Grand Canyon University Is A Christian College Full Of

Grand Canyon University is a Christian College full of deep history. Starting sixty-five years ago as a Baptist Church. It started its location in Prescott, AZ but eventually grew and relocated to Phoenix where is created a strong reputation as a private Christian University (History of GCU). In the early 2000’s, Grand Canyon University was having a hard time producing academic experiences of high quality. The financial support dropped, leaving the college with the only choice of starting a new practice that turned around the operations (History of GCU). Grand Canyon University re-did itself, and enhanced the nursing and education programs in particular. Now, GCU offers bachelors, masters and doctoral degrees in many fields, and the†¦show more content†¦Grand Canyon University offers a wide selection of 76 programs, the most popular being Nursing, Special Education, Business Management and Education (Key Facts). To be on the Dean’s list, â€Å"students whose enrollment cumulative GPA is 3.5 or above qualify for the Dean’s List,† (GCU Student Handbook). Grand Canyon University offers many different types of internship programs as well. There are two types of internships, â€Å"programmatic internships aligned with your field of study,† and â€Å"Elective internships overseen by the Office of University Internships,† (GCU Internship Programs). Both are easy to apply for and will help you connect better with the school and some have the opportunity to earn credits from the internships, (GCU Internship Programs.) Not only does the campus of Grand Canyon University have several activities such as a gym, pools, a recreational center, and many sporting events; the surrounding area of Grand Canyon University has activities also( GCU Clubs and Organization). According to Google Maps, there are a few restaurants surrounding GCU; these restaurants include, Qdoba, Domino’s Pizza, Jamba Juice, Denny’s, Wendy’s, Olive Garden, Chili’s, and Applebee’s. There’s also a supermarket called Grand Mart just one mile from campus, and a Walgreens across the street from that (GoogleShow MoreRelatedUniversity Of Arizona And Grand Canyon University1371 Words   |  6 PagesThe high school senior year is indeed a rough year. Students are overwhelmed with stress applying for colleges, having their fingers crossed to be accepted in their first choice college. The primary step before applying for colleges is selecting which college best suits them in pursuing their dream caree r. Sometimes, more than half of the students dream of being in the medical field, satisfying that there’s still people in the world that want to help out others, and what’s better than helping themRead MoreUniversity Vs Northern Arizona University822 Words   |  4 PagesCollege Search Arizona State University and Northern Arizona University are two schools that I’ve been accepted in. I would like to go to GCU, but I’m not sure if I’ll be accepted. If I don’t get accepted I would want to attend Northern Arizona University full time. I would also like to live on campus only at NAU. If I go to another university I will just plan on still living with my parents. School Profile Arizona State University’s tuition and fees comes to a total of $10,522 (ASU Tuition, 1)Read MoreProfessional Nurse Practice Act ( Bsn ) Curriculum1347 Words   |  6 PagesPractice Act (2013). The plan builds on self-assessment findings completed as part of Grand Canyon University’s nursing education seminar course, Georgia Baptist College of Nursing of Mercer University’s knowledge and theory development in nursing course, and Berry College’s annual faculty report. Resources for student and academic services will be the responsibility of the proposed parent institution, Reinhardt University (RU) and will be evaluated on a regular basis. While budget and course developmentRead MoreMastering Graduate Studies 1e32499 Words   |  130 PagesDiVincenzo Consulting Editors: Mark Alexander, Nicole Quow-Thomason Art Direction Senior Art Director: Miranda Hildebrand Art Development and Design: Jo DeSnyder-Rolfe Permissions contact Grand Canyon University 3300 W Camelback Rd Phoenix, AZ 85017 602.639.7500 Copyright Information Grand Canyon University. All rights reserved. No part of this book may be reproduced, in any form or by any means, without permission in writing from the publisher  custom textbook usage The following icons haveRead MoreComparative Study of Pakistan Chinese Cultures13385 Words   |  54 Pagestwo friendly boarder countries. It has been found that both courtiers have different religion ideologies and living styles but both share the same shades of love, harmony and respect for the elders. School of Management Northwestern Polytechnical University Comparative study of Pakistan and Chinese Cultures 2013 CHAPTER-1......................................................................................................................................................... 3 INTRODUCTION.........Read MoreTourism of Switzerland10781 Words   |  44 Pagesurban and rural states were at times strained. Following the Reformation, it was religion that stirred up tensions, with conflict breaking out between some Catholic and Protestant cantons. Despite these clashes, which in certain instances bordered on full-scale war, the Old Swiss Confederacy began to take root from the end of the Middle Ages and the start of the Early Modern era. Relations within the cantons and with neighbours also varied. For example, some towns and territories, althoughRead MoreReview Of Charlotte Bronte s Jane Eyre 10879 Words   |  44 Pagescan bear to have my morsel of bread snatched from my lips, and my drop of living water dashed from my cup? Do you think, because I am poor, obscure, plain, and little, I am soulless and heartless? You think wrong! — I have as much soul as you — and full as much heart! And if God had gifted me with some beauty and much wealth, I should have made it as hard for you to leave me, as it is now for me to leave you. I am not talking to you now through the medium of custom, conventionalities, nor even ofRead MoreStephen P. Robbins Timothy A. Judge (2011) Organizational Behaviour 15th Edition New Jersey: Prentice Hall393164 Words   |  1573 PagesOrganizational Behavior This page intentionally left blank Organizational Behavior EDITION 15 Stephen P. Robbins —San Diego State University Timothy A. Judge —University of Notre Dame i3iEi35Bj! Boston Columbus Indianapolis New York San Francisco Upper Saddle River Amsterdam Cape Town Dubai London Madrid Milan Munich Paris Montreal Toronto Delhi Mexico City Sao Paulo Sydney Hong Kong Seoul Singapore Taipei Tokyo Editorial Director: Sally Yagan Director of Editorial Services:Read MoreMarketing and Page Ref14698 Words   |  59 Pagescharacterizes Millennials? A) They are children of baby boomers. B) They are less ethnically diverse than Gen Xers. C) They have reached their peak earning and spending years. D) They were once labeled the MTV generation. E) They have graduated from college and are taking over positions of power in the business world. Answer: A Diff: 2 Page Ref: 74 AACSB: Multicultural and Diversity Skill: Concept Objective: 3-2 28) Which demographic group is characterized by a total fluency and comfortRead MoreDeveloping Management Skills404131 Words   |  1617 Pagesbuilt-in pretests and posttests, focus on what you need to learn and to review in order to succeed. Visit www.mymanagementlab.com to learn more. DEVELOPING MANAGEMENT SKILLS EIGHTH EDITION David A. Whetten BRIGHAM YOUNG UNIVERSITY Kim S. Cameron UNIVERSITY OF MICHIGAN Prentice Hall Boston Columbus Indianapolis New York San Francisco Upper Saddle River Amsterdam Cape Town Dubai London Madrid Milan Munich Paris Montreal Toronto Delhi Mexico City Sao Paulo Sydney Hong Kong Seoul Singapore

Emirates Airline - 1780 Words

The Emirates Group is composed of airport services provider DNATA (the Dubai National Air Transport Association) and Emirates Airlines. Owned by the government of Dubai and based at the busiest airport in the Middle East, Emirates has flourished under the sheikdoms wide open skies policy, in spite of the restrictions placed on it by other countries. The airline, renowned for its luxurious in-flight service, was unique among long-haul airlines in that it had not joined a global alliance such as the Star Alliance or oneworld by the beginning of the new millennium. The Maktoum family led the tribe throughout the 19th and 20th centuries. Dubai became one of seven sheikdoms in the United Arab Emirates, which was formed in 1970. Gulf Air†¦show more content†¦We now have a team of more 40,000 loyal workers, many living far away from their own families, and we are committed to caring for them within ours. This dedication to the welfare of our employees does not distract from the fundamental economic role of our business – to reward stakeholders. While rivals have faltered under the strain of fluctuating fuel prices and the intense level of competition synonymous with our industry, we have posted profits in all but one year of our history. While we are focused on maximising profit margins, as a leader in aviation innovation, we are devoted to growing our business while using fewer resources and creating less waste and pollution. The billions of dollars we have invested in purchasing the most advanced aircraft in production mean we operate one of the youngest and most eco-efficient fleets in the world. Our commitment to the environment extends to our interests on the ground. We take great pride in our involvement with the Dubai Desert Conservation Reserve, which is dedicated to preserving the natural and cultural heritage of area. The National Park, the largest protected area in the UAE and home to more than 30 species indigenous to the Arabian Peninsula, is considered the regional benchmark for sustainable development and conservation. Our green projects do not stop at home and plans are already wellShow MoreRelatedEmirates Airlines4429 Words   |  18 PagesHub of the World Emirates is one of the fastest-growing and most profitable airlines in the world. Yet the secret of its success is largely unknown outside the Arab world. Donald N. Sull, Sumantra Ghoshal and Felipe Monteiro unveil some of the mystery that shrouds a national carrier that enjoys no state handouts – and treats its employees as a giant family. The ess than two decades after its foundation, Emirates placed the biggest order in civil aviation history, for $19 billion worth ofRead MoreEmirates Airlines12540 Words   |  51 Pages9 -7 1 4 -4 3 2 JANUARY 29, 2014 JUAN ALCà CER JOHN CLAYTON Emirates Airline: Connecting the Unconnected Introduction Late afternoon was fading to dusk as Tim Clark, President of Emirates Airline, gazed out at the large crowds mingling outside at the 2013 Dubai Airshow. Front and center at the event was the official program launch of the Boeing 777X, a massive new hit thanks to Emirates’ record order of 150 new planes. Valued at $76 billion at list prices, this was the largest airplaneRead MoreEmirates Airlines5871 Words   |  24 Pagesï » ¿Assignment On Strategic Management Of Emirates Airlines Course Title: Strategic Management Course No: 409 Submitted To: Tanvir M H Arif Associate Professor Department of Finance Banking. University of Chittagong. Submitted By: Group: B.B.A. (4th Year)-Mid Term Session: 2008-2009 DepartmentRead MoreEmirates Airline1090 Words   |  5 PagesEmirates Airline is one of the five world leading airline companies founded in 1985. It was awarded the â€Å"World’s Best Airline† by Skytrax at the 2013 World Airline Awards. In addition Emirates Airline was awarded the â€Å"Best Middle East Airline† and for the ninth year in a row â€Å"World’s Best Inflight Entertainment†. Emirates Airline serves over 39 million customers a year based on 2013 data. Nonetheless as every other business, Emirates Airline faces its own challenges. The company needs to updateRead MoreEmirates Airline Overview1460 Words   |  6 PagesIntroduction Emirates (Fly Emirates) is the national airline of the United Arab Emirates. It is one of the fastest growing airlines and is known for consistently turning a profit. Though Emirates is owned by the UAE government, is has â€Å"evolved into a globally influential travel and tourism conglomerate known for its commitment to the highest standards of quality in every aspect of the business† (The Emirates Story). History In March of 1985, Emirates airlines was created with supportRead MoreEmirates Airlines Case Analysis1197 Words   |  5 Pagesenvironment of Emirates, one of the world’s most reputed international airlines. Emirates Airlines is owned by the government of Dubai, which is located in United Arab Emirates. Emirates Airlines has been operating for more than twenty years. Political environment The growth and success of Emirates Airlines can be largely attributed to the consistent backing of the government. The support of the local government has certainly provided the necessary impetus to Emirates Airlines to move aheadRead MoreSwot and Pestel of Emirates Airlines1364 Words   |  6 PagesIntroduction Emirates Airlines (also known as Fly Emirates) is a major airline in the Middle East, and a subsidiary of The Emirates Group. It is the national airline of Dubai, United Arab Emirates and operates over 1,990 passenger flights per week, from its hub at Dubai International Airport, to 157 destinations in 55countries across 6 continents. The company also operates four of the world’s longest non-stop commercial flights from Dubai to Los Angeles, Sà £o Paulo, Houston, and San Francisco, allRead MoreStrategic Location Of Emirates Airlines1599 Words   |  7 PagesI. Core Problem / Issue Emirates Airline is a â€Å"global success story. In just twenty-five years the airline had grown to become the third-largest airline globally by capacity and the largest by number of international passengers.† (Alcacer Clayton, 2014, p. 1) The strategic location of Dubai and Emirates Airlines focus on investing in emerging and underserved markets, such as the BRICS countries, which has allowed them first-mover advantage to lock up and limit competition in these markets, especiallyRead More Analysis of Emirates Airlines Essay1986 Words   |  8 PagesIntroduction The company of Flying Emirates The Emirates Airlines is one of company of the United Arab Emirates Airline. Emirates airline established in 25th may in 1985, their head office is in Dubai and it based on the international airport. The Emirates Group is the parent company of the United Arab Emirates airline. Emirates airline emirates government owns from Dubai. Emirates Airlines is one of the fastest-developing airline. Emirates Airline has abundant and independent finance, inRead MoreEmirates Airlines Case Study1535 Words   |  7 Pages On October 25, 1985, Emirates Airline was established with help from the Dubai government. Since its inception, the company has successfully expanded to 140 destinations over 6 continents and added 150 new aircraft. Indeed the purchase of 150 aircraft was costly but this move increased the capacity of planes into the routes. As a result, Emirates became one of the top five largest leading airline companies globally. Emirates are indeed a global success story in an industry where lucrative companies

