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Building Your LPO Before The Business Plan. Essay? In our previous blog, #8220; Before The Business Plan Define Your Life#8217;s Primary Objective #8221; we illustrated the POWER of Essay on Zara Case Analysis, defining your Life#8217;s Primary Objective (LPO) before you start a business plan. A Comparison Study Of Russia Essay? Plus we showed the in Culture Essay 5-Steps to and Estonia Essay, building your LPO. In this blog we will walk you through each of the of tehran 5-Steps in A comparison and Estonia Essay, detail. Drinking Age Usa? Follow along and build your LPO as you go. Step 1) List the A comparison Study of Russia Essay things that you DONT want in al capone biography, your life. Make a list of A comparison, what you dont want in anthem summary, your life. A Comparison Essay? Dont think too much about each item.

List everything you can think of of innovation, that causes you anger, stress, frustration, fear, hatred, embarrassment, and dissatisfactionwhatever it is Study and Estonia Essay, that you do not want in anthem summary, your life. And Estonia? Dont think too much about it, just write as many as you can think of. Drinking Age Usa Change? Then go back over and Estonia, your list, thinking carefully about define reus each item. A Comparison Essay? Notice your feelings, your sense of anthem summary, importance about Study of Russia and Estonia each one. Circle the al capone book few items, no more than five or six, that are the and Estonia most important not to have in prisoner summary, your life. Step 2) List the things that you DO want in your life. A Comparison? Make another long list of Gender Essay, what you do want in Study of Russia and Estonia, your life.

Stay away from material things and al capone book, moneythey have little or nothing to do with your LPO. As before, go back over the list and circle the items you most want to of Russia and Estonia Essay, be part of your life. This time, circle the discovered america items that generate the Study of Russia and Estonia strongest attraction, the strongest positive feelings. Al Capone Biography? Dont circle more than a few itemsone, two, a half-dozen at most. Of Russia And Estonia? Step 3) Set your priorities and break through barriers. Copy the circled items from Gender in Culture your do-want list onto a new list. As you do, think about each item and try to rank it in order of A comparison Study of Russia, importance. Drinking Change? Then for each one, think about what it is that gets in the way.

What blocks you from having your do-wants? Finallyand this is A comparison of Russia and Estonia, importantidentify your self-imposed limitations. What barriers do you put in Stereotypes in Culture, your own way with limiting beliefs about yourself and A comparison Study of Russia Essay, with counterproductive habits? Step 4) Write your own eulogy. Anthem Summary? Think of that far-off day when you are gone and all the A comparison Study of Russia Essay people who are most important to you are assembled at your memorial ceremony. You get to write your own eulogy. What do you want it to in Culture Essay, say? What do you want to be remembered for? What kind of of Russia and Estonia, legacy do you want to leave behind? In the fewest possible words, write a statement of the age usa change essence of your LPO. Try for of Russia Essay a phrase or a single sentence that describes what you want your life to anthem summary, be like in order for it to Study of Russia, express whats most important to you.

Often its easier to know what you dont want than what you do want. A good way to begin the search for define your LPO is to become very clear about of Russia and Estonia Essay all the things you know you dont want. Make a list. Dont stop writing until youve put down everything you can think of. Essay Analysis? There is a basic premise at work here.

It says that focusing on A comparison Essay, what you dont want creates more of the same. Stereotypes? These things you know you dont want are probably things you think about frequently. You probably play them over A comparison and Estonia, and over again in your mind. The result is that you are mentally rehearsing them, practicing them, reinforcing them. In sports and music, there is Essay on Zara, a technique called visualizing. The athlete or musician mentally goes through the right motions in preparation for Study of Russia Essay the actual event. It has been proven to Essay on Zara Analysis, be a. powerful technique for Study of Russia Essay improving performance, and the same technique works for 4 p's of innovation improving any other aspect of Study Essay, your life. But there is a dark side.

If your habit is al capone book, fault finding and Study and Estonia, focusing on Stereotypes Essay, what goes wrong, then your mind stays on the negative, and A comparison Study and Estonia, even though you wish for the positive, you are mentally rehearsing the negative. Its a tough habit to drinking age usa, overcome. And Estonia? After all, if you are told not to think about a pink elephant, whats the reus first thing that pops into your mind? If you are repeatedly told, or tell yourself, to avoid something, what stays on your mind? So why do we start your LPO exploration by focusing on the negative? Its a way of reaching or discovering what you really do want. Once you have a clear picture of what you dont want, it can be a simple process of A comparison and Estonia, reversing the items to determine your truest wants. Expanding on biography book, What You Do Want. When do you feel most free?

What is it that makes you feel most in A comparison Study of Russia and Estonia Essay, touch with yourself? What gives you the greatest sense of of tehran, fulfillment? Everyone has had moments of peak experience. What are those moments for A comparison Study Essay you? What do you want your life to of innovation, stand for?

Whats really important to you? This is A comparison Study and Estonia Essay, what your LPO is reus, all about. A Comparison Study? Again, you start by discovered, making a list. Of Russia And Estonia? Think about what you appreciate, what is al capone book, important to Essay, you, the discovered parts of your life you treasure, what gives you your deepest sense of satisfaction? If your list fills up with material things, dig deeper. Study Of Russia? Your LPO isnt about stuff#8217;.

Its about Stereotypes in Culture being alive. Essay? Expanding on on Zara Case Analysis, What Gets in Your Way. A Comparison Essay? Heres a prediction. As you make your list, you will think of 4 p's of innovation, some things you will be tempted to ignore because, Thats not realistic for A comparison Essay me. Or, Who am I to of tehran, want that? Or, Thats not something a pe. rson li ke me should want. Or, I dont have the A comparison Study ability to define reus, [whatever]. Do not impose limitations on A comparison Study, yourself! For the in Culture most part, limitations turn out to be more imaginary than real. A Comparison Essay? And even completely unrealistic wishes, if they are heartfelt, tell you something about your core value. Thats valuable to summary, know. A Comparison Of Russia Essay? Consider, for discovered instance, David Moss, a 63-year-old owner of and Estonia, a successful auto repair shop in Ohio.

David yearned to Essay, ride the space shuttle. Study Of Russia And Estonia? It was a heartfelt, deep-seated desire of anthem summary, his, but an of Russia, impossible one. So he didnt add it to anthem summary, his do-want list. But he did mention it in a conversation, and it turned out to be an of Russia and Estonia Essay, important hint about his LPO. It turns out anthem summary that being in space, looking back at A comparison Study of Russia Essay the Earth, had qualities that were important to him, and that he imagined would be intensely gratifyingqualities having to do with being in touch with grand ideas of widespread importance.

He learned, after some discussion, that he could get some of that same feeling of gratification and define actus, fulfillment by doing public benefit work in highly visible positions with charitable organizations. He even found a way to involve his business in A comparison, contributing to this higher cause#8217;. His self-limiting perception of the impossibility of space travel had blinded him to a real source of gratification and the wide range of life experiences that could be truly satisfying to him. Anthem Summary? The point? Dont ignore heartfelt desires simply because they seem impossible, undeserved, embarrassing, inappropriate, or not within your grasp. Dig within yourself for the source of the Study of Russia and Estonia Essay emotion behind the prisoner desire, and A comparison Study and Estonia, see where that leads you. More often than not, it will lead you to a new source of 4 p's of innovation, fulfillment. A Comparison Of Russia And Estonia Essay? Consider the following. With a diagnosis of terminal cancer and summary, one leg already amputated, would it be reasonable to think of running across Canada to raise awareness for cancer?

Would it be impossible, embarrassing, inappropriate, and Essay, not within your grasp? Could you run 5,373km before succumbing to the cancer if you hadnt first ignored the anthem summary obvious self-limiting beliefs, like the of Russia and Estonia Canadian hero, Terry Fox? There is greatness within all of us. We see and hear the stories every day. Is it time to anthem summary, create your Terry Fox moment? Is it time for your legacy to A comparison of Russia and Estonia, unfold? I certainly hope so! Your Personal Goals Should Be in anthem summary, Line with Your LPO. Once youve identified your LPO, how do you live day to day in and Estonia, a way that brings it to life? Personal objectives are an al capone book, effective way to do it. If your life is like a puzzle, and Study of Russia and Estonia Essay, your LPO is the key to the big picture, then personal goals are the pieces of the puzzle.

Personal goals and actus reus, objectives are the specific things you want to accomplish within a defined period of time. How Does Your Business Fit into A comparison of Russia and Estonia This Picture? Your business is an important vehicle, maybe the most important vehicle, through which you can achieve your aim. Your business should contribute to the life you want. However, it must still serve your LPO.

It can happen in of innovation, either of A comparison of Russia and Estonia Essay, two ways. Prisoner Of Tehran Summary? You could choose to A comparison and Estonia, develop your business plan in biography, such a way that it frees you to other interests, or the business plan could itself be a reflection of the very essence of A comparison and Estonia, whats most important to you in life. 4 P's? The Business Navigator Program, for instance, is Study and Estonia, such an enterprise. The principles created it as one of their personal objectives, one that contributes greatly to the realization of their LPO. Anthem Summary? What Really Matters is A comparison and Estonia Essay, You.

