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  • A Substantive Due Process Challenge to the War on Drugs

    A Substantive Due Process Challenge to the War on Drugs

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    Substantive Due Process Analysis of the Incarceration of Drug Offenders

    A. Framework

    In Washington v. Glucksberg, Chief Justice Rehnquist described the framework for substantive due process analysis:

    Our established method of substantive-due-process analysis has two primary features: First, we have regularly observed that the Due Process Clause specially protects those fundamental rights and liberties which are, objectively, “deeply rooted in this Nation’s history and tradition,” and “implicit in the concept of ordered liberty,” such that “neither liberty nor justice would exist if they were sacrificed.” Second, we have required in substantive-due-process cases a “careful description” of the asserted fundamental liberty interest. Our Nation’s history, legal traditions, and practices thus provide the crucial “guideposts for responsible decisionmaking,” that direct and restrain our exposition of the Due Process Clause. As we stated recently in Flores, the Fourteenth Amendment “forbids the government to infringe . . . ‘fundamental’ liberty interests at all, no matter what process is provided, unless the infringement is narrowly tailored to serve a compelling state interest.”

    Applying this method, one must first examine freedom from incarceration to determine if it is a fundamental right. If so, government policies that require the incarceration of offenders, including drug offenders, must serve compelling interests and be narrowly tailored to achieve them. This article assumes for the sake of argument that drug problems give rise to compelling state interests. It then reviews the interests asserted by the government in its pursuit of its drug war policies and the results of those policies to determine whether the policy of incarcerating drug offenders is narrowly tailored to those asserted interests.

    B. The Fundamental Liberty Interest: Freedom from Incarceration

    Federal and state laws subject drug offenders to incarceration. Incarceration is a tremendous deprivation of liberty that triggers the protections of the Due Process Clause. The Supreme Court has recognized this right on a number of occasions. In DeShaney v. Winnebago County DSS for example, the court held:

    [I]t is the State’s affirmative act of restraining the individual’s freedom to act on his own behalf–through incarceration, institutionalization, or other similar restraint of personal liberty–which is the “deprivation of liberty” triggering the protections of the Due Process Clause . . . .

    Perhaps the earliest explicit recognition by the Supreme Court of freedom from incarceration as a fundamental right under substantive due process came in Allgeyer:

    The ‘liberty’ mentioned in [the fourteenth] amendment means, not only the right of the citizen to be free from the mere physical restraint of his person, as by incarceration, but the term is deemed to embrace the right of the citizen to be free in the enjoyment of all his faculties; to be free to use them in all lawful ways; to live and work where he will; to earn his livelihood by any lawful calling; to pursue any livelihood or avocation; and for that purpose to enter into all contracts which may be proper, necessary, and essential to his carrying out to a successful conclusion the purposes above mentioned.

    An 1891 law review article noted that Blackstone described “freedom from restraint of the person” as “perhaps the most important of all civil rights,” and that Lord Coke felt “the liberty of a man’s person is more precious to him than everything else that is mentioned [in the Magna Charta].” Blackstone states that “the rights of all mankind . . . may be reduced to three principal or primary articles; the right of personal security, the right of personal liberty, and the right of private property.” Indeed, the original Latin in the Magna Charta’s “law of the land” clause uses the term “imprisonetur.”

    No court has invalidated a criminal statute through the application of substantive due process analysis to the fundamental right of freedom from incarceration. At the same time, no court has ruled to the contrary. The Supreme Court avoided the question in Reno v. Flores:

    The “freedom from physical restraint” invoked by respondents is not at issue in this case. Surely not in the sense of shackles, chains, or barred cells, given the Juvenile Care Agreement. Nor even in the sense of a right to come and go at will, since, as we have said elsewhere, “juveniles, unlike adults, are always in some form of custody,” and where the custody of the parent or legal guardian fails, the government may (indeed, we have said must) either exercise custody itself or appoint someone else to do so.

    This analysis would not apply to adult drug offenders. The Fourth Circuit also avoided addressing freedom from incarceration as a fundamental right in Hawkins v. Freeman:

    Hawkins’s rhetorical reference to the right as being “freedom from unjust incarceration,” and that of amicus, American Civil Liberties Union of North Carolina, as the “right to be free from arbitrary incarceration,” are issue-begging generalizations that cannot serve the inquiry. A properly precise description can, however, be found in the facts and legal authorities relied upon by Hawkins in support of his claim. From these, we deduce that the precise right asserted is that of a prisoner to remain free on erroneously granted parole so long as he did not contribute to or know of the error and has for an appreciable time remained on good behavior to the point that his expectations for continued freedom from incarceration have “crystallized.”

    Hawkins is distinguishable because it deals with an inmate whose parole was revoked. In any event, the casual dismissal as an “issue-begging generalization” flies in the face of nearly 800 years of common law tradition and over a century of Supreme Court decisions recognizing freedom from incarceration as a fundamental right. Indeed the language of the Supreme Court’s Ingraham decision supports the application of substantive due process proposed in this paper:

    While the contours of this historic liberty interest in the context of our federal system of government have not been defined precisely, they always have been thought to encompass freedom from bodily restraint and punishment. It is fundamental that the state cannot hold and physically punish an individual except in accordance with due process of law.

