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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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  • How to Take Amazing Photos for Instagram As a Digital Marketer

    How to Take Amazing Photos for Instagram As a Digital Marketer

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    Instagram has recently grown to become even larger than Twitter. This clearly indicates what an amazing opportunity the site represents for marketers, especially those with something very physical to sell.

    But still you'll find that a lot of businesses are reluctant to invest much time or money into the site. Why is that? Often it comes down to confusion over what type of content they should be creating and what type of content does well on the site.

    How to Take Great Photos

    Apart from anything else, success on Instagram often comes down to knowing how to take great photos. Instagram is an arty app that's all about showing the beauty in everyday life.

    As a business, this means showing the beauty in your product or in your niche.

    To do that, you need to start thinking of composition in your photos and of how a photograph can potentially tell a story.

    How can a photo tell a story? An example might be to show an empty wine glass with a lipstick mark around the edge and a fire burning just out of focus in the background. Perhaps feet lingering in a doorway. This tells the story of a romantic night that has just come to an end and people are free to imagine the details of that night.

    Likewise, a photo of a gym kit discarded on the ground next to a protein shaker, suggests a workout. Maybe there are headphones here too and maybe there are muddy trainers, showing that it was a run in the rain. The caption might be something like 'No Excuses' , from which we can infer that even on rainy days, we should still be working out.

    If you're selling trainers, or a brand of wine, these pictures are far more effective than simply showing the products themselves – as they put your product in context and they 'show the lifestyle'.

    Show the Lifestyle

    When you sell a product, you are really always selling a 'value proposition'. In other words, you are selling the lifestyle or the improvement that your product promises. You don't sell fat-free yogurt … you sell abs!

    Understanding this distinction is very important for marketing because it should be the value proposition that really gets your audience excited – rather than the product itself.

    Likewise, people like seeing pictures that create some kind of emotional response.

    Think of this and start framing your shots in more interesting ways that infer rather than tell, and you will start to gain traction on Instagram.

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    Source by Olla Boluwatife Joseph

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  • Entrepreneurship Ideas

    Entrepreneurship Ideas

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    The world is full of need. Need is the foundation of business. Ergo, the world is full business opportunities. This analogy is true being that products and services are generally created to respond to a given social requirement. Food, shelter, security, comfort, entertainment – these are needs commonly recognized and catered by experienced entrepreneurs. This is probably the reason why there is an abundance of restaurants, convenience stores, rental apartments and townhouses, security agencies, spas and clubs in communities around the world. If you are a first time entrepreneur who wants to penetrate the business world, you have got to tap innovative entrepreneurship ideas. Otherwise, you’ll just be drowned out by senior competitors.

    Many of those the established entrepreneurs we have today made their mark in the industry with unique businesses thoughts. They even sought to address needs which were not that recognized by people. Socialization and information are human desires that have given some ingenious individuals access to the big bucks. Facebook and YouTube are ground-breaking entrepreneurship ideas, made real, that dared to redefine the concept of modern entrepreneurship.

    Honestly, it’s hard to top what these young industrialists have achieved. But aspiring businessmen need not feel discouraged about losing out. Here are some creative business proposals that might just get you that free slot with the big shots.

    1. Search Engine Optimization and Web Design
    Given the popularity of the use of the internet and the emergence of online businesses that wish to hit it big in search engines, these services are bound to be profitable. It can be done on a project basis so you don’t have to be committed to something long term. You can even keep another job while running such a business. Moreover, resources for SEO and web design are 50% free and the tools you use for it can be paid by monthly basis. Downside is you have to learn. Search engine optimization and web design aren’t complicated. But they will require some time investment in the beginning. What some start up entrepreneurs do is act as middle men for SEO and web design requests and outsource the tasks to cheap but capable Filipino or Indian specialists.

    2. Deliver Anything Service
    People are very busy nowadays and have hardly enough time to run errands. Running a deliver anything service is gainful considering that you would be able to cater to a large market with basically the same need – fast, efficient delivery of goods. You can be contracted by a studio owner who wants to deliver an important footage to a television station in another side of town; or a mother who wants to get her son’s lunchbox to him while he’s in school in one hour or less; or a businessman who wants to get a gift sent to a client living in another city within the day. The downsides are: it will require a hefty sum of capital and that you have established competitors known as the internet and couriers. Information sharing is fast and cheaper via emails and collaborative folders. And couriers basically give the same service. You’re only advantage is you are not fickle with what deliveries you make.

