#Elizabeth Price Foley
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davidrivkin · 1 month ago
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What Jack Smith Gets Wrong About Immunity
By David B. Rivkin, Jr., and Elizabeth Price Foley
October 14, 2024, in the Wall Street Journal
Jack Smith made no concessions in his response to the Supreme Court’s July ruling in Trump v. U.S., which rejected the special counsel’s contention that he had unlimited authority to prosecute Donald Trump for alleged crimes that involved official presidential acts. Chief Justice John Roberts provided a framework for distinguishing official acts from private ones and for determining which official acts could be prosecuted.
In a 165-page brief filed with Judge Tanya Chutkan, who is presiding over the election-fraud case, Mr. Smith acknowledges only that Mr. Trump’s communications with Justice Department officials were official acts and can’t be prosecuted—as the justices expressly said. But Mr. Smith characterizes then-President Trump’s official conversations with the vice president as outside the zone of immunity and his communications with state officials and the public not as official acts of the president but private acts of a candidate. In so doing he gives short shrift to the separation-of-powers justification for immunity.
Trump v. U.S. extended presidential immunity, which the court recognized in Nixon v. Fitzgerald (1982), from civil lawsuits to criminal prosecutions. Like the immunity enjoyed by prosecutors, judges and members of Congress, the president’s immunity for official acts is predicated on separation of powers. Fitzgerald held that immunity is especially important for the president, who “occupies a unique position in the constitutional scheme” as head of a branch of government—an “easily identifiable target” for legal attacks that could thwart the effective functioning of the office.
A president’s immunity from criminal prosecution is absolute when he exercises his core constitutional powers, such as recognizing foreign governments, nominating and firing executive officers, commanding the military, issuing pardons, faithfully executing the laws—and, as in this case, directing an executive-branch department.
Other acts within the “outer perimeter” of the president’s responsibility, the court explained, have “at least” a presumptive immunity. The presumption is rebuttable only if the prosecutor can prove that the acts are “manifestly or palpably beyond” the president’s authority, such that, as Fitzgerald put it, imposing liability would “pose no dangers of intrusion on the authority and functions of the Executive Branch.”
Mr. Smith’s brief falls short of making that case. His primary argument is that the “throughline” of Mr. Trump’s postelection efforts “was deceit,” because the president made “knowingly false claims of election fraud.”
The prosecutor’s focus on Mr. Trump’s motive is a critical legal error. The Trump decision reiterated Fitzgerald’s holding that in distinguishing between official and private acts, “courts may not inquire into the President’s motives.” Allowing such an inquiry would vitiate the president’s immunity, since virtually every presidential decision is based in part on political considerations, and suits against a president would always allege improper motives.
The only relevant questions, therefore, are whether a president’s acts, objectively viewed, are official or unofficial, and if they are official, whether they can be prosecuted without intruding on the president’s legitimate authority. Mr. Smith asserts that when a president seeks “to influence his Vice President” about electoral certification, it is outside the zone of immunity because the vice president exercises this power as president of the Senate, and the “Executive Branch plays no role.” He deems Mr. Trump’s interactions with state officials private because the president has “no official role” in the Electoral College process or enforcing state election law. And he asserts that Mr. Trump made various public statements in his capacity as a candidate, not as president.
The court has rejected Mr. Smith’s cramped view of presidential authority on several occasions. In his concurrence in Youngstown Sheet & Tube v. Sawyer (1952), Justice Felix Frankfurter observed that executive power extends beyond statutes and express constitutional provisions to include the “gloss” of longstanding presidential practice. In Dames & Moore v. Regan (1981), a majority embraced Frankfurter’s view.
The Trump decision also accepted Frankfurter’s view, observing that “some Presidential conduct—for example, speaking to and on behalf of the American people—certainly can qualify as official even when not obviously connected to a particular constitutional or statutory provision.” The president is “expected to comment on those matters of public concern” and in so doing so, he may pressure others—outside the executive branch—to behave in certain ways. In McDonnell v. U.S. (2016), the court held that an “official act” under the federal bribery statute includes using one���s office “to exert pressure on another official to perform an official act.”
Mr. Smith asserts that Mr. Trump’s legal efforts in his “capacity as a candidate” to challenge certain state elections prove that his conversations with officials and statements to the public were private actions. But that gets it backward. Under Trump, the burden is on the prosecutor to show that his allegations don’t infringe on the president’s official duties, not on the president to show that his exercise of those duties is untainted by private considerations.
Chief Justice Roberts writes in Trump that immunity is a “farsighted” constitutional doctrine designed to prevent constant legal harassment from enfeebling the presidency. Without immunity, the threat of civil and criminal liability would create, as George Washington put it in his Farewell Address, the “alternate domination of one faction over another, sharpened by the spirit of revenge” with every new administration.
Democrats profess to be worried that Mr. Trump, if returned to office, will use the justice system to seek retribution against his political opponents. They should stop and consider that presidential immunity also restrains that “spirit of revenge” if Mr. Trump wins in November.
Mr. Rivkin served at the Justice Department and the White House Counsel’s Office during the Reagan and George H.W. Bush Administrations. Ms. Foley is a professor of constitutional law at Florida International University. Both practice appellate and constitutional law in Washington.
Source: https://www.wsj.com/opinion/what-jack-smith-gets-wrong-about-immunity-law-election-presidential-power-f4f57ead
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simply-ivanka · 6 months ago
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Trump’s Trial Violated Due Process
Trump was denied notice of the charges, meaningful opportunity to respond and proof of all elements.
By 
David B. Rivkin Jr. and Elizabeth Price Foley
Wall Street Journal
Whether you love, hate or merely tolerate Donald Trump, you should care about due process, which is fundamental to the rule of law. New York’s trial of Mr. Trump violated basic due-process principles.
“No principle of procedural due process is more clearly established than that notice of the specific charge,” the Supreme Court stated in Cole v. Arkansas (1948), “and a chance to be heard in a trial of the issues raised by that charge, if desired, [is] among the constitutional rights of every accused in a criminal proceeding in all courts, state or federal.” In in re Winship (1970), the justices affirmed that “the Due Process Clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged.” These three due-process precepts—notice, meaningful opportunity to defend, and proof of all elements—were absent in Mr. Trump’s trial.
The state offense with which Mr. Trump was indicted, “falsifying business records,” requires proof of an “intent to defraud.” To elevate this misdemeanor to a felony, the statute requires proof of “intent to commit another crime.” In People v. Bloomfield (2006), the state’s highest court observed that “intent to commit another crime” is an indispensable element of the felony offense.
New York courts have concluded that the accused need not be convicted of the other crime since an “intent to commit” it is sufficient to satisfy the statute. But because that intent is, in the words of Winship, “a fact necessary to constitute the crime,” it is an element of felony falsification. Due process requires that the defendant receive timely notice of the other crime he allegedly intended to commit. It also requires that he have opportunity to defend against that accusation and that prosecutors prove beyond a reasonable doubt his intent to commit it.
Mr. Trump’s indictment didn’t specify the other crime he allegedly intended to commit. Prosecutors didn’t do so during the trial either. Only after the evidentiary phase of the trial did Judge Juan Merchan reveal that the other crime was Section 17-152 of New York’s election law, which makes it a misdemeanor to engage in a conspiracy “to promote or prevent the election of any person to a public office by unlawful means.”
To recap, the prosecution involved (1) a misdemeanor elevated to a felony based on an “intent to commit another crime,” (2) an indictment and trial that failed to specify, or present evidence establishing, another crime the defendant intended to commit, and (3) a jury instruction that the other crime was one that necessitated further proof of “unlawful means.” It’s a Russian-nesting-doll theory of criminality: The charged crime hinged on the intent to commit another, unspecified crime, which in turn hinged on the actual commission of yet another unspecified offense.
To make matters worse, Judge Merchan instructed the jury: “Although you must conclude unanimously that the defendant conspired to promote or prevent the election of any person to a public office by unlawful means, you need not be unanimous as to what those unlawful means were.”
Due process demands that felony verdicts be unanimous, but in Schad v. Arizona (1991), a murder case, the high court indicated that there need not be unanimity regarding the means by which a crime is committed. But a plurality opinion by Justice David Souter cautioned that if the available means of committing a crime are so capacious that the accused is not “in a position to understand with some specificity the legal basis of the charge against him,” due process will be violated. “Nothing in our history suggests that the Due Process Clause would permit a State to convict anyone under a charge of ‘Crime’ so generic that any combination of jury findings of embezzlement, reckless driving, murder, burglary, tax evasion, or littering, for example, would suffice for conviction,” Justice Souter wrote.
Justice Antonin Scalia concurred, observing that “one can conceive of novel ‘umbrella’ crimes (a felony consisting of either robbery or failure to file a tax return) where permitting a 6-to-6 verdict would seem contrary to due process.” Four dissenting justices argued that the In re Winship precedent requires unanimity regarding all elements of a crime, including the means by which it’s committed.
All nine justices in Schad, then, believed unanimity is required to convict when the means by which a crime can be committed are so broad that the accused doesn’t receive fair notice of the basis of the charge. New York’s election law requires that the violation occur “by unlawful means,” so any “unlawful” act—including, in Scalia’s example, either robbery of failure to file a tax return—can qualify. That’s clearly overbroad. Thus, Judge Merchan’s instruction that the jury “need not be unanimous as to what those unlawful means were” was unconstitutional.
That isn’t all. Judge Merchan hand-selected three laws—federal election law, falsification of “other” business records and “violation of tax laws”—as the “unlawful means” by which state election law was violated. Mr. Trump received no notice of any of these offenses, and the prosecutor briefly alluded only to federal election law, during the trial. Mr. Trump tried to call former Federal Election Commission Chairman Brad Smith to explain why this law wasn’t violated, but Judge Merchan ruled Mr. Smith couldn’t testify on whether Mr. Trump’s conduct “does or does not constitute a violation” of federal election law, denying him a meaningful opportunity to be heard.
Judge Merchan’s second “unlawful” means, falsification of other business records, is circular: A misdemeanor becomes a felony if one falsifies business records by falsifying business records. Further, the prosecution never alleged or provided evidence that Mr. Trump falsified “other” business records. The prosecutors likewise neither alleged nor offered evidence that Mr. Trump had violated tax laws, Judge Merchan’s third predicate.
