Seat Belt Laws free essay sample

However, the driver likely would have lived if he would have been wearing his seat belt. With scenes such as this, it is evident that seat belt laws should be in effect as well as enforced. Vehicle fatalities have a big impact on mortality rates and insurance premiums; therefore, enforcing seat belt laws can have a positive effect on society. Automobiles have progressed through the years, and have become faster, yet the faster you go the greater the impact when an accident occurs. Federal and State agencies have developed speed limits and other guidelines, which when enforced, help keep passengers safe. Even though these laws are in place, accidents still occur; however, when the proper precautions are taken, risks can be minimized. As technology progresses so will vehicles; therefore, safety will continue to be a major concern. It is up to the motorists to decide to wear a seat belt, yet law enforcement officers are the ones who are there to enforce seat belt laws. We will write a custom essay sample on Seat Belt Laws or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Seat belts are installed into every car and truck, but should we have to wear them? Every state has a different law about who does and does not have to wear them, but in the state of Indiana if you are in a car that is equipped with seat belts and anyone above the age of 14 you are required to wear a seat belt. Also, children must use the correct car seat for their weight until they reach 135 centimeters tall or their 12th birthday, whichever comes first. There are several other reasons that you do not need to wear a seat belt such as if you are a driver who is reversing, or supervising a learner driver who is reversing, in a vehicle used for police, fire, and rescue services, a assenger in a trade vehicle and you are investigating a fault, driving a good vehicle on deliveries that is traveling no more than 50 meters between stops, or a licensed taxi driver who is ‘playing for hire’ or carrying passengers (Using, 1). If there is a reason that you cannot wear a seat belt due to medical reasons, your doctor must issue you a ‘Certificate of Exemption for Compulsory Seat Belt Wearing’. You must keep this in your car at all times and handy if a police officer pulls you over. There are strict seat belt laws world-wide but, according to statistics, they are hardly followed. Approximately 50% of lives will be saved in an accident if people wear seat belts. Seat belt safety statistics show that mostly the younger population between the age groups 16-35 is hardly found wearing seat belts. Seat belt facts also prove that 70% of the people wearing a seat belt have prevented injuries even on meeting with an accident. It is found that nearly 10,000 lives can be saved every year only by wearing a seat belt (Pandit 1). According to studies cited by the Independence Institute, â€Å"When subjects who normally did not wear seat belts were asked to do so, they were observed to drive faster, followed more closely, and braked later. In other words, people who are naturally cautious voluntarily choose to wear seat belts, and voluntarily drive safely. When reckless people are forced to wear seat belts, they â€Å"compensate† for the increased safety by driving more recklessly. Furthermore, no jurisdiction that has passed a seat belt law has shown evidence of a reduction in road accident death. (Veksler 1) Seat belts were designed to save peoples’ lives, this only works if they are worn correctly or even at all. Many people do not wear their seatbelts because they do not believe in their efficacy, because they have heard that wearing seat belts might actually cost them their lives in certain types of accidents (Mikkelson 1). The constitution allows everyone to have the freedom rights, but ho w fair is it for the government to dictate what we can and can’t do when it comes to wearing a seat belt. The U. S. National Highway Safety Bureau first required automobile manufacturers to install lap belts for all seats and shoulder belts for front seats in 1968; however, most Americans did not regularly use safety belts until 1984, when the first state laws were passed mandating seat belt use. As of today, there are 48 states in which it is illegal for a driver or passenger to travel without a seat belt (the exceptions are Maine and New Hampshire). Of those 48 states, 10 have primary enforcement, meaning that police can stop and ticket a motorist simply for not wearing a seat belt. The other 38 states with seat belt laws have secondary enforcement, meaning that police can only ticket people not wearing seat belts if they pull the car over for some other reason. If not all