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Anne Sexton#8217;s #8220;Cinderella#8221; Essay Sample. Quotations On Democracy? Through literary devices such as simile, repetition and symbolism, Anne Sexton delivers the message that there is no way to live #8220;happily ever after.#8221; Using four short stories as a lead in, Sexton makes powerful arguments about society by creating the symbol of the dove and alluding to the story of Cinderella. For Sexton there is of Drinking, no Cinderella, there is no prince charming, and there is no happy ending. However, through #8220;Cinderella,#8221; she argues that the #8220;happy ever after#8221; ending remains an illusion society chases. Sexton initially presents examples of success stories in which people, with lives of hardship, receive everlasting happiness due to superficial commodities.
Sexton creates emphasis for on democracy the multiple stories using sentence fragments such as #8220;from toilets to riches,#8221; (4) and reports essays, repetition of on democracy essay, #8220;that story#8221; to capital summary create colloquial tone. Since colloquial tone and essay, repetition are devices used everyday during conversations, the reader experiences the stories on a more intimate level, as if they were communicating with a friend. Sexton#8217;s first story describes a #8220;plumber with the Promise of Equal Opportunity Essays, twelve children#8221; (2) who transforms his life from tragedy to triumph from winning the #8220;Irish Sweepstakes#8221; (3). Sexton uses the stories to point out a reoccurring theme: a person cannot become instantaneously happy despite their good fortune, because real life is filled with tribulation. Similar stories of disheartened souls who change their lives from #8220;rags to riches#8221; are used as a lead in to the Sextons main allusion, #8220;Cinderella.#8221; Sexton leads into #8220;Cinderella#8221; by contrasting the supposed success stories to the tale of a young woman who searches for a similar fate, only to quotations find a modicum of contentment after an ordeal. Cinderella, the main character in the poem, is portrayed as being unfortunate, mistreated, and discouraged. Sexton creates understanding for Cinderella using similes. In the first stanza, Cinderella#8217;s step-sisters are said to be beautiful although they still have #8220;hearts like blackjacks#8221; (29). Sexton constructs the simile to compare the sister#8217;s characteristics to that of a lethal weapon, heartless and violent.
Furthermore, the comparison is made because it helps define a reoccurring theme: appearances can be deceiving. Such a theme can also be applied to Cinderella. Sexton associates Cinderella#8217;s appearance, blackened with soot, to that of Al Jolson through metaphor. Al Jolson used make-up to blacken his originally white skin. Initially, the metaphor implies Cinderella is not only tired and disheveled, but filthy from head to toe. Such a metaphor also reveals that Cinderella#8217;s personality, which is constantly overlooked, is white beneath the surface of a black exterior. Sexton establishes additional pity for Cinderella, by having Cinderella#8217;s father bestows gifts upon each sister, where the other sisters receive gifts fit for alliance definition queens, and Cinderella merely receives a twig. The twig, planted upon the grave of Cinderella#8217;s mother, brings a symbol of protection and truth. A dove, which represents Cinderella#8217;s mother and protector, sits upon on democracy the newly planted twig and grants happiness to Cinderella whenever she requests it.
Initially, the dove is assigned is to pick-up the lentils, spilt by the wicked step-mother, allowing Cinderella to go to the ball. For Progress? With the help of quotations, many other birds, the dove completes the extremely difficult task. Reports Essays? Because of this, Cinderella is on democracy essay, freed of the Power of Drinking, shackles bounding her to domestic housework, therefore, allowing her to pursue her happiness. Sexton relates Cinderella to the dove by announcing the bird#8217;s #8220;warm wings#8221; (51) and gentle touch originate from the on democracy, #8220;fatherland,#8221; (51) which represents Hitler#8217;s tyrannical reign. Similarly, Cinderella#8217;s kindness and love are suppressed by side the cruelty of her family. After the step-mother still does not allow Cinderella to go to the ball, Cinderella pleads to the dove, her provider of pleasure, and is answered in full. As the dove becomes more essential to the happiness of Cinderella, the dove also becomes more powerful. Quotations Essay? It is noted by the narrator that the dropping off of a dress and shoes is #8220;rather a large package for such a simple bird#8221; (63). With her magnificent gown and majestic shoes in hand, Cinderella proceeds to the ball where the prince falls madly in love with her solely based on for progress her appearance. However, the quotations on democracy essay, prince is unable to recognize Cinderella after she changes back to her sooty face and ragged clothes. The shallow relationship between Cinderella and the Prince reveals another fault of society: the pressure placed on side superficial characteristics and the emphasis placed upon beauty is a priority set too high.
When people must #8220;gussy up#8221; (30) to be noticed, the person within is unable to be seen. The Prince searches for his beloved beauty using a golden shoe left by Cinderella at the ball. The shoe signifies the #8220;happy ever after#8221; ending that so many people in society pursue. The step-sisters, who are both #8220;delighted because they [have] lovely feet,#8221; (80) represent many citizens in society. Although their feet are beautiful, the on democracy, step-sisters are willing to take their foot and #8220;slice it off and put on for progress definition the slipper#8221; (83) to live the blissful ending they were hoping for. As the image of self-mutilation indicates, people across the world take extensive measures to try and obtain the happiness that they have sought after for so long. The same happiness the step-sisters are close to quotations on democracy stealing is ruined by the dove. Summary? Cinderella#8217;s protector, the dove, speaks to the prince and announces his obvious mistake in choosing the wrong woman. By revealing the step-sisters as merciless frauds, to quotations on democracy the Prince, the dove becomes defined as the movie summary, revealer of truth in a story of corruption. Quotations On Democracy Essay? The truth the dove relays to the Prince helps to relay a truth of society: competition for the same dream will not only turn fair intentions sour, but also cause people to use extreme measures against one another in hopes of accomplishing their goals.
The two sisters are willing to ruin Cinderella#8217;s happiness in Essay on The Power exchange for their own. The subtle tragedy of the sisters is created by Sexton to strengthen her argument about people in society being able to hurt one another. The first sister suffers defeat and quotations, is left with a mutilated toe: #8220;That is the way with amputations. They don#8217;t just heal up like a wish#8221; (86-87). Sexton then creates sympathy for the originally cruel sisters by stating their injuries will have a lasting effect. Sexton uses the comparison between the sisters#8217; amputation and the blind side movie, a wish to add emphasis to a prior theme: lasting effects occur when people in society compete for the same dream.
Sexton alludes to the step-sisters to demonstrate that the injuries of those who cannot obtain the dream are often great. Sexton acknowledges how oblivious people can be to each other by creating another simile. The reference to Cinderella#8217;s foot fitting the shoe #8220;like a love letter into quotations on democracy essay, its envelope#8221; (94) is a contradiction. The connotations of a love letter are associated with true love, tender care, and a romantic life. These conceptions are very different from the supposed #8220;love#8221; the Prince and Cinderella share. Reports Essays? Their love includes competition, superficiality, and agony upon others. Both of them become utterly unaware of the multiple people they crush in attempting to achieve their personal goals. Through the irony of Cinderella#8217;s #8220;perfect#8221; relationship with the prince, Sexton displays how purposefully ignorant members of quotations on democracy, society can become in order to achieve their own happiness. Sexton distinguishes the hot stove rule, dove as Cinderella#8217;s protector at Cinderella#8217;s wedding. As the wretched step-sisters make a final attempt to steal Cinderella#8217;s groom, the dove sees through their pretty faces to their blackened hearts and dark intentions.
The symbol of the dove gains importance as the quotations on democracy, announcer of Essay on The Power, truth because it destroys the sisters#8217; plans as well their exterior beauty by quotations on democracy essay #8220;[pecking] their eyes out#8221; (97). Cinderella#8217;s goal is marx, achieved. After a life of essay, hardship she is able to obtain her #8220;happy ending#8221; at the cost of her sister#8217;s anguish. However, throughout the final stanza Sexton uses similes to show the reader that such a life of happiness does not exist. On The Power Of Drinking? Instead, the quotations on democracy essay, Prince and Cinderella are #8220;like two dolls in a museum case#8221; (103), always perfect, never facing adversity, and on display for others to envy. Sexton uses the example to state that many members in alliance for progress definition society look upon each other in envy because other people appear to have the perfect life. Furthermore, Sexton supports the quotations on democracy, statement by implying the Essay on The Power, Prince and Cinderella live like #8220;regular Bobbsey twins#8221; (109) comparing them to children who effortlessly solve mysteries with almost overwhelming perfection. These similes provide information to lend support to the theory that such a life is meaningless, because there is so much more to life than simply being happy. Although the dolls appear cheerful, they are not truly alive. Sexton uses parallel construction about problems in reality such as, #8220;arguing over the timing of an egg,#8221; (104) and #8220;getting a middle-aged spread#8221; (106), to quotations on democracy state that living #8220;happily ever after#8221; is impossible because any real life contains hardship.
Throughout the the blind movie summary, poem Sexton alludes to the story of quotations essay, Cinderella, uses the symbol of the dove, and various similes to create a concrete theme about society#8217;s deranged perspective of what happiness is. Sexton couples allusion, symbolism, and simile with colloquial tone to identify the theme as society#8217;s inability to recognize its wrongdoings. Hot Stove Rule? When a society places false value upon superficial beauty, and quotations essay, feels the constant need to strive for the unattainable #8220;happily ever after,#8221; nothing but destruction ensues. Is this the perfect essay for you? Save time and order Anne Sexton#8217;s #8220;Cinderella#8221; essay editing for only $13.9 per page. Top grades and quality guaranteed! Relevant essay suggestions for Anne Sexton#8217;s #8220;Cinderella#8221; With many variations of fantasies, #8220;Happily ever after#8221; is reoccurring in every fairy tale. #8220;Cinderella#8221; by Anne Sexton is a different variation of the classic tale. The author sets up#8230; Satire in Anne Sexton#8217;s Cinderella.
In Anne Sexton#8217;s #8220;Cinderella#8221; one may ponder what the hot stove rule, purpose and tone is. Anne Sexton uses a strong satiric and on democracy essay, humorous undertone when poking fun at marriage. The use of#8230; Comparative Analysis of #8220;Cinderella#8221; and #8220;Ashputtle#8221; The purpose of this paper is to make a comparative analysis of two perspectives on reports essays the children#8217;s story of Cinderella. It contrasts the time periods and cultures of France and#8230; ?Good Triumphs Evil: Cinderella. Cinderella, as told by quotations on democracy Jacob and Wilhelm Grimm in Household Tales, is a tale most of Promise v. Reality of Equal, us are familiar with. Most know the version of the tale as told in#8230; Cinderella: A Literary Analysis. The story of Cinderella is a timeless classic that characterizes the essay, different aspects of historical writing.
Many later variations of the story derive their origin from classic antiquity, one being#8230; Symbolism in Disney#8217;s #8220;Cinderella#8221; The story of Cinderella has been shared through many generations, exploring the life of a beautiful girl who is cruelly abused by her wicked stepsisters and stepmother. For Progress? The director of#8230;
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How an quotations on democracy essay, Anti-Mormon Attorney Became a Member of the Church He Hated. What David Archuleta's Powerful Response to alliance for progress definition, the Las Vegas Shooting Taugh. A 20-Year-Old LDS Man Was Among Those Killed in Las Vegas Shooting. How Is a New Apostle Chosen in the LDS Church? Watch: Agnostic Las Vegas Shooting Survivor Testifies on essay CNN I'm a Firm. The Most Hilarious Twitter Reactions from General Conference. 35+ Cute and Clever Family Halloween Costume Ideas. How the Family of a Sandy Hook Victim Showed Me Christ Embraces Us, Even When Our Hearts Are Breaking. 16 Perfect Christmas Gift Ideas for LDS Missionaries. Jake Healey - We sing about them in beloved Christmas hymns.
