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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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  • Customer Satisfaction Management

    Customer Satisfaction Management

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    General understanding of consumer satisfaction or dissatisfaction is the result of differences between consumer expectations and performance perceived by consumers. From the various definitions of consumer satisfaction that have been researched and defined by marketing experts, it can be concluded that customer satisfaction is a behavior response consumer in the form of after-purchase evaluation of an item or service that they feel (product performance) compared to consumer expectations.Consumer satisfaction is very dependent on the perceptions and expectations of consumers themselves. Factors that influence consumers’ perceptions and expectations when making purchases of goods or services are needs and desires felt by consumers when making purchases of goods or services, past experiences when consuming these goods or services and experiences of friends who have consume these goods or services and advertising.In a competitive environment, an indicator that can show customer satisfaction is whether the consumer will buy back and use the product in the future.

    Customer needs are fulfilled is one of the factors forming Customer Satisfaction (Customer Satisfaction), in addition to other factors related to Customer Service. And this customer satisfaction is what we need to ensure the continuity of our business. Aspects that can affect customer satisfaction effectively [13], namely:

    1. Warranty costs. Several companies deal with the warranty costs of their products / services through a percentage of sales. The company’s failure to give satisfaction to customers is usually because the company does not provide guarantees for the products they sell to customers.

    2. Handling of complaints from customers. Statistically this is important to note, but it is often too late for companies to realize it. If complaints / claims from customers are not immediately resolved, customer defections cannot be prevented.

    3. Market Share. It is a matter that must be measured and related to company performance. If the market share is measured, then the quantity is measured, not the quality of the company’s service.

    4. Costs of poor quality. This can be of satisfactory value if costs for customer defect can be estimated.

    5. Industry reports. There are many types and industry reports, as stated by J.D Power in Bhote, which is the report that is the fairest, most accurate, and most eagerly made by the company.Guiltinan [14] argues that one of the benefits of customer satisfaction is that it can increase customer loyalty, as shown in the figure below

    Customer satisfaction is an emotional response to the evaluation of the consumption experience of a product or service. Kotler defines customer satisfaction as the level of one’s feelings after comparing the performance (or results) that he feels compared to his expectations (Kotler, Philip, and Garry Armstrong, 2005). Basically, customer satisfaction includes the difference between expectations and performance or the results obtained.

    According to Kotler [1], satisfaction is feeling happy or disappointed someone who appears after comparing between perceptions or impressions of the performance or results of a product and expectations. So, satisfaction is a function of perception or impression of performance and hope. If the performance is below expectations, the customer is not satisfied. If the performance meets expectations, the customer will be satisfied. If the performance exceeds expectations, the customer will be very satisfied or happy. The key to generating customer loyalty is to provide high customer value.The relationship between customer satisfaction and loyal customers is disproportionate [2], for example, customer satisfaction is ranked on a 1-5 scale, namely:

    1. Customer satisfaction at a very low level (level 1), most likely customers will move away from the company and speak ill of it.

    2. Customer satisfaction at level 2 to level 4, customers feel somewhat satisfied, but it is still possible to move when a better offer appears.

    3. Customer satisfaction at level 5, customers are very likely to buy back and even disseminate good news about the company.

    High satisfaction or satisfaction creates an emotional bond with the brand or company and is not only fixated on reasonable choices.While satisfaction according to Kotler and Armstrong (2001: 9): Consumer satisfaction is the extent to which the assumption of product performance meets the expectations of buyers. If the product’s performance is lower than the customer’s expectations, the buyer is satisfied or very happy. According to Zeithaml and Bitner (2000: 75) the definition of satisfaction is: Consumer response or response regarding fulfillment of needs. Satisfaction is an assessment of the features or features of a product or service, or the product itself, which provides the level of consumer pleasure related to meeting consumer consumption needs. Consumer satisfaction can be created through quality, service and value.

    Customer expectations are believed to have a large role in evaluating product quality (goods and services) and customer satisfaction. Customer expectations basically have a close relationship between determining quality and customer satisfaction. Customer expectation always exists because of four things (Kertajaya, 2004):

    1. Individual Need or individual needs

    If your customer already has high demands, then his expectations are definitely high too.