    The Court also stressed this fundamental liberty interest in Foucha v. Louisiana, a case involving the confinement of a person found not guilty by reason of insanity:

    Freedom from bodily restraint has always been at the core of the liberty protected by the Due Process Clause from arbitrary governmental action. “It is clear that commitment for any purpose constitutes a significant deprivation of liberty that requires due process protection.” We have always been careful not to “minimize the importance and fundamental nature” of the individual’s right to liberty.

    While the Foucha Court indicated that “a State may imprison convicted criminals for the purposes of deterrence and retribution,” the remark was dicta and did not involve any discussion of substantive limits on the police power. In Meachum v. Fano the Court made a similar remark in the context of a case dealing with prison conditions: “[G]iven a valid conviction, the criminal defendant has been constitutionally deprived of his liberty to the extent that the State may confine him.” Again there was no discussion of substantive limits on the police power. Indeed the previous sentence noted: “The Due Process Clause by its own force forbids the State from convicting any person of crime and depriving him of his liberty without complying fully with the requirements of the Clause.”

    Recently in Zadvydas v. Davis, the Court noted:

    The Fifth Amendment’s Due Process Clause forbids the Government to “depriv[e]” any “person … of … liberty … without due process of law.” Freedom from imprisonment–from government custody, detention, or other forms of physical restraint–lies at the heart of the liberty that Clause protects.

    Freedom from incarceration is not just a fundamental right. It is the one of the most fundamental of rights.

    C. Identifying the State’s Interests

    Governmental drug policy interests identified in federal statutes include “demand reduction,” “supply reduction,” and “reducing drug abuse and the consequences of drug abuse in the United States, by limiting the availability of and reducing the demand for illegal drugs.”

    Federal law sets specific goals for the National Drug Control Strategy. These include:

    “Reduction of unlawful drug use to 3 percent of the population”;

    “Reduction of adolescent unlawful drug use to 3 percent of the adolescent population”;

    “Reduction of the availability of cocaine, heroin, marijuana, and methamphetamine”;

    “Reduction of the respective nationwide average street purity levels for cocaine, heroin, marijuana, and methamphetamine”; and

    “Reduction of drug-related crime.”

    Goals are also set forth with regard to drug-related crime:

    (i) reduction of State and Federal unlawful drug trafficking and distribution; (ii) reduction of State and Federal crimes committed by persons under the influence of unlawful drugs; (iii) reduction of State and Federal crimes committed for the purpose of obtaining unlawful drugs or obtaining property that is intended to be used for the purchase of unlawful drugs; and (iv) reduction of drug-related emergency room incidents . . . .

    D. Defining “Narrow Tailoring” in the Context of Substantive Due Process

    Assuming that the governmental interests are compelling, we must determine whether the incarceration of drug offenders is narrowly tailored to achieving them. The government must show that its policy passes strict scrutiny. The concept of narrow tailoring is not well defined in the context of substantive due process, but has been fairly well defined in regard to the First Amendment and Equal Protection. Equal Protection cases also arise out of the Fourteenth Amendment. In Wygant v. Jackson Bd. of Education the Supreme Court held: “Under strict scrutiny the means chosen to accomplish the State’s asserted purpose must be specifically and narrowly framed to accomplish that purpose.” In a footnote, the Court described narrow tailoring in even further detail:

    The term “narrowly tailored,” so frequently used in our cases, has acquired a secondary meaning. More specifically, as commentators have indicated, the term may be used to require consideration of whether lawful alternative and less restrictive means could have been used. Or, as Professor Ely has noted, the classification at issue must “fit” with greater precision than any alternative means. “[Courts] should give particularly intense scrutiny to whether a nonracial approach or a more narrowly-tailored racial classification could promote the substantial interest about as well and at tolerable administrative expense.”

    It is important to note here that a policy that does not advance the government’s interests violates substantive due process regardless of how it compares with the alternatives. If it does not accomplish its purpose, logic dictates it cannot be specifically and narrowly framed to accomplish its purpose.

    E. Advancing Governmental Interests

    Congress has identified certain tools for assessing the national drug control strategy. The National Household Survey is the measure for “unlawful drug use.” Similarly, “adolescent unlawful drug use” is to be measured “by the Monitoring the Future Survey of the University of Michigan or the National PRIDE Survey conducted by the National Parents’ Resource Institute for Drug Education.” On these measures, the goals are not being reached.

    The measure of adolescent drug use that was specifically identified by Congress, illicit drug use in the past 30 days, worsened in 2001. More than 25% of US twelfth graders reported using illicit drugs in the past 30 days. That is nearly double the figure for 1992 and more than eight times the stated goal of 3%. Over 40% of 12th graders tried an illicit drug in the past year.

