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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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  • SAP Business One: Your One Solution for All Your Multiple ERP Needs

    SAP Business One: Your One Solution for All Your Multiple ERP Needs

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    Over the years, Businesses and organizations around the world have worked to evolve and implement various techniques or tools in order to streamline their core business activities. SAP Business One is one of such software systems that unite various business functions like finance, operations, sales, inventory, and CRM(Customer Relationship management) into under one centralized system. While there are a number of software solutions available in the market for small business enterprises, SAP Business One is different from all of them to a big extent. Moreover, it’s a single application which is easier to manage and use in comparison to other software solutions. It’s not required to be installed and then integrating with various modules likes other business applications as well.

    Benefits of Choosing SAP one

    Big on Efficiency

    Achieving greater efficiency is always one of the core motives of any type of business in the current global markets as its helps the business to sustain and prosper for long. With SAP Business One you can collaborate with all the business functions into one thread. This more or less confirms no space for all those irrelevant data entries, expenses, and unwanted errors. With SAP Business One, you can always stay assured to achieve good levels of growth for your business. While all your business activities will then be streamlined, you can now focus on making better decisions for your business.

    Support decision making

    The time taken in decision making would get minimized once you would implement SAP Business One in your business operations. This further allows you to include including all your business information in a single database. While this also helps in getting the latest information updated in the systems, you can enjoy greater level of freedoms in your decision making processes.

    Understanding the value of time

    SAP Business One allows you to get started with your business activities in as less as 2 weeks time. The User interface of this software is easy to understand too and any employee would not take long to get used to it. You also don’t need to invest money in hiring an IT expert as you yourself can operate and troubleshoot the software.

    Reduced Costs

    The cost factor always remains the main focal point for any business or organization. With SAP Business One you can instantly eradicate additional costs that have incurred by using the traditional operating systems for your business purpose which while lacking efficiency, were high on cost. Moreover, as you will now be able to coordinate with various business functions simultaneously, you can have a greater control over your business as usual. Since extra costs will now be eliminated from your business activities, you can now think of doing some good investments to further help in the overall growth of your business.

    Increased Revenue

    While using the SAP Business One solutions, you can now work towards responding to your customers, vendors, and clients in a better manner with minimal time possible as you are now more than capable with all the information you need by using a single software application.

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    Source by Kapil Kapoor

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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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  • Don’t Ignore These Telltale Signs of Drug Abuse in Teens

    Don’t Ignore These Telltale Signs of Drug Abuse in Teens

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    Drug abuse has for a long been a problem among teenagers with peer pressure as the key factor driving it. Despite being well documented, parents and caregivers tend to ignore the apparent symptoms of drug abuse in the growing children. The early instances of drug abuse evoke far greater health consequences in this age group than in any other group.

    One of the reasons behind the increase in the severity of repercussions of drug abuse is that during adolescence both body and mind are still in the process of development. Apart from the fact that drugs can alter brain chemistry and structure, illicit drug use among teenagers can increase vulnerability to motor crashes and instigate risky sexual behavior. Additionally, drug abuse increases suicidal tendencies, assaults, symptoms of mental health conditions and dropout rate at schools.

    Illicit drug use also entails legal and social consequences, such as increase in incidents of violence, criminal activities and neglect, as well as a higher likelihood of abusing drugs in later life. In addition, pregnant teenage girls who continue engaging in drugs are at risk of harming the fetus and themselves in many ways.

    Absence of evidence is not evidence of absence

    Nurturing and caring for a teenager is no easy task. The bumpy journey of growth that includes a number of transitional phases, ranging from hitting puberty to adolescence, yearning for dependence to realizing independence, “I love you” to “I hate you,” to confronting life without a safety net to making sense of it all, can mislead parents, guardians and caregivers, especially when their children are on drugs.

    Even in the absence of any evidence, it is important that parents who feel that something is wrong with their children trust their hunch and take significant remedial actions, such as talking to their children or seeking professional help.