states have to wear them, then why make it a law? Many fatalities that are related to vehicle accidents can be avoided if the occupants wear their seat belts. Some say seat belts can be the cause of deaths. Although this may be true, it is proven that in most cases seat belts are far more likely to save a life than kill the occupants of a vehicle. As written in the World Almanac and Book of Facts, â€Å"In 2006, safety belts and child restraints saved an estimated 15,808 lives† (â€Å"U. S. Motor† 1746). Seat belts do save lives; therefore, the laws that promote their use should be enforced. When police have the authority to stop a motorist solely for not wearing a seat belt, which is called primary law, motorists have more of a reason to wear their seat belts. Furthermore, vehicle insurance premiums could decrease if seat belt laws are followed. It makes sense that insurance companies charge more because accidents are escalated due to negligence of the driver by not wearing his seat belt. This point is reiterated in the Hudson Valley Business Journal: â€Å"The safer all drivers are, the fewer injuries there will be, which affects everyone’s insurance premiums† (â€Å"Seat Belts† 18). If drivers would just take that extra step before driving, and buckle their seat belt, society as a whole might notice a decrease in insurance premiums in the future. Insurance providers may not notice the change right away, but in the long run they would have to notice that fatalities are decreasing. Though law enforcement programs such as Click-It-Or-Ticket help raise the use of seat belts, they do so by threatening drivers with fines for not buckling up. Laurie F. Beck, from the National Center for Injury Prevention and Control wrote, â€Å"Although rates of safety belt use in the United States have increased substantially since the first state law was passed in 1984, many motor vehicle occupants continue to travel unrestrained† (1619). Sometimes threats stop short of reaching the amount of people intended. Perhaps if programs were developed to reward drivers who get pulled over and are wearing their seat belt, then we would see a stronger increase in seat belt use. Patrol officers could be required to note when a driver was properly restrained; that information could be provided to insurance companies; those companies would know which motorists were driving safely, and could reward them with discounted premiums. We as American citizens should have the choice in if we wear them or not. There are many reasons that many people do not wear them, but here are just a few. Some people feel if they are going a speed of less than 40 mph, then they do not need to wear them; however the National Transportation Safety Board (NTSB) states that 80 percent of all crashes come at speeds of less than 40 mph and 75 percent of those are within 25 miles of home (Silverman 1). Another reason people do not wear their seat belts are because they believe they are uncomfortable. They believe the combination of the lap and shoulder belt is uncomfortable, so they either do not wear it or they put the shoulder belt under their arm. In doing this, it can cause internal injuries if they were ever in an accident. A different reason that some people do not wear their seat belt is because they feel their independence is being taken from them for being told what to do in their car. They feel that their car is their fortress and they should not be told what to do in it, especially by the government. Some people feel that if they are thrown from a car they have a better chance of being saved then staying in the car with the accident. This is not true according to the Kansas Traffic Safety Resource Office; individuals who get thrown from their cars are more likely to get killed than those wearing seat belts (Silverman 2). Finally, many drivers say they want to increase their chances of surviving a car fire or a submerged car. They feel that if they are buckled is it not only going to take longer to get out of the car, but if they are dazed or not alert, it is going to hinder their chances of getting out of the car alive. Less than ? of 1 percent of all accidents involve car fires or submersion. If some type of reward program happened to be in place, the scenario earlier could have ended differently. Maybe the driver would have suffered some type of injury, yet the seat belt could have stopped him from hitting his head on the windshield. Although seat belt laws promote the reduction of vehicle related fatalities and help decrease the cost of insurance premiums, other programs such as a reward program could further reach motorists. The more benefits motorists see about wearing seat belts the greater the chance they will choose to wear them. References: Beck, Laurie F. , et al. Associations Between Sociodemographics and Safety Belt Use in States With and Without Primary Enforcement Laws. American Journal of Public Health 97. 