Saturday, June 13, 2020
Anti-Perverse Incentives: Understanding military detention motives in light of the War on Terror and establishing a workable review process I. Introduction The Fifth Amendment to the United States Constitution provides that no citizen may be detained by the government without due process of law.[footnoteRef:1] The liberty interest represented in that amendment is specifically protected through habeas corpus, the ability of federal courts to review detentions for due process and grant further review of base-less detentions. Article 1, Section 9 of the Constitution provides that Ã¢â¬Å"[t]he privilege of the writ of habeas corpus shall not be suspended, unless when in cases of rebellion or invasion the public safety may require it.Ã¢â¬ [footnoteRef:2] The Supreme Court and the legislature have enshrined significant protections of this right, particularly in the instance of criminal detentions. [1: U.S. Const. amend. V. ] [2: U.S. Const. art. I Ã § 9, cl. 2. ] The advent of the War on Terror and the resulting conflict in the Middle East have evoked significant challenges for habeas petitions, particularly the level of review that Article III courts can and should exercise over the militaryÃ¢â¬â¢s detention of those suspected of being or known to be terrorists. In 2017, the American military detained an American citizen, known as John Doe in court documents, in Iraq. The military detained Doe because he supported the Islamic State in committing war crimes against the United States in Syria. Doe remained in Iraq under military detention for over a year before filing a petition for habeas corpus in federal court in the United States. He contended that his detention was illegal and that he was entitled to habeas review in a federal court. Although the Doe v. Mattis case has ultimately resolved, in an anti-climactic fashion, the litigation illustrates significant questions about executive detention, the scope of habeas review, military power, and national security. Viewed against the light of both the Guantanamo Bay litigation and the national security interests of the United States military, these developments are pressing and must be resolved. In Boumediene and its progeny, the Supreme Court enunciated a list of factors that courts should consider when analyzing whether there is adequate review of any particular executive detention. These factors are intended to clearly secure the rights of individuals against the governmentÃ¢â¬â¢s power to detain them, while recognizing that the government must also act in the interest of the nation and detain those who threaten that interest. Those factors are intended to prevent situations like the one that Japanese-American citizens experienced in the aftermath of Pearl HarborÃ ¢â¬âindividuals must have a right to vindicate their liberty rights against unjustified executive detentions. Generally, the Boumediene factors function well to analyze and prevent unjustified executive detentions. However, the factors do not account for the incentives that drive the military to detain and question individuals solely in a military context. Further, the factors as applied in a military context create a worse situation than that they seek to remedyÃ¢â¬âthe military must accomplish its purpose and applying the Boumediene factors to its detention of terrorists merely causes the military to utilize other, less reviewable methods in order to secure mission success. The Supreme Court and lower federal courts should take the factors that underly military detentions into account when analyzing whether habeas review is appropriate for those detained as enemy combatants. Rather than using a blunt instrument to balance the governmentÃ¢â¬â¢s interest in national security against the citizensÃ¢â¬â¢ liberty interests, the Court should take full account of both interests and accurately consider the incentives at play in the context of military detention. Ultimately, where the Court allows the military to detain individuals at fault for crimes against the United States, those individuals can be tried without article III courts but with adequate due processÃ¢â¬ânamely through the military court martial process. II. The Lay of the Land: Boumediene The Boumediene decision provides a number of factors that courts may employ to analyze the necessity of habeas review over executive detentions. Before the court reached the merits question, however, it rightfully analyzed the historical background surrounding the writ of habeas corpus in order to put these factors into context. As Justice Kennedy wrote in the Boumediene majority, Ã¢â¬Å"The Framers viewed freedom from unlawful restraint as a fundamental precept of liberty, and they understood the writ of habeas corpus as a vital instrument to secure that freedom.Ã¢â¬ [footnoteRef:3] However, even the modern Court does not agree on exactly what the historical writ of habeas corpus entailed. Justices Kennedy, Scalia, and Roberts each provided a differing historical analysis within their respective opinions, and each provides part of the background necessary to understand the modern landscape of habeas doctrine. [3: Boumediene v. Bush, 553 U.S. 723, 739 (2008).] a. Dueling Accounts: Historical Basis of habeas corpus i. Justice Kennedy Justice KennedyÃ¢â¬â¢s majority opinion in Boumediene characterized the historical analysis surrounding habeas review as asking whether an individual is barred from seeking review.[footnoteRef:4] In his opinion, Justice Kennedy ultimately concluded that the Boumediene petitioners were entitled to habeas review because neither their status nor their physical location in Guantanamo Bay prevented habeas review in the historical context of that writ.[footnoteRef:5] In support of this conclusion, Justice Kennedy cited sources ranging from Magna Carta through the Eisentrager decision arising from the AlliesÃ¢â¬â¢ post-World War II detentions in Germany.[footnoteRef:6] [4: Id. at 739, 746-47, 752. ] [5: Id. at 752. ] [6: Id. at 739-64. ] First, Justice Kennedy analyzed the historical basis of habeas as embodied in Magna Carta.[footnoteRef:7] The English princes involved in Magna CartaÃ¢â¬â¢s drafting chose to include within that document the same fundamental protection that the Due Process Clause of the Fifth Amendment codified in the United States: no Englishman could be imprisoned contrary to the law of the land.[footnoteRef:8] Magna Carta did not, however, include an enforcement mechanism to vindicate this right against abuse.[footnoteRef:9] Ultimately, English citizens and the English crown turned to the writ of habeas corpus as this necessary mechanism.[footnoteRef:10] The English courts, acting as instruments of the Crown, could issue the writ to probe the authority of any jailer to hold a citizen prisoner, ensuring a form of due process protections: the right of the sovereign to review its agentsÃ¢â¬â¢ actions whenever they impair a citizenÃ¢â¬â¢s fundamental liberty interest.[footnoteRef:11] [7: Id. at 739. ] [8: Art. 39, in Sources of Our Liberties 17 (R. Perry J. Cooper, eds. 1959).] [9: Boumediene, 553 U.S. at 739. ] [10: Id. ] [11: Id. at 741, citing 2 J. Story, Commentaries on the Constitution of the United States Ã § 1341, 237 (3d. ed. 1858). ] One example of this philosophy that Justice Kennedy analyzes is DarnelÃ¢â¬â¢s Case, which concerned citizens who were imprisoned for refusing to lend money to the crown.