Wednesday February 22nd, 2012 07:11 Hotel Intel: Gayana Eco Resort Makes March 22 to April 22 Marine Awareness Month

For the Gayana Eco Resort in Malaysia, it’s not all honeymoons and three-hour spa services. They also work to reverse receding coral reefs and Giant Clam populations. Starting March 22, they’ll celebrate these undersea things with Marine Awareness Month (psst, there’s a party!).

Located off the northern coast of Borneo on Gaya Island, Gayana Eco Resort waters are home to gorgeous coral reefs and the Giant Clams that inhabit them. Because of illegal “fish bombing,” the use of explosives to net fish, both species have dwindled. Through their own Marine Ecology Research Centre (MERC), the resort has been working to protect and the propagate the species.

During the month, replanted coral fragments now stabilized and spawned baby clams matured in a safe environment at the center will be transferred to the resort’s ocean nursery for the next stage of their development. It all caps off with a Marine Awareness Day on April 22, 2012 at the resort’s other Gaya Island property Bunga Raya.

The celebratory-cum-educational event includes lunch, prizes, live performances, coral planting and a Zumba party with fitness instructor Michelle Koh. Tickets are $ 66 USD for adults and $ 33 USD for children, with all proceeds going to MERC’s environmental efforts.


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Sunday February 19th, 2012 00:13 Freezing Carrots the Right Way

Carrots are available almost throughout the year and their antioxidant health benefits make them ideal for consumption throughout the year. However, there are quite a few people who are frustrated by the prospect of stocking up these roots only to find them gone rotten or sprouting within a few days in the refrigerator. If you’re one of those who love to buy carrots in bulk but have a lurking fear of them turning rubbery or misshapen before you have had a chance to try out the recipe, you might find this article useful. By adopting proper methods of storage, carrots can be made to remain fresh and flavorsome for a long period of time.

Simple Techniques to Store Carrots
Freezing these hardy root vegetables is one of the most effective ways of storage. But there is more to it than just dumping them in the refrigerator. Listed below are a few simple techniques that will tell you how to freeze carrots the right way.

Freezing Carrots: What to Do

Always trim the top green stubble before freezing as it draws out the moisture from the root and causes rotting. If you need to use the stubble in your cooking, store it separately (lasts fewer days).

Let the carrots dry in the sun for a day or so. The moisture on the outer skin can accelerate rotting. Then store the dry carrots in an equally dry plastic bag in the coolest part of your refrigerator. Carrots will remain fresh for several months if stored this way.

Refrigerated carrots often form a white root film on the exterior, after a few days. Just peel the carrots before use to expose the orange fresh layer. It will not affect the taste of the carrots.

While buying carrots from the store, pick the ones with the greens attached as they will undoubtedly be more durable than those with the trimmed greens. If you must pick up frozen carrots from the store, leave them in their original film packing when storing at home.

Most varieties of carrots have a long storage life; however, baby carrots wilt faster than the regular ones. To prevent them from becoming rubbery, it is best to blanch them. We will learn how to blanch them later in this article.

Vacuum packing or storing in zip lock pouches (or thick bags) makes the carrots stay fresh longer than in regular plastic bags.

Freezing Carrots: What Not to Do

Washing carrots before freezing them is a no-no.

Avoid packaging carrots to be frozen in a huge single pack. It is better to freeze in smaller batches instead of one single container, especially if the carrots are homegrown or purchased in bulk.

Avoid postponing harvesting of homegrown carrots until they’re old. Younger carrots last longer due to the relatively lesser fibrous content.

Deep freezing is a better option than storing in frost-free setups.

Avoid storing carrots next to vegetables like potatoes or fruits like apples and pears which give out ethylene gas, making the carrots bitter in taste.

Avoid storing almost damaged carrots. They will ruin the fresh ones as well and they’re anyway best used immediately.

Blanching Carrots for Storage and Preservation
Fresh produce when exposed to the atmosphere triggers enzyme action. This, in addition to rotting from moisture, causes loss of flavor, texture and color of the vegetable. In order to stop the enzyme activation, blanching carrots is an effective method. The steps are described below.

