The Hierarchy of the Labor Union - 2083 Words

Are union locals independent of employers or are they incorporated into the management of the workplace? The hierarchy of the labor union begins with the international union that is labeled as the highest level of labor organization. It is followed by district council that can be found all over the country. Furthermore, the jurisdiction of the union locals only covers small areas that would include towns and cities. It will not be wrong to say that the employees of individual work places are represented by union locals (Mayhew, 2013). The precise demarcation of the union locals as being dependent or independent of the employer cannot be made since the union locals are an organization within the workplace. Therefore, union locals are organizations that are formed by the employees of a certain company, firm or any other workplace, for the welfare of the members of the union locals and other employees. The objective of this organization is to advance the interest of the employees of that work place in terms of wages, working conditions and employee benefits. Likewise, union locals are not a part of the management but they form a bridge between the management of the workplace and the employees. This implies that the members of the local unions represent the employees and negotiate with the management, in the forms of contracts and otherwise, whenever they feel that the welfare of the employees is at stake. The relationship between the union locals and the management isShow MoreRelated Norma Rae and Labor Conflict Essay examples879 Words   |  4 Pagesand Labor Conflict Labor conflict is strongly portrayed in Norma Rae, especially since in the second half of the 20th century labor unions were taken for granted as a basic workers right (even as membership declined). Norma Rae both emphasizes the power unemployment has over the worker and shows the power that unions can have in the capitalist system. Companies want to control every aspect of the labor process because they need to make profits, and the way in which they control the labor processRead MoreHumanistic Era Reflection Paper1315 Words   |  6 PagesHuman Relations Perspective was Abraham Maslow. Maslow is one of the more well known behavioral theorists, and his contribution to the Humanistic Era would be his Hierarchy of Needs theory. This theory states that an individual has 5 levels of needs (physiological, safety, love, esteem, and self-actualization). He felt each need of hierarchy had to be met before moving onto satisfying the next need. There was also a theorist by the name Dougl as McGregor. His theory was known as Theory X and TheoryRead More Two Major Unions in America Essay1440 Words   |  6 PagesTwo Major Unions in America Unions in America were created to improve the working conditions of its labor force. These labor force consisted of the men, women, and children that were employed by the owners of industry. Many unions were established in the early 1800s, but due to the widespread fear of socialism and the repression from the courts, the majority of them eventually failed. Most capitalist, at the time, felt there was no need to share with its employees the profits of their businessesRead MoreDelta Airlines Tense Relationship with Its Employees1102 Words   |  4 PagesBenefits The key issue for compensation and benefit for Delta’s airline was labor expense through salary and wages for their employees. These issues raise for the increase in taxes and security fees, rising prices of fuel, labor management mistakes, and large executive perks. 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As a general rule, the Fair Labor Standard Act (FLSA) sets 14 years of age as the minimum age for employment, and limits the number of hours worked by minors under the age of 16. The U.S 2014 census estimates also shows that Texas population has been dominating by Whites (80.0%) over Black or African American (12.5%);Read More The Working Class Essay1578 Words   |  7 Pagesrather of a complex mechanism† who yielded to their boss’s every demand (Pollard 1). Once-skilled artisans and craftsmen were often subject to working routine processes as machines began to mass produce the goods formerly made by hand. This change in labor had a devastating impact on accomplished workers; they were no longer any different than their unskilled counterparts, women, and children in the eyes of factory owners. Due to the noticeable difference between Proletariats and the Bourgeoisie, socialRead MoreA Common Choice For Immigrant Women885 Words   |  4 Pagesstructural aspect of gender formation. Harrison 2 Gender formation is the grouping of people into categories within the hierarchy of gender through structural institutions and societal representation. In the example of the Triangle Shirtwaist fire, the structure of the law allowed for the women to be treated carelessly because of their position below men in the gender hierarchy. There were no laws in place for there to be emergency exits or adequate working conditions for them at the time. WomenRead MoreThe Success Of Total Rewards Program Essay1577 Words   |  7 Pagesof this metric is to see an increase in satisfaction of employees within the organization. Including a section for employees to add their own comments could also be beneficial. Question 2: Given what you have learned about employee relations and labor relations, do you think it is possible for an HR practitioner to be an effective advocate for both employees and the organization at the same time? Why or why not? The HR practitioner’s roles are more evolved than what it used to be. When you heardRead MoreStiglitz Business Report724 Words   |  3 Pageshas also increasingly placed the burden onto the backs of the lower and middle classes in order to keep important social programs going. Worker suppression is also a trend that Stiglitz takes issue with. He believes that, the ongoing weakening of unions has led to corporations being able to take unfair advantage of their employees due to their decreased bargaining power. How They Should be Changed Stiglitzs proposed solutions to this two issues are rebalancing the tax and transfer system and empowering

Gun Control Is One Of The Biggest And Most Debated Issues

Gun control is one of the biggest and most debated issues nowadays and decisions are rarely made and only on a small scale. However, it is an issue that needs to be addressed which brings up several questions like, When should we do something about gun violence? and When should we act? According to the white house, the time to act is now. As a matter of fact after a big gun tragedy at the Sandy Hook Elementary School, president Obama said the following, We won t be able to stop every violent act, but if there is even one thing that we can do to prevent any of these events, we have a deep obligation, all of us, to try. There are, however, two popular, yet completely opposite, ideas on how deal with the gun violence in the United States. One extreme is banning all firearms, while the other to have no gun control at all. Those two opposite opinions pose an important question to be addressed. Should guns be accessible to most people or should stricter gun control be enforced instead? (No w is the Time) One of the major pro-gun control arguments points out that more guns equal more homicides and suicides. Recent studies and statistics show that, while the United States has 10.3 gun deaths per 100,000 people, countries which have stricter gun control have a much lower ratio. Take for example the following countries and their gun death rate per 100,000 people – United Kingdom (0.23), Germany (1.01), Denmark (1.28), and Sweden (1.47). While some might argue that there areShow MoreRelatedThe Debate Over The Gun Control892 Words   |  4 PagesOne of the most debated and talked about issues going on today concerns gun control. There are many different aspects being brought up with concern to gun control. One of the biggest this past year especially here in Texas is the issue of allow-ing conceal carry on college campuses. College campuses are usually gun free zones, but with so many shootings happening on campuses some want to be allowed to carry. A lot of people are for infringing upon a person’s constitutional right to life andRead MoreMemorandum On Firearm Policies While Answering The Four Main Questions1443 Words   |  6 Pagespeople. 1. I’ve used various frameworks from class to approach this issue. I applied concepts from Alinsky, Cobb Elder, and lessons from Sinclair. I based my work on Alinsky theory of â€Å"limited wins. My objective is to gradually implement firearm control policies. In this case my policy was limited to prevent criminal from purchasing firearms and documenting private firearm transactions. Even if this policy is implemented, other issues such as mentally ill people and potential domestic terrorist havingRead MoreThe Issue Of Gun Control1199 Words   |  5 PagesOne main issue in the Americas is the problem of gun control and if guns should be allowed. Many Americans will argue that since it is allowed in the Second Amendment there should be no argument that the people should be allowed to own guns. Others will say there should be gun control because many crimes committed are with guns. On the other hand it could be seen as criminals still finding some way of getting guns albeit th rough smuggling or some other way of obtaining guns which would lead to moreRead MoreEssay on How Big is Your Gun1158 Words   |  5 Pagestype of arms should be allowed to bear? How can the people obtain these arms? All of these questions have been debated, discussed, and argued by both sides of the controversy. Who should be allowed to keep and bear arms? Federal law states that one must be eighteen years old or older to purchase a rifle or shotgun, and twenty-one years old or older to purchase a handgun. The pro-gun advocate argues that eighteen to twenty year olds should be allowed to own handguns and sixteen year olds shouldRead MoreEssay On Gun Control1248 Words   |  5 PagesViews on Gun Control Gun control is one of the few things in today’s society that is a major problem and that is extremely prevalent in the United States. This phenomenon has been a controversy for decades that is still highly debated today. One of the reasons why this topic is so important is because of how dangerous firearms can be towards others or even yourself. Just in the past couple of years there has been multiple incidents involving firearms and death. For example, the shootings at SandyRead MoreGun Control in America Essay993 Words   |  4 PagesThere are gun control laws to try and reduce the number of violent shootings that occur. They are trying to put limits on weapons that Americans can own. The government is trying to take our guns away mainly because of people that are criminally insane. Most of the people who commit crimes don’t even have the weapons legally. If the government takes away the rights of people who are allowed to have firearms in their possession, it will most definitely cause an outrage. Most people believe that theRead MoreThe Issue Of Gun Control1288 Words   |  6 PagesThe issue of gun control is one the most heavily debated topics in today’s society. With the increase in school shootings starting around the turn of the century, gun control advocates have been blaming guns instead of the deranged people for these heinous acts, and been calling for the banning of guns for civilian use. Gun control would be harmful in today’s day and age where people don’t have complete trust in the government and the police and where gangs are very prevalent especially in urbanRead MoreObama Care: Ted Cruz Essay923 Words   |  4 Pagesâ€Å"Washington Post† would call his win the biggest upset of the 2012 elections. Coming form a very republican state such a Texas means that his stance on issue would be very involved with that of the Republican Party. Pro-life, traditional marriages between one man and one woman, and a very heavy supporter of gun rights, he votes strictly along party lines. Also, he would not be afraid to flex his muscles out on the floor, and would threaten to filibuster any gun control legislation that wou ld come up (LengellRead MoreGun Laws And Gun Control1584 Words   |  7 Pages Guns in the U.S has been a problem for many years now. So much so that America is what comes to mind when people think about guns. America is the most known nation in the world when it comes to firearms, with citizens owning about an astonishing 270 million of the world’s 875 million firearms(Marshall). That is thirty percent on the world registered firearms. The reason why Americans own so may guns comes down to the second Amendment, which claims, â€Å"A well-regulated Militia, being necessaryRead MoreGun Control And Gun Rights Essay1888 Words   |  8 Pagesviolence, abortion, discrimination, racism, gun control and gun rights. Guns have been a hotly debated topic for decades now. There are many different reasons for why it is such a prevalent issue such as, safety, constitutional rights, self defense, mental health, and many more. The two sides of gun control and gun rights see t he social issue differently. One side views guns as a safety hazard that needs to be fixed, and the pro gun side view that guns are a Constitutional right that should not be