[footnoteRef:12] The writ was denied in that case, as the King merely issued a warrant in response to the petition, but the English Parliament ultimately secured the petition for habeas corpus through procedures codified in the Habeas Corpus Act of 1679.[footnoteRef:13] The American Colonies ultimately based their habeas statutes on this Act.[footnoteRef:14] Kennedy concluded Ã¢â¬Å"that the Framers considered the writ a vital instrument for the protection of individual libertyÃ¢â¬ and as such took immense care in prevention the Executive branch from suspending the writ at will.[footnoteRef:15] [12: DarnelÃ¢â¬â¢s Case, 3 How. St. Tr. 1 (K. B. 1627).] [13: Habeas Corpus Act of 1679, 31 Car. 2, ch. 2, Statutes of the Realm, at 935.] [14: See Rex A. Collings, Jr., Habeas Corpus for ConvictsÃ¢â¬âConstitutional R ight or Legislative Grace, 40 Cal. L. Rev. 335, 338-39 (1952).] [15: Boumediene, 553 U.S. at 743.] The historical records surrounding the Suspension Clause support this conclusion to some extent, referring to the writ as a method of ensuring limited government and embodying checks and balances.[footnoteRef:16] The Suspension Clause assumes that Americans are entitled to judicial review of any detention in order to prevent abuses of executive power.[footnoteRef:17] However Kennedy goes a step further, extending that right to judicial review to aliens as well as American citizens, citing common law precedent in SomersettÃ¢â¬â¢s Case,[footnoteRef:18] King v. Schiever,[footnoteRef:19] and the Case of Three Spanish Sailors.[footnoteRef:20] Ultimately Kennedy depended on these precedents and others[footnoteRef:21] to shape his understanding that the fundamental question in modern habeas litigation is whether or not review is precluded by some attribute of the particular detentionÃ¢â¬ânamely the detaineeÃ¢â¬â¢s status or the location of detention.[footnoteRef:22] [16: See 3 Debate s in the Several State Conventions on the Adoption of the Federal Constitution 460-64 (J. Elliot 2d ed. 1876); The Federalist No. 84. ] [17: See U.S. Const., art. I, Ã § 9, cl. 2. ] [18: 20 How. St. Tr. 1, 80-82 (1772) (granting habeas to an African slave).] [19: 2 Burr. 765, 97 Eng. Rep. 551 (K. B. 1759) (denying habeas to prisoners of war). ] [20: 2 Black. W. 1324, 96 Eng. Rep. 775 (C. P. 1779) (denying habeas to prisoners of war).] [21: See, e.g., De Lima v. Bidwell, 182 U.S. 1 (1904); Dooley v. United States, 182 U.S. 222 (1901); Downes v. Bidwell, 182 U.S. 244 (1901). ] [22: Boumediene, 553 U.S. at 748. ] ii. Justice Scalia Justice Scalia, in stark contrast to Justice Kennedy, focused his dissenting opinion on whether the petitioners were entitled to habeas review at all.[footnoteRef:23] Justice Scalia emphasized and reiterated the CourtÃ¢â¬â¢s reasoning in Johnson v. Eisentrager, where Justice Jackson wrote that there had been Ã¢â¬Å"no instance where a court Ã¢â¬ ¦ has issued [the writ of habeas corpus] on behalf of an alien enemy who, at no relevant time and in no stage of his captivity, has been within its territorial jurisdiction. Nothing in the text of the Constitution extends such a right.Ã¢â¬ [footnoteRef:24] [23: Id. at 827-50 (Scalia, J., dissenting). ] [24: Johnson v. Eisentrager, 339 U.S. 763, 770-71 (1950).] Justice Scalia first turned to an in-depth analysis of Eisentrager.[footnoteRef:25] The petitioners in Eisentrager were Germans who had originally been detained in China and ultimately transferred to an American base in Germany to finish out their terms of detention.[footnoteRef:26] The Court there held that the German soldiers did not have a right to habeas review because they were not American citizens, they had not entered the United StatesÃ¢â¬â¢ sovereign territory at any relevant time, and they were not being held in the United States.[footnoteRef:27] [25: Boumediene, 553 U.S. at 836-43.] [26: Eisentrager, 339 U.S. at 777. ] [27: Id.] Similarly, Scalia looked to EisentragerÃ¢â¬â¢s sister decision in Reid v. Covert, which concerned an American civilian who murdered her husband in England.[footnoteRef:28] There, the Court affirmed that American citizens do have constitutional habeas protections while detained abroadÃ¢â¬âthey cannot be tried and convicted by military court martial under ordinary circumstancesÃ¢â¬âbut as Justice Scalia noted in his Boumediene dissent, the Court limited its reasoning to the fact that Ms. Reid was an American citizen.[footnoteRef:29] Nowhere in the Reid or Eisentrager decisions was, at least in Justice ScaliaÃ¢â¬â¢s reading, any indication that habeas review extended to non-citizen alien combatants like the detainees were in Boumediene. [28: Reid v. Covert, 354 U.S. 1, 13 (1957). ] [29: Id. at 5-6 (plurality opinion). ] Justice Scalia read these decisions and their historical context to frame the question of modern habeas litigation as whether the petitioner was entitled to habeas review at all.[footnoteRef:30] He further examined the sources that Justice Kennedy cited, finding no support for the idea that non-citizens detained outside of a nationÃ¢â¬â¢s sovereign territory were entitled to habeas review.[footnoteRef:31] This starkly contrasts with Justice KennedyÃ¢â¬â¢s historical analysis, which defined the fundamental inquiry of habeas litigation as whether the pre-existent right to habeas was precludedÃ¢â¬âgranting as a preliminary matter that such review was available, even to aliens.[footnoteRef:32] Justice Scalia fiercely disagreed with Justice KennedyÃ¢â¬â¢s analysis, writing in his dissent: [30: Boumediene, 553 U.S. at 836-43 (Scalia, J., dissenting).] [31: Id. at 847-48.] [32: See id. at 836-43. ] There is simply no support for the CourtÃ¢â¬â¢s assertion that constitutional rights extend to aliens held outside U.S. sovereign territory, and Eisentrager could not be clearer that the privilege of habeas corpus does not extend to aliens abroad. . . . the Nation will live to regret what the Court has done today.[footnoteRef:33] [33: Id. at 841, 850.] These historical analyses, though drastically different, paved the way for Justice Kennedy to enshrine the functional test that he laid out in BoumedieneÃ¢â¬â¢s majority opinion: habeas review is available to aliens, even those held outside of U.S. sovereign territory, where certain conditions are met as weighed by the district court.[footnoteRef:34] [34: Boumediene v. Bush, 553 U.S. 723, 729 (2008).] b. Factors in granting habeas review i. Citizenship and Status Ã¢â¬â Doe v. Mattis The Boumediene decision first focused on the citizenship and status of the detainee.[footnoteRef:35] Where the detainee is a United States citizen, habeas review must be available, absent a valid suspension.[footnoteRef:36] Where the detainee is not a citizen, however, the line becomes more blurred.[footnoteRef:37] The inquiry then depends on the detaineeÃ¢â¬â¢s status as an enemy combatant, and the process afforded them while that their captors determine that status.[footnoteRef:38] The questions elicited by Eisentrager and Reid came to prominence again in the past year, when the D.C. Circuit considered the case of John Doe, a dual Saudi-American citizen held in Iraq for committing war crimes against the United States.