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Phase IV will be released on 4K Ultra HD + Blu-ray on March 26 via Vinegar Syndrome. Adam Maida designed the new cover art for the 1974 sci-fi horror film are include; the original poster is on the reverse side.
Acclaimed title designer Saul Bass (Psycho, North by Northwest) makes his lone directorial effort from a script by Mayo Simon (Futureworld). Michael Murphy, Nigel Davenport, and Lynne Frederick star.
Phase IV has been newly restored in 4K from its 35mm original camera negative with HDR and mono sound. The 84-minute theatrical cut and an 89-minute preview version are included.
Special features for the three-disc (one 4K UHD, two Blu-ray) set are listed below.
Special features:
84-mintue theatrical version (4K UHD + Blu-ray)
89-minute preview version (Blu-ray)
Theatrical audio commentary by film historian Matthew Asprey Gear
Evolutions: The Making of Phase IV - 48-minute documentary with Jeffrey Bass, actor Michael Murphy, screenwriter Mayo Simon, archivist Sean Savage, and Saul Bass biographer Pat Kirkham (new)
Formicidae Sinfonia: The Music and Sounds of Phase IV - 15-minute featurette with composer Brian Gascoigne and electronic music artist David Vorhaus
Deleted shots and sequences
Raw footage from the original ending montage sequence
Theatrical trailer
Still gallery
youtube
Following a mysterious eclipse-like solar event, scientists begin to notice strange and unexplainable behavioral changes in ants. While initially written off as an unconcerning anomaly, it soon becomes apparent that the creatures have developed advanced intelligence along with the ability to work collectively. Scientists Ernest Hubbs and James Lesko have been transferred to a futuristic lab in a remote part of the Arizona desert in which to study these phenomena. However, when the ants begin to attack and kill both wildlife and humans, Hubbs and Lesko realize that the entire human race might now be at a deadly evolutionary disadvantage to the tiny insects...
Pre-order Phase IV.
#phase iv#saul bass#michael murphy#lynne frederick#vinegar syndrome#dvd#gift#adam maida#psycho#north by northwest#horror#70s horror#1970s horror#sci fi#70s science fiction#Youtube
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The field of human rights is littered with hypocrisy. No individual or organization possesses a scale of judgment that carefully matches the condemnation to the crime and then applies it consistently across a globe of oppression; personal and political biases always skew the calculation. Governments never separate human rights from national interests and domestic politics.
— Who Cares About Human Rights?
#adam maida#history#politics#international relations#human rights#activism#government#oppression#hypocrisy
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"Only Tuesday?" Adam gave a chuckle that ended in a sigh, he'd personally found this near death encounter sort of fun, especially compared to the 5th Blight. But living breathing people can be intimidated and distracted with nonsense words and Darkspawn can't, not to mention they looked a lot better. He placed his swords in their sheaths.
"Now that's an offer I can't refuse. Especially if I haven't even seen the best showing yet." He said with a grin before putting out his hand to shake and/or help her up with as he continued. "Besides I can't just leave a beautiful woman I just helped kill thugs with go without introducing myself now can I?" He said with a smirk, ever the shameless flirt of a person he ever was, before adding. "Adam Bayher, a pleasure."
@stellstells asked: "At least we’re alive. That’s no small feat." [From Adam for Maida] / prompts tag.
“ oh, you might say that – but i’d like to remind you: it’s just tuesday. ” a breathy laugh blends well with maida’s sarcastic humor, her now relaxed body slowly sliding down the wall that was recently used as a cover from those carta’s thugs. oh, darktown and its heartwarming hospitality! nothing says ‘welcome home’ better than an assassination attempt. the adrenaline rush finally begins to simmer down, hawke grins and stores away the few arrows she was prepared to nock in case reinforcements decided to pop out from nowhere (like the usually do.)
“ crazier shit goes down on the weekend, you know? if you wanna stick around for that. ” she offers a playful wink and a shrug, fully aware of how uninviting the proposition sounds.
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BLACK WOMEN IN THE WARTIME STRUGGLE
Black women were on the frontlines of civil rights activism during the war years.
The grassroots organizing work of young leaders like Juanita Jackson, Ella Baker and Rosa Parks helped fuel a dramatic increase in NAACP membership and branch activism. Union organizers like Dollie Lowther Robinson and Maida Springer labored to ensure workers’ rights. Black women also engaged in direct-action protests against segregation like Pauli Murray’s 1940 arrest for sitting in the whites-only section of a bus in Virginia.
Grassroots organizers Juanita Jackson, Ella Baker, and Rosa Parks helped the NAACP grow dramatically during the war. - https://www.mdhistory.org/resources/jackson-and-mitchell-family-portrait/ - https://www.loc.gov/pictures/item/94504496/ - https://www.loc.gov/pictures/item/2015647352/
More than half a million Black women left farm and domestic work for better-paying jobs in wartime shipyards and defense factories. But they had to struggle against employers who refused to hire Black women (or confined them to menial jobs) and white employees who resisted working alongside them.
Black women also overcame determined opposition to enter the armed services. Mary McLeod Bethune served as a special assistant in the War Department and worked with the National Council of Negro Women and Eleanor Roosevelt to open the Women’s Army Corps (WAC) to Black recruits. Eventually, 6,500 served. Bethune also lobbied successfully for officer appointments. Still, Black WACs served in segregated units and were often assigned low-skilled work. The Army also limited the number of Black nurses and restricted them to segregated hospitals. Conditions in the Navy were even worse. Secretary of the Navy Frank Knox opposed the entry of Black women into the service’s women’s auxiliary (WAVES). They were only admitted after his death in 1944.
Major Charity E. Adams inspects a Women’s Army Corps (WAC) battalion in England, February 15, 1945 (https://catalog.archives.gov/id/531249)
African American women also took on the then taboo subject of sexual violence. Sexual assaults on Black women by white men were a parallel offense to the lynchings of Black men. A 1944 Alabama rape case involving Recy Taylor sparked an NAACP investigation by Rosa Parks and widespread publicity. The Committee for Equal Justice, organized by Parks, led a national protest drive to bring the seven, armed white rapists to justice. Its allies included the Southern Negro Youth Congress (SNYC), described by historian Erik McDuffie as “the shock troops for Black equality across the Jim Crow South during the war.” The SNYC conducted wartime campaigns for desegregation and voting and labor rights. Its leadership included women like Rose Mae Catchings and Sallye Bell Davis, mother of activist Angela Davis.
Please visit our current special exhibition BLACK AMERICANS, CIVIL RIGHTS, AND THE ROOSEVELTS, 1932-1962: https://www.fdrlibrary.org/civil-rights-special-exhibit
#women's history month#rosa parks#Juanita Jackson#Ella Baker#Recy Taylor#wwii#world war ii#1940s#ww2#black american history#american history
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as someone who. does not keep up with games pre-release, like, at all. what was below zero like before it was changed? i don't think i even heard about BZ until after it was released which is shocking considering how obsessed i am with the first game lmao
God so. It was actually pretty dang different. Jacksepticeye has a playlist where he played through the early access below zero builds. If you were unsatisfied with below zero (as i very much was), I greatly recommend looking up the playthroughs and checking them out cause the whole arc is sooo much better than what we ended up getting
for starters, robin's sister sam wasnt dead. Robin and her spoke to each other, as her sister was on a space station orbiting 4546B, and the main plot was about thwarting alterras meddling with the planet and keep the precursors and their tech from their knowledge, with robin as an actor on the surface doing stuff, and robins sister on the satellite using her admin job to keep alterra off of robins back. it was actually a pretty dope setup!
Another major difference is what pushed robin into the ocean, which was a huge avalanche destroying the base she was in. As in, robin was ACTUALLY stationed in the frozen zone working, when an avalanche destroys her base and forces her to go into the water to survive.
All of this was changed in the final cut to remove sam from the plot and having robin instead just crash land on 4546B to try to find her.
I think they also changed Maida's purpose a LOT because she was hinted at being more useful and it feels like, if the whole 'keeping alterra off your back' arc had remained, she would have had much more to do with it than she ended up having in the final cut. which was bossing you around to fetch a single thing and then not being relevant again
It just really feels like something went wrong and the story of the game is half baked at MOST (not to mention the design of the map but that's for another rant...) because like... when robin gets al-an in her head she is just so adamant on removing her and then SHE STAYS THAT WAY basically the whole game? al-an is nothing but a sweetheart to her and shes so fucking mean to him all the time i actually just didnt get it while i was playing. its so unnecessary, constantly cuts him off, shuts him up, etc etc. pretty much all the way until the end.
and then suddenly for the ending cutscene they are practically in love with zero warning. shes like oh my god i would follow you anywhere i would go anywhere with you. Bestie you hated his guts the whole 10 hour runtime of game what are you talking about................
It genuinely feels like something went wrong for sure.