Financial Management Evaluation of the Business Proposal†Free Samples

Question: Discuss about the vehicle for Environmental Protection Against carbon Emission for RUNWELL Corporation. Answer: Introduction The present budget report is focused on the evaluation of case study of RUNWELL Corporation in order to assist them in making viable decision regarding their new proposal. For this purpose, various financial tools and industry facts will be considered in the financial evaluation. On the basis of the analysis, the recommendation will be provided to GM of RUNWELL Corporation so they can make a selection of the most beneficial option. Table of cash flows Table of cash flow shows outflow and inflow of cash affected by this project. Initially, RUNWELL Corporation is required to make an investment of $1,570,000. In addition to this, variable cost will be of 45% and fixed cost of $160,000 every year. Employees are required to be trained for training cost, and quality assurance cost is to be incurred. All these expenses are easily recovered through revenues that will be earned through the proposed project and at the end of each financial year there is positive cash flow. Further, at the end of the project i.e. in 8th year, there will be higher cash flow as realisable value of the asset will be recovered. Cash budget of the company shows that GM had considered all possible expenses and revenue to showcase actual position of the project. Positive cash flow at the end of every single financial year clearly shows that proposed project is beneficial financially as it will make improvement in overall credibility and financial position of busine ss. Investment appraisal tools Net present value This is the most viable capital appraisal tool as it considers all crucial aspects of projects like time, inflow and outflow of cash and the present value of money. In accordance with this tool, the project is considered to be favourable if it provides positive value by considering all outflow and inflow of cash. By considering net present value calculation of present proposal, it can be noticed that NPV of the project is $610,636. Discounting for this project is done by considering WACC in order to appropriate consideration of time value of money in cash flows. The project is also beneficial because in initial years there is high flow which increases the overall value of investment in the proposed venture. Internal rate of return This capital appraisal tool computes the interest rate at which NPV is zero i.e. cash inflow is equivalent to the cash outflow. This tool is beneficial for evaluation of attractiveness of project for the purpose of investment. As per this technique, the project is said to be profitable if IRR is higher in comparison to the required rate of return. Computation shows that IRR of proposed venture is 23% which is higher than the cost of capital. It shows that project inflows are sufficient to recover the cost of investment as well as to provide positive returns to the company. Payback Period Payback period is specified as the number of years which are required to pay back initial investment of a capital project through cash flows of the project. Formula = No of years before full recovery of project cost+ Unrecovered cost at the start of year/ Cash flows during full recovery year. The net cash flow is the cash generated through the investment each year. It is also considered as a frequent method of capital budgeting as the same provides management with a rough estimate regarding the decision of acceptability of the project. Hence it is applied in a variety of capital decision for ascertaining appropriate decision. In the present case, according to calculation, it can be observed that a short payback period i.e. 3.8 years thus the project should be accepted by management. Discounted Payback period Discounted payback can be said as that period of time which is required to cover the cost of a project, by including positive discounted cash generated from the profits of the project. The advantage that can be attained by applying the specified method is that the final decision is taken considered after taking into account the time value of money. Formula = Year before discounted payback period occurs + Cumulative cash flow in the year before / Discounted cash flow in the year after recovery. The calculation of discounted payback period is having a minor change in comparison to payback period i.e. the cash flow used in calculations are discounted by the weighted average cost of capital which is used at the interest rate. Discounted payback period occurs when the negative cumulative cash flow converts to positive cash flow; this generally exists in a second and third year. In the present scenario as high positive cash flows exists in initial years and at the same time a lower discounted payback period exists; the project should be accepted by the management. As the existing conditions will allow management to cover investment cost in starting years i.e. in 5.51 years and even possibilities are available for earning higher profits. Industry factors By considering the trends of the industry, it can be noticed that huge efforts are made by automobile manufacturers to make a reduction in carbon emission by making an investment in research and development activities in order to meet environmental standards. However, technologies used for this aspect is continuously changing, but previous technologies are not getting absolutely obsolete. It is because huge technical investment is made to achieve even smaller reductions. Thus, the considered project for 10 years will not be significantly affected by the technological advancement. Although, if in meanwhile duration of the project if there is better technology then GM of RUNWELL Corporation can opt for that by considering cost-benefit analysis of the same. Further, being a part of the automobile industry, RUNWELL Corporation should focus on other factors influencing emissions during the use of the vehicle along with considering environmental aspects. These factors comprise carbon conte nt of fuels, the behaviour of the driver, infrastructure and the age of the car fleet. This has been considered in the proposed project which shows investment is viable financially as well as non-financially. Recommendations By considering the above analysis, GM of RUNWELL Corporation is recommended to accept the proposal for introducing a new line of parts of the vehicle for environmental protection against carbon emission. Investment in this project will provide monetary as well as non-monetary benefits to the company. The investment will provide positive returns to the company as there is positive NPV of $610636 and internal rate of return is comparatively higher than the cost of capital. Furthermore, regulatory authorities are changing regulations to promote technologies in favour of environment and reduction in carbon emission is one of them. In addition to this, customers also consider the fact of carbon emission while making their purchase decision by being conscious about the environment. As a consequence, this project will provide a competitive advantage to the company by generating goodwill and strengthening brand image. With the completion of this project, the company can make an investment in advanced technologies that will ensure environment protection as well as profitability for the business. The concern of GM is viable regarding unexpected growth in car manufacturing technology, but industry analysis clearly indicates that proposed project is in favour of market trends through which company will be able to attain competitive advantage and grab market opportunities for extraordinary profits. Conclusion In accordance with the present study, the conclusion can be drawn that proposed project is in benefit of RUNWELL Corporation as it will make an increase in their operating profits along with providing non-monetary advantages such brand enhancement and competitive advantages in the market. References Books and Journals Garrison, R.H., Noreen, E.W. and Brewer, P.C., 2003. Managerial accounting. New York: McGraw-Hill/Irwin. Haron, N., Yahya, S. and Haron, H., 2014. Cash Flow Information And Small Enterprises'performance. International Journal of Organizational Innovation, 7. Fleisher, C.S. and Bensoussan, B.E., 2015. Business and competitive analysis: effective application of new and classic methods. FT Press. DRURY, C.M., 2013. Management and cost accounting. Springer. Grant, R.M., 2016. Contemporary strategy analysis: Text and cases edition. John Wiley Sons. Michalski, G., 2013. Planning optimal from the firm value creation perspective levels of operating cash investments. arXiv preprint arXiv:1301.3824. Braun, K.W., Tietz, W.M. and Harrison, W.T., 2013. Managerial accounting. Pearson. Needles, B.E., Powers, M. and Crosson, S.V., 2013. Principles of accounting. Cengage Learning. Brigham, E.F. and Ehrhardt, M.C., 2013. Financial management: Theory practice. Cengage Learning. Carraher, S. and Van Auken, H., 2013. The use of financial statements for decision making by small firms. Journal of Small Business Entrepreneurship, 26(3), Pp.323-336.

Why Content Curation is Important and How To Get Started

Nothing beats original, high-quality content to get the attention of your customers and connect with them. But carefully selected, relevent pieces from other sources can be a great complement to your mix. It can help you fill gaps in your content schedule, increase trust with your customers as a reliable source of information and even earn you thanks from the original authors. Understanding Content Curation Many businesses are increasingly using curated content to add diversity and interest to their social media channels. One study even showed that one-third of content marketers share some kind of industry news or other related information on a daily basis. The key to curating successfully though is the unique editorial slant or commentary your brand adds to it.For example, provide your own thoughts on why you disagree with the author or you could just highlight key points you agree with.Whatever you decide, the best results will come from adding some value when you share the piece rather than just sharing it with no context for your unique audience. Benefits of Curating While thought leadership is probably the most compelling reason to incorporate content curation in your marketing strategy, there are several other benefits: Conserves resources:Curating content allows you to boost your online presence without the same time and effort that comes when creating your own original content. This give you more time to devote to optimizing your strategy and other tasks. Improves SEO:Sharing interesting items can help make your content more â€Å"link-worthy,† adding significant SEO juice.For the biggest SEO boost, focus on sharing visual content such as infographics and videos.Research shows that posts featuring videos earn triple the inbound links of their text-only counterparts. Boosts visibility:If you want to stand out in a competitive social-media marketplace, it’s important to maintain your visibility and post on a regular basis.Curating allows you to do just that. Filling those gaps with carefully curated content will help keep your brand visible. Furthermore, tagging the original author will increase your visibility with them which can come in handy when you’re looking for people to share your original content. Not sure where to begin with curating content?Here are a few free or cheap tools to help you get started and turn you into a content-curation master in no time: Pocket:This save-for-later app is a must-have for the new content curator.No need to keep sending yourself links or bookmarking countless items:Pocket lets you keep all your saved articles, videos and images in one place.You can add the Pocket button to your browser and get the app for your phone for easy cross-platform functionality. And the app integrates with Evernote and hundreds of other apps. Twitter lists:Without lists, it can be difficult to organize information and manage the various handles you follow.Twitter’s list functionality allows you to create custom groups of users you follow. For example, you could start a â€Å"content marketing† list for all your must-follow accounts related to the field.If you’re using Pocket in conjunction with Twitter lists, curating content gets even easier:You can save articles found on Twitter right to your Pocket account. Scoop.it:For marketers who have already nailed the basics of content curation, Scoop.it can help you take your curation game to the next level.Choose a topic that interests you, and Scoop.it will deliver relevant articles for you to read and share.Even better, it will generate related topics that might interest you and suggest Scoop.it users you may want to follow.The most robust version of the platform costs $11 per month, but you can try the free version first before you subscribe. Boosting Your Marketing Strategy In the world of content marketing, nothing will ever trump the power of high-quality, original content. But content curation can be a valuable tool in any brand’s marketing strategy.By understanding the benefits of content curation and using the right tools for the job, you can use curated content to maintain your online presence and establish your brand as a real authority in its field.

