Prostitution of Children and Child Prostitutes

PROSTITUTION Prostitution is defined as the act, practice or profession of offering the body for sexual relations for money. (New Webster’s Dictionary 1995:802). The Encyclopedia Americana (1997) defined prostitution as â€Å"the performance of sexual acts with another person in return for the payment of a fee. † Child prostitution is therefore, prostitution embarked upon by children who are below the age of 18 and are supposed to be catered for by their parents.It is commonly acknowledged that acts of prostitution are performed by women for men nevertheless occasions arise when the acts are done by men for men. The context of this work deals particularly with female child prostitution. UNICEF considers child prostitutes as young girls in sex trade, who are between the age bracket of 8 and 16. (Jubilee Action Report 1995). In the Nigerian milieu, prostitutes below the age of 18 are regarded as child prostitutes, since only persons above 18 years of age are statutorily r egarded as adults.Child prostitution is the â€Å"sexual exploitation of girls and teenagers† (Awake February 8, 2003:6). Available data show that approximately 1. 5million children in India, 1 million in Asia, 100,00 children in United States and 500 children in Latin America are engaged in prostitution (Healy, 1995:35). Awake (February 8,2003:2) reported,â€Å"there were about 300,000 child prostitutes on the streets, in another land where drug trafficking flourishes†. According to Jubilee Action report (1995:10), up to 1 million female children join prostitution each year around the globe.However, the clandestine nature of child prostitution makes it impossible to calculate the exact number of working prostitutes, nonetheless the International Labour Organization (ILO) analysis (1993-1994), estimates that between 0. 25% and 1. 5% of the total female population are engaged in this trade. Globally, child prostitution is illegal and it is also regarded as a barbarous c rime, yet it persists. Why? Child prostitution does not just happen. It is caused by a variety of factors some are perpetrated by the prostitutes themselves, while other factors are external to the prostitutes themselves.This is really a growing problem in developed world and developing world like Nigeria (Quintanilla, 1997:20). CAUSES OF CHILD PROSTITUTION IN Owerri Municipal Council 1. Misery and POVERTY: Poverty is the most common reason why most families sell the services of their female children to augment their income in order to buy food or clothes and other necessities of life. (Janssen, 2001:10). The case of child labour is a typical factor that exposes children to prostitution. The hired female children are sent out to hawk food items on the streets, motor parks, and mechanic garages thereby exposing them to rapes as well as sexual harassment s.Barnes H. C. (1959:95) observed that some females take to prostitution due to sheer destitution. Awake (February 8,2003:5) reporte d that some street children resort to prostitution because they see it as their only means of survival. The Awake further related an experience of a mother of 14-year-old girl who lured her daughter into this ignominious trade. The woman said about her daughter, â€Å"she was beautiful and that men would like her very much. Besides, she would earn a lot of money. † In the evenings, the woman takes her daughter to a motel where they make contacts.The mother stays nearby to receive the payments. Each night, this girl has sex with three or four men. 2. UNEMPLOYMENT: Unemployment of either the parents or the child results in unreliable source of income thereby forcing children into prostitution as an alternative means of income to support the family. Ironically, the International Labour Organization observes that a child’s ability to earn money is limited. It is estimated that the money earned by the child only contributes to approximately 10% of the family’s overal l income and therefore has minimal effect on the family’s monetary gain (Dimenstein, 1994:12).Due to high degree of unemployment, the brothels employ some female children who serve in their drinking spots to promote their business. 3. HUMANS TRAFFICKING: Human trafficking is another evil leading to child prostitution. Human trafficking which represent the world’s third largest criminal activity following only after drug and weapons trafficking is sometimes purported to send teenagers to other countries to work. These would-be workers who sometimes end up prostitutes actually â€Å"work† and repatriate money to their respective home countries (Awake, February 8, 2003: 5).Many times, hard times hit these fellows as they are deported to come and continue this profession at home. Some of the female prostitutes come home to take some younger females to their places either to help them or to make them their servants and at the long run they get converted to prostituti on, which is their boss’ profession. 4. DECEPTION ENCOURAGES PROSTITUTION: Pimps or brothel owners deceive some parents by paying them money and assuring to enlist their children in their â€Å"domestic services†, which later turns to be prostitution.These brothel owners who are termed the girl’s â€Å"owners† take control of the child’s’ activities. Moreover, these owners do everything possible to retain these girls who earn money for them to maintain their lavish lifestyle (Robinson, 2001:50) and (Dimenstein 1994:10). Apart from the pimps, other intermediaries who benefit from child prostitution do anything possible to see the act continued. Most females are led into this act of prostitution by their masters.Some of them could be anaesthetized by their masters in order to have fun with them and when eventually the woman of the house gets to know about the act she will be thrown out side to continue the act with other men including the mast er. 5. DYSFUNCTIONAL FAMILY ENVIRONMENT PROMOTES PROSTITUTION: Children of broken homes sleep wherever they see space to do so in the day, and go to the disco and nightclubs in the night. Ekejiuba I. K. (1996:13) discovered that ill treatment of children at home might make them to take to the street in order to find solace.Then the end result may be the hawking of their body to support themselves. 6 POOR EDUCATION: Some children cannot support themselves materially in view of low educational training they received, so they resort to prostitution as their only profession (Rodriguez- Garcia, 1999:55). Girl-child Education Initiative In Africa (January 2003:20) highlights the effect of poor education in the whole of Africa. In connection with poor education, peer pressure, bad association The causes and effects of child prostitution in Owerri Municipal Council and street ganging contribute to child prostitution.Identifiably, a girl may end up as a prostitute by her association, peer pr essure and by running with a street gang (Okebugwu, 1989:25); Adetore, (1974:60); Oti (1984:15); and Daily Times ( May 15,1999:12). 7. AIDS SCARE PROMOTES CHILD PROSTITUTION: The high incidence of sexually transmitted diseases like AIDS make customers of prostitutes to look for children who are considered to be of low risk, and most probably virgins (Robinson, 2001:13). Patrons of child prostitutes are willing to pay a great deal of money to be a girl’s first client.In the streets, brothels and drinking spots these days a lot of female children are being employed to help lure more male customers to their spots. Places like Amaram by Tetlow Road and some places in Onyeche Street in Owerri have a high number of female child prostitutes who are employed only to facilitate their business. This is because there is the fear that other older female prostitutes in the same profession could have various STDs. 8. DRUG ABUSE AND ADDICTION ARE PRO-CHILD PROSTITUTIONThe influence of drugs can subject a child to prostitution and to certain indignifying acts of prostitution which she may otherwise never agree to given her sound mind (Lewis 1980:70); and Udechi (1987:15). 9. REBELLION AND FEELING OF INDEPENDENCE This is another factor promoting child prostitutions. Some girls are shamelessly bold. What is more, they feel that the body is theirs thus they should decide what to do with their body. (Bennet, G and Robert, P. 1985:207). 10. PORNOGRAPHY AGGRAVATES CHILD PROSTITUTION: Pornography also puts viewers at increased risk for developing sexually deviant tendencies. Awake July 22, 2003:7). Pornography is identified as promoting â€Å"the rape myth† which is a belief that women cause and enjoy rape. Additionally, the repeated use of pornography interferes with the ability to enjoy and participate in normal marital intimacy. Dr. Victor Cline, who specializes in treating sex addiction claims that â€Å"deviant sexual acts results† when a viewer tries to ac t out the pornography-based fantasies. 11. Incestuous violation and rape in homes as a factor: Some youths were raped in their own homes, which act changed their outlook in life.Some of such ones give vent to prostitution. Two other closely related causes of prostitution are glamor associated with it and insatiable sexual urges in some females. Blag(1976:68) observed that some prostitutes take to this lifestyle because of their innate desire for glamour or that they want to maintain a standard of life, which is impossible by ordinary means of earning, a life reminiscent of Greek aether. On the other hand, Ekejiuba(1996:14) identified other females, nymphomaniacs, who engage in prostitution for the sake of â€Å"fun† or pleasure they derive from it. 2 SUDDEN EXPOSURE: Furthermore, illicit love affairs in the presence of children may subject them to early prostitution. Some parents perform extra marital affairs in the presence of their wards. This exposes the children to early sex life. The premature death of one or both of the parents has also been discovered as one of the causes of child prostitution. Because of the chasm created by such loss, a teenage girl may be fraught with the onerous task of catering for herself and other family members. More importantly, no one may exist to give stern guideline on her.One Owerri girl who returned from Kumasi Ghana claimed that her father died when she was eight years. This demise of his father left her with the responsibility of catering for her younger siblings and her mother who hails from Kumasi, Ghana. These challenges make her to dabble into prostitution. Child prostitution is not without its consequences, some of which are seemingly pardonable, whereas others are taboo at mere mention of them. High patronage of child prostitutes by wealthy men is another factor that has caused and sustained child prostitution ( Ekejiuba 1996: 13).Some teenage girls find it difficult to resist the temptation of prostitution because of huge sum of money they receive there-from. This accounts for why some IMSU, Alvan and FUTO ladies readily avail themselves for this business. Marxist oriented scholars see prostitution as an outgrowth of capitalism. Many of these see the gradual removal of subsidy from petroleum, which is the main balance of Nigerian economy as exposing many persons to difficulty and leading to sexual promiscuity.