[footnoteRef:39] DoeÃ¢â¬â¢s detention posed complicated habeas questions, particularly once the military attempted to transfer Doe to the custody of another nation or release him in Syria where he was originally detained. [footnoteRef:40] Ultimately, pointing to th e fact that Doe was ultimately a U.S. citizen, the courts involved found that he was entitled to habeas review of some sort, and that habeas protections (such as required notice before transfer to another sovereign) applied.[footnoteRef:41] Where the detainee is not a citizen, however, the inquiry must turn on the individualÃ¢â¬â¢s status as an enemy combatant and the process by which the government made that determination.[footnoteRef:42] [35: Id. at 766. ] [36: See Reid v. Covert, 354 U.S. at 10-12.] [37: See Eisentrager, 339 U.S. 763 (1950). Some scholars argue that the Court should adopt a presumption against extraterritorial application of the Constitution to avoid this blurred line. See John H. Knox, A Presumption Against Extrajurisdictionality, 104 Am. J. IntÃ¢â¬â¢l L. 351 (2010). ] [38: Boumediene, 553 U.S. at 766-67. ] [39: ACLU v. Mattis, 286 F. Supp. 3d 53, 54 (D.D.C. 2017). ] [40: Ernesto Hernandez-Lopez, 71 Okla. L. Rev. ___, (2019) (manuscript at 8) (forthcoming). ] [41: See Doe v. Mattis, 889 F.3d 745 (D.C. Cir. 2018); Doe v. Mattis, 288 F. Supp. 3d 195 (D.D.C. 2018). ] [42: See Eisentrager, 339 U.S. at 777; Shawn E. Fields, From Guantanamo to Syria: The Extraterritorial Constitution in the Age of Extreme Vetting, 39 Cardozo L. Rev. 1123, 1175-76 (2018). ] ii. Nature of detention and apprehension sites Ã¢â¬â Boumediene, Eisentrager, Al-Maqaleh Second, the decision discussed the nature and location of the sites of apprehension and detentionÃ¢â¬âwhere was the individual detained, and were they held on a military installation or in a prison such as Guantanamo Bay, etc.[footnoteRef:43] This factor has been applied in cases ranging from Eisentrager, which denied habeas review because of the detention site being outside of United StatesÃ¢â¬â¢ control to Boumediene itself which found that Guantanamo was sufficiently close to within the sovereign control to merit habeas protections.[footnoteRef:44] The application of this factor was less clear, however, in the Al-Maqaleh case, where the detention site was somewhat less permanent than Guantanamo Bay as considered in Boumediene but somewhat more permanent than Landsberg Prison as contemplated in Eisentrager.[footnoteRef:45] [43: Id. ] [44: Eisentrager, 339 U.S. at 766; Boumediene, 553 U.S. at 768. ] [45: Al-Maqaleh v. Gates, 899 F. Supp. 2d 10 (D.C. Cir. 2012). ] In Al-Maqaleh, the D.C. Circuit considered the instance of detainees at Bagram Air Force Base in Afghanistan.[footnoteRef:46] These detainees were held for crimes committed in the context of the conflict in Afghanistan, and were held in anticipation of intended trials in Afghanistan by Afghan authorities.[footnoteRef:47] The court found some similarities between Bagram and Guantanamo Bay in that there was no distinct term of occupation at the Afghan base, after which the United States would withdraw from the base.[footnoteRef:48] However, the court ultimately found that Bagram was not equivalent to Guantanamo based on the fact that the military did not intend to establish a permanent military base in that location, and that the military held the detainees in question with the ultimate intent to transfer them to the Afghan authorities.[footnoteRef:49] This reasoning illustrates the importance of the site of detention, but also the intent behind that detention, to the exercise of habea s jurisdiction. [46: Id.] [47: Id. ] [48: Id. at 16-18. ] [49: Id. ] iii. Practical obstacles Ã¢â¬â Al-Maqaleh Finally, the decision discussed the practical challenges inherent in habeas review of the prisonerÃ¢â¬â¢s habeas claim.[footnoteRef:50] By including these practical challenges in the calculus, the Court recognized that there are inherently difficult and complicated motivations that underly the militaryÃ¢â¬â¢s decision to detain an individual as a result of involvement with terrorist organizations.[footnoteRef:51] This factor is where Justice ScaliaÃ¢â¬â¢s scathing dissent puts most of its weight: the intangible factors that face the military when detaining an individual, determining their status, and ultimately holding them or prosecuting them cannot be understated.[footnoteRef:52] [50: Id. ] [51: See id., see also Al-Maqaleh v. Gates, 605 F. Supp. 2d 84, 98 (D.C. Cir. 2010). ] [52: See Boumediene, 553 U.S. at 849-50 (Scalia, J., dissenting). ] In Boumediene, the Court articulated the practical obstacles with relative clarity, and rejected them.[footnoteRef:53] The de jure sovereignty that the United States enjoys at Guantanamo Bay belied claims that habeas jurisdiction would threaten the militaryÃ¢â¬â¢s fundamental mission there.[footnoteRef:54] The practical obstacles at play in Al-Maqaleh were more complex and weighed in favor of the government.[footnoteRef:55] As the D.C. Circuit wrote in its opinion: [53: Id. at 769-71 (majority opinion). ] [54: Id.] [55: Al-Maqaleh, 605 F. Supp. at 97-99. ] [T]he third factor, that is the practical obstacles inherent in resolving the prisoners entitlement to the writ, particularly when considered along with the second factor, weighs overwhelmingly in favor of the position of the United States. It is undisputed that Bagram, indeed the entire nation of Afghanistan, remains a theater of war. Not only does this suggest that the detention at Bagram is more like the detention at Landsberg than Guantanamo, the position of the United States is even stronger in this case than it was in Eisentrager.[footnoteRef:56] [56: Id.] The Bagram detainees are more similar to the majority of modern detainees than the detainees at issue in Boumediene. Due to the failure of Guantanamo Bay, most detainees are no longer held there.[footnoteRef:57] Although this may not be because the government wishes to avoid habeas jurisdiction and merely because the military has adapted to a modern theater of war, it is worth noting the problems that habeas review poses for military interests.[footnoteRef:58] As the Al-Maqaleh court emphasized, the fact that these individuals were detained in an active theater of war meant that trying them and extending habeas jurisdiction over their detentions would severely hamper the ability of the military to accomplish its core mission effectively.[footnoteRef:59] Although no decision can lay out an exhaustive list of the practical considerations that could hamper military operations if habeas jurisdiction were extended, the Boumediene, Eisentrager, and Al-Maqaleh decisions do emphasize the bur den that habeas jurisdiction would put on military operations in extra-territorial contexts. [57: Human Rights First, Facts About the Transfer of Guantanamo Detainees, (Oct. 10, 2018), https://www.humanrightsfirst.org/resource/facts-about-transfer-guantanamo-detainees. See also Al-Maqaleh, 605 F. Supp. at 98-99. ] [58: See Al-Maqaleh, 605 F. Supp. at 98-99.] [59: Id.] III. Uphill Both Ways: The Failures of Boumediene The practical considerations prong of Boumediene is vitally important when considering the instances of military detentions resulting from the War on Terror. The Boumediene decision, and Justice KennedyÃ¢â¬â¢s presumption that detainees enjoy a right to habeas review unless something precludes the exercise of that review, create significant perverse incentives for the military to attempt to avoid habeas jurisdiction in order to effectively protect and defend the United States and her national security.