Report of Contract of Agency Free Essays

Topic: Law of agency Summary of Facts: Company Star Boat employed Tom as the manager for marketing and sales department. Being an agent for Star Boat, Tom frequently concluded contracts with a number of suppliers for acquiring certain parts to manufacture boats. Smooth Sailing was one of the suppliers. We will write a custom essay sample on Report of Contract of Agency or any similar topic only for you Order Now Tom resigned from Star Boat in July 2012 upon being offered a better position in Star Ferry. However, he acquired 4,000 parts from Smooth Sailing in August and manager of Smooth Sailing did not notice that in the contract Tom indicated his signature as â€Å"manager, Star Ferry† and thought they were dealing with Star Boat as usual. When Smooth Sailing later notified Star Boat to make payment, Star Boat wanted to ratify the contract. Legal Issues: First, Star Boat wants to ratify the contract, we must know that whether there is any valid contract formed. There are six elements to create a valid contract including intention to create legal relation, an offer and acceptance, consideration, privity of contract, capacity of contract and legality of contract. The first element – intention to create legal relation is not fulfilled. As Smooth Sailing intended to deal with Star Boat but not Star Ferry. However, the contract now is dealing with Star Ferry. Smooth Sailing has no intention to deal with Star Ferry. As there is no intention, no valid contract is formed. Second, there is a unilateral mistake in this contract. Unilateral mistake involves only one party mistaken. To be operative, it must be known to the other party. Normally involve fraud on the part of the non-mistaken party. In the above case, Tom was dealing with Smooth Sailing before July. However, in August, Tom did not tell the truth to Smooth Sailing that he is the agent of Star Ferry but not Star Boat now. Therefore, Smooth Sailing thought that he was dealing with Star Boat as usual. In the following paragraph, we list two relevant cases which are similar to the present case. Cundy v. Lindsay (1876) HL, L Co, a linen manufacturer, received an order for a large number of linen handkerchiefs from Blenkarn, who signed his name in such a way that it looked like ‘Blenkiron Co’, a well-known respectable firm. L Co dispatched the goods on credit to Blenkarn, who resold 250 dozen to Cundy. Blenkarn did not pay for the goods. L Co sued Cundy to recover the handkerchiefs. It was held that the contract between L Co and Blenkarn was void for unilateral mistake. L Co intended to deal with Blenkiron Co, not Blenkarn. Cundy was liable to return the handkerchiefs to L Co because no right of ownership had passed to him. Lewis v. Avery (1971) Lewis sold his car to a man who claimed to be Richard Greene, a popular star. The man paid by cheque, providing a film studio pass as a proof of his identity. He sold the car to Avery. The cheque had been taken from a stolen cheque book and was later dishonoured. Lewis sued Avery to recover his car. It was held that this contract cannot be voided as the plaintiff cannot show the importance of identity. The mistaken belief to the credibility of act is not sufficient. Comparison: Comparing the legal issue between Cundy v. Lindsay (1876) and our case, both cases have the unilateral mistake. Cundy v. Lindsay can be voided because the identity was vital for them to form a contract. For the second case Lewis v. Avery (1971) compare with our case, both are also have the unilateral mistake. But the case Lewis v. Avery cannot be voided as it cannot show the importance of the identity. In our case, Smooth Sailing was dealing with Star Boat in the past and it shows that the identity is very important. Conclusion: In our case, Smooth Sailing thought it was dealing with Star Boat as usual and the identity is very important as it affects the credibility. In fact, Smooth Sailing always deals with Star Boats. We apply the case law, the contract should be voided because Smooth Sailing mistakes the identity and the identity is vital to the contract. Moreover, Smooth Sailing has no intention to deal with Star Ferry. Therefore, no valid contract exists and Star Boat cannot ratify the contract. How to cite Report of Contract of Agency, Papers

Total Quality Management and Fast Food free essay sample

Second part is a review of Total Quality Management literatures. Every aspect of the company connected with TQM shall be discussed. Third part is purely company condition where TQM program put into action. Fourth part consists of chapter four of final result of this thesis; from analyzing some points that affected company performance in delivering service. Fifth part is the philosophy of the three gurus presented in gaining more understanding with TQM, and some questionnaires that the researchers used to research situation in the working place where the main object is drawn on ‘service quality’. Seeing TQM as a fashion always adopts changing situation in world globalization and company structure, is a very good reason as a tool, which the company can use for making quality in meeting customers’ expectations. Background of the Study Restaurants are in the business of serving food to their customers. In other words, they are providing a product and a service. We will write a custom essay sample on Total Quality Management and Fast Food or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The quality of the food and service is defined as meeting or exceeding the expectations of the customer as if. This will also help them to equip with knowledge, experience, skills and abilities in this field. 2. Community This study will benefit the community in terms of knowing the importance of total quality management. 3. Government This study will benefit the government as this will give insight in providing programs that will help schools implement better teaching techniques that will teach HRM students about total quality management. . This will also help the government to lay the foundation for the innovation, economic growth, and social improvement of the quality of life that Filipinos have come to expect. And it promote amp; recommend national innovation and industrial competitiveness by advancing measurement science, standards (particularly ISO), quality concepts, and technology in ways that enhance economic security and stability, and improve the quality of life. C. Scope and Limitation of the Study This study will cover all about the perception of respondents on the application of total quality management in terms of services of selected fast food chain in Market-Market Ayala Malls namely: Tokyo-Tokyo, Goldilocks and Mc Donald’s. This study is limited to 100 respondents who are employees and staff of the five selected fast food chains, ages 19-40 years old. D. Hypothesis or Assumption The null hypothesis tested is: H1 There is no significant relationship between the age of respondents and the study about total quality management. H2 There is no significant relationship between the gender of respondents and the study about total quality management. H3 There is no significant relationship between the civil status of respondents and the study about total quality management. The above concept of total quality management is also reinforced in other studies. In their study on TQM in the Hospitality Industry, Saunders and Graham (2008) the concept has achieved a great deal of success in the hospitality industry. Total Quality Management (TQM) is however sometimes difficult to implement in hospitality industry owing to the difficult in identifying some of the most appropriate quality measures. This study identified the need to use the quality triangle in hospitality industry including focus on customers, teamwork approach to unify goals and use of scientific approach in decision making. Through comparing TQM in manufacturing and hospitality industry, the study gives important review on how hospitality industry can use the TQM concept to improve their services. This study is important since it shows how organization in the hospitality industry can actually use TQM concept to enhance quality in their products and services. It is important to understand that TQM is wholesome approach which doesn’t only look at one aspect of quality management but concentrate on quality in all aspects. HACCP is one of the most important aspects in TQM that efines quality. HACCP defines the important points at which quality should be ensured. Through understanding the important points in the process of food production or offering of service where quality can be enhanced, it become easier to enhance quality. In her study on HACCP for the hospitality industry: History in the making, Eunice (2008) notes that while HACCP is an important factor in quality enhancement process which has been used in large food manufacturers, it has been slowly employed in the small business especially in the hospitality industry.