9 (2007): 1619-1624. Biomedical Reference Collection: Basic. EBSCO. Web. 29 Sept. 2011. Mikkelson, Barbara amp; David. â€Å"Seat Belted. † Snopes. com. Urban Legends, 4 July 2011: 1-2. Web. 22 Sept. 2011. http://www. snopes. com/autos/accident/seatbelt. asp Pandit, Madhura. â€Å"Reasons to Wear your Seat Belt. † Buzzle. com. Buzzle. com, 2000-2011: 2. Web. 28 Sept. 2011. http://www. buzzle. com/articles/reasons-to-wear-your-seat-belt. htmlSeat Belts, Car Seats Save Lives and Affect Insurance Premiums. Hudson Valley Business Journal 6. 34 (1995): 18. Regional Business News. EBSCO. Web. 29 Sept. 2011. Silverman, Steve. â€Å"Why People Don’t Wear Seat Belts. † eHow. Demand Media Inc. 1999-2011: 4. Web. 28 Sept 2011. http://www. ehow. com/about_5456493_people-dont-wear-seat-belts. html U. S. Motor Vehicle Accidents, 2006. World Almanac amp; Book of Facts (2009): 1746. Academic Search Premier. EBSCO. Web. 29 Sept. 2011. â€Å"Using a seat belt. † Direct. gov. Crown, 29 Sept. 2010: 3. Web, 28 Sept 2011. http://www. direct. gov. uk/en/Tr avelAndTransport/Roadsafetyadvice/DG_4022064 Veksler, David. â€Å"The One Minute Case Against Mandatory Seatbelt Laws. † One Minute Cases. Politics, 21 May 2007: 1-3. Web. 22 Sept. 2011. http://oneminute. rationalmind. net/mandatory-seatbelt-laws/

Learn How to Make Invisible Ink With Cornstarch

Learn How to Make Invisible Ink With Cornstarch Do you want to write a secret message? Try making invisible ink! The writing for this invisible ink technique is done using cornstarch. An iodine solution is used to reveal the writing. What You Need CornstarchIodineWaterToothpick or Cotton SwabHot Plate or StovePaper Make the Invisible Ink Essentially you want to make a thin cornstarch gravy. You will write using the gravy, allow the writing to dry, then reveal the message using an iodine solution.If you dont have a pre-made iodine solution, you can make some by adding a teaspoon of iodine to about 10 teaspoons of water. Set the iodine aside for later.Mix about 2 Tbsp cornstarch with 4 tsp water in a pan. Heat, while stirring, until smooth. You can boil the mixture to make a gravy; just be careful not to burn it!Remove the cornstarch gravy from the heat. Dip a toothpick, small paintbrush, or cotton swab into it and use it to write your message on paper.Let the paper air-dry.Brush a small sponge, swab, or paintbrush dipped in the iodine solution over the paper to reveal the hidden message. The message should appear purple. Tips You can use simple cornstarch in water to write the message, but the writing wont be as invisible as it is using cornstarch gravy.If the heat source is a problem, try using very hot tap water to hydrate the cornstarch rather than using a stove or hot plate.Iodine binds to the starch molecules to reveal the message.Try using other starches instead of cornstarch, such as diluted mashed potatoes or  mashed cooked rice with water.Cornstarch slightly alters the surface of the paper, so another way to reveal the secret message is to heat the paper with the message over a flame or with an iron. The message will darken before the rest of the paper, revealing the secret.

The Worlds First Artificial Satellite

The World's First Artificial Satellite On October 4, 1957, the Soviet Union stunned everyone by launching the worlds first artificial satellite,  Sputnik 1.  It was an event that galvanized the world and spurred the fledgling U.S. space effort into high gear. No one who was alive at that time can forget the electricity of the moment when humans first lofted a satellite into orbit. The fact that it was the U.S.S.R. beating the U.S. to orbit was even more shocking, especially to Americans. Sputnik by the Numbers The name Sputnik comes from a Russian word for traveling companion of the world. It was a smallish metal ball that weighed just 83 kg (184 lbs.) and was lofted into space by an R7 rocket. The tiny satellite carried a thermometer and two radio transmitters and was part of the Soviet Unions work during the International Geophysical Year. While its goal was partly scientific, the launch and deployment into orbit had heavy political significance and signaled the countrys ambitions in space.   