text:
Archives of the Center for Invasive Species Management
Montana State University.
The Center for Invasive Species Management closed in 2015. Archives of relevant materials are available here.
Biological Control: A Guide to Natural Enemies in North America
Cornell University. Agriculture and Life Sciences.
This guide provides photographs and descriptions of biological control (or biocontrol) agents of insect, disease, and weed pests in North America. It is also a tutorial on the concept and practice of biological control and integrated pest management (IPM). Whether you are an educator, a commercial grower, a student, a researcher, a land manager, or an extension or regulatory agent, we hope you will find this information useful.
Biology, Ecology, and Management of Scotch Broom (2010)
Montana State University Extension.
Biology, Ecology, and Management of Whitetop (Cardaria spp.) (2011)
Boll Weevil Eradication Program
Louisiana Department of Agriculture and Forestry.
In May 2010 the last boll weevil was trapped in the state and in March 2012 the boll weevil was declared eradicated from the state of Louisiana. The Eradication Program is now at a maintenance level, funded through grower maintenance inspection fees. Traps are placed and monitored according to an approved trapping protocol. Cotton producers have seen increases in yields along with a reduction in the cost of insect control.
Bureau of Plant Industry - Plant Pest Programs
Mississippi Department of Agriculture.
Connecticut Mile-A-Minute Vine
University of Connecticut. Department of Plant Science and Landscape Architecture.
Control and Utilization of Tree-of-Heaven: A Guide for Virginia Landowners (Mar 2019) (PDF | 6.6 MB)
Virginia Department of Forestry.
See also: Publications and Reports - Invasive Species for more resources
Controlling Aquatic Plants and Enhancing Freshwater Habitat
Louisiana Department of Wildlife and Fisheries.
CropWatch - Soybean Cyst Nematode
University of Nebraska - Lincoln. Institute of Agriculture and Natural Resources.
Downy Brome Control
University of Nebraska - Lincoln. Cooperative Extension.
Early Detection & Distribution Mapping System (EDDMapS)
Early Detection and Distribution Mapping System (EDDMapS), provides a more accurate picture of the distribution of invasive species. EDDMapS will allow land managers, agencies and others to set priorities for early detection and rapid response (EDRR), as well as formulate overall invasive plant management action plans. Includes distribution data by species and by county.
Early Detection & Distribution Mapping System (EDDMapS) - Invasive Species Status Report by State
Includes invasive species by category for insects, diseases, plants, and animals.
See also: Invasive Species Status Report by Congressional District
Early Detection is Key: University of Guam Keeps an Eye Out for Deadly Tomato Pests (Oct 8, 2020)
University of Guam.
The University of Guam received another round of funding in September under the U.S. Department of Agriculture Plant Protection Act for the surveying and monitoring of invasive pests of solanaceous crops that are on USDA's Priority Pest List for 2021. Solanaceae, or nightshades, are a family of flowering plants that include tomato, eggplant, and chili pepper. As part of the national effort this year, UOG was awarded $38,000 to survey and monitor for two pests: Tuta absoluta, which is a moth and type of leafminer capable of destroying an entire crop, and Ralstonia solanacearum race 3 biovar 2, which is a bacterium, known as a bacterial wilt, that infects through the roots and is deadly to plants.
The work through UOG better prepares the island to manage these invasive species if or when they arrive. "There are certain pathogens and insects that have a reputation of being really bad. These are two of them," said project lead Robert L. Schlub, a researcher and faculty member of UOG Cooperative Extension and Outreach with a doctorate in plant pathology. "They aren't on Guam, but if they show up, we want to know so we can help get them under control."
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Former CIA agent and political activist Ray McGovern (1939) is one of the prominent guests at the Movies that Matter Festival in The Hague that kicks off today. McGovern worked for the CIA for 27 years, chairing the National Intelligence Estimates and preparing the daily briefings on national security for US presidents Reagan and George H.W. Bush.
McGovern received the Intelligence Commendation Medal to honour his work. He returned the medal in 2006 to protest against the involvement of the CIA in torture.
McGovern, who is highly critical about the use of drones by the Obama administration, will attend several screenings of the film Dirty Wars as part of the Movies that Matter Festival's A Matter of ACT programme. On Saturday 22 March, he will participate in the War on Terror talk show about the excrescences of the war on terror. Sir Nigel Rodley, Chair of the UN Human Rights Committee, will also be among the participants in the debate, which will be moderated by Arabist Petra Stienen. Read the press release.


Academic partnerships are the most comprehensive partnerships Berklee has with external educational institutions. Through a credit-transfer agreement (CTA), the curricular alignment between Berklee and the academic partner allows students to transfer specific courses taken at the partner institution to Berklee in order to complete their program of study. This is a key element in support of Berklee's affordability initiative. Partner institutions can also collaborate with Berklee to host Berklee on the Road clinics and workshops, faculty exchanges, auditions and interviews, alumni and advancement events, mutually beneficial branding opportunities, and more.


When Grim Fandango and Day of the Tentacle received remastered versions, Double Fine decided to include a rather nifty addition and allow players to switch between the new and original graphics at the push of a button, and even allow for cutomizable audio and user interfaces in the case of the latter. And now DotEmu and developers Lizardcube are taking a similar approach to their remastered version of the Master System cult classic, Wonder Boy: The Dragon's Trap. As seen in the new trailer below, players will be able to switch between their preferred choices of HD and 8-bit graphics and music whenever they want.
In addition to that, though, Lizardcube has gone the extra mile and will allow players to use the original passwords from the 1989 version in order to jump to whatever point in the game they wish. So between these options, the astonishing hand-drawn graphics, and the classic gameplay, it's looking like Wonder Boy: The Dragon's Trap is shaping up to be one of the year's best comebacks, so make sure not to miss out on the game when it comes out for the Switch, PlayStation 4, and Xbox One this Spring.


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Our savings are not available to the general public and can only be published to WCC members.
When you receive a With Compliments Club membership you can be sure the issuer truly appreciated your custom, service, or contribution.


Did you ever accidentally hit 'reply all' and send out a message to someone who wasn't suppposed to get it? That's the premise of a hilarious show coming to Asbury Park.
For one night only, you can see a show that has been running in NYC and has attracted a huge following.
You've Got Hate Mail stars Billy Van Zandt (Little Steven's brother) and Jane Milmore, Monmouth County natives and Hollywood sitcom writers!
They have performed the show to packed houses at Brookdale and off-Broadway, and the show has now gone worldwide because of the critic's reviews and the sheer comic genius of the actors. I have seen it myself many times and if you can't make it to New York, I'd say this is a great opportunity for you to see the show this coming Saturday night, June 29th, at Tim McLoone's supper Club on Ocean Avenue in Asbury Park.
The show is about an affair gone horribly wrong, thanks to a juicy email left sitting on a desktop. And it will leave you fighting for oxygen as you laugh your #$%%&* off!
For tickets, click here! Or call 732-774-1155. For more information, go to www.youvegothatemail.com.


text:
package lineup.splitters;

import java.util.*;
import lineup.*;
import lineup.util.*;

public class Word extends Token {

	private int index;
	private String value;
	private List<Match> matches;

	public Word(int index, String value, List<Match> matches) {
		this.index = index;
		this.value = value;
		this.matches = matches;
	}

	public Word(int index, String value) {
		this(index, value, new LinkedList<Match>());
	}

	/**
	 * Word's index within the list of words of its source sentence.
	 */
	public int getIndex() {
		return index;
	}

	public String getValue() {
		return value;
	}

	public List<Match> getMatches() {
		return matches;
	}

	public boolean isCapital() {
		return getValue().length() > 0 && Character.isUpperCase(getValue().charAt(0));
	}

