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Amazon unveils the new Fire TV dongle with 4K HDR and Alexa on board
Amazon's quest to take over the living room just got another step closer. Today, in addition to a ton of new Echo announcements, the e-commerce giant announced the new Fire TV, a $70 dongle that supports 4K HDR content and has Alexa built in. It looks a lot like the Chromecast Ultra but still acts like a set-top box with a remote.
The new Fire TV plugs right into your HDMI port and you're off and running. You can then stream HDR content in up to 4K resolution at 60 frames-per-second. It also supports Dolby Atmos audio if you have speakers or a soundbar that can push it. The remote is rather standard but does support voice search. If you have an Amazon Echo, you can pair your Echo and Fire TV for a truly hands-free searching experience.
Prime members will have access to their library of content with the Fire TV and upcoming special events like Amazon's broadcast of Thursday Night Football. Additionally, you can load apps like Hulu, PlayStation Vue, or Sling TV and ditch cable. The new Fire TV will launch on October 25 for $69.99. You can head over to Amazon now to pre-order yours.
GET IT ON AMAZON
Amazon, Amazon Echo, Amazon Fire TV, Google, Google Chromecast, Hulu, Playstation Vue, Sling TV
GoogleAmazonGoogle ChromecastAmazon EchoHulu


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Chinese State Newspaper Slams US Mocking of North Korean Leader Kim Jong Un
The disrespect of the US toward Kim Jong Un stems from "senseless cultural arrogance", a Chinese state-run newspaper emphasizes, commenting on the postponed... 20.12.2014, Sputnik International
https://cdnn1.img.sputniknews.com/img/101575/37/1015753770_0:177:3500:2156_1920x0_80_0_0_8b525ba25f8cd29d31b8c5d6d7414ca7.jpg
https://cdnn1.img.sputniknews.com/img/101575/37/1015753770_0:67:3500:2267_1920x0_80_0_0_fb0d7ddf4aa8a3e0d428e37bf2341454.jpg
asia & pacific, world, news, us, china, sony pictures, hacker attack, hackers, democratic republic of north korea (dprk), kim jong-un
© REUTERS / KCNA China criticizes the United States for mockery of the North Korean leader Kim Jong Un in a recently postponed comedy "The Interview", Chinese state-run newspaper Global Times stated.
© REUTERS / KCNA
The disrespect of the US toward Kim Jong Un stems from "senseless cultural arrogance", a Chinese state-run newspaper emphasizes, commenting on the postponed comedy "The Interview".
Obama: US to Respond Proportionally to North Korean Cyberattack on Sony
19 December 2014, 19:23 GMT
MOSCOW, December 20 (Sputnik) – China criticizes the United States for mockery of the North Korean leader Kim Jong Un in a recently postponed comedy "The Interview", Chinese state-run newspaper Global Times stated.
"No matter how the US society looks at North Korea and Kim Jong-un, Kim is still the leader of the country. The vicious mocking of Kim is only a result of senseless cultural arrogance," the Friday editorial said.
The Global Times noted that the United States needed to show more respect toward other countries.
"The US society stands on the upper stream of global competition of culture. It needs to show some good manners instead of being too aggressive. The American elites should not just speak like gentlemen, but behave like them," the newspaper stated, adding that if the film were demonstrated on a large scale, it would further complicate already strained US-North Korea relations.
FBI Names North Korea as Sony Cyberattack Culprit
Earlier it was reported that Sony Pictures decided to cancel the premier of its comedy "The Interview" after it had received threats from a hacker group called Guardians of Peace, which hacked the company's computer network and said it would attack all US theaters which showed the film.
On Friday, the US Federal Bureau of Investigation (FBI) said it had evidence of North Korea's involvement in the computer attack, which was later denied by North Korean officials.
hacker attack

redpajama_set_name: RedPajamaCommonCrawl


Dez. RB Leipzig geht mit einem harterkämpften Sieg in die Winterpause. Am Spieltag gaben die Sachsen beim ()-Erfolg über Werder. Liveticker zur Partie RB Leipzig - SV Werder Bremen am Spieltag 17 der Bundesliga-Saison / Übersicht Werder Bremen - RB Leipzig (Bundesliga /, Spieltag).
Yussuf Poulsen RB Leipzig wins a free kick on the right wing. Johannes Eggestein SV Werder Bremen right footed shot from the right side of the box is close, but misses to the right.
Corner, SV Werder Bremen. Conceded by Konrad Laimer. Assisted by Milot Rashica with a cross. Milot Rashica SV Werder Bremen left footed shot from outside the box is high and wide to the left following a corner.
Assisted by Milos Veljkovic. Conceded by Willi Orban. Conceded by Kevin Kampl. Ishak Belfodil replaces Milot Rashica. Timo Werner RB Leipzig header from the centre of the box is saved in the top centre of the goal.
Assisted by Thomas Delaney. Timo Werner RB Leipzig header from the left side of the box is close, but misses to the right. Assisted by Bernardo with a cross.
Timo Werner RB Leipzig right footed shot from a difficult angle on the left misses to the right. Assisted by Diego Demme. Ademola Lookman RB Leipzig right footed shot from the right side of the six yard box to the bottom right corner.
Assisted by Emil Forsberg with a cross following a corner. Conceded by Marco Friedl. Ademola Lookman replaces Dominik Kaiser.
Assisted by Max Kruse. Zlatko Junuzovic SV Werder Bremen right footed shot from the left side of the box is saved in the centre of the goal. Milot Rashica SV Werder Bremen right footed shot from outside the box is saved in the centre of the goal.
Kevin Kampl RB Leipzig wins a free kick in the defensive half. Dominik Kaiser RB Leipzig right footed shot from outside the box is blocked.
Virtual Predictions is unavailable. View All Leagues. Download Data to CSV. Dec 22, Apr 15, Nov 25, Mar 18, Oct 23, RB Leipzig Home Team. Germany Bundesliga Matchday 17 Sat, December 22, 2: Red Bull Arena Leipzig.
Timo Werner No Assist. Max Kruse Theodor Gebre Selassie. Werder Bremen Away Team. Rasen Ballsport Leipzig League Pos.


C.V. Scheepsvaartonderneming Phillippe is a company located in Netherlands, 9679BP Scheemda at Torenstraat 14. C.V. Scheepsvaartonderneming Phillippe has an ACTIVE entity status and an ISSUED LEI code. The Legal Entity Identifier code of C.V. Scheepsvaartonderneming Phillippe is 529900JWNQPKCZ11SJ30. The legal form of this company is CODH.


heels or trainers? how to get the most out of your new season dress!
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Jinan Linteng Forging Machinery Co., Ltd. the leading company in China having been specialised in manufacturing forging hydraulic press,forging manipulator,ring rolling mill,cross wedge rolling mill,electric power press,friction screw press,etc for over many years. So far, the max. capacity of forging hydraulic press we've made is up to 50000 tons and up to 120 tons for manipulator and up to 8 meters in diameter for ring rolling mill.
Hot die forging production line consists of 100MN hot die forging hydraulic press(preforming),120MN hot die forging hydraulic press(forming),25MN trimming hydraulic press.
Cross wedge rolling machine: it has four work modes: adjusting, single, continious and auto. The upper roller can move up and down to adjust the distance between the rollers. The lower roller can rotate and adjust the phase postion with the phase position system in the gear box. The overload protection device inside can protect the machine. What more, it is easy to install and repair for the tools with the openable guide plate mechanism.
Cross wedge rolling machine is widely used in forging connecting rod, crankshaft, camshaft, auto parts, etc., with the advantage of high productivity, efficiency, high rate of finished products. What more, the tools can be used three times longer than air hammers.
Friction screw press can be used in die forging, extruding, cutting edge, bending and correcting for nonferrous and ferrous metal and pressing and forming work of refractory material as well. The press, with simple in structure, large energy, low noise, long life, safe and reliable in operation, convenient service etc, can be widely used in aviation, auto, tractor, tool manufacturing, textiles machinery industries etc.
Cross Wedge rolling mill is a highly efficient production processing technology of shaft forging, particularly suitable for rolling with the various steps shaft which is almost close to the final product shape required by customer, highly material utilization; which could allows blank to get an accurate distribution when used to mold forging billet, D46 series cross wedge rolling mill characteristics, compact conformation, nice appearance, small occupation area. Being equipped with brakes and clutch, which can achieve a continuous, semi-automatic single together with adjusting the operating mode; mounted worm and worm gear on the roller up and down linear movement to adjust the spacing of the roller. The following roll rotary motion by the phase adjusting mechanism in the gear box can be to adjust the phase of the mold; according to some overload protection device, make sure the security of the machine. The mill not only rolling a variety of large and medium-sized shaft, but also can be used as a forging production line system molding equipment for the forging process precision billets.
The automatic promotion of forging pressure raised the production efficiency greatly. It is used special multi-unloading valve that can eliminate the decompress impaction at the great flow rate for it raises the speed of decompression.And it also provides the technical guarantee for fast forging. It has established the connection for the press and the manipulator linkage. It has reliable measure of fire protection.