Sputnik 1 Assembly. Asif A. Siddiq / NASA Sputnik circled Earth once every 96.2 minutes and transmitted atmospheric information by radio for 21 days. Just 57 days after its launch, Sputnik was destroyed while reentering the atmosphere but signaled a whole new era of exploration. Almost immediately, other satellites were built and an era of satellite exploration began at the same time that the U.S. and U.S.S.R. began making plans to send people to space. Setting the Stage for the Space Age To understand why Sputnik 1 was such a surprise, its important to look at what was going on at the time, to take a good look back to the late 1950s. At that time, the world was poised on the brink of space exploration. The development of rocket technology was actually aimed at space but was diverted to wartime use. After World War II, the United States and the  Soviet Union (now Russia) were rivals both militarily and culturally. Scientists on both sides were developing bigger, more powerful rockets to take payloads to space. Both countries wanted to be the first to explore the high frontier. It was just a matter of time before it happened. What the world needed was a scientific and technical push to get there. Space Science Enters the Main Stage Scientifically, the year 1957 was established as the International Geophysical Year (IGY), a time when scientists would use new methods to study Earth, its atmosphere, and magnetic field. It was timed to coincide with the 11-year sunspot cycle. Astronomers were also planning to observe the Sun and its influence on Earth throughout that time, particularly on communications and in the newly emerging discipline of solar physics.   The U.S. National Academy of Sciences created a committee to oversee U.S. IGY projects. These included investigations of what we now call space weather caused by solar activity, such as auroral storms and other aspects of the upper ionosphere. They also wanted to study other phenomena such as airglows, cosmic rays, geomagnetism, glaciology, gravity, make determinations of longitude and latitude and planned to conduct tests in meteorology, oceanography, and seismology. As part of this, the U.S. had a plan to launch the first artificial satellite, and its planners were hoping to be the first ones to send something into space. Such satellites were not a new idea.  In October 1954, scientists called for the first ones to be launched during IGY to map Earths surface. The White House agreed that this might be a good idea, and announced plans to launch an Earth-orbiting satellite to take measurements of the upper atmosphere and the effects of the solar wind. Officials solicited proposals from various government research agencies to undertake the development of such a mission. In September 1955, the Naval Research Laboratorys Vanguard proposal was chosen. Teams began building and testing missiles. However, before the United States could launch its first rockets to space, the Soviet Union beat everyone to the punch. The U.S. Responds The beeping signal from Sputnik not only reminded everyone of Russian superiority, but it also galvanized public opinion in the U.S. The political backlash over the Soviets beating Americans to space led to some interesting and long-reaching results. The U.S. Defense Department immediately began providing funding for another U.S. satellite project. At the same time, Wernher von Braun and his Army Redstone Arsenal team began work on the Explorer project, which was launched to orbit on January 31, 1958. Very quickly, the Moon was announced as a major target, which set in motion planning for a series of missions.   Dr. Wernher von Braun was part of the U.S. space effort at the time of the Sputnik launch, working to build rockets to take U.S. satellites and astronauts such as L. Gordon Cooper (right) to space.   NASA The Sputnik launch also led directly to the creation of National Aeronautics and Space Administration (NASA) to carry on a civilian space effort (rather than militarizing the activity). In July 1958, Congress passed the National Aeronautics and Space Act (commonly called the Space Act). That act created NASA on October 1, 1958, uniting the National Advisory Committee for Aeronautics (NACA) and other government agencies to form a new agency aimed at putting the U.S. squarely in the space business.   Models of  Sputnik commemorating this daring mission are scattered around the world. One hangs at the United Nations building in New York City, while another is in a place of honor at the Air and Space Museum in Washington, D.C. The World Museum in Liverpool, England has one, as does the Kansas Cosmosphere and Space Center in Hutchinson and the California Science Center in L.A.. The Russian Embassy in Madrid, Spain, also has a Sputnik model. They remain gleaming reminders of the earliest days of the Space Age at a time when science and technology were coming together to create a new era of exploration.   Edited and revised by Carolyn Collins Petersen.

