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Benito Cereno, Herman Melville - Essay. “Benito Cereno” Herman Melville. The following entry presents criticism of Melville's short story, “Benito Cereno” (1855). See also Billy Budd Criticism , Pierre, or, The Ambiguities Criticism , and Redburn: His First Voyage Criticism . Melville freely adapted “Benito Cereno,” his highly-regarded and ironic tale of a slave mutiny at Dr. Segal's The Cookie sea, from an episode in Amasa Delano's Narrative of mary wollstonecraft rights, Voyages and Dr. Segal's The Cookie FAD Diet Essay Travels in karangan rumusan the Northern and Southern Hemispheres (1817). Dr. Segal's FAD Diet? The work was originally serialized in Putnam's Monthly in 1855 and when human genome project began later revised and reprinted in Melville's The Piazza Tales the following year. Ostensibly a story of mystery on the high seas, “Benito Cereno” demonstrates Melville's subtle narrative manipulation of Delano's historical account of an 1805 slave uprising. In the story, Melville presents a naive protagonist who stumbles upon the remnants of a violent rebellion, but fails to recognize the horrors that have occurred. Considered by critics to be one of Melville's finest stories for its symbolic richness and Dr. Segal's The Cookie FAD Diet narrative complexity, “Benito Cereno” is additionally acknowledged for its skilled thematic depiction of human depravity and moral relativism. Plot and Major Characters. “Benito Cereno” opens aboard the Bachelor's Delight, an of sports, American sealer and merchant ship anchored near a deserted island off the southern coast of Chile. Scanning the horizon, Amasa Delano, the vessel's captain, observes a strange ship apparently in Dr. Segal's FAD Diet Essay need of aid. Delano boards his whaleboat, has some supplies loaded, and makes his way to angela bega the craft, a decaying Spanish merchant vessel called the San Dominick.
Once onboard, Delano sees that the crew is in a dismal state and that the ship carries a number of black slaves, many of whom, much to Delano's surprise, are not shackled. He speaks with Don Benito Cereno, the ship's grave and sickly captain, who assures him that the FAD Diet slaves are docile. Sending his boat back for additional supplies and of sports new sails, Delano remains on the San Dominick and Dr. Segal's attempts to discover from the tight-lipped Cereno what has caused the currently bleak condition of his craft and crew. Mary Wollstonecraft A Vindication Of Women? After some time, Cereno—who is constantly attended by Dr. Segal's The Cookie, Babo, his short Negro slave—explains that the San Dominick met with severe weather off Cape Horn and has endured bouts of sickness and scurvy that killed most of the Spanish crew and passengers, including Don Alexandro Aranda, the slave owner. Project Began? Noting that the The Cookie FAD Diet weather has been calm of late, Delano begins to suspect that the Spaniard may be mentally as well as physically ill. That evening, Delano dines with Cereno and Babo, and finds that he is unable to convince the Spaniard to send Babo out of the room. After dinner, Babo shaves the extremely nervous and agitated Cereno, nicking his check slightly with his blade. Later, Delano discovers that Babo has received a small cut on his check as well, which he claims was given him by Cereno. Delano's whaleboat returns and, as the American prepares to depart, Cereno, having previously refused to join him aboard the Bachelor's Delight, desperately springs into the waiting craft.
A shocked Delano looks up to see Babo wielding a knife. Once back at Delano's ship, Cereno explains to mary a vindication Delano that the Dr. Segal's Essay slaves had mutinied shortly after the San Dominick left port. The Americans then pursue the stolen vessel, subdue the mutineers, and set sail for Lima, where a trial is karangan rumusan, held. Babo is hanged, and Don Cereno enters a nearby monastery. He dies some three months after giving his court deposition. Dr. Segal's FAD Diet? Critics perceive in “Benito Cereno” Melville's principal concern to be with the wollstonecraft rights problem of human savagery, and its specific manifestation in the institution of slavery. Scholars have forwarded a number of theories regarding this element of the tale, with most acknowledging that Melville's narrative, while complex and Dr. Segal's FAD Diet ambiguous, presents a critique of slavery and the systems of tyrannical oppression that lead men to commit horrible acts of depravity. A related strain in the story involves Melville's denigration of wollstonecraft a vindication of the, colonial expansionism and warns of the lurking dangers associated with the widespread American belief in Manifest Destiny during the mid nineteenth-century. Focusing on the figure of Dr. Segal's FAD Diet Essay, Amasa Delano, a number of commentators see in “Benito Cereno” Melville's complex use of narrative structure and his portrayal of the story's naive and highly credulous protagonist, who is angela bega, unable to FAD Diet Essay comprehend the evils that Babo and rumusan his fellow slaves have performed upon their former captors. Commentators also see in the work a subtle critique of historical narrative as a medium of truth, given Delano's inability and unwillingness to perceive that a slave revolt has occurred aboard the San Dominick and that many of its original crew members have been slain. Thus, Melville's manipulation of Amasa Delano's historical Narrative as a text that purports itself as a factual account calls into question the notion of FAD Diet Essay, historical and indeed moral truth, as well as the ordinary separation between historical fact and fiction.
Like most of Melville's writing, “Benito Cereno” was largely unappreciated during his lifetime and wollstonecraft a vindication of the rights of women it was not until a thorough reassessment of his oeuvre was made in the early twentieth century that critics and readers began to take notice of the merits of this work. In the ensuing years, critics have praised Melville's manipulation of narrative form to create a compelling mystery that delves into Dr. Segal's The Cookie FAD Diet Essay the ambiguities of good and evil. Others have remarked upon the technical virtuosity of the angela bega tale, as well as Melville's skillful use of irony and the symbolic imagery of nature. Modern critics have continued to debate the matter of Melville's opinions on slavery as depicted in the story, though most concede that the author's intentions are far from racist. “Benito Cereno” is generally considered one of the most brilliantly realized pieces of short narrative fiction in nineteenth-century American literature. Access our Benito Cereno Study Guide for Free. Typee: A Peep at Polynesian Life. During a Four Months' Residence in a Valley of the FAD Diet Essay Marquesas (novel) 1846.
Omoo: A Narrative of Adventures in the South Seas (novel) 1847. Mardi: And a Voyage Thither (novel) 1849. Redburn: His First Voyage (novel) 1849. White-Jacket; or, The World in a Man-of-War (novel) 1850. Moby-Dick; or, The Whale (novel) 1851; also published as The Whale (novel) 1851. Pierre; or, The Ambiguities (novel) 1852.
Israel Potter: His Fifty Years in Exile (novel) 1855. The Piazza Tales (short stories) 1856. The Confidence-Man: His Masquerade (novel) 1857. Battle-Pieces and Aspects of the War (poetry) 1866. Clarel: A Poem and Pilgrimage in the Holy Land (poetry) 1876. Angela Bega? John Marr and Other Sailors (poetry) 1888. Timoleon (poetry) 1891. Billy Budd and Other Prose Pieces (novel and short stories) 1924. Allan Moore Emery (essay date 1984) SOURCE: “‘Benito Cereno’ and Manifest Destiny,” in Nineteenth-Century Fiction, Vol. Dr. Segal's The Cookie FAD Diet? 39, No.
1, June, 1984, pp. 48-68. [ In the following essay, Emery examines Melville's critique of American expansionism in “Benito Cereno.” ] Like most authors of the first rank, Herman Melville has commonly been considered a devotee of the timeless, one who, especially in Moby-Dick (1851), sought ultimate answers to life's eternal questions. Only during the past two decades has Melville's “topicality” come to be recognized, as critics have underlined with increasing frequency his timely interest in racial prejudice and technological progress, in English slums and. (The entire section is 8354 words.) Get Free Access to this Benito Cereno Study Guide. Start your 48-hour free trial to unlock this resource and thousands more. Examples? Get Better Grades. Our 30,000+ summaries will help you comprehend your required reading to ace every test, quiz, and essay. We've broken down the chapters, themes, and characters so you can understand them on your first read-through. Access Everything From Anywhere.
We have everything you need in one place, even if you're on the go. Download our handy iOS app for free. SOURCE: “Masquerades of Language in Melville's Benito Cereno, ” in Arizona Quarterly, Vol. 44, No. 2, Summer, 1988, pp. 5-21. [ In the following essay, Hauss probes the link between language and political oppression in “Benito Cereno.” ] … the The Cookie Essay principle relic of faded grandeur was the angela bega ample oval of the shield-like stern-piece, intricately carved with the arms of Castille and Leon, medallioned about by groups of mythological or symbolical devices; uppermost and central of which was a dark satyr in The Cookie FAD Diet a mask, holding his foot on the prostrate neck of a writhing figure, likewise masked. 1. (The entire section is 5596 words.) Get Free Access to this Benito Cereno Study Guide. Start your 48-hour free trial to unlock this resource and thousands more.
Gloria Horsley-Meacham (essay date 1991) SOURCE: “Bull of the Nile: Symbol, History, and Racial Myth in ‘Benito Cereno,’” in The New England Quarterly, Vol. LXIV, No. 2, June, 1991, pp. 225-42. [ In the following essay, Horsley-Meacham argues that while “Benito Cereno” ostensibly upholds racial myths, it contains a subversively “egalitarian and humane” element. ] Herman Melville seems an astute observer of contoh karangan rumusan, African sensibilities when, in Moby Dick, his sharp-witted Daggoo inveighs against conventional associations with his color, declaring: “Who's afraid of Dr. Segal's The Cookie FAD Diet, black's afraid of me!” 1 Yet, in a later work, “Benito Cereno,” a setting perfectly designed to explore Black ethos. (The entire section is 5927 words.) SOURCE: “Voicing Slavery Through Silence: Narrative Mutiny in Melville's Benito Cereno, ” in Mosaic, Vol. 26, No. 2, Spring, 1993, pp. 21-38. [ In the following essay, Haegert studies the complex narrative structure of journals, “Benito Cereno” and its relation to the work as anti-imperialist fiction. Dr. Segal's? ] If anything can be said to contoh rumusan dominate our cultural and historical preoccupations of recent years, it is the need for greater reticence and restraint in portraying the Essay “alien” life of others. This pervasive concern with reticence—with the need to listen to rather than to angela bega speak for the cultural experience of other peoples—has become a staple feature of such.
(The entire section is Dr. Segal's Essay, 8665 words.) SOURCE: “The Idea of Nature in Benito Cereno, ” in Studies in Short Fiction, Vol. Of The Of Women Summary? 30, No. 2, Spring, 1993, pp. 161-68. [ In the following essay, Martin discusses the Dr. Segal's allegorical qualities of nature depicted in with Electronic Prescription Systems Essay “Benito Cereno.” ] Although many critics have analyzed specific natural images in Melville's “Benito Cereno,” no one has yet focused exclusively on the role of nature in The Cookie FAD Diet the novella, nor looked fully at its problematic relation to Delano. Socialogy? Such an FAD Diet Essay, examination can both reveal much about Melville's artistry and enhance our understanding of the protagonist's special kind of self-delusion. Midway through the novella, Delano performs an act that is at. (The entire section is 3501 words.) SOURCE: “The Gaze of History in “Benito Cereno,’” in Studies in Short Fiction, Vol.
32, No. Reflective Examples? 2, Spring, 1995, pp. 171-83. [ In the following essay, Pahl explores the ways in which Melville's historical narrative in “Benito Cereno” represents “the illusion of Dr. Segal's The Cookie Essay, moral truth.” ] There is no document of civilization which is not at the same time a document of barbarism. —Walter Benjamin, “Theses on the Philosophy of History,” p. 256. Historiography is as much a product of the passion of forgetting as it is the product of the passion of remembering. (The entire section is 6000 words.) SOURCE: “‘The Creature of His Own Tasteful Hands’: Herman Melville's Benito Cereno and the ‘Empire of Might,’” in Modern Philology, Vol. Reflective Examples? 93, No. 4, May, 1996, pp. 445-67. [ In the following essay, Bartley analyzes “Benito Cereno” as a portrayal of inverted tyranny. ] But how is it with the American slave? … He is said to be happy; happy men can speak. But ask the Dr. Segal's The Cookie Essay slave what is his condition—what his state of mind—what he thinks of enslavement? and rumusan you had as well addressed your inquiries to the silent dead. The Cookie FAD Diet Essay? There comes no voice from the enslaved. We are left to gather his feelings by mary a vindication rights, imagining what ours would. (The entire section is 10493 words.) SOURCE: “At the Crossroads of the Nineteenth Century: ‘Benito Cereno’ and the Sublime,” in America's Modernisms: Revaluing the Canon, edited by Dr. Segal's Essay, Kathryne V. Of Sports? Lindberg and Joseph G. Kronick, Louisiana State University Press, 1996, pp.
77-100. FAD Diet Essay? [ In the following essay, Sussman interprets the sublime and ironic qualities of “Benito Cereno.” ] Still swept up in when human genome project began the whirlwind that emanates in the nineteenth century, twentieth-century readers share the predicament of Benjamin's Angelus Novus, 1 even on the threshold of Dr. Segal's The Cookie Essay, a millennial hyperspace in which the spatial barriers once separating social and cultural anomalies have been obliterated. The wind blowing. (The entire section is 10988 words.) Bloch, Bernard B. “Babo and Babeuf: Melville's ‘Benito Cereno.’” In Melville Society Extracts, No. 96 (March 1994): 9-12. Employs textual evidence related to naming and word play in “Benito Cereno” in of sports order to Dr. Segal's Essay argue that Melville presents an anti-slavery sentiment in the story. Eaton, Mark A. “‘Lost in Their Mazes’: Framing Facts and reflective journals Fictions in The Cookie Benito Cereno. ” In Journal of Narrative Technique 24, No. 3 (Fall 1994): 212-36. Argues that “Benito Cereno” disputes the authority of historical narratives, citing narrative framing techniques and the story's mediation between. (The entire section is 918 words.) Benito Cereno Homework Help Questions. The power of blackness is shown to be both a literal and symbolic element intrinsic to the themes in Benito Cereno. On its literal level, there is of sports, a power of blackness shown in how the slaves.
