Friday, August 28, 2020
&#9; Rutherford B. Hayes was considered by numerous individuals to be a straightforward, uncontroversial, and genuine man to run for the administration. That is the reason numerous individuals are baffled that such an insightful individual ought to have one of the most dubious decisions and administrations ever. Thinking about HayesÃ¢â¬â¢ fair standards, it came as a shock to perceive how he could unwittingly settle on a choice about reproduction where its belongings were so unmitigatedly critical to the reason he was attempting to help. &#9;The contention started when he was just pursuing position. Hayes was running against Democrat Samuel J. Tilden. At the point when the voting forms were counted in 1876, Hayes plainly lost the well known vote, and had lost the discretionary vote 184 to 165 . Notwithstanding, twenty votes in Oregon, South Carolina, Florida, and Louisiana were contested because of the dissent that blacks were not given the equivalent opportunity to go to the surveys and vote. Congress made and discretionary commission, which painstakingly concluded that Hayes would get each of the twenty votes. Confronting the likelihood that the nation would be left without a president, the two gatherings were thinking about taking the workplace forcibly. Disregarding all the contention, an arrangement was at long last struck. Republicans made a mystery manage Democrats in congress, who made a deal to avoid contesting the Hayes triumph in return for a guarantee to pull back government troops from the south and end remaking . Hayes followed through on the arrangement. He quickly finished Reconstruction and hauled government troops out of the last two involved states, South Carolina and Louisiana . During the short time of radical recreation the negro appreciated both common and political rights. &#9;This political deal contained three for the most part perceived parts: 1) The north would keep hands off the Ã¢â¬Ënegro problemÃ¢â¬â¢. 2) The guidelines administering race relations in the South would be composed by whites. 3) These standards would surrender the negro constrained social liberties, yet neither social nor political uniformity (page 787) . It is clear, in any case, that by 1876-77, a larger part of white Americans were exhausted of proceeding to fight southern counter to the reproduction, particularly when there showed up some likelihood that the South was prepared to give more than empty talk to the rights guaranteed by the Civil War Amendments. This deal immediately created a scene by its rivals. Democrat William Clay stated, "Instead of pulling back... ...et out his southern approach obviously. He needed to dispose of political demonstrations of viciousness against blacks. He demanded, and accepted, that white southerners would cling to the fundamentals of the Civil War Amendments. He demanded that the national government had an obligation to give help to instruction and open upgrades. He additionally trusted it was fundamental that legit government by instructed residents be reestablished in the south. His hypothesis was that this sort of government could be accomplished by guaranteeing that blacks get instruction so they can take part wisely in the races. His optimal of having instructed blacks was very solid. Hayes stated, "securing harmony, success, and the assurance of human rights require training. For whatever length of time that any impressive quantities of our comrades are uneducated, the citizenship of each American in each state is impaired". There are numerous confirmations that President Hayes meant well when making the arrangement to end recreation. His objective was to enable the person of color to pick up and keep up social equality. In spite of the fact that he couldnÃ¢â¬â¢t anticipate at that point, finishing reproduction was a choice that quickly decelerated the dark manÃ¢â¬â¢s race for fairness.
Saturday, August 22, 2020
Stereotypes about Homelessness in America in Dumpster Diving by Lars Eighner Essay Example For Students
Generalizations about Homelessness in America in Dumpster Diving by Lars Eighner Essay Generalizations about Homelessness in America in Dumpster Diving by Lars Eighner Lars Eighners short paper, Dumpster Diving, uncovers the generalizations about vagrancy in America. So as to affirm these known generalizations about American culture, Eighner incorporates self-portraying records of the financially sub-par class, just as uncovering his elitist decides that administers the life of a vagrant. As indicated by Eighner, vagrants fall into the accompanying classifications, can scroungers, Dumpster jumpers, and foragers. (Eighner, 1993). Moreover, Eighners glaring exhibit of his prevalence over the individuals he searches from uncovers his actual character of pretentiousness. We will compose a custom exposition on Stereotypes about Homelessness in America in Dumpster Diving by Lars Eighner explicitly for you for just $16.38 $13.9/page Request now In spite of the fact that Eighner uncovers that his picked way of life was to live on anothers asylum, he kept as per his demonstrations of prevalence and vainglory by barring himself from the term Dumpster Diving. Rather, he liked to be known as a scrounger on account of its straightforwardness in the term. (Eighner, 1993). Moreover, Eighner, clarifies that there are rules to comply with when effectively rummaging through dumpsters, utilizing the