A dolls house Essays (337 words) - Ibsen Family, British Films

A dolls house A Doll's House as Tragedy Henrik Ibsen's A Doll's House can be seen as defining modern tragedy, and Ibsen's innate ability at creating dramatic situations is evident in the fact that many of the conventions seen in theatre and television drama were developed within this play, some 120 years ago. For instance, the popular BBC1 soap EastEnders recently featured a plot strand revolving around the fate of a letter left by the dead Tiffany, and whether this letter would be presented to the police or destroyed. Ibsen creates a near-identical scenario between Torvald and Nora concerning Krogstad's letter disclosing the details of her loan. A development of these ideas can be traced in the preliminary notes Ibsen made before writing A Doll's House, entitled Notes for a Modern Tragedy (1878). This phrase itself appears ironic, even paradoxical: the tragedy is a classical literary form dating back to the time of the Greeks, when Aristotle gave his now famous definition of tragedy in terms of catharsis, namely the cleansing effect which explains the pleasure an audience derive from watching tragedy performed on stage. This tragedy unfolds against an ancient, pre-Christian backdrop. It is important to appreciate A Doll's House as a creature of its time; although still of value, it was written for (and concerns) Norwegian society at the turn of the century. With theatre, perhaps more than any other art form, an audience will construct their own meaning for a play based on their own cultural upbringings and belief systems. This argument can be carried to extremes, but it is important to realise that the world of Ibsen is not (necessarily) the world of today. In Notes for a Modern Tragedy, Ibsen wrote: [There are] two kinds of moral laws: one for men, and another (quite different) for women. They don't understand each other, but in practical life woman is judged by masculine law as though she weren't a woman but a man. He continues with more specific...

Fraudulent Chats With Unlike A essays

Fraudulent Chats With Unlike A essays Your standing in the lunch line and who happens to be in front of you, but Natalie Smith, that girl you just can't stand, everything she does just irks you. Even the thought of her brings these disturbing thoughts, that can't be that healthy, like wanting to take her by her little, blonde pig tails and swing her off from the highest building, making those little rosy cheeks stained with blood, this bringing the biggest grin to your face. Being her bubbly, cheerful self, she turns around, gives you the brightest smile, and acts as if its a surprise to see you. This all follows with one of those fake conversations. Everyone has had to have one, so I am sure you all know what I am talking about. You both know you don't care for one another, but you carry on with a friendly, "How have you been? What have you been up to?" bogus conversation. I particularly hate when I bump into these people. What I rather do, is turn to them and say, "I really don't like you and I know you don't really like me, I could care less, my life will go on, I really have no reason at all to talk to you, so please... step aside!" This of course is the nice way of putting it. And its really a simple solution to get out of those miserable conversations, with the phonies that like to put on fronts. Those people that like to be nice to everyone. Saying something along these lines, would surely set these people in their places and they will come to see that maybe not everyone is a Mary Poppins sunshine 24/7. You can just be upfront, you wont have to struggle to smile to the person you most despise, you wont have to act like you care about what they did during their vacation. If they went para sailing off in Hawaii, unless the little ropes on their parachute snapped and there little, fragile body went crashing down on the cold, brisk water, instantly braking every bone in their body. Then you would not only not have to talk to them, but wouldn't even have to see their ...

Digital Marketing Case Study 4 Example | Topics and Well Written Essays - 1250 words

Digital Marketing 4 - Case Study Example Their lifestyle also denotes a proper work-life balance. As per the demographic segmentation, there is increased percentage of middle age group individuals in UK market. Poverty level is considerably low in UK market due to economic stability in the geographical region. Cookery and textile business is utilizing online platform to communicate with target audience (Bea’s Handmade, 2014). Expert classes are designed for students along with production of unique textiles for UK consumer market segment. However majority percentage belongs to middle income group segment and this requires proper designing of communication strategy. Technological developments in UK have been able to transform its business environment. UK government is actively involved in lump sum investment towards research and development activities. Funds of  £4 billion have been allocated in R&D sector. Key developments have been mainly in communication and internet segment. The rapid change of broadband diffusio n has enhanced growth of internet and mobile communications. Technological development has also encouraged transfer of high street shops to online platform. This aspect has been incorporated in the marketing strategy of cookery and textile business. Online platform such as Facebook, Twitter, etc., is being utilized by the firm to promote products and interact with customer base (UK Parliament, 2015). Governmental support towards developing new communication channels shall be an opportunity for the business in future years. As per the analysis on income distribution in UK market, majority of population belongs to middle income group segment. This might negatively affect Becky’s business to certain extent since individuals would not have high disposable income to be spent on cookery classes or handmade products. Positive impact on the business shall be in the form of governmental support to promote textile products. Culture of UK denotes a proper work-life balance,

Public Relations - The Communication Cycle Essay

Public Relations - The Communication Cycle - Essay Example Apple is a multinational company belonging to the technology sector and subsector computers manufacturing. It engages itself in computer, mobile phone, tablet manufacturing and developing software. It is best known worldwide for its computer brand Imac, tablet computer ipad, mobile phone brand iphone. As a company belonging to the IT sector it comes 2nd after Samsung electronics. It was named as the most valuable company in the United States in 2003, a place which it acquired by surpassing Coca cola. Apple was founded by Steve Jobs, Steve Wozniak and Ronald Wayne in 1977 and by 2013 has a market capitalization of 170 billion dollar (Apple Inc., 2014). Apple belongs to a sector which is experiencing very rapid changes, particularly in field of innovation. The number of consumers having a mobile device now days has increased tremendously (Hoskisson, Michael, Ireland, & Harrison, 2007). The threat of a new entrant bringing in a new technology is too high these days. So no company in this particular sector can just sit back on its laurels and accolades and relax. Even for a Company like apple, if it stops innovating and comes out with newer product lines or innovation some other player will bring in a new product. Another factor that plagues companies like apple is that its designs may easily be copied by some other company and used to produce a similar phone at a much cheaper price range. In fact there have been instances in the past where Samsung has allegedly violated copyright restrictions of apple’s designs and the two companies have engaged themselves in legal battle. So to successfully hold its position in today’ s market Apple needs to: 1. Trend of innovating newer product lines and there by entering virgin markets. 2. Build a strong association with its customer base (Scott, 2013). 3. Build its reputation in the field of customer service and designing products that

French Favorites For Woodwind Trio Essay Example | Topics and Well Written Essays - 500 words - 1

French Favorites For Woodwind Trio - Essay Example The concert was attended by large crowd of classical music lovers and the fans of the ‘French Favorites for Woodwind Trio (Keith par 1).’ Upon entering the hall, I was mesmerized by its attractiveness. First, the hall is well designed such that the stage can be viewed from any place in the hall. Then, the decorations of the hall, that consisted of flashing disco lights and spelt classical music. Since I was late, I had to wedge my way through the crowd, which consisted mainly of familiar college mates, although with speckles of excited lecturers here and there. I even obtained a giggle from my music teacher who had settled at the fore spaces. I finally got a spacious position at the back place, where I could jig and dance my worry of life outside the hall off. Well, I hastily obtained a dancing partner, my classmate who also had found a position at the back. The master of ceremony was this kind of gentle men that are comedians by nature. From the point of his ushering in the concert’s audience, to his introduction of the performers, the audience could not help but laugh. He made the concert very lively. At the point where he pronounced the names of the ‘French favorite favorites for Woodwind trio’, they received a deafening applause from the crowd. Then, chattering followed as the faces of the audience registered excitement with anticipation. Soon the theatre was grave silent again, and the beats of ‘Suite Breve en Trio’ started to engulf the stage like a wave coming from very far off the horizons. Although so soft and from an old age origin (1905-1991), this music had the power of sweeping off from my feet, and for a moment, I was floating in the air with ecstasy. Oh my! The power of classical music, I did not even realize it as the guest performers entered the stage. I became conscious of them only after the beats faded and then the sound of the English horn in the