And like, the alpha game pre-release was practically done!! The last major update they did to the early access was up until you create the body for al-an, which is literally the second to last thing you do for the story. You give him a body, and then immediately after that you can trigger the ending scene (at least in the final release, they might have had more planned after that in the original writing bu we will never know)
Which just made it so insanely jarring when you played the final release, which released over a year after that (i think), and the whole story arc was just. Gone. Replaced with what we got. I might be insane and the story got more and more replaced as early access went on, I am just going off of my memories of watching Jack's playthrough so take what I say with a grain of salt in terms of timeline accuracy, but the game was definitely changed beyond recognition from early access to final release as it went a complete and total rewrite more than halfway into production when they let go of their lead writer
#ask#anon#subnautica#i followed this game relatively closely as it was released bc yeah im a huge subnautica fan#the first game is absolutely one of my favorites of all time for sure#so seeing the second game flop so hard just made me upset. and some of the game design elements are actually atrocious too#that it had me completely tilted playing some parts of it too bc it got infuriating. the fuckin ice basin zones.... god damn.#anyway this is my rant. i should go rewatch jacks early access videos its been a while since i did that
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17776 by Jon Bois//"Universal interferometric signatures of a black hole’s photon ring"//Fallen Angel-BEBUSH//Black Circles Set-dreammachine//deactivated tumblr user-could not credit//Adam Maida//"Perfect Day"-Alex Demitrov//Cockroach Inc//"a lesson of the march by archy"-Don Marquis
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palindrome and emordnilap names
Aban Abani Abbas Adam Adda Addia Adek Adella Adian Adiave Adilenad Adilim Adinaja Adinamera Adinas Adira Adle Adlesti Adyana Aidaya Aidellya Aidia Ailam Ailayram Airicam Airie Aisak Ajahample Ajana Ajar Ajnahlise Akeel Akeeving Akina Akinad Akir Alad Aladian Aleen Alegnar Alemus Alenar Ales Alesil Alhabila Alham Alile Alinte Alinveen Aliss Alle Alled Alledalso Alleen Allegnad Allema Allenter Allidam Alor Alordna Alyala Amajak Amarian Ameem Ameema Amere Ameria Amersiri Amesa Amia Aminah Amiram Amirami Amirenam Anaela Anaidya Analin Analleyn Analso Anana Anarik Anasira Andaram Andron Aneemo Aneer Aneles Aneli Anella Anet Ange Anilap Anileda Anilie Anin Anisa Anish Aniv Anivi Anna Annasiana Anner Anumes Arana Aranaya Arat Arenahari Areven Ariam Arican Arida Arim Arimajib Armiam Armiled Arue Aruna Aryah Aryalles Asej Asiah Asira Aslia Assa Assira Asyadeli Asyahlian Atarika Atat Avane Aveel Aven Avena Avenadia Avissa Axella Ayadira Ayadyan Ayalsa Ayamya Ayana Aydame Ayma Aymada Aymara Ayrah Aysak Azak Azizan Azizar Baher Bahersi Baya Bayrama Bema Bija Bijak Bobeeron Camer Dala Dana Daradil Daram Daratin Date Dayan Dela Delie Deva Ebban Ebbe Edah Edana Ednah Ednamyala Eilen Eirimra Ekim Elande Elaya Eleen Eles Elika Elinven Ella Ellameeri Ellem Emon Emor Enani Englia Englika Ennam Ennia Eria Erian Esliama Eslish Eveem Gemo Hada Hading Hadyn Hailis Haima Haira Halame Halie Hana Hanel Hare Hean Ilan Ilhas Ilso Imar Imerika Inne Innilia Irahlika Irenas Ireve Iridya Irika Irim Irish Isma Ismana Itan Jana Jesa Jesti Junah Kajahaven Kajarim Kajibasil Kaza Kedian Keva Kilaman Kirah Kiratata Kiris Kive Leam Leamar Leanam Leanay Ledish Leeka Leera Leord Lexama Lianai Lidda Lidiam Lile Linael Linahlie Lingli Lisej Mahab Mahames Mahana Mahomes Maida Mailaher Mailed Maish Malesa Mali Manale Manalina Manar Marasia Marat Mare Marid Marike Marom Maron Maya Mebor Meel Meem Meemo Meera Meere Megnahlia Melda Meli Miaveka Milam Milegna Milena Mira Mirame Mirames Mirela Mish Moham Naam Naanam Naba Nabas Nadi Nadiani Nadil Naela Naelah Nahamor Nahat Nahirama Naida Nail Nailena Nair Nale Nali Nama Namael Name Namersian Namo Namor Namyan Nanam Nane Nanother Naramer Narik Nata Natate Nave Naveka Navisso Navivan Nayazak Neel Neem Neena Nelam Nelik Nell Nelles Nerid Neva Neveemin Nevek Nevi Nidalika Nidanel Nidata Nidel Nidil Nidiramon Nilordna Niman Niteda Nitela Nivar Nive Nivi Niviva Noelda Nolf Nome Nomes Nord Nossa Nossak Olida Orena Palsel Qira Rahlia Rahoma Ramer Ramerik Ramin Rample Ravek Ravia Ravika Razak Raziza Reek Reela Reen Reerahan Reevi Rehabila Rehanas Rehas Ridias Ridya Rihab Rihami Rihan Rimra Rinala Rinam Rinas Rinven Robeel Roelia Rola Rolayada Romael Saila Same Sanadya Sanothama Sanother Seema Sela Sema Semanay Sida Siddi Sidel Sivik Span Spana Suset Taram Tarid Ther Therel Tren Trev Trun Truna Unan Vaila Vaima Wela Wordna Yada Yally Yanay Yaniram Zayan Zizak
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U.S. GEOGRAPHY (BLUEZEPHYR)
1. Shenae Grimes's head
2. Amy Winehouse's bottom (Tooting Bec)
3. John Stamos's knee
4. Bill Rancic's buttocks
5. Jason Bateman's finger (Holborn)
6. Brandi Glanville's eyelash
7. James Franco's lower leg
8. Rebel Wilson's thigh (Maida Vale)
9. Toby Keith's nostril (Tottenham Court Road)
10. Molly Sims's forehead
11. Alanis Morissette's back
12. Ryan Adams's chin (Holborn)
13. Jenna Dewan's tooth
14. Kris Jenner's eye
15. Anderson Cooper's eye
16. Daniel Craig's hip (Dagenham Heathway)
17. Reggie Bush's lower leg (Turnham Green)
18. Molly Shannon's eyebrow (Queensway)
19. Shoshanna Lonstein's leg
20. Mia Farrow's nostril
21. Swizz Beatz's hair (Kew Gardens)
22. Celine Dion's elbow
23. Chelsea Clinton's thigh (Latimer Road)
24. Angelina Jolie's hip
25. Kate Hudson's ankle
26. John F. Kennedy, Jr.'s tooth
27. Patrick Schwarzenegger's forehead (Blackfriars)
28. Lance Armstrong's nostril
29. Cacee Cobb's upper arm
30. Mark Wahlberg's thigh
31. Snoop Dogg's knee
32. Kelly Preston's waist
33. Gordon Ramsay's mouth
34. Haylie Duff's hair
35. Alessandra Ambrosio's waist
36. Jason Lee's forehead
37. Matthew Morrison's ankle
38. Jay Lyon's back (Woodside Park)
39. Taye Diggs's ear (Heathrow Terminals 1, 2, 3)
40. Rosie Huntington-Whiteley's back
41. Lauren Holly's mouth
42. Josh Bowman's ear (West Harrow)
43. Foo Fighters's mouth
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Can State Supreme Courts Preserve—or Expand—Rights?
With a Lopsided Conservative Majority on the U.S. Supreme Court, Progressive Activists are Seeking Legal Opportunities in State Constitutions.
When it comes to expanding citizens’ rights, the current U.S. Supreme Court appears to be a dead end—and it could stay that way for years. Yet, for lawyers, activists, and scholars looking to eke out gains in areas such as reproductive rights and criminal-justice reform, there may be reason for hope. As Eyal Press explores in this week’s issue, state courts, “with their freedom to experiment,” are increasingly viewed as the most vital legal venues in the country. Here are a few reasons for that:
State courts offer freedoms beyond federal protections. “Although the Constitution’s supremacy clause forbids states from violating federal rights,” Press notes, “nothing bars them from amplifying those rights.” The high courts of eleven states have identified in state constitutions the right to an abortion. And various state constitutions protect more novel concepts, including “social welfare,” the power to grow and harvest food, and access to “a clean and healthful environment”—positive rights that have no federal analogue.
State courts support democracy. The current Supreme Court can be seen as both an embodiment and a perpetuator of minority rule, which some argue is embedded in the U.S. Constitution. But state constitutions reflect what some legal scholars call “the democracy principle”: “a commitment to popular sovereignty that is reflected in language vesting power in the people and in explicit assurances of the right to vote.” State courts can also better reflect the needs of local residents, by crafting “remedies without imposing a one-size-fits-all rule on the entire country.”
State courts can be catalysts for national change. The Supreme Court’s decision in favor of marriage equality in Obergefell v. Hodges, for example, came after a decade in which same-sex union and marriage rights were enshrined in places such as Vermont and Massachusetts. Scholars argue that the current fight to reëstablish reproductive rights could follow a similar path.