Touro University International Essays (466 words) -

Touro University International James L. White ETH 501 Module 4, Session Long Project Dr. Steven J. Gold INTRODUCTION The purpose of this report is to describe any sense of barriers in women's advancement in my firm or if there have been such barriers in the past. This report will provide the reader with some information about the company I work for and some facts about the barriers women have been through. By discussing these topics I hope to offer some knowledge about my organization. I will conclude this report with a brief summary of the entire analysis, highlighting some of the most significant parts that the report contains. BARRIERS As you can recall; I am in the military and we train and mentor Health Service Management Apprentice. In an article entitled Amazing Women in War and Peace by Retired Captain Barbara A. Wilson she explained, "In October of 1778 Deborah Samson of Plimpton, Massachusetts disguised herself as a young man and presented herself to the American army as a willing volunteer to oppose the common enemy. She enlisted for the whole term of the war as Robert Shirtliffe and served in the company of Captain Nathan Thayer of Medway, Massachusetts." (Barbara, 1996) Women for years to come tried to join the military service only to be denied because of their gender. In May 1942 the Women's Army Auxiliary Corps was created to serve at aircraft service stations which freed men to do other vital duties needed by the military. In the spring of 1943 the Women's Army Auxiliary Corps was changed to the Women's Air Corp's. It was not until 8 July 1948 that the first woman, Esther M. Blake, was able to join the Air Force. In accordance with 5 U.S.C 2301. Merit Systems Principles," Recruitment should be from qualified individuals from appropriate sources in any endeavor to achieve a work force from all segments of society, and selection and advancement should be determined solely on the basis of relative ability, knowledge, and skills, after fair and open competition which assures that all receive equal opportunity." 5 U.S.C, 2006). What that means is no one can be denied employment because of their gender. This is one barrier that women like Deborah Samson and Esther M. Blake have paved the way to overcome. CONCLUSION In today's Air Force you can see that women play a big role in the military mission serving in many vital roles, from pilots to ground troops. History has taught us that we lose out on a lot of good ideas and employees if we discriminate against an individual because of race, gender, religion, etc... WORK CITIED 1. Amazing Women in War and Peace by Retired Captain Barbara A. Wilson, retrieved on 21 August 2006 from http://coelacanth.aug.com/captbarb/ 2. Air Force Pamphlet 36-2241 Volume 1, retrieved 25 August 2006 3. Retrieved 21 August 2006 from http://www.mspb.gov/

Pollution Prevention for Tannery Industry Essay Example

Pollution Prevention for Tannery Industry Essay Example Pollution Prevention for Tannery Industry Paper Pollution Prevention for Tannery Industry Paper Essay Topic: Water pollution The assessment identified following pollution prevention opportunities at this facility: recycling the spent chrome tanning wastes, oxidize the sulfide containing wastes, decreasing the volatile organic discharge by changing finishing materials, decreasing water use by batch washing, and using solid wastes from the waste stream as fertilizer. Chromium recycling. This step allows the collection of the spent chrome Nanning solutions, without dilution or contamination, for use in the pickle and tanning process. Since the tannery also tans splits, the spent chrome tanning solution can be used here as well. The tanning of splits results in very good fixation of chromium, so the concentration of chromium in the final effluent should meet effluent regulations. This system results in a saving of about 25 percent in the chromium chemicals used. Solvents. The suppliers of finishing products have developed water-based lacquers with significantly lower volatile solvent contents. These materials are now widely accepted as quality products, and their use is strongly advised. Process Water. In some hide wetting processes there is an opportunity to recycle the final rinses. The final rinse wastewater in this process is compatible with fluids used for the first wetting of the hides. Solid Waste. Elimination of solid leather waste discharges through the use optimizing in reconstituted leather will ease the burden on landfills. Capital Intensive Modifications. Eliminating sulfides from the effluent is very important, as they will corrode pipes, cause objectionable doors, and may cause fatal accidents. The sulfide-lime solution, and washes from this process, can be collected without contamination from other solutions. These collected wastes can be placed in a tank and the sulfides oxidized by air with a catalyst. This method is effective and can destroy the sulfide in 4-8 hours. At this point the lime waste, with high BODY and suspended solids, can be used to neutralize the acid wastes that are being continuously discharged. The acid and alkaline wastes from the tanning process will react to produce a expectoration of much of the suspended lids and BODY. This is done with a mixing tank and automatic pH control. Coagulants can also be added at this point. The neutral streams can then flow to a primary clarifier for the removal of suspended solids as sludge. The sludge can be dewatered in a sand bed to more than 50 percent solids for disposal. Although this effluent is somewhat high in BODY, over 80 percent of the pollution load have been removed. The sludge is a good soil conditioner, and if used as such, will eliminate possible high disposal costs. Secondary Treatment. In the future, a secondary treatment system can be added for BODY removal. The secondary system need only be as large as needed for the clarified wastes, and it may consist of a trickle filter, a secondary clarifier, and/ or a filter press. Environmental and Economic Benefits implementation of the suggestions will lead to a number of positive environmental and economic benefits. Chromium recycling will decrease the chromium in the discharge by 80-90 percent. It decreases chromium to less than 3 MGM/l. Costs were estimated at $20,000 (US), savings at $60,000 per year ND therefore payback period of 4 months. The reduction of volatile solvents will decrease VOCE releases to the atmosphere by 60-90 percent. Changes to water usage patterns will decrease effluent volume by 20-40 percent. Elimination of solid leather waste discharges through the use of trimmings in reconstituted leather eases the burden on landfills. This decrease leather waste by 60-80%. Costs were estimated at $1 0,000 (US). Destroy sulfides by air oxidation decreases sulfide wastes by 95- 98 percent. Costs were estimated at $30,000. (US) With primary and secondary treatment, the BODY an be reduced by 75 percent.

A biographical sketch of Johannes Brahms Research Paper

A biographical sketch of Johannes Brahms - Research Paper Example His education began in 1835 when he enrolled at Heinrich Friedrich, elementary school. In 1844, he joined a private secondary school managed by Johann Friedrich Hoffman where he conducted his studies until 1847. He loved Bach and Beethoven and his audience marveled as they watched him play the piano and even conquered that his playing of the Bach was masterful and came from the heart (Van Camp, Leonard, Ottley, Jerold 156). And by 1846, he was earning money for playing piano in some local entertainment joints. Brahms initially became renowned as a composer in the chamber of music, a fact that has made some of his critics to place him in the conservative German camp of Schumann. However, it was his inclination to write in a chamber music style while stressing on thematic-motive development, and logical forms that earned him fame as an accomplished composer of brain music. Chamber music was critical for Brahms compositional output at every level during his auspicious career (Steib 96). Brahms was self-conscious of his technical abilities and worked effortlessly to improve them (Littlewood 344). He started composing at an early age, but he was so self-critical and did not want to acknowledge his effort by putting his name on his compositions. In 1848, Brahms attended a performance by Joseph Joachim in Hamburg Philharmonic Orchestra of Beethoven’s Violin Concert though he did not meet him until 1853. In the same year, Brahms held his first own concert, where he played music composed by; Theo Dohker, Jacob Rosenhain, Marxen, Bach, and Herz. Other artists who performed at the event included Franziske Cornet-Kiel and her daughter Adele. In 1849, Brahms began to write potpourris for music journalist August Cranz under the alias G.W. Marks. The same year he held his second own concert where he performed music by; Sonata, C. Mayer while Cornet-Kiel and her daughter participate yet again. He

Race and gender assignment Movie Review Example | Topics and Well Written Essays - 750 words

Race and gender assignment - Movie Review Example The film then cuts to another scene with different characters. In this scene two individuals are carjacked. The film then explores an instance where two undercover police officers, one white and one black shoot at each other, with the black officer being killed. Another scene has a Latin locksmith change the locks of an individual. The individual then indicates to another that they do not trust the locksmith because they could be a gang member. The next scene demonstrates two officers pulling over a car that matches the description of a car that was stolen earlier. The officers have the two people get out of the car and one of the officers molests the female passenger. The other officer then goes and requests the he be assigned a new partner, saying that his partner is a racist. The film cuts to a later time when the two passengers that were featured earlier are talking. The woman that was violated by the officer is angry with her husband because he did not do anything to intervene, while he claims that he acted appropriately. The film then cuts to a man talking to his daughter because she is hiding under her bed after hearing a gun shot. He then gets ready for his job as a locksmith, and its clear that he was the individual from earlier that the woman referred to as a possible gang member. The film then cuts to another scene where two men are in a stolen car. They are talking about race and lose track of what they are doing and hit an Asian man. They stop and then later leave the man in front of a hospital. The film then cuts back to the shop that was featured earlier in the film. Daniel the locksmith that has been featured throughout the film is at the shop and attempts to fix a door, but becomes involved in a conflict with the owner. Later the door is pa inted upon and the shop owner blames the locksmith. The officer featured earlier then goes and visits an insurance agent. He talks with

Annotated Bibliography for Intellectual Property Rights

For Intellectual Property Rights - Annotated Bibliography Example Trading necessitate liberalized economic policies which are cited in the General Agreement on Tariff Trade which the author presupposed as an instrument that hinder the use of war as instrument for economic expansion. This policy is however should be rechecked using cost-benefit analysis to secure issues pertaining to environment, culture, use of technology, child labor, migration, and presence of other multinational organizations and concerns for world peace. Author further argued that the company explicitly argued that to secure the products being introduced to the market, necessary measure for intellectual properties rights should be adopted to protect itself from distortions happening in the market or those that are made by the government. Intellectual property (IP) is defined as creations of the mind and preservation of authorship on inventions, literatures, arts, movies, symbols, names, images, and designs used in commerce (WIPO, 2012, p. 1). This cover industrial property of trademarks, patents, industrial designs, and geographic indications of source, and copyright (WIPO, 2012, p. 1) . Traders argued that IPR balance and neutralize the impacts of all possible effects of tariff policy and also improves the countrys position the worlds productivity rank. This is because it sets legal limitations to conditions in industrial developments to protect the properties and creation of innovators (Lerner, Strojwas, & Tirole, 2005). This limitations are universally applied thus can’t be considered as negative for new entrants in the market. Many research studies proved that this is a theory that protects the authors from those that can do infringement e.g. pirate the nature of products made by another. Many poor countr ies however criticized this policy as unfavourable to the indigenous people whose vast knowledge on natural medicines cannot avail of patents and

