Service learning Assignment Example | Topics and Well Written Essays - 500 words

Service learning - Assignment Example This implies that every member of the society is equally important and holds the potential to make positive contributions consequently leading to the overall societal development. Racism is a global problem that can affect anyone since it arguably depends on an individual’s location. For example being white in America and other Western countries is seemingly a free ticket from racism unlike other races such as Asians. However, this privilege is limited to regions where the highest percentage of inhabitants are white. For example, during a tour to Africa with my family we encountered an incident where we were overcharged simply due to the divisions and notions created by race. There was no considerable benefit to the oppressors apart from the extra cash of course. Nonetheless, racism is seemingly double sided since in some instances I get served first regardless there being people from a different race that had arrived earlier. Stereotyping is a common practice in the society and can either be positive or negative. For example, the stereotype that all politicians are selfish or that girls are not good at sports or that all Muslims are terrorists or all women like make-up. Going by this examples it is evident that stereotypes are specific to particular groups such as politicians, girls, Muslims, and women respectively. Additionally, stereotypes are seemingly true but the main contestation is the generalization that is not necessarily true. For example, a relatively high number of women like and frequently use make-up. However, there is also a relatively high number of women who do not wear make-up and in fact do not like it. The theory of voluntary oppression is deeply rooted in the provisions that for oppression to occur one must belong to a group that is facing oppression. This is despite the fact that the particular individual in play may not be directly affected. This implies that an individual is oppressed simply due to the fact that they

1987 Constitution Interpretation Essay Example for Free

1987 Constitution Interpretation Essay By the 1850’s The Constitution, originally framed as an instrument of national unity, had become a source of sectional discord and tension and ultimately contributed to the failure of the union it had created. This is all shown by the misinterpretations of the Constitution and documents that followed on many occasions and topics. The Constitution was never explained to how it was meant to be interpreted, which cause many disagreements, which ultimately started sectionalism, which is the loyalty to interests or views in one’s region of a country rather than the views or interests of the country as a whole. Sectionalism kick started the idea of sucession from the union, which started the bloodiest war on american soil, the Civil War. The misinterpretation on the views of slavery was the biggest argument as shown in multiple documents, (Document E), â€Å"To the Argument, that the word ‘slaves’ and ‘slavery’ are not to be found in the Constitution, and therefore it was never intended to give any protection or countenance to the slave system, it is sufficient to reply, that no such words are continued in the instrument, other words were used, intelligently and specifically, to meet the necessities of slavery.† This basically means that the constitution could have many interpretations on the basis that no â€Å"right† interpretation was ever stated.There were many feuds between documents following the Constitution such as the Compromise of 1850 as show in in the map of (Document A) where the country is broken into 2 parts, not unified because of slavery, along with the Fugitive Slave Law, (Document D)

Napoleon Bonaparte’s Invasion of Russia Essay -- European History Russ

Napoleon’s Invasion of Russia Napoleon Bonaparte’s invasion of Russia was a major factor in his downfall. In 1812, Napoleon, whose alliance with Alexander I had disintegrated, launched an invasion into Russia that ended in a disastrous retreat from Moscow. Thereafter, all of Europe, including his own allies, Austria and Prussia, united against him. Although he continued to fight, the odds he faced were impossible. In April 1814, Napoleon’s own marshals refused to continue the struggle and stepped down from their positions. During the actual Russian campaign, there were many key factors that greatly impacted his downfall. The largest army ever assembled for one single invasion was reduced to a mere fraction of its original size. Because of the rebellions from his allies, Austria and Prussia, Napoleon had to fight a war on both the western and the eastern front. The losses he suffered in Russia greatly affected his future campaigns. Throughout his reign, Napoleon was able to overcome many obstacles that others before him could have only dreamed. One was the idea of having a United Europe under France. With his Grand Armà ©e, Napoleon had already conquered, and was controlling an enormous amount of Europe, such as Switzerland, the Confederation of the Rhine, Austria, and the Grand Duchy of Warsaw (Broers, 47). These countries, or provinces, made up the bulk of central Europe. Napoleon had recently ended a war with Spain, and now had signed a peace treaty with them. In 1805, France, under Napoleon, and Russia, under Alexander I, signed the Treaty of Tilsit. The treaty was one of peace under certain conditions. Russia was prohibited to trade with England, and they were also obligated to turn over some of their land to France (Elting, 63). The territory that France gained control over was the Grand Duchy of Warsaw. The treaty was extremely harsh on Russia. The prohibition of trade with England greatly affected the economy of Russia. The Continental System, which Napoleon instituted, prohibited trade with England. Alexander I violated the Treaty of Tilsit by renewing trade with England. Napoleon invaded Russia in an attempt to force Czar Alexander I to abide by the Treaty of Tilsit (Web, Russian Embassy). The summer of 1812 was an ideal time for Napoleon to begin an invasion. Russia’s economy was weak due to the trade embargo and other internal problem s.... ..., New York. 1997. 4. Palmer, R. France Under Napoleon. Princeton University Press, New Jersey. 1990. Internet: 1. Connelly, Owen. Tempe of Napoleon. http://sangha.net/messengers/napoleon.htm 2. Minard. Napoleon's Invasion of Russia, 1812. http://uts.cc.utexas.edu/~jrubarth/gslis/lis385t.16/Napoleon/ 3. Russian Embassy. Napoleon’s Invasion of Russia. http://www.interknowledge.com/russia/rushis05.htm 4. Saglamer, Emin. 1812: Napoleon's March to Russia. http://www.ddg.com/LIS/InfoDesignF96/Emin/napoleon/textindex.html 5. Unknown. Napoleon is Russia: 1812. http://home.rmci.net/toddjohnson/russia.htm The map, based on the 1869 chart by Minard, graphically illustrates (both literally and figuratively) how the size of the French army dwindled during the march into Russia and was reduced to almost nothing on the wretched rout back into Poland. The map can be read in several ways. The size of the peach colored bar indicates the relative strength of the French army during the march on Moscow. The black bar shows the dwindling French army during the retreat. In the lower portion of the map, the temperature in degrees Celsius is shown, along with dates during the retreat.

Some Unusual Properties of Water Essay -- Geology

Some Unusual Properties of Water Cohesion/Adhesion Water molecules attract each other as a result of hydrogen bonding. This ionic attraction is 1/20 as strong as covalent bond in water's liquid form. They form, break and re-form with great frequency; each hydrogen bond last only a few trillionths of a second, but the molecules bond promiscuously to a succession of partners. At any instant, a substantial percentage of all the water molecules are bonded to their neighbors, giving water more structure than other liquids. Collectively, this phenomenon is known as cohesion. A related property of cohesion is adhesion, a water molecule's attraction to other polar surfaces. This is, again, directly attributed to water's high polarity. Hydrophilic substances/materials, having similar strong polarity, are attracted to water through polar interactions. If you have ever tried to separate two glass slides stuck together with a film of water, you can appreciate how tightly water adheres to glass, a hydrophilic substance. (Water Module) Biological Impact: Water's cohesive property is especially crucial to the survival of plants. Cohesion due to hydrogen bonding contributes to the transport of water against gravity in plant xylem. As transpiration, water evaporation, in leaves occurs, water in the plant xylem is "tugged" into the leaves to replace evaporated water. This upward pull is transmitted along the vessel all the way to the roots. This cohesive property allows tall evergreen trees to survive. Water cohesion also leads to another property known as surface tension, a measurement of the strength and toughness of the surface of a liquid to penetration. Because of water's high surface tension, due to hydrogen bonding, insects such ... ... bonded to a maximum of four partners. In this structure, the hydrogen bonds distance the molecules so that ice is 10% less dense than liquid water. Biological Impact: The expansion of water as it solidifies is especially important to the fitness of the environment. Ice's natural tendency to float prevents the freezing of lakes, ponds and even oceans during winter, allowing organisms within these ecosystems to survive. Further, because ice floats, it is able to prevent the loss of heat from bodies of water, providing insulation for aquatic organisms. The freezing of water and melting of ice also ease the transition between seasons for organisms. When water solidifies into ice or snow, the heat released warms the surrounding air, helping to temper the autumn. Similarly, during the spring, melting ice absorbs heat, tempering the transition into the warmer season.