The purposes of Dr. Segal's The Cookie FAD Diet Essay, Herman Melville’s short novel Benito Cereno have been interpreted in contoh karangan a number of ways, including the Dr. Segal's The Cookie following: to expose the social, political, economic, and especially racial. Benito Cereno tells the of sports tale of Dr. Segal's The Cookie Essay, a Spanish slave ship. After a revolt, the slaves kill most of the Spaniards and plan to angela bega sail the ship to their freedom. Dr. Segal's FAD Diet? The true condition of the slaves on the ship. Ask a question.
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Look Both Ways Essays and Research Papers. LOOK BOTH WAYS - The film is an authentic personal and group portrait of how humans deal with personal tragedy, . Dr. Segal's The Cookie FAD Diet Essay? depression and loss - Depicts the daily life we all lead, where tragedy and crisis are just around the corner Characters: Nick - not yet in control with his medical diagnosis; hasn’t come to terms with his father’s death, therefore impossible to accept his own - describes his life with self-critical cynicism as a matter of “poverty, wars, natural. Acceptance , Death , Grief 759 Words | 4 Pages. Look Both Ways is an Optimistic Film. To what extent do you agree? Sarah Watt’s film, “ Look . Both Ways ” depicts the angela bega, initial inability of people to deal with grief but with understanding and communication its shows everybody is capable of dealing with pain. Presented when fear had taken control of the Essay, Western World as a result of the horrific terrorist attacks of contoh karangan, September 11th, 2001, Watt convinces the audience that there can still be optimism which leads happiness even when people are fearful. Death , Fear , Optimism 1405 Words | 4 Pages. “ Look both ways ” is a 2005 Australia independent film, written and directed by Sarah Watt. Moreover, the film won . The Cookie FAD Diet Essay? four AFI Awards. In the film, a train accident happened in examples Arnow Hill on a hot Australia weekend and the accident not only impacts the main character’s life but also relates each other.
Fear is one of the main themes in the film and it is obvious to show audiences that the protagonists in the hard circumstance who are coping with their real and imagine death. Firstly, the relationship. Antagonist , Character , Protagonist 952 Words | 3 Pages. “ Look Both ways ” unearths intrinsic human vulnerabilities. It follows the life journey of ordinary Australian . citizen’s, exposing a multitude of negative and Dr. Segal's The Cookie FAD Diet Essay positive human experiences. The first musical interlude, “Crashing- Gersey”, delves into the psychological and social dilemmas of each character. The melancholic yet sympathetic music renders the scene with a relative sensitive and intimate mood. Minimal dialogue and rumusan close range shots build on the concept of personal anguish and pain. All the. 2215 Words | 6 Pages.
connections with others. Essay? To what extent does Look Both ways depict human communication as problematic. In the of Health Electronic Systems, . film text Look Both Ways , problems in communicating with people are examined through many of the main characters, especially with Andy. In life, communicating with others can be difficult particularly when circumstances arise in which you do not know how to express your personal feelings or there are past experiences that hinder the way you view life. In Andy's character we are presented. Communication , Failure , Human 810 Words | 3 Pages. Look Both Ways, Animations and Photomontages.
The animations and Dr. Segal's photomontages mean that we learn more about Nick and Meryl than other characters in the film’ Discuss The hand painted animated . Care Electronic Prescription Systems? sequences in Look Both Ways have their origin in this film. They use the same signature ‘painterly’ style. The animated s sequences are a way of giving Nick and Meryl a visible internal life, rather than relying on the actors performances. FAD Diet? Its one that’s to each of them” to a painter and a photographer. This also proves that all the characters have. Apartment , Character , Cinematic techniques 1206 Words | 4 Pages. Death and Life in contoh karangan rumusan Sarah Watts's Look Both Ways.
?Year 11 ESL Examination Semester 2 Reading and Responding Sample Text Response Q 3. ‘ Look Both Ways affirms death . as part of life.’ Discuss Look Both Ways , a film by Sarah Watts examines death and life in a profound way where the characters have to The Cookie FAD Diet Essay, confront death and learn about socialogy of sports themselves. Dr. Segal's The Cookie? The film examines the notion of death as a universal theme that is with Systems Essay random and the consequences of death related issues which can be painful at times. Furthermore, the film also explores the notion of Dr. Segal's The Cookie FAD Diet, death. Anxiety , Cancer , Death 1964 Words | 4 Pages. … LOOK BOTH WAYS … “It doesn’t matter how life ends it matters how it was” How is this quote relevant to the . characters and why is it important? Sarah Watts “ Look Both Ways ” is of the rights a compelling story of the Dr. Segal's FAD Diet Essay, tragic lives of several Adelaide adults. It doesn’t how life ends it matters how you lived it and what you accomplished in the time given to angela bega, you.
Look Both Ways shows viewers the struggle Nick journeys through as he is told he has cancer, to Phil realizing he has missed his family growing. Brachytherapy , Cancer , Metastasis 741 Words | 2 Pages. technique is The Cookie FAD Diet critical to exploration of contoh karangan, character and theme in Look Both Ways . Discuss. Mixing of animation and . action slips clearly show what is going on inside the mind of characters. Meryl images train wreck, sharks attack, being run over by a car or even earthquake. Her thoughts are full of ways that she could die. The audients will realise that Meryl is The Cookie FAD Diet a person who thinks in a negative way all the time and never looks both ways . In Nick’s mind, there are horrible images all related to cancers. Cancer , English-language films , Film 650 Words | 2 Pages. “The fragmented structure of ‘ Look Both Ways ’ makes identification with the characters difficult. Do you agree?” . The independent Australian film, “ Look Both Ways ”, is unlike most “Hollywood” films. Socialogy Of Sports? Applying narrative techniques of the old film noir genre, this film is both unconventional and structurally unusual.
The protagonists, Meryl, Nick, and Andy, are all complex personalities, making it difficult for Dr. Segal's the audience to when did the human project, relate. Director, Sarah Watt, employs many visual forms to Dr. Segal's FAD Diet Essay, assist the audience. Audience , Audience theory , Film noir 638 Words | 2 Pages. Look both ways shows us that tragedy is a part of wollstonecraft a vindication of the rights of women summary, life. The Cookie FAD Diet? To what extent do you think this is true? The Australian . Socialogy? film “ Look both ways ” directed by Sarah watt explores many enduring aspects of the human situation and examines the changes that can potentially occur during the course of one’s daily life. The film treats a range of issue of practical, emotional and psychological as well as our different characters in changing life situations can impinge upon other characters both in a positive and The Cookie FAD Diet Essay negative.
American film actors , Cancer staging , Film 716 Words | 2 Pages. anxiety, suspicion and contoh karangan rumusan despair. These recurring, mental images cause both Meryl and Dr. Segal's FAD Diet Nick, to live life in fear of death. When Nick was . diagnosed with cancer, he immediately saw his life flashing past him in of the rights of women summary the form of FAD Diet Essay, a photomontage. Angela Bega? Watt uses these montages to FAD Diet, describe Nick's fear of death and that though he may seem in control on the outside, he is actually feels alone, confused and angela bega anxious that his life will end the same way his father's did.
His fear of cancer and his assumption that he won't. Anxiety , Anxiety disorder , Claustrophobia 677 Words | 2 Pages. Look Both Ways Essay About the Theme Fear. Fears can paralyse individuals by The Cookie Essay, making them feel anxious and paranoid with their lives and surroundings. They would be constantly worried about what’s . happening around them, which causes them to feel restless and did the human began isolated.
In ‘ Look Both Ways ’, Meryl experiences her fear with death after attending her Dad’s funeral and Dr. Segal's The Cookie FAD Diet Essay witnessed a man getting run over by a train. She realises that death can happen to reflective journals, anyone at unexpected times. She starts to The Cookie FAD Diet, perceive negative things and death happening to her. Socialogy? Her. Anxiety , Anxiety disorder , Emotion 710 Words | 2 Pages. Acad. English 1st hour 9-19-07 Word Count: 1208 A look in the mirror Take a long look in the . mirror… afraid of what’s seen?
Is the person in the mirror different from the one outside of it? Is the perception of the Dr. Segal's The Cookie Essay, identity not the one hoped for? Strength and approval comes from ones inner self. Without the of sports, approval of ones self a person cannot expect approval of Dr. Segal's FAD Diet, someone else. A long look in socialogy the mirror tells people who they are. People don’t understand what power that.
Metamorphoses , Ovid , Portrait of Dr. Segal's Essay, a Lady 1181 Words | 4 Pages. Look Both Ways by Sarah Watt's - 'We Must Learn to Accept Death in Order to Move on with Our Own Lives' Sarah Watt’s “ Look Both Ways ” shows us that death is socialogy a normal part of The Cookie, our lives, and if we are unable to accept it, . then it can hold us back from living our lives to its fullest. Using a variety of contoh karangan rumusan, filming techniques, Watts effectively displays and accentuates the pain and grief of her characters, especially Nick and Meryl who “have been seeing death everywhere”, in order to Dr. Segal's The Cookie Essay, demonstrate how fears of death can restrict our ability to live, in terms of anything from relationships and being social. Cancer , Cancer staging , Disease 1004 Words | 3 Pages. “The Way ” By: Ariana Grande Featuring Mac Miller American singer-songwriter and actress Ariana Grande featuring rapper Mac Miller recorded the . song “The Way ” and was released on March 26, 2013 by Republic Records and as the project, lead single from Dr. Segal's her album Daydreamin’.
This song was written by the Cost with Systems Essay, Mac Miller himself, Harmony Samuels, Jordin Sparks, All Sherrod Lambert, and Sevyn Streeter. “The Way ” is The Cookie FAD Diet Essay a pop genre song whose melody is directly from the Ramp;B 1998 hit “Still Not a Player,” originally recorded. Art music , Beat , Big Pun 1633 Words | 4 Pages. A Guilty or Innocent Way: a Look at Clytemnestra’s Actions. boastful expression about the killings. This action causes a great deal of rage in Clytemnestra.
One could very well understand why she would act this . way . Clytemnestra see’s the killing of her daughter as just being killed for her husband’s gain. She also feels that he could have chosen a different virgin to Cutting of Health Prescription Systems Essay, sacrifice. One the other hand, if one looks at Agamemnon’s problem they could be otherwise. Agamemnon was the general of his army and the leader that his men looked up to. The Cookie? So when the mary of the, profit came. Aeschylus , Agamemnon , Cassandra 1112 Words | 3 Pages. contradict this overall message.
One such aspect is the character Look , who serves a role both as comic relief and as commentary . on racist depictions of Native Americans. Dr. Segal's The Cookie FAD Diet? The Searchers does a superb job of highlighting the contorted representation of Indians in the Western genre, but Director John Ford’s comic portrayal of Look unwittingly reflects the prejudices and when genome stereotypes entrenched in American culture in Dr. Segal's The Cookie Essay the 1950s. Look , or “Wild Goose Flying Across the Night Sky,” appears in a brief flashback. Audience , Audience theory , Comedy 1384 Words | 4 Pages. A Double-Edged Sword Cuts Both Ways. Paige Ruby Mabry, Period 1 English IV 8 February 2013 A Double Edged Sword Cuts Both Ways The phrase “a doubled edged sword . cuts both ways ” means that something has both beneficial and reflective examples adverse outcomes. The comparison is made to The Cookie FAD Diet, a double-edged sword because it allowed the wielder of the sword to slash on the backswing without having to pivot the weapon in their hand, but it also allowed the wielder to cut themselves on the backswing. The actual origin of the phrase is unknown, but the earliest.
Edgar Allan Poe , Eternal Sunshine of the Spotless Mind , Julius Caesar 1359 Words | 4 Pages. The way , i am. it is the way . way way way . BBC News Typhoon Haiyan's death toll . rises in socialogy of sports Philippines CBS News - ?1 hour ago? Updated at 1:03 p.m. ET. FAD Diet? TACLOBAN, Philippines The central Philippine city of Tacloban was in ruins Saturday, a day after being ravaged by one of the strongest typhoons on record, as horrified residents spoke of storm surges as high as trees and authorities . Related Philippines » Red Cross Fears 1000 Deaths in reflective journals Philippine TyphoonNew York Times Why is. Autonomous Region in Muslim Mindanao , Filipino language , Leyte 1391 Words | 7 Pages. John Berger’s “ Ways of Seeing” John Berger’s “ Ways of Dr. Segal's Essay, Seeing” is rumusan an in Dr. Segal's Essay depth look on art, the way . people view it and the influences that traditional oil painting has had on society and modern day publicity. The beginning of the book goes into the issue of how people now look at art versus how people in the past look at art and how reproduction has effected this. The relationship between social status and the subjects of oil painting, particularly the female nude is discussed as well.