Chocolate Brand Expansion into India

Chocolate Brand Expansion into India Submitted by: Sanjay Sharma   Whittakers is a New Zealand based chocolate company, owned and operated by Whittakers family since 1896. This chocolate brand is one of the most popular and trustworthy brand in the country, all the products are made in their own factory located in Wellington. The company exports its chocolate products to countries like Australia, Malaysia, Singapore, and Middle East and so on. This evaluation report targets India as its international market, focusing on possibilities of international business trade for Whittakers chocolate brand. Analysis through market research helps a business to understand the kind of the products and services that can help an organization to earn profit and meet customers expectations. PESTLE Analysis:   Ã‚   PESTLE analysis is a popular business tool utilize to understand the external factors that can affect a business or an organization, say, political or economic factors. Political factors: India: India, one of the worlds largest democracies functions through a federal government. The business environment in the country gets affected by multifarious factors say governments policies, ideologies and interests of political figures. The political environment in the country can be considered cyclic as the elections are conducted in every few years and there are chances that the selected political party can be different from the previously elected one. New Zealand: New Zealand follows democracy strongly creating an environment to business steadily. Here the political system is stable however the Queen supremacies but the government rules. The country offers a supportive tax guidelines for investing and growing a business. Observation: Both the countries follow democracy system of government, though India has a huge population so the chances prediction of political environment gets really tough. Because of re-election process the political factor is least predictable as the rules and regulations can be changed or updated for upward mobility. Economic factors: India: 25 years ago, India embarked on a journey of economic liberalization, opening its doors to globalization and market forces. According to a report by International Monetary Fund, the countrys GDP is said to grow by 7.4 percent in the year 2016-17, which will make it the fastest-growing large economy in the world. (Madgavkar, 2016) New Zealand: Social factors: India: A pleasant arrangement of increasing disposable incomes, changing standard of living and a young populations rising liking for indulgence has transformed the country as the fastest growing chocolate market globally. The chocolate industry in India is growing nearly by 20% every year. (Karnik, 2015)India hold a majority proportion of young people, according to CIA, median age in India was 27.3 years in 2015.Indias urban ranges make a noteworthy commitment to the nations economy. Albeit short of what 33% of Indias population live in urban communities and towns, these zones produce more than 66% of the nations GDP and record for 90% of the administrations incomes. Accordingly, urban territories have been developing quickly, with a solid inundation from the rustic populace. New Zealand: New Zealands economy is greatly reliant on exchange with different nations. Change in outside request may influence the nations monetary circumstance. The nation has bring down spending in RD exercises bringing about outside reliance for new innovation. New Zealand has distinctive culture just like the significantly Christian ruled religion. Along these lines, amid Christmas and different celebrations, New Zealand is altogether extraordinary, for example, utilization and imports of nourishments and refreshment and electronic contraptions increment amid merry season. Future rate is progressively and death rate is low in New Zealand which is useful for nation however not consider so great at association forthcoming in light of the fact that in New Zealand, after retirement, without doing any work individuals get annuity, tip subsidize till long time which influence organization benefit. Technological factors: India: There has been huge sustainable change in technological sector in India, the number of institutions has increased within past years in the country. Also there is easy availability of 3G and 4G network in most places in the country. Considering total number of startups including both tech and non tech areas the country. As far as aggregate number of new businesses, including both tech and non-tech regions, India again figured among the five biggest has on the planet, alongside China (10,000). IT center point Bengaluru is host to 26 for each penny of household tech new businesses, trailed by Delhi NCR (23 for every penny) and Mumbai (17 for each penny). In the making up for lost time class were Hyderabad (8 for each penny), Chennai and Pune (6 for every penny each). (PTI, 2016) New Zealand: The country has made noteworthy development in numerous technological products. India is one of the largest and fastest growing economy globally, the country represents enormous chances for line of work and is a significance association for the New Zealand Government. The innovation area is New Zealands quickest developing part and backings a huge number of employments. Sends out have multiplied in the course of recent years and are currently worth more than $6 billion. Inside this, the advanced economy and the weightless division is currently assessed to be worth $1.3 billion. It is the nations third biggest fare worker behind dairy and tourism and addresses each other real market section. (Macleod) Legal and Environmental factors: India: An exhaustive lawful and administrative system has made it feasible for business elements in India to flourish. Later charge changes, for example, the usage of VAT, have been fruitful and have expanded aberrant duty accumulations in the nation. The fund service has proposed the execution of the Direct Tax Code (DTC), which means to extend charge pieces and negate the various assessment exceptions that are at present set up. Merchandise and enterprises charge (GST), a far reaching backhanded tax collection framework, is likewise anticipated that would be executed in the close term. Changes in both direct and aberrant duties would supplement the administration assess income considerably by extending the expense base instead of expanding the expense rates. (MarketLine) New Zealand: India is the seventh biggest nation on the planet, and Asias second biggest country, with a zone of 3,287,263 sq. km. In spite of having just 2.5% of the worlds property range, India represents 7-8% of comprehensively recorded species. The nation is among the 12 uber biodiversity areas of the world, which are accepted to be home to 60-70% of worldwide biodiversity. India has almost 2,400 known types of creatures of land and water, fowls, warm blooded creatures, and reptiles, of which 18.4% are boundless. Of these, 10.8% are debilitated. The nation is home to almost 19,000 types of vascular plants, of which 26.8% are endemic. There are a huge number of advantages of biodiversity including solutions, mechanical materials, and the arrangement of environmental administrations. (MarketLine) In 2011 Prime Minister John Key propelled the NZ Inc. India Strategy, an arrangement for India to wind up distinctly a center exchange, financial and political accomplice for New Zealand. The NZ-India FTA is a significant stride toward accomplishing that objective. New Zealand and India as of now appreciate a solid relationship. India was New Zealands tenth biggest exchanging accomplice in the year to June 2016, with aggregate exchange products and enterprises worth more than NZ$2.5 billion. Fares to India were worth NZ$1.7 billion (NZ$656 million in products, NZ$1 billion in administrations) with imports worth NZ$821 million (NZ$591 million in merchandise, NZ$230 million in administrations). More than 10,000 Indian understudies came to ponder in New Zealand in 2015, and another 35,000 Indian vacationers went by that year. There are well more than 100,000 Indian nationals inhabitant in New Zealand. (New Zealand-India FTA, n.d.) There are certain possible benefits to this agreement, it can create an improved access in the Indias enormous market focusing on the developing middle class and also it will create vast opportunity in various New Zealands service sector say, tourism, environmental. Certain clashes like competitors like Cadbury and other well settled brand can be faced. Moreover vegetable fats can be a content for chocolates internationally but in India doing so is not permitted. Certain number of companies have faced issues as they did not fir the Indian standard requirements. Social Media: Internet systems administration is incredibly being utilized these days. Online headways ought to be conceivable by method for Twitter, LinkedIn, Facebook, Blogger and so forth. We can make web diaries, we can make page on Facebook and Twitter. This will help us to exhibit our things among youth masses. Posting progressions on goals that get overpowering human affiliation is one approach to manage get the word out about your business, for example, we can use Facebook having broadcasting programs with headways only fitted to a specific measurement masses. These promotions appear to be recently adjacent profiles that meet the inspirations driving your things objective business section. In like way, we can use Google AdWords association to post online advertisements this organization is extraordinarily to post advancements. E-mail: Email is the current electronic media to send message. It is a way to deal with bestow people wherever all through the world for the span of the day and night without holding up the beneficiary to wake up and making himself appear. It can send messages to numerous people in a matter of moments. It can in like manner send records, photos or even video cuts. Radio and Television: These two are the wellspring of data. They give us the most recent data in the state of news and commercials and furthermore a wellspring of excitement for us. Telecommunication:    Media transmission is the most imperative method of correspondence. It builds up direct connection between two gatherings situated at better places and whenever. Telephone utility was begun in 1881 in India however in the most recent two decades, there has been gigantic development in media transmission division. India has now the biggest media transmission arrange in Asia. Moreover cellular services are at boom in the country.