  1. Boil a generous quantity of water (a gallon per pound of carrot) on high heat.
  2. If the carrots are big, you may cut them into manageable chunks or slices; baby carrots are best blanched whole. Remove the green stubble, wash and peel the young carrots.
  3. Immerse the carrots into the boiling water and let them stay for 2-5 minutes while the water is still boiling (2 minutes for slices and 5 minutes for whole carrots).
  4. Now, for some flash cooling – remove the carrots with a slotted spoon and drop them into a large container filled with ice water so that the carrots chill quickly.
  5. Next, drain the carrots of excess moisture, blot them on paper towels so that they’re completely dry.
  6. Put the blanched, dry carrots into plastic bags with about half an inch of head space and quickly put them in the freezer.
  7. Do not blanch carrots for more than five minutes or you’ll be left with a rubbery, overcooked almost useless vegetable unfit for freezing.

Some Offbeat Tips
The below tips are not tried and tested but they’re talked about among experienced homemakers and cooks.

  • A water bath is known to be effective in keeping carrots fresh for a longer duration. Store the carrots in a container filled with water, just ensure you change the water occasionally.
  • Some claim that bubble wrapping keeps carrots fresh for a long time.
  • Peeled carrots when placed and wrapped tightly in a damp towel seems to be a popular technique. They are then sealed in a plastic bag before storing. Open the bag and dampen the towel every other day for best results.

Like most other veggies, drawing the maximum nutritional value of carrots into your food is possible when it is freshly consumed. Storing vegetables in root cellars were effective ways of preservation before the age of refrigerators. However, using the above techniques you can come very close to the near-fresh experience with all the crunch intact. Even though carrots can last for months using some of the techniques, we still recommend using them as soon as possible. The sooner it gets out of that freezer and into your recipe, the fresher it will be.


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Wednesday February 15th, 2012 16:36 Just in time for Carnival: Beginner’s guide to Rio

The Associated Press

RIO DE JANEIRO — “Brazil is not for beginners,” the late, great Brazilian composer Tom Jobim once quipped. Nowhere does the remark hold more true than for the country’s pulsing, chaotic oceanfront metropolis, Rio de Janeiro.

This is a city of contrasts, where vastly different worlds rub shoulders, and the unexpected lies lurking around every corner.

Hang a right during an aimless stroll through the chic beachside neighborhoods of Ipanema or Copacabana and you might just bump into a lush tropical forest. Hang a left, and the luxury condominiums could give way to a warren of brick and corrugated iron houses perched precariously on a rocky outcropping — a “favela,” or hillside slum.

It’s this proximity between rich and poor, city and nature that gives Rio its intensity. But it also makes navigation a challenge for first-time visitors. It’s even more difficult during Carnival season, when city streets morph into rowdy block parties with tens of thousands of costumed revelers dancing to infectious samba beats.

Luckily, Rio is dotted with landmarks that allow you to easily find your bearings. Sugarloaf Hill, the awesome rocky outcropping that can be visited by aerial cable car, presides over Guanabara Bay in the east. The monumental statue Christ the Redeemer reaches toward the sea from his perch inside the dense Tijuca Forest in the heart of the city. A 5-mile (8 kilometer) stretch of white sand marks Rio’s southern edge, home to the legendary Copacabana, Ipanema and Leblon beaches.

Here, the beach is a way of life, and these iconic stretches of sand are the stage upon which Rio natives — known as Cariocas — play out their lives. Weekends draw huge crowds from across the class spectrum to swim, surf, sun, jog, picnic, gossip, frolic, flirt, stretch and strut.

During the Southern Hemisphere summer, January to March, the throngs are often so thick that towel-size real estate can be hard to come by. But persevere.

Between the tall, tan young and lovely girls from Ipanema, their muscle-bound, tattoo-covered male counterparts, the flocks of screaming children and steady stream of vendors, hawking everything from sunscreen to frozen slush made from Amazon berries, the action is not to be missed.

Theft has long been on a problem on the beach, but the government’s recent takeover of some nearby slums — which pushed the drug lords who reigned there out — has improved security throughout the city, including the seaside.