	@Override
	public boolean isWord() {
		return true;
	}

	@Override
	public String toString() {
		return String.format("W(%d, %s)", getIndex(), getValue());
	}

	@Override
	public boolean equals(Object o) {
		return super.equals(o) && ((Word) o).getIndex() == getIndex();
	}

	@Override
	public int hashCode() {
		return super.hashCode() + 59 * getIndex();
	}

	public static class Match extends Tuple<Word, Float> {

		public Match(Word word, Float distance) {
			super(word, distance);
		}

		public Word getWord() {
			return this._1;
		}

		public float getDistance() {
			return this._2;
		}

		@Override
		public String toString() {
			return String.format("Match(%s, %.2f)", getWord().toString(), getDistance());
		}
	}
}

redpajama_set_name: RedPajamaGithub


Five years after the most devastating hurricane ever to hit the United States and the massive destruction that followed, a permanent exhibition opened at the Louisiana State Museum. "Living with Hurricanes: Katrina and Beyond," a $7.5 million, 6,700 square-foot exhibit on the ground floor of the historic Presbytere in the French Quarter's Jackson Square, tells the stories of people caught in the hurricane's wrath. It documents their rescue, recovery, and rebuilding, and the renewal of New Orleans in a way certain to move both survivors and those who watched the events unfold on television.
When it hit southeastern Louisiana and the Mississippi Gulf Coast on the morning of August 29, 2005, the storm caused fearsome destruction. But the disaster wasn't entirely the result of natural causes. Levees and floodwalls, the man-made barriers built to protect New Orleans from the water surrounding it, failed. Their collapse in a dozen or more locations, plus tidal surges from the low-lying eastern edge of New Orleans, flooded 80 percent of the city. By the time the waters receded and the survivors regrouped, Katrina, and then Hurricane Rita, had claimed more than 1,400 lives and caused billions of dollars worth of destruction.
Gallery One illustrates Louisiana's history with water, from the Mississippi River's benefits to the threats of coastal storm surges and floods. Visitors move through the Evacuation Corridor, overhearing residents' voices weighing their options as Katrina approaches. A state-of-the-art Storm Theater shows Katrina's full fury with moving and dramatic footage of the hurricane's onslaught.
Gallery Two takes visitors past a leaking floodwall, into an attic, and onto the roof of a house surrounded by rising floodwaters where they can view the city surrounding them. They'll hear a firsthand account of one St. Bernard Parish family's rescue and view artifacts, histories, and photographs.
Throughout the galleries are compelling artifacts, including music legend Fats Domino's baby grand piano, found in his flooded Ninth Ward house; a Coast Guard rescue basket; and seats from the heavily damaged Louisiana Superdome, where thousands of people sought refuge and rescue.
The forensics of Katrina unfold in Gallery Three where science and innovative displays come together. A large interactive table map shows the paths of Katrina and Rita plus the sequence of floods that overwhelmed the region. Through digital animation, visitors discover how the levees failed. Additional displays illustrate the realities of eroding wetlands, disaster management, engineering, and the science of predicting and tracking hurricanes and tropical weather patterns and phenomena.
Gallery Four celebrates recovery, promotes preparedness, and showcases the ingenuity of Louisianans in rebuilding their lives and communities. The gallery will be updated regularly to reflect advancements in flood protection and coastal restoration as well as new strategies for living with hurricanes.


Wednesday, I get a call from the BBC World Service, saying would I like to take part in World Business Review - a discussion programme - about the whole Google/YouTube malarkey. WBR is a good 'un, because you get around quarter of an hour on air instead of the usual two minutes.
Wednesday, I get a call from the BBC World Service, saying would I like to take part in World Business Review - a discussion programme - about the whole Google/YouTube malarkey. WBR is a good 'un, because you get around quarter of an hour on air instead of the usual two minutes. It's also scary, since they tend to have People Who Know on - my fellow panelists will include a prof from Harvard Business School and some blokey from Forrester. I'll have to do my homework.
So I said yes.That meant being at Bush House for a 2pm recording - on a Friday.
Fridays are my diary days, when I try and distill the week into a couple of thousand words, which always means an afternoon of uninterruptable panic. Never mind, I thought, I'll get up early (yes, stop laughing at the back there) and get the back of the beast broken by lunchtime.
Thursday: our esteemed Editorial Site Head Editor-In-Chief-Director-Honcho-Don't-Mind-Me-I'm-In-A-Meeting Matt "Yes, Another Meeting" Loney (in a meeting) declareth: "Editorial Offsite. Friday. Nine till one."
Which means writing the darn thing on Thursday night. IE, now. I'm just glad I haven't got some new blog to test to distract me further.


Celebrating Friday with this gorgeous stack!! 🤩🌼✨Jude Frances trunk show today! Come shop new arrivals from the spring and summer collections.
PANJSHIR EMERALDS ‼⠀ It's believed the first emeralds that the Romans saw were Panjshir emeralds from the foothills of the Himalayan mountain range. ⠀ No two emeralds are alike. They have inclusions which tell a story. Let us find you your perfect piece @ritique_byritikaatwal.
Its here! Typical order to ship date time is 2 weeks, so this weekend is a great time to order your jewelry✨ Sale ends 5/13/19 at 11:59pm. No exclusions.
Vacation Time with Caviar Perlé 💙🌴💛🏝🌊☀ #pinkpigletjewellery . . The Pearl: Symbol of affection as well as good luck. Balancing ones karma, strengthens relationships with purity, generosity, integrity, and brings loyalty of its wearer. . . Chalcedony: Promoting brotherhood and good will. Absorbing negative energy. It brings the mind, body, emotions and spirit into harmony. . . Turquoise: 'The Healer' spiritual lullaby to soothe any emotional storms that might blow through your world.
We are getting ready for Kingsday tomorrow! This antique coral gold ring is our statement piece in this celebrational spirit. Oranje boven, as we say in Dutch. 💥👑💥 You can now easily tap the product to buy it in our shop. How fab is that!
We just love this ring we made last year featuring one of our favourite bi colour ethical sapphires. ⠀⠀⠀⠀⠀⠀⠀⠀⠀ This sapphire works so well with the diamond triangles. And all finished in a contemporary polished bezel set style. ⠀⠀⠀⠀⠀⠀⠀⠀⠀ Call or email to start your bespoke ring journey. Link in bio.


The Vodafone Sony Xperia XZ1 Compact is now available to buy on Vodafone for £32 per month (£30 upfront cost) which includes unlimited texts, unlimited minutes and 1GB of data.
Alternatively, customers can choose a Red Entertainment 8GB plan which includes unlimited texts unlimited minutes, 8GB of data and a choice of Sky Sports Mobile TV, Spotify Premium or NOW TV for 24 months at £44 per month (£10 upfront cost).
The Xperia XZ1 Compact runs Google Android™ O, has a Qualcomm® Snapdragon™ 835, 4GB RAM, a 4.6″ HD Display and a super-wide selfie camera, with a 120° field of view, you can fit more people and scenery into the shot. Switch from super-wide to wide in a single click. It's water resistant (IP65/68) and has a 2700mAh battery.
Customers will also benefit from Vodafone's Network Satisfaction Guarantee – which gives new or upgrading customers 30 days to put the network to the test. If they have any feedback about the network after those 30 days, they can use the My Vodafone app to tell Vodafone about their experience.