Innovation of Ipad

IS THE IPAD A DISRUPTIVE TECHNOLOGY? Technology has been moved towards advancement day after day bringing new and improved devices and system. People are always on the verge of inventing something new and exciting. About a decade ago, mobile phone was rarely used by people but now everyone has a smartphone with all the possible gadgets in it like camera, video player, internet and more. Talking about disruptive technology which almost replaced any other company in new innovation was Apple. Apple launched iPhone which was one of the major successes in disruptive technology because it provided every bit of comfort to its user while using it.When apple launched ipad in 2010 there was a huge marketing and hype about its new innovated technology in the market. It was 10 inch tablet which runs on IOS (iphone operating system) as any other apple product. The ipad only runs apps from the Apple App Store. There are thousands of these applications available in the iTunes from movies, songs, ga mes and more. The ipad is not a necessity like the smartphone which do have the same gadget however it improves the quality of life of its users.Ipad has been used by the first author in two units offered by the Department of Statistics at Macquarie University (Sydney, Australia): a second-year Introduction to Probability unit (PROB) and a masters-level unit Mathematical Background for Biostatistics (BCA), delivered through the Biostatistics Consortium of Australia (Simpson, 2009). The use of technology, particularly the use of ipad, has supported a different mode of teaching in these two units that takes account of the general needs of the students and it enables students to be responsive to their individual requests.The ipad has been used as a way to involve, and motivate students through high-level presentation and communication tools. It has changed the approach in learning, experience simpler and deeper. Students will now experience the most amazing textbooks they’ve eve r read through the means of ipad because it provides with the images and dictionary one tap away to find the meaning of any word. This facilitates the user to become more relax while reading through ipad. Talking about the market that ipad is looking to compete is kindle. A kindle is a device just like ipad but smaller than ipad.Kindle is specially design only for reading purposes. It is dark ink display which enables user to study freely in the sunlight without any hesitation unlike ipad. Ipad is more likely a multi-purpose device which is used for almost everything that we need. It is easy to study at night rather at day because of its multi-colour display. But after apple launched the new ipad it has been solidified its presence on the e-reader device market, a market that has been previously been the dominated by Amazon, with its Kindle, and Barnes and Noble.Those devices are especially dedicated to e-book readers, while the new ipad series is an e-book reader in along with its various features, such as web browsing, multimedia, and support. But that flexibility doesn't make ipad a better product than kindle. Sometimes device that can do only one thing can be way more interesting than a multi-purpose device. The smallest, lightest, least expensive, easiest for reading purposes are the black-and-white e-book readers. If user wants only a reading tablet device it is to say the kindle is the favourite excluding the joy of watching videos and images.Each company offers varieties of models which gets the best lighting conditions. The one you want is the Kindle Paper White, whose brilliance is more pleasant than the equivalent any other device out on the market With plain, no-touch, no-light Kindles, with the ads on the screen saver, are quite cheaper but the light and the touch-screen are really worth having. One of the important parts in the learning experience is when a student does not understand a topic or a step in an exercise. The easiest way to help him or her is to go through the question using written words.With the introduction of the ipad into the teaching method, written answers can be incomplete to some cases when they are applicable and an answer to a student’s question can be produced in the form of a video lecture particular to the topic or exercise. The learning module of distance students has now been completely changed. If they cannot solve a problem or face any problem with the subject material by themselves, there is a new possible way by dedicating video by the tutorial/lecturer that shows every step of the problem and solution.This format is particularly important and has been successful. Written solutions are the same as the textbook and are often unable to provide the student with a new approach on solving the problem. It is common that a lecturer’s first response to a question is not enough and students ask for more visions. A video is different because it allows the student go through every step of the explanation in a more verbal way and probes asking for further explanation after such a mini video lecture are unusual.

How Fed Uses Open Market Operations Essay

Open market operations, which consist of purchases and sales of government securities, is the Federal Reserve’s conventional device for exercising monetary policy. Based on the Fed, the term monetary policy refers to the actions taken by a central bank to influence the availability and cost of money and credit and to help promote national economic goals (FederalReserve.gov). These securities transactions help dictate the federal funds rate (rate at which banks lend excess reserves to one another). The fed funds rate is significant to our economy because it somewhat controls the overall financial situation, affecting employment, output, and the overall level of prices. FOMC In 1913, the Federal Reserve Act was passed, giving the Fed authority for setting monetary policy. In 1935, the Federal Open Market Committee (FOMC) was created. They are the board in charge of setting monetary policy for the Fed. THE FOMC implements the policies and also discloses them to the public. The board consists of 12 members that serve one-year terms on a â€Å"rotating basis†. They hold 8 scheduled meetings a year, and discuss economic and financial conditions, proper stances of monetary policy, and risk-assessments of things like price stability and sustainable economic growth (FederalReserve.gov). GOALS of MONETARY POLICY The two primary goals of monetary policy are to promote sustainable output and employment to the highest capacity and to promote price stability. Although monetary policy cannot affect these two things in the long run, it certainly can help influence them in the short-term. An example of this is interest rates. The Fed can lower interest rates to help raise demand and thus help to momentarily stimulate the economy. The problem with this, though, can be inflation. In the long run, attempting to fuel an economy beyond its capabilities will not help unemployment rates or output, but rather, just create more inflation, hurting economic growth. OPEN MARKET OPERATIONS: TOOL of MONETARY POLICY Open market operations are very useful in exercising monetary policy due to their relation with the total supply of balances at the Federal Reserve and the federal funds rate (Edwards, pg. 859). At the federal funds market, using the fed funds rate, depository institutions lend Federal Reserves balances to one another. The total amount of Federal Reserve balances that are available to these institutions is assessed via open market operations. These operations are aimed at either achieving a desired quantity of balances, or a desired price. The problem is that it is difficult to attain both, considering they negatively converse one another. According to Cheryl L. Edwards, of the Boards Division of Monetary Affairs: â€Å"The greater the emphasis on a quantity objective,   the more short-run changes in the demand for balances will influence the federal funds rate; conversely, the greater the emphasis on a funds-rate objective, the more shifts in demand will influence the quantity of Federal Reserve balances.† Throughout the years, the Fed has used both methods for open market operations. ADVANTAGES There are numerous reasons as to why the Fed uses open market operations to control monetary policy. First, the Fed has complete control over the type of open market operation and its size. Second, open market operations can be implemented quite hastily and without delays. They are also flexible, so the Fed can quickly reverse any mistakes. Lastly, the funds rate lets the FED adjust reserve balances when things past the Fed’s control cause reserves to rise and fall (Akhtar,1997). DISADVANTAGES With everything, there are advantages and disadvantages. The disadvantages of open market operations relate to specific, isolated situations. For example, if the money market is not developed, the central bank can’t exert full control over the bank reserves(blurit.com). Also, if commercial banks have excess reserves but still use an easy lending policy, the sale of government securities will not have the intended effect of lowering cash reserves of the commercial banks. And if there is a return of notes from circulation, the securities sale might not be able to â€Å"reduce the cash reserves of member banks†. HOW FED USES OPEN MARKET OPERATIONS The Federal Reserve operates open market operations with primary dealers (government securities dealers that have a strong trading relationship with the Fed (newyorkfed.org). These dealers hold accounts at depository institutions, so when the Fed does funds transactions with the dealer at it’s bank, the transaction either adds to or takes away from the reserves in the banking system. Because of this, open market operations indirectly influence the fed funds rate. Changes to the fed funds rate ultimately have a powerful effect on other short-term rates. CONCLUSION In conclusion, open market operations have always been the most prominent of the three tools used in affecting monetary policy. In today’s technological and highly competitive financial environment, monetary policy can sometimes be difficult, but the Fed still accepts open market operations as the most essential way to control our policies. As Michael Akbar Akhtar, vice president of the Federal Reserve Bank of New York, explains: â€Å"Among the policy instruments used by the Federal Reserve, none is more important for adjusting bank reserves than open market operations, which add or drain reserves through purchases or sales of securities in the open market. Indeed, open market operations are, by far, the most powerful and flexible tool of monetary policy† BIBLIOGRAPHY – http://research.stlouisfed.org/aggreg/meeks.pdf. Understanding Open Market Operations, M.A. Akhtar. Federal Reserve Bank of NY, 1997. – http://www.federalreserve.gov/monetarypolicy/default.htm -http://www.newyorkfed.org/aboutthefed/fedpoint/fed32.html -http://www.federalreserve.gov/pubs/bulletin/1997/199711lead.PDF. Open Market Operations in the 1990’s, Cheryl L. Edwards. -http://www.blurtit.com/q696680.html