Berger turns. History of painting , Oil painting , Painting 1453 Words | 4 Pages. LOOK AT TEACUP The essay ‘ Look At A Teacup’, written by Patricia Hampel, shows how a simple writing helps in finding out great . events. It is about the history of writer’s mother in a delicate teacup. The two major themes of this essay are relationship between a mother and her daughter and of sports a connection between the FAD Diet Essay, past generation and present generation. Both these things are represented by a teacup. The writer’s mother was married in the year 1939, the karangan rumusan, beginning of the Second World War. The same. Cup , Essay , Family 1903 Words | 5 Pages. How Was Sarah Watt Explore the Ways People Deal with Their Personal Tragedies in 'Look Both Ways'
How does Sarah Watt explore the The Cookie FAD Diet Essay, ways people deal with their personal tragedies in Look Both Ways ? . Did The Genome? Discuss. In Look Both Ways , Sarah Watt explores a variety of Dr. Segal's The Cookie, emotions and experiences, focusing on the ways people deal with their personal misfortune. Including the death of mary wollstonecraft of the summary, loved ones, the fear of Dr. Segal's Essay, death, possible relationship breakdowns and the grief of feeling responsible for somebody’s death. Watt uses visual images; animations, flashbacks and when began periods of Dr. Segal's FAD Diet Essay, silence to angela bega, show the FAD Diet Essay, effects these issues. Aerosmith , Conductor , Emotion 795 Words | 2 Pages. Within both the angela bega, Aeneid and Illiad. Within both The Aeneid and Dr. Segal's The Cookie FAD Diet Essay Iliad, there is a strong urge to when began, present a world in which wars are glorious, the gods have a direct hand in human . events, and these deities influence fate. Through the Essay, representation of two similarly “blessed” protagonists, Achilles and Aeneas, the reader is able to view the ways in which these two cultural issues intertwine and attempt to create a picture of the ancient world which is at socialogy, once brutally real and filled with the magical and supernatural of the gods. Throughout. Aeneas , Apollo , Greek mythology 1355 Words | 3 Pages. Summary (Seminar on a Third Look at Jesus) The seminar last February 12, 2011 tackled about “A Third Look at Dr. Segal's Essay, Jesus” which was . discussed to us by the Cost with Prescription Systems, Mr.
Jimmy Cabag, an elementary public-school teacher in Escalante Central Elementary School, at the same time a servant in the Catholic Institution here in the city. The discussant told us that we need a third look . As we tread our spiritual path, it is imperative that we keep step with Jesus or rather we strive to heighten our bond with Him. Therefore. Bible , Christianity , God in Christianity 2432 Words | 6 Pages. Nowadays the way many people interact with each other has changed because of technology. In what ways has technology affected the . types of relationships people make? Has this become a positive or negative development? 1. In the 21st century, technology, the main driving force behind the productivity, has played a pivotal role in Dr. Segal's The Cookie Essay transforming the reflective examples, ways in which we interact. Thus, a spirited debate has risen whether technological development is a blessing or a curse to The Cookie FAD Diet, people's relationships. In. Facebook , Internet , Interpersonal relationship 776 Words | 3 Pages.
A Look at Abortion Abortion has always been a highly debated topic in America, as well as the rest of the world. Anyone faced with the reflective journals, . question of abortion has a very difficult decision to make, one that they could regret for the rest of FAD Diet Essay, their lives. Mary? Abortion has a long history, in which there has always been the arguments of those against abortion and Dr. Segal's FAD Diet Essay those who say it is the mothers choice. In todays society we simply refer to them as the pro-choice side and the pro-life side. When Did The Human Project Began? Abortion, throughout. Abortion , Abortion clinic , Abortion debate 936 Words | 3 Pages. youths look up to their parents as role mdel. ?“Youths look up to their parents as role models.” Do you agree? Nowadays, youths always look up to pop stars, famous . speakers or even their leaders in The Cookie FAD Diet Essay school as their role models. Therefore, do they still look up to their parents as role models?
In my opinion, I feel that youths nowadays do not look up to their parents as role models. This is a vindication of the rights summary because there is The Cookie FAD Diet a generation gap between the did the human project began, youths and their parents which result in the difference in The Cookie FAD Diet Essay mindset between the two parties. Not only wollstonecraft of the of women, that. Present , The Generation Gap , Time 932 Words | 3 Pages. Fear and Anxiety Are Endemic in Contemporary Society and Must Be Controlled and Harnessed for a Healthy Life. Is This a Central Idea in FAD Diet Look Both Ways? film Look Both Ways . It is found that fear and anxiety are dolefully present throughout society today which is . reasonably revealed in this film. Of Health Care Prescription Essay? Fear can lead to one taking steps to rid their lives of risk so that consequently one may live a wholesome, healthy existence.
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I chose this literature because it elucidates the backbone of marketing. 1969 , 1971 , 1972 1739 Words | 7 Pages. Look at the Way Shakespeare Explores Relationships Between Men and Women in Measure for Measure. Theme: Male/Female relationships and Dr. Segal's The Cookie FAD Diet the role of women * Look at the way Shakespeare explores relationships between men and . Socialogy Of Sports? women in FAD Diet Measure for Measure. Consider how the male characters treat the female characters and in particular, how Isabella reacts to Angelo’s proposition When Shakespeare wrote Measure for Measure in approximately 1604, society was very sexist towards females and men were seen as the stronger sex, however Shakespeare included lots of strong female characters in his plays. Adultery , Gender , Human sexual behavior 1385 Words | 4 Pages. Looking at Life in Different Ways. “At the end of angela bega, Look Both Ways , the film-maker convinces viewers that the The Cookie FAD Diet, characters are capable of looking at their . lives in different ways .” Do you agree? In the film Look Both Ways , director Sarah Watt explores the theme that perspective can determine experience in life.
The film demonstrates that life is an unscripted event where no one knows the final outcome and we can often become overwhelmed by how seemingly little control we exert over the navigation of when did the began, our lives By using main characters. Afterlife , Change , Death 1177 Words | 3 Pages. ? Man, Woman, Both ? August 11, 2013 Man, Woman, Both ? Every society has their thoughts on what . is normal, morally correct and even accepted when it comes to sexuality and gender. Throughout my research on these topics, I have often wondered if I understand what I am reading or writing. It was stated in the writings by Serena Nanda that “Because sex, gender, and Dr. Segal's FAD Diet Essay sexuality are at angela bega, the very core of the Western understanding of FAD Diet Essay, individual identity, it is not easy to dislodge. Gender , Gender identity , Gender role 1668 Words | 4 Pages. Last Look And At Castle Boterel Strong Memories.
?“Last Look ” and “At Castle Boterel” both have a similar theme present, strong memories. “Last Look ”, written by . Seamus Heaney appearing in his sixth collection of did the, poems in 1984, is both an elegy and Dr. Segal's Essay a eulogy as it has a mournful tone whilst also being in praise of contoh karangan, someone and commemorating their death. The Cookie FAD Diet Essay? In this poem, that person is examples Gallaher, who we can assume is an Dr. Segal's The Cookie Essay old friend that Heaney misses. The title of the poem is ambiguous, it could mean the last time he saw Gallaher or it could suggest that. Grammatical tense , Past tense , Poetry 1522 Words | 3 Pages. How Has Moral Studies Influenced the Way We Look at Our Lives. stems from understanding the reasons and the need for it. Without understanding, our intellect can only shape our thinking and not our desire to apply. . Morality and mary a vindication rights understanding are like a lever and a fulcrum as they can only function if they are both present. This combination of reason and morality is needed for conviction to The Cookie Essay, take place within oneself.
The basics of right, wrong, good and bad : Moral studies can also help us in solving moral conflicts in our daily lives. A moral conflict is. Culture , Good and evil , Human 1928 Words | 5 Pages. The Ways Jean Valjean Both Helps and Hinders Cosette in Les Miserables. The Ways Jean Valjean both Helps and Hinders Cosette in Les Miserables In the 19th century of France most of the children . were poor orphans because parents could not provide for their children. The Cost Of Health Care Electronic Prescription? Usually they would throw the boys on the streets but keep the girls because they could make profit off of them.
However, some orphans like Cosette as portrayed in Les Miserables found someone who would love and care for Essay them. Upon careful research this paper will show not only how Jean Valjean helped Cosette. 19th century , Fantine , France 1011 Words | 3 Pages. Explore the Ways Hamlet and angela bega Macbeth Both Shows Depression in Their Plays. Despair one of the key emotions that drive both the plots of Dr. Segal's The Cookie FAD Diet, ‘Hamlet’ and ‘Macbeth’.
Although the despair in Macbeth is represented by contoh rumusan, guilt . FAD Diet? and in ‘Hamlet’ it is by grief. Both emotions result in the tragic ends of characters such as Ophelia and Lady Macbeth. In ‘Macbeth’ Shakespeare repeatedly plays around with the rumusan, word ‘sleep’ in ways that are both hidden and obvious. In doing this, he leads the audience to think of sleep as something that soothes the mind and is a release from stress. Macbeth. Duncan I of Scotland , King Duncan , Macbeth 1612 Words | 4 Pages. this occur in Swann's Way ? How inadequate is the narrator's as well as the Essay, reader's first idea of the character of Swann? How does that work . for other characters like Francoise, Aunt Leonie and M. Did The Human Genome? Vinteuil? According to Proust, the act of Dr. Segal's Essay, “seeing someone we know” is Cutting with Prescription Systems Essay “an intellectual process”. It is only the “physical outline” we see, for Dr. Segal's The Cookie the complete picture of that person which our minds create is based primarily on the ideas we already had about him. So often the way we see a person, the qualities.
First-person narrative , Grammatical person , In Search of Lost Time 2614 Words | 7 Pages. much more prominent to go abroad to socialogy of sports, work for both parents. If we look at past times, we can see many families, which consisted of . Dr. Segal's The Cookie FAD Diet? a father who went out to work and a mother who stayed at home and looked after the children. However, it is much more different today and many families think that it is important for both parents to go out to Cutting of Health Care with Electronic, work. This circumstance can affect children both positively and negatively. Some people believe that children whose both parents go out to work have more access in. Children Act 1989 , Family , Father 1052 Words | 3 Pages. are presented for Dr. Segal's The Cookie Essay both the benefit of cheap amusements for mary wollstonecraft rights summary a woman s place in society and for the reinforcement of her place.
In one breath, . Peiss says that mixed-sex fun could be a source of autonomy and pleasure as well as a cause of [a woman s] continuing oppression. The following arguments will show that, based on Dr. Segal's The Cookie Essay, the events and when did the human genome project circumstances described in Cheap Amusements , the changes in the ways that leisure time is Dr. Segal's Essay spent by women has indeed benefited them in journals both the workplace and at. Female , Gender , Gender role 1836 Words | 5 Pages. ? A Look at On Killing By Sgt Jesse Boyer On Killing, by Lt Col Dave Grossman, is a book about what it takes for The Cookie a man to kill . another person or rather what it takes for him to learn to kill. In his book Lt Col Grossman breaks down the war fighter mindset why a man, or woman, is either able to or unable to take another human beings life. He breaks it down between the target and the firers and the non-firers, distance between the target and the killer, the mary wollstonecraft a vindication of women, mindset of the war fighter.
Army , Fighter aircraft , Human 3180 Words | 6 Pages. I Like a Look of Agony In the poem I like a look of Agony, by Emily Dickinson, one of the ways the poem's . Dr. Segal's The Cookie FAD Diet Essay? affects on the reader is reflective journals examples improved is Dr. Segal's FAD Diet though the use of angela bega, literary devices. People normally have trepidation of agony, but Dickinson uses literary devices such as imagery, personification, and connotation to reveal her contrasting enjoyment to the social norm. The opening line I like a look of Agony, (line 1) could be interpreted as sadistic and FAD Diet cold. Completely reading the poem allows. Emotion , Fiction , Irony 1625 Words | 5 Pages. Hiring for looks , gives you a boost Marshal Cohen, a senior industry analyst with the NPD Group, a market research firm believes retailers . that hire applicants based on Cutting of Health Care with Electronic Essay, their appearance is the smart thing to do and they see it as necessary. Dr. Segal's? This method is old.
Industries such as cocktail waitresses and Cutting the Cost of Health with Systems strippers have always used it. Dr. Segal's The Cookie Essay? But, many companies have taken this approach. A Vindication Of The Rights Of Women? Especially, retailers. Attractive employees attract customers, therefore they get bigger profits. Attractive people also. Abercrombie Fitch , American Apparel , Clothing 1017 Words | 3 Pages. “ Ways of Seeing” First Paper Assignment: Visual Analysis Essay by Dang Mai Trang September 2012 Buddhism is one of the FAD Diet, oldest and major . world religions with many different phases, numerous sects and when did the genome project began layers of art. Buddhism began in India around the 6th century BCE.
The oldest Buddhist religious monuments are believed to The Cookie FAD Diet, be stupas in India, which contain Buddha’s relics after his parinirvana. One of them is the mary of the summary, Bharhut stupa from the 1st century BCE. It contains various stories carved on Dr. Segal's FAD Diet Essay, large. Bodhi , Buddhahood , Buddhism 1453 Words | 5 Pages. John Berger’s “ Ways of Seeing” John Berger’s “ Ways of Seeing” examines points of view in art through an in-depth analysis of . artistic perspectives, how it is interpreted, and the impact of reproductions in today’s modern society. Berger’s explanation of reproductions and how art is reflective examples interpreted differently than in Dr. Segal's The Cookie FAD Diet Essay the past is valid because only the artist will know the true meaning of his work and be able to portray it effectively. Pictures are the best way to contoh, communicate a point. Some things. Art , Art critic , Flag of the United States 1184 Words | 3 Pages. Analysis Project of “A Look Behind the Veil” Thesis statement: Middle-Eastern and Dr. Segal's The Cookie FAD Diet Essay North African clothing culture is distinguished from other . cultures by the veil, a clothing that provokes many reactions from journals authors and debates between the Western and Eastern people. The Cookie FAD Diet? Subject: The main topic of this text is the veil in North African and Middle-Eastern regions.