We read about Essay on The Power them in holy scripture. We even have one of them standing triumphantly atop our temples. As members of The Church of Jesus Christ of on democracy Latter-day Saints, we wholeheartedly believe in hot stove rule, the existence of quotations on democracy angels. Of Drinking! But . Quotations On Democracy Essay! . . what are they, exactly? Perhaps much of the mystery that surrounds angels comes from Promise v. Reality of Equal Essays our reluctance to talk about them—and according to Elder Jeffrey R. On Democracy Essay! Holland, this needs to change. “I believe we need to speak of and believe in and bear testimony of . . On The Power! . angels more than we sometimes. Danielle B. Wagner - Faces of USGA, a nonprofit photojournalism project that dedicates itself to quotations on democracy, spreading awareness of LGBTQ students on Promise Opportunity Essays BYU campus, recently featured a lesbian student at BYU, one who simply calls herself a Mormon girl. (USGA, or Understanding Same-Gender Attraction, is an unofficial student group at BYU.) I want people to see my face. LGBTQ people at BYU have been anonymous for too long. I have been anonymous for too long.
I want people to know that we are here, she writes. > You'll also like: One Gay Man's Powerful Journey Away from the quotations on democracy, Church and Back Again (+ Important Insights for. LDS Living Staff - Five LDS artists recently released a new cover of One Sweet Day by Mariah Carey and karl capital, Boyz II Men. The five artists—Wayne Burton, Yahosh Bonner, Patch Crowe, Rebecca Lopex, and quotations, Madilyn Paige—had been working on the song for some time, but after the tragedy in Las Vegas, the group decided to release it earlier. The message in the song, that we can be with loved ones after we've lost them, is especially timely and poignant right now. The group of singers has dedicated the video to the victims and heroes of the for progress, Las Vegas shooting and the artists hope it will.
Deseret News - A Latter-day Saint and quotations essay, the first Tongan and Samoan to compete on the PGA Tour, Tony Finau says his faith and prayer is essential to his success in golf. It’s really an honor for me to represent my people at capital summary the level that I am. I think the Polynesian people and the gospel are in harmony,” Tony said. “We’re very respectful people, and very humble people . . On Democracy Essay! . and I try and let that shine through as much as possible. Tony Finau started playing golf in the 1990s when pictures of the blind side movie Tiger Woods graced the Wheaties boxes in the grocery store. Becky Douglas, Meridian Magazine - What a powerful story of quotations on democracy repentance and love that reaches beyond judgment and fear to see others the karl summary, way our Heavenly Father does. Essay! Several years ago a letter arrived with a return address that immediately caught my attention. It was from hot stove rule a prisoner in Maximum Security at the Utah State Prison. On Democracy Essay! My interest was immediately piqued and I tore open the envelope and began to read. It was from a prisoner on alliance for progress death row, Doug Lovell.
His story caught me completely by surprise: Several years ago PBS had featured a one-hour documentary on the work we do in India with the. Daily news, articles videos right to your inbox. We keep your email private. Angels Don't Have Wings + 4 More Things We Know About Them. Jake Healey - We sing about them in beloved Christmas hymns. We read about them in holy scripture. We even have one of them standing triumphantly atop our temples. As members of The Church of Jesus Christ of Latter-day Saints, we wholeheartedly believe in on democracy essay, the existence of angels.
But . . . what are they, exactly? Perhaps much of the mystery that surrounds angels comes from our reluctance to talk about them—and according to Elder Jeffrey R. Holland, this needs to karl marx capital, change. “I believe we need to speak of and believe in and bear testimony of . . Quotations On Democracy! . angels more than we sometimes. 35+ Cute and Clever Family Halloween Costume Ideas. LDS Living Staff - Halloween is v. Reality, so much more fun with kids! Here are our favorite epic costume ideas that involve the whole family. Peanuts Family Costume Mary Poppins Family Costume Peter Pan Family Costume S’more Family Costume Care Bear Family Costume Hot Dog Stand Family Costume Cinderella Family Costume Flinstone Family Costume Beekeeper Family Costume Ratatouille Family Costume MM Family Costume Up Family Costume How to Train Your Dragon Family Costume Harry Potter Family Costume Monopoly Family Costume Sleeping Beauty Family Costume Scooby Doo Family Costume Football Family Costume 101 Dalmatians Family Costume Star Wars Family Costume Goldilocks and the Three Bears Family Costume. Lesbian Mormon Shares a Powerful Message to Members of the Church: I Want People to See My Face Danielle B. Wagner - Faces of USGA, a nonprofit photojournalism project that dedicates itself to spreading awareness of LGBTQ students on BYU campus, recently featured a lesbian student at quotations on democracy BYU, one who simply calls herself a Mormon girl. (USGA, or Understanding Same-Gender Attraction, is an unofficial student group at BYU.) I want people to see my face.
LGBTQ people at BYU have been anonymous for reports essays too long. I have been anonymous for too long. I want people to quotations on democracy essay, know that we are here, she writes. Hot Stove Rule! > You'll also like: One Gay Man's Powerful Journey Away from the Church and Back Again (+ Important Insights for. 5 LDS Artists Sing Beautiful, Emotional Tribute to Victims and Heroes of quotations Las Vegas Shooting. LDS Living Staff - Five LDS artists recently released a new cover of One Sweet Day by movie Mariah Carey and Boyz II Men. The five artists—Wayne Burton, Yahosh Bonner, Patch Crowe, Rebecca Lopex, and Madilyn Paige—had been working on the song for quotations on democracy some time, but after the tragedy in Las Vegas, the group decided to release it earlier.
The message in the song, that we can be with loved ones after we've lost them, is especially timely and poignant right now. Side Summary! The group of singers has dedicated the video to the victims and heroes of the Las Vegas shooting and the artists hope it will. Historic Professional Golfer Shares How Living His Faith Helps His Game. Deseret News - A Latter-day Saint and the first Tongan and Samoan to compete on quotations essay the PGA Tour, Tony Finau says his faith and prayer is essential to his success in golf. It’s really an honor for me to represent my people at marx capital the level that I am. I think the Polynesian people and the gospel are in harmony,” Tony said. “We’re very respectful people, and quotations essay, very humble people . . . and the blind movie, I try and let that shine through as much as possible. Tony Finau started playing golf in quotations on democracy, the 1990s when pictures of the blind movie summary Tiger Woods graced the Wheaties boxes in the grocery store.
A Surprising Letter and Lesson I Received from a Man on Death Row. Becky Douglas, Meridian Magazine - What a powerful story of repentance and on democracy, love that reaches beyond judgment and fear to see others the way our Heavenly Father does. Several years ago a letter arrived with a return address that immediately caught my attention. It was from the blind side a prisoner in Maximum Security at the Utah State Prison. My interest was immediately piqued and I tore open the envelope and began to read. It was from a prisoner on death row, Doug Lovell. His story caught me completely by surprise: Several years ago PBS had featured a one-hour documentary on the work we do in essay, India with the. How One Humbling Question Led Sister Neill Marriott to Join the for progress definition, Church. Sister Neill Marriott, adapted from Seek This Jesus - General Young Women presidency second counselor Neill Marriott has had a lot of quotations powerful moments of inspiration in her life. One of those was the moment she joined the Church. Read her story here, as she tells it in v. Reality of Equal, her new book, Seek This Jesus . By the time I graduated from Southern Methodist University and moved to Cambridge, Massachusetts, to work, I think I had decided my religion would be based on quotations essay my belief that God wanted me to do my best, go to any Christian church, and then occasionally He would let me feel His loving acceptance . . LDS Church Donates 17,000 Meals for the Hungry in karl capital, Virginia.
LDS Living Staff - Just last week, The Church of Jesus Christ of Latter-day Saints donated more than 20,000 pounds of food to Feeding America in quotations essay, Richmond, Virginia, for the third year in a row. Reports Essays! That's the equivalent of essay 17,000 meals. September is Hunger Action Month and Essay of Drinking, this donation will replenish many of the on democracy essay, empty shelves in food banks. Feeding America Southwest Virginia President and CEO Pamela Irvine tells News Channel 7 in reports essays, Virginia the empty shelves are likely because the food has been sent to places hit hard by the recent natural disasters. Essay! The Church donated high-demand food such as flour, tuna, canned vegetables. How the Family of a Sandy Hook Victim Showed Me Christ Embraces Us, Even When Our Hearts Are Breaking.
Danielle B. Wagner - I have had the rare and achingly beautiful honor of reports essays getting to know Robbie and Alissa Parker, the essay, parents of Promise Emilie Parker, a victim of the quotations essay, Sandy Hook shooting that took the life of hot stove rule 20 elementary students and 6 school employees. Over the past three months, I have read their story, heard their story one-on-one, and essay, have even had the unique privilege of writing a small piece of alliance for progress definition their story. Alissa and Robbie's bravery has astounded me as they have shared vulnerable, spiritual aspects of their loss, opening my eyes to how an act of violence can impact a family. But what is. Elizabeth Smart Shares Why She Decided to quotations on democracy, Help Create a Movie About Her Kidnapping, Abuse.
Deseret News - I just felt like (this Lifetime film) was another opportunity to definition, share my story, to help—hopefully—other victims realize that they’re not alone, and on democracy, nobody deserves for these things to definition, happen to them, but they do (happen), but that no matter how hard it gets, don’t give up, Elizabeth Smart said. Elizabeth Smart told herself she would never make a movie about her kidnapping. “I also said I was never going to write a book and quotations on democracy essay, I was never going to speak about reports essays it, and I have and quotations on democracy, do both,” Smart said in an interview with the Deseret News . “I think. LDS Mom Writes Breathtaking Song I Need Thee Lord Months Before Losing Her 2-Year-Old Son. LDS Living Staff - Six months ago, CC Sampson felt inspired to write a song titled Show Me How, one that says, Please help me Lord, I need Thee now. Sampson had no way of knowing just two months later she would need those words more than ever when her 2-year-old son was hit and side summary, killed by a car just three days before his third birthday. After Levi's death, the on democracy, Sampson's raised money to help sick children at reports essays Primary Children's Hospital for Levi's birthday and began the campaign Live for Levi. The campaign inspires others to essay, do good, live and love everybody, and live fearlessly.
LDS Family Creates Amazing, Imaginative LEGO Scenes Based on General Conference Talks. LDS Living Staff - It's no secret that many people use LEGOs to construct amazing gospel-related structures including a six -foot model of the Christus , portraits of the prophets , and summary, scenes from the Book of Mormon or gospel life . No one can say Mormons lack creativity, and that extends to even the youngest members. Daniel and Brittany Burton and their children have been creatin g scenes based on general conference talks for more than two years now. Many of their posts use #ShareLegoGoodness . Ch eck out some amazing creations this adorable family has made from last weekend and quotations essay, conferences past. Mormon Creates Beautiful General Conference Notes That Are Mind-Blowing and Inspiring. LDS Living Staff - Many Mormons have their own unique ways of alliance definition viewing conference. Some build epic LEGO creations , others jot down inspiration that looks more like a work of art than notes. Take, for quotations on democracy essay instance, these notes posted to Facebook by Julie Hansen Olson. Essay On The! Filled with words from apostles and Church leaders, Olson writes down reminders, gospel truths, and quotations essay, insights that also visually capture what was shared during conference.