Ict in Teacher Education

ICT in Teacher Education Dr. R. Sivakumar Assistant Professor Department of Education Annamalai University Annamalai Nagar – 608002. Abstract Information and Communication Technologies has a great potential to contribute positively towards knowledge dissemination, effective learning and the development of more efficient education service. In teacher education, student-teachers acquire appropriate knowledge, skills and competences on how to integrate technology in education. The knowledge and competences are how to use ICT in teaching and learning has gained enormous importance in today’s teacher education programs.The integration of information and communication technologies can help revitalize teachers and students. This can help to improve and develop the quality of education by providing curricular support in difficult subject areas. Use of ICT in learning settings can act to support various aspects of knowledge construction and as more and more students employ ICTs in their learning processes. ICT enabled education will ultimately lead to the democratization of education. Introduction Teacher is considered to be the architect of the nation. One can realize how important education is which makes one a teacher.Teacher education is looked after by a systematic operation of various agencies involved in it. Various education commissions and a number of expert committee have discussed the aims of teacher education in India. One of the main reasons is the inadequate academic, professional and pedagogic preparation and insufficient level of knowledge and the skills of the faculty. Besides this, traditional versus modern methods of teaching, outdated knowledge and information and lack of skills, teachers attitude, aptitude and authenticity of their sources of knowledge are some of the other core issues.Owing to knowledge explosion and tremendously fast changing ICT, the teachers sometimes find it rather difficult to cope with the new intellectual chall enges being thrown up by the changed global and local context. Therefore, they need to acquire new knowledge, and reliable and authentic information. In present scenario, teachers need to help their students in: how to learn, how to grow in future, how to develop study skills, how to conduct fundamental research, how to examine, evaluate and assess information This is necessary if the teachers really want to survive in the ICT world of education.A teacher plays a significant role not only in class teaching learning situation but in social engineering too. Society gives a respectable place to teachers who are really perspective empowered. This empowerment is not at in terms of physical perspective. It is in academic, intellectual, social, and national perspectives. ICT in Education Information and Communication Technologies has a great potential to contribute positively towards knowledge dissemination, effective learning and the development of more efficient education service. Inform ation and Communication Technologies are becoming increasingly pervasive in reaching schools.It is essential that teachers and teacher-educators have a thorough working knowledge of these media and their influence on the performance and engagement of their students. ICT includes, but is not limited to, personal computers, laptops, printers, LCD projectors, palm devices, iPods, fax machines, cell phones, Internet, Intranet and Web-Based Education that offers accessibility, flexibility and innovativeness in teaching and learning. Teachers have ability to use digital technology, communication tools, and networks appropriately to solve information problems in order to function in an information and knowledge society.This encompasses three areas of ICT literacy, namely cognitive, technical, and social. ICT integrated teacher education is more important to Indian education system that is committed to maintain global partnership as well as leadership in knowledge-based society. ICT in educ ation are not only new tools bringing evolution and changes. They raise new fundamental paradigms, new fundamental concepts, which change profoundly our societies, which change knowledge and access to knowledge. The digital natives will bring this new context, whatever the schools do or not. This is a new challenge for schools and for teachers.Digital natives are not only new pupils, a kind of new step in the humankind; they are the main actors of the new digital society, the new citizens of the knowledge society. Learning and teaching in the digital society. It should be no surprise that teachers who, like other professionals, are expected to be lifelong learners, must also meet the challenges of digital and mobile technologies. It is not simply a matter of mastering new technology; since the entire traditional paradigm has been up-ended, they must re-examine their profession and redefine their role of the teachers in the learning process.Understanding and mastering technology is t he starting point of a process of creating a new school. ICT in Teacher Education Information and Communication Technology (ICT) have the potential of educational challenges. In teacher education, student-teachers acquire appropriate knowledge, skills and competences on how to integrate technology in education. The knowledge and competences are how to use ICT in teaching and learning has gained enormous importance in today’s teacher education programs.This is because student-teachers’ adoption of ICT use in the classroom has strong positive correlation with the pedagogical training rather than technical skills a particular ICT-related teacher education program or course must seek to promote the following aspects of knowledge so as to help students-teachers know how to use technology in the teaching and learning processes: * Knowledge of problems or situations that can be solved by technology. * Knowledge of the kind of technology that can solve this kind of problem. * Knowledge of how the technology can solve a specified problem.This kind of knowledge is known as Technological Pedagogical Content Knowledge (TPCK). It is important that student-teachers are trained on how to use ICT in delivering of education to make learning more meaningful for using Education Technologies to support instruction. Student-teachers should be introduced to TPCK concept and should work in an environment that promotes this understanding for effective integration of technology in their future teaching. ICT courses in teacher education must also strive to develop a sound understanding of the learning theories and ways how ICT can be used to enhance teaching and learning.It is expected that ICT courses in teacher education should make student-teachers appreciate that the choice of any particular technology should be grounded not only on specific learning theory but also on pedagogical needs and the context. This ICT course must promote among student-teachers the knowledge and competences related to the application of ICT to promote teaching and learning process. Using ICT in education includes: * the use of ICT as object of study: which refers to learning about ICT which enables student-teachers to use ICT in their daily life. the use of ICT as aspect of a discipline or profession: meaning that ICT is used for development of ICT skills for professional or vocational purposes. * ICT as medium for teaching and learning which focuses on the use of ICT for the enhancement of the teaching and learning process. To effectively use the new information and communication technologies (ICTs) to improve learning, the following essential conditions must be met: * Students and teachers must have sufficient access to digital technologies and the Internet in their classrooms, schools, and teacher education institutions. High quality, meaningful, and culturally responsive digital content must be available for teachers and learners. * Teachers must have the knowledge and skills to use the new digital tools and resources to help all students achieve high academic standards. Teacher education institutions are faced with the challenge of preparing a new generation of teachers to effectively use the new learning tools in their teaching practices. For many teacher education programmes, this daunting task requires the acquisition of new resources, expertise and careful planning.In approaching this task it is helpful to understand: * the impact of technology on global society and the implications for education, * the extensive knowledge that has been generated about how people learn and what this means for creating more effective and engaging student- centred learning environments, * the stages of teacher development and the levels of adoption of ICTs by teachers, * the critical importance of context, culture, leadership and vision, lifelong learning, and the change process in planning for the integration of technology into teacher education, * the IC T competencies required of teachers related to content, pedagogy, technical issues, social issues, collaboration, and networking, * the importance of developing standards to guide implementation of ICTs in teacher education, * the essential conditions for successful integration of ICTs into teacher education, * important strategies to consider in planning for the infusion of ICTs in teacher education and managing the change process. Integrating ICT into teachingThe integration of information and communication technologies can help revitalize teachers and students. This can help to improve and develop the quality of education by providing curricular support in difficult subject areas. To achieve these objectives, teachers need to be involved in collaborative projects and development of intervention change strategies, which would include teaching partnerships with ICT as a tool. ICT enhancing teaching and learning process Introduce ICT into their classrooms: teachers should believe in the effectiveness of technology, teachers should believe that the use of technology will not cause any disturbances, and finally teachers should believe that they have control over technology.The use of ICT will not only enhance learning environments but also prepare next generation for future lives and careers. The integration of ICT into teaching and learning processes contributes to increase the interaction and reception of information. Such possibilities suggest changes in the communication models and the teaching and learning methods used by teachers, giving way to new scenario which favours both individual and collaborative learning. Students using ICTs for learning purposes become immersed in the process of learning and as more and more students use computers as information sources and cognitive tools. The influence of the technology on supporting how students learn will continue to increase.In the past, the conventional process of teaching has revolved around teachers plann ing and leading students through a series of instructional sequences to achieve a desired learning outcome. Learning approaches using contemporary ICTs provide many opportunities for constructivist learning through their provision and support for resource-based, student centred settings and by enabling learning to be related to context and to practice. Use of ICT in learning settings can act to support various aspects of knowledge construction and as more and more students employ ICTs in their learning processes, the more pronounced the impact of this will become. Teachers generate meaningful and engaging learning experiences for their students, strategically using ICT to enhance learning. ICT enhancing the quality of educationICT increases the flexibility of delivery of education so that learners can access knowledge anytime and from anywhere. It can influence the way students are taught and how they learn as now the processes are learner driven and not by teachers. This in turn wo uld better prepare the learners for lifelong learning as well as to improve the quality of learning. In concert with geographical flexibility, technology-facilitated educational programs also remove many of the temporal constraints that face learners with special needs. Students are starting to appreciate the capability to undertake education anywhere, anytime and anyplace. One of the most vital contributions of ICT in the field of education is- Easy Access to Learning.With the help of ICT, students can now browse through e-books, sample examination papers, previous year papers etc. and can also have an easy access to resource persons, mentors, experts, researchers, professionals, and peers-all over the world. This flexibility has heightened the availability of just-in-time learning and provided learning opportunities for many more learners who previously were constrained by other commitments. Wider availability of best practices and best course material in education, which can be s hared by means of ICT, can foster better teaching. ICT also allows the academic institutions to reach disadvantaged groups and new international educational markets.As well as learning at any time, teachers are also finding the capabilities of teaching at any time to be opportunistic and able to be used to advantage. Mobile technologies and seamless communications technologies support 24Ãâ€"7 teaching and learning. Choosing how much time will be used within the 24Ãâ€"7 envelope and what periods of time are challenges that will face the educators of the future. Thus, ICT enabled education will ultimately lead to the democratization of education. Especially in developing countries like India, effective use of ICT for the purpose of education has the potential to bridge the digital divide. Uses of ICT in language arts How ICT improves the teaching/learning of language or how to improve language teaching through intelligent and informed use of technology * Searching and using Internet resources for language materials and lessons * Searching literature-based, creative writing, problem-solving Internet projects with the option of using interpersonal exchanges, virtual gatherings, peer feedback or mentoring to support student learning. * Constructing technology-enhanced lessons or lesson plans within a language art curriculum Uses of ICT in science * How ICT improves the teaching/learning of science or how to improve science teaching through intelligent and informed use of technology * Searching and using Internet resources for science materials and lessons * Science education on the Internet Use of computers software and calculators for science teaching * Use of computer to simulate scientific phenomena and use of graphic calculators to collect and analyse data * Constructing technology-enhanced lessons or lesson plans within a science curriculum Uses of ICT in mathematics * How ICT improves the teaching/learning of mathematics or how to improve mathematics teachi ng through intelligent and informed use of technology * Searching and using Internet resources for mathematics materials and lessons * Use of computer software and calculators for mathematics teaching * Use of computers and graphic calculators to collect and analyse data and to build and test mathematical models of the real-world * Constructing technology-enhanced lessons or lesson plans within a mathematics curriculum Uses of ICT in social studies How ICT improves the teaching/learning of social studies or how to improve social studies teaching through intelligent and informed use of technology * Searching and using Internet resources for social studies materials and lessons * Searching problem-solving, enquiry and creative thinking materials with the option of using interpersonal exchanges, virtual gatherings, peer feedback or mentoring to support student learning * Constructing technology-enhanced lessons or lesson plans within a social studies art curriculum Conclusion The teach er education system empowered by ICT driven infrastructure can have a great opportunity to come up to the centre stage and ensure academic excellence, quality instruction and leadership in a knowledge-based society. ICT has revolutionized the entire concept of education. It is really a challenging task to strengthen ICT in teacher education because a large majority of the teacher education institutions are unequipped or under-equipped in the terms of digitized and high-tech infrastructure. References Ahmed, S. and Singh, M. (2010).Multimedia in Teacher Education Empowering Accessible, Flexible and innovative learning,  Shikshak – Shikha Shodh Patrika  Vol. (04) No (1) pp. 32-33. Flecknoe, M. (2002). â€Å"How can ICT help us to improve education†? Innovations in Education & Teaching International, Vol. 39, No. 4, Pp; 271-280 Mishra, P. , & Koehler, M. (2006). Technological pedagogical content knowledge: A framework for teacher knowledge. Teachers College Record, 10 8(6), 1017-1054. Montgomerie, C. , & Irvine, V. (2001). Computer skill requirements for new and existing teachers: Implications for policy and practice. Journal of Teaching & Learning, 1(1), 43-55. Moore, M. amp; Kearsley, G. (1996). Distance Education: A Systems View. Belmont, CA: Wadsworth. Paliwal A. K. (2006). Faculty development in teacher education perceptions and changing context, sovinier 7th National conference MATE pp 10-11. Takwal, R. (2003) Problems and Issues faced by Indian Education system UGC Golden Jubilee Lecture series. pp. 5. Venna S. K (2010) Teacher Education some qualitative consideration,  Shikshak – Shikha Shodh Patrika  vol (04) NO (1) pp. 10. Yusuf, M. O. (2005). Information and communication education: Analyzing the Nigerian national policy for information technology. International Education Journal Vol. 6 No. (3), Pp; 316-321.