    3. Events Organization
    This is a fun business and it will challenge all aspects of your being an entrepreneur, from marketing to planning to budgeting and execution. You can cater to weddings, corporate parties, birthdays, baptisms etc. You will be able to widen your network as you pursue this service. And unlike the previous entrepreneurship ideas, YOU WILL NOT BE INVESTING ANY CAPITAL. You just got to establish a reputation and exert effort. You can start small. Start with friend. Get his/her money, spend it wisely and secure a high level of satisfaction. Marketing is basic word-of-mouth. If you do well, you will have a hoard of fans in no time.

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    Source by Greg Peter Candelario

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  • Naval Architect As Entrepreneur

    Naval Architect As Entrepreneur

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    These days a lot of Naval Architects are leaving well paying jobs to start their own entrepreneurial ventures. In this article, I will be exploring the minimal requirements required by a Naval Architect to start his own entrepreneurial venture.

    Different Avenues for a Naval Architect as an Entrepreneur

    i). Start their own Shipyard/ Ship Repair Yard

    ii). Start your Design firm

    iii). Start a Naval Architectural Consultancy

    Starting one’s own shipyard / repair yard will be beyond the means of a majority of wannabe entrepreneurs because of the large amount of capital involved. I will not discuss this topic, any further.

    Start your own Design Firm

    A Naval Architect, by profession is a designer. Design is his bread and butter and hence setting up a design firm will not be all that difficult for a wannabe entrepreneur. Let us see one by one, the minimal requirements for setting up a firm. I will not go into the business plans and cash flows required to set up a design firm as there are lot of books / articles in the net covering the same.

    i). Knowledge Base: A thorough knowledge in the inside-out of Naval Architecture touching all aspects of Naval Architecture. These include (but might not cover everything) Lines Plan, Hydrostatics, Stability, Initial Weight & Volume design, weight estimation, volume estimation, Resistance, Propulsion, Ship Structure, Sea keeping and Maneuvering. This knowledge base can be you yourself, and if you feel that you want to augment your intellectual base, then you can hire naval architects to work for you. If you are a One Man Army, then your costs for maintaining the Knowledge base will be restricted to the books and journals you subscribe to, to keep yourself updated. If you are employing Naval Architects, then you have to factor in their costs too. However if you are stating out as an Entrepreneur, then I am confident that your knowledge base will be sufficient to set you up, in the initial stages. Later on, once your business picks up, you can augment your manpower.

    ii). Office for Hiring: You should have an office space to set up your Naval Architectural Firm. The Office is to have 1-2 rooms, covering a floor area of approximately 1000-1200 sqft. The costs will depend on the area where you have chosen to hire your office.

    iii). Softwares; In the initial days, all the Naval Architectural calculations were done manually or at the most, by using Slide Rules and Logarithmic tables. However, with the advent of computers, things have changed. Nowadays sophisticated softwares are there to cater to each and every aspect of Naval Architectural calculations. These softwares start with the concept design and evolve on to full design at the workshop level stage. However these proprietary softwares are very costly as they are not mass produced to cater to millions of users. A single license can cost up to a million dollars. This will make it out of reach for most of the budding Naval Architects. However, if one does have the resources, then go for it. Some of the proprietary softwares used in the Ship Design field are TRIBON, AUTOKON & SHIPCONSTRUCTOR.

    However these days, with the advent of Open Source Software and freeware, one can get almost all the functionalities of proprietary softwares in these OSS and free softwares, though may be not, all in one.

    For drafting of lines plan, one can go for AUTOCAD. A single license, costs anywhere between 1000-1500 US$. However, these days there are excellent freeware drafting softwares, which one can use. I recommend FREESHIP, an excellent software with all the drafting and graphic functionalities of a Proprietary software.

