title: Antisemitism in Christianity

text: Antisemitism in popular European Christian culture escalated beginning in the 13th century. Blood libels and host desecration drew popular attention and led to many cases of persecution against Jews. Many believed Jews poisoned wells to cause plagues. In the case of blood libel it was widely believed that the Jews would kill a child before Easter and needed Christian blood to bake matzo. Throughout history if a Christian child was murdered accusations of blood libel would arise no matter how small the Jewish population. The Church often added to the fire by portraying the dead child as a martyr who had been tortured and child had powers like Jesus was believed to. Sometimes the children were even made into Saints. Antisemitic imagery such as Judensau and Ecclesia et Synagoga recurred in Christian art and architecture. Anti-Jewish Easter holiday customs such as the Burning of Judas continue to present time.


title: Antisemitism in Christianity

text: During the Middle Ages in Europe persecutions and formal expulsions of Jews were liable to occur at intervals, although this was also the case for other minority communities, regardless of whether they were religious or ethnic. There were particular outbursts of riotous persecution during the Rhineland massacres of 1096 in Germany accompanying the lead-up to the First Crusade, many involving the crusaders as they travelled to the East. There were many local expulsions from cities by local rulers and city councils. In Germany the Holy Roman Emperor generally tried to restrain persecution, if only for economic reasons, but he was often unable to exert much influence. In the Edict of Expulsion, King Edward I expelled all the Jews from England in 1290 (only after ransoming some 3,000 among the most wealthy of them), on the accusation of usury and undermining loyalty to the dynasty. In 1306 there was a wave of persecution in France, and there were widespread Black Death Jewish persecutions as the Jews were blamed by many Christians for the plague, or spreading it. As late as 1519, the Imperial city of Regensburg took advantage of the recent death of Emperor Maximilian I to expel its 500 Jews.


title: Antisemitism in Christianity

text: The largest expulsion of Jews followed the Reconquista or the reunification of Spain, and it preceded the expulsion of the Muslims who would not convert, in spite of the protection of their religious rights promised by the Treaty of Granada (1491). On 31 March 1492 Ferdinand II of Aragon and Isabella I of Castile, the rulers of Spain who financed Christopher Columbus' voyage to the New World just a few months later in 1492, declared that all Jews in their territories should either convert to Christianity or leave the country. While some converted, many others left for Portugal, France, Italy (including the Papal States), Netherlands, Poland, the Ottoman Empire, and North Africa. Many of those who had fled to Portugal were later expelled by King Manuel in 1497 or left to avoid forced conversion and persecution.


title: Antisemitism in Christianity

text: On 14 July 1555, Pope Paul IV issued papal bull Cum nimis absurdum which revoked all the rights of the Jewish community and placed religious and economic restrictions on Jews in the Papal States, renewed anti-Jewish legislation and subjected Jews to various degradations and restrictions on their personal freedom.


title: Antisemitism in Christianity

text: The bull established the Roman Ghetto and required Jews of Rome, which had existed as a community since before Christian times and which numbered about 2,000 at the time, to live in it. The Ghetto was a walled quarter with three gates that were locked at night. Jews were also restricted to one synagogue per city.


title: Antisemitism in Christianity

text: Paul IV's successor, Pope Pius IV, enforced the creation of other ghettos in most Italian towns, and his successor, Pope Pius V, recommended them to other bordering states.


title: Antisemitism in Christianity

text: Martin Luther at first made overtures towards the Jews, believing that the "evils" of Catholicism had prevented their conversion to Christianity. When his call to convert to his version of Christianity was unsuccessful, he became hostile to them.


title: Antisemitism in Christianity

text: In his book "On the Jews and Their Lies", Luther excoriates them as "venomous beasts, vipers, disgusting scum, canders, devils incarnate." He provided detailed recommendations for a pogrom against them, calling for their permanent oppression and expulsion, writing "Their private houses must be destroyed and devastated, they could be lodged in stables. Let the magistrates burn their synagogues and let whatever escapes be covered with sand and mud. Let them be forced to work, and if this avails nothing, we will be compelled to expel them like dogs in order not to expose ourselves to incurring divine wrath and eternal damnation from the Jews and their lies." At one point he wrote: "...we are at fault in not slaying them..." a passage that "may be termed the first work of modern antisemitism, and a giant step forward on the road to the Holocaust."


title: Antisemitism in Christianity

text: Luther's harsh comments about the Jews are seen by many as a continuation of medieval Christian antisemitism. In his final sermon shortly before his death, however, Luther preached: "We want to treat them with Christian love and to pray for them, so that they might become converted and would receive the Lord."


title: Antisemitism in Christianity

text: In accordance with the anti-Jewish precepts of the Russian Orthodox Church, Russia's discriminatory policies towards Jews intensified when the partition of Poland in the 18th century resulted, for the first time in Russian history, in the possession of land with a large Jewish population. This land was designated as the Pale of Settlement from which Jews were forbidden to migrate into the interior of Russia. In 1772 Catherine II, the empress of Russia, forced the Jews living in the Pale of Settlement to stay in their "shtetls" and forbade them from returning to the towns that they occupied before the partition of Poland.


title: Antisemitism in Christianity

text: Throughout the 19th century and into the 20th, the Roman Catholic Church still incorporated strong antisemitic elements, despite increasing attempts to separate anti-Judaism (opposition to the Jewish religion on religious grounds) and racial antisemitism. Brown University historian David Kertzer, working from the Vatican archive, has argued in his book "The Popes Against the Jews" that in the 19th and early 20th centuries the Roman Catholic Church adhered to a distinction between "good antisemitism" and "bad antisemitism". The "bad" kind promoted hatred of Jews because of their descent. This was considered un-Christian because the Christian message was intended for all of humanity regardless of ethnicity; anyone could become a Christian. The "good" kind criticized alleged Jewish conspiracies to control newspapers, banks, and other institutions, to care only about accumulation of wealth, etc. Many Catholic bishops wrote articles criticizing Jews on such grounds, and, when they were accused of promoting hatred of Jews, they would remind people that they condemned the "bad" kind of antisemitism. Kertzer's work is not without critics. Scholar of Jewish-Christian relations Rabbi David G. Dalin, for example, criticized Kertzer in the "Weekly Standard" for using evidence selectively.


title: Antisemitism in Christianity

text: The counter-revolutionary Catholic royalist Louis de Bonald stands out among the earliest figures to explicitly call for the reversal of Jewish emancipation in the wake of the French Revolution. Bonald's attacks on the Jews are likely to have influenced Napoleon's decision to limit the civil rights of Alsatian Jews. Bonald's article "Sur les juifs" (1806) was one of the most venomous screeds of its era and furnished a paradigm which combined anti-liberalism, a defense of a rural society, traditional Christian antisemitism, and the identification of Jews with bankers and finance capital, which would in turn influence many subsequent right-wing reactionaries such as Roger Gougenot des Mousseaux, Charles Maurras, and Édouard Drumont, nationalists such as Maurice Barrès and Paolo Orano, and antisemitic socialists such as Alphonse Toussenel. Bonald furthermore declared that the Jews were an "alien" people, a "state within a state", and should be forced to wear a distinctive mark to more easily identify and discriminate against them.


title: Antisemitism in Christianity

text: In the 1840s, the popular counter-revolutionary Catholic journalist Louis Veuillot propagated Bonald's arguments against the Jewish "financial aristocracy" along with vicious attacks against the Talmud and the Jews as a "deicidal people" driven by hatred to "enslave" Christians. Gougenot des Mousseaux's "Le Juif, le judaïsme et la judaïsation des peuples chrétiens" (1869) has been called a "Bible of modern antisemitism" and was translated into German by Nazi ideologue Alfred Rosenberg. Between 1882 and 1886 alone, French priests published twenty antisemitic books blaming France's ills on the Jews and urging the government to consign them back to the ghettos, expel them, or hang them from the gallows.


title: Antisemitism in Christianity

text: In Italy the Jesuit priest Antonio Bresciani's highly popular novel 1850 novel "L'Ebreo di Verona" ("The Jew of Verona") shaped religious anti-Semitism for decades, as did his work for "La Civiltà Cattolica", which he helped launch.


title: Antisemitism in Christianity

text: Pope Pius VII (1800–1823) had the walls of the Jewish ghetto in Rome rebuilt after the Jews were emancipated by Napoleon, and Jews were restricted to the ghetto through the end of the Papal States in 1870. Official Catholic organizations, such as the Jesuits, banned candidates "who are descended from the Jewish race unless it is clear that their father, grandfather, and great-grandfather have belonged to the Catholic Church" until 1946.


title: Antisemitism in Christianity

text: In Russia, under the Tsarist regime, antisemitism intensified in the early years of the 20th century and was given official favour when the secret police forged the notorious "Protocols of the Elders of Zion", a document purported to be a transcription of a plan by Jewish elders to achieve global domination. Violence against the Jews in the Kishinev pogrom in 1903 was continued after the 1905 revolution by the activities of the Black Hundreds. The Beilis Trial of 1913 showed that it was possible to revive the blood libel accusation in Russia.


title: Antisemitism in Christianity

text: Catholic writers such as Ernest Jouin, who published the "Protocols" in French, seamlessly blended racial and religious anti-Semitism, as in his statement that "from the triple viewpoint of race, of nationality, and of religion, the Jew has become the enemy of humanity." Pope Pius XI praised Jouin for "combating our mortal [Jewish] enemy" and appointed him to high papal office as a protonotary apostolic.


title: Antisemitism in Christianity

text: In 1916, in the midst of the First World War, American Jews petitioned Pope Benedict XV on behalf of the Polish Jews.


title: Antisemitism in Christianity

text: “I have been attacked because of my handling of the Jewish question. The Catholic Church considered the Jews pestilent for fifteen hundred years, put them in ghettos, etc., because it recognized the Jews for what they were. In the epoch of liberalism the danger was no longer recognized. I am moving back toward the time in which a fifteen-hundred-year-long tradition was implemented. I do not set race over religion, but I recognize the representatives of this race as pestilent for the state and for the Church, and perhaps I am thereby doing Christianity a great service by pushing them out of schools and public functions.”