    The PRIDE Survey and National Household Survey show similar results.

    The drug war has also failed in its other goals. The Monitoring the Future Survey tracks how twelfth graders perceive the availability of drugs. Reducing availability is an explicit goal of the drug war. The perceived availability of marijuana in 2001 was slightly higher than in 1975. The figures for harder drugs are more disturbing. From 1975 to 1986, roughly 20% of twelfth graders said heroin was easy to get. That number shot up in the late 1980s and has remained consistently higher than 30%. Cocaine remains widely available to our youth, with nearly 50% of twelfth graders saying it is easy to get. The survey began measuring the availability of ecstasy in 1989, when only 22% of twelfth graders felt it was easy to get. In 2001, that number went over 61%, having jumped from 51% the year before.

    Drug war policies are not achieving the stated drug war goals. They cannot be “specifically and narrowly framed to accomplish their purpose” because they are not accomplishing their purpose. Drug use has not been reduced in any significant way, and levels of drug use are far above the stated goals. Our children have easy access to drugs. We can’t even keep drugs out of jails. The drug war and the incarceration of drug offenders have also failed to achieve secondary goals regarding supply, demand, purity, drug-related health problems and drug-related crime. The policy of incarcerating drug offenders does not “directly advance[] the governmental interest asserted.” The War on Drugs is not working.

    F. Alternative Means

    Even if a court is persuaded that incarceration advances the government’s interests, the government must also show that its policy choice fits better than the alternatives. Critics of the drug war encompass a broad spectrum of backgrounds, and the range of “solutions” is just as wide. Libertarians and others favor outright legalization of drugs. The legalization of marijuana is a somewhat popular variation of overall legalization, and there are other variations such as the legalization of marijuana for medical purposes and decriminalization of drugs or marijuana. Another leading approach, known as harm reduction, looks at drugs from a public health perspective.

    The effectiveness of some of these alternatives is difficult to assess. Even so, certain comparisons can be made. Advocates of treatment point to studies showing that treatment is much more effective than incarceration. Spencer notes:

    The recidivism rate for first time Dade County drug offenders was sixty percent, but for those who successfully completed the Dade County Drug Court treatment programs, the recidivism rate reported by Dade County officials was only seven percent. Drug court treatment programs are also cost effective. It costs Florida only $2,000 to put a drug offender through a drug court program, as compared to $17,000 per drug offender for incarceration. As a result, other drug court programs are being established throughout the country.

    Similarly, a Rand study found treatment to be seven times more cost-effective than current supply-control policy in reducing cocaine consumption.

    G. The Incarceration of Drug Offenders is Not Narrowly Tailored

    Incarceration involves a far greater infringement of fundamental rights than alternatives which are both more effective and less intrusive. The incarceration of offenders is not advancing the state’s asserted interests. The drug war is not narrowly tailored, failing the Supreme Court’s “established method of substantive-due-process analysis” as described by Chief Justice Rehnquist. The laws requiring the incarceration of drug offenders are therefore unconstitutional, if substantive due process analysis is applied.

    IV. CONCLUSION

    It is true that the approach suggested in this paper would limit the police power. Constitutional protection of individual rights exists for that very purpose. We face coercive government action, carried out in a corrupt and racist manner, with military and paramilitary assaults on our homes, leading to mass incarceration and innocent deaths. We can never forget the tyranny of a government unrestrained by an independent judiciary. Our courts must end the War on Drugs.

    For the full article, with endnotes, see: http://www.redlichlaw.com/crim/substantive-due-process-drug-war.pdf

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    Source by Warren Redlich

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  • What Do Wives Do To Get Their Separated Husbands To Come Home?

    What Do Wives Do To Get Their Separated Husbands To Come Home?

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    I sometimes hear from wives who want to know “the secret” that separated wives use to get their husbands to come home. I often hear comments like: “what do those women do to get their separated husbands to willingly come home? They must be doing something that I’m not doing. Because in my mind, I have tried everything but my husband isn’t even remotely interested in returning home.” I heard from a wife who said: “my husband and I separated about the same time as our neighbors separated. My female neighbor and I would often have dinner together and discuss strategies. Well, her husband came home last weekend ready to work things out and mine is still living away from me and is showing no signs that he might return. What did she do that I didn’t? Because when I ask her this, she says she can’t pinpoint anything that she said or did. She said that her husband just seemed ready to come home. What is she doing that I’m not? I need to know how all of these wives get their husbands to come home so that I can do the same things because I miss him and need him here.”

    I could completely understand this wife needing answers. I was separated myself a few years ago and I was absolutely desperate for any answers. I was willing to try absolutely anything to get my husband to come home. And sometimes, I feel as if that were part of the problem. While I was grappling for answers, my desperation got the better of me and I jumped around trying different things and changing behaviors, which eventually just made things worse.

    I think that sometimes, the husband is just ready to come home or he just comes to his own realizations. But I think that other times, there are things that some wives are able to do to nudge their husband to come home a little sooner. Through research, I learned some of these methods which really helped me and I will share some of them with you now.