Mr. Trump, like all criminal defendants, was entitled to due process. The Constitution demands that higher courts throw out the verdict against him. That takes time, however, and is unlikely to occur before the election. That unfortunate reality will widen America’s political divide and fuel the suspicion that Mr. Trump’s prosecution wasn’t about enforcing the law but wounding a presidential candidate for the benefit of his opponent.
Mr. Rivkin served at the Justice Department and the White House Counsel’s Office during the Reagan and George H.W. Bush Administrations. Ms. Foley is a professor of constitutional law at Florida International University College of Law. Both practice appellate and constitutional law in Washington.
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likeclarabow · 3 years ago
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Books Read In 2022
Our Violent Ends - Chloe Gong (Dec 31-Jan 1)
How the King of Elfhame Learned to Hate Stories - Holly Black (Jan 1)
A Conjuring of Light - V.E. Schwab (Jan 2-Jan 5)
The Enigma Game - Elizabeth Wein (Jan 6-Jan 8)
The Invisible Life of Addie LaRue - V.E. Schwab (Jan 8-Jan 12)
The Bronzed Beasts - Roshani Chokshi (Jan 14-Jan 16)
The Hunger Games (reread) - Suzanne Collins (Jan 16-Jan 18)
Les Jeux Sont Faits - Jean-Paul Sartre (Nov 10-Jan 19)
Catching Fire (reread) - Suzanne Collin (Jan 20-Jan 22)
Mockingjay (reread) - Suzanne Collins (Jan 22-Jan 23)
The Wrath and the Dawn -  Renée Ahdieh (Jan 24-Jan 28)
Heartstopper: Volume 4 - Alice Oseman (Jan 28)
The Final Girl Support Group - Grady Hendrix (Jan 29)
The Outsiders - S.E. Hinton (Jan 30-Jan 31)
The Ballad of Songbirds and Snakes (reread) - Suzanne Collins (Jan 31-Feb 3)
A Pho Love Story - Loan Le (Feb 4-Feb 5)
Shatter Me - Tahereh Mafi (Feb 5-Feb 8)
Josh and Hazel’s Guide to Not Dating - Christina Lauren (Feb 8-Feb 12)
Felix Ever After - Kacen Callender (Feb 12-Feb 13)
The Inheritance Games - Jennifer Lynn Barnes (Feb 13-Feb 16)
You’ll Be the Death of Me - Karen McManus (Feb 17-Feb 18)
Caraval (reread) - Stephanie Garber (Feb 19-Feb 21)
Legendary (reread) - Stephanie Garber (Feb 21-Feb 23)
Cinder (reread) - Marissa Meyer (Feb 24)
Scarlet (reread) - Marissa Meyer (Feb 25)
Cress (reread) - Marissa Meyer (Feb 26)
Winter (reread) - Marissa Meyer (Feb 27)
The Seven Husbands of Evelyn Hugo (reread) - Taylor Jenkins Reid (Feb 28-Mar 2)
One Last Stop (reread) - Casey McQuiston (Mar 4-Mar 6)
The Confessions of Frannie Langton - Sara Collins (Mar 9-Mar 12)
One True Loves - Taylor Jenkins Reid (Mar 13)
All Your Twisted Secrets - Diana Urban (Mar 14)
Hang the Moon - Alexandra Bellefleur (Mar 15)
Truly Devious - Maureen Johnson (Mar 16)
Get A Life Chloe Brown - Talia Hibbert (Mar 17)
Take a Hint Dani Brown - Talia Hibbert (Mar 18)
Act Your Age Eve Brown - Talia Hibbert (Mar 19)
Finale - Stephanie Garber (reread) (Mar 20-Mar 25)
Love and Other Words - Christina Lauren (Mar 26-Mar 29)
A Study In Charlotte - Brittany Cavallaro (Mar 30-Mar 31)
Written in the Stars - Alexandra Bellefleur (Apr 1-Apr 3)
The Raven Boys (reread) - Maggie Stiefvater (Apr 4-Apr 6)
The Dream Thieves (reread) - Maggie Stiefvater (Apr 6-Apr 9)
Blue Lily Lily Blue (reread) - Maggie Stiefvater (Apr 10-Apr 11)
The Guest List - Lucy Foley (Apr 11-Apr 15)
Count Your Lucky Stars - Alexandra Bellefleur (Apr 16-Apr 19)
The Vanishing Stair - Maureen Johnson (Apr 20-Apr 22)
Pride and Premeditation - Tirzah Price (Apr 22-Apr 23)
Hook, Line, and Sinker - Tessa Bailey (Apr 23-Apr 25)
The Raven King (reread) - Maggie Stiefvater (Apr 25-Apr 28)
The Last of August - Brittany Cavallaro (Apr 28-Apr 30)
The Case For Jamie - Brittany Cavallaro (Apr 30-May 1)
Sense and Second Degree Murder - Tirzah Price (May 2-May 6)
Saga, Volume 1 - Brian K Vaughan, Fiona Staples (May 10)
A Question of Holmes - Brittany Cavallaro (May 7-May 12)
Saga, Volume 2 -  Brian K Vaughan, Fiona Staples (May 14)
When You Get the Chance - Emma Lord (May 13-May 16)
If On a Winter’s Night a Traveler - Italo Calvino (May 2-May 17)
Book Lovers - Emily Henry (May 18-May 20)
Saga, Volume 3 - Brian K Vaughan, Fiona Staples (May 20)
Dare Me - Megan Abbott (May 21)
The Paris Apartment - Lucy Foley (May 22)
The Hand on the Wall - Maureen Johnson (May 22-May 23)
The Box in the Woods - Maureen Johnson (May 24-May 25)
Queen of the Tiles - Hanna Alkaf (May 25-May 26)
The Most Dangerous Place on Earth - Lindsey Lee Johnson (May 26-May 27)
Saga, Volume 4 - Brian K Vaughan, Fiona Staples (May 27)
Saga, Volume 5 - Brian K Vaughan, Fiona Staples (May 28)
Cover Story - Susan Rigetti (June 4-June 5)
The Murder of Roger Ackroyd - Agatha Christie (June 5-June 6)
Weather Girl - Rachel Lynn Solomon (June 7-June 10)
Forever - Pete Hamill (May 29-June 10)
They Never Learn - Layne Fargo (June 10-June 14)
The Poppy War - R.F. Kuang (June 15-June 17)
The Dragon Republic - R.F. Kuang (June 18-June 24)
Something Wilder - Christina Lauren (June 24)
A Million Junes - Emily Henry (June 25)
I Kissed Shara Wheeler - Casey McQuiston (June 26-June 27)
Great or Nothing -  Joy McCullough, Caroline Tung Richmond, Tess Sharpe, Jessica Spotswood (June 28-June 29)
The Burning God - R.F. Kuang (June 30-July 1)
The Drowning Faith - R.F. Kuang (July 1)
The Cartographers - Peng Shepherd (July 1-July 2)
House of Salt and Sorrows - Erin A Craig (July 2-July 3)
A Flicker in the Dark - Stacy Willingham (July 3-July 5)
Ninth House - Leigh Bardugo (July 6-July 9)
Death On the Nile - Agatha Christie (July 9)
The Agathas - Kathleen Glasgow, Liz Lawson (July 9-July 10)
Malibu Rising (reread) - Taylor Jenkins Reid (July 11-July 12)
The Priory of the Orange Tree - Samantha Shannon (July 13-July 18)
Murder on the Orient Express - Agatha Christie (July 19-July 20)
Gallant - V.E. Schwab (July 21-July 24)
The Hawthorne Legacy - Jennifer Lynn Barnes (July 25-July 26)
Last Night at the Telegraph Club - Malinda Lo (July 27-July 28)
The Summer I Turned Pretty - Jenny Han (July 28-July 30)
It’s Not Summer Without You - Jenny Han (July 30-July 31)
We’ll Always Have Summer - Jenny Han (July 31-Aug 1)
Persuasion (audiobook) - Jane Austen (July 30-Aug 2)
Lower East Side Oral Histories - Eric Ferrara, Nina Howes (Aug 1-Aug 3)
Every Summer After - Carley Fortune (Aug 3-Aug 5)
Anne of Green Gables (reread) - L.M. Montgomery (Aug 6-Aug 7)
Evidence of the Affair - Taylor Jenkins Reid (Aug 8)
Into the Drowning Deep - Mira Grant (Aug 11-Aug 12)
The Spanish Love Deception - Elena Armas (Aug 12-Aug 13)
A Far Wilder Magic - Allison Saft (Aug 14-Aug 18)
Seven Days In June - Tia Williams (Aug 19)
This Golden State - Merit Weisenburg (Aug 20)
Emma - Jane Austen (Aug 9-Aug 21)
Sorcery of Thorns - Margaret Rogerson (Aug 20-Aug 24)
Today Tonight Tomorrow - Rachel Lynn Solomon (Aug 25-27)
Babel, Or the Necessity of Violence: An Arcane History of the Oxford Translators’ Revolution - R.F. Kuang (Aug 28-Aug 31)
Red White and Royal Blue (reread) - Casey McQuiston (Sept 1-Sept 3)
Carrie Soto Is Back - Taylor Jenkins Reid (Sept 4-Sept 6)
The Love Hypothesis - Ali Hazelwood (Sept 8-Sept 9)
Once Upon a Broken Heart (reread) - Stephanie Garber (Sept 9-Sept 14)
Finley Donovan Is Killing It - Elle Cosimano (Sept 15-Sept 17)
Gone Girl - Gillian Flynn (Sept 18-Sept 19)
Indian Horse - Richard Wagamese (Sept 16-Sept 25)
Sharp Objects - Gillian Flynn (Sept 21-Sept 26)
Before the Coffee Gets Cold - Toshikazu Kawaguchi (Sept 29-Oct 5)
I’m Glad My Mom Died - Jennette McCurdy (Oct 5-Oct 6)
Dark Places - Gillian Flynn (Oct 9-Oct 12)
Pride and Prejudice (reread) - Jane Austen (Sept 26-Oct 12)
The American Roommate Experiment - Elena Armas (Oct 12-Oct 15)
Daisy Jones and the Six (audiobook) (reread) - Taylor Jenkins Reid (Oct 6-Oct 16)
Everything I Never Told You - Celeste Ng (Oct 12-Oct 25)
Bunny - Mona Awad (Oct 17-Oct 27)
Frankenstein - Mary Shelley (Oct 28-Nov 4)
Fight Club - Chuck Palahniuk (Nov 1-Nov 10)
Becoming Unbecoming - Una (Nov 6-Nov 11)
Beach Read (reread) - Emily Henry (Nov 7-Nov 14)
Dracula - Bram Stoker (May 6-Nov 17)
Kill Joy - Holly Jackson (Nov 23)
If We Were Villains (reread) - M.L. Rio (Nov 20-Nov 28)
The Atlas Six - Olivie Blake (Dec 4-Dec 14)
The Picture of Dorian Gray - Oscar Wilde (Dec 20-Dec 23)
The Summer of Bitter and Sweet - Jen Ferguson (Dec 23)
If the Shoe Fits - Julie Murphy (Dec 24-Dec 25)
The Girls I’ve Been (reread) - Tess Sharpe (Dec 26-Dec 28)
Foul Lady Fortune - Chloe Gong (Dec 28-Dec 29)
Five Survive - Holly Jackson (Dec 29-Dec 30)
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foreverlostinliterature · 3 years ago
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11/29 (Additional) Book Deals 
Good morning, everyone! I hope your week is off to a wonderful start! :) 
Apologies for not posting more last week, I was trying to take some time off of the internet and decompress a bit before diving into what is sure to be a rather stressful month. Last week also marked the 15 year anniversary of my dad’s death, so that’s always a weird time for me, as well. I’d love to hear how you all are doing! How’s life? Can you believe it’s already almost December?? How’s your weather?? We’re still getting warm weather here off and on, go figure. 