If you have come to the conclusion that the discovery of of tehran, your LPO is one of the most important things you will discover then you get the point. It may seem a bit odd that in order to A comparison Essay, get your business plan in shape, you first have to reus, look within yourself, but its not really odd at A comparison and Estonia all. Drinking Change? When all is said and Study Essay, done, the al capone bottom linehave we said it enoughis you . In fact, your LPO is really the A comparison Study Essay only time you get to anthem summary, think about you in your business because thereafter it is never going to Study of Russia, be about age usa you it is Study of Russia and Estonia Essay, always going to actus, be about A comparison of Russia your customers . So take this moment and al capone book, discover you and enjoy the Study of Russia Essay process. Questions to Stimulate the LPO Thought Process. Question yourself. Biography Book? Then question your answers. Of Russia Essay? The following list of 4 p's, questions can be helpful for A comparison Study and Estonia stimulating your thoughts and putting you in the right frame of mind for biography working on your LPO. Take time to A comparison Study and Estonia Essay, think about your answers. Of Tehran Summary? There are, of of Russia Essay, course, no right or wrong answers, just answers that are true for you.

Some questions have easy, instant answers, some questions have difficult answers that can take a great deal of thought, and some questions can cause you to rethink your most basic values and attitudes. Anthem Summary? Most importantly, be brutally honest with yourself. What matters most at this point in your life? What would you like to be able to Study, say about discovered your life after its too late to Study of Russia and Estonia Essay, do anything about it? What are your daydreams about? Many years from define actus reus now, at your funeral, what do you hope will be said about you in your eulogy? If you no longer had to work, how would you spend your time? And with whom? What is missing from A comparison and Estonia your life? What would you like peoples perceptions of you to anthem summary, be? Of all the A comparison of Russia things you have done in summary, your life, what has given you the most satisfaction or pleasure?

When you were young, what did you want to Study of Russia, be when you grew up? When you find yourself wishing for Case something, what is Study and Estonia, it? Do you ever find yourself wishing you were different? What do you wish for yourself? Why arent you that way? What do you want to achieve, but you find it impossible to do? What are your greatest strengths? What are your greatest weaknesses?

What do you want your life to age usa change, look and feel like? What gets in A comparison Study and Estonia Essay, your way? What motivates you to anthem summary, perform above and beyond the call of A comparison Study of Russia, duty? What barriers make it impossible? Think again, are those barriers really insurmountable? What do you value most? Whats important to 4 p's of innovation, you? How do you want your life to and Estonia, feel on a day-to-day basis?

With your LPO now defined you have a clearer mindset for on Zara creating a brilliant and A comparison Study and Estonia Essay, aligned business so you#8217;re now ready to build the business plan that will define the anthem summary journey of your business in A comparison and Estonia, a manner that is book, true to YOU. A Comparison Study Of Russia? 1. Drinking Age Usa Change? You can find out Study and Estonia more about what a business plan is and its importance with the international best-selling book CHAOS; How Business Leaders Can Master the define actus reus Power of Focus . Get your FREE copy HERE. Study Of Russia? 2. Use our FREE business planning program FOCUS Yourself; A 7 Module Business Plan Program . Stereotypes In Culture Essay? This is Study and Estonia Essay, not a business plan template; it is biography, a full business plan that is EASY and Study of Russia and Estonia, FAST , making your plan SUSTAINABLE and entirely PRACTICAL . Discovered? Start your business plan NOW. 3. Study? Not sure why you need a small business plan? REGISTER f or a FREE FOCUS Discovery Consultation where you will talk business, your business, with international best-selling author James Burgess.

4. Challenge yourself to FOCUS Your Business In Just 30-Days and learn how to Analysis, build a business that will THRIVE not just survive with our FREE webinar HERE . You must be logged in to A comparison of Russia and Estonia, post a comment. Anthem Summary? August 2017 (1) July 2017 (1) May 2017 (2) January 2017 (2) January 2016 (1) June 2015 (1) May 2015 (3) April 2015 (3) March 2015 (1) August 2014 (1) May 2014 (1) April 2014 (3) March 2014 (2) August 2013 (1) June 2013 (1) May 2013 (2) April 2013 (4) March 2013 (5) November 2012 (3) April 2012 (2) January 2012 (3) December 2011 (1) October 2011 (2) May 2011 (2) November 2010 (7) October 2010 (8) September 2010 (9) Focus 31 2017. Study? All Rights Reserved. | Designed by Paradigmmedia.

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roe vs wade essay Because neither interest is compelling before the second trimester, the State may not regulate abortion in of Russia, the first trimester either to preserve the womans health or to protect the anthem summary life of the unborn child. Id . at 163. After the first trimester, however, the State may regulate the performance of an abortion, but only for the purpose of preserving the womans health, not for the purpose of A comparison protecting the life of the unborn child. After viability, the State may regulate, and even prohibit, abortion to protect the life of the unborn child, except when the performance of the abortion is necessary to preserve the life or health of the woman. Id . at 164-65 (summarizing holdings). Drinking Age Usa? The abortion statutes challenged in Roe , which prohibited abortion throughout pregnancy except to save the life of the mother, did not conform to the Courts trimester framework. Accordingly, they were declared unconstitutional. Id . at of Russia Essay, 164. In Roe , the Court also held that an unborn child is not a person as that word is used in 1 of the age usa Fourteenth Amendment and, therefore, is not protected by either the Due Process Clause or the Equal Protection Clause, id . at 156-59, a holding from which no Justice on the Court then or since has dissented. In Roes companion case of Doe v. A Comparison Study And Estonia Essay? Bolton , 410 U.S.

179 (1973), decided the same day as Roe , the Court struck down various procedural requirements imposed by anthem summary, a Georgia abortion statute based on 230.3 of the Model Penal Code (that the abortion be performed in a licensed and accredited hospital, that the procedure be approved by the majority of a medical staff committee of the hospital, and that two other physicians in addition to A comparison Study of Russia the attending physician certify that the abortion was necessary for one of the reasons specified in the statute). Of Tehran? 3 410 U.S. at 192-200. A Comparison Study Essay? The Court also rejected a vagueness challenge to what remained of the substance of the statute after major provisions of the statute had been declared unconstitutional by a federal district court. Id . at 191-92. 4 Both Justice Byron White and Justice William Rehnquist dissented from the opinions in Roe and Doe striking down the Texas and prisoner, Georgia abortion statutes. Roe , 410 U.S. at 171 (Rehnquist, J., dissenting); Doe , 410 U.S. at 221 (White, J., dissenting from both opinions); id . at 223 (Rehnquist, J., dissenting). I. Essay? The Origins of a Constitutional Right ^ top. Roe , as noted in the Introduction, was based on the right of privacy. As Roe itself acknowledged, however, [t]he Constitution does not explicitly mention any right of of innovation privacy. A Comparison And Estonia Essay? 410 U.S. at define reus, 152.

Nevertheless, in a line of decisions going back to the late nineteenth century, the Court has recognized that a right of personal privacy, or a guarantee of certain areas or zones of A comparison Essay privacy, does exist under the Stereotypes in Culture Essay Constitution. Id . This right of privacy, founded in the Fourteenth Amendments concept of personal liberty, the Court in Roe held, is broad enough to encompass a womans decision whether or not to terminate her pregnancy. Id . at 153. The roots of a right of personal privacy have been found in of Russia and Estonia, the U.S. Constitution in the following places: in the free speech guarantee of the First Amendment, which has been held to protect the possession of pornography in reus, ones home, Stanley v. Georgia , 394 U.S.

557, 564 (1969); in the Fourth Amendment, which secures the right of the A comparison of Russia people against of innovation unreasonable searches and seizures of their persons, homes, papers and effects, and the Fifth Amendment, which prohibits compulsory self-incrimination, see Boyd v. United States , 116 U.S. 616, 630 (1886) (Fourth and A comparison and Estonia Essay, Fifth Amendments protect against on Zara Case Analysis all governmental invasions of the sanctity of a mans home and the privacies of life); in the Ninth Amendment, which preserves other rights not enumerated in the Constitution, Griswold v. Connecticut , 381 U.S. Of Russia And Estonia? 479, 486 (1965) (striking down statute prohibiting use of contraceptives by married couples) (Goldberg, J., concurring) ; in the penumbras (shades) of the Stereotypes Essay Bill of Rights as a whole, Griswold , 381 U.S. at 484-85 ; and in the liberty language of the Due Process Clause of 1 of the Fourteenth Amendment, Meyer v. Nebraska , 262 U.S. 390, 399 (1923) (striking down a state statute forbidding the A comparison of Russia and Estonia teaching of any subject in any language other than English, or the Gender in Culture teaching of modern foreign languages below the eighth grade). The right of privacy, the Court in A comparison Study and Estonia Essay, Roe noted, also has some extension to activities relating to 4 p's marriage, . . . Study Of Russia Essay? procreation, . . Essay? . Study? family relationships, . . . and child rearing and education. Prisoner Of Tehran Summary? 410 U.S. at 152-53 , citing the following cases: Loving v. Virginia , 388 U.S. 1, 12 (1967), recognizing liberty interest in marrying the person of ones choice; Skinner v. Oklahoma , 316 U.S.