Graphic Design Timelines

Timeline 1: Works of the First Half of the 20th Century Trends of the Period The first half of the 20th century is called the Modernist Era. Being an important period in the history of graphic design, modernism had a number of important trends which made it one of the most interesting and influential periods. The following trends have to be mentioned:Advertising We will write a custom essay sample on Graphic Design: Timelines specifically for you for only $16.05 $11/page Learn More Functionality: the vast majority of artists truly believe that the form of the work should be determined by function (Meggs and Purvis 238), this is why it was necessary to consider the space and its possible impact on the image. Simplicity of fonts: people should get a chance to perceive information on a proper level, and the idea to search for simplicity became the best option to rely on (Arntson 46). Loss of integral subject: Barnard defines it as the condition when  "individuals are no longer consistent or in harmony with themselves rather they are presented as divided, riven by inner conflict† (113). Montage: the idea to use the already created works and improve them by means of current technologies. Illusion of paradox: it means beyond someone’s belief (Barnard 113); the technique that develops the sense of absurd in the artwork. The above-mentioned trends may be properly observed and understood in the works of famous designers and artists. Though the same criteria were set as well as the same technologies and material were offered, each creator made personal improvements to underline the uniqueness of his/her work. The works described below were created during the Modernist Era between 1908 and 1950. Works and Designers Bellows, George. Black House. 1924. Museum Quality: Oil Paintings Reproductions. 8 March, 2011, http://www.huntfor.com/absoluteig/bellows.htm George Bellows was the representative of American realism. He was b orn in Ohio, still, the vast majority of his works were devoted to and created in New York. In spite of his talents in sports, his true love was art, and he found it necessary to develop his skills in art. His Black House is a perfect example of functionality trend. McNeil Whistler, James Abbott. The White Girl. Museum Quality: Oil Paintings Reproductions. 8 March, 2011, http://www.huntfor.com/absoluteig/whistler.htmAdvertising Looking for essay on art and design? Let's see if we can help you! Get your first paper with 15% OFF Learn More Whistler’s American roots made him one of the most famous British painters. His attempt to use the idea of simplicity provided people with a chance to accept the reality as it is without any other improvements. Steinlen, Theophile Alexandra. Chat sur un Fauteuil. Museum Quality: Oil Paintings Reproductions. 8 March, 2011, http://www.huntfor.com/absoluteig/steinlen.htm Steinlen is the French Art Nouveau painter whose ideas and methods deserve attention due to their loss of integral subject. The possibility to enjoy the harmony of an idea seems to be a brilliant approach to contribute to the field of graphic art. Munch, Edvard. Girls on the Bridge. 1920. Museum Quality: Oil Paintings Reproductions. 8 March, 2011, http://www.huntfor.com/absoluteig/munch.htm Advertising We will write a custom essay sample on Graphic Design: Timelines specifically for you for only $16.05 $11/page Learn More Munch was an important figure in Expressionistic art. He was born in Norway, got education in an engineering college, however, a serious illness interrupted his education. With time, he made a decision to become a painter, and his works serve as the main proof of the correctness of his decision. He took the already known backgrounds and ornaments and introduce his own vision of the image. Rivera, Diego. Portrait of Natasha. 1943. Museum Quality: Oil Paintings Reproductions. 8 March, 2011, http ://www.huntfor.com/absoluteig/rivera.htm The example of Mexican talent is observed in the work by Rivera. Simplicity of the forms helps to underline the beauty of the image. Singer-Sargent, John. A Morning Walk. Museum Quality: Oil Paintings Reproductions. 8 March, 2011, http://www.huntfor.com/absoluteig/sargent.htm The success of the American painter may be based on his well-round education in German and Italy or on his in-born talents and abilities to use watercolor.Advertising Looking for essay on art and design? Let's see if we can help you! Get your first paper with 15% OFF Learn More Cassatt, Mary. Mother Berthe Holding Her Baby. 1900. Museum Quality: Oil Paintings Reproductions. 8 March, 2011, http://www.huntfor.com/absoluteig/cassatt.htm Female positions and ideas were successfully introduced by a French painter and printmaker from Pennsylvania, Mary Cassatt. Her works show how it is possible to combine functionality and simplicity to represent a perfect image from real life. Crane, Walter. The Renaissance of Venus. Museum Quality: Oil Paintings Reproductions. 8 March, 2011, http://www.huntfor.com/absoluteig/crane.htm The example of paradox and montage trends is observed in the works of an English artist, the representative of Crafts movement, Walter Crane. Alma-Tadema, Lawrence. Welcome Footsteps. Museum Quality: Oil Paintings Reproductions. 8 March, 2011, http://www.huntfor.com/absoluteig/tadema.htm The Victorian painter from Belgium, Sir Lawrence Alma-Tadema, became a famous artist in London due to his abilities to depict the luxury and underline the int eriors. Gill, Eric. Title Page: Troilus and Criseyde. 1929. Eric Gill. 8 March 2011. http://www.ericgill.com/view_art.php?art_id=1631min=0max=1000000portrait=original=sub=sort_by=otherssold= The works of this typeface designer are recognized in different spheres, and his contribution to literature deserves much attention. Eric Gill was a British designer who introduced Perpetua in its proper way. His idea to combine letters with images in a new style became a captivating discovery of the first half of the 20th century. Timeline 1: Works of the Second Half of the 20th Century Trends of the Period The second half of the 20th century is also known as the postmodern period. The peculiar feature of this period in graphic design is that artists, painters, and designers did not want to consider the importance of rules and made everything possible to demonstrate personal attitude to the already formulated ideas. The main trends of this period are as follows: Unnecessary connection between form and function: now, it is not obligatory to follow each detail of an image and consider its function but it is more interesting to neglect the idea of functionality. Lack of cultural difference in the works of art: the process of globalization (Heller 193) made many people forget their roots and neglect the importance of their own cultures in order to meet the expectations of the audience who is ready to break the rules. De centering of a subject: artists want to underline the importance of indirect themes in their works and make the public consider various aspects of the image offered. Complexity of the forms: it is more captivating to integrate several ideas, several images, and several forms and introduce one image with the help of which the idea of design is interpreted (Poynor 62). Works and Designers Kienholz, Edward. The Birthday. 1964. History of Art. 8 March 2011, http://www.all-art.org/art_20th_century/kienholz1.html The paradox of the ideas of this American artist made him recognizable within a short period of time. He tried to underline the complexity of modern life and human inability to control it properly. Saar, Lezley. White Face. 1997. History of Art. 8 March 2011, http://www.all-art.org/art_20th_century/saar1.html Various ideas are offered by the painters and designers from postmodernism era. Saar is the representative of African-American visual assemblage. In his works, he underlined the complexity of modern life and the necessity of human mind to accept huge amounts of information. Tinguely, Jean. Baluba III. History of Art. 8 March 2011, http://www.all-art.org/art_20th_century/tinquely1.html Tinguely was a Swiss painter, sculptor, and the developer of kinetic art in a variety of Dada traditions. De centering of a subject was probably the main idea supported by the creator in his work Baluba III. What he tried to present is a complex image that promote the power imagination of the public. Bury, Pol. 19 Boules sur 3 Plans Courbes en Ancier. History of Art. 8 March 2011, http://www.all-art.org/art_20th_century/bury1.html The Belgian sculptor offers his ideas in various forms, and one of them is the eternity of the modern life. It is hard to define the beginning and the end, and the works by Bury reflects this idea in a good way. People cannot always stop the moment and enjoy it to its full extent, and the attempts of Bury show that the moment may be caught. Rickey, George. Weathervane. 1976. History of Art. 8 March 2011, http://www.all-art.org/art_20th_century/rickey1.html Another attempt to explain the complexity of life and human choice was made by the kinetic sculpture from the USA. His idea to use the definite forms and unite them into something abstract attracted the attention of many critics and made the sculpture popular in the chosen field. Rotella, Mimmo. Untitled. 1958. History of Art. 8 March 2011, http://www.all-art.org/art_20th_century/rotella1.html The achievements of an Italian artist, Mimmo R otella, are known around the whole world. His decollage and psychogeographics works improve considerably the idea of poster presentation. Though not all his works are understandable to the public, his contribution is still regarded as crucial. Berman, Wallace. Untitled. 1967. History of Art. 8 March 2011, http://www.all-art.org/art_20th_century/berman1.html The works by an American West Coast Visual artist introduce the idea of repetition that is noticeable in everyday life. His attitude to the art makes it possible to understand that de centering of an image is not an obstacle in postmodern art but a possibility to define a variety of aspects of modern continuity. Spoerri, Daniel. Prose Poems. 1959-60. History of Art. 8 March 2011, http://www.all-art.org/art_20th_century/spoerri1.html A Swiss artist from Romania contributed a lot the sphere of art in the second half of the 20th century. He showed how the trend of complexity of the art forms may be disclosed in the vast majority o f his works. It is not enough to pay attention to one subject only but try to integrate several various ideas into the one whole. Arman. Red Tubes of Paint. 1980. History of Art. 8 March 2011, http://www.all-art.org/art_20th_century/arman1.html The French-born artist became popular in America. He used art objects as paintbrushes in order to organize the process of painting itself. The more objects are considered in one work, the massive the whole image is. Swierzy, Waldermar. Polish Poster. 8 March, 2011. http://www.polish-poster.com/waldemar-swierzy-3.htm The peculiar feature of many works of this artist is the attention to folk forms of art and the desire to promote inspiration in the public. The typography field introduced by the designer was characterized by the possibility to change forms and to create the reality that has to be accepted. Works Cited Arntson, Amy. Graphic design basics. Belmont, CA: Cengage Learning, 2007. Print. Barnard, Malcolm. Graphic design as communicat ion. New York: Routledge, 2005. Print. Heller, Steven. The education of a graphic designer. New York: Allworth Communications, 2005. Print. Meggs, Phillip, B. and Purvis, Alston, W. Meggs’ history of graphic design. Hoboken, NJ: J. Willey Sons, 2006. Print. Poynow, Rick. No more rules: Graphic design and postmodernism. London: Laurence King Publishing, 2003. Print. This essay on Graphic Design: Timelines was written and submitted by user Guadalupe Thornton to help you with your own studies. You are free to use it for research and reference purposes in order to write your own paper; however, you must cite it accordingly. You can donate your paper here.