Mark Doty: Life and Career Essay

Doty was born in Maryville, Tennessee, earned his Bachelor of Arts from Drake University in Des Moines, Iowa, and received his Master of Fine Arts in creative writing from Goddard College in Vermont. In 1989, his partner Wally Roberts tested positive for HIV,[1] which drastically changed Doty’s writing. Roberts’s death in 1994 inspired Doty to write Atlantis. Heaven’s Coast: A Memoir also deals with this subject and received the PEN/Martha Albrand Award for First Nonfiction. [2] In 1995, he was the first American poet to win the  £10,000 T.S. Eliot Prize for Poetry, for his book My Alexandria. The book was also a finalist for the National Book Award and the winner of the 1993 Los Angeles Times Book Prize for Poetry and the National Book Critics Circle Award. Doty also received a 1994 Whiting Writers’ Award. Look more:  mark twain satire essay He has written twelve books of poetry and three memoirs. Firebird told the story of his childhood in the American South and in Arizona. Dog Years was a memoir of the lives of two of his dogs who Doty had while dealing with the death of his partner and the devastation of 9-11. Louise Erdrich praised the book as being â€Å"about dogs, that is to say, about everything we cannot talk about†¦ the ‘unsayable’ about our relationships with animals, and about unspeakable times of loss, Dog Years is not a dark book. It is illuminated from within by gorgeous wonder.† Dog Years is the winner of the 2008 American Library Association Stonewall Book Awards Israel Fishman Non-Fiction Award. His last book of poetry Fire to Fire: New and Selected Poems won the 2008 National Book Award for Poetry.[3] He lives in New York City and Fire Island, New York. He was the John and Rebecca Moores Professor in the graduate program at The University of Houston Creative Writing Program. He has also participated in The Juniper Summer Writing Institute at the University of Massachusetts Amherst’s MFA Program for Poets & Writers and was on the faculty of the Bread Loaf Writers’ Conference in August 2006. He is the inaugural judge of the White Crane/James White Poetry Prize for Excellence in Gay Men’s Poetry. Doty is a judge for the 2013 Griffin Poetry Prize. He now teaches at Rutgers University. His husband since 1995 is the writer Paul Lisicky.

Free Essays on Definition Of An Empire

An empire is an extension of political rule by one people over and it is categorized by the way it is established and maintained. There are two major ways an empire is acquired; the first is called â€Å"hegemony†. If an empire is brought forth by hegemony, the subjects willingly accept the new leadership. This is done peacefully and without the use of force. The conquered are usually better off with the new form of government, which is why they accept. The other way of acquiring an empire is the use of force, which is called â€Å"dominance†. If a empire forms using this technique, the subjects have been forcefully overthrown by the use or threat of military force. The overthrown people reject the foreign rule and are despondent to the idea of a new governance. The Persian empire was built through the use of dominance. Cyrus The Great forcefully spread the reaches of his empire using military force. Up until Cyrus, no culture or individual had ever really thought this one up. Territorial conquests, like monarchical power, were justified on religious grounds, but these religious grounds never gave rise to the notion that one's religious duty was to conquer the whole entire world. Cyrus had conquered all of Persia and defeated the Medes for control of the region. He soon conquered Lydia in Asia Minor, Babylon in 539 BC and, by the time he died in 529 BC, he had conquered a vast territory- in fact, he probably was the greatest conqueror in human history. Although the internal structure of the Persian imperial government was somewhat shaky, the conquests and fire for conquest continued after Cyrus's death. His son, Cambyses, conquered Egypt in 525 BC, but the Chaldeans revolted in Mesopotamia and the Medes revolted east of the Tigris. Camby ses's son, Darius I (reigned 522-486 BC), or Darius the Great, quelled the Chaldeans and Medes and worked on firming up the state. His great innovation was to divide the huge empire into more ... Free Essays on Definition Of An Empire Free Essays on Definition Of An Empire An empire is an extension of political rule by one people over and it is categorized by the way it is established and maintained. There are two major ways an empire is acquired; the first is called â€Å"hegemony†. If an empire is brought forth by hegemony, the subjects willingly accept the new leadership. This is done peacefully and without the use of force. The conquered are usually better off with the new form of government, which is why they accept. The other way of acquiring an empire is the use of force, which is called â€Å"dominance†. If a empire forms using this technique, the subjects have been forcefully overthrown by the use or threat of military force. The overthrown people reject the foreign rule and are despondent to the idea of a new governance. The Persian empire was built through the use of dominance. Cyrus The Great forcefully spread the reaches of his empire using military force. Up until Cyrus, no culture or individual had ever really thought this one up. Territorial conquests, like monarchical power, were justified on religious grounds, but these religious grounds never gave rise to the notion that one's religious duty was to conquer the whole entire world. Cyrus had conquered all of Persia and defeated the Medes for control of the region. He soon conquered Lydia in Asia Minor, Babylon in 539 BC and, by the time he died in 529 BC, he had conquered a vast territory- in fact, he probably was the greatest conqueror in human history. Although the internal structure of the Persian imperial government was somewhat shaky, the conquests and fire for conquest continued after Cyrus's death. His son, Cambyses, conquered Egypt in 525 BC, but the Chaldeans revolted in Mesopotamia and the Medes revolted east of the Tigris. Camby ses's son, Darius I (reigned 522-486 BC), or Darius the Great, quelled the Chaldeans and Medes and worked on firming up the state. His great innovation was to divide the huge empire into more ...

Essay on FNAR 132 Group Lesson Plan

Essay on FNAR 132 Group Lesson Plan Essay on FNAR 132 Group Lesson Plan Subject Math Grade Level K Common Core Standard: CCSS.Math.Content.K.CC.A.3 Write numbers from 0 to 20. Represent a number of objects with a written numeral 0-20 (with 0 representing a count of no objects). Instructional Objective: After listening to and singing the â€Å"Counting Down by Twenty† song and making a numerical visual aid, students will be able to identify numbers 0-20 and put objects in sequential order with 90% accuracy. Materials/Equipment: Counting Down By Twenty Song by: Have Fun Teaching Colored Construction Paper Squares Blocks Glue Sticks Crayons Markers Colored Pencils Introductory Activities: Assess the students’ prior knowledge of counting to twenty and the concept of associating number and objects. Ask students questions for their participation. â€Å"Who can count to twenty? Let’s go around our circle and count.† â€Å"Today we will be learning to county to twenty and how to illustrate each number using colored squares.† Core Activities: Direct Instruction: Teacher will demonstrate how to count with numbers using objects. ‘Counting doesn't only involve saying numbers, it also involves using objects. Today we will be using our counting blocks to illustrate different numbers. Let's start with one. Here is one block that represents the number one.† Guided Practice: After the discussion and demonstration, inform students about the â€Å"Counting Down by Twenty song† and the movement that accompanies the song. Teach students the basic hand movements and words that accompany the song. Go over the movements two to three times until the class masters them. Then perform the song. ‘To help us learn more about counting to twenty, I’m going to share with you all a fun song and dance. Let’s start by standing straight. We will count backwards from twenty to one and then we'll dance. Let’s perform.’ Independent Practice: Have class break up into groups and assign each group a