sensesÃ¢â¬ ¦knowing the dumpsters of a given areaÃ¢â¬ ¦. what's more, Why was this disposed of? It is the clarification of the three rules Eighner affirms to be better than can scroungers (Homeless individuals who scavenge through the dumpsters for cash). The creator further explains his self importance by uncovering that he has attempted the intolerable way of life of can scroungers, and concluded that lone a couple of dollars could be gotten. In addition, Eighner states, one can extricate the necessities of life from the dumpsters legitimately with far less exertion than would be required to aggregate what could be compared to jars. (Eighner, 1993). The creator stereoty. .ghner, 1993). It is the creators conviction that customers know about their utilization, just as acknowledge how inefficient they are with food when all is said in done For the understudies who don't fit into Eighners inefficient classification, he presents a gathering of economical purchasers who, cautiously wrap up even the littlest extras and push it into the rear of the fridge for a half year or so before disposing of it (Eighner, 1993). Through the exposition, Dumpster Diving, Eighner intrigues his predominance by delineating impartial individuals and their need to finish certain errands the creator is adept at. His contempt and impudence of studentsÃ¢â¬ ¦ Eighners self-portraying article shows the debasement vagrants indure, yet his own pretentiousness of everyone around him Works Cited Eighner, Lars. Dumpster Diving. http://www1.broward.edu/~nplakcy/docs/dumpster_diving. htm
Friday, August 21, 2020
Oliver Stone, Get Your Facts Straight! Some have said that Oliver Stones The Doors was a sensible and precise depiction of Jim Morrisons life and The Doors melodic capers. Lamentably, executive Oliver Stone has a propensity for placing his own convictions and thoughts into the mouths of his characters. This would not really be awful if his characters were anecdotal. Jim Morrison and his individual musicians are genuine, and the individuals who realized him best are as yet living. The principal significant slip-up that Stone made occurred when Jim and Ray Manzarek (Kyle Maclachlan) were going to UCLA film school. An entertainment of Jims short understudy film is appeared. In Stones adaptation there is a lot of what is by all accounts Nazi purposeful publicity. Scenes of Hitler and his soldiers yelling and holding up Nazi banners are appeared with Kilmer perusing Jims verse out of sight. The WWII film in Jims unique film was terribly distorted. It was an entertaining, light scene with an enormous German young lady moving on a T.V. to American awesome music out of sight. Stones rendition portrayed Jim as a supporter of Adolf Hitler. Notwithstanding all the counter Semitism Stone put in the film, he likewise had Kilmer misquoting Friedrich Nietzsche. The scene at Andy Warhols party was Stones next error. Stone figures out how to make different individuals from The Doors into the miscreants. Jim remains solitary. It is an enthusiastic scene that has Jim requesting that different Doors remain at the gathering since he doesnt ...comprehend what could happen this evening, perhaps demise. All the individuals from the band were companions, companions that dont desert each other when they are out of luck. In actuality, different individuals from The Doors didn't leave Jim at the gathering, and he never verbalized a hunch of anything awful happing. Stone may have required something to move his plot further, however did he truly need to criticize others to do this? Another mino...
Tuesday, May 26, 2020
M Butterfly Essay Topics for Dummies M Butterfly Essay Topics Explained Forced to reside in the actual world, Gallimard's preference for illusion is inadequate. The only constant in your lives it's possible to count on is that you're always changing. Finally, the rhetoric ought to have a life cycle. Change in actions and behaviors are deeply linked to the changes in the phases of life. But What About M Butterfly Essay Topics? While the completely free essays may give you inspiration for writing, they cannot be used `as is' because they won't satisfy your assignment's requirements. Pretending your life isn't being affected by anxiety is operating away and naturally, running away brings on adrenaline. Just digest what has been said in this post and you've going on the path to recovery. There are a succession of clues to the reader that Song actually is a guy. Letting the cat from the bag a couple of days earlier than expected will unfortunately impact his very first week sales, as physical CDs weren't available in stores during the first couple of days, but he's still pumped out 363,000 within the very first week, currently sitting around 485,000. There's no difference if you're ill with anxiety. You are able to ascertain the response length by setting the most amount of. As Gallimard says at the start of the drama. What Has to be Done About M Butterfly Essay Topics To produce the wait bearable. So the first thing which you need to do is learn not to attempt to fight them off. There's no opportunity to waste. Well, since the practice is essential to being a master, consequently, you must begin learning beginner's level tricks. There is barely any on-line shopper who's far from PressBuy. However, on the opposite hand for laying options strategies, Tastyworks is definitely the more intuitive provider, thinkorswim