In addition to creating these notes, Olson posts them online, encouraging others to print and use these beautiful creations to remind them of the feelings they had during conference. But Olson isn't the alliance definition, only Latter-day. Las Vegas Shooting Survivor Says She Owes Her Life to Guardian Angel Deseret News - This story reflects this powerful quote from Elder Jeffrey R. Holland : When we speak of on democracy essay those who are instruments in the hand of God, we are reminded that not all angels are from the other side of the veil. Some of them we walk with and talk with—here, now, every day. A survivor of the Las Vegas shooting says she met her “guardian angel” during the night of capital gunfire. Essay! Gail Davis told CBS News that she witnessed the terrifying event, at reports essays which 59 people were killed and more than 500 were injured. She said she heard “four little pop, pop. When General Conference Feels Overwhelming, Uninspiring, and quotations on democracy essay, Frustrating. Aggieland Mormons - What a beautiful reminder that we won't always be in the same place spiritually for every general conference, and when we run into difficulties, we should be patient with ourselves and find ways to receive inspiration without becoming overwhelmed. As Koby Dudley reminds us,It is important to recognize that the purpose of conference is to guide and edify us.
This can be done in a myriad of ways. Heavenly Father loves us and knows us individually. The Blind! So we aren’t expected to all learn and love in the same way. When I am struggling with work, school, or personal matters I tend. How Latter-day Saints in Las Vegas Are Lifting Others After the Deadly Shooting. LDS Church News - It’s really been amazing to quotations essay, see the way people have rallied and come together in our city, says Dee Moody. Latter-day Saints in the Las Vegas area recoiled in horror Sunday after learning their city had become the site of the most deadly shooting spree in U.S. history. Their second response? Let’s get busy and help. Just hours after the tragedy, Mormons across Nevada’s Clark County and beyond were mobilizing to hot stove rule, do all they could to offer relief and a bit of hope to shooting victims, their families, first responders and quotations essay, hospital workers.
The Church members who spoke to of Equal Essays, the Church. How the Life and on democracy essay, Death of an the blind movie, LDS Teen Saved One Woman from Suicide and Brought Her and Others to quotations on democracy, the Church. Jannalee Sandau - “They are not far from us, and hot stove rule, know and understand our thoughts, feelings, and motions, and are often pained therewith.” – Joseph Smith, Jr. This quote from the first prophet of this dispensation about how thin the veil is rings especially true for essay the friends and family of the late LDS teen Kennedy Hansen. Kennedy, who started out as a normal little girl, had a passion for kindness, a talent for hugs, and side movie, a dream of being a cheerleader. Kennedy was diagnosed with juvenile Batten disease when she was 15. Though her mental and physical state quickly declined, Kennedy’s sense of. 16 Perfect Christmas Gift Ideas for LDS Missionaries.
LDS Living Staff - It might seem early, but now is the quotations on democracy essay, time to send gifts to ensure that they arrive before Christmas. Here is the the blind side summary, perfect gift guide full of inspiring and affordable gifts for your missionary. Plaid Wool Missionary Stocking Send love from on democracy essay home to your favorite missionary and his or her companion with these adorable Christmas stockings. Get one for hot stove rule the home as well to keep your missionary a part of the festivities! Buy Now Called to Serve Missionary Journal Designed especially for missionaries, this journal include pages to record personal history, line of authority, companions, special dates and more. Buy Now. 8 Behind-the-Scenes Pictures of the Mormon Tabernacle Choir at Conference. LDS Living Staff - The Mormon Tabernacle Choir is world-renowned for its spectacular performances and talented members. And this last general conference was enhanced by the wonderful voices of the choir as they sang hymns cherished by members. But not everyone gets to see what happens behind-the-scenes at conference. Quotations On Democracy Essay! Check out these amazing pictures below of the Mormon Tabernacle Choir like you've never seen them before.
All images from the side movie, Mormon Tabernacle Choir Facebook page . How Is a New Apostle Chosen in the LDS Church? LDS Living Staff - Have you ever wondered how a new Apostle is chosen in the LDS Church? In Biblical times, we read of how Matthias was chosen to take up the office of apostle after Jesus ascended into heaven: And they gave forth their lots; and essay, the lot fell upon Matthias; and he was numbered with the the blind side movie, eleven apostles ( Acts 1:26 ). In the Latter days, we learn that the Quorum of the quotations, Twelve was called by revelation received by the Three Witnesses to the Book of Mormon (see Doctrine Covenants 18:26-47 ). Much the the blind side, same process is still used today. The Church. A 20-Year-Old LDS Man Was Among Those Killed in Las Vegas Shooting. Deseret News - Our thoughts and prayers are with the Robbins family. A 20-year-old member of The Church of Jesus Christ of quotations Latter-day Saints, Quinton Robbins, was among those killed in Sunday’s shooting at a Las Vegas country music festival. The massacre, which took place when a 64-year-old man opened fire from a high-rise hotel room, was the most deadly in modern U.S. history, killing 59 people and injuring 527. Alliance! The oldest of three children and a student at the University of on democracy Nevada at Las Vegas, Robbins was remembered by his grandmother as “just a jewel,” according to the Washington Post . Lead image. The Most Heartwarming and Opportunity Essays, Inspiring Photos from General Conference. LDS Living Staff - Pictures capture emotion and feeling beyond what words can describe.
Here are some photos from this general conference that encapsulate the feelings we felt and capture touching moments from this past weekend. General Women's Session All the following photos are from the Deseret News . To see more incredible photos and coverage from quotations on democracy essay conference, visit their site. Saturday Morning Session All the following photos are from the marx capital, Deseret News . To see more incredible photos and coverage from essay conference, visit their site. Saturday Afternoon Session All the following photos are from the Deseret News . To see more incredible photos and coverage from. Funeral Arrangements Announced for Elder Robert D. Hales.
Mormon Newsroom - Elder Robert D. Hales, a member of the reports essays, Quorum of the Twelve Apostles, passed away Sunday, October 1. Recently, funeral arrangements were announced for on democracy essay this beloved apostle who spent so much of his life in the service of the the blind side movie, Lord. Funeral services for Elder Robert D. Hales of the Quorum of the Twelve Apostles of on democracy essay The Church of karl capital summary Jesus Christ of Latter-day Saints will be held in on democracy, the Tabernacle on movie summary Temple Square Friday, October 6, 2017, at 11:00 a.m. MDT. The funeral will be open to the public ages 8 and quotations on democracy, older. Elder Hales died from causes incident to age on October 1. Elder Holland Shares What to We Need to movie, Remember When We Don't Feel Good Enough LDS Living Staff - The satisfaction that comes from self-improvement can be eclipsed by feelings of self-doubt, insecurity, or feeling like our best is quotations essay, not enough. These feelings, if not checked, can become dangerous and destructive in our lives.
So how do we combat them? In a recent Facebook post, Elder Jeffrey R. Holland helps shared a part of his general conference address that demonstrates where we can turn to when we feel we are just not good enough. I hear many who struggle with this issue: “I am just not good enough.” “I fall so far short.” “I will never measure up.” I hear.
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10 Resume Tips From A Legal Recruiter. Ed. note : This is the latest installment in quotations on democracy essay a series of posts on lateral partner moves from Lateral Link’s team of movie expert contributors. Abby Gordon is a Director with Lateral Link’s New York office. Abby works with attorney candidates on law firm and in-house searches, primarily in quotations on democracy New York, Boston, and alliance, Europe. Prior to quotations on democracy joining Lateral Link, Abby spent seven years as a corporate associate with Cleary Gottlieb, focusing on capital markets transactions for Latin American clients in marx New York and for essay, the last five years for European clients in Power Paris. A native of Boston, Abby holds a J.D., cum laude, from on democracy Georgetown University Law Center and a B.A. in Promise Essays government and quotations on democracy, romance languages, magna cum laude, from Dartmouth College. Alliance For Progress! Abby also worked with the International Rescue Committee as a Fulbright Scholar in Madrid, Spain.
She is a member of the quotations on democracy essay New York Bar and is fluent in French and Spanish (and dabbles in summary Portuguese and Italian). As a legal recruiter, I review numerous resumes each week in an effort to essay assist my candidates with the substance and presentation of their one-page life summaries. Here are ten tips based on the most common problems I see and questions I am asked: 1. Assume no one will read your resume word-for-word. Picture your interviewer pulling your resume off the of Equal printer and reading only quotations on democracy essay, what he can in the time it takes to walk back to his office. You need to make the most important stuff jump off the page.
Use bold. Use bullet points. Use headings. Give some thought to the format that will convey the of Equal Opportunity Essays necessary information in the most logical way. 2. Be concise and make every word count.
This is related to Tip #1. You want the most important stuff to jump off the page, but every word on your resume should serve the quotations on democracy purpose of showing that you are the best candidate for the specific job. It’s just one page. 3. Tailor your resume to the specific job. Promise V. Reality Essays! Keep in the forefront of your mind that you are applying for quotations on democracy essay, a legal job. Do not view “updating” your resume as merely adding to the same document you first created 20 years ago. Delete information that is no longer relevant #8212; remember, every last word should serve the purpose of getting you this job. If you are applying to 10 general litigation openings, one version may be just fine. But if you are applying to some general litigation spots and some patent litigation spots, you may want to have two versions of your resume, with each tailored to the specific opening or category of opening. 4. Be sure you can talk intelligently about every last thing you include on your resume. If you can no longer remember the main argument of your senior thesis from Essay on The college, delete it from your resume or refresh your memory before any interviews.
You also must be prepared to quotations on democracy talk about the any legal matters you claim to have worked on, including about the underlying legal issues. 5. When describing your legal experience, give concrete examples . Opportunity! Instead of merely asserting that you are a capital markets lawyer, note that you “Drafted the underwriting agreement as lead associate representing the underwriters in on democracy the offering of karl marx summary $300 million in floating rate notes by on democracy, a large U.S. manufacturing company.” Even if you have a separate representative matters sheet, it may be helpful to include a few bullets points showing this experience in your actual resume as well. Reports Essays! And remember from Tip #2, every word counts. Don’t use neutral words where a more positive word could convey more meaning. For example, which is quotations on democracy essay, more powerful, stating that you “worked on” a project or that you “successfully implemented” a project? 6. Be sure all information is up-to-date. If you are no longer on a committee, delete it from your resume or indicate the proper dates. Change the verbs (“represent,” “draft,” “negotiate”) from the alliance for progress definition descriptions of your prior jobs to the past tense (“represented,” “drafted,” “negotiated”). No longer fluent in French?
Be accurate in the assessment of your language ability as of today, not as of mid-way through your junior year abroad. 7. Additional Information: Space is a commodity, but you should still make room for two or three lines that show you are a human being and not just a robot. Include a few interests (but be sure they are real interests of yours and on democracy essay, not aspirational hobbies). Maybe you and one of the interviewers will find you have a hobby in common. If nothing else, this “fluff” gives interviewers some material for a few softball questions to break the ice or end the interview on a lighter note.
Aside from true interests/hobbies, include language abilities, bar admissions, and Essays, memberships/affiliations so long as you are an active and not just passive participant in quotations these organizations. Remember the essential test: “Can you talk intelligently about it if asked?” If someone asks about your membership in an alumni network, will you state proudly that you assisted in raising $500,000 in Power alumni contributions for a scholarship fund or will you cower in quotations on democracy essay your chair and confess that you are on the e-mail list for the committee but have yet to attend a meeting? 8. Education first or work experience first? This is a common question. Remember Tip #1 #8212; you want the most important stuff to jump off the page. So if you went to a top law school, you may want to list education first. If your law school was not as highly ranked but you somehow landed a job at Wachtell, list work experience first. The Blind Side Movie Summary! In the case of a tie, I’d go with work experience first.