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The Literary Table
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Tag Archives: Washington Irving
The Devil and Tom Walker: A Property Tale — Part II: Property as mediator of human conduct 1
by Marc L. Roark • Property, Uncategorized • Tags: American Religious History, Law and LIterature in the Law School Curriculum, Law school, Property, Uncategorized, Washington Irving
In my first post, I described how the landscapes shape the relationships in the Devil in Tom Walker. Today, I am going to look at elements of the story that focus on the relationships of people to property. To do so, lets pick up the tale where we left off. In fact
As Tom returns from his encounter with the Devil, he reluctantly tells his wife of his encounter. As we described in the first post, the relationship between Tom and his wife is centered around their individual quest to hoard property; there is no community action between the two. What might seem to be an attempt to partner with her husband is really a selfish push to allow Tom Walker to absorb the risk of dealing with the devil for the mutual benefit of the gold. But Tom remained determined to not "be damned to please her." The wife not to be deterred, attempts to negotiate with the Devil herself. After her first attempt is unsuccessful, she returns offering all of their valuable chattels to the Devil — their silver teapot, silver spoons, and other belongings. Later Tom, when he goes to look for her, discovers her apron with a heart and a liver tied in it.
As before, when the wife and Tom bickered over stashed items, Tom's pursuit of his wife is more about retrieving the things she took than it is about retrieving her from Old Scratch. Its even unclear whether Tom sought after her; though the author seems to believe he did. Whatever the case, the story is clear that Tom was not remorseful for his wife's loss. "Tom consoled himself for the loss of his property with the loss of his wife; for he was a man of fortitude. He even felt something like gratitude towards the black woodsman, who he considered had done him a kindness." Notice how property in this last instance mediated the relationship (the broken relationship) between Tom and his wife. Tom's dissatisfaction of losing property is ameliorated by the loss of his wife — as if the spouse were another piece of property to be bargained away.
Ironically, though Tom does not have trouble accepting the loss of his wife as a good bargain for property (thereby reducing her to property to be bargained), he finds the Devil's suggestion that he engage in the slave trade to be distasteful. Tom's distaste is difficult to explain. His willingness to part with his spouse for a few chattels suggests he has no problem equating humans with economic value — as long as those humans are as wretched as his wife. Likely, Tom's reluctance to engage in the slave trade is a commentary by Irving on the moral choices made by slave opposed states. The story is set in Massachusetts and was written in 1824. This should not be taken that Irving was particularly opposed to slavery. As Kenneth Reed has pointed out, Irving was rather agnostic towards the plight of African Americans, and often used them in stories as a means of pointing to fallacies in his white characters — like Tom Walker. In this instance, let me proffer a theory. Massachusetts, and Boston were the sources of many anti-slavery advocates, like William Ellery Channing, William Lloyd Garrison and David Walker, who published his Appeal to the Colored Citizens of the World in 1829. Though both Garrison and Walker come several years after the publication of the Devil and Tom Walker, there was brewing before that a sentiment that Boston was an anti-slavery society.
Much of the Bostonian view was symbolized in the preacher William Ellery Channing. It is no accident that Irving has Tom Walker establish a usury business using pirate gold in Boston, and thereby become a respected member of the community, while refusing to take part on the tasteless activity of the slave trade. Irving is pointing out the North's hypocrisy in turning a blind eye to deeds that take advantage of others through ill-gotten or less-than-honorable means, while condemning the slave trade of the South. In fact, we see as much glee in Tom Walker's acceptance for opening a broker shop as a usury lender as he showed distaste for the slave trade.
"You shall open a broker's shop in Boston next month," said the black man.
"I'll do it to-morrow, if you wish," said Tom Walker.
"You shall lend money at two per cent. a month."
"Egad, I'll charge four!" replied Tom Walker.
"You shall extort bonds, foreclose mortgages, drive the merchant to bankruptcy-"
"I'll drive him to the d–l," cried Tom Walker, eagerly.
"You are the usurer for my money!" said the black legs, with delight. "When will you want the rhino?"
"This very night."
Tom Walker then finds a successful career as a money lender. His success is built on the failure of others, collecting large sums against defaulting lenders. More than a few commentators have found allusions to the world of Tom Walker and our current lending climate (or at least the climate a few years ago). For Tom, though, the gold shapes his interactions with his clients. It affords him the opportunity to be lenient, which he refuses. Likewise, it shapes his revival as he realizes his soul will be called shortly, much like the loans for which he is calling.
At this propitious time of public distress did Tom Walker set up as a usurer in Boston. His door was soon thronged by customers. The needy and the adventurous; the gambling speculator; the dreaming land jobber; the thriftless tradesman; the merchant with cracked credit; in short, every one driven to raise money by desperate means and desperate sacrifices, hurried to Tom Walker.
Thus Tom was the universal friend of the needy, and he acted like a "friend in need;" that is to say, he always exacted good pay and good security. In proportion to the distress of the applicant was the hardness of his terms. He accumulated bonds and mortgages; gradually squeezed his customers closer and closer; and sent them at length, dry as a sponge from his door.
As with the miserly house from the first part, Tom's property begins to reflect the condition of his soul. Tom "set up a carriage in the fullness of his vain glory, though he nearly starved the horses which drew it; and as the ungreased wheels groaned and screeched on the axle trees, you would have thought you heard the souls of the poor debtors he was squeezing."
And Tom knowing the state of his soul does not seek mercy but seeks to best the Devil — yet another contrast to those in the social order that Tom is distancing himself from. He attempts to out pious the pious and in fact leads them to believe he is more pious than they. At the end of the day, its Tom's failure to show mercy that warrants him no mercy from his own usury lender of the soul.
What is important from a Property perspective is the role that property plays in shaping the social relations around Tom Walker. Property becomes the mediator between his wife and the devil; it becomes the mediator between illicit activities and Tom; and it becomes the mediator (or the stage) upon which Tom's religion is played out. In short, The Devil and Tom Walker illustrates the role of Property in shaping human interactions.
Here are some discussion questions like the last post. What other questions would you raise?
Some Questions for Students Following Tom Walker:
Drawing on Justice Marshall's opinion in The Antelope, how is Tom Walker's moral position on slavery similar to Justice Marshall? How is it different?
We talk about Property being primarily about "relationships amongst people to things;" is Property the primary tie between the characters? Is there something else?
The Devil is primarily a bailor with respect to the pirate gold. If Captain Kidd indeed never returned, should the Gold be treated as abandoned property? Should it be treated as treasure trove? Why?
Should we understand this story as a critique of the financial lending market? Why or why not.
For more information See Kenneth Reed, Washington Irving and the Negro, Negro American Literature Forum (1970).
The Devil and Tom Walker — A Property Tale 4
by Marc L. Roark • Property, Uncategorized • Tags: American Indians and Literature, Law and LIterature in the Law School Curriculum, Law school, Nathaniel Hawthorne, Property, Religion, Uncategorized, Washington Irving
I want to thank Warren, Patrick, Allen and Mai-Linh for having me here at the Table.
Washington Irving's The Devil and Tom Walker has been exemplified as a an example of Irving's use of folklore in constructing narratives of context. Most writers and commentators focus on the karma-istic nature of the story, the faustian detail (devil story), or the role of greed. But the Devil and Tom Walker is a property story. Yes — its about, at its core, the capacity of property to shape relationships amongst people. A few areas of intersection emerge in a property world. We see the conflict between entitlements that are respected and those that are not. In fact, as the last assignment for the semester, I am having my students read the Devil and Tom Walker. These are some of the things I want them to see. Today I want to point out how landscapes and their surroundings in The Devil and Tom Walker are intertwined in the property world.
The beginning of the story tells us that there are two property conflicts that will shape the story. We learn that the Pirate Kidd has stashed gold in the hills amongst the trees in an inland swampy area under the watchful "guardianship" of the devil, "as [the devil] always does with buried treasure, particularly when it has been ill-gotten." We also learn that Tom Walker and his wife lived in a state of conflict over the things that might be termed their "earthly treasures." The wife hid things as they were acquired (like the eggs laid by the hen) and Tom pried about to discover her secret hoards, causing fierce conflicts over what Irving tells us should have been "common property." These conflicts left their marks on Tom's face from time to time, though no one ventured to interfere with their business.
We also get an early glimpse of the poverty in which they lived — poverty which was common amongst their peers.
They lived in a forlorn looking house, that stood alone and had an air of starvation. A few straggling savin trees, emblems of sterility, grew near it; no smoke ever curled from its chimney; no traveller stopped at its door. A miserable horse, whose ribs were as articulate as the bars of a gridiron, stalked about a field where a thin carpet of moss, scarcely covering the ragged beds of pudding stone, tantalized and balked his hunger; and sometimes he would lean his head over the fence, look piteously at the passer by, and seem to petition deliverance from this land of famine. The house and its inmates had altogether a bad name.
Their Property, it seems, began to mimic the desolate nature of their souls. Their home, like them, was forelorn. The story does not tell us that Tom or his wife had children, but their property reflecting their nature suggests they were sterile, producing no fruit. Moreover, the house was unwelcoming — there was no warmth either by fire or welcoming nature and no "traveller stopped at its door." The house became anthropomorphasized, at least as it reflected its two inhabitants, similar to the House of Usher in Poe's tales, or the House of the Seven Gables from Hawthorne.
As Tom went walking one day, through the land, he came upon an area known amongst the common people as a dim place. Tom stops for a rest amongst a great tree and uncovers an indian skull with an ax embedded within it. The place was known to be one where Indians performed incantations and made sacrifices. It was a place where the sacred and the profane met. But Tom was not one to be trifled with such stories. Here, the story tells us a couple of things. First, Tom perceives himself differently from the common people. Common people believe in the mystical nature of the place which shapes the entitlements of people to enter; but not Tom. Tom's view of property then is shaped by what we would term entitlements, rather than propriety. This is exemplified when Tom encounters the devil after kicking away the skull he has unearthed.
"Let that skull alone!" said a gruff voice….
He scowled for a moment at Tom with a pair of great red eyes.
"What are you doing in my grounds?" said the black man, with a hoarse growling voice.
"Your grounds?" said Tom, with a sneer; "no more your grounds than mine: they belong to Deacon Peabody."
In Tom's view, the Devil has no right to exclude Tom from the property. Its only Deacon Peabody, whose entitlement is legally proper — that is respected by the white community. In this end, it does not matter that Tom does not have an entitlement to the property. All that matters is that neither does the devil, and from where Tom sees the world, his entitlement is probably better anyway. Similarly, when Tom learns that the Devil is hewing trees (which represent the souls of the great men of the town), Tom asks what right did the devil have to tear down the trees. And the Devil responds: ""The right of prior claim," said the other. "This woodland belonged to me long before one of your white faced race put foot upon the soil."
There is an irony in the claim of first title that emerges in the discussion between Tom and the Devil. Tom does not respect the right of the native American's to occupy the land. He believes the entitlement is only proper with Deacon Peabody — an opinion which was consistent with the prevailing worldview as title goes. See Johnson v. M'cintosh for example. Ironically, Tom seems to accept the Devil's account when he learns that the devil is not merely native american, but rather absorbs the dark matters across all cultures. At this, the Devil has trumped Tom's view of entitlement drawing on a greater source of right, than that which Deacon Peabody claimed his right — the actual right of first occupancy.
Similarly, the question of who has the rights to the chattels on the property are shaped by how Tom and the Devil perceive the entitlement to the wooded area. The Devil tells Tom of the treasure that falls under his protection. At first, Tom is skeptical of the Devil. In fact the story tells us that Tom was a "hard-minded fellow" and did not at all fear the devil and asked for proof that what the devil said was true." As the story proceeds, we see Tom does ultimately deal with the devil (I am going to cover Tom's and his wife's encounters with the devil in part II) and takes possession of the gold. But what is important is how Tom perceives the Devil's entitlement to the gold. The Devil tells Tom that the only way to find the gold is through the Devil, who has hidden it so that none may find it. As Tom prospers with the Devil's gold, he begins to think about how he can cheat the devil out of his gold.
Once again, Tom defers to entitlements. His solution is to appeal to the what he believes can conquer the devil — zeal and devoutness. Once again, relating the property course to this work, we see the American perspective shaped by how entitlements are created.
Some Questions for Students from the Devil and Tom Walker
1. How does Tom's perception of the entitlements to the forest land shape his interactions with "Old Scratch?"
2. Does Tom's lack of respect for the entitlements shape the way he respects the things found on the land? Compare the Skull with the Trees, with the Treasure.
3. Considering the reasoning of Justice Marshall in Johnson v. M'Insosh, how should we understand entitlements to the property in the forest. Could Johnson v. M'Intosh be consistent with Devil's entitlement to the forest land?
4. How should disputes relating to various chattels be resolved in relation to the Skull, the Trees, the Treasure? Consider Pierson v. Post, Ghen v. Rich, Popov v. Hayashi, Keeble v. Hickeringill, and NAGPRA. Does it matter if the Devil's entitlement isn't legitimate?
5. How does Property shape the various relationships in the story? Tom and the Devil; Tom and his wife; Tom and Deacon Peabody; the Devil and Mr. Peabody?
6. Are there entitlements we should respect, regardless of their legal enforceability?
Are there other things that you would ask? Please post comments below.
Forthcoming — The Devil and Tom Walker: A Property Tale — The Relationships of People to Property.
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I just came back from Illinois, where I was visiting my sister, bro-in-law, niece, and brand new nephew. Spending time with their newly-turned family of four brought back memories - both good and not-so-good - of the challenging days and weeks after Will and Hallie were born.
Most of the parents out there will understand... Back in college you could function fairly well on just a few hours of sleep for multiple nights in a row, but now, after a few years in the real world, you wonder how that was ever the case. At three-weeks-old your bundle of joy is a pretty poor sleeper, and as difficult as it is to acknowledge and accept, you know he's unfortunately still weeks (and weeks may as well be years in the eyes/mind of a sleep-deprived new parent) away from the supposedly blessed six-week-old point at which he will miraculously start sleeping for longer stretches of time at night. You're exhausted. And if this bouncing baby boy is not your first child, you're also pretty tired of juggling the baby's needs against the needs of your older children (let alone your own needs and the needs of your spouse, both of which went out the window an eternity ago). It's difficult to see beyond the next hour, let alone a few months down the road when everyone will be better rested and settled into a routine.
This is where my sister and her family are now. They love their beautiful little girl and sweet little boy something fierce, but they're beat. There's very little I can do (especially now that I'm back in Texas), nor is there any advice I can give, to suddenly help the baby sleep longer or them feel more rested. It sounds silly, but whenever I feel lost or helpless and the end is nowhere in sight I turn to Dory, whose words of wisdom have gotten me through some tough times. So for my sister, and for any of you who may be a dark or lonely place, remember how Dory (well, Nemo, with Dory's encouragement) survived. When all else fails...just keep swimming.
This fellow's annual "People Are Awesome" video needs only a simple introduction: four and a half minutes of people doing awesome things. We're talking amazing acrobatics, athletic stunts, and Dude Perfect-style shots, nearly all of which will make you gasp, mutter "holy cow" under your breath, or breath a sigh of relief when the risk-taker doesn't die. Enjoy!
Do you live there? My in-laws do!
In case you missed it the first time around, here's a glimpse into the chaos that resulted with a little critter moved took up residence in Hallie's dollhouse.
This post ran for the first time a year ago, but is once again relevant since we all just suffered through another Spring Forward time change. What would you do with an extra hour in your day?
Thanks for the words of wisdom - I will try to keep swimming! I appreciate your help more than I can say!