[footnoteRef:60] These incentives manifest in a number of methods that the military can use to effectively detain those who threaten the security of the United States without the heavy burden of proving the adequacy of the basis for that detention to an Article III court. [60: See Satvinder S. Juss, Human Rights and AmericaÃ¢â¬â¢s War on Terror ch. 8 (2018).] a. Doe v. Mattis Ã¢â¬â Transfer One such incentive is illustrated through the Doe v. Mattis saga: the United States could transfer detainees to other sovereigns.[footnoteRef:61] The military ultimately transferred John Doe to Bahrain and cancelled his American passport.[footnoteRef:62] Although the litigation did produce some consequential rulings, such as that regarding the notice required before transferring an American citizen detainee, it is fundamentally useful to illustrate the post-Boumediene incentive to transfer detainees to the custody of other nations. Doing so effectively circumvents the possible habeas jurisdiction required under Boumediene, but still provides some effect to the militaryÃ¢â¬â¢s national security purpose of incapacitating the individuals it detains. [61: See Robert Chesney, Doe v. Mattis Ends With a Transfer and a Cancelled Passport: Lessons Learned, Lawfare (Oct. 29, 2018) https://www.lawfareblog.com/doe-v-mattis-ends-transfer-and-cancelled-passport-lessons-learned. ] [62: Id.] However, this practice will ultimately make it even more difficult for detainees to challenge their detentions at all.[footnoteRef:63] As Daniel Meltzer emphasized in the Supreme Court Review, the geographic element in the Boumediene decision creates: [63: Daniel J. Meltzer, Habeas Corpus, Suspension, and GuantÃ ¡namo: The Boumediene Decision, 2008 Sup. Ct. Rev. 1, 33, n. 137.] [I]ncentives for officials to hold detainees in some places and not others in order to avoid the risk of judicial review. If aliens Ã¢â¬Å"trulyÃ¢â¬ abroad are outside habeas jurisdiction, military officials may hesitate to bring them from foreign countries to Guantanamo or the United States, where the conditions of confinement might be more secure or humane but where habeas jurisdiction would attach. The only way to avoid some kind of perverse incentive is to establish a fully worldwide jurisdiction, and even that would not eliminate incentives to escape judicial reviewÃ¢â¬âfor the United States could still engage in extraordinary rendition, for example, so that detainees are no longer in American custody. We know that the government already has engaged in such actions, sometimes with horrifying results. There is, in short, no simple solution to the incentives problem.[footnoteRef:64] [64: Id.] In a similar vein, though much less well documented, the Boumediene factors create an incentive to have any other country besides the United States detain individuals, though the United States military would retain access to those individuals for questioning. More frightening still is the incentive that some have identified to kill suspected terrorists rather than detaining them after Boumediene.[footnoteRef:65] [65: Nathaniel H. Nesbitt, Meeting BoumedieneÃ¢â¬â¢s Challenge: The Emergence of an Effective Habeas Jurisprudence and Obsolescence of New Detention Legislation, 95 Minn. L. Rev. 244, 275, n.177 (2010) (Ã¢â¬Å"Indeed, mandating that all suspected terrorists face trial in federal court would undercut the governmentÃ¢â¬â¢s incentives to pursue legal remedies and would create perverse incentives, including making more attractive the option of killing suspected terrorists rather than risk a loss in federal court. E.g., Capture or Kill? Lawyers Eye Options For Terrorists (NPR radio broadcast Oct. 8, 2009), available at https://www.npr.org/templates/story/story.php?storyId=113612058 (Ã¢â¬Å"Many national security experts interviewed for this story agree that it has become so hard for the U.S. to detain people that in many instances, the U.S. government is killing them instead.Ã¢â¬ )Ã¢â¬ ). ] b. Practical Challenges Ã¢â¬â unable to detain and try properly The second major category of incentives and problems with Boumediene is that federal courts are relatively inept in their ability to try those accused of terrorism.[footnoteRef:66] The evidentiary and jurisdictional burdens alone in federal court pose significant obstacles to an effective prosecution of terrorists in Article III courts while still protecting fundamental government interests.[footnoteRef:67] Evidentiary issues including double and triple hearsay pose significant challenges to effectively proving criminal cases against detainees.[footnoteRef:68] As the District Court noted in Ahmed v. Obama, [66: Id.] [67: See id. See also, e.g. Bostan v. Obama, 662 F. Supp. 2d 1, 5 (D.D.C. 2009); Ahmed v. Obama, 613 F. Supp. 2d 51, 56 (D.D.C. 2009). ] [68: Id. ] Ã¢â¬Å"The kind and amount of evidence which satisfies the intelligence community . . . certainly cannot govern the CourtÃ¢â¬â¢s ruling.Ã¢â¬ [footnoteRef:69] [69: 613 F. Supp. 2d 51, 56 (D.D.C. 2009). ] IV. The Path Less Taken: Courts Martial as alternatives to habeas review The decision in Boumediene, the resulting cases, the factors that they illustrate, and the perverse incentives they create all lend support to the conclusion that some review of military detentions is important. As the Court rightly noted in Boumediene, separation of powers must be considered where any one branch may be able to exercise ultimate power and avoid scrutiny by other branches.[footnoteRef:70] Ultimately, the military is not a prison agencyÃ¢â¬âtheir purpose is to defend the United States from attackÃ¢â¬âand there should be some method for reviewing the militaryÃ¢â¬â¢s decision to detain an individual and deprive them of their fundamental liberty. It does not follow, however, that the best avenue for that review is to open Article III courts to those that the military chooses to detain in connection with its national security mission. Justice Scalia emphasized this in his dissent in Boumediene, writing: [70: Boumediene, 553 U.S. at 743.] Today the Court warps our Constitution in a way that goes beyond the narrow issue of the reach of the Suspension Clause . . . It sets our military commanders the impossible task of proving to a civilian court, under whatever standards this Court devises in the future, that evidence supports the confinement of each and every enemy prisoner.[footnoteRef:71] [71: Id. at 849-50 (Scalia, J., dissenting). ] The cases discussed above illustrate the fundamental challenges that face the military when detaining, and ultimately prosecuting, those detained in the context of the War on Terror in particular. Rather than opening Article III courts to these detainees through habeas review, the Supreme Court would be better suited to direct the vindication of these liberty interests through the military justice system, which affords many of the benefits of Article III courts and habeas review, but which is more adaptable to the unique challenges of prosecuting those suspected of terrorist acts and those detained by the military. Courts martial can remedy the jurisdictional, evidentiary, and practical challenges of reviewing the militaryÃ¢â¬â¢s detention of suspected terrorists, such as John Doe, without compromising the governmentÃ¢â¬â¢s fundamental interests. a. Jurisdiction of Courts Martial As discussed above, the right of habeas corpus as originally codified did not clearly apply to detentions that took place outside of the territory of the United States.