    Some Wives Plant The Idea That Their Husband Has Something Meaningful To Come Home To: This is common sense, but it is so often missed. In order for your husband to come home, he will often need to believe that his quality of life with you at home is going to be much better than his quality of life without you away. Sometimes, this isn’t very difficult because your husband is having bad experiences or feelings while he is away. But other times, this can be a little more difficult because, even if the husband isn’t completely happy away, he is able to avoid the conflict and the drama of life at home when the future of his marriage is uncertain.

    Coming home sometimes leaves him with an unknown. And since he can’t see into the future, he will often rely on past behavior. If the past leaves you a lot to overcome, then you will have to rebuild the trust and allow him to see how or why things might change when or if he comes home. He must believe that things are going to be better at home not just for the short term or the long term. Sometimes, this takes time and requires you to carefully lay the groundwork.

    You’ll want to be patient, understanding, and easy to approach and talk to. If the two of you argue when you are together (or even argue about his coming home,) then he will understandably have doubts about moving forward and coming home. After all, if you can’t get along now, what is going to change once he comes home?

    Separated Wives Who Nudge Their Husbands Home Will Often Cultivate A Playful New Dynamic Between Them: Many wives whose husbands are eventually lured back will admit that they were able to put their fear aside, at least while their husband was present. They were able to keep things light hearted and positive, even if they didn’t always feel this way deep inside. They did this because they knew that when things went well with their husband, then he was more willing to see or interact with them in the future. They also knew that keeping things light and playful would help to neutralize what was already a stressful situation. They suspected that focusing on fear and uncertainty was only going to make things worse.

    I know first hand that this is sometimes challenging to pull off. Sometimes, you feel anything but upbeat, and you really have to look at the big picture so that you don’t just give into your negative feelings and make things worse. But in the end, it is worth it. As I improved my attitude, our relationship improved. And my husband was more willing to spend time with me. And as he was more willing to spend time with me, I made each encounter count so that things continued to get better and better.

    Successful Wives Don’t Try To Rush Or Push Their Husbands To Come Home Before He’s Truly Ready: Here’s one last important point. When things are going well, it’s extremely easy to be quite tempted to suggest that your husband comes home the second that your situation improves. Sometimes, this is a mistake. It’s often better if you can wait for him to suggest that he is ready to come home. At the very least, make sure that he is enthusiastic and willing before you suggest it. Because, if you suggest it to soon, he may well think that your light hearted and easy going attitude was only meant to get him home. He may worry that once he gives in and comes home, you’re going to drop the act. And this is the last thing you want. You want for him to not only believe that things are going to change and improve, you want that to be the truth so that your marriage not only reconciles, it lasts for the long haul and it makes you both happy.

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    Source by Leslie Cane

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  • Cougar Dating: New Trend in the Dating World

    Cougar Dating: New Trend in the Dating World

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    Today, we are all standing in the modern world where most people are trying their best to shed off the conservative mindset. Earlier men did not have the thought to approach elderly women. Neither the women agreed ever to such open-ended relationships. Now, the society has become liberated. Elder women with younger men as couples are becoming a common sight.

    Why do we get to see this change?

    As we have already discussed, the society is getting liberated. No more are the family ties or what people are going today, bothering them. They are feeling free to express their thoughts as and when they want and to whomsoever they like. Most of them have claimed that they are fed up with the long-term relations and do not want the unnecessary dramas that bring with it. Most of the cougar ladies do not want to remarry. They want to enjoy being free.

    Where can these couples meet?

    For people in love, the whole world is a meeting point. Who can stop them from meeting each other? Still if one claims that one has not yet met his or her partner one can seek into the cougar dating websites. There are several such dating sites where one can find their love interest.

    Any recent developments in the matter

    Well, there has been quite observations on this matter and some say that there is a new angle in the cougar dating. Most women dating their younger partners are now looking into the aspect of marriage. Some have even taken the major step. They claimed that they are happy in their marriage. These women have also said that they no longer want to date men of their age or older.

    How should a man prepare for a cougar dating?

    Well, men who are interested in dating elderly women have to be very careful doing so. The cougar world is full of women who have a high self-esteem and are successful in their careers. The men in order to approach them should have to put on their best manners and have a sense of dressing smartly. The cougar ladies have an eye for good look manners. They do not like men who are too much fast. In fact, they like to pursue the men themselves.

    Another thing that the men should avoid doing is treating the ladies in a negative manner. They should be treated with respect, love and care. They should never feel that they have been used.

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    Source by Achal Mehrotra

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  • New Book Removes Fear From Sales With Practical, Easy-To-Implement Techniques

    New Book Removes Fear From Sales With Practical, Easy-To-Implement Techniques

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    As a small business owner, I found Greg Andersen's Small Business Sales, WTF (Without the Fear) full of practical advice, new ideas, and down-to-earth common sense to help me rethink my sales approaches. Andersen has been in sales for many years in the printing business, but the advice he offers is applicable to anyone in sales, especially small business owners who may be wearing all the hats themselves or unable to focus on sales because they're too busy looking after everything else.