    One of the most practical tools to address the problem of drug abuse among teenagers is communication. Usually, drug-using teenagers develop traits that assist them in concealing their growing addiction-related practices.

    They also spend their time incommunicado. When a teenager displays odd behavioral patterns, such as not being themselves after a social event, being vague about the details of the movie watched, getting home beyond curfew, avoiding interaction or getting close to their parents, it is best to investigate to safeguard their health and life.

    Some of the below-mentioned warning signs specified by the National Institute on Drug Abuse (NIDA) can assist parents in keeping a check on their adolescent children:

    • A change in peer group
    • Carelessness with grooming
    • Poor academic performance
    • Increased absenteeism
    • Loss of interest in favorite activities
    • Changes in eating or sleeping habits
    • Deteriorating relationships with family members and friends

    Although the 2016 Monitoring the Future (MTF) survey of drug use among American teenagers suggests decline in the past year use of illicit drugs, except marijuana, alcohol and drug use amidst teenagers is a major public concern. In addition, there is substantial evidence that drug use in early years increases the likelihood of a teenager developing substance use disorder and the symptoms of mental health conditions in their adulthood. However, early intervention is known to reduce and treat these conditions more successfully compared to those who let the abuse linger or get treated late.

    Pull the plug on drugs

    The earliest warning signs of drug abuse among teenagers are changes in their behavior and mannerism. Usually, addressing a teenager’s drug abuse habits can be an unpleasant ordeal, which is at times riddled with extreme opposition from the patient.

    Therefore, it is important that parents communicate with their adolescent children about the life-threatening consequences of drug abuse. They should also discuss about the ways that can assist in overcoming the challenge of drug abuse. They can guide their children in the right direction through their love and care.

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    Source by Courtney Whetstone

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  • 10 Reasons Masturbation Is Good for a Man’s Health

    10 Reasons Masturbation Is Good for a Man’s Health

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    Nope, it doesn’t cause blindness or hair to sprout wildly from a man’s hands. Masturbation is actually a very healthy hobby to have, affecting all areas of a man’s health and wellness from the top of his head to the depth of his heart. Ranging from everything from cancer prevention to self-love, masturbation is a free, easy hobby that yields powerful results for a man’s wellness.

    #1: Body Confidence

    Getting sexy with oneself is a great way to get in touch with erogenous zones and feel pleasure. Masturbation has also been shown to help people be more in touch with and feel better about their bodies, promotes intimacy, and improves communication regarding likes, desires, and dislikes with a partner. It’s a pathway to accepting oneself as well as being a confident lover.

    #2: Feel-Good Hormones and Relaxation

    Unlike partner play, masturbation is generally all about the orgasm. When a man orgasm, his body is flooded with dopamine, oxytocin, and endorphins. These are the “love and bonding” hormones that create a feeling of safety and warm fuzzies. They also lower cortisol, the evil stress hormone, which leads to less inflammation, weight gain, and stress-eating. Masturbation has also been shown to lower blood pressure, creating a relaxing mood.

    #3: Cheeto-Fighting Powers

    Remember that oxytocin? It keeps a man happy which stops emotionally-triggered food cravings for things like cheese, sugar, and other comfort goods. So put away the Ben & Jerry’s and pull out the lube instead.

    #4: Improves Sperm Quality

    Give swimmers an extra boost. Like anything else perishable, the fresher, the better. There are less motility issues and DNA damage when sperm is regularly turned over.

    #5: Improved Microbiome

    Who knew the key to bloating and gassiness was masturbation? The regular flood of pleasure keeps the guts in check and balances digestion. It’s due to the bloods increased circulation and positive hormone balance.

    #6: Reduced Pain

    Orgasm circulates the blood through the body which naturally help soothe aches and even headaches because pain can frequently be caused by dehydration and low oxygenation. Also, what feels better than an orgasm. Try for a P-Spot orgasm to extend the good vibes.