title: Antisemitism in Christianity

text: The transcript of the discussion does not contain any response by Bishop Berning. Martin Rhonheimer does not consider this unusual because in his opinion, for a Catholic Bishop in 1933 there was nothing particularly objectionable "in this historically correct reminder".


title: Antisemitism in Christianity

text: The Nazis used Martin Luther's book, "On the Jews and Their Lies" (1543), to justify their claim that their ideology was morally righteous. Luther even went so far as to advocate the murder of Jews who refused to convert to Christianity by writing that "we are at fault in not slaying them."


title: Antisemitism in Christianity

text: Archbishop Robert Runcie asserted that: "Without centuries of Christian antisemitism, Hitler's passionate hatred would never have been so fervently echoed... because for centuries Christians have held Jews collectively responsible for the death of Jesus. On Good Friday Jews, have in times past, cowered behind locked doors with fear of a Christian mob seeking 'revenge' for deicide. Without the poisoning of Christian minds through the centuries, the Holocaust is unthinkable." The dissident Catholic priest Hans Küng has written that "Nazi anti-Judaism was the work of godless, anti-Christian criminals. But it would not have been possible without the almost two thousand years' pre-history of 'Christian' anti-Judaism..." The consensus among historians is that Nazism as a whole was either unrelated or actively opposed to Christianity, and Hitler was strongly critical of it, although Germany remained mostly Christian during the Nazi era.


title: Antisemitism in Christianity

text: The document Dabru Emet was issued by over 220 rabbis and intellectuals from all branches of Judaism in 2000 as a statement about Jewish-Christian relations. This document states,


title: Antisemitism in Christianity

text: "Nazism was not a Christian phenomenon. Without the long history of Christian anti-Judaism and Christian violence against Jews, Nazi ideology could not have taken hold nor could it have been carried out. Too many Christians participated in, or were sympathetic to, Nazi atrocities against Jews. Other Christians did not protest sufficiently against these atrocities. But Nazism itself was not an inevitable outcome of Christianity."


title: Antisemitism in Christianity

text: According to American historian Lucy Dawidowicz, antisemitism has a long history within Christianity. The line of "antisemitic descent" from Luther, the author of "On the Jews and Their Lies", to Hitler is "easy to draw." In her "The War Against the Jews, 1933-1945", she contends that Luther and Hitler were obsessed by the "demonologized universe" inhabited by Jews. Dawidowicz writes that the similarities between Luther's anti-Jewish writings and modern antisemitism are no coincidence, because they derived from a common history of "Judenhass", which can be traced to Haman's advice to Ahasuerus. Although modern German antisemitism also has its roots in German nationalism and the liberal revolution of 1848, Christian antisemitism she writes is a foundation that was laid by the Roman Catholic Church and "upon which Luther built."


title: Antisemitism in Christianity

text: The Confessing Church was, in 1934, the first Christian opposition group. The Catholic Church officially condemned the Nazi theory of racism in Germany in 1937 with the encyclical ""Mit brennender Sorge"", signed by Pope Pius XI, and Cardinal Michael von Faulhaber led the Catholic opposition, preaching against racism.


title: Antisemitism in Christianity

text: Many individual Christian clergy and laypeople of all denominations had to pay for their opposition with their lives, including:


title: Antisemitism in Christianity

text: By the 1940s, few Christians were willing to publicly oppose Nazi policy, but many Christians secretly helped save the lives of Jews. There are many sections of Israel's Holocaust Remembrance Museum, Yad Vashem, which are dedicated to honoring these "Righteous Among the Nations".


title: Antisemitism in Christianity

text: Before he became Pope, Cardinal Pacelli addressed the International Eucharistic Congress in Budapest on 25–30 May 1938 during which he made reference to the Jews "whose lips curse [Christ] and whose hearts reject him even today"; at this time antisemitic laws were in the process of being formulated in Hungary.


title: Antisemitism in Christianity

text: The 1937 encyclical "Mit brennender Sorge" was issued by Pope Pius XI, but drafted by the future Pope Pius XII and read from the pulpits of all German Catholic churches, it condemned Nazi ideology and has been characterized by scholars as the "first great official public document to dare to confront and criticize Nazism" and "one of the greatest such condemnations ever issued by the Vatican."


title: Antisemitism in Christianity

text: In the summer of 1942, Pius explained to his college of Cardinals the reasons for the great gulf that existed between Jews and Christians at the theological level: ""Jerusalem has responded to His call and to His grace with the same rigid blindness and stubborn ingratitude that has led it along the path of guilt to the murder of God."" Historian Guido Knopp describes these comments of Pius as being ""incomprehensible"" at a time when ""Jerusalem was being murdered by the million"". This traditional adversarial relationship with Judaism would be reversed in "Nostra aetate", which was issued during the Second Vatican Council.


title: Antisemitism in Christianity

text: Prominent members of the Jewish community have contradicted the criticisms of Pius and spoke highly of his efforts to protect Jews. The Israeli historian Pinchas Lapide interviewed war survivors and concluded that Pius XII "was instrumental in saving at least 700,000, but probably as many as 860,000 Jews from certain death at Nazi hands". Some historians dispute this estimate.


title: Antisemitism in Christianity

text: The Christian Identity movement, the Ku Klux Klan and other White supremacist groups have expressed antisemitic views. They claim that their antisemitism is based on purported Jewish control of the media, control of international banks, involvement in radical left-wing politics, and the Jews' promotion of multiculturalism, anti-Christian groups, liberalism and perverse organizations. They rebuke charges of racism by claiming that Jews who share their views maintain membership in their organizations. A racial belief which is common among these groups, but not universal among them, is an alternative history doctrine concerning the descendants of the Lost Tribes of Israel. In some of its forms, this doctrine absolutely denies the view that modern Jews have any ethnic connection to the Israel of the Bible. Instead, according to extreme forms of this doctrine, the true Israelites and the true humans are the members of the Adamic (white) race. These groups are often rejected and they are not even considered Christian groups by mainstream Christian denominations and the vast majority of Christians around the world.


title: Antisemitism in Christianity

text: Antisemitism remains a substantial problem in Europe and to a greater or lesser degree, it also exists in many other nations, including Eastern Europe and the former Soviet Union, and tensions between some Muslim immigrants and Jews have increased across Europe. The US State Department reports that antisemitism has increased dramatically in Europe and Eurasia since 2000.


title: Antisemitism in Christianity

text: While it has been on the decline since the 1940s, a measurable amount of antisemitism still exists in the United States, although acts of violence are rare. For example, the influential Evangelical preacher Billy Graham and the then-president Richard Nixon were caught on tape in the early 1970s while they were discussing matters like how to address the Jews' control of the American media. This belief in Jewish conspiracies and domination of the media was similar to those of Graham's former mentors: William Bell Riley chose Graham to succeed him as the second president of Northwestern Bible and Missionary Training School and evangelist Mordecai Ham led the meetings where Graham first believed in Christ. Both held strongly antisemitic views. The 2001 survey by the Anti-Defamation League reported 1432 acts of antisemitism in the United States that year. The figure included 877 acts of harassment, including verbal intimidation, threats and physical assaults. A minority of American churches engage in anti-Israel activism, including support for the controversial BDS (Boycott, Divestment and Sanctions) movement. While not directly indicative of anti-semitism, this activism often conflates the Israeli government's treatment of Palestinians with that of Jesus, thereby promoting the anti-semitic doctrine of Jewish guilt. Many Christian Zionists are also accused of anti-semitism, such as John Hagee, who argued that the Jews brought the Holocaust upon themselves by angering God.


title: Antisemitism in Christianity

text: Relations between Jews and Christians have dramatically improved since the 20th century. According to a global poll which was conducted in 2014 by the Anti-Defamation League, a Jewish group which is devoted to fighting antisemitism and other forms of racism, data was collected from 102 countries with regard to their population's attitudes towards Jews and it revealed that only 24% of the world's Christians held views which were considered antisemitic according to the ADL's index, compared to 49% of the world's Muslims.


title: Antisemitism in Christianity

text: Many Christians do not consider anti-Judaism to be antisemitism. They regard anti-Judaism as a disagreement with the tenets of Judaism by religiously sincere people, while they regard antisemitism as an emotional bias or hatred which does not specifically target the religion of Judaism. Under this approach, anti-Judaism is not regarded as antisemitism because it does not involve actual hostility towards the Jewish people, instead, anti-Judaism only rejects the religious beliefs of Judaism.


title: Antisemitism in Christianity

text: Others believe that anti-Judaism is rejection of Judaism as a religion or opposition to Judaism's beliefs and practices "essentially because" of their source in Judaism or because a belief or practice is associated with the Jewish people. (But see supersessionism)


title: Antisemitism in Christianity

text: The position that "Christian theological anti-Judaism is a phenomenon which is distinct from modern antisemitism, which is rooted in economic and racial thought, so that Christian teachings should not be held responsible for antisemitism" has been articulated, among other people, by Pope John Paul II in 'We Remember: A Reflection on the Shoah,' and the Jewish declaration on Christianity, Dabru Emet. Several scholars, including Susannah Heschel, Gavin I Langmuir and Uriel Tal have challenged this position, by arguing that anti-Judaism directly led to modern antisemitism.


title: Antisemitism in Christianity

text: Although some Christians did consider anti-Judaism to be contrary to Christian teaching in the past, this view was not widely expressed by Christian leaders and lay people. In many cases, the practical tolerance towards the Jewish religion and Jews prevailed. Some Christian groups condemned verbal anti-Judaism, particularly in their early years.


title: Antisemitism in Christianity

text: Some Jewish organizations have denounced evangelistic and missionary activities which specifically target Jews by labeling them antisemitic.


title: Antisemitism in Christianity

text: The Southern Baptist Convention (SBC), the largest Protestant Christian denomination in the U.S., has explicitly rejected suggestions that it should back away from seeking to convert Jews, a position which critics have called antisemitic, but a position which Baptists believe is consistent with their view that salvation is solely found through faith in Christ. In 1996 the SBC approved a resolution calling for efforts to seek the conversion of Jews "as well as the salvation of 'every kindred and tongue and people and nation.'"


