the world strive to create nuclear power, and they do not promise to use it for peaceful purposes. Some examples of the struggles caused by nuclear weapons include the bombings of HiroshimaRead MoreThe War Of The European Powers1605 Words Ã |Ã 7 PagesMonroe doctrine, In the wars of the European powers, in matters relating to themselves, we have never taken part, nor does it comport with our policy, so to do. GermanyÃ¢â¬â¢s submarine warfare and ZimmermanÃ¢â¬â¢s note shifted our view and got us involved in WWI. (Ã¢â¬ Å"U-S-History.comÃ¢â¬ ) Today USA is a world super power and not nearly as isolated as we used to be. A foreign issue becomes an American issue when it threatens our security. This can be seen through the Cold War, global wars, cyber warfare, and terrorismRead MoreThe Division Of War Powers1418 Words Ã |Ã 6 Pagesof War Powers There is a long standing debate in American politics over whether or not the President has unilateral war powers. Article II, Section 2, Clause 1 of the United States Constitution states that the President will be Commander in Chief of the navy and army and thus has the power to organize and lead military operations. However, the power to declare war officially lies in the hands of Congress based on Article I, Section 8, Clause 11 of the Constitution. This division of war power betweenRead MoreThe Balance Of Power And The Cold War1619 Words Ã |Ã 7 PagesCritically analyse the balance of power with two examples. 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Instead, the Constitution grants Congress the powers to declare war, provide for armed forces, and pass legislation to authorize military action against another nation as done in the recent War against Afghanistan in 2001. While Congress has the ultimate authority to declare war; an authority determined constitutional during the quasi-wars, the PresidentRead MoreThe Power to Declare War Essay1246 Words Ã |Ã 5 PagesThe Power to Declare War Ritwik Ravin Poltical Science Mrs. Mooney December 13, 2010 Ricky Ravin, Mrs. Mooney The Power to Declare War Congress and the president use their powers to check and balance each other. One power of Congress is the ability to declare war. However, Congress generally gives the president control during war time. Because of this, the president is able to acquire more power over the war while Congress can do little if they have already given theirRead MoreThe War Powers Resolution Of 1973986 Words Ã |Ã 4 PagesWho has the power to go to war? Most people would say the President while others would say Congress. The War Powers Resolution of 1973 may shine some light on who or whom can declare war. The War Powers Resolution of 1973 also know simple as the War Powers Act states the President must notify Congress within a 48 hour time frame that he is sending troops into military combat. The act does not allow military solders from remaining in a state of conflict for more than 60 days. After 60 days the President
Chinmaya Sharma Field LNG 406 25 January 2011 Capital Punishment Ã¢â¬â Just: An Annotated Bibliography Capote, Truman. In Cold Blood: A True Account of A Multiple Murder and Its Consequences. New York: Vintage, 1994. Print. Crowe, Robert E. Should Capital Punishment be Retained? Pro. Congressional Digest Aug. 1927: 228+. Academic Search Complete. EBSCO. Web. 26 Jan. 2011. Crowe believes the primary benefit of capital punishment is its usefulness in deterring any future criminal acts, particularly murders. He asserts the death penalty is the only punishment equal in value to the murders or other crimes for which capital punishment is sentenced. While attacking the United States government for its lack of criminal regulation, Crowe suggests capital punishment will instill fear in criminals and make them think twice before committing a violent crime. He states this fear of punishment is what protects citizens from the wrath of brutal murderers who, without the death penalty, would believe they have nothing to fear. Crowe proclaims someone who tries to nullify the death penalty in court is hampering the progress of the American government and is keeping the rest of society in danger. As the article continues, Crowe concurs that the feeling of being on the jury of a murder trial is one of the most difficult as you hold the life of a person in your hands. However, he believes people have the best interest of their society in mind. Crowe uses Chicago as an example of how capital punishment as resulted in the decrease in murders and other crimes. Throughout the rest of the article, Crowe discusses how the life of the victim is forever lost and the punishment should be proportionate to the rime, how even those who are deemed irresponsible should be sentenced to the death penalty for the better of society, and how there is proof of capital punishment deterring further crime. CroweÃ¢â¬â¢s analysis of capital punishment and its justification is