Workshop 5 Essay Example | Topics and Well Written Essays - 500 words

Workshop 5 - Essay Example Part of the restructuring that happened in the auto industry is the changing of the labour regulations and practices to enable the auto industry cope and compete with the new economic environment. The major labor regulation change in the auto industry was the Labour Conract Law which stipulate open term contract. It meant that employer-employee relationship mist be written in a contract the failure to do so would mean the indefinite employment which employers cannot just terminate. The law also stipulated labour dispatching which requires the labour contract between the service provider and the employee will be fixed for more than 2 years and the employee will be remunerated monthly even if there is no work to be done. In the labour practice, globalisation has provided employers greater latitude to easily reduce its workforce depending on the demand of the market. Where before workers had job security, it is now underpinned by a one year contract as stated by the new Labour Contract Law. 2. What is the role of unions in China? How does China’s Political System impact this? Should unions be founded on supporting the workers in China or the Organisations/Government? Justify your answer. The role of unions in China is to motivate employees to achieve the objective of the enterprise rather than represent and perform functions that are typically associated to HR in capitalist countries. This means that unions are still subordinated to the Communist Party, an arrangement compounded by the This set up of unions being subordinated to the Communist Party defeats the very purpose of union of why they were set up. Even in the former Soviet Union, workers were represented by the union whom in turn are represented in the Communist Party. With the current set up in China, workers are virtually powerless and voiceless to air their grievance or plight or to even make suggestion to make their conditions

What are the moral responsibilities of managers Essay

What are the moral responsibilities of managers - Essay Example This research will begin with the statement that the moral responsibilities of managers’ whether in the private sector or public sector should be characterized with a manager perpetuating the law, fulfilling the legitimate duties of their position, observing the relevant codes of ethics and otherwise abiding by generally held moral principles such as honesty and not knowingly doing harm. A manager will be held liable for an immoral act if he had knowledge of it and had the ability to prevent it from happening. Moral managers subscribe to ethical leadership which requires the manager to be a moral person as well as moral managers. A   moral manager should possess traits such as honesty, integrity and trustworthy. This involves respecting the soundness of organization and adherence to the codes set by the organization. This allows the managers to do the right thing, reason well and uphold the highest level of justice even in the most difficult circumstances. A   moral manage r learns from multiple social situations which allow him to have a vast knowledge of conflict resolution skills without harming any party in case a dispute arises. The personal standards developed by a moral manager enables him to be fair and considerate by making clear justifications in his mind. For example, a moral manager will solve a   dispute between two staff members by being fair and sticking to their values and objectivity without compromising on the basis of relations or closeness to either party.

Analysis of the Free Movement of Goods and Services Policy

Analysis of the Free Movement of Goods and Services Policy The Court of Justice of the European Union (CJEU) has developed an extensive body of case law on free movement in relation to persons, goods, services and establishment. Over the years, the Courts approach to free movement as evolved and adapted to the modern European Union (EU) today. Through comparison of the case law it will be clear that how the Court deals with free movement is similar in all the areas of persons, goods, services and establishment. In the beginning the CJEU would only strike down legislation which was discriminatory to nationals from other Member States. It then began to strike down rules that were non-discriminatory and more recently rules that act as a barrier or hindrance to market access. Analysing these areas of the Courts jurisprudence, it will be evident that the Courts early approach was a more literal interpretation of the treaties towards a more teleological approach that expanded the Courts powers but perhaps this is ultimately needed if the CJEU was to every achieve the Internal Market.[1] As already mentioned in the early case law the CJEU would strike down national legislation due to them being discriminatory on the basis of nationality.[2] This approach was clearly based on the treaty articles that prohibited this.[3] Rules where initially struck down because they were obviously discriminatory such as in Commission v French Republic[4]in relation to workers and Humblot[5] with regards to goods. This approach was echoed across the freedoms.[6] It was clear though, that from the jurisprudence across these areas striking down barriers that were obliviously discriminatory would not be enough as often there was national legislation that was indirectly discriminating against nationals.