Analysis of Martin Luther King’s “I Have a Dream” Essay

The Speech I have chosen to do is â€Å"I have a dream† by Martin Luther King. â€Å"I have a dream that one day this nation will rise up and live out the true meaning of its creed: â€Å"We hold these truths to be self-evident: that all men are created equal.† I have a dream that one day on the red hills of Georgia the sons of former slaves and the sons of former slave owners will be able to sit down together at the table of brotherhood. I have a dream that one day even the state of Mississippi, a state sweltering with the heat of injustice, sweltering with the heat of oppression, will be transformed into an oasis of freedom and justice. I have a dream that my four little children will one day live in a nation where they will not be judged by the color of their skin but by the content of their character. I have a dream today.† This is a particularly inspirational speech because he was saying exactly what he felt and it came straight from his heart, and it was exactly what the people that were listening were thinking about the how they were being treated. The speech shows how angry he is with all the racism in the United States of America, and he tells everyone how things should be, this worked particularly well because all the black people in America were treated poorer than white people and it summed up all the hatred and anger that was inside them. Martin Luther king used very cleverly thought out sentence structure to make more impact on the listeners. He used the quick and snappy sentences to grab their attention and then he would use the longer sentences to explain his deeper feelings. Luther king also uses the word freedom a lot because it shows that is what they didn’t have, which also again makes the listeners feel that they don’t have a lot of freedom. The definition of inspiration is â€Å"the process of being mentally stimulated to do or feel something, especially to do something creative.† This is exactly what Dr King got people that listened to his speech to feel, inspired to do something to help themselves. Thank you for listening.

Post natal depression - a challenging Phase for the new mothers Essay

Post natal depression - a challenging Phase for the new mothers - Essay Example If one has a close watch on these mothers, they will exhibit roller coaster of emotions leading to extreme mood swings. In a way, the symptoms of post natal depression could be similar to other mental other depression. Early Signs In most of the cases, the mothers are usually unsure of what is happening and they may not know what needs to be done to solve the problem. Literally they will be cornered. They are often filled with mixed emotions with the joy of the new born and at the same time dissatisfaction with their body conditions and other mental pressures. A common thing that will be visible most of the affected new mothers is the lack of sleep. Some of the other symptoms include low self esteem, negative thoughts, irritability, poor concentration and difficulty in making crucial decisions, loss of appetite, etc. Failure in identifying the post natal depression can cause devastating effects on both the mother and the child. Like any other depression, the post natal depression can also be cured and the patients need not panic because of their condition, as the only step they have to take is identify the symptoms early and get treated immediately. What are the factors that could lead to Post natal depression? Physical changes â€Å"New mothers are experiencing biological, physical, emotional and social changes. It is likely that postnatal depression is caused by a combination of these things.† (â€Å"The Causes for Postnatal Depression†). From the above sentence one can clearly understand that the main causes of the Post natal depression is based on the Physical changes, emotional changes and social changes a mother will undergo after the delivery of her child. Many friends of mine, who were recent mothers, revealed that they felt worn out and was tired all the time, after the delivery. This is one of the major physical changes and it can be described in the form of the exhaustions and the post operative pain, if the expectant mother had a caesa rian delivery. Also the mother’s appetite may be affected due to improper intake of food and as a result they may become physically worn-out. They feel less confident and also less attractive because of the changes in the body conditions and become less inclined to look after themselves. As new mothers will be naturally fat due to pregnancy, they will think that their beauty has all gone, and their husbands will not like them. Emotional Changes The next aspect that could cause this Post-natal depression is the strong emotional changes, which may occur in the mothers’ minds. They may not experience the same positive feelings, which they might have had or expected during the pregnancy, after they had delivered their babies. â€Å"Adapting to parenthood is daunting.† (â€Å"Better health Channel†). As per the statement the new mothers need to fulfill the constant demands of the child which is a highly tiresome process. On the other hand, the tiredness caused due to the delivery pain can also bring about depression and therefore they will not be overwhelmed with their babies. Social Changes The other vital contributing factor for the post natal depression is the social changes, when will be undergone by the mother. It seems that even the whole society could act as a ‘villain’ against the mother. That is, the arrival of the new baby might cause an upheaval in

Compensation, Rewards, and Incentives Research Paper

Compensation, Rewards, and Incentives - Research Paper Example The various compensation, rewards and incentives programs designed By IBM have facilitated the organization to draw quality and skilled workforce and maintain workplace satisfaction of the existing employees. Furthermore, the monetary and non-monetary incentive programs practiced by IBM have facilitated the organization to prevent competent and quality employees from leaving the organization along with motivating them to perform dedicatedly in the workplace. The benefit programs have enabled the organization to foster and deliver enhanced employee development. Furthermore, the benefit programs of IBM have facilitated the organization to profitably respond to the rapidly altering market and industry trends. The benefit programs have also facilitated IBM to maintain skilled and agile workforce within the organization. The increased level of employee satisfaction within the organization has enabled IBM to quickly and effectively meet the supply and demand scenario as well as positively manage and develop costs and other revenue generation prospects associated with its performance (Boudreau, 2010). These factors have had a deep-rooted impact on IBM’s attainment of being on the ‘Best Places to Work For’

Analysis Assignment Example | Topics and Well Written Essays - 500 words - 1

Analysis - Assignment Example Indeed, he claims that bureaucracy is the most rational and efficient form of organization established by man.2 Most assuredly, Weber establishes the merits and demerits of bureaucracy. Notably, Weber conceived sociology as a science with a view of interpreting and understanding social conduct.3 In addressing the substance of sociology, he focused on rationalization as the most general element in the philosophy of history and the constitutive element of modern western society.4 He contends that strict systematic forms of thoughts, which characterize law, are fundamental to rational jurisprudence. Notably, Weber measured rationalization by assessing the extent at which ideas gain in systematic coherence and consistency as well as by assessing the displacement of magical elements of thoughts.5 Moreover, he classifies rationalization into value rationality and purpose rationality. While value rationality focuses on intrinsic value only, purpose rationality focuses on consequences of an action.6 Furthermore, Weber analyzed the concept of domination and established that the emergence of rational societies is critically dependent on the exercise of domination.7 The Weber’s central theme of rationalization process moves from magicians to priests who seek to protect their positions using systematic religious beliefs.8 He also believed that capitalism is the highest level of rationality in economic behavior and established that the concepts of economic ratio nality are in conflict.9 Ultimately, he asserts that the religious roots of modern capitalism led to utilitarianism, which further led to materialism.10 This chapter reckons that there has been immense growth in public administration where the emergence of a wide range of generic and specialized journals, the increasing number of public administration programs, and the

Opinion- vs. Research-Based Resources Assignment

Opinion- vs. Research-Based Resources - Assignment Example The purpose of the scholarly articles is to publish the results of research mostly to professionals. The results of the study are organized in groups and discussed under a title. For instance the results published by Draper et al (2008) shows how the shift from managing illness to the promotion of health has taken place. It reports how the initiatives responsible for health and wellness have fared, the purposes for building of capacities regarding to health and wellness, range of activities targeted for the improvement of health and wellness, engagement of the enrollee as well as the investment payoff. The journal also explains the source of data as well as the implications. The purpose non-scholar articles are to report the trends in industries, practical advice as well as the news in the industry mostly to the audience who are mostly non-professionals. In this case, Schoen (2003) reports the trends in the health industry in different countries including Australia, the United Kingdom, New Zealand, Canada and the United states and provide the news from those states in regard to health. It is now possible to conclude that both articles are valuable in terms of the subject area they cover. The subject which in this case is health is examined well enough through research which makes the articles valuable. However, the value of scholarly articles can be said to be more valuable due to their wide usage of literature review and the provision of references unlike non-scholarly articles which are rarely referenced. The value of the two articles and their credibility is significant since each of the articles have got its audience. They are therefore written for a purpose and to a specific target who are interested in the specific article. Another similarity is that they both fill the need for the country or rather language of the country. They both communicate in the language that would be effective to the

Shutdown procedures on Mixers, Crutcher and Pumps Essay

Shutdown procedures on Mixers, Crutcher and Pumps - Essay Example Preferably not all of the succinic acid is flushed through the buffer tank. This means that when the supplies of succinic anhydride, water and alkali are switched on for start-up, there is still some acid in the buffer tank to "seed" the hydrolysis reaction. During the period that the process is not operating, the buffer tank should be maintained at an elevated temperature (typically 60Â °-80Â ° C.) in order to prevent solidification of the succinic acid/anhydride mix’ (Patentstorm 1998). A crutcher is the ‘main reaction vessel in the semi-boiled saponification process, or simply a mixing vessel in the soap modification process. It can be used to make a wide variety of soaps or for mixing additives and fillers into liquid soap. Crutches are very easy to use and are generally found in laundry soap factories. They are also used in more sophisticated plants, such as for making transparent soap. A process is described for retarding or preventing the setting of a miscible and pumpable crutcher slurry intended to be spray dried to base beads for subsequent conversion to a built synthetic organic nonionic detergent composition.