9. The squint test : It seems a bit unsophisticated but it works. Quotations! Tape your resume to a wall about 10 feet away or just hold it far out in front of you and squint. Does the balance of black and white on the page make your eyes happy? Is there much too much dense text? Or way too much white space?
If you’ve ever strung lights on a Christmas tree, it’s the same principle. V. Reality! Squint and quotations on democracy, then follow your instincts. 10. Proofread your resume carefully. Then proofread it again.
Then ask a friend to proofread it. Reports Essays! And another friend. And your legal recruiter. Quotations! Then proofread it again. Nothing screams “Don’t hire me!” like a glaring typo or spelling mistake. On The Of Drinking! 10?. Here’s a freebie. It’s not the most important tip unless… well if it is, you know who you are. You know that photo of you in the Bahamas in quotations on democracy your bikini? Shirtless?
You remember how you uploaded it to your Google profile? And now you list your Gmail address on on The of Drinking, your resume? Well guess what… When I am e-mailing you at your Gmail address, yes, I can see that photo of you in the right-hand sidebar on my screen. If I can see it, so can the recruiting coordinator and so can the partner at on democracy the firm where you’re interviewing. Oh, and one more thing: your Twitter feed will also now show up on the right-hand sidebar. I’m not asking you to stop using social media. On The Of Drinking! But if you are indiscriminate about your tweets, think about setting up a separate e-mail address for the job search process. There is not just one right way of designing a resume. But there are wrong ways. Look at quotations on democracy essay models but don’t just copy someone else’s.
This singular piece of paper is your key to getting your foot in the door in the next step of your career… or not. It’s worth spending a few extra hours getting it right. Lateral Link is one of the Essay on The Power top-rated international legal recruiting firms. With over on democracy essay, 14 offices world-wide, Lateral Link specializes in for progress definition placing attorneys at the most prestigious law firms in the world. Managed by former practicing attorneys from top law schools, Lateral Link has a tradition of hiring lawyers to execute the lateral leaps of practicing attorneys. Click ::here:: to find out more about quotations on democracy essay us. Sign up for our newsletter. Tesla Is Immune To Bad Financial Data Because Logic Is Officially Dead In Silicon Valley. Hey Jeff Sessions, THIS Is How You Deal With Protesters At A Law School. Law Schools Rip Bar Exam Cut Score Recommendations.
Move Over LSAT #8212; As Of Today 6 Law Schools Accept The GRE. Is Math Legal? Gill v. Promise V. Reality Of Equal! Whitford Will Determine If We Can Have Nice Things. Quotations On Democracy Essay! Preet Bharara#8217;s 5 Secrets To Success In The Law. Hot Stove Rule! Yes, Overtime Laws Apply To Law Firms. Senior Attorney Fired For Cruel Commentary On Las Vegas Shooting. Quotations On Democracy! Law Student Seriously Injured During Las Vegas Mass Shooting. Lawyer Takes Aim At Bottomless Brunches. Social Media Can Get You Fired So Plan Accordingly. This Story About Dershowitz Getting #8216;Blocked#8217; At Berkeley Seems Way Overblown. Attorney Fatally Wounded During Las Vegas Mass Shooting.
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essay on roe vs wade Because neither interest is quotations essay, compelling before the second trimester, the State may not regulate abortion in the first trimester either to karl capital, preserve the woman’s health or to protect the life of the unborn child. Id . at 163. After the quotations essay first trimester, however, the State may regulate the performance of an abortion, but only for the purpose of preserving the v. Reality of Equal woman’s health, not for the purpose of protecting the life of the unborn child. On Democracy Essay? After viability, the hot stove rule State may regulate, and even prohibit, abortion to protect the life of the unborn child, except when the performance of the abortion is on democracy essay, necessary to preserve the life or health of the woman. Id . at 164-65 (summarizing holdings). The abortion statutes challenged in Roe , which prohibited abortion throughout pregnancy except to save the life of the mother, did not conform to the Court’s “trimester” framework. Accordingly, they were declared unconstitutional. Id . at 164.
In Roe , the Court also held that an hot stove rule unborn child is not a “person” as that word is used in § 1 of the Fourteenth Amendment and, therefore, is not protected by either the Due Process Clause or the Equal Protection Clause, id . at 156-59, a holding from which no Justice on the Court – then or since – has dissented. In Roe’s companion case of Doe v. Bolton , 410 U.S. 179 (1973), decided the same day as Roe , the on democracy Court struck down various procedural requirements imposed by a Georgia abortion statute based on § 230.3 of the Model Penal Code (that the abortion be performed in a licensed and accredited hospital, that the procedure be approved by the majority of a medical staff committee of the hospital, and that two other physicians in addition to hot stove rule, the attending physician certify that the abortion was necessary for one of the reasons specified in the statute). 3 410 U.S. at 192-200. The Court also rejected a vagueness challenge to quotations, what remained of the substance of the statute after major provisions of the statute had been declared unconstitutional by a federal district court. Hot Stove Rule? Id . at 191-92.
4 Both Justice Byron White and Justice William Rehnquist dissented from the opinions in Roe and Doe striking down the Texas and Georgia abortion statutes. Roe , 410 U.S. at 171 (Rehnquist, J., dissenting); Doe , 410 U.S. at 221 (White, J., dissenting from both opinions); id . at 223 (Rehnquist, J., dissenting). I. The Origins of a Constitutional Right ^ top. Roe , as noted in the Introduction, was based on quotations on democracy, the right of privacy. Alliance Definition? As Roe itself acknowledged, however, “[t]he Constitution does not explicitly mention any right of privacy. 410 U.S. at 152. Nevertheless, in a line of decisions going back to the late nineteenth century, “the Court has recognized that a right of personal privacy, or a guarantee of certain areas or zones of privacy, does exist under the Constitution.
Id . This right of privacy, “founded in the Fourteenth Amendment’s concept of personal liberty, the Court in Roe held, “is broad enough to encompass a woman’s decision whether or not to terminate her pregnancy. Id . at 153. The roots of a right of on democracy essay personal privacy have been found in reports essays the U.S. Constitution in quotations on democracy essay the following places: in the the blind side movie summary free speech guarantee of the quotations First Amendment, which has been held to protect the possession of karl marx pornography in one’s home, Stanley v. Georgia , 394 U.S. Quotations? 557, 564 (1969); in the Fourth Amendment, which secures the right of the side movie summary people against “unreasonable searches and seizures of their “persons, homes, papers and effects, and the Fifth Amendment, which prohibits compulsory self-incrimination, see Boyd v. United States , 116 U.S. 616, 630 (1886) (Fourth and Fifth Amendments protect against all governmental invasions “of the sanctity of a man’s home and the privacies of life”); in the Ninth Amendment, which preserves other rights not enumerated in the Constitution, Griswold v. Connecticut , 381 U.S.
479, 486 (1965) (striking down statute prohibiting use of contraceptives by married couples) (Goldberg, J., concurring) ; in the “penumbras (shades) of the Bill of Rights as a whole, Griswold , 381 U.S. at 484-85 ; and in the liberty language of the quotations essay Due Process Clause of § 1 of the Fourteenth Amendment, Meyer v. Nebraska , 262 U.S. 390, 399 (1923) (striking down a state statute forbidding the teaching of any subject in any language other than English, or the teaching of modern foreign languages below the eighth grade). The right of privacy, the Court in Roe noted, also has “some extension to activities relating to marriage, . . . procreation, . . . family relationships, . . . and child rearing and hot stove rule, education. 410 U.S. at 152-53 , citing the following cases: Loving v. Virginia , 388 U.S. Quotations On Democracy Essay? 1, 12 (1967), recognizing liberty interest in marrying the person of one’s choice; Skinner v. Oklahoma , 316 U.S. 535, 541-42 (1942), striking down statute mandating sterilization of certain recidivists; Eisenstadt v. Baird , 405 U.S. 438 (1972), striking down statute prohibiting distribution of contraceptives to capital, unmarried persons; Prince v. Massachusetts , 321 U.S. 158, 166 (1944), recognizing authority of parents over their children, but upholding child labor laws as applied to the children of Jehovah’s Witnesses who were distributing religious literature in exchange for voluntary contributions; Pierce v. Society of Sisters ,268 U.S. 510, 535 (1925), striking down statute mandating public education of children between the ages of eight and sixteen; and Meyer v. Nebraska (holding described above).
II. Critique of Roe’s Privacy Theory ^ top. The Supreme Court’s reliance on on democracy, privacy theory to support a right to abortion is problematical at several levels. First, as the Court itself recognized, Roe , 410 U.S. at 152, the Constitution itself “does not expressly mention any right of privacy.” To be sure, as Justice Hugo Black noted in his dissent in Griswold v. Alliance? Connecticut , 381 U.S. 479, 508-10 (1965) (Black, J., dissenting), various provisions of the quotations essay Bill of hot stove rule Rights protect specific privacy interests, for example, the First Amendment’s right of associational privacy, the quotations on democracy essay Fourth Amendment’s protection against unreasonable searches and seizures and movie, the Fifth Amendment’s prohibition of compelled self-incrimination. But the essay Constitution does not create a general right of privacy. See , e.g ., Katz v. United States , 389 U.S. 347, 350 (1967) (Fourth Amendment, which “protects individual privacy against certain kinds of governmental intrusions,” “cannot be translated into v. Reality Opportunity a general constitutional ‘right to privacy’”).
Recognition of essay a “general constitutional ‘right to privacy’” cannot be reconciled with the care with which the Framers of the Bill of Rights described the specific rights that were being secured. Second, the concept of “privacy” is amorphous and for progress definition, chameleon (or, in quotations essay Justice Black’s words, “broad, abstract and ambiguous,” Griswold , 381 U.S. at 509 ). Roe’ s attempt to collect cases under the rubric of “privacy” – a term that does not even appear in most of the cases cited – simply creates an artificial common denominator among a very disparate and largely unrelated group of cases that have nothing to do with the subject of abortion, as the Court in Promise v. Reality Opportunity Roe freely admitted: “The situation [involving a pregnant woman and her unborn child] . . . is inherently different from marital intimacy, or bedroom possession of obscene material, or marriage, or procreation, or education, with which Eisenstadt and Griswold , Stanley , Loving , Skinner , and Pierce and Meyer were respectively concerned.” 410 U.S. at 159 (emphasis added). 6 If a pregnant woman’s decision whether or not to carry her pregnancy to quotations, term is the blind summary, “inherently different” from all of the “privacy” cases on which the Court relied, then it is difficult to understand how those cases could possibly support recognition of a right to obtain an on democracy abortion. Third, most of the side summary cases Roe cited in support of its privacy theory were decided under one or another of the provisions in the Bill of Rights. Roe itself, however, derived the right of privacy (and a subsidiary right to abortion) from the quotations liberty language in the Due Process Clause of the Fourteenth Amendment, 410 U.S. at 153, not from any of the specific guarantees set forth in the Bill of Rights. That directly contradicted the hot stove rule Court’s express refusal, only a few years earlier in quotations essay Griswold , 381 U.S. at 481-82, to rely upon the Due Process Clause in postulating a right of privacy. Fourth, even with respect to the Due Process Clause, the Court no longer examines substantive due process claims (of which, more below) through the capital lens of privacy, and that includes the subject of abortion. In reaffirming the “core holding” of Roe – that the State may not prohibit abortion before viability for any reason or after viability if the pregnant woman’s life or health would be endangered by continuing the pregnancy – the Court, in Planned Parenthood v. Casey , 505 U.S. 833, 846-53 (1992), relied upon the liberty language of the Due Process Clause of the Fourteenth Amendment, not upon privacy theory. 7 See also Cruzan v. Director , Missouri Dep’t of Health , 497 U.S. 261, 279 n. 7 (1990) (analyzing right to refuse unwanted medical treatment “in terms of a Fourteenth Amendment liberty interest, rather than under a “generalized constitutional right of privacy”).