535, 541-42 (1942), striking down statute mandating sterilization of certain recidivists; Eisenstadt v. Baird , 405 U.S. 438 (1972), striking down statute prohibiting distribution of contraceptives to A comparison Study unmarried persons; Prince v. Massachusetts , 321 U.S. 158, 166 (1944), recognizing authority of parents over anthem summary, their children, but upholding child labor laws as applied to the children of Jehovahs Witnesses who were distributing religious literature in A comparison Study of Russia Essay, exchange for voluntary contributions; Pierce v. Society of Sisters ,268 U.S. 510, 535 (1925), striking down statute mandating public education of children between the ages of eight and sixteen; and anthem summary, Meyer v. Nebraska (holding described above). II. Critique of A comparison Study Roes Privacy Theory ^ top. The Supreme Courts reliance on privacy theory to support a right to abortion is problematical at of innovation, several levels. And Estonia Essay? First, as the Court itself recognized, Roe , 410 U.S. at 152, the Constitution itself does not expressly mention any right of privacy. To be sure, as Justice Hugo Black noted in his dissent in Griswold v. Connecticut , 381 U.S.

479, 508-10 (1965) (Black, J., dissenting), various provisions of the Bill of Rights protect specific privacy interests, for example, the First Amendments right of associational privacy, the Fourth Amendments protection against unreasonable searches and Stereotypes in Culture Essay, seizures and the Fifth Amendments prohibition of compelled self-incrimination. But the Constitution does not create a general right of privacy. Study And Estonia Essay? See , e.g ., Katz v. United States , 389 U.S. 347, 350 (1967) (Fourth Amendment, which protects individual privacy against certain kinds of drinking governmental intrusions, cannot be translated into of Russia and Estonia Essay, a general constitutional right to privacy). Recognition of a general constitutional right to privacy cannot be reconciled with the care with which the Framers of the anthem summary Bill of Study Rights described the specific rights that were being secured.

Second, the concept of privacy is amorphous and chameleon (or, in Justice Blacks words, broad, abstract and ambiguous, Griswold , 381 U.S. at 509 ). Roe s attempt to collect cases under the rubric of privacy a term that does not even appear in most of the cases cited simply creates an artificial common denominator among a very disparate and largely unrelated group of cases that have nothing to do with the subject of abortion, as the Court in Roe freely admitted: The situation [involving a pregnant woman and her unborn child] . . . is inherently different from marital intimacy, or bedroom possession of obscene material, or marriage, or procreation, or education, with which Eisenstadt and Griswold , Stanley , Loving , Skinner , and Pierce and Meyer were respectively concerned. 410 U.S. at 159 (emphasis added). Define Reus? 6 If a pregnant womans decision whether or not to carry her pregnancy to term is inherently different from all of the of Russia and Estonia privacy cases on which the Court relied, then it is difficult to understand how those cases could possibly support recognition of a right to obtain an abortion. Third, most of the cases Roe cited in support of its privacy theory were decided under one or another of the 4 p's provisions in the Bill of Rights. Roe itself, however, derived the right of privacy (and a subsidiary right to abortion) from the liberty language in of Russia and Estonia Essay, the Due Process Clause of the Fourteenth Amendment, 410 U.S. at Essay Case Analysis, 153, not from any of the specific guarantees set forth in the Bill of Rights. That directly contradicted the Courts express refusal, only a few years earlier in Griswold , 381 U.S. at 481-82, to Study of Russia rely upon age usa change the Due Process Clause in postulating a right of Essay privacy. Fourth, even with respect to Case the Due Process Clause, the Court no longer examines substantive due process claims (of which, more below) through the Study and Estonia Essay lens of privacy, and of innovation, that includes the subject of abortion. A Comparison Study And Estonia? In reaffirming the core holding of Roe that the State may not prohibit abortion before viability for any reason or after viability if the 4 p's pregnant womans life or health would be endangered by continuing the pregnancy the Court, in Planned Parenthood v. Casey , 505 U.S. And Estonia? 833, 846-53 (1992), relied upon the liberty language of the Essay Case Analysis Due Process Clause of the Fourteenth Amendment, not upon privacy theory. A Comparison Study? 7 See also Cruzan v. Director , Missouri Dept of Health , 497 U.S. 261, 279 n. 7 (1990) (analyzing right to refuse unwanted medical treatment in terms of a Fourteenth Amendment liberty interest, rather than under a generalized constitutional right of privacy).

Focusing more particularly on the Fourteenth Amendment, 1 thereof provides, in relevant part, that no State shall deprive any person of of tehran life, liberty, or property, without due process of law . . . . As its language suggests, the A comparison Study of Russia and Estonia Essay Due Process Clause is concerned with the process by which a person may be deprived of life, liberty or property, not the on Zara substance of the law authorizing such deprivation. See Lawrence v. Texas , 539 U.S. 558, 592 (2003) (Scalia, J., dissenting) . It was never the intent of the Framers of the Fourteenth Amendment that the Due Process Clause would serve as a battering ram to knock down statutes the substance of which offended the sensibilities of a majority of Justices who happen to sit on the Supreme Court from A comparison Study Essay, time to time. See Raoul Berger, Government by Judiciary The Transformation of the Fourteenth Amendment (Liberty Fund 2d ed. 1997) 221-39, 273-306. 8 Despite its focus on process, the Due Process Clause, at various times in of innovation, our history, has been given substantive content, resulting in A comparison, the invalidation of state laws thought to 4 p's of innovation be inconsistent with prevailing understandings of liberty. The paradigmatic case in this area, before Roe v, Wade was decided in 1973, is Lochner v. New York , 198 U.S.

45 (1905). In Lochner , the Supreme Court, over the vigorous dissent of Justice Oliver Wendell Holmes, Jr., held that state legislation setting limits on A comparison the number of hours a person could work in a bakery daily (ten hours) and 4 p's of innovation, weekly (sixty hours) violated the liberty of an employer to contract with his employees on terms that were mutually agreeable to them. The notion that the Due Process Clause has substantive (as opposed to only procedural ) content bedeviled constitutional adjudication for a generation, until it was laid to rest, at least with respect to the review of social and economic legislation, in West Coast Hotel v. A Comparison And Estonia Essay? Parrish , 300 U.S. Stereotypes In Culture? 379 (1937), which upheld a minimum wage law. Twenty-five years later, the Supreme Court could state that it had returned to the original constitutional proposition that courts do not substitute their social and economic beliefs for the judgment of legislative bodies. Ferguson v. Skrupa , 372 U.S. 726, 730 (1963). Despite the interment of of Russia what may be called economic substantive due process, libertarian substantive due process is alive and define, well. Under this strand of substantive due process analysis, the Study of Russia and Estonia Due Process Clause provides heightened protection against on Zara Case Analysis government interference with certain fundamental rights and liberty interests. Washington v. Glucksberg , 521 U.S.

702, 720 (1997). Roe v. Wade , while sounding in A comparison Study of Russia, privacy theory, was ultimately based on the liberty language of 4 p's 1 of the Due Process Clause of the Fourteenth Amendment, see Roe , 410 U.S. at 153, and, therefore, may justly be regarded as the modern paradigm of A comparison and Estonia (libertarian) substantive due process analysis. See Richard Epstein, Substantive Due Process by Stereotypes in Culture Essay, Any Other Name , 1973 Sup. Ct. Rev. 159, 184. But Roe flunks the test the Court uses for evaluating substantive due process claims. In determining whether an Study of Russia asserted liberty interest (or right) should be regarded as fundamental for anthem summary purposes of substantive due process analysis (infringement of which would call for Study Essay strict scrutiny review), the Supreme Court applies a two-prong test.

First, there must be a careful description of the asserted fundamental liberty interest. Glucksberg , 521 U.S. at 721 (citation and internal quotation marks omitted). Second, the interest, so described, must be firmly rooted in the Nations history, legal traditions, and practices. Id. at 710. An asserted interest in (or right to) abortion does not meet the second prong of the Glucksberg test. Quite the contrary. As much research has established, especially that of Professor Dellapenna ( see n. 4, supra ) , abortion was a crime in English and American common law, at least after quickening (that stage of pregnancy when the woman first detects fetal movement, usually sixteen to eighteen weeks gestation), and very possibly without such a limitation. With the gradual replacement of common law crimes by statutory crimes in the nineteenth century, the overwhelming majority of States had made the performance of an abortion at any stage of Stereotypes Essay pregnancy a crime well before the Fourteenth Amendment was adopted in 1868. And the case law interpreting these statutes revealed that the principal, if not exclusive, purpose in enacting these statutes was to protect unborn human life, not (or not solely) to safeguard women from dangerous medical and/or surgical procedures. See Paul Benjamin Linton, Planned Parenthood v. Casey : The Flight from Reason in the Supreme Court , XIII St. Louis U. Pub.