Looking At Globalization And The Effect On Cultures Religion Essay Example

Looking At Globalization And The Effect On Cultures Religion Essay Example Looking At Globalization And The Effect On Cultures Religion Essay Looking At Globalization And The Effect On Cultures Religion Essay With the coming of globalisation and vanishing of boundaries between the states, it is really common to see people from assorted geographicss, civilizations coming down and working or analyzing. It is a common scenario even at a work topographic point or a college where we can descry people from assorted states interacting with each other, making concerns, analyzing or being portion of each other s life in a large manner. Before traveling in front and depicting about my experiences let s seek specifying cultural and its importance at workplace. Culture could be defined anything related to art, civilization, life style, music, etc associating to a peculiar community or a group of people populating together or holding and following the same set of beliefs. Now looking at the importance of civilization in the workplace, it plays a really critical function. Cultural defines the values, the beliefs of the persons or a community, even their twenty-four hours to twenty-four hours behaviour is influenced by it. So it has a direct impact on their on the job manner and relationships with people at workplace, their behaviour at workplace, etc. Now when we talk about this, we should besides see the organisation civilization and its impact on the person. Of class, the organisation or the establishment plays a important function in determining the behaviour and the civilization of the person at work topographic poi nt, now how does he suit into this is of import. By and large people opt for such organisations or establishments where they fit in on or where similar values and civilization exists. Now let us look how things are today with the coming of organisations which consists of diverse squads. But before that Lashkar-e-Taiba me portion some of my experiences One thing I was truly looking to when I decided to come to UK was to run into and interact with assorted people. But at the same clip I was really nervous. I had all kinds of uncertainties in my head besides. Would I be accepted? Would I suit into the civilization? Bing lived in India throughout my life and non interacting with anyone from outside India, I had all impressions in my caput. Even I had apprehensivenesss sing the life styles and the behaviour of the people. But after I landed in UK my perceptual experience changed a batch. I was non the lone cat who had left his state and had come down here. There were 1000s like me. And even the people were really receptive. Though I mingled with my community and state folks in the beginning, it was merely after I came into college and started working and run intoing other pupils I realized that it was non bad really. All my perceptual experiences and frights were a complete false. My first interaction was so during one of those assignments. My group had perceived me as a geek and person who would be good at mathematics so would hold by birth analytical accomplishments being an Indian. But I truly had to state them that though we have rather a good figure of the population who was good at these things back place, but I was a awful batch at mathematics. This was when we all realized how we had pre-conceived impressions about people based upon their cultural and geographical backgrounds. Like I thought, Pakistanis were a closed batch who would be tough to interact but they were as a affair of fact merely like me. Of class, people ever find comfort in people with similar involvements or similar community and background. Like for illustration, I was merely with my Indian friends for about a month after I came to UK. I was merely excessively diffident and scared to interact or do friends with any one else. And I had so many Indians that I did nt happen the demand to besides. But shortly I realized that by making so I am halting myself from spread outing my skylines in cognition besides. I got to cognize about a batch of things through my series of interactions with assorted people. Benefits of Cross-Culture Teams With the squad being more and more diverse, the thought will be different and it will ensue in truly different positions and thoughts fluxing in. The squad would non merely make consensus but truly believe of many solutions or different replies. This would promote creativeness and innovativeness. It makes the group insight effectual. Common benefits The whole squad being diverse would carry through the short approachs of each other to some extent. And besides it is a learning experience. Geting to cognize about other civilizations, linguistic communications, and people is ever interesting. Enhancement of interpersonal accomplishments. Working with such a squad, broadens your thought and you come across new avenues and positions. Brands you more adaptable to any environment and people. Continuous betterment groups with such diverseness ever inquiries, therefore doing it more and more ambitious and endeavoring to acquire the best out of the group. Sometimes people in homogeneous groups do non take part much believing everyone thinks the same. But in such instances relatively the engagement degrees of the group is high. Because everyone bring in a different thought and position before the group. If I have to speak about my experiences, good I must state I have gained vastly. At first I used to be soundless and non-participative. But now I feel I can pour in really of import points because I think really otherwise from the remainder of the group, so I bring in a different set of thought. This really benefits our treatments. I have truly developed great interpersonal accomplishments besides. Now I feel free to speak to anyone and from anyplace. I am non diffident or scared any longer. Even being in a diverse group, we use each of our single strengths and unite them to organize the strengths of the group. For illustration, one of my squad members is good at placing and roll uping the information, I am good at analysing it, some one else is good at showing it and the other at placing mistakes. So all these strengths are combined together so that we eventually present the chef-doeuvre. Problems faced with cross-culture squads Language: This is one of the major issues. Though English has emerged as the common International linguistic communication but there is a batch of difference in British English and American and of class Indian. Even the pronunciation and the spoken linguistic communication differ a batch. This can sometimes do miscommunication. Language barriers can besides take to non-participation or inability to show thoughts freely. Apart from verbal and written communicating, a major portion of communicating happens through Non-verbal communicating. Now across assorted civilizations we have different communicating manners and besides different significances to certain things. Now it is highly of import to better cognize before we communicate anything as others might acquire pained if we do non understand decently. Cultural clangs Sometimes, there can be a entire clang in the civilizations and their beliefs. Such things should be handled decently and non merely ignored. Time this is a really of import factor while working in groups. The attitude of the squad members towards clip is really of import. Sometimes few of them group members emphasize on clip a batch but others do non see it that of import or neglect it because of their old beliefs and patterns. This could take to a struggle of involvement. Pre-conceptions and stereotypes: Peoples have a batch of preconceived impressions in their heads sing people from some civilizations and topographic points. Now that could be wholly incorrect. The individual might be wholly different. So it is non good to judge anyone merely because they belong to a civilization or a location. Difference in executing of work. False Consensus consequence: Sometimes people think that others besides think precisely like them or they feel that everyone would hold the same set of beliefs. Wayss to get the better of troubles faced when working in an international squad Effective communicating: This is one of the most of import facets. The members should look into if their points are decently understood. And look into for any miscommunication. Adhere to certain regulations, which can be framed consequently, so that everyone sticks to it. For illustration, we talked about the importance of clip. Now its better if the group decided that clip has a batch of importance and no 1 is late for the meetings, etc. Having a planetary mentality ever helps instead than transporting those old beliefs to the group. Every member of the group should workout on their strengths and failing so that we can work out of the overall strengths and failing. Avoiding prepossessions and stereotypes The whole energy of diverseness is good if used positively and for the improvement of the group. But we have to be careful and avoid any negativeness or struggles. Now allow me come to my personal experiences. I have already mentioned about the benefits I had got working with such a group. But I excessively faced many jobs. Like for illustration, in the beginning I was non so good at understanding the linguistic communication. Though I had learnt English throughout my instruction in India, but sometimes the degree of vocabulary and the pronunciation was really hard to hold on in the beginning and I used to sound amusing with my Indian speech pattern. Those were my tough times when I sometimes kept shut so that I do nt abash myself or even I did nt understood anything I would non reiterate it. But so of class during the class of clip, things settle down. There was a similar experience with clip. Bing a lazy Indian, I was non used to the promptness in my school or college. Back place it was a kind of a relaxed environment. But here every 2nd counts, hence I had to truly alter myself to accommodate to the current values and beliefs of the group. One of the effectual ways of get the better ofing such jobs is by increasing the Cultural Intelligence of the squad members. Now what is this Cultural Intelligence? It is seeking to understand other s behaviour and seeking to understand his values and beliefs so that to interact with him in a manner he is comfy. Peoples can be classified into 6 classs of Cultural Intelligence: The Provincial: Such individual is effectual merely when working with people from a similar civilization and background of his ain. Lacks the ability to work with others. The Analyst: He is the individual, who would analyse the civilization of his fellow mate and seek to acquire the strengths and frame schemes consequently. The Natural: Relies wholly on intuition and is non interested in analysing or larning new beliefs and about new civilizations. The Ambassador: He is nice and friendly. Though he is non cognizant much about the people or persons from other civilizations and backgrounds, but he is confident he can manage them. The Mimic: He gels in really good and has enormous assurance and he knows he will suit into the function. The Chameleon: Changes his colourss consequently. He is sometimes even baffled about his beginning. He fits into really absolutely. Now the work would be sorting all the members into the above class and work out how to manage them. Decision We have seen through this paper and through the penetrations and experiences of the writer about the cross-culture squads and their benefits and challenges. But these yearss, with the coming of globalisation such squads are ineluctable. Hence, we should work to get the better of the challenges and utilize the strengths of the persons to construct up the strengths of the squad. It is of import to truly understand persons and their civilizations and work consequently so that there is no miscommunication or struggle.

Peasant Life in Elizabethan England Research Paper

Peasant Life in Elizabethan England - Research Paper Example The neediness hit individuals made due with constrained assets and were drained by the rich in each and every condition receptive. Religion was a key part of life in the lives of the individuals in the Elizabethan period with Roman Catholic as the prevailing religion. This paper focuses on the lives of the peasants inside the Elizabethan time of time. Religion was a key part of the Elizabethan life. The Church was the wellspring of both assistance and treachery for poor people. The Justice of Peace (Jps) were assessment authorities profited in every ward that gathered a duty from the individuals who claimed land in the area. It was known as the Poor Rate and was utilized to help poor people (Mcginnis 203). The Poor Rate had two functions in the social order. First and foremost, it made the poor feel that something was being ruined them and made them feel less furious about the neediness. Besides, some great work could be carried out by the poor inside the area to help that ward. Along these lines, the Justice of Peace went about as administrators of the poor throughout the Elizabethan period. The poor were sorted into three aggregations by the administration. To start with, there were the defenseless poor (Mortimer 26). This assembly incorporated the old, the debilitated, the disabled and the stranded youngsters. Seniors and the crippled had been given a differing measure of cash and sustenance proportions on week after week foundation. At whatever point they were unable to gather their endowments, they could be transported to their living arrangement. Poor youngsters got an extraordinary apprenticeship secured due to the ward. In this way, the ward profited from the free work until the youngster became a mature person and deduce new dexterity. The powerless poor were not viewed as a trouble to the legislature. Ordinarily, the wards offered them the permit to ask (Claments). The second classes were distinguished as the capable poor. These people were

Mass Extinction Essay Example | Topics and Well Written Essays - 1000 words

Mass Extinction - Essay Example I think that this is the possible reason why Douglas Erwin said it is quite difficult to identify which is the real cause of the mass extinction in the past. There are these many factors that contribute; they are all giving different degrees of impact to the environment, which the scientists need to delve into each to know the actual influencing degree. The world population is growing exponentially but the land is so limited. Humans exploit virgin land, like the jungle and mountains. They cut down the jungle and make the mountains flat to make houses and farmland. The equivalence of the whole ecosystem is disturbed. Firstly the flora and fauna in the wild lost their habitat. They cannot even find food that they used to get. As a result, this leads to wildlife extinction. Loss of soil due to loss of plants also caused the river- and seabeds to become shallow. This is obvious with the increase of sea water level. The situation becomes worse when the pole's glacier starts melting due to greenhouse effect! Eventually, the increasingly warming atmosphere triggered the people's interest to study the global warming phenomena. This is how the greenhouse effect situation was discovered. It is estimated that about 15 to 37 per cent of the species will become extinct from now to 2050 if the climate keep on changing (Kirby, 2004). The causes of global warming were identified: excretion of greenhouse gases like carbon dioxide, water vapor and methane, use of aerosol products and depletion of jungle land and ozone layer. Carbon dioxide and methane will trap heat in the atmosphere. They are the by products from the use of fuel energy. Meantime, depletion of jungle land reduces the number of green plants that can convert... The world population is growing exponentially but the land is so limited. Humans exploit the virgin land, like the jungle and mountains. They cut down the jungle and make the mountains flat to make houses and farmland. The equivalence of the whole ecosystem is disturbed. Firstly the flora and fauna in the wild lost their habitat. They cannot even find food that they used to get. As a result, this leads to wildlife extinction. Loss of soil due to loss of plants also caused the river- and seabeds to become shallow. This is obvious with the increase of sea water level. The situation becomes worse when the pole’s glacier starts melting due to greenhouse effect! Eventually, the increasingly warming atmosphere triggered the people’s interest to study the global warming phenomena. This is how the greenhouse effect situation was discovered. It is estimated that about 15 to 37 percent of the species will become extinct from now to 2050 if the climate keeps on changing. The causes of global warming were identified: excretion of greenhouse gases like carbon dioxide, water vapor, and methane, use of aerosol products and depletion of jungle land and the ozone layer. Carbon dioxide and methane will trap heat in the atmosphere. They are the by-products from the use of fuel energy. Meantime, depletion of jungle land reduces the number of green plants that can convert the carbon dioxide gases back to oxygen. The increase of methane gave the similar effect to the environment, methane plays an important role in the previous mass extinction.