Focusing more particularly on the Fourteenth Amendment, § 1 thereof provides, in relevant part, that no State shall “deprive any person of life, liberty, or property, without due process of law . . . .” As its language suggests, the Due Process Clause is quotations, concerned with the process by which a person may be deprived of side life, liberty or property, not the substance of the law authorizing such deprivation. Quotations Essay? See Lawrence v. Opportunity Essays? Texas , 539 U.S. 558, 592 (2003) (Scalia, J., dissenting) . It was never the intent of the Framers of the Fourteenth Amendment that the Due Process Clause would serve as a battering ram to knock down statutes the substance of which offended the sensibilities of a majority of Justices who happen to sit on the Supreme Court from on democracy, time to time. Definition? See Raoul Berger, Government by Judiciary The Transformation of the Fourteenth Amendment (Liberty Fund 2d ed. 1997) 221-39, 273-306. 8 Despite its focus on process, the Due Process Clause, at various times in our history, has been given substantive content, resulting in the invalidation of state laws thought to be inconsistent with prevailing understandings of “liberty.” The paradigmatic case in this area, before Roe v, Wade was decided in 1973, is essay, Lochner v. New York , 198 U.S. 45 (1905). In Lochner , the Supreme Court, over the vigorous dissent of Justice Oliver Wendell Holmes, Jr., held that state legislation setting limits on the number of hours a person could work in a bakery daily (ten hours) and side movie summary, weekly (sixty hours) violated the liberty of an employer to essay, contract with his employees on on The of Drinking, terms that were mutually agreeable to them.
The notion that the Due Process Clause has substantive (as opposed to only procedural ) content bedeviled constitutional adjudication for a generation, until it was laid to rest, at least with respect to the review of social and economic legislation, in West Coast Hotel v. Parrish , 300 U.S. 379 (1937), which upheld a minimum wage law. Twenty-five years later, the quotations on democracy essay Supreme Court could state that it had “returned to on The of Drinking, the original constitutional proposition that courts do not substitute their social and on democracy, economic beliefs for the judgment of legislative bodies.” Ferguson v. Skrupa , 372 U.S. 726, 730 (1963). Despite the interment of what may be called “economic” substantive due process, “libertarian” substantive due process is the blind side summary, alive and well. Under this strand of substantive due process analysis, the Due Process Clause “provides heightened protection against quotations, government interference with certain fundamental rights and Essay on The of Drinking, liberty interests.” Washington v. Glucksberg , 521 U.S. 702, 720 (1997). Roe v. Wade , while sounding in privacy theory, was ultimately based on the liberty language of § 1 of the quotations Due Process Clause of the Fourteenth Amendment, see Roe , 410 U.S. at 153, and, therefore, may justly be regarded as the modern paradigm of (libertarian) substantive due process analysis.
See Richard Epstein, Substantive Due Process by Any Other Name , 1973 Sup. Ct. Rev. 159, 184. But Roe flunks the test the Court uses for evaluating substantive due process claims.
In determining whether an alliance asserted liberty interest (or right) should be regarded as fundamental for on democracy essay purposes of substantive due process analysis (infringement of which would call for strict scrutiny review), the v. Reality Essays Supreme Court applies a two-prong test. First, there must be a “careful description” of the asserted fundamental liberty interest. Glucksberg , 521 U.S. at 721 (citation and internal quotation marks omitted). Second, the interest, so described, must be firmly rooted in quotations “the Nation’s history, legal traditions, and practices.” Id. at marx, 710. An asserted interest in (or right to) abortion does not meet the second prong of the Glucksberg test. Quite the contrary. As much research has established, especially that of Professor Dellapenna ( see n. 4, supra ) , abortion was a crime in English and American common law, at least after “quickening” (that stage of pregnancy when the woman first detects fetal movement, usually sixteen to eighteen weeks’ gestation), and very possibly without such a limitation. With the on democracy essay gradual replacement of common law crimes by statutory crimes in the nineteenth century, the overwhelming majority of hot stove rule States had made the on democracy performance of an abortion at any stage of pregnancy a crime well before the for progress Fourteenth Amendment was adopted in 1868. And the case law interpreting these statutes revealed that the principal, if not exclusive, purpose in enacting these statutes was to protect unborn human life, not (or not solely) to safeguard women from dangerous medical and/or surgical procedures.
See Paul Benjamin Linton, Planned Parenthood v. Casey : The Flight from on democracy essay, Reason in the Supreme Court , XIII St. Of Equal? Louis U. Pub. L. Rev. 15, 109-15 (1993). In light of the foregoing, an interest in (or right to) abortion cannot be said to be firmly rooted in our “history, legal traditions, and practices.” III. Applications of Roe ^ top. The Supreme Court has decided almost three dozen abortion cases since and including Roe v. Wade and Doe v. Quotations On Democracy? Bolton . A detailed analysis of the holdings in these cases would unduly prolong the reports essays length of this essay. The principal holdings, however, may be briefly summarized:
In addition to on democracy essay, the Texas abortion statutes struck down in Roe , the Court has struck down state statutes prohibiting particular abortion methods, Planned Parenthood of Central Missouri v. Danforth , 428 U.S. 52, 75-79 (1976) (saline amniocentesis), Stenberg v. Carhart , 530 U.S. Promise V. Reality Of Equal Essays? 914 (2000) (partial-birth abortion), but more recently has upheld the federal Partial-Birth Abortion Ban Act, Gonzales v. Carhart , 550 U.S. 124 (2007). The Court has upheld statutes prohibiting non-physicians from performing abortions, Mazurek v. Armstrong , 520 U.S.
968 (1997) ( per curiam ) and has held that non-physicians may be prosecuted for performing abortions, Connecticut v. Menillo , 423 U.S. 9, 11 (1975) ( per curiam ) . The Court has struck down statutes and ordinances requiring all abortions (or all abortions after the first trimester) to be performed in hospitals, Doe v. Quotations? Bolton , 410 U.S. 179, 193-95 (1973) (all abortions), City of Akron v. Hot Stove Rule? Akron Center for Reproductive Rights ( Akron Center I ) , 462 U.S. Quotations On Democracy? 416, 431-39 (1983) (all abortions after the for progress first trimester), Planned Parenthood Ass’n of Kansas City , Missouri , Inc. v. Ashcroft , 462 U.S. 476, 481-82 (1983) (all abortions after the first twelve weeks of pregnancy), but has upheld a statute requiring all second trimester abortions to be performed in either a hospital or a licensed outpatient clinic, Simopoulos v. Quotations On Democracy Essay? Virginia , 462 U.S. 506, 510-19 (1983). The Court has struck down parental consent and notice statutes and v. Reality Opportunity Essays, ordinances if they did not contain a judicial bypass mechanism that would afford the pregnant minor the opportunity to avoid obtaining the consent of (or giving notice to) her parents or legal guardian, 9 Danforth , 428 U.S. at quotations on democracy, 72-75 (one-parent consent), Akron Center I , 462 U.S. at 439-42 (one-parent consent without judicial bypass), Bellotti v. Baird , 443 U.S.
622 (1979) (two-parent consent) (inadequate judicial bypass), Hodgson v. Minnesota , 497 U.S. Reports Essays? 417, 450-55 (1990) (two-parent notice without judicial bypass), 10 but has upheld statutes that contained an adequate judicial bypass, Ashcroft , 462 U.S. at 490-93 (one-parent consent). Essay? Hodgson , 497 U.S. at 497-501 (Kennedy, J., concurring in the judgment in alliance definition part and on democracy essay, dissenting in part), id. at 461 (O’Connor, J., concurring in Essay on The of Drinking part and concurring in the judgment in on democracy part) (two-parent notice with judicial bypass), Ohio v. Akron Center for definition Reproductive Health ( Akron Center II ) , 497 U.S. 502 (1990) (one-parent notice with judicial bypass), Planned Parenthood v. Casey , 505 U.S. 833, 899-900 (1992) (one-parent consent), Lambert v. Wicklund ,520 U.S. 292 (1997) (one-parent notice) ( per quotations, curiam ) . The Court has struck down statutes requiring a married woman to obtain the consent of, or give notice to, her husband before undergoing an Promise v. Reality of Equal Opportunity Essays abortion, Danforth , 428 U.S. at 67-72 (consent), and Casey , 505 U.S. at 887-98 (notice) . The Court has upheld state and federal statutes restricting public funding of essay abortions, Beal v. Doe , 432 U.S. 438 (1977), Maher v. Roe , 432 U.S. 464 (1977), Harris v. McRae , 448 U.S. 297 (1980), and Williams v. Zbaraz , 448 U.S. V. Reality Of Equal Opportunity? 358 (1980), as well as state statutes and quotations on democracy, municipal government policies prohibiting the performance of abortions by public employees within the scope of their employment or in publicly owned and operated facilities (other than those necessary to save the life of the Promise v. Reality Opportunity mother), Poelker v. Doe , 432 U.S.
519 (1977), and Webster v. Quotations On Democracy Essay? Reproductive Health Services , 492 U.S. 490, 507-11 (1989). The Court has also upheld federal administrative regulations (since rescinded) requiring physical and financial separation of side movie summary Title X family planning projects from other projects operated by Title X grantees that perform, counsel or refer for on democracy abortion, Rust v. Sullivan , 500 U.S. 173 (1991). The Court has upheld a requirement that a pathology report be prepared for the blind side summary all fetal tissue obtained in the course of an abortion, Ashcroft , 462 U.S. at essay, 486-90 , but has struck down a requirement that fetal remains be disposed of in a “humane and sanitary manner,” Akron Center I , 462 U.S. at 451-52 . The Court has upheld some record keeping and reporting requirements, Danforth , 428 U.S. at 79-81 , Casey , 505 U.S. at 900-01 , while striking down others, Thornburgh v. American College of Obstetricians Gynecologists , 476 U.S. 747, 765-68 (1986), because of what the Court perceived as inadequate guarantees of patient confidentiality. The Court has upheld a requirement that a second physician be present during the performance of a post-viability abortion to Opportunity, provide immediate medical care for a viable child who survives an abortion procedure, Ashcroft , 462 U.S. at 482-86 , but has struck down a second-physician requirement that did not contain an express or implied exception for medical emergencies, Thornburgh , 476 U.S. at 769-71 . The Court has also struck down standards of quotations on democracy care for the performance of post-viability abortions that were either vague, Colautti v. Franklin , 439 U.S. Hot Stove Rule? 379, 397-401 (1979), or posed an unacceptable risk to quotations essay, the mother’s health, Thornburgh , 476 U.S. at 768-69 , but has upheld a statute mandating fetal viability testing at twenty weeks’ gestation, Webster , 492 U.S. at 513-21 . In a pair of decisions, later overruled in part by v. Reality of Equal Opportunity, Planned Parenthood v. Quotations On Democracy? Casey , 505 U.S. 833 (1992), which is discussed in the next part of this essay, infra , the Court held that States and municipalities could not require a short waiting period before the performance of hot stove rule a non-emergency abortion; that they could not required detailed informed consent information to be given to the pregnant woman seeking an abortion; and on democracy, that they could not require portions of the informed consent information to be conveyed in person to the patient by reports essays, the attending physician, see Akron Center I , 462 U.S. at quotations essay, 442-51 and Thornburgh , 476 U.S. at 759-65 . 11.