The Media Discourse Of Youth Subcultures Media Essay

The Media Discourse Of Youth Subcultures Media Essay The cultural universe of young people is a complex and dynamic one (White, 1999) and there has always been a tendency among youth researchers to investigate the significant social changes that are being revealed through the experiences of contemporary youth (Leccardi Ruspini, 2006). Some of the earliest sociological researches on youth can be linked to the emergence of new forms of consumptions and distinct youth cultures that began to rise in the late 1950s. The changes in youth at this era were highly visible through music and fashion the young populations were consuming. This was viewed both as a result of the increase time available for leisure and personal resources (Leccardi Ruspini, 2006) as well as an attempt to create some symbolic meaning for self (White, 1999). In times of high unemployment where youth were caught in between the ideology of spectacular consumption promoted by the mass media and the traditional ideology of capitalism and the meritocratic work led to a pro liferation of empirical studies across a wide range of diverse issues from homelessness to unemployment, youth crime to street gang violence that engages in research relevant to both empirical and theoretical matters in order to stretch the conceptual boundaries in the contemporary society (White, 1993). Youth subcultures can be viewed as a response to the interaction between these different areas. This response is seen by some as an identity seeking reaction between resistance to consumerism created by the production based Puritanism and the new hedonism of post war consumption (White, 1993). This paper looks into the contemporary youth subcultures and the media discourse used in the representation of these subcultures. It is argued that such negative representations of youth subcultures would result in the popularization and re enforcement of activities rather than limiting or controlling such deviant behaviors and thereby confirming the labeling of a demonized and at risk youth groups. Further, the reports supports the idea that the media interventions in crime and social problem areas can lead to misplaced reactive political resources in mythic rather than real social problem areas resulting in amplified and exacerbated social problems generating moral panics (White, 1999). A culture can be defined as designs for living that constitute peoples way of life (Macionis Plummer, 2008:128). The five components of culture identified by Macionis and Plummer (2008: 130) include; symbols, language, values, norms and material culture. Culture has several, often contradictory meanings that carries ambiguity that can be traced in its different uses throughout history (Brake, 1985). While the classical perspective views culture as a standard of excellence (high culture), others view culture as a way of life which expresses certain meanings and values attached with a particular way of life known as the low culture'(Williams, 1961, p. 57). It is this conceptualisation of low culture that is central to the development of subcultures as an analytical concept (Brake, 1985). Subcultures can be defined as a cultural pattern that set apart some segment of a societys population (Macionis Plummer, 2008: 139) or a social group which is perceived to deviate from the normative ideals of adult communities (Thornton, 1995: 2). The earliest use of subcultural theories within sociology can be linked to its application as a subdivision of a national culture (Lee, 1945; Gordon, 1947). Culture in this context was viewed as learned behaviour with emphasis on the effects of socialisation within the cultural subgroups of a pluralist society (Brake, 1985). In most of the Western world, studies of youth subcultures have been dominated by a tradition associated with the 1970s work of the Centre of Contemporary Cultural Studies, University of Birmingham, England (Thornton, 1995). The Birmingham subcultural studies tend to banish media and commerce from their definition of authentic culture seen media and commerce as incorporating subcultures into the hegemony and effectively dismantling them (Hedbige, 1978). Chicago School sociologists on the other hand were concerned on researching empirical social groups by taking precedence over their elaboration of theory and were mainly focused on the shadier recesses of polite society (Nayaka, 2003:14 in Thornton, 1995). This report will look at subcultures as cultures that are labelled directly or indirectly by the media with a problematic authenticity and as media and commerce integral to the authentication of its cultural practices. Supporting this, A.K. Cohen states that a major determinant of s ubcultures among the youth as what people do depending upon the problems they contended with (Cohen, 1955, p.51). Cultural theorists argue that what it means to be young should be seen in the context of its cultural significance indicating that it is the context of cultural significance that makes been young so distinctive and not the structural focus of society (Alan, 2007). That is, the context the youth are exposed to and the issues that their exposures carry play a significant role in the construction of a youths culture. When understanding the conflicts surrounding young people and the way they use public space, the media plays a central role by constituting and shaping the principal form of the public sphere and by gathering and distributing important public information (Thompson, 1994 in Sercombe, 1999). One may argue that there is no certain measure of the direct effects of media coverage on the public. However, there are often negative and powerful cultural effects of media produced by the constant flow of its commercialized imaginary fictions and stereotypical coverages that socially construct a moral and narrative set of offerings upon which the youth attempt to build their identities on (White, 1993). Not only in building identities, the youth tend to use these social constructions by the media also as a measure for their achievements and personal worth by simply deriving an identity from a set of meanings drawn on the basis of media constructed stimulations instead of their local experiences (Baudrillard, 1983). It is important to note that the notion of identities are constructed across and by differences, and the social construction of youth identities though historically varied is tightly bound with the media representations made available at the time (White,1999). Therefore, we can argue that media is a critical component of the development and maintenance of the representation of young people which often feeds into the fears and negative attitude surrounding the presence of young people in public space as problematic or threatening (Sercombe, 1999). Moral panics in relation to youth music and subculture are not uncommon in the news and other media (Goode Ben-Yehuda, 2008, pp. 124-145, in Phillipoy 2009). Most cities in Australia like many other cities around the world housed for a large number of subcultural activities ranging from skateboarders occupying the steps and benches in the Melbourne streets to Goths congregating the inner city suburbs (Gelder, 2007). It also has a number of drag night clubs, gay and lesbian bars, a remarkable graffiti subculture; in which Melbourne has been claimed as a stencil graffiti capital (Smallman Nyman, 2005). Australia has several times witnessed its teenage subcultures clash in the streets; like the Mods and Sharpies in August 1966 (Sparrow Sparrow, 2004: 73-77). Stan Cohens classic Folk Devils and Moral Panics (1980) and the centre for Contemporary Cultural Studies Policing the Crisis (Hall et al. 1978) both indicate how mainstream media contributes to the public anxiety about youth subcultures and youth groups that are deemed to be deviant. Cohen, in his work looks at the development of conflict between mods and rockers, in a British seaside town, and particularly the escalation of conflict that arose as a result of the medias representation of these events. He argues that the media were responsible for amplifying the perception of deviance arising from a few of small-scale disturbances, which ultimately led to an escalated interventions from the police and judiciary, with the demonization and over-typification of young people involved in the mod or rocker styles. Similarly in Australia Cunneen et al. 1989, carried out a study on the disturbances at the Bathurst motorcycle races concluding that it was the over representation of the small di sturbances that led to the large scale conflicts and that the press concentrated on authority opinion while sensationalizing the material published (Cunneen et al., 1989). When analysing the literature published on the media representations of youth and youth subcultures it is evident that communications media create subcultures in the process of naming them and drawing boundaries around them in the act of describing them (Thonrton, 1995). The way media is inextricably involved in the meaning making and organization of youth subcultures will be discussed through the analysis of the representations of many recent incidents related to youth subcultures, particularly the ravers, Goths and emo subcultures. The rave subculture emerged worldwide in the late 1980s as a musical subculture and was a phenomenon in the area that attempted to invert the traditional rock n roll authenticity by remixing and creating a cutting edge disk culture with a warehouse party format and was established in Chicago, Detroit and across Britain (Thornton, 1995:4). Soon groups of young people were clustered in sites conventionally aligned with musical performance to listen and dance to electronic dance music played by djs in Sydneys alternative rock scene Unlike other musical subcultures such as alternative rock scene where performances generally took place in formal environments such as pubs and clubs the raves in Australian cities began to use spaces such as old warehouses, factories and train stations for their activities (Gibson Pagan, 2006). Since the late 1980s rave culture worldwide has increased their members and was diversified and fragmented in many aspects becoming more contradictory with various s ubcultures emerging such as the Doofs, Drum and Bass and Happy hard core. Mean while controversies and public moral panics were starting to generate over the diverged more politicized illegal party culture that were shifting itself from the mainstream (Gibson Pagen, 2006). Associations were made between these part scenes and illegal drugs such as ecstasy by the media providing the basis for a moral panic. Ravres were described as new age hippies where their activities summed up to no sex, but drugs and rock roll (Sun Herald, 15/1/1995:1995,121). Dance parties in Sydney eventually became associated with tropes of youth deviance and illegality making the rave space in the public consciousness as a site beyond the domain of mainstream, and thereby causing strong reactions from the public and a need for increased control over their events (Gibson Pagen, 2006). A major shift in the perception of the public of youth subcultures could be related to the ecstasy related death of teenager A nna Woods from Sydney at an Apache party in 1995. Her death was magnified within the media creating an unprecedented wave of media attention and public panic. With headlines such as Ecstasy agony and Ecstasy secret world running on the front pages for nearly two weeks, dramatically altering not only the rave culture but the perception of youth subcultures as a whole (See Sydney Morning Herald, 26/20/1995:1,4). The initial response of sympathy by the public to the incident soon turned into fear and anger that progressed from tension and social anxiety to a full blown social and political crisis (McRobbie, 1994) with scapegoating not only the ravers but creating fear against many youth subcultures (see Daily Telegraph, 25/10/1995:415). The death of Anna was interpreted as a symptom of the malaise affecting many young Australians (Daily Telegraph, 5/11/1995:8), with the NSW state government taking actions to close down clubs and bars which have promoted drugs in parties (Gibson Pagen, 2006). For a few months in 2007, the dangers of Emo and computer use were significant themes in many Australian newspaper coverages (Phillipoy, 2009). Emo is an abbreviation of the terms emocore or emotional hardcore which is a musical sub-genre of punk rock music, characterised by emotional or personal themes. They adopt a look that includes black stovepipe jeans, dyed black hair and side-parted long fringes, which might merely have been one of the many tribes (Bennett, 1999) that characterise this contemporary youth culture(Phillipoy, 2009). Following the deaths of Melbourne teenagers, Jodie Gater, Stephanie Gestier and Carly Ryan in year 2007, over an approximately five months period the media portrayed the two separate incidents linking the suicide and the murder to the Emo subculture and to the social networking site MySpace, presenting both as dangerous and worrying developments in contemporary youth culture (Phillipoy, 2009). These media discourses surrounding the deaths included many features of moral panic including a build-up of concerns disproportionate to the real risk of harm (see Goode Ben-Yehuda, 2002, pp.33-41). While the emo youth were viewed as straightforward folk devil (Cohen, 1972) or the enemy, the problem of emo was also framed as a product of much broader problems of youth culture (Goode Ben-Yehuda, 2002). The connections between emo and the deaths of these young girls were tenuously published over the mass media and was seen as symptomatic of what John Hartley (1998) describes in the context of r eporting on young people more generally as a profound uncertainty in the textual system of journalism about where the line that defines the boundary of the social should be drawn by the broader groups of non-subculturaly affiliated youth. The result of this according to Phillipoy, is a cultural thinking out loud (Hartley, 1998) where broader cultural anxiety are expressed and explored that can be described as anxiety about disclosure. The newspaper coverages on the deaths focused on the dangers of young peoples disclosures that made them inaccessible to adult authority that otherwise could have prevented the tragedies. Although some of these concerns were connected to the specificities of emo subcultural expression, with excessive emotions on display and the enigma associated with subcultural imagery respectively, they were on the whole linked to a broader problem in contemporary youth culture that was seen to apply to all young people, irrespective of any subcultural affiliation. T he expressions of anxieties that the private lives of young people were becoming increasingly unknowable to adult authorities, and, hence, that youth culture itself was increasingly unknowable were popular statements made by the media (Phillipoy, 2006). Reportings such as bizarre teenage goth and emo world world constructed both as dangerous (in the sense that the apparent involvement in subcultural activities was presented as disturbing and something that put her at risk of harm) and impenetrable (in the sense that subcultural affiliations and imagery was understood not simply as harmful but also as bizarre). In conclusion, the representations of young people in the media directly or indirectly depend on the interest of the newspapers and the discourse of its source. Language used by these media allows painting young people in different colors (Sercombe, 1999) and as youth subcultures are prime fare for the news media as in terms of news value they are both exotic and familiar (White, 1993) media and youth subcultures have a complex and symbolic relationship where young people are devoted consumers and producers of media and engage with media in the approval and adaptation of subcultural forms for their own context. Therefore, many of the subcultures can be argued to be reproduced and constructed through the media (White, 1999). The mainstream media however tend to represent youth subcultures mythologically as they often attempts to represent not the real world but the world that suits the advertisers, owners and the government. This leads to the constant stereotyping, reinforcing and exa ggerating issues, particularly in relation to the youth (White, 1993). Youth was been commodified and portrayed within the media as the mindless hedonism of lost youth (Brown, 2005). They were categorized as a careless generation that was only concerned with seeking pleasure and satisfaction from personal risk taking and drug use (Brown, 2005). By constructing notions of deviance and illegality, commercial media not only position youth and youth subcultures but are implicated in defining authentic underground activities that further strengthen subcultural practices that are deemed deviant (Gibson Pagan, 2006). Therefore, it is clear that media have been and is today, a major influence in fuelling and reinforcing perceptions of problem youth. Subcultures are constructed and stereotyped by the media as deviant and the media representations linked to the issues around subcultures have created an image of uncaring, hedonistic and self centered youth (Alan, 2007). Hence, this report suggest that the media is directly or indirectly responsibility for the fuelling and reinforcing of such deviant activities that they have constructed aligned to youth subcultures and that youth subcultures are a social construction mainly influenced by the national mass media. Therefore, the national media, particularly newspapers as the most commo nly used news media has a responsibility in the a discourses that are used to represent youth groups and youth subcultures as it carries an impact on the broader youth communities worldwide.