Western people and Middle-Eastern people do not share the same opinion about journals examples its use, while the occidental region considers it as a. Arabic language , Asia , Central Asia 1486 Words | 4 Pages. Harbhajan Singh of Upper Sikkim Our travel writer planned to write about Sikkim as a destination but got diverted by The Cookie, an intriguing military-tourist to a . Sikh soldier’s shrine up by the India-China frontier. Contoh Karangan Rumusan? Harbhajan Singh's shrine, sacred to both Sikhs and soldiers. Crossing state borders in India does not tend to be very eventful, unless you are badly hassled at a checkpoint leading into some sensitive zone. The landscape is The Cookie usually the same, linguistic boundaries are not really clear until. East Sikkim , Gangtok , Indian Army 2995 Words | 7 Pages. critics in reflective journals one of his well-known book “ Way of seeing”. Berger intention by writing this book was to help people “start a process of The Cookie Essay, . questioning” on the way people see things in general through art; on when did the human genome, how what we learn, what our culture teaches us affect the Dr. Segal's, way we see images that surround us. Socialogy? Even though art and writing have some similarity, if one comes before another, it will alter the way they affect each other.
A painter is defined by people through their way of The Cookie FAD Diet Essay, looking at their art piece because. Art critic , Demon , God 2025 Words | 5 Pages. Geography has a significant impact on reflective journals, the way people communicate both verbally and nonverbally. ? CMS1000 Assignment 01: Essay Plan by Yari Wildheart Topic 2: Geography has a significant impact . on the way people communicate both verbally and nonverbally. . Historically, one of the most important institutions has been that of the nation-state. It is an institution that still dominates our culture and society and in today’s geopolitically globalised climate, it is often cause for intercultural miscommunication. It is this. Anthropology , Communication , Cross-cultural communication 1149 Words | 5 Pages. A Look at FAD Diet, Neo-Paganism Through Ethnography. cults in America and focus upon Cutting of Health Systems what it reveals about Dr. Segal's The Cookie Essay identity and Cutting the Cost Electronic Prescription belief in 21st century America. Through her careful employment of ethnographic techniques, . Magliocco allows both the Dr. Segal's The Cookie FAD Diet Essay, Neo-Pagan cult to be represented accurately, and likewise, scientifically.
I argue that Magliocco's ethnographic approach is the genome project began, correct way to go about this type of research involving religions. Dr. Segal's The Cookie FAD Diet Essay? Magliocco defines Neo-Paganism as others have before her as a movement of new religions that attempt to revive, revitalize. Anthropology , Cult , Cultural anthropology 1851 Words | 6 Pages. Evaluate the angela bega, Way Language Perception Helps or Hinders Knowledge Acquisition in Biology. Evaluate the way language amp; perception helps or hinders knowledge acquisition in Dr. Segal's The Cookie FAD Diet biology In this area of Cutting of Health Care Prescription Essay, knowledge – biology – language . is an important tool that helps us understand the concepts of Dr. Segal's The Cookie FAD Diet Essay, biological processes.
As there are many terminologies in of sports biology; language is the only tool that can translate the terminology into The Cookie FAD Diet, terms that are comprehensible in our language. Language also allows each of angela bega, us to communicate with each other. Perception is also an FAD Diet important way of knowing since. DNA , Endoplasmic reticulum , Eukaryote 950 Words | 3 Pages. the market then they have to realize that they are not the reflective journals, only one out there trying to win success. Nutella is a product that has various competitors, but . Dr. Segal's The Cookie Essay? one major competitor they face is another popular breakfast spread, Kraft’s Peanut Butter. One way they can precisely measure their competition with Kraft’s Peanut Butter is through a competitive analysis. A competitive analysis allows a company to know if their product has a competitive advantage over Cutting of Health Care with Prescription Systems, its competitors, furthermore, it gives them. Breakfast cereal , Butter , Competition 1267 Words | 4 Pages.
Look At Me Now informal logic March 19, 2012 Look At Me Now Being a young African-American woman stereotyping has always . been a part of Dr. Segal's FAD Diet, my life and I have to come to a conclusion that it will always be a part of it. Stereotype is defined as to characterize or regard as a stereotype; to give a form to. It has not been as bad as in the 1900’s; but it has affected my life and the way that I look at certain situations. Because of where I grew up, my uncommon as well as my appearance; I encounter. Counterstereotype , Minority group , Prejudice 1111 Words | 3 Pages.
What Is the Best Way of Explaining Football Hooliganism? What is the best way of explaining football hooliganism? “Serious sport has nothing to do with fair play. It is bound up with hatred, . jealousy, boastfulness, disregard of all rules and sadistic pleasure in witnessing violence. In other words: it is war minus the shooting. (Oswell, 1945) The best way to karangan rumusan, explain football hooliganism is to perceive it in the same context as war. Like war, football hooliganism has different factors that all contribute to the overall goal. Although the. Football hooliganism , Hooliganism , ID 2439 Words | 7 Pages. also present in antiquity, Langmuir attempts to prove disconnect between Norwich and those prior myths. He also goes into detail about William’s murder, then . Monmouth’s investigation and writings. The Cookie FAD Diet Essay? He convincingly argues that Monmouth had allot to gain both in this world and the next by reporting William’s killing as a ritual murder preformed by Jews. Of Health Care Prescription Essay? Simply stated, Monmouth saw what he wanted to while investigating the The Cookie Essay, crime.
Langmuir uses a broad range of angela bega, sources in his attempt to prove that the accusation. Antisemitism , Homicide , Jews 1289 Words | 3 Pages. or personal regard. Your own ideas or beliefs about what a friend really is likely include much more information, but this basic definition can present . you with a good starting point in forming your own. 5. 5 Research the Dr. Segal's The Cookie Essay, word's origins. Human Project Began? Look up your chosen word in the Oxford English Dictionary or in another etymology dictionary. * These sources can tell you the history behind a word, which can provide further insight on a general definition as well as information about how a. Definition , Definitionism , Dictionary 1323 Words | 5 Pages. Non Violence and Way It Is Morally Right. Ethics Soto Final Writing Assignment 05/06/2013 “Non-Violence” and Dr. Segal's The Cookie Essay its Powerful Statement on Rights and Morality The statue looks like . the final chapter in a Warner Brothers cartoon; Bugs Bunny has finally gotten the contoh karangan, best of Elmer Fudd. The Cookie Essay? Instead of destroying the contoh, gun with a finger down the Dr. Segal's, barrel, resulting in journals examples a face full of soot for FAD Diet Essay the violent hunter, it looks like the famous rabbit decided to gift wrap the weapon. The bullet would likely end up shooting towards the air, hitting a branch.
Civil and angela bega political rights , Firearm , Human rights 1424 Words | 4 Pages. ?Characters of Way Back Home Joanna- Kathryn Bernardo Jessica – Julia Montes Michael- Enrique Gil Aj- Sam Concepcion Ariel- Tonton gutierez . Amy- Agot isidro Lerma- Lotlot Isidro Cinematography- Julius Palomo Directed By: Jerry lopez sineneng Plot One of the The Cookie, big dramatic moments of Way Back Home has one of the the Cost Care with Electronic, main characters yelling at The Cookie, her sister for did the genome began having the gall to wash her hedgehog plushie. Dr. Segal's The Cookie FAD Diet? She freaks out to an extent that just doesn’t seem comprehensible anymore. And that’s largely the problem. Agot Isidro , Audience , Audience theory 728 Words | 3 Pages.
Eating the Ayurvedic Way Eating is something we all know how to do and it is a hot topic today with Michelle Obama’s directive to promote . healthy eating and reduce the rate of obesity in this country. Ayurveda is a word that many people cannot even pronounce, but it holds guidance and mary a vindication rights summary benefit for healthy eating. By way of Essay, introduction, Ayurveda is an ancient system of reflective, medicine that offers health on both the body and spirit level. The underlying theory behind Ayurveda is the power of healing from. Digestion , Eating , Food 1023 Words | 3 Pages. Unexpected Killers: a Look Into Parricide. UNEXPECTED KILLERS: A LOOK INTO PARRICIDE 1 Unexpected Killers: A Look Into Parricide EN 101: English Composition . Miller-Motte Online Stacey Reid UNEXPECTED KILLERS: A LOOK INTO PARRICIDE 2 Several nights ago, my eight year old daughter and I were lying on Dr. Segal's FAD Diet Essay, the sofa together watching a movie.
I remember stroking her hair as she fell asleep and of the rights thinking, as I often do, how much I love her. If you are a parent, then you know exactly the kind of moment I am describing: the moments where.
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Try using the ‘Freeman’ template. Best of luck on the promotion! Hi! What resume template would you recommend for a college freshman trying to apply for a competitive summer program with the USDA and South Dakota State University? Sound like the ‘Entry-Level’ template would be a good fit for what you’re trying to do. Good luck with the summer program. Hi! Which resume template would you recommend for someone trying to tap into socialogy the finance and accounting market.
Looking for an entry-level position. You should go with the The Cookie FAD Diet Essay ‘Entry-Level’ template. Good luck with the job hunt. I have worked 32+ years as a nurse, the angela bega last 4 years taking care of my elderly father and online work. Now seeking to get back into the job market for extra income, not necessarily in the health field, just to FAD Diet, earn some income and socialize. Angela Bega? What resume do you suggest? Try the Dr. Segal's The Cookie Essay ‘Job Hopper’ template. Angela Bega? Good luck with your job search!
Hi! What resume template would you recommend for The Cookie FAD Diet, a 9th grader trying to apply for a doctor (any)?? Apparently, resume making and interviewing is our project for the fourth quarter this year. I couldn’t find any clear examples on the web, and I was hoping you could help me out with what template I should use.. Try using the ‘Elegant 2.0’ template. Angela Bega? Good luck on your project. Yes, if you click the Dr. Segal's The Cookie View all Resume Designs button and click the download link for the template pack of your choice. If you’ve never written a resume before, I’d recommend checking out our “How to Write a Resume” guide to get a clearer idea (it’s much more comprehensive than any answer I can give here). https://resumegenius.com/how-to-write-a-resume. Hit us up with any follow-up questions after giving that a read we’ll see if we can help further! Good luck! Hey there Margaret,
In order to best understand which template works, it’s a good idea to check out which resume format fits your particular needs; then you can take it from socialogy of sports, there. https://resumegenius.com/resume-formats. All of the templates were created by Dr. Segal's, professional resume writers, so it’s hard to go wrong with any of them — it just depends on your preference. Good luck! It really depends on Care with Prescription Systems what job you’re applying for. Since you have substantial work experience, try quantifying that in your resume (think: any numbers that a hiring manager can look at and better understand what you accomplished during your time working there). Check out this page and choose the one you find most fitting, that should be a good start: https://resumegenius.com/resume-formats. Good luck on The Cookie Essay the job hunt! Hey there hbil036, This way, you can focus on your skills qualifications critical to the job application.
As an aside, you may want to look into whether you’re qualified to get back into accounting after that many years outside of the wollstonecraft a vindication of the rights field. I understand that some regulations and rules change over the years — it may just be a matter of taking a test or updating your certifications, but I’m not certain. If that doesn’t seem to be a problem then go with the functional resume for sure. The Cookie? Good luck on the job hunt! If you are lacking in major experience, I’d recommend using a reverse chronological format for your resume.
Our “Classic” template on this page should do the of Health Care Electronic Systems trick: https://resumegenius.com/resume-templates/ Good luck at the job fair! I recommend you first check out our internship resume sample page: https://resumegenius.com/resume-samples/internship-resume-example. Afterwards, feel free to choose any format – just use a comprehensive education section instead of a professional experience section, and you should be good. Good luck landing that internship! Share Free Downloadable Resume Templates Our code geeks and HR experts are proud to introduce our new Free Resume Builder software to help you land more interviews in Dr. Segal's The Cookie FAD Diet Essay, today’s competitive job market. We provide HR-approved resume templates, built-in job description bullet point phrases to choose from, and easy export to MS Word and PDF.
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7 Best Free Business Plan Templates. Didn#039;t go to business school? No Problem. Download a free business plan template and customize it to your needs. SCORE, a nonprofit association that helps foster startups by providing mentorship and planning tools, says that the value of Dr. Segal's FAD Diet Essay, completing a business plan is not the the Cost of Health with Electronic Systems Essay, finished product, but rather the process. The act of planning helps you to The Cookie FAD Diet Essay, think things through thoroughly, study and mary wollstonecraft summary research if you are not sure of the facts, and The Cookie FAD Diet Essay look at your ideas critically. It takes time now, but avoids costly, perhaps disastrous, mistakes later, the introduction to SCORE's business template says. Having a clear picture about the purpose of your business, its goals, and how it will operate is critical not only for your understanding of these issues, but more importantly to get potential lenders and investors to buy in. Thankfully, you don't have to go to business school—or hire someone who did—to create a business plan. You can download a free business plan template and customize it to your needs. Where to Find Free Business Plan Templates.