In regard to the books (which is why we’re all here), there are a ton on sale, so seems like an awesome time to stock up on both new and backlist releases for really great prices if you need to get some more books to read! Also, I will link to and repost my deals post from last week because I’m pretty sure those are also still on sale, so lots of options. :) The Book of Koli is one I always recommend, and I’ve really enjoyed books by H.G. Parry! Also, I haven’t read them, but the entire Cursebreaker series (A Curse so Dark and Lonely, etc.) is on sale as a bundle, so if you’ve been wanting to read that it seems like a really good deal! There are just basically a lot of awesome books available to choose from, including some super new releases, as well as some really popular backlist titles (like The Fifth Season!), so definitely have a look. :)
Anyway, I hope you all have a truly wonderful day, and happy reading to all!
Today’s Deals:
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The Four Winds by Kristin Hannah - https://amzn.to/319eZRK
The Rose Code by Kate Quinn - https://amzn.to/3E8hpi2
The Sweetness of Water by Nathan Harris - https://amzn.to/3d24VfH
The Fifth Season by N.K. Jemisin - https://amzn.to/2ZxzOFI
New Spring by Robert Jordan - https://amzn.to/3xzk01L
The Exiles by Christina Baker Kline - https://amzn.to/3o2qMKo
The Hunting Party by Lucy Foley - https://amzn.to/3rgZuBV
The Only Woman in the Room by Marie Benedict - https://amzn.to/3FVhEgL
Seven Days in June by Tia Williams - https://amzn.to/3D3jWsu
My Dark Vanessa by Kate Elizabeth Russell - https://amzn.to/3D2gL4g
Homo Deus: A Brief History of Tomorrow by Yuval Noah Harari - https://amzn.to/3xDhism
The Things We Cannot Say by Kelly Rimmer - https://amzn.to/3FYoEta
Good Company by Cynthia D'Aprix Sweeney - https://amzn.to/3FWGOeT
Parable of the Sower by Octavia E. Butler - https://amzn.to/3d1pA3K
Snow by John Banville - https://amzn.to/2ZAvOEt
The Galaxy, and the Ground Within by Becky Chambers - https://amzn.to/3FViDgX
The Best of Me by David Sedaris - https://amzn.to/3I2M8z8
Life, Unscheduled by Kristin Rockaway - https://amzn.to/3xB2URh
Island Queen by Vanessa Riley - https://amzn.to/3xy3rU7
Appleseed by Matt Bell - https://amzn.to/3GdDcFJ
Incense and Sensibility by Sonali Dev - https://amzn.to/3E4ucSB
The Icepick Surgeon: Murder, Fraud, Sabotage, PIracy, and Other Dastardly Deeds Perpetrated in the Name of Science by Sam Kean - https://amzn.to/3D5qBCr 
Outlawed by Anna North -  https://amzn.to/3pdyAZ2
Capture the Crown by Jennifer Estep - https://amzn.to/3cXYNFt
Boundless (Drizzt) by R.A. Salvatore - https://amzn.to/3lfvhiL
Her Heart for a Compass by Sarah Ferguson - https://amzn.to/3lisHJ9
A Happy Catastrophe by Maddie Dawson - https://amzn.to/31acSgE
The Bennet Women by Eden Appiah-Kubi - https://amzn.to/3E5Thwo
The Last Story of Mina Lee by Nancy Jooyoun Kim - https://amzn.to/3pblWtF
The Elegance of the Hedgehog by Muriel Barbery & Alison Anderson - https://amzn.to/31ad9jG
Land: How the Hunger for Ownership Shaped the Modern World by Simon Winchester - https://amzn.to/3rkPnfI
Medium Raw by Anthony Bourdain - https://amzn.to/3E5qxns
The Book of Koli by M.R. Carey -  https://amzn.to/31aLdMa
A Declaration of the Rights of Magicians by H.G. Parry - https://amzn.to/3o3BWi8
The Kingdoms by Natasha Pulley - https://amzn.to/3lkP5Br
The Rehearsals by Annette Christie -  https://amzn.to/3cWj3r0
A Touch of Jen by Beth Morgan - https://amzn.to/3o3n2Zd
Brave New World by Aldous Huxley - https://amzn.to/3p7Oog1
Snare (Reykjavik Noir Trilogy) by Lilja Sigurdardottir - https://amzn.to/32JWB2s
An Unnecessary Woman by Rabig Alameddine - https://amzn.to/3FYSJZA
Hot Stew by Fiona Mozley - https://amzn.to/3D5mGFI
The Cat Proposed by Dento Hayane - https://amzn.to/31dnmeY
Would You Like to Be a Family? by Koyama - https://amzn.to/3liYKZl
The Cursebreaker Series (all three books!) by Brigid Kemmerer - https://amzn.to/3liOiRM
Who They Was by Gabriel Krauze - https://amzn.to/2ZyTUPY
Good Night Stories for Rebel Girls: 100 Immigrant Women Who Changed the World by Elena Favilli - https://amzn.to/316a44i
The Essential Chomsky by Noam Chomsky - https://amzn.to/3DguOU1
You'll Never Believe What Happened to Lacey: Crazy Stories About Racism by Amber Ruffin & Lacey Lamar - https://amzn.to/3p4VIJg
Mind of My Mind by Octavia E. Butler - https://amzn.to/3E7hH8y
NOTE:  I am categorizing these book deals posts under the tag #bookdeals, so if you don’t want to see them then just block that tag and you should be good. I am an Amazon affiliate and will receive a small (but very much needed!)  commission on any purchase made through these links. If you’d rather shop at other bookstores, I am also a Bookshop.org and Indiebound affiliate! :)
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thediverismylove · 4 years ago
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every book i read in 2020
books i read for school are bolded, rereads are starred
paradise rot by jenny hval 
tin man by sarah winman
we were feminists once by andi zeisler
little weirds by jenny slate 
a girl is a half formed thing by eimear mcbride 
deaf republic by ilya kaminsky
reverie by ryan la sala 
the year of magical thinking by joan didion 
on beauty by zadie smith
dark and deepest red by anna-marie mclemore 
black dog of fate by peter balakian 
the elements of style by william strunk jr & eb white
tell the wolves i’m home by carol rifka brunt
long live the tribe of fatherless girls by t kira madden 
the fact of a body by alex marzano-lesnevich 
lovely war by julie berry 
foul is fair by hannah capin 
the king of crows by libba bray
the end we start from by megan hunter
uprooted by naomi novik 
the monster hypothesis by romily bernard 
the line becomes a river by francisco cantu
the queen by josh levin 
red hood by elana k. arnold 
the lying game by ruth ware 
bunny by mona awad
the last true poets of the sea by julia drake 
citizen by claudia rankine 
my year of rest and relaxation by ottessa moshfegh 
the vacationers by emma straub 
their eyes were watching god by zora neale hurston 
the virgin suicides by jeffrey eugenides
*dare me by megan abbott
the water cure by sophie mackintosh 
the chronology of water by lidia yuknavitch 
the subversive copyeditor by carol fisher saller 
*on earth we’re briefly gorgeous by ocean vuong 
how to do nothing by jenny odell 
the midnight lie by marie rutkoski 
future home of the living god by louise erdrich 
the nightingale by kristin hannah 
*a great and terrible beauty by libba bray
*rebel angels by libba bray 
the fountains of silence by ruta sepetys 
*the sweet far thing by libba bray 
the bluest eye by toni morrison 
the paper wasp by lauren acampora 
piecing me together by renee watson 
get a life, chloe brown by talia hibbert
you’ll miss me when i’m gone by rachel lynn solomon 
the widow of pale harbor by hester fox
passing by nella larsen
my dark vanessa by kate elizabeth russell 
kindred by octavia butler 
beach read by emily henry 
you should see me in a crown by leah johnson 
the guest list by lucy foley 
the magic toyshop by angela carter 
the southern book club’s guide to slaying vampires by grady hendrix 
catherine house by elisabeth thomas 
home before dark by riley sager 
take a hint, dani brown by talia hibbert 
what we lose by zinzi clemmons 
the burning girl by claire messud
godshot by chelsea bieker 
the thirteenth tale by diane setterfield
such a fun age by kiley reid
the party upstairs by lee conell 
my education by susan choi
the city we became by nk jemisin
the lightness by emily temple 
followers by megan angelo 
temporary by hilary leichter
the kingdom of back by marie lu 
the lady’s guide to celestial mechanics by olivia waite 
mexican gothic by silvia moreno-garcia 
the bloody chamber & other stories by angela carter 
burn our bodies down by rory power
dangerous alliance by jennieke cohen
i’m thinking of ending things by iain reid 
pizza girl by jean kyoung frazier
i’ll be gone in the dark by michelle mcnamara 
the ghost map by steven johnson
luster by raven leilani
blood water paint by joy mccullough 
death in her hands by ottessa moshfegh
cemetery boys by aiden thomas 
madame bovary by gustave flaubert 
exciting times by naoise dolan 
blood countess by lana popović
the hazel wood by melissa albert 
jane doe by victoria helen stone
problem child by victoria helen stone 
eight perfect murders by peter swanson
heart berries by terese marie mailhot 
the austen playbook by lucy parker 
take me apart by sara sligar 
salt slow by julia armfield
the vanishing half by brit bennett
the price of salt by patricia highsmith
the last by hanna jameson
the comeback by ella berman
horrid by katrina leno
the clique by lisi harrison 
another brooklyn by jacqueline woodson
the great believers by rebecca makkai
heartburn by nora ephron
spoiler alert by olivia dade 
memorial by bryan washington 
will my cat eat my eyeballs?: big questions from tiny mortals about death by caitlin doughty
the lying life of adults by elena ferrante 
plain bad heroines by emily m. danforth
days of distraction by alexandra chang 
*bunheads by sophie flack
what we don’t talk about when we talk about fat by aubrey gordon 
pet by akwaeke emezi 
know my name by chanel miller 
the glass hotel by emily st. john mandel 
leave the world behind by rumaan alam 
a certain hunger by chelsea g. summers 
because internet by gretchen mcculloch 
writers & lovers by lily king 
averno by louise glück 
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tothemattresses · 5 years ago
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2020 Reading Challenge - E-Book Edition!