Arizona V Johnson Essays

Arizona V Johnson Essays Arizona V Johnson Paper Arizona V Johnson Paper Arizona v Johnson (2009) 129 S. Ct. 781 Date of Judgment: January 26, 2009 INTRODUCTION In 2002, Lemon Montrea Johnson was the passenger in the backseat of a car stopped for a traffic violation. Johnson was charged with; inter alia, possession of drugs and possession of a weapon by a felon. These items were discovered during a protective pat-down search of Johnson. Johnson was convicted by the trial court. Johnson argued that his conviction should be overturned because the trial court was in error by denying his motion to suppress the evidence. He argued that he had been unlawfully â€Å"seized† because being a passenger in a vehicle does not automatically constitute â€Å"seizure. † He furthered argued that even if he had been â€Å"seized,† that by the time Officer Trevizo searched him he was no longer â€Å"seized† as their conversation had become consensual. Furthermore, the evidence should not be considered because the search violated his Fourth Amendment rights and because the officer had no reasonable suspicion that criminal activity was occurring as mandated by Terry v Ohio. On September 10, 2007, the Arizona Court of Appeals overturned the conviction. The court concluded that Trevizo had no right to pat Johnson down even though she believed he was armed and dangerous. The court held that Johnson, although legally detained, had evolved into consensual conversation with officer Trevizo regarding his gang affiliation. This conversation was not connected to the traffic stop of the driver; therefore, the officer may not conduct a pat-down without reasonable cause to believe that â€Å"criminal activity may be afoot. On appeal to the United States Supreme Court, the state argued that police officers should have the right to conduct a pat-down search if they believe the person may be armed and dangerous. On June 23, 2008 the United States Supreme Court granted the State’s petition for a writ of certiorari. The question presented in this case is do police officers have the authority to â€Å"stop and frisk† a passenger in a motor vehicle temporar ily detained upon police detection of a traffic infraction on the basis they believe the person may be armed and dangerous, even when there is no reasonable suspicion of criminal activity? The Supreme Court decided that yes an officer’s reasonable belief that a person is armed and dangerous is sufficient for performing a pat-down search. They established that a Terry â€Å"stop† is met when police lawfully detain a vehicle and its occupants on a traffic violation. The police do not have to believe anyone in the vehicle is involved in criminal activity. A Terry â€Å"frisk† is justified if police reasonably believe the person may be armed and dangerous. Although this case is based on conditions of a traffic stop, one has to wonder if this will open the door to intrusive searches by officers in varying situations. FACTS On April 19, 2002, Officer Maria Trevizo and Detectives Machado and Gittings, members of Arizona’s gang task force, were patrolling in the Tucson neighborhood Sugar Hill, an area associated with the Crips gang. Around 9 p. m. , they pulled over a vehicle after a license plate check revealed its registration had been suspended for mandatory insurance law. The vehicle had three occupants, the driver, a passenger in the front seat, and Lemon Montrea Johnson, respondent, in the back seat. At the time of the stop, the officers had no reason to suspect anyone in the vehicle of criminal activity. The officers walked toward the car. Machado told the occupants to keep their hands in sight. He inquired if there were any weapons in the vehicle, all three said no. Machado instructed the driver to get out of the car. Gittings talked to the front seat passenger, who remained in the vehicle throughout the duration of the traffic stop. Machado interviewed the driver regarding the insurance and registration. Trevizo dealt with Johnson. As Officer Trevizo approached the vehicle, she noticed Johnson alternately watching the officers and commenting to the front seat passenger. This alerted Officer Trevizo. When she drew closer to the vehicle, she noticed Johnson wearing a blue bandana, the chosen color of the Crips. Additionally, she observed that Johnson had a police scanner in his jacket, which she found to be unusual and cause for concern, as† most people† would not carry a scanner â€Å"unless they’re going to be involved in some kind of criminal activity or [are] going to try to evade the police by listening to the scanner. † Trevizo questioned Johnson, who did not have any identification with him but he did provide his name and date of birth. He also stated he was from Eloy, Arizona, a known home to the Crips. Johnson revealed he was a convicted felon who had served prison time for burglary. These factors led Officer Trevizo to believe Johnson may have been a gang member. Officer Trevizo wanted to gather intelligence about the gang Johnson may have been in, as gathering intelligence was one of her main missions in the task force. Officer Trevizo wished to question Johnson away from the others and asked Johnson to get out of the car. Johnson complied. Officer Trevizo was trained extensively as a gang task force officer and knew gang members generally tend to carry a gun. She was concerned for her safety, but did not have a reasonable indication that â€Å"Johnson was engaged in or about to engaged in criminal activity. † When Johnson got out of the car, Trevizo â€Å"patted him down for officer safety. † While patting Johnson down, Trevizo discovered a gun. At that time, Johnson began to struggle. Officer Trevizo hand cuffed Johnson. PROCEDURAL BACKGROUND A. Trial Court Johnson was charged with possession of a weapon by a prohibited possessor, possession of marijuana, and resisting arrest. On October 31, 2005, Johnson filed a motion to suppress evidence found on his person during the pat-down search. The motion was denied. In November, 2005, Johnson was found guilty of the weapons charge as well as possession of marijuana, but not of resisting arrest. He was sentenced to eight years and one year concurrently. B. Arizona Court of Appeals Johnson appealed. The Arizona Court of Appeals in State v Johnson reversed the conviction. The majority held that Johnson was lawfully detained at the time of the stop; however, the conversation between Trevizo and Johnson had turned into a consensual one that was unrelated to the traffic stop. Since Trevizo had no indication that criminal activity was occurring, she had no right pat Johnson down even if she believed he was armed and dangerous. The court referred to Terry v Ohio finding that a Terry stop allows officers to conduct a pat-down search in order to protect the officers, a consensual search does not as they stated in Ilono H: â€Å"Terry and its Supreme Court progeny addressed the propriety of a pat-down search exclusively in the context of a lawful investigatory stop. We do not read those cases to authorize a pat-down search as part of a mere consensual encountereven hen an officer may have grounds to believe the targets of the encounter are potentially armed and dangerous. † The court also drew upon the Supreme Court’s holding in Brendlin v California to determine if Johnson had been lawfully seized. In Brendlin v California, â€Å"a passenger is seized when the vehicle in which he or she is riding in is lawfully stopped by police. However, Johns on contended that even though he had been seized that was no longer the case because it had turned into a â€Å"consensual encounter before Trevizo patted him down. The court cited cases that stated a traffic stop may become consensual â€Å"when officers return the license or registration to a stopped driver, issue the driver a citation or warning, or tells the driver he or she is free to go† or â€Å"asks questions without further constraining the driver by an overbearing show of authority. † The court could not find any case law to establish that point with a passenger, but they reasoned that common sense suggests that at some point the passenger should be free to walk away. To decide when that point was, they applied a standard of reasonableness. The court elaborated on what was a consensual encounter. They considered a consensual encounter is if a person cooperates with the police voluntarily, answering non-coercive questioning. Additionally, if that person is free to leave at any time, he or she is not seized under the Fourth Amendment. Furthermore, the court stated that the encounter would not be consensual if the person did not feel free to leave. In Johnson’s case, the reason Officer Trevizo wished to speak with Johnson to learn more about his gang affiliation, not about the traffic stop and Trevizo testified that Johnson was free to leave at any time. The court stated that Trevizo could have ordered the passengers out of the car, but she did not. Trevizo had also stated that Johnson could have refused to get out of the car. Arizona case law agrees that a Terry stop can evolve into a consensual encounter as in State v Navarro. In Navarro’s case, a suspect in a shooting was taken into custody during a valid Terry stop, but the court determined it evolved into a consensual encounter because the suspect had not been â€Å"confront[ed] and surround[ed] at the initial detention† His handcuffs were removed and he voluntarily agreed to go (unfrisked and in the officer’s front seat) down town with the officer to talk about the shooting. In comparing the cases, the court believed Navarro was subjected to a greater level of coercion than Johnson. After examining every aspect of Johnson’s encounter with Trevizo, the court determined that Johnson’s getting out of the car to talk to Trevizo was consensual. They stated any â€Å"reasonable person in Johnson’s position and under these circumstances would have felt he could have remained in the vehicle. † They acknowledged that Trevizo had a reason to believe Johnson was armed and dangerous (clothing, scanner, hometown) but that fact alone did not give her the right to pat Johnson down in a consensual encounter. They determined that the trial court made an error when they chose not to suppress the evidence found. They reversed Johnson’s convictions and sentences and remanded the case for further proceedings. Judge Espinosa dissented. He found it unrealistic to conclude that just because Trevizo did not use coercion and Johnson volunteered to talk to her, made the encounter evolve into a consensual encounter. Consequently, Trevizo, fearing for her safety and the safety of others, could not legally conduct a pat-down search. The dissent noted that in Ilono H. the right to conduct a pat-down search should be dependent on the legality of the original Terry stop. Additionally, the dissent stated Arizona courts had many cases affirming the right of an officer to conduct a pat-down search when there is reasonable concern for his safety, as in State v Riley where a passenger was patted down during a traffic stop, in State v Valle where a passenger was