Preparation for professional practice. The WritePass Journal

Preparation for professional practice.   INTRODUCTION Preparation for professional practice. ) concluded that a lack of awareness and understanding in an organisation’s nursing management theories have shown that the way in which an organisation is managed can affect nurses’ confidence to communicate the need for change. Maddock (2002) argued that the approaches to change and the proposal thereof may be ineffective unless individuals’ management strategies are put in place to develop leaders.   ACCOUNTABILITY/ RESPONSIBILITY According to Marquis et al. (2009) one of the legal requirements of a registered nurse is accountability. Scrivener et al. (2011) identified that accountability involves the ability of the nurse to define every action he/she carries out. The (NMC, 2008) emphasised that   accountability is seen as being of great importance and a qualified nurse is accountable for his/her own actions such as supervision, delegation, creative acts, intervention, assessing a situation or follow-up concerns. NMC (2008) further explained that the entire health care professionals are accountable and responsible for any action, error or omission made in practice. Huber (2006) states that as members of a multidisciplinary team, nurses must maintain their professional accountability. Nurses should also be able to use their communication skills to make complicated information understandable, explain choices, offer reassurance, look out for side-effects and liaise with medical colleagues about the subsequent p rogress of individuals with mental health problems (Garon, 2012). This was seen as a critical aspect of the operation here with regular reviews being planned to evaluate the success of the change and to amend the program where appropriate. Furthermore, if a nurse is meant to delegate care to another professional or support worker, she/he must delegate effectively and should be accountable for the appropriateness of the delegation. During one of the author’s practice placements in the acute ward, a newly qualified nurse delegated the task of security nurse to an agency staff who was very new on the ward. This agency staff let one of the patients out of the ward, not knowing that the patient was on level 1 observation restricted to the ward and the patient absconded from the unit. This resulted in an investigation which revealed that the newly qualified nurse did not delegate the task properly and did not communicate effectively. This raised the question of accountability and responsibility. The specifics of the nurse’s role are identified as being responsible for assessment, planning, the delivery of care and the evaluation of nursing care for their patients (NMC, 2008). According to RCN, 2011), nurses are accountable and responsible, on a daily basis, carrying out patient care most of the time and acting as care provider. Nurses have the responsibility for communicating the relevant information necessary for the patient to receive their full nursing care provision (NMC, 2008).  Ã‚   (RCN, 1992) also states that with an increase in the level of responsibility and accountability, nurses need adequate training and competence to develop these changes. It is the responsibility of the nurses to make sure that patients are suitably dressed and eat their meals, while also managing their welfare rights and dealing with individuals’ psychological distresses; theses roles have to be carried out in conjunction with running organisational demands (RCN, 2011). INTER-PROFESSIONAL COLLABORATION Orchard et al. (2005) described inter-professional collaboration as a combination of different professionals working together in a partnership in order to achieve common goals, establish a therapeutic relationship, showing respect for others and the skilled therapeutic use of self. On the other hand, inter-professional collaboration means the adoption of multi-disciplinary and multi-agency working as the most effective route towards comprehensive mental healthcare (Audrey, 2003). However, Garon (2012) states that when talking about change in inter-professional collaborative team work, it is important to consider how staff members would need to be motivated to accept and welcome this change. It is also very important to select the right leader, which was a key advantage of this approach, to implement the change and involve all team members in the change process, as well as considering the safety of the patients, their comprehensive care and the stress the change might cause (NICE, 200 7b). CONCLUSION During this implementation of â€Å"Protected Mealtimes†, all the team members on the ward worked collaboratively, demonstrated excellent communication skills, showed motivation and were very enthusiastic and committed to the plan. Word count: 2,200. PART 2 THE PROFESSIONAL DEVELOPMENT PLAN (PDP) The purpose of writing this professional development plan is to think and reflect on a facet of the professional development experienced by the author during their three-year course. It will also enable the author to work efficiently and effectively in their areas of weakness and help   to sustain areas of strength, as well as developing delegation skills in the nursing environment, upon qualification. In order to accomplish these goals, a plan utilising SMARTER theory (Specific, Measurable, Realistic, Timely, Ethical and Recorded/ Reflective (Appendix 1) is proposed. During the three years of nursing training, the author of this essay has utilised Gibbs Reflective Cycle (1988), as a framework for reflection on day-to-day actions, strengths and weaknesses. According to Brechin (2000), reflection means not only thinking about a situation, but also using it as a form of systematic appraisal of the events that have occurred and as an examination of an individual’s ability to le arn from the experience and influence future practice. During this placement in the acute ward, the author discovered that delegating duties to staff when co-ordinating shifts was a far more complex issue than originally anticipated. The RCN (2006) described delegation in nursing as a process of entrusting or allocating responsibility to another person who is seen as being able to carry out such a task. The Nursing and Midwifery Council (2008) states that a nurse’s   job cannot be completed or carried out without delegating some part of the care functions to others, as it is highly impossible to deliver total care for different patients with different care needs. Barr and Dowding (2008) in their research emphasised that delegation is a critical leadership skill that must be learned. This became evident when considering a situation which emerged when dealing with a violent patient in a ward environment. In order to delegate tasks relating to this individual it was necessary to use confidence, communication, courate, compassion, competence and care. On the whole this was doen relatively well by myself however it was found that the newly qualified staff nurse is more likely to be unfamiliar with the procedure delegated to him and this made communication a more vital so that guidance could be obtained. Having identified a weakness in the authors ability to delegate, this communication between the two parties in the case mentioned above was used as a clear example of how greater comfort from the process of delegation could be obtained. This would in turn improve confidence. By watching delegations within the ward environment it became apparent to the author that there were greater difficulties when the manager used the autocratic style and this often created hostility amongst other staff and may hinder creativity and improvement. This brought the manager’s delegation skills into question. There was also an increased danger that the more junior member of staff would find themselves unsupervised in an inappropriate and unacceptable way according to RCN (2011). This leadership style as described by Bass 2008 as creating difficulties. Where better delegation communication were used the author was much more comfortable with the delegation process as they were aware that the process would be used appropriately and would be successful. With this in mind the PDP going forward would focus on risk management and controlling the process without following an autocratic style which would lead to loss of control when delegating. CONCLUSION The author of this essay has learned from undertaking this assignment that delegation not only saves time, but is also an essential skill which a registered nurse must posses; it is also requires good leadership and is an important role for every nurse involved in health care delivery. Through this Personal Development Plan (PDP), personal areas of weakness have been identified which the author is currently striving very hard to correct.   REFERENCE LISTS Allan, E., 2007. Change management for school nurse in Scotland. Nursing Standard. 21, (42) 35-39. Allan, E., 1988. Planning a psychiatric intensive care unit. Intensive Care for people with serious mental illness. Hospital and Community Psychiatric, Vol- 39. Bass, B.M., 2008. The Bass Handbook of leadership: Theory, Research and Managerial Applications. 4th ed. New York:   Free Press. Bass, B.M., and Avolio, B.J., 1994. Improving organizational effectiveness through transformational leadership. London: Sage. Braine, M., 2006. Clinical governance: applying theory to practice. Nursing Standard. 20, (20) 56-65. Brechin, A., 2000. Introducing critical practice. In Brechin, A., Brown, H. Eby, M., eds. Clinical practice in Health and Social Care. London: Sage Cummings, J., 2012. Developing a Vision and Strategy for Nursing, Midwifery and Care- Givers, tinyurl. Com/c89xe4x [Last accessed:   May 2 2012]. Cherry, B., and Jacobs, S., 2995. Contemporary Nursing: Issues trends and management. 3rd ed. Elsevier: Health Science. Christie, P., and Robinson, H., 2009. Using a communication framework at handover to boost patient outcomes. Nursing Times, 105,(47) 13-15. Crevani, L.,Lindgren, M., Packendororff, J., 2010. Leadership, not leaders: on the study of leadership as practices and interactions. Scadinavavian Journal of Management. 26 (1)77-86. Cummings, G., Lee, H., Macgregor, T., 2008. Factors contributing to nursing leadership: a systematic review. Journal of Health Services. Research and Policy. 13(4) 240-248. Department of Health, 2008. Code of Practice: Mental Health Act 1983. London: DoH. Doran, G.T., 1981. There’s SMART way to write management’s goals and objectives. Management Review. 70, (11) 35-36. Food in Hospitals National Catering and Nutrition Specification, 2008. [Last accessed on 30 May 2013]. Garon, M., 2012. Speaking up, being heard: registered nurse’ perceptions of workplace communication. Journal of Nursing Management. 56, (2) 35-39. Green, T., Heath, I., 2010. Measuring Relationship. London: The King’s Fund. Gibbs, G., 1988. Learning by doing: A Guide to Teaching and Learning Methods. Oxford Further Education: Oxford. Hersey, P., Blanchard, K.H., and Johnson, D.E., 2001. Management of organizational behaviours: leading human resources. 8th ed. Upper Saddle River, NJ: Prentice- Hall. Huber, D.L., 2010. Leadership and nursing care management.4th ed. Maryland Heights: Saunders Elsevier. Huber, D.L., 2006. Leadership and Nursing Care Management. 3rd ed. Lowa. The University of Lowa: The University of Lowa. Maddock, S., 2002. Making modernisation work: new narratives change strategies and people management in the public sector. International Journal of public Sector Management. 15, (1) 13-43. Marquis, B.L., and Huston, C.J., 2009. Leadership roles and management functions in nursing: theory and applications. 6th ed. London: Wolters Kluwer Health/ Lippincott William and Wilkins. McConnell, C.R., 2007.   The effective Health care Supervisor. 6th ed. Sudbury, MA: Jones and Bartlet Publishers. McKimm, J., and Held, S., 2009. The Emergency of Leadership Theory: From the Twentieth to the Twentieth-First Century. In: McKimm, J., and Phillips, K., eds. 2009. Leadership and Management in Integrated Services. Exeter: Learning Matters. Ch1. National Institute for Clinical Excellence, 2007b. How to change practice. London: NICE. National Institute for Innovation and Improvement, 2013. NHS Change Model: Our Shared Purpose. Tinyurl, com/bwefn79 [Last accessed: May 2 2013]. National Patient Safety Agency 2007.Protected Mealtimes review Findings and Recommendations Report. Nursing and Midwifery Council, 2008. The Code: Standards of Conduct, Performance and Ethics for Nursing and Midwives. London: NMC. O’Connell, B., Macdonald, K., and Kelly, C., 2008.Nursing handover: time change. Contemporary Nurse. 30 (1) 2-11 Creating a Culture for Interdisciplinary. Orchard, C.A., Curran, V., Kabene, S., 2005. Creating a Culture for Interdisciplinary. Collaborative Professional Practice. Medical Education. Rolfe, P., 2011. Transformational leadership theory: What every leader needs to know. Nurse Leader. 9, (2) 54-57 Royal College of Nursing. 2012b Health and Social Care Act 2012. Tinyurl.com/HealthSocialCareAct2012 [Last accessed May 9 2013]. Royal College of Nursing, 2011. Accountability and Delegation: What you need to know. Royal Collage of Nursing. London:   RNC. Rosener, J.B., 1990. Ways women lead. Harvard Business Review. In Barker, P., 2009. Psychiatric and Mental Health Nursing. The Craft of Caring. 2nd ed. London: Hodder Arnold. Scrivener, R., 2011. Accountability and Responsibility: Principles of Nursing Practice. Nursing Standard, 25, (29) 35-36. Scott, L., and Caress, A.L., 2005. Shared governance and shared leadership: meeting the challenges of implementation. Journal of Nursing Management, 13(1) 4-12. Tomey, A.M., 2009. Guide to nursing management and leadership. 8th ed. St Louis, MO: Mosby/ Elsevier. Yoder-Wise, P., 2011. Leading and Managing in Nursing. 5th ed. St Louis: Elsevier Mosby. APPENDIX- 1  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   S.M A.R.T.E.R PLAN          SPECIFICS   Ã‚   Within six months of the preceptor-ship course, there will be a need to build better confidence that will improve communication skills which will support the author in their nursing career. MEASURABLE How can one ascertain that the intended outcomes have been achieved? The learning outcomes will be gained via the professionals consultants, occupational therapist, staff nurses and preceptor-ship mentor involved. The author is confident that these professionals have the necessary assertive skills that will help achieve the desired learning outcomes. Achievable The intention is to attend training courses, discuss any difficulties experienced with the preceptor-ship mentor or manager of the ward or any member of staff, and integrate the proposal as advice. REALISTIC Within three months of completion of the nursing course, it is anticipated that the author will be able to demonstrate effective leadership, delegating tasks properly, and entrusting responsibility to a person who is perceived as being able to carry out these tasks by utilising one’s newly gained assertiveness skills. TIMELY   Within three months of registration, an evaluation of achievements will be carried out and competencies will be examined frequently by the preceptor-ship mentor. The aim is to be constantly monitored by members of the team and to reflect upon performance and the impact of these actions. If there are any obstacles to achieving these goals or any concern from the team about the author’s approach, these issues will be discussed with the preceptor-ship mentor or ward manager, as this will facilitate the development of ongoing skills.       ETHICAL Being knowledgeable about ethical issues such as social and cultural, rights, confidentiality and being aware of how this might impact on one’s practice. As a nurse there is a need to ensure that the patient’s autonomy is respected.    RECORDED/REFLECTIVE Reflection on personal strengths, weaknesses, opportunities and threats (SWOT), on a regular basis.                      Appendix 2 – SWOT Analysis    MY STRENGTHS The SWOT analysis has helped me to develop, maintain a learning environment in which both education and lifelong learning are seen as integral to clinical setting, to work and focus on the goals and strategies, enable me to grab the opportunities I would love to achieve and work very hard to reduce my weakness and increase my strength. With the aid of SWOT analysis, I have been able to identify my strength as being a good team player, good listener, a good communicator and interacting well with my colleagues and patients. Showing compassion to my patients and having the ability to work under pressure. I like taking the lead and I am always happy when people appreciate me, it makes me happy and also motivates me.                MY WEAKNESS I identify my weakness as being easily distracted, tending to carry out many tasks at a time and I am always fearful of making mistakes.   I also felt that there are some areas I lack leadership skills such as being a good delegator because Barr and Dowding (2008) in their research emphasised that delegation is a critical leadership skill that must be learned. I find it complex to delegate duties when coordinating shifts. OPPORTUNITIES My opportunities are to update my knowledge in relation to the new pre-registration courses which include existing educational, personal and professional career development within the establishment.   During this my practice placement I also had the opportunity to learn and share ideas with my colleagues, had the opportunity for questioning and giving feedback. THREATS My threats   Ã‚  are whilst on this practice placement, I found some areas very stressful.   I discovered that some of the mentors were unfamiliar with the new- pre registration programme and unaware of the needs of the nursing students in relation to the learning opportunities or activities . Appendix 3   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Service Improvement Activity – Notification Form Student Details Student SID Number: 0820968 Details of student pledge on which the proposed improvement is based. I must treat individuals kindly and considerately.   I will provide a high standard of practice and care at all times. I will respect individuals’ confidentiality. I must show compassion and unconditional positive regard to my clients. I must disclose information, if I believe some one may be at risk of harming him/her self in line with the law of the country in which I am practising. I must listen to individual in my care and respond to their concerns and preferences. Details of proposed service improvement project/activity: The service improvement initiative is to facilitate Protecting Patient Meal Time in the Psychiatric Intensive Care Unit (PICU).   The purpose of this service improvement is to help and manage mealtimes without unnecessary and avoidable interruptions. Mealtimes are not only a vehicle to provide patients with adequate nutrition, but also provide an opportunity to support social interaction amongst patients. Reason for development: During my practice placement in the PICU. I discovered that there have been a lot of interruptions and argument between some patients and staff during meal time and also staff members who supposed to assist during meal time always claimed to be very busy. This made me choose to introduce to the team about â€Å"Protected Mealtimes†.   This development is to support those patients who were finding it very difficult to eat or drink. Time spent on the project/activity: The service improvement lasted for the period four weeks because I first and foremost had the meeting with the multidisciplinary team members before introducing the change to the patients. Resources used: National Health Service (NHS boarder) Evidence on topic relating Protecting Meal Time Information from in the internet. Policy and regulation from the trust Text book Some information from dietician. Who will be involved? The ward consultant My mentor as a nursing staff, Occupational therapist staff Support worker The ward manager The dietician Myself( a student nurse) Future plans: The future plans are for me to distribute leaflets to the other professionals for them to read it in the internet and be awareness of the protecting meal time. Date discussed with clinical staff in placement area:

Mental health promotion workshop Literature review

Mental health promotion workshop - Literature review Example Aside from incorporating the concept of interpersonal variables, Health Promotion Model can be use to predict people’s behaviour concerning health promotion which increases the healthcare workers’ ability to deal with people with mental health problems (Allender, Rector and Warner, 2014, p. 370). Precede and Proceed Model makes it easier for healthcare workers to â€Å"plan, implement, and evaluate the effectiveness of health promotion programmes (p. 370). Under the precede model include social issues, epidemiology of certain illness, education, policies, and implementation whereas the proceed model include process, impact, and outcome evaluation (Allender, Rector and Warner, 2014, p. 370). Completing the report on mental health promotion made me able to develop some strategies that are effective in treating patients with cognitive, behavioural and affective problems based on the SMART criteria. 1. By the end of July 2014, the administrator of a couple of nearby schools will be approached for permission to conduct mental health teachings to the students’ parents. After communicating with the school teachers, a schedule will be set whereby the students’ parents will be invited to attend child development programme within the school vicinity. 2. By end of September 2014, social networking site like Facebook will be used to communicate with parents who are interested in learning more about strategic ways on how to prevent the long-term consequences of childhood abuse and neglect. Child Welfare Information Gateway. (2013, July). Long-term Consequences of Child Abuse and Neglect. [Online] Available at: https://www.childwelfare.gov/pubs/factsheets/long_term_consequences.cfm [Accessed April 13, 2014]. Every Child Matters. (2010, September 6). Effective communication with children, young people and families.[Online] Available at:

Homicide and Criminal Justice Term Paper Example | Topics and Well Written Essays - 500 words

Homicide and Criminal Justice - Term Paper Example As noted by Fox and Jack (2001), homicide is considered excusable if death results from a mistake that cannot be described as sufficient to declare someone guilty. An example of excusable homicide is a road accident that leads to death but does not result from driver’s serious negligence. Justifiable homicide is the acceptable killing of a person (Fox & Jack, 2001). For example, a person can kill another person in self-defense or soldiers can shoot and kill members of enemy camps without committing criminal offenses. Acceptable killing is also called non-felonious homicide (Fox & Jack, 2001). On the other hand, felonious homicides – also known as criminal homicides - comprise of two broad forms of illegal killing (Fox & Jack, 2001). In this regard, as pointed out by Fox and Jack, a felonious homicide that is not premeditated is called manslaughter in most US states. The worst form of homicide called murder is a criminal act in which a person’s meditation to kill leads to the actual killing of another person (Fox & Jack, 2001). In some states, criminal homicide is classified in terms of degrees depending on circumstances under which killing takes place. A person can bear murder related responsibilities in two ways (Arafa, 2008). First, an individual can only bear criminal liability for murder if he or she intended to kill and actually killed another person. However, according to Arafa (2008), sometimes people can bear criminal responsibilities for crimes they did not commit. In this regard, a person who assists or encourages the commission of murder bears accomplice responsibility. A person can only be an accomplice in the murder case if he or she wanted the killed person to die and would bear responsibility for any other crime committed as a result of the commission of the original crime (Arafa, 2008).

Why did Progressive reformers believe it essential to curb the power Essay

Why did Progressive reformers believe it essential to curb the power of American capitalism Were they right - Essay Example Reformers comprised of both women and men emanating from various social classes, occupations as well as races who felt regime’s traditional attitudes were inapplicable comparable to harsh conditions, which Americans during then experienced on daily basis. This was contrary to what the then government, which through the constitution claimed to offer its citizens. During then, Americans were not only experiencing poverty due to permanent wage limit policies but also majority working in extremely deplorable conditions coupled with child labor. Therefore, social, economical and political inequalities convinced Progressive Reformers into believing their quest in curbing American capitalism was right, which I also concur with due to the then inapplicable policies whose aim encompassed protecting only the well-heeled people. Reformers in their quest to ensure welfare of the entire public, â€Å"revolted† to end inefficiencies in the central regime, corrupt political machines a nd improving people’s living standards. ... because they believed that the government should be made up of the working-class people (Lecture notes, 7 October 2013).† Since, this will ensure equality in the entire state besides preventing the affluent from exploiting less privileged people, which is contrary to what they did before inception of new rules through influencing economic policies in their favor. Industrial moguls due to the regime’s laxity and numerous benefits, which they enjoyed while in their quest to augment respective profitability rates, resulted to processing poor quality products to the then unsuspecting consumers. Hence, plants exposing lives of numerous unsuspecting citizens to risks especially food industry, which supplied low quality, canned meat. This is evident in Sinclair’s book citing how plants processing meat, â€Å"†¦..it was the custom, as they found, whenever meat was so spoiled that it could not be used for anything else, either to can it or else to chop it up into sau sage† (Sinclair 164). Consequently, revealing utter state of inhuman on the part of industrial moguls who employed chemistry tactics to process meat that had decayed. This was by rubbing meat with soda to eliminate bad odor and sell it to free lunch counters where ordinary citizens used to frequent (Sinclair 164). Consequently, this prompted to the institution ofâ€Å"†¦.The Meat Inspection Act strengthened requirements for sanitary conditions in packing houses and required the inspection of meat for interstate commerce (Mooney, 71)†. The aim of this act ensured the quality of meat supplied to the consumer was of good condition besides meeting the already set standards outlined by regime. Reformers felt the state during then had to be free from any sinister influences whereby their ambitions aimed at

The causes and effects of torture in prison

The causes and effects of torture in prison Prison Torture explains the harmful consequences that prison torture can cause to the detainees and why it should be abolished. The first part of this paper discusses the common causes of prison torture in which the most known is obtaining confidential information from criminals. The second part of this paper reflects the physical consequences of the prisoner during the process of torture. The third part explains how the experience of being tortured can lead to post-traumatic psychological disorders and other issues. This traumatic disorder could eventually intervene in the individuals behavior towards the society. In brief, torture in prison may generate results that could be even worse than the crimes committed by prisoners and therefore it should be banned. Introduction There are deplorable insights on the realism of life within prisons in the United States and around the world. Sadistic actions and treatment that are almost similar happen in all prisons evoking a lot of debate from human rights activists among other concerned bodies on the magnitude of torture in prisons. Torture varies in different prisons but at the end of the day, the human rights of a prisoner are violated. Some corrective institutions release prisoners to fierce dogs and they are savaged for about half an hour or so, other torture methods include electrocuting with Cattle Prods which is very traumatizing, in some cases a prisoner is burned by highly toxic or corrosive chemicals, among other barbaric abuse. Looking in the societal context a prisoners are considered to have little powers as long as they are behind bars. This explains why a prisoner is the most vulnerable to torture. Although a prisoner finds himself or herself behind bars owing to wrongdoing or breaking laws of a given society they are viewed as isolated people; who deserves to be deprived their freedom or liberty hence they are well placed in prisons. A common cause of prison torture is in a case where a prisoner is abused to obtain confidential information from him, this is common in war crimes, terrorism, or crimes against the state for instance treason. In some States, a prison or a corrective institution may choose to use torture on culprits in case they want to curb serious crimes like illegal movements and cults, drugs networks etc. Criminals netted in relation to specific crimes are tortured to a point of confession. American criminal judicial system is extremely ineffective, expensive, and revoltingly merciless with a rich history with racism. Most city departments are famous for their notorious brutality hence there is a record of over 2 million people in corrective or federal facilities; while other 3.5 million are placed under other types of social control like community service. For this reason Americans reformists came up with modern prisons in support of anti torture policies; they argued that even hard-core criminals would reform by imprisonment alone, hard labor and contrition. Although slavery was not legitimized, captives were punished for crime (Jared Elizabeth, 2006). Following the Abu Ghraib military prisoner torture and abuse scandal in the year 2004, prison torture was redefined since so much was revealed through leaked video tapes (Jared Elizabeth, 2006). Therefore many independent observers and researchers went ahead to explore the activities of torture in various prisons around America. It was evident that most prisons used similar or closely related ways of torture. Study shows that the brutality prisoners are exposed to leave irreversible physical and psychological scars or even cause death. In cases where prison officials use toxic chemicals on prisoners, it is obvious severe physical disfigurations may occur due to burns and erosion of flesh by the harsh chemicals some victims burn to death. Some prisons deprive the torture victims medical attention even after inflicting wounds on them. Moreover some prisons avail medical care which either is too little or too late. Other institutions may choose to have dogs that are released to prisoners in an enclosure and they let them savage on the prisoner causing so much pain and even loss of limbs or other body parts. Ruthless beating and kicks may cause fractures and cuts, which may worsen if they go untreated at times, they rot and a prisoner ends up losing the fractured part of the body. Some officers are so radical that they may choose to amputate a prisoner without anesthesia. The most common method of torture in prisons around the world is the electrocution using cattle prod; this can cause severe brain damage. Sexual abuse takes place every day in almost every prison in the world this is a form of torture from prison officials or fellow prisoners who may be forced to engage in sodomy, homicide and other inhumane acts like rape (Gebhardt, 2004). There are episodes in life that cannot be erased from the mind of a human being; Thus Personal experiences can make or damage the life of a prisoner. In most prisons the criminals are tortured before their fellow inmates hence their counterparts may see a prisoner tortured to death, their lives are filled with fear and anxiety and it is likely to find them hallucinating or they are rendered in permanent shock. Psychological and Social consequences are very common in victims of prison torture psychological outcomes include conditions like Post-traumatic psychiatric where a victim may have experienced a brain injury or brain trauma. This is symbolized by changes in personality traits, disorientation, confusion and at times impaired memory (Dylan, 2006). A victim of prison torture may never be able to interact freely with the people around him or her. This due to various factors that affect them from low self esteem to dull emotional responses like sexual inappropriateness especially if sexually abused, paranoid, aggressiveness etc A person who has experienced prison torture may change or may not change their lifestyle of crime; this could be because of general outlook of life. Some tend to harden and even become hardcore criminals than they were before. They develop a tendency to hate on law enforcers and all they want is to associate with criminals and rebels. Their relationship even with family and friends deteriorates since they feel unwanted. Many a times they may have episodes of their lives in their mind and they may do weird things like screaming, nightmares, wailing, or even trying to fight back; so they prefer staying alone (Coltheart, 2009). Torture might be a method used to gain information and to punish prisoners for decades, but we have to consider the use of other procedures. Torturing should also be considered as a crime, because the torturers behavior of causing pain and simulating death is an unethical process used by criminals as well. Revisiting the infamous horrors of Nazi prisons, which was discovered after the World War II; it really enhanced awareness all over the world about the extensive use of torture to get information from prisoners (Zinger, 2006). Movements such as World Medical Association (WMA) emerged in 1947 following protests and mission to curb torture and other cruel penal approaches used on prisoners. According to (Burgers Mark, 1994) the United Nations further endorsed conventions against torture of prisoners that are in place until today. It defines torture as any act by which severe pain or suffering. This may be physical or mental and intentionally inflicted on a person for such purposes as obtaining from him or a third person information or a confession. It is aimed at punishing him for an act he has or is suspected of having committed. It can also be aimed at intimidating or coercing him or a third person for any reason based on discrimination of some kind. when such pain or suffering is inflicted by or at the instigation of or with the consent or acquiescence of a public official or other person acting in an official capacity. It does not include pain or suffering arising only from, or incidental to lawful sanctions (UN, 2007).Thus prison torture is illegal according to the international law.