L. A Comparison Of Russia? Rev. 15, 109-15 (1993). In light of the foregoing, an interest in (or right to) abortion cannot be said to be firmly rooted in our history, legal traditions, and practices. III. Applications of drinking change Roe ^ top. The Supreme Court has decided almost three dozen abortion cases since and A comparison Study, including Roe v. Wade and Doe v. Bolton . A detailed analysis of the holdings in these cases would unduly prolong the length of this essay. The principal holdings, however, may be briefly summarized:

In addition to the Texas abortion statutes struck down in Roe , the Court has struck down state statutes prohibiting particular abortion methods, Planned Parenthood of Central Missouri v. Danforth , 428 U.S. 52, 75-79 (1976) (saline amniocentesis), Stenberg v. Carhart , 530 U.S. 914 (2000) (partial-birth abortion), but more recently has upheld the federal Partial-Birth Abortion Ban Act, Gonzales v. Carhart , 550 U.S. 124 (2007). The Court has upheld statutes prohibiting non-physicians from performing abortions, Mazurek v. Armstrong , 520 U.S. 968 (1997) ( per curiam ) and drinking change, has held that non-physicians may be prosecuted for performing abortions, Connecticut v. A Comparison Study And Estonia Essay? Menillo , 423 U.S. 9, 11 (1975) ( per curiam ) . The Court has struck down statutes and of innovation, ordinances requiring all abortions (or all abortions after the Study and Estonia Essay first trimester) to be performed in hospitals, Doe v. Stereotypes In Culture? Bolton , 410 U.S. 179, 193-95 (1973) (all abortions), City of Akron v. Akron Center for Reproductive Rights ( Akron Center I ) , 462 U.S. 416, 431-39 (1983) (all abortions after the first trimester), Planned Parenthood Assn of A comparison and Estonia Essay Kansas City , Missouri , Inc. v. Ashcroft , 462 U.S.

476, 481-82 (1983) (all abortions after the first twelve weeks of pregnancy), but has upheld a statute requiring all second trimester abortions to be performed in in Culture Essay, either a hospital or a licensed outpatient clinic, Simopoulos v. Virginia , 462 U.S. 506, 510-19 (1983). The Court has struck down parental consent and notice statutes and ordinances if they did not contain a judicial bypass mechanism that would afford the pregnant minor the opportunity to avoid obtaining the consent of (or giving notice to) her parents or legal guardian, 9 Danforth , 428 U.S. at Study of Russia and Estonia, 72-75 (one-parent consent), Akron Center I , 462 U.S. at 439-42 (one-parent consent without judicial bypass), Bellotti v. Baird , 443 U.S. 622 (1979) (two-parent consent) (inadequate judicial bypass), Hodgson v. Minnesota , 497 U.S. Of Innovation? 417, 450-55 (1990) (two-parent notice without judicial bypass), 10 but has upheld statutes that contained an adequate judicial bypass, Ashcroft , 462 U.S. at Study of Russia Essay, 490-93 (one-parent consent).

Hodgson , 497 U.S. at 497-501 (Kennedy, J., concurring in the judgment in part and dissenting in part), id. at 461 (OConnor, J., concurring in part and concurring in the judgment in part) (two-parent notice with judicial bypass), Ohio v. Akron Center for Reproductive Health ( Akron Center II ) , 497 U.S. 502 (1990) (one-parent notice with judicial bypass), Planned Parenthood v. Casey , 505 U.S. 833, 899-900 (1992) (one-parent consent), Lambert v. Wicklund ,520 U.S. 292 (1997) (one-parent notice) ( per curiam ) . The Court has struck down statutes requiring a married woman to anthem summary obtain the consent of, or give notice to, her husband before undergoing an abortion, Danforth , 428 U.S. at 67-72 (consent), and Casey , 505 U.S. at 887-98 (notice) . The Court has upheld state and A comparison Study and Estonia, federal statutes restricting public funding of abortions, Beal v. Doe , 432 U.S. Drinking Change? 438 (1977), Maher v. Roe , 432 U.S. 464 (1977), Harris v. McRae , 448 U.S. A Comparison Of Russia And Estonia? 297 (1980), and Williams v. Zbaraz , 448 U.S.

358 (1980), as well as state statutes and municipal government policies prohibiting the performance of abortions by public employees within the scope of their employment or in reus, publicly owned and operated facilities (other than those necessary to save the life of the mother), Poelker v. Doe , 432 U.S. 519 (1977), and Webster v. Reproductive Health Services , 492 U.S. A Comparison Study Essay? 490, 507-11 (1989). The Court has also upheld federal administrative regulations (since rescinded) requiring physical and financial separation of Title X family planning projects from other projects operated by Title X grantees that perform, counsel or refer for abortion, Rust v. Sullivan , 500 U.S. 173 (1991). The Court has upheld a requirement that a pathology report be prepared for all fetal tissue obtained in the course of an abortion, Ashcroft , 462 U.S. at prisoner of tehran, 486-90 , but has struck down a requirement that fetal remains be disposed of in a humane and sanitary manner, Akron Center I , 462 U.S. at 451-52 . The Court has upheld some record keeping and reporting requirements, Danforth , 428 U.S. at 79-81 , Casey , 505 U.S. at Study and Estonia, 900-01 , while striking down others, Thornburgh v. American College of Obstetricians Gynecologists , 476 U.S. 747, 765-68 (1986), because of what the Court perceived as inadequate guarantees of Essay Case patient confidentiality. The Court has upheld a requirement that a second physician be present during the performance of a post-viability abortion to provide immediate medical care for a viable child who survives an abortion procedure, Ashcroft , 462 U.S. at 482-86 , but has struck down a second-physician requirement that did not contain an Study of Russia Essay express or implied exception for of innovation medical emergencies, Thornburgh , 476 U.S. at A comparison of Russia, 769-71 . The Court has also struck down standards of care for the performance of post-viability abortions that were either vague, Colautti v. Franklin , 439 U.S. Anthem Summary? 379, 397-401 (1979), or posed an unacceptable risk to the mothers health, Thornburgh , 476 U.S. at 768-69 , but has upheld a statute mandating fetal viability testing at twenty weeks gestation, Webster , 492 U.S. at 513-21 . In a pair of decisions, later overruled in part by Planned Parenthood v. A Comparison Of Russia And Estonia Essay? Casey , 505 U.S.

833 (1992), which is discussed in the next part of this essay, infra , the Court held that States and define actus reus, municipalities could not require a short waiting period before the performance of Study of Russia and Estonia Essay a non-emergency abortion; that they could not required detailed informed consent information to Gender be given to the pregnant woman seeking an abortion; and that they could not require portions of the informed consent information to be conveyed in Study and Estonia, person to of tehran summary the patient by the attending physician, see Akron Center I , 462 U.S. at of Russia, 442-51 and Thornburgh , 476 U.S. at 759-65 . 11. IV. Roe Revisited: Planned Parenthood v. 4 P's Of Innovation? Casey ^ top. In 1992, the Supreme Court revisited Roe and, in a Joint Opinion authored by Justices Sandra Day OConnor, Anthony Kennedy and David Souter, substantially modified its holdings. Planned Parenthood v. Casey , 505 U.S. 833 (1992). In Casey , the Court reaffirmed what it characterized as the A comparison Study of Russia and Estonia Essay essential (or central) holding of anthem summary Roe , consisting of three parts: First, a woman has the right . . . . to choose to have an abortion before viability and to obtain it without undue interference from the State. Before viability, the States interests are not strong enough to support a prohibition of and Estonia abortion or the imposition of a substantial obstacle to the womans effective right to anthem summary elect the procedure. 505 U.S. at 846. Second, the State has the power to restrict abortions after fetal viability, if the law contains exceptions for pregnancies which endanger the womans life or health. Id . And, third, the State has legitimate interests from the outset of the pregnancy in protecting the health of the woman and the life of the fetus that may become a child. Id . While reaffirming the essential (or central) holding of Roe , the authors of the Study of Russia and Estonia Joint Opinion rejected Roes trimester framework as an unnecessarily rigid construct which in its formulation . . . Age Usa Change? misconceives the nature of the pregnant womans interest, and in practice . Of Russia Essay? . . Actus? undervalues the States interest in potential life . Study Of Russia? . . . Id . at 872-73. The trimester framework misconceives the nature of the prisoner of tehran summary pregnant womans interest because [w]hat is at stake is [her] right to make the ultimate decision [to obtain an abortion prior to Study of Russia viability], not a right to be insulated from all others in doing so. Id . at 877. Drinking Age Usa? Though the woman has a right to choose to Study of Russia and Estonia terminate or continue her pregnancy before viability, the Joint Opinion explained, it does not at all follow that the State is drinking, prohibited from taking steps to ensure that [her] choice is thoughtful and Study and Estonia Essay, informed. Id . at 872.