Still, it’s best to leave all valuables — cell phone, camera, watch — at home and avoid drawing attention to yourself by dressing like the locals. Rest assured, while they don’t cover much up, Brazilian “sunga” or Speedo-style suits for men and “fio dental” string bikinis for women have a magical way of bringing out everyone’s best assets, whatever your body type.

No trip to the beach is complete without a stroll down Avenida Visconde de Piraja, Ipanema’s main drag — a sort of relaxed Fifth Avenue, where the dress code consists of bikinis, sarongs and flip-flops. Homegrown clothing lines abound, churning out pretty but pricey sundresses, short-shorts, pantsuits for the daring and, naturally, bikinis. Top Brazilian beachwear houses include Lenny, Salinas and Osklen.

If you haven’t gotten your fill of snacks on the beach, head to Bibi Sucos, which serves up a dizzying array of freshly squeezed exotic juices — jabuticaba, anyone? — and, with Brazil’s dizzily spiraling prices, is among Rio’s few remaining inexpensive pleasures. A more sophisticated meal can be had at Market, also on Visconde de Piraja, which serves up tasty, healthy alternatives to the “comida por quilo” self-service buffets that offer up meat in all its imaginable incarnations, paid by the weight.

If you’re a Brazilian at heart, with a well-developed carnivorous instinct, no trip to Rio is complete without a visit to a “rodizio,” a fixed price restaurant where an endless variety of meats, from filet mignon to chicken hearts, are served off the spit by a parade of waiters. Porcao, which has three Rio locations including one in Ipanema, is a “rodizio” of epic proportions.

To work off the meat overdose, a hike will doubtless be in order, and Rio offers several excellent options.

The world’s largest urban forest, Tijuca is home to a host of monkeys, parrots and cute raccoon-like creatures called coatis (cuatis in Portuguese) as well as the Christ statue, perched atop a verdant, 2,300-foot (701-meter) peak. You could take the “bondinho,” or little street car, that winds its way to the top.

But if you really want to burn off those extra calories, a better option is a hike to the top of the Tijuca Peak, which is a full 1,000 feet (300 meters) higher and offers unparalleled panoramic views over the city. Take a cab to Alta Boa Vista, where the trail to the top begins. Get an early start, because the park closes at sundown, and the hike can take up to six hours round trip.

A less strenuous way to commune with Rio’s unique brand of urban nature is a stroll through the Jardim Botanico, 350 well-manicured acres of flora from Brazil and beyond. Founded in the early 19th century by Portuguese King Joao VI, the botanical gardens include the stunning Orquidario, where hundreds of delicate orchids are on display.

Should one of Rio’s spectacular rainstorms force you indoors, you can seek shelter in a museum. Top choices are the MAM modern art museum near the historic downtown, which includes exhibits by top contemporary artists; the Instituto Moreira Salles in Gavea, with its topnotch photography collection; and the Museu de Arte Contemporanea, a space age complex designed in by celebrated Brazilian architect Oscar Neimeyer in Rio’s sister-city, Niteroi.

For a stiff dose of Rio nightlife, hit Lapa. Bars serving up Brazilian cane alcohol, “cachaca,” tiny clubs with live music and massive, multilevel mega-discos are all concentrated in this historic neighborhood near the city center. Friday nights, this is where the action is, and the crowds are so thick you can barely walk — let alone dance.

Crowds are an inescapable fact of life in Rio during Carnival.

Weeks before the official Feb 18-22 celebrations, “blocos,” or block parties that attract up to tens of thousands of revelers start sprouting up across the city. While most blocos are simply an excuse for drunken dancing in the streets, some have themes, like Copacabana’s “Blocao” costumed pet parade or “Sargento Pimenta,” or Sargent Pepper, with its medley of Beatles hits.

But the crowning jewel of Rio Carnival remains the two-night long competition at the Sambodromo. Thirteen samba schools vie for the top prize: Their elaborate floats, massive percussion sections and troupes of sequin and feather-clad dancers samba their way down the avenue as ticket-paying spectators look on from the bleachers.

And for a bit of post-Carnival relaxation, there’s only one place to go: Back to the beach.

___

February 15, 2012 11:26 AM EST

Copyright 2012, The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.