thorough, but only thorough in one aspect. The author focuses only on the deterring effect the death penalty has on crime and other murderers. His information is credible, but seems to be more focused on appealing to the emotion s rather than stating blatant facts. The source of this article is a congressional magazine. service writing format Therefore, staying within the limits of the slight bias, the information is coming from a credible source and should be valuable for my research and debate.. Due to the article dating back to the 1920s, the statistics and facts of this article may not be accurate. While some of my other research has focused on addressing counter-arguments, this article solidifies one strong point. CroweÃ¢â¬â¢s argument revolves around the deterring effect of capital punishment on murders. Therefore, this article will provide a basis for my analysis of the societal results of the death penalty. I will also use the statements made by Crowe about how it is the moral duty of the justice system to protect and provide for the citizens for the country. By leaving these murders and criminals alive, he believes we are putting the rest of society at risk. This article will prove to be invaluable when addressing some of the issues such as societal safety and the overall effects of capital punishment on future criminal acts. Franklin, H. Bruce. Billy Budd and Capital Punishment. American Literature. Web. 02 Feb. 2011. . History: Early World and American Death Penalty Laws. Ã Death Penalty. Web. 02 Feb. 2011. . Johnson, Robert, and Sandra Smith. Life Without Parole, AmericaÃ¢â¬â¢s Other Death Penalty. The Prison Journal. Sage Publications. Web. 30 Jan. 2011. . Life without parole is examined as a form of death penalty. The authors declare how life without parole is a true life punishment because the prisoners must live their lives knowing that they will never be allowed out. The t wo interview many of the prisoners and prison officers to understand the conditions, both mentally and physically, of the prisons in which these criminals stay. Smith and Johnson indicate the conditions of the prisons are ideal because they include food, a bed, recreation and many other commodities. The true impact comes from the emotional turmoil from knowing that the prison is where they will die. While many assume the life without parole prisoners must be a threat to society within and outside of the prison, the authors prove the emotional impact changes the criminals and makes them more respectable people The article also shows how these people feel so lonely and that is why life without parole is a viable alternative for the death penalty. Overall, this source will probably be the least used source out of my entire bibliography. I chose this source when I knew that my part of the argument would be about the conditions of prisons. However, the article does satisfy the part of my argument that shows how the prisons of these criminals are actually in perfect condition and how the prisoners enjoy the conditions while living there. Robert Johnson and Sandra Smith both work at large universties and are publishing a significant article. Therefore, I believe this article is reliable and the information should be credible. The goal of the source is to show how life without parole is not as good as everyone believes it is. The source is objective because it shows both good and bad aspects of prison. I will use this source to help prove my point about the condition of the prisons. Johnson and Smith both indicate how the conditions are fantastic with food and recreation. These conditions are better than many of the conditions of people living in America. I will also utilize the first-hand account of one of the prisoners to back up my argument. It will fit perfectly into the body of my argument by shaping how I explain how tax-payersÃ¢â¬â¢ money is furnishing a lavish living style of these criminals compared to what they were in before. Hopefully, this evidence will help convince people that the minor cost difference that may occur at times between life without parole and capital punishment is miniscule when considering the broader aspect. Sharp, Dudley. Death Penalty Paper. Ã Pro-death Penalty. Web. 30 Jan. 2011. . SharpÃ¢â¬â¢s article assesses every aspect of the capital punishment argument. He starts by indicating how the anti-death penalty movement has overwhelmed the debate and has filled peopleÃ¢â¬â¢s minds with lies which have no substantial evidence. He states how capital punishment is the only punishment which fits the amplitude of the crime. When addressing the risk of a innocent man being executed, he explains how the statistics given by most people are incorrect. In the United States, there have only been a minute amount of cases where an innocent man was executed. Sharp illustrates the lack of mistakes involving the death penalty. Sharp continues to summarize how the death penalty