The trimester framework undervalues the States interest in potential life, the Joint Opinion continued, because the anthem summary State has a substantial state interest in potential life throughout pregnancy, id . at 876, not just after viability. In light of their dissatisfaction with the trimester framework of Roe and how it had been applied in of Russia and Estonia, subsequent cases, the anthem summary authors of the Joint Opinion developed a new standard for reviewing pre-viability abortion regulations, the so-called undue burden test. Casey , 505 U.S. at of Russia, 874-79. Under that test, a state regulation [that] has the purpose or effect of placing a substantial obstacle in the path of a woman seeking an abortion of a nonviable fetus is unconstitutional. Id . at 877. Applying that test to the statutes challenged in Casey (multiple provisions of the Pennsylvania Abortion Control Act of 1982, as amended), a majority of the Court upheld the detailed informed consent requirement (including the mandated twenty-four hour waiting period), the parental consent requirement and the record keeping and prisoner of tehran summary, reporting requirements, id . at 881-87, 899-901, but a differently constituted majority struck down the spousal notice requirement , id . at 887-98 . 12 In upholding the informed consent requirement (and the accompanying waiting period), the Court overruled, in part, its earlier conflicting precedents in Akron Center I and Thornburgh . Id . at 881-82. 13. Both Justice Harry Blackmun and A comparison and Estonia, Justice Paul Stevens dissented from the Joint Opinions abandonment of Roes trimester framework and the strict scrutiny standard of review, while Chief Justice William Rehnquist, joined by Justices Byron White, Antonin Scalia and Clarence Thomas, dissented from the reaffirmation of the essential holding of Essay Analysis Roe , arguing that the rational basis standard should be applied to all regulation of abortion.

14. The Joint Opinion in Casey is A comparison Study and Estonia Essay, notable in five respects: First, in reaffirming what it characterized as the essential (or central) holding of Roe , the authors of the Joint Opinion raised the of tehran summary issue but refused to state whether they believed that Roe had been correctly decided as an original matter of constitutional interpretation, Casey , 505 U.S. at 871 ([w]e do not need to say whether each of us, had we been Members of the A comparison of Russia and Estonia Court when the valuation of the state interest [in the protection of potential life] came before it as an original matter, would have concluded, as the Roe Court did, that its weight is insufficient to justify a ban on Stereotypes Essay abortions prior to viability even when it is subject to certain exceptions), 15 relying instead on principles of institutional integrity and the rule of stare decisis [deferring to precedent]. Id . at 845-46; see also id. at 854-69. Second, the Joint Opinion provided no principled basis for distinguishing between the essential (or central) and the inessential (or peripheral) holdings of Roe , reaffirming the former and overruling the latter. As Justice Scalia commented, I must . . . confess that I have always thought, and I think a lot of other people have always thought, that the arbitrary trimester framework, which the Court today discards, was quite as central to Roe as the arbitrary viability test, which the Court today retains. Id . at 993. Study? (Scalia, J., concurring in the judgment in anthem summary, part and and Estonia Essay, dissenting in part). Gender Stereotypes In Culture Essay? Third, in reaffirming the essential holding of Roe , the Joint Opinion abandoned Roes reliance on privacy theory, resting its analysis, instead, on the liberty language of 1 of the Fourteenth Amendment. Fourth, the Joint Opinion tacitly abandoned Roes characterization of the right to abortion as fundamental. 16 And, fifth, the Joint Opinion substituted a new standard of review undue burden in place of the strict scrutiny standard employed in Roe for evaluating fundamental rights, which clearly allows for Study a broader scope of regulation (but not prohibition) of pre-viability abortions. 17.

The strict scrutiny standard of judicial review applies to laws that either interfere with the exercise of Essay Case a fundamental constitutional right ( e.g ., voting) or discriminate on the basis of a suspect classification ( e.g ., race). Study Of Russia And Estonia Essay? A law reviewed under this standard is presumed to be un constitutional and will not be upheld unless its proponents are able to demonstrate that it is necessary to promote a compelling state (or governmental) interest. Few, if any, laws reviewed under this standard survive. At the opposite end of the spectrum is the rational basis standard of review, which applies to almost all other legislation. 18 Under this standard, a law is anthem summary, presumed to be constitutional and will be upheld so long as it has a rational relationship to A comparison and Estonia any legitimate state (or governmental) purpose. Most laws reviewed under this standard survive constitutional scrutiny. V. The Roberts Court and the Future of Abortion Jurisprudence ^ top. Under the leadership of Essay on Zara Analysis Chief Justice John Roberts, the Supreme Court has taken a more cautious approach to A comparison and Estonia Essay the review of abortion regulation. Most obviously, the Court, in an opinion by Justice Kennedy, upheld the federal Partial-Birth Abortion Ban Act in Gonzales v. Carhart , 550 U.S. 124 (2007) ( Carhart II ), after a differently constituted Court struck down a similar (but more vaguely worded) state statute only seven years earlier in Stenberg v. Carhart , 530 U.S.

914 (2000) ( Carhart I ). Less obviously, the Court has suggested that, at least with respect to the regulation of abortion, facial challenges, i.e ., a claim that a given statute is unconstitutional in its entirety, are disfavored, Carhart II , 550 U.S. Drinking Change? 124 at 130 (these facial attacks should not have been entertained in the first place), and as-applied challenges, i.e ., a claim that a statute is unconstitutional in particular circumstances, are preferred, id . at A comparison Study of Russia, 168 ([a]s-applied challenges are the basic building blocks of define actus reus constitutional adjudication) (citation and internal quotation marks omitted). Relatedly, in another decision of the Roberts Court, the Court unanimously held, in an opinion by Justice OConnor, that when only and Estonia, a limited number of of innovation applications of an abortion statute would be unconstitutional, the A comparison Study of Russia proper remedy (if otherwise consistent with legislative intent) is to enjoin enforcement of those applications only, not to Essay on Zara Analysis declare the entire statute unconstitutional. Ayotte v. A Comparison? Planned Parenthood of Northern New England , 546 U.S. 320, 328-31 (2006) (reviewing parental notice law). Significantly, in Ayotte , Justice OConnor acknowledged that the Court did not take this more circumspect approach in Carhart I, id . at 330-31 (explaining that the parties . . . did not ask for, and Case Analysis, we did not contemplate, relief more finely drawn than complete invalidation). 19. In light of the Roberts Courts more cautious approach to the review of A comparison Study and Estonia abortion legislation, fewer challenges to abortion statutes may be expected. Moreover, even with respect to those challenges that are brought and anthem summary, are determined to have merit, both the Supreme Court and the lower federal courts are likely to strike down the statute and enjoin its enforcement only with respect to its invalid applications, not in its entirety. VI.

A Comment on A comparison Study of Russia the Scope of the Health Exception ^ top. Finally, a brief comment on reus an unresolved area of abortion law the scope of the health exception required by Roe (as reaffirmed in Study of Russia, Casey ). In Roe , the Supreme Court held that the States may prohibit abortion after viability except when it is on Zara, necessary to preserve the Study life or health of the anthem summary mother. 410 U.S. at 164. The Court, however, did not define the term health. In the companion case of Doe v. Bolton , the A comparison Study Court considered a challenge to of tehran what remained of the Georgia abortion statute after major provisions of the statute had been declared unconstitutional by A comparison Study of Russia and Estonia Essay, a federal district court. As a result of the district courts decision, a physician could perform an abortion whenever he determined, in his best clinical judgment, that the abortion was necessary. At issue in Doe was whether this standard was impermissibly vague. The Court concluded that it was not: [T]he medical judgment [as to of innovation whether an abortion is necessary] may be exercised in the light of all factors physical, emotional, psychological, familial, and the womans age relevant to the well-being of the patient.

All these factors may relate to health. Whether Doe , properly understood, mandates an Study of Russia and Estonia Essay open-ended health exception for post-viability abortions is debatable. Although there is the merest hint in one older case that the Court (as then constituted) may have regarded the broad language in Doe as a limitation on the States authority to prohibit post-viability abortions, see Colautti v. In Culture Essay? Franklin , 439 U.S. 379, 400 (1979), the Court has never directly considered the validity of a post-viability ban. Lower federal courts have read Doe as a gloss on the scope of the health exception that must be included in any post-viability ban, 20 but that reading misinterprets Doe , as Justice Thomas noted in his dissent from the A comparison Study and Estonia Essay denial of of innovation certiorari in A comparison Study of Russia, Voinovich v. Womens Medical Professional Corp . , 523 U.S. 1036 (1998): Our conclusion that the statutory phrase at issue in Doe [whether the abortions was necessary] was not vague because it included emotional and psychological considerations in no way supports the proposition that, after viability, a mental health exception is required as a matter of federal constitutional law . Drinking Change? Doe simply did not address that question. 523 U.S. at 1039 (emphasis in original). As things now stand, whether the open-ended health language of Doe is a limitation on A comparison of Russia and Estonia Essay the authority of the States to prohibit post-viability abortions remains an open question, but one that should be answered by a challenge to an appropriately drafted statute. Given the present composition of the Court, there is reason to Stereotypes in Culture believe that such a statute would be upheld. In recognizing a constitutional right to abortion, the Court in Roe believed that it was meeting the profound problems of the A comparison and Estonia Essay present day. 410 U.S. at 165.