Investigating children and their childhoods (babies with senorineural Literature review

Investigating children and their childhoods (babies with senorineural hearing loss and developent under 6months) - Literature review Example Shulman Brian and Capone Nina concluded that nearly all persons affected with senorineural hearing loss usually experience some degree of speech clarity problems and the severity of the loss does not indicate the clarity of the speech (2009, p.116). Congenital hearing loss is seen in newborn babies in most circumstances either by inheritance or by abnormal development in the foetal stages of a child. A comprehensive research done by Valente, Hosford-Dunn and Roesser found that three out of a thousand children born have birth defects that results in hearing loss; sixty per cent of these being inherited, and seventy per cent of the inherited defects are nonsyndromic while fifteen to thirty per cent being syndromic (2008, p.251). One of the most common causes of sensorineural hearing loss amongst children is congenital cytomegalovirus, although majority of children affected by this virus have normal hearing. There are indicators present in newborn children that can be used to predict va lues necessary for the development of loss of hearing with congenital cytomegalovirus infection. ... Congenital hearing loss may also happen after the birth of a child, which is caused by trauma, Meniere’s disease, age-related loss of hearing – presbycusis, and exposure to noise causing machines such as firearms. In order to be able to manage hearing loss, it is advisable to detect senorineural hearing loss at an early stage by the use of high-risk registry. Screening procedures that are conducted in hospitals has great importance in determining audio sensitivity. A child begins learning about language in the womb and staying a minute without sound affects the speech and language development of an infant. Most important domains in the development of a child are speech and language acquisition. A child who has lost speech after acquiring language is able to communicate orally than a deaf child. Early identification of hearing loss enables a child to have high language quotient for development of language as compared to a child who is identified at a later age. From the journal written by Iyer and Oller, there is an interpretive advantage in maturation of children (2008, p.120), as children with similar age are supposed to be alike in several aspects of maturity except when affected with factors such as canonical babbling. However, with a difference in other factors such as hearing, children experience difference in maturation. The explanations for late maturity in children with the onset of canonical babbling in infants with typical hearing are the fact that there are more syllables produced per utterance in sessions of canonicals than when in canonical precessions. The fact that utterances respond to breath, infants with typical hearing problem, who start producing canonical

Strategic Planning for International Tourism Essay

Strategic Planning for International Tourism - Essay Example The current branding strategies will be looked into and other than the analysis, we will look into possible ways or practices that could improve the exposure of tourism in New Zealand and result in an even more successful approach. Currently, New Zealand is one of the top contenders among modern tourist attractions. With its beautiful landscapes, tourist attractions, rich cultures, numerous opportunities for adventures and of course, the Lord of The Rings films sites; New Zealand makes an ideal holiday getaway. (Tourism Information and Accommodation, 2008) With all this and more, anyone's time and money spent in New Zealand will definitely be worthwhile. New Zealand Tourism Online (NZTO) has taken a very user friendly and fun-filled approach towards promoting tourism in New Zealand. They offer a wide range of choices to any tourist depending on their interests, tastes, budget and objective. New Zealand is a place where anyone can have the time of their life, if you're a young kid or a retired corporate executive or a young couple deciding to lay back for a while, New Zealand has something for everyone. Lord of the Rings is a fantasy story written by the author J. R. R. Tolkien. Its movie adaptations have swept the international box office with multiple Academy Awards for the three films made so far; The Fellowship of the Ring, The Two Towers and The Return of the King. It would be nothing new to the fans around the world that New Zealand is home to Lord of The Rings! The three films were shot at different locations in New Zealand. This makes New Zealand one of the hottest modern day tourist attractions, not only for the LOTR fans, but everyone can enjoy the story behind the locations and experience a piece of the amazing saga. 1.1.1 Middle Earth is New Zealand As mentioned earlier, New Zealand was home to the Lord of The Rings movie franchise. The set of Middle Earth was chosen to be the scenic landscapes of New Zealand. The person who chose to shoot the movie here, Peter Jackson, is also a native. The location for Hobbiton was chosen as the hilly area of Matamata, The famous Mt. Doom was actually the Mt Ruapehu. Other than that Queenstown was the used sets for locations such as the Pillars of Argonath and the Eregion Hills. (Lord of the Rings - New Zealand, 2007) New Zealand Tourism Online has made great use of this fame New Zealand has been accredited to. They offer a complete list and description for all the movie sites and ways to experience these locations to the fullest. Also they provide in depth description of the movie itself with images and graphics on the website along with further details. Branding for the Key Destinations' Products The tourism industry of New Zealand has been performing a good job with branding the top attractions and products New Zealand has to offer. The NZTO website features a 'Highlights' section in which they very main key attractions that New Zealand has to offer to tourists are described in detail. The features and attractions listed include: Skiing and snowboarding, New Zealand is one of the top ski holiday destinations in the world. The country offers a variety of locations and terrains for all kinds of snow sporting experiences, from snow boarding to skiing. Apart from that, New Zealand offers extensive training in

Issues, concerns, and challenges in environmental adjucation in the philippine court system Essay Example for Free