IV. Roe Revisited: Planned Parenthood v. Casey ^ top. In 1992, the Supreme Court revisited Roe and, in a Joint Opinion authored by Justices Sandra Day O’Connor, Anthony Kennedy and David Souter, substantially modified its holdings. Reports Essays? Planned Parenthood v. On Democracy? Casey , 505 U.S. 833 (1992). In Casey , the Court reaffirmed what it characterized as the “essential” (or “central”) holding of Roe , consisting of three parts: First, a woman has “the right . . . . to choose to alliance for progress definition, have an abortion before viability and to obtain it without undue interference from the State. Before viability, the State’s interests are not strong enough to support a prohibition of abortion or the imposition of a substantial obstacle to the woman’s effective right to elect the procedure.” 505 U.S. at 846. Second, the State has the power “to restrict abortions after fetal viability, if the law contains exceptions for pregnancies which endanger the woman’s life or health.” Id . And, third, “the State has legitimate interests from the outset of the pregnancy in quotations protecting the hot stove rule health of the woman and quotations on democracy, the life of the reports essays fetus that may become a child.” Id . While reaffirming the “essential” (or “central”) holding of Roe , the authors of the Joint Opinion rejected Roe’s “trimester” framework as an unnecessarily “rigid construct” which “in its formulation . . . misconceives the quotations on democracy nature of the pregnant woman’s interest,” and “in practice . . . undervalues the State’s interest in potential life . . . .” Id . at 872-73. The trimester framework “misconceives the nature of the pregnant woman’s interest” because “[w]hat is at stake is karl marx capital summary, [her] right to on democracy, make the ultimate decision [to obtain an abortion prior to viability], not a right to be insulated from all others in doing so.” Id . at 877. “Though the woman has a right to choose to terminate or continue her pregnancy before viability,” the Joint Opinion explained, “it does not at the blind movie, all follow that the State is prohibited from taking steps to on democracy essay, ensure that [her] choice is thoughtful and informed.” Id . at 872.
The trimester framework “undervalues the the blind State’s interest in potential life,” the Joint Opinion continued, because the State has a “substantial state interest in essay potential life throughout pregnancy,” id . at 876, not just after viability. In light of their dissatisfaction with the trimester framework of Power of Drinking Roe and how it had been applied in subsequent cases, the authors of the Joint Opinion developed a new standard for reviewing pre-viability abortion regulations, the so-called “undue burden” test. Casey , 505 U.S. at 874-79. Under that test, “a state regulation [that] has the quotations on democracy purpose or effect of placing a substantial obstacle in the path of a woman seeking an abortion of a nonviable fetus” is unconstitutional. Alliance Definition? Id . at 877. Quotations? Applying that test to the statutes challenged in Casey (multiple provisions of the Pennsylvania Abortion Control Act of 1982, as amended), a majority of the Court upheld the detailed informed consent requirement (including the mandated twenty-four hour waiting period), the hot stove rule parental consent requirement and the record keeping and reporting requirements, id . at essay, 881-87, 899-901, but a differently constituted majority struck down the spousal notice requirement , id . at 887-98 . 12 In upholding the informed consent requirement (and the accompanying waiting period), the Court overruled, in part, its earlier conflicting precedents in Akron Center I and Thornburgh . The Blind Movie Summary? Id . at 881-82. 13. Both Justice Harry Blackmun and quotations, Justice Paul Stevens dissented from the Joint Opinion’s abandonment of the blind Roe’s trimester framework and quotations on democracy, the strict scrutiny standard of review, while Chief Justice William Rehnquist, joined by Justices Byron White, Antonin Scalia and Clarence Thomas, dissented from the reaffirmation of the “essential” holding of karl summary Roe , arguing that the rational basis standard should be applied to all regulation of abortion.
14. The Joint Opinion in on democracy essay Casey is notable in five respects: First, in reaffirming what it characterized as the “essential” (or “central”) holding of Roe , the summary authors of the Joint Opinion raised the issue but refused to state whether they believed that Roe had been correctly decided as an original matter of constitutional interpretation, Casey , 505 U.S. at 871 (“[w]e do not need to say whether each of us, had we been Members of the Court when the valuation of the state interest [in the protection of “potential life”] came before it as an on democracy essay original matter, would have concluded, as the Roe Court did, that its weight is insufficient to justify a ban on abortions prior to reports essays, viability even when it is on democracy, subject to certain exceptions”), 15 relying instead on “principles of institutional integrity” and “the rule of stare decisis [deferring to precedent].” Id . at 845-46; see also id. at 854-69. Of Equal Opportunity? Second, the Joint Opinion provided no principled basis for distinguishing between the “essential” (or “central”) and the inessential (or peripheral) holdings of Roe , reaffirming the former and overruling the latter. As Justice Scalia commented, “I must . . . confess that I have always thought, and I think a lot of other people have always thought, that the arbitrary trimester framework, which the Court today discards, was quite as central to Roe as the arbitrary viability test, which the Court today retains.” Id . at quotations on democracy, 993. (Scalia, J., concurring in the blind side the judgment in quotations part and dissenting in part). Third, in karl summary reaffirming the “essential” holding of Roe , the on democracy Joint Opinion abandoned Roe’s reliance on privacy theory, resting its analysis, instead, on the liberty language of § 1 of the on The Fourteenth Amendment. Fourth, the Joint Opinion tacitly abandoned Roe’s characterization of the right to abortion as “fundamental.” 16 And, fifth, the Joint Opinion substituted a new standard of review – “undue burden” – in place of the strict scrutiny standard employed in Roe for quotations on democracy evaluating fundamental rights, which clearly allows for movie summary a broader scope of regulation (but not prohibition) of quotations pre-viability abortions.
17. The strict scrutiny standard of judicial review applies to laws that either interfere with the exercise of the blind side a fundamental constitutional right ( e.g ., voting) or discriminate on the basis of a suspect classification ( e.g ., race). A law reviewed under this standard is quotations, presumed to alliance for progress, be un constitutional and will not be upheld unless its proponents are able to demonstrate that it is necessary to promote a compelling state (or governmental) interest. Few, if any, laws reviewed under this standard survive. At the opposite end of the quotations essay spectrum is the rational basis standard of review, which applies to almost all other legislation. 18 Under this standard, a law is presumed to be constitutional and hot stove rule, will be upheld so long as it has a rational relationship to any legitimate state (or governmental) purpose.
Most laws reviewed under this standard survive constitutional scrutiny. V. The Roberts Court and quotations essay, the Future of hot stove rule Abortion Jurisprudence ^ top. Under the leadership of Chief Justice John Roberts, the Supreme Court has taken a more cautious approach to the review of on democracy essay abortion regulation. Most obviously, the Court, in an opinion by Justice Kennedy, upheld the federal Partial-Birth Abortion Ban Act in Gonzales v. Karl Marx Capital? Carhart , 550 U.S. 124 (2007) ( Carhart II ), after a differently constituted Court struck down a similar (but more vaguely worded) state statute only seven years earlier in Stenberg v. Carhart , 530 U.S. 914 (2000) ( Carhart I ). Less obviously, the Court has suggested that, at least with respect to the regulation of abortion, “facial challenges,” i.e ., a claim that a given statute is unconstitutional in its entirety, are disfavored, Carhart II , 550 U.S. 124 at quotations, 130 (“these facial attacks should not have been entertained in the first place”), and “as-applied” challenges, i.e ., a claim that a statute is alliance definition, unconstitutional in particular circumstances, are preferred, id . at 168 (“[a]s-applied challenges are the basic building blocks of constitutional adjudication”) (citation and internal quotation marks omitted).
Relatedly, in another decision of the Roberts Court, the Court unanimously held, in quotations an opinion by alliance definition, Justice O’Connor, that when only on democracy essay, a limited number of hot stove rule applications of an quotations abortion statute would be unconstitutional, the proper remedy (if otherwise consistent with legislative intent) is to enjoin enforcement of those applications only, not to declare the entire statute unconstitutional. Ayotte v. Planned Parenthood of Northern New England , 546 U.S. 320, 328-31 (2006) (reviewing parental notice law). Significantly, in Ayotte , Justice O’Connor acknowledged that the Court did not take this more circumspect approach in Carhart I, id . at 330-31 (explaining that “the parties . . . did not ask for, and we did not contemplate, relief more finely drawn” than complete invalidation). 19. In light of the Roberts Court’s more cautious approach to the review of abortion legislation, fewer challenges to hot stove rule, abortion statutes may be expected.
Moreover, even with respect to those challenges that are brought and are determined to have merit, both the Supreme Court and quotations, the lower federal courts are likely to strike down the Essay of Drinking statute and enjoin its enforcement only with respect to its invalid applications, not in its entirety. VI. A Comment on the Scope of the quotations Health Exception ^ top. Finally, a brief comment on an unresolved area of abortion law – the scope of the alliance definition health exception required by Roe (as reaffirmed in Casey ). In Roe , the quotations Supreme Court held that the States may prohibit abortion after viability “except when it is necessary to preserve the life or health of the mother.” 410 U.S. at 164. The Court, however, did not define the term “health.” In the companion case of Doe v. Bolton , the Court considered a challenge to reports essays, what remained of the Georgia abortion statute after major provisions of the statute had been declared unconstitutional by quotations essay, a federal district court. As a result of the district court’s decision, a physician could perform an abortion whenever he determined, in “his best clinical judgment,” that the abortion was “necessary.” At issue in Doe was whether this standard was impermissibly vague. The Court concluded that it was not: [T]he medical judgment [as to whether an abortion is “necessary”] may be exercised in the light of hot stove rule all factors – physical, emotional, psychological, familial, and the woman’s age – relevant to the well-being of the quotations essay patient.
All these factors may relate to health. Whether Doe , properly understood, mandates an open-ended “health” exception for the blind post-viability abortions is debatable. Although there is the on democracy merest hint in one older case that the Court (as then constituted) may have regarded the broad language in v. Reality Essays Doe as a limitation on quotations essay, the State’s authority to prohibit post-viability abortions, see Colautti v. The Blind Side Movie Summary? Franklin , 439 U.S. 379, 400 (1979), the quotations on democracy essay Court has never directly considered the validity of a post-viability ban. Lower federal courts have read Doe as a gloss on the scope of the health exception that must be included in any post-viability ban, 20 but that reading misinterprets Doe , as Justice Thomas noted in his dissent from the denial of certiorari in reports essays Voinovich v. Women’s Medical Professional Corp . , 523 U.S.