The problems which the Court thought would be ameliorated by its decision included the medical risks associated with pregnancy, a distressful life and future for the pregnant woman confronted with an unwanted pregnancy, [p]sychological harm, the difficulty in drinking, providing child care, the distress, for all concerned, associated with the unwanted child, the problem of bringing a child into a family already unable, psychologically or otherwise, to care for it, and, for of Russia and Estonia Essay some, the additional difficulties and continuing stigma associated with unwed motherhood . . On Zara? . . Id . at 153. More than thirty years of experience with legalized abortion has failed to solve these problems, as well as others for which abortion was touted as a panacea (crime and poverty). Indeed, the regime of legal abortion has aggravated them. See Clarke D. Forsythe and Stephen B. A Comparison Study Of Russia? Presser, The Tragic Failure of Roe v. Wade: Why Abortion Should be Returned to the States . 4 P's? 10 Tex. Rev. of A comparison Study of Russia and Estonia Essay Law Politics 85, 108-36 (Fall 2005). In reaffirming, as modified, Roe in Casey , the Supreme Court call[ed] the contending sides of a national controversy to end their national division by define actus, accepting a common mandate rooted in the Constitution. 505 U.S. at 867.

Given the Study and Estonia issues at stake in abortion, that call, not surprisingly, has not been heeded. The abortion liberty has no roots in the Nations history, traditions and drinking, legal practices. And the national division over the abortion controversy, which Roe created and Casey continued, will not end until, initially, the Supreme Court returns the issue of abortion to the States and, eventually, the Constitution is amended to Essay protect the lives of all unborn children. A discussion of the various standards of judicial review may be found in Part IV of this essay, infra . back. When Roe was decided, an unborn child was viable, i.e ., capable of living outside of 4 p's of innovation his or her mother, at twenty-eight weeks of A comparison of Russia Essay gestation.In light of medical advances made since Roe , viability may occur at twenty-three to twenty-four weeks, or, in some instances, even earlier, as the 4 p's Supreme Court recognized almost twenty years ago in Planned Parenthood v. Casey , 505 U.S. 833, 860 (1992) (noting that viability may occur at twenty-three to twenty-four weeks). A Comparison Study And Estonia? back.

Section 230.3 of the Model Penal Code, one version or another of which was adopted by thirteen States before Roe v. Wade , allowed abortion whenever the 4 p's of innovation physician believed that there was a substantial risk that continuance of the pregnancy would gravely impair the physical or mental health of the mother, that the child would be born with grave physical or mental defect, or that the pregnancy resulted from A comparison of Russia and Estonia, rape, incest, or other felonious intercourse.In Doe , the Court also struck down a requirement that an drinking change abortion could be performed only upon a bona fide resident of the State of Georgia. Doe , 410 U.S. at 200. back. As a result of the A comparison Study Essay district court's judgment, a physician could perform an abortion whenever, in his best clinical judgment, the prisoner procedure was necessary. back. Interested readers, however, may wish to consult some of the following sources. An early critique of the Court's handiwork in Roe , which includes a brief review of the initial academic responses to Roe (both favorable and unfavorable) is John T. Noonan, Jr.'s, A Private Choice: Abortion in A comparison of Russia Essay, America in the Seventies (The Free Press 1979). Dennis J. Horan, Edward R. Grant and Paige C. Cunningham (eds.), Abortion and the Constitution: Reversing Roe v. Wade Through the Courts (Georgetown University Press 1987), is a compendium of articles written by Analysis, a variety of authors criticizing various aspects of the holdings and analysis in Roe . A Comparison Of Russia And Estonia Essay? The most comprehensive and of tehran, thorough analysis of Roe's treatment of the historical treatment of abortion in Study and Estonia, English and American law, as well as the restatement of that history in James C. Mohr's Abortion in America (Oxford University Press 1978), is define reus, Joseph W. Dellapenna's Dispelling the Myths of A comparison of Russia and Estonia Essay Abortion History (Carolina Academic Press 2006) (an extremely abbreviated version of Professor Dellapenna's analysis appears in Abortion and Essay, the Constitution , supra , at A comparison, 137-58). A concise critique of the Court's historical excursus in drinking change, Roe , particularly its explanation for the reasons nineteenth century abortion statutes were enacted, may be found in Appendix A to Paul Benjamin Linton's article, Planned Parenthood v. Casey : The Flight from Reason in the Supreme Court , XIII St.

Louis U. Pub. L. Rev. 15, 103-19 (1993). The poor quality of the analysis and reasoning in Roe has led some academics to rewrite the opinion. Of Russia And Estonia Essay? A collection of such opinions and opposing dissents, along with a useful selected bibliography, appears in Jack M. Balkin (ed.), What Roe v. Wade Should Have Said (New York University Press 2005). back. All of the drinking age usa holdings in these cases, and the full citations thereto, appear in Part I of Study and Estonia Essay this essay, supra . back.

Planned Parenthood v. Casey is discussed in more detail in drinking age usa change, Part IV of this essay, infra . back. Justices Oliver Wendell Holmes, Jr., Louis D. Brandeis and Hugo Black, as well as Judge Learned Hand, who served on the Second Circuit Court of Appeals for decades, all agreed that the use of the liberty language of the Due Process Clause to invalidate the substance of state enactments is fundamentally illegitimate. See Berger, Government by Judiciary , at 227-28 n. 27 (Black), 282 n. 46 (Holmes, Brandeis and Study of Russia and Estonia, Hand). back. Consent of (or notice to) a parent or legal guardian may be waived by a court in a judicial bypass hearing if the minor can demonstrate to the satisfaction of the court that she is mature enough to make the decision to obtain an abortion without the consent of (or notice to) her parent(s) or legal guardian, or, alternatively, that obtaining consent (or giving notice) would not be in her best interests. The Court has upheld both consent statutes, see , e.g ., Planned Parenthood v. Casey , 505 U.S. Define? 833, 899-900 (1992), and Planned Parenthood Ass'n of Kansas City , Missouri v. Ashcroft , 462 U.S. 476, 490-93 (1983), and notice statutes, see , e.g ., Ohio v. Akron Center for of Russia Reproductive Health , 497 U.S.502 (1990), and Hodgson v. Minnesota , 497 U.S.

417 (1990). back. See also Ayotte v. Drinking Change? Planned Parenthood of A comparison Study Essay Northern New England , 546 U.S. 320 (2006) (one-parent notice statute could not be enforced constitutionally in medical emergencies requiring the immediate performance of an abortion). back. A general and non-specific requirement that a physician obtain the informed consent of the patient before performing an abortion was upheld in Danforth , 428 U.S. at 65-67. Anthem Summary? back. The Court also upheld the medical emergency definition. Casey , 505 U.S. at 879-80. back.

The holdings in Akron Center I and A comparison Study of Russia and Estonia Essay, Thornburgh are discussed in drinking, Part III, supra . back. These alternative standards of of Russia and Estonia review are discussed below. back. See also id. at actus reus, 853, 858, 864, 869. back. Nowhere in the Joint Opinion is the right to abortion described as fundamental. back. The Joint Opinion in Essay, Casey has been subjected to withering criticism. See Paul Benjamin Linton, Planned Parenthood v. Casey : The Flight from Reason in the Supreme Court , XIII St. Of Innovation? Louis U. Pub. L. And Estonia? Rev.

15, 103-19 (1993); Michael Stokes Paulsen, The Worst Constitutional Decision of All Time , 78 Notre Dame L. Rev. 995 (2003). Casey is of innovation, also extensively discussed and critiqued in A comparison and Estonia, Professor Dellapenna's magnum opus , Dispelling the Myths of Abortion History , supra , n. 4. back. Under federal constitutional equal protection doctrine, an intermediate standard applies to classifications based on sex or illegitimacy. Under that standard, often referred to as heightened scrutiny, the anthem summary classification must be substantially related to an important state (or governmental) interest. back.

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Book Condition: Very Good. Edition Unstated. All pages clean. Quantity Available: 1. Category: Film, Radio Television; ISBN: 0156309203. ISBN#x2F;EAN: 9780156309202. Pictures of prisoner summary this item not already displayed here available upon request. Of Russia And Estonia Essay. Inventory No: 1560719443. Bookseller Inventory # 1560719443. Item Description: HOUGHTON MIFFLIN HARCOURT, 1969. Trade Paperback. Book Condition: Good.

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Pages clear and bright. Binding tight. Anthem Summary. Bookseller Inventory # M9690. Sergei Eisenstein; Translator-Jay Leyda. Item Description: Harcourt, 1969. A Comparison. Paperback. Book Condition: Used: Good.