patted down after he reached for his waistband when he was asked if he had a weapon, and in Adams v Williams that stated an â€Å"The purpose of this limited search is not to discover evidence of crime, but to allow the officer to pursue his investigation without fear of violence. The dissent continued that this was a legal traffic stop and since Officer Trevizo believed Johnson was armed and was a threat to her as well as the others; therefore she had the right to conduct a pat-down search of Johnson. The Arizona Supreme Court denied review. C. United States Supreme Court The State of Arizona appealed. The United States Supreme Court granted certiorari and reversed the judgment of the Arizona Cou rt of Appeals. They began by looking at Terry v Ohio. The police must have a reasonable belief that a person is engaged in criminal activity in order to stop him or her and a reasonable suspicion that the person temporarily detained is armed and dangerous in order to frisk him or her â€Å"stop and frisk. † â€Å"Because a limited search of outer clothing for weapons serves to protect both the officer and the public, a pat-down is constitutional. † With traffic stops being short in nature, similar to the detention authorized in Terry, the threat of danger to the police officer is heightened who is authorized to reduce the risk by taking â€Å"unquestioned command of the situation. To elaborate on Johnson being in a Terry situation, the court referred to Pennsylvania v Mimms which held that it does not violate the Fourth Amendment â€Å"because the governments legitimate and weighty interest in officer safety outweighs the de minimis additional   [**699]  intrusion of requiring a driver, already lawfully stopped, to e xit the vehicle. † Once outside the vehicle, Terry v Ohio states the driver can be then be patted down if there is suspicion he is armed and dangerous. The Mimms rule pertains to passengers as well as to drivers. They both have the same motivation to steer clear of being arrested for more significant crimes than traffic related offenses they have the same motivation to use violence to avoid such arrest. The safety of the officer outweighs the â€Å"minimal† intrusion of being asked to get out of the car and all the occupants of the vehicle have already been seized by nature of the car stop. The Supreme Court held that the Arizona court was in error in believing that Trevizo and Johnson’s encounter had evolved into a consensual encounter. Trevizo had not told Johnson he was free to leave nor did she inform him he did not have to cooperate with her and answer her questions. In other words, she did not give Johnson any reason to believe that her interrogation was consensual. Furthermore, a lawful roadside stop begins when the vehicle is pulled over and ends when police no longer need to control the situation at which time they inform the driver and passengers they are free to leave. A reasonable passenger would understand that as long as the car was seized, he was seized as well. The fact that Johnson was being interrogated about matters other than traffic would not change that understanding. Nothing had happened in the encounter before the frisk that would lead Johnson to believe he was free to leave without the officer’s permission. In a unanimous decision written by Justice Ruth Bader Ginsburg, the Supreme Court reversed the Arizona Court of Appeals. Arizona v Johnson was reversed and remanded. The Court held that Johnson’s encounter was not consensual and did not violate his Fourth Amendment rights. The court opined: valid traffic stops give officers the right to detain the driver and passengers for the duration of the stop; drivers and passengers may be removed from the vehicle with no additional justification; occupants may be asked for identification; if the officer reasonably believes the person may be armed and dangerous, he may conduct a pat-down search (even if he does not believe the person has been or is engaged in criminal activity); officers may inquire or converse about matters other than the traffic stop without it turning in to a consensual encounter as long as it does not â€Å"meaningfully prolong† the traffic stop. LEGAL BACKGROUND The Fourth Amendment to the Bill of Rights of the United States Constitution states: â€Å"The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized. † When the Fourth Amendment law was created, no one could have predicted the controversy that would follow in this era of mobility. The first time the Court had to address how the Fourth Amendment applies to searches of automobiles was in 1925, Carroll v United States. Two men were suspected of bootlegging. The police pulled them over and discovered illegal liquor in the trunk of their automobile. The defendants argued there was no warrant served allowing police to search their vehicle, therefore, the evidence should be suppressed. The Court disagreed, reasoning it was impractical to obtain a warrant due the mobility of an automobile. The Court noted difference between buildings and automobiles. Automobiles have the ability to leave the jurisdiction, taking the evidence with them, before a warrant could be obtained. The ruling in Carroll v United States enacted warrantless searches of vehicles are permissible if there was â€Å"probable cause† to believe contraband could be in the vehicle and belief that the vehicle could be moved before the officer could get a warrant. This became known as the â€Å"automobile exception. † The Court had created distinct guidelines for searching, with or without warrant. Now they needed to determine a clear definition of seizure. The benchmark case to define seizure is Terry v Ohio. The â€Å"stop and frisk† procedure was formally created in the case of Terry v Ohio. In October, 1963 a police officer observed two suspicious acting men standing on a street corner. One of the men would leave, walk down the street, look carefully in store windows, continue walking, turn around and look in the same windows again, and return to the corner to talk to the other man again. The second man did the same thing. In fact, they went back and forth six times. The police officer found this behavior highly bizarre and believed they were going to rob the store they had been observing. This led him to believe they were probably armed as well. He followed the men around the corner, where they were meeting with a third man. He approached them and asked their names. They mumbled incoherently. The officer grabbed the man in the middle (Terry) and patted down the outside of his clothing. He found a pistol in the left breast pocket of his jacket, but he could not retrieve it, so he asked them to go into the store. He removed Terry’s jacket and retrieved the pistol. The officer patted down the second man and found a pistol on him as well. The third man did not have a weapon on him. The men were taken into custody and charged with carrying a concealed weapon. Terry moved that the evidence should be suppressed as the evidence found was the result of an illegal search which violated his Fourth Amendment rights. The judge denied this motion stating that the officer’s experience granted enough cause to conduct an interrogation. The defense appealed to the Supreme Court. The main issue the Supreme Court had to deal with was whether or not Terry’s Fourth Amendment rights had been violated by unreasonable search and seizure. They held what came to be known as â€Å"stop and frisk,† which contained two parts. First, an officer may stop a person if he has â€Å"reasonable suspicion,† based on articulable facts that the person has committed or is in the process of committing a crime. The existence of reasonable suspicion depends on the overall view of the circumstances, including the† information known to the officer† and any â€Å"reasonable inferences to be drawn at the time of the stop. † This â€Å"investigative stop† does not require â€Å"probable cause† found the Fourth Amendment’s warrant clause. Probable cause in short is a reasonable belief that a person has committed a crime. † In determining what is probable cause . . . [w]e are concerned only with the question whether the affiant had reasonable grounds at the time of his affidavit . . . for the belief that the law was being violated on the premises to be searched; and if the apparent facts set out in the affidavit are such that a reasonably discreet and prudent man would be led to believe that there was a commission of the offense charged, there is probable cause justifying the issuance of a warrant. A person, within the meaning of the Fourth Amendment, is seized â€Å"whenever a police officer accosts an individual and restrains his freedom to walk away. † They also determined that patting down the outer clothing is a â€Å"search† under that Amendment. Second, to proceed from the â€Å"stop† to the â€Å"frisk† â€Å"a reasonably prudent officer must believe that he or others are in d anger, then he may make a reasonable search of the person that he believes is armed and dangerous, regardless if he is certain the person is armed or regardless of whether or not he has cause to arrest the person. They stated that police must have probable cause and when possible have a warrant to search. In on-the-spot cases, however, it is not practical to obtain a warrant. The officer in the Terry case did have reason to suspect the men were armed. Therefore, the Supreme Court affirmed Terry’s conviction. Elaborating on whether or not a person has been seized is found in United States v Mendenhall. The Court held that a person is seized â€Å"if, in view of all the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave. On February 10, 1976, Sylvia Mendenhall flew in to the Detroit Metropolitan Airport on a flight from Los Angeles. DEA agents observed her behavior as suspicious as if she were possibly carrying illegal drugs. The agents approached her and asked for identification and her airline ticket. Her airline ticket showed her name as â€Å"Annette Ford. † When questioned, she responded she just felt like using that name. Agent Anderson asked Mendenhall to go with him to the airport DEA office. She did. He asked her if she would allow him to search her handbag, clearing stating she did not have to if she did not want to. She handed him the handbag. A female officer arrived to search her person. Before proceeding, the officer asked Mendenhall if she consented to being searched which she responded she did. When heroin was found, she was arrested. The District Court denied Mendenhall’s motion to suppress, since she had consented to the search. The question to the Supreme Court was whether or not Mendenhall was â€Å"seized† when the DEA agents first approached her and requested her identification. The Court concluded that a person has been â€Å"seized† if considering all the circumstances, a reasonable person in that situation, would believe he did not have the freedom to leave. According to Mendenhall, without â€Å"reasonable suspicion† law enforcement may make consensual contact with a person. The person does don have to answer any questions. As long as he or she is free to walk