Not only am I able to lead you through the planning of your wedding day, I am also able to provide you with professional counseling addressing any issues pertaining to your marriage or other personal areas that you would like to process through. I have been a registered counselor in the State of Washington #RC00050568 since 2004.
I received my BA in Speech Communication from the University of Washington and my MA in Counseling from The Seattle School Of Theology & Psychology and have worked extensively with individuals, adolescents, at risk teens, and their families for the last twenty years. I'm a seasoned marriage counselor and also enjoy working with issues of faith and spirituality.
Along with doing weddings I facilitate individual, family/marriage, and group counseling at my private practice located near Lake Washington and Matthews Beach in Seattle, WA and I am also available for leading retreats. I am a member of the American Counseling Association, Seattle Counseling Association, and the Counseling Seattle Network.
Working from existential, relational, and psychodynamic models of psychotherapy, I strive to work with individuals by diving into the depths of their stories and authentically engaging and exploring their relational styles and most personal struggles.
I am committed to providing a safe and confidential space to explore your life and how it impacts you socially, mentally, physically, and spiritually.


Marble is not as hard as other stones like granite, but it is an ideal stone that could stay for a very long period of time if maintained properly. This means you could experience the luxury of your home's flooring for an extended period of time without worrying about the condition. With occasional sealing, the floor can sustain you for quite a long time. In order to serve you better for the longest period of time, it also has to be cleaned often.
The other advantage of using marble floor medallion or any other design of marble in your floor is that it can suit any room in the house. You can use it in the bathroom, kitchen, sitting area, entrance among other areas that you may want.
Compared to other kinds of floor tiles, marble floor medallion is quite easy to install. You can even do it yourself without the need for a plumber. Besides, you are also able to do repairs on the floor by yourself in case it needs sealing and any other kinds of repairs.
Marble resists water and moisture. This will ensure that your house remains warm and comfortable even in very cold seasons like in winter.


text:
SubTopic Career development
IT executive compensation, priorities and job satisfaction
CIOs offer IT guidance for 2014
What's your IT earning potential?
Senior IT compensation: The sum also rises
Executives have positive outlook for the year ahead
To the cloud, say SMB IT execs
Compensation and IT priorities by job title
IT head counts and budgets: On the up-and-up
Project planning: BYOD in, outsourcing out
GRC professionals: Are salaries keeping up with pertinence?
Networking professionals staying put, despite salary gap
Is your data center management plan ready for prime time?
Data center duties: Challenges in the new year
Developer-programmers: A tale of two pay structures
Are IT security professionals getting paid their worth?
IT channel pros a highly compensated group
This content is part of the Essential Guide: IT career survey 2013: Employee satisfaction, executive compensation
For senior IT, job satisfaction, optimism tied to innovation and growth
Senior IT execs expressed a sense of job satisfaction and an optimistic outlook on their organizations in this year's TechTarget IT Salary Survey.
Karen Goulart, Features Writer
For senior IT executives, the view from the top was a little brighter in 2013. Results from this year's TechTarget IT Salary and Career Survey indicated that as the U.S. emerges from the Great Recession, IT leaders are feeling positive about their jobs and also detect a sense of optimism within the organizations they serve. And while the sunny outlook is helped along by stable and surging salaries, as documented by the survey results, money isn't all that is making the glass appear half full.
One reason for the optimism? Company business is picking up for many of the senior IT execs in our survey, and that's encouraging them to stick around. The survey found that 53% of the 464 senior IT leader respondents aspire to stay with their current company for the next three to five years. Among that group, 23% would like to move up in the company, 14% hope to move up in the IT organization, and 14% would be happy to stay in their current role.
In all, 68% expressed happiness with their job, 23% claimed they were satisfied with their current position and company, and 45% said they'd be open to new opportunities but weren't actively looking. Senior IT executives were defined as CIOs, chief technology officers (CTOs), executive vice presidents and directors of IT/MIS/IS.
Daniel Salama, CIO for Fort Lauderdale, Fla.-based MCNA Dental, counts himself among that 53% of senior IT leaders who see themselves sticking with their company for at least three to five more years. "It's an exciting time," he said. "The company is growing quickly, which keeps everyone challenged and on their toes." Salama plans on growing with the company, and anticipates his job will transition to a higher authority role in the next few years.
For the CIO at a regional IT consulting practice in the Northeast who requested anonymity, the chance to grow along with a burgeoning business also factors into his current job satisfaction. He's part of the leadership team at the practice, and right now that's right where he wants to be. After spending years in unhappy work situations in order to develop his technical and leadership skills, he has earned the luxury of taking only the jobs he wants.
"I have a seat at the table and a voice in the overall direction the company is moving. … I am quite content where I am," he said.
Read more about IT job satisfaction
SearchCIO readers weigh-in on factors affecting job satisfaction
Why senior IT leaders stay at their jobs, and why they flee
Money doesn't equal on-the-job happiness for senior IT leaders
For MCNA Dental's Salama, job satisfaction boils down to a handful of simple yet important things, like knowing he's making a difference in his company and for their clients, feeling eager to come to work even when it stretches beyond the normal 9 to 5 hours, and being recognized for accomplishments. And it also hinges on the job satisfaction of those who work for him.
"My job satisfaction includes knowing that my own employees feel they've achieved their own definition of job satisfaction and that I've helped them in achieving that," Salama said.
Optimism inspired by growth and innovation
It's easier to feel good about work when the vibe is upbeat. Among the senior IT executives in our survey, 78% said the mood in their organization was either optimistic (39%) or neutral (38%). Two of the top reasons cited for the mostly positive outlook were the encouragement of innovation (61%) and business growth (34%). That correlation is key, according to Salama.
As the company grows, his team is working on "exciting" projects and has the freedom to stay on the "bleeding edge," he said.
"We're tasked to continuously innovate our technologies and be the best of the best in what we do," Salama said. This requires a lot of hard work, but results in a great deal of satisfaction. "Our drive for innovation keeps everyone motivated, challenged and engaged at all times."
Sam Cattle, now practice manager at Cincinnati-based Mainstream Security, agreed. "To excel at a job, innovation and growth are key," he said. Cattle recently left a job where many of the factors cited by IT leaders in the survey as being crucial to a positive outlook were waning or lacking entirely. There were layoffs, unresolved customer challenges and no growth. His new IT organization is different.
"The care and feeding elements -- budget, training, effective management, career management and advancement -- are critical, from an employee's point of view," Cattle said. He loves what he's doing and would be happy to continue working for Mainstream Security into the foreseeable future.
"Nothing is driving me to look," he said. "I'm bullish on my new company."
Let us know what you think about the story; email Karen Goulart, senior features writer.
Dig Deeper on CIO career development and career paths
Dubai Health Authority completes final phase of Salama electronic medical records system roll-out
Kubernetes adoption sends Rancher users back to eval mode
By: Meredith Courtemanche
Stop treating servers like cattle, not pets -- try a fleet instead
By: Emily Mell
Second phase of electronic medical record system goes live in Dubai
Karen Goulart asks:
For you, what's the single most important factor in IT job satisfaction?
Want Engaged and Inspired Employees? Give Them the Digital Workspace of Their ... –Citrix
What's Next in Digital Workspaces: 3 Improvements to Look for in 2019 –Citrix
Karen Goulart - 19 Dec 2013 11:27 AM
abimbola - 3 Jan 2014 5:07 AM
despite IT management strategies, enterprising IT based human resources, a good IT environment or architecture should also be put in place to actualise IT job satisfaction