    1. Word of Mouth

    Customers can have certain expectations because of other people’s stories. Other people’s stories are often seen as references.

    1. Past experience or past experience

    People who already have good experience in the past will be able to receive services at least the same as they used to be. If not, he will be disappointed.

    1. External communication or external communication

    It is an attempt by the company to promise something to customers in order to attract customers.

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    Source by Yufi Priyo

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  • Jimmy Carter's Cancer Cure

    Jimmy Carter's Cancer Cure

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    Jimmy Carter's cancer cure has been a breakthrough and godsend for many people expected to negotiate this terrible disease. The big difference is his treatment was successful without the use of traditional and nauseating chemotherapy.

    Cancer is the second leading cause of death behind heart disease. That's more than 1600 Americans every day. If you ever watched a friend or family go through chemotherapy, you know how awful and sickening that can be. Worse yet, some doctors use chemotherapy for certain cancers which never have responded to that treatment.

    Trying to find research that shows if chemotherapy works or not is difficult. We know that 97% of all patients who receive this treatment are deceased in less than five years. But, simple studies comparing those treated versus those who are not to evaluate if life is extended cannot be found. Yet, most oncologists want to inject this into you and tell you its the only way.

    Earlier this year, 91 year old Jimmy Carter announced his cancer cure after using new immune boosting medications. He was suffering from metastatic (spreading) melanoma to his brain and liver. Jimmy Carter was given a combination of Keytruda, surgery, and radiation therapy to send his cancer into remission.

    "These drugs work by tearing down defenses tumors erect against immune cell eradication. (1)" This Life Extension article mentions three approved immune drugs also called check point inhibitors: Yervoy, Opdivo and Keytruda. In the past, cancers with multiple gene mutations were more difficult to treat. With these new drugs, it is multiple mutations that respond most favorably. The article points out another study that injected the immune drug interleukin-2 directly into cancer tumors. All 11 patients in the study responded with a complete absence of malignant cells in a compete srinkage of the tumor.

    In terms of treating breast cancer, a similar protocol called photodynamic immunotherapy was used. It begins with sending a photosensitizing agent to the tumor. This enables the immune system to mount a response. Survival rates of these 15 women was similar or exceeded conventional methods. Except in this case, there was no mastectomy, no radiation, no chemotherapy and no serious side effects. For more information about this therapy, call the Strategic Cancer Alliance at 1-610-628-3419.

    In conclusion, not everyone responds as well as Jimmy Carter. But, the architecture for treating cancer is clearly changing. Rather than kill the cells, the medications augment your immune response. In this case, we have some studies that actually show results. Now you have a choice and can ask your oncologist about this new immunotherapy. Finally, a new day has arrived for cancer treatment and survival rates.

    (1) Life Extension Mag 2016 June "Immune-Modulating Cancer Drugs" Vol.22, No.6 p84-92.

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    Source by H Lee Johnson

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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

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  • Unbiased Renegade Network Marketer Review

    Unbiased Renegade Network Marketer Review

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    Renegade Network Marketer was written by someone who has been in and out of the MLM industry for nearly 20 years – Ann Sieg.

    She started out in the old days of cold calling, bothering friends and family and inviting disinterested people to hotel meetings and into her own home.

    Twenty years ago we didn’t have the internet, and everything has changed in the MLM industry since it came along.

    It really is nice to find a course written by someone who has been in the business that long and isn’t afraid to admit that she nearly gave up on many occasions. Too often these kinds of courses are written by young men that are barely out of high school, hoping to impress people with scantily clad models spread out over a rented Ferrari. Ann’s book is nothing like that, if you are already saying “oh not another one”.

    Renegade Network Marketer Review – The Pros

    This course is different. It has been painstakingly written by someone who knows and has been through all the pitfalls of internet marketing and who tried every method known to man to become successful in MLM.

    The Renegade Network Marketer review was written after she nearly gave up again but after she had one of those “Aha” moments.

    There was nothing wrong with network/MLM business marketing model, it was how marketing was being taught that was at the root of most network marketer’s problems. It was the methods not the business.