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Communication Research and of Russia, Advertising Essay. Content analysis of different creative concepts and their characteristics applied in eight selected advertisements found in two publications weekly magazines Drum and You of July 11, 2013. 1.1Main issue criteria. Creative concepts applied in the advertisement will play a meaningful role whether the actus reus campaign succeeds or not. Pictures, text and captions are but some of the few items that are used to structure the advertisement. Study Of Russia And Estonia Essay! In other instances, advertisers use unique payoff lines which enable them to be a cut above the rest. 1.1.1Nature of research. The research approach is both qualitative and quantitative. The use of narrative data on 4 p's the study prompted the adoption of qualitative approach.

The quantitative approach came as a result of a data that was counted and A comparison Study, numerically measured. The nature of the research is change, cross-sectional. The study is conducted through the and Estonia use of July 11, 2013 editions of on Zara Case Analysis, Drum and You. Both are weekly magazines. Therefore research findings are limited to the abovementioned period. Exploratory and descriptive studies are used to determine characteristics of creative concepts used in selected advertisements for A comparison and Estonia, the research project. The issue at hand is to look at creative concepts used by various advertisers from the age usa change selected advertisements published in the July 11, 2013 editions of Drum and You.

A content analysis of two publications Drum and You and A comparison Study of Russia Essay, promotional messages carried through the use eight selected advertisements. Every study conducted has to anthem summary, meet research criteria. It had to be relevant, researchable, cost-effective and Study of Russia, should not violate acceptable ethical standards. Drum and You form part of the print media which remain vital component of mass communication. Advertisers also used these platforms to reach out to the target market. Prisoner Summary! As a result of that, the research issue is relevant and meets the criteria for communication research.

Every newspaper and magazine carries various advertisements. Advertisers pay for the space booked in the publication. The study will therefore be easily conducted due to the growing number of businesses that used these platforms to A comparison of Russia, promote their goods and services. Every advertisement has atleast a creative concept. Drum and You have been readily available. There were other daily and weekly newspapers to choose from.

The same goes about magazines; there were weekly and Stereotypes, monthly magazines which were available at a reasonable cost. A Comparison Essay! One has chosen these two publications as they were already in the collection. They form part of researchers regular weekly and monthly read. Decision to choose the two publications was somehow influence by the content they offer. The other one carries women issues while the next one is for soccer enthusiasts.

Advertisements used will be acknowledged in the sources consulted section. Anthem Summary! The same will apply about publications that carried them, Drum and You. Two publications have been chosen to conduct the research; they are July 11, 2013 editions of Drum and A comparison and Estonia Essay, You both are weekly magazines. The study analyses creative concepts applied in the advertisements. 3.1Brief background of the publications. It is imperative to know about the publications used for the study.

In this research we use popular weekly publications. Drum is a family magazine mainly aimed at black readers and contains market news, entertainment and feature articles. It was established in 1951 as African Drum by Essay, former test cricketer and of Russia, author Bob Crisp and Jim Bailey. In 2005 Drum was described as the first black lifestyle magazine in Africa. Drums heyday in the 1950s fell between the Defiance Campaign and the tragedy at Sharpeville. This was the anthem summary decade of potential Black emergence, the decade when the Freedom Charter was written. The aim was to promote an equal society. The Nationalist government responded with apartheid crackdowns and treason trials. A Comparison Study Of Russia! Drum was a record of naivety, optimism, frustration, defiance, courage, dancing, drink, jazz, gangsters, exile and death. The magazine described the world of the urban Black; the culture, the on Zara Analysis colour, dreams, ambitions, hopes and struggles.

The backbone of the magazine was crime, investigative reporting, sex (especially if across the colour line) and sport. This was fleshed out by imaginative photography. The formula worked and made for compulsive reading. Each issue of Drum was read by up to nine people, passed from hand to hand on the streets, in the clubs or on the trains. It became a symbol of Black urban life. About 240000 copies were distributed each month across Africa. This was more than any other African magazine. 3.1.2You. You is Study of Russia, a South African family magazine which is aimed at demographically diverse South African English-speaking readers of different ethnicities with coverage on current events and interesting people.

It has two sister magazines: Huisgenoot (aimed at White and Gender in Culture Essay, Coloured Afrikaans-speaking. readers) and Drum. The You magazine was launched in A comparison Study of Russia Essay, 1987 by Nasionale Pers, which later became Media24. Summary! You is published in and Estonia Essay, Cape Town. The publication covers human interest articles, celebrity news, both local and international current affairs. The study will be conducted in Bloemfontein, Free State. Actus Reus! The researcher is based in the Free State capital hence the reason for the study to be conducted in the area. 3.3Nature of the time dimension.

This is a cross-sectional study which will be conducted through the A comparison Study and Estonia Essay use of Drum and You July 11, 2013 editions. Drum has variety of advertisements targeting general society, from body lotions to luxury vehicles. You on the other hand had advertisements such as education, mens health promotions and cellphones. The study will be conducted between July and September 2013. 3.3.1Motivation for drinking, choice of time. Both copies of Drum and of Russia and Estonia, You have been purchased a few weeks after one has registered for anthem summary, the course Communication Research (COM3706). Advertisements which met basic requirements for the assignment were readily available. This is the main reason why the choice of time is relevant to pursue the A comparison Study and Estonia study. According to Van Rensburg (2010:150) a population can be defined as the on Zara Analysis entire group of persons or set of Study of Russia, objects and events the researcher wants to study. According to Du Plooy, GM (2009:109) target population is the actual population to which the anthem summary study is used to generalise results.

The population for the study has to of Russia and Estonia, be all the newspapers and magazines from which various advertisements were reviewed before a final decision was taken by the researcher. Eventually two publications Drum and You were. identified. Four advertisements have been selected from each publication. Both copies have carried many other advertisements but the assignments requirement is to select just four of them from a copy. The researcher has gone through weekly and weekend newspapers. They included Sowetan, Daily Sun, The Citizen, The New Age, Mail Guardian, City Press and Sunday Times. On the other hand magazines included KickOff, Move, Real, Soul, True Love, Drum and You. In this regard, the of innovation accessible population is the publications from which the sample will be drawn for the study.

Drum and You are conveniently available for the researcher to and Estonia, identify advertisements that will be analysed for research purposes. Advertisements comprise various creative concepts to make sense of the meaning and messages conveyed to the target market. Therefore various population parameters have been used to achieve advertisers goal with the published promotion. In the study, we have seen how pictures, punchy headlines, well-designed texts, among others, were used to draft different creative concepts. Below is the list of four population characteristics that one reported about in the research findings. ? Colour codes applied. 4.4Units of analysis. The smallest units that were analysed for the study, among others, include well-designed texts to differentiate certain products from that of their competitors. Pictures of the advertised products were also attached. In Drum, DSTV, Rajah, Playtex and Edgars advertisements have been identified.

for the research. On the other hand, in anthem summary, You the Study of Russia and Estonia Essay researcher has identified advertisements of Kentucky Fried Chicken (KFC), Samsung, Dermalex and Regal Pet Health. Various eye-catchers have been applied in the advertisements used for the study. Subheadings were punchy, but we cannot confirm if they were indeed factual. Headlines and pictures seemed to complement each other. Drinking Age Usa! So far, headings that promised customers benefit appeared to A comparison Study and Estonia Essay, work the best. One has analysed pictures and graphics used, slogans, text applied, including headlines used in the advertisement. The abovementioned elements form a backbone in Analysis, making sense of creative concepts. Lingerie designers use young, beautiful ladies in their promotional campaigns to drive the message home that their underwears will make them look stunning and Study Essay, energetic.

Advertisers use slogans to of innovation, catch the attention of Study of Russia and Estonia, consumers and thus ensuring that they easily recall their products. And more importantly, they were able to define reus, differentiate them from those of their competitors. Amplification creative concept becomes a must when advertisers promote expensive goods such as cars. Brand names are repeated more than once in the advertisements and this is done through the Study use of well-designed texts, logos and pictures. Do lingerie designers use young and gorgeous ladies to promote their wears? Do advertisers use slogans to get the attention of consumers in order to ensure that they recall their products and not confuse them with those of.

Is an amplification creative concept a must when advertisers promote expensive goods such as cars? Do brand names get repeated more than once in the advertisements through the Gender Stereotypes in Culture Essay use of well-designed texts, logos and pictures? 6GOAL and OBJECTIVES. The study seeks to investigate practical issues which are creative concepts used in advertisements. 6.1Nature of the goal. The nature of the research is applied goal. The researcher has investigated how creative concepts can be more effective in the advertisements.

The study is more practical as one had to cut advertisements from Study and Estonia Essay both Drum and You magazines before they could be converted into soft version via the use of a scanner. 6.2Relationship of goal to the main issue. By its own nature applied communication research is descriptive and 4 p's, explorative. This is also the case with the study the A comparison of Russia and Estonia researcher is persuading. The explanatory objective is as a result of practical exercises to be conducted throughout the course of the study.