The nonprofit business mentorship program offers free templates for both startup and angela bega established businesses, as well as planning tools for nonprofits. Dr. Segal's The Cookie Essay? Their startup business plan is socialogy of sports made up of a narrative along with financial worksheets. The template includes over 150 questions to establish the body of your business plan and can be answered in any order. The executive summary, however, should be completed last. The goal of this completed template is to provide you with a fluid narrative. This site offers a free, basic template to download. The BPlan free template offers an organized guideline to creating your business plan and takes you though the steps to get your business plan investor-ready and SBA-approved. If that's not in-depth enough for you, then you can buy their Business Plan Pro software or use LivePlan, an Dr. Segal's The Cookie, online business plan creator with built-in formulas for financial planning, videos from experts and the opportunity to Care Electronic Systems, collaborate with colleagues. Editor's Note: Looking for a business plan template or services for Dr. Segal's The Cookie Essay your business? If you're looking for information to help you choose the of sports, one that's right for you, use the Dr. Segal's The Cookie, questionnaire below to have our sister site, BuyerZone, provide you with information from a variety of vendors for mary wollstonecraft a vindication of women summary free: The Microsoft Office site offers a gallery of templates, including business plan checklists, financials, presentations and The Cookie marketing.
These templates are useful if you want a specific template, rather than a general business plan. Reflective Journals Examples? In addition, there is a PPT for business presentations for when you are ready to showcase your business to potential investors. The Cookie FAD Diet? Offers a comprehensive Word-based document that contains a detailed framework for building your business plan, including sample text, tables and charts, as well as a manual with section-by-section assistance. Free-Plan is ideal for new and established businesses looking to expand and in need of a business plan for journals internal or external use. Their micro-plan is FAD Diet designed for startups and very small businesses. This site allows you to fill out human a template online, with instructions on what to include in Dr. Segal's The Cookie Essay, each section. When Human Began? Next to each category, tips and Dr. Segal's FAD Diet examples are provided as an additional resource. Of Sports? After completing the template, you can generate your business plan and save it to your computer as a Word document.
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Make it enthusiastic, professional, complete and concise, advises SCORE. If a section of the template doesn't apply to your business, don't worry about filling it out. When Did The Genome Began? If you're having trouble filling out your template or have questions about Dr. Segal's, creating a business plan, SCORE has mentors that can give you free advice in person or via e-mail. Or, look for feedback and advice from groups like the Small Business Network on Cutting the Cost Care with Electronic Prescription Essay, LinkedIn. As evidenced above, there are plenty of options for free business templates, so don't feel like you need to The Cookie FAD Diet, pay for one, unless you can't find a template that thoroughly addresses your needs. Software like Business Plan Pro or Plan Write Business Planner can provide you with further customization and assistance. In addition to completing a business plan checklist, look for a due diligence checklist from potential lenders or investors to make sure you have a better understanding of the of sports, types of information they need. Many sites, including Bplans.com, Entrepreneuer.com and toolkit.com, offer free samples of business plans categorized by the type of company for you study before starting your own. According to the U.S. The Cookie Essay? Small Business Administration, a good business plan is a living document that should be reviewed and updated regularly.
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Can the Chain of Causation ever be broken in cases of Manslaughter? The simple maxim that the accused in a criminal proceeding ought to The Cookie FAD Diet Essay have caused the crime is one of the potentially most important doctrines in law. It has a direct bearing on the entire scope of the criminal law and speaks fundamentally to how we view our society. The proximity between cause and effect that we consider to bring rise to a positive moral duty of care , when we refer to when did the the imposition of punitive sanctions on members of Essay society, is one of the most important tests of criminality. Those areas in the penumbrary cause the most difficulty for judges, academics and society in generally. Therefore the when did the human prosecution of drug dealers for Dr. Segal's The Cookie Essay, the death of those they supply , doctors who were negligent and contribute to the death of their patients , Reckless transmission of HIV / Aids to sexual partners or the denial of karangan access to life-saving treatment are all areas where the person being accused of the Dr. Segal's FAD Diet Essay crime may or may not be considered to have ‘caused’ the harm. Reflective Journals! The quotation above by Seneca represents one of the key difficulties in establishing a chain of causation from the accused to the victim of any crime. In English law omission to act cannot be considered the cause of The Cookie FAD Diet Essay a crime because there is not the causal link; however there is an undoubted argument that someone who refuses to help upon seeing a crime is encouraging that action. The main focus of the work is whether, if ever, the chain of causation can be broken in cases of manslaughter , this attribute alone would be sufficient to make it generic.
The work starts with a section on the general principle of causation in criminal law. We will then move onto have an in depth discussion and analysis concerning the journals examples case law on Dr. Segal's, the issue before finally using the other jurisdictions and areas of law to compare to the application of the test in manslaughter. Of Sports! This is an incredibly vast subject matter and the restriction to consideration of manslaughter is hoped to give the essay more poignancy and give a more holistic understanding to the operation of Dr. Segal's The Cookie Essay causation from which we maybe able to extrapolate general principles about causation. The main focus will be on the drug supply cases and their impact on the principles of causation . Causation is an extremely important part of the socialogy of sports Actus Reus in result crimes. The failure of the Dr. Segal's The Cookie Essay prosecutor to establish causation is disastrous to a case because ‘if the angela bega death, damage or destruction occurred because of some other cause then the offence has not been committed even though all the other elements of the actus reus are present and The Cookie the accused had the necessary mens rea’ However, it is far from a simplistic concept of deciding that the action caused the result. The concept of causation represents a nexus between fact and law, they are at certain points clearly distinguishable and at others not. This work cannot possibly hope to do justice to the complexity and history of the concept of causation however the aim is to give a general overview of the concept so that we have a working understanding when we go onto consider the case law on manslaughter . The first principle that the law requires of the facts is that an act will only be considered the cause of an event if it is a ‘causa sine qua non’ . In other words this is a test that requires the karangan rumusan cause to be material; ‘it must be established that the consequence would not have occurred as and when it did not ‘but for’ the accused’s conduct’ . Essay! This principle is consequently referred to as the ‘but for’ or ‘sine qua non’ test.
The natural justice of Care with Prescription this principle is clear but it is not simple necessarily to apply. At a conceptual level there is difficulty with the fact that the decision-maker has to decide between the ‘infinite number of prior conditions of which it is true that if it had not occurred some given event would not have occurred’ . This can be a tricky situation especially if we consider the The Cookie FAD Diet Essay penumbrary examples mentioned in the introduction. The death of somebody from a drugs overdose has numerous prior conditions but the two obviously competing ones would be the supply of drugs by a dealer and the voluntary act of the mary wollstonecraft a vindication of the deceased to take the drugs, they are both events but for which the person would not be dead. The choice of these prior conditions as a ‘cause’ of the death is artificial, in reality both and many more are the cause including the friends the person made, family life, wealth, mental health and attitude to risk-taking. This is why the Dr. Segal's The Cookie FAD Diet sine qua non test is contoh karangan rumusan, considered to be the purely factual element of causation because once a decision-maker goes beyond these considerations they begin to make legal and policy judgements about Dr. Segal's The Cookie Essay, which causes merit moral opprobrium. Reflective Examples! Hart Honore commented on this duality within causation: ‘These two aspects of causation, even if they cannot be crudely opposed as ‘factual’ and ‘non-factual’, are of Dr. Segal's Essay very different character.
They occasion different kinds of doubts and difficulties, and different kinds of criteria are used in socialogy their resolution’ The classic example of the application of the sine qua non test is FAD Diet Essay, R v. White where a man had put cyanide in his mother’s drink, when his mother’s corpse was found the glass had not been fully drunk; evidence proved that she had died of a heart attack. The accused was acquitted of murder because his mother’s death was not contingent upon the cyanide drink and socialogy of sports would have occurred in any case. The sine qua non test is conceptually and legally restricted so as to The Cookie Essay make it practical and equitable and it is these concerns that we need to turn our attention towards. In understanding the angela bega various impinging concerns we need to have a deeper understanding of cause and effect as it is understood in the legal sense. The cause of something has to be ‘sufficient to bring about the consequences in conjunction with other ‘mere conditions’’ and furthermore a cause ought to be necessary.
However the ‘condition sine qua non’ doesn’t always embody these ideals and we can start to get into difficulty quickly if we do not pay attention to Dr. Segal's The Cookie Essay the fact that there are many situations where the test is satisfied but ‘the connection between X and Y has nothing to do with any form of causal connection even in the broadest sense of causal’ . The obvious example given by Hart Honore is that it is analytically true to Cutting the Cost of Health with Electronic Prescription Systems Essay state that a person would not be a widow if they had not been married but there is no factual connection between the marriage and her status as a widow. There is furthermore an intuitive distinction which we must be careful of distinguishing between facts which are causally related to the outcome and Dr. Segal's The Cookie FAD Diet those which only serve to individuate the particular act in question. This will become even more important when we begin to socialogy of sports consider cases of Dr. Segal's The Cookie Essay manslaughter which make a distinction between harm caused by an illegal act and those caused by a legal act. There is a tendency in dealing with causation issues here to blur the issues and argue that there must be a causal link between the wrongful act and the harm caused but in a situation where a person who is driving without a licence hits someone and injures them the fact of not holding a licence is when did the human genome project, merely incidental to the harm caused. One final conceptual issue to remember is that most writers present the sine qua non test as the sole factual issue of Dr. Segal's FAD Diet Essay causation, this doctrine is however not the contoh rumusan only factual doctrine and there are allowances for The Cookie FAD Diet Essay, other approaches.
The inherent vagueness of the sine qua non test means that there will be situations where the journals rule will not give a nice neat factual answer. It is perhaps correct therefore to endorse the approach that Ormerod has outlined and state that ‘The ‘but for’ principle is a starting point in the causation inquiry, but nothing more’ . As I mentioned above the duality of causation requires us to Dr. Segal's give consideration to the more complex and inherently more difficult legal side of causation. The first legal causation issue is that of culpability. The case of R v. Dalloway is the landmark case on this issue where it was established that if the culpable behaviour of the accused in no way contributed to contoh the result then the chain of causation would be broken. In that case a child was killed when he ran in front of a cart being driven by D, it so happened that the driver had not been holding onto the reins. The accused was acquitted on the basis that even had the driver been holding the reins he wouldn’t have had time to stop, thus the negligent act had not legally caused the death of the child.
In other words the causal link between an action and its consequence will not be assumed simply because there was a negligent act. The culpable act must have a degree of substantiality as a cause of death, the determination of this is for the judiciary and it certainly seems to be construed narrowly as was stated by FAD Diet Essay, Goff LJ in reflective journals examples R v. Pagett ‘the accused’s act need not be the Dr. Segal's FAD Diet sole cause, or even the main, of the victim’s death, it being enough that his act contributed significantly to that result’. The distinction between a minimal contribution and a significant contribution has no technical meaning and in socialogy most violent criminal cases it will be what the ‘twelve men and women sitting as a jury in the jury box would regard in Dr. Segal's The Cookie FAD Diet a common-sense way as the cause’ . In Adams, where Devlin J stated that approach, he was discussing the issue in relation to a doctor administering his terminally ill patient with pain relieving drugs. This illustrates the distinction between a minimal and major contribution very well. If the administration of drugs was considered part of a doctors duty which had the incidental effect of shortening life then this was not murder however if it was considered to be an angela bega intentional attempt to end the life of the patient then it was a substantially intervening fact so as to be considered the cause of death.
Related to this distinction is the clear line of cases which has established that the negligence of The Cookie Essay third parties doesn’t necessarily abrogate or dilute the liability of the accused. This flows naturally from the Pagett dicta that the accused’s act need not be the sole cause of any particular harm. In R v. Benge there was evidence that there was negligence over and above the accused’s which had contributed to journals a train accident. In that case Pigott B had directed the jury that ‘if D’s conduct mainly or substantially caused the accident it mattered not that it might have been avoided if the others had not been negligent’ . The flipside of this approach is what is known as the Novus Actus Interveniens doctrine which is where the act of Dr. Segal's The Cookie FAD Diet a third party is ‘significant enough to acquire causative potency for itself’ . Cutting Of Health With Prescription Essay! The border between the intervention of third parties being significant or not is Dr. Segal's FAD Diet Essay, sometimes incredibly difficult to demarcate to any great extent but the effect of an intervening act is to break the chain of causation. The easiest to identify as a novus actus interveniens is an ‘Act of God’ which is when did the project began, understood to have to be something occurring in nature which is random and unpredictable. There are various hypothetical situations given in the literature but the distinction seems clear; if the natural event is Dr. Segal's, foreseeable then it will not be considered to be an act of god: ‘the phrase is usually used in context of very extreme climatic conditions, it can also be used to of Health Care with Systems Essay cover the equally unpredictable and unforeseeable operation of The Cookie animate forces, such as the rate which gnawed a hole in when did the human genome began the cistern in Carstairs v Taylor (1870) LR 6 Ex 217’ The examples given in the literature show this distinction for example, if a man is assaulted and knocked unconscious then the situation can make a big difference. It is foreseeable that if it were on a beach then it is reasonably foreseeable he may die with high tide. The Cookie Essay! However if it were in a building it is not reasonably foreseeable that an earthquake might occur causing the building to collapse and kill the person in question.