— By Eyal Press | June 3, 2024
State constitutions explicitly affirm rights that are not mentioned in the U.S. Constitution. Montana’s invokes a right to “a clean and healthful environment.” New York’s includes a right to “social welfare.” Photo Illustration By Adam Maida; Source Photograph From Getty Images
In November, 2020, Lauren McLane, a Professor at the University of Wyoming College of Law, was forwarded a letter from Christopher Hicks, an incarcerated man who’d been sentenced to life without parole for his role in a murder. The letter was part of a petition, prepared by Hicks, laying out “all the pertinent information, charges and reasons” that he deserved consideration for a pardon. The murder, he wrote, had been carried out fifteen years earlier by another man, who entered the victim’s house while Hicks remained in the back seat of a car, intoxicated. Noting that he was a teen-ager at the time, Hicks claimed that he’d been pressured into participating in the crime by a third, older man, who lived in the trailer where Hicks had been residing.
McLane runs a clinic that regularly helps indigent clients in Wyoming file motions to reduce their sentences. Yet, when she finished Hicks’s petition, she said to herself, “This is an absolute lost cause.” In part, she felt this way because of the notorious reputation of Kent Proffit, Sr., the older man who’d orchestrated the murder: Proffit, an alleged child molester, had wanted to prevent the victim, a sixteen-year-old boy, from testifying against him in a sexual-assault trial. Another problem was that Hicks had been nineteen when the crime occurred. In a 2012 Supreme Court case, Miller v. Alabama, the Justices had barred judges from sentencing juveniles to mandatory life without parole, on the ground that doing so violated the Eighth Amendment’s ban on cruel and unusual punishment. Justice Elena Kagan, who wrote the majority opinion, argued that children’s “diminished culpability and heightened capacity for change” required judges to consider their age when determining their punishments. But, as McLane knew, the Miller decision applied only to defendants who were younger than eighteen when they’d committed crimes. Because Hicks had been a little older than this, McLane assumed that no judge would deem his age a mitigating factor.
A few months later, however, she learned about a case that made her reconsider. The case, In re Monschke, came before the Supreme Court of Washington State, which, in a 4–3 decision, ruled that Miller should be extended to two petitioners who’d committed homicides when they were nineteen and twenty years old, respectively. The justices noted the prohibition on “cruel punishment” in Washington’s state constitution, and cited neuroscientific research, presented in court, showing that the brains of young adults were still developing, leaving them susceptible to the same impulsive behavior as juveniles.
One lawyer involved in the Monschke case was Jeffrey Ellis, who taught a seminar on capital punishment that McLane had taken in law school, at Seattle University. She began to wonder whether a similar case might be brought in her home state. McLane recognized the vast differences between the political climates of Washington, which had one of the most liberal supreme courts in the country, and Wyoming, where Donald Trump won nearly seventy per cent of the vote in 2020. But she also knew that Wyoming, like much of the rest of the Mountain West, prided itself on not taking directives from the federal government.
McLane combed through recent Eighth Amendment cases that had come before the Wyoming Supreme Court and spotted evidence of this independent spirit. In a 2014 case, Bear Cloud v. State, the justices noted that the plaintiff, who sought an itemized sentencing hearing for an aggregate punishment he’d been given for a series of crimes committed when he was sixteen, had made “no more than a passing reference to the protections that might be afforded by our state constitution.” They added, “Our state constitution need not necessarily be analyzed by ‘blindly follow[ing] the United States Supreme Court’s interpretation.’ ”
Wyoming’s constitution, like those of several other states, contains an analogue to the Eighth Amendment that prohibits cruel or unusual punishment—a minor but potentially important textual difference. After weighing these factors, McLane called Christopher Hicks. She mentioned the Monschke decision and said, “I think this is something we can do.”
In 1976, Justice William Brennan delivered a speech at the annual convention of the New Jersey State Bar Association. In the previous two decades, Brennan, who had served on the New Jersey Supreme Court for five years before Dwight Eisenhower appointed him to the U.S. Supreme Court, had written, or joined, dozens of influential opinions that broadened the rights of criminal defendants, women, Black people, and indigent Americans. Many of these decisions invalidated state laws that sanctioned racial discrimination, by augmenting the authority of the federal government. But Brennan, in his speech, endorsed an idea that seemed to move in the opposite direction, making an impassioned case for state courts to issue rulings that pushed beyond protections enshrined in federal law. “State courts cannot rest when they have afforded their citizens the full protections of the federal Constitution,” he said. “State constitutions, too, are a font of individual liberties, their protections often extending beyond those required by the Supreme Court’s interpretation of federal law.”
As Brennan peered around the ballroom where the conventioneers were gathered, he saw the crowd thinning, and became convinced that his speech was flopping—so much so that he walked offstage before finishing it. But, the following year, his full address was published in the Harvard Law Review, and it became one of the most widely cited law-review articles ever written, inspiring what legal scholars have called “the new judicial federalism”—a movement in which state courts, citing provisions in their own constitutions, issued a flurry of decisions widening the scope of rights. Among them was State v. Novembrino, a 1987 case in which the New Jersey Supreme Court endorsed protections against unreasonable searches and seizures that were more robust than those in federal law, siding with a suspect who had been charged with possession of illegal drugs on the basis of evidence obtained through a nonconsensual search. (The decision rejected the “good-faith exception” endorsed by the Supreme Court, which critics have argued gives the police too much latitude to engage in misconduct.) Although the Constitution’s supremacy clause forbids states from violating federal rights, nothing bars them from amplifying those rights. In the decade after Brennan’s article appeared, state courts handed down more than two hundred such rulings, on issues ranging from free speech to the death penalty—a tenfold increase from the previous ten years.
Brennan’s article had a major impact because of his stature, and because, by the late seventies, the Supreme Court was no longer engaged in the expansion of rights that had unfolded under Chief Justice Earl Warren, who retired in 1969. The subsequent appointment of four Justices who were nominated by Richard Nixon—including Warren Burger, who succeeded Warren as Chief Justice—had left Brennan increasingly isolated and dismayed, a feeling that he didn’t hide in his speech. The Supreme Court was failing to protect rights, he complained, including in cases involving the equal-protection clause—a retreat that “constitutes a clear call to state courts to step into the breach.”
As necessary as such interventions may have seemed to Brennan nearly half a century ago, a growing number of advocates and legal scholars believe that they are far more urgent today. In February, I heard this view expressed repeatedly at a two-day symposium on state constitutions held at New York University School of Law and organized by the Brennan Center for Justice. (The center is named for Brennan himself.) A decade ago, a conference on such a subject likely would have been a modest gathering. This year, the turnout was so heavy that many attendees had to sit outside the main room and watch the proceedings on a simulcast.
“Justice Brennan’s call to action has never been more salient,” Michael Waldman, the president of the Brennan Center, declared in the opening address. If the symposium owed a debt to Brennan, it owed no less of one to Senator Mitch McConnell and to President Trump, who helped to entrench a lopsided 6–3 conservative majority on the Supreme Court. Recent Court rulings—from Dobbs v. Jackson Women’s Health Organization, which overturned Roe v. Wade, to Sackett v. Environmental Protection Agency, which weakened the Clean Water Act—have left many progressive analysts convinced that, for at least a generation, trying to expand federal rights will be a hopeless cause. (A notable exception is the rights of gun owners, toward whom the Justices have been solicitous.) State litigation offers far more opportunities, the speakers at the symposium affirmed. Forty-nine states “have stronger protections for voting rights than the U.S. Constitution does,” Waldman noted in his address. State constitutions are also much easier to change: whereas a federal constitutional amendment must be ratified by three-quarters of state legislatures, a process that can take decades, amending the constitutions of most states requires a single referendum. For this reason, pro-choice advocates in numerous states have lately pushed to place amendments legalizing abortion on the ballot. (So far, four states have amended their constitutions to protect abortion rights, and in November there could be referendums on the matter in as many as fourteen states.)
In Dobbs, the Supreme Court left it to states to fashion their own laws and policies on abortion. Fourteen states have bans in effect which criminalize the procedure in nearly all circumstances. But the high courts of eleven others have recognized that their constitutions protect abortion rights independently from the federal Constitution. Some states have also framed abortion access in novel ways—for example, as a matter of equality rather than privacy, an argument that many feminist scholars have long considered superior. Shortly before the N.Y.U. symposium, the Supreme Court of Pennsylvania ruled that a state ban on Medicaid coverage for abortion was “presumptively unconstitutional” because it violated both the Equal Rights Amendment, which Pennsylvania has ratified, and the equal-protection clause in the state’s constitution. At the symposium, Mary Ziegler, a legal historian, speculated that, in fifty years, when scholars write the story of Dobbs’s reversal, “many of the early chapters are going to be about what occurs in state courts.”
One Criticism of the Call For State Courts to play a more prominent role in protecting rights is that the underlying motive is ideological; in Brennan’s case, he was openly trying to counter the Burger Court’s rightward shift. At the N.Y.U. symposium, Goodwin Liu, a justice of the Supreme Court of California and a strong proponent of judicial federalism, said that such concerns were likely why many of his peers “look a little bit askance at this project,” dismissing it as an attempt to preserve only liberal rights.