George Polya :: essays research papers

George Polya (1887-1985) -Chronological order: Fibonacci, Simon Stevin, Leonhard Euler, Carl Gauss, Augustus DeMorgan, J.J. Sylvester, Charles Dodgson, John Venn, and George Polya   Ã‚  Ã‚  Ã‚  Ã‚  George Polya was born and educated in Budapest Hungry. He enrolled at the University of Budapest to study law but found it to be boring. He then switched his studies to languages and literature, which he found to be more interesting. And in an attempt to better understand philosophy he studied mathematics. He later obtained his Ph.D. in mathematics from Budapest in 1912. He later went on to teach in Switzerland and Brown, Smith, and Stanford Universities in the United States.   Ã‚  Ã‚  Ã‚  Ã‚     Ã‚  Ã‚  Ã‚  Ã‚  Solving problems is a particular art, like swimming, or skiing, or playing the piano: you can learn it only by imitation and practice†¦if you wish to learn swimming you have to go in the water, and if you wish to become a problem solver you have to solve problems. -Mathematical Discovery   Ã‚  Ã‚  Ã‚  Ã‚  In 1914 while in Zurich Polya had a wide variety of mathematical output. By 1918 Polya published a selection of papers. These papers consisted of such subjects as number theory, combinatorics, and voting systems. While doing so he studied intently in the following years on integral functions. As time went by he was noted for many of his quotes such as the following. -In order to solve this differential equation you look at it till a solution occurs to you. -This principle is so perfectly general that no particular application of it is possible. -Geometry is the science of correct reasoning on incorrect figures. -My method to overcome a difficulty is to go round it. -What is the difference between method and device? A method is a device which you use twice.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   (www-groups.dcs.st-and.ac.uk)   Ã‚  Ã‚  Ã‚  Ã‚  One of Polya’s most noted problem solving techniques can be found in â€Å"How to Solve it†, 2nd ed., Princeton University Press, 1957. 1. Understanding the problem 2. Devising a plan 3. Carrying out the plan 4. Looking back   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   This can be described as See, Plan, Do, Check.   Ã‚  Ã‚  Ã‚  Ã‚  Polya continued to write many more books throughout the years and has been distinguished as one of the most dedicated mathematicians. George Polya :: essays research papers George Polya (1887-1985) -Chronological order: Fibonacci, Simon Stevin, Leonhard Euler, Carl Gauss, Augustus DeMorgan, J.J. Sylvester, Charles Dodgson, John Venn, and George Polya   Ã‚  Ã‚  Ã‚  Ã‚  George Polya was born and educated in Budapest Hungry. He enrolled at the University of Budapest to study law but found it to be boring. He then switched his studies to languages and literature, which he found to be more interesting. And in an attempt to better understand philosophy he studied mathematics. He later obtained his Ph.D. in mathematics from Budapest in 1912. He later went on to teach in Switzerland and Brown, Smith, and Stanford Universities in the United States.   Ã‚  Ã‚  Ã‚  Ã‚     Ã‚  Ã‚  Ã‚  Ã‚  Solving problems is a particular art, like swimming, or skiing, or playing the piano: you can learn it only by imitation and practice†¦if you wish to learn swimming you have to go in the water, and if you wish to become a problem solver you have to solve problems. -Mathematical Discovery   Ã‚  Ã‚  Ã‚  Ã‚  In 1914 while in Zurich Polya had a wide variety of mathematical output. By 1918 Polya published a selection of papers. These papers consisted of such subjects as number theory, combinatorics, and voting systems. While doing so he studied intently in the following years on integral functions. As time went by he was noted for many of his quotes such as the following. -In order to solve this differential equation you look at it till a solution occurs to you. -This principle is so perfectly general that no particular application of it is possible. -Geometry is the science of correct reasoning on incorrect figures. -My method to overcome a difficulty is to go round it. -What is the difference between method and device? A method is a device which you use twice.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   (www-groups.dcs.st-and.ac.uk)   Ã‚  Ã‚  Ã‚  Ã‚  One of Polya’s most noted problem solving techniques can be found in â€Å"How to Solve it†, 2nd ed., Princeton University Press, 1957. 1. Understanding the problem 2. Devising a plan 3. Carrying out the plan 4. Looking back   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   This can be described as See, Plan, Do, Check.   Ã‚  Ã‚  Ã‚  Ã‚  Polya continued to write many more books throughout the years and has been distinguished as one of the most dedicated mathematicians.