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Sunday February 12th, 2012 09:20 Are High School Teachers More Qualified to Teach Than College Professors?

Today, millions of students each pay gargantuan tuition fees to institutions across the country in their quest to attain a college degree. A college is known to be an institution of “higher learning”. With that its assumed that professors must be highly qualified, much more qualified than the teachers of the high schools that the students have previously graduated from. But is that really true?

Different states have different requirements for becoming a high school teacher. Generally, a bachelor’s degree is required with sufficient coursework in the content area that the individual would like to teach. There are a variety of tests required, usually being a basic skills test, a content-area specific test, and a teaching assessment.

It is also required that the individual passes through an approved teaching certification program. These programs are designed to to teach how to handle a classroom in various aspects, and more importantly teach “how to teach”. In addition to coursework, there is also required clinical hours in the classroom.

Compared to high school, college courses involve decreased instruction time while at the same time increasing the amount of material required. It is realistic to expect that professors must be more effective at teaching, and have therefore undergone even more extensive training than high school teachers.

To become a college professor you must have: a Ph.D in the field that you’d like to teach…and that’s it.
Are there any required teaching clinical hours? The answer is no. Any assessment of teaching abilities? Also a no. The amount of required education coursework is zero, unless of course you’re an education professor.

Most Ph.D students have served as teaching assistants at their respective institutions. However in majority of cases TAs are simply entrusted with the responsibility of grading assignments and at most answering questions in a small discussion section. Without a doubt, a Ph.D is a degree that requires great effort, difficult coursework in the content area, as well as abundant research. But should the responsibility of pas sing on more complex material at a faster pace be given to teachers who simply have not been trained?
The answer is a clear no.

Without any training requirements, what we see in our colleges today are plenty of brilliant minds with a great personal understanding of the material, but are absolutely useless at teaching it. Simply reading information from a PowerPoint presentation is NOT teaching. During registration period students stress over enrolling in classes taught by the 1-2 professors in possibly the entire department that are actually effective educators. It is unfortunate that it appears college boards are more concerned with the level of research these professors will bring to their institution (and even more concerned about athletics, but that’s another topic). The students and their education should always come first. This is our future.


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Thursday February 9th, 2012 02:18 Apple Determines iTunes Match Royalties By Counting How Many Times A Song is Accessed

TuneCore president Jeff Price today wrote a blog post praising Apple’s iTunes Match service for creating money “out of thin air” for copyright holders. iTunes Match launched with all the major record labels on board, but some small labels refused to participate over concerns the service was legitimizing music pirates.

Price disagrees:

A person has a song on her computer hard drive. She clicks on the song and plays it. No one is getting paid. The same person pays iTunes $ 25 for iMatch. She now clicks on the same song and plays it through her iMatch service. Copyright holders get paid.


Price tells MacRumors that Apple keeps 30% of iTunes Match revenues for itself — the same percentage the company keeps from the iTunes and App Stores. The remaining 70% is divided, with 88% going to record labels and 12% going to songwriters. The royalties are split amongst artists based on “how many times someone accesses your song” via iTunes Match and it doesn’t matter if a song is matched or uploaded — the royalty is paid either way.

Price and other record industry execs are thrilled with the iTunes Match service, and by extension, Apple. Not only are artists finally getting paid something for pirated music, but for legitimate song purchases they are getting paid twice. If a listener purchases a CD, rips it to their computer, and then uploads it to iTunes Match, the record company books revenue for both the purchase and the small cut they receive from iTunes Match.

Regarding other music services, Price says, Pandora or Spotify customers are “paying a fee to listen to Spotify’s music collection.” iTunes Match customers are “paying a fee to have access to [their] own music collection.”


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Sunday February 5th, 2012 18:53 Juvenile Announces “Mardi Gras” Mixtape, Reveals Cover Art

Juvenile is teaming with DJ Smallz for the street release.

Juvenile has announced the release of a new mixtape entitled Mardi Gras, which is set to be hosted by DJ Smallz.

Smallz, aka Mr. Southern Smoke, took to his blog to reveal the cover art for the street release. Artist Blake Gaston created the image for the cover, a portrait of Juvie with a Mardi Gras mask on his face.