But not everyone who is sympathetic to judicial federalism leans left. At the symposium, Clint Bolick, a self-described “textualist” who served in the Reagan Administration and is now a justice of the Arizona Supreme Court, said, of state jurists, “U.S. Supreme Court Justices do not take oaths to the state constitution, but we do.” In Bolick’s view, state courts that reflexively follow the Supreme Court are shirking their duty to protect the rights enshrined in their own constitutions.
The best-known recent book on state-constitutional law is “51 Imperfect Solutions,” by Jeffrey S. Sutton, a judge on the U.S. Court of Appeals for the Sixth Circuit and a former clerk for Justice Antonin Scalia. Sutton writes, “For too long, we have lived in a top-down constitutional world, in which the U.S. Supreme Court announces a ruling, and the state supreme courts move in lockstep in construing the counterpart guarantees of their own constitutions.” In a diverse democracy, Sutton argues, it is preferable for state courts to exercise independence, spurring the kind of experimentation that America’s federalist system was designed to cultivate. Because state courts preside over smaller jurisdictions, he notes, they can craft remedies without imposing a one-size-fits-all rule on the entire country. One example that Sutton cites is San Antonio Independent School District v. Rodriguez, a 1973 case in which the Supreme Court ruled that inequalities in Texas’s public-education system did not violate the Constitution. (The lawsuit was brought by a parents’ association in an underfunded school district.) In response, numerous lawsuits were filed in state courts, many of them invoking the right to a public education—something that all state constitutions explicitly affirm. In 1989, the Texas Supreme Court ordered officials to create a more equitable system, citing the state constitution’s guarantee that the “general diffusion of knowledge” will be fostered. By 2004, the school district in the Rodriguez case was spending more per pupil than Alamo Heights, an affluent neighborhood that the plaintiffs had highlighted in their original lawsuit.
A skeptic might note that granting states more leeway to work out constitutional questions has sometimes had pernicious effects, particularly in the Jim Crow South. Sutton acknowledges this, but argues that the dynamic has changed. On many issues, he writes, “the state courts in recent years have gone from being civil-rights followers to leaders.”
This shift has been especially evident with gay rights. I recently spoke with Mary Bonauto, the senior director of civil-rights and legal strategies at G.L.B.T.Q. Legal Advocates & Defenders (glad). In 1997, glad, along with two Vermont lawyers, filed a lawsuit on behalf of three same-sex couples in the state who’d been denied marriage licenses. Same-sex marriage was then illegal throughout the United States. Bonauto drew inspiration from Justice Ruth Bader Ginsburg’s formulation, in 1996, that “the history of our Constitution . . . is the story of the extension of constitutional rights and protections to people once ignored or excluded.” Bonauto was also motivated by a personal longing, she told me—the desire to marry the woman she loved.
The case was brought in Vermont’s state-court system, Bonauto said, in part because in the U.S. marriage is regulated by state law. But the choice of venue was also strategic. She and her co-counsellors didn’t want to file a federal case that might eventually come before the Supreme Court, knowing that it could issue a decision that would set back their cause. In 1986, the Justices had ruled, in Bowers v. Hardwick, that a Georgia law criminalizing sodomy did not violate the Constitution. A decade earlier, it had dismissed an appeal from two men in Minnesota who’d been denied the right to marry; the Court rejected their petition “for want of a substantial federal question.” Bonauto told me, “I don’t think any of us who were working on this wanted to have premature Supreme Court review, because we were very confident that we would lose.”
Given that states have the final say when interpreting their own constitutions, glad’s lawsuit in Vermont—one of the first states to pass a nondiscrimination law protecting gays and lesbians—avoided the risk of federal intervention. In 1999, the Vermont Supreme Court, citing a clause in the state constitution that prohibits bestowing favoritism on any particular “set of persons,” ruled that same-sex couples were entitled to “the same benefits and protections” afforded to married couples. Bonauto was thrilled, even though the decision left the remedy to the legislature, which passed a civil-union law instead of legalizing same-sex marriage.
glad soon filed a similar lawsuit in Massachusetts, on behalf of seven same-sex couples. In 2003, the Supreme Judicial Court of Massachusetts ruled in the plaintiffs’ favor. The decision cited the Massachusetts constitution, particularly its Declaration of Rights, which the justices pointedly described as “more protective of individual liberty and equality than the Federal Constitution.” Same-sex couples started getting married in Massachusetts more than a decade before the Supreme Court eventually ruled, in Obergefell v. Hodges, that all Americans had the right to do so.
The triumph of marriage equality might seem inevitable today. Bonauto doesn’t see it that way, recalling how much fear pervaded the L.G.B.T.Q. community when the first cases were filed. “I find it hard to imagine that we would be where we are today without Vermont and Massachusetts,” she told me. By the time the Obergefell decision was issued, in 2015, popular attitudes had shifted, she acknowledged. The U.S. Supreme Court acted as a “consensus confirmer,” she said. But state courts, with their freedom to experiment, had helped to bring about that social change. “They can have a catalytic effect,” she told me.
Photo Illustration By Adam Maida; Source Photograph From Getty Images
Between Sessions at the N.Y.U. Symposium, I went to a café to meet Kyle Barry, an advocate who hopes that a similar pattern might play out in the movement for criminal-justice reform. Barry came to the conference from San Francisco, where he directs the State Law Research Initiative, a nonprofit organization whose mission is to limit extreme sentences and address inhumane prison conditions by strengthening state-constitutional rights. Criminal-justice scholars have traditionally framed mass incarceration as a national phenomenon driven by such harsh federal legislation as the 1994 crime bill. But, as the authors of a recent Iowa Law Review article note, “ninety percent of people confined in U.S. prisons are confined under state laws.” Given this, the authors ask why state courts have been “missing from the debate” about how to curb excessive punishment regimes.
Barry’s organization hopes to address this gap. He told me that state litigation was especially urgent because the Supreme Court has “completely abdicated” enforcing constitutional rights in the criminal-justice system, rubber-stamping extreme sentences that many other countries prohibit. In most of Europe, he noted, the sentence of life without parole is unheard of. In 2022, Canada’s Supreme Court ruled unanimously that such sentences were cruel and unconstitutional for offenders of any age. In the U.S., as of 2020, sixty thousand people were serving what Barry calls “death in prison” sentences—more than in the rest of the world combined. Although the Miller ruling forbade mandatory impositions of life without parole for juveniles, it didn’t ban them altogether. And a more recent Supreme Court opinion, Jones v. Mississippi, written by Justice Brett Kavanaugh, relieved judges of having to establish that a juvenile is “permanently incorrigible” before issuing such a sentence.
In a scathing op-ed in the Washington Post, the legal scholar John Pfaff argued that the Jones ruling demonstrated that America was willing “to throw lives away.” Yet Barry told me that he felt optimistic about the possibilities for state reform, naming Michigan, in addition to Washington, as a place where a high court had recently extended Miller to young adults. Lauren McLane, the law professor fighting to reduce the sentence of Christopher Hicks, joined us at the café, dressed in a gray University of Wyoming sweatshirt. McLane and Barry had first communicated a few weeks earlier, after she’d read comments that he’d made on a Listserv about Commonwealth v. Mattis, a case in which the Supreme Judicial Court of Massachusetts banned life without parole for “emerging adults”—defined as anyone between eighteen and twenty-one. The ruling, which was made in January, cited the ban on “cruel or unusual punishment” in the Massachusetts constitution, and also the principle that Eighth Amendment jurisprudence should be informed by “the evolving standards of decency that mark the progress of a maturing society”—a standard that the U.S. Supreme Court itself has endorsed.
McLane informed Barry of her plans to file a lawsuit challenging mandatory life without parole for young adults in Wyoming. She discussed Hicks’s case, and talked about how she’d got to know him, learning more about his teen-age years—he’d endured extensive abuse—and about his determination to make amends for what he’d done. (At the Wyoming State Penitentiary, Hicks helped to run a mentoring program for incarcerated youth.) McLane acknowledged that, in a conservative state like Wyoming, the odds of securing a new sentencing hearing for Hicks might be long. But, she said, “I’ve been telling my students, ‘If we can do this here, we can do it anywhere.’ ”
McLane wanted her lawsuit to highlight the commitment to reform that permeates Wyoming’s constitution, something its high court had alluded to in several rulings she’d come across. A core tenet of judicial federalism is that state constitutions contain provisions reflecting states’ distinctive values and history. In Wyoming, Article 1, Section 15, says, “The penal code shall be framed on the humane principles of reformation and prevention.” McLane planned to cite this language in her lawsuit. She also intended to quote an 1898 ruling by the Wyoming Supreme Court which declared that “the modern prison system, at every stage of its evolution, revolves around one central thought—the possibility of reformation. . . . The reformation of the prisoner is its one animating purpose.”
McLane told me, “I’ll be submitting a motion to challenge Chris’s sentence this summer, and I am hopeful that he and other similarly situated young adults in Wyoming will be granted the same grace, dignity, and justice that those emerging adults in states like Washington and Massachusetts have been extended.”