Issues, concerns, and challenges in environmental adjucation in the philippine court system Essay Introduction The court system is an integral part of environmental enforcement in the Philippines and has made many important contributions to the field. However, environmental cases do not always progress smoothly through the judicial system. This paper is intended to identify important legal issues in the judicial system that affect or limit environmental adjudication. 2 The issues are divided between access to and competency of justice, and legal procedures. While many of these issues could be analyzed further, this paper will highlight the ones to which attention should be paid in any more comprehensive study of Philippine environmental case law. 3 This paper will also use examples and case studies from the United States to illustrate important legal points, since the U. S. and Philippines have similar legal systems. II. Issues A. Legal Procedure and Rules of the Court Because of their unique and complex nature, environmental cases are sometimes hindered by legal mechanisms and rules of procedure designed for non-environmental cases. These include rules on standing and class action suits that often do not take into account the fact that environmental damage impacts all citizens. Furthermore, the nature and science of environmental violations often means that statutes of limitations, evidentiary rules, and burdens of proof are not suitable. Some of these issues can be handled internally by the judicial system by instructing lower courts to apply rules liberally. The impact of all of these issues, and how many actually present problems for plaintiffs, is crucial. 1. Standing of Plaintiffs and Citizens Suits In environmental cases, a plaintiff may not necessarily be legally injured in the traditional sense by an act of environ-mental destruction to impair his livelihood. For example, plaintiffs cannot recover damages for fish killed by pollution because they lack standing, despite the obvious economic loss they suffered. 4 While the destruction of natural aesthetic beauty is a moral outrage that indirectly harms all citizens, under traditional legal standing person no would have standing to sue. 5 Furthermore, environmental laws are designed to prevent catastrophic harm that is often not imminent or contained to one geographic area, as opposed to the narrow, immediate harms that provide the basis of most standing requirements. 6 Strict rulings on standing could stifle environmental enforcement, especially since the Philippines lacks sufficient enforcement capacity and personnel. The Philippine Supreme Court has held that standing requires: Such personal stake in the outcome of the controversy as to assure that concrete adverseness which sharpens the presentation of issues upon which the court depends for illumination of difficult constitutional questions. 7 The plaintiff himself must have some cognizable and redressable injury. Litigating for a general public interest, or â€Å"mere invocation†¦ of [plaintiff’s] duty to preserve the rule of law†¦ is not sufficient to clothe it with standing†¦. †8 However, the standing requirement is considered a technicality that courts may waive if the case concerns a â€Å"paramount public interest. †9 In its dictum in Oposa v. Factorum, the Court said that children might even have intergenerational standing to sue to prevent the destruction of forests for future generations. 10 There are questions as to the strength of these to reduce the standing threshold for environmental plaintiffs. While courts may waive technical standing provisions when a case deals with a paramount public interest, it is not required to do so. 11 Furthermore, judges may reasonably differ on what constitutes a â€Å"paramount public interest† since there is no overriding theme o define it. For example, in Kilosbayan, the Court found that determining the legality of an online lottery system fell within this definition, whereas in Integrated Bar, it held that determining whether deploying marines for crime deterrence violates the Constitution does not. 12 The Court did reduce some of this ambiguity in Oposa by declaring that the right to a balanced and healthful ecology concerns nothing less than self-preservation and self-perpetuation, presumably a â€Å"paramount public interest. †13 However, because the Court’s discussion on standing in Oposa was dictum, neither this claim nor the right to intergenerational standing is binding law upon the lower courts. 14 Without further guidance from the Court, it is likely that many lower court judges would be reluctant to act boldly by declaring that a particular issue is a â€Å"paramount public interest† and would deny standing. Congress tried to reduce the standing threshold with citizen suit provisions in environmental statutes, but these have been of limited use thus far. First, only the Philippine Clean Air and Ecological Solid Waste Management Acts contain citizen suit provisions;15 notably, the Philippine Clean Water Act, enacted after these two laws, does not. 16 Second, citizens still bear the risk of paying a winning defendant’s attorney’s fees, which could be costly enough to discourage even valid suits. Most importantly, these suits are still subject to the â€Å"actual controversy† requirement of the Constitution. 17 What this means in the context of citizen suits has not yet been heavily litigated in the Philippines. However, lower court judges often require plaintiffs to show actual injury in the narrow or traditional legal sense. 18 Likewise, when prosecutors deputize citizens to enforce a suit, judges sometimes insist that such deputization is only valid for a single case or even invalid under the Rules of the Court. 19 As a result, citizens suit provisions have been largely unused. 20 Standing under environmental laws is hotly contested in the U. S. 21 The U. S. has put citizens’ suit provisions into almost all of its environmental laws. 22 Plaintiffs are required to show 1) an injury in fact, 2) causation between the injury and the defendant’s actions, and 3) redressability in court. 23 NGOs can sue upon a showing that any of their members would have had standing to sue. 24 The focus is not on the injury to the environment, but rather the injury to the plaintiff or NGO representing him. However, the injury can be economic or non-pecuniary, including aesthetic or recreational value. 25 The Court also held that civil penalties payable to the U. S. Treasury serve as redress as they deter polluters. 26 Causation is often the more difficult element to prove, which will be discussed below in  § 4. In New Zealand, the Environment Court has taken a more radical approach. It has eliminated formal standing provisions, requiring only that a plaintiff have a greater interest than the public generally in a controversy or that he represents a relevant public interest. 27 This makes citizen enforcement very easy. However, one might also be concerned about whether this would overburden the court; granting standing is a fine balance between permitting valid environmental claims and risking frivolous litigation. 2. Class Actions and Large Number of Plaintiffs As the notorious mudslide at Ormoc in 1991 and Marcopper mine tailings in Marinduque show, injuries from environmental damage can be grave, costly, and affect a huge number of persons. 28 Even in less publicized events, the number of injured persons may often make individual litigation burdensome and complex. Furthermore, some members of an injured class may be too poor to prosecute their claims individually. Class action suits can facilitate litigation of such situations by providing for: [T]he protection of the defendant from inconsistent obligations, the protection of the interests of absentees, the provision of a convenient and economical means for disposing of similar lawsuits, and the facilitation of the spreading of litigation costs among numerous litigants with similar claims. 29 Other studies have shown that class action suits can provide important social benefits and encourage citizen enforcement to supplement agency regulation. 30 Class actions may the discourage attorney disloyalty that encourages lawyers to plea bargain for less than the actual injury. As happened in the Chinese poachers case in Palawan, lawyers or prosecutors may not seek full compensation for the damage caused because they have an incentive to expend less time and money on a small case. 31 However, because class actions provide aggregate incentives for lawyers, and fees and settlements undergo higher judicial scrutiny, such â€Å"disloyal† settlements are less likely to occur. 32 While the Philippine Rules of the Court provide for class action suits,33 judges will sometimes be reluctant to certify classes and instead treat the injuries of plaintiffs as separate, despite any common questions of law or fact. In Newsweek, Inc. v. IAC, the Supreme Court ruled that a defamatory remark directed at 8,500 sugar planters do not necessarily apply to every individual in a group, and therefore are not actionable as a class action. 34 Likewise, a judge might refuse to certify a class of pollution victims because they suffer different types of physical injuries, even if the source was the same pollution. In a more litigated legal system, there would be more case law to guide judges on the appropriateness of class actions. However, in the Philippines, this does not yet exist. Add to this the high cost for lawyers, and class actions become even less feasible for most Philippine plaintiffs. 35 In the U. S. , it is much easier to litigate environmental class action suits. The Supreme Court has clearly instructed courts to construe its class action rules liberally and encourage class action suits. 36 This limits judicial discretion in refusing to certify classes to only extreme situations. Furthermore, the rules allow plaintiffs to join by default rather than affirmatively. 37 For environmental cases, the courts will look at the potential number of plaintiffs or the size of the estimated areas that a pollutant has infected to see if plaintiffs have met the numerosity requirement, but they are not required to meet a certain minimum number. 38 For the Philippines, which, unlike the U. S. , has too few environmental class action suits, adopting some of these mechanisms may create a more efficient adjudication process for plaintiffs, defendants, and the courts. 3. Statute of Limitations and Delayed Injuries Unlike a traditional tort or crime, many environmental injuries are not discrete events but only manifest themselves after many years. Pollutants may build up in soils, waters, or human bodies for years without reaching a dangerous level. Cleanup of such sites can take even longer. For example, when the U. S. military left Subic Bay in 1992, it left behind hazardous waste sites with contaminated water that continue to poison the land over a decade later. 39 However, for environmental torts, the statute of limitations is four years, a relatively brief time. This could preclude the litigation of injuries from pollutants with an onset delayed for many years. Thus far statutes of limitation issues have not been a significant factor in environmental litigation. The Philippine Supreme Court addresses similar problems in other fields of law with the discovery rule, allowing the statute of limitations to run when the plaintiff actually or should reasonably have discovered the injury. 40 However, as the courts handle more brown environment cases, it will have to address the tensions between punishing past violators and protecting defendants from time-barred claims. 41 U. S. courts have adopted the due diligence discovery rule, particularly for Clean Water Act and wetlands violations. Because immediate detection of pollution or illegal fill into a wetlands is almost impossible, applying a statute of limitations strictly would defeat the remedial purpose of the act. 42 Courts try to effectuate the Congressional purpose of the statute with the due diligence discovery rule and giving the government a chance to file action against the polluter once the violation is reported to the EPA. 43 Some courts44 realize that a statute of limitation may be inappropriate for cases when pollution continues to cause problems over time. These courts argue that a: Defendants unpermitted discharge of dredged or fill materials into wetlands on the site is a continuing violation for as long as the fill remains. Accordingly, the five-year statute of limitations †¦ has not yet begun to run. 45 The statute of limitation will not run for as long as the pollution remains. Many courts will also treat common law tort nuisances as continuing violations. 46 This approach has the added benefit of allowing the government to fine violators for each day the pollution remains, capturing the more of the costs of environmental destruction. 47 Much of U. S. case law regarding the effect of statutes of limitations on environmental issues comes from ambiguities in the statute of limitation for complex processes, particularly the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), or Superfund law. 48 Because Congress anticipated the complexity and long-term nature of site cleanups, it structured the statute of limitations in a flexible manner, allowing the court hear an initial cost recovery action prior to issuing a declaratory judgment to avoid letting the statute run. It also allows the plaintiff to file subsequent cost-recovery actions to recapture further response costs incurred at the site. 49 However, the law’s different statutes of limitation for remedial and removal actions phases of the cleanup has led to confusion over how the phases are defined. Courts often defer to EPA determinations in characterizing the type of action due to its technical expertise, rather than making that judgment itself. 50 4. Meeting the Burden of Proof In environmental cases, there may be no line of direct evidence from the perpetrator to the harm. In pollution cases it is often impossible to prove that the plaintiff’s harm was caused by his exposure to the toxic material. 51 For example, if several factories dump pollution into Manila Bay, it is impossible to determine which caused a particular environmental harm. Furthermore, the courts cannot expect absolute scientific certainty on the effects of a health risk such as electro-magnetic fields from power cables. 52 Given these problems, the traditional burden of proof standards, preponderance for civil cases and beyond a reasonable doubt for criminal,53 may prove to be prohibitively high. Philippine courts employ liability-shifting mechanisms to manage this difficulty in environmental cases. For example, pursuant to the Fisheries Code, courts use reverse burden of proof to place the burden of exculpation on defendants found with high-explosive or cyanide fishing gear. 54 Furthermore, the courts have begun to experiment with the precautionary principle, placing the constitutional rights to health and safety above development. 55 The courts also employs res ipsa loquitor in tort suits,56 although this has not been a prominent feature of environmental litigation. Plaintiffs may also hold multiple defendants jointly and severally liable for an act of environmental destruction that cannot be traced to a single defendant company, such as the pollution in Manila Bay. 57 Until recently, Philippine lawmakers did not see a need to introduce a strict liability58 regime into environmental laws. 59 Strict liability was employed in other fields, but not environ-mental laws. More recent anti-pollution laws such as the Clean Air and Solid Waste Management Acts establish that a violation of the standard is actionable through citizen suits. 60 In U. S. , because of its common law tradition, courts are more willing to employ strict liability. Generally, when a defendant, â€Å"though without fault, has engaged in [a] perilous activity †¦, there is no justification for relieving it of liability. †61 Such â€Å"perilous activities† include operating explosives, nuclear energy, hydropower, fire, high-energy explosives, poisons, and other extremely hazardous materials. 