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Thursday February 2nd, 2012 11:36 Are You Advertising?

Building a business requires letting as many people know about it as possible. There are many different ways on how to do this. I will be mentioning just a few inexpensive paths to advertising. Just remember to keep all receipts for tax purposes.

Business Cards

Business cards are essential for a businessman or businesswoman. They are small enough to carry around and large enough to hold just enough information to give to a customer. This information should include the name of your business, your name, phone number, business address and (a website if you have one).

Make sure your business cards look professional, but have a modest approach. Don’t go overboard with background color. In fact, just your business logo would be enough. Too much color tells the people looking at your business card that you are a “money shark!” You do not want to be a “money shark,” or what everyone else calls a conman.

Posters and Fliers

Professionally made fliers can be eye-catching, which is important for a business to thrive. When making a flier, only bold print the important information like your business website. Background color is essential because it draws in your customers. So, have fun with the fliers you make and don’t forget to put down the normal information.

Fliers usually announce special deals that your business is offering. Such information as sales, offers, and sweepstakes are important to announce on a business flier. Also, don’t forget to place these in main streets so people can see them.

Business Networking

In today’s economy, many small business owners find it rewarding with making customers out of other business owners. This is what many call business networking. This is especially common on social-networking sites, mainly on Facebook, and it is becoming more and more popular because of its advertising exposure. Many in these business communities help each other out by advertising each other’s businesses to people they know.

This is a thriving business method of advertising, and it can potentially reach thousands of people at a time. Business relationships tend to grow and both sides see the benefits of helping each other out.

Despite the rewards of business networking, the cons depend much on your business. This kind of networking brings in potential customers from around the world. Your business will need to provide for them. If you are selling a product, you will need to find some way of delivering it.

In my opinion, businesses that provide online services reap the best rewards out of business networking.


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Monday January 30th, 2012 04:23 Christina Aguilera’s Tribute to Etta James

The world was saddened when the news of Etta James’ death was announced Jan. 20. Her funeral brought together many great artists that were influenced by Etta James and whom knew the star personally.

James’ funeral was held Saturday. One of the many singers whom had been influenced by James is Christina Aguilera, who sang James’ most popular song “At Last.” Aguilera’s rendition of “At Last” is something James would have been proud of and so honored to have heard as a tribute to her. The way Aguilera sang was with a sensational amount of soul and heartfelt feeling that literally gave me chills and goose bumps. Out of all the people whom have sang James’ song “At Last,” Aguilera is definitely one of the best.

Aguilera’s tribute is one of the most positive reviews the singer has had in most recent years. I think most of us remember her singing the national anthem and butchering the lyrics to “The Star Spangled Banner” to tiny giblets at the 2011 Super Bowl. She has also been in the news negatively because of weight gain and rumored alcohol abuse.

Since the funeral, Aguilera has become a hot topic, receiving lots of accolades and positive remarks for her tribute to one of the first women who has been an inspiration for many. In an article from People Magazine, Aguilera commented on how much James inspired her life and music: “Etta wasn’t just any performer, she was a strong woman whose talent came from a place so deep it moved people in ways they never felt before. Losing her was, to me, like losing a part of my soul. … I can only hope that she felt the love in the room as we all came together to pay tribute to her and celebrate her life as a person and as an artist. She will be deeply missed and I thank her family for allowing me such a great honor.”

It is unfortunate the circumstance that Aguilera had to sing “At Last” as a tribute to James, but, as a fan of both women, I think it was a tribute that was beautifully done.

Heather M. Johnson-Emerson is a graduate from the University of South Carolina where she earned a Bachelor of Arts degree in Communications in 2008. She has been writing for over 17 years and just recently started a career in freelance writing. Mrs. Johnson-Emerson is an amateur NPC bikini competitor and is a certified step instructor. Mrs. Johnson-Emerson’s interests are found in: beauty, spirituality, painting, politics, celebrity gossip, and of course sports and fitness!


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Thursday January 26th, 2012 21:03 Wall Street falls after weak housing data (Reuters)

NEW YORK (Reuters) – Wall Street is set for a slightly lower open on Thursday, giving back some of the gains from the previous session, when the Federal Reserve boosted equities by saying it was likely to keep interest rates near zero until at least late 2014.