[footnoteRef:72] The factors that Boumediene enunciated apply to detainees extraterritorially, but the functional approach that Boumediene enunciates emphasizes that the military must still have some reason for making those detentions.[footnoteRef:73] In the case of Doe v. Mattis, and other cases arising from the War on Terror, the basis for these detentions is the Authorization for the Use of Military Force, passed by Congress after the attacks on September 11, 2001.[footnoteRef:74] This act permits the President to take military action against all responsible for the attacks on September 11 and any associated forces.[footnoteRef:75] It also supports the jurisdictional foundation for military detention. The Court in Hamdi v. Rumsfeld held that Ã¢â¬Å"enemy combatantsÃ¢â¬ who were involved in military attacks agains t the United States (in that case specifically in Afghanistan) could be detained under the AUMF.[footnoteRef:76] Detaining these individuals, the Court reasoned, was fundamentally incident to the act of waging war, and that Congress had specifically authorized the President to make such detentions as part of that war effort.[footnoteRef:77] The Court extended this reasoning on the same day as the Hamdi decision in Rasul v. Bush, holding that detainees must have some method of challenging their detentions.[footnoteRef:78] In Boumediene v. Bush, the Court elaborated on these precedents and established a number of factors that measure whether someone has adequate opportunity to challenge their detention.[footnoteRef:79] [72: See Johnson v. Eisentrager, 339 U.S. 763 (1950) (discussing the case of German individuals detained in China and eventually transferred to an American air base in Germany). ] [73: See Boumediene v. Bush, 553 U.S. 723 (2008).] [74: See Authorization for the Use of M ilitary Force (AUMF), Pub. L. No. 107-40, 115 Stat. 224 (2001) (codified at 50 U.S.C. Ã § 1541 note (2006)). ] [75: Id. ] [76: Hamdi v. Rumsfeld, 542 U.S. 507, 517 (2004). ] [77: Id. ] [78: Rasul v. Bush, 542 U.S. 466 (2004). ] [79: Boumediene v. Bush, 553 U.S. 723, 729 (2008). ]
Sunday, May 17, 2020
The Significance of Chapter 1 in Great Expectations by Charles Dickens Great Expectations is a riveting book set in Victorian London and published in 1861. The novel is set in historical context and illustrates ideas of implication such as how the really interesting people could often be found in the lower classes, in the time of social division and where the shift from agriculture to industrial processes was contemporaneous. Nevertheless the plot contains significant relevance to modern day life in the subtle message that we can be happy as we are; we dont need always to aim higher at riches. This great novel is so successful as it applies to historical and contemporary issues alike in themesÃ¢â¬ ¦show more contentÃ¢â¬ ¦He himself was enslaved in a blacking house at age 12. It is because of his experiences that he is not apprehensive in literal application of his moral and philosophical views on how the lives of the poor could be made more tolerable. Dickens has written many other articles stating his disapproval of mistreatment of people, the dan ger to their lives and even animal rights, this often comes across in his novels. Charles Dickens was a typical Victorian novelist concerned with issues of character, plot and the Victorian social world. He along with other novelists such as Charlotte Bronte, Emily Bronte, George Eliot and Thomas Hardy revolutionised literature. Although Dickens is often perceived as the most vigorous writer with a style of writing that has irrepressible vengefulness (which can be seen for example by his descriptive language of a young boy humiliating Pip smirked extravagantlyÃ ¢Ã¢â ¬Ã ¦wriggling his elbows and body). This of course is merely opinion however. Chapter 1 is crucial to the whole plot as it introduces the idea of many themes to follow and informs us of basic information such as the characters name. The book is an example of a Bildungsroman which is the name for a book which describesShow MoreRelatedTale of Two Cities4458 Words Ã |Ã 18 PagesBook I, Chapter 1: The Period 1. What is the chronological setting of this opening chapter? What clues enable us to determine The Period? 2. How does Dickens indicate the severity of social conditions in both France and England? 3. Who is the king with a large jaw and a queen with a plain face? 4. How does Dickens satirize the superstitious nature of the English? 5. What oblique reference does Dickens make to the American Revolution? 6. How in this chapter does DickensRead MoreEssay on Pips Relationship with Magwitch in Great Expectations3097 Words Ã |Ã 13 PagesHow does Dickens use Pips relationship with Magwitch to interest the reader? -------------------------------------------------------------------- The novel called Ã¢â¬ËGreat ExpectationsÃ¢â¬â¢ written by Charles Dickens, uses a very unique relationship between two characters to form the main Ã¢â¬ËstemÃ¢â¬â¢ of the book. PipÃ¢â¬â¢s relationship with Abel Magwitch is extremely interesting because it is so significant. It is at the heart of the book mainly for the reason that it is the closest and deepest relationshipRead MoreEssay about Analysis of Chapters 1 through 8 of Great Expectations6805 Words Ã |Ã 28 PagesAnalysis of Chapters 1 through 8 of Great Expectations Plot and Setting- The plot starts out with a little boy name Phillip Pirrip. It is a first person narrative about a boy back in the nineteenth century. The first eight chapters deal mostly with PipÃ¢â¬â¢s childhood years. It also deals with who Pip is, and his family. In the beginning of the story Pip introduces himself, and introduces his dead parents. He is in the graveyard, and then a scary looking man comes up. The man threatens himRead Moreessay on dickins journey to niagra3989 Words Ã |Ã 16 PagesDickens felt transported by the sublimity ofÃ Niagara FallsÃ when he visited it on his 1842 journey to theÃ United StatesÃ and Canada. In a letter to Forster (26 April 1842), he said of Horseshoe Falls (the Canadian side of Niagara) that It would be hard for a man to stand nearer God than he does there (Letters 3: 210). Dickens proceeds toÃ effuseÃ over the beauty and majesty of the falls in a passage that forms the chief part of his description of his experienc e in American Notes, although the letterRead MoreEssay Prompts4057 Words Ã |Ã 17 PagesFaustus Orlando Don Quixote A portrait of the Artist as a Young Man A Gesture Life Rosencrantz and Guildenstern Are Dead Ghosts The Scarlet Letter Great Expectations Sister Carrie The Great Gatsby The Sound and Fury GulliverÃ¢â¬â¢s Travels Sula Heart of Darkness The Sun Also Rises Invisible Man Their Eyes Were Watching God Joe TurnerÃ¢â¬â¢s Come and Gone The Things They Carried King Lear The Turn ofRead MoreANALIZ TEXT INTERPRETATION AND ANALYSIS28843 Words Ã |Ã 116 Pagesthe text reveals under close examination. Any literary work is unique. It is created by the author in accordance with his vision and is permeated with his idea of the world. The readerÃ¢â¬â¢s interpretation is also highly individual and depends to a great extent on his knowledge and personal experience. ThatÃ¢â¬â¢s why one cannot lay down a fixed Ã¢â¬Å"modelÃ¢â¬ for a piece of