    #7: It Makes a Man Mindful

    Nothing requires a man to be in the moment like masturbation. Solo play is a form of erotic meditation, reducing stress and a racing brain. Sometimes it’s just the break a man needs.

    #8: It Wards off Cancer

    An Australian study found that men who ejaculated more than five times a week were a third less likely to develop prostate cancer. This seems to be because toxins build in the urogenital tract. When a man orgasms, it flushes the toxins from the system.

    #9: Tones the Love Muscle

    It’s like doing dead lifts for your dick. Everyone loses muscle tone with age; however, masturbation keeps the pelvic floor muscles strong which also help keep ED and incontinence at bay.

    #10: Mood Booster

    Back to those love chemicals. Masturbating releases dopamine and oxytocin which not only destress, but also lift the spirits, boost levels of happiness and satisfaction, and activate the reward circuits in the brain.

    Of course, a man needs to keep his member primed and ready for action at all times. That’s why it’s important to use a penis health creme (health professionals recommend Man 1 Man Oil , which has been clinically proven safe and mild for skin) which is created especially for delicate penile skin and contains all the nutrients and vitamins essential to a strong, supple penis. It’s a quick and easy piece that should be included in every man’s grooming regimen that not only is good for him but feels amazing too.

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    Source by John Dugan

    Views: 0

  • 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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  • Understanding Love's True Nature

    Understanding Love's True Nature

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    Since the dawn of homo sapiens, we have been investigating, experiencing, and trying to crack the secret code of love. Many of us seem to have forgotten that in the earlier days, free love was a scarcity. From aristocrats to slaves, marriages and relationships were often given as commands and choices of individuals in higher power and authority for political, religious, material and personal gains. Thus, there are the great love tragedies of "Romeo and Juliet" and "Abelard and Heloise", as well as countless others who were heedlessly persecuted for their innocent expression of love. These tragic love stories left many of us wondering, why is it so hard to love and what is like to experience that depth of love?

    Free will love has made much progress in the 21st century through the evolution of humans' love experiences, technological advancement, and cultural changes. In today's more liberal societies, people are given the freedom to choose and express their admirations and desires to the subjects of their affection with little or no consequences. However, in societies where we can freely choose whom we want to love, we have witnessed an increase in divorce rate, a decline in marriage rate, and more people delaying marriage for different reasons.

    Duality of Love

    But regardless whether we follow the "Abelard and Heloise" love model of 'following one to the end of the Hell' to 'you are just one of the 100 people that I am seeing and what is your name again?', We experience the universal conditions of pleasures and pains, the coming together, and the ultimate disintegration of love and relationships, no matter how little or how much we love. No matter how much wealth and power one possesses, one is still subject to others' emotional and physical transgressions.

    So, if we know the ultimate end to any love and relationship, why are we still relentlessly pursuing love, whether it is in the form of a committed monogamous relationship or sleeping with as many people as we can? What is it that we pursue in our teens, 20s, 30s, 40s, 50s, 60s, 70s, and up to the moment of our death? And if we are to look back at our lives, would we regret the times we did not try harder, the people we have hurt, and most painful of all, we easily let go of that person who awakens our soul, only to learn so too late.

    Pleasures and pains are the twin brothers of love. We cannot expect one and not the other. We think we deserve God-like love and it is someone else's responsibility to make us happy. If we want God-like love, then we should put in God-like work. If we are not willing to open our hearts to experience judgements, disappointments, and pains in experiencing love, how can we ask for a love that brings us happiness? If we are not willing to overcome our egos and karmic conditionings, how we can manifest a love that brings us meaning? If we are not willing to heal our souls' deepest wounds, how can we expect to live without pain?