Legal Writing

555 P. 2d 696 Supreme Court of New Mexico. Zelma M. MITCHELL, Plaintiff-Appellee, v. LOVINGTON GOOD SAMARITAN CENTER, INC. , Defendant-Appellant. No. 10847. Oct. 27, 1976. Appeal was taken from an order of the District Court, Bernalillo County, Richard B. Traub, D. J. , reversing a decision of the Unemployment Security Commission and awarding benefits to discharged employee. The Supreme Court, Sosa, J. , held that employee’s insubordination, improper attire, name calling and other conduct evidencing wilful disregard of employer’s interests constituted ‘misconduct’ disqualifying her from receiving certain unemployment benefits. Reversed. Attorneys and Law Firms *576 **697 Heidel, Samberson, Gallini & Williams, Jerry L. Williams, Lovington, for defendant-appellant. Gary J. Martone, J. Richard Baumgartner, Joseph Goldberg, Albuquerque, for plaintiff-appellee. OPINION SOSA, Justice. This case presents the issue of whether petitioner’s actions constituted misconduct so as to disqualify her from certain unemployment compensation benefits. On June 4, 1974, petitioner-appellee Zelma Mitchell was terminated for alleged misconduct from the Lovington Good Samaritan Center, Inc. On June 12, 1974, Mrs. Mitchell applied for unemployment compensation benefits. Finding that Mrs. Mitchell’s acts constituted misconduct, a deputy of the Unemployment Security Commission disqualified Mrs. Mitchell from seven weeks of benefits pursuant to s 59-9-6(B), N. M. S. A. 1953. On July 24, 1974, Mrs. Mitchell filed an appeal. The referee of the Appeal Tribunal reversed the deputy’s decision and reinstated these benefits to Mrs. Mitchell on August 28, 1974. On September 13, 1974, the Center appealed the decision of the Appeal Tribunal to the whole Commission pursuant to s 59-9-6(E), N. M. S. A. 1953. The Commission overruled the Appeal Tribunal and reinstated the seven week disqualification period. Mrs. Mitchell then applied for and was granted certiorari from the decision of the Commission to the District Court of Bernalillo County pursuant to s 59-96(K), N. M. S. A. 1953. On January 16, 1976, the District Court reversed the Commission’s decision and ordered it to reinstate the benefits to Mrs. Mitchell. From the judgment of the District Court, the Center appeals. The issue before us is whether Mrs. Mitchell’s actions constituted misconduct under s 59-9-5(b), N. M. S. A. 1953. Mrs. Mitchell started work at the Center in Lovington on July 4, 1972 as a nurse’s aide. After approximately one year on the job in addition to her normal duties she also served as a relief medications nurse two days per week. On June 4, 1974, she was terminated. The testimony concerning the events leading up to her termination that day is somewhat contradictory but basically is the following. Mrs. Mitchell arrived punctually to work at three p. m. The director of the Center, Mr. Smith, questioned her about why she was already filling in her time card. Mrs. Mitchell answered that she filled in eight hours, which she would work that day as long as she did not ‘break a leg or die. ’ Mr. Smith replied, ‘Well, I’m not so sure about that. ’ Mrs. Mitchell then became defensive and stated that she had supported him when the Director of Nurses, Mrs. Mary Stroope, sought to have him fired as director. Mrs. Stroope, in the vicinity, overheard this comment, denied it, and called Mrs. Mitchell a liar. At various times during this exchange Mrs. Mitchell referred to Mr. Smith, Mrs. Stroope, and others as ‘birdbrains. This occurred in a crowded area where the Center’s employees were checking in and out, so Mr. Smith told both to go into his office. There, Mrs. Stroope apologized to Mrs. Mitchell for calling her a liar and Mrs. Mitchell apologized for saying that Mrs. Stroope had circulated a petition to replace Mr. Smith. However, tempers soon flared again and Mr. Smith resolved to fire Mrs. Mitchell. Mrs. Mitchell then demanded her check. Mr. Smith paid her for that day, a week’s vacation, and another week’s salary for being terminated, which he was not required to do since Mrs. Mitchell failed to give him two weeks’ notice. 577 **698 Appellee Mitchell argues that the events of June 4, 1974, do not constitute misconduct within the meaning of s 59-9-5(b), supra. Appellant Center argues that these events were the last of a series of acts of misconduct, and the ‘birdbrain’ incident should be considered the ‘last straw’ resulting in her termination. Mitchell counters that the prior acts of misconduct should not be considered. The alleged acts of prior misconduct are the following. On April 2, 1974, Mrs. Mitchell went to work at the Center out of uniform (she wore gold pants rather than navy blue). On that day the Federal Regulation Inspectors visited the Center. Mrs. Mitchell stated that she did not know that the federal inspectors would be there that particular day. The Director of Nurses reprimanded her and told her to go home and to change into the proper attire, which Mrs. Mitchell refused to do. The following day Mrs. Mitchell again came to work out of uniform but this time she was directed to go and did go home to change. On May 24, 1974, Mrs. Mitchell was switched from medications to the floor routine. Angered, Mrs. Mitchell refused to give medications, even though the charge nurse and Mrs. Stroope explained to her that the reason for the switch was that she was familiar with both jobs whereas the replacement nurse, Carol Skurlock, was unfamiliar with the floor routine. Mrs. Mitchell stated that she did not like being replaced by a ‘white’ nurse’s aide (Carol Skurlock). Mrs. Mitchell considered herself and Carol to be just ‘birdbrain against birdbrain,’ apparently because neither she nor Carol was a licensed nurse. From May 24 to June 4 Mrs. Mitchell refused to perform her duties as a relief medications aide. On May 15, 1974, and other days, Mrs. Mitchell sang while counting medications and was not very co-operative, which caused Betty Clarke, R. N. , to complain that Mrs. Mitchell’s actions were unethical and time-consuming. The term ‘misconduct’ is not defined in the Unemployment Compensation Law. The Wisconsin Supreme Court in Boynton Cab Co. v. Neubeck, 237 Wis. 249, 259-60, 296 N. W. 636, 640 (1941) examined the misconduct subsection of its unemployment compensation act, found no statutory definition of misconduct, and formulated the following definition: . . ‘misconduct’ . . . is limited to conduct evincing such wilful or wanton disregard of an employer’s interests as is found in deliberate violations or disregard of standards of behavior which the employer has the right to expect of his employee, or in carelessness or negligence of such degree or recurrence as to manifest equal culpability, wrongful intent or evil design or to show an intenti onal and substantial disregard of the employer’s interests or of the employee’s duties and obligations to his employer. On the other hand mere inefficiency, unsatisfactory conduct, failure in good performance as the result of inability or incapacity, inadvertencies or ordinary negligence in isolated instances, or good faith errors in judgment or discretion are not to be deemed ‘misconduct’ within the meaning of the statute. We adopt this definition. Applying this definition of misconduct to the facts of the case before us, we hold that Mrs. Mitchell’s acts constituted misconduct. *578 **699 Mrs. Mitchell’s insubordination, improper attire, name calling, and other conduct evinced a wilful disregard of the interests of the Center. Although each separate incident may not have been sufficient in itself to constitute misconduct, taken in totality Mrs. Mitchell’s conduct deviated sufficiently to classify it as misconduct under the above test. Appellee’s argument that the ‘last straw’ doctrine should not be used is hereby rejected. The district court is reversed and the decision of the Commission is reinstated. McMANUS and EASLEY, JJ. , concur. 764 P. 2d 1316 Supreme Court of New Mexico. Billie J. RODMAN, Petitioner–Appellant, v. NEW MEXICO EMPLOYMENT SECURITY DEPARTMENT and Presbyterian Hospital, Respondents– Appellees. No. 17721. Nov. 30, 1988. The District Court, Bernalillo County, Ross C. Sanchez, D. J. , upheld administrative decision denying unemployment compensation to claimant. Claimant appealed. The Supreme Court, Ransom, J. , held that incident precipitating claimant’s termination demonstrated willful disregard for her employer’s interests. Affirmed. Stowers, J. , specially concurred and filed opinion. Attorneys and Law Firms **1317 *759 Juan A. Gonzalez, Legal Aid Society of Albuquerque, Inc. , Albuquerque, for petitioner-appellant. Connie Reischman, New Mexico Employment Sec. Dept. , Albuquerque, for respondents-appellees. OPINION RANSOM, Justice. An administrative decision of the New Mexico Employment Security Department denying unemployment compensation to Billie J. Rodman was reviewed on certiorari by the district court. Rodman now appeals to this Court from the order of the district court affirming the administrative decision. Rodman had been employed by Presbyterian Hospital as a unit secretary for nearly eight years when, on February 17, 1987, she was terminated under hospital personnel policies following a â€Å"third corrective action† notice. Prior restrictions had been placed on Rodman’s conduct due to personal problems adversely impacting upon her place of work. At issue is whether the misconduct which warranted termination from employment rose to the level of misconduct which would warrant denial of unemployment compensation under NMSA 1978, Section 51–1–7 of the Unemployment Compensation Law. The Department reasonably summarizes the substantial evidence as follows: Rodman was reprimanded in June of 1986 for receiving an inordinate number of personal telephone calls and visitors at her work station, which was disruptive to her own work and to her co-workers. The formal reprimand set forth conditions to prevent further corrective action. Rodman was to have no personal telephone calls during work hours outside of a designated break or dinner time, in which event they were to occur in an area not visible to patients, physicians, or other department staff. When leaving the department for dinner, Rodman was to report to her immediate supervisor and was not to leave the hospital. Rodman was to make every effort to resolve the matters in her personal life that were causing problems at work. Nevertheless, according to the testimony of her supervisor, extremely disruptive telephone calls continued. The doctors were beginning to comment on it. The staff was getting more distressed. According to her supervisor, â€Å"[A]gain we talked about the visits, the behavior at the desk. When it got pretty bad with the phone calls, Billie would slam charts, push chairs and be a little abrupt with the people she worked with. † Another written reprimand in November of 1986 warned Rodman that her job was in jeopardy if the disruptive behavior continued. The supervisor established restrictions prohibiting the claimant from having visitors at the department and instructed her to notify security if there was a potential problem. On February 15, 1987, Rodman began work at 1:00 o’clock in the afternoon. She had spoken to her boyfriend’s mother earlier in the day to tell her that she did not want him to use her car as she had broken off their relationship. The boyfriend’s mother called her at work and told her the boyfriend had her car keys. Rodman told the mother to have the boyfriend call her at work. When he did, she informed him that she could not talk to him at her duty station, and he hung up on her. He called her back and left a number where he could be reached. She left the work area and went to the break room to call him. After returning to her duty station, Rodman got another telephone call from her boyfriend who told her to go downstairs to the lobby to meet him and pick up the keys. When she refused, he told her that if she did not come down he would come up to her department. Claimant eft the department to confront her boyfriend, and, because her supervisor was at lunch in the hospital cafeteria, Rodman notified a co-worker, a registered nurse, that she was leaving. Rodman testified, â€Å"I didn’t want any kind of confrontation at the desk, so I went downstairs. † Before she left her desk, Rodman called the employer’s security guard and asked him to meet her in the lobby because she anticipated that a problem could develop. When Rodman got to the l obby, her boyfriend started yelling and forced her outside. In doing so, he tore her shirt. At this point the security guard arrived and observed them arguing. Rodman was in the passenger seat of her car. The security guard instructed the boyfriend to return the keys, but the boyfriend jumped into the driver’s seat, locked the doors and drove off. About thirty-five minutes later, Rodman returned to her work station, after having changed her torn shirt. She resumed working, but, as the shift progressed, more telephone calls were received for her in the department. The supervisor became frustrated with the volume of calls and the behavior of Rodman. It was determined that Rodman should be sent home. Thereafter she was terminated. The Appeals Tribunal of the Department of Employment Security found on the basis of the evidence that the appellant had proven unwilling to restrict her personal contacts while at work, as requested by her employer. The hearing officer dismissed as without **1319 *761 merit Rodman’s contention that she could not stop her acquaintances from calling or visiting her at work. The hearing officer concluded that Ms. Rodman’s behavior was unreasonable, had caused many problems for her work section, and constituted misconduct connected with work under Section 51–1–7(B). The Meaning of â€Å"Misconduct† in New Mexico’s Unemployment Compensation Law. Given the remedial purpose of the Unemployment Compensation Law, New Mexico courts, like most jurisdictions, interpret the provisions of the law liberally, to provide sustenance to those who are unemployed through no fault of their own, and who are willing to work if given the opportunity. Wilson v. Employment Sec. Comm’n, 74 N. M. 3, 14, 389 P. 2d 855, 862–63 (1963); Parsons v. Employment Security Comm’n, 71 N. M. 405, 409, 379 P. 2d 57, 60 (1963). Like most states, New Mexico also provides that an employee who is determined to have been discharged for â€Å"misconduct† is ineligible for unemployment compensation benefits. 