Any Excitement at the N.Y.U. Symposium was qualified by an acknowledgment that a victory in a state supreme court has much more limited effects than winning a U.S. Supreme Court case. It’s “a second-best alternative,” Robert Williams, the director of the Center for State Constitutional Studies, at Rutgers, said on one panel. The Mattis ruling underscored this: the decision made more than two hundred incarcerated people in Massachusetts serving life-without-parole sentences eligible for new hearings, but it did nothing for the tens of thousands of people serving similar sentences outside the state.
Williams has been writing about state-constitutional law since 1980. In 2000, Bonauto sought his guidance about the Massachusetts lawsuit that glad filed, for which he submitted an amicus brief. As a distinguished figure in a marginalized specialty, he is delighted that his area of expertise is finally generating wider interest. One indication of this change is the A.C.L.U.’s decision, a year ago, to launch a State Supreme Court Initiative. Among the effort’s leaders is Matthew Segal, a senior staff attorney at the organization. Segal was given the job in part because he’d had a string of successes with civil-rights cases while serving as the legal director of the A.C.L.U. of Massachusetts. In 2020, he secured the release of five thousand people from state prisons and jails because of health risks related to covid-19. He was the lead A.C.L.U. counsel in two cases that ended with more than sixty thousand drug charges being overturned on the ground that state-run labs had engaged in misconduct and relied on fabricated evidence. According to the A.C.L.U., this is the largest dismissal of wrongful convictions in U.S. history. These victories stood in stark contrast to Segal’s experiences in federal court, which, he told me, had often been frustrating. In 2017, for example, a federal judge declined to extend a temporary restraining order that Segal and several colleagues had obtained to block Trump’s travel ban, which excluded people from seven majority-Muslim countries from entering the U.S. (The Supreme Court later upheld a revised version of the ban.) When the opportunity to run the State Supreme Court Initiative arose, Segal immediately said yes. In the past thirteen months, the project has filed amicus briefs or served as co-counsel in twenty-five cases in eighteen states, on issues ranging from abortion to election reform.
Segal attended Yale Law School, where, he said, he received little training for such work. “The focus at a lot of law schools that are highly regarded has been federal law,” he said. “There’s been no real teaching in state-constitutional law.” But, last fall, Yale did offer a seminar on the subject—one that Segal co-taught with Julie Murray, another senior A.C.L.U. attorney. Segal told me that he saw the class as a complement to his advocacy work—he is now teaching a similar course at Tufts—and that he hoped to get the next generation of activist lawyers to rethink their priorities. “If there are going to be advances in civil rights and civil liberties in the near term—and maybe even the medium and long terms—they’ll have to come from state courts,” he said.
One Yale student in the seminar was Pragya Malik. The previous year, she’d taken two classes that reflected her passion for social justice: “Litigating Civil Rights, Policing, and Imprisonment,” and “Law and Inequality.” The courses left her deflated, she said, in part because they focussed on federal law, where the barriers to effecting change seemed so daunting. “You’re jumping through all these hoops,” she said. Malik learned that, in addition to the obstacles posed by the Supreme Court’s conservative super-majority, there were legal hurdles such as qualified immunity, which shields law-enforcement officials from liability for abuses unless a violation of specific civil rights is “clearly established.”
Last summer, Malik worked at a public-defender service in Washington, D.C., where she overheard a peer talking about a mass-exoneration case in Massachusetts. She consulted the A.C.L.U.’s Web site to learn more, and saw that the leading force behind the suit, Segal, would be teaching a course at Yale that fall. She signed up. After taking the seminar, she came away excited about the power that lawyers could have to “affect people’s lives” through state courts. Segal told me that, in his class, he emphasizes that state supreme courts, far more than federal courts, viewed themselves as “problem solvers.” The wrongful-conviction cases that he’d litigated came about when the Supreme Judicial Court of Massachusetts invoked its “superintendence authority” over lower courts where tainted evidence had been used, forcing the state to clear thousands of people’s records and enabling the victims to recover millions of dollars in fines and fees. Federal courts also possess this authority, but rarely exercise it. Segal said, “The world of state courts allows for more creativity and inventiveness than you see in federal court.”
One Potential Barrier to Litigating Civil-rights Cases in State Courts is that, unlike at the federal level, lawyers are generally not entitled to recover attorneys’ fees if they win. At the N.Y.U. symposium, Julie Murray, of the A.C.L.U., recalled that, when she was employed at another nonprofit, she worked on a civil-rights lawsuit in Iowa that dragged on for more than a year. The organization won in trial court, but recouped only three hundred dollars in costs.
James A. Gardner, a professor of law at the University at Buffalo who has written extensively about judicial federalism, has raised other caveats. He is skeptical that state courts can spearhead a meaningful expansion of rights, because of heightened partisanship and “the politicization of constitutional law,” which has eroded the independence of state courts, particularly where Republicans wield power. As Gardner documents in a forthcoming law-review article, in recent years Republicans in places such as Georgia have packed state supreme courts to insure rulings favorable to their agenda. In 2017, Georgia’s Supreme Court expanded from seven justices to nine.
Judges in Republican-controlled states who have made expansive rulings in favor of rights have also been attacked politically, and even threatened with impeachment. For judicial federalism to flourish, “state judiciaries must enjoy genuine independence from transitory political winds,” Gardner argues. “Judges who are tethered tightly to trends in state and national politics, and thus fearful of partisan retaliation for decisions they make, are unlikely to enjoy the independence necessary to forge a state constitutional jurisprudence of any organic distinctiveness.”
State courts are significantly less insulated from political pressure than their federal counterparts. In 2022, the North Carolina Supreme Court struck down a voter-I.D. law that it concluded was racially discriminatory. The next year, the decision was reversed—after Republicans elected two new conservatives to the bench. This shift in the balance of power occurred after Republicans in the state legislature eliminated public funding for appellate judicial elections and changed the law so that party labels could be affixed to candidates. Douglas Keith, a scholar who tracks the role of dark money in judicial campaigns, told me that before these changes judicial elections in North Carolina had been quiet, nonpartisan affairs. They have now become hyperpartisan battles in which candidates bankrolled by the Republican State Leadership Committee—the nation’s largest spender on state-supreme-court elections—have largely prevailed.
A related trend in American politics is politicians’ declining commitment to democracy itself. The journalist Ari Berman, in a new book, “Minority Rule,” examines how tactics such as voter suppression and gerrymandering have undermined the popular will. The Supreme Court has not seemed terribly troubled by this, issuing rulings that have weakened voting rights and, in May, determining that Republicans in South Carolina did not unlawfully consider race when they drew a congressional district in a way that removed thirty thousand Black voters, overriding a lower court that had ordered legislators to redraw the district. A case can be made that the U.S. Constitution was designed to sustain minority rule, protecting white male property owners from the so-called tyranny of the majority. Indeed, as Berman points out, the current Supreme Court is itself a product of minority rule: five of the six conservative Justices—including Samuel Alito, who wrote the majority opinion in the South Carolina case—were appointed by Presidents who had assumed office after losing the popular vote.
State Constitutions Offer a Potential Counterweight to These Trends. They embody what the law professors Miriam Seifter and Jessica Bulman-Pozen have termed “the democracy principle”—a commitment to popular sovereignty that is reflected in language vesting power in the people and in explicit assurances of the right to vote. Seifter co-directs the State Democracy Research Initiative, at the University of Wisconsin Law School, in Madison, which she launched, in 2021, with her husband, Robert Yablon, a professor who specializes in election law. One of their goals is to advance research and dialogue about state courts, thereby strengthening democracy. In Seifter’s state, progressives recently scored a major victory in this arena. Starting in 2011, creatively designed legislative maps enabled Republicans to retain power in the state legislature even after losing the popular vote. Janet Protasiewicz, a circuit-court judge, decried these maps, calling them “rigged.” Her outspokenness on the issue helped her to win election to the state supreme court in 2023. Republicans threatened to impeach Protasiewicz unless she agreed to recuse herself from any cases involving the maps, but the effort failed, and a case challenging partisan gerrymandering soon came before the justices. In December, they ruled that more than half of the legislative districts in Wisconsin violated a provision of the constitution requiring them to be composed of “contiguous territory,” and ordered that new maps be drawn.
Another state in which the “democracy principle” has been tested is Montana, where, in 2021, a coalition of Native American tribes challenged voting restrictions, including the elimination of Election Day registration, which they claimed had a disproportionate impact on them. In recent years, federal courts have rarely taken exception to such measures, applying strict scrutiny only to a law that “severely burdens” the right to vote. In an amicus brief, ten constitutional-law scholars, among them Miriam Seifter and Robert Williams, argued that upholding the voting restrictions would “erase Montana’s distinctive constitutional language, structure, and tradition,” all of which warranted a more exacting standard. (The Montana constitution mandates that all elections “be free and open,” and that no power “shall at any time interfere to prevent the free exercise of the right of suffrage.”) In March, the Montana Supreme Court struck down the restrictions, and warned that it would view skeptically any state law that “impermissibly interferes” with the right to vote.