    For Hydrostatic calculations and detailed stability calculations, one can go for MS EXCEL or Open Office spreadsheet. With the help of these spreadsheets one can do the calculations for Hydrostatics, Stability, Resistance (Based on various empirical formulae) and even propulsion calculations.

    I will talk about other free open source softwares in another article. Let me summarize the gist of my argument here.

    The softwares to set up a Ship Design Consultancy Firm are now freely available as Open Source Software. If at all, some calculations have to be carried out, which are not catered for, by these softwares, one can always go for Spreadsheet applications using Open Office or other similar Open Source products.

    iv). Other Overheads: Includes office furniture, stationary, etc.

    Starting your own Consultancy Firm

    A Naval Architect is a jack of all trades. His field encompasses a host of other fields like Mechanical Engineering, Architecture, Interior Designing, Chemical Engineering, Corrosion, Welding Technology, Software writing skills, Project Management, Hydrodynamics, Ocean & Offshore Structures, to name only a few.

    He can offer consultancy in a wide range of subjects.

    i). Initial Concept design which includes Sizing, Hydrostatics & Stability, Resistance & Propulsion, Initial estimates of weight.

    ii). Propeller-Engine Matching

    iii). Boat/Ferry design

    iv). Propeller Design

    v). Structural Calculations/ Buckling Calculations

    vi). Computational Fluid Dynamics

    vii). Finite Element Analysis

    viii). Offshore structures

    ix). Submarine cables and piping design

    x). Resistance calculations

    xi). Maneuvering calculations

    xii). Seakeeping Calculations

    xiii). Welding & Corrosion related consultancy

    xiv). Many others which cannot be detailed down

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    Source by Candice Gillifaasi

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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

    Views: 0

  • The Internet Lifestyle For College Students

    The Internet Lifestyle For College Students

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    The reality that most college students are facing when they graduate from school are either.

    One.

    They will not be able to find a job.

    Two.

    If they do find a job, it won’t be the one that they want to work at.

    Which is why starting an internet business in their dorm room and working on it around their schedule is the best option for them.

    Many go out and do part-time work, but that is really a waste of time.

    Students would better off using that same amount of time to working on an internet business that will start bringing them in passive income.

    There are 2 types of income that you can earn.

    Active income- the amount you are paid for by the hour for being there.

    Passive Income- money coming to you, whether or not you working or not!!

    See the difference?

    Your main goal in your career is to set up a business that allows you to earn MASSIVE passive income daily!!

    This what the schools aren’t teaching their students and it is a huge problem in our society.

    Okay, now that you understand the difference between active and passive income.

    Here are the 4 steps to starting your online business from your dormitory and living the internet lifestyle.

    1). Target a market or niche.

    2). Set-up a 1-page opt-in site.

    3). Drive a lot of traffic to that site.

    4). Monetize that traffic.

    This is an outline of what your internet business should look like.

    Now, let go little more into details here about each step.

    Targeting a niche.

    Do your research and find out what type of problems your classmates are facing in school or look to find a product or market that is being underserved.

    Once you find it.

    Go get a product or service that can solve that problem.

    It’s really that simple.

    Also, make sure that the market you choose is full of hungry prospects.

    Because the market will always determine the niche that you choose.

    After you find your affiliate product.

    Buy a domain name and set up a 1-page site.

    You will need to write up a short 12-page report that you give away to people who opt-in to your newsletter.

    Your report must be of value to your prospect, because you want to build trust with them.

    Next, do videos to drive traffic to your site.

    I would interview experts and then link your site in the resource box.

    Start a Facebook group as well.

    Write a few articles or share some in your newsletter.

    The next thing is to start making money from all your previous efforts.

    You should have already signed up with a ClickBank/Commission Junction and any other affiliates.

    It’s free too, so don’t worry about that.

    I like to contact companies who don’t have an affiliate program and then help them create one and create a distribution channel from it.

    Look, this is just an outline that any college student can use.

    Keep in mind too.

    This only cost you about 30$ to start and you can use that money bootstrap your way from there.

    ACTION TIP

    Get started today on doing your market research and find a hungry market and then follow the steps I gave you here in this article!

    Good luck!

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    Source by Thomas Jay Daniels

    Views: 0

  • 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

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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

    Views: 0

  • 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