away, the encounter does not violate any liberties granted in the Fourth Amendment. In Pennsylvania v Mimms, the Court held that an officer may order a driver out of the car, provided the traffic stop was lawful. Two Philadelphia policemen were patrolling when they noticed a car with an expired license. They pulled the car over to ticket the driver for driving with expired tags. One of the officers asked the driver, Mimms, to step out of the vehicle to provide his license and registration. Upon doing so, the officer noticed a â€Å"bulge under his jacket. † The officer frisked Mimms and found a loaded 38-caliber revolver. Mimms was charged and convicted with carrying a concealed deadly weapon and unlawfully carrying a firearm without a license in the trial court. Mimms moved to suppress the evidence. The Pennsylvania Supreme Court reversed the conviction after determining that the way the gun was discovered was a violation of the Fourth Amendment. They held that the officer’s request for Mimms to get out of the car was an unlawful seizure, protected against in the Fourth Amendment. â€Å"This was so because the officer could not point to â€Å"objective observable facts to support a suspicion that criminal activity was afoot or that the occupants of the vehicle posed a threat to police safety. † They continued that the officer should have never had the opportunity to notice the bulge; therefore, the search should have never taken place. The United States Supreme Court did not agree with the Supreme Court of Pennsylvania. The Court referred to Terry v Ohio as setting the standard of whether the facts available to the officer at the moment of the seizure or the search `warrant a man of reasonable caution in the belief that the action taken was appropriate there is little doubt that the officer was justified. The Court stated â€Å"the officers safety outweighs the additional intrusion of the driver to get out of the car which was â€Å"de minimis† since he was already detained by the traffic stop. The Court reversed the decision of the Pennsylvania Supreme Court. Maryland v Wilson extended the ruling of Pennsylvania v Mimms that an officer may order the driver out of the car, to passengers as well. A Maryland state trooper pulled over a speeding car on I-95 in Baltimore County. The officer noticed the passenger, Wilson, sweating and appearing to be very nervous. The officer ordered Wilson to get out of the car . When he did, a quantity of cocaine fell on the ground. Wilson was charged with possession of cocaine with intent to deliver. The Baltimore County Circuit Court granted the motion to suppress the evidence stating that ordering Wilson to get out of the car violated his Fourth Amendment rights, constituting an unreasonable seizure. The Maryland Court of Special Appeals affirmed. The United States Supreme Court had to decide whether or not the ruling in Mimms should be extended to include passengers. The Court held that the ruling should extend to the passengers as the â€Å"additional intrusion of exiting the vehicle as â€Å"de minimis† in comparison to the officer’s safety. The Court reasoned that a passenger would have the same motivation as a driver prevent additional crimes from being discovered during the stop, thereby, bringing the threat of violence from the passenger. The Arizona Court of Appeals relied on two Arizona cases they felt set precedent in this case, State v Navarro and In re Ilono H. In Navarro, a shooting had taken place. A few hours later, police stopped a car near the sc ene of the shooting. One of the passengers met the description of the shooter. He was handcuffed then questioned by the police. After conversing ith the police, they removed the handcuffs and asked Navarro to go with an officer to the police station. Navarro agreed to go with the officer. He was allowed to sit, unrestrained, in the front seat with the officer. Navarro was not told he was free to go, nor did he express a desire to leave. At the police station, Navarro was left in the interrogation room unattended, while the officer went to buy him a drink. Navarro agreed to have his testimony taped, his photograph taken, and to be fingerprinted. Navarro signed consent forms and admitted he was aware of his Miranda rights. This led to the conviction of Navarro. Navarro argued the evidence was illegally obtained. Navarro argued the legal detention had evolved into an illegal arrest when he went with the officer to the station. The court held that Navarro was neither in custody, nor under arrest when he agreed to go to the police station because â€Å"under the circumstances, a reasonable, innocent person would have felt free to decline the officer’s request to accompany him for questioning downtown. † In Ilono H. , two policemen approached five people in a park who were known for drug activity. They were dressed in red, a color associated with gang activity. After talking with the individuals, officers conducted pat down searches of the youth because gang members often carry weapons. The pat-down revealed Ilono had a 40-ounce beer on him. He was arrested for illegal possession of alcohol. In a search incident to the arrest, cocaine was found in Ilono’s pocket. Ilono was convicted. On appeal to the Arizona Court of Appeals, the court determined that a Terry frisk is only allowed when the officer believes the person is, or will be in the near future, engaged in criminal activity. The court found that this was a consensual encounter, which an officer may initiate but it may be terminated at any point if the person so desires. The court held that the officers did not have a right to make an investigatory stop because they had no reasonable belief Ilono had committed or was committing a crime; therefore, the pat-down search was illegal in this consensual encounter. The two most recent Supreme Court cases setting important precedent in Arizona v Johnson is Knowles v Iowa and Brendlin v California. In Knowles v Iowa, Knowles was pulled over for speeding. In lieu of an arrest, the officer issued Knowles a citation. After issuing the citation, the officer searched the vehicle. He found marijuana along with a pipe and charged him with possession. The issue at hand was, considering the officer had not made an arrest, did he have the authority to conduct the search consistent with the Fourth Amendment? The Court said â€Å"no. † The issue at hand was not the subject referred to by the Court in Arizona v Johnson. The issue brought up was that the Court in that case stated â€Å"that officers who conduct ‘routine traffic stop[s]’ many ‘perform a pat-down of a driver and any passengers upon reasonable suspicion that they may be armed and dangerous. In Brendlin, the Court held that a passenger is seized, according to the Fourth Amendment, just as the driver is seized. On November 27, 2001 in Sutter County, California, Bruce Brendlin was a passenger in a vehicle pulled over for an expired registration. The officer had inquired about the registration earlier in the day while th e car was parked. He had been informed that the renewal was being processed and the temporary registration was displayed in the back window was legal. While addressing the driver, Karen Simeroth, the officer recognized Brendlin as one of the â€Å"Brendlin Brothers. † The officer was certain he was a parole violator. After verifying that indeed Brendlin was a parole violator, the officer called for backup, ordered Brendlin out of the car at gunpoint, and arrested him and the driver. In the search incident to arrest, the officer found a syringe cap on Brendlin, syringes and marijuana on Simeroth, and methamphetamine along with equipment used to manufacture the drug in the vehicle. Brendlin argued to suppress the evidence stating that he was unlawfully seized by the traffic stop because the officer did not have probable cause to make the stop. Brendlin was denied by the trial court as they stated Brendlin was not seized until the officer ordered him out of the car and therefore did not have the right to challenge the legality of the stop. The California Court of Appeals reversed the decision made by the trial court. This court found that Brendlin was seized by the traffic stop; however, they determined the traffic stop was illegal. The United States Supreme Court had to decide whether or not a passenger is seized, according to the Fourth Amendment, in a traffic stop. The Court used the analogy of â€Å"whether a reasonable person in Brendlin’s position when the car was stopped would have believed himself free to ‘terminate the encounter’ between the police and himself. † The Court held â€Å"We think that in these circumstances any reasonable passenger would have understood the police officers to be exercising control to the point that no one in the car was free to depart without police permission. The Court explained that a traffic stop limits the actions of the passenger just as it does the driver and that the officer initiating the traffic stop â€Å"acts with an implicit claim of right based on fault of some sort, and a sensible person would not expect a police officer to allow people to come and go freely. † Therefore, the Court concluded that the Brendlin was seized by t he traffic stop â€Å"despite the fact that he was merely a passenger and not the target of the stop itself,† consequently he did have the right to challenge if his Fourth Amendment rights had been violated. COURT’S RATIONALE Before Johnson, according to Terry v Ohio, law enforcement was allowed to detain a person briefly if they believed he is was in the process of committing a crime or had committed a crime. Additionally, if the officer believed the detainee was armed and dangerous, the officer was allowed to conduct a pat-down of the detainee’s outer clothing to ensure he had no weapons on him. The Arizona Court of Appeals interpreted the Terry ruling did not apply to a person involved in a consensual encounter if the officer did not believe criminal activity was occurring, even if they believed he was armed and dangerous. The question this court asked was Johnson â€Å"seized† when he was frisked or had the encounter turned into a consensual conversation? They did refer to the United States Supreme Court’s ruling in Brendlin v California that a passenger is â€Å"seized† during a traffic stop, however, they noted that the Court did not designate when the seizure ended. They reasoned that â€Å"common sense† would allow that there must be a point in time where the passengers in the vehicle are free to leave and that â€Å"their fate is not entirely tied to that of the driver. They further compared this case to In re Ilono H. and reasoned that since Johnson was engaging in conversation unrelated to the traffic stop with Officer Trevizo, it had evolved into a separate consensual encounter. The court emphasized that Officer Trevizo believed Johnson was free to terminate the encounter at any time. The court also compared Johnson to Navarro. They determined Navarro had been subj ect to a greater level of coercion that Johnson had been and that the reasonable person in Johnson’s position would have believed