At Thompson's Point last summer there was a forlorn sailboat and a simple garage. The sailboat seemed to be dreaming of sailing on a lee wind as it angled just a bit towards the building, and the door seemed to stretch itself towards the boat in a welcoming gesture. A good partner knows how to keep dreams alive.


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Have I mentioned that I'm having trouble getting out of bed lately?
Not only am I not sleeping well, but I'm just large enough for gravity to keep me in bed long after I'm awake. It requires a ridiculous amount of energy to peel the still-pregnant me out of the bed and into a vertical position.
So when I hear the boys stirring next door in their room, I tend to wait until somebody is hollering at me to get up- and buck up- and be the mom.
But this morning the hollering was taking a suspiciously long time to begin, and since I've learned to worry when it's quiet for too long, I fought the good fight, got myself upright, and went to check on them.
Sir O had taken it upon himself to bring the Captain breakfast in bed. Cookies, lots of cookies, that my little sister just baked last night. They were both so pleased with themselves that I couldn't quite get upset. And it is sort of my fault for not bouncing out of bed at the first sound of awake children, right?
Looks like I'll have an extra load of laundry today. It's good to know these boys are minded to look after each other, even if they do it in ways I am never prepared for. I think they'll be good big brothers, and that's more important right now than healthy breakfasts or clean sheets.
Love it! Two cute little cookie monsters. Sarah also loves to climb into Abby's crib with her. I think it is adorable, messes and all.
wow, I'm impressed with 2 things.
1. Where are the crumbs? My kids are like cookie monster when they eat. They'd be jumping up and down in the crumbs.
2. At least Sir O had the right thought to bring a toothbrush along! I bet Renn is glad to see that.
I would be so proud of them too! What resourceful little guys, and they love each other! Cute cute!
love that Sir O! Your boys are cute and we miss them!
At least he has his toothbrush in hand for good hygiene!