title: Antisemitism in Christianity

text: Most Evangelicals agree with the SBC's position, and some of them also support efforts which specifically seek the Jews' conversion. Additionally, these Evangelical groups are among the most pro-Israel groups. ("For more information, see Christian Zionism".) One controversial group which has received a considerable amount of support from some Evangelical churches is Jews for Jesus, which claims that Jews can "complete" their Jewish faith by accepting Jesus as the Messiah.


title: Antisemitism in Christianity

text: The Presbyterian Church (USA), the United Methodist Church, and the United Church of Canada have ended their efforts to convert Jews. While Anglicans do not, as a rule, seek converts from other Christian denominations, the General Synod has affirmed that "the good news of salvation in Jesus Christ is for all and must be shared with all including people from other faiths or of no faith and that to do anything else would be to institutionalize discrimination".


title: Antisemitism in Christianity

text: The Roman Catholic Church formerly operated religious congregations which specifically aimed to convert Jews. Some of these congregations were actually founded by Jewish converts, like the Congregation of Our Lady of Sion, whose members were nuns and ordained priests. Many Catholic saints were specifically noted for their missionary zeal to convert Jews, such as Vincent Ferrer. After the Second Vatican Council, many missionary orders which aimed to convert Jews to Christianity no longer actively sought to missionize (or proselytize) them. However, Traditionalist Roman Catholic groups, congregations and clergymen continue to advocate the missionizing of Jews according to traditional patterns, sometimes with success ("e.g.", the Society of St. Pius X which has notable Jewish converts among its faithful, many of whom have become traditionalist priests).


title: Antisemitism in Christianity

text: The Church's Ministry Among Jewish People (CMJ) is one of the ten official mission agencies of the Church of England. The Society for Distributing Hebrew Scriptures is another organisation, but it is not affiliated with the established Church.


title: Antisemitism in Christianity

text: There are several prophecies concerning the conversion of the Jewish people to Christianity in the scriptures of the Church of Jesus Christ of Latter-day Saints (LDS). The Book of Mormon teaches that the Jewish people need to believe in Jesus to be gathered to Israel. The Doctrine & Covenants teaches that the Jewish people will be converted to Christianity during the second coming when Jesus appears to them and shows them his wounds. It teaches that if the Jewish people do not convert to Christianity, then the world would be cursed. Early LDS prophets, such as Brigham Young and Wildord Woodruff, taught that Jewish people could not be truly converted because of the curse which resulted from Jewish deicide. However, after the establishment of the state of Israel, many LDS members felt that it was time for the Jewish people to start converting to Mormonism. During the 1950s, the LDS Church established several missions which specifically targeted Jewish people in several cities in the United States. After the LDS church began to give the priesthood to all males regardless of race in 1978, it also started to deemphasize the importance of race with regard to conversion. This led to a void of doctrinal teachings that resulted in a spectrum of views in how LDS members interpret scripture and previous teachings. According to research which was conducted by Armand Mauss, most LDS members believe that the Jewish people will need to be converted to Christianity in order to be forgiven for the crucifixion of Jesus Christ.


title: Antisemitism in Christianity

text: The Church of Jesus Christ of Latter-day Saints has also been criticized for baptizing deceased Jewish Holocaust victims. In 1995, in part as a result of public pressure, church leaders promised to put new policies into place that would help the church to end the practice, unless it was specifically requested or approved by the surviving spouses, children or parents of the victims. However, the practice has continued, including the baptism of the parents of Holocaust survivor and Jewish rights advocate Simon Wiesenthal.


title: Antisemitism in Christianity

text: In recent years, there has been much to note in the way of reconciliation between some Christian groups and the Jews.


title: Role model

text: A role model is a person whose behaviour, example, or success is or can be emulated by others, especially by younger people. The term "role model" is credited to sociologist Robert K. Merton, who hypothesized that individuals compare themselves with reference groups of people who occupy the social role to which the individual aspires., an example of which is the way young fans may idolize and imitate professional athletes or entertainment artists.


title: Role model

text: In the second half of the twentieth century, U.S. advocates for workplace equity popularized the term and concept of role models as part of a larger social capital lexicon—which also includes terms such as glass ceiling, networking, mentoring, and gatekeeper—serving to identify and address the problems barring non-dominant groups from professional success. Mainstream business literature subsequently adopted the terms and concepts, promoting them as pathways to success for all career climbers. In 1970 these terms were not in the general American vocabulary; by the mid-1990s they had become part of everyday speech. Although the term "role model" has been criticized more recently as "outdated", the term and its associated responsibility remains prominent in the public consciousness as a commonly used phrase, and a "powerful presence" in the entertainment industry and media.


title: Role model

text: Role models can also be national, for example, Chilean politicians and intellectuals had France as the prime role model during much of the 19th century until they shifted to Germany in the last decades of the century. In short, a role model is a person looked to by others as an example to be imitated.


title: Role model

text: According to historian Pamela Laird, a person's chosen role models may have a considerable impact on his or her career opportunities and choices. The suitability of a role model depends, in part, on the admirer’s perceived commonality with the model, who should provide an image of an ambitious yet realistic goal. For example, Laird suggests that, Benjamin Franklin served as the role model for countless nineteenth-century white businessmen, including notables such as Thomas Mellon, B.F. Goodrich, and Frederick Weyerhäuser. Laird suggests that the lack of commonalities between potential role models and would-be admirers helped perpetuate barriers to American minorities and women as they tried to advance in a business world dominated by white men, thus spurring late twentieth-century efforts to develop suitable role models for these groups.


title: Role model

text: Parent role models also significantly influence a person's "education and training aspirations, task self-efficacy, and expectancy for an entrepreneurial career".


title: Role model

text: The ever-widening reach of the media in popular culture has elevated certain celebrities to worldwide acclaim. This boom of media coverage and constant exposure to these individuals resulted in a change of mindset toward celebrities in both adults and youth alike. According to a survey of teachers in the United Kingdom conducted in 2008 by the Association of Teachers and Lecturers, young people most frequently chose sports stars as role models, followed by pop stars. Many, however, simply aspired to be "famous for being famous", believing that fame and fortune could be easily accessed through reality television.


title: Role model

text: According to Rita Pierson, teachers, because of the large amount of time spent with children, have such a huge impact on children that they're being advised to be likeable in order to build strong emotional relationships with children.


title: Role model

text: There is significant discussion as to whether athletes should be considered role models. Some athletes have been asked to behave as if they were role models for their local communities, and some such as Hank Greenberg have deliberately tried to set a good example but generally regarding athletes as role models has been criticised due to their appointment often being based solely on sporting ability rather than any morality – it has been suggested that the discipline and control shown continuously by sportspeople on the field leads to a belief from viewers that these same qualities are continuously shown off the field. These and other factors such as the elements of competition, excitement and success are what make people want to emulate them.


title: Role model

text: Charles Barkley has stated that he believes athletes are not the figures that children should be emulating and that it is the parent's responsibility to be role models, that the role is deliberately applied by the media out of jealousy in order to make life more difficult for sportspeople, and that it sets up the sportspeople as an unattainable target for most.


title: B. M. Hegde

text: Belle Monappa Hegde (born 18 August 1938) is a cardiologist, professor of medicine, and author. He was the Vice Chancellor of Manipal Academy of Higher Education from 1999 to 2003. He was awarded Padma Bhushan in 2010 and Padma Vibhushan in 2021. He has supported theories of homeopathy and quantum healing.


title: B. M. Hegde

text: Hegde was born on 18 August 1938 in Pangala near Udupi, Karnataka, India He obtained MBBS from Stanley Medical College, Madras in 1960 and later M.D. from King George Medical College, Lucknow


title: B. M. Hegde

text: Over a long career at Kasturba Medical College, Mangalore, Hegde served in various positions such as Professor, Principal and Dean. He was appointed the Vice Chancellor of Manipal Academy of Higher Education in 1999 and served till 2003. He was an Independent Director of Zydus Wellness. He also served as chairman of an expert committee of Bihar State Health Society


title: B. M. Hegde

text: He is the chairman of Mangaluru branch of Bharatiya Vidya Bhavan. He started a medical journal, Journal of the Science of Healing Outcomes and serves as its Editor-in-Chief. Hegde was a fellow of the National Academy of Medical Sciences till 2016.


title: B. M. Hegde

text: He has proposed that 'quantum healing' can bring sick persons back to normal, a concept widely regarded in the scientific community as pseudoscientific.


title: B. M. Hegde

text: In 2019, when Hegde was invited to deliver a lecture on "Sauce of Happiness" at the campus of Indian Institute of Technology, Madras, he was called a proponent of "pseudo-science and quackery" by a group of research scholars, who questioned his criticism of modern medicine and accused him of promoting unverified treatments for various ailments. Hegde said it showed "how much the protesters knew about science."


title: B. M. Hegde

text: Hegde has also written articles and given talks in support of homeopathy, regarded globally as a pseudoscience. Hegde argues that even if one thinks incorrectly that Homeopathy is a placebo, it is still important, as most modern medicine is worse than placebo.


title: Carlos Dengler

text: Carlos Andres Dengler (born April 23, 1974), previously known as Carlos D., is an American actor, musician, writer, and filmmaker, known as the former bass guitarist for American rock band Interpol. After departing the band in 2010, he began pursuing an acting career.


title: Carlos Dengler

text: Dengler was born on April 23, 1974, in Queens, New York, to a Colombian mother and a German father. He and his family lived there until his early teens, after which they relocated to Lawrenceville, New Jersey. Speaking to "Spin" magazine in 2005, Dengler described this move and the subsequent period as formative.


title: Carlos Dengler

text: While attending New York University (NYU) in 1997, he was approached by the guitarist Daniel Kessler after a class the two had enrolled in. Kessler had been looking for musicians to play with and assumed Dengler to be one based on the clothes he wore, a style Kessler described as "similar to the way he's dressed now". He was studying philosophy and history at the time and wanted to pursue a career as an academic but agreed to play with the then unformed band, eventually finding his place within the group.