    Love's True Nature

    Perhaps we can think ourselves as individuals who have came together to help each other learn and master the experiences of love and separation in different forms: commitment, marriage, infidelity, rejection, betrayal, and abandonment. So, in facing repetitive failures, disappointments, and hurts, we don't easily give up, and we continue to seek, learn, and understand love's true nature. In doing so, we can look beyond the rise and fall of constant changes in our everyday interactions and relationships.

    We learn to not waste energy on trivial questions like why he / she never responded to my text or never called me back. We don't doubt our values ​​because the person we love chooses someone else and we respect his / her choice and will. We don't live the rest of our lives in disappointment and hurt over people's betrayal. We don't take the easy route of love at the expense of others.

    When we transcend our experiences and learnings, love is no longer an idea of ​​you, me, he, she, or us. To love is to release us from our pains, fears, regrets, shame, guilt, and delusions, so we can transcend beyond our limited perceptions of ourselves and what love is.

    We can overcome our conditioned desires that dictate our thinking, beliefs, and behaviors in relationships. We develop the wisdom and courage to stay true to our hearts and not give in to our fears and pains for short term pleasures and gains.

    In experiencing the beginning and end of all human love relationships and their associated pleasures and pains, we learn unconditional acceptance, forgiveness, and love.

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    Source by Wendy Lin

    Views: 0

  • 3 Lazy Ways To Make Money Online

    3 Lazy Ways To Make Money Online

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    Okay I get it. You’re lazy. Not only are you lazy, you’re ridiculously lazy but you want to make some money. So I’m going to go over what I found to be literally the laziest methods to making real money online that actually works. So follow along. We’re going to go over

    3 lazy methods to make money online.

    Let’s focus on how you can be super lazy and make money online. So the first method is kind of an obvious one which is taking surveys, okay? Just sit around and basically fill out you know, answer personal questions about stuff, a really simple site that you can actually start taking surveys on.

    It’s through Amazon. So if you see on Amazon, there’s a lot of different jobs that you can do to make money online. They don’t pay all that much. They’re very simple, basic tasks you can… You know like spot objects in image and it will pay 30 cents. I mean it can’t get more lazy than that. You’re just spotting objects images to see what’s going on there. That sounds super lazy. So here’s another basic, lazy task you can do which you know you can describe a fact.

    Describe a fact and you get paid 20 cents, 3000 people have done this already. They give you instructions on how to do these things. So pretty lazy stuff. Again, these are basic tasks. You don’t get paid much for but you can make a couple bucks an hour doing this and just be totally lazy sitting out, mind numbed at your computer.

    Let’s go over a second lazy thing. So playing video games is another super lazy task that really requires very little thought time or money to do.

    And the way you would make money if you’re just going to play video games is you actually want a live stream yourself, okay? You’d want to livestream yourself on Twitch and you can make donations from people. So go to twitch.tv and here you see you can play poker on Twitch as well but a lot of people watch for Fortnite.

    You know Fortnite is the popular thing. And as you see, there’s some of the big, big people have thousands, thousands of people watching them play video games. Now to become big on you know twitch or any of these platforms, YouTube, YouTube live stream, you have to be lazy consistently you know.

    So that is the kind of annoying part is you have to consistently be lazy and just play video games and livestream yourself or else, you won’t get an audience and you know, the more animated you are the better but if you’re just a couch slob and you’re doing nothing, unless you’re a super hot chick wearing some really cute anime type gear, you’re not going to get a lot of viewers. Again, like all of this stuff, there are ways to be effectively lazy but playing video games online at least gives you the opportunity to get people to donate or ad revenue on twitch TV.

    So the third way to make money online being super lazy, just play poker. Play low stakes poker. Screw it. You know you could play poker online. Obviously, you can make money playing poker in real life but you could also lose money too and what I’m going to show you is just a super simple way of making money playing poker without really any chance of losing. And that would be to actually be an affiliate marketer for poker programs and livestream on YouTube. You can live stream on YouTube just like you do on Twitch.