Shakespeare's life Research Paper Example | Topics and Well Written Essays - 1500 words

Shakespeare's life - Research Paper Example Speaking about the personal history of the Shakespeare himself, we cannot state the precise date of his birth, because only according to the information from the church archives we can know that Shakespeare was baptized on April 26, 1564. He lived in Stratford-upon-Avon. Some details about the origin of legendary playwright we can take from his plays, sonnets, and other poems, however, more light can shed official documentation. However, they provide only very brief sketches of the important events of the Shakespeare’s life. From the official documents comes the information that the Shakespeare was baptized at the Holy Trinity Church in Stratford-upon-Avon. From this moment many people consider the beginning of the Shakespeare life. On November 28, 1582, in Worcester, in Canterbury Province, William Shakespeare married Anne Hathaway. Hathaway was from Shottery, it was small village a mile west of Stratford. William was 18 and Anne was 26, and, she was pregnant. Their first child, a daughter they named Susanna, was born on May 26, 1583. Then, after two years they had twins, Hamnet and Judith. However, Hamnet died of unknown causes when she was eleven. Then the history of records ends and seven years considered to be the â€Å"lost years†. These years are undocumented and there are much information from various sources regarding this hidden period of time. Some of them tell that Shakespeare has gone into hiding from the local landlord. Another possibility that Shakespeare could work as an assistant to the schoolmaster of the Lancashire.

Infulence of particpation in strategic change; resistance, Annotated Bibliography

Infulence of particpation in strategic change; resistance, organization commitment and goal achievement - Annotated Bibliography Example The article examines how the right to reject a decision on resistance to change, change goal achievement, and post change commitment to the organization; and consultative participation are related. Lines, in testing his hypotheses, opted to include the option of rejecting a proposed change since may assist in capturing instances where organizations forego changes that they deem optimal because from the change recipient perspective, they are not acceptable. Additionally, Lines used a set of three variables that represented outcomes, which allowed for a comprehensive assessment of whether a strategy implementation is complete or not. He tries to establish whether the effects of participation are dependent on the context in which an approach is applied by focusing on the extent to which change is: compatible to organizational culture, expected to lead to less or more job variety, and expected to lower costs. The finding of the study indicated that existence of positive relationship between participation and organizational commitment and goal achievement. The findings showed that a strong negative relationship exists between participation and resistance to change and that the personal goals of recipients and the compatibility of changes with the culture of the organization moderated the effects of participation. I picked Mowday et al., (1979) because it offered a lot of insight with regards to the compatibility of change with the organizational culture and the recipients’’ acceptance of the values and beliefs of the organization. I also picked Porter et al, (1974) as an influential article because it offered more insight into assessing post change organizational commitment, and how it is affected by participation. The article by Hackman and Oldham (1975) was influential in the interpretation of the study’s results, especially with regards to

Personal Assessment and Worldview Concerning Christianity Essay

Personal Assessment and Worldview Concerning Christianity - Essay Example For decades, most Christian social workers have strived to enhance social prominence so as to gain substantial recognition and publicity. Isaiah and Jesus, as depicted in the Biblical Scriptures, advised their followers to worship God in conjunction with the provision of service to God’s creation. According to their message, worship involves some activities such as breaking bread with the hungry, treating employees fairly, inviting into our homes the helpless, and embracing a life of personal righteousness.For decades, most Christian social workers have strived to enhance social prominence so as to gain substantial recognition and publicity. Isaiah and Jesus, as depicted in the Biblical Scriptures, advised their followers to worship God in conjunction with the provision of service to God’s creation. According to their message, worship involves some activities such as breaking bread with the hungry, treating employees fairly, inviting into our homes the helpless, and emb racing a life of personal righteousness.Politically, Christians should not distinguish themselves from other people by country or customs. One of the Christian philosophies states that any individual involved in the material history represents another order or master other than God. Hence, Christians have to engage themselves in political issues so as to influence the world, with no intentions of making the world a paradise, but to minimize the opposition of the world against the Kingdom of God.

Infulence of particpation in strategic change; resistance, Annotated Bibliography

Infulence of particpation in strategic change; resistance, organization commitment and goal achievement - Annotated Bibliography Example The article examines how the right to reject a decision on resistance to change, change goal achievement, and post change commitment to the organization; and consultative participation are related. Lines, in testing his hypotheses, opted to include the option of rejecting a proposed change since may assist in capturing instances where organizations forego changes that they deem optimal because from the change recipient perspective, they are not acceptable. Additionally, Lines used a set of three variables that represented outcomes, which allowed for a comprehensive assessment of whether a strategy implementation is complete or not. He tries to establish whether the effects of participation are dependent on the context in which an approach is applied by focusing on the extent to which change is: compatible to organizational culture, expected to lead to less or more job variety, and expected to lower costs. The finding of the study indicated that existence of positive relationship between participation and organizational commitment and goal achievement. The findings showed that a strong negative relationship exists between participation and resistance to change and that the personal goals of recipients and the compatibility of changes with the culture of the organization moderated the effects of participation. I picked Mowday et al., (1979) because it offered a lot of insight with regards to the compatibility of change with the organizational culture and the recipients’’ acceptance of the values and beliefs of the organization. I also picked Porter et al, (1974) as an influential article because it offered more insight into assessing post change organizational commitment, and how it is affected by participation. The article by Hackman and Oldham (1975) was influential in the interpretation of the study’s results, especially with regards to

See the attachment Essay Example | Topics and Well Written Essays - 500 words - 2

See the attachment - Essay Example In the 2005 ranking of poverty stricken countries by the United Nations, Kenya was position 154 out of 177countries.There are several factors that cause poverty in Kenya (Hughes, 2009). For instance, limited economic diversity most of the people in Kenya do depend on the agricultural industry yet an unstable sector because of weather changes. Most rural dwellers do depend on their substance farming for both monetary incomes as well as for their food. Jobs are less available living people with scarce opportunities. School fee is out of reach for poor families. It leaves many looking for a less productive job. According to research done by transparency international, Kenya is among the most corrupt country. Unequal distribution of resources favoritism, bribes and tribalism are some of the factors that contribute to poverty levels since most resources are not accessed. Several actions have been developed to help reduce poverty in the country (Asadi et al., 2008). An example is the introduction of free primary education by the Kibakis government. This medium tends to promote development. The government is also trying to ensure people in rural areas access health care services. Dispensaries are built in different places in villages. In addition to this, there is a ‘Kazi Kwa vijana’ initiative for job creation that ensures the government creates jobs for the youth. This is done by the provision of Uwezo funds to help the young people to start a business, as well as farming projects. The situation of poverty in my country can be improved by providing free business education and training especially to youths. The government should also provide loans for micro-business projects. There should be Equal allocation and distribution of resources. Provision of equal opportunities in the business sector harmonizes the poor and the rich. There were 192 nations represented in the seminar Kenya included. During the seminar, we had several presentations on