critical appreciation. Nevertheless, one can give information and suggestions that may prove helpful. PLOT The Elements of Plot When weRead MoreLanguage of Advertising and Communication Via Advertising16638 Words Ã |Ã 67 PagesAdvertising and Communication via Advertising Contents Introduction 3 Chapter 1. Concept of advertising as an act of communication 7 1.1. Definition of Advertising 7 1.2. Communication and Advertising 8 1.3. Functions of Advertising 12 1.4. Image Advertising 14 1.5. Advertising Text and Slogan 15 1.6. Conclusion 16 Chapter 2. Language of advertising 18 2.1. General Characteristics of the Ad-sloganRead MoreLanguage of Advertising and Communication Via Advertising16651 Words Ã |Ã 67 PagesCommunication via Advertising Contents Introduction 3 Chapter 1. Concept of advertising as an act of communication 7 1.1. Definition of Advertising 7 1.2. Communication and Advertising 8 1.3. Functions of Advertising 12 1.4. Image Advertising 14 1.5. Advertising Text and Slogan 15 1.6. Conclusion 16 Chapter 2. Language of advertising 18 2.1. General Characteristics of theRead MoreOrganisational Theory230255 Words Ã |Ã 922 Pagesorganization theory within the scholarly debates on modernism and postmodernism, and provides an advanced introduction to the heterogeneous study of organizations, including chapters on phenomenology, critical theory and psychoanalysis. Like all good textbooks, the book is accessible, well researched and readers are encouraged to view chapters as a starting point for getting to grips with the field of organization theory. Dr Martin Brigham, Lancaster University, UK McAuley et al. provide a highly readableRead MoreA Study on Delay in Disposal of Civil Litigation in Bangladesh Perspective8735 Words Ã |Ã 35 PagesA STUDY ON DELAY IN DISPOSAL OF CIVIL LITIGATION IN BANGLADESH PERSPECTIVE Historical Background:- The age old adage Ã¢â¬ËJustice delayed Justice deniedÃ¢â¬â¢ has control significance for meeting the ends of justice. Delayed justice in the means of inflicting injustice through process of law. Speedy disposal of case is an important condition of ends of justice. The laws contained themselves to protection of the weak against the economically strong. The fisc against corruption, the ignorant against the knowledgeable
Wednesday, May 6, 2020
Outline 1. Biography 2. Theory 3. Theory Application to Teaching 4. Works Cited Biography Abraham Maslow was born on April 1, 1908 in Brooklyn, New York. He was the first born of seven. His parents were uneducated Jewish immigrants from Russia to the United States before he was born. They came to America to get away from the harsh conditions and socio-political turmoil. His parents, hoping for their children to do better than they did, pushed for educational excellence. He grew up with almost no friends to play with because his father would make him study for long hours. When Maslow wasnÃ¢â¬â¢t busy studying, he was assisting his father to make end meet. He was a very lonely boy who spent a lot of his time with his nose in a book.Ã¢â¬ ¦show more contentÃ¢â¬ ¦This analysis served as the basis of his theories and research on human potential. In 1951 he switched jobs and started worked at Brandels University until 1969. During the 1950Ã¢â¬â¢s Maslow became one of the founders and driving force behind the school of thought, known as humanistic psychology. His theories, hierarchy of needs, self-actualization and peak experienced became fundamental subjects in the humanist movement. Maslow argued that each person had a hierarchy of need that must be satisfied, ranging fro basis physiological requirements to love, esteem, and finally self-actualization. As each need is satisfied, the next higher level in the emotional hierarchy dominates conscious functioning. Struggling with ill health, Maslow decided to spend his final year in California where he was half retired. On June 8, 1970 he died of a heart attack. Theory Maslow first introduced his theory of a hierarchy of needs in a paper he wrote in 1943 called Ã¢â¬Å"A Theory of Human Motivation,Ã¢â¬ and also in a book he wrote called Motivation and Personality. This hierarchy suggests that people are motivated to fulfill basic need before moving on to other needs. His theory is most often shown in a pyramid where the lowest level of the pyramid represents the most basic needs, while the more complex needs are located at the top of the pyramid. The basic needs consist of the need for food, water, sleep and warmth.Show MoreRelatedAbraham MaslowÃ¢â¬â¢s Hierarchy of Needs Essay1315 Words Ã |Ã 6 PagesIntroduction The term motivation is derived from the Latin word movere, meaning to move. Motivation is the push of the mental forces to accomplish an action or goal willingly without being forced or told to do so. It is an unsatisfied need that drives human behavior to exert effort to reach the goals. For example we study because we are lack of knowledge; we work because we are lack of money. We will in turn be motivated by what we are lack of. Motivation techniques in the past were very differentRead More Abraham MaslowÃ¢â¬â¢s Hierarchy of Needs Essay1667 Words Ã |Ã 7 PagesAbraham MaslowÃ¢â¬â¢s Hierarchy of Needs When one thinks of what families do for each other, they will most likely think of care. More specifically they think of the care that a parent has for their child. Parents have to meet certain Ã¢â¬Å"needsÃ¢â¬ for the child in order for the its healthy survival. Children must be fed and clothed. Parents must also watch over the safety of and be the friends of the children. Cheering on in good times and making their child the best it can be are also responsibilitiesRead MoreAbraham MaslowÃ¢â¬â¢s Hierarchy of Needs Essay1307 Words Ã |Ã 6 PagesIntroduction The term motivation is derived from the Latin word movere, meaning to move. Motivation is the push of the mental forces to accomplish an action or goal willingly without being forced or told to do so. It is an unsatisfied need that drives human behavior to exert effort to reach the goals. For example we study because we are lack of knowledge; we work because we are lack of money. We will in turn be motivated by what we are lack of. Motivation techniques in the past were veryRead MoreAnalysis Of Abraham Maslows Hierarchy Of Needs898 Words Ã |Ã 4 Pages Abraham Maslow theory on hierarchy of needs view humans as having tremendous potential for personals development. He believed it was human nature for people to seek to know more about themselves and strive to develop their capacities to the fullest. He viewed human nature as good and saw them striving for self-actualization as a positive process because it leads people to identify their abilities, to strive to develop them, to feel good as they become themselves, and to be beneficial toRead MoreAbraham Maslows Hierarchy of Needs Theory Essay1019 Words Ã |Ã 5 PagesAbraham Maslows Hierarchy of Needs Theory Abraham Maslows Hierarchy of Needs is one of the first theories of motivation and probably the best-known one. It was first presented in 1943. in Dr. Abraham MaslowÃ¢â¬â¢s article A Theory of Human Motivation in Psychological Review, and was further expanded in his book Ã¢â¬Å"Toward a Psychology of BeingÃ¢â¬ . Maslow tried to formulate a needs-based framework of human motivation. His research was based upon his clinical experiences with humans, rather than priorRead MoreCharacter Analysis Of