62 For citizens suits under environmental statutes, plaintiffs need only show that the law was violated, not prove fault or any actual or threatened harm, without regard to mens rea. 63 When it is impossible to determine the proportion of fault of a large number of defendants, U. S. courts may approximate fault through other indicators, including market share and production output. For example, in Hymowitz v. Eli Lilly ; Co. , the New York Court of Appeals calculated the size of each defendant drug company’s market share for DES to determine their fault in the injuries caused by the drug. 64 This also allows courts to address injuries sustained in the past by approximating past fault through data available in the present. The Environment Court in New Zealand has adopted an even more radical approach and done away with formal burdens of proof. It focuses instead on obtaining the best possible evidence for a case. This makes it easier for plaintiffs appealing to the court to dislodge an unfavorable opinion from a lower court. 65 While the Philippine Supreme Court may not wish to go this far, the court could more strict liability for hazardous materials and market share liability tools. 5. Damages and Remedies Even if a plaintiff wins damages from a defendant, if the defendant keeps polluting or cutting trees, the damage will continue. 66 In the Philippines, this is particularly problematic as the fines and penalties imposed under law are often not enough to change a company’s behavior. In order to encourage development, Congress prohibited temporary restraining orders against government projects. 67 Since government infrastructure projects can cause massive damage to ecosystems, this prohibition is significant. Some courts try to avoid this loophole by claiming that the prohibition cannot violate a person’s constitutional right to health or safety. 68 The extent of this loophole is unclear. Finally, even if a plaintiff or prosecution wins its case, most of the time the true costs of the defendant’s actions will not be reflected in the award. Damages in civil cases and punishments in criminal cases generally capture the costs of any suffering caused to humans, not animals or plants. While some settlements may include forcing a defendant to install pollution-control equipment or contribute money to conservation programs, this still likely does not recoup the full extent of damage to the environment. It is difficult to regenerate natural forest, coral reefs, or populations of endangered animals. The judicial system does not have much power to remedy this problem. The decision on the purpose of environmental laws and how much plaintiffs recover is for the Congress. However, it is important for judges to understand that environmental cases deal with only a fraction of the true costs of environmental damage. This may convince some judges to be more sympathetic toward environmental cases. While punishments for defendants may seem exorbitant, understanding the unaccounted costs of environmental damage puts these into perspective. B. Access to and Competency of Justice Aside from the legal issues described above, in any country, there are a host of practical and logistical issues that impede the judicial system’s ability to handle environmental cases. This includes the lack of financial resources of plaintiffs, particularly in poorer parts of the Philippines. Plaintiffs and their lawyers must also feel safe from physical and financial harassment while litigating their case. On the other hand, both courts and lawyers are often unfamiliar with environmental laws and science, limiting their ability to adjudicate in the field. Finally, court dockets are often congested, and environmental cases are not given priority. The judicial system’s role in addressing these issues ranges from fairly involved to almost no role. Yet, in attempting to understand environmental adjudication in the Philippines, it is crucial to recognize the role these practical realities play. 1. Financial Costs of Adjudication In any legal system, filing and litigating a case takes an enormous amount of time and money. Philippine courts impose a filing and transcript fee, although these are waived for citizens suits. Reflecting on his experiences, famous environmental attorney Antonio Oposa suggested that these costs were the greatest inhibitions for most plaintiffs. 69 Furthermore, for injunctive remedies, plaintiffs must post a bond to cover the defendant’s potential damages, which may be too large for a poor plaintiff with livestock and property as his only assets. 70 Most Philippine lawyers do not use a contingency fee system, so plaintiffs must be able to pay for legal services up front and over the lengthy litigation process. 71 On top of this, there is the risk of financially crushing harassment suits from defendants, or Strategic Lawsuit Against Public Participation (SLAPP). Even the logistics of feeding and housing witnesses, and their lost time from work, poses significant problems for predominantly poorer plaintiffs. In the U. S. , NGOs often receive enough donations to allow them to engage in litigation and have staff lawyers. More importantly, plaintiffs’ attorneys often work on a contingency basis, allowing poorer plaintiffs to avoid large financial risk. Furthermore, NGOs and environmental groups seeking injunctive remedies are often required only to pay a nominal bond or may be exempted completely. 72 While some might worry this makes litigation in the U. S. too easy, it drastically improves poor people’s access to justice. Pursuant to the Constitution’s emphasis on the poor, the Supreme Court of the Philippines has taken some efforts to alleviate this problem. Poorer plaintiffs are exempted from paying docket, transcript, and other fees and are granted free legal counsel. Furthermore, the Court provides an annual grant to the Integrated Bar of the Philippines’ Free Legal Aid Program. 73 However, not all environmental plaintiffs qualify as poor, particularly NGOs, even though they often have limited financial resources. Furthermore, even though the amount of the bond is under the discretion of the judge, judges are reluctant to do this because they worry about being accused of abusing their discretion. 74 2. Harassment of Plaintiffs and Lawyers Because of the high stakes involved in environmental cases, defendants may go to extraordinary means to intimidate and harass plaintiffs and their lawyers. It is not uncommon for defendants to lodge harassment or SLAPP suits against environmental plaintiffs or DENR prosecutors to attempt to force them to drop their charges. 75 Enforcers who confiscate the equipment of criminals are often sued for robbery. 76 Some defendants take even more extreme means such as physical violence or even murder. 77 Such dangers were recently illustrated by the murder of environmental advocate Elpidio de la Victoria and death threats against attorney Oposa. 78 This makes lawyers unwilling to take on difficult environmental cases. To stifle SLAPP suits, the courts should promptly apply the anti-SLAPP provisions in the Philippine Clean Air and Ecological Solid Waste Management Acts when applicable. 79 This means dismissing any harassment suits as quickly as possible. However, plaintiffs relying on other laws have less protection. 80 Congress must expand the use of anti-SLAPP provisions to other environmental laws. Furthermore, law enforcement must vigorously prosecute any defendants who resort to violence. In short, to facilitate environmental cases, the court must protect the ones bringing the cases. 3. Technical Knowledge Among Judges and Attorneys Judges must decide questions of science as well as law in order to dispose of most environmental cases. This is particularly true for brown issues, which involve uncertain science regarding the exact effects of a pollutant. In the U. S. , scientific understanding of pollutants led to new classes of trespass and tort suits that held emitters liable for their actions. 81 However, both sides in a case will try to use any scientific uncertainty to their advantage, or even create scientific uncertainty even when it does not exist in order to confuse the court. Judges must understand what scientific evidence should be admitted and what is not valid. 82 Judges and lawyers need to understand the science well enough to determine which arguments are unfounded and which are plausible. Because general the courts have general jurisdiction and are not specialized in environmental issues, this problem will have to be addressed by providing judges and lawyers with supplemental training in environmental sciences and law. PHILJA and other organizations are already successfully doing this. 83 Eventually, however, this problem may be resolved through a change in the adjudication system. If the Philippines moves toward environmental courts or administrative adjudication84 (as is being considered), judges would be trained specifically to handle environmental cases. 4. Obtaining and Preserving Evidence For green issues, preserving evidence may be difficult. After an illegal logger or fisher is captured, DENR can confiscate the logs and fish. These goods rot or deteriorate over time. Proper procedure requires taking pictures of the logs and fish for admission into court. Specially trained fish examiners prepare reports on the cause of death of fish. When done correctly, this preserves the evidence for use at court. However, some areas may not have fish examiners on hand or the prosecution may not properly prepare the pictures for admissible evidence. It is not uncommon for custodians of the confiscated items to lose track of them over time. Because cases take so long in the court system, this can be a real problem. 85 It is also difficult for enforcement agents to find and confiscate the equipment and vehicles used in environmental crimes, as the boats and trucks perpetrators use are highly mobile. Despite the inconvenience it may cause defendants, such equipment must be held as evidence and to prevent further environmental damage. The accused, or unindicted conspirators, will often petition for the release of their equipment. 86 Unfortunately, sympathetic lower court judges may sometimes grant these requests, despite the contravening case law. 87 Moreover, prosecutors must have the vehicles stored in a safe area despite the lack of storage space. Finally, it is important for enforcers to determine the location of violators, particularly close to the boundaries of natural parks. Community enforcers may not be trained in determining the exact location of where they apprehended the violators. Wealthier units can use GPS, but often the location of apprehension is disputed. 88 Any doubt in this area can destroy the prosecution’s case. 5. Docket Congestion In many countries, including the Philippines, courts are overburdened with cases. Yet, the Philippines’ forests and animals are already disappearing quickly. Irreversible damage to ecosystems can occur much more quickly than the many years it may take the court system to resolve a case. As Prof. La Vina noted, the environment cannot wait for the court system. 89 According to Justice Nazario, the Philippines needs over 300 trial court judges to fill the vacancies and resolve pending cases. 90 Low pay discourages the few who are qualified. Many of these vacancies are in remote parts of the country, such as Nueva Ecija, Occidental Mindoro, and Surigao Norte, where much of the fishing and forestry violations occur. Furthermore, the Supreme Court is burdened by the large amount of cases granted review each year, including the automatic review for death penalty cases. 91 Given this burdensome congestion, environmental cases are not given any special treatment on their own merits. Criminal environmental cases may be somewhat more expedited because they involve criminal punishments, but most judges and lawyers show no urgency with regard to environmental cases. 92 The Supreme Court attempted to alleviate this problem with Administrative Order No. 150B-93, setting up special courts to handle illegal logging, but these remain underutilized. 93 Until cases can move through the court system more quickly, the enforcement of environmental law will be delayed. III. Conclusion This paper has highlighted important legal and practical issues preventing efficient adjudication of environmental cases in the Philippines. However, due to logistical and budgetary constraints, this paper focused mostly on case law from the Supreme Court and the personal experiences of lawyers. In order to fully understand environmental adjudication throughout the court system, further research should ideally analyze environmental cases from all Municipal and Regional Trial Courts, Courts of Appeal, and the Supreme Court. It is important to see how cases area actually treated, particularly with respect to the issues examined in this paper. Furthermore, there may be important regional variations, particularly between areas with more natural resources and more urban areas. Even before such a study is undertaken, the courts can apply several lessons from this paper in the near future. First, while the courts have already taken commendable steps to waive filing fees and other costs for paupers, as mentioned above the definition of pauper may be under inclusive by not including NGOs. The courts should consider other definitions to reflect the realities of environmental NGOs. 94 Second, the Supreme Court should instruct the courts to dismiss SLAPP suits expeditiously. While the natural resource laws may not have anti-SLAPP provisions, Congress clearly did not intend to encourage such suits and there is nothing legally preventing the courts from dismissing them faster. Finally, the courts can address standing for citizens and class action suits. In particular, it should set out a clear position on standing in environmental cases. Other challenges will require long-term planning for the courts. Reducing the docket congestion is critical to expedite justice, although doing this will likely take years and require more judges. Likewise, the ongoing effort to train judges and lawyers in environmental law and science must continue, particularly as new judges and lawyers enter the judicial system. The courts should also familiarize themselves with the legal mechanisms available to them, particularly in shifting the burden of proof. However, this will be most useful in pollution cases as they become more common in the future. Ultimately, the challenges described above will require multifaceted solutions from various stakeholders in the Philippine legal system. For example, Congress must work to improve standing and citizens suit provisions in other environmental laws. To reduce the financial risk of brining a suit, law firms could move toward a contingency fee system. Furthermore, it is the responsibility of DENR and environmental agencies to ensure that evidence is properly recorded and preserved. Finally, as the Philippine grows and wealth spreads, more plaintiffs will be able to undergo the financial costs of adjudication. Eventually, the best solution to these challenges may come not from within the courts but from a new adjudication system. The U. S. has worked successfully with administrative adjudication for environmental issues in the EPA and Department of Interior. Other countries have set up independent environment courts. Based on the results of further studies and the needs of the country, the Philippines may move to adopt one of these models. This would allow expert adjudicators to handle cases under rules that make sense for environmental issues. Finally, it is important for judges at all levels of the judicial system to understand the severity of environmental degradation in the Philippines. The only redress environmental plaintiffs or prosecutors may have is in their court. Thus, they should not be reluctant to grant standing or award large damages, when appropriate, because doing so will ensure that both humans and the environment have their proper day in court.