Not only do state constitutions generally express a stronger commitment to democracy than the U.S. Constitution does; they enumerate many rights and protections that have no federal analogue. In several states, for example, a person in custody cannot be treated with “unnecessary rigor.” I discussed this concept recently with Daniel Greenfield, who helps to run the Prisoners’ Rights Clinic at U.C.L.A. Last year, Greenfield petitioned the U.S. Supreme Court to review the case of Michael Johnson, a mentally ill man in Illinois who’d been caged in a filthy solitary-confinement cell for nearly three years, without access to exercise or fresh air. The Court denied the petition, overriding a strong dissent from Justice Ketanji Brown Jackson, who noted the “unusually severe” conditions that he’d endured. The decision, Greenfield told me, left him “with the unshakable feeling that it was time to turn to state courts and state constitutions.” He’s now working with law students to identify state courts where incarcerated clients can get relief. One of the places they are eying is Oregon, whose constitution has an “unnecessary rigor” clause, which has recently been invoked to hold prison officials accountable for inhumane conditions.
Many state constitutions also affirm positive rights absent from the U.S. Constitution, including a right to “social welfare,” which New York recognizes, and a right to grow and harvest food, which was incorporated into Maine’s constitution in 2021, after voters approved an amendment, propelled by concerns about the growing power of agribusiness. The amendment asserts that individuals have the right to “produce and consume the food of their own choosing.” Some scholars contend that the mutability of state constitutions is a flaw. But the comparative ease of amending them also means that many of their provisions “are quite recent, and often reflect contemporary concerns,” Alicia Bannon, a scholar at the Brennan Center who edits State Court Report, a new online publication that tracks state-constitutional developments across the country, told me.
Among the contemporary concerns that state courts have begun addressing is climate change. Held v. Montana, a lawsuit filed in 2020, invokes an inalienable right to “a clean and healthful environment.” This phrase doesn’t appear in the U.S. Constitution, of course, but it’s enshrined in Montana’s constitution, which was rewritten in 1972—two years after the first Earth Day took place. When the Held lawsuit was filed, the plaintiffs ranged in age from two to eighteen, reflecting the fact that, as the complaint noted, “children are uniquely vulnerable to the consequences of the climate crisis.” Among those named in the lawsuit are Rikki Held, who grew up on a ranch that has recently been ravaged by floods and wildfires, which have threatened her family’s livelihood, and Olivia Vesovich, a teen-ager who has repeatedly had to leave the state in the summer because smoke-filled air exacerbated her asthma. The complaint quotes the preamble of Montana’s constitution, which celebrates “the quiet beauty of our state, the grandeur of our mountains, the vastness of our rolling plains . . . for this and future generations.”
Our Children’s Trust, a nonprofit public-interest law firm, filed the case. It also litigates in federal court, and in 2015 it submitted a complaint in U.S. District Court on behalf of young people in Oregon. For years, that case stalled as the U.S. Department of Justice filed motion after motion to delay it. The tactic felt particularly egregious, Andrea Rodgers, a lawyer with Our Children’s Trust, told me, because mitigating climate change requires immediate action. In May, a U.S. circuit court of appeals finally weighed in on the case and, to the dismay of the plaintiffs, dismissed it. “I have been pleading for my government to hear our case since I was ten years old, and I am now nearly nineteen,” one of the plaintiffs said. “A functioning democracy would not make a child beg for their rights to be protected in the courts, just to be ignored.”
In Held v. Montana, a very different scenario played out. There were few delays in the case, and last year it went to trial, enabling Held and her fellow-petitioners to testify. A state district court ruled that their rights had been violated. Addressing the plaintiffs’ injuries imposes “an affirmative duty upon their government to take active steps,” the district court declared, striking down a Montana provision that had allowed state agencies to ignore greenhouse-gas emissions when approving energy projects. State officials immediately appealed to the Montana Supreme Court, which, in January, declined to stay judgment in the case. Oral arguments are scheduled to begin in Helena on July 10th.
Our Children’s Trust has since filed another lawsuit challenging inaction on climate change, in Hawaii; the case will go to trial in June. Like Montana, Hawaii recognizes the right to a clean and healthful environment in its constitution. If the Hawaii Supreme Court ends up invoking this provision, it will not mark the first such occasion. Last year, the court ruled unanimously that a state agency had the power to block an energy company from building a tree-burning facility on the Big Island which, in three decades, would have emitted eight million tons of carbon dioxide. In a concurring opinion, Justice Michael Wilson observed that Hawaii was “constitutionally mandated” to address the climate crisis because it was a “sui generis” emergency. (Deadly wildfires engulfed a town on Maui last summer, killing a hundred and one people.) Addressing global warming was also necessary because of the “stark failure of the federal judiciary to grant redress to present and future generations alleging knowing destruction of a life-sustaining climate system,” he went on. Among the examples he cited was West Virginia v. E.P.A., a 6–3 decision, issued in 2022, in which the Supreme Court curtailed the agency’s latitude to regulate greenhouse-gas emissions. The federal courts were abdicating their responsibility “to leave future generations a habitable planet,” Justice Wilson wrote. Unlike those courts, “the Hawai‘i Supreme Court does not choose to ‘throw up our hands.’ ” ♦
— Published in the Print Edition of the June 10, 2024, Issue, with the Headline “States of Play.” — Eyal Press has been contributing to The New Yorker since 2014 and became a contributing writer in 2023.
#The New Yorker#The Political Scene#United States 🇺🇸 Supreme Court#State Courts#Conservative Majority#Progressive Activists#Legal Opportunities#State Constitutions
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Magnet Market| Market Size, Analysis and Forecast, 2024 – 2028
Originally published on Technavio: Magnet Market Analysis APAC, North America, Europe, South America, Middle East and Africa - US, China, Japan, India, Germany - Size and Forecast 2024-2028
**Introduction:** The Magnet Market is poised for significant expansion, driven by increasing demand from sectors such as automobiles, defense aircraft, and storage technology. This article provides a comprehensive analysis of market dynamics, including trends, drivers, challenges, and key players shaping its evolution.
**1. Market Overview:** The magnet market is projected to witness substantial growth, with a forecasted increase of USD 17.54 billion and a Compound Annual Growth Rate (CAGR) of 7.89% between 2023 and 2028. Factors driving this growth include rising demand from the automotive sector, defense applications, and the expanding role of magnets in storage technology.
**2. Market Definition:** Magnets are materials with magnetic properties that attract iron, nickel, cobalt, and objects containing these metals. They are essential components in various industries due to their unique ability to generate magnetic fields.
**3. Segment Insights:** - **Type Insights:** The permanent magnet segment is expected to witness significant growth, driven by its utilization in various industries. Permanent magnets, made from alloys like nickel, cobalt, and iron, retain their magnetic properties even when removed from a magnetic field. - **End-user Insights:** The consumer goods and electronics segment is anticipated to dominate, fueled by increasing demand for magnets in products like kitchenware, personal electronics, and appliances. Countries like China, Japan, and India are key consumers in the Asia-Pacific region, driving market growth.
**4. Regional Analysis:** - **APAC Region:** Asia-Pacific is forecasted to contribute significantly to market growth, attributed to rapid industrialization and expansions in sectors like automotive, energy, and consumer electronics. Increasing disposable incomes and improving standards of living drive demand for magnets in the region.
**5. Market Dynamics:** - **Drivers:** Growing demand from sectors like automotive, defense, and storage technology is a key driver of market growth. Additionally, technological advancements and the increasing use of magnets in renewable energy and electric vehicles propel market expansion. - **Trends:** The market is witnessing trends such as the increased applicability of magnets in storage technology and the growing use of nanocrystalline magnetic particles in the biomedical industry. These trends contribute to market growth by expanding the scope of magnet applications. - **Challenges:** High Research and Development (R&D) costs associated with magnet manufacturing pose a challenge to market growth. Developing novel magnet materials and improving manufacturing processes require significant investments in R&D activities.
**6. Major Market Players:** Key companies in the magnet market include Adams Magnetic Products, Arnold Magnetic Technologies Corp., DEXTER MAGNETIC TECHNOLOGIES, and TDK Corp. These players employ various strategies such as alliances, mergers, and product launches to enhance market presence and drive growth.
**7. Customer Landscape:** The market forecasting report includes insights into customer adoption lifecycle and purchase criteria, aiding companies in developing growth strategies tailored to market demands.
To Learn deeper into this report , View Sample PDF
**Conclusion:** The magnet market presents lucrative opportunities for stakeholders across industries, driven by increasing demand from sectors like automotive, defense, and storage technology. By addressing challenges and leveraging emerging trends, companies can capitalize on market growth and contribute to advancements in various sectors.
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Is there a kind of worshipping peculiar to the Arafah of (the day before) Eid al-Fitr?
Arafah is the day one day before eid al-adha, the 9th day of the month of Dhul-hijjah of the Hijri calendar. No other day can be called Arafah. However, the day before eid al-fitr is also called Arafah in some Islamic countries.