is a deterrent to crime and how this fact is conclusive and irrefutable. He also states how capital punishment makes American society a safer place to live. Throughout the rest of the article, Sharp talks about a variety of topics including race and the death penalty, cost of capital punishment versus life without parole, death penalty procedures and the relation between Christianity and capital punishment. Sharps analysis of every argument makes this article absolutely perfect for the debate supporting capital punishment. For every point he makes, he provides a resource and occasionally a justification if numbers should be altered. Since this site is primarily about supporting capital punishment, a small bias maybe evident in his writing. He seems to be a credible source because he works as the Death Penalty Resources Director at Justice For All. I think his article could be used for a variety of purposes because he encompasses all of the major points supporting capital punishment. He frequently takes information from the Death Penalty Information Center, reinforcing his credibility. I think this article will be valuable to be because of the statistics and information it uses to show how capital punishment is actually cheaper then life without parole. Unlike most of the other sites I have looked at, it actually provides calculations step by step and justification if certain numbers are only estimates and how these estimates were made. Sharp does not leave any part of the argument with a weak end. Since my argument is the cost between death penalty and life without parole, this article will almost suffice as all I need. I believe it will be very difficult to refute evidence which is so precise such as the information Sharp has provided. This article will help show that the death penalty is cheaper than life without parole. Stanton, Edward C. Should Capital Punishment be Retained? Pro. Congressional Digest Aug. 1927: 232+. Academic Search Complete. EBSCO. Web. 25 Jan. 2011. StantonÃ¢â¬â¢s article assesses each specific argument made by people supporting the abolishment of capital punishment and provides a logical and complete rebuttal. After reviewing past articles and statements made by these abolitionists, Stanton states that most of these people are sentimentalists who have completely battered the minds of readers into a state of submission. Through the use of two court cases in the past few years in which murderers were given a lighter sentence than they deserved, the author reiterates sentimentalists brainwash and destroy the backbone of juries. Furthermore, Stanton provides statistics demonstrating the increase of homicides in the United States. Stanton declares most of the sentimentalists lack experience dealing directly with murders which makes their statements difficult to believe. Throughout the rest of the article, the author indicates several of the arguments these sentimentalists put forth and counters with his own support of capital punishment. Stanton includes counter-arguments against all of the following: choosing life-imprisonment over capital punishment, giving opportunities to the criminals, capital punishment being a practice of the past, and the chance of having an innocent person convicted and executed. Stanton provides a substantial and thorough analysis of why capital punishment should be maintained as a policy in the United States. His information seems credible as he uses several statistics and court cases to reinforce his statements. Stanton may be slightly biased because he has dealt with murders in the past, but this also contributes to his authenticity. The information is quite reliable as it comes from a congressional magazine. This article primarily focuses on telling the complete truth about capital punishment and convincing people capital punishment is a just form of punishment. Stanton tries to eliminate the flowery and false information sentimentalists provide for readers. The only negative aspect of this article is it dates back to the 1920s. Therefore, the statistics cannot be used for present-day. StantonÃ¢â¬â¢s article on capital punishment satisfies one of the requirements for my debate. He provides an answer for many of the points the other team may use. The article shapes how I will write my rebuttal by providing information which would counter most of the arguments put forth by those arguing capital punishment as an unjust form of punishment. Stanton solidifies my view that capital punishment deters criminals from committing the worst crimes because they fear the death penalty. He also addresses the fear of executing people are innocent of a crime. Since the chance of a false conviction is so small, any doubt that the death penalty is a proper form of punishment for those criminals with unforgiveable crimes should be forgotten. StantonÃ¢â¬â¢s views coincide with my own and provide a solid base for a rebuttal in the debate.