Aside from these situations it becomes more difficult to identify a novus actus interveniens when they are in when did the project began the form of a third party. Goff LJ cited Hart Honore in Pagett when they stated ‘The criterion which they [Hart Honore] suggest should be applied in such circumstances is whether the intervention is voluntary, i.e. whether it is free, deliberate and informed’. The court felt that this was the correct approach to be taken to the situation. This automatically rules out innocent agents being forced by third parties, involuntary actions caused by Dr. Segal's The Cookie FAD Diet Essay, a shock and acts done by ‘a police officer in the execution of his duty acts to prevent a crime, or to apprehend a person suspected of a crime’ . All of the above do not break the chain of causation, thus it is only in the very narrow category of a novus actus which is ‘free, deliberate and human project began informed’. The cases on this issue cover a very wide area and discussion of the issues raised in those cases could form a piece of work on their own right. However a brief outline of the issues raised is necessary; this work is primarily concerned with whether the chain of causation can ever be broken in cases of manslaughter. An understanding of this issue is fundamental for a comparative approach. I will talk briefly about the various categories that have considered the Dr. Segal's intervention of third parties: • Negligent Medical Treatment. The issue of negligent medical treatment is one that has occupied the courts attention on journals, a number of The Cookie Essay occasions.
There are ancient authorities such as James Williamson where it was stated that ‘unskilful and unjudicious treatement’ of a ‘simple and early cured wound’ . This was followed in modern times in the seminal case of R v. Jordan where a doctor’s negligence was held as sufficient grounds for the overturning of a conviction. The problem is that the court specifically declined to make any comment about how this decision was grounded in principles of Cutting the Cost of Health with Electronic causation. Dr. Segal's! Furthermore in the case of karangan rumusan R v. Smith negligent medical treatment wasn’t held as a novus actus interveniens. The distinction between the authorities is ambiguous . The most recent authority on the issue is the case of R v. Cheshire where the court seems to Dr. Segal's The Cookie Essay have significantly narrowed the operation of this doctrine, here the reflective examples deceased was shot in the leg and suffered ensuing respiratory problems. This required a tracheotomy to be performed. The death occurred because of complications with the Dr. Segal's The Cookie tracheotomy due to medical negligence, this occurred some 2 months after the karangan shooting.
The court held that the gunshot was the cause of death and thus the accused was convicted. The rationale of the court was based on the fact that only the most extraordinary and unusual case would suffice and they argued ‘treatment which falls short of the standard expected of the competent medical practitioner is unfortunately only too frequent in human experience for it to be considered abnormal’ . This is more in line with the authorities such as R v. Holland and Flynn where the refusal of a patient to Dr. Segal's FAD Diet Essay receive treatment that exacerbates a minor injury will not constitute a novus actus interveniens. • Thin Skull Rule. It is clear from the authorities that where the human genome project victim has some pre-existent condition then this will not excuse the accused: ‘It would never do for it to go forth from this court that house-breakers or robbersshould be entitled to lay violent hands on very old or very sick or very young people, and, if their victim died as a result, to turn around and say that they would never have died if they had not been very weak or very old’ This is a fundamental rule and obviously will not count as a novus actus. The previous two categories are examples of Dr. Segal's Essay when the law has held that third parties do not intervene on the chain of causation. Mary A Vindication Rights Summary! This is indicative of an Essay extremely strict approach to issues of causation, they do not allow potentially large supervening factors to get in when genome began the away and if you were cynical then it would be tempting to state that consequences simply cannot be too remote from the The Cookie Essay culpable act. Only in a situation such as R v. White can the chain really be broken and those situations have got to be truly extraordinary. Current Case Law on Manslaughter Chain of Causation. We now turn to consider the specific subject matter of this work which is the mary wollstonecraft a vindication chain of causation as it is applied in cases of manslaughter.
The major issue in this section will be focused on the penumbrary issues of The Cookie manslaughter. Undoubtedly in core cases the principles of causation sit nicely with the facts. The major issue of interest are areas such as prosecution of drug suppliers where the mary wollstonecraft a vindication principles of causation are stretched to their limit and open to no small amount of criticism. The first issue is just to briefly recap what exactly the crime of manslaughter is and how it is distinct from FAD Diet murder. The nature of the crime can often have effect on the way principles of causation are applied.
Manslaughter is an offence which covers a vast area only a vindication rights of women ‘limited in scopeby murder at Dr. Segal's The Cookie FAD Diet one extreme and accidental killings at the other’ . There are two forms of manslaughter; voluntary and involuntary, in the latter the person has the mens rea for murder but there is some mitigating circumstances which reduce the crime to manslaughter. Voluntary manslaughter was put into statutory form by the Homicide Act 1957 and socialogy now only occurs in Dr. Segal's FAD Diet Essay three defined situations: provocation, diminished responsibility and wollstonecraft a vindication rights summary a suicide pact. Involuntary manslaughter covers a vast area such as negligence, recklessness and unlawful or dangerous acts. This means that the scope of the crime is far from The Cookie FAD Diet Essay distinct; issues of causation are thus inevitably raised in angela bega cases of Dr. Segal's The Cookie FAD Diet Essay involuntary manslaughter where the thing that caused death may have a remote link to the accused in the particular case. The linking of a criminal act to death can be fraught with difficulty as can the difficulty of intervening acts. It is wollstonecraft of the rights summary, clear that the chain of causation can theoretically be broken in manslaughter, both the authorities and the case law agree on this issue. However, there have been a series of FAD Diet cases over the 30 years regarding manslaughter which seem to imply that the angela bega chain of causation may not be able to be broken even by the voluntary intervention of third parties; the chain of causation may not be possible to break. In Cato the accused was charged with the manslaughter of a man called Kennedy. The facts were that Kennedy had brought the drugs with him to a house, him and Cato had paired off and taken turn to inject each other with heroin throughout the night.
Kennedy was found to Dr. Segal's FAD Diet Essay have died the next morning as a result of the overdose. One of the other important factors was that each party had made up the syringe with the requisite mix of heroin and water themselves and thus the partner was merely injecting the drugs. The accused was convicted of manslaughter by an unlawful and dangerous act which requires proof of the when did the human genome basic act which was criminal. In this case it was held that heroin was a ‘noxious thing’ as understood under s.23 of the Offences Against the Person Act 1861 and that this base crime was sufficient to establish manslaughter. In the case there were a number of issues that revolved around causation and the interplay between legal and factual causation was nowhere better illustrated. In this case causation in the strictest sense was not really an Essay issue. There was an attempted argument on karangan rumusan, appeal that it had not been proved satisfactorily that it was heroin that had caused death but on the evidence this was rejected. The really interesting issues were sidestepped in this case because per se under the The Cookie Misuse of Drugs Act 1971 the actions of Cato was an offence. When Genome! The dubious judicial chicanery of using s.23 of the Offences Against the Person Act 1861 aside the question sidestepped the issue of Dr. Segal's whether consent would have broken the chain of causation in Cutting of Health Electronic Prescription a charge of manslaughter by gross negligence or recklessness, Lord Widgery in FAD Diet Cato specifically stated that the argument was not pertinent, he went as far as to say that they would have used unlawful possession as a substitute to s.23. This is obviously damaging to principles of causation in that actual possession cannot be considered to have caused the death, it would be one of these incidental factors that we have discussed in when did the human began the previous section . Furthermore the case law under the Misuse of Drugs Act 1971 precludes any alternative such as supply of drugs interpretation: R v. Maginnis and R v. Harris , both on similar factual circumstances to Dr. Segal's The Cookie FAD Diet Essay Cato, found that it would be a farcical situation that where a person was merely insisting with the injection that it couldn’t be considered supply. It would seem to make sense, given the Pagett test of a ‘free, deliberate and rights informed’, that the consent of the person would constitute a novus actus to Dr. Segal's The Cookie Essay break the chain of angela bega causation.
However, this issue of the supply or administration of drugs has come before the courts on numerous occasions since Cato and we can derive a number of Dr. Segal's The Cookie FAD Diet Essay lessons from these cases about the operation of causation in cases of manslaughter however it has to be argued that the logic in Cato ‘seems to stretch credulity’ . The rationale that seemed obvious to of the of women many commentators after Cato was upheld in The Cookie FAD Diet R v. Dalby . On appeal the court came to consider whether someone who supplied a person with drugs was liable for manslaughter when the victim went onto make up the solution and inject themselves. The court decided that ‘Where the charge of manslaughter is based on an unlawful and dangerous act, it must be an act directed at the victim and likely to rumusan cause immediate injury’ . The major criticism of this judgement was that it wasn’t couched in terms of causation but made it very unclear what the basis for stating that an act not directed at the victim could not form the basis of a manslaughter by unlawful and dangerous act. Common sense seems to imply that it is the lack of Dr. Segal's causal relationship but this was not endorsed by the court. Of Health Systems Essay! The requirement for an act to be ‘directed at the victim’ was considered to be incorrect in FAD Diet the later case A-G's Reference (No 3 of 1994) . However, the fundamental criterion that meant a supplier was not liable for contoh karangan rumusan, manslaughter was considered to The Cookie be the likelihood to socialogy of sports cause immediate injury. This makes it a causational issue. The fact that it is a causational issue and The Cookie FAD Diet the correctness of the approach in R v. Dalby have been divisive issues which have been treated with a lack of coherence in subsequent case law on the issue. Did The Genome! The case of R v. Armstrong considered whether or not it was manslaughter when the accused supplied the victim with heroin and the means by FAD Diet Essay, which to mix and inject it. The court overruled the initial conviction on two grounds; there wasn’t sufficient evidence that the heroin was a major cause of death i.e. it fell foul of the de minimis principle and angela bega more importantly that the voluntary act of taking the drugs constituted a novus actus interveniens and The Cookie FAD Diet Essay consequently broke the socialogy of sports chain of causation. Since this case there has been a great deal of oscillation by the courts on the issue. The cases of Dalby and Armstrong seemed to imply that the voluntary act of the victim was enough to overcome a conviction of manslaughter and importantly was sufficient to breach the chain of causation. Dr. Segal's The Cookie Essay! The problem was that Armstrong didn’t deal with the effect of an unlawful act by the accused and Delby didn’t directly deal with the principles of causation.
It was therefore unclear whether the novus actus interveniens of reflective voluntary injection was sufficient to overcome manslaughter by unlawful and dangerous act, furthermore the question of manslaughter by gross negligence was left completely aside in these cases, however I will discuss this issue in greater detail below. The next case to consider the issues was the much maligned R v. Kennedy which came to consider a different factual circumstance. In Kennedy the facts were such that the defendant had made up the mixture in the same room as the victim, handed him one of two syringes made up by himself and left the room. Prima facie this is incredibly similar to the facts of Armstrong and Dalby however the court in Kennedy managed to come up with a conclusion that, according to Heaton, would ‘have been a cause for embarrassment for any competent law student’ . Here, they drew a distinction, relying on Cato, that the defendant had ‘assisted or encouraged Bosque to inject himself with the mixture of heroin and Dr. Segal's FAD Diet water’ . They furthermore on the issue of causation came to the conclusion, based on the dicta of Goff LJ in Pagett, that the chain of causation was not broken because the appellant could be considered ‘jointly responsible for the carrying out of that act’. This imported a completely novel concept that appeared to be some form of accessorial liability by assisting another commit a crime. Cutting Of Health Care Systems Essay! The inconsistencies of this decision with basic causation principles and the other case law have lead to Dr. Segal's The Cookie FAD Diet fairly universal condemnation. Primarily they failed to make adequate distinction between the the Cost of Health Electronic Systems sine qua non test and a novus actus interveniens, they seemed to assume that if the sine qua non test was satisfied then this somehow circumvented the voluntary injection of the drugs by the victim. The legal argumentation was also completely flawed in that case because the victim hadn’t in himself been committing a crime so the defendant couldn’t have been art and part guilty of assisting him and even more forcefully a person cannot commit manslaughter on himself so the accused cannot be accessorially liable for The Cookie Essay, that manslaughter. Furthermore, the rationale of dangerousness in Kennedy and when the distinction from Dalby that the court made are not supported when we consider the dicta in the latter case that we mentioned above about ‘immediate harm’. It also doesn’t square with general principles of causation concerning the kind of ‘dangerous’ behaviour that ought to be exhibited. In the cases of R v. The Cookie FAD Diet! Watson and R v. Angela Bega! Dawson the courts accepted that if the act’s danger was contingent on Dr. Segal's The Cookie FAD Diet, natural conditions such as frailty then the the Cost Systems chain of causation could be broken.
Thus in both cases there were robberies, in Watson the victim was an old man but in Dawson the The Cookie FAD Diet victim was seemingly healthy. In both cases the victims suffered heart attacks but the a vindication of women summary courts held the dangerousness of the act was only established in Watson because the harm was foreseeable. It is at least arguable when we consider the fact that given Heroine can be a safe drug when taken in the correct quantities and with knowledge of the particular person’s tolerance level that there would have been no way the Dr. Segal's The Cookie defendant’s actions could be considered dangerous. This aside the court in Kennedy made no reference to Armstrong, however it might be possible to cynically distinguish the two on the basis that the accused in Armstrong couldn’t be bothered to when human genome project make up the mixture and left it to the victim however in Kennedy he was the one who did the preparation. Kennedy’s rationale was never very clear and FAD Diet Essay more recent judgements have even further complicated the issues by attempting to distance themselves from the dicta of that case whilst still achieving the same result. It seemed that lucidity had been achieved when the decision in R v. Dias was handed down by angela bega, the court of appeal; on facts almost identical to Kennedy the court quashed the conviction of manslaughter. Dr. Segal's! The court distanced itself from Kennedy and elaborated the conceptual difficulty with that court’s approach very well. Reflective Examples! Primarily, the injection of drugs was not an offence so the accused could not be considered to have been guilty of this by accessorial liability. Separately, the issue of causation cannot be made out as between the illegal supply of drugs and the death of the FAD Diet accused because of the voluntary actions of the victim. And finally the main crux of confusion in mary wollstonecraft a vindication of the of women Kennedy was highlighted from this point: ‘It follows from that that the appellant could only Essay have been guilty of manslaughter as a secondary party and not as a principal.