1036 (1998): Our conclusion that the statutory phrase at issue in Doe [whether the abortions was “necessary”] was not vague because it included emotional and psychological considerations in no way supports the essay proposition that, after viability, a mental health exception is required as a matter of federal constitutional law . Doe simply did not address that question. 523 U.S. at 1039 (emphasis in original). As things now stand, whether the open-ended “health” language of summary Doe is a limitation on the authority of the States to prohibit post-viability abortions remains an open question, but one that should be answered by a challenge to an appropriately drafted statute. Given the present composition of the quotations on democracy essay Court, there is reason to believe that such a statute would be upheld. In recognizing a constitutional right to abortion, the Court in hot stove rule Roe believed that it was meeting the “profound problems of the present day.” 410 U.S. at 165. The “problems” which the Court thought would be ameliorated by its decision included the medical risks associated with pregnancy, a “distressful life and future” for the pregnant woman confronted with an unwanted pregnancy, “[p]sychological harm,” the difficulty in providing “child care,” “the distress, for all concerned, associated with the unwanted child,” “the problem of quotations on democracy bringing a child into a family already unable, psychologically or otherwise, to the blind side movie, care for it,” and, for some, “the additional difficulties and continuing stigma associated with unwed motherhood . . Quotations On Democracy Essay? . .” Id . at 153. More than thirty years of experience with legalized abortion has failed to Opportunity, solve these problems, as well as others for which abortion was touted as a panacea (crime and poverty). Quotations On Democracy? Indeed, the regime of legal abortion has aggravated them. See Clarke D. Forsythe and Promise v. Reality of Equal Opportunity, Stephen B. Presser, The Tragic Failure of Roe v. Wade: Why Abortion Should be Returned to the States . 10 Tex.
Rev. of Law Politics 85, 108-36 (Fall 2005). In reaffirming, as modified, Roe in Casey , the Supreme Court “call[ed] the quotations on democracy essay contending sides of a national controversy to end their national division by accepting a common mandate rooted in the Constitution.” 505 U.S. at 867. Given the issues at stake in abortion, that call, not surprisingly, has not been heeded. The abortion liberty has no “roots” in the Nation’s history, traditions and hot stove rule, legal practices. And the “national division” over the abortion controversy, which Roe created and Casey continued, will not end until, initially, the Supreme Court returns the issue of abortion to the States and, eventually, the Constitution is on democracy, amended to protect the lives of all unborn children. A discussion of the various standards of hot stove rule judicial review may be found in Part IV of this essay, infra . back. When Roe was decided, an unborn child was “viable,” i.e ., capable of living outside of his or her mother, at twenty-eight weeks of gestation.In light of medical advances made since Roe , viability may occur at twenty-three to twenty-four weeks, or, in some instances, even earlier, as the Supreme Court recognized almost twenty years ago in Planned Parenthood v. Casey , 505 U.S. 833, 860 (1992) (noting that viability may occur at quotations, twenty-three to twenty-four weeks). The Blind Movie? back.
Section 230.3 of the Model Penal Code, one version or another of which was adopted by thirteen States before Roe v. Quotations On Democracy Essay? Wade , allowed abortion whenever the karl marx capital summary physician believed that there was a “substantial risk” that continuance of the pregnancy “would gravely impair the physical or mental health of the mother,” that “the child would be born with grave physical or mental defect,” or that “the pregnancy resulted from rape, incest, or other felonious intercourse.”In Doe , the Court also struck down a requirement that an abortion could be performed only upon a bona fide resident of the State of Georgia. Doe , 410 U.S. at quotations on democracy essay, 200. back. As a result of the district court's judgment, a physician could perform an abortion whenever, in his best clinical judgment, the procedure was necessary. Reports Essays? back. Interested readers, however, may wish to consult some of the following sources. An early critique of the Court's handiwork in Roe , which includes a brief review of the initial academic responses to Roe (both favorable and unfavorable) is quotations essay, John T. Noonan, Jr.'s, A Private Choice: Abortion in America in the Seventies (The Free Press 1979).
Dennis J. Horan, Edward R. Grant and Paige C. Cunningham (eds.), Abortion and the Constitution: Reversing Roe v. Wade Through the Courts (Georgetown University Press 1987), is a compendium of articles written by a variety of authors criticizing various aspects of the holdings and analysis in Roe . The most comprehensive and thorough analysis of Roe's treatment of the historical treatment of abortion in English and American law, as well as the restatement of that history in for progress James C. Mohr's Abortion in quotations on democracy essay America (Oxford University Press 1978), is Joseph W. Dellapenna's Dispelling the Myths of Abortion History (Carolina Academic Press 2006) (an extremely abbreviated version of Professor Dellapenna's analysis appears in Abortion and the Constitution , supra , at alliance for progress definition, 137-58). A concise critique of the Court's historical excursus in quotations Roe , particularly its explanation for the reasons nineteenth century abortion statutes were enacted, may be found in Appendix A to Paul Benjamin Linton's article, Planned Parenthood v. Casey : The Flight from Reason in the Supreme Court , XIII St. Louis U. Pub. L. Capital? Rev. 15, 103-19 (1993). The poor quality of the analysis and quotations, reasoning in Roe has led some academics to rewrite the marx summary opinion.
A collection of such opinions and opposing dissents, along with a useful selected bibliography, appears in quotations on democracy Jack M. Balkin (ed.), What Roe v. Wade Should Have Said (New York University Press 2005). back. All of the alliance for progress definition holdings in these cases, and the full citations thereto, appear in Part I of this essay, supra . Quotations Essay? back. Planned Parenthood v. Casey is discussed in karl capital more detail in on democracy Part IV of hot stove rule this essay, infra . back. Justices Oliver Wendell Holmes, Jr., Louis D. Brandeis and Hugo Black, as well as Judge Learned Hand, who served on the Second Circuit Court of Appeals for on democracy essay decades, all agreed that the use of the liberty language of the Due Process Clause to invalidate the of Drinking substance of state enactments is fundamentally illegitimate. See Berger, Government by Judiciary , at 227-28 n. 27 (Black), 282 n. 46 (Holmes, Brandeis and quotations on democracy essay, Hand). back. Consent of (or notice to) a parent or legal guardian may be waived by a court in a judicial bypass hearing if the alliance minor can demonstrate to the satisfaction of the quotations court that she is karl, mature enough to make the decision to obtain an abortion without the consent of essay (or notice to) her parent(s) or legal guardian, or, alternatively, that obtaining consent (or giving notice) would not be in her best interests. The Court has upheld both consent statutes, see , e.g ., Planned Parenthood v. Casey , 505 U.S. The Blind Side Movie? 833, 899-900 (1992), and Planned Parenthood Ass'n of quotations essay Kansas City , Missouri v. Hot Stove Rule? Ashcroft , 462 U.S. 476, 490-93 (1983), and notice statutes, see , e.g ., Ohio v. Akron Center for Reproductive Health , 497 U.S.502 (1990), and Hodgson v. Minnesota , 497 U.S. 417 (1990). back. See also Ayotte v. Planned Parenthood of Northern New England , 546 U.S.
320 (2006) (one-parent notice statute could not be enforced constitutionally in medical emergencies requiring the immediate performance of an abortion). back. A general and non-specific requirement that a physician obtain the informed consent of the patient before performing an abortion was upheld in Danforth , 428 U.S. at 65-67. back. The Court also upheld the medical emergency definition. Casey , 505 U.S. at 879-80. back. The holdings in Akron Center I and essay, Thornburgh are discussed in Promise of Equal Part III, supra . back. These alternative standards of review are discussed below. back.
See also id. at 853, 858, 864, 869. Quotations On Democracy Essay? back. Nowhere in the Joint Opinion is the right to abortion described as fundamental. back. The Joint Opinion in Casey has been subjected to withering criticism. See Paul Benjamin Linton, Planned Parenthood v. Casey : The Flight from Reason in the Supreme Court , XIII St. Louis U. Pub. L. Rev. 15, 103-19 (1993); Michael Stokes Paulsen, The Worst Constitutional Decision of All Time , 78 Notre Dame L. Rev. 995 (2003). Casey is also extensively discussed and Promise Essays, critiqued in Professor Dellapenna's magnum opus , Dispelling the Myths of Abortion History , supra , n. 4. back. Under federal constitutional equal protection doctrine, an intermediate standard applies to classifications based on sex or illegitimacy.
Under that standard, often referred to as heightened scrutiny, the classification must be substantially related to on democracy, an important state (or governmental) interest. On The Power? back.
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Fortress of Tedium: What I Learned as a Substitute Teacher. A novelist’s education in the classroom. By NICHOLSON BAKER SEPT. Essay? 7, 2016. O ne wintry mix of a morning, while I was in training to be a substitute teacher, I saw a textbook that was being used in an 11th-grade English class. The class was studying transcendentalism, and the students were required to read excerpts from an essay called “Nature,” by Ralph Waldo Emerson. Emerson was an unmethodical writer with low, puffy sideburns who liked to work himself up into paragraphs of capital summary rapture. When it came time for him to quotations write an marx capital essay or give an quotations essay oration — about nature, say, or self-reliance — he combed through his voluminous journals and pulled out choice bits that were more or less on topic, and he glued them together with some connective prose. Karl? For instance, in “Nature,” Emerson writes: “Standing on the bare ground, — my head bathed by the blithe air, and quotations essay uplifted into infinite space, — all mean egotism vanishes. I become a transparent eye-ball.” In the textbook, next to this passage, there was a brief assignment printed in the margin.
It said: “Review the elements of transcendentalism listed on movie summary, Page 369. Which aspect of transcendentalist thought is on democracy reflected in hot stove rule Lines 12-19? Explain your answer.” Isn’t that just about the most paralyzingly unrapturous question you’ve encountered in any textbook? “Explain your answer.” No, thank you. I will not explain my answer. My answer is my answer. On Democracy? I am a transparent eyeball.
I am a huge, receptive visual instrument with a flexible lens, and I’m taking in summary the infinitude of all space and on democracy time and reports essays dragonflies and on democracy essay owls and life and roadkill and hydrogen gas. I am nothing and everything. I am bathed in air. Alliance? I’m a carefree, happy huge shining slimy eyeball of weird wonderment. I can swivel in any direction. Any direction I look, I will find something interesting. That’s the extremely interesting thing: Everything is interesting . Potentially. Sometimes it may not seem so.
You may think a certain thing is completely without interest. You may think, or I may think, eh, dull, boring, heck with it, let’s move on. But there is someone on this planet who can find something interesting in that particular thing. And it’s often good to try. You have to poke at on democracy essay a thing, sometimes, and find out v. Reality Opportunity, where it squeaks. On Democracy? Any seemingly dull thing is made up of subsidiary things.
It’s a composite — of smaller events or decisions. Or of atoms and molecules and prejudices and hunches that are fireflying around in unexpected and impossible trajectories. Everything is interesting because everything is not what it is, but is reports essays something on the way to being something else. Everything has a history and a secret stash of fascination. That was the basic idea behind the alternative public high school I attended in Rochester. It was called the School Without Walls — no walls because it’s a big world out there, and life is the great tutor. It was founded by a wonderful, jittery, smart, chain-smoking man named Lew Marks.
We called him Lew. He was the principal. Everyone went by first names. Lew had been a hotshot English teacher but wanted to be part of a revolution in education, so he hired nine teacher-coordinators and set the thing up, and the school district said O.K. There was no entrance exam. A lot of people wanted to get in to the School Without Walls after they read about it in the newspaper, so the school held a lottery, and I was one of the lucky ones. I was there on my first day of ninth grade, on quotations essay, the very first day of the school’s existence, in capital September 1971. Every Wednesday, Lew held something called Town Meeting, where the whole school, all 125 of us noble savages, would meet with him and quotations essay the other teachers and discuss the philosophy of education, the meaning of life and on The Power the problem of quotations on democracy essay applying to college sans G.P.A. Sign Up for hot stove rule the Magazine Newsletter. Get the best of the Magazine delivered to your inbox every week, including exclusive feature stories, photography, columns and more. An error has occurred.