    Small Business Sales, WTF is divided into two sections: Pre-Sales Planning, in which Andersen discusses products, going to market with products, creating a sales environment, and then The Sales Process, in which he explores how to find customers, make contact , get the opportunity to sell to the customer, execute the sale, and then follow up with and retain the customer long-term. Andersen walks readers through each step of the sales process, providing practical and personal examples of what has worked for him that readers can easily model or put their own spins on.

    Andersen writes in a humorous but tell-it-like-it-is style to dismiss myths about the sales process and cut through sales jargon to get to what the reader really needs to know. For example, early in the book, he has a list of "Words / Phrases you will not hear in my book." Among the phrases included is "Belly-to-Belly" to which he responds, "Gross. How about face-to-face." Another phrase is "Low Hanging Fruit," which he says does not really exist, and still another is "Hook," which he finds insulting because it assumes customers are suckers or fish. Instead, Andersen prefers to treat his customers like human beings and rather than "close the sale" come to an "agreement" between two parties who trust and respect each other.

    For most people, sales can have a bad name. No one likes being sold to, and people who reluctantly take on a sales role are aware of that and often fearful of selling. Andersen teaches readers how to remove the fear of sales by rethinking what sales really is. Most people dread the "cold call," so Andersen talks about instead viewing sales as "demand generation." It's about looking for where there is a demand for your services and then providing the product or service to fulfill that demand. It's also about listening to customers.

    Andersen states: "When all is said and done, only a few methods of outreach will really get you in contact with a prospective new customer-the phone, letter writing, a trade show, and email. What really counts is the technique you employ . " He then provides creative examples of how to handle sales through each of these approaches, as well as discussing social media as a sales strategy. His examples are drawn from personal experiences, from his days as a shoe salesman at Nordstrom to his current sales role in the printing industry. Best of all, he even includes copies of letters he has sent to clients. His techniques are simple and straightforward, so anyone, no matter how scared of sales, can implement them.

    Of course, there will be difficult clients or people who don't want to hear how you can help them. Andersen provides strategies for getting past the gatekeepers to the decision makers. He reveals his research techniques, which are quite clever and even include looking at prospective customers' job postings to determine who in a company is or will be in a buyer position for his product.

    When facing resistance from a potential client, Andersen realizes it's not always about him, his approach, or his product. I loved the following invaluable point he made: "Another way I like to approach these challenging situations is to remind myself that all these excuses mean the customer is probably protecting his current vendor. If he is being loyal to his current vendor, some day he will be loyal to me. Stay positive. " Personally, I know this is true as a business owner. If I have a vendor providing me with a good service at a good price, I feel loyal to that vendor and am not willing to change. Such clients may be resistant to change, but they are the ones you want because they are loyal. Andersen shows how persistence pays off in these situations. Sometimes he makes contact with customers who are not in need of his services right then, but years later, he secures business with them, and even if at first he doesn't get the level of business he wants, they often will give him some business as a trial and then he can work his way in to larger sales with them.

    Perhaps what I liked most about Andersen's approaches is that he truly believes in being responsive to clients. I cannot stress enough how frustrated I feel when I send an email to someone who does not reply to me for several days. I am personally always very responsive to my clients and usually reply within hours if not minutes. Andersen points out that even if you don't have an answer to a client's problem or you can't take the time to respond to a question at that moment, a simple response like, "I'm on it," lets clients know you will get back to them and then they can quit worrying about their problem and go on to the next item on their to-do list until you do get back to them. In other words, Andersen is always in favor of reassuring the client that you will do what you say and provide reliable and quality service.

    Altogether, Small Business Sales, WTF does take a lot of the fear and stress out of sales. I believe most readers will be pleasantly surprised by this book; they'll read Andersen's stories and examples and say to themselves, "I can do that," and even find ideas of their own popping into their heads as they build off of Andersen's advice. Whether you are a small business owner with absolutely no sales experience, are just starting out in sales, or have been in sales for years, there are plenty of nuggets of advice here that can make your sales process easier, more lucrative, and all around more enjoyable.

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    Source by Tyler Tichelaar

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  • Book Advocates Natural Healing for Man's Best Friend

    Book Advocates Natural Healing for Man's Best Friend

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    Healing Your Dog Naturally is a revolutionary new book by Nicole Gabriel that will make you rethink how you care for your dog. It will teach you how to be proactive about your canine's healthcare and by extension rethink your own eating and medicinal habits. Consequently, you can kill two birds with one stone, or in this case, heal your dog and yourself, or better yet, prevent the need to heal from arising.