But in journals that case who is the principal guilty of manslaughter? As there is Dr. Segal's FAD Diet Essay, no offence of self-manslaughter, it is difficult to see how the appellant could be guilty of that offence as a secondary party because of his encouragement or assistance to Escott over the injection of the drug’ The decision in Cutting the Cost Care with Electronic Prescription Systems Essay Dias amply highlighted the difficulties the courts had been struggling with because of conflation of causation with the unlawful act itself. The failure to realise that accessorial liability to The Cookie Essay manslaughter where the principal was the victim made no logical sense was at the heart of this confusion. It appeared as though trial judges had accepted that supply couldn’t be the cause of death and embarked upon reverse logic. Care Electronic Prescription! They assumed that if they found a crime that could be considered to have caused the Dr. Segal's FAD Diet Essay death then manslaughter could be established. This is to make a fundamental mistake about manslaughter by unlawful and karangan dangerous act, the The Cookie Essay first step is to establish that an unlawful act has occurred and then to see whether that act caused the death. Given that this was the angela bega problem it is reasonable to see why the court in Dias left the door open when they hinted that there could be certain situations where a Manslaughter by Gross Negligence may be able to be established when a duty of care may arise. The main issue is just always to bear the distinction between causation and the unlawful act separately.
There was by this point a growing corpus of decisions in the form of Dalby, Armstrong and Dias with obiter support from Cato that the supply of drugs could not be considered manslaughter however the decisions in R. v Finlay and R. v Rogers have ‘muddied the waters’ . In Rogers the accused had held the tourniquet whilst the victim injected himself. The victim had procured the The Cookie Essay drugs himself, injected the accused and then the accused had assisted the victim inject himself by reflective examples, holding the tourniquet. He was convicted of manslaughter by unlawful and dangerous act, the court relying s.23 of the Offences Against the Person Act 1861. The court distinguished Dias in that it was considered these actions fell within the remit of ‘administering’ the drug. Like in FAD Diet Cato the of the summary court were obviously using a real stretch of logic. FAD Diet Essay! It was clear that ‘administer’ in the sense meant by the OAPA 1861 did not envision this kind of interpretation and has subsequently been criticized.
However, the angela bega case of Finlay was a blatant attempt at judicial chicanery to circumvent the line of authority ending with Dias. The facts were identical to Kennedy and Dias but the result was different. They re-established the chain of The Cookie FAD Diet causation between the supplier of drugs and the victim by relying on s.23 of the journals OAPA 1861 where it states ‘Whosoever shall unlawfully and maliciously administer to or cause to The Cookie FAD Diet Essay be administered’ The court used the socialogy of sports famous case of Environment Agency v Empress Car Company to establish that in fact the chain of causation could not be broken by the voluntary act of the The Cookie FAD Diet victim as a novus actus interveniens when that action would be an ‘ordinary occurrence’ as opposed to an ‘extraordinary’ occurrence . The court in Finlay felt that the voluntary injection was an ordinary event and would not break the chain of causation, thus the voluntary nature was just a factor to be taken into when human genome project began, consideration. The court confusingly relied on The Cookie Essay, the idea of ‘joint principalship’ drawing on Rogers however it is extremely difficult to see how this escapes the problems identified above. Rumusan! The victim and the accused cannot be joint principals in an s.23 offence and also cannot be joint principals in manslaughter. In both of these cases there is a requirement of a third party. Furthermore the use of Empress Cars as authority is Dr. Segal's The Cookie, extremely dubious given that the contoh karangan rumusan case is also one which is subject to a high degree of criticism. The decision has been described as ‘perverse’ , ‘heresy’ , ‘aberrant’ and ‘bad principle, bad law, bad reasoning’ . The decision in Empress Cars was based on pollution and the holding of FAD Diet Essay someone responsible as causing the effect because the act which did it was not so extraordinary as to examples be unforeseeable. The decision in The Cookie Finlay was simply terrible because it took one maligned case and applied the angela bega incredibly dubious logic to a separate set of factual circumstances. The latest case is unfortunately also to be lamented because it has once again moved in a different direction in order to achieve the same effect as Finlay, Kennedy and Rogers. This involved the second appeal of Kennedy to the court of The Cookie FAD Diet appeal . In Kennedy (No2) the court impliedly rejected the Finlay approach and rejected the Empress Cars logic.
Instead the court fabricated a completely new doctrine of ‘joint participation’ which completely sidesteps the issue and seems to imply that causational issues are irrelevant . The court argued that in mary wollstonecraft a vindication of the rights of women summary situations such as Kennedy the accused can be considered to be acting in concert with the Essay victim to commit an offence under s.23 OAPA 1861. This seems prima facie to ignore the fact that a s.23 offence requires a third party, a ‘other person’ , the question of how the human began victim and the accused can act in concert to commit a s.23 OAPA 1861 is tautologous and The Cookie FAD Diet amounts to the same argument in Kennedy. The whole decision tries to sidestep causation. The court is fully aware if it can establish an s.23 OAPA 1861 then it can establish causation in angela bega the natural manner. However, it has been unable to convincingly do this in the case where the accused merely supplies the victim. The reliance on joint participation cannot resolve the problems created by the drug supply question for two very important reasons that Ormerod Fortston identify: Primarily, the Dr. Segal's FAD Diet court in Kennedy (No2) recognised an accused cannot be held liable as a secondary party for the reasons explained in rumusan Dias. FAD Diet! However principles of secondary liability require that one person is the principal and one the secondary, thus when acting in a team both parties cannot be liable both as principles or if they can then the court in Kennedy (No2) has rewritten the principles of secondary liability without telling anyone.
Secondarily, the use of ‘Joint Participation’ would be unjust in many situations if taken to its logical extreme. Ormerod Fortston give a specific example here: D who supplies the bullets for project began, P's gun for him to murder V now becomes a murderer as a principal, not as an accessory. This undermines the principles of secondary liability in Dr. Segal's The Cookie as fundamental a way as did the ruling in Kennedy (No.1)’ The clear message from the case law is that the judiciary seem willing to convict at any cost no matter the damage to principles of causation and the general criminal law.
The application of the law in project these cases is incoherent and from Kennedy (No1) to Kennedy (No2) we have heard four different justifications all completely flawed. The chain of causation in these cases is continually held not to be severed by Dr. Segal's Essay, the seeming novus actus interveniens of voluntary injection but the rationale for this is very unclear. It is clear however from other case law on unlawful act manslaughter that the rights summary drug cases are not consonant with other principles of causation. In R v. Williams the court talked about the voluntary act by a third party on the chain of causation and stated that the voluntary act had to be ‘within the ambit of Dr. Segal's FAD Diet reasonableness and not so daft as to make it his own voluntary act which amounted to a novus actus interveniens and consequently broke the chain of causation’. This was dealing with cases where the victim was threatened and then did some act which caused his death; the key thing for these cases is that the voluntary act by the accused had to exhibit rationality. If the the Cost with Electronic Prescription Systems facts of the case indicated that the The Cookie FAD Diet victim was being irrational then the accused couldn’t not be said to have caused the contoh death. The rationale of the drugs cases is to Essay completely circumvent questions of when did the project causation by attempting to say that the voluntary act of Dr. Segal's The Cookie Essay injection was somehow overcome. The principle of novus actus interveniens when the victim or another person makes a ‘free, deliberate and informed’ decision is one of the human genome most important concepts of causation. The drugs and manslaughter cases have ridden rough shod over these principals. In cases involving manslaughter the The Cookie FAD Diet prosecution always has open to them to attempt a prosecute under the idea of ‘recklessness’ or ‘gross negligence’.
The issues of socialogy of sports causation are also pertinent here and given the Dr. Segal's The Cookie speculative nature of the crime the chain of wollstonecraft a vindication of the summary causation can sometimes be difficult to FAD Diet establish. Care Systems! However, for our purposes we will want to consider the principles as they potentially apply to Dr. Segal's FAD Diet drug suppliers and other categories where legal causation may be difficult to establish. There was considerable confusion in mary recent years but the confusion seems to have been settled by the court in R v. Adomako . Following that case it is clear the prosecution must establish three criteria: • Must be in breach of the duty of care under established principles of negligence. • The negligence must have caused death. • The action must be considered as ‘gross negligence’
In the drug supply cases it was suggested by R v. Dias that ‘manslaughter by way of gross negligence may arise if a duty of care can be established’ . Heaton was of the opinion in this case that whilst undoubtedly a duty of care would have existed on Essay, the facts as they had existed in Cato however the finely balanced issues may preclude a finding of ‘gross’ negligence. In cases such as Dalby, Kennedy and Finlay where the victim self-injects it is rumusan, hard to see how this progresses the issue of causation any further. The main problem with drugs cases is The Cookie FAD Diet Essay, that the reasoning is completely circular and very difficult to grasp without detailed contemplation of potential analogies. The crucial distinction for the whole case law is between the situation in Cato and those in Kennedy. The difference between those two is that Cato could be considered to mary wollstonecraft a vindication of the of women summary have ‘caused’ the death of the victim in Dr. Segal's The Cookie Essay that he was the one doing the injecting, the consent of a victim is no defence for angela bega, good reason. Prima Facie in Dr. Segal's FAD Diet Essay the supply case the Cutting the Cost Systems Essay intervening voluntary act of the The Cookie FAD Diet Essay victim acting in a free deliberate and informed manner would normally break the chain of causation. What the socialogy court did in Kennedy (No2) was to leave the law in confusion, especially because they didn’t couch their approach in terms of causation. The problem was amply highlighted by The Cookie FAD Diet, Heaton: ‘An individual, D, might be regarded as a factual cause of the prohibited result where his action combined with others brings about that result. This does not mean on orthodox principles that he will necessarily be held to be a legal cause: his actions may well be treated in law as too remote’
The use of joint participation to establish the wollstonecraft a vindication of the rights of women s.23 OAPA 1861 doesn’t close the causation gap because the supplier still is Dr. Segal's The Cookie FAD Diet, too remote. The court attempted to angela bega circumvent this inevitability by relying on R v. The Cookie FAD Diet Essay! Latif and others : ‘The free, deliberate and informed intervention of reflective journals a second person, who intends to exploit the situation created by the first, but is not acting in concert with him is held to Dr. Segal's The Cookie FAD Diet relieve the first actor of criminal responsibility’ Thus causation becomes reliant on the perception of ‘acting in concert’ however this causes a beehive of problems. Whilst they maybe acting in concert how does this create an unlawful act? S.23 was clearly instituted for the ‘protection of the person to whom the substance is administered ’ and thus surely they cannot act in concert to commit a crime that only one of them can commit. The court seems to have made a mistake here and angela bega conflated legal causation with factual causation, they seem to Dr. Segal's Essay think that Cato has created authority that if you can establish administration then automatically causation is established. It is clear that this is not the case however the court in Kennedy wants to shift the legal basis the facts remain the same there was not a traditional causational link. The basic answer to whether the angela bega chain of causation can be broken in cases of manslaughter is that theoretically and it has been broken in numerous cases. However, the logic and approach of the courts in the drug supply cases threatens to undermine all these principles. 2: Comparison to The Cookie Essay other areas of Criminal Law.
The decisions in Empress Cars and when did the human genome began the drug supply cases have been heavily criticised as having caused ‘a revolution within the field of criminal causation’ . It is primarily because in Essay Empress and the drug supply cases they have completely disregarded the novus actus interveniens of a third party’s voluntary actions. Journals Examples! The chain of causation can only really be broken by a limited number of defined cases as we discussed in The Cookie Essay the first section these are roughly stated, failure to be a sine qua non or failure to establish an intervening act between the cause and effect. The removal of the did the project began voluntary action intervention distorts these principles and Dr. Segal's FAD Diet if taken to its logical extreme could cause serious defects in criminal causation. However, the socialogy principles of causation, as traditionally understood always seem to find the ‘best illustrations supporting the thesisin cases other than homicide’ , this is undoubtedly an Dr. Segal's The Cookie FAD Diet accurate description. The interesting thing about this area of law is that whilst there are plenty of academic authorities to the fact that ‘The novus actus rule is of fundamental importance’ it is particularly difficult to find cases other than the ones we have mentioned already where the court has upheld a novus actus. Journals! However, one of the main justifications for the existence of the rules on causation is the Dr. Segal's FAD Diet Essay distinction in criminal law between principal and accessory ; it is in these cases that we are able to find dicta which are at odds with the approach in the drugs supply cases. Angela Bega! The whole basis of accessorial liability is based on the fact that the accused didn’t in fact cause the harm, in The Cookie fact he may have had absolutely no intention to commit the crime but he can still be an contoh karangan accessory to the crime. Thus take the famous case of R v. Bainbridge as an The Cookie FAD Diet example of why the mary of the of women logic of causation is heinously wrong in the drug cases. In Bainbridge the accused sold oxygen-cutting equipment to another person, that person in turn broke into a bank and stole £18,000.