According to Amazon, I have exactly 294 e-books currently sitting in my Kindle library. 
Granted, some of these books have been read and are being saved for a second (or third, or fourth) re-read, but when it comes down to it, that number is around 40 books, give or take. 
Which means I still have over 250 books that need to be read. 
And it’s not like I haven’t tried! There are plenty of titles that, when opened up, will go to the last place I left off - that being chapter 5, or maybe chapter 10. But sometimes life gets in the way. Or a sudden interest in another author. Or a new season of RuPaul’s Drag Race. But whatever the reason may be, it’s over 250 books that haven’t been read. Challenge accepted! 
For 2020, I commit to not buying any new books to add to my Kindle library (checking out books from the library is ok, because you’ve gotta support your local library!), and instead focus on the books I already have. So no addition of 99 cent books, or Kindle Unlimited books, or books that are suddenly 75% off. Only the books that I currently have. 
As the reading commences, and after the book is finished, I’ll update my list to indicate what has been completed, along with the date purchased, and a short review (or a reason I just couldn’t finish it at all). 
Below is the list for future reference - and to clarify my what my favorite genre is. Spoiler: it’s romance novels. 
Here we go!
Adulting: How to Become a Grown-up in 535 Easy(ish) Steps – Kelly Williams Brown
An Affair with Mr. Kennedy (Gentlemen of Scotland Yard) – Jillian Stone
All About Love (Cynster Book 6) – Stephanie Laurens
All Afternoon with a Scandalous Marquess: A Lords of Vice Novel – Alexandra Hawkins
Almost a Scandal: A Reckless Brides Novel (The Reckless Brides Book 1) – Elizabeth Essex
Alpha – Jasinda Wilder
A Duke’s Guide to Seducing His Bride (Chase Family Series- The Jewels Book 4) – Lauren Royal
The American Heiress: A Novel – Daisy Goodwin
When an Earl Meets a Girl (Chase Family Series- The Jewels Book 1) – Lauren Royal
The Andy Cohen Diaries: A Deep Look at a Shallow Year – Andy Cohen
Angel in a Devil's Arms: The Palace of Rogues – Julie Anne Long
Angel in Scarlet: A Bound and Determined Novel – Lavinia Kent
Anything He Wants & Castaway – Sara Fawkes
The Astronaut Wives Club – Lily Koppel
At Any Price: A Billionaire Virgin Auction Romance (Gaming the System Book 1) – Brenna Aubrey
At Any Turn: A Billionaire Romance (Gaming the System Book 2) – Brenna Aubrey
At Your Pleasure – Meredith Duran
The Awakening of Ivy Leavold (Markham Hall Book 1) – Sierra Simone
Badd Motherf*cker (The Badd Brothers Book 1) – Jasinda Wilder
Bare Ass in Love (Hard, Fast, and Forever Book 1) – Sasha Burke
Because of Miss Bridgerton: A Bridgertons Prequel (Rokesbys Series Book 1) – Julia Quinn
The Bed and the Bachelor (Byrons of Braebourne Book 5) – Tracy Anne Warren
Betrayal (Infidelity Book 1) – Aleatha Romig
Beware That Girl – Teresa Toten
Beyond Scandal and Desire: A Sins for All Seasons Novel – Lorraine Heath
The Big Bad Office Wolf (Kings of the Tower Book 1) – May Sage
Bittersweet (True North Book 1) – Sarina Bowen
Blame It on Bath: The Truth About the Duke – Caroline Linden
Bound by Your Touch – Meredith Duran
The Bride (Lairds' Fiancees Book 1) – Julie Garwood
Bridget Jones's Diary: A Novel – Helen Fielding
Burn (The Breathless Trilogy Book 3) – Maya Banks
Burning Offer (Trevor's Harem Book 1) – Aubrey Parker
Captivated by You (Crossfire, Book 4) – Sylvia Day
Captive of Sin – Anna Campbell
Cash: A Power Players Stand-Alone Novel – Cassia Leo
Catch a Wave: The Rise, Fall, and Redemption of the Beach Boys' Brian Wilson – Peter Ames Carlin
Catching Sin (Las Vegas Sin Book 2) – J. Saman
Catholicism For Dummies – John Trigilio
A Certain Age: A Novel – Beatriz Williams
Chasing Lady Amelia: Keeping Up with the Cavendishes – Maya Rodale
Checkmate: This is War (Travis & Viola, #1) (Checkmate Duet) – Kennedy Fox
Claiming the Courtesan (Avon Romantic Treasures) – Anna Campbell
Collide: Book One in the Collide Series – Gail McHugh
The Controversial Princess (The Smoke & Mirrors Duology Book 1) – Jodi Ellen Malpas
Crave: A Billionaire Bachelors Club Novel (Billionaire Bachelors Club Series Book 1) – Monica Murphy
Dating You / Hating You – Christina Lauren
Deal with the Devil (Forge Trilogy Book 1) – Meghan March
Desperate Duchesses – Eloisa James
Desperate to Touch (Hard to Love Book 2) – W. Winters
Destiny – Sally Beauman
Devil's Daughter: The Ravenels meet The Wallflowers – Lisa Kleypas
Dirty Sexy Inked (A Dirty Sexy Novel Book 2) – Carly Phillips
Dirty Sexy Saint (A Dirty Sexy Novel Book 1) – Carly Phillips
Double Down: Game Change 2012 – Mark Halperin
The Duchess Diaries: The Bridal Pleasures Series – Jillian Hunter
The Duchess Hunt (House of Trent Book 1) – Jennifer Haymore
The Duke and I (Bridgertons Book 1) – Julia Quinn
The Duke Is Mine (Fairy Tales Book 3) – Eloisa James
Duke of Scandal (Moonlight Square, Book 1) – Galen Foley
The Duke of Shadows – Meredith Duran
Duke of Sin (Maiden Lane Book 10) – Elizabeth Hoyt
The Duke's Holiday (The Regency Romp Trilogy Book 1) – Maggie Fenton
Dusk with a Dangerous Duke: A Lords of Vice Novel – Alexandra Hawkins
Edenbrooke: A Proper Romance – Julianne Donaldson
Elite (Elite Doms of Washington Book 1) – Elizabeth SaFleur
Entwined with You (Crossfire, Book 3) – Sylvia Day
Everything Is Perfect When You're a Liar – Kelly Oxford
The Fall of Legend (Legend Trilogy Book 1) – Meghan March
The Fight for Forever (Legend Trilogy Book 3) – Meghan March
A Fine Imitation: A Novel – Amber Brock
The Fix Up – Kendall Ryan
Flowers from the Storm – Laura Kinsale
For Everly – Raine Thomas
For the Earl's Pleasure – Anne Mallory
For the Record – K.A. Linde
Gabriel's Inferno (Gabriel's Inferno Trilogy Book 1) – Sylvain Reynard
Gabriel's Rapture (Gabriel's Inferno Trilogy Book 2) – Sylvain Reynard
Gabriel's Redemption (Gabriel's Inferno Trilogy Book 3) – Sylvain Reynard
Going Down Easy (Billionaire Bad Boys Book 1) – Carly Phillips
A Good Debutante's Guide to Ruin: The Debutante Files (The Debutante Files Series Book 1) – Sophie Jordan
Good Girl: A Rockstar Romance (Wicked Book 1) – Piper Lawson
The Good Luck Charm – Helena Hunting
Grayson's Vow – Mia Sheridan
Grey: Fifty Shades of Grey as Told by Christian (Fifty Shades of Grey Series Book 4) – E.L. James
Hard As Stone: Heart of Stone Series #8 – K.M. Scott
Hard to Love – W. Winters
The Hardest Fall – Ella Maise
Hating The Boss – Natalie Wrye
The Heir (Windham Book 1) – Grace Burrowes
Heiress in Love: A Ministry of Marriage Novel (The Ministry of Marriage Book 1) – Christina Brooke
Heiress Without A Cause (Muses of Mayfair Book 1) – Sara Ramsey
Hello Stranger: The Ravenels, Book 4 – Lisa Kleypas
Her Forbidden Love Match (A Willow Cove Novel, #1) – Theresa Paolo
Her Husband's Harlot (Mayhem in Mayfair Book 1) – Grace Callaway
Hidden Gabriel: Formerly Winter Peril (Hidden Alphas Book 1) – Victoria Pinder
Highland Surrender – Tracy Brogan
Highlander Betrayed (Guardians of the Targe Book 1) – Lauren Wittig
His Favorite Mistress: A Novel (The Mistress Trilogy Book 3) – Tracy Anne Warren
His Virgin: A First Time Romance (His and Hers Book 1) – Vivian Wood
Hitman: My Real Life in the Cartoon World of Wrestling – Bret Hart
Hollywood Dirt – Alessandra Torre
Hollywood on Tap (Sweet Salvation Brewery) – Avery Flynn
The Hotel – Lola Darling
House of Scarlett (Legend Trilogy Book 2) – Meghan March
How a Lady Weds a Rogue: A Falcon Club Novel – Katharine Ashe
How to Marry a Duke Vicky Dreiling
How to Ravish a Rake – Vicky Dreiling
How to Seduce a Scoundrel – Vicky Dreiling
If He's Wicked (Wherlocke Book 1) – Hannah Howell
The Imperfectionists: A Novel – Tom Rachman
In the Arms of a Marquess (Rogues of the Sea Book 3) – Katherine Ashe
In the Unlikely Event – L.J. Shen
In Total Surrender – Anne Mallory
An Irresistible Temptation (The Cavallo Brothers Book 2) – Elsa Winckler
It Had to Be You (Chicago Stars Book 1) – Susan Elizabeth Philips
It Happened One Midnight: Pennyroyal Green Series – Julie Anne Long
It Started with a Scandal: Pennyroyal Green Series – Julie Anne Long
It's Not You: 27 (Wrong) Reasons You're Single – Sara Eckel
Just Roll With It (A Perfect Dish Book 4) – Tawdra Kandle
Kaleidoscope Hearts (A brother's best friend romance) – Claire Contreras