text:
Home Essays Actus Reus - Essay
Actus Reus - Essay
Topics: Criminal law, Manslaughter in English law, Manslaughter Pages: 31 (10109 words) Published: April 15, 2012
Hill v Baxter (1958)
Court gave examples where a driver of a vehicle could not be said to be to doing the act of driving voluntarily. These included where a driver lost control of his vehicle because he was stung by a swarm of bees, was struck on the head by a stone or had a heart attack while driving. Larsonneur (1933)
The defendant had been ordered to leave the United Kingdom. She decided to go to Eire, but the Irish police deported her and took her back to the UK. She did not wish to go back and was certainly not doing this voluntarily. When she landed in the UK she was immediately arrested and charged with 'being an alien to whom leave to land in the UK had been refused, was found in the UK'. She was convicted because she was an alien who had been refused leave to land and she was found in the UK. It did not matter that she had been brought back by the Irish police against her will. Omissions
Contractual Duty
Pitwood (1902)
A railway crossing keeper failed to shut the gates of the crossing before he went to lunch. A cart was crossing when it was hit by the train and a man was killed. The keeper was guilty of manslaughter as he had a contractual duty which he breached. A Duty Because of a Relationship (usually parent and child) Gibbins and Proctor (1918)
A child's father and his mistress failed to feed the child, so that it died of starvation; they were guilty of murder. A Duty Which Has Been Taken on Voluntarily
Stone and Dobinson (1977)
Stone's elderly sister came to live with the defendants. She became ill and unable to care for herself. She died. The two defendants were convicted of manslaughter through failing to care for her or summons help when she became helpless. A Duty Through one's Official Position
Dytham (1979)
A police officer witnessed a violent attack on the victim, but took no steps to intervene or summon help; instead he drove away from the scene. The officer was guilty of wilfully and without reasonable excuse neglecting to perform his duty. A Duty Which Arises Because The Defendant has set in Motion a Chain of Events Miller (1983)
A squatter accidentally started a fire. When he realized this was he realised this he left the room and went to sleep in another room. He did not attempt to put out the fire or summon help. He was guilty of arson. A Modern Case of Omission
DPP v Santana-Bermudez (2003)
In this case a police woman, before searching the defendant's pockets, asked him if he had any needles or other sharp objects on him. This defendant said 'no', but when the police officer put her hands in his pockets she was injured by a needle which caused bleeding. The Divisional Court held that the defendant's failure to tell her about the needle could amount to the Actus Reus for the purposes of an assault causing actual bodily harm. Causation
Factual Cause
Pagett (1983)
The defendant used his pregnant girlfriend as a shield while he shot at armed policemen. The police fired back and the girlfriend was killed. Pagett was convicted of her manslaughter. She would not have died 'but for' him using her as a shield in the shootout. White (1910)
The defendant put cyanide in his mother's drink intending to kill her. She died of a heart attack before she could drink it the defendant did not cause her death; he was not guilty of murder, though he was guilty of attempted murder. Legal Causation
Blaue (1975)
A young woman was stabbed by the defendant. She was told she needed a blood transfusion to save his life but she refused to have one as she was a Jehovah's Witness and her religion forbade blood transfusions. She died and the defendant was convicted of her murder. The fact that she was a Jehovah's Witness made the wound fatal, but the defendant was still guilty because he had to take his victim as he found her. Medical Treatment
Smith (1959)
Two soldiers had a fight and one was stabbed in the lung by the other. The victim was carried to a medical centre by other soldiers but was...
Actus Reus Research Paper
...THE FACULTY OF LAW CRIMINAL LAW I UNIT 4 ACTUS *REUS INTRODUCTION The cardinal doctrine of English Law is that an Act does not of itself constitute guilt unless the mind is guilty – Actus non facit recum nisi mens sit rea. The maxim draws attention to the 2 essential elements of a crime which are: ( 1) The physical element or the _actus _reus – the so – called "condition of illegality " (2) The mental element or the mens rea – the "condition of the mind " The general rule is that for all crimes save for certain statutory exceptions ex. strict liability offences the prosecution must prove both. R v Deller (1952) Generally the two must coincide that is there should be coincidence of actus reus and mens rea. Haughton v Smith (1975) AC 467 pages 491- 2 "An act does not make a man guilty unless his mind be also guilty." The actus reus includes all the elements of the definition of a crime except the accused's mental element. It is too narrow to define the concept only in terms of "acts" therefore it includes" Acts Omissions A criminal state of affairs ACTS An exception to this rule is where the act was done in a case of self –induced intoxication and the crime is a case of basic intent as for crimes of specific intent it is still a defence. R v Lipman (1970) 1 QB 152 approved in DPP v Majewski (1977) AC 443...
Essay about Actus Reus in Law
...Actus Reus An act is not of itself wicked unless the mind is wicked also. The ACTUS REUS is absolutely essential as it is the physical element of the crime, you must prove the ACTUS REUS first before anything else. A person is NEVER punished merely for wrong thinking or evil thoughts. Can be: A positive act A failure to act (omission) All crimes require an Actus Reus. No crime if defendant did not commit the actus reus. MURDER: ACTUS REUS: The unlawful killing of a human being. Actus Reus of a crime can be made up of 3 elements: Conduct Consequences Circumstances Crimes only made up of: Conduct: eg PERJURY Conduct (cause) and Consequences (force/fear): eg ASSAULT Conduct (destroys or damages property), Circumstances (belonging to another), Consequences (property be destroyed or damaged): eg CRIMINAL DAMAGE ACTUS REUS AND MENS REA doesn't have to occur at the same time. EG – Thabo Meli and Fagan Actus Reus can begin half way through a lawful act. EG - Kaitamaki Actus Reus must be voluntary. Actus non-facit reum nisi mens sit rea – no act is punishable unless it is performed with a criminal mind Actus Reus – the prohibited conduct,...
SCOTTISH LAW BASICS CRIME ACTUS REUS Essay
...CRIME INTRODUCTION: ACTUS REUS 1. CRIME NATURE a. Actus non facit reum nisi mens sit rea – conduct does not make a man guilty without a guilty mind b. Two elements must be proved in Scots crime: i. Actus Reus – Wrongful Act/Physical Act ii. Mens Rea – Wrongful State of Mind/Mental Element c. Exceptionally – some crimes (usually statutory – speeding, parking) don't require proof of Mens Rea 2. ACTEUS REUS a. Mere intentions do not make a criminal offence – there must be a criminal act or omission b. Specifically, blameworthy conduct: a physical act prevented by law. i. There are conduct crimes – eg Misuse of Drugs Act 1971 – physical act of possession of an illegal drug constitutes Actus Reus. ii. And result crimes (series of events) – a forbidden consequence results from the physical conduct (eg. A death). Usually you have to prove Mens Rea for all parts of the series of events (eg. Murder – intention to do the act and intention to cause death) 3. CONDUCT a. Three types of conduct: Positive Act, Act of Omission, State of Affairs i. A Positive Act 1. Voluntary acts – controlled by the actor 2. Involuntary acts – where person cannot control their actions, this is an involuntary act a. Hogg vs McPherson (1928) External forces, such as a heavy gale, causing a horse carriage to collide with a lamp standard are an involuntary act. b. Hugh Mitchell (1856) Woman...
Essay on Actus Reas and Men Rea
...Actus Reus and Mens Rea Actus reus and mens rea are two of the five elements of a crime that the prosecution may have to prove to get a conviction in a criminal case. Actus reus is the criminal act. Mens rea is the intent to commit the crime. In general, the more serious a crime is, the more important it is for the prosecution to prove that both a criminal act was committed and that there was criminal intent. These more serious crimes are also known as conduct crimes. Not surprisingly, conduct crimes involve the proof of criminal conduct. Criminal conduct is often confused with criminal acts. The distinction is that criminal conduct involves both actus reus and mens rea, whereas a criminal act only involves actus reus. In the most severe of crimes, such as criminal homicide, three more elements of crime must be proven: concurrence, attendant circumstances and a bad result. Actus reus and mens rea are important because both elements are necessary to get a conviction beyond a reasonable doubt in a criminal case (Samaha, 2008, chap. 3). In order to qualify as actus reus, the act must be deemed a bodily movement that was voluntary. The reason for this is that the law is intended to punish people who meant to commit the act or can be blamed for the act. Only then are they...
CRJ 306 Week 2 DQ 1 Actus Reus and Mens Rea Essay
... This work of CRJ 306 Week 2 Discussion Question 1 Actus Reus and Mens Rea includes: Distinguish between the terms actus reus and mens rea; how are they significant in criminal law? Which of the two is more difficult to prove in a trial, beyond a reasonable doubt? Fully explain your answers, with authorities. Substantively respond to at least two of your classmates' postings. Law - General Law Mens Rea, Actus Reus, and Concurrence. Please answer the following questions below: Distinguish between the terms actus reus and mens rea. How are they significant in criminal law? Define how concurrence works with actus reus and mens rea to lead to criminal liability. Why is concurrence so significant? Which of the three legal requirements listed above (i.e., actus reus, mens rea, or concurrence) is more difficult to prove beyond a reasonable doubt in a trial? Your college might have a course in study skills if you need help. Studying for college is much different than high school, which might impact your grades. Improving your study skills can enable you to succeed in your classes and reach all of your goals. This work of CRJ 306 Week 2 Discussion Question 1 Actus Reus and Mens Rea includes:...
...can be identified in many different categories, it can be from a simple mistake to an atrocious crime against a person. I will be discussing the crimes of murder, degrees of murder and the difference between voluntary and involuntary manslaughter. Killing of another person can be the most vicious crime one can commit; yet people still choose to kill. The social norm is that people don't just kill people for fun there is always some sort of motive behind it. What is murder? The common law that easily divides homicides into two categories is murder and manslaughter. Murder can happen in any sort of manner. It can come from a simple act of self-defense to a criminal homicide against a person. The elements that are included in murder are actus reus the act of killing, mens rea the intentional knowing of the killing, causation, death, and if there is any attendant circumstances. Murder comes with different degrees as it is given by the circumstance of the taking of life. First-degree murder, "consist of premeditated, deliberate intent to kill murders, and felony murders; the only crime today in which the death penalty can be imposed". Criminal Law Chapter 9 (J. Samaha) This definition states that the meaning of murder in the first degree is done intentionally with the malice of doing harm to another person. First-degree murder is the most vicious crime a human being can commit against another person. For example Dan comes home to find his wife in...
Actus Reus Essay