redpajama_set_name: RedPajamaCommonCrawl


text:
Tue. Dec 7th, 2021
ByPriscilla Carson
How to record a phone conversation on Android or iPhone. All the tricks and secrets
A topic that seems simple and obvious, causes a lot of confusion and curiosity for most people. You can or can't record phone conversations, what you need to do to do this and so on. In this material, let's figure out how to record your conversations.
The legal aspect of recording phone conversations
Read moreAn App for Tracking a Guy's Phone
Recording phone conversations is handy in many life situations, although here it all depends on what country you are in. For example, in some U.S. states it is illegal to record conversations unless both parties are notified, such as California law. And near Arizona, you can record a conversation and not notify the person you are talking to. Of course, we are talking about recording your own conversations, in almost every country in the world recording other people's conversations is illegal, unless there is court permission to do so, which is issued by law enforcement.
For example, trying to listen to and record a conversation with your spouse will lead to criminal punishment in the vast majority of countries, the degree of intimacy does not play any role, you are breaking the law. Exactly the same approach, anyone involved in the conversation can record the conversation without warning, no permission is required. You can record the conversation for personal use, such as listening to it on long winter evenings. Many people have heard that the secrecy of telephone conversations is protected, and mistakenly interpret the article as prohibiting such conversations.
But that's not true at all, let's read this article:
Violating the privacy of the correspondence, telecommunications, postal, telegraph or other communications of individuals – penalised by a fine of up to eighty thousand or in the size of the wages or other income of the convict for up to six months, or compulsory works for up to 360 hours, or corrective labor for a term of up to one year.
The same act committed by a person using his official position – is penalised by a fine of a hundred to 300 thousand or in the amount of the wages or other income of the convicted person for a period of one to two years, or deprivation of the right to hold certain positions or engage in certain activities for two to five years, or compulsory works for up to four hundred and eighty hours, or forced labour for a term up to four years, or detention for a term up to four months, or imprisonment for a term up to one year.
Read moreThe Best Phone Tracking Apps
Accordingly, you will violate the secrecy of the negotiations in the case if you do not participate in them, but you keep a recording. The penalty will be a fine of up to 80 thousand. Another important point is that by keeping a recording of the conversation for personal use, you do not violate the law. But if you share such a recording without the permission of the other party, it is also a violation of the law.
You've probably called operator customer service, banks, and other companies and heard the answering machine say: "In order to improve quality control, all conversations are recorded." Indeed, such companies record all conversations and can use those recordings to determine the essence of the customer's claims and what was going on during the call. But they cannot publish such recordings without your explicit and explicit permission. In addition, whoever recorded the conversation is responsible for keeping it safe and inaccessible to third parties. Keep this in mind before you decide to record all of your conversations.
Please familiarize yourself with the laws in your country so that you do not violate them when recording conversations with interlocutors. This is important! Technical capabilities for recording conversations are available anywhere in the world.
So you have determined that recording conversations is legal, and now you need to figure out how to do it and what it takes.
Recording on a dictaphone the old-fashioned way – an easy way for everyone
You can't record your conversation on the recorder, which is built into the smartphone, unless the manufacturer initially allowed you to record conversations (then no dancing with tambourine is necessary). For example, in Samsung smartphones, you will see an inscription that the work of the voice recorder during a conversation is not supported.
But no one forbids using the same phone to record a conversation on a second device. Then you will have to turn on speakerphone mode. It's inconvenient, this way is suitable at home, but on the street it doesn't work. And your interlocutor will know that you are talking on speakerphone mode, it is well noticeable. If there is no other way, and the conversation must be recorded here and now, then this method is reliable and working, but far from convenient.
How to record a phone conversation on iPhone
The answer in the title sounds simple – no way. If you go deeper into the question, it turns out that there are several ways, and they are relatively exotic. If you jailbreak the device, you can install software that will record all conversations on the line. But the security of this approach is questionable, and I strongly advise against it. It's enough that your iPhone is not the most secure smartphone in the world, and it could potentially be tracked by school kids or people you don't know. And access to your conversations would be a tidbit for your blackmail. Is that what you want? I don't think so.
Another expensive and exotic way is to buy a special adapter for iPhone, a crowdfunding project on Indiegogo by PhotoFast. A small box connects to the Lightning connector, and you plug in a regular headset with a 3.5 mm jack. During a call, all you have to do is press the record button, and the conversation is saved on the microSD card. This accessory costs about $125 and is quite difficult to find on sale, it seems that Apple has consistently banned its sale. The plus side is that you can record any conversation in any app. And it's all at the expense of using the regular audio output. So I consider this method as exotic as the first, but someone will surely track down this accessory.
The easiest way, which is available on absolutely any phone and depends directly on your operator, is to use the second line. This feature of cellular networks is used by the creators of apps or individual services, as well as by the operators themselves.
Here's how the service is described in a company press release:
"Calls and voice messages are recorded using the technical number 333. To record an outgoing call, you must:
Call the 333 number.
Press the "Add call" button.
Call the necessary addressee and after connection with it to unite calls.
To record a conversation that has already begun, you must:
During a conversation with the caller, press "Add call" on the screen.
Call the number 333.
Merge the calls, and then the recording will begin.
To record a voice memo, dial 333 and dictate the message
After the call is ended the recording will appear immediately and will be available in Tinkoff Mobile app under Events -> Calls. Recordings will be available only to the subscriber, who can dispose of them at his discretion. They can be downloaded and saved on the smartphone, as well as sent by e-mail, text message or forwarded to any messenger".
This method is brand-independent and can work on pushbutton devices if they support a second line. On the iPhone, you always need to manually add a third call, there is no way to do this without it.
How to record a phone call on Android
Many smartphone manufacturers initially added the ability to record conversations, no additional programs or services are required. For example, you can record conversations on Xiaomi (until recently), OPPO, realme and others. You can clarify this point in the characteristics of the smartphone.
For example, Samsung believes that the recording of conversations should not be available to users, and therefore in most countries this option is not available by default. For Samsung smartphones, recording conversations is prohibited. For smartphones you can get root access, put programs that are able to record all conversations from the line, but we also do not advise you to do this – it is an unnecessary risk, which you definitely do not need.
In the Play Market you can find many conditionally free or paid programs that are able to automatically record calls on any Android smartphone. As a rule, they use the same method as Tinkoff Mobile, that is, they add a third line and then send you a file (or immediately record it on your device).
It is important to note that most apps do not know how to record conversations using VoLTE, VoWifi, this should be taken into account and apparently turn off such features if you need to record a conversation in the app. Also on Android 10, third-party apps can't transmit call information, so you have to manually enter the name of the call, who the conversation was with. This is extremely inconvenient.
Quick Conclusions
Although recording conversations for personal use of one of the interlocutors is allowed in many countries around the world, there are almost no technical solutions to make it painless and convenient. In Android smartphones, where such recording is present, it is impossible to record all conversations in a row, you must activate this function. Third-party services (third line) handle this better, they record all conversations without stopping.
Google has banned recording conversations on Android, and is consistently forcing all manufacturers using GMS services to drop this feature. For example, Xiaomi last year refused to record conversations, such an option disappeared. However, in the phone book from Google, the release of which is planned for 2021, appeared the option of recording conversations, it differs in the fact that when you press the record key, you also notify the interlocutor (he hears a voice warning that the conversation will be recorded). Saved conversations can be transcribed and read as text. This is a great way to conduct a phone interview. But for recording, hidden from the interlocutor, this caller from Google is definitely not suitable. As a consequence, if we discard hardware solutions, that leaves only the third line, implemented in one service or another. This is the kind of solution that will remain functional for a long time.
Do you record conversations? Do you need such an option?
By Priscilla Carson