title: Carlos Dengler

text: Dengler's trademark style is marked by grounded and stylized bass lines, strident staccato bursts, a clean tone brought about by his Fender Jazz Bass, and octave jumps, almost in a disco-like fashion. The low E string is lowered to D as the band writes many songs in the keys of D and B minor. One of his influences is the Joy Division/New Order bass guitarist Peter Hook and, like Hook, he also wears his bass guitar very low – often near knee level – and uses a pick to pluck the strings. Others of his biggest bass influences are Simon Gallup of The Cure and John Taylor of Duran Duran.


title: Carlos Dengler

text: In addition to bass guitar, Dengler played keyboards in the studio. Until the band started hiring touring musicians in support of their first album, "Turn on the Bright Lights", he played both instruments during live performances.


title: Carlos Dengler

text: He was a regular in the Lower East Side party scene and in 2005 "URB" magazine put him on the cover with a headline reading "Interpol + The Cult of Carlos D". Interviews tied in with the band's third album, "Our Love to Admire", in 2007, however, marked a change in Dengler's attitude. Quotes from the time hint at a growing dissatisfaction with touring and the band in general. He described his switch from leather corset-belts, slicked hair, gun-holster and combat boots to bolo tie, waist coat, his natural curls and mustache as freeing: "Everyone stopped recognizing me on the street. I forgot what it's like just to be a normal person. It felt so good."


title: Carlos Dengler

text: In May 2010, his departure was announced on the band's official website. The posting stated that he had participated in the writing and recording process for their fourth album but would not be going forward with any other Interpol related activities. A permanent replacement was not announced, only that multiple players would be taking his place on the 2010 tour.


title: Carlos Dengler

text: Three months after Dengler left Interpol, the band revealed that he actually disliked playing bass guitar. Drummer Sam Fogarino stated that Dengler had grown tired of the instrument and of touring, and that it was neither his first instrument nor his instrument of choice.


title: Carlos Dengler

text: The band chose not to officially replace Dengler, with David Pajo and later Brad Truax occupying the role of touring bass guitarist. For the writing and recording of Interpol's post-Dengler studio albums, Paul Banks occupies the role of bass guitarist. When asked if the band missed Dengler during a 2022 Reddit AMA, Banks stated: "He was difficult, but not too difficult. Total genius tbh."


title: Carlos Dengler

text: Dating back to his days at NYU, Dengler is a skilled club DJ. He stopped for a short time, but picked it up again and as Interpol's fame increased he started pulling in bigger crowds both at the band's after-parties and separate gigs in various cities. He was the first rock star to appear on the cover of the electronic and hip-hop centered "URB" magazine, in 2005. The article focused on his history and talent as a DJ, his thoughts on various scenes, personal style and his role as the face of the band. Dengler has remixed songs for B-side releases including VHS or Beta's "Night on Fire", Nine Inch Nails's "Every Day is Exactly the Same" alongside Sam Fog (Interpol bandmate Samuel Fogarino) and Interpol's own "Public Pervert". He also contributed the piece "Katya and Josh Ain't Havin' It" to the HBO Voyeur Project.


title: Carlos Dengler

text: After leaving Interpol in 2010, Dengler remained out of the public light for several years. In a 2015 interview, he stated that he had since completed a graduate degree in drama from the Tisch School of the Arts at NYU, and was pursuing acting professionally. In the time between "Antics" (2004) and "Our Love to Admire" (2007), Dengler took an interest in film composition and scoring. His work in this medium includes the short film "Golgotha", which he wrote, produced and scored, as well as "My Friends Told Me About You", in which he was a lead actor.


title: Carlos Dengler

text: In March 2016, Dengler was a guest musician with the 8G house band on "Late Night with Seth Meyers". Dengler also presented an autobiographical one-man show at the 2016 New York International Fringe Festival, "Homo Sapiens Interruptus", which focused on his interest in heavy metal and paleoanthropology.


title: Carlos Dengler

text: Dengler played his brother's black American Standard Fender Jazz Bass (which was used on "Turn on the Bright Lights", "Antics" and "Our Love to Admire") with the knobs removed ("Antics" era and beyond) and the pickguard changed from white to black early in the band's career. He was also seen playing a cream Jazz Bass on the "Late Show with David Letterman" in 2007. He never used any effects pedals, claiming "Our music is almost symphonic in nature, because the harmonic structures are defined by the union of two guitars and a bass, and sometimes keyboard as well. If I were to start freaking out with effects, it would create too much of a bass presence, or it would distract from the band's most important aspect-the unity of all those musical elements together."


title: Carlos Dengler

text: He also worked with a mixture of classic synthesizer and orchestral emulations to generate arrangements for Interpol and for his scores.


title: Jeffrey Lundgren

text: Jeffrey Don Lundgren (May 3, 1950 – October 24, 2006) was an American self-proclaimed prophet, cult leader, and mass murderer who, on April 17, 1989, killed a family of five in Kirtland, Ohio. Lundgren led a Latter Day Saint movement-based cult and interpreted scripture using an unconventional method that he described as "chiastic", which involved searching text for recurring patterns. He and several of his followers murdered the Avery family, fellow members of his cult, for which he was convicted and sentenced to death. Lundgren was executed in 2006.


title: Jeffrey Lundgren

text: Jeffrey Lundgren was born on May 3, 1950, in Independence, Missouri, and grew up as a member of the Reorganized Church of Jesus Christ of Latter Day Saints (RLDS Church). According to Lundgren, as well as some of his former neighbors, he was severely abused as a child, particularly by his father. Lundgren was, by most accounts, a loner when he was in middle and high school. He became an expert hunter when he began to spend time with his father as a teenager, becoming knowledgeable in the use and maintenance of firearms.


title: Jeffrey Lundgren

text: Lundgren enrolled at Central Missouri State University and spent time at a house that was specially built for RLDS youth. While at the house, he became friends with Alice Keeler and Keith Johnson. Keeler, who had also been abused by her father, quickly bonded with Lundgren, and the couple married in 1970. On December 2, 1970, the couple's first child, a boy, was born. By 1974, Keeler was pregnant for the second time.


title: Jeffrey Lundgren

text: Lundgren enlisted in the United States Navy the same year as his marriage. Prior to receiving an honorable discharge at the end of his first term of duty, he sought an early release arguing that his presence was necessary for the sustenance of his family. He was denied an early release for reasons that were non-necessary according to military recommendations. Lundgren received an honorable discharge days before his four-year enlistment was completed. His second son was born soon afterward.


title: Jeffrey Lundgren

text: Lundgren and his new family settled in San Diego, California, after his discharge, but economic problems forced the Lundgrens to move back to Missouri. In 1979, Keeler gave birth to a third child, a daughter. People close to the couple claim that Lundgren seemed frustrated by the family's money problems and generally tired of his wife; he allegedly became abusive after the birth of his daughter. According to hospital records, Keeler was hospitalized for a ruptured spleen, which may have been caused by Lundgren pushing her into a closet door handle. In 1980, the couple had their fourth child, another boy.


title: Jeffrey Lundgren

text: While Lundgren was living in a church-owned home in Kirtland, Ohio, he volunteered as a tour guide at the RLDS Church's historic Kirtland Temple next door. In this capacity, he began to teach the concept of "dividing the word", known as "chiastic interpretation" or "chiasmus", to interpret scriptures. Lundgren falsely claimed to have created this interpretative method. The foundation was that in everything created by God, the right side is a mirror image and, therefore, scripture had to be interpreted using that same method. Lundgren cited the Kirtland Temple as an example because the right side was a mirror image of the left side. To apply this concept to scripture, one takes a sentence from scripture; if the sentences before and after are consistent, the center sentence is the "truth"; when the sentences before and after conflict, the center sentence is a lie. These teachings of scriptural interpretations by Lundgren attracted followers. He claimed that he moved to Ohio because the word, is "chiastic". Lundgren was asked to leave the Kirtland house around 1987, and his job as tour guide was terminated due to suspicions of theft.


title: Jeffrey Lundgren

text: Lundgren and his family moved to a rented farmhouse located at 8671 Chardon Road on U.S. Route 6, east of Ohio State Route 306. At that time, some followers started to move into his new home. Among these followers were Kevin Currie, Richard Brand, Greg Winship, Sharon Bluntschly, Daniel Kraft, and Debbie Olivarez. Ronald and Susan Luff; Dennis and Tonya Patrick; and Dennis and Cheryl Avery maintained their own residences. Some of his followers had known Lundgren in Missouri, while others were drawn to Lundgren at the Kirtland Temple. While Lundgren was living at the farmhouse, he began to practice methods which were consistent with Robert Lifton's criteria for mind control. For example, cult members were forbidden to talk amongst themselves; doing so was a sin, called "murmuring". Lundgren would eavesdrop on cult members to cause them to believe that he could read their minds.


title: Jeffrey Lundgren

text: On April 23, 1988, a neighbor told Kirtland police officer Ron Andolsek that she suspected that a cult was living at the farmhouse, and that Lundgren's son warned the neighbor's children that the earth would open up and demons would emerge on May 15. On April 28, 1988, a former cult member, referred by the FBI, contacted Kirtland Police and reported a conspiracy by the cult to take over the Kirtland Temple. Kirtland's police chief, Dennis T. Yarborough, did not believe the informant's information and, on May 2, 1988, confronted Lundgren at Kirtland police station. When Lundgren left, Yarborough said that he "neutralized the situation" by warning Lundgren that there were complaints about gunfire on Lundgren's property. Lundgren went back to his followers and called off the temple takeover, planned for May 3, because he had purportedly spoken to a higher power. Kirtland police initiated surveillance of his residence and of church-owned properties. In September 1988, a second informant came forward. Officer Andolsek cultivated the informant and made contact with the FBI and the ATF. The FBI initiated a domestic terrorism investigation.


title: Jeffrey Lundgren

text: On October 10, 1988, the day that Lundgren was excommunicated from the RLDS Church, there was a thunderstorm at the south end of Kirtland. When the sun emerged, a large rainbow appeared to the east. Lundgren told his followers that the rainbow signified the opening of the "Seven Seals". Lundgren and his family soon abandoned the group, and he began to feel a call to teach the Bible in the way he understood it. He formed his own splinter group soon after, whose membership never exceeded twenty. This group was largely composed of conservative RLDS members who believed that God communicated through regular revelations, although some members admitted that they claimed to have revelations even when they did not. They were also opposed to more liberal rights for women in the RLDS Church, which contributed to their decision to join the new sect. Keeler told followers that she had once had a revelation that she would meet an important leader of the RLDS Church, concluding that this alleged revelation referred to Lundgren.