...So what is Actus Reus? Actus Reus is the conduct of the accused (The defendant). It can be an act of commission or act of omission, and it must be a voluntary act that causes the damage or harm. It can also be a "state of affairs". * Commission or act of Omission: A person may incur criminal liability for failing to do that which the law requires him to do as much as by doing that which the law prohibits. The actus reus includes the state of affairs or circumstances surrounding the commission of the offence, together with the results or consequences (if any) that flow from that act or omission. It is essential that the defendant acted voluntarily and that he caused the injury, damage or harm. In other words, actus reus includes all the elements of the offence indicated in the definition except the mens rea (the state of mind), if any. * Must be a voluntary act: Generally the accused's conduct must be a voluntary act or omission. The accused will not be held liable for acts done in a state of automatism. Automatism resulting from self-induced intoxication is no excuse. * The accused must cause the prohibited consequences: The crime must be caused by some conduct by the accused. That conduct need not be a direct cause of the crime, but can be through the agency of others. The conduct need not be the sole or the effective cause of the crime,...
...Actus Reus AR = the conduct element. Prescribes what needs to be done, in what circumstance and with what result (but not necessarily all three). Result: V is killed (note that we don't really criminalise results in themselves, but rather the causation of results). Conduct: in rape: penetration. Circumstance: property belongs to another. All crimes have an AR. It is possible to have missing MR elements but this is not so for AR. Omissions Stephen LJ: "It is not a crime to cause death or injury, even intentionally, by any omission". This is not strictly true, but we are usually unwilling to prosecute for omissions: Criminal liability for failure to act breaches autonomy. It is less burdensome of the law to require someone to refrain from doing something then it is to oblige him or her to do it. Often difficult to distinguish between acts and omissions (e.g. child accidentally puts hand on D's genitals in Speck, but D is guilty of an offence by positive act). Note relevance of 'killing' v 'letting die'. Doctors could turn of life support in Airedale v Bland because it was allowing nature to take its course. Mustill: 'the omission to perform what had previously been a duty will' not be illegal. EXCEPTIONS: Duty to act: can arise by virtue of (note that where there is a duty D must do what is reasonable, as assessed by a jury): Automatically arising duty e.g. parent. Assumed duty for a person e.g. carer. Includes stepparent; this is a continuing...
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Driver charged in deadly Pomona taco stand crash
By Ruby Gonzales | rugonzales@scng.com | San Gabriel Valley Tribune
PUBLISHED: October 18, 2022 at 4:56 p.m. | UPDATED: October 18, 2022 at 6:01 p.m.
Authorities filed charges Monday, Oct, 17, against a driver accused of a hitting a taco stand in Pomona that left one man dead and 12 other people injured. The driver, who took off after the crash, later turned herself in.
Diana Beatriz Martinez-Umana, 25, of Pomona was charged with one count of vehicular manslaughter, two counts of hit-and-run resulting in death or serious injury and eight counts of reckless driving causing injury, said Matthew Krasnowski, a spokesman for the Los Angeles County District Attorney's Office.
She wasn't arraigned Tuesday at Pomona Superior Court because she posted bond, a court official said.
Police don't know yet if drugs or alcohol played a role in the crash because they're still waiting for the toxicology report.
The charges stem from a hit-and-run crash in the 1600 block of West Holt Avenue which was reported to police at 7:42 p.m. on Friday, Oct. 14.
The driver of a Nissan Sentra was heading east on Holt Avenue when she veered into westbound lanes and crashed into a taco stand, police said. She took off and officers searched for her. She returned to the scene more than an hour later and turned herself in, officials said.
Gilberto Cazares Payan, 52, died of blunt force injuries, according to the coroner's office. Mejia didn't know how many of the injured were still in hospital as of Tuesday.
Booking records show Martinez Umana was previously arrested by the California Highway Patrol Antelope Valley office on Nov. 20, 2021 for a felony but it didn't show the charge. She posted bond for a $50,000 bail and was released the next day.
Murder of CHP commander's husband: New details of tangled case are revealed
Half Moon Bay mass shooting fueled by simmering tensions among farmworkers, sources say
Top Stories IVDB
Ruby Gonzales | Reporter
Ruby Gonzales started working for the company in 1991. Since then she has written about cities, school districts, crimes, cold cases, courts, the San Gabriel River, local history, anime, insects, forensics and the early days of the Internet when people still referred to it as the "information superhighway." Her current beat includes breaking news, crimes and courts for the San Gabriel Valley Tribune, Pasadena Star News and Whittier Daily News. When not in crime reporter mode, she frequents the remaining bookstores in the San Gabriel Valley, haunts craft stores or gets dragged to eateries by a relative who is a foodie.
rugonzales@scng.com
Follow Ruby Gonzales @RubyGonzales2
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Protesters flood General Assembly decrying Republican moves to reassert constitutional authority ahead of Cooper administration
Republicans completed legislative actions despite disruptions,
December 16, 2016 admin News
Alice Hiller of Raleigh
RALEIGH — As the N.C. General Assembly reconvened for their fourth special legislative session of 2016, and the Republican super-majorities proposed legislation to reassert the body's constitutional authority over myriad issues, word was spread through left-leaning activist groups calling the lawmakers' actions nefarious and aimed at illegally reducing the power of the Democrat Governor-elect Roy Cooper.
Over the course of the week, the call to action resulted in chamber galleries with standing room only, as hundreds of protesters flooded the legislature in a bid to disrupt legislative proceedings they were politically opposed to.
Orchestrated disruptions erupted in chamber galleries at least three times, requiring the legislature's Sergeant-at-arms and police to clear the chambers. As activists were forced into the third floor rotunda between the two chambers, chants of "Who's House?! Our House!" and "This is what democracy looks like!" became deafening to the point of further delaying resumption of lawmakers' business.
Armed with signs and disobedience training, more than two dozen protesters were arrested in the latter part of the week for refusing police orders. Those arrested protesters were cheered by the crowd, who chanted "Thank you! We love you!" as they were marched by police out of the building toward waiting police vans in zip-ties.
The commotion received national press in outlets such as the New York Times, Washington Post, CNN, and NPR.
Governor-elect Roy Cooper joined in, holding a press conference and encouraging the legislature to adjourn and come back next year to reach compromises with his administration that would benefit the everyday North Carolinian.
"Major changes in the way state government operates should be done deliberately, with input from all parties, particularly something as important as elections and making sure people have the opportunity to vote," said Cooper. "They shouldn't be pushed through in the dark of night.
"The Cooper campaign also circulated a petition to tell the lawmakers to go home, stating "Republican legislators are taking unprecedented action — and it goes beyond just their normal partisan games. This could hurt North Carolinians for years to come.
"Through out the protests against the Republicans' actions, from activists and Democrat legislators alike, Republican lawmakers iterated and reiterated that their proposals were not only constitutional, but good governance on behalf of the constituents who elected them to represent their interests in Raleigh. Republicans have been elected to majorities in the state legislature since 2010.
Much of the action of the fourth special session of the General Assembly is typical of transitional periods in which the constitutional balance of powers between the respective branches of government is reasserted in the wake of election results.
Sen. Jerry Tillman (R-Randolph) called it "just good ol' politics.
"For instance, Sen. Harry Brown (R-Jacksonville) spoke during floor debate of the 1988 election of Lt. Governor Jim Gardner. Before North Carolina's first Republican lieutenant governor took office, the then-Democrat controlled legislature transferred much of the position's authority to the Senate President Pro Tempore, effectively neutering the essential powers of that office.
The Republican lawmakers also lamented the level of disruption caused by protesters, arguing that it infringed upon the right of other citizens to witness legislative process.
North Carolina House majority leader Rep. John Bell (R-Wayne) feels, that while the protesters can and should engage in the process, their actions went too far.
"These protesters have every right to protest under our First Amendment rights. However, some protesters have left trash all over the building, destroyed property of members, and have consistently disrespected the rules of the House and Senate chamber," Bell said in a statement provided to the North State Journal.
"I'm disappointed in the Minority Leader and the Democratic Caucus for not condemning this type of behavior. This is the House of the people and these protesters have taken away the rights of everyday citizens, including the 4th graders who were scheduled to visit the North Carolina General Assembly today.
"I want to personally thank the Sergeant-at-arms and the police for their quick response. I appreciate them keeping our citizens, staff and legislators safe," concluded Bell.
Some legislators reported problems accessing the chamber for floor votes due to fervent crowds of protesters. Others confirmed that multiple elementary school groups, on field trips to visit the State's capital and witness the legislative process, were turned away as the protest atmosphere made simple observance infeasible.
While the fourth special session of 2016 has now concluded, lawmakers will return in January to write a biennial budget, redraw legislative districts, and face court-mandated elections in the fall. The 2017 legislative calendar is ripe with opportunities for partisanship, and thus more high profile conflicts with the Governor-elect, and active political opposition, likely assure further activist inundations to come.
Yurtseven ready to do more than just smell the food for NC State against App State
Future UNC-Kentucky games in doubt because of expanding ACC schedule
Ice Cube will headline Azalea Festival
March 6, 2019 North State Journal Staff Features, News
The N.C. Azalea Festival announced Tuesday that Ice Cube will headline the festival's Saturday night concert on April 6. Ice Cube is an award-winning musician, actor, director, producer and CEO of his own basketball league, […]
Libertarian presidential, VP candidates ruffle party faithful with comments contrary to Libertarian principles
August 24, 2016 admin Article
ALEXANDRIA , VA — Earlier this month in an interview with Revolt TV, Libertarian vice presidential candidate and former Republican governor of Massachusetts, Bill Weld, compared rifles to weapons of mass destruction, upsetting many Libertarian […]
Delta flights resume after computer crash strands passengers
August 8, 2016 admin News
ATLANTA — Delta Air Lines flights gradually began taking off again Monday after computer systems crashed, causing planes to be grounded and leaving passengers of one of the world's largest carriers stranded at airports around […]