Abraham Maslows Hierarchy Of Needs945 Words Ã |Ã 4 Pagesrealize that he needs to learn how to let go, that not every single person he meets will stay right beside him in his life. According to Abraham MaslowÃ¢â¬â¢s Hierarchy of Needs, when people strive to be the best versions of themselves, there are certain levels that they must pass. I feel that Harvey is fixated on the esteem level of the hierarchy since he focuses primarily on achievements (motivated by achievements), considering the fact that his other needs are met (basic needs, safety needs...). PersonalityRead MoreAbraham MaslowÃ¢â¬â¢s Needs Hierarchy Theory Essay1916 Words Ã |Ã 8 Pagescan be motivated and the end result is that the organization Goals or targets achieved. This essay will revolve around the motivation three motivational theories and how the managers of the organization implement these theories by looking at the needs and expectations of the employees. Reference will be made throughout the essay to a case study of BEST BUY sales man (Michael V. Copeland, 2004). To know something about motivation we should getting through another way related somehow to psychologyRead MoreAbraham MaslowÃ¢â¬â¢s Hierarchy of Needs and the Road to Self-Actualization2459 Words Ã |Ã 10 PagesAbraham MaslowÃ¢â¬â¢s Hierarchy of Needs and the Road to Self-Actualization PSY 330: Theories of Personality January 30th, 2012 Abraham Maslow: Hierarchy of Needs and the Road to Self-Actualization Abraham Maslow was an American theorist that was one of the advocates of humanistic psychology. He believed that self-actualization is Ã¢â¬Å"a situation that exists when a person is acting in accordance with his or her full potentialÃ¢â¬ (Hergenhahn Read MoreThe Hawthrone Studiesdouglas | Mcgregors Theory X and Theory Y | Abraham Maslows Hierarchy of Needs8409 Words Ã |Ã 34 PagesHERE ARE NOT MY OWN WORDS. THIS PAPER WAS DONE FOR THE PURPOSE OF AN ASSIGNMENT. NO PROFIT WAS PLANNED TO BE MADE FROM THIS. ENGINEERING MANAGEMENT (ES24) Assignment The Hawthorne Studies Douglas McGregorÃ¢â¬â¢s Theory X and Theory Y Abraham MaslowÃ¢â¬â¢s Hierarchy of Needs The Hawthorne Studies Hawthorne Studies The Hawthorne Studies are experiments which inspired Elton Mayo and others to develop the Human Relations Movement. These were conducted by the Western Electric Company of Chicago to measureRead MoreCompare and Contrast Clayton Paul Alderfers Erg Theory of Motivation and Abraham Maslows Needs Hierarchy1708 Words Ã |Ã 7 PagesNeeds Theories Overview Needs-based motivation theories are based on the understanding that motivation stems from an individuals desire to fulfill or achieve a need. Human beings are motivated by unsatisfied needs, and certain lower needs must be satisfied before higher needs can be satisfied. In general terms, motivation can be defined as the desire to achieve a goal, combined with the energy, determination and opportunity to achieve it. This Wiki explores Abraham H. Maslows Hierarchy of Needs
In the Indian Army Regiments are of two kinds battalion-sized units of arms like the Armoured Corps, Artillery, Engineers, and Signals, or a specific mixture of Infantry battalions. In Artillery, the complete Artillery mass in the order of battle is known as the Regiment of Artillery. The Infantry Regiments are identified by their distinctive individual names; they have a Regimental Centre for training and equipping of the staff for the infantry battalions of the Regiment. The Centre maintains records of each soldier till he retires and is out of service.The Record office and the Pay and Accounts offices perform these functions. These Regimental Centres send qualified soldiers to infantry battalions which are assigned to tactical units Brigades and Divisions. The infantry battalions known by their individual Regimental number and name are active units fit to fight and carry out desired duties in the battle. The Regiments are headed by a Colonel, who is a high-ranking officer. We will write a custom essay sample on Regiment and Infantry Battalions or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The Colonel of the Regiment is the head of the family and is responsible for the protection of the best interests of the Regiment.He is almost always an officer of General rank who at one time served in the Regiment. The idea is that such a person would take personal interest in the well-being of the Regiment, its troops and its widows. The way the wounded and dead are handled in a battle is a powerful example of Regimental spirit. In the Regiments of Indian Army it is a matter of honour not to let a wounded comrade fall into enemy hands. Many a time special operations have been carried out to recover wounded soldiers.A major feature of the Regimental system has been to train young officers to Ã¢â¬Ëknow their men better than their mothers do and care even more. Ã¢â¬â¢ Practically it requires officers to learn the Regimental language in the shortest possible time; not to eat till their men are fed; excel their men in physical fitness and handling of weapons; become epitomes of military disciplines in punctuality, turnout, and thoroughness; play games with their men, spend time in their langars and dining rooms, coach them to be the best in the unit in all soldierly activities, sports and beha viour.They are guided by just one ideal that is, their performance and that of their men must be worthy of the good name of the Regiment. This system gives them a sense of belonging and a cause bigger than themselves and acts as a crucible for promoting espirit-de-corps. Regiments provide a living example of how Indians, without abandoning their religious belief or ethnic pride can whole heartedly work together for the good of the country.It is a brotherhood in which Hindus, Muslims, Sikhs and Christians try to excel in their service for the good name of their Regiment, Indian Army and the Country. Battle Honour days have been devised to remind all ranks of a Regiment of the achievements and sacrifices of their predecessors. There is nothing better than the study of Regimental history to understand these traditions and inculcate pride in them. Every opportunity is taken to remind the members of those achievements and traditions so that a high standard of behaviour, courage and comradeship is set.This is done through the Part-I orders, evening roll call time, lectures, unit Darbars and Mandir, Masjid, Gurudwara, Church parades. It is with this repeated treatment that a soldier learns to practice unselfishness and find roots and pride in the traditions of a Regiment. Hence, we can say that the Regiment becomes the religion of those who have the honour to serve in it. Did you know? ON JULY 27 1961, a speed boat, carrying three persons crossing the English Channel capsized and sank, leaving three crew members struggling for survival in the waters.On receiving the distress message, the RNAS Lee on Solent Control Tower issued a general rescue call, which was picked up by two helicopters in the area, belonging to the INS Vikrant. Lt Cdr Wadhwan and Lt Cdr Menon were flying a training mission in these helicopters leased from the French, when they proceeded for rescue. As only WadhwanÃ¢â¬â¢s chopper was fitted with a rescue winch, Wadhwan and his aircrew man on board operated the winch and rescued all the three. This incident bought wide publicity in the British Papers for the Indian Navy.