    So she set out to write this comprehensive course after realizing why network marketing was so frustrating and difficult. The number one problem was how to get the prospect to come to you, instead of you going after them! Now that was revolutionary! It is so ridiculously obvious.

    When you do that the playing field becomes a much friendlier place, you never get rejected or fobbed off with excuses ever again. Your social life and your friends want to be around you again, because you don’t have to try and sell them on your latest and greatest opportunity. You go from defensive to offensive, negative to positive and it’s amazing how empowering a thriving business can be. You can’t wait to get out of bed in the morning!

    The Renegade Marketer review has the tools and insight to help grow any network marketing business. It will help you generate leads and the tools to take you as far as you want to go with your business.

    The Renegade Network Marketer, deservedly, gets many positive reviews from people who have gone from debt and depression to positive cashflow and success.

    If you want a truly amazing system that will cram your funnel full of high quality prospects, take a look at the Renegade Network Marketer.

    The Renegade Network Marketer contains a 143 page in-depth, manual that details the same formula the writer used to build her successful businesses bringing not streams, but floods of income.

    Renegade Network Marketer is a must for anyone who wants to take a giant leap with their network marketing business.

    Renegade Network Marketer Review – The Cons

    Ann Sieg’s program is great. You will LEARN a lot. But you will still find yourself without a viable “process” or online marketing “system” to produces the results you need to grow your business.

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    Source by Rob Fore

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  • How Exactly Does The Salt Water Cure Work?

    How Exactly Does The Salt Water Cure Work?

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    The Salt Water Cure is one of the most effective cures for negative energy in Feng Shui. Many people question how it works. That question is a difficult one to answer satisfactorily for many. You must remember there are certain enhancements, cures or remedies in Feng Shui that require a leap of faith more than an exact scientific explanation.

    The Salt Water Cure has been used for thousands of years by Feng Shui Masters. Salt Water has also been a integral part of religions around the world (or example its inclusion in Holy Water). As well, medically, doctors in the present have been using it for many different purposes including injecting it into patients who have frozen shoulder syndrome, and getting better results than with surgery. We know that is works because it has throughout time. However let me try to be a little scientific (and I mean a little as that is not my background!) Negative Energy fills the air from a number of sources.

    Bad flying stars entering different cycles, previous owners or tenants, violence, arguments, ill health as well as power grids, computer and TVs (which all transmit positively charged ions) Salt Water cures release negative charged ions that neutralize positively charged ions. When you are by the sea or close to moving water in nature the air is filled with negatively charged ions, and we are hoping to duplicate or to create that incredible environment in your home. Some say that living in a environment charged with negative ions is the same as filling your body with nutritional food full of vitamins! You are surrounded by the best air possible.

    Another option to increase the air quality and rid your environment of negative energy is with Himalayan Rock Salt Lamps, which work in the same way.They are made from salt crystal rocks and release negative ions when used. They are excellent when faced with health issues, and can be used in a variety of ways including:

    Shape

    Use a triangular lamp when you need the element of fire or round to help enhance the metal element

    Colour

    You can also combine colour therapy with these rock salt lamps by using; Red is the traditional colour that is good to helps with tiredness and low blood pressure. Yellow is Good for spiritual pursuits and those wishing to grow within themselves. Orange is for creative pursuits and freedom and Green is for adding adding balance to your life

    The Salt Water Cure and Rock Salt Lamps for some defy explanation. But what harm can it do? Why not give it a try!

    © 2008 Fay Chapple

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    Source by Fay Chapple

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  • Climate Change: Its Ill-Effects on Health

    Climate Change: Its Ill-Effects on Health

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    The temperature increase in the atmosphere is more specifically referred to as global warming. But the climate change is the term currently favored by scientists, as it explicitly includes not only Earth’s increasing global average temperature, but also the climate effects caused by this increase.