The descriptive objective is as a result of determining how creative concepts will be applied in the selected advertisements from Drum and You. Does the use of young models in lingerie effective to attractive customers and connect them with the benefits of the advertised underwears? Can advertisement deliver the good message to anthem summary, the intended audience even if the slogan was not applied to the optimum use? Why is it so vital to use amplification creative concept over others when promoting expensive goods such as vehicle? What is the role played by headlines, pictures and copy text in conveying the of Russia and Estonia advertisement message? The theory that is drinking change, applicable for the study will be explained through both connotative and A comparison Study of Russia Essay, denotative. Some of the anthem summary creative concepts used are attached to literal meaning while others are figurative. For instance, some beauty products claimed that they will enhance the skin of young ladies and they will appear more attractive than ever before after using their lotions. The use of young models offered the literal meaning as one could easily associate with what was seen on the photo accompanying the advertisement.

Ponds and Johnsons African Nurture are case in point in this regard. Figurative meaning, for example, can be seen in the Toyota Etios advertisement. Study Of Russia And Estonia Essay! The words such as, Take your smile for a test drive. It was a figurative expression that one will be happy to drive the car and prisoner of tehran, the testimony of that can be found in A comparison Study and Estonia Essay, the test drive. 8.1What each creative concept mean. Pink is the Essay Analysis feminine colour. The Ponds and Johnsons African Nurture advertisements made use of the colour as they promote womens beauty products. The happy looking ladies, who have been used as the faces of these products, somehow, were a sign of the benefit that comes with their use. The promise of benefit was one of the fundamental creative concepts. The ladies were used as a proof to of Russia, the claim that was made by the advertisers that their products will do wonders for the users.

Another colour that was used by the advertisers was yellow. Age Usa Change! The denotative meaning of the colour was happiness. The Toyota Etios advertisement promised users some excitement as they will be smiling. The yellow colour was used extensively in the background of the advertisement. The same colour yellow was used heavily in yet another Johnsons African Nurture advertisement. Study! We have seen a group of actus, young gorgeous ladies, mostly dressed in of Russia Essay, yellow dresses, overjoyed after using the anthem summary beauty-enhancing product. A factual approach was applied that one can hammer on was in the SuperSport advertisement of HD-PVR Decoder. Of Russia Essay! Action pictures of footballers such Orlando Pirates striker Benni McCarthy and Chelsea forward Fernando Torres have been used to drinking age usa change, back up the story.

Over and above watching high definition pictures on television, viewers will have the benefit of watching best football matches in Europe the live coverage of Barclays Premier League, Spanish La Liga, Germans Bundesliga, South Africas Premier Soccer League and the UEFA Champions League matches. Slogans on the other hand form a vital component. The advertisements of Peugeot, Toyota and Ponds were among those that have used this creative concept to back up their brands. A detailed explanation of the new Toyota Etios summed up the use of amplification creative concept in A comparison of Russia and Estonia, the advertisement. Users were informed in not so many words about the define actus benefits of the car and of Russia and Estonia, which features have been installed. Both the Johnsons African Nurture advertisements were loaded with the appeal creative concept.

They were specifically targeted at African women. The SuperSport advertisement provokes curiosity while it also had the slogan on, World of champions. They urge readers and welcome them to the next. level. It was a metaphor used to urge readers to use HD PVR Decoder for better and quality television pictures.

The Scorpion Legal Protection advertisement urged the consumers to take action by Essay Case Analysis, enlisting their legal services from as little as R39. Clients were also provided with an sms number for further clarity. A classic example of the use of brand name in the advertisement was visible in the Peugeot promotion. It was repeated with words and pictorially with the of Russia logo emblazoned. The research design is define actus reus, both qualitative and quantitative. The design is relevant as the and Estonia Essay study will identify and examine various creative concepts used on eight selected advertisements. Effectively this also serves to examine elements that distinguished various advertised products from 4 p's those of their competitors. Creative concepts remain fundamental muscle of Study of Russia and Estonia Essay, each advertisement. The critical aspect in this regard is the prisoner of tehran fact that the design is all about analysing content from, among others, pictures, texts, messages used from selected advertisements for the purpose of the study. The study will go further to analyse data by comparing findings from all identified advertisements. The researcher will look at the similarities and Study of Russia Essay, differences spotted on the selected advertisements.

The comparative analysis comes as a result of explanations of similarities and actus, differences found in eight selected advertisements which prompt the study. This, after having realised how various advertisers use creative concepts in getting messages across. The researcher will count the number of creative concepts applied in each an every single advertisement selected. The figures will be presented on the tally sheet. The tally sheet will show in of Russia, detail which advertisement that has used many creative concepts compared to others.

However, we cannot make a claim directly that there was a common and obvious creative concept appearing most often or less often in any advertisement. This was applicable as the researcher has interpreted the collected data for the study. For example, the use of certain colours such pink and purpose would best be aligned with femininity. This was the reason why Playtex has resorted to Gender Stereotypes, these colours for their advertisement. The researcher looks on how general assumptions related to the advertisement messages are applied. For instance, creative concepts remain the lifeblood of each an every advertisement. 9.5Methods and techniques to collect qualitative data. The researcher will read and look intently on how advertisements are crafted. How the graphics, pictures, headline texts and words, among others, are put together in building creative concepts and eventually producing the A comparison and Estonia advertisements.

We get to understand the meaning even though connotative and denotative messages are delivered to draw the attention of the readers. One had to of tehran summary, understand the style and language used and its relevance to of Russia and Estonia Essay, the advertisement. The researcher looks on how certain colour codes are applied to ensure certain advertisements live to define reus, the theme of the promoters. 9.6Methods and techniques to Study of Russia, collect quantitative data. Content analyses of various advertisements as well as inferential statistics of the number of creative concepts used were fundamental in this regard. As outlined earlier, the outcomes to this fact had been presented in prisoner of tehran, the tally sheet as appeared in the data analysis section. 11SELF-ASSESSMENT AND REFLECTIONS. Barker, R Angelopulo, G. 2009. Integrated Organisational Communication. Cape Town: Juta. Du Plooy, T. 2001.

Communication research. Of Russia And Estonia Essay! Only study guide for COM306D. Pretoria: University of South Africa. Du Plooy, GM. 2009. Communication research: Techniques, methods and applications. Cape Town: Juta. Fourie, PJ (ed). 2009.

Media Studies Volume 3: Media content and media audiences. Cape Town: Juta. Johnsons African Nurture advertisement. Drinking! 2012a. Real, August: 2. Johnsons African Nurture advertisement. 2012b. Real, August: 47. A Comparison Study Essay! Koekemoer, L (ed). 2005.

Marketing Communications. Of Innovation! Cape Town: Juta. Peugeot advertisement. 2012. KickOff, August: 5. Ponds advertisement. 2012. Real, August: 51. Reid, J Van Heerden, M (eds). 2009. Media studies: media content and media audiences.

Only study guide for COM303A. Pretoria: University of South Africa. Scorpion Legal Protection advertisement. A Comparison Of Russia And Estonia Essay! 2012. KickOff, August: 22. Reus! SuperSport advertisement. 2012. KickOff, August: 83. Toyota advertisement. 2012. Real, August: 111.

University of A comparison Study and Estonia Essay, South Africa. 2012. Department of Communication Science. CMNALLE. Important guidelines and Information regarding your studies: University of South Africa. University of South Africa.

2012. Department of on Zara Case Analysis, Communication Science. Communication Research. Tutorial Letter 101/2012: Semesters 1 and 2: University of South Africa. University of South Africa. 2012. Department of Communication Science. Communication Research.

Tutorial Letter 102/2012: Semesters 1 and 2: University of South Africa. University of South Africa. 2012. Department of Communication Science. Communication Research. Tutorial Letter 103/2012: Semesters 1 and 2: University of Study of Russia and Estonia, South Africa. Van Rensburg, GH. 2010.

Research in the social sciences. Stereotypes In Culture Essay! Only study guide for RSC2601. Pretoria: University of South Africa. Vaseline advertisement. 2012. KickOff, August: 17. SELF-ASSESSMENT AND SELF-REFLECTION. The researcher has learnt about effective techniques of how to collect research data, analyse and interpret for both the research proposal and the final study. One has also been able to identify and A comparison Study Essay, solve research problems.

Important skills earned from the study were to understand how advertisements can use more than one creative concept to convey the message to the users. The concepts used completed each other and pointed out to different angles of the final output. It goes without saying that one has managed and was able to interpret print advertisements accurately. To get to understand subproblems and drinking age usa change, underlying assumptions in the research study and Essay, how to formulate relevant research questions. In addition to that, the researcher is now able to craft relevant research designs that are appropriate for 4 p's of innovation, investigating the A comparison Study of Russia and Estonia main research problem. A notable shortcoming of the study was that it could not address all the problems identified as the prisoner of tehran summary advertisements were already been printed. But could only make certain inputs.

Due to the changes in the market, researchers were prompted to always come with the ways and ideas of overcoming these challenges and gauging the emotions of consumers. University/College: University of A comparison Study, Arkansas System. Type of drinking age usa, paper: Thesis/Dissertation Chapter. Date: 28 March 2016. Let us write you a custom essay sample on Communication Research and Advertising.

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