51–1–7(B). Two purposes are served by this statutory bar: first, it prevents the dissipation of funds for other workers; second, it denies benefits to those who bring about their own unemployment by conducting themselves with such callousness, and deliberate or wanton misbehavior that they have given up any reasonable expe ctation of receiving unemployment benefits. Given the remedial purpose of the statute, and the rule of statutory construction that its provisions are to be interpreted liberally, the statutory term â€Å"misconduct† should not be given too broad a definition. Accordingly, in adopting the majority definition of the term, this Court wrote in Mitchell v. Lovington Good Samaritan Center, Inc. , 89 N. M. 575, 577, 555 P. 2d 696, 698 (1976): â€Å"[M]isconduct† * * * is limited to conduct evincing such wilful or wanton disregard of an employer’s interests as is found in deliberate violations or disregard of standards of behavior which the employer has the right to expect of his employee, or in carelessness or negligence of such degree or recurrence as to manifest equal culpability * * *. M]ere inefficiency, unsatisfactory conduct, failure in good performance as the result of inability or incapacity, inadvertencies or ordinary negligence in isolated instances, or good faith errors in judgment or discretion are not to be deemed â€Å"misconduct† within the meaning of the statute. Where an employee has not acted with the requisite degree of â€Å"fault† under Mitchell, he or she has not sacrificed a reasonable expectati on in continued financial security such as may be afforded by accrued unemployment compensation benefits. It is therefore possible for an employee to have been properly discharged without having acted with such willful or wanton disregard for an employer’s interests as would justify denial of benefits. This Court recognized in Alonzo v. New Mexico Employment Security Department, 101 N. M. 770, 689 P. 2d 286 (1984), that even an act of willful disobedience which leads to termination will not always rise to the level of â€Å"misconduct† when the act is an isolated incident in an otherwise favorable employment history and the incident does not cause a significant disruption of the employer’s legitimate interests. Trujillo v. Employment Sec. Dep’t, 105 N. M. 467, 472, 734 P. 2d 245, 250 (Ct. App. 1987) (where employment contract gave employer the right to draft employees to work overtime in emergency situations significantly affecting the employer’s interests, it was â€Å"misconduct† for appellees to have refused to report for overtime work). Alonzo and Trujillo demonstrate that there are two components to the concept of misconduct sufficient to justify denial of benefits. One is the notion that the employee has acted with willful or wanton disregard for the employer’s interests; the other is that this act significantly infringed on legitimate employer expectations. *1320 *762 Totality of circumstances and the â€Å"last straw† doctrine. Often, the courts have been confronted with a series of minor infractions by the employee, where each incident showed a willful disregard of the employer’s interests, but no single incident was serious enough to justify denial of benefits. In su ch cases, courts have applied a â€Å"totality of circumstances† or â€Å"last straw† test to determine whether, taken together, this series of incidents constitutes misconduct sufficient to disqualify the claimant from receiving benefits. Mitchell v. Lovington Good Samaritan Center, Inc. 89 N. M. 575, 555 P. 2d 696 (1976). Rodman recognizes the â€Å"last straw† doctrine, but contends that the district court erred in applying the rule in this case because her infractions of February 15 were the result of acts of third parties over whom she had no physical or legal control. Appellant contends that she may not be denied unemployment benefits where the â€Å"last straw† which led to her termination was not willful or intentional, especially where, under the employer’s personnel policy, she could not have been discharged at all before this final incident. The Department contends that it is immaterial whether the precipitating act was a willful or intentional violation of the employer’s rules, where the record indicates that the claimant had a history of previous acts which demonstrate a willful or wanton disregard for the employer’s interests, and the employer discharged the employee for the accumulation of events, including the precipitating event. Fort Myers Pump & Supply v. Florida Dep’t of Labor, 373 So. 2d 429 (Fla. Dist. Ct. App. 1979). Although Fort Myers does offer support for the appellee’s position, we believe termination for a series of incidents which, taken together, may constitute â€Å"misconduct† is distinguishable from termination for a single incident following one or more corrective action notices. In the latter event, as here, we hold that the â€Å"last straw† must demonstrate a willful or wanton disregard for the employer’s interests for unemployment benefits to be denied. If substantial evidence existed that Rodman’s conduct on February 15, considered in light of the totality of ircumstances including her previous history of personal phone calls and unauthorized visitors, showed a willful or wanton disregard for her employer’s interests, then Rodman’s benefits were properly denied. Although the evidence in this case is amenable to more than one reasonable interpretation, we conclude that there was a substantial basis for the district court to decide t hat Rodman’s actions on February 15, when considered in light of the restrictions which had been placed upon her and her previous failure to comply with those restrictions, demonstrated a willful disregard for her employer’s interests. Therefore, the decision of the district court is affirmed. IT IS SO ORDERED. WALTERS, J. , concurs. STOWERS, J. , specially concurs. 769 P. 2d 88 Supreme Court of New Mexico. In re Claim of Lucy APODACA. IT’S BURGER TIME, INC. , Petitioner–Appellee, v. NEW MEXICO DEPARTMENT OF LABOR EMPLOYMENT SECURITY DEPARTMENT, BOARD OF REVIEW and Lucy Apodaca, Respondents–Appellants. No. 17952. Feb. 22, 1989. Employer filed writ of certiorari to challenge Employment Security Department’s award of unemployment compensation to fast-food restaurant employee who refused to retint her purple hair. The District Court, Dona Ana County, Lalo Garza, D. J. reversed award of benefits. Employee appealed. The Supreme Court, Ransom, J. , held that evidence supported Department’s award of benefits. Reversed and remanded. Attorneys and Law Firms **89 *176 Jose R. Coronado, Southern New Mexico Legal Services, Inc. , Las Cruces, Connie Reischman, New Mexico Dept. of Labor, Albuqu erque, for respondents-appellants. Kelly P. Albers, Lloyd O. Bates, Jr. , Las Cruces, for petitioner-appellee. OPINION RANSOM, Justice. A determination by the Board of Review of the New Mexico Employment Security Department awarding unemployment compensation to Lucy Apodaca was reversed by the district court on certiorari. Apodaca appeals the district court decision, arguing that the court erred in finding the administrative determination was unsupported by substantial evidence and was contrary to law. We conclude substantial evidence supports the Board of Review decision that the conduct leading to Apodaca’s termination did not constitute misconduct warranting denial of unemployment compensation under Section 51–1–7(B) of the Unemployment Compensation Law. Accordingly, we reverse the district court. Apodaca was employed as a counter helper from August 1986 to August 1987 with It’s Burger Time, Inc. Apodaca’s supervisors had no complaints concerning the performance of her work. Several times during the summer of 1987, Apodaca approached the store manager, John Pena, to ask how the owner, Kevin McGrath, would react if she were to dye her hair purple. Pena did not at first take the question seriously. When Apodaca persisted, Pena told her that he would have to ask McGrath. Apparently, he never did so. After several weeks, Apodaca went ahead and dyed her hair. McGrath saw Apodaca’s tinted hair for the first time at work two days later. He instructed Pena to give Apodaca a week to decide whether she wanted to retain her new hair color or her job. In a letter to the Board of Review, McGrath wrote that he had a good sense for community standards and believed he could not afford to wait until â€Å"this incident [took] it’s [sic] toll on my business. † Apodaca had signed the company handbook upon being hired, which instructed employees about acceptable hygiene and appearance. The handbook said nothing specific about hair color. Pena relayed McGrath’s message to Apodaca and suggested she make up her mind quickly so he could find someone to replace her if necessary. Two days later, Apodaca told Pena she had decided to keep her hair the way it was. She was then terminated and applied for unemployment benefits. The Department initially determined that Apodaca was ineligible for compensation because she had been terminated â€Å"for refusing to conform to the standards of personal grooming compatible with the * * * work [she was] performing. † The claims officer concluded this constituted misconduct under Section 51–1–7(B). Apodaca appealed to the Appeals Tribunal, which affirmed the denial of her benefits after a hearing. She appealed the Tribunal’s decision **90 *177 to the Department’s Board of Review. After reviewing the record of the hearing, the Board concluded that the employer failed to show how the color of Apodaca’s hair affected its business; therefore, her refusal to return her hair to its original color did not rise to the level of â€Å"misconduct† required for denial of her benefits. For review of the Board’s decision, the employer filed a writ of certiorari with the Dona Ana County District Court. The district court determined Burger Time’s request to Apodaca to change the color of her air was reasonable and enforceable and Apodaca’s refusal of that request was misconduct. The court concluded that the Board of Review’s decision was not supported by substantial evidence and was contrary to the law and reversed the decision granting Apodaca her benefits. This appeal followed. In reviewing the district court decision, we look first to see whether the court erred in concluding that the Department’s decision was unsupported by substantial evidence. Because we conclude that the court erred in this determination, it is unnecessary for us to examine the findings and conclusions adopted by the court. Misconduct and the employer’s interest. Both Apodaca and Burger Time agree that the definition of â€Å"misconduct† as used in Section 51–1–7(B) is to be found in this Court’s opinion in Mitchell v. Lovington Good Samaritan Center, Inc. , 89 N. M. 575, 577, 555 P. 2d 696, 698 (1976): â€Å"[M]isconduct† * * * is limited to conduct evincing such wilful or wanton disregard of an employer’s interests as is found in deliberate violations or disregard of standards of behavior which the employer has the right to expect of his employee, or in carelessness or negligence of such degree or recurrence as to manifest equal culpability. * * [M]ere inefficiency, unsatisfactory conduct, failure in good performance as the result of inability or incapacity, inadvertencies or ordinary negligence in isolated instances, or good faith errors in judgment or discretion are not to be deemed â€Å"misconduct† within the meaning of the statute. Apodaca d oes not deny that her refusal to redye her hair was an intentional and deliberate act. At issue in this case is whether an employee who refuses to alter her personal appearance in conformity with the employer’s personal beliefs about acceptable community standards has engaged in misconduct. The employer argues, and the district court apparently agreed, that so long as the request is reasonable and the employee is given adequate time to comply, refusal amounts to â€Å"insubordination and misconduct. † We disagree. In Alonzo v. New Mexico Employment Security Department, 101 N. M. 770, 772, 689 P. 2d 286, 288 (1984), we recognized that termination for an isolated incident which does not â€Å"significantly affect[ ] the employer’s business† may not form the basis for denial of benefits on the grounds of misconduct. In Alonzo, an employee was terminated after refusing to wear a smock when working at the cash register as required by company policy. Id. at 771, 689 P. 2d at 287. As here, the employee’s previous work history was completely satisfactory, and there was no evidence that the employer’s business interests had been affected. Alonzo should be compared with Trujillo v. Employment Security Department, 105 N. M. 467, 471–72, 734 P. 2d 245, 249–50 (Ct. App. 987), which held that failure to report for overtime work pursuant to an employment contract provision allowing the employer to draft employees in emergency situations constituted misconduct, when the evidence demonstrated that the orders directing employees to report early to work were explicit and not confusing. In Trujillo, unlike Alonzo, failure to comply with the employer’s request was recognized as having significantly affected the employer’s interest. See also Thornton v. Dep’t of Hum an Resources Dev. , 32 Cal. App. 3d 180, 107 Cal. Rptr. 92 (1973) (refusal of restaurant employee to shave beard immediately or be terminated was not misconduct when employer failed to show that beard was unsanitary or otherwise detrimental to business); cf. Lattanzio v. Unemployment Comp. Bd. of Rev. , 461 Pa. 392, 336 A. 2d 595 (1975) (claimant’s refusal to report back to work was for good cause when employer demanded he shave beard but no evidence supported contention that requested alteration in appearance was essential to performance of duties other than employer’s vague assertion that claimant’s â€Å"modish† appearance might reflect unfavorably on business). In this case, there is absolutely no evidence that the color of Apodaca’s hair significantly affected Burger Time’s business. McGrath and Pena both testified they received no customer complaints regarding the color of Apodaca’s hair. Apodaca’s immediate supervisor, testifying in her behalf, reported that the only comments she heard were compliments and that Burger Time’s customers had readily registered complaints in the past when they found something amiss. Under these circumstances, the Board of Review could properly decide that Apodaca’s refusal to retint her hair did not rise to the level of misconduct. Burger Time argues that none of our previous cases require an employer to demonstrate its business was affected by an employee’s refusal to comply with a request from the employer. However, it is well established in New Mexico that the party seeking to establish the existence of a fact bears the burden of proof. See Newcum v. Lawson, 101 N. M. 48, 684 P. 2d 534 (Ct. App. 1984); Carter v. Burn Constr. Co. , 85 N. M. 27, 508 P. 2d 1324 (Ct. App. ), cert. denied, 85 N. M. 5, 508 P. 2d 1302 (1973); Wallace v. Wanek, 81 N. M. 478, 468 P. 2d 879 (Ct. App. 1970); cf. Moya v. Employment Sec. Comm’n, 80 N. M. 39, 450 P. 2d 925 (1969) (when claimant sought to establish that he ought not be disqualified from receiving benefits because the position for which he refused to interview was not suitable employment, he bore burden of proof on this issue). In this case, pursuant to Department regulations requiring an employer to report why a claimant was fired or have that claimant’s benefits charged against the employer’s account, Burger Time submitted a letter stating that Apodaca refused to comply with company grooming standards. At each subsequent stage of the administrative process and before the district court, Burger Time sought to establish that Apodaca was terminated for misconduct. It therefore fell upon Burger Time to show that Apodaca’s refusal to change the color of her hair amounted to misconduct under the standard considered in Alonzo and Trujillo. This, Burger Time failed to do and thus failed to meet its burden of proof. Moreover, Apodaca presented uncontroverted testimony that no customers complained, and some complimented her for her hair. We do not question Burger Time’s right to establish a grooming code for its employees, to revise its rules in **92 *179 response to unanticipated situations, and to make its hiring and firing decisions in conformity with this policy. However, as we noted in Rodman, â€Å"It is * * * possible for an employee to have been properly discharged without having acted [in a manner] as would justify denial of benefits. † 107 N. M. at 761, 764 P. 2d at 1319. 2 Definition of misconduct and the right to terminate. Although not directly presented on appeal in this case, we note that in their decision letters both the Appeals Tribunal and the Board of Review used the following definition: â€Å"The term ‘misconduct’ connotes a material breach of the contract of employment or conduct reflecting a willful disregard of the employer’s best interests. (Emphasis added. ) We rejected this definition in Rodman, 107 N. M. at 763, 764 P. 2d at 1321, as inconsistent with the Mitchell standard requiring a willful or wanton disregard of the employer’s interests. The use of the term â€Å"or† implies that any breach of the employment contract sufficient to warrant discharge of the employee serves as adequate grounds for denial of benefits, whether or not the employee acted in a willful or wanton manner. Where an employee has not acted with the requisite degree of ‘fault’ under Mitchell, he or she has not sacrificed a reasonable expectation in continued financial security such as may be afforded by accrued unemployment compensation benefits. † Id. at 761, 764 P. 2d at 1319. The decision of the trial court is reversed, and this case is remanded for entry of judgment consistent with the decision of the Board of Review. IT IS SO ORDERED.