At 4:21 a.m. ET, futures for the S&P 500, Dow Jones and Nasdaq 100 were down between 0.1 and 0.3 percent.

The FTSEurofirst 300 (.FTEU3) index of leading European shares was up 0.3 percent at 1,042.50 points, with miners higher on stronger copper prices, which were boosted by the Fed’s statement, as were oil prices.

The euro was near five-week highs at $ 1.3110 though little changed on closing New York levels.

U.S. initial jobless claims are seen correcting up to 370,000 from 352,000 the week before, mostly from the smaller seasonal factor in the week ended January 21 after a reading where claims sunk to a nearly 4-year low. Claims just dropped 50,000 as they worked their way back from a reading that historically sees a rise in the first week of a new year. The data is due at 8:30 a.m ET.

The transportation sector could be a big wildcard for December durable goods, but is seen exerting only a modest drag, pulling the headline down to a 2.0 percent gain from 3.7 percent the month before, according to a Reuters poll of 69 economists.

Starbucks (SBUX.O), the world’s biggest coffee chain, reports quarterly results and may offer an early read on the success of its lightest yet “Blonde” roast coffee and an update on its recently introduced K-cups for Green Mountain’s (GMCR.O) popular Keurig one-cup brewers.

Other companies reporting include Caterpillar (CAT.N), the world’s largest maker of earth-moving equipment and telecoms heavyweight AT&T (T.N).

Big profits from Apple (AAPL.O) and a promise from the Federal Reserve to keep rock-bottom rates for at least two more years powered the U.S. stock market higher on Wednesday.

The Dow Jones industrial average (.DJI) rose 0.7 percent, the Standard & Poor’s 500 Index gained 0.9 percent, the Nasdaq Composite Index (.IXIC) ended 1.1 percent higher.

Stanley Black and Decker (SWK.N) shares slipped 1 percent after the bell following the release of its results.

(Reporting by Brian Gorman. Editing by Jane Merriman)


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Monday January 23rd, 2012 13:48 The Unbearable Wrongness of Roe

39 years ago, the Supreme Court delivered a radical, legally untenable, immoral decision. It has forfeited its entitlement to have its decisions respected, and followed, by the other branches of government, by the states, and by the people.

Today, thousands of people at the March for Life in Washington, D.C., are commemorating the thirty-ninth anniversary of a legal and moral monstrosity, Roe v. Wade, and its companion case, Doe v. Bolton. The two cases, in combination, created an essentially unqualified constitutional right of pregnant women to abortion—the right to kill their children, gestating in their wombs, up to the point of birth. After nearly four decades, Roe’s human death toll stands at nearly sixty million human lives, a total exceeding the Nazi Holocaust, Stalin’s purges, Pol Pot’s killing fields, and the Rwandan genocide combined. Over the past forty years, one-sixth of the American population has been killed by abortion. One in four African-Americans is killed before birth. Abortion is the leading cause of (unnatural) death in America.

It is almost too much to contemplate: the prospect that we are living in the midst of, and accepting (to various degrees) one of the greatest human holocausts in history. And so we don’t contemplate it. Instead, we look for ways to deny this grim reality, minimize it, or explain away our complacency—or complicity.

It is important, however, to view reality with eyes wide open, focus clear, and gaze not averted. On this thirty-ninth anniversary of Roe and Doe, I would like simply to set forth what Roe and Doe held, in as clear-headed and straightforwardly descriptive legal terms as possible, and to lay out its human and moral consequences. My brief tour of Roe’s unbearable wrongness begins with Roe’s radicalism—its extreme holding creating a plenary right to obtain or commit abortion—proceeds with Roe’s legal untenability, and concludes with Roe’s immorality and the moral problem of our seeming passivity and quiescence in response to the greatest legal and moral wrongs of our age.