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Justia › US Law › Case Law › Kansas Case Law › Kansas Supreme Court Decisions › 1964 › Rankin v. United Commercial Travelers of America
Rankin v. United Commercial Travelers of America
193 Kan. 248 (1964)
RUBY LaVERNE RANKIN, Appellant, v. UNITED COMMERCIAL TRAVELERS OF AMERICA, Appellee.
No. 43,702
Supreme Court of Kansas.
Opinion filed June 6, 1964.
W. Luke Chapin, of Medicine Lodge, argued the cause, and appeared on the briefs for the appellant.
W.A. Kahrs, of Wichita, argued the cause, and Riley W. MacGregor and John W. MacGregor, both of Medicine Lodge, Robert H. Nelson, H.W. Fanning, Richard C. Hite, and Darrell D. Kellogg, all of Wichita, were with him on the briefs for the appellee.
The opinion of the court was delivered by
HATCHER, C.:
This is an appeal from a judgment holding that death from a heart attack while fighting a pasture fire was not an accidental death within the meaning of an accidental death certificate issued by a fraternal benefit society.
At a pretrial conference the above issue was presented to the trial court on the statement of counsel for the defendant that he would, for the purpose of having the issue determined, admit all facts alleged in the petition and also all facts contended for by the plaintiff at the pretrial conference. It is necessary, therefore, that the facts which were alleged in the petition, in detail, be presented. We quote in part, omitting introductory allegations:
"That on the 26th day of November, 1941, in consideration of the payment of Eugene O. Rankin, deceased husband of this plaintiff, to defendant of a *249 premium as determined by defendant, defendant made and delivered to Eugene O. Rankin its insurance certificate in writing, upon the life of Eugene O. Rankin, a copy of which is annexed to this petition, marked `Exhibit A,' and by reference is made a part hereof; and defendant thereby insured the life of Eugene O. Rankin, in the sum of $5,000.00 against loss of life by accidental means. "That this plaintiff, Ruby LaVerne Rankin, is the beneficiary under such insurance certificate. "That thereafter and on March 18, 1962, while said insurance certificate was in full force, all premiums due having been paid thereon, Eugene O. Rankin, died, his death having occurred as a result of accident, as hereinafter set forth. "That on the 18th day of March, 1962, which was a Sunday, Eugene O. Rankin, age 54, was in good health, having been attending to all of his duties as a farmer and livestock man, and doing most of his own work in these activities, and not having had any cause or reason to see a doctor during the five years prior thereto, except for a hernia repair made in 1958, insurance examinations and a cold in February, 1962; at about 3:00 p.m. on that date, after having had Sunday dinner and visiting with his son and family, the son, Larry Rankin, having just returned from military service, Eugene O. Rankin received a telephone call informing him that there was a large pasture fire in the Hawkins pasture just south of the Rankin pasture where his cattle were being kept; Eugene and Larry both immediately changed their clothes, got some gunny sacks, wire and pliers, got in Eugene's car, Eugene driving, and left for the scene of the fire, which was about five to six miles northeast of Sharon, Kansas, and a little over twenty miles from Kiowa, Kansas, where the Rankins lived; they drove to and entered the Rankin pasture and could see a huge pasture fire in the pasture adjoining the Rankin pasture on the south; they could see that the Rankin cattle were toward the south end of the Rankin pasture, so immediately drove down toward the cattle, Eugene called the cattle and attempted to get them to follow the car, but they would not do so, so Larry got out and hazed the cattle toward a corral in the north end of the pasture while Gene drove the car and called the cattle to follow it; at the north end of the pasture there was a gate leading into an enclosure near a tree belt; Gene got out of the car and he and Larry both herded and drove the cattle, on foot, about 70 head of two year old heifers, some with calves, through the gate; they then herded the cattle in the same manner toward a corral which was east of the first mentioned gate; as they reached the corral gate, Gene got out of the car, and he and Larry herded and drove the cattle through the corral gate and shut the gate; Gene then continued driving east, Larry with him, into what is known as the big Rankin pasture, then they drove to the south end of the pasture, where they could see the huge pasture fire, about a quarter of a mile to half a mile away, traveling northwest and burning on a northeast-southwest angle; they could see men fighting the fire with gunny sacks and spray pumps; at about that time, a group of men in a pickup truck drove away from the fire and toward a windmill in the Stone pasture adjacent to the Rankin pasture on the east; Larry left Gene and walked or ran over to the men in the pickup and went with them to fight the fire; Gene drove back to the north, apparently to get to a gate where he could get into the pasture where the pickup was; this probably was at about 4:30 p.m.; Larry *250 and the other men continued fighting the fire until it was about dark and the fire was about out; this was about 6:30 p.m.; they went to the Don Rankin farm house, near Nashville, thinking Gene would be there; the men fighting the fire had been spread out over a large area of more than a mile, and no one had seen Gene; when he did not return, they commenced to hunt for him; they did not find him for about four or five hours; when they found him, he was dead, lying in part of the burned out area in the Hawkins pasture, with a wet gunny sack in his hand; his car was parked in the Stone pasture adjoining on the north, about one-fourth mile away; he had undergone extreme mental emotion and physical exertion and stress in fighting the pasture fire and events connected therewith, from which over exertion and as a result of the unusual and unexpected pasture fire; he suffered heart failure and death."
The defendant in its answer demurred to the petition for the reason that it failed to state facts sufficient to constitute a cause of action, admitted the general allegations of the petition for all practical purposes and further alleged:
"It is admitted that Eugene O. Rankin died on or about March 18, 1962. It is expressly denied that his death occurred as a result of accident or that his death occurred under such circumstances as to bring it within the insurance coverage provided by defendant's certificate of insurance and by-laws. "As an alternative and separate defense it is alleged that if Eugene O. Rankin's death was in any degree caused by accident, natural and non-accidental causes contributed to his death."
The reply was a general denial.
After the issues were joined the case was set for a pretrial conference. It was there agreed by counsel for defendant that all of the facts stated by counsel for plaintiff would be admitted in addition to the facts alleged in the petition for the purpose of determining the question of law in advance of the trial. We have, therefore, searched the record for the purpose of determining what statements of fact were made at the pretrial conference which were not covered by the allegations of the petition.
Counsel for plaintiff stated in connection with the general nature of the terrain:
"... I might comment at this point that this land in here (indicating) is rough pasture land with the exception of a few little portions or crop land that are indicated there. They are a little smoother but the pasture land is rough; hills and deep valley...."
Counsel for plaintiff stated his contention as to the cause of the heart attack:
"We are not maintaining that any other injury was involved. We do maintain that the heart attack was precipitated by the unusual activity of Eugene Rankin on that date, both physical and mental, and that this huge pasture fire *251 so close to his cattle was an unusual event, a very unusual event. He was under continuous nervous and mental strain in seeing the fire and herding the cattle up to the corral and that was followed by extreme physical exertion that goes along with fighting a fire and putting out part of the fire and perhaps flaming fence posts with a gunny sack, and that, we say, precipitated a heart attack and death."
Counsel for defendant introduced the constitution and by-laws of the defendant as exhibits with the consent of plaintiff. Counsel for defendant stated in connection therewith:
"... Referring to the 1961 edition at page 59, it's Article XI, Section 13, of the 1961 Constitution and By-Laws, there is a statement as to the insurance provided by this fraternal benefit society which states in part as follows: "`Class A Insured Members shall be indemnified in accordance with the terms hereinafter set out in this Article, against the results of bodily injury hereinafter mentioned, effected solely through external, violent and accidental means, herein termed the accident, which shall be occasioned by the said accident, alone and independent of all other causes.' "This in effect is a definition of an accident insofar as the United Commercial Travelers insurance is concerned."
The admissions as to medical testimony are disclosed by the following colloquy between counsel:
"Mr. Chapin: You'd admit for the purpose of this motion that medical testimony would state that mental emotional strain, physical exertion, particularly extreme physical exertion can and does precipitate heart attacks and event death? "Mr. Hite: For the purpose of this motion we would so admit.
"Mr. Chapin: All right."
The case was submitted to the trial court as a question of law to be determined on the facts as admitted.
After careful consideration and following a well written and helpful memorandum opinion, the trial judge concluded that the defendant's motion for judgment on the pleadings, stipulations and admissions should be sustained. Judgment was entered accordingly and plaintiff has appealed.
It would perhaps be helpful to all interested if we, before proceeding with the discussion, attempt to consolidate into one brief statement the issues of fact and issues of law which present the question for determination.
Where an able-bodied man, 54 years of age, without apparent physical or health impairment, dies of a heart attack caused exclusively from emotional strain, heat and physical exertion while engaged in fighting a large pasture fire, is the death the result of *252 bodily injury effected solely through external, violent and accidental means, independent of all other causes?
It is agreed by the parties that the defendant which issued the accident indemnity insurance certificate was a fraternal benefit society with its home office in the state of Ohio, and that the answer to the controversy should be determined by the decisions of the Supreme Court of Ohio.
Unfortunately the determination of the question based on the decisions of the Ohio Supreme Court presents a complicated problem. The court's decisions after its latest pronouncement do not appear to be in complete harmony. It would appear that the court is divided four to three on just what its decisions on the particular question do mean.
The first case from Ohio which touched directly on the question was Casualty Co. v. Johnson, 91 Ohio St. 155, 156, 110 N.E. 475. The appellee relies chiefly on this case and it was given considerable consideration by the lower court in making its determination. In its opinion the court stated the undisputed facts as follows:
"The insured was a well and active man. He had no organic trouble with his heart. He was accustomed to take cold plunges, when heated and after exercising and horseback riding, without any apparent trouble. The cold plunge caused the heart dilation. The dilation of the heart from taking the cold plunge was an unusual result and one not reasonably to have been expected."
It was held in the syllabus:
"Where an insured holding an accident policy indemnifying him against bodily injuries which independently of all other causes are effected solely and exclusively by external, violent and accidental means, suffers an injury due to the dilation of the heart following the voluntary taking of a coldwater bath, it will not be considered as the result of an accident where under the circumstances attending the dilation, there is no evidence that anything occurred which the insured had not planned or anticipated, excepting the dilation and its consequences."