13 for the 20th Annual stars Dallas Stars Casino Night. Dallas Stars players and coaches will leave their dallas sticks at the door tonight to serve as casino dealers at the 16th annual Park Place park Lexus & Jaguar Dallas Stars Casino Night at Park Place Lexus.
Park Place is stars your premier dealership for new and pre- owned Bentley, Jaguar, Lexus, Maserati, McLaren, Mercedes- Benz, Porsche, Rolls- Royce, Volvo, Land Rover, and Lotus luxury vehicle sales, leasing and service in Dallas, Ft. casino More than 500 fans turned out for the 12th annual Park Place Dealerships - Dallas Stars Casino stars Night, benefiting the Dallas Stars Foundation, which supports local children' s charities.
Join us for the 20th Annual Dallas Stars Casino Night presented by Park Place Lexus Plano! Play blackjack with place Jamie Benn, night grab a drink with Tyler Seguin, roll the dice with Alexander Radulov, or stars hang out with your other favorite place Stars!
Hundreds of Stars fans turned out for the 19th annual Dallas Stars Casino night Night at Park Place Lexus Plano. As part of the Fantasy Camp, participants will attend Dallas Stars Park Place Lexus Casino Night and mingle with former players and the entireDallas Stars team.
Help Dallas Stars Foundation spread the word about Dallas Stars Foundation - Powered by GiveSmart Thank you to our Title Sponsor Park Place Lexus Find Out More Thank you to our sponsor Find Out More Thank you for our Diamond Bar! Customer Portal Dallas Stars Foundation.
The event raised $ 350, 000 for the Dallas Stars place Foundation, making it one of the most successful Casino Nights in its 19- year history. The event raised more than $ 300, 000 for the the Dallas casino Stars Foundation, making it one of the most successful Casino Nights in its 17 year history.
To begin, enter your login information. Dallas stars park place casino night.
On January 12,, over $ 300, 000 was raised at the Dallas Stars park Foundation' s 17th Annual Casino Night, presented dallas park by dallas Park Place Lexus in Plano. Dallas Stars players are as competitive off stars the ice as on.
Former Stars goaltender Marty Turco brings you inside all the action park from the Dallas Stars Foundation' s Casino Night VIDEO Behind the scenes at Casino Night. Dallas stars park place casino night.
More than 700 fans turned out for the recent Dallas Stars Casino Night at Park Place Lexus Plano. But park one night each year they check their egos at the door and serve as casino dealers to benefit the Dallas Stars Foundation.
Worth and Houston, dallas TX. Dallas Stars players and coaches will leave their sticks at place the door tonight to serve place as casino dealers at the 16th annual Park Place Lexus & Jaguar Dallas Stars Casino Night at Park Place Lexus.
Welcome to Greater Giving Online dallas Payments. January 25, January 25, Staff Report 0 Comments Annual Dallas Stars Casino Night, Dallas Stars Foundation, event, fundraiser, Park Place Lexus Plano, society More than 750 Dallas Stars fans filled the showrooms at Park Place Lexus Plano on Jan.


Priva UK has recruited two new employees to two key roles within its expanding team. Adrian Scott and Malcolm McKechnie join as sales and business development manager and business development manager for Scotland respectively.
Gavin Holvey, Priva UK's UK & Ireland sales manager congratulated both men commenting, "Both Adrian and Malcolm have extensive backgrounds in the controls sector and we are delighted they are on board. We have recognised that we need to strengthen our infrastructure and support to look after our larger clients in the commercial, retail, hotel and leisure sectors where we have some high profile, big brand-name projects.


Consumer needs are consistently changing. Therefore, it is crucial to respond rapidly with relevant products and solutions. Customer-oriented companies must address a myriad of questions–and Deloitte member firms are here to help.
Today's retailers are confronted by savvy, smartphone-toting consumers and an uncertain economic future. Shifts in the supply chain require wholesale distributors to operate more efficiently. Our Retail, Wholesale & Distribution practice offers insights and services tailored for your organization.
Transportation, Hospitality & Services companies—seeking growth—look to respond to the challenges of an increasingly multi-channel environment, where options are many and customer loyalty is at a premium.


After knowing how to install Angular 5, this tutorial is made to create a simple Angular 5 DataTable example. This Angular 5 DataTable Tutorial is written to help the people to easily integrate the DataTable with their Angular 5 application.
Hi, BPM - 8.5.7 2017.06. For customization purposes, am trying to create an agGrid angular grid table using the oob angular implementation provided by the BPM coach view framework.
Here Mudassar Ahmed Khan has explained with an example, how to get the Row data of the HTML Table which is populated from JSON array using AngularJS ng-repeat directive.
When you first hear about AngularJS Directives, they appear magic in the 'omg what is going on here' way. As a newcomer to AngularJS, the idea of extending HTML with your own elements seems foreign, or a callback to IE6.


text:
PeopleTech
The Remote Work Report By GitLab: The Future Of Work Is Remote
relay March 14, 2020
GitLab, the single application for the DevOps lifecycle and the world's largest all-remote company, published findings from its inaugural Remote Work Report, which surveyed 3,000 professionals from the United States, Canada, United Kingdom and Australia who work remotely or have the option to work remotely. The survey highlights the ever-increasing value employees and employers place on remote work as an alternative to traditional, in-office practices. In an era with increasing recognition and understanding that mental health and physical health directly impact employee performance, it's undeniable that the future of work will be remote.
"We believe all-remote is the future of work, as it delivers extraordinary benefits to businesses and employees," said Sid Sijbrandij, CEO and co-founder of GitLab. "For companies, there are unique operational efficiencies, huge cost savings on office space and a broader pool of job applicants. For employees, this structure enables off-peak lifestyles, family-friendly flexible schedules, and improved work/life harmony. We believe that a world with more all-remote companies will be a more prosperous one, with opportunity more equally distributed."
"The reality is that almost every company is already remote whether you're working across floors or across continents," said Darren Murph, Head of Remote at GitLab. "GitLab believes all-remote is the purest form of remote, and we're working to empower other companies to implement great remote practices. This year's report breaks down preconceived notions about remote and sheds light on its power to plant opportunities in underserved regions, make communities less transitory, and create authentically diverse teams."
Debunking Remote Work Myths
Contrary to popular belief, remote employees aren't all traveling nomads. In fact, 52% of survey respondents reported they traveled less as remote employees. The 38% who view a lack of commute as a top benefit instead spend the time earned back from commuting with family (43%), working (35%), resting (36%), and exercising (34%). Additionally, employees find themselves overall to be more productive (52%) and efficient (48%) when working remotely.
Remote Work Levels the Playing Field
Fourteen percent of remote workers surveyed reported they have a disability or chronic illness. Eighty-three percent of those cite remote work as a key factor in their ability to contribute to the workforce. Remote work also empowers all employees to move their organization forward. Fifty-six percent of the respondents said they feel everyone in their company can contribute to process, values, and company direction, and 50% say they default to shared documents and rely on meetings only as a last resort. Remote work levels the playing field by fostering a better sense of work-life balance and creates opportunities for everyone to contribute in the workplace.
Remote Work Enables Work-Life Balance
Remote work enables employees to focus on their families without having to sacrifice their careers. Thirty-four percent of those surveyed say the ability to care for family is a top benefit of remote work, while 52% cite schedule flexibility and 38% say the lack of commute is a major benefit. Additionally, 43% reported that the absence of a commute freed up time to spend quality time with their families. Fifty-five percent of respondents have children under 18.
All-Remote is Surging
All-remote is the purest form of remote work, with each team member on a level playing field. Forty-three percent of remote workers surveyed feel that it is important to work for a company where all employees are remote. Currently, more than 1 in 4 respondents belong to an all-remote organization, with no offices, embracing asynchronous workflows as each employee works in their own native time zone. An added 12% work all-remote with each employee synched to a company-mandated time zone.
Remote Work is Here to Stay
The benefits of remote work are only going to increase, and survey respondents agree. Eighty-six percent believe remote work is the future, but it's also the present, as evidenced by 84% who say they are already able to accomplish all of their tasks remotely. As technology continues to improve how we communicate and how businesses operate across the globe, the need for brick-and-mortar offices and consistent, on-site attendance will continue to decrease. Remote work is here to stay, and use cases for it will only multiply.
GitLab surveyed 3,000 adult professionals, aged 21 and older, who work remotely or have the option to work remotely and are in roles with digital output from January 30, 2020 to February 10, 2020. The margin of error for this survey is +-1.8% at 95% confidence level.
To read the full Remote Work report, please visit https://about.gitlab.com/remote-work-report.
Remote Work Resources As a leader in all-remote work, GitLab hopes to inspire other companies to embrace the future of work by publicly sharing its challenges and solutions to creating a thriving remote culture. To learn more, check out GitLab's Remote Manifesto and browse its extensive library of remote work resources.
GitLab is a DevOps platform built from the ground up as a single application for all stages of the DevOps lifecycle enabling Product, Development, QA, Security, and Operations teams to work concurrently on the same project. GitLab provides teams a single data store, one user interface, and one permission model across the DevOps lifecycle allowing teams to collaborate and work on a project from a single conversation, significantly reducing cycle time and focus exclusively on building great software quickly. Built on Open Source, GitLab leverages the community contributions of thousands of developers and millions of users to continuously deliver new DevOps innovations. More than 100,000 organizations from startups to global enterprise organizations, including Ticketmaster, Jaguar Land Rover, NASDAQ, Dish Network and Comcast trust GitLab to deliver great software at new speeds. GitLab is the world's largest all-remote company, with more than 1,200 team members in over 65 countries.
Future Of WorkGitLabRemote WorkRemote Work Report
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text:
Polygonum argyrocoleon, common names silver-sheath knotweed and Persian knotweed, is an Asian species of plants in the buckwheat family. It is native to Siberia, western China, Central Asia, and the Middle East. It has also become naturalized in parts of the United States, primarily the Southwest, and northwestern Mexico.