Wednesday, April 22, 2020
Technology Effect On Society The microeconomic picture of the U.S. has changed immensely since 1973, and the trends are proving to be consistently downward for the nation's high school graduates and high school drop-outs. "Of all the reasons given for the wage squeeze - international competition, technology, deregulation, the decline of unions and defense cuts - technology is probably the most critical. It has favored the educated and the skilled," says M. B. Zuckerman, editor-in-chief of U.S. News & World Report (7/31/95). Since 1973, wages adjusted for inflation have declined by about a quarter for high school dropouts, by a sixth for high school graduates, and by about 7% for those with some college education. Only the wages of college graduates are up. Of the fastest growing technical jobs, software engineering tops the list. Carnegie Mellon University reports, "recruitment of it's software engineering students is up this year by over 20%." All engineering jobs are paying well, proving that highly skilled labor is what employers want! "There is clear evidence that the supply of workers in the [unskilled labor] categories already exceeds the demand for their services," says L. Mishel, Research Director of Welfare Reform Network. In view of these facts, I wonder if these trends are good or bad for society. "The danger of the information age is that while in the short run it may be cheaper to replace workers with technology, in the long run it is potentially self-destructive because there will not be enough purchasing power to grow the economy," M. B. Zuckerman. My feeling is that the trend from unskilled labor to highly technical, skilled labor is a good one! But, political action must be taken to ensure that this societal evolution is beneficial to all of us. "Back in 1970, a high school diploma could still be a ticket to the middle income bracket, a nice car in the driveway and a house in the suburbs. Today all it gets is a clunker parked on the street, and a dingy apartment in a low rent building," says Time Magazine (Jan 30, 1995 issue). However, in 1970, our government provided our children with a free education, allowing the vast majority of our population to earn a high school diploma. This means that anyone, regardless of family income, could be educated to a level that would allow them a comfortable place in the middle class. Even restrictions upon child labor hours kept children in school, since they are not allowed to work full time while under the age of 18. This government policy was conducive to our economic markets, and allowed our country to prosper from 1950 through 1970. Now, our own prosperity has moved us into a highly technical world, that requires highly skilled labor. The natural answer to this problem, is that the U.S. Government's education policy must keep pace with the demands of the highly technical job market. If a middle class income of 1970 required a high school diploma, and the middle class income of 1990 requires a college diploma, then it should be as easy for the children of the 90's to get a college diploma, as it was for the children of the 70's to get a high school diploma. This brings me to the issue of our country's political process, in a technologically advanced world. Voting & Poisoned Political Process in The U.S. The advance of mass communication is natural in a technologically advanced society. In our country's short history, we have seen the development of the printing press, the radio, the television, and now the Internet; all of these, able to reach millions of people. Equally natural, is the poisoning and corruption of these medias, to benefit a few. *From the 1950's until today, television has been the preferred media. Because it captures the minds of most Americans, it is the preferred method of persuasion by political figures, multinational corporate advertising, and the upper 2% of the elite, who have an interest in controlling public opinion. Newspapers and radio experienced this same history, but are now somewhat obsolete in the science of changing public opinion. Though I do not suspect television to become completely obsolete within the next 20 years, I do see the Internet being used by the same political figures, multinational corporations, and upper 2% elite, for the same purposes. At this time, in the Internet's young history, it is largely unregulated, and can be accessed and changed by any person with a computer and a modem; no license required, and no need for millions of
Monday, March 16, 2020