The Kingmaker (All the King's Men Duet Book 1) – Kennedy Ryan
Lady of Desire (Knight Miscellany Book 4) – Gaelen Foley
The Last Arrow (The Medieval Trilogy Book 3) – Marsha Canham
The Last Summer – Judith Kinghorn
Lead by Example: 50 Ways Great Leaders Inspire Results – John Baldoni
The Legend of Lyon Redmond: Pennyroyal Green Series – Julie Anne Long
Legend (The REAL series Book 6) – Katy Evans
Let's Do It: A Journey's End Novel – Ann Christopher
Life with My Sister Madonna – Christopher Ciccone
Lily and the Duke (Sex and the Season Book 1) – Helen Hardt
Lord of Scoundrels – Loretta Chase
Losing It – Cora Carmack
Lost Without You (The Debt Book 1) – Molly O’Keefe
A Loving Scoundrel: A Malory Novel (Malory-Anderson Family Book 7) – Johanna Lindsey
Luck Is No Lady (Fallen Ladies Book 1) – Amy Sandas
Lucky (Elite Doms of Washington Book 4) – Elizabeth SaFleur
A Mackenzie Clan Gathering (Mackenzies Series) – Jennifer Ashley
Mad About the Earl: A Ministry of Marriage Novel (The Ministry of Marriage Book 2) – Christina Brooker
Maid for the Billionaire (Book 1) (Legacy Collection) – Ruth Cardello
A Man Above Reproach – Evelyn Pryce
Manwhore (The Manwhore Series Book 1) – Katy Evans
Marriage For One – Ella Maise
Masques of Gold (Casablanca Classics Book 0) – Robert Gellis
Melt For Him (Fighting Fire Book 2) – Lauren Blakely
Midnight Angel (Stokehursts Book 1) – Lisa Kleypas
Midnight Pleasures With a Scoundrel (Scoundrels of St. James Book 4) – Lorraine Heath
Mine (The REAL series Book 2) – Katy Evans
Mine Till Midnight (Hathaways Book 1) – Lisa Kleypas
Miss Hillary Schools a Scoundrel (Beau Monde Book 1) – Samantha Grace
More Than Charming (Book 3 Dashing Nobles Series) – JoMarie DeGioia
The Most to Lose (The Redeemed series Book 1) – Laura Landon
Mr. Corporate (The Mister Series Book 3) – JA Huss
Mr Imperfect: Lost Boys #1 – Karina Bliss
Mr. Mysterious (The Mister Series Book 4) – JA Huss
Mr. Romantic (The Mister Series Book 2) – JA Huss
My Lady, My Lord: A Twist Series Novel – Katherine Ashe
My Notorious Gentleman (Inferno Club Book 6) – Gaelen Foley
My Reckless Surrender – Anna Campbell
My Ruthless Prince (Inferno Club Book 4) – Gaelen Foley
My Scandalous Viscount (Inferno Club Book 5) – Gaelen Foley
The Nearness of You – Iris Morland
Never a Mistress, No Longer a Maid (Kellington Book 1) – Maureen Driscoll
Never Let Me Go – Kazuo Ishiguro
No Good Duke Goes Unpunished: The Third Rule of Scoundrels (Rules of Scoundrels Book 3) – Sarah MacLean
No Mistress of Mine: An American Heiress in London – Laura Lee Guhrke
A Notorious Countess Confesses: Pennyroyal Green Series – Julie Anne Long
Notorious Pleasures (Maiden Lane Book 2) – Elizabeth Hoyt
Once a Soldier (Rogues Redeemed Book 1) – Mary Jo Putney
Once More, My Darling Rogue (Scandalous Gentlemen of St. James Book 2) – Lorraine Heath
One Last Time – Corinne Michaels
One Night in London: The Truth About the Duke – Caroline Linden
One Taste (The "One" Series Book 1) – K.A. Berg
One with You (Crossfire Series Book 5) – Sylvia Day
Only With Your Love (Vallerands Book 2) – Lisa Kleypas
The Paris Wife: A Novel – Paula McLain
Party Animals: A Hollywood Tale of Sex, Drugs, and Rock 'n' Roll Starring the Fabulous Allan Carr – Robert Hofler
Perfect (Elite Doms of Washington Book 3) – Elizabeth SaFleur
The Phantom of the Opera – Gaston Leroux
The Pleasure of Your Kiss – Teresa Medeiros
Prince of Dreams (Stokehursts Book 2) – Lisa Kleypas
Princes at War: The Bitter Battle Inside Britain's Royal Family in the Darkest Days of WWII – Deborah Cadbury
The Princess and the Peer (The Princess Brides series Book 1) – Tracy Anne Warren
Princess Charming: A Legendary Lovers Novel – Nicole Jordan
Pulse: Book Two in the Collide Series – Gail McHugh
A Rake's Midnight Kiss (Sons of Sin Book 2) – Anna Campbell
Reason to Wed (The Distinguished Rogues Book 7) – Heather Boyd
The Rebel Queen (The Rebel Queen Duet Book 2) – Jeana E. Mann
Refining Felicity (The School for Manners Series Book 1) – M.C. Beaton
Reflected in You (Crossfire, Book 2) – Sylvia Day
The Revenge of Lord Eberlin (The Secrets of Hadley Green) – Julia London
Ripped (The REAL series Book 5) – Katy Evans
Rock Me (Bodyguard Bad Boys Book 1) – Carly Phillips
Rogue (The REAL series Book 4) – Katy Evans
The Royal Arrangement (The Rebel Queen Duet Book 1) – Jeana E. Mann
Royally Bad (Bad Boy Royals Book 1) – Nora Flite
The Rule Book (Rule Breakers 1) – Jennifer Blackwood
The Scandal in Kissing an Heir: At the Kingsborough Ball – Sophie Barnes
Scandal Wears Satin (The Dressmakers Series Book 2) – Loretta Chase
A Scoundrel by Moonlight (Sons of Sin Book 4) – Anna Campbell
Seduced By A Scoundrel – Olivia Drake
The Seduction of Lady X – Julia London
The Seduction of Lord Stone (Dashing Widows) – Anna Campbell
Shattered With You (Stark Security Book 1) – J. Kenner
The Shoemaker's Wife: A Novel – Adriana Trigiani
Shutdown Player: Game On in Seattle (Seattle Sockeyes Book 7) – Jami Davenport
Signed (The Agency Series) – Marni Mann
A Single Glance (Irresistible Attraction Book 1) W. Winters
A Single Kiss (Irresistible Attraction Book 2) – W. Winters
A Single Touch (Irresistible Attraction Book 3) – W. Winters
The Six Wives of Henry VIII – Alison Weir
The Sleeping Beauty Trilogy (A Sleeping Beauty Novel) – A.N. Roquelaure
The Soldier (Windham Book 2) – Grace Burrowes
The Stolen Mackenzie Bride (Mackenzies Series Book 8) – Jennifer Ashley
The Studying Hours: How to Date a Douchebag – Sara Ney
Suddenly You – Lisa Kleypas
Summer Heat: A Storm Inside Novel (The Wild Pitch Series Book 1) – Alexis Anne
A Summer Seduction (Legend of St. Dwynwen Book 2) – Candace Camp
Tangled Beauty (Tangled, Book 1) – K.L. Middleton
Tank (Blue-Collar Billionaires Book 1) – M. Malone
Tempt the Devil – Anna Campbell
Tempted to Kiss (Hard to Love Book 3) – W. Winters
That Woman: The Life of Wallis Simpson, Duchess of Windsor – Anne Sebba
Thief of Shadows (Maiden Lane Book 4) – Elizabeth Hoyt
This Man (A This Man Novel Book 1) – Jodi Ellen Malpas
This Side of Paradise – F. Scott Fitzgerald
Three Nights of Sin – Anne Mallory
Tinseltown: Murder, Morphine, and Madness at the Dawn of Hollywood – William J. Mann
To Beguile a Beast (Legend of the Four Soldiers series Book 3) – Elizabeth Hoyt
To Kill a Mockingbird – Harper Lee
To Seduce a Sinner (Legend of the Four Soldiers series Book 2) – Elizabeth Hoyt
To Taste Temptation (Legend of the Four Soldiers series Book 1) – Elizabeth Hoyt
Too Distracting (The Lewis Cousins Book 3) – Bethany Lopez
Too Wicked to Kiss (Scoundrels & Secrets Book 1) – Erica Ridley
The Trouble With Being a Duke: At the Kingsborough Ball – Sophie Barnes
The Trouble with Dukes (Windham Brides Book 1) – Grace Burrowes
Troubles (Beekman Hills) – K.C. Enders
Truth or Beard: Enemies to Lovers Small Town Romantic Comedy (Winston Brothers Book 1) – Penny Reid
Twilight with the Infamous Earl: A Lords of Vice Novel – Alexandra Hawkins
Undisputed: How to Become the World Champion in 1,372 Easy Steps – Chris Jericho
Untouchable (Elite Doms of Washington Book 2) – Elizabeth SaFleur
Untouched – Anna Campbell
Victoria Victorious: The Story of Queen Victoria (Queens of England Book 3) – Jean Plaidy
The Viscount's Wicked Ways – Anne Mallory
Wallbanger (The Cocktail Series Book 1) – Alice Clayton
The Way to a Duke's Heart: The Truth About the Duke – Caroline Linden
We Two: Victoria and Albert: Rulers, Partners, Rivals – Gillian Gill
Well Hung (Big Rock Book 3) – Lauren Blakely
What a Duke Dares (Sons of Sin Book 3) – Anna Campbell
What Color Is Your Parachute? 2019: A Practical Manual for Job-Hunters and Career-Changers – Richard N. Bolles
When a Duke Loves a Woman: A Sins for All Seasons Novel – Lorraine Heath
When the Duke Found Love (The Wylder Sisters Book 3) – Isabella Bradford
Where Good Girls Go to Die: A Second Chance Romance (The Good Girls Series Book 1) – Holly Renee
Wicked Becomes You – Meredith Duran
Wicked in Your Arms: Forgotten Princesses – Sophie Jordan
Wicked Intentions (Maiden Lane Book 1) – Elizabeth Hoyt
Written on Your Skin – Meredith Duran
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mtalviharju022583-blog · 6 years ago
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Friendship Joel Osteen Salvation quotes
Friendship quotes
Friendship is not about who you've known the longest. It's about who walked into your life, said "I'm here for you" and proved it.