The Messenger of Allah (pbuh) states the following :
"The most virtuous day among the days is the day of Arafah. It is like Friday in terms of virtue. It is more virtuous than seventy hajjs except the one performed on Friday. The most virtuous prayer (dua) is the one said on the day of Arafah. The most virtuous sentence uttered by me and the prophets before me is (Lailaha illallah wahdahu la sharika lahu. (There is no god but Allah; He is one; He has no partners.)" (Muwatta, Hajj, 246)
Hazreti Aisha narrates:
"There is no day when Allah sets free more servants from Hell than the day of Arafah. He draws near His slaves and praises them to the angels, saying: 'What do these want?'" (Muslim, Hajj, 436)
The Messenger of Allah (pbuh) said,
"Show respect to the day of Arafah. Arafah is a day that Allah appreciates."
Thus, the Prophet (pbuh) wanted us to show respect to the day that Allah appreciates and to try to live consciously. Respect starts by realizing the boon that is granted and being able to know and see. To spend the day of Arafah by performing fasting, saying prayers, asking for forgiveness without committing sins is an expression of respect and gratitude to Allah, who gave the glad tiding that He would forgive His slaves. (Daylami)
The following conversation between Hz. Umar and a Jew shows the importance of the day of Arafah:
During the caliphate of Hz. Umar, a Jew said to him,
"O Umar! You read a verse; if it had been sent down to us, we would have celebrated that day as an eid (festival)."
It was the third verse of the chapter of al-Maida. Allah Almighty stated the following:
"This day have I perfected your religion for you, completed my favor upon you."
That verse was sent down in the tenth year of the Migration during the Farewell Hajj on Friday, which was the day of Arafah, in the afternoon when the Prophet (pbuh) was on his camel called "Adba". The camel slumped down due to the heaviness of the revelation.
When Hz. Umar heard the verse from the Jew, he said,
"We know that day and the place where that verse was sent down. It was on Friday and Arafah." Thus, Hz. Umar mentioned the importance of Arafah by stating that it was eid for us.
The day of Arafah is the day when Hz. Adam and Hawwa (Eve) met.
Tawriyah is one day before Arafah.
The Prophet (pbuh) stated the following:
"A Muslim who performs fasting on the day of Tawriyah and does not utter any sinful words enters Paradise."
The fasting performed on that day is equal to supererogatory fasting of one thousand days. Besides, it causes the repentance of the previous year and the next year to be accepted. One gets a lot of rewards when he fasts on the day of Arafah. The Messenger of Allah (pbuh) stated the following:
"A reward of twice the number of the people that lived beginning from Hz. Adam and that will live up to the Day of Judgment will be given to a person who performs fasting on the day of Arafah."
"The fasting performed on the day of Arafah is equal to supererogatory fasting of one thousand days."
"The fasting on the day of Ashura is equal to supererogatory fasting of one year and on the day of Arafah two years."
The fasting performed on the day of Arafah is equal to freeing two thousand slaves, sacrificing two thousand camels and giving two thousand horses in the way of Allah for jihad."
"The fasting performed on the day of Arafah will be atonement for the sins of the previous year and the next year."
It is recommended to read the chapter of al-Ikhlas one thousand times by some great personalities. It is stated in hadiths that reading the chapter of al-Ikhlas will be a means of forgiveness for the sins except individual rights.
"The sins of a person who reads al-Ikhlas one thousand times with Basmala are forgiven and his prayer is accepted."
The Prophet (pbuh) prayed to Allah on the night of Arafah to forgive his ummah. His prayer was answered as follows: 'I have forgiven them, except for the wrongdoer, with whom I will settle the score in favor of the one whom he wronged.' The Messenger of Allah said,
'O Lord, if You wish, You will grant Paradise to the one who is wronged, and forgive the wrongdoer.' No response came from Allah in Arafat to this prayer. The next day at Muzdalifah, he repeated the same prayer. This time, his prayer was accepted. The Messenger of Allah (pbuh) laughed, showing his joy. Thereupon, Hz. Abu Bakr and Umar said to him,
‘May my father and mother be sacrificed for you! This is not a time when you usually laugh. What made you laugh?’ The Messenger of Allah (pbuh) said,
‘When the enemy of Allah, Iblis, came to know that Allah answered my prayer and forgave my nation, he took some dust and started to sprinkle it on his head, crying 'Woe on you! You have been destroyed!' This cry of Satan's, which I saw, made me laugh.'
It is necessary to show respect to the day of Arafah; we should join the prayers of hajjis who are on Arafat on that day by feeling that we are with them spiritually. We should avoid anything that can cause us to commit a sin on that day. Nowadays, the day of Arafah is experienced as a very busy day with worldly affairs since it is one day before eid. In fact, Arafah is one of the most important time periods given to man. These days are days of worshipping and forgiveness. It is the most valuable time period when hajjis come together in Arafat regardless of their languages, races and skin colors reminding of the Day of Gathering by saying, "Labbayk (Here I am at your service)" and when servitude is presented to Allah by supplications and talbiyahs. The Messenger of Allah (pbuh) states the following:
"The most virtuous prayer is the one said on the day of Arafah." (Bayhaqi)
"Allah looks at His slaves on the day of Arafah and forgives anyone who has even a very little amount of belief."
Allah informed the Prophet (pbuh) that prayers are not rejected on some nights. The four holy nights when the doors of mercy are opened are as follows:
1. The night of (before) eid al-fitr,
2. The night of (before) eid al-adha,
3. The night of Tarwiyah (8th night of Dhul-hijjah),
4. The night of Arafah. (Isfahani)
It is very virtuous to spend the day and night of Arafah worshipping. There are narrations stating that a person who spends the night of Arafah worshipping will be saved from Hell. It was stated by the Messenger of Allah (pbuh) that a person who avoids sins on the day of Arafah will be forgiven.
"On the day of Arafah, a young man who was near the Messenger of Allah (pbuh) was thinking about women and looking at the women. The Messenger of Allah (pbuh) turned the man's face away from the women a few times. The young man started to think about them again. The Messenger of Allah (pbuh) said,
"My brother's son! Today is such a day that anyone who controls his ears, eyes and tongue is forgiven." (Musnad)
The following are advised to do on the day of Arafah:
1. It is necessary to start uttering takbirs of tashrik after the fard of the morning prayer.
2. One should perform fasting on the day of Arafah.
3. One should show respect to the day of Arafah and try not to commit sins.
4. One should pray to Allah and ask for forgiveness a lot on the day of Arafah.
5. One should read the chapter of al-Ikhlas 1000 times on the day of Arafah.
#Allah#god#islam#quran#muslim#revert#convert#revert islam#convert islam#reverthelp#revert help#revert help team#help#islam help#converthelp#prayer#salah#muslimah#reminder#pray#dua#hijab#religion#mohammad#new muslim#new convert#new revert#how to convert to islam#convert to islam#welcome to islam
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Knowledge of Islam's philosophy of life (one)
The main voice of the Islamic way of life is the vision of knowledge of the Qur'an and the vision of love of Ahl al-Bayt and its simultaneous union, which is the implementation of the essence of the farewell Hajj speech given by the Prophet (PBUH). The speech informed that the only way to stay on the right path and not to go astray is to cherish the knowledge of the Qur'an with love and itrat, i.e. love for Ahlul Bayt. This approach is the main philosophy of Islamic life law and the essence of worship. The main goal of this article is to show what needs to be done to implement that philosophy in every aspect of life.
The formation of the loving nature of Allah-Rasul is the real life philosophy and knowledge Allah says - وَالَّذِيْنَ امَنُوْا اسَدُّ حُبَّا لِلَّهِ. Those who believe have a lot of love with Allah. - Baqarah: 165 verses Allah says this verse differently in Hadith Qudsi - 'I was a hidden treasure; I manifested myself in love to make myself known and created everything in the heavens and the earth to know me.' (Hadith Qudsi) This means that God's creation is the symbol of His love and in fact love is the generational process of all creation. Without love there is no birth and development of creation. The human birth process is also a product of that same love. Therefore, the loving creation has to wait for God's love by nature. Without love, no act of worship is possible for a servant. Allah made Adam (Alaihis Salam) his knife, He said - 'Inni khalaka Adama ala churatihi (Qur'an). That is why the children of Adam are urged - 'Takhallaku bi akhlakillah - you form nature according to the nature of Allah (Qudsi in the hadith)' and Kalamepa also said - صِبْغَةَ اللَّهِ. Chhibgatallah - Be colored in the color of Allah or form nature by nature. (Baqarah: 138) In order to form such a character, one has to do hard Riyazat Sadhana and Ibadat-Bandeghi from the path of truth-right-siratal mustaqeem for a lifetime. So Allah Almighty says- اَلَّذِيْنَ جَاهَدُوْا فِسْنَا لَنَهْدِ يَنَّهُمْ سُبُلَنَا ط
That is, those who endure hardships in my way, surely I will guide them to my nearness and virtue. (Ankabut: 69 verse) Thus, the means of nearness and virtue is the Habib of Allah (SAW); It is not possible to earn Allah's love and satisfaction if one does not love him, if one does not follow and imitate his Sunnah and moral character. So the last Prophet (peace be upon him) said - 'You (no one) can become a believer, until you keep friendship with me (most) than your lives and property, children and children, parents and the whole human race. (Hadith) Therefore Ishke Rasool is the medium and standard of Ishke Ilahi. It is said in the hadith Qudsi - Laulaka Lama Khalaktu Aflakh (O Prophet) If I had not created you, I would not have created anything. The echo of this is the saying of the Holy Prophet - 'I was a Prophet when Hazrat Adam was in the mud of water and mud. (Hadith) So he (the Prophet) assuredly said - He who loves me, surely loves Allah. Whoever follows me follows Allah, whoever sees me has indeed seen Allah. (Hadith) This is the true philosophy of the means of attaining Allah or Siratal Mustaqeem and the constitution of the Islamic way of life.