We must agree, as argued by appellee, that the Johnson case was decided on the distinction made between "accidental means" and "accidental results" and if followed would require the affirmance of the case now before us for consideration.
The Johnson case was decided in 1914. In 1940, the Ohio Supreme Court decided the case of Mitchell v. N.Y.L. Ins. Co., 136 Ohio St. 551, 27 N.E.2d 243. It was held:
"Where no unexpected, unforeseen or unusual happening intervenes, and an insured dies as the result of a ruptured sigmoid, caused by administering *253 to himself an enema in the manner intended, by voluntarily connecting the rubber tube to the faucets in a bathtub, such death will not be deemed effected by accidental means within the intent and meaning of a life insurance policy, which agrees to pay double indemnity if the death of the insured `resulted directly and independently of all other causes from bodily injury effected solely through external, violent and accidental means.'" (Syl.)
We quote from the opinion at some length because what is there said is diametrically opposite to the conclusion reached in the next decision to be considered. On page 554 of the opinion the court, quoting from Rock v. Travelers' Insurance Co., 172 Cal. 462, 156 Pac. 1029, stated:
"`... A differentiation is made, therefore, between the result to the insured and the means which is the operative cause in producing this result. It is not enough that death or injury should be unexpected or unforeseen, but there must be some element of unexpectedness in the preceding act or occurrence which leads to the injury or death. Policies like the one before us have been before the courts in many cases, and the great weight of authority we think, sustains the view which we have just expressed.'"
The opinion continued:
"In the case of Landress v. Phoenix Mutual Life Ins. Co., 291 U.S., 491, 78 L.Ed., 934, 54 S.Ct., 461, the Supreme Court of the United States had before it the interpretation of the same words that are involved in this case. The insured in that case suffered sun stroke while playing golf, and the question was presented whether this was an injury inflicted by accidental means. "The court held in that case that while the result was accidental, the means was not. In the opinion of the case, on page 495, the following words appear: "`Petitioner argues that the death, resulting from voluntary exposure to the sun's rays under normal conditions, was accidental in the common or popular sense of the term and should therefore be held to be within the liability clauses of the policies. But it is not enough, to establish liability under these clauses, that the death or injury was accidental in the understanding of the average man that the result of the exposure "was something unforeseen, unsuspected, extraordinary, an unlooked for mishap, and so an accident," ...'"
It will be noted that in Landress v. Phoenix Ins. Co., 291 U.S. 491, 78 L. Ed. 934, 54 S. Ct. 461, 90 A.L.R. 1382, cited in the above quotation, that recovery was denied for death from a sun stroke under an insurance policy covering death by accidental means because there was no "accidental means" although there was an "accidental result." The court stated that there must be some unforeseen or unintended condition or combination of circumstances, external to the victim's body, which contributed to the accidental result. It further stated:
*254 "This distinction between accidental external means and accidental result has been generally recognized and applied where the stipulated liability is for injury resulting from an accidental external means...." (p. 497.)
Justice Cardozo warned in a dissenting opinion that an attempt to distinguish between "accidental means" and "accidental results" would plunge "this branch of the law into a Serbonian Bog."
At this point we would call special attention to the Landress case which is reported in 90 A.L.R. 1382 and an annotation follows at page 1387. The case and the annotation cite the numerous cases touching on the present controversy and they will not be repeated here.
Getting back to the Mitchell case, supra, the dissenting opinion approved by three of the justices is worthy of consideration because what was said was a forerunner of what was to come. It is stated at page 556:
"This dissent from the majority opinion occurs at the point of interpretation of the term `accidental cause' or `accidental means,' both terms being used by the courts interchangeably as having the same meaning. The confusion of thought on this subject arises, in my humble opinion, in the failure to differentiate or to recognize the distinction between the origin of injury flowing from the voluntary act of the party injured, accompanied with full knowledge and apprehension of the probable consequences of his act, and the origin of injury flowing from the voluntary act of the party injured unaccompanied by apprehension on his part of unforeseen and unexpected consequences resulting from such act. In the latter case, the event or circumstance which he failed to apprehend and which was responsible for the mishap furnishes the basis of accident by accidental means."
The above statement was, in fact, followed in the next Ohio case which was decided in 1952. In Hammer v. Accident Assn., 158 Ohio St. 394, 395, 109 N.E.2d 649, the court had under consideration a sunstroke case. The facts are stated as follows:
"... On the day of his death the insured was approximately thirty-five years of age. He and another man employed by a roofing company were engaged in shingling the roof of a house in Greenfield, Ohio. The weather is described as `very hot,' `mighty hot' and `so hot we couldn't hardly get our breath.' In the middle of the afternoon both men left the roof and rested in the shade about a half hour. Then each picked up a bundle or shingles weighing approximately 70 pounds. The men started up the ladder with the decedent in the lead. The latter threw his bundle on the roof and asked his associate whether he needed help. On receiving an answer in the negative, the decedent stepped from the ladder to the roof. It was necessary to place the shingles higher on the roof. The decedent attempted to accomplish this, but as he did so he suddenly collapsed and fell on his bundle of shingles. He died within a few minutes."
*255 It was held:
"Heat exhaustion or sunstroke, if suffered unexpectedly, is within the protection of a life and accident policy insuring against bodily injuries sustained through accidental means. "To warrant a recovery it is not necessary that the exposure to the sun should be the result of an accident." (Syl. 1 and 2.)
The court stated in the opinion:
"The question whether heat exhaustion or sunstroke may constitute accidental means is, counsel agree, one of first impression in this state. The general rule is summarized as follows in 29 American Jurisprudence, 759, Section 1004: "`It is held by the weight of authority that a sunstroke, suffered by one unexpectedly, is within the protection of an accident insurance policy insuring against bodily injuries sustained through external, violent, and accidental means. In accordance with this view, it has been held that death from a sunstroke suffered while the insured is engaged in his ordinary duties or occupation is a risk covered by the policy, and that it is unnecessary, in order to warrant a recovery, that the exposure to the sun should be the result of an accident.'" (p. 397.)
The court appears to have followed the general rule without stating the reason for it. The great weight of authority allows recovery for death from a sunstroke under an accidental death policy because it recognizes the accidental result although the instrumentality which caused the result was not necessarily accidental.
In the opinion the court attempts to distinguish its previous decisions. It said of Casualty Co. v. Johnson, supra:
"... In the Johnson case the insured died from a heart attack following a voluntary cold bath, and in the opinion it is observed that the insured planned for and deliberately entered on the project and it was carried precisely as intended. The water was no colder than he wanted it to be...." (P. 399.)
We fail to distinguish between the above situation and one where the insured deliberately enters on a project which takes him out into the rays of the sun which are no hotter than he knows them to be and dies of a heart attack from heat exhaustion.
We agree with the statement in the dissenting opinion approved by three of the justices:
"The result in this case marks a departure to some extent from the decisions in the following cases: New Amsterdam Casualty Co. v. Johnson, 91 Ohio St., 155, 110 N.E. 475, L.R.A. 1916B, 1018; Mitchell v. New York Life Ins. Co., 136 Ohio St., 551, 27 N.E. (2d), 243; and Burns v. Employers' Liability Assurance Corp., 134 Ohio St., 222, 16 N.E. (2d), 316, 117 A.L.R., 733." (P. 400.)
*256 Thus the Ohio court in the Hammer case has adopted what is now the general law in most jurisdictions, as stated in 166 A.L.R. 473:
"In an increasing number of jurisdictions, the distinction between the term `accidental means' and the terms `accident,' `accidental result,' `accidental injury,' `accidental death,' and the like, has been rejected or repudiated, and the terms are regarded as legally synonymous."
Regardless of any distinction which the Ohio Supreme Court may make in the future between "accidental means" and "accidental result," we are unable to make any distinction between a case in which a man dies from a heart attack caused by heat exhaustion and overexertion from the rays of the sun in which he is working, and a case in which a man dies from a heart attack caused by heat exhaustion and overexertion from the flames of a pasture fire which he is fighting. If there is any distinction the latter would come nearer being an unusual occurrence and the result of accidental means, if it is desired to distinguish between "accidental means" and "accidental result."
The court had to consider that the sunstroke in the Hammer case was, in and of itself, an accidental means, or drop its distinction between "accidental means" and "accidental cause." The decisions which hold that death from a heart attack as the result of a sunstroke, consider "accidental means" as a means or a cause that is unexpected, unforeseen, and fortuitous; it is an accidental event, unexpected and unforeseeable, an occurrence that is unexpected and unforeseen.
The Ohio Supreme Court appears to have adopted the rule that where death or injury is not the natural and probable result of a voluntary and intentional act by the insured, or something unforeseen or unexpected or unusual occurs in the act which precedes the injury, then the injury is the result of accidental means.
In cases arising under accident insurance policies, where possible negligence on the part of the assured does not affect the question of liability, the efficient cause of a sunstroke, the vis major which inflicts the injury, is considered to be the excessive heat, and it must, therefore, be deemed "the means" of the injury.
The general rule permitting recovery for heart attacks under circumstances such as are before us for consideration is stated in 56 A.L.R.2d 816, with supporting citations as follows:
"There is seemingly general agreement on the proposition that if an unusual happening occurs in conjunction with exertion or exercise on the part of the *257 insured, and this is followed by a heart attack, recovery may (assuming causation is established) be had under a policy providing benefits for the results of `accidental means,' whether the unusual happening precipitated the exertion or occurred in the course of the same."
We are forced to conclude that under the authority of Hammer v. Accident Assn., supra, where an able bodied man, without apparent physical or health impairment, dies of a heart attack caused exclusively from emotional strain, heat and physical exertion while engaged in fighting a pasture fire, the death is the result of bodily injury effected solely through external, violent and accidental means.
The plaintiff may not be able to prove the facts alleged in the petition which brings the case within the above rule but she should have the opportunity.
It follows from what has been said that the trial court erroneously rendered judgment in favor of the defendant, as a matter of law, on the pleadings, stipulations and admissions following the pretrial conference.
The conclusion reached renders unnecessary a discussion of other alleged trial errors.
The judgment is reversed.
APPROVED BY THE COURT.
of Kansas Supreme Court opinions.