Business resources M1 Essays Business resources M1 Essay Business resources M1 Essay Asses how managing these resources can improve the performance of your selected organisation. Managing business resource is vital for any business if they are determined to do well. A business has two types of resources and by managing the business resource it can improve the performance of the business in many areas such as profit margins and market share. If Sainsbury use they staff in an appropriate manner and make use of all they skills and abilities then the business can gain high amount of output for instance high level of productivity, motivated and improve team working. The business can give the staff training to broaden the skills and abilities of the staff which will benefit the business has the staff will be multi-skilled and will be able to work in different areas so if there was a staff absent another staff can filled and do the job task required.. There is two kind of training that could be given to the staff one is one the job training and the other is off the job training. This will benefit the business as it will have staff who can do various task and might decide to save money by making some employees redundant. If Sainsbury manages its equipment appropriately use the equipment to it full capacity and strength then the business can gain good level of productivity from the machine. If the business uses it equipment appropriately it will improve the performance of the business for instance if the business use they tills appropriately it will help speed queue time, help them with level of stock and minimise errors for the employees.. Every year the equipment which business uses depreciate in value so the business needs to cover the cost of the equipment by using the equipment properly. If Sainsbury manages its building properly by using to its full capability and ability then the business will manage to decrease costs and by redeeming cost from the use of the building. For instance if the business has empty shelves in the building then the business will not be gaining any money from that space of the building and they are not using the equipment to its strength which means they are not recouping they cost. If Sainsbury manages its security properly then the business has the assurance of they stock and valuable in the business are safe and secure. This can be only done if the security cameras are checked regularly if they are working and if the alarms set on at the right time. If these are not checked then business risks losing they stock and valuables by little mistakes which could have been corrected. If Sainsbury manages it materials correctly then the business will manage to produce loads of goods with those materials and save cost. However if the business doesnt not use its materials appropriately then the business will risk wasting they materials increase in costs. So using the business materials appropriately then it would improve the performance of a business as it will reduce cost by using the materials correctly. If a business uses its safety materials appropriately by cleaning the building on a regular basis then it would attract customers and the customers would appreciate the environment. If Sainsbury manages its vehicles such as vans and trucks correctly then the business will manage to recoup the cost of those vehicles by using the vehicles to its capabilities. If Sainsbury for instance use their vans appropriately for home deliveries then the business might manage to increase sales through online shopping as customers would be content with the service. If Sainsbury for instance use they trucks properly then they will manage to maintain they stock level by having the deliveries on time. This will eventually have an impact in the performance of the business by improving the performance. If Sainsbury manages it products correctly then the business will manage to sell most of its product and gain profits from those products. However if the business doesnt manage its products appropriately then the business will risk wasting those products which will mean the business would have increase costs. So using the products owned by the business appropriately would improve the performance of a business as it will have high sales levels and gain high profit margins from those products.
Saturday, February 29, 2020
A Worn Path Short Story Research Paper Essay ? Many obstacles can be taken when one desired the most is at risk. Phoenix Jackson is an old woman who has the right intentions, but meets many conflicts on the way. In the short story, Ã¢â¬Å"A Worn PathÃ¢â¬ , Eudora Welty predicts that one never knows where a path will end up leading them through conflict and symbolism. Phoenix Jackson warns that one never knows where a path will end up leading to. In the short story Ã¢â¬Å"a Worn PathÃ¢â¬ , Phoenix Jackson goes through many obstacles on the path to find medicine for her Ã¢â¬Å"grandsonÃ¢â¬ (Welty). Phoenix is on a mission to retrieve treatment for her grandson. She is willing to face anything that gets in the way of her path leading to her destination. As Phoenix faces her journey she will reach conflicts beyond the way. While on the path to complete her mission phoenix stumbles upon many conflicts. In the short story Ã¢â¬Å"a Worn PathÃ¢â¬ , Phoenix comes encounter with intimidation of a Ã¢â¬Å"young hunterÃ¢â¬ in the woods (Heller). The hunter tests the old lady of weakness as he boasts of himself throughout the scavenged woods. Although the hunter has a gun with any possible chance to use it on Phoenix, she resembles courage upon the conflict for going about her business and continuing about her quest. In the short story Ã¢â¬Å"a Worn PathÃ¢â¬ , old woman Phoenix struggled up a hill Ã¢â¬Å"extricate[ed] herself from a thorn bushÃ¢â¬ , and crossed a log over a creek (Piwinski). As the woman struggles to get out of the bush she chooses to not give up and continue forward her path. The woods may have brought conflict and obstacles to Phoenix, but that wonÃ¢â¬â¢t stop her from reaching the end of her journey. A Worn Path Short Story Research Paper. (2018, Oct 26).