a great deal more technical and with a greater learning curve. It is going to keep you safe during practice. Both weather predictions, one based on the whole procedure, another on the part of the data. But, the one difference is it comprises a dull blade that isn't so sharp, which means not dangerous for you. Here in this informative article, we've produced some most-asked questions relating to this wonderful knife. Due to its distinctive look, individuals really like to learn Butterfly Knife Tricks. As knife flipping tricks aren't so simple to do, thus the use of this knife can be quite dangerous for you at an initial stage. Being a real beginner, you should realize that a fan knife is completely unsafe to use, in addition to, it's quite hard to take care of. Generally, a balisong refers to a folding pocket knife that makes it a perfect alternative for many. Nonetheless, aside from its bloody history linked to crime and criminals, butterfly knives are famed for some other very good explanations. The Importance of M Butterfly Essay Topics Second, both insects are quite cute. A butterfly, in the shape of a larva or a caterpillar, eats the utmost sum of food inside this stage. Caterpillars have only one aim, which is to eat a growing number of food. Unique varieties of caterpillars eat various kinds of food. In English we sometimes use the term farfalle to refer to this same sort of pasta. The contemporary German word schmettern ways to smash, but apparently smetern once meant cream in some specific sections of Germany. Both of these words aren't synonyms. The Scandinavian words aren't consistent either. He's attempting to call this counterpublic into action to select the power structures in the united states and rebuild them themselves. The opening conversations of the folks at a party don't specifically state the situation. Its 2012 attack, which caused the compromise of lots of significant fish, was noisy and garnered plenty of attention. But first I have to have out of my own head. Understanding M Butterfly Essay Topics The business because it's today shouldn't be sacrificed for some punts on the future. Regardless of the monumental increase in the entrepreneurial sector, it's correct that not everybody is cut out for entrepreneurship. Therefore, it's a ban in various countries around the planet. A Real Estate company unlike any other centered on the mission of constructing a network of career-minded pros who strive to cultivate their company and their future.
Friday, May 15, 2020
Describe a time in your life when you used music to communicate with an audience outside the traditional setting of the concert hall. What did you learn form the experience? How did this experience influence your approach to music and performance? In order to support my musical studies and make a living, I wait tables at the Beat Hotel in Harvard Square. Beat is not a traditional hotel in the sense of providing temporary living quarters for a period of time. It is a beautiful restaurant space that seats about 170 guests. We function as a brasserie/ live music venue. I have been with the restaurant since its opening 16 months ago. Since then, I have gained quite an appreciation for the live music we provide our guests every evening. All of our performers are local and touring musicians well versed in all musical styles pertaining to jazz, RB, classical, and world music. Many are world renowned performers and teachers at our reputable music institutions such as Longy School of Music of Bard, New England Conservatory, and Berklee College of Music. For example, pianist/composer and improvisational specialist Leo Blanco is one of our main acts at Beat. Working alongside these fantastic musicians make all the difference in turning a stressful and demanding food service position into a trendy, and unique nightclub environment for our staff and clientele. There is no other restaurant like ours, except our sister location, known as the Beehive in the South End. Being an operaShow MoreRelatedPersonal Narrative : My School Day1703 Words Ã |Ã 7 PagesStopping right in the middle of my driveway, I needed to take a moment to figure out where it was from and what it was for. Once I read the back of the letter, I could not help but start thinking about what I had done to deserve this, it was from Harvard Square, Cambridge, Massachusetts. To myself, I thought, Ã¢â¬Å"Did they have the right person and address?Ã¢â¬ Of course, I knew that was a ludicrous question. Why would they have gotten my address and name correct if it was not meant for me? My heart was racingRead MoreDescriptive Essay About School Day1727 Words Ã |Ã 7 PagesStopping right in the middle of my driveway, I had to take a moment to figure out wh ere it was from and what it was for. Once I read the back of the letter, I could not help but start thinking about what I had done to deserve this, it was from Harvard Square, Cambridge, Massachusetts. I think to myself, Ã¢â¬Å"Did they have the right person and address?