    While Gabriel's background is not in veterinary medicine, she has plenty of experiencing caring for sick dogs and loving them. This is a woman who deeply bonds with her pets and wants the very best for them. After she lost one of her Shar Pei dogs to an illness she believes was caused by a required vaccination in order for her to move to Hawaii, she decided to begin researching vaccinations and everything else about caring for one's dog. Now she has compiled all that research along with her personal experiences and successes into this new book, which may long be overdue considering the health and natural foods revolution going on for humans. I have to agree with Gabriel on this point: If we are all becoming more health and nutrition conscious about our own bodies, shouldn't we extend that same care and concern to our pets?
    Gabriel walks the reader through a plethora of topics and information on everything from diet and nutrition to allergies, vaccinations, using essential oils, spaying and neutering, homeopathy, and even how to align your dog's chakras.

    But before I go further, this book isn't just a book about how to heal your dog and make him healthier. It's also a book that encourages you to change your own lifestyle so that both you and your dog benefit.

    For example, Gabriel is not a fan of commercial dog food. She provides a brief history of dog food and how it was affected by World War II, why it is taurine-deficient, and why that matters. She makes a great point in saying that if we would not eat the dog food ourselves, why would we feed it to our dogs? Ultimately, she advocates that you cook dinner for your dog just like you would for your spouse, children, or yourself. She even offers several recipes to provide your dog with a nutritious diet. Okay, I know many people might think this is radical-cooking dinner for your dog-but if you want your pet to be healthy, it is a decision worth considering. You can even do it while making dinner for yourself. As Gabriel states, "When you wake up to nutrition, you begin to question everything. This is not a journey that is just for your dogs. Have you gotten that yet? We are all doing this together. This is a pack effort. you choose for you, you choose for your dog and vice versa. "

    The rest of the book may be viewed as equally radical or perhaps just applying common sense. Gabriel comes down hard on vaccinations, not because they are not well-intended but because she has seen her own pet die as the result of one. She walks readers through what may be harmful about certain vaccines and how to reverse possible issues is you've already had your dog vaccinated and it is causing health issues. She also offers advice on spaying and neutering-another "don't do it" chapter you'll have to read for yourself.

    But not everything in these pages is focused on overturning common canine care practices. If anything, this book is written with a lot of love. There are adorable cartoons of dogs throughout reminding us of how much we love our best friends. Gabriel goes into detail about all the wonderful experiences she's had with her pets and why they matter so much to her. She is not afraid of discussing the most sensitive issues, including how to deal with loss of your pet and your grief. She provides simple and natural remedies for everything from dealing with cut footpads to ingenious ways to offer nutritious treats to your pets, and even ways to test your dog for various allergies and make changes to his diet accordingly.

    Most importantly, Gabriel challenges us to see our pets with new eyes and to think more deeply about what we do in our care for them. I can't say whether she is right on every subject, but I do know her heart is in the right place and she provides a great deal of food for thought. I imagine people who read this book will have already gone or be going through a traumatic or heart-wrenching experience with a pet, so they will be looking for answers beyond what their local veterinarian may be able to provide. If so, this book is an excellent place to start. I truly believe Healing Your Dog Naturally will open many eyes, and hopefully, it will lead to a revolution in canine healthcare.

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    Source by Tyler Tichelaar

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  • Where to Get a Small Business Loan? Learn About Your Options and How to Choose a Good Organization

    Where to Get a Small Business Loan? Learn About Your Options and How to Choose a Good Organization

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    When they are first starting out, small businesses usually require loans to help them get going. Depending on your type of business and industry, you might need funding for inventory, strengthening your firm’s foundation, advertising, expansion, etc. “Where to get a small business loan?” is a very common question by owners of start-ups. Your choice of a lender could either help you in your success or cause damage to your business, so it’s important that you choose wisely.

    According to estimates, over 60% of small employer businesses have some sort of debt they are dealing with. If you choose the wrong lender, you could end up in an even worse situation. While many entrepreneurs and start-ups are turning to crowdfunding sources, this approach often requires a great deal of hard work, and most campaigns fail to reach their goal. There are also “Venture Capital” and “Angel Funding” solutions, but these types of alternative funding only play a small role in overall business financing.

    For many businesses, it’s still better to go the traditional route and apply for a small business loan. How do you know which lender to trust? How do you know where to get a small business loan from a reputable organization? A free quote is always a good place to start. You’ll definitely want to check with the Better Business Bureau as well. Only consider lenders that have at least a 3-star rating. Any complaints submitted concerning that particular firm should have been resolved.

    Where to Get a Small Business Loan That Won’t Scam You

    Reputation is also another important factor. Has a company you are interested in appeared in major financial publications, websites, or even television programs? Forbes Magazine, CNN Money, Business Insider, and INC 500 are always a plus.

    If you are in need of a particular type of service, there should be an ideal financial solution for you. For instance, some small businesses require a Working Capital Loan, some require financing for equipment, and others need assistance with vendor programs. There are also businesses that require real estate loans. Whatever your need capital for a start-up or need assistance expanding your small business, there should be a solution tailored just for your needs.

    Not only should you be able to obtain a free quote, the application process itself should be simple and straightforward. You’ll be required to provide some financial statements and personal background information, which will vary depending on the lender and what kind of small business loan you are interested in.