This guide will provide a critical overview of two popular front-end web development tools - React and Angular 2. The tools will be evaluated based on their approaches to building application structure, adoption by the community, performance, and ability to integrate with different platforms.
The goal of this guide is to highlight core differences and understand the similarities between the two tools, thus facilitating the decision-making process when it comes to choosing which tool is appropriate for a given project specification.
Services - Injectable elements that are used to consume data from an API or share state between multiple components.
Components - Building blocks of the user interface that consume services. Can be nested inside each other through structural directive selectors.
Directives - Divided into structural and attribute directives. Structural directives (ex. \*ngFor) manipulate the DOM (Document Object Model) while attribute directives are part of elements and control their style and state.
Pipes - Used to format how data is displayed in the view layer.
Modules - Exportable blocks of the application that isolate components, directives, pipes, services and routes together.
React is far less rigid than Angular 2. It is a library that provides the most basic tools for building a web applications - a HTTP service and Components. There is no built-in router or anything that sets a particular convention. It is mostly up to the developer's choice what kind of packages he/she is going to use to shape the application.
Using TypeScript makes setting up an Angular 2 application somehow tedious, as it introduces extra overhead for configuration.
To get a clearer comparison between React and Angular 2's code strucures, we are going to compare how a basic TODO application is built (example apps built by Mark Volkmann (mvolkmann).
Both applications use Webpack for development and deployment.
In terms of application structure, both React and Angular 2 need two files - TodoList which represents the list of tasks and Todo which represents a single task.
I've spotted the key differences between the tools using comments.
// Used for type of state property in TodoListCmp class.
// the code more maintainable.
// under consideration to be included in ES2016.
template:`  ` /*This is where the markup for the template can be put.
super(); // must call before accessing "this"
As seen above, the creation process is quite similar for both tools, but React's is slightly shorter and appears to need less developer logic.
(t: ITodo) => t.id === id ?
//An Angular module can import functionalities from other modules and export some of its building blocks to other modules.
//The module is bootstrapped, making the bootstrapped component the root //of the application if no routes are defined.
// inside a specified DOM element.
// easy comparison with the React render method.
This uses a for loop to generate TodoCmps.
#todo defines a variable to use within the loop.
[todo] sets a property on each TodoCmp.
on TodoListCmp with emitted values.
deleteTodo receives a type of number.
toggleDone receives a type of ITodo.
<todo *ngFor="let todo of state.todos" [todo]="todo"
// to a variable and refer to it later.
Angular 2 uses @Component decorators to specify the different constructs (services, directives, pipes) that it contains and to define its own properties. It also lets the developer specify a selector for the component and put the code for the template using the template property or the templateUrl if a separate file is used. The same applies for styles - there is an option to input styles directly using the styles property or to include an array of files using styleUrls. React does not have an analog for a component decorator and requires the template of the component to be included in the component file itself, thus limiting the options for customization and making the information about a component harder to interpret.
* denotes a directive that manipulates the DOM. For example, *ngFor iterates over an array of values and creates a new element for each. *ngIf is used to denote whether an element can be seen or not.
 denotes a property binding, indicating that the element receives a value from the component. It is used mostly to pass data to a child component to the parent.
() indicates an event binding (such as (click), which triggers a function in the components.
[()] indicates two-way binding, meaning that any changes to the data that are passed will be propagated.
// initialization values from the containing component.
// publish values to the containing component.
// There are three ways to define React components.
// which only receives data through "props".
// Optional validation of props object.
Because it is the main building block of a React application, the component offers greater flexibility in the way it can be structured. Stateless components are built with one-directional data flow in mind, leaving the majority of the logic to stay outside of the component itself. Angular 2 also offers similar functionality, but it does it with more complexity.
Angular 2 is using the standard bi-directional data flow model. Once an action is made, the data goes up to the service layer, then it goes back to the view. This way of manipulating data has been widely criticised because the state of the data can be changed both ways, resulting in inconsistencies.
React uses Flux to construct its applications. Each action is sent to a dispatcher, which sends the new information to stores. The stores then update (mutate) the information and send it down to the views (controller-views), which listen for changes.
Redux is the cool kid on the block. Like Flux, it is based on one-directional data flow, but it manages the data in a different way.
An application that uses Redux has a global state that is shared among the whole application. When an action is made, it is sent to a dispatcher, which serves to make a HTTP call to the API. Then, the changes are sent to reducers - pure functions that specialize in managing a part of the global application state. For example, if your application has users, projects and items as models, each of the models will be part of the global state and there will be a set of reducers that take care of managing their state. Once the state is 'mutated' by the reducers, the new information is sent down to the view.
In this way, state of the application is kept in one place, providing for an easier state management.
Redux was first introduced for React as an alternative to simplify Flux. Because of that, Redux is more widely adopted in the React community.
Recently, Angular 2 has started adopting the Redux pattern for data flow by utilizing rxjs's observables to maintain the state of the data and using pure functions to manipulate it. Attemps have been made to build unidirectional data flow in Angular 2 applications, but the adoption of this technique is still low.
Performance is another critical point of comparison. It shows how Angular 2 and React handle under heavy load and gives predictions for future problems as the applications become bulkier and more difficult to optimize.
Both Angular 2 and React are seem on par, with Angular 2 having a slight advantage on all DOM manipulations except for creating new elements.
In terms of memory management, React outperforms Angular 2 by using less memory, especially after page load. This is mainly due to the fact that React itself is smaller-sized than Angular 2.
The cross-platform development world has made a huge leaps since the massive adoption of mobile devices. Now, WebView-based tools for building cross-platform mobile applications are obsolete.
NativeScript, built by Telerik (now Progress), is intended to enable native mobile applications to be built with Angular 2. Even though it has only 8k stars on Github, NativeScript is mature and comes with great documentation and numerous extensions. It preaches a "write once, run everywhere" methodology of developing cross-platform applications. Even though this is an efficient approach, it does not enable devleopers to use many platform-specific UI features.
On the other hand, React Native, developed by Facebook, gives React native capabilities. Compared to NativeScript, React Native is still young but quite popular and maturing quickly, boasting over 37k stars on GitHub. React Native uses a "learn once, write anywhere" approach to developing cross-platform applications. Instead of attempting to generalize different platforms like NativeScript does, Rect Native embraces their differences, offering different ways to construct UI for the different platforms. Recently, the Angular 2 team has started adopting React Native, making a renderer for it.
React, on the other hand, is over 53K stars on Github. There are 95, 500 repositories containing the word "react" in them, roughly over nine times more than what Angular 2 has.
Still, one of the big reasons for the large number of repositories is that React comes with just a few built-in functionalities and relies on its community to provide it with the needed tooling to develop full-scale applications.
Both Angular 2 and React have large communities and boast corporate backing. Even though they have different philosophies to how an application development must be approached, there is a place for both of them in the software development world.


text:
Q: Set 'Artist' name in iTunes Connect on registration? This question isn't really a programming question, so it doesn't exactly belong on Stack Overflow, so I apologise for that in advance, but there seem to be many questions like this round here, as there are many iPhone devs around here...

Is there anyone who has recently (like within the last 3 months) registered an Individual Apple Developer account? When you first logged into iTunes Connect, did it provide you with the opportunity to set the artist or 'company' name that appears above your app in the store (in search results, etc.), that isn't your legal name?

EDIT
Previously with an individual account, your legal name appeared as the seller, however, you could set any name you wished to appear as the company name, but you could not change it afterwards. However, as corban said below, it is now apparently not possible to set a company name for an individual account, so if you want a company name, you will have to register a company account (and do all the related legal crap).

A: Yes, even with an individual account you are allowed to set a company/artist name when you create your first app in itunesconnect. This can be different from your legal name.
The legal name (with which you registered as a developer) comes up as the "Seller" of the app (below the app icon, in small print, in iTunes) whereas the artist/developer name is the name you enter in iTunesconnect and what shows up on the top in iTunes.

A: Apple has removed the possibility to add a company/artist name for an individual account. There are some discussions in the apple forums about that. I hope that there will be a possibility to add one.

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