Ã¢â¬ Of course, I knew that was ludicrous question, why would they have gotten my address and name correct if it was not meant for me? My heart was racing,Read MoreAl Capone: One of the Most Ruthless Men of All Time1958 Words Ã |Ã 8 Pagesgambling, extortion, and protection rackets (Schoenberg 23-25). Al Capone worked at the Harvard Inn as a bartender and a bouncer. One night he tried to pick up a woman that he found attractive, not knowing that her brother was sitting next to her. The brother jumped up and hit Capone in the face. Capone became raged and the other man pulled out a knife and cut Capones face 3 times before he ran out of the Harvard Inn with his sister. This is how Capone earned his nickname , Scarface (Bardsley 7-9)Read More Al Capone: One Of The Most Ruthless Men Of All Time Essay1929 Words Ã |Ã 8 Pagesgambling, extortion, and protection rackets (Schoenberg 23-25). Al Capone worked at the Harvard Inn as a bartender and a bouncer. One night he tried to pick up a woman that he found attractive, not knowing that her brother was sitting next to her. The brother jumped up and hit Capone in the face. Capone became raged and the other man pulled out a knife and cut CaponeÃ¢â¬â¢s face 3 times before he ran out of the Harvard Inn with his sister. This is how Capone earned his nickname, Scarface (Bardsley 7-9).Read MoreFour Seasons Goes to Paris10233 Words Ã |Ã 41 Pagessenior Four Seasons manager In 2002, Four Seasons Hotels and Resorts was arguably the worldÃ¢â¬â¢s leading operator of luxury hotels, managing 53 properties in 24 countries and delivering what observers called Ã¢â¬Å"consistently exceptional service.Ã¢â¬ For Four Seasons, that meant providing high -quality, truly personalized service to enable guests to maximize the value of their time, however the guest defined doing so. In 1999, Four Seasons opened the Four Seasons Hotel George V Paris (hereafter, Ã¢â¬Å"F. S. George VÃ¢â¬ )Read MoreJay-Z Essay6109 Words Ã |Ã 25 Pagesdrum patterns on the kitchen table. Eventually, she bought him a boom box for his birthday and thus sparked his interest in music. He began freestyling, writing rhymes, and followed the music of many artists popular at the time. It is stated that he beat Busta Rhymes in a rap battle, but also has lost to DMX. On top of that, Bone Thugs-N-Harmony member Bizzy Bone was snatched by his employer and taken to New York to battle Jay-Z; Bizzy reportedly was victorious in the battle. InRead MoreNew York City: History and Landmarks4966 Words Ã |Ã 20 Pagescities at that time--voted to Ã¢â¬Å"consolidateÃ¢â¬ with Manhattan to form a five-borough Ã¢â¬Å"Greater New York.Ã¢â¬ As a result, on December 31, 1897, New York City had an area of 60 square miles and a population of a little more than 2 million people; on January 1, 1898, when the consolidation plan took effect, New York City had an area of 360 square miles and a population of about 3,350,000 people.Ã The 20th century was an era of great struggle for American cities, and New York was no exception. The constructionRead MoreWal-Mart Research Paper5020 Words Ã |Ã 21 Pagesand CEO of Wal-Mart, Walton Implemented several vision that would serve as part of Wal-Mart success. Today, there are 624 stores offering a pleasant and convenient shopping experience across the United States. The size of an average store is 108,000 square feet. Each store employs about 225 associates (Walmartstores.com 2012). Wal-Mart aisles and shelves are stocked with a variety of quality, value-priced general merchandise, including: Ã¢â¬ ¢ Family apparel Ã¢â¬ ¢ Electronics Ã¢â¬ ¢ Lawn and garden items Ã¢â¬ ¢ AutomotiveRead MoreWalmart In 200311485 Words Ã |Ã 46 Pages2003 President and Fellows of Harvard College. To order copies or request permission to reproduce materials, call 1-800-545-7685, write Harvard Business School Publishing, Boston, MA 02163, or go to http://www.hbsp.harvard.edu. No part of this publication may be reproduced, stored in a retrieval system, used in a spreadsheet, or transmitted in any form or by any meansÃ¢â¬âelectronic, mechanical, photocopying, recording, or otherwiseÃ¢â¬âwithout the permission of Harvard Business School. This documentRead MoreHbr When Your Core Business Is Dying74686 Words Ã |Ã 299 PagesHeineman, Jr. How do you keep thousands of employees, operating in hundreds of countries, as honest as they are competitive? General ElectricÃ¢â¬â¢s longtime general counsel describes the systems the company has put in place to do just that. 78 90 4 Harvard Business Review | April 2007 | hbr.org Cover Art: Joshua Gorchov continued on page 8 APRIL 2007 14 Departments 12 COMPANY INDEX 14 FROM THE EDITOR 53 2006 MCKINSEY AWARDS AND 2007 MCKINSEY JUDGES 20 What the Boss
Wednesday, May 6, 2020
MEMORANDUM Subject: CSR Program Proposal for Columbia Bank This memorandum proposes a corporate social responsibility program for Columbia Bank with a focus on student loan debt in our community. This CSR program could be implemented in addition to the community and customer events currently arranged on the branch level. Columbia Bank, and the local communities we serve, would greatly benefit from offering a CSR program that focuses on educating high school students, college students, parents and any potential borrower on the long-term implications of excessive student loan debt. Student Loan Debt and Our Community The first sentence of our mission statement reads, Ã¢â¬Å"We will increase shareholder value and enrich the communities weÃ¢â¬ ¦show more contentÃ¢â¬ ¦Mortgages Second, Columbia Bank could potentially issue more home mortgages to individuals with little to no student loan debt. A Consumer Financial Protection Bureau report (2013) states, Ã¢â¬Å"According to the National Association of Realtors, Americans between the ages of 25 and 34 made up 27 percent of all homebuyers in 2011, the lowest share in the past decade. That percentage represents a 25 percent decline year-over-year from 2010 (para. 8).