    So you see poker party millions you can live stream yourself playing poker. And how you would make money, you could make money on Twitch through ads but what I’m going to show you is more effective way is live stream on YouTube. I don’t see many people doing this and I actually think this would be really effective. I don’t know why people don’t do this. But you’ll see right here is that you can get people to sign up to play poker online themselves and this company 888poker has paid out over $207,700,000 to affiliate marketers who have referred new players.

    You know, you can get anywhere from a 100 to $250 per player that signs up to play poker on 888poker. So it’s almost like they’re a sponsor of you playing poker but on a performance basis. And look at that money figure. That is a big, beautiful number right there. So really easy way play poker online and refer other people to play poker online as well.

    there you have it 3 Easy, lazy way to make money online. Sorry took a little long with that last example. But I hope this was informative, 3 super lazy ways to make money online. Again, if you don’t want to put in a lot of time, thought or money, I just gave you 3 super easy ways to get started.

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    Source by Troy D. Johnson

    Views: 0

  • How To Prevent Alcohol And Drug Addiction

    How To Prevent Alcohol And Drug Addiction

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    Drug addiction is a serious disorder. If not treated, it can lead to crises like loss of employment, living quarters and important relationships. And as if this weren’t enough, this kind of addiction can cause illness and even death. Drug addiction is multi-layered and has a variety of causes as well as contributing factors. With the knowledge we have today, Simplistic anti-drug campaigns, such as the “Just Say No” program back in the 1980’s, and even more complex programs like “War on Drugs” is not very effective. The reason for this is that these campaigns do not address the root causes of drug addiction but battles the symptoms not the causes of drug addiction.

    When most people consider a drug addiction problem, their minds go automatically to old movies or TV-series. A junkie trembling on a street corner, selling her own body for her next fix, or a tragic, pale old man lying in a gutter with a needle in his arm, or even a college girl snorting a line of crystal meth in a frat house bathroom during a wild party. These images are powerful indeed, but drug addiction generally creeps up in a slow but determined pace. Months or years are passing, during which time the addicted person is still able to function in a job, maintain a place to live as well as keeping relationships going. A drug or alcohol addiction problem generally passes slowly through several phases. Just because someone you know has not lost everything he or she owns to drugs does not have to mean that he or she does not have a drug addiction problem.

    One of the most insidious drug addiction is prescription drug addiction, followed closely by alcohol addiction. Let’s face it; we are a nation of pill poppers and alcohol beverage drinkers. Since we were children we learned that if something hurts, we should take a pill to make the pain disappear. We also see that children are being prescribed drugs such as Ritalin in increasing amounts, as parents and doctors smudge the line between active, healthy kids and kids with a true Attention Deficit Hyperactivity Disorder (ADHD). All the time we are bombarded with advertising for pain relievers, sleep medication and a lot of other remedies; prescribed and over the counter. Seen from this point of view, prescription drug addiction is not hard to understand. We hardly question the doctor thoroughly about the risk of dependency on any medication, since using medicine for almost any problem is so widely accepted. It’s so easy to take the drug without question and before we know it, we may have developed a prescription drug addiction.

    Alcohol addiction is almost as easy to develop for much the same reason. We live in a culture of drinking. We often go out for cocktails after work or drinking beer with friends during a sports event slowly gives way to having one, two, three, even six or eight beers every night. It feels normal to continually re-visit the bar during a night at a pub. Next thing we identify is a full-blown alcohol drug addiction.

    How harsh (or maybe great) it may sound, you are the only person that can prevent alcohol or drug addiction, due to the choices or decisions you make. Although addiction is classified as a disease, it may well be one of the few diseases that people choose to get. Each drug or alcohol addicted person started their life as an addict by making a choice. You are free to make the same choice or you can choose to not allow drug addiction to be your disease. It’s your choice and whether you like it or not, it is the price you have to pay for being a human with a free will.addiction a seat in your life. It’s up to you.

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    Source by David Richards

    Views: 0