Polygonum argyrocoleon is an annual herb up to  tall. It has very small leaves rarely more than  long.

References

External links
Line Drawing from Flora Palaestina

argyrocoleon
Flora of Asia
Plants described in 1847

redpajama_set_name: RedPajamaWikipedia


It took all of Navaleen's emotional strength to face Fyora and the council the next day. Her eyes burned with the effort to keep her tears at bay. She felt better having Lydriel by her side to support her in her decision. Turning toward the group of faeries, the princess spoke, her voice hard with determination.
"I know I am the heir, but it is also my right to refuse the crown if I see myself unworthy to wear it," began Navaleen. She couldn't meet her sister's eyes. "I do not see myself worthy and I will now forsake my right to be queen and pass it down to Fyora." She winced as the several of the faeries, including Fyora, stood in protest.
"You are the heir!" cried the fire faerie.
"Fyora is too young," added the Lilia, the earth faerie.
Navaleen went up to embrace Fyora. Her sister began to cry into her shoulder.
"But you are..." began Fyora.
The council continued to bicker with Navaleen, but it was obvious that they were fighting a hopeless battle. It was Fyora who first realized and accepted this. Moving away from her sister's embrace, she straightened and dried her eyes.
"Enough," she said. The others looked at her. "If Navaleen refuses the crown, as is her right, I will accept it as next in line." Navaleen smiled at her sister gratefully.
"I can only hope that she will stay here to be amongst my advisors." Fyora smiled. "I am certainly going to need the help." Navaleen walked up to her sister and put a hand on her shoulder.
Navaleen's words had an immediate affect on the council faeries. They rushed about the council room, trying to arrange the time and date of the coronation and at the same time trying to figure out where it would take place and who to invite. Not wanting her sister to get caught up in the chaos, Navaleen pulled Fyora out of the room, Lydriel following close behind.
The princess led the future queen to their mother's study, or what had used to be their mother's study. Now, it was Fyora's.
"Sit down, both of you. Before you fall down," ordered Lydriel. She quickly brought both girls drinks. Navaleen looked at Fyora guiltily.
"I'm sorry, Fyora," she whispered. "I just couldn't..." her voice trailed off.
"I know why you did it," said Fyora. Her voice was clear and strong. "I know I shouldn't be but I'm glad you did." Lydriel and Navaleen looked at her, startled.
"Very funny," muttered Navaleen. Lydriel, knowing Navaleen's sharp tongue and even sharper temper, threw her head back and laughed.
The coronation for Fyora was short and very informal. There was no feasting and rejoicing as there had been in the past. Fyora's speech was quick and to the point. She promised to do all she could do to fix Thyora's mistakes and help restore parts of the great city she had neglected.
As Navaleen watched from her place beside Fyora, she scanned the faces in the crowd, her sharp eyes seeing the emotions in the faeries' eyes. She saw hope, admiration and respect. But she also saw hate, resentment and anger. Her hand moved to the hilt of the sword that was hung at her waist.
Now that there was no Thyora to hide it from, Navaleen had announced her lessons in martial arts and had very forcefully told the protesting council that she planned to use them if need be. Lydriel and Anna had also helped Navaleen persuade the members by having their student give them a small demonstration.
Seeing how close Navaleen was to the two faeries, she had asked them to be Navaleen's personal body guards. Both girls were glad the two veterans accepted. It gave reassurance to Fyora and Navaleen had someone to talk to during boring meetings in the council room.
After the coronation, Fyora was put to work straight away. She read reports, sorted documents and listened to complaints and still somehow managed to tour the city and figure out which parts needed funding and or rebuilding. Desperate to keep her sister from becoming too stressed, Navaleen volunteered to do the tour of Faerieland. Fyora accepted the offer with gratitude. Neither queen nor princess realized how dangerous these outings were, at least not until rebels decided to point that small fact out to them.
Navaleen rode through the poorer parts of Faerieland with Lydriel and Anna by her side. They had just finished looking at some homes that needed some repairing and were now on their way back to the castle. All three of them were relaxed and none of them expected to be attacked in the middle of a busy street. It wasn't until a group of about ten dark faeries blocked their path did they notice something was wrong.
"But you have one with you," snapped the dark faerie who appeared to be their leader. Navaleen gasped in recognition.
"You!" she cried. Her guards and the dark faeries turned toward the girl. "You're the faerie who attacked Fyora and me in the marketplace. You're the fortune teller!" The dark faerie laughed.
"If you wish to insult me," said Navaleen, "then do so in another way than calling Thyora names. You will find I call her much worse things myself." The dark faeries glared.
"We have heard of your sharp tongue, princess," began the fortune teller. Lydriel interrupted her.
"Sorry, no can do," said the faerie in front of them. As one, the dark faeries pulled out their concealed assortment of weapons. Lydriel and Anna moved into position in front of Navaleen. The princess stiffened and was suddenly glad she had brought her swords with her.
With loud cries, the dark faeries threw themselves at the guards, who attacked in earnest. The guards' Unis reared and kicked. Anyone foolish enough to get too close to them soon learned their lesson. Almost half of the dark faeries lay unconscious on the ground when the fortune teller raised her hands, shouting a word Navaleen had never heard before.
Black fire flew from the faerie's hands to hit Navaleen's guards. Both fell from their saddles and lay on the ground unmoving. Navaleen went dead white with terror and the dark faerie turned toward her with a smile.
Navaleen looked around her and felt her stomach twist with nervousness. Many faeries of different elements watched the battle take place. None of the faeries who were not part of this rebel group would help her. She could see it in their pale faces. They did not want her to get hurt, but they didn't care about her enough to actually interfere. She was after all, Thyora's daughter.
"You would be surprised at what I can do," she said to her opponent.
"All right," she said aloud. The dark faeries cackled in triumph.
"Dismount," said their leader. Navaleen moved to obey.
Stepping off her Uni in a way that the dark faeries wouldn't see her actions, Navaleen drew her swords and leapt at them. Caught unaware and startled by the princess's lightning like movements, the dark faeries fell one by one until only the fortune teller remained standing.
The two faeries stood facing each other. They sized their opponent up and looked for the others' weakness. Navaleen found the dark faerie's first. Despite what she said to Fyora months ago in an alley, the dark faerie was very gifted in magic, but her skill with a sword was mediocre. Navaleen attacked using her extraordinary speed. Her blades flashed in the sun and the dark faerie soon found herself disarmed and standing with two sword points at her chest.
Navaleen backed away from the faerie. She stepped backward until she was close to the unconscious Lydriel and Anna. Before the dark faerie could come to her senses, Navaleen muttered the spell which would transport her and her guards to the palace courtyard. The last thing she heard was the dark faerie's shriek of rage as her quarry disappeared.