Ã¢â¬ This decline is negatively correlated with the increase in student loan debt among that age group. Car Loans According to Brown and Caldwell (2013), 25-year-olds who have student loan debt are now dramatically less likely to incur automobile debt compared to those without student loan debt. Historically, individuals with student loan debt had three to four percent more automobile debt than those without student loan debt (para. 9). This is impacting the number of applicants who may otherwise be interested in our automobile loans services. Small Business Loans Small business loans are an opportunity area for Columbia Bank as well. Aspiring young entrepreneurs can be rejected for these types of loans due to a large debt to income ratio or low credit scores. According to the Consumer Financial Protection Bureau (2013), Ã¢â¬Å"The Small Business AdministrationÃ¢â¬â¢s Startup America initiative advises young entrepreneurs to lower their student loan payments by taking advantage of anShow MoreRelatedThe Proposed Corporate Social Responsibility1329 Words Ã |Ã 6 Pagesthe community. The proposed corporate social responsibility (CSR) program aims to reduce the homeless population in the region by implementing a financial education program in homeless shelters. Background According to Metropolitan Washington Council of Government (COG), as of 2014, there are 11,946 homeless individuals inhabit in Washington Metropolitan area. This region consists of Alexandria, Arlington Country, District of Columbia, Frederick Country, Loudoun Country, Montgomery Country, PriceRead MoreThe Myth of Csr5260 Words Ã |Ã 22 PagesThe Myth of CSR The problem with assuming that companies can do well while also doing good is that markets donÃ¢â¬â¢t really work that way By Deborah Doane Stanford Social Innovation Review Fall 2005 Copyright Ã © 2005 by Leland Stanford Jr. University All Rights Reserved DO NOT COPY Stanford Social Innovation Review 518 Memorial Way, Stanford, CA 94305-5015 Ph: 650-725-5399. Fax: 650-723-0516 Email: firstname.lastname@example.org, www.ssireview.com ~ DO NOT DISTRIBUTE ~ FOR PERSONAL USE ONLY ~ Read MoreArticle: Performance Appraisal and Performance Management35812 Words Ã |Ã 144 Pageset al. 1981). By using a formal system performance appraisals have many advantages if they are designed and implemented properly. Not only in reward allocation, promotion/demotions, layoffs/recalls, transfers and selecting training and development program for employees but it may also assist individual employeeÃ¢â¬Å¸s decisions regarding career choices and the subsequent direction of individual time and effort. Additionally, performance appraisals may increase employeeÃ¢â¬Å¸s commitment and satisfaction (WieseRead MoreInternational Management67196 Words Ã |Ã 269 Pagesand the end-of-book skill-building exercises and simulations on the Online Learning Center complete the package. To help instructors teach international management, this text is accompanied by a revised and expanded InstructorÃ¢â¬â¢s Resource Manual, Test Bank, and PowerPoint Slides, all of which are available passwor d protected on the Online Learning Center at www.mhhe. com/luthans8e. Two other innovations new to the eighth edition are an additional case, Nokia Targets the Base of the Pyramid, availableRead MoreProject on Risk Management46558 Words Ã |Ã 187 PagesA Summer Training Project Report on Ã¢â¬Å"RISK MANAGEMENT BY INDUSIND BANK LTD.Ã¢â¬ Undertaken at INDUSIND BANK, AGRA 10th April to 10th June 2009 Submitted by SUBODH AGARWAL Enrollment no. : 4108163163 Read MoreExploring Corporate Strategy - Case164366 Words Ã |Ã 658 Pagesimpressive international growth of an Irish company driven from a Ã¢â¬ËleanÃ¢â¬â¢ corporate centre. Numico Ã¢â¬â difficulties with diversification for a Dutch nutritional products company. AIB Ã¢â¬â competing in the global banking industry: the challenges for a mid-size bank. SABMiller Ã¢â¬â an African brewer takes on the world: learning to thrive in difficult circumstances. MacPac Ã¢â¬â from a New Zealand start-up to internationalisation in the outdoor equipment industry. Key: Ã¢â" Ã¢â" = major focus Ã¢â" = important subsidiary focus Read MoreProject Mgmt296381 Words Ã |Ã 1186 PagesCross Reference of Project Management Body of Knowledge (PMBOK) Concepts to Text Topics Chapter 1 Modern Project Management Chapter 8 Scheduling resources and cost 1.2 Project defined 1.3 Project management defined 1.4 Projects and programs (.2) 2.1 The project life cycle (.2.3) App. G.1 The project manager App. G.7 Political and social environments F.1 Integration of project management processes [3.1] 6.5.2 Setting a schedule baseline [8.1.4] 126.96.36.199 Setting a resource schedule 188.8.131.52 ResourceRead MoreStephen P. Robbins Timothy A. Judge (2011) Organizational Behaviour 15th Edition New Jersey: Prentice Hall393164 Words Ã |Ã 1573 Pages52 Intellectual Abilities 52 Ã¢â¬ ¢ Physical Abilities 55 Ã¢â¬ ¢ The Role of Disabilities 56 Implementing Diversity Management Strategies 56 Attracting, Selecting, Developing, and Retaining Diverse Employees 56 Ã¢â¬ ¢ Diversity in Groups 58 Ã¢â¬ ¢ Effective Diversity Programs 58 Summary and Implications for Managers 60 S A L Self-Assessment Library WhatÃ¢â¬â¢s My Attitude Toward Older People? 