Chemical Medications or Natural Healing Essay Example

Chemical Medications or Natural Healing Essay Example Chemical Medications or Natural Healing Essay Chemical Medications or Natural Healing Essay Many times when people get sick they go to the doctor to be diagnosed, then they make their way to the pharmacy to pick up the prescriptions the doctors say you need to cure the problem. What if the prescription is wrong? But is there a better solution? Natural healing is much better than any chemical medication the doctor prescribes to you because they are natural and more effective. Many prescriptions are easy to overdose on, and usually end in death or serious health problems. â€Å"Overdosing on NSAIDs also can damage kidneys† says transplant pharmacist McDevitt, a clinical specialist in organ transplantation at Tufts Medical Center. Prescriptions aren’t the only drug that people can overdose on. It is very common for people to overdose on over-the-counter drugs such as Tylenol, Aleve, and ibuprofen. â€Å"People play loose and free with Benadryl,† says Ausim Azizi, chair of the department of neurology at Temple University School of Medicine. â€Å"There are a lot of side effects. One is loss of memory in the imediant period after taking it, and disorientation in older people. † Experts are trying to get the manufacturers to make it harder for people to overdose, but what if they got rid of all the chemical ingredients and replaced them with natural herbs and plants? Without the chemicals made in medications, then people wouldn’t have to worry about overdosing and cause damage to their body. Chemical medications have very serious side effects that can cause death in extreme cases. Many people just ignore these serious effects because they think they have no other choice. Chemical medicines do work, but natural medications work better and longer. â€Å"The best thing is to find the best medicine that will be fast and effective. And in the health market out there, there are tons of medicines that will promise to do that, yet at the same time, the small print tells us to beware of the side effects. This little warning is one that we often ignore. Yet at the same time it is important to acknowledge its existence so that we do not end up making ourselves sicker. Natural health medicine has the benefits in that it is one of the few medicines that have little or no side effects. The only side effect that it might have is if you are allergic to a certain ingredient and you didn’t know it. † [Crosshealth, Emmanuel Aubrey] Approximately 25% of the prescription drugs sold in the United States are plant based. These medications are better for the body but not as good as the all natural medicine. When the chemicals are added to the pills, they cancel out the healing powers of the plant. Natural medications actually heal the sickness and infection, instead of just covering up the symptoms. Chemical medications are made to cover up the symptoms so people can go on with their days without having to suffer with misery of the illness. â€Å"Conventional medicine focuses on symptoms and uses ‘drugs’ (man made synthetics) to ‘suppress,’ (NOT heal) those symptoms. Natural health and alternative medicine focuses on the ‘causes’ and getting to the ‘root cause,’ which always improves your overall health. This is the right way of curing health problems, instead of just ‘masking’ it. † [Jonathan Benson] Natural healing does take longer than the quick chemicals, but they heal thoroughly and have a no chance of making someone sicker or killing. Doctors say that natural cures are dangerous and a misuse of public money. They call it encouraged quackery. Professor Marcello Costa of Flinders University said: â€Å"It is disturbing to see a centre of learning†¦ perpetuating health practices based on beliefs in principles that are totally unscientific. † Doctors are wrong about natural healing not being proven scientifically. The NCCAM (National Center of Complementary and Alternative Medicine) has proven and backed up many alternative treatments such as chiropractic and acupuncture practices. Natural healing should be the first thing given to a patient when they have been diagnosed by a doctor. Chemical medications have been known to be overdosed on, to have caused serious side effects, and have been known to not heal the problem but to just simply cover up the symptoms that let a person know something is wrong.