[7] Therefore indirect discrimination was present from the beginning to tackle the double burden that was often placed by Member States on free movement. This move by the Court is comparable across the freedoms such as Uglioa[8] in relation to workers. Critically though the Court might have created indirect discrimination criteria to stop dual burden but this has raised problems from the Court as not all indirectly discriminatory rules create such a burden.[9] Even with these potential issues the practice was echoed across the jurisprudence of goods, services and establishment.[10] The case of Dassonville[11] further increased the Courts ability to strike down national legislation for being discriminatory measures having equivalent effect in relation to goods.[12] This is interesting as the expansion of the Court powers arguably goes beyond a literal interpretation of the treaty articles. It had a big effect not only on the subsequent cases regarding goods but also free movement of persons, services and establishment.[13] The CJEUs application of a wider definition in Dassonville[14] is comparable to the other freedoms particularly services and establishment.[15] The broader scope the Court has given themselves across the freedoms is a move towards a more cohesive internal market. On the other hand though, the Court was always very clear though from the beginning that free movement of persons, goods and services are not absolute.[16] This is evident from the Treaty articles in so far as certain discriminatory restrictions can be justified.[17] This indication by the Court might initially seem to be just following the Treaties but ultimately, they expanded the remit of these justifications in relation to indirectly discriminatory restrictions in all of the areas through case law.[18] The early jurisprudence shows that the Court was not willing to strike down non-discriminatory legislation such as in Chemical Farmaceutici.[19]This all changed though and the Court no longer stopped at discrimination but expanded to striking down barriers that were non-discriminatory.[20] This was possibly in order to fulfil the aims of the treaty provision, in so far as to create an successful internal market.[21] This resulted in further autonomy for the CJEU through case law in 80s but mainly 90s.[22] The CJEU developed an approach to free movement that restrictions which are non-discriminatory in nature fall within the scope of the relevant treaty articles and have to be examined for validity.[23] Similarly to the earlier jurisprudence the Court applies this thinking to all the free movement areas.[24]Bosman [25] open up this idea within free movement of persons and expanded the Courts ability to strike down national legislation.[26] Cassis de Dijon[27]had a big effect on the area of non-discriminatory national rules arguably more than Bosman[28], when you compare the effect Cassis de Dijon had.It is seen as a landmark decision in the area of indistinctly applicable restrictions.[29] It and the subsequent cases have extended the Courts ability to declare a barrier to trade unlawful.[30]In a sense it has reduced the need for harmonisation and instead has advanced the internal market ideals through case law.[31] In comparison to this development within the free movement of persons, Cassis de Dijon resulted in a surge of cases.[32] This resulted in CJEU departing from the previous case law in Keck[33] to deal with the flood of cases. It is interesting to note that at the time of the Cassis de Dijon judgement was at a time of legislative stagnation which was impeding the development of the Internal Market.[34] Therefore the Courts decision meant that the negative integration rate was speed up.[35] Arguably the Court was attempting to full the requirements of Article 26 of the TFEU and but as they couldnt do this within the treaty itself they needed to expand the parameters of their power. Similar to the free movement of persons and goods, services jurisprudence developed to include non-discriminatory barriers, meaning that anything which impedes free movement is struck down.[36] As in the earlier cases and to the other areas where it is seen to be a dual barrier that barrier is struck down such as in Sager.[37] Interestingly AG Jacobs makes a direct comparison to Cassis di Dijon here and that cases approach to non-discriminatory restrictions.[38] Similarly, the free movement of establishment the old point of view discrimination only can be seen in Commission v Belgium[39]which allowed member states to make their own rules in the absence of Community harmonisation. Klopp[40] shows the change in the Courts jurisprudence for establishment in the same way as the other freedoms. The key case here is Gebhard[41]which repeated the view the Court highlighted in Sager.[42] According to Spaventa, Gebhard[43] was not only an expansion but a qualitative leap for free movement rights.[44] It indicates a further move away from a literal interpretation towards a more teleological approach to the internal market that can be seen across the freedoms. The success of the implementation of non-discriminatory ground has dispelled any argument, according to Connor, of ever full achieving an Internal Market on the basis of discrimination alone.[45] It is important note that as the CJEUs capacity has increased across the free movement, the Member States ability to justify them continued to grow exponentially.[46] The Court has been clear that the creation of the internal market through the harmonisation of laws does not mean that all barriers to trade will be abolished.[47] Instead they will engage in an assessment of balance.[48]The Court will essential look to see if the measure can be justified and if the restriction was appropriate and ensure that it doesnt go beyond what is necessary.