40 Myth or Science? Ã¢â¬Å"Dual-Career Couples Divorce LessÃ¢â¬ 47 An Ethical Choice Religious Tattoos 51 glOBalization! Images of DiversityRead MoreContemporary Issues in Management Accounting211377 Words Ã |Ã 846 Pagesfocuses on performance measurement, evaluation, and incentives in the context of creative industries. Lawrence A. Gordon is the Ernst Young Alumni Professor of Managerial Accounting and Infor- mation Assurance, and the Director of the Ph.D. Program at the Robert H. Smith School of Business. He is also an Affiliate Professor in the University of Maryland Institute for Advanced Computer Studies. Dr Gordon earned his Ph.D. in Managerial Economics from Rensselaer Polytechnic Institute. His researchRead MoreCase Study148348 Words Ã |Ã 594 Pagesmaterial: Johnson Gerry, Whittington Richard, Scholes Kevan - Exploring Strategy Instructors Manual on the Web... We are grateful to the following for permission to reproduce copyright material: Tables Table 14.1 adapted from Ã¢â¬ËWhy change programs don t produce changeÃ¢â¬â¢, Harvard Business Review, November to December (Beer et al; 1990) In some instances we have been unable to trace the owners of copyright material, and we would appreciate any information that would enable us to do so. 6
Tuesday, May 5, 2020
Jury Nullification and Its Effects on Black Americ Essay aIt is obvious that significant improvements have been made in the way that the criminal justice system deals with Blacks during the history of the United States. Blacks have not always been afforded a right to trial, not to mention a fair one. Additionally, for years, Blacks were unable to serve on juries, clearly affecting the way both Blacks and whites were tried. Much of this improvement has been achieved through various court decisions, and other improvements have been made through federal and state legislatures. Despite these facts, the development of the legal system with regard to race seems to have become stagnant. Few in this country would argue with the fact that the United States criminal justice system possesses discrepancies which adversely affect Blacks in this country. Numerous studies and articles have been composed on the many facets in which discrimination, or at least disparity, is obvious. Even whites are forced to admit that statistics indicate that the Black co mmunity is disproportionately affected by the American legal system. Controversy arises when the issue of possible causes of, and also solutions to, these variations are discussed. Although numerous articles and books have been published devising means by which to reduce variance within the system, the most recent, and probably most contentious, is that of Paul Butler, Associate Professor of Law, George Washington University Law School, and former Special Assistant United States Attorney in the District of Columbia. Butlers thesis, published in an article in the Yale Law Journal, is that for pragmatic and political reasons, the black community is better off when some nonviolent lawbreakers remain in the community rather than go to prison. The decision as to what kind of conduct by African-Americans ought to be punished is better made by African-Americans themselves.1 The means by which Butler proposes for Blacks to implement these decisions is termed jury nullification. By placing the race of the defendant above the facts of the case, and thus producing either an acquittal or a hung jury, Butler hopes that Blacks will be able to keep a large portion of Black ma les out of prison. Although several commentators have voiced criticisms with the ideas of Professor Butler, most of these criticisms focus on what is best for the American legal system, what legal precedents dictate, or as is most often the case, on what is right. It is, however, negligent to simply focus on these issues when examining the proposal of Professor Butler. Instead criticism and analysis must be based upon what is best for the Black community in this country. From this perspective it becomes clear that although race-based jury nullification has many attractive features, it must be modified to be truly beneficial. The first step in analyzing Butlers conception of jury nullification is to examine problems which Butler claims cause a need for a solution. These problems are flaws in the criminal justice system, intrinsic or otherwise, which present themselves as disparities in treatment of whites and Blacks. In any policy discussion, formulation of a plausible and effective solution clearly mus t be based upon the nature of the problem. Butler lists many examples of racism in the criminal justice system, but many are simply specific cases meant to illustrate his point. Although these cases are important, they are nearly impossible to discuss in a general examination of discrimination in the justice system because specific cases do not necessarily entail widespread discrimination. However, Butler does cite past and contemporary administration of the death penalty, disparities between punishments for white-collar crimes and punishments for other crimes, more severe penalties for crack cocaine users than for powder cocaine users, and the high rate of incarceration of African-American men.2 All arguments regarding Butlers thesis must be framed within the context of these problems, if not directly addressing them. Although Butler lists it last, he does note that the problem of high incarceration rates among Black males is the one noted most frequently. This problem is one which is essential to the discussion