title: Jeffrey Lundgren

text: Lundgren began to offer Bible study sessions at his home. There, he would dominate the sessions, intimidate anyone who did not agree with his interpretations of scripture, and later encourage others to intimidate those who disagreed as well. Lundgren sought to convince his sect that he was God's last prophet. He asked for money from his supporters, some of whom would give him their life's savings, which often were calculated to be thousands of dollars. He then proclaimed he had received a call from God to move to Kirtland, where he and his supporters would soon witness the second coming of Christ on May 3 (Lundgren's birthday, no year specified) at the Kirtland Temple. Lundgren told his followers that it would be necessary to seize the Temple by force and hold it for the momentous event. The conspiracy involved burglarizing adjacent church-homes and committing murder as part of the takeover. He called the land around the temple "The Vineyards", which had to be "redeemed" or "cleansed" for him and his followers to take the temple.


title: Jeffrey Lundgren

text: By this time, seven of Lundgren's twelve followers had moved into his family's farmhouse. The remaining five were members of Dennis Avery's family. Lundgren felt that the Averys were committing a sin by not living in his house. Avery, who had sold his Missouri house in order for his family to move to Ohio, believed in and trusted Lundgren. Lundgren, however, considered Avery to be weak and, when he was no longer useful to Lundgren, he began talking about Avery behind his back. Lundgren often used Avery as a scapegoat for the sect's troubles, even though he was one of its biggest financial contributors. Avery decided to set apart a relatively small amount of money for his family's use, with a bank account. Once again, Lundgren considered this a sin because he wanted all of his followers' money to be given exclusively to him.


title: Jeffrey Lundgren

text: In time, Lundgren convinced his followers that they had to seize the temple, from which he had stolen about $40,000, and to kill anyone who stood in their way. He changed his mind, however, and started telling his followers that they had to kill a family of five instead if they wanted to see God. As punishment for their "disloyalty", he chose the Averys. At some point, he referred to the slaughter of the Avery family as "pruning the vineyard".


title: Jeffrey Lundgren

text: On April 10, 1989, Lundgren ordered two of his followers to dig a pit in the barn in anticipation of burying the Averys' bodies there. The expectation was that there could be five bodies buried in the pit. Lundgren told the rest of his followers, including the Averys, that they would go on a wilderness trip. On April 17, he rented a motel room and had dinner with all of his followers. He then called his group's men into his room. He questioned each as to their purpose in the action. All of the men assured Lundgren that they were with him in the sacrifice. Dennis Avery was not invited to the meeting in Lundgren's room.


title: Jeffrey Lundgren

text: According to followers' admissions, Lundgren later went inside the barn with a church member named Ron Luff, luring Avery into a place where the other men awaited by asking him for help with equipment for the camping trip. Luff attempted to render Avery unconscious with a stun gun, but due to a malfunction, a stun bullet struck Avery but failed to knock him out. Avery then was gagged and dragged to the place where Lundgren awaited. He was shot twice in the back, dying almost instantly. To mask the sound of the gun, a chainsaw was left running. Luff then told Avery's wife, Cheryl, that her husband needed help. She was gagged like her husband, but also had duct tape put over her eyes, and dragged to Lundgren. She was shot three times, twice in the breasts and once in the abdomen. Her body lay next to her husband's. The Averys' 15-year-old daughter, Trina, was shot twice in the head. The first shot entered but ricocheted off of her skull, missing her brain, but the second killed her instantly. Thirteen-year-old Becky Avery was shot twice and left to die, while six-year-old Karen Avery was shot in the chest and head.


title: Jeffrey Lundgren

text: The barn where the incident took place was demolished on November 13, 2007. The New Promise Church now stands on the property, which they bought for $350,000.


title: Jeffrey Lundgren

text: On April 18, 1989, the day after the murders, officers coincidentally came to Lundgren's farm to talk to him. After this encounter he became paranoid about being caught and left Ohio with the rest of his cult, moving south to West Virginia. As months went by and nothing happened, Lundgren became disillusioned, and he and his family moved to California, leaving the rest of the surviving cult members behind in West Virginia.


title: Jeffrey Lundgren

text: Nine months after the killings, on January 3, 1990, a tip from an informant led police back to the long-abandoned farm, where the five bodies of the Avery family were uncovered. The Lundgrens became fugitives, media attention increased, and police began to track the cult members, with the FBI joining in the manhunt. Eventually, Lundgren's abandoned followers were found back east and they helped catch him and his family. Thirteen members of Lundgren's sect were arrested in early 1990, including Lundgren and his wife.


title: Jeffrey Lundgren

text: Lundgren was given the death penalty. Alice received five life sentences (140 years to life) for conspiracy, complicity and kidnapping, while their son, Damon, was sentenced to 120 years to life. Luff, the key planner and facilitator of the murders with Lundgren, was sentenced to 170 years to life. Daniel Kraft was sentenced to 50 years to life. Five of the cult members were released in 2010 or early 2011, after roughly 20 years of incarceration (including pre-trial period). Prosecutor Charles Coulson confirmed that the original plea agreements meant that the five were to be eligible for release "at the earliest possible time", but the Ohio State Parole Board had repeatedly denied earlier requests for parole by Richard Brand and Greg Winship (both were serving 15 years to life), as well as Sharon Bluntschly, Debbie Olivarez and Susan Luff (all were serving 7 to 25 years). Lundgren followers Kathryn Johnson, Tonya Patrick and Dennis Patrick were determined not to have been involved in the murders, and each received a one-year sentence for obstruction of justice (the Patricks' sentences were suspended).


title: Jeffrey Lundgren

text: The Ohio Supreme Court set October 24, 2006, as Lundgren's execution date, and according to the state attorney general's office, as of August 2006, he had exhausted his appeals.


title: Jeffrey Lundgren

text: On October 17, 2006, Judge Gregory L. Frost issued an order temporarily delaying Lundgren's execution. Lundgren attempted to join a lawsuit with five other Ohio death row inmates challenging the state's death penalty law, claiming that due to his obesity, the lethal injection would be particularly painful and amount to cruel and unusual punishment. State Attorney General Jim Petro appealed to the United States Court of Appeals for the Sixth Circuit in Cincinnati. The 6th Circuit Court of Appeals issued an order allowing the execution to go forward. The U.S. Supreme Court refused a last-minute request to stop his execution, and Governor Bob Taft also denied clemency.


title: Jeffrey Lundgren

text: On October 24, 2006, Jeffrey Lundgren was executed at the Southern Ohio Correctional Facility in Lucasville. Nobody claimed his body, so he was buried in the prison cemetery.


title: Old Bushmills Distillery

text: The Old Bushmills Distillery is an alcohol (primarily Irish whiskey) distillery in Bushmills, County Antrim, Northern Ireland, owned by Casa Cuervo. Bushmills Distillery uses water drawn from Saint Columb's Rill, which is a tributary of the River Bush. The distillery is a popular tourist attraction, with around 120,000 visitors per year.


title: Old Bushmills Distillery

text: The company that originally built the distillery was formed in 1784, although the date 1608 is printed on the label of the brand – referring to an earlier date when a royal licence was granted to a local landowner to distil whiskey in the area. After various periods of closure in its subsequent history, the distillery has been in approximately continuous operation since it was rebuilt after a fire in 1885.


title: Old Bushmills Distillery

text: The area has a long tradition with distillation. According to one story, as far back as 1276, an early settler called Sir Robert Savage of Ards, before defeating the Irish in battle, fortified his troops with "a mighty drop of acqua vitae". In 1608, a licence was granted to Sir Thomas Phillips by King James I to distil whiskey.


title: Old Bushmills Distillery

text: for the next seven years, within the countie of Colrane, otherwise called O Cahanes countrey, or within the territorie called Rowte, in Co. Antrim, by himselfe or his servauntes, to make, drawe, and distil such and soe great quantities of aquavite, usquabagh and aqua composita, as he or his assignes shall thinke fitt; and the same to sell, vent, and dispose of to any persons, yeeldinge yerelie the somme 13s 4d ...


title: Old Bushmills Distillery

text: The Bushmills Old Distillery Company itself was not established until 1784 by Hugh Anderson. Bushmills suffered many lean years with numerous periods of closure with no record of the distillery being in operation in the official records both in 1802 and in 1822. In 1860 a Belfast spirit merchant named Jame McColgan and Patrick Corrigan bought the distillery; in 1880 they formed a limited company. In 1885, the original Bushmills buildings were destroyed by fire but the distillery was swiftly rebuilt. In 1890, a steamship owned and operated by the distillery, SS "Bushmills", made its maiden voyage across the Atlantic to deliver Bushmills whiskey to America. It called at Philadelphia and New York City before heading on to Singapore, Hong Kong, Shanghai and Yokohama.


title: Old Bushmills Distillery

text: In the early 20th century, the U.S. was a very important market for Bushmills (and other Irish Whiskey producers). American Prohibition in 1920 came as a large blow to the Irish Whiskey industry, but Bushmills managed to survive. Wilson Boyd, Bushmills' director at the time, predicted the end of prohibition and had large stores of whiskey ready to export. After the Second World War, the distillery was bought by Isaac Wolfson, and, in 1972, it was taken over by Irish Distillers, meaning that Irish Distillers controlled the production of all Irish whiskey at the time. In June 1988, Irish Distillers was bought by French liquor group Pernod Ricard.


title: Old Bushmills Distillery

text: In June 2005, the distillery was bought by Diageo for £200 million. Diageo have also announced a large advertising campaign in order to regain a market share for Bushmills.


title: Old Bushmills Distillery

text: In May 2008, the Bank of Ireland issued a new series of sterling banknotes in Northern Ireland which all feature an illustration of the Old Bushmills Distillery on the obverse side, replacing the previous notes series which depicted Queen's University of Belfast.