Assignment 1 Essay Example for Free

Assignment 1 Essay Professor Identify the pros and cons of the partnership as a form of ownership. Discuss funding options for small businesses. Determine and discuss how managerial accounting can help managers with product costing, incremental analysis and budgeting. Discuss the basic components of the marketing process using a product or service of your choice as an example. Discuss the roles of social responsibility and technology in the marketing function. A partnership as a form of ownership is formed quite simply. When two or more people get together and come to an agreement on what type of business to take part in, then all parties share investment, profit, and of course loss. Lets discuss the pros and cons ofa partnership. Pros, one of the many things all investors would like to see out weight the cons in anything they are engaged in mentally, physically, and of course financially. First of all, one pro would be how easy it is to create a partnership. You simply get with at least one other person come to an agreement over all the business details, and BAM you have a partnership. Some people are comfortable in erbal agreements but I personally would suggest you get all your partnership details on a written legal document Just in case. Funding is another advantage toa partnership. When two or more people come together to form a business partnership money is invested from all parties involved in turn the business has a stronger financial backing to support it. Not only will the business have a strong financial backing all partners invested may have access to outside money to support the business even further along. One of the best advantages in being in a business partnership is shared responsibility. Shared responsibility is crucial in a successful business and of course partnership. When the business starts to get a bit heavy you can hand it to your partner or partners to carry the work load for a while. You can also look to your partners for moral support when you may think things arent going as stated in your business plan. So far we have heard the pros ofa business partnership but like every bandage that fixes that painful spot you eventually have to pull it off. Cons, the opposite of Pro, the many things that all business investors need to know before investing but never want to hear. You may be thinking since it was a breeze to create this business partnership the rest will come as a breeze. You could your mind; everyone who is a partner is liable for all debts. You and your partners are all Jointly or individually liable for all debts accumulated by the business. For example, lets say your partner or partners are taking the profits the business is making and gambling with it. Your partners blow away all the profits on poker games and skip town what then, thats right you are still liable for any debt accumulated by the business. Another obvious con is your business partners will want to share the rofits made by the business. You cant assume when the business makes profit everyone will agree on saving it. Your partner or partners may want to buy cars, houses, or maybe boats. You dont have total control of the business. Business decisions are made Jointly not on your own. You may run into disagreements that in turn create the other partner to leave the business, or even lead to buying out the other partner. Pros and cons are a great way to see if youre the, partner type, if so make sure you pick the right partner or partners for your business. There are many ther factors in owning and running a business. For example, in order to get your business off the ground you have to find the money to do so. Debt financing is one way you can start up your business. Debt financing is simply going to a bank that knows you have good credit, a good standing history with them, and apply for a small business loan. In the current economy most banks can be very hesitant to offer you the loan so another way is equity. Selling a share of your business meaning you arent solely in charge or will now be sharing the profits may be scary, but it can help you start up your business. After starting up your business you now have to manage the business or appoint someone for the Job. Managing the accounting is a great way to stay on top of product cost, and budgeting. Managerial accounting is detailed data used for inside members of a company. Managerial accounting includes things like cost of the product, cost of shipping, cost of employee benefits, cost of turnover, basically every number available to you and your partners. You can determine if you have the budget to raise wages for your employees to boost employee morale. Each business owner can use the data to do their Job better. You can go to your losses data and determine if your employees are stealing from you. Then determine how much more security you will need in order to prevent product loss. If you or your manager for your business needs to determine if their product was set at the right price they could view the sales data to see if the supply met the demand. If you see that one of your items hasnt been selling very well you can set it at a lower price or you can Just order less of such product. If you see you sold a lot of a particular product you can raise the price as you see fit. You now know if you are the partner ype, you know a couple ways to possibly fund your business, and you know how to manage your data and budget. How are you going to get costumers through your door or buying your product? How will you market yourself? Lets use my dream business as an example. I would like to open up a caf © lounge that serves fair trade coffee, craft beer, and fine wines. In order for me to make any kind of better profit for my business I have to market my business. You have to give the people what they want in my case I would produce amazing cups of coffee. My business would offer a coffee with better taste, and appeal. My coffee would be made with love and not thrown at you in the pickup line simultaneously saying, NEXT. My caf © lounge would major downtown street. Location is important for my caf © lounge so doing a little research of the area by visiting throughout all times of the day to see the amount of traffic the area receives is crucial. Then maybe you can ask around the nearby stores to see if customers purchase a lot of coffee. You can even go to the nearest coffee shop and see what coffee and vibe they offer and simply ask the locals what kind of coffee they like or would like to drink in what kind of atmosphere. After finding your target market, a great location, building your business, affordable product pricing, and setting your hours of operation it is time to promote your business. You can put ads in the local newspaper, ads in local magazines, and maybe even do a commercial broadcast in the tri county area. You will have to set your product apart from all the other competitors. For me coffee is all about personality, process, and taste. In order to retain customers your employees have to be personable, professional, and building customer relationships. Then theres process, customers will see you make heir drink every step of the way making it an enjoyable experience. Lastly is taste, my employees being highly trained baristas will make you a drink to your satisfaction in a timely fashion all the while maintaining a welcoming atmosphere for my caf © lounge. Having the best tasting coffee and vibe may do Justice but for long term business it may not be enough this is when you bring in the events. Doing special events with your business such as charities, open mic nights, acoustic Jam sessions, and book clubs is a great way to attract more customers and maintain current ones. Internet is your best friend. Creating a website for your business is an amazing marketing play. It allows your customers to have 2417 access to information, and product choices. You can post updates on new product arrivals, special events, and specific information for each product you offer. The best part about having a website is they can look you up anywhere in the world that offers internet. Another great marketing strategy is purchasing ad space on other websites like a grocery franchise or sports sites. Green marketing is another great way to market your business. Customers love knowing your business is eco friendly by recycling, or using recycled aterial. By simply pushing customers to buy coffee to drink in house rather than take away conserves paper cups in turn less garbage. If customers choose to take to go anyways inform the customers all your paper products are recycled and recyclable. Offering organic treats to eat along with their coffee can promote a green business as well. In the end knowing everything there is to build, manage, and market your business your goal is to have long term profitability. You want to exceed customer satisfaction, you want to blow away the competition, and be prepared for even harder competition in the future.

Facebook: A Useful Communication Tool

Facebook: A Useful Communication Tool This report provides an analysis about Facebook, which has become an important source of communication now days. The report starts with an introduction of Facebook, history of Facebook and its importance now days. The report then moves on the use of the social network as a communication tool, entertainment, business and information. The report also tells about the usage of Facebook among different people of different regions and different ages. The report then covers the main advantages and disadvantages of Facebook and then finally discusses how to make the usage of Facebook limited and safe. 1.0 Introduction A social network is defined as an internet based service that allows its users to create a public or private profile in which they could list their personal details, hobbies, relationships and share it with people they want to share their personal details with. Most popular social networks now days are Facebook, Twitter, Linked in, My Space and Google Plus. This research is carried out to provide information about Facebook, the importance of Facebook now days and to mention advantages and disadvantages of Facebook. Facebook was found on 4th February 2004 by a teenage boy Mark Zuckerberg in Stanford. The companys first name was thefacebook.com, after a month company shifted its platform of functions to Florida and Palo Alta. The company bought its name Facebook from the website Facebook.com in 2005 for $200,000. After 8 years Facebook has become one of the most famous website on the internet, even from a school boy to a busy business man everybody seems to be addicted to Facebook. Thi s research tells us about the use of Facebook by different people of different ages and regions. People of different ages use Facebook for different purposes children and teenagers mostly use this network for communication and entertainment, Business men use this for multiple purposes such as communication, information, and marketing and also as an entertainment. According to research carried out Facebook is used in every country of the world. The report then finally discusses what problems have risen as a result of excess use of Facebook and its effect on International media and daily life of people. 2.0 Importance of Facebook now days: According to this research Facebook is a lawful activity in every country of the world, and from a small child to a busy professional business man Facebook is an addiction to all of them. Facebook has become a part of daily routine of people and for some people part of their hourly routine, people of all ages use Facebook for following different purposes. 2.1 Communication: The main purpose of this social network is communication; the main logo of Facebook is connect and share with the people in your life. Facebook allows its users to chat, talk and share their daily life activities with their friends and family. 2.2 Entertainment Due to the advance features of this network entertainment has become as equal purpose as communication; as a member logs into his Facebook account his attention is readily diverted towards different entertainment stuff like time line applications, online game applications, picture jokes, funny videos and other interesting content. 2.3 Source of Earning Facebook is also used as a source of earning by people i.e. Facebook is one of the most visited websites on internet so it is an excellent website for advertisement and offers about brands and products, therefore Facebook is also used for marketing of business and hence it assists people in earning money. 2.4 Data Storage and Information Some people also use Facebook as data storage i.e. to store their memorable photos and videos on internet as in case their compute data gets corrupt or lost. Facebook is also sometimes used to obtain information about famous people, locations, cultures and events. Facebook also keeps people up to date about the world. 3.0 Usage of Facebook by people of different ages and different regions According to the research carried out Facebook population is made up of Millions of people around the globe. As compared to males, females lead the population on Facebook; young adults aged 18 to 25, possess the most population of the Facebook due to their interests in chatting, entertainment, cyber dating and other youth stuff. After this age sector Facebook is heavily populated from people aged 26 to 34, due to the same interests as of young adults. The rest of the population is covered by people of different ages including children and people over 45. Coming to the regional statics of Facebook usage, Facebook is a lawful activity in every country of the world. America has the most Facebook users of the world, Brazil has the second most users of Facebook in the World and third country with most Facebook users is India. Ireland possesses 59th position in relevance to the Facebook population. All these statistics show that Facebook is huge and on the present day it is the most popula r social network and one of the most visited website on internet. 4.0 Advantages and disadvantages of Facebook: Today the world has become a place of instant communication with the help of social networks like Facebook, twitter, Google plus etc. and by other means of communication like emails and telephones. Facebook is the most popular social network on internet and its use is rapidly increasing, according to research carried out Facebook is the most popular communication tool used, followed by SMS and email. Facebook is the most popular social network in the world, with over 350 million users, so it should come as no surprise to discover that people are using it as a primary tool for communication, said Hazel Butters, CEO of Prompt Communications. As far as communication and sharing Facebook is considered as an excellent tool, but problems arise when Facebook becomes an addiction. Facebook has become a part of daily routine of people and for some people part of their hourly routine and hence they are moving away from their daily healthy activities by spending hours on Facebook. Teens especially are being accused of constantly logged in their account, some specialists narrate that this develops social skills in them which are essential in practical life. But other people believe that this disturbs their studies and their healthy outdoor activities. Privacy is another issue with Facebook, although the social network offers the users full control of their private information still there is insecurity with many different features of Facebook, also hacking is another threat for users, if some account gets hacked all the personal details and stuff of the user will be leaked. Another drawback of Facebook is fraud and fake accounts, a ccording to the stats 83 million accounts on Facebook are fake or duplicate, this creates a lot of confusion among the users e.g. people may not be talking or sharing their details with the person they think they actually are, sometimes people are fooled into funding or sharing money for the name of some well-known company or fund raisers by fake accounts. Facebook an incredible place for young boys and girls in relevance of dating sometimes becomes a goldmine for identity theft and dating Sometimes people are in love with person they dont even know that exists or not. Cyber bullying is another major problem with Facebook, people often criticize others on Facebook and sometimes a group targets an individual and insult the person in front of their friends or even family. This causes mental stress to people, makes them victim of complex and diverts their attention from their carrier or studies. With all these problems it is hard decided that Facebook is a beneficial or not, but inste ad of criticizing a solution should be found. Facebook was found for communication and entertainment purpose so it should be kept that way, Facebook should not be taken as an addiction and there should be a small time period for it. Facebook should not be preferred over studies, outdoor activities or work. Moral Values should be followed on Facebook one must not abuse somebodys privacy, should not cheat anybody on Facebook or criticize any other person on Facebook. This way we can make Facebook beneficial. 5.0 Conclusion: The research carried out tells us that Facebook has become an important part of our lives by means of communication, entertainment and business all around the globe, but it is misused by people and therefore it is losing its reputation. But instead of walking out from Facebook it should be used properly to avoid the loss of a very useful communication and entertainment tool. Contents Geekosystem.com, 2012, to prove a point dating site steals 250,000 profiles on Facebook, 2012, http://www.geekosystem.com/dating-site-stole-facebook-profiles/, accessed on 25/11/2012. Katin Rogers, 2012, Facebook users raise privacy concerns as company tweaks security settings, 15/10/2012, http://www.guardian.co.uk/technology/2012/oct/15/facebook-users-privacy-concerns-security, accessed on 25/11/2012. Social Bakers, 2012, Facebook Statistics, 2012, http://www.socialbakers.com/facebook-statistics, accessed on 25/11/2012. History of Facebook, 2012, History of Facebook, 2012, http://www.historyoffacebook.com/, accessed on 25/11/2012. Mike Sachoff, 2009, Survey found Facebook most useful communication tool, 11/12/2009, http://www.webpronews.com/survey-finds-facebook-most-popular-communication-tool-2009-12, accessed on 25/11/2012.