Documentary evidence of the use of means in Islamic life rules:
The Qur'an says: يَاَویُّهَا الَّذِيْنَ اَمَنُوا اتَّقُوا اللَّهَ وَابْتَغُوْوّا اِلَيْهِ الْوَ سِيَلَةَ وَخَا هِدُ وْا فِىْ سَبِيْلِهِ لَعَلَّكُمْو تُفْلِحُونَ 0 'Ya Ayyuhallajina Amanu'ttaqu'llaha Wabtagu' Ilaihil Wasilata, Wa Zahidu' Fi'Sabilihi La'Allakum Tuflihun -O you who believe! (You) fear and love Allah and seek means or means for Allah, and strive (spiritually and physically) in His way; So that you can be successful. (Surat al-Maida, verse 35); Surah Baqarah verse 143 says- and Thus I have established you as a nation of moderates so that you may be witnesses for mankind and the Messenger will be witnesses for you.' This means the identity of the Ummah Muhammadi - as a nation of mediums and moderates. Allah says - فَلَا تَخَا فُوْهُمْو وَخَا فُوْنِ "Don't fear people, love and respect me. (Ale Imran: 175 verses); He who has this fearful love of Allah in his heart can be a righteous believer of the Muhammadan Ummah and a beloved servant of Allah. But in the case of human life, it is mostly seen that they love Allah's creation more than Allah, which is becoming and becoming a partner. These are the wayward Siratal Mustaqeem, the wayfarers of the opposite course. Their predecessors were Ezidi-Abu Jaheli characters, unbelieving drunkards, maluni (cursed) servants, and infidels-mushrik-fasek-monafek servants.
Islamic philosophy of life philosophy:
According to the hadith narrated by Hazrat Abu Hurairah Radi Allah Anhu, the Prophet, may God bless him and grant him peace, said: “Whoever believes in Allah and the Hereafter, let him speak good words or remain silent.” (Bukhari and Muslim) He also said, "Whoever preaches something to slander a Muslim, Allah Ta'ala will cast him into the fire on the Day of Judgment." (Continued)
#Islamic way of life#Islamic philosophy of life#Hazrat Abu Hurairah#mushrik-fasek-monafek#Siratal Mustaqeem
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Surah Al -Ikhlas (purity)
This sura is main theme of Islamic concept not only islamic concept but from Adam to Jesus all Prophets gave this message and last prophet Muhammad SAW also give this message this is called islamic monotheism. This is the purity These verses are from sura maida chapter 5 these are about Jesus pbuh and Mozez
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Yükleniciler yarar sağlamaz, sadece OpenAI'nin ChatGPT'sini eğitmek için gereklidir. — NBC News için Adam MaidaKansas City'de ikamet eden Alexej Savreux, fast-food sandviç montajcılığından bekçiliğe ve hurda nakliyecisine kadar çeşitli meslekleri kapsayan, hatta canlı tiyatro için teknik ses işleriyle uğraşan oldukça çeşitli bir kariyere haiz. Bununla beraber, mevcut görevi, daha azca uygulamalı olmasına karşın, bir suni zeka (AI) eğitmeni olarak eşit derecede etkilidir.Savreux, AI sistemlerinin geliştirilmesinde oldukça mühim sadece çoğu zaman gözden kaçan bir rol oynayan gizli saklı bir sözleşmeli çalışanlar ordusunun bir parçasıdır. Emekleri, verileri çözümleme etmek ve ChatGPT benzer biçimde son teknoloji ürünlerin kullanıcılarını hayrete düşüren ilgi çekici metin ve resimler oluşturmak için suni zeka modellerini eğitmeyi içeriyor. AI doğruluğunu ve etkinliğini çoğaltmak için Savreux, fotoğrafları etiketleme ve metin üretimi için tahminler yapma benzer biçimde görevlerle meşgul olur. Mühim katkılarına karşın, bu yükleniciler herhangi bir yarar sağlamadan saatte 15 dolardan süregelen tazminat alıyorlar. Son yıllarda Savreux ve yüklenici arkadaşları, OpenAI sistemlerini eğiterek ChatGPT'nin yanıtlarını iyileştirmek için sayısız saat harcadılar. Geri bildirimleri, OpenAI ve rakipleri için acil ve devamlı bir ihtiyacı karşılar: durağan(durgun) bir cümle, etiket ve eğitim verisi akışı. Savreux, sözleşmeli çalışanların tehlikeli sonuç rolünü vurgulayarak, "Biz homurdanan işçileriz, sadece onsuz hiçbir suni zeka dil sistemi olmazdı. İstediğiniz tüm sinir ağlarını tasarlayabilir ve istediğiniz tüm araştırmacıları dahil edebilirsiniz, sadece olmadan etiketleyiciler, ChatGPT hiçbir şey olmazdı."Yaptıkları işin önemine karşın, suni zeka sözleşmeli çalışanları çoğu zaman suni zeka alanındaki teknolojik gelişmelerin cazibesinin gölgesinde kalmış olarak fark edilmeden kalıyor. Partnership on AI'da AI, emek ve iktisat program lideri Sonam Jindal, AI etrafındaki söylemin, geniş bir insan işgücüne güvenmeyi kaçırırken kutlama edici yönlere odaklanma eğiliminde olduğuna dikkat çekerek bu gözetimin altını çiziyor.Tarih süresince teknoloji endüstrisi, imparatorluklarını inşa etmek için binlerce düşük nitelikli ve düşük ücretli işçinin çabalarına güvendi. Geçmişteki delikli kart operatörlerinden, ikinci derslik çalışanlar olarak işlem görmeleriyle ilgili endişelerini dile getiren günümüzün Google yüklenicilerine, sektörün sözleşmeli çalışanlara bağımlılığı yeni bir şey değil. Amazon Mechanical Turk benzer biçimde çevrimiçi esnek emek harcama platformlarının yükselişi, bilhassa pandemi esnasında bu eğilimi daha da sağlamlaştırdı.Gelişmekte olan AI endüstrisi, istikrarsız, talep üstüne bir emek harcama doğasını benimseyerek benzer bir model izliyor. Sözleşmeli çalışanlar, ya direkt firmalar tarafınca ya da geçici emek harcama ya da dış kaynak kullanımına odaklanan uzmanlaşmış üçüncü taraf satıcılar vesilesiyle yazılı sözleşmeler yöntemiyle çalıştırılır. Sıhhat sigortası ve yan haklar çoğu zaman yoktur, bu da teknoloji şirketlerinin maliyetlerini azaltır. Ek olarak, emek harcama çoğu zaman anonimdir ve teknoloji şirketi yöneticileri ve araştırmacılar krediyi alır. Suni Zeka Üstüne Ortaklık, "veri zenginleştirme emek vermesi" için talepte yaklaşmakta olan bir artış mevzusunda uyarıda bulunmuş oldu ve adil tazminat ve iyileştirilmiş uygulamalar önerdi. Sadece, yalnızca Google'ın bir AI yan kuruluşu olan DeepMind, bu yönergelere uymayı açıkca taahhüt etmiştir.Jindal, sözleşmeli çalışanların katkılarını tanımanın ve bunlara saygı duymanın önemini vurgulayarak, suni zeka tarafınca yaratılan bu nispeten yeni işin, çalışanların katkılarına gore kıymet görmüş olduğu yüksek kaliteli bir meslek olma potansiyeline haiz bulunduğunu öne sürüyor.Suni zeka sözleşmeli çalışmasına olan talep artmaya devam ederken, bazı suni zeka sözleşmeli çalışanları daha iyi koşullar için savunuculuk yapıyor. Nairobi, Kenya'da Feysbuk, TikTok ve ChatGPT benzer biçimde firmalar için AI üstünde çalışan 150'den fazla şahıs, düşük ücret ve işin zihinsel bedelini gerekçe göstererek bir sendika oluşturmak için oy kullandı. Suni zeka sözleşmeli çalışanlarının hakları ve refahı, sektör geliştikçe bir münakaşa mevzusu haline geldi.
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These memories popped up today. From the 2015 trip to play the Outlaw Roadshow with my pals and heroes Sal Maida and Frank Funaro. Plus drinks with a guy who supports indie artists in a big way, Adam Duritz. (at The Bowery Electric) https://www.instagram.com/p/CnjsRXtOA1R/?igshid=NGJjMDIxMWI=
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Adam Maida — Stalker (movie poster, 2019)
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