    Any gas, which has the property of absorbing infrared radiation emitted from Earth’s surface and reradiating it back to Earth’s surface, is called greenhouse gas. Carbon dioxide, methane, and water vapor are the most important greenhouse gases. Other greenhouse gases include, but are not limited to, surface-level ozone, nitrous oxide, sulfur hexafluoride, hydro fluorocarbons, per fluorocarbons and chlorofluorocarbons.

    Though a naturally occurring phenomenon, the greenhouse effect results in a warming of Earth’s surface and troposphere – the lowest layer of the atmosphere. Of the greenhouse gases, water vapor has the largest effect.

    Some important causes of greenhouse effect include burning of fossil fuels such as coal, oil and natural gas, deforestation, increase in population, farming, and industrial wastes and landfills.

    Greenhouse gases trap heat in the atmosphere. With higher than normal concentrations, they lead to unnatural warming. The main cause of the current global warming trend is human expansion of the greenhouse effect, a warming that results when the atmosphere traps heat radiating from Earth toward space.

    Even a small global temperature increase could lead to troubling consequences like rising sea levels, population displacement, disruption to the food supply, flooding, and ill-effects on health. As a matter of fact, human health bears the greatest brunt of the consequences of the climate change.

    Ill-effects of climate change on health –

    Climate change can affect human health mainly in two ways: first, by changing the severity or frequency of health problems that are already affected by climate factors and second, by creating health problems in places where they have not previously occurred.

    Effects of temperature increase –

    Increasing concentrations of greenhouse gases lead to an increase of both average and extreme temperatures. This can compromise the body’s ability to regulate its temperature. Loss of internal temperature regulation can result in a cascade of illnesses, including heat cramps, heat exhaustion, heatstroke and hyperthermia in the presence of extreme heat, and hypothermia and frostbite in the presence of extreme cold. Temperature extremes can also worsen chronic conditions such as cardiovascular disease, respiratory disease, cerebro-vascular disease, and diabetes-related conditions.

    People working outdoors, socially isolated, economically disadvantaged and those with chronic illnesses are more vulnerable to the impact of temperature increase.

    Effects of air quality –

    Climate change has modified weather patterns, which in turn have influenced the levels and location of outdoor air pollutants such as ground-level ozone (O3) and fine particulate matter. Increasing carbon dioxide (CO2) levels also promote the growth of plants that release airborne allergens. Higher pollen concentrations and longer pollen seasons can increase allergic sensitization and asthma episodes, thereby limiting productivity at work and school. Poor air quality, whether outdoors or indoors, can negatively affect the human respiratory and cardiovascular systems.

    Effects of extreme events –

    Climate change causes an increase in the occurrence and severity of some extreme events, which can have health impacts such as death or injury during an event, for example, drowning during floods. Health impacts can also occur before and after an extreme event, as individuals involved in activities such as disaster preparation and post-event cleanup put their health at risk. The severity and extent of health effects associated with extreme events depend on the physical impacts of the extreme events themselves.

    Vector borne diseases –

    Vector-borne diseases are transmitted by vectors, which include mosquitoes, ticks, and fleas. These vectors can carry infective pathogens such as viruses, bacteria, and protozoa, which can be transferred from one host (carrier) to another. The seasonality, distribution, and prevalence of vector-borne diseases are influenced significantly by climate. Climate change is likely to have both short- and long-term effects on vector-borne disease transmission and infection patterns, affecting both seasonal risk and disease occurrence over decades.

    Water related diseases –

    Climate change is expected to affect fresh and marine water resources in ways that will increase people’s exposure to water-related contaminants which cause illness. Water-related illnesses include waterborne diseases caused by pathogens such as bacteria, viruses, and protozoa. Water-related illnesses are also caused by toxins produced by certain harmful algae and by chemicals introduced into water sources by human activities. Exposure occurs through ingestion, direct contact with contaminated drinking or recreational water and through consumption of contaminated fish and sea food.

    Effects on mental health –

    Mental health consequences of climate change range from minimal stress and distress symptoms to clinical disorders such as anxiety, depression, post-traumatic stress, and suicidal tendencies. The children, elderly, women (especially pregnant and post-partum women), people with preexisting mental illness, economically disadvantaged, and homeless are more exposed to its mental health consequences.