Leonardo Da Vinci :: essays research papers

It was the period of the renaissance when Leonardo da Vinci was born on April 15, 1452. Leonardo was born a farmhouse in Anchiano, which is 2 Â ½ miles away from Vinci. The family of Leonardo lived in this area since the 13th century. The father of Leonardo da Vinci, Ser Piero, was 25 years old; he was a public notary when Leonardo was born. The mother of Leonardo was called Catarina. Her first name is all what is known today. The Baptismal chapel in Vinci is where Leonardo was christened. Leonardo was christened from the name Piero da Bartholomew to the name Lionardo not Leonardo. The chapel is inside the church of Vinci. The church beside the castle of Vinci are formed the skyline of his town. Leonardo lived in Anchiano for five years until he settled to Vinci. Vinci is a small town, placed at the foot of Monte Albano. From this time he was member of his fathers family, but he was never considered born to his mother and father. In Vinci Leonardo went to school. It was told that teachers of Leonardo da Vinci were despaired about all the questions and doubts of Leonardo. Leonardo learned at school to read write and mathematics. He also learned geometry and Latin. Later Leonardo tried to improve his knowledge in Latin, because he thought that he didn't learn enough Latin in school. This may be the reason why Leonardo did his notes in Italian. Leonardo lived in Vinci until 1466. With the age of 14 Leonardo moved to Florence where he began to work in the workshop of Verrocchio. Verrocchio was at this time the most gifted artist in Florence. He was a sculptor, painter, goldsmith, bronze caster and more. Verrocchio had a lot of influence on Leonardo. Verrocchio was fascinated by the drawings of Leonardo so he gave him a place in his workshop. Leonardo worked at the workshop of Verrocchio with some other famous artists like Botticelli. Leonardo started working with mixing of colors and then he painted simple parts of paintings. There are no works of Leonardo known between 1466 and 1472, but Leonardo taught himself to paint in oils at this time. In June 1472 Leonardo was listed in the red book of painters from Florence. With the membership in the painters’ guild of Florence ended the apprenticeship of Leonardo.

Courtship Violence :: essays research papers fc

Courtship Violence The term courtship violence refers to a couple’s interaction with emotional commitment with or without sexual intimacy. Dating violence involves the perpetration or threat of an act of physical violence by at least one member of an unmarried couple on the other within the context of the dating process (Barnett, Miller-Perrin, Perrin 163). The study of dating violence is important for two reasons. First, such behavior often results in physical and emotional injury. Second, there is reason to believe that dating violence is often a precursor to spousal abuse. Many battered women report that they were first assaulted by their husbands during courtship (Simons 467). Women, more than men, appear to bear the brunt of courtship violence. Despite the fact that rates of partner abuse by males and females are similar, women report more injuries and a greater negative impact as a result of their male partners’ physical aggression (Ronfeldt 72). Studies consistently show that it is women who are disproportionately likely to sustain serious injury. Some significant negative consequences are emotional harm, feelings of victimization, and fear of further violence (Barnett, Miller-Perrin, Perrin 164). The most popular explanation for dating violence is that it is a learned behavior acquired in the family origin. Witnessing parents’ marital aggression or being the victim of harsh corporal punishment may greatly increase the chances that a child will grow up to use violence in a dating relationship (Simons 468). There is a substantial body of evidence suggesting that violence in the family is a risk factor for the perpetration of partner abuse. Men who witnessed interparental violence were three times more likely to hit their wives than men who did not (Ronfeldt 72). Men who witnessed their fathers hitting their mothers were more likely to approve of violence against women and to abuse their own partner. Those growing up in a violent home were more likely to move from verbal to physical aggression. Witnessing paternal marital violence would moderate the association between psychologically controlling behaviors and physical violence so that the association would be stronger for individuals who had witnessed paternal marital violence (Ronfeldt 73). Researchers usually specify observational learning as the process whereby parents influence the probability that their children will be violent in intimate relationships. Some describe the learning process as one of imitation; others emphasize lessons about the legitimacy of violence in intimate relationships. The imitation explanation asserts that children learn about romantic relationships by observing interactions between their parents (Simons 468).