lieshod White Lies in Joseph Conrads Heart of Darkness Essay

White Lies in Heart of Darkness      Ã‚  Ã‚  Ã‚   In his novella Heart of Darkness (1899), Joseph Conrad through his principal narrator, Marlow, reflects upon the evils of the human condition as he has experienced it in Africa and Europe. Seen from the perspective of Conrad's nameless, objective persona, the evils that Marlow encountered on the expedition to the "heart of darkness," Kurtz's Inner Station on the banks of the snake-like Congo River, fall into two categories: the petty misdemeanors and trivial lies that are common- place, and the greater evils -- the grotesque acts society attributes to madmen. That the first class of malefaction is connected to the second is illustrated in the downfall of the story's secondary protagonist, the tragically deluded and hubristic Mr. Kurtz. The European idealist, believing the lies of his Company and of the economic imperialism that supports it, is unprepared for the test of character that the Congo imposes, and succumbs to the potential for the diabolical latent within e very human consciousness. Although numerous critics (including Johanna M. Smith, Peter Hyland, Herbert Klein, and Garrett Stewart) have drawn attention to how Marlow's lie to the Intended informs the whole preceding text and how that culminating scene with the Intended is connected to Marlow's initial impression of Brussels as a whited sepulchre (how appropriate in light of Belgian King Leopold II's hypocritical defense of his private company's rapacious exploitation of the ludicrously- named Congo Free State!), few have until recently focussed on how the lie affects the reader's reaction to Marlow as the protagonist and narrator of Conrad's Congo tale. Answering questions which the dead man's Intended poses him reg... ... Rosmarin, Adena. "Darkening the Reader: Reader- Response Criticism and Heart of Darkness ." Joseph Conrad, Heart of Darkness: A Case Study in Contemporary Criticism , ed. Ross C. Murfin. New York: St. Martin's Press, 1989. Pp. 148-171. Smith, Johanna M. Smith. "'Too Beautiful Altogether': Patriarchal Ideology in Heart of Darkness ." Joseph Conrad, Heart of Darkness: A Case Study in Contemporary Criticism , ed. Ross C. Murfin. New York: St. Martin's Press, 1989. Pp. 179-198. Stewart, Garrett. "Lying as Dying in Heart of Darkness ." PMLA 95 (1980): 319- 331. Trilling, Lionel. " Huckleberry Finn ." The Liberal Imagination: Essays on Literature and Society . New York: Doubleday Anchor Books, 1950. Pp. 100-113. Wright, Walter F. "Ingress to The Heart of Darkness ." Romance and Tragedy in Joseph Conrad . New York: Russell and Russell, 1966. Pp. 143-160.