Roe’s Radicalism

Start with Roe’s radicalism, a radicalism that we may no longer grasp because it has become so familiar. Roe created a constitutional right to obtain or commit an abortion of a human life—that is, to terminate the life of a human embryo or fetus. It is important to be clear-sighted about this: abortion kills a living human embryo or fetus. What distinguishes “abortion” from (say) miscarriage is the specific intention to kill a living fetus. What was alive before has been deliberately killed. Abortion takes a life. Further, the life taken is human life. There is really no doubt about that as a matter of biology. The embryo or fetus belongs to the species homo sapiens. It is a separate, living human being that is killed by abortion.

To be sure, that human being is killed at an early stage in its life cycle, and for a substantial part of that time could not live without direct biological connection to his or her mother (the person in whom Roe vests the right to terminate that human life). But that does not make the human embryo any less alive, any less human, or any less a separate life from the mother. It just makes the unborn baby more vulnerable and dependent.

The right created by the Supreme Court in Roe is a constitutional right of some human beings to kill other human beings. I do not mean for my description to be provocative, but simply direct—blunt about facts. One need not presume that the human fetus has a right not to be killed in order to recognize that, as a descriptive matter, Roe creates a right for one class of human beings to kill other human beings.

Roe, coupled with Doe, creates a plenary right to kill the embryo or fetus for essentially any reason, at any time throughout all nine months of pregnancy. Distilled to its essence, Roe created a “trimester” framework for abortion. In roughly the first three months of pregnancy, the right of abortion is avowedly plenary: abortion may be had for any reason. In the second three months, government may regulate abortion to protect the life or health of the mother, but again the right to have an abortion remains plenary. In the final three months—after the point of “viability,” when the human fetus could live on his or her own outside the mother’s womb—Roe says that abortion can be restricted or prohibited . . . except where abortion is necessary to protect the “life or health” of the pregnant woman.

This is a big exception. And here is where Doe steps in. On its face, Roe might appear, to the unwary or uninitiated, “moderate”—its trimester-balancing framework a measured, reasonable-sounding, proportionate act of judicial legislation concerning abortion. It is Doe that does a lot of the work, through an indirect and ultimately disingenuous definition of the “health” reasons that always may justify a woman’s decision to have an abortion and trump any interest of society in protecting fetal human life, even when the child could survive outside the mother’s womb. Doe holds that relevant “health” considerations justifying late-term abortions include “all factors—physical, emotional, psychological, familial, and the woman’s age—relevant to the well-being of the patient. All these factors may relate to health.” (Doe’s understanding of “the patient” did not include the fetus; Roe held elsewhere that the human fetus has no legal rights that any person is bound to respect.)

Roe then cross-referenced Doe’s stylized definition of health and incorporated it into the main holding. The result is that an abortion may be had, under Roe and Doe, for essentially any reason, throughout all nine months of pregnancy, up to the point of birth.

Nothing in any of the Court’s later abortion cases alters this definition of “health” or the right to abortion throughout pregnancy. Planned Parenthood v. Casey, the 1992 case reaffirming Roe, tinkered slightly with the trimester framework and the point at which “viability” occurs but did not change Roe’s (and Doe’s) holding that abortion may be had for any reason, before viability, and for any “health” reason throughout pregnancy. The partial-birth abortion cases carried this understanding forward, holding that the state may not prohibit the abortion method of inducing birth and killing the fetus on the way out of the birth canal (Carhart I [2000]), unless an equally effective, equally “healthy” method of killing the fetus is available (Carhart II [2007]).

I suspect that if more people understood Roe’s and Doe’s actual holding fewer would support that constitutional regime. Roe was a truly extreme decision, creating an effectively unrestricted constitutional right to abort a living human being for any reason the mother might have, throughout pregnancy right up to the point of birth.

Roe’s Legal Untenability

This brings us to Roe’s utter indefensibility as a matter of constitutional law. If the U.S. Constitution actually protected such an extreme personal legal right to kill the human fetus, that would be troubling enough, but the trouble would be with the content of the Constitution. The further problem with Roe is that it has absolutely no basis in the text, structure, or history of the Constitution. No rule or principle of law fairly traceable to the text, discernible from its structure, or fairly derived from evidence of intention or historical understanding of an authoritative decision of the people, remotely supports the result reached in Roe. In terms of fair principles of constitutional interpretation, Roe is perhaps the least defensible major constitutional decision in the Supreme Court’s history.


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