Friendship is born at that moment when one person says to another: "What! You too? I thought I was the only one." -C.S. Lewis
The most beautiful discovery true friends make is that they can grow separately without growing apart. -Elizabeth Foley
I'm glad friendship doesn't come with price tags. For if it does, I'd never afford someone as great as you.
The language of friendship is not words but meanings. -Henry David Thoreau
Walking with a friend in the dark is better than walking alone in the light. -Helen Keller
Joel Osteen quotes
Choosing to be positive and having a grateful attitude is going to determine how you're going to live your life.
When you focus on being a blessing, God makes sure that you are always blessed in abundance.
You can change your world by changing your words... Remember, death and life are in the power of the tongue.
Do all you can to make your dreams come true.
Why don’t you start believing that no matter what you have or haven’t done, that your best days are still out in front of you.
Salvation quotes
The thief had nails through both hands, so that he could not work; and a nail through each foot, so that he could not run errands for the Lord; he could not lift a hand or a foot toward his salvation, and yet Christ offered him the gift of God; and he took it. Christ threw him a passport, and took him into Paradise.
Salvation is from our side a choice, from the divine side it is a seizing upon, an apprehending, a conquest by the Most High God. Our “accepting” and “willing” are reactions rather than actions. The right of determination must always remain with God. ~ A.W. Tozer, Preacher
Surely scripture is right when it makes the sin of sins that unbelief, which is at bottom nothing else than a refusal to take the cup of salvation. Surely no sharper grief can be inflicted upon the Spirit of God than when we leave His gifts neglected and unappropriated. ~ Alexander MacLaren, Pastor
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mtalviharju1983 · 6 years ago
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Courage, friendship, salvation quotes 6-10-2018
Courage quotes
What would life be if we had no courage to attempt anything? -Vincent van Gogh
It is not because things are difficult that we do not dare; it is because we do not dare that they are difficult. -Lucius Annaeus Seneca
Courage is the art of being the only one who knows you’re scared to death. -Harold Wilson
All our dreams can come true, if we have the courage to pursue them. -Walt Disney
Courage is going from failure to failure without losing your enthusiasm. -Winston Churchill
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Friendship quotes
Friendship is not about who you've known the longest. It's about who walked into your life, said "I'm here for you" and proved it.
Friendship is born at that moment when one person says to another: "What! You too? I thought I was the only one." -C.S. Lewis
The most beautiful discovery true friends make is that they can grow separately without growing apart. -Elizabeth Foley
I'm glad friendship doesn't come with price tags. For if it does, I'd never afford someone as great as you.
Friendship means understanding, not agreement. It means forgiveness, not forgetting. It means the memories last, even if contact is lost.
Friendship is the only cement that will ever hold the world together. -Woodrow T. Wilson
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Salvation quotes
I am not the author of the plan of salvation, but I am responsible for the way I preach it. ~ Billy Sunday, Evangelist
And now let me address all of you, high and low, rich and poor, one with another, to accept of mercy and grace while it is offered to you; Now is the accepted time, now is the day of salvation; and will you not accept it, now it is offered unto you? ~ George Whitefield, Preacher & Evangelist
Christians do not practically remember that while we are saved by grace, altogether by grace, so that in the matter of salvation works are altogether excluded; yet that so far as the rewards of grace are concerned, in the world to come, there is an intimate connection between the life of the Christian here and the enjoyment and the glory in the day of Christ’s appearing. ~ George Mueller, Missionary
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bertiemyhill · 4 years ago
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Artist work 
Recommendation Ellie 
Her work revolves around moving image and sound which builds into an acoustic field of rythm and movement.
There is a foley element to her work that corrlates to actions hapening on screen.  She also works with speech in the form of text within the video.
0 notes
minnamarie1983-blog · 7 years ago
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Friendship & love quotes 11-8-2017
Friendship quotes
Friendship is not about who you've known the longest. It's about who walked into your life, said "I'm here for you" and proved it.
Friendship is born at that moment when one person says to another: "What! You too? I thought I was the only one." -C.S. Lewis
The most beautiful discovery true friends make is that they can grow separately without growing apart. -Elizabeth Foley
I'm glad friendship doesn't come with price tags. For if it does, I'd never afford someone as great as you.
Friendship means understanding, not agreement. It means forgiveness, not forgetting. It means the memories last, even if contact is lost.
Friendship is the only cement that will ever hold the world together. -Woodrow T. Wilson
A true friend is the person who walks in when the rest of the world walks out.
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Love quotes
Love takes off masks that we fear we cannot live without and know we cannot live within.”
— James Baldwin
“Love yourself first and everything else falls into line. You really have to love yourself to get anything done in this world.”
— Lucille Ball
“Once the realization is accepted that even between the closest human beings infinite distances continue, a wonderful living side by side can grow, if they succeed in loving the distance between them which makes it possible for each to see the other whole against the sky.”
— Rainer Maria Rilke
“The most important thing in life is to learn how to give out love, and to let it come in.”
— Morrie Schwartz
“If I know what love is, it is because of you.”
— Herman Hesse
“I love you not because of who you are, but because of who I am when I am with you.”
— Roy Croft
“Love is a friendship set to music.”
— Joseph Campbell
“We are shaped and fashioned by what we love.”
— Johann Wolfgang von Goethe
“When we are in love we seem to ourselves quite different from what we were before.”
— Blaise Pascal
“The way to love anything is to realize that it may be lost.”
— Gilbert K. Chesterton
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davidrivkin · 3 months ago
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Why Trump's Conviction Can't Stand
By David B. Rivkin, Jr., and Elizabeth Price Foley
September 8, 2024, in the Wall Street Journal
Donald Trump runs no risk of going to prison in the middle of his campaign, thanks to Judge Juan Merchan’s decision Friday to postpone sentencing until Nov. 26. The delay gives his lawyers more time to prepare an appeal. Fortunately for Mr. Trump, his trial was overwhelmingly flawed, and a well-constructed appeal would ensure its ultimate reversal.
A central problem for the prosecution and Judge Merchan lies in Article VI of the U.S. Constitution, which makes federal law the “supreme law of the land.” That pre-empts state law when it conflicts with federal law, including by asserting jurisdiction over areas in which the federal government has exclusive authority.
Mr. Trump’s conviction violates this principle because it hinges on alleged violations of state election law governing campaign spending and contributions. The Federal Election Campaign Act pre-empts these laws as applied to federal campaigns. If it didn’t, there would be chaos. Partisan state and local prosecutors could interfere in federal elections by entangling candidates in litigation, devouring precious time and resources.
That hasn’t happened except in the Trump case, because the Justice Department has always guarded its exclusive jurisdiction even when states have pushed back, as has happened in recent decades over immigration enforcement.
The normal approach would have been for the Justice Department to inform District Attorney Alvin Bragg, who was contemplating charges against Mr. Trump, of the FECA pre-emption issue. If Mr. Bragg didn’t follow the department’s guidance, it would have intervened at the start of the case to have it dismissed. Instead the department allowed a state prosecutor to interfere with the electoral prospects of the chief political rival of President Biden, the attorney general’s boss.
Mr. Trump was indicted under New York’s law prohibiting falsification of business records, which is a felony only if the accused intended “to commit another crime” via the false record. Judge Merchan instructed the jury that the other crime was Section 17-152 of New York election law, which makes it a misdemeanor to “conspire to promote or prevent the election of any person to a public office by unlawful means.” Prosecutors alleged that Mr. Trump violated this law by conspiring with his lawyer, Michael Cohen, and Trump-related businesses to “promote” his presidential election by coding hush-money payments as “legal expenses” when they should have been disclosed publicly as campaign expenses or contributions—matters that are governed by FECA.
FECA declares that its provisions “supersede and preempt any provision of state law with respect to election to Federal office.” The 1974 congressional conference committee report accompanying enactment of FECA’s pre-emption language states: “It is clear that the Federal law occupies the field with respect to reporting and disclosure of political contributions and expenditures by Federal candidates.” Federal Election Commission regulations likewise declare that FECA “supersedes State law” concerning the “disclosure of receipts and expenditures by Federal candidates” and “limitation on contributions and expenditures regarding Federal candidates.”