Challenges in Pension Reform

CHALLENGES IN PENSION REFORM A RESEARCH PROJECT SUBMITTED TO THE FACULTY OF NATIONAL UNIVERSITY IN PARTIAL FULFILLMENT OF THE REQUIREMENTS FOR THE DEGREE OF MASTER OF PUBLIC ADMINISTRATION NOVEMBER 2012 By James Michael Sandburg Capstone Project Faculty Advisor Gary Geiler CAPSTONE PROJECT APPROVAL FORM I certify that I have read the Project of James Michael Sandburg entitled Challenges in Pension Reform, and that, in my opinion, it is satisfactory in scope and quality for the degree of Master of Public Administration at National University. Approved by: ___________________________________________________________________ Gary GeilerDate ABSTRACT The purpose of this study is to examine the challenges faced by public sector administrators as they grapple with restoring pension plans to solvency and sustainability. The objectives are to research and describe how public pension plans have become insolvent over the course of the past dozen years; to discuss legal issues that make reform d ifficult; to suggest how to involve unions in meeting the challenge of reforming pension plans through negotiation with collective bargaining units; to discuss how to chieve pension reform without violating constitutional and statutory protections; to suggest a means of paying off unfunded pension liabilities. Unfunded public sector pension liabilities has become a nationwide problem, with total unfunded liabilities totaling between 1 and 5 trillion dollars, depending upon investment return assumptions. Pension problems have plagued the City of San Diego, California, since the late 1990s. Pension reform became a key element in San Diego’s 2012 mayoral race.The prevailing candidate stood alone among three challengers, as the only one who seemed to recognize the depth of the legal implications of pension reform that will be discussed herein. The idea has become widely held that implementing public pension reform is essential to restore pension plans to financial health and sust ainability. The premise of this study is that it is possible to accomplish necessary reforms without alienating stakeholders, and without exacerbating the problem by doing further battle in the courts.In the end, pension abuses can be eliminated, sound principles of pension finance can be sustained, and the public interest can be preserved. TABLE OF CONTENTS CAPSTONE PROJECT APPROVAL FORMii ABSTRACTiii LIST OF TABLES AND FIGURESv Chapter I: Introduction7 Background7 Problem Statement10 Purpose and Objectives11 Limitations of our Study11 Summary of Remaining Chapters13 Chapter II: Pensions in Peril14 Chapter III: Social Security23 Chapter IV: Reform Propositions34 Chapter V: Legal and Constitutional Hurdles43 San Diego Pension Issues:43 ERISA Pension Reform:47 Contracts Clause:48Due Process & Takings Clause:49 The Due Process and Equal Protection Clause:49 The Eyes of a Nation May Be Upon San Diego51 Chapter VI: Union Participation53 The Meyers-Milias-Brown Act (MMBA):53 The Public E mployment Relations Board (PERB):54 Chapter VII: Pension Obligation Bonds56 Chapter VIII: Conclusions and Recommendations62 LIST OF TABLES AND FIGURES 2. 1 Illinois State Retirement System Rate of Return on Investment†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. †¦.. 16 3. 1 Summary data for 2010 and 2011†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦19 3. 2 Select Unfunded Accrued Pension Liabilities†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 29 Chapter I: Introduction Background.The life cycle in America and most developed countries is to spend the first five years learning to walk, talk, and manage our bodily processes. We then spend a dozen to 16 years gaining an education and figuring out what we want to be when we grow up. Once we determine that, some of us then need to continue with another several years of education to gain an adva nced degree or two, and learn the specialized skills of our chosen occupation. We then spend the next 30 or 40 years working 5 or 6 days a week earning a living to support our families and raise up a new generation to repeat the process.By this point we are 60 to 70 years old and ready to retire in some level of comfort and dignity, without having to work anymore – retirement and our â€Å"declining years,† they say. That lasts another dozen years, give or take a decade. The level of comfort and dignity one enjoys during those final years is measured mostly by the wealth we have managed to accumulate during the 3 or 4 decades we toiled at those chosen professions we spent so many years preparing for. For most of us, that wealth consists mainly in something modern society calls a pension.Because most of us lack the discipline, sophistication, or skills needed to set aside and invest money during our working years, the task of accumulating pension funds is left mainly up to our employers, who in turn hire highly specialized teams of people to administer those pension funds. Some of them do that extremely well; others not so much. Because not all employers offered pensions, in 1935 Congress passed legislation authorizing the federal government to tax workers and their employers, in exchange for guaranteeing a basic pension. That legislation was the Social Security Act.Social Security was never intended to replace employer-provided pensions, or to discourage workers from accumulating their own retirement funds. Rather, the intent was that Social Security would provide a guaranteed base upon which workers and their employers could build. Employer-provided pensions are not gratuities. They are offered as a part of the compensation package designed to entice workers to spend 20, 30, or 40 years working for those employers. In the case of Social Security, once again, this is not a gratuity; but rather something workers and their employers pay for over th e entire course of one’s working life.As such, these pensions are something to which workers are therefore entitled. â€Å"Entitlement† is one of those terms that takes on an entirely different meaning, depending upon who says the word. Some wealthy people tend to use the term in a pejorative sense, as if it is something to which recipients are not actually due. Some people at the opposite end of the social ladder toss the word around as if it represents a basic right that is owed to them by society, like the air they breathe.For our purposes, we use the term to describe a set of benefits one actually does earn through years of working, paying taxes, and making contributions, either directly or as an element of one’s compensation. State and local government employers provide pensions through public sector retirement systems. For reasons we will explore later, many government workers are not covered by Social Security, and hence are not entitled to Social Securit y benefits. Whether or not these workers are covered under Social Security, their pensions have been promised as a part of the compensation package by which they were enticed to work for their employers.Pension funds accumulate from three sources: employer contributions, worker contributions, and investment income. Some States and local government entities have done a better job than others, in administering, managing, and contributing to these retirement systems. Because pension funds generally accumulate over long periods time, the 20, 30, or 40 years of the employee’s working life, the largest part of pension funds have historically come from investment earnings. Indeed, typical public sector retirement systems throughout America rely upon those pension funds earning 7. 5% to 8% or more annually.Shrewd investment strategies have often returned even greater earnings. But during the past dozen years, several things have occurred to interfere with such growth. First was the d ot-com bubble burst in the Spring of 2000. Then came the terrorist attacks of September 11, 2001. Then came the â€Å"Great Recession† and mortgage crisis starting in 2007 and escalating over the following several years. Each of these factors played an increasingly damaging role in depleting pension funds, yet were never anticipated by those who designed and managed the funds, or by the local politicians who exercised control over contributions to the pension funds.In some cases, such as in the City of San Diego, City Councils actually chose to take pension holidays to suspend contributions. San Diego promised pension benefit formula increases in exchange for the privilege of suspending pension plan contributions. In retrospect such a plan makes no sense whatsoever, but to some it seemed like the right thing to do at the time. In San Diego the practice ultimately led to a nationally publicized scandal, involving charges of reckless fiscal mismanagement, and leading the New Yo rk Times to dub San Diego, â€Å"Enron by the Sea† in 2004. Broder) An audit report in 2006, prepared by a New York risk management company, and which cost the City $20 million to prepare, summarized the problem: â€Å"San Diego officials cultivated and accepted a culture of financial management and reporting premised upon non-transparency, obfuscation, and denial of fiscal reality. † (Kroll, p. 3) San Diego may have garnered the headlines, but was certainly not alone in its failure to grasp reality when it came to pension finance.San Jose was another, among countless cities, that promised enhanced pension benefit formulas without committing to the requisite pension contributions needed to support them. Problem Statement. Unsupported promises, together with investment losses, unrealized projected earnings, skipped contributions, and even inaccurate mortality assumptions, have put pension plans in crisis in nearly every State and local government throughout the United S tates. There are a few exceptions, of course, but calls for â€Å"pension reform† are rapidly becoming nearly universal.Public sector pensions provided to employees of state and local governments, like all other forms of government worker compensation, are paid in large part from tax revenues, which suggests to some that taxpayers should have something to say about them. In actuality, that may not be the case, any more than taxpayers should exercise direct control over salaries or other employment benefits. Nevertheless, the political process in both San Diego and San Jose, California, brought major pension reform proposals to local voters in 2012.Proposals call for slashing benefits, and even elimination of defined benefit pension plans. Understandably, such ideas have met considerable opposition from employees and the unions who represent them. The fact that these are the 8th and 10th largest U. S. cities respectively, means that all States and political subdivisions facing similar fiscal problems will be paying close attention to what happens in these two California cities. In the process there has been a lot of finger pointing, largely at labor unions, as politicians and city leaders are slow to admit their own roles in the creation of the crisis.Closer scrutiny may suggest that labor unions are less culpable than the politicians are willing to admit. Purpose and Objectives. The purpose of this study is to explore some of the challenges in pension reform. We will suggest some guidelines for bringing stakeholders together to deal with the problem. Finally, we will suggest a possible solution to the financial crisis faced by states and their political subdivisions stemming from widespread unfunded pension liabilities. Limitations of our Study. We have not gone into excruciating detail regarding San Diego’s pension scandals, though it may have been instructive to do so.Neither have we discussed uncounted millions of dollars in wasted legal fees that stemmed from confrontations that might have been avoided, had the City of San Diego taken a more cooperative approach toward labor. While relevant to the present discussion, these details were a bit beyond the scope of this study. We looked at a thirteen pension plans as a representative sample. Twelve of these were chosen specifically because they were held out as being exemplary in the late 1990s, to support the idea that public retirement systems outperform Social Security.A number of these plans were highlighted in a Pew Institute study suggesting that Social Security should be privatized, rather than run by the federal government. It is noteworthy that, with the exception of just one, all of these non-FICA pension systems are today in serious trouble. Another plan was selected to illustrate just how bad off one State pension system had become, underscoring the magnitude of the nationwide problem. We did not study the intricacies of each plan to discuss why they have togeth er amassed hundreds of billions, or even trillions of dollars in unfunded pension liabilities.We presume the reasons were common among them all, and that they represent the majority of public sector pension plans in trouble today throughout the United States. We also did not go into great detail to examine the single non-FICA plan that has managed to operate for several decades without a dime in unfunded pension liabilities. The Galveston County alternative to Social Security plan is quite unique among public sector pension systems, with only two neighboring Texas counties following its lead. The plan deserves further study, but this is beyond the scope of our presentation.Even if its adoption were to become widely accepted in the future, however, it would not address current issues faced by the nation’s other public sector retirement systems. Additionally, this study does not attempt to examine the legislative steps that may be involved in making any solution work. The