title: Old Bushmills Distillery

text: In November 2014 it was announced that Diageo had traded the Bushmills brand with Jose Cuervo in exchange for the 50% of the Don Julio brand of tequila that Diageo did not already own.


title: Old Bushmills Distillery

text: Some Bushmills offerings have performed well at international Spirit ratings competitions. In particular, its Black Bush Finest Blended Whiskey received double gold medals at the 2007 and 2010 San Francisco World Spirits Competitions. It also received a well-above-average score of 93 from the Beverage Testing Institute in 2008 and 2011.


title: Thali

text: Thali (meaning "plate"), Bhojanam (meaning "full meal") or Chakluk is a round platter used to serve food in South Asia, Southeast Asia (except Vietnam) and the Caribbean. Thali is also used to refer to an Indian-style meal made up of a selection of various dishes which are served on a platter.


title: Thali

text: As noted by the Indian National Trust for Art and Cultural Heritage, the earliest evidence of use of continuity in cooking and food habits of India can be established by the existence of tandoor (cooking oven), thali, lotas and chakla-belan for making chapatis found in excavations at Indus Valley civilization site of Kalibangan (3500 BCE – 2500 BCE).


title: Thali

text: "Thali" refers to the metal plate that a thali meal may be served on, while "Bhojanam" refers to full meals. Thali is popular method of serving meals in South Asia. The idea behind a thali is to offer all the 6 different flavours of sweet, salt, bitter, sour, astringent and spicy on one single plate (technically the last two are actually forms of chemesthesis rather than true flavours). According to Indian food custom, a proper meal should be a perfect balance of all these six flavours. Restaurants typically offer a choice of vegetarian or meat-based thalis. Vegetarian bhojanams are very typical and commonplace in Tamil Nadu canteens


title: Thali

text: Dishes served in a thali vary from region to region in the Indian subcontinent and are usually served in small bowls, called "katori" in India. These katoris are placed along the edge of the round tray, the actual thali; sometimes a steel tray with multiple compartments is used. Typical dishes include rice, dal, vegetables, roti, papad, dahi (yogurt), small amounts of chutney or pickle, and a sweet dish to top it off. Rice or roti is the usual main dish that occupies the central portion of the thali, while side dishes like vegetable curries and other aforementioned delicacies are lined circularly along the round thali. Depending on the restaurant or the region, the thali consists of delicacies native to that region. In general, a thali begins with different types of breads such as puris or chapatis (rotis) and different vegetarian specialities (curries). However, in South India and Southeast Asia, rice is the only staple served with bhojanams. Thalis or Bhojanams are sometimes referred to by the regional characteristic of the dishes they contain. For example, one may encounter Andhra bhojanam, Nepalese thali, Rajasthani thali, Gujarati thali, Maharashtrian thali, Manipuri chakluk, Tamil unavu and Thai unavu. In many parts of South Asia, Southeast Asia and the Caribbean, the bread and the rice portions are not served together in the thali. Typically, the bread is offered first with rice being served afterwards, often in a separate bowl or dish.


title: Thali

text: The Economic Survey of India 2020 has a section called "Thalinomics" which shows an increase in affordability of a vegetable 'thali' by 29% and by non-vegetarian by 18% during 2006–07 to 2019–20.


National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), was a landmark United States Supreme Court decision in which the Court upheld Congress's power to enact most provisions of the Patient Protection and Affordable Care Act (ACA), commonly called Obamacare, and the Health Care and Education Reconciliation Act (HCERA), including a requirement for most Americans to pay a penalty for forgoing health insurance by 2014. The Acts represented a major set of changes to the American health care system that had been the subject of highly contentious debate, largely divided on political party lines.


title: National Federation of Independent Business v. Sebelius

text: The Supreme Court, in an opinion written by the Chief Justice, John Roberts, upheld by a vote of 5–4 the individual mandate to buy health insurance as a constitutional exercise of Congress's Taxing and Spending Clause (taxing power). A majority of the justices, including Roberts, agreed that the individual mandate was not a proper use of Congress's Commerce Clause or Necessary and Proper Clause powers, although they did not join in a single opinion. A majority of the justices also agreed that another challenged provision of the Act, a significant expansion of Medicaid, was not a valid exercise of Congress's spending power, as it would coerce states to either accept the expansion or risk losing existing Medicaid funding.


text: In March 2010, President Barack Obama signed the Patient Protection and Affordable Care Act into law. A number of parties sued, including the National Federation of Independent Business, claiming that the sweeping reform law was unconstitutional for various reasons. The Supreme Court granted certiorari to three cases, totaling 5½ hours of oral arguments: "National Federation of Independent Business v. Sebelius" (which consolidated a part of "Florida v. Dept. of Health and Human Services") on the issues of the constitutionality of the individual mandate and the severability of any unconstitutional provisions, "Dept. of Health and Human Services v. Florida" on the issue of whether review was barred by the Anti-Injunction Act, and "Florida v. Dept. of Health and Human Services" on the matter of the constitutionality of the Medicaid expansion.


text: The state of Florida filed a lawsuit against the United States Department of Health and Human Services, challenging the constitutionality of the law. On January 31, 2011, Judge Roger Vinson ruled that the mandatory health insurance "individual mandate"—the provision of Internal Revenue Code section 5000A imposing a "shared responsibility penalty" on nearly all Americans who fail to purchase health insurance—was outside the power of Congress. Vinson also held that the mandate could not be severed from the rest of the Affordable Care Act and struck down the entire act.


text: The Department of Health and Human Services appealed to the 11th Circuit Court of Appeals. A three-judge panel issued a 2–1 ruling affirming Vinson's findings in part and reversing in part. The court affirmed the District Court's holding that the individual mandate was unconstitutional, but, contrary to the District Court's view, it held that the individual mandate could be severed, leaving the rest of the law intact. The government decided to not seek "en banc" review from the full Circuit and instead petitioned the United States Supreme Court to review the Eleventh Circuit's rulings.


text: Other federal courts heard cases related to the Affordable Care Act that were not directly reviewed by the Supreme Court, but caused a divide regarding the law's constitutionality. Two federal judges appointed by President Bill Clinton upheld the individual mandate in 2010. Judge Jeffrey Sutton, a member of the Sixth Circuit Court of Appeals appointed by George W. Bush, was the first Republican-appointed judge to rule that the law is constitutional in June 2011, as part of a divided three-judge panel that upheld the law.


text: On November 14, 2011, the Supreme Court granted certiorari to portions of three cross-appeals of the Eleventh Circuit's opinion: one by the states ("Florida v. U.S. Dept. of Health and Human Svcs."), one by the federal government ("U.S. Dept. of Health and Human Svcs. v. Florida"), and one by the National Federation of Independent Business ("Nat'l Fed. of Independent Bus. v. Sebelius").


text: The Court announced in December 2011 that it would hear approximately six hours of oral argumentation over a three-day period, from March 26 to March 28, 2012, covering the various aspects being questioned by the principal parties involved in this and other related cases concerning the ACA.


text: The court first heard argument on whether the Anti-Injunction Act, which limits suits "for the purpose of restraining the assessment or collection of any tax", barred a decision before the ACA fully entered into force in 2014. Since neither the government, represented by Solicitor General Donald Verrilli, nor the states, represented that day by Gregory G. Katsas of the law firm Jones Day, were willing to defend that position (which had been accepted by three of the 12 appellate court judges who heard the cases), the Court appointed Robert Long of the law firm Covington & Burling as "amicus curiae" to defend that position.


text: On the second day, the court heard arguments over whether the ACA's "individual mandate" fell under the constitutional powers of Congress. The states (Florida et al.) were represented during the hearings by former Bush administration Solicitor General Paul Clement while the government was represented by current Solicitor General Donald Verrilli. Tom Goldstein of SCOTUSblog, while acknowledging that Verrilli had an initial stumble, called Verrilli's performance "tremendous", but also said that Clement's performance was "the best argument I've ever heard".


text: On the morning of the third day, the Court considered the issue of severability—whether the ACA could survive if the Court struck down the individual mandate. Paul Clement, Deputy Solicitor General Edwin Kneedler, and Court-appointed "amicus curiae" H. Bartow Farr, III of the law firm Farr & Taranto argued their various positions before the Court.


text: On the afternoon of the third day, the Court considered whether the Medicaid expansion the ACA instituted was coercive. Both Clement and Verrilli again argued before the Court. Chief Justice Roberts extended the time limit for both parties by 15 minutes during the arguments.


text: The case generated a complex division on the bench. With respect to the Tax Anti-Injunction Act and individual mandate penalty, judgment was for the U.S. Secretary of Health and Human Services. With respect to the Medicaid expansion, judgment was for the challenging states.


text: Roberts authored an opinion, of which three parts gained the assent of five justices (Roberts, Ginsburg, Breyer, Sotomayor, and Kagan) and became the opinion of the Court, and one part gained the assent of a plurality (Roberts, Breyer, and Kagan) and became part of the holding. Those parts of Roberts's opinion that gained the assent of five justices were Parts I, II, and III-C. Part I recounted the facts and procedural history of the cases. Part II concerned the applicability of the Anti-Injunction Act to the individual mandate penalty. Part III-C held that, for constitutional purposes, the individual mandate penalty was a valid exercise of Congress's taxing power.


text: The Anti-Injunction Act prohibits federal courts from enjoining agencies of the federal government from collecting a tax while a challenge to the tax is pending. Congress's motivation in passing the act was to prevent the starvation of the federal treasury while tax issues are being litigated before the courts. Instead, Congress requires a taxpayer who challenges any tax to first pay that tax, and only afterwards is the taxpayer allowed to bring suit and seek a refund. Challengers of the Affordable Care Act maintained that the individual mandate's enforcement mechanism was not a tax. The Court agreed. Because the ACA calls the individual mandate's shared responsibility payment a "penalty" instead of a "tax", it prevents the penalty from being treated as a tax under the Anti-Injunction Act.


text: Taking a functional view to the individual mandate penalty, the Court held that it was a tax for constitutional purposes. The Court noted that the label of the individual mandate shared responsibility payment as a penalty for the purposes of the Anti-Injunction Act did not control whether it was a tax for purposes of constitutional analysis. The Court asserted that the individual mandate penalty, in practical operation, exhibited all the characteristics of a tax—the penalty "looks like a tax in many respects." That is, the individual mandate penalty had all of the following features of a tax:


text: Neither did the penalty's operation as a tax run afoul of even "our narrowest interpretations of the taxing power", which disallows punitive taxation:


text: Moreover, adhering to prior precedent, the Court reasoned the tax imposed by the individual mandate penalty is not a direct tax ("i.e.", it is not a capitation or poll tax, nor a tax on real estate) and consequently does not require apportionment: "[a] tax on going without health insurance does not fall within any recognized category of direct tax. ... The shared responsibility payment is thus not a direct tax that must be apportioned among the several States." Even where one views an individual's decision to self-insure as economic inactivity, the safety that such an omission to act provides from Congress's commerce power does not similarly apply to taxation. The Court provided three reasons that Congress's use of its taxing power in this manner was not troubling:


text: As stated above, seven justices agreed in judgment for the states against the Department of Health and Human Services on the issue of the Medicaid expansion, but no opinion among them obtained the assent of five justices. At issue were amendments to the Social Security Act contained in Title X of the Affordable Care Act. These amendments, in expanding Medicaid coverage, made changes to the plan requirements states must meet in their Medicaid plans. The 1965 amendments to the Social Security Act that created Medicaid authorized the Secretary of Health and Human Services to withhold federal payments to state Medicaid plans that were not in compliance with statutory requirements.


text: The seven justices were in agreement that the Secretary's existing ability to withhold all funds from noncompliant plans, coupled with the substantial coverage changes enacted by the Title X amendments, amounted to an unconstitutionally coercive use of Congress's spending power, given that Congress was not going to cover the full cost of the Medicaid expansion after 2016. Where the justices differed was in what they thought constituted the appropriate remedy. Four (Scalia, Kennedy, Thomas, and Alito) believed the Title X amendments should be struck down due to their impermissibly coercive nature. The remaining three (Roberts, Breyer, and Kagan) instead opted to exercise the existing severability clause (codified at 42 USC §1303) in the Social Security Act, as amended, holding that the ability given to the Secretary by statute to withhold federal payments could not be applied to the Title X amendments for those states refusing to participate in the Medicaid expansion. Since this latter opinion concurred in the judgment on the narrowest ground ("i.e.", severing only part of the application of the law instead of striking all of the amendments), the three-justice plurality became the controlling opinion under the rule set out by "Marks v. United States" (1977).


text: Writing only for himself, Roberts would hold that the individual mandate penalty exceeded both Congress's commerce power and its Necessary and Proper Clause power. In part III-A of his opinion, he argued that Congress's authority under the Commerce Clause necessarily presupposes activity already exists for Congress to regulate, but the individual mandate seeks to compel activity in order to then regulate it. Such compulsion represents a "new and potentially vast domain to congressional authority" well beyond even the "most far reaching" extent of authority allowed under the precedent of "Wickard v. Filburn". In Roberts's view, such a view of the commerce power would fundamentally change the relationship between the federal government and the individual; while Congress may anticipate the effects of activity on commerce, it has never been allowed to anticipate economic activity by those not engaging in commercial acts. "The Commerce Clause is not a general license to regulate an individual from cradle to grave, simply because he will predictably engage in particular transactions."


text: Nor could the Necessary and Proper Clause, in Roberts's view, support the individual mandate penalty. While authorizing Congress to enact laws incidental to powers enumerated in the Constitution, its authority is not a grant of any substantive and independent power. The individual mandate penalty represented an attempt by Congress to reach and draw in individuals beyond the scope of its authority; while the penalty may be necessary to Congress's ends, it is not a proper means of reaching it.


text: In part III-B of his opinion, Roberts argued that the failure to uphold the individual mandate penalty under those two clauses did not end the inquiry. He referred to canons of judicial interpretation, particularly the canon of beneficial interpretation: where a law "has two possible meanings, one of which violates the Constitution, courts should adopt the meaning that does not do so." Thus, if the individual mandate penalty payment can be read as a tax, then it may fall within Congress's taxing authority.


text: Justice Ginsburg concurred in the judgment in part and dissented in part. Joined by Breyer, Sotomayor, and Kagan, she would have upheld the individual mandate under the Commerce Clause and Necessary and Proper Clause:


text: Further, joined only by Sotomayor, she dissented on striking down the Medicaid expansion penalty, arguing that it was within Congress's power under the Spending Clause:


text: Ginsburg's dissent went on to highlight the implications of the majority's finding that the federal government's threat of taking away existing funding from states unwilling to implement Medicaid expansion left states with no "legitimate choice".


text: Justices Scalia, Kennedy, Thomas, and Alito joined an unsigned dissent that argued the individual mandate was unconstitutional because it represented an attempt by Congress to regulate beyond its power under the Commerce Clause. Further, they argued that reclassifying the individual mandate as a tax rather than a penalty in order to sustain its constitutionality was not to interpret the statute but to rewrite it, which they deemed a troubling exercise of judicial power:


text: The dissent also disputed Ginsburg's claim that the court's opinion failed "to explain why the individual mandate threatens our constitutional order":


text: Finally, the joint dissent argued that since the ACA exceeded its constitutional powers in both compelling the purchase of health insurance and in denying non-consenting States Medicaid funding, the whole statute should have been deemed inoperative because the two parts were central to the statute's design and operation. The joint dissent mentioned that "the Constitution requires tax increases to originate in the House of Representatives" per the Origination Clause, though that issue was not addressed by the majority opinion.


text: In a one-paragraph dissent, Justice Thomas emphasized his long-held belief that the Supreme Court's precedents have broadened Congress's powers under the Commerce Clause in a manner "inconsistent with the original understanding of Congress's powers and with this Court's early Commerce Clause cases". Thomas wrote that he agreed with Roberts's interpretation of precedents allowing Congress to use the Commerce Clause to regulate "the channels of interstate commerce" and the "persons or things in interstate commerce" and disallowing the regulation of commercial inactivity. But he disagreed with the court's third, "substantial effects" test as established by "Wickard v. Filburn", articulated within "United States v. Morrison", and strengthened by "Gonzales v. Raich".


text: The Court convened on the morning of June 28, 2012, to announce its decisions on the ACA and two other cases; it announced its ruling on the ACA shortly after 10:00 am EDT. CNN and Fox News initially reported that the individual mandate was found unconstitutional, but corrected themselves within minutes. President Obama initially heard from CNN and Fox News that the mandate had been found unconstitutional, but then heard the correct information shortly thereafter.


text: Immediately after the decision, there was speculation that the joint dissent was the original internal majority opinion, and that Roberts's vote changed sometime between March and the public issuance of the decision.


text: On July 1, 2012, CBS News, citing unnamed sources within the Court, said that over the course of internal deliberations Roberts changed his position from striking down the mandate to upholding it. The article, by journalist Jan Crawford, reported that during the Court's private conference immediately after the oral arguments, Roberts was inclined to strike down the mandate but, in disagreement with the other four conservative justices, was not certain this required striking down the law in its entirety. News articles in May 2012 that warned of potential "damage to the court—and to Roberts' reputation—if the court were to strike down the mandate" reportedly increased the external pressure on Roberts, who "is keenly aware of his leadership role on the court [and] is sensitive to how the court is perceived by the public", and pays more attention to media coverage of the Court than some of his colleagues. It was around this time that Roberts decided to uphold the law. One of the conservative justices reportedly pressed Roberts to explain why he had changed his view on the mandate, but was "unsatisfied with the response".


text: On July 2, Adam Liptak of "The New York Times" insinuated that the leak could have come from Justice Thomas, as Liptak pointed out that Crawford has long had a relationship with Thomas, who had granted her rare interviews and singled her out as his favorite reporter, saying, "There are wonderful people out here who do a good job—do a fantastic job—like Jan [Crawford]."


text: Some observers have suggested Roberts's philosophy of judicial restraint or the lack of Supreme Court precedents available "to say the individual mandate crossed a constitutional line" played a part in his decision. The article reported that after Roberts "withstood a month-long, desperate campaign to bring him back to his original position", with Kennedy, who is typically the swing vote in 5–4 decisions, leading the effort, the conservatives essentially told him, "You're on your own." The conservative dissent was unsigned and did not, despite efforts by Roberts to convince them to do so, make any attempt to join the Court's opinion, an unusual situation in which the four justices "deliberately ignored Roberts' decision, the sources said, as if they were no longer even willing to engage with him in debate".


text: In 2019 it was reported that Roberts had originally voted to invalidate the individual mandate and uphold the Medicaid expansion requirement. He believed that the Constitution's commerce clause never was intended to cover inactivity, such as the refusal to buy insurance. But he was uneasy with the political division in the vote tally and also did not want to invalidate the entire law because he thought the individual mandate was only inseverable from "community rating" and "guarantee issue" provisions of the law. Due to this impasse he explored the argument that the individual mandate could be upheld as a tax and invalidating the Medicaid expansion. Breyer and Kagan had previously voted to uphold the Medicaid expansion, but decided to switch and join Roberts's opinion on that section.


text: President Obama praised the decision in a series of remarks, while discussing the benefits of the legislation in a statement shortly after the decision. House Minority Leader Nancy Pelosi, who as Speaker of the House had been instrumental in the passage of the ACA, said that Senator Edward Kennedy of Massachusetts, a longtime proponent of health care reform who died before the bill became law, could now "rest."


text: The ruling quickly became a rallying cry for Republicans, who criticized the Court's reasoning and vowed to repeal the ACA. Though they had already repeatedly attempted to do so starting in January 2011, they were unsuccessful in enacting a repeal. Conservatives quickly seized on the fact that Obama and the bill's proponents insisted repeatedly throughout the protracted political debate 2009 and 2010 that the mandate was not a tax, but the Court upheld it on the grounds that it was. Republican presidential candidate Mitt Romney said he would repeal the bill, as did Speaker of the House John Boehner and Senate Minority Leader Mitch McConnell. Several state attorneys general who challenged the law said they were disappointed with the Court's decision but happy that in doing so, the Court limited Congress's powers under the commerce clause. Several state Republican officials indicated their desire to take the option the Court granted them to not further expand Medicaid.