Media & Invasion of Privacy

LAGOS STATE UNIVERSITY SCHOOL OF COMMUNICATION A TERM PAPER SUBMITTED IN PARTIAL FULFILLMENT OF THE COURSE: ETHICS AND PROFESSIONAL PRACTISE (MAC 854) LECTURER: DR. JIMI KAYODE TITLE: MEDIA AND THE INVASION OF PRIVACY BY AKANDE ADEFEYISAYO ADEBOLARINWA †¢ SUBMITTED ON 30th JANUARY, 2010 INTRODUCTION Media practitioners possess the function of gathering, processing and disseminating news item to a heterogeneous large audience which often times not done with sound moral judgement in mind lands them into pool of troubled waters. Celebrities, politicians and other sought-after sources of news have over time expressed justifiable anguish over the diminishing aspects of their lives that are no longer free from prying eyes and publication from the press. They routinely assert that members of the media violates their privacy based strictly on their need to publish any news story that comes their way for the main purpose of profit and simply can not distinguish what type of information is private, public or newsworthy. Journalists, however, often possess diverse concepts of privacy and newsworthiness, and know that the issue is more complicated based on the fact that reporting news stories in a way that serves and informs the public will often require publicizing details or displaying images that will mortify or anger someone. To make privacy issues even more complicated for journalists, courts constantly redefine what is private based upon interpretations of the elusive legal standard of a â€Å"reasonable expectation of privacy. ( www. winning-newsmedia. com/privacy) â€Å"The U. S. Supreme Courts scolding of the media in the 1999 â€Å"ride along† cases for a perceived inattention to the privacy rights of the people featured in the news most likely reflects the current attitude of many judges and lawmakers and, thus, underscores the importance for journalists to be aware of general privacy principles. † (www. associatedcontent. com/topic) The intrusion and publication of private images can expose journalists to overwhelming financial liability if a court determines that a news organization has invaded a person’s privacy. The invasion of another’s privacy is a tort, meaning a civil wrong against another that results in injury. A privacy tort occurs when a person or entity breaches the duty to leave another person alone. When reporters intrude on a person’s privacy and cause emotional or monetary injury, they may be forced to pay damages. To avoid lawsuits, journalists must know how the law operates while seeking to balance the competing interests of the press and the public against the privacy interests of the subjects of the reports. Journalists often run contrary of this tort through the process of gathering information. Actions that may violate this privacy right include intrusion onto private property, concealed observation and the deceptive access into private areas. Conduct that invades privacy may also violate the criminal law. In general, courts have held that journalists must obey all relevant laws. In Cox Broadcasting Corp. v. Cohn, 420 U. S. 469 (1975) â€Å"the U. S. Supreme Court noted that in privacy tort, claims of privacy most directly confront the constitutional freedoms of speech and press†. www. definitions. uslegal. com) This study provides a universal explanation of each privacy tort and related causes of action. The privacy facts tort presents the unsettling circumstances in which journalists may be liable for monetary damages for coverage of news item. In several cases the Supreme Court has held that â€Å"where a newspaper publishes truthful information which it has lawfully obtaine d, punishment may lawfully be imposed, if at all, only when narrowly tailored to a state interest of the highest order. Florida Star v. B. J. F. , 491 U. S. 524, 541 (1989). Although the Supreme Court has prevented states from punishing journalists who published legally obtained names of juvenile offenders and rape victims, the Court has not absolutely rejected the private facts tort in this context. Although crimes such as rape are newsworthy and newsworthiness is a defence to a private facts suit, not all courts have agreed that the identity of a rape victim is newsworthy. Apart from news story either in the broadcast or in the print medium, photography has also been observed as posing some inimitable problems in privacy law, broadly, the legal analysis for invasion of privacy through images parallels the analysis for invasions through words. Essentially, the scope of this study is simply to analysis the fundamental nature of privacy laws, the various types that a mass media practitioner can run afoul of in the course of his or her duty and its implication for the society as a whole. Emergence of Privacy Laws: Concerns about intrusive newspaper reporting were mainly the beginning of the law of privacy. At that time, metropolitan daily newspapers used a variety of sensational information to attract potential readers. Media practitioners often played out the lives of the affluent and famous on the pages of their newspaper, permitting their readers to vicariously enjoy the wealth and the status of the celebrity. It was the kind of journalism now commonly referred to as â€Å"yellow journalism† that drove two Boston lawyers, Samuel D. Warren and Louis Brandeis to use the pages of the Harvard Law Review to recommend an officially documented right to privacy titled â€Å"The Right to Privacy† in 1890. Thus, their enterprise can be justifiably referred to as the source from which the law of privacy sprouted from. In their words as cited in Pember & Calvert, 2006: To satisfy a prurient taste the details of sexual relations are spread broad-cast in the columns of the daily papers. To occupy the indolent, column upon column is filled with idle gossip, which can only be procured by intrusion upon the domestic circle†¦Ã¢â‚¬ ¦.. The common law has always recognised a man’s house as his castle, impregnable, often, even to its own officers engaged in the execution of its commands. Shall the courts close the front entrance to constituted authority, and open wide the back door to idle or prurient curiosity? Warren and Brandeis strongly proposed that people should be able to go to courts to stop such unwarranted intrusions and also to secure monetary damages for the hardship or emotional distress they suffered from prying and from publication of private materials about them. The question of when the coverage and reporting of news became an invasion of privacy is a difficult one, especially for photographers and videographers. Consequently, the combination of a lack of clear definitions of privacy standards and an acceptance of degree of privacy puts media practitioners in a precarious position. In Sanders v. American Broadcasting Cos. , Inc. , 978 P. 2d 67 Cal. 1999, â€Å"the California Supreme Court held in 1999 that even an employee who holds a conversation in an open office space and overheard by co-workers can pursue an invasion of privacy claim if that conversation is recorded by a reporter’s hidden camera. The court rejected the notion of privacy as an â€Å"all-or-nothing† concept and described an â€Å"expectation of limited privacy† as follows: †¢ A subjective expectation of privacy is an opinion of a person that a certain place or situation is private. †¢ An objective, legitimate or reasonable expectation of privacy is an expectation of privacy recognized by society Under different circumstances, however, courts have established that news media are justified in doing what their subjects may feel is invasive. ( wikipedia: 2002) Definitions: According to the United Nations’ Universal Declaration of Human Rights Resolution 219A (III), Article 12 of 10 December 1948 as cited in Malemi (2002: 163): No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks. Privacy refers primarily to a person’s right to be left alone by the media, not necessarily a physical intrusion into one's private property or personal space. Invasion of privacy charges are usually presented in a civil lawsuit against media outlets that have crossed a perceived line into a celebrity or other public figure's private life, or have used his or her likeness or name in an unauthorized public manner Privacy law is the area of law concerned with the protection and preservation of the privacy rights of individuals. Increasingly, governments and other publics as well as private organizations collect vast amounts of personal information about individuals for a variety of purposes. The law of privacy regulates the type of information which may be collected and how the information may be used. The Right to Privacy: According to the 1999 Constitution of the Federal Republic of Nigeria, chapter IV, Section 37 on the right to private and family life says: â€Å"Citizens have right to privacy of themselves, their homes, correspondence, telephone and telegraphic communications. † A violation of this rights amounts to invasion of privacy. Remedies can then be pursued in the courts when anyone goes contrary to the above provisions. The right of privacy is a common-law cause of action that is a recent legal development. The U. S. Constitution contains no direct references to the right of privacy, although the Fourth Amendment states: â€Å"The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated†¦ † The right of privacy competes with the freedom of the press as well as the interest of the public in the free dissemination of news and information, and these permanent public interests must be considered when placing the necessary limitations upon the right of privacy. The First Amendment states: â€Å"Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech or of the press†¦ † â€Å"[pic][pic]Invasion of privacy, then is the intrusion into the personal life of another, without just cause, which can give the person whose privacy has been invaded a right to bring a lawsuit for damages against the person or entity that intruded. It encompasses workplace monitoring, Internet privacy, data collection, and other means of disseminating private information†. Photographers’ guide to Privacy, 2003). The wrongful intrusion into a person's private activities by other individuals, the media or by the government has generally been defined as invasion of privacy. Privacy is invaded when one intentionally intrudes, physically or otherwise, upon a person's solitude or into his private area or affairs. Invasion of privacy is considered a violation of to rt law and can be litigated inside the civil courts for monetary damages. Recently, invasion of privacy has taken on even greater meaning with recent technological advances. Bussian & Levine 2004 opine that: Whether an article or broadcast is newsworthy, whether the information was gathered in an objectionable fashion, whether truthful information is nonetheless highly offensive — all are considerations in weighing individuals' claims against the news media. Invasion of privacy is a tort, a civil wrong, which can lead to jury trials and potential claims for compensatory and punitive damages. It also places judges in the unfamiliar and uncomfortable role as â€Å"editors† of last resort. Celebrities are not protected in most situations, since they have voluntarily placed themselves already within the public eye, and their activities are considered newsworthy. Categorically, invasion of privacy or the intrusion into the personal life of another, without just cause, can give the person whose privacy has been invaded a right to bring a lawsuit for damages against the person or entity that intruded. Folarin, 2005:155 also agrees that the right to privacy is a legal means by which consumers can control media content through suits instituted against the media in defence of their right relating to invasion of privacy which includes insulation from needless publication of private matters. Also that people can sue any media that uses their names falsely. He asserts that the people who have little or no chance of winning most of the suits are acknowledged public figures who are generally assumed to have lost their to privacy by taking up public office or otherwise become public by being involved in a newsworthy act or incident. In distinguishing invasion of privacy among other claims facing the media, unusual situations involving crime victims and witnesses and also photographs of virtually anything visible in a public place do not give rise to actions for publication of private facts. Also facts that give rise to a false light claim may support a defamation claim while injury to reputation is not required for a false light claim. The false light tort aims primarily to protect against emotional distress rather than to protect one’s reputation. Based on First Amendment of the US constitution concerns, and the similarity between the claims, some states have not been persuaded to recognize the false light tort. However, public personalities are not protected in most situations, since they have placed themselves already within the public eye, and their activities (even personal and sometimes intimate) are considered newsworthy and are perceived to be of legitimate public interest. Dimensions of Invasion of Privacy: ) Intrusion on one's solitude or into one's private affairs includes: †¢ The Home: A person's home gets the highest protection from the courts. Entering a house or apartment without permission of the occupant or, in some circumstances, the police, can be considered as an unlawful intrusion. †¢ Photographs and Tape Recording: Taking photographs of a person or his property in a private place may be an invasion of privacy. Tape recording a person without his consent may also provoke damage awards. ) Public di sclosure of embarrassing private information such as: †¢ Personal Matters: Details about a private person's sexual relationships, the contents of personal letters, private facts about an individual, or other intensely personal matters are off-limits to the news media unless they are considered as absolutely newsworthy. †¢ Newsworthiness: Even truthful accounts are actionable if they contain highly offensive details which are not of legitimate concern to the public. ) Publicity which puts him/her in a false light to the public: †¢ Fabrication: Ascribing quotes or fictionalizing actual events can lead to invasion if a person is portrayed in a false light before the public. †¢ Photographs: Using photographs or films to illustrate a story that implies falsely that a person is involved in a disreputable incident. d) Appropriation of one's name or picture for personal or commercial advantage such as: †¢ Advertising: The unauthorized use of a person's name or photo graph in an advertisement is another immense subject in nvading people’s privacy. †¢ Property Rights: This happens when the press offers to give away unauthorized broadcasts or photographs of a performance. The Supreme Court in the United States has ruled that there is a limited constitutional right of privacy based on a number of provisions in the Bill of Rights and subsequent amendments. This includes a right to privacy from media surveillance into an area where a person has a â€Å"reasonable expectation of privacy† and also in matters relating to marriage, procreation, contraception, family relationships, child rearing and education. However, records held by third parties such as financial records or telephone call records are generally not protected unless a specific federal law applies. The court has also recognized a right of anonymity and the right of groups to not have to disclose their members' names to media agencies. (www. answers. com) Generally, it’s been considered that one ought to have a reasonable â€Å"expectation of privacy†, meaning: i. A place where a reasonable person would believe that he or she could disrobe in privacy, without being concerned that his or her undressing was being photographed or filmed by another; or ii. A place where one may reasonably expect to be safe from casual or hostile intrusion or surveillance. Given the similarity to voyeurism, an adjudicator might find that placing a hidden camera in a certain location may amount to the torts of indignation or deliberate infliction of emotional distress. Invasion of privacy laws are usually broken into four separate categories highlighted earlier including intrusion, appropriation, false light and public disclosure of embarrassing facts. Intrusion of Solitude: Intrusion of solitude, seclusion or into private affairs is an arm of invasion of privacy done by spying on or intruding upon another person where that person has the expectation of privacy. Places that a person ought to have an expectation of privacy are usually in a home or business setting. Consequently, people who have become public figures do not have the same expectation of privacy. A media practitioner, who intentionally intrudes, physically or otherwise, upon the solitude or seclusion of another or his private affairs or concerns, is subject to liability for invasion of privacy, if the intrusion would be highly offensive to a reasonable person. To be liable for intrusion upon seclusion or solitude, the plaintiff must prove the following elements: Invasion of a secluded place or privacy: this happens when the defendant is alleged to have invaded the plaintiff's personal or private space. This could be determined by: Physical intrusion into a place where the plaintiff has secluded himself. ) Use of the defendant's senses to eavesdrop or spy in order to oversee or overhear the plaintiff's private affairs or b) Some other form of investigation or examination into plaintiff's private concerns. Objectionable intrusion: this is the type of intrusion that would be highly offensive to the ordinary reasonable person. †¢ Invasion of private affairs or matters: the i nterference with the plaintiff's privacy must be substantial (however, if the event reported occurs in public, there is no expectation of privacy). Other examples of intrusion upon privacy include placing microphones or cameras in someone's