he was free to stay in the vehicle. Furthermore, since Officer Trevizo had no suspicion that Johnson was involved in criminal activity, she had no right to frisk him, even if she believed he was armed and dangerous. Since the court had determined the encounter was consensual, they held that the evidence found should be suppressed. Judge Philip Espinosa dissented stating that the majority had placed police in greater danger. Judge Espinosa pointed out the language of Ilono H. stated a pat-down search should rely on the legality of the original stop and that in this case the original stop was legal. He also pointed out that Arizona courts had long acknowledged the right of an Arizona officer to conduct pat-down searches when he has a â€Å"reasonable concern for his safety. † Since Officer Trevizo did have a concern for her safety and the stop was legal, the dissent concluded the search was lawful and the evidence should not be suppressed. In a unanimous opinion written by Justice Ginsburg, the Court established that an officer may pat-down a passenger in a vehicle during the course of a traffic stop if the officer has an articulable suspicion to believe that person is armed and dangerous. ANALYSIS The Fourth Amendment is critical when it comes to protecting the rights of individuals from unreasonable seizures and searches. Johnson’s case required the Court to set a balance between these rights and the safety of law enforcement. The Supreme Court had already made exceptions to warrantless searches in Terry v Ohio. This Johnson decision expanded the Terry rule of †stop and frisk† to traffic stops. The Court reasoned that traffic stops indicate to a reasonable passenger that he is â€Å"seized† along with the passenger for the duration of the stop. Additionally, the Court noted that traffic stops are â€Å"fraught with danger to police officers. Unlike Terry, however, no longer do police need to believe the detainee is engaged in or has been engaged in criminal activity, they just need to â€Å"reasonably suspect† the person subjected to the pat-down is armed and dangerous. Conclusion The significance of this holding is that it increased officer safety by allowing them to pat-down a person, â€Å"seized† by a traffic stop (be it driver or passenger), provided the stop is legal and the officer has a reasonable suspicion that the person may be armed and dangerous. The Supreme Court has always faced the challenging job: balancing individual liberties with need for law and order. Fourth street advocates state this is another nail in the coffin of our Fourth Amendment rights. As with any expansion of police authority, there is always the chance of abuse of power. It is possible some police will abuse this power, using pat-downs during routine traffic stops in the hopes of turning a speeding ticket into something more interesting. Could Johnson eventually apply to any person the police may confront and/or detain? Pat-down searches are intrusive, humiliating, and embarrassing. Does this give law enforcement to pat-down anyone, anywhere under the disguise of officer safety? Will this lead to targeting and profiling? Will police be able to ignore the plastic baggie found while searching for weapons? Furthermore, will this prevent individuals from voluntarily interacting with police, knowing they may be frisked? Time will tell. On the other hand, officer safety is paramount. Not allowing officers to search occupants, within the context of a traffic stop, for weapons when there may be a threat to their safety would cripple their ability to perform their job effectively. Johnson was fresh out of prison, wearing gang colors, and carrying a police scanner. Even to an untrained civilian, it would seem common sense to frisk Johnson. In this case, highly trained Officer Trevizo took the chance that the evidence may have been suppressed, but that chance may have saved her life as well as the other officers. If Johnson had been allowed to leave the scene with the weapon, other lives were in jeopardy. The fact that the everyday law abiding citizen may face an intrusive pat-down seems a small price to pay for protecting the law enforcement that are sworn to protect and serve. The bottom line is the Supreme Court unanimously decided that officer safety comes first. It is what it is. 1 ]. State v Johnson, 170 3d 667, 668,674 (Ariz. Ct. App, 2007). [ 2 ]. Id. [ 3 ]. Id. at 669. [ 4 ]. Id. [ 5 ]. Id. at 668. [ 6 ]. Id. at 671. [ 7 ]. Id. [ 8 ]. Bill of Rights Amendment IV, The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by oath or affirmation, and particul arly describing the place to be searched, and the persons or things to be seized. [ 9 ]. Terry v Ohio, 392 U. S. 1, 88 S. Ct. 1868, 20 L. Ed. 2d 889 (1968). The court held that an officer is justified in conducting a limited search of persons whom he suspects may be armed and dangerous in order to discover any weapons which might be used to assault him or others nearby, even if they have no suspicion that the passenger has committed any crime. [ 10 ]. Id. at 667. [ 11 ]. Johnson, 170 P. 3d at 669. [ 12 ]. Id. [ 13 ]. Johnson, 170 P. 3d at 667 (quoting Terry v Ohio, 392 U. S. 1, 30 (1968)). [ 14 ]. Arizona v Johnson, 128 S. Ct. 339, 172 L. Ed. 2d 14 (2008). [ 15 ]. Id. [ 16 ]. Id. [ 17 ]. Id. [ 18 ]. Johnson, 170 P. 3d at 668. [ 19 ]. Id. [ 20 ]. Id. [ 21 ]. Joint Appendix at 29, Johnson, 128 S. Ct. 2961 (No. 07-1122). [ 22 ]. Joint Appendix at 14. [ 23 ]. Id. at 15. [ 24 ]. Id. at 31. [ 25 ]. Id. at 42-43. [ 26 ]. Id. [ 27 ]. Id. at 12. [ 28 ]. Id. at 17. [ 29 ]. Id. at 16. [ 30 ]. Johnson, 170 P. 3d at 667, 669. [ 31 ]. Id. [ 32 ]. Joint Appendix at 19, Johnson, 128 S. Ct. 2961 (No. 07-1122). [ 33 ]. Id. [ 34 ]. Johnson, 170 P. 3d at 669. [ 35 ]. Joint Appendix at 10, Johnson, 128 S. Ct. 2961 (No. 07-1122). [ 36 ]. Id. at 29. [ 37 ]. Id. at 20. [ 38 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 669-670. [ 39 ]. Id. [ 40 ]. Id. at 669-670. [ 41 ]. Id. [ 42 ]. Id. at 668. [ 43 ]. Id. [ 44 ]. Id. at 671. [ 45 ]. Id. at 673. 46 ]. Id. [ 47 ]. Terry v Ohio, 392 U. S. 1 (1968). [ 48 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 671. [ 49 ]. Ilono H. , 210 Ariz. 473, P2, 113 P. 3d at 697. [ 50 ]. Id. at P12. [ 51 ]. Brendlin v California, U. S. 127 S. Ct. 2400, 2410, 168 L. Ed. 2d 132 (2007). [ 52 ]. Id. [ 53 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 671. [ 54 ]. United States v Hernandez, 93 F. 3d 1493, 1498 (10th Cir. 1996). [ 55 ]. United States v Werking, 915 F. 2d 1404, 1408-09 (10th Cir. 1990). [ 56 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 671. [ 57 ]. Id. [ 58 ]. Hernandez, 93 F. 3d at 1498. [ 59 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 672. [ 60 ]. Id. 61 ]. Id. [ 62 ]. State v Navarro, 201 Ariz. 272, 34 P. 3d 971 (App. 2001). [ 63 ]. Id. [ 64 ]. Id. [ 65 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 672. [ 66 ]. Id. [ 67 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 672. [ 68 ]. Id. [ 69 ]. Ilono H. , 210 Ariz. 473, P2, 113 P. 3d at 697. This was a consensual encounter, not a traffic stop between a juvenile and an officer. [ 70 ]. State v Riley, 196 Ariz. 40, P16, 992 P. 2d 1135, 1140 (App. 1999). [ 71 ]. State v Valle, 196 Ariz. 324, P9, 996 P. 2d 125, 128 (App. 2000). [ 72 ]. Adams v Williams, 407 U. S. 143, 146, 92 S. Ct. 1921, 1923, 32 L. Ed. 2d 612 (1972). [ 73 ]. Johnson, 217 Ariz. 0, 170 P. 3d at 672. [ 74 ]. State v Johnson, 2007 Ariz. LEXIS 154 (Ariz. Nov. 29, 2007). [ 75 ] . Arizona v Johnson, 128 S. Ct. 2961, 171 L. Ed. 2d 884, 2008 U. S. LEXIS 5208, 76 U. S. L. W. 3673 (U. S. 2008). [ 76 ]. Arizona v Johnson, 129 S. Ct. 781, 172 L. Ed. 2d 694, 2009 U. S. LEXIS 868, 21 Fla. L. Weekly Fed. S 620 (U. s. 2009). [ 77 ]. Terry v Ohio, 392 U. S. 1 (1968). [ 78 ]. Id. at 24. [ 79 ]. Id. at 23-24, 27, 30-31. [ 80 ]. Berkemer v McCarty, 468, U. S. 420, 439, n. 29, 104 S. Ct. 3138, 82 L. Ed 2d 317 [ 81 ]. Michigan v Long, 463 U. S. 1032, 1047, 103 S. Ct. 3469, 77 L. Ed 2d 1204. [ 82 ]. Maryland v Wilson, 519 U. S. 408, 414, 117 S. Ct. 882, 137 L. Ed 2d 41. [ 83 ]. Pennsylvania v Mimms, 434 U. S. 106, 98 S. Ct. 330, 54 L. Ed. 2d, 331. [ 84 ]. Id. at 111. [ 85 ]. Id. at 110-111. [ 86 ]. Terry v Ohio, 434 U. S. , at 112. [ 87 ]. Pennsylvania v Mimms, 434 U. S. 106 [ 88 ]. Johnson 129 S. Ct. 781, at 698. [ 89 ]. Id. [ 90 ]. Brendlin, 551 U. S. , at 257. [ 91 ]. Johnson 129 S. Ct. 781, at 698. [ 92 ]. U. S. Constitution – Amendment 4. [ 93 ]. Carroll v United States, 267 U. S. 132 (1925). [ 94 ]. Id. at 160. [ 95 ]. Id. at 132. [ 96 ]. Id. at 158. [ 97 ]. Id. at 150-53. [ 98 ]. Id. at 153. [ 99 ]. Id. [ 100 ]. Terry, 392 U. S. at 16. 101 ]. Id. at 4-7. [ 102 ]. Terry, 392 U. S. at 2. [ 103 ]. Id. at 16-20. [ 104 ]. Id. at 24. [ 105 ]. U. S. Constitution – Fourth Amendment. [ 106 ]. lectlaw. com. [ 107 ]. Dumbra v. United States, 268 U. S. 435, 439 , 441 (1925). [ 108 ]. Id. at 16. [ 109 ]. Id. [ 110 ]. Id. at 20-27. [ 111 ]. Id. at 20. [ 112 ]. Id. [ 113 ]. United States v Mendenh all, 446 U. S. 544, 545 (1980). [ 114 ]. Id. at 554. [ 115 ]. Id. at 547-49. [ 116 ]. Id. [ 117 ]. Id. at 555. [ 118 ]. Id. [ 119 ]. Id. at 544. [ 120 ]. Id. at 554. [ 121 ]. Pennsylvania v Mimms, 434 U. S. at 106, 98 S. Ct. 330, 54 L. Ed. 2d 331 (1977). [ 122 ]. Id. [ 123 ]. Id. [ 124 ]. Id. [ 125 ]. Id. [ 126 ]. Id. [ 127 ]. Id. [ 128 ]. Id. [ 129 ]. Id at 106, 108. [ 130 ]. Id. [ 131 ]. Id. [ 132 ]. Id. [ 133 ]. Id. [ 134 ]. Id. at 106, 112 (quoting Terry, 392 U. S. , at 21-22). [ 135 ]. Mimms 434, U. S. 106, at 112. [ 136 ]. Id. at 111. [ 137 ]. Id. [ 138 ]. Maryland v Wilson, 519 U. S. 408 (1997). [ 139 ]. Id. [ 140 ]. Id. [ 141 ]. Id. [ 142 ]. Id. [ 143 ]. Id. [ 144 ]. Maryland v Wilson, 519 U. S. , 408 (1997). [ 145 ]. Id. at 414. [ 146 ]. State v Navarro, 34 P. 3d 971 (Ariz. Ct. App. 2001). [ 147 ]. In re Ilono H. , 113 P. 3d 696 (Ariz Ct. App. 2005). [ 148 ]. Navarro, 34 P. d at 971, 973. [ 149 ]. Id. [ 150 ]. Id. [ 151 ]. Id. [ 152 ]. Id. [ 153 ]. Id. [ 154 ]. Id. at 973-974. [ 155 ]. Id. at 972. [ 156 ]. Id. at 974. [ 157 ]. Id. at 974-975. [ 158 ]. Id. [ 159 ]. Id. [ 160 ]. Ilono H. , 113 P. 3d at 697. [ 161 ]. Id. [ 162 ]. Id. [ 163 ]. Id. [ 164 ]. Id. [ 165 ]. Id. [ 166 ]. Id. [ 167 ]. Id. at 700-701. [ 168 ]. Knowles v Iowa, 52 5 U. S. 113, 117–18 (1998). [ 169 ]. Brendlin v. California, 127 S. Ct. 2400, 2410 (2007). [ 170 ]. Knowles v Iowa, 525 U. S. at 114. [ 171 ]. Idat 113. [ 172 ]. Id. at 118. [ 173 ]. Brendlin, 127 S. Ct. at 2403. [ 174 ]. Id. at 2404. [ 175 ]. Id. [ 176 ]. Id. 177 ]. Id. [ 178 ]. Id. [ 179 ]. Id. [ 180 ]. Id. [ 181 ]. Id. at 2404-05. [ 182 ]. Id. at 2405-06 (quoting Florida v Bostick, 501 U. S. 429, 435-36 (1991)). [ 183 ]. Id. at 2406-07. [ 184 ]. Id. at 2407. [ 185 ]. Id. at 2410. [ 186 ]. Terry, 392 U. S. at 2. [ 187 ]. Johnson, 170 P. 3d at 671. [ 188 ]. Brendlin, 551 U. S. at 262. [ 189 ]. Johnson, 170 P. 3d at 671. [ 190 ]. Id. [ 191 ]. Id. at 672. [ 192 ]. Id. [ 193 ]. Id. at 673. [ 194 ]. Id. [ 195 ]. Id. at 674. [ 196 ]. Id. at 674 (Espinosa, J. , dissenting). [ 197 ]. Id. [ 198 ]. Id. (quoting State v Riley, 992 P. 2d 1135, 1140 (Ariz. Ct. App. 1999)). [ 199 ]. Id.