[49] The more the CJEU gives itself the ability to strike down legislation, the more the Court creates justifications through case law to allow for this but it needs to be careful to ensure that it does not step into the legislative realm.[50] The increase in ways to justify restrictions has been demonstrated across free movement and as the Court expands its parameters into the market access test the justifications continue to grow.[51] In recent years the Court has again expanded free movement provisions through the market access test.[52] The Court refined their approach from Keck[53]in the cases of Commission v Italy[54]and Mickelson and Roos[55]and embraced the market access test.[56] Not only does this test include measures that are a barrier to goods entering the market but also once the good is in the market.[57] This shows a clear expansion of the Courts powers in relation to free movement of goods. Comparing this development to the other areas, establishment is   another area where this test has clearly been discussed and accepted by the court in Commission v Spain.[58] These cases demonstrate the CJEUs liberalising view of the free movement doctrine in recent years.[59] In comparison, the case law in the other areas of free movement seems to suggest that the market access test is are less severe than the restrictions in Commission v Italy and Mickelson.[60] The market access test has be subject to criticism with some questioning the basis of the test and whether the CEJU is potentially violating the separation of powers within the EU.[61] Some academics believe this market access test is a development as a result of Union Citizenship and this is the basis for the test.[62] The test marks a move towards convergence and harmonisation of the internal market.[63] The idea of citizenship seems to have taken hold and it is evident that it has had an impact on free movement.[64] Tryfonidou argues that these judgements indicate a move away from assessing impact of barriers on cross-border trade to promoting free movement of commerce by Union Citizens.[65] Ultimately the jurisprudence shows that the market access test has become the main principle for the free movement cases.[66] To conclude, the CJEU has moved from a discriminatory based approach to restrictions on the free movement of goods and services to non-discriminatory one to a market access test. The jurisprudence in the area isnt clear cut but the general understanding of academics seems to be that the move towards a non-discriminatory approach was needed to have a successful internal market. The subsequent move to a market access test seems to be founded on the idea of union citizenship and perhaps a deeper idea of ultimately, in so far, as possible having the freedoms converge. Through comparison, it is clear that each section of the free market is different but ultimately the CJEU feels similar. What is evident though is that the removal of regulatory barriers CJEU feels is needed, across the free movement of persons, goods, services and establishment, in order to fulfil the aims of the internal market.[67] [1] Eleanor Spaventa, From Gebhard to Carpenter: Towards a Non-Economic European Constitution, (2004) 41 Common Market Law Review 743 [2] Paul Craig and Grainne De Bà ºrca, EU Law: Texts, Cases, And Materials (6th edn, OUP 2015) 758 [3] Consolidated version of the Treaty on the Functioning of the European Union [2012] OJ OJ C326 Article 26 and Article 45 Treaty of the Functioning of the European Union [4] Case 167/73 Commission of the European Communities v. French Republic [1974] ECR 359 [5] Case 112/84 Michel Humblot v Directeur des services fiscau [1985] ECR 1367 [6] Case 8/74 Procureur du Roi v Benoà ®t and Gustave Dassonville [1974] ECR 837 [7] Tim Connor, Goods Persons Services and Capital in the European Union/ Jurisprudential Routes to Free Movement (2010) German Law Journal 159 [8] Case 15/69 Wà ¼rttembergische Milchverwertung-Sà ¼dmilch AG v Salvatore Ugliola [1970] ECR 363 [9] n7, 165 [10] Case 71/76 Jean Thieffrey v. Conseil de lOrdre des Avocatsà   la cour de Paris [1977] ECR 765; Case 33/74 Van Binsbergen v Bestuur van de Bedrijfsvereniging voor de Metaalnijverheid [1974] ECR 122 [11] n6 [12] Ailbhe ONeill, The Path Not Taken: The Global Approach to the Free Movement of Persons, (200) 3(1) Trinity College Law Review 111 [13] Case 53/76 Procureur de la Rà ©publique de Besanà §on v Les Sieurs Bouhelier and others [1977] ECR 197; Case 249/81 Commission of the European Communities v Ireland (Buy Irish Case) [1982] ECR 4005; Case 45/87 Commission of the European Communities v Ireland (Dunalk Water Supply) [1988] ECR 4929 [14] n6 [15] Case C-55/94 Gebhard v Consiglio dellOrdine degli Avvocati e Procuratori di Milano [1995] ECR I-4165 [16] Eleanor Spaventa, Leaving Keck behind? The free movement of goods after the rulings in Commission v Italy and Mickelsson and Roos (2009) 34(6) European Law Review 914 [17] Article 36, 45, 52 of the TFEU [18] Laurence W. Gormley, Free Movement of Goods within the EU Some issues and an Irish Persepctive, (2011) 46(1) The Irish Jurist 74 [19] Case 140/79 Chemical Farmaceutici SpA v DAF SpA [1981] ECR 1 [20] n12, 112 [21] n7, 169 [22] Peter Oliver and Wulf-Henning Roth, The Internal Market and the Four Freedoms (2003) 41 Common Market Law Review 407 [23] n12, 112 [24] n12, 112 [25] Case C-415/93 Union royale belge des socià ©tà ©s de football association ASBL v Jean-Marc Bosman, Royal club lià ©geois SA v Jean-Marc Bosman and others and Union des associations europà ©ennes de football (UEFA) v Jean-Marc Bosman [1995] ECR I-4921 [26] Case C-190/98 Volker Graf v Filzmoser Maschinenbau GmbH [2000] ECR I-493;Case C-464/02 Commission of the European Communites v. 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A Short Analytical Paper of Abraham Lincoln’s “a House Divided” Essay