of jury nullification, and should be explored specifically for a number of reasons. First, whatever the reason, the number of Black men in prison is frighteningly high. One out of every twelve black males in their 20s is in prison or jail. Additionally, there are seven Black males in prison for every one white male.3 More than half of all black males are under the supervision of the justice system in some way.4 These two factors indicate a very important trend. A high number of black males are in prison, and many more black males are in prison than white males. This would definitely lead a reasonable person to assume at least some measure of discrimination within the criminal justice system. Secondly, and perhaps more significantly, the high rate of incarceration, upon further examination, leads to conclusions about its causes which then shed light on the discussion of jury nullification. The first step in examining this phenomenon is to examine what role racism plays in the high rate. There are several levels within the system at which discrimination could occur.The initial contact which anyone has with the justice system is with the police. The police are the institution which serve as a gateway to the legal system, and thus it is only logical to look here first. First, in 1984 almost 46% of those arrested for violent crimes were Black, while Blacks constitute only about 12% of the national population on the whole. 5 Overall, Blacks are twice as likely to be arrested when compared to whites.6 This data could be construed to mean simply that Blacks commit more crimes than whites. Although this may be true, the argument that police behavior is undistorted by racial discrimination flatly contradicts most studies, which reveal what many police officers freely admit: that police use race as an independently significant, if not determinative, factor in deciding whom to fo llow, detain, search, or arrest.7Despite the fact that discrimination may exist among police, the arrest figures still do not account for the vast disparity in incarceration rates. So other aspects of the criminal justice system must be examined. Another level in which discrimination can be claimed is that of the prosecutor. Because prosecutors have such enormous discretion when deciding which charges to file, which penalties to seek, and which cases to prosecute, there are many instances in which a prosecutors racism can be turned into discrimination against a defendant. Indeed, statistical studies indicate that prosecutors are more likely to pursue full prosecution, file more severe charges, and seek more stringent penalties in cases involving minority defendants than in cases involving nonminority defendants.8This discrimination becomes even more evident, and disturbing, when examining the death penalty. A study in Georgia found that in matched cases, prosecutors sought the death penalty in 70 percent of the cases in which a Black killed a white, and 15 percent of the cases in which a white killed a Black.9 Although these numbers cannot be extrapolated to indict the entire nations prosecutors, other figures do indicate vast disparity. In McCleskey v. Kemp, the defendant introduced a comprehensive, multiple regression analysis of the death penalty, done by Professor David Baldus. The study controlled for 230 independent variables, and indicated that race is by far the most important factor in whether a defendant receives the death penalty. It also found that Black killers of white victims are far more likely than white killers of Black victims to receive the death penalty.10 Although the Court upheld the death penalty, it only did so because of precedent which states that discrimination must be proved through demonstration of intent, and not just results.This disparity is reflected in the number of Black death row inmates. The NAACP Legal Defense fund report s that nearly 39 percent of the inmates on death row in the 35 states in which the death penalty is used. It also found that of all federal death row inmates, 67 percent are Black.11Despite the fact that these statistics are startling and important, they are insufficient to justify race-based jury nullification at face value. First, the studies of Dean Alfred Blumstein of Carnegie-Mellon and of Joan Petersilia of the RAND Corporation conclude that about 80 percent of the black overrepresentation in prison can be explained by differential involvement in crime and about 20 percent by subsequent racially discriminatory processes.12 Twenty percent is definitely significant and does deserve action, but it is not as high of a number as some might speculate, and therefore might dictate a more moderate solution. This will be discussed further later. Second, the crime and delinquency rates of incarceration, and rates of arrest and of victimization of those who move away from these slums are indistinguishable from whites of the same social class.13 This fact suggests that socioeconomic factors are very important in the existence of crime. Butler argues that the this fact is simply more impetus for the implementation of his plan. He asserts that discrimination and segregation deprive Blacks of adequate opportunity to improve their social and economic standing. He describes a radical critique, by which he states he is persuaded, in which the radical critic deduces that but for the (racist) environment, the African-American criminal would not be a