The accused was convicted as an accessory to the theft. Essay! Here we have analogous facts to the drugs supply cases, if we leave aside the fact that the third party did in fact commit an of sports offence in this case. One cannot be accessory to theft where there are only two parties. Dr. Segal's The Cookie! For example if the third party had taken the Cutting the Cost Care with Electronic Prescription Systems oxygen-cutting machine and broken into his own house and ‘stolen’ £18,000 then no offence is committed by the accused. However it maybe that the accused is guilty of an offence such as supplying the oxygen-cutting machine without a licence. The problem is that in this case there is Dr. Segal's The Cookie FAD Diet Essay, no extra element such as in a homicide which is an unlawful act resulting in death.
Therefore lets say when the third party is using the oxygen-cutting machine breaking into his own house he cuts himself, there is no crime of of Health Electronic Prescription Essay self-injury but there is one of Dr. Segal's The Cookie FAD Diet assault. Angela Bega! Using the logic in Kennedy (No 2) the accused and the third party could somehow be ‘joint participants’ in causing an assault on the third party. This obviously makes absolutely no sense and The Cookie would be completely ridiculous. Thus the approach taken in the manslaughter cases doesn’t sit easily with principles of accessorial liability because as I have argued above legal causation seems to have taken precedence over factual causation which means that establishment of who is the principal and the accessory become questions of legal construction as well as fact. The rest of the criminal law of angela bega result crimes however shows a distinct pre-occupation with voluntary actions, thus there have been plenty of cases such as R v. Hanson where the accused was the original thrower of a squib which then was thrown away by the intended target and caused injury to a third party. The fact that the throwing of the target was not voluntary meant that it couldn’t break the chain of causation. In the cases surrounding Assault occasioning actual bodily harm we can see the The Cookie causation element become of great importance.
In R v. Roberts the assault was an attempt to remove a woman’s coat which occasioned her to jump out of a car and sustain injury. The court again upheld the dicta that the contoh rumusan action had to be so unreasonable or irrational that it was unforeseeable. The clear theme arising from Dr. Segal's The Cookie Essay these cases is that the voluntary action of a victim must be caused by the criminal act of the accused. This can be established in these ‘escape’ cases such as Roberts because the facts bear out angela bega that it was the cause, however it is clear in drug supply questions the implied assertion and the one accepted in Dias is that the supplier cannot be said to cause the death. The foreseeability issue that Finlay raised was taken in The Cookie FAD Diet Essay the wrong context, it is clear the stressed mindset of the victim was what made the angela bega harm foreseeable. It is a warning as to why principles of causation ought not to The Cookie Essay be treated holistically in that they are often fact sensitive and can be used as they were in Finlay to distort their intention.
It is arguable that the principles in of sports other result crimes such as assault ought not to be treated as being binding on the approach in manslaughter. We will see that the crime can make a difference to the way causation is established in the next section when we turn to The Cookie look at the approach in other jurisdictions. 3:Comparisons to other Jurisdictions. The issue of the supply of drugs has been raised in a few cases north of the border and it is when project, interesting to look at their approach as a comparator. The courts have taken a similar view to the courts in England but based on different grounds. Dr. Segal's The Cookie FAD Diet! However, the decisions north of the border have consistently found suppliers to be guilty and that the Novus Actus Interveniens of voluntary behaviour doesn’t break the chain of causation. In both Khaliq v. Socialogy! HMA and FAD Diet Ulhaq v. HMA the supply of solvents was enough to contoh karangan establish the crime of ‘Culpably and recklessly endangering life and health’.
In Lord Advocate’s Reference (No1 of 1994) the court considered a directly analogous case to those of the drug supply when the accused was charged with the Scots Law equivalent of manslaughter, Culpable Homicide. Essay! On Appeal to the High Court after an initial acquittal the High Court upheld the views of Khaliq and Ulhaq and specifically stated: ‘The purpose and the intention of the supply libelled was that the solvents should be abused, employing the angela bega means of abuse provided. The solvents were, it is averred, abused, and Dr. Segal's The Cookie this could be regarded as the expected, intended and probable consequence of the angela bega supply’ This knowledge of abuse thus in Scots Law was held to be vital because the foreseeability of the use meant that the chain of causation was not broken. They argued that the distinction between supply and administration was so negligible where ‘supply is closely related to Essay the use by words of instigation or by some act of instigation on the part of the panel’ . The proximity and foreseeability of use therefore negate the Novus Actus Interveniens on that basis. The argumentation is more convincing than in the English cases although it is submitted this is because of the double test requirement of Manslaughter by Unlawful Act. It seems quite clear that the supply of drugs can constitute a murder charge in certain states of America. In particular two cases are pertinent on this issue and these are State of Iowa v. Of Sports! Albertson and Lofthouse v. The Cookie FAD Diet! Commonwealth of socialogy Kentucky the courts came to Dr. Segal's FAD Diet consider very similar issues as we have discussed in the cases above. In the latter case the accused was charged with reckless homicide under the Kentucky Penal Code. The courts in Kentucky made a distinction as far as supervening factors were concerned between an ‘independent intervening cause’ and of sports a ‘’dependent intervening cause’.
The latter did not relieve the Dr. Segal's accused of criminal responsibility unless the socialogy of sports human act was completely abnormal, the former would relieve unless it was ‘reasonably foreseeable at the time of Dr. Segal's The Cookie his conduct’ . Contoh! The issue of causation was thus circumvented on The Cookie FAD Diet Essay, the basis of Cutting with Systems Essay foreseeability based on the inherent dangerousness of the drugs: ‘The Commonwealth posits that, as a matter of law, the act of furnishing narcotic drugs to another creates a substantial risk of death to the transferee sufficient to convict of either second-degree manslaughter (awareness of and conscious disregard of the risk) or reckless homicide (failure to Essay perceive the risk)’ The test is very similar to the Empress and Finlay approach and the distinction between ordinary and extraordinary occurrence that was made in the latter case, however the main issue here is angela bega, that whilst foreseeability is the test they have specifically attuned the offence so that the issue of Dr. Segal's The Cookie FAD Diet causation is correctly centred on the foreseeability of the angela bega harm resulting from an action. The crime is reckless homicide and the only way the novus actus interveniens can intervene was held to be, much like our escape cases such as R v. Dr. Segal's FAD Diet Essay! Roberts and R v. Mackie was where the act of the victim was abnormal or completely irrational in the situation. Interestingly the US has completely rejected what was known as the felony murder rule which is defined as: ‘If death ensues as a consequence of the commission of a dangerous felony, the intent to commit the dangerous felony provides the reflective element of intent necessary to convict of the The Cookie homicide’ The court in did the began Lofthouse discussed the case law surrounding this crime which bears obvious analogies to manslaughter by unlawful and dangerous act. It appears as though the approach has been abandoned in Kentucky and other states for a number of reasons. One of the main reasons is that many states have their own statutory crime of homicide caused by The Cookie FAD Diet Essay, the supply of narcotics this includes states such as Connecticut, New Jersey and Florida. However the use of the felony-murder doctrine is identical in most respects to the manslaughter by unlawful and dangerous act, including the attendant difficulties of establish a causal relationship between the felonious conduct and the death. The approach in the seminal case of Heacock v. When Genome Project! Commonwealth was too hold that the distribution of cocaine was an inherently dangerous act enough to establish second degree murder under the felony murder rule. It has subsequently been held in numerous cases that the supply of drugs under the The Cookie Essay felony murder rule will constitute a crime see Ingleton v. State , State v. Whitted and Sheriff, Clark County v. Morris . The South African approach to causation issues seems to be very similar to the one in this country.
In two particular cases; S v. Grotjohn and S v. Hibbert the South African Courts fell to consider the effect of the voluntary act of the victim on the accused’s liability in homicide cases. In both these cases the victim had committed suicide but the accused had handed her a gun in a manner where it was very foreseeable that they would shoot themselves., Steyn CJ stated in socialogy of sports the case of Grotjohn that the important issue was that the novus actus interveniens be ‘a completely independent act, in the sense that it should be totally unconnected and has no relationship to the act of the perpetrator’ . The cases are not completely analogous because in the cases there was an intention or desire to bring about a fatal result and they had a particularly close involvement in the instigation of the actions of the victim. In a situation very similar to Cato the Dr. Segal's court in the New Zealand case of R v. Bennett found that a young man who had injected drugs into his friend at a party was guilty of manslaughter. Continental Approach to Causation. In surveying the foregoing case law it becomes apparent that in both Scotland and the U.S.A the law is in effect much the same as the when human genome project result in Kennedy (No 2). However, what we see is that both on Dr. Segal's The Cookie FAD Diet Essay, the continent and in these other jurisdictions is that undoubtedly any liability is based upon the idea of negligent manslaughter or culpable homicide because death was reasonably foreseeable. In all the Cutting with Prescription Systems jurisdictions the interrelation between foreseeability and causation is that the causal link can be established by negligence. This is because in those situations the seemingly voluntary action of the victim is foreseeable, or ought to be, so the accused is deemed to have been aware of the dangers and Essay continued any way. The English approach to the question has seemingly been correct then in embracing the Empress Cars foreseeability test in with Systems Essay criminal law. The problem is FAD Diet Essay, that this is not really relevant in manslaughter by unlawful and dangerous act.
The act must have caused the death, the foreseeability of the issue isn’t relevant because if the act was unforeseeable then it is established that the chain of causation can still be established (i.e. the person had a thin skull or a rare disorder). However, in other jurisdictions the foreseeability issue goes to negligence not causation and examples this avoids the problems. In all jurisdictions the supply of drugs is Dr. Segal's The Cookie FAD Diet Essay, a causa sine qua non however the chain of causation is held not to be broken because the crime is consequent upon negligence by definition whereas the manslaughter cases require a standard causational link between the act and death. This work has concentrated predominantly on reflective examples, the drug supply cases in manslaughter; this mirrors the domination that is given to them in all the textbooks and articles on the issue. It is well understood that there are numerous things which could potentially break the chain of causation in manslaughter such as failure to Dr. Segal's FAD Diet Essay be a causa sine qua non, intervention by an act of nature, intervention by a third party, it may not be a substantial cause of death. The intervention of a third party, particularly where that third party is the victim himself, is a foundational principle of causation and as mentioned above the basis for accessorial liability. The drug supply cases seem to offend these principles and yet there is a paucity of good authority to contradict their conclusions.
In many ways the conclusions in Kennedy (No 2) defy logical explication, however it is an angela bega obvious attempt at maintaining the policy that drug dealers can be guilty of manslaughter. The Cookie! This principle is recognised both north of the border and in Cutting of Health with Essay the USA which in turn creates pressure for conformity. However, the detriment to causational principles seems to lie in the fact that it in many respects completely bypasses the operation of causation. It doesn’t pay attention to the fact that causation is a mixture of fact and law, the Dr. Segal's FAD Diet one cannot exist without the other, and furthermore it is simply not tenable to argue that once de minimis factual cause is Cutting of Health Care Electronic Prescription Systems Essay, established that the facts have no effect. Kennedy (No 2) tried to Dr. Segal's The Cookie FAD Diet create some kind of legal chain of causation, whereby the establishment of ‘administration’ by constructing the facts so as to fit into the definition somehow changed the reflective journals facts from what they were, thus legally all administration causes death where in fact it does. The chain of causation can be broken in cases of manslaughter; it is clear from American authorities such as People v. Dr. Segal's FAD Diet Essay! Elder and Smith v. State that where the accused commits a minor crime which is then followed by a grossly disproportionate killing by a third party then this will break the examples chain of causation. However there are virtually no examples in English law and if we follow the approach under R v. Dear as we discussed above the chain of causation in cases concerning homicide may be incredibly difficult because even the Dr. Segal's FAD Diet most unreasonable behaviour of the victim in exacerbating an initially trivial harm are not relevant in breaking the chain of causation. It is as well to remember however that this doesn’t necessarily entail a conviction of manslaughter, causation is primarily concerned with the karangan rumusan actus reus of a crime and the mens rea may have a very important bearing on the outcome. Allen, Michael Textbook on Criminal Law 2005 / OUP / 8th ed.
Fletcher, George Rethinking Criminal Evidence 2000 / OUP Hart, HLA Causation in the Law 1985 / OUP / 2nd ed. Honore, T McCall Smith, R Scots Criminal Law 1997 / Butterworths / 2nd. Sheldon, D 2nd ed. Ormerod, David Smith Hogan Criminal Law 2005 / OUP / 11th ed. Heaton, Russell Dealing In Death 2003 CLR 497 Principals?
No Principles 2004 CLR 463 Ormerod, D Drug Suppliers As Manslaughterers (Again) 2005 CLR 819. Fortson, R Padfield, N Clean Water And Muddy Causation: Is 1995 CLR 68 Causation A Question Of Law Or Fact, Or Just A Way Of Allocating Blame. Phippen, L Drugs and manslaughter 2005 NLJ 1054. Radlett, D Reed, Alan Involuntary Manslaughter And Assisting 2003 JCL 431. Drug-Abuse Injection Court of Appeal: Causation and Assisting 2005 JCL 384. Drug-abuse Injection Toczek, L Is the supplier also the killer? 2002 NLJ 595 Weait, M Taking the blame: criminal law, social 2001 JSWFL 441. responsibility and the sexual transmission of HIV Williams, R Policy And Principle In Drugs Manslaughter Cases 2005 CLJ 66.
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