The House Divided Speech was addressed by Abraham Lincoln on June 1958. He delivered the speech upon his acceptance of Illinois Republican Party’s nomination as the senator of the state. Thus the speech became a very important launching campaign for his success in politics thus giving him a national limelight that saw him in the elections to the presidency in 1860.The speech primarily addressed on the issue of slavery in America. Abraham Lincoln delivered his speech aimed at establishing his strong beliefs towards the acts of slavery. The speech was also meant to point out a differentiating factor of beliefs from Stephen Douglas and the rest of the top governmental officials who seemed to practice corruption in their transactions. According to Abraham Lincoln, â€Å"A House divided against itself cannot stand†. This was the major crucial theme of Abraham Lincoln’s speech. From this important statement,Licoln meant that the American nation could not in whatever terms or state face a positive survival phase when it was composed of a state of half-slavery and half-free. He meant that only one of those two states could only exist. Thus his bold statement was that he expected that the division that existed had to cease so as to embrace success and good governance. Lincoln’s speech helped rouse to the people of America the recognition of the extent to which slavery had gone. Lincoln’s speech is still relevant in this 21st century in that even today, each nation should embrace unity in all its undertakings whether political, social and economic. He believed that the ideals of a nation with freedom for all could not have a chance of coexistence whether socially, morally or in legal terms under one nation. Thus slavery should either be accepted among all people or be universally denied. A universal truth is clearly bears a clear significance from Lincoln’s statement to the extent that such a statement even pervades a lot of importance to the modern society and even the governments in power today. Such relevance can be clearly seen in the experiences in Sudan. Continued irreconcilable differences in culture and religion against the people of Sudan saw Southern Sudan seceding to become the republic of South Sudan. Such success for secession bears credit from the prophetic work of Abraham Lincoln. A division had always existed between the people from Northern Sudan who were associated with Muslim religion and the people from the Southern Sudan who were associated with Christianity. This scenario bred a situation of ethnic and cultural differences between the two states to the extent where secession could be avoided. Even today, the American nation is still faced with challenging political divisions and differences especially between the parties of the Republicans and the Democrats. The unwillingness of the two parties to arise to compromised solutions has always been evident in most of the major recent crises facing the nation. Clear evidence is the recent crisis on the debt ceiling where the Republicans were on the favor of maintaining cuts on spending as opposed to the Democrats who were advocating for an increase in taxes so as to increase revenue collection in the country. Further differences saw a compromised situation of debt ceiling being arrived at as the solution. This led to the country facing an economic disaster as a result of the oppositions from the two strong political parties. In the recent world, the institution of marriage can be compared to the speech of Abraham Lincoln. Marriage is a union of two people who are bound to each other by law. Division is prone to occur in a marriage situation in case of a divorce. For the married partners to embrace endured togetherness and unity in their marriage, they must appreciate common interests of concerns in their practices. In case one of the partners dissent from the unity and togetherness set up, the marriage is susceptible to division brought about by breaking of the legal bonds that hold the marriage partnership in unison. Continued lack of an amicable compromised solution between the two conflicting partners will thus lead to separation. Continued separation will see the two partners seek a divorce in a court of law and the marriage will fail completely. Most marriages nowadays are failing as a result of continued disagreements of interests between the married couple. As per words of Lincoln that a divide house cannot stand, thus the divided marriage partnership cannot even endure survival thus it breaks up. Even today, divisions in groups have been as a result of continued differences among the uniting groups. Humans have a tendency to incline towards the protection of their interest’s aid favors of their perceived groups. Such favourism makes them advocate fully for their interests posing a challenging opposing side to the interests of their unperceived groups. Many nations today are faced with such opposing groups having differing interests and ideals. People advocating for similar ideals tend to create strong ties of loyalty and even alliances creating a boundary to the opposing group or alliance. The existence of the two opposing groups as a whole sees each group maintain conflicting interests. Continued disagreement leads to one group conquer the other resulting to a failing side and a winning side. Ultimately such results create division in the nations. Thus, Abraham Lincoln’s works from the speech â€Å"A House Divided† bears a lot of significance and relevance in our modern world.