Marduk the Mesopotamian Creation God

Marduk the Mesopotamian Creation God Marduk- also know as Bel or Sanda- is a Babylonian creator god who defeats an earlier generation of water gods to form and populate the earth, according to the earliest written creation epic, the Enuma Elish, which is presumed to have heavily influenced the writing of Genesis I in the Old Testament. Marduks acts of creation mark the start of time and are commemorated annually as the new year. Following Marduks victory over Tiamat, the gods assemble, celebrate, and honor Marduk by conferring 50 name attributes on him. Marduk Gains Power Over the Gods Marduk became prominent in Babylonia, thanks historically to Hammurabi. Nebuchadnezzar I was the first to officially acknowledge that Marduk was head of the pantheon, in the 12th century B.C. Mythologically, before Marduk went into battle against the salt-water god Tiamat, he obtained power over the other gods, with their volition. Jastrow says, despite his primacy, Marduk always acknowledges Eas priority. The Many Names of Marduk Marduk, having received 50 names, received epithets of other gods. Thus, Marduk may have been associated with Shamash as a  sun god and with Adad as a storm god. According to A Dictionary of World Mythology, there was a henotheistic tendency in the Assyro-Babylonian pantheon that led to the incorporation of various other gods within Marduk. Zagmuk, the spring equinox new years festival marked the resurrection of Marduk. It was also the day the Babylonian kings powers were renewed. Sources Studies in Marduk, by W. G. Lambert. Bulletin of the School of Oriental and African Studies, University of London (1984).Sennacherib and Tarsus, by Stephanie Dalley. Anatolian Studies (1999).The civilization of Babylonia and Assyria, by Morris Jastrow (1915)

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