The New York State Board of Elections agreed in a 2018 formal opinion that issues relating to disclosure of federal campaign contributions and expenditures are pre-empted because “Congress expressly articulated ‘field preemption’ of federal law over state law in this area” to avoid federal candidates’ “facing a patchwork of state and local filing requirements.”
In using New York’s election law to brand Mr. Trump a felon based on his actions with respect to a federal election, Mr. Bragg subverts FECA’s goal of providing predictable, uniform national rules regarding disclosure of federal campaign contributions and expenses, including penalties for noncompliance. Congress made its goals of uniformity and predictability clear not only in FECA’s sweeping pre-emption language but also in its grant of exclusive enforcement authority to the FEC for civil penalties and the Justice Department for criminal penalties. Both the FEC and Justice Department conducted yearslong investigations to ascertain whether Mr. Trump’s hush-money payments violated FECA, and both declined to seek any penalties.
Prior to Mr. Trump’s New York prosecution, it would have been unthinkable for a local or state prosecutor to prosecute a federal candidate predicated on whether or how his campaign reported—or failed to report—contributions or expenditures. In 2019 the FEC investigated whether Hillary Clinton’s 2016 presidential campaign failed to disclose millions in contributions from an outside political action committee. The agency deadlocked, and no penalties were imposed. In 2022 the FEC levied $113,000 in civil penalties against Mrs. Clinton’s campaign for violating FECA because it improperly coded as “legal services,” rather than campaign expenditures, money paid to Christopher Steele for production of the “dossier” that fueled the Russia-collusion hoax. In neither instance did any state or local prosecutor indict Mrs. Clinton under state election law based on failure to disclose these contributions or expenditures properly. If New York’s Trump precedent stands, Mrs. Clinton could still be vulnerable to prosecution, depending on various states’ statutes of limitation and the Justice Department’s potential involvement.
Mr. Bragg’s prosecution of Mr. Trump is plagued by many reversible legal errors, of which the failure to accord pre-emptive force to FECA is the strongest grounds for its reversal on appeal. The prosecutor’s interference in the 2024 presidential election process has created legal and political problems. The Justice Department’s failure to intervene before the trial is a dereliction of duty.
The department aggressively prosecuted Mr. Cohen based on the same hush-money payments, so it was well aware that New York’s prosecution invaded its exclusive FECA jurisdiction. This is another stark example of the Biden administration’s incompetence—or, worse, the distortion of justice through a partisan lens. It is left to the appellate courts, and ultimately the Supreme Court, to clean up the mess Mr. Bragg and the Justice Department have made.
Mr. Rivkin served at the Justice Department and the White House Counsel’s Office during the Reagan and George H.W. Bush Administrations. Ms. Foley is a professor of constitutional law at Florida International University College of Law. Both practice appellate and constitutional law in Washington.
Source: https://www.wsj.com/opinion/why-trumps-hush-money-conviction-cant-stand-appeal-federal-law-pre-empts-11ae9dc3
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simply-ivanka · 3 months ago
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Why Trump’s Conviction Can’t Stand
It rests on an intent to violate a state law that is pre-empted by the Federal Election Campaign Act.
By David B. Rivkin Jr. and Elizabeth Price Foley Wall Street Journal
Donald Trump runs no risk of going to prison in the middle of his campaign, thanks to Judge Juan Merchan’s decision Friday to postpone sentencing until Nov. 26. The delay gives his lawyers more time to prepare an appeal. Fortunately for Mr. Trump, his trial was overwhelmingly flawed, and a well-constructed appeal would ensure its ultimate reversal.
A central problem for the prosecution and Judge Merchan lies in Article VI of the U.S. Constitution, which makes federal law the “supreme law of the land.” That pre-empts state law when it conflicts with federal law, including by asserting jurisdiction over areas in which the federal government has exclusive authority.
Mr. Trump’s conviction violates this principle because it hinges on alleged violations of state election law governing campaign spending and contributions. The Federal Election Campaign Act pre-empts these laws as applied to federal campaigns. If it didn’t, there would be chaos. Partisan state and local prosecutors could interfere in federal elections by entangling candidates in litigation, devouring precious time and resources.
That hasn’t happened except in the Trump case, because the Justice Department has always guarded its exclusive jurisdiction even when states have pushed back, as has happened in recent decades over immigration enforcement.
The normal approach would have been for the Justice Department to inform District Attorney Alvin Bragg, who was contemplating charges against Mr. Trump, of the FECA pre-emption issue. If Mr. Bragg didn’t follow the department’s guidance, it would have intervened at the start of the case to have it dismissed. Instead the department allowed a state prosecutor to interfere with the electoral prospects of the chief political rival of President Biden, the attorney general’s boss.
Mr. Trump was indicted under New York’s law prohibiting falsification of business records, which is a felony only if the accused intended “to commit another crime” via the false record. Judge Merchan instructed the jury that the other crime was Section 17-152 of New York election law, which makes it a misdemeanor to “conspire to promote or prevent the election of any person to a public office by unlawful means.” Prosecutors alleged that Mr. Trump violated this law by conspiring with his lawyer, Michael Cohen, and Trump-related businesses to “promote” his presidential election by coding hush-money payments as “legal expenses” when they should have been disclosed publicly as campaign expenses or contributions—matters that are governed by FECA.
FECA declares that its provisions “supersede and preempt any provision of state law with respect to election to Federal office.” The 1974 congressional conference committee report accompanying enactment of FECA’s pre-emption language states: “It is clear that the Federal law occupies the field with respect to reporting and disclosure of political contributions and expenditures by Federal candidates.” Federal Election Commission regulations likewise declare that FECA “supersedes State law” concerning the “disclosure of receipts and expenditures by Federal candidates” and “limitation on contributions and expenditures regarding Federal candidates.”
The New York State Board of Elections agreed in a 2018 formal opinion that issues relating to disclosure of federal campaign contributions and expenditures are pre-empted because “Congress expressly articulated ‘field preemption’ of federal law over state law in this area” to avoid federal candidates’ “facing a patchwork of state and local filing requirements.”
In using New York’s election law to brand Mr. Trump a felon based on his actions with respect to a federal election, Mr. Bragg subverts FECA’s goal of providing predictable, uniform national rules regarding disclosure of federal campaign contributions and expenses, including penalties for noncompliance. Congress made its goals of uniformity and predictability clear not only in FECA’s sweeping pre-emption language but also in its grant of exclusive enforcement authority to the FEC for civil penalties and the Justice Department for criminal penalties. Both the FEC and Justice Department conducted yearslong investigations to ascertain whether Mr. Trump’s hush-money payments violated FECA, and both declined to seek any penalties.
Prior to Mr. Trump’s New York prosecution, it would have been unthinkable for a local or state prosecutor to prosecute a federal candidate predicated on whether or how his campaign reported—or failed to report—contributions or expenditures. In 2019 the FEC investigated whether Hillary Clinton’s 2016 presidential campaign failed to disclose millions in contributions from an outside political action committee. The agency deadlocked, and no penalties were imposed. In 2022 the FEC levied $113,000 in civil penalties against Mrs. Clinton’s campaign for violating FECA because it improperly coded as “legal services,” rather than campaign expenditures, money paid to Christopher Steele for production of the “dossier” that fueled the Russia-collusion hoax. In neither instance did any state or local prosecutor indict Mrs. Clinton under state election law based on failure to disclose these contributions or expenditures properly. If New York’s Trump precedent stands, Mrs. Clinton could still be vulnerable to prosecution, depending on various states’ statutes of limitation and the Justice Department’s potential involvement.
Mr. Bragg’s prosecution of Mr. Trump is plagued by many reversible legal errors, of which the failure to accord pre-emptive force to FECA is the strongest grounds for its reversal on appeal. The prosecutor’s interference in the 2024 presidential election process has created legal and political problems. The Justice Department’s failure to intervene before the trial is a dereliction of duty.
The department aggressively prosecuted Mr. Cohen based on the same hush-money payments, so it was well aware that New York’s prosecution invaded its exclusive FECA jurisdiction. This is another stark example of the Biden administration’s incompetence—or, worse, the distortion of justice through a partisan lens. It is left to the appellate courts, and ultimately the Supreme Court, to clean up the mess Mr. Bragg and the Justice Department have made.
Mr. Rivkin served at the Justice Department and the White House Counsel’s Office during the Reagan and George H.W. Bush Administrations. Ms. Foley is a professor of constitutional law at Florida International University College of Law. Both practice appellate and constitutional law in Washington.
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lvaartebella · 7 years ago
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Vignette: Elizabeth Foley
"Making the work becomes a journey of balance in and of itself." - Elizabeth Foley
“My work focuses on the interplay of lives and the concept of life-balance, explains Elizabeth Foley. “I explore the circle as a resolved but potentially irregular shape, representing both the balance and variety we all strive for in our lives. How is wholeness achieved and what tips the circle off center? What distracts from the main circle? Does wholeness come at the price of predictability?” 
Printmaking need not avoid explorations of depth in form and space, yet it would appear to be a common trend in contemporary art that prints be concerned with surface, texture, pattern, and field. Of course, this technical and compositional observation doesn’t restrict depth in subject or theme. Much to the contrary, the embrace or even celebration of 2-dimensional surface art by working print makers calls attention to the profundity of abstract and limited representational imagery. Foley shows how much the opportunity for suggestion and meaning in her work depends on the invitation to the viewer inherent in abstraction.
“The vibrant dialogue between shape, color, and pattern invites viewers into the work. I create spaces in which the viewer feels involved in the work: being both delighted and challenged. The colors activate the imagination; they influence and play off each other in order to shift and tilt planes of information. Overlapping transparencies create the illusion of distance and scale, as well as deepening relationships between shapes.” Foley uses relief, monoprint, and collagraph techniques together to make unique images from the same plates – “a potential template for life balance”. She is currently exhibiting in "Venn Diagram" Work by Blake Snyder Eames & Elizabeth Foley, running through December 18, 2017 at The Grand Theater, Frankfort, KY, and will be participating in the Sixth Annual Black Friday Art Sale at Loudoun House in Lexington, December 1 from 6-9pm and December 2 from 2-7pm
Foley was also selected to be a part of the inaugural Hadley Creatives Program, a 6-month learning and engagement experience for local artists who are at a pivotal point in their careers administered by The Community Foundation of Louisville and Capital Creative.