    As to the question ” Where to get a small business loan? ” It’s a good idea to start with US Business Funding. It has an A+ rating at the BBB and has appeared in the aforementioned publications. You can get a free quote if you apply today.

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    Source by George Botwin

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  • Sore Penis TLC – Help for Bruised Penile Tissue

    Sore Penis TLC – Help for Bruised Penile Tissue

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    Bruises can be painful and a little disconcerting no matter where they appear on the human body, but when they show up on the penis, men might reasonably react with more than a little alarm. Thankfully, most cases of penile bruising are mild, and they tend to dissolve and disappear on their own, with a little supportive penis health care. But there are times when a bruised, sore penis merits a trip to the doctor for more advanced healing options.

    Bruising Basics

    The tissues of the penis are lined with blood. Deep channels inside the penis fill up with blood when a man is aroused, and this movement of fluid makes an erection possible. Even when a man isn’t focused on sex, however, the penis is nourished by blood flowing into thick veins and arteries that line the penis, as well as tiny capillaries that lie beneath the skin.

    Both large blood vessels and the smaller channels can burst when they’re subjected to pressure or some other form of trauma, and when they burst, bruises are soon to follow, as the blood rushes out and flows freely beneath the skin. Penile trauma can come in many forms, but common causes of intimate bruising include:

    • Surgical procedures;
    • Rough or dry sex;
    • Twisting motions during masturbation;
    • Accidents or blunt trauma.

    A typical bruise looks reddish when it first appears, but as the bruise heals and the blood is reabsorbed into nearby tissues, the skin can take on spectacular colors, including purple, green and yellow.

    Cause for Concern

    Some bruises are best handled with the help of an expert. For example, some bruises develop when a man hits his penis on something hard, like a partner’s pubic bone, and the impact can break delicate internal tissues. Such trauma won’t heal on its own, and it is often very painful, so incidents like this require a trip to the doctor’s office or ER.

    Helping the Healing

    An ordinary bruise that has no other complicating factors tends to disappear within a few weeks, no matter what a guy might do. Human physiology is adept at healing these sorts of damaged tissues, and the body’s cleanup crews head to the site mere minutes after the original injury and make sure that all is progressing as it should. There are some things men can do, however, to ensure that this process moves as quickly as it possibly can.

    Allowing time for healing is vital, as continued pressure or friction on bruised tissues can allow yet more blood cells to escape, and the bruise might spread instead of disappearing. Even if a man isn’t experiencing pain, it might be best to avoid sexual activity until the discoloration begins to fade and the tissue returns to its normal color. If pain accompanies the bruising, letting the injured tissues rest is especially important.

    Washcloths dipped in cool water can provide relief in the 24 to 48 hours following the injury, but in the days that follow, warm compresses can also help to speed healing. The warmth allows blood vessels to expand, so the damaged cells can be accessed and swept away as quickly as possible. A washcloth soaked in warm water, applied several times per day, should help the discoloration to fade.

    Applying a high-quality a penis health creme (most experts recommend Man1 Man Oil) may also help to promote healing. While penile creams are not intended as a cure for damaged tissue, vital nutrients such as vitamin C can help to promote the restoration of circulatory tissue, while natural moisturizers such as shea butter keep the skin feeling soft, supple and responsive to the touch.

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    Source by John Dugan

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  • Is She Addicted to Sex Toys? The Truth About Women Who Prefer "Toys" Over Sex With You!

    Is She Addicted to Sex Toys? The Truth About Women Who Prefer "Toys" Over Sex With You!

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    Is she addicted to sex toys? Does she prefer “time alone” over time with you? What does it mean when your girlfriend, wife or lover seems to value alone time more than sexual intercourse?

    Any of these questions sound familiar? If you are anything like the millions of men who worry about their ability to satisfy their partner in the sack, the truth is, a woman who enjoys sexual “props”, especially in her alone time, can be a very intimidating thing.

    Why? Because for many men, it signals that they may NOT be doing things right, and that their woman is quite literally, taking her sexual satisfaction into her own hands.

    Is it possible for a woman to become “addicted” to sex toys?

    The truth is, like any other pleasurable behavior that can become an obsession, or compulsive, it is.

    The good news?

    It’s rare, and a woman who really does compulsively use any sort of instrument of self pleasure in a hyper active way, typically is NOT doing it for the orgasm or sexual sensations alone. Usually, it’s a sign of hyper compulsive sex drive, and often, other deeper and unrelated psychological issues.

    The BAD news?

    The REAL issue that men worry about is genuine. Many women DO turn to masturbation, be it through using a “toy” or otherwise, simply because they are not able to climax during sex.

    The reasons that women report NOT being able to orgasm with their partner during sex?

    In a highly publicized sexual survey done in late 2012, the big reasons women privately reported for preferring a sexual toy like a vibrator OVER partner sex were the following.

    1 – Their male partners climaxed too quickly. It’s no surprise that sexual stamina and staying power remains the #1 complaint women make about bad sex.