Euthanasia (Mercy Killing) Essay Example for Free

Euthanasia (Mercy Killing) Essay The topic I chose is Euthanasia (mercy killing) should be permitted in cases of terminally ill patients. Euthanasia is from the Greek word to die well. In other words, a good death. Some people call it the act of killing a person who suffers from a mental or physician condition. Mercy Killing, is another name for it. Euthanasia (mercy killing) or physician-assisted suicide/PAS, is a confusing and heart-wrenching issue for many. We are all likely to face difficult end-of-life choices at some point, whether for ourselves or for a loved one. I know for me that this is a very hard decision, as much as I would like to be support Euthanasia or physician-assisted suicide/PAS, I could not allow this to be done because of the moral issues and it’s against what GOD stands for. One shot is all it takes to kill a loved adored family member. But is an injection of death a good way to die? With lack of judgment and a bad day someone could be killed. Euthanasia or physician-assisted suicide/PAS is putting people to sleep just like you would put to sleep your dog when he gets too old. Where do we draw the line between murder and helping patients? Is a doctor putting patience to sleep considered murder? Who makes that decision? I watched my sister suffer with pancreatic cancer from the time that she was diagnosed until she passed away. Every time she went for her chemotherapy treatments and returned home, she was sick to the point that she just stopped going places and doing things with the family. I can remember the call that I received from my niece, when they had left the doctor’s office and he had inform them, that there was nothing else that they could do. The cancer has spread through the stomach lining. At that point my sister made the decision to stop the chemotherapy and the doctor put her and family in touch with Hospice. I can still remember the comment that was made by the nurse, â€Å"we are here to make her comfortable living with cancer not to help her die†. By legalizing assisted suicide could send us down a road from which there is no return. We can do far more to aid suffering patients by improving pain management and mental health care through legislative reform than we can by legalizing their self-destruction. I did not expect to get the results that I did receive on Euthanasia (mercy killings) or physician-assisted suicide/PAS. I would like to say that the split was 30/70, which was very surprising to me because I was thinking that the split would have been 50/50. After taking the survey, I found out that most people are against Euthanasia (mercy killings). Based on the comments that I received from my survey, regarding mercy killings and how it was against GOD’s commandments, while others stated that people should not have to suffer and be in pain all their life if there is n o cure for their disease. But just think is an injection of death a good way to die? With lack of judgment and a bad day someone could be killed and how do you bring them back or even live with it. As much as we do not want to see our love ones suffer and be in pain, I just don’t believe I could go through Euthanasia with any of my family members. As much as I may love them I can’t have their death on my hands. Euthanasia (mercy killings) or physician-assisted suicide/PAS, is a decision that you will have to live for the rest of your life. Even though that love one may be suffering and in pain, can you really honestly say that you could be responsible for helping them to die and is this something that you will be able to live with yourself for the rest of your life. Its important to understand the distinction between the terms assisted suicide and euthanasia. The former describes a situation where the doctor (or some other agent) provides the means for a patient to commit suicide, but the patient follows through on the final act himself. Euthanasia, on the other hand, is carried out from beginning to end by a doctor on the patients behalf. In the wake of the Schiavo case, there was much debate over the question of care for the severely handicapped or terminally ill, and what exactly those appropriate levels of care were. At the base level is ordinary care—generally speaking, that which any prudent person would administer in similar circumstances. It could include keeping the room at a comfortable temperature, providing attentive human contact, and ensuring that the patient has enough to eat and drink. Ordinary care is considered mandatory by the Catholic Church. Proportionate treatment (or proportionate means), which is also mandatory, is any medical action that meets all of the following three criteria: (1) It has a reasonable chance of curing the patient or assisting with the cure; (2) it does not carry a significant risk of death; and (3) it does not, in and of itself, present an excessive burden. For example, a sterile blood transfusion during surgery would be considered proportionate treatment, as the risk and burden involved are relatively low compared with its curative potential. Disproportionate means, on the other hand, are not mandatory. If any treatment would present an excessive burden—in terms of finances, emotions, religious beliefs, or the pain of the procedure—or fail to offer a reasonable chance of curing the patient, it is optional. Withdrawing disproportionate treatment is an act that, according to Dr. Kathleen Foley, former chief of pain service at Memorial Sloan-Kettering Cancer Center, respects [the] patie nts autonomous decision not to be battered by medical technology (Competent Care for the Dying Instead of Physician-Assisted Suicide, New England Journal of Medicine). There comes a time when continued attempts to cure are neither compassionate, wise, nor medically sound. Palliative care refers to the alleviation of pain or other symptoms, though some expand the definition to include the provision of mental, emotional, and spiritual support. A caregiver is required to offer palliative care—or at least pain management—as far as he is able, but it is not mandatory for a patient to accept. In fact, as Pope John Paul II said in The Gospel of Life, it is even licit to relieve pain by narcotics, even when the result isa shortening of life, if no other means exist. The issue of artificial nutrition and hydration is not fully defined; the question is currently being examined by the Magisterium, but the most recent pronouncement came from John Paul II himself in March 2004, when he stated that it is immoral to remove a feeding tube from anyone in a persistent vegetative state, calling it euthanasia by omission. Outside of a vegetative state, however, there are situations where a feeding tube would become burdensome and thus constitute disproportionate care—as in the case of a person dying from advanced stomach cancer—so these decisions must be made prudently on a case-by-case basis. For more information on this issue, visit www.euthanasia.com. For frequent updates on current court cases and legislation, checkwww.internationaltaskforce.org, and www.lifenews.com/bioethics.html. Once youve been armed with the latest facts and information, youre ready to begin the discussion. Strategy No. 1: Oppose the Status Quo of End-of-Life Pain Management First, we must recognize a basic truth: Patients in our medical system often have insufficient access to pain relief. Therefore, its vital to support increased patients rights, including access to health insurance, a choice in doctors, the latitude to see an independent specialist, open access to all of ones personal medical records, and the right to use palliative treatments. Its equally important to support the right of doctors to manage their patients pain properly without fear of government interference and prosecution. The issue of pain is an emotionally striking one, so its comforting to know that pain can be controlled. According to a report by the New York State Task Force on Life and the Law titled When Death Is Sought: Assisted Suicide and Euthanasia in the Medical Context, Modern pain relief techniques can alleviate pain in all but extremely rare cases. In fact, according to Dr. Eric M. Chevlen, the director of palliative care at St. Elizabeth Health Center in Youngstown, Ohio, 90 [percent] of cancer patients in pain can have dramatic relief with relatively simple oral therapies. Dr. Chevlen is also the author of the book Power Over Pain: How to Get the Pain Control You Need (International Task Force, 2002), a useful resource for those suffering due to a lack of proper palliative care. The American Pain Foundation estimates that with todays technology, close to 98 [percent] of all pain problems can be relieved or reduced. But most doctors have never actually studied pain in any detail. According toPain Net Inc., Of all pain practitioners, fewer than 10 [percent] are proficient in more than eight out of 130+ diagnostic or therapeutic procedures relative to pain. For this reason, its important to advocate a greater focus on pain in medical schools and continuing-education courses in pain management for all medical doctors, especially those frequently involved in end-of-life situations. We can also urge recognition for patients rights to see pain-therapy specialists (which some health-care plans are trying to restrict). What cannot be accepted is the notion that assisted suicide is a form of comfort care. Dr. Gregory Hamilton, the chair of Physicians for Compassionate Care, put it bluntly in an article in the Oregonian: Comfort care results in a comfortable patient; assisted suicide results in a corpse. Emphasize the Need to Diagnose and Treat Depression One of the chief arguments for PAS appeals to the American ideal of autonomy. The desire for self-determination resonates strongly with many Democrats, and they believe that the denial of these rights is un-American. Of course, a love of personal freedom is not unique to Democrats, and its easy for anyone to agree that we should have the freedom to live our lives as we see fit. But that freedom must come with restrictions. For example, child pornography is illegal in America—even in the privacy of ones home—and no judicious person would consider it a permissible use of our freedom. Clearly, Americans acknowledge the need to limit certain behaviors. The question is, what actions should be permitted or restricted? The issue of autonomy assumes that the person attempting to exercise his personal freedom can make decisions in a rational manner. But in fact, when it comes to requests for PAS, rational decision-making is rarely in play. Suicidal feelings in a person who has been diagnosed with a terminal illness are no different from those experienced by someone who isnt terminally ill. Depression, family conflict, hopelessness, feelings of abandonment—these are the conditions that lead to suicidal thoughts, regardless of ones physical state. According to the British Journal of Psychiatry and the New York State Task Force, between 93 and 95 percent of those contemplating suicide have a diagnosable mental disorder, most commonly severe depression. Is mental disorder also in play for the terminally ill who request suicide? One study in the American Journal of Psychiatry reported, All of the patients who had either desired premature death or contemplated suicide were judged to be suffering from clinical depressive illness; that is, none of those patients who did not have clinical depression had thoughts of suicide or wished that death would come early. The New York State Task Force report states that depression accompanied by feelings of hopelessness is the strongest predictor of suicide for both individuals who are terminally ill and for those who are not. It is depression or other mental illness, not ones physical condition, that makes a person suicidal. Pain plays an obvious part in this—diagnosable anxiety and depression, for example, are higher in cancer patients with pain. Not only is uncontrolled pain an important risk factor for suicide, in that it contributes to hopelessness and depression, but depression and anxiety can