text: The American Medical Association, the National Physicians Alliance, the American Academy of Pediatrics, and the Association of American Medical Colleges said that the ruling was a victory.


text: "The New York Times" reported that the Court's ruling was the most significant federalism decision since the New Deal. It reported it in this respect about the new limits the ruling placed on federal regulation of commerce and about the conditions the federal government may impose on money it gives the states. With respect to the Commerce Clause, the Court ruled that the federal government had no permission to force individuals not engaged in commercial activities to buy services they did not want. With respect to the Medicaid expansion under the Affordable Care Act, the Supreme Court held that the ACA's requirement that states rapidly extend coverage to new beneficiaries or lose existing federal payments was unduly coercive. The health-care law had to allow states to choose between participating in the expansion while receiving additional payments, or forgoing the expansion and retaining existing payments. Virginia Attorney General Ken Cuccinelli, the first to challenge the ACA in federal court, praised the limits the Court placed on federal regulation of commerce and on the conditions the federal government could impose on money it gives the states.


text: Georgetown Law professor Randy Barnett said that by invalidating the withholding of existing Medicaid funding as unconstitutionally coercive, the Court found an enforceable limit on the spending power of the federal government. This limit on the spending power is part of Georgetown University law professor Neal Katyal's ruling analysis. Katyal, who served as acting solicitor general of the United States and argued the health care cases at the appellate level, argued that the ruling could change the relationship between the federal government and the states because of "the existence of an extraconstitutional limit" on the federal government's power under the Spending Clause. He said that until now it had been understood that when the federal government gave money to a state in exchange for the state's doing something, the federal government was free to do so as long as a reasonable relationship existed between the federal funds and the act the federal government wanted the state to perform. He then referred to the Court holding that the ACA's requirement that states rapidly extend Medicaid coverage to new beneficiaries or lose existing federal payments was unduly coercive by noting that the court found that "such a threat is coercive and that the states cannot be penalized for not expanding their Medicaid coverage after receiving funds. And it does so in the context of Medicaid, which Congress created and can alter, amend or abolish at any time. ... This was the first significant loss for the federal government's spending power in decades. The fancy footwork that the court employed to view the act as coercive could come back in later cases to haunt the federal government. Many programs are built on the government's spending power, and the existence of an extraconstitutional limit on that power is a worrisome development." Katyal also mentioned that the federal government told the court that long-standing laws contain clauses that condition money on state performance of certain activities. "The decision leaves open the question of whether those acts, and many others (like the Clean Air Act), are now unconstitutional as well." Reuters later reported that Katyal had reversed his opinion and stated that he didn't see any litigation coming out of the Supreme Court holding in the near term.


text: In the same direction as Katyal argues Kevin Russell, who teaches Supreme Court litigation at Harvard and Stanford Law Schools and clerked for Judge William Norris of the Ninth Circuit and Justice Breyer. According to him, several significant civil rights statutes, enacted under Congress's Spending Power, are at risk to be unconstitutional, because the Court held that Congress exceeded its Spending Clause authority by forcing states into an all-or-nothing choice by threatening to revoke all of their Medicaid funding if they did not participate in the Medicaid expansion. Russell remembers that a decade ago several states made challenges to a number of important civil rights statutes that condition receipt of federal funds on the state's agreement to abide by non-discrimination principles in the federally funded programs. "These statutes include Title IX (sex discrimination in federally funded education programs), Title IV (race discrimination in any federally funded program), and the Rehabilitation Act (disability discrimination in federally funded programs). States argued that by threatening to take away all of a program's funds if the States didn't agree to abide by these statutes, Congress was engaging in unconstitutional coercion."


text: David B. Kopel, an adjunct professor of constitutional law at University of Denver, said that the ruling was the Court's most important ruling in defining the limits of Congress's power under the Spending Clause, because this clause must, like , conform to the principles of state sovereignty embodied in Constitution, the Tenth and Eleventh Amendments. According to him, this has a tremendous impact on state budgets: "Today (and from now on!), states do not need to provide Medicaid to able-bodied childless adults. Likewise, states today have discretion about whether to provide Medicaid to middle-class parents. Undoubtedly, some states will choose to participate in the ACA's massive expansion of medical welfare, but fiscally responsible states now have the choice not to."


text: University of Michigan law professor Samuel Bagenstos told "The Atlantic" that the Court's holding on the Medicaid expansion could be a landmark decision in federalism jurisprudence, if the Medicaid issue were not in the same case as the individual mandate. He deemed it "a big deal" that the Court had for the first time struck down a condition on federal spending on the grounds that it coerced the states. In his opinion, this means that a number of federal statutes that had not really been subject to effective legal challenge before could now be challenged by the states.


text: Fairleigh Dickinson University's PublicMind conducted research on the public's constitutional perspective by asking registered voters about key legal issues brought up by ACA litigation through two surveys based upon a random sampling of the population. The authors, Bruce G. Peabody and Peter J. Woolley contend that, through public response on this case, despite claims of an ignorant and uninformed public, the masses can be confident, properly conflicted, and principled when considering major controversies and dilemmas. Rather than polling the public on raw personal opinion, the study inquired into random voters' legal judgment of the ACA's constitutionality. For example, 56% of Americans (as of February 2012) deemed that Congress does not have the legal right to require everyone to have health insurance, while 34% believed that such a mandate was legally permissible.


text: "Sebelius" was the centerpoint of the third legal challenge to the ACA to reach the Supreme Court in "California v. Texas", heard in the 2020–21 term. In 2017, Congress passed the Tax Cuts and Jobs Act that reduced the health insurance requirement of the ACA to $0 from 2019 onward, effectively eliminating the individual mandate. Texas and several states sued the federal government, arguing on the basis of "Sebelius" that with mandate eliminated, the entire ACA was unconstitutional. A district court agreed with this, which was upheld on a challenge by California and other states to the Fifth Circuit, stepping in when the government declined to challenge the ruling. The Supreme Court agreed to hear the case to consider not only if the elimination of the individual mandate makes the ACA unconstitutional, but factors related to the severability of the individual mandate from other provisions in the ACA, as well as whether California has standing.


title: Phreatic eruption

text: A phreatic eruption, also called a phreatic explosion, ultravulcanian eruption or steam-blast eruption, occurs when magma heats ground water or surface water. The extreme temperature of the magma (anywhere from ) causes near-instantaneous evaporation of water to steam, resulting in an explosion of steam, water, ash, rock, and volcanic bombs. At Mount St. Helens in Washington state, hundreds of steam explosions preceded the 1980 Plinian eruption of the volcano. A less intense geothermal event may result in a mud volcano.


title: Phreatic eruption

text: Phreatic eruptions typically include steam and rock fragments; the inclusion of liquid lava is unusual. The temperature of the fragments can range from cold to incandescent. If molten magma is included, volcanologists classify the event as a phreatomagmatic eruption. These eruptions occasionally create broad, low-relief craters called "maars". Phreatic explosions can be accompanied by carbon dioxide or hydrogen sulfide gas-emissions. Carbon dioxide can asphyxiate at sufficient concentration; hydrogen sulfide acts as a broad-spectrum poison. A 1979 phreatic eruption on the island of Java killed 140 people, most of whom were overcome by poisonous gases.


title: Marlinspike

text: A marlinspike (; sometimes marlin spike, marlinespike, or marlingspike [archaic]) is a tool used in marine ropework. Shaped in the form of a polished metal cone tapered to a rounded or flattened point, it is used in such tasks as rope for splicing, untying knots, drawing marline tight using a marlinspike hitch,


title: Marlinspike

text: Marlinspikes are usually about long, but may reach or more when used for working heavy cables and ropes. They are usually made from iron or steel, whereas fids, similar in shape and function, are formed from wood or bone. The marlinspike may be a separate tool or one item on a pocket knife.


title: Marlinspike

text: Sailors who become proficient at knot tying, splicing, and sewing using the marlinspike are said to have mastered marlinespike seamanship, earning them the right to be known as "marlin spikes" or "marlinspike seamen".


title: Marlinspike

text: "Marlinspike" derives from the practice of "marling", winding small diameter twine called marline around larger ropes to form protective whippings. The long-billed fish marlin is thought to be named after the marlinspike.


title: Static variable

text: In computer programming, a static variable is a variable that has been allocated "statically", meaning that its lifetime (or "extent") is the entire run of the program. This is in contrast to shorter-lived automatic variables, whose storage is stack allocated and deallocated on the call stack; and in contrast to objects, whose storage is dynamically allocated and deallocated in heap memory.


title: Static variable

text: Variable lifetime is contrasted with scope (where a variable can be used): "global" and "local" refer to scope, not lifetime, but scope often implies lifetime. In many languages, global variables are always static, but in some languages they are dynamic, while local variables are generally automatic, but may be static.


title: Static variable

text: In general, is the allocation of memory at compile time, before the associated program is executed, unlike dynamic memory allocation or automatic memory allocation where memory is allocated as required at run time.


title: Static variable

text: This definition is subtly different from a static variable: it only specifies behavior, and hence lifetime, not storage: an own variable can be allocated when a function is first called, for instance, rather than at program load time.


title: Static variable

text: The use of the word "static" to refer to these variables dates at least to BCPL (1966), and has been popularized by the C programming language, which was heavily influenced by BCPL. The BCPL definition reads:


title: Static variable

text: Note that BCPL defined a "dynamic data item" for what is now called an "automatic" variable (local, stack-allocated), not for heap-allocated objects, which is the current use of the term "dynamic allocation".


title: Static variable

text: The codice_1 keyword is used in C and related languages both for static variables and other concepts.


title: Static variable

text: The absolute address addressing mode can only be used with static variables, because those are the only kinds of variables whose location is known by the compiler at compile time. When the program (executable or library) is loaded into memory, static variables are stored in the data segment of the program's address space (if initialized), or the BSS segment (if uninitialized), and are stored in corresponding sections of object files prior to loading.