    Effects on food safety and quality –

    Climate change is very likely to affect global, regional, and local food safety by disrupting food availability, decreasing access to food and making utilization more difficult. Higher concentrations of CO2 can lower the levels of protein and essential minerals in a number of widely consumed crops, including wheat, rice, and potatoes, with potentially negative implications for human nutrition. Poor nutritional quality of food is more likely to affect adversely the vulnerable sections of the population.

    The bottom line –

    Over the last 50 years, human activities have released sufficient quantities of carbon dioxide and other greenhouse gases to trap additional heat in the lower atmosphere and affect the global climate. According to WHO (World Health Organization):

    • Climate change affects the social and environmental determinants of health – clean air, safe drinking water, sufficient food and secure shelter.
    • Between 2030 and 2050, climate change is expected to cause approximately 250000 additional deaths per year, from malnutrition, malaria, diarrhea and heat stress.

    So, in view of the serious repercussions of climate change on human health, we all have to make concerted efforts to reduce emissions of greenhouse gases through better transport, food and energy use choices so as to improve our health particularly through reduced air pollution.

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    Source by Dr. Pran Rangan

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  • Smart Entrepreneurs Wear Six Hats

    Smart Entrepreneurs Wear Six Hats

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    Entrepreneurs are necessarily optimistic. You need to be, it allows you to see the possibilities around you and act on them.

    However, the downside is that your emotional attachment can blind you to problems that are otherwise obvious to someone who is not as personally invested in the project.

    This is why smart entrepreneurs learn to wear six hats: six "Thinking Hats". Originally defined by psychologist Edward DeBono, the Six Thinking Hats are a structured creativity tool to help you look at a situation from different perspectives, to solve a problem or to foresee and minimize risks before they turn into problems.

    When you "wear" a specific color hat, it gives you permission to look at your problem is a specific way:

    • White Hat: Analytical – What does the data say? Look at the available data, both quantitative and qualitative. What are past trends? What can you extrapolate? Where is the evidence to support your assumptions? Where do you need more data?
    • Red Hat: Emotional – How do you feel about this? Access your intuition, gut reaction, emotion. Talk about your feelings about the situation, where you feel good and not as good. How would others feel about this?
    • Black Hat: Pessimist – What could go wrong? Think cautiously, defensively, why it might not work. Poke holes in the idea, look for the weak spots, all with the intention to identify what needs to be addressed in order to overcome any problems.
    • Yellow Hat: Optimist – What if all goes right? Think optimistically, positively. Imagine all the opportunities, the benefits, the advantages. Reach for the stars!
    • Green Hat: Creative – How can we make this better? Use your creative juices to think "out of the box". Explore weird tangents, unexpected synergies, make it into a "purple cow" (something remarkable that stands out from the crowd).
    • Blue Hat: Process – What do we need to do now? Direct the process of creativity so avoid getting stuck. When in "Blue Hat" mode, step back from the problem and consider if you are giving all of the other hats equal time.

    Entrepreneurs seem to do quite well with the Yellow, Red and Green Hat approaches to thinking about an idea. There is more resistance to the White Hat (analytical) and definitely a big block around Black Hat thinking. Could this be because the Analytical and Pessimist are associated with external control?

    There is nothing to fear from the Black Hat – it can be your best friend. Wearing the Black Hat gets you out of cheerleader mode and forces you to examine your assumptions up close. From personal experience, I know that when a project backfires, the failure can be traced back to an assumption that was not properly tested. Black Hat thinking gives your project real traction by foreseeing the difficulties and encouraging defensive planning. This makes the plan more resilient and improves the probability of success.

    As you explore wearing the various Hats, put on the Blue Hat (Process) from time to time to see if you are considering all the perspectives of your project. Note that the purpose of this thinking exercise is not to assign fault or blame. The mindset of every Hat is to make sure the project succeeds.

    It is great fun to dream big and to reach for the stars. But if you want to make any progress, you need to keep your feet on the ground. Practice wearing the Six Thinking Hats as you plan and execute your business project. This mindset will give you the traction to power your project towards real and enduring results.

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    Source by Davender Gupta

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