Sunday, April 12, 2020
Irac Essay Samples For Many IssuesWhen you are looking for information on what to write for your college's essay, consider using the resources that are available for you at various sites around the internet. The resources are geared toward helping students with Irac essay samples for many issues.First of all, when you are searching for specific guidelines about writing a student's essay, you may find some different places that you can use. However, you should always read through the samples provided and take notes.When you are trying to follow a particular sample, remember that it is generally meant to be used as a guideline. The fact is that every college requires their students to have essays that look impressive on paper.It is important to try to obtain the proper essay to read and make notes from, as well as review the campus paper. This is because not everyone has the same idea of what would look good in their essay. Many individuals take the college essay tests that are offered each year, and this will help you avoid making errors.One of the topics that you can get is a short form essay. This is also great for those students who want to complete their first one. A short form contains much of the same material as a standard or traditional one, so it should be easy to work with for your situation.Of course, the truth is that a sample may not include everything that you will need to write. You should always make sure that you check the sample in advance and then go through it once you are finished with it.For those students who feel that they might not have enough time to fully understand the Irac sample, it is important to know that there are several other resources available that will help you out. Of course, you should make sure that you only get the information that you need and that you can follow it correctly. The more you do it, the better.
Saturday, April 4, 2020
Find Out Who is Concerned About School Writing Paper and Why You Should Be Paying Attention The Unusual Secret of School Writing Paper Knowing the way the paper is made, what the degree of quality is, and what types of products can be made out of the recycled paper can help you make up your mind. You will want somewhere where you truly feel comfortable and that it is possible to focus on the job at hand with no interruptions. If you would like to acquire high excellent research and thesis papers punctually and for an affordable price, you should probably attempt using EssaySupply.com. By employing the help of the correct business, you are going to have access to an abundance of quality services for affordable rates. If you wish to learn to paper quill, the ideal thing you could do is to come across a set of instructions and follow them carefully. It is crucial to learn letter first. Especially, in regards to ordering a paper from an internet firm. Also, if you're using co lored printable paper for text documents, make sure that you pick a color that's simple to read. You may hire us for a variety of essays. If necessary, you may include another part of your paper named Intended Audience in the body of your white paper. The very first paper industry was constructed in Europe. You must keep the exact same pressure on the paper in any respect times when you're winding. New Step by Step Roadmap for School Writing Paper Essays are typically not very long, therefore it's not surprising that teachers would assign a good deal of them to write. Writing cursives isn't as simple as writing letters in printable form. Reading book isn't obligation. You're going to be surrounded by writing professionals throughout the plan of order placement, and once you choose to purchase essay and select an allocated writer, things are likely to get even more exciting. Actually, a seasoned writer can get the job done much faster than any student as they've been writing academic assignments during their entire life. If you're rude to an editor they will not ever consider your work again. English writing can be difficult if the writer doesn't make use of many English language writing resources which are available to assist them. You should make sure the information on your research paper is organized, in order for your readers won't have any trouble reading. Writing white papers isn't an easy job for the majority of companies, but every business needs them to effectively educate and advertise their services and products to prospective clients. With no doubt, it is an indispensable product, being extensively utilized in a variety of indus tries, as well as for personal purposes. The next step in how to compose a research paper demands a tiny bit of organization as soon as the time arrives to really write it down. Maintaining motivation A key to maintaining your motivation is to find that you're moving in the direction you would like to go and that you're gaining the advantage of your efforts. Before you go out and spend money on products which aren't for your particular project, here are a couple pointers to help you select the best type of printable paper. Today, lots of research was done on how best to go about making effective ballpoint pens. Your research pursuit does not need to have to be hard if you understand what you're doing. Although essays and research papers can be an issue, term papers are a lot more complex than the majority of the academic assignments. One of several new methods is named Group writing. Writing is a process which needs to start from the kid's primary school years. It's never too late to create decent handwriting abilities. Utilizing a writing service is the perfect approach to have a well-written essay to use as a guideline to guarantee the essays you write are hitting all the critical points and are at the appropriate depth necessary for your academic grade. The increasing number of essay writing services is totally overwhelming. Using our services is wholly safe. Once more, the benefits of writing services stay unmatched, and the benefits offered by our writing service are quite diverse.
Tuesday, March 10, 2020
Computer Essay TopicsWhen writing your essays on my computer, you need to look for my computer essay topics. If you don't find any you can choose from a wide variety of subjects that can be adapted to your unique personality. Your essay will be well thought out and concise.Computer essay topics are not difficult to find. You just need to know where to look. Good places to start are the college fairs and writing competitions. These are the places where many students submit their articles.The next place to look is the Internet. You may have to do some investigating, but there are many websites that allow you to write an essay on my computer. Many of these are very good sites.One reason why many students prefer computer essay topics is that they do not have to write the essay word for word. The technology used in the latest computer models makes it easy to perform a substitution. You have your own computer expert using it to suggest substitutions and help you avoid an incorrect substitu tion.You can also find many other ways to make your computer essay topics more interesting. Many online authors write their essays from PowerPoint presentations and slideshows. This is quite easy because you can easily convert these presentations into an essay.There is a lot of information overload at our colleges and universities. We need to write essays that are not only interesting but also fairly easy to read. Writing short paragraphs makes the most sense if you want to have a brief essay without dragging on too long.A word about the 'must write' rule. Some students worry that computer essay topics must be super-easy. Other students do not worry about this rule because they do not think they have the time to work on essays that are hard to read. But neither of these students is going to make the grade in college if they do not learn how to adapt computer essay topics to their own style.As you get used to writing on my computer essay topics, you will soon be able to do so without feeling bogged down by reading material. After all, you are a college student, not a child, and you will not have time to complete many other activities as well. But your goal is to be able to get through all your courses and get a solid grade.