criminal.14 Certainly this is a compelling argument. It is not clear, however, exactly how economic inequalities cause crime. Logic would certainly support the idea that Blacks, faced with stark living conditions, would commit crime either to strike back at whites or to attain more wealth. There are several problems with this idea, however. First, many crimes are unrelated, if not contrary, to acquisition of wealth. Not all murde rs are committed over material goods, and assuredly drug use in no way is helpful to the attainment of financial security. Second, to assume that crime is dictated by social or psychological purposes is to ignore that fact that in most cases commission of criminal acts is governed by the proximity, ease, and convenience of reward. In short, crime is an ill-conceived mechanism for the redistribution of wealth or for the extraction of revenge on ones oppressors, and no racial or ethnic group believes otherwise.15 Once again, the merits of jury nullification in alleviating these problems will be discussed, as will other solutions, later. The True Tragic Hero in Sophocles Antigone EssayThe question, then, is how can progress be made? One significant omission on Butlers part is a set of goals or requests which would make Butlers intentions clearly known. The only goal which Butler discusses is the release of Black males into the community. He even neglects analysis of possible changes which he would hope to instigate through jury nullification. Inclusion of specific reforms which would be desired would have two positive effects. First, it would help to avoid white backlash. By demonstrating that jury nullification had specific purposes, Butler would deflect criticism that the plan is simply a racially selfish scheme to keep Blacks from receiving punishment. Explicit goals would also make it clear to the public that there are discriminatory practices which Butler wishes to end. Second, only by explaining what jury nullification is meant to accomplish can the government be expected to reform the criminal justice system . This is especially true if the goals include public policy changes not directly related to the legal system, such as the elimination of discriminatory housing practices or augmentation of job training programs. Then, if jury nullification proves effective, and the government is forced to some concessions, Blacks will benefit much more than just from the release of Black males. Clearly, Blacks have much more to expect from public policy and the criminal justice system than they currently experience. Discrimination, to at least some extent, occurs at almost every level of the system. Although there is no way to be sure whether racism, socioeconomics, or some other mysterious factor is to blame for the high level of Black incarceration, clearly something ought to change. Jury nullification, despite some gaps in Butlers explanation and justification, is one of the only methods by which Blacks can hope to affect change. Even if Paul Butler accomplishes nothing else, he can reasonably expect to achieve one goal: raising awareness of race in criminal justice. As Butler states in the conclusion of his article, Perhaps, when policy makers acknowledge that race matters in criminal justice, the criminal law can benefit from the successes and failures of race consciousness in other areas of the law To get criminal justice past the middlepoint, I hope that the Essay wi ll facilitate a dialogue among all Americans in which the significance of race will not be dismissed or feared, but addressed.271 See Paul Butler, Racially Based Jury Nullification: Black Power in the Criminal Justice System, 105 Yale Law Review No. 3. This article was retrieved using LEXIS, thus no specific page numbers are available. The page range of the article was originally 677-725. 2 Id. 3 See Norval Morris, Race and Crime: What evidence is There That Race Influences Results in the Criminal Justice System?, 72 Judicature No.2, (1988) at 112. 4 Butler, supra note 1. 5 See Bureau of the Census, Statistical Abstract of the United States 25 (106th edition, 1986). 6 Morris, supra note 3. 7 See 101 Harvard Law Review (1988)at 1472. 8 See Harvard Law Review at 1520. 9 Morris, supra note 3. 10 See McCleskey v. Kemp, 107 Supreme Court (1987). 11 See Coramae Richey Mann, Unequal Justice (1993) at 202-3. 12 Morris, supra note 3. 13 Morris, supra note 3. 14 Butler, supra note 1. 15 Michael R. Gottfredson and Travis Hirschi, A General Theory of Crime (1990), at 152. 16 Butler, supra note 1. 17 See William Julius Wilson, The Truly Disadvantaged: the inner city, the underclass, and public policy (1990), at 91. 18 See Kate Stith, The Government Interest in Criminal Law: Whose Interest Is It, Anyway?, Public Values in Constitutional Law (Stephen E. Gottlieb ed., 1993), at 137, 15819 Randall Kennedy, The State, Criminal Law, and Racial Discrimination: A Comment, 107 Harvard Law Review (1994), at 1262. 20 Morris, supra note 3. 21 Morris, supra note 3. 22 See Douglas S. Massey, Americas Apartheid and the Urban Underclass, Social Service Review (December 1994), at 480. 23 Butler, supra note 1. 24 Michael Vitiello, Reconsidering Rehabilitation, 65 Tulane Law Review (1991). 25 Benjamin A. Holden, Laurie P. Cohen, and Eleena De Lisser, Does Race Affect Juries? Injustice with Verdicts, Chicago Sun-Times (October 8, 1995) at 28. 26 Butler, supra note 1. 27 Butler, supra note 1. Category: Law