bedroom or hacking into their computer. Society does not expect a journalist to place wiretaps on a private individual’s telephone without his or her consent. Opening someone's mail is also considered to be intrusion of solitude, seclusion or private affairs. The information gathered by this form of intrusion need not be published in order for an invasion of privacy claim to succeed. Trespass is closely related to the intrusion tort and may be claimed simultaneously. Intrusion claims against the media often centre on some aspect of the newsgathering process. This tort may involve the wrongful use of tape recorders, cameras or other intrusive equipment. Trespass also can be a form of intrusion. An actionable claim for intrusion may arise whether or not a news story is published or aired. (A photographer’s guide to privacy, 2003) Appropriation of Name, Likeness or Identity: The appropriation of a private person's name, likeness or identity by a person or company for commercial gain is prohibited under the invasion of privacy laws. However, this law pertains to a private figure and not a public figure or celebrities, who have fewer and different privacy rights. The Restatement (Second) of Torts Section 652C (1977) defines appropriation of name or likeness as follows: â€Å"One who appropriates to his own use or benefit the name or likeness of another is subject to liability to the other for invasion of his privacy. † (Bussian & Levine, 2004) Appropriation of name or likeness occurs when someone uses the name or likeness of another for their own advantage. Action for misappropriation of right of publicity protects against commercial loss caused by appropriation of an individual's personality for commercial exploitation. It gives the individual exclusive right to control the commercial value of his or her name and likeness to prevent others from exploiting that value without permission. It is similar to a trademark action with the person's likeness, rather than the trademark, being the subject of the protection. The appropriation category of invasion of privacy prevents others from using a person's name or identity for commercial gain. Ordinarily, the news media do not run afoul of this form of tort. However, seemingly harmless news coverage or advertisements can lead to lawsuits. This law came into existence from a couple of court decisions in the early 1900's where a private person's photograph was being used without consent for advertising purposes and without them receiving any monetary reward for using their pictures in print. The court recognized that the common law right to privacy including a person's identity had been violated by the unauthorized commercial use. In later cases, a person's voice was also included. Public figures, especially politicians do not have the same right to privacy as regards to appropriation of name, likeness or identity since there is much less expectation of privacy for public figures. Celebrities may sue for the appropriation of name, likeness or identity not on grounds of invasion of privacy, but rather on owning their own right to publicity and the monetary rewards (or damages) that come from using their likeness. False Light: As cited in Bussian , (2004) The Restatement (Second) of Torts Section 652E (1977) provides that: One who gives publicity to a matter concerning another that places the other before the public in a false light is subject to liability to the other for invasion of his privacy, if the false light in which the other was placed would be highly offensive to a reasonable person, and the actor had knowledge of or acted in reckless disregard as to the falsity of the publicized matter and the false light in which the other would be placed. Creating a false image for an individual may constitute an invasion of privacy. This is an aspect of invasion of privacy that deals with untruthful publication. In this instance, the offended person is placed in a false light through misleading descriptions, confusion of the person's identity with another, fictionalization of actual events, or photographs taken out of context. Its features are: It gives an individual unreasonable and highly objectionable publicity that attributes false characteristics, conduct or beliefs to him or her. The said material must be published to a third person or publicised to a large audience or to so many persons that the matter must be regarded as substantially certain to become one of public knowledge. The invasion of privacy tort of false light is upheld in court when the plaintiff can prove that the defendant publicize the plaintiff in such as way that it would be highly offensive to a reasonable person. However, it is pertinent to note that this tort shares many similarities with libel and many courts have trouble separating the two. Public Disclosure of Embarrassing Private Facts: Public disclosure of embarrassing private facts becomes an invasion of privacy tort when the disclosure is so despicable that it becomes a matter of public concern and it outrages the public sense of decency. In this invasion of privacy tort, the information may be truthful and yet still be considered an invasion if it is not newsworthy, if the event took place in private and there was no consent to reveal the information. The Restatement (Second) of Torts Section 652D (1977) provides that: One who gives ublicity to a matter concerning the private life of another is subject to liability to the other for invasion of his privacy, if the matter publicized is of a kind that (a) would be highly offensive to a reasonable person, and (b) is not of legitimate concern to the public. (ibid) The media can also be held accountable for damages for truthful publication. It is considered that the antisocial article or broadcast exposes to public view certain highly offensive matters that are not considered newsworthy. In order for an offended plaintiff to prevail, he must prove that the publication was: a) Extremely offensive to a reasonable person, b) And that the matters were not of legitimate concern to the public. The latter requirement may give the news media what might be called the newsworthiness defence. Though, the legal concern of the public in a matter is not presumed by the matter's publication. Thus, a plaintiff may prove that an article is lacking in newsworthiness despite its publication. Below is a good example: Case study: Publication of Embarrassing Private Facts Nollywood actress and 2005 Gulder Ultimate Search star, Anita Hogan, was reported to have lost a three-month-old pregnancy following the shock caused by the publication of her nude pictures in Daily Sun, an evening newspaper in 2006. Anita, according to her lawyer, was engaged to be married to a white man whose nude pictures were published along with hers in the Friday, August 11th edition of the newspaper. Police detectives in Lagos eventually arrested one Emeka Nwankwo, a computer engineer who allegedly circulated the shocking pictures to the media, after the actress rebuffed his alleged bid to blackmail and extort money from her over the lurid shots. The actress through her counsel explained that the computer where the controversial photos were saved developed a fault and had to be taken for repairs, from where they were allegedly stolen. The shots were said to have been taken by Anita’s fiance and stored on her personal computer. Emeka allegedly approached her to pay him N500, 000 or risk getting her pornographic pictures with the white man published in newspapers. The actress was said to have turned down the request, which she regarded as blackmail, and Emeka allegedly went ahead with his threat to circulate the pictures to media houses. A petition written by Anita’s lawyer, Mr Tony Dania of Dania and Associates, to the Deputy Commissioner of Police SCID, Lagos, actually admitted that the pictures in circulation were those of the actress but stressed that they were Anita’s private pictures with her fiance, stolen and doctored to suit the purpose of blackmail. The aforesaid publication is a criminal invasion of our client’s privacy. From the story the suspects published, it was obvious that there was blackmail and attempts to extort money from our client. They stole some of our clients’ pictures, used the computer to improvise and superimpose further images on them, called our clie nt and demanded for money. â€Å"The white man in the published pictures is a true resemblance of Anita’s fiance who works in a very decent organisation. In fact, they have done the pre-marriage formal introduction. Anita, who lost her dad recently, was actually carrying the baby of the white man, but the shock of the aforesaid inglorious publications made her to lose her pregnancy between Saturday/Sunday, August, 12, 13, 2006,† the petition alleged. CONSTITUTIONAL PROVISIONS Misappropriation: There are statutes that govern the right of publicity. These laws have two purposes: 1) To protect ordinary individuals from the mental anguish that may accompany the undesired commercial use of their name or image, and 2) To protect the property interest that celebrities develop in their identities. Under these laws the use of a relevant picture to illustrate a newsworthy article will generally not lead to liability. The unauthorized use of a celebrity’s picture in an advertisement often will. False Light: A photograph or videotape by itself will rarely place a subject in a false light. Rather, the accompanying text, caption, or voice-over could be misleading and portray the person in a false context. However, an accurate depiction of a person in a publication the person finds offensive does not, in itself, state a false light claim. Private Facts: The private facts tort presents unsettling scenario in which media practitioners may be iable for money damages for reporting the truth. In several cases the US Supreme Court has held that â€Å"where a newspaper publishes truthful information which it has lawfully obtained, punishment may lawfully be imposed, if at all, only when narrowly tailored to a state interest of the highest order. † Florida Star v. B. J. F. , 49 1 U. S. 524, 541 (1989) as cited in Bussian & Levine 2004. Although the Supreme Court has prevented states from punishing journalists who published legally obtained names of juvenile offenders and rape victims, the Court has not absolutely rejected the private facts tort in this context. Although crimes such as rape are newsworthy not all courts have agreed that the identity of a rape victim is newsworthy. Intrusion: Intrusion always comes into play through the process of gathering information. Here, the subsequent publication of the information is not required. Actions that may violate this privacy right include trespass onto private property, hidden surveillance, and the fraudulent entry into private areas. Conduct that invades privacy may also violate the criminal law. In general, courts have held that journalists must obey generally applicable laws. Trespass is the illegal entry onto private property. If the owner or person in charge of private property orders a photographer to leave, the photographer should leave or be prepared to face a trespass charge. Photographers who accompany police onto private property are not necessarily immune from liability. Camera operators should also be aware of federal and state laws that govern the taping of oral communications. The federal wiretap statute prohibits the interception of oral communications unless one party such as the journalist consents to the recording. And there have been instances where barring the taping of oral communications exist unless all parties consent to the taping. Privacy and the Internet: â€Å"The US Congress and its state legislatures across the nation have considered or are considering scores of bills aimed at reducing public concern about the ability of Internet users to protect their private lives as they surf the World Wide Web. † (Pember & Calvert, 2006). Despite the positive usage of the internet, the have been growing concern among users about the technology considering the ease with which third parties can collect data bout users and what the data collectors can do with the material they have gathered. However, the Nigerian Government have not woken from its slumber towards the direction of giving adequate protection to its citizens, properties and of course, rights. Defences available to Privacy Suits: Several defences are available to photographers and news organizations accused of invasion of privac y: Legitimate concern: defendant in a disclosure can challenge the plaintiff's proof of the basic elements of intrusion. For example, the defendant may be able to show that the facts that the defendant disclosed were matters of legitimate public concern. If a person is involved in a matter of legitimate public concern, a â€Å"newsworthy† event, the person becomes a public figure with respect to that event, regardless of the person's intentions or desires. If a person is a public official or public figure, his or her reasonable expectations of privacy are dramatically reduced. As a practical matter, a public official or public figure cannot successfully sue unless the invasion of privacy is outrageous or done with actual malice. Consent: it is a voluntary agreement to a publication or permission to enter a private place to gather information. It could be expressed or implied. Allis (2009) opines that a person who accepts money or other considerations in exchange for the invasion of privacy is said to have sold his or her â€Å"rights. † Though some defendants, such as prosecutors and government officials do have immunity if they are acting within the scope of their authority. Anything to be used in a commercial context, whether it is a photo taken in public or in private, must have consent, usually in the form of a model release. Consent must be obtained from someone who can validly give it. Consent to enter a home may not be consent to photograph it. Consent exceeded can be the same as no consent at all. Although oral consent may protect the press from liability for invasion of privacy, written consent is more likely to foreclose the possibility of a lawsuit. However, a subject’s subsequent withdrawal of consent does not bar the publication of the photograph. It simply means that the journalist may not assert consent as a defence if the subject later files suit. Cornwell (2008) sums it by saying â€Å"the more explicit the consent, the better the protection for the press. † Newsworthiness: Is generally defined as what the public is interested in. According to Wulfemeyer (2003), if a story that includes legally obtained private information that is embarrassing to the plaintiff but the subject matter is of public concern, it would be difficult for the plaintiff to win the law suit because courts give wide latitude to the newsworthiness defence. Photographs taken in public places generally are not actionable. Photographs of crimes, arrests and accidents usually are considered newsworthy and immune from privacy claims. Public places: if an event occurs in public view, they are almost always considered public and not private. Though public places defence have been considered not absolute. Public proceedings: Information obtained during public meetings, hearings or trials can be reported by a news organization. Public records: if information has been obtained from a document that is of a public record, it can not be deemed private. ETHICAL OBLIGATION Momoh (2004) opines that as a rule a journalist should respect the privacy of individuals and their families unless it affects public interest in the following ways: †¢ Information on the private life of an individual or his family should only be published if it impinges on public interest, †¢ Publishing of such information about an individual as mentioned above should be deemed justifiable only if it is directed at: 1. Exposing crime or serious misdemeanour; 2. Exposing anti – social conduct; 3. Protecting public health, morality and safety; 4. Preventing the public from being misled by some statement or action of the individual concerned. SUMMING UP The Right of Privacy is a good measure to check media practitioners on inappropriate media content so a news medium while carrying out its function must at all time be concerned with the welfare of its consumer. A media practitioner must ensure the accuracy of his or her information and must be ready to make corrections and clarifications when necessary after publishing or broadcasting untrue information. A media practitioner must at all time uphold the dignity of his or her profession comply with his or her professional codes and respect the human rights. A media expert must also recognise that gathering and reporting information may sometimes cause discomfort, so must seek ways to minimise the hurt. (Kayode, 2009). REFERENCES Allis. (2009). Invasion of Privacy—Appropriation. Retrieved September 19, 2009, from Lexis-Nexis database. Bussian & Levine. (2004). Invasion of Privacy: The Right â€Å"to be left alone† Retieved September 18, 2009, from Lexis-Nexis database. Cornwell, C. N. (2008). Freedom of the Press: Rights and liberties under the law. Retrieved September 18, 2009, from http://www. abc. clio. com Expectation of privacy (2002). Retrieved September 18, 2009, From http://www. wikipedia. com Folarin , B. (2005). Theories of Mass Communication: An Introductory Text. Abeokuta: Bakinfol Publication Invasion of Privacy (2003). Retrieved September 18, 2009, From http://www. winningnewsmedia. com/privacy Kayode, J. (2009). Ethics and professional practise [Record] . Lagos. Malemi, E. (2002). Mass Media Law: Cases and materials Lagos: Grace Publishing Incorporation Momoh, T . (2004). Nigerian Media Laws & Ethics Lagos : Efua Media Associates. Pember & Calvert. (2006). Mass Media Law Boston: McGraw Hill. Phtographers’ giude to Privacy (2003), Retrieved September 18, 2009, From http://www. rcfp. org Wulfemeyer, K. T. (2003). Radio & TV Newswriting: A workbook Retrieved September 19, 2009, from Lexis-Nexis database.