text:
Felony murder rule
(Redirected from Felony murder)
"Felony murder" redirects here. For the general felony of murder, see Murder.
Not to be confused with Malice murder.
The rule of felony murder is a legal doctrine in some common law jurisdictions that broadens the crime of murder: when an offender kills (regardless of intent to kill) in the commission of a dangerous or enumerated crime (called a felony in some jurisdictions), the offender, and also the offender's accomplices or co-conspirators, may be found guilty of murder.
The concept of felony murder originates in the rule of transferred intent, which is older than the limit of legal memory. In its original form, the malicious intent inherent in the commission of any crime, however trivial, was considered to apply to any consequences of that crime, however unintended.
While there is debate about the original scope of the rule, modern interpretations typically require that the offence be an inherently dangerous one, or one committed in an obviously dangerous manner. For this reason, the felony murder rule is often justified by its supporters as a means of deterring dangerous felonies.[1]
According to some commentators, the common law rule dates to the twelfth century and took its modern form in the eighteenth century. The modern conception of the felony murder rule arose in 1716, with William Hawkins' Treatise of Pleas of the Crown, during his work on English criminal law. Hawkins reasoned that malice was implicit in a crime that "necessarily tends to raise Tumults and Quarrels, and consequently cannot but be attended with the danger of personal hurt." Thus, "this rule should extend to killings in the course of felonies à fortiori."[2]
ElementsEdit
In most jurisdictions, to qualify as an underlying offense for a felony murder charge, the underlying offense must present a foreseeable danger to life, and the link between the offense and the death must not be too remote. For example, if the recipient of a forged check has a fatal allergic reaction to the ink, most courts will not hold the forger guilty of murder, as the cause of death is too remote from the criminal act.
There are two schools of thought concerning whose actions can cause the defendant to be guilty of felony murder. Jurisdictions that hold to the agency theory admit only deaths caused by the agents of the crime. Jurisdictions that use the proximate cause theory include any death, even if caused by a bystander or the police, provided that it meets one of several proximate cause tests to determine if the chain of events between the offence and the death was short enough to have legally caused the death.[3]
The merger doctrine excludes from the offenses that qualify as underlying offenses any felony that is presupposed by a murder charge. For example, nearly all murders involve some type of assault, but so do many cases of manslaughter. To count any death that occurred during the course of an assault as felony murder would obliterate a distinction that is carefully set by the legislature. However, merger may not apply when an assault against one person results in the death of a different person.[4]
Felony murder is typically the same grade of murder as premeditated murder and carries the same sentence as is used for premeditated murder in the jurisdiction in question.[5]
Critics of the felony murder rule argue that the rule is unjust because it requires no intent to kill.[6] For example, 20-year-old Florida resident Ryan Holle was convicted of first-degree murder for lending his car to a friend after his friend told him that he intended to go beat an 18-year-old girl. The friend took the car and beat the girl to death.[7] In favor of the rule, it can be argued that the rule affirms the principle of the sanctity of human life by imposing harsher penalties for crimes that destroy human life.[6]
Some commentators regard the rule of transferred intent as a legal fiction whereby the law pretends that the person who intended one wrongful act also intends all the consequences of that act, however unforeseen. Others regard it as an example of strict liability whereby a person who chooses to commit a crime is considered absolutely responsible for all possible consequences of that action. Lord Mustill regards the historical rule as a convergence of those views.[8]
By countryEdit
The felony murder rule has been abolished in England and Wales[9] and in Northern Ireland.[10] In Canada, it has been held to be unconstitutional, as breaching the principles of fundamental justice.[11][12] In some jurisdictions (such as Victoria, Australia), the common law felony murder (called constructive murder) rule has been abolished, but has been replaced by a similar statutory provision in the Crimes Act 1958.[13] Similarly, in NSW (New South Wales), common law has been overridden and the question needs only be dealt with through statutory construction and application.[14]
§ 18(1)(a) of the Crimes Act 1900 (NSW) provides the statutory definition of 'constructive murder'. The act or omission causing death must be 'done in an attempt to commit or during or immediately after the commission, by the accused, or some accomplice with him or her, of a crime punishable by imprisonment for life or for 25 years'.[15] The rationale is to discourage acts of felony which are dangerous to human life.
Ryan v R [16] clarifies the elements of constructive murder. The prosecution must prove beyond reasonable doubt: (1) a base offence with 25 years' imprisonment or more; and that (2) the act causing death occurred in attempt, during, or immediately after this base offence. This means that the prosecution must prove both the actus reus and mens rea of this base offence. R v Munro[17] confirmed that the mens rea of the act causing death is not required to prove constructive murder. For example, the accused may commit an act causing death in the course of robbery or armed robbery without any intention to kill, to inflict grievous bodily harm, or with reckless indifference to human life.
CanadaEdit
See also: Murder (Canadian law)
As Canadian criminal law aims to maintain proportionality between the stigma and punishment attached to a conviction and the moral blameworthiness of an offender, in R v Martineau the Supreme Court of Canada held that it is a principle of fundamental justice under sections 7 and 11(d) of the Canadian Charter of Rights and Freedoms that a conviction for murder requires proof beyond a reasonable doubt of a subjective foresight of death. In so doing, the court declared sections 230 and 229(c) of the Criminal Code to be unconstitutional.[18]
S. 230 provided that a conviction for murder would lie for any killing that was "objectively foreseeable as a result of the abominable nature of the predicate crimes...inter alia...coupled with intentional infliction of bodily harm".[18] This largely equated with a Canadian form of felony murder, though it is technically closer to constructive murder[further explanation needed] in other jurisdictions.[19] Similarly, according to s. 229(c) it was sufficient for a person to do anything that he "ought to know is likely to cause death".
Nevertheless, s. 229(c), as far as it provides for a form of constructive murder in situations where "an accused for an unlawful object did anything knowing that it was likely [on an objective standard] to cause someone's death" is still operative, as confirmed in a 1999 appellate court decision.[18]
Bill C-39 has been introduced in 2017 in order to repeal s. 230 and modify s. 229(c).[20]
Like other common law jurisdictions, Canada's Criminal Code specifically enumerates offences to account for instances where (a) person(s) is/are unintentionally killed during the commission of a crime (for example, criminal negligence causing death and impaired driving causing death). In cases where multiple deaths are caused by the same criminal act, the accused will face a separate charge for each death caused. While such charges are not considered to be murder under Canadian law, the maximum penalty for such offences is still life imprisonment - although unlike murder this is not a mandatory sentence and is only very rarely imposed. The main difference between a sentence of life imprisonment for murder and a sentence of life imprisonment for an offence such as criminal negligence causing death is that in the latter case, the offender is eligible for parole after serving seven years.