Please try again later. You are already subscribed to this email. We could do whatever we wanted at S.W.W., academically speaking: There were no grades and no attendance requirements. I read Samuel Butler’s “Erewhon” in a utopian-literature class taught by a shy volunteer with rimless glasses (“Erewhon” is “nowhere” spelled backward, sort of), but I stopped going — there’s only so much utopian literature you can take. My friend Steve and I took a physics class with a blind genius in quotations essay his dorm room at the University of Rochester — laundry everywhere, socks, underwear. He dictated long equations, his sad blind eyes zigzagging as we hurried to on The Power of Drinking keep up. (Steve became a neurologist.) I spent hours, days at the piano, noodling around, and I took a biology class, which met in on democracy essay a lab in a community college on the outskirts of on The Power town. Quotations Essay? Sometimes it took an side movie summary hour and quotations on democracy a half to get there by bus. Hot Stove Rule? The school gave us bus tokens, and some of the kids asked for three times as many as they needed and resold them. When the token budget got out of on democracy control, Lew clamped down: “I’m trusting you to ask for the tokens you actually need.” I stopped attending the alliance definition, biology class when we were supposed to dissect fetal pigs.
Sometimes, while eating a grilled-cheese sandwich at a downtown lunch counter at quotations essay 2 in hot stove rule the afternoon on a Tuesday, when most of the city’s 16-year-olds were sitting in big brick schools, I wanted something more. I wanted to be forced to take final exams. I wanted to quotations essay be lectured to, really taught a lesson , in the basic sense. Only once did it happen. One afternoon, near the end of the on The of Drinking, day, Bob, the essay, history teacher, suddenly stood up, went to the blackboard and gave a virtuosic half-hour lecture on the movement of barbarian tribes, the Saxons and the Visigoths and the Huns, with arrows indicating where they migrated. That one history lecture was a revelation. After I went to college and karl capital married and had a family, I would wistfully watch John Hughes movies or shows like “Freaks and Geeks” and dearly wish that I had gone to a normal high school, with sports and debate clubs and junior proms — and valedictorians and salutatorians, homerooms and cliques, funny men in the back row, announcements on the loudspeaker, shouts in the halls, bake sales, lockers . On Democracy? There were no lockers at School Without Walls, no little sets of gills on the doors so the air could sneak in and out. I wanted to hot stove rule have had a locker.
All of which may explain why, several years ago, when it occurred to me to quotations on democracy essay write a meditation on the blind movie, American education, I thought: I really need to become a substitute teacher. Like many a think-tank learning theorist, I hadn’t spent a single day in front of a K-12 class. When I first described my substitute-teaching plan to my son — who was in high school at the time — he said: “Dad, don’t do it. They’ll destroy you. They’ll crush you.” I taught all ages, from quotations on democracy essay kindergarten to high school; I taught remedial classes and honors students. One day we factored polynomials, another day we made Popsicle-stick bird feeders for reports essays Mother’s Day, another day it was the Holocaust. Sometimes I substituted for an “ed tech” — a teacher’s aide whose job was to shadow kids with A.D.H.D. or dyslexia, or kids who simply refused to do any work at all. I was a bungling substitute most of the quotations on democracy, time; I embarrassed myself a hundred different ways, and got my feelings hurt, and complained, and definition shouted, and ate espresso chocolate to quotations on democracy essay stay awake. It was shattering, but I loved it. After a while, I stopped being so keen on developing my grand treatise on educational theory, and instead I found that I enjoyed trying to keep a class going and watching it fall apart.
I liked listening to students talk — even when they were driving themselves, and me, bonkers. The result of my 28 hellish, joyous days of paid work (I made $70 a day) was a book, more chronicle than meditation, called “Substitute: Going to School With a Thousand Kids.” The teachers left me daily assignments called “sub plans” to follow — which I clutched throughout the day until they became as finely crumpled as old dollar bills — and mostly what the sub plans wanted me to do was pass out work sheets. I passed them out by the thousands. Of all the work sheets I passed out, the ones in high school were the worst. In my experience, every high-school subject, no matter how worthy and jazzy and thought-provoking it may have seemed to an earnest Common Corer, is stuffed into the curricular Veg-O-Matic, and out comes a nasty packet with grading rubrics on the back. On the first page, usually, there are numbered “learning targets,” and inside, inevitably, a list of reports essays specialized vocabulary words to master. In English it’s unreliable narrator , or ethos , or metonymy , or thesis sentence . On Democracy Essay? This is all fluff knowledge, meta-knowledge. In math, kids must memorize words like apothem and alliance definition Cartesian coordinate ; in science they chant domain! kingdom! phylum! class! etc., etc., and meiosis and allele and daughter cell and third-class lever and the whole Tinkertoy edifice of terms that acts to draw people away from the freshness and surprise and fantastic interfused complexity of the world and darkens our brains with shadowy taxonomic abstractions. The instantly forgettable gnat-swarm of word lists is useful in big-box high schools because it’s easier to test kids on quotations on democracy essay, whether they can temporarily define a set of terms than it is to talk to them and find out whether they have learned anything real and thrilling about reports essays what’s out there. All teaching takes a toll on on democracy, what’s taught, but high school is wondrously efficient at making interesting things dull.
So why are kids forced to go? Well, one reason has to do with child-labor laws. Reports Essays? In the middle of the 19th century, kids in most states could stop going to school after eighth grade, once they had learned to read and do a little arithmetic, and they got jobs. They worked on farms or in essay dark satanic mills, and one by one the Promise of Equal, states made laws (or began to enforce existing laws) that said that young people had to stay in school so their morals wouldn’t be corrupted and they wouldn’t languish in ignorance and be roped into a life of labor from on democracy dawn to dusk and die of consumption before they reached 30. So the government built high schools, lots of Essay on The Power them, and the number of kids in high school burgeoned, and blossomed, and ballooned. By 1940, there were five times as many high-school graduates as there were before the labor-law reforms.
It was a huge change all over the country, and it required discipline. Squads of truant officers would go sniffing around finding kids who were evading high school, and they threatened parents with fines or even jail time and got them to comply. What happens if you suddenly have millions of kids in quotations on democracy high school who would have been working under the old laws? You have to hire more teachers, and the blind summary you have to figure out what they’re going to teach. You then get endless debates about quotations cultural literacy — about what subjects should be required. Should everyone in reports essays high school learn Greek? What about Latin? What about sewing? Or needlepoint? Cursive? And the schools became bigger.
The local schoolhouse went away, and quotations essay the gigantic brick edifice on the edge of alliance definition town took its place. James Conant, a president of Harvard, decided in the 1960s that the ideal high school should have at least 750 students. That’s a lot of students — it’s a battalion of essay students, in fact — and that’s perhaps where it all began to go wrong. The regional schools became meatpacking plants, or Play-Doh fun factories, squeezing out supposedly educated human beings, marching them around from class to class — bells bonging, punishments escalating, homework being loaded on. And yet the human beings who were marching from class to class weren’t being paid. The Blind Movie Summary? “Review the elements of transcendentalism listed on Page 369.” Oh, and do it for quotations essay free . Every day something like 16 million high-school students get up at the crack of dawn, slurp some oat clusters while barely conscious, hop on a bus, bounce around the county, show up and sit in a chair, zoned out, waiting for the first bell. The Blind Movie? If they’re late, they are written up. Even if they don’t do much academic work, they are physically present. Their attendance is a valuable commodity, because if students don’t attend, teachers and guidance counselors and principals and textbook makers and designers of educational software have no jobs. A huge lucrative industry is built around them, and the students get nothing out of quotations essay it but a G.P.A.
They deserve not to have their time wasted. And it is Promise Opportunity wasted, as everyone knows. Teachers spend half their time shouting themselves hoarse, and young adults are infantilized. Their lives are absurdly regimented. Every minute is accounted for. They sit in one hot room after another and wait for each class to end. Time thickens. It becomes like saltwater taffy — it becomes viscous and quotations sticky, and it stretches out and it folds back on itself through endless repetition. Tuesday is just like Wednesday, except the schedule is shuffled.
Day after day of work sheets. Promise V. Reality Opportunity? By the time they graduate, they’ve done 13 years of work sheets. When they need to go to the bathroom, they have to write their name on a piece of paper by the door. If they hide in the bathroom, they’re in quotations on democracy trouble. Hot Stove Rule? Whole hierarchies of punishment for scofflaws arise — school-supplied iPads are restricted, parents are called on essay, the phone, in-school suspensions are meted out. What makes all this almost tolerable is the kids themselves. Hot Stove Rule? They find ways to on democracy make it entertaining. They discover friends and co-conspirators.
They rebel. Reports Essays? They interrupt one another constantly in quotations on democracy search of some tiny juicy Jolly Rancher of alliance surprise. On Democracy? They subvert the system. They learn to lie convincingly to avoid work. The teacher’s aide (sometimes it was me) says, “Are you all caught up?” Kid: “Yep.” Aide: “Did you do that BrainPOP about the flipflap of the doodlesquat?” Kid: “Yep, handed that in yesterday.” One young man I talked to seemed unusually intelligent but downcast. Hot Stove Rule? I asked him how he survived his days. He pulled out his earbud, and he said one word: “music.” To find their way in American life, high-schoolers need to be able to speak English, to read, to listen to and respect other people’s opinions, to have a command of the quotations, basic elements of courtesy and, to a lesser extent, to write. (They do not need to know how to the blind movie summary write a thesis sentence. More injury is done to high-school essays by the imposition of the thesis-sentence requirement than by quotations on democracy essay, any other means. Alliance Definition? The trick, kids are sometimes told, is to begin with a word like “although.” No.) It’s also useful to know how to add and subtract and do percentages, how to measure dimensions, and how to read graphs. Quotations? Beyond these basics, there’s a vast, beautiful, glittering midden of applied and miscellaneous knowledge — of natural science, history, material science, design, music, tradecraft and artistic dexterity — and because everything is potentially interesting, everything is potentially worthy of study, and arguing over the fine-grained specifics of the standard curriculum is a waste of time.
Let’s end homework forever — just end it now — and open up more daylight hours for life’s inexhaustible succession of microlessons. Knowing how to paddle a canoe, or fix a faucet, or work a cash register, or bake a coffeecake, or comfort someone who is unhappy, is much more important than knowing the names of the six kingdoms of Essay on The Power living organisms, or the layers of the atmosphere, even if you’re going to quotations on democracy essay become a naturalist or an atmospheric physicist — and paddling and hot stove rule faucet-fixing and cash-registering and cake-baking and the offering of sympathy, like most memorable proficiencies, happen best when they’re voluntary, after school is essay out. Emerson would have liked the School Without Walls. Its motto, although it had no motto, could have been “Self-Reliance.” Now that I’ve spent time teaching in a regular high school, I’m hugely grateful to Essay Lew Marks — who died in on democracy essay 2010 — and the institution he created. (It’s still going, by the way.) The school respected us and Essay on The trusted us. It was a sort of nowhere Utopia — a big, soft, stretchy packet of temporal freedom within which to be bored and idle and sleep late and watch reruns of “My Three Sons” and daytime talk shows and stare through the curtains out the window, and smell the quotations essay, curtains, which had a deep dusty smell, and hot stove rule learn one of the on democracy essay, profound lessons of life, which is that all education is self-education. Nobody needs you to reports essays do anything, so that anything you do has to come from yourself. Nicholson Baker is the author of 16 books, including “Substitute: Going to quotations on democracy School With a Thousand Kids,” published Sept. 6.
Sign up for our newsletter to marx summary get the best of The New York Times Magazine delivered to your inbox every week. A version of this article appears in print on September 11, 2016, on Page MM66 of the Sunday Magazine with the headline: Fortress of Tedium. Essay? Today's Paper | Subscribe. We’re interested in your feedback on Promise Essays, this page. Tell us what you think.