    2 – Their partners were “doing it wrong.” Believe it or not, especially with men UNDER 30, lack of sexual skill is one of the most common reasons why a woman can’t have an orgasm, and ultimately resorts to using an aide like a vibrator later, in private. (often when our man has fallen asleep, or the next morning when he’s gone)

    3 – Poor “body part” compatibility. Many men simply aren’t properly endowed to satisfy their partners during sex. The truth is, about 80% of women have difficulty achieving orgasm due to size or stamina issues with their present partners. They aren’t able to hit the right spots… and even if they are, they can’t last long enough to bring her to orgasm.

    Many women are simply not willing to compromise the “climax” part of the sexual experience any longer, and will resort to ensuring that they DO get their own release, often by ourselves!

    Lastly, sex toys WORK! With so much myth and misinformation out there about the female orgasm, the truth is, more than 90% of women report being able to orgasm each and every time when using a toy or sexual prop.

    Compare this against the abysmally bad rates women report being able to climax during “real” sex, it’s no big surprise that so many of us now seemed “addicted” to our erotic aides and prefer more “alone” time than we let you know!

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    Source by Amy A.

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  • What Is Regenerative Medicine?

    What Is Regenerative Medicine?

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    When Adrienne Shapiro’s daughter Marissa was diagnosed with sickle cell disease, the doctors said that she would not live till her first birthday. However, when Marissa managed to live past that benchmark, it did not mean the end of Adrienne’s worries. In fact, it was the beginning of many painful years of blood transfusions and immunological disorders. When an improperly matched blood transfusion caused a severe reaction leading to the removal of Marissa’s gall bladder and temporary kidney failure, she was unable to receive further blood transfusions.

    However, luckily for Marissa a project sponsored by the California Institute for Regenerative Medicine (CIRM), headed by Don Kohn, MD at UCLA, was starting a clinical trial. The objective of the project was ‘to remove bone marrow from the patient and fix the genetic defect in the blood-forming stem cells. Then those cells can be reintroduced into the patient to create a new, healthy blood system.’The success of this clinical trial has given hope to Adrienne that with the help regenerative medicine her daughter will be able to lead a healthy and pain-free life.

    The Stem Cell & Regenerative Medicine Center at the University of Wisconsin-Madison describes ‘Regenerative Medicine’ as ‘a new scientific and medical discipline focused on harnessing the power of stem cells and the body’s own regenerative capabilities to restore function to damaged cells, tissues and organs.’

    Stem cells that are found in the umbilical cord blood of new born children have the ability to renew and regenerate themselves. A stem cell, through the process of mitosis, can divide itself to either become a specialized cell like a brain cell or muscle cell, or remain a stem cell. They are also able to repair internal damage caused by any type of disease, disorder or trauma. Stem cell transplantation, stem cell grafting and regenerative medicine are some of the ways in which these cells are used to cure disorders and illnesses.

    Regenerative medicine includes a wide range of scientific disciplines, such as biochemistry, genetics, molecular biology and immunology. Scientists from these fields have been conducting research and studies in this domain and have identified three methods of using regenerative medicine. They are cellular therapies, tissue engineering and medical devices and artificial organs.

    Cellular Therapies – In this method, cellular materials, in most cases adult stem cells, are extracted and stored and then injected into the site of injury, tissue damage or disease. These cells, thereafter, repair the damaged cells or regenerate new cells to replace the damaged ones.

    Tissue Engineering – This method is related to the field of biomaterials development and utilizes a combination of functioning tissues, cells and scaffolds to engineer a fully functioning organ which is then implanted into the body of the receiver in place of a damaged organ or tissue.

    Medical Devices and Artificial Organs – When a body organ fails, the most common method of treatment is to replace it with a donor organ. Donor organs are not easily available and can pose as a hindrance in such cases. Even if a donor is available, he or she may need to take immunosuppressant drugs before the transplant and these drugs have been known to cause side-effects. In such circumstances, medical devices that imitate the function of the failed organ can be used, instead of transplantation. An example of one such device is the ventricular assist device (VAD) that is used in place of heart transplants.

    Since regenerative medicine deals with the use of stem cells, it occasionally requires embryonic stem cells for research purposes. This use of embryonic stem cells can often give rise to questions regarding ethics and legality. The laws and regulations concerning regenerative medicine are different in different countries. Creation of human embryos for research is only legally permitted in three countries. Majority of the countries only allow extraction of cells from surplus IVF embryos. A recent study, related to human embryonic stem cells (hECS) research policy, was conducted which revealed that UK, Sweden and Belgium were very permissive in authorizing the creation of human embryos for research, whereas, Luxembourg, Austria, Poland and Ireland had no laws regarding hECS. The legislations regarding hESC in most other countries range between being mildly restrictive to very restrictive.

    Regenerative medicine is the future of modern medical treatments. Scientists are conducting clinical trials and studies every day to further enhance and improve in this area of medicine.

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    Source by Richa Verma

    Views: 0