often augment the patients experience of pain. This brings us back to the need for pain therapy. The New York State Task Force report notes that the notion of competence to make treatment decisions, or the capacity to make a particular decisionpresumes that the patient is not clinically depressed. In the presence of clinical depression, there can be no true autonomy, no ability to make a rational decision or a clear, objective request for death. The good news is that mental illness, once diagnosed, is treatable. In a 1992 article for American Medical News suicidologist Dr. David C. Clark observed that depressive episodes in the seriously ill are not less responsive to medication than episodes in those who are not. The same opinion is held by Dr. Joseph Richman, former president of the American Association of Suicidology, who wrote in a letter to the editor of the Journal of Suicide and Life-Threatening Behaviour, Effective psychotherapeutic treatment is possible with the terminally ill. And in testimony to the New York State Task Force in 1992, Dr. William Breitbart of the Memorial Sloan-Kettering Cancer Center agreed, reporting that more than 80 percent of their patients diagnosed with major depression can be treated effectively. The New York State Task Force report puts the number even higher, saying treatment for depression resulted in the cessation of suicidal ideation for 90 percent of patients. Finally, its important to remember that the desire for suicide is often transient. In a study published in the Journal of the American Medical Association, the cases of 886 people who were rescued from attempted suicides were followed over a five-year period. At the end of those five years, only 34 had since taken their own lives. Where there is depression, there is no true autonomy. Treating patients for pain and depression, as well as other mental illnesses, can eliminate suicidal desires by giving the patient more control. In that way, we can help them achieve self-determination instead of self-destruction. Strategy No. 3: Oppose Discrimination Against the Disabled and the Poor If any one element has stopped PAS bills and ballot measures from becoming the law of the land, it has been the public efforts of activist groups for the disabled such as Not Dead Yet. While groups like the former Hemlock Society (now named Compassion and Choices) were founded on the belief that some lives were not worth living and that they were doing a service to the disabled by expanding their autonomy to include a right to die, this kind of attitude actually betrays a prejudice against the disabled—one that would inevitably make the right to die a duty to die. This sort of prejudice is already seen on the opposite end of the spectrum in the abortion debate. Dr. Anthony Vintzileos, a board member of the American Institute of Ultrasound Medicine, estimated in a May 2005 article for the New Jersey Record that 90 percent of women who receive a prenatal diagnosis of Down syndrome for their children choose to abort. People with disabilities are considered to have no real quality of life, nothing to contribute, and nothing to live for. The poor are also potential targets. Already receiving substandard medical care, the impoverished will be the last to ask for a second opinion, the first to see themselves as worthless, and the most likely to be dismissed as having nothing to contribute to society. If an authority figure were to counsel a poor person to ease the financial burden of medical care on his family through PAS, it would be difficult to say no. Democrats largely identify themselves as friends of the underdog and protectors of the weak. What better way to open their eyes to the injustice of PAS than by pointing out the potential for victimization of the disabled and poor at the hands of an often profit-driven health-care industry? Strategy No. 4: Examine Data from Europe At this point, your interlocutor will likely argue that Doctors would never do that, or that there should be guidelines to make sure that this victimization could never take place. The best response is simply to have a look at euthanasia in Europe (including its legal form in the Netherlands). Many familiar with the history of euthanasia recognize that the idea was a natural outgrowth of social Darwinism, where the strong survive and the weak are left behind. According to the New York State Task Force report, The practice of mass murder in Nazi Germanybegan with the active killing of the severely ill, and built upon earlier proposals advanced by leading German physicians and academics of the 1920s. Like policies currently advocated in the United States, these proposals were limited to the incurably ill, and mandated safeguards such as review panels. R. J. Lifton, author of The Nazi Doctors: Medical Killing and the Psychology of Genocide, is quoted in the report as saying that the phrases life unworthy of life and killing as a therapeutic imperative were vital in soothing the publics conscience when it came to the Nazi program of genocide: The medicalization of killing—the imagery of killing in the name of healing—was crucial to that terrible step. Its ironic that the Netherlands—whose doctors once refused the Nazis genocidal agenda—is now the site of the most extensive assisted suicide and euthanasia program in the world. Though euthanasia was not legalized in the Netherlands until 2002, it was commonly practiced well before then, with almost no danger of prosecution for the doctors performing it. The International Task Force on Euthanasia and Assisted Suicide reports that, according to the Dutch government–sponsored Remmelink Report examining death rates in Holland from 1990: †¢ 2,300 people died through voluntary euthanasia †¢ 400 died through assisted suicide †¢ 1,040 died through involuntary euthanasia—euthanasia was performed without the patients knowledge or consent, even though 72 percent of those patients had never indicated any desire for it †¢ 8,100 died from a deliberate overdose of pain medication to hasten the patients death, though in 61 percent of these cases the patient gave no consent. Of the estimated 130,000 deaths in Holland in 1990, 9.1 percent were the direct result of assisted suicide or euthanasia. And given that these numbers were voluntarily provided by doctors at a time when euthanasia was still technically illegal, its likely that the actual number of deaths through euthanasia was even higher. According to a February 1999 article in the Journal of Medical Ethics, almost 59 percent of euthanasia cases in Holland in 1995 went unreported, in clear violation of the guidelines in place. However, not a single Dutch doctor was prosecuted under the criminal charges of euthanasia, assisted suicide, or anything related. Euthanasia was technically illegal but not prosecuted in the Netherlands for more than a decade. Today, those over 16 can be euthanized for any reason; in certain circumstances, those as young as twelve can opt for euthanasia. Currently, the Netherlands is considering allowing euthanasia for infants, though some Dutch doctors have openly admitted to euthanizing infants already. Those who believe there is no slippery slope need to take another look. And while some may argue that the situation in the Netherlands at least offers patients more options when faced with end-of-life decisions, the reality is just the opposite. Hospice care—palliative centers that make up an important component of end-of-life treatment—is practically nonexistent in Holland. England, for example, had 183 hospices in 1999. The Netherlands, with a quarter of Englands population, had only three. Clearly, with such easy access to euthanasia, little effort is expended to offer alternatives to end-of-life pain management when its not as cost-effective as a quick death. What does this have to do with the United States? Dr. Herbert Hendin, executive director of the American Suicide Foundation, made the connection clear in his 1996 testimony before Congress, wherein he declared that Dutch patients and doctorssee assisted suicide and euthanasia, intended as an unfortunate necessity in exceptional cases, as almost a routine way of dealing with serious or terminal illness. The [American] public has the illusion that legalizing assisted suicide and euthanasia will give them greater autonomy. If the Dutch experience teaches us anything, it is that euthanasia enhances the power and control of doctors who can suggest it, not give patients obvious alternatives, ignore patients ambivalence, and even put to death patients who have not requested it. This is the safety that guidelines provide, as both history and current events have borne out. If we were to open the doors to PAS in the United States, a brave new world of involuntary euthanasia would be inevitable. Strategy No. 5: Oppose Profiteering by Managed-Care Providers If assisted suicide were legalized, managed-care providers would inevitably embrace it as a money-saving technique. The New York State Task Force report states that under anysystem of health care deliveryit will be far less costly to give a lethal injection than to care for a patient throughout the dying process. A 1998 study conducted by Dr. Daniel P. Sulmasy in the Archives of Internal Medicine found that doctors who are cost-conscious and practice resource-conserving medicine were six times more likely to write illegal, lethal prescriptions for their terminally ill patients. Dr. Diane Meier, a former advocate of assisted suicide, said in a 1998 New York Times article, Legalizing assisted suicide would become a cheap and easy way to avoid the costly and time-intensive care needed by the terminally ill. Substantiating this claim is the fact that Oregons Medical Assistance Program (OMAP) for the poor moved to provide physician-assisted suicide to its recipients as soon as the Death with Dignity Act was passed in 1997. Only 18 months later, the OMAP announced plans to cut back on pain medication coverage for the same population. Hospice care has also suffered—the International Task Force reports that one Oregon insurance company has a paltry $1,000 cap on in-home hospice care. With the cost of a lethal overdose running about $35, there would be little motivation to pay any more for palliative treatment. If this is how a liberal, Democratically controlled state government behaves, is there any doubt how profit-minded managed-care providers would react if assisted suicide were legalized throughout the United States? We would begin to see a new stratification of society, where the under-insured would be advised to settle for assisted suicide, while those with better insurance could get the medical assistance they needed. According to the International Task Force, If policies or laws permitting assisted suicide are approved, assisted suicide could become the only type of medical treatment to which certain people—those who are members of minority groups, those who are poor, or those who have disabilities—would have access. The last to receive health care would be the first to receive assisted suicide. The Dead End of Assisted Suicide Legalizing assisted suicide could send us down a road from which there is no return. We can do far more to aid suffering patients by improving pain management and mental health care through legislative reform than we can by legalizing their self-destruction. Euthanasia, in practice, almost inevitably becomes eugenic in nature, which is an affront to the disabled and a serious threat to the lives of the poor and unwanted. Further, the decriminalization of assisted suicide and euthanasia in Europe has produced horrific results that no sane nation would want to imitate. Its a noble impulse that drives Americans to help those struggling through illness and decline, but we cant let the desire to ease anothers suffering lead us to believe that there are quick fixes or easy answers in euthanasia. Instead, we must respond with love, prayer, and compassion—not with murder. As John Paul II wrote in Evangelium Vitae, True compassion leads to sharing another persons pain; it does not kill the person whose suffering we cannot bear.