Permanent Collections Bluegrass Printmakers Cooperative Saint Joseph Hospital Chase Bank, Cincinnati, OH and Louisville, KY Saint Joseph Jessamine County Emergency Treatment Center Good Samaritan Hospital Southern Graphics Council Kentucky One Health Alliance Tiger Lily Press Keystone Financial Group University of Arizona LexArts University of Kentucky Hospital Littler Mendelson, P.C. University of Miami May Department Store Washington University School of Art Ohio University School of Art West Virginia University Ohio University Alden Library
Hometown: Wellesley, Massachusetts Education: BFA, Graphic Design, Washington University, 1990; MFA, Printmaking, Ohio University, 1997; M.Ed, Secondary Education, Ohio University, 1997 Website: foleyprints.com Instagram: @foleyprints
  Scroll down for more images
Written by Keith Waits. Entire contents copyright © 2017 Louisville Visual Art. All rights reserved.
Are you interested in being on Artebella? Click here to learn more
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americanmysticom · 5 years ago
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This Impeachment Subverts the Constitution
http://davidbrivkin.com/this-impeachment-subverts-the-constitution/
By David B. Rivkin, Jr., and Elizabeth Price Foley
October 25, 2019, in the Wall Street Journal
peaker Nancy Pelosi has directed committees investigating President Trump to “proceed under that umbrella of impeachment inquiry,” but the House has never authorized such an inquiry. Democrats have been seeking to impeach Mr. Trump since the party took control of the House, though it isn’t clear for what offense. Lawmakers and commentators have suggested various possibilities, but none amount to an impeachable offense.
The effort is akin to a constitutionally proscribed bill of attainder—a legislative effort to punish a disfavored person. The Senate should treat it accordingly.
The term “Bill of Attainder” refers to the act of declaring a group of people guilty of a crime, and punishing them for it, usually without a trial. Officials have used bills of attainder to strip individuals of everything from their property to their lives. For example, bills of attainder caused the famous executions of several people by the English king, Henry VIII. To explore this concept, consider the following Bill of Attainder definition.
https://legaldictionary.net/bill-of-attainder/
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plusorminuscongress · 6 years ago
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New story in Politics from Time: Democrats Are No Longer Afraid of a Trillion-Dollar Price Tag. Here’s Why
When the Obama Administration set out to design a stimulus to stop the economy from a freefall in 2009, word came back from Republican and Democratic moderates in Congress that it couldn’t exceed $800 billion.
That didn’t stop many of its conservative critics from decrying the plan as a “trillion-dollar stimulus.”
But as Democratic contenders gear up for the 2020 primary, they no longer seem afraid of the trillion-dollar price tag. In fact, several major candidates are leaning into it with proposals that tout the dollar sign as a marker of seriousness.
Minnesota Sen. Amy Klobuchar wants to spend a trillion dollars upgrading America’s infrastructure. Massachusetts Sen. Elizabeth Warren wants to spend more than a trillion dollars erasing student debt and making college tuition free. California Sen. Kamala Harris has proposed a $3 trillion tax credit plan. Former Texas Rep. Beto O’Rourke wants to spend $5 trillion fighting climate change. And Vermont Sen. Bernie Sanders wants to spend trillions on Medicare for All.
Even some of the generic Democratic plans have trillion-dollar price tags. The Center for American Progress, a liberal think tank, has proposals for expanding Medicare and improving infrastructure that cost at least $1 trillion.
(Note that these plans count spending over as much as a 10-year period.)
“Trillion is the new billion,” joked Jared Bernstein, a senior fellow at the Center on Budget and Policy Priorities, a progressive think tank.
Asked for a comment about the proposals, Erin Perrine, deputy communications director for the Trump campaign, said only, “Socialism is expensive.”
Here’s a closer look at the major reasons why Democrats are touting trillion-dollar plans.
America has a few trillion-dollar problems
Erik McGregor—Pacific Press/LightRocket/Getty Images Activist groups and concerned citizens held a rally at Foley Square and then marched to New York City Hall in protest of Trumps attack on the Paris climate agreement on June 1, 2017.
The issues Democrats are discussing have some pretty big costs associated with them.
Americans owe a total of more than $1.5 trillion in student loans. A report from the U.N. Intergovernmental Panel on Climate Change estimates that the world should spend about $2.4 trillion per year on clean energy between now and 2035 to avoid the most catastrophic effects of climate change. And the American Society of Civil Engineers estimates that the U.S. needs to spend $4.5 trillion by 2025 to improve roads, bridges, dams, airports and schools, among other things.
Given those estimates, plans to spend a trillion dollars erasing student debt, improving infrastructure and fighting climate change are arguably on the low end. And some experts argue that the candidates will do better by putting forward a plan that seriously addresses them.
“Ambitious plans are going to have ambitious price tags,” said Mark Schmitt, director of the political reform program at the New America Foundation. “They’re going to get bashed exactly the same no matter what. If you came up with a health care plan that cost a mere $50 billion, it would get beat up in exactly the same way, so you might as well get it out there now.”
A trillion dollars also isn’t as much money as it used to be. Given inflation, a trillion dollars in 2000 would be nearly $1.5 trillion in today’s dollars.
Donald Trump had a trillion-dollar plan in 2016
Mark Lyons—Getty Images Republican Presidential candidate Donald Trump models a hard hat in support of the miners during his rally at the Charleston Civic Center on May 5, 2016 in Charleston, West Virginia.
Former Secretary of State Hillary Clinton had a typical Democratic pitch in 2016: a $275 billion infrastructure plan over five years to fix roads, bridges, airports and water systems. “We’re going to have the biggest infrastructure investment program since World War II,” she told rally-goers.
But Trump had a plan nearly four times as large: $1 trillion on infrastructure. “Her number is a fraction of what we’re talking about. We need much more money to rebuild our infrastructure,” he told Fox Business Network.
Fiscal conservatives weren’t big fans of Trump’s plan. After the election Senate Majority Leader Mitch McConnell warned him against trying to pass a “trillion-dollar stimulus,” but Trump insisted he need to “prime the pump” and influential advisers like Steve Bannon argued that low interest rates meant it was “the greatest opportunity to rebuild everything. Shipyards, ironworks, get them all jacked up.”
Trump’s infrastructure plan has stalled repeatedly, but he’s never backed down from the idea. In a recent meeting with Democratic leaders in Congress, he even agreed in principle to $2 trillion in infrastructure spending.
Whether or not Trump succeeds in getting a plan that large through Congress, he’s raised the bar on how much a candidate can promise to spend and shown that, at least for a Republican candidate, the number alone is not disqualifying.
Bernstein, who was chief economic adviser to Vice President Joe Biden during the Obama Administration, recalled some of the internal debate over the stimulus was about keeping it below a trillion dollars.
“There was a sense that keeping it below a trillion was a political reality,” he said. “We can argue about whether that was right or wrong, but it certainly wouldn’t be the case right now.”
Trump signed a $1.5 trillion tax cut as president
Brendan Smialowski—AFP/Getty Images President Donald Trump signs the Tax Cut and Reform Bill in the Oval Office at The White House on Dec. 22, 2017.
Trump may not have gotten a trillion dollars in spending approved, but he did sign into law a $1.5 trillion tax cut. But while the Tax Cuts and Jobs Act cut individual income taxes for about two-thirds of households, according to the Tax Policy Center, polls have consistently shown that Americans don’t see it that way, and the law remains unpopular.
The law increased the deficit as well. A recent analysis by the Tax Foundation based on data from the first year of the Trump tax cuts projected that they will end up adding $900 billion to federal deficits over 10 years.
That has given a boost to Democrats seeking to spend more on their issues in several ways. First, it reinforces the idea that a trillion dollars is a reasonable amount of money for a presidential proposal. Second, it makes it easier for Democrats to pay for their ideas, since they can simply pledge to roll back some of the unpopular Trump tax cuts that benefited the wealthy. And third, it offers a counter to traditional conservative arguments about adding to the deficit.
“He defanged the Republican Party’s scolding about government spending and deficits,” says Jesse Lee, a spokesman for the Center for American Progress Action Fund. “There is nothing that Democrats are proposing that would be remotely in line with the amount of added deficits [from the Trump tax cuts] compared to the minuscule amount of benefits.”
Bernstein agreed. “Not every trillion-dollar idea is any good,” he said.
With Brian Bennett in Washington
By Ryan Teague Beckwith on May 08, 2019 at 12:25PM
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itunesbooks · 6 years ago
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What Would Cleopatra Do? - Elizabeth Foley & Beth Coates
What Would Cleopatra Do? Life Lessons from 50 of History's Most Extraordinary Women Elizabeth Foley & Beth Coates Genre: Humor Price: $12.99 Publish Date: November 6, 2018 Publisher: Scribner Seller: SIMON AND SCHUSTER DIGITAL SALES INC Irreverent, inspirational, and a visual delight, What Would Cleopatra Do? shares the wisdom and advice passed down from Cleopatra, Queen Victoria, Dorothy Parker, and forty-seven other heroines from past eras on how to handle an array of common problems women have encountered throughout history and still face today. What Would Cleopatra Do? tackles issues by reminding us of inspiring feminists from the past, telling their stories with warmth, humor, and verve. From sticking up for yourself, improving body image, deciding whether to have children, finding a mentor, getting dumped, feeling like an imposter, being unattractive, and dealing with gossip, we can learn a lot by reading motivational stories of heroic women who, living in much tougher times through history, took control of their own destinies and made life work for them. Here are Cleopatra’s thoughts on sibling rivalry, Mae West on positive body image, Frida Kahlo on finding your style, Catherine the Great on dealing with gossip, Agatha Christie on getting dumped, Hedy Lamarr on being underestimated—to list only a few—as well as others who address dilemmas including career-planning, female friendship, loneliness, financial management, and political engagement. Featuring whimsical illustrations by L.A.-based artist Bijou Karman, What Would Cleopatra Do? is a distinctive, witty, and gift-worthy tribute to history’s outstanding women. http://dlvr.it/R1FMTk
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