IrelandEdit
The rule was abolished in the Republic of Ireland by section 4 of the Criminal Justice Act 1964 which codified the mens rea for murder as intention to kill or seriously injure another person.
England and Wales, Northern IrelandEdit
The rule was abolished in England and Wales by section 1 of the Homicide Act 1957, and in Northern Ireland by section 8 of the Criminal Justice Act (Northern Ireland) 1966; but its effect is preserved by the application of the Common Law principle of "Joint Enterprise". In England and Wales, the definition of murder requires only an intent to cause grievous bodily harm to the victim, rather than specific intent to kill; the effect is the same as that of the felony murder rule applied to crimes of personal violence, though not to all felonies.
ScotlandEdit
There is no equivalent to the felony murder rule in Scots Law, which has also never had a specific concept of felonies in the previous style of English Law. However, the Scots equivalent of "Joint Enterprise" known as "Art and Part" also has a similar effect.
See also: Felony murder and the death penalty in the United States
As of August 2008[update], 46 states in the United States have a felony murder rule,[21] under which felony murder is generally first-degree murder. In 24 of those states, it is a capital offense.[22] When the government seeks to impose the death penalty on someone convicted of felony murder, the Eighth Amendment has been interpreted so as to impose additional limitations on the state power. The death penalty may not be imposed if the defendant is merely a minor participant and did not actually kill or intend to kill. However, the death penalty may be imposed if the defendant is a major participant in the underlying felony and exhibits extreme indifference to human life.[23]
Most states recognize the merger doctrine, which holds that a criminal assault cannot serve as the predicate felony for the felony murder rule.[24]
To avoid the need for reliance upon common law interpretations of what felony conduct merges with murder, and thus what offenses do and do not qualify for felony murder, many U.S. jurisdictions explicitly list what offenses qualify in a felony murder statute. Federal law specifies additional crimes, including terrorism, kidnapping, and carjacking.[25]
The American Law Institute's Model Penal Code does not include the felony murder rule, but allows the commission of a felony to raise a presumption of extreme indifference to the value of human life.[26][27] Thus, the felony murder rule is effectively used as a rule of evidence. The Model Penal Code lists robbery, rape or forcible deviant sexual intercourse, arson, burglary, and felonious escape as predicate felonies upon which a charge of felony murder can be maintained.
State lawEdit
Hawaii (abolished)
Kentucky (abolished)
Maryland[28]
Massachusetts[29]
Michigan (abolished)
Ohio (abolished)
Common purpose
^ Sidak, J. Gregory (2015). "Two Economics Rationales for Felony Murder" (PDF). Cornell Law Review. 101: 51. Retrieved 23 September 2017.
^ Binder, Guyora (2011). "Making the Best of Felony Murder" (PDF). Boston University Law Review. 91: 403. Retrieved 23 September 2017.
^ Hilliard, James W. (2001). "Felony Murder in Illinois The "Agency Theory" vs. the "Proximate Cause Theory": The Debate Continues". Southern Illinois University Law Journal. 25: 331. Retrieved 23 September 2017.
^ See, e.g., "State v. Huynh, 92 P. 3d 571, 278 Kan. 99 (2004)". Google Scholar. Google. Retrieved 23 September 2017.
^ Fletcher, George P. (1980). "Reflections on Felony-Murder". Southwestern University Law Journal. 12: 413. Retrieved 23 September 2017.
^ a b Crump, David (2009). "Reconsidering the Felony Murder Rule in Light of Modern Criticism: Doesn't the Conclusion Depend upon the Particular Rule at Issue". Harvard Journal of Law & Public Policy: 1155. Retrieved 23 September 2017.
^ Liptak, Adam (12 April 2007). "Serving Life for Providing Car to Killers". The New York Times.
^ See statements of Lord Mustill, "Judgments - Attorney General's Reference No. 3 of 1994". www.parliament.uk. 24 July 1997. Retrieved 23 September 2017.
^ The Homicide Act 1957 (5 & 6 Eliz.2 c.11), section 1
^ See the Criminal Justice Act (Northern Ireland) 1966, "Criminal Justice Act (Northern Ireland) 1966". legislation.gov.uk. U.K. National Archives. Retrieved 23 September 2017. (the Homicide Act 1957 did not extend to Northern Ireland, except in relation to courts-martial by section 17(3) of that Act)
^ R v Vaillancourt, [1987] 2 SCR 636.
^ R v Martineau, [1990] 2 SCR 633.
^ Crimes Act 1958 s.3A
^ Vincent Ryan v R [2001] HCA 21, (2001) 206 CLR 267 (3 May 2001), High Court (Australia).
^ Crimes Act 1900 (NSW) s 18(1)(a).
^ Robert Ryan v R [1967] HCA 2, (1967) 121 CLR 205 (3 March 1967), High Court (Australia).
^ R v Munro (1981) 4 A Crim R 67 Supreme Court (Full Court) (NSW, Australia).
^ a b c Edited case version in Stuart, Don; et al. (2009). ...Criminal Law. p.443-p.455.
^ See dissent by L'Heureux-Dubé, Edited case, version in Stuart, Don; et al. (2009). ...Criminal Law. p.443-p.455.
^ Bill C-39: An Act to amend the Criminal Code (unconstitutional provisions) and to make consequential amendments to other Acts
^ Mays, G. Larry; Ball, Jeremy; Fidelie, Laura (2015). Criminal Law: Core Concepts. Publisher. p. 136. ISBN 1454846674. Retrieved 23 September 2017.
^ See "Enmund v. Florida, 458 US 782, 102 S. Ct. 3368, 73 L. Ed. 2d 1140 (1982)". Google Scholar. Google. Retrieved 23 September 2017. ("Thirty-six state and federal jurisdictions presently authorize the death penalty. Of these, only eight jurisdictions authorize imposition of the death penalty solely for participation in a robbery in which another robber takes life.[5] Of the remaining 28 jurisdictions, in 4 felony murder is not a capital crime.")
^ Larson, Aaron (7 October 2016). "What Are Homicide and Murder". ExpertLaw. Retrieved 23 September 2017.
^ Bonnie, R.J. et al. Criminal Law, Second Edition. Foundation Press, New York, NY: 2004, p. 865
^ "18 U.S. Code § 1111 - Murder". Legal Information Institute. Cornell Law School. Retrieved 23 September 2017.
^ Bonnie, Richard J.; Coughlin, Anne M.; Jeffries, John C., Jr., ,; Low, Peter W. (2004). Criminal Law (2 ed.). Foundation Press, 2004. p. 860. ISBN 1587787202. Retrieved 23 September 2017.
^ American Law Institute Model Penal Code, § 210.2(1)(b) (Official Draft, 1962)
^ Md. Code, Criminal Law Art., 2-201(A)(4). See "Maryland Code, Sec. 2-201". Code of Maryland. General Assembly of Maryland. Retrieved 23 September 2017.
^ Only for crimes punishable by death or life imprisonment. See "M.G.L., Part IV, Title I, Chpt. 265, Sec. 1: Murder defined". Massachusetts General Laws. General Court of the Commonwealth of Massachusetts. Retrieved 23 September 2017.
R v Serné (1887) 16 Cox CC 311.
Binder, Guyora (October 2004). "The Origins of American Felony Murder Rules". Stanford Law Review.
Curtis Brooks didn't kill anyone. He was still convicted of felony murder and sent to prison for life.
New York Times on the felony murder rule as "a distinctively American legal doctrine"
CBS News story on the felony murder rule in California (Brandon Hein case)
Prisons Foundation objections to the rule
Arizona Supreme Court on the rule and the death penalty
The case of Lisl Auman of Colorado, charged with felony murder for a killing that happened during an ongoing crime for which she was already in custody Jeff Kass, Rocky Mountain News March 18, 2001; "Lawyers debate centuries-old legal concept."
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