U. S. Supreme Court has had little to say on the subject of modern pension reform, but we can expect that to change in the near future as current challenges to State and local pension reforms make their way through the court system.Stay tuned, as it is only a matter of time before the nation’s highest court will have an opportunity to weigh in on the topic. Summary of Remaining Chapters. In Chapter I we have introduced the concept of pensions, and their place in society as something to which workers are entitled. We have noted that in today’s tight fiscal environment, State and local governments have become challenged to continue providing pensions. Chapter II discusses the widespread nature of the problems leading to the call for pension reform nationally. In Chapter III we put Social Security in perspective.Chapter IV touches upon some of the proposals put forth in the political processes of 2012. Chapter V notes that there are legal and even constitutional implications s tanding in the way of draconian pension reforms. In Chapter VI we discuss bringing unions on board to seek solutions in cooperation with management, rather than continuing in a pattern of confrontation. Chapter VII discusses one creative way to handle widespread unfunded pension liabilities, and suggests a way to make it work for the benefit of everyone involved. Chapter VIII closes by offering our conclusions and recommendations. Chapter II: Pensions in PerilThere has been much talk in recent months concerning pension reform. At issue is the fact that defined benefit pension plans are unfunded to an alarming degree. This is true nationwide. State and municipal pension funds in many state and local governments currently have less than half of the assets needed to meet their obligations to current and future retirees. The Stanford Institute for Economic Policy Research conducted extensive research on California public pension systems, releasing its report in February, 2012. They anal yzed the 24 of the largest public pension systems in 20 California municipalities.While most pension systems nationally release financial reports assuming long term investment returns of near 8%, the Stanford study applied a more conservative estimate of 5%. Authors of the Stanford study, Evan Storms and Joe Nation, PhD. , make the alarming finding that these 24 systems, in aggregate, are only 53. 6% funded. To illustrate the issue, as of 2010, the San Diego City Employees Retirement System (SDCERS) had accrued liabilities of $9. 871 billion. This estimate is based upon Stanford’s assumed discount rate of 5%, a more conservative estimate than the 7. 75% used in SDCERS official projections.The higher the assumed rate of investment return, the lower the liabilities appear. Sugarcoating the issue by making unrealistic assumptions may ultimately make the matter worse. This is money required to meet the obligations due current retirees, as well as to meet vested benefits already e arned by current employees. To meet this nearly $10 billion obligation, SDCERS has assets only approaching $4. 4 billion. This represents a funding ratio of only about 44. 4% of the amount needed to fulfill the City’s promises to its employees. According to Stanford’s research, the City of San Diego’s 2010 unfunded liability was $5. 489 billion. Storms & Nation, p. 38) The County of San Diego was similarly situated, with assets of nearly $8. 2 billion to meet accrued liabilities of $15. 693 billion, a shortfall of nearly $7. 5 billion. (Storms & Nation, p. 28) The City and County of San Diego are by no means unique in the state. The four pension plans for the City and County of Los Angeles have assets totaling near $70 billion and accrued liabilities of over $90 billion, a $20 billion shortfall. (Storms, pp. 19 and 23) The City and County of San Francisco has assets of close to $16 billion against liabilities of well over $26 billion, or a bit over $10. billion in unfunded liabilities. (Storms & Nation, p. 22) The Stanford study included the 24 largest county and municipal pension systems in the State of California and reveals a total aggregate unfunded liability of $135. 7 billion. This represents approximately 46. 4% of the total accrued liabilities of these 24 city and county pension systems. (Storms& Nation, p. vii) The Stanford study examined 2010 results, and suggested that long term investment assumptions in excess of 5% should not be relied upon.On July 21, 2011, the San Diego County Employees Retirement Association (SDCERA) announced preliminary investment results for fiscal year 2011. SDCERA had managed an outstanding 21% gain. This amazing return added $1. 6 billion to the SDCERA pension fund. Surely the SDCERA Board should be commended on such outstanding results. A few such years can do wonders in restoring this particular fund to health. But just as surely, such results cannot be expected to continue each and every year. Neit her can other funds rely upon such results. Indeed, few have ever done so well.In 2012 the SDCERA fund realized investment income at the rate of only 6. 5%. While most State retirement systems have reported billions of dollars in unfunded liabilities, Illinois may be the poster child of sickly State sponsored pensions. As of 2011, the 5 Illinois State pension plans report funding ratios of only 43%, with a total unfunded pension liability of $83 billion. The shortfall in 1996 was only $20 Billion. In the intervening 15 years the unfunded liability multiplied 4 times, from 20 Billion to over $83 Billion, well over $4 billion each year, on average. The nearly $64 billion question: How did this happen?This question was studied recently by the Civic Committee of the Commercial Club of Chicago. Investment losses, resulting mainly from the mortgage crisis starting in 2007, are estimated by the Committee report to account for nearly 22% of the shortfall. (Civic Committee, p. 11) Investment returns play the major role in pension fund growth, but they are unpredictable, as illustrated in the following chart, taken from the Civic Committee of the Commercial Club of Chicago report on the Illinois State Retirement System: Another major impact comes from changes in actuarial assumptions, due to an improvement in mortality rates.This phenomenon may be good for life insurance companies, paying less in death benefits, but defined benefit pension annuities cost more to fund when people are expected to live longer, since retirees will collect their pensions for longer periods of time. The Centers for Disease Control and Prevention recently reported that, â€Å"In the most recent period from 1969 to 2010, significant progress in the prevention, diagnosis, and treatment of cardiovascular diseases likely contributed to the 41 percent decline in age-adjusted mortality. † (Hoyert) The drop in mortality rates has been quite dramatic. For all but the oldest age group (85 years and over), mortality risk fell more than 50 percent between 1935 and 2010. . . [F]or persons 65–74 years of age, death rates declined by 62 percent, while death rates decreased by 58 percent for those 75–84 years of age, and declined 38 percent for persons 85 years or more. † (ibid. ) Applying these statistics to pension plans, particularly defined benefit plans with cost of living adjustments (COLAs), it only stands to reason that the costs to keep the retirement checks flowing to retirees who are living longer, will have a major impact on pension funds.According to the Chicago study, in 1970 a 60 year old was expected to live to the age of 78. By 2007, however, a 60 year old was expected to live to the age of 82. 5. Paying benefits to a 60 year old retiree receiving a pension of $50,000 per year, therefore, has thus increased by over $225,000, estimating that he will be receiving that benefit for about 4. 5 years longer than might have been the case 40 years ag o. †Such variances, multiplied across the hundreds of thousands of articipants in the state pension plans and without corresponding increases in employee contributions, can have a significant impact on the plans’ unfunded liabilities. † (Civic Committee, p. 14) The same phenomenon can be applied to other pension plans throughout the United States. Couple improved mortality factors with reduced investment earnings, and catastrophic losses resulting from the â€Å"Great Recession. † Add to this the fact that states and municipalities are also suffering from dramatic the tax revenue reductions. It quickly becomes evident that pensions are in peril.The Civic Committee report states that, â€Å"If Illinois fails to address its pension system through a set of comprehensive and lasting reforms, all of its citizens will ultimately suffer. Participants in the underfunded pension plans will be put at risk. The state’s ability to provide vital public services will be severely hampered. And a growing financial burden will be imposed on Illinois residents. † (Civic Committee, p. 1) Official reports from pension funds throughout the country estimate unfunded liabilities totaling close to a trillion dollars as of mid-2011.That figure, however, is based upon future average investment earnings at the rate of approximately 8%. While there have been years in which pension systems have attained such a return, or even greater, to rely upon such returns long term, in today’s tight economy, may seem unrealistic. Accordingly, such an assumption grossly understates the magnitude of the problem. In July of 2010 the National Center for Policy Analysis estimated unfunded public pension liabilities throughout the United States in excess of 3. 1 trillion dollars. Collins & Rettenmaier) Even this estimate may be optimistic. In July of 2012, Andrew Biggs, Ph. D. , a scholar with the American Enterprise Institute in Washington, D. C. , released a report suggesting a more accurate calculation for public sector unfunded pension liability may be closer to $4. 6 trillion. (See Table 1) The wide differences among these estimates are accounted for by investment returns, or discount rates, that are more or less optimistic. Andrew Biggs understands pension accounting. He was formerly Principal Deputy Commissioner of the Social Security Administration.Dr. Biggs holds Masters degrees from Cambridge University and the University of London, along with a Ph. D. from the London School of Economics. (Biggs) Whether the actual number is 1 or 5 trillion, either number represents a seemingly insurmountable crisis for public pensions in the U. S. Faced with such a situation, governors, county administrators, mayors, and city councils throughout the nation are seeking creative solutions to handle their part of the shortfall. The urgent call for pension reform has reached crisis proportions in many State and local governments.During the preside ntial primary election in June of 2012, the cities of San Diego and San Jose, California, introduced ballot measures seeking voter authorization to reform the pension plans of their respective municipal employees. In both cities the ballot measures were passed by an overwhelming majority of voters, though one might wonder whether the voters were fully informed. On June 22, 2012, San Jose Mayor Chuck Reed hand delivered a letter to the U. S. Treasury Department summarizing his City’s fiscal problems as follows: San Jose's cost for retirement benefits has gone from $73 million ten years ago to $245 million this year.To cope with this increase, we have reduced our work force from 7400 to 5400 employees. We also made many organizational changes to be more efficient, and every employee in the city took a 10% cut in pay. Yet, our unfunded liabilities for retirement benefits continue to grow, and we are facing rising costs for at least another decade. Short of bankruptcy, we have a very limited range of steps we can take to control retirement costs. In addition to layoffs and pay cuts, we can require our employees to pay more for the cost of their benefits.Hundreds of cities in California and in other states have already done so. Starting in June 2013 our employees will have to pay an additional 4% of their pay towards unfunded pension liabilities. That amount will increase annually until it reaches 16% of pay or 50% of the cost of unfunded liabilities. San Diego and San Jose barely represent the tip of the iceberg. The problem, as Mayor Reed suggested, is national. Most State and local government pension programs today sense the need for some form of pension reform. Some have been quick to blame the problem on the greed of labor unions.Labor unions have a responsibility to represent their members, and to bargain for the best possible terms and conditions of employment, including pensions. But the unions are not the ones who write the checks or manage public p ension funds. Labor unions do not choose to take pension contribution holidays. The most highly compensated public employees, those taking the largest pensions, are often not represented by unions. So while unions make wonderful scapegoats, the most grievous of pension abuses that have brought public sector pensions to the brink of insolvency may not lie with unions or their members.Assigning blame to either faction does little to address the problem, and it is not within the scope of this report to point fingers at anyone. Rather we hope to point the way toward a workable solution. Before looking at proposed or potential solutions we should first understand the role of Social Security. While many public sector employees are not covered under Social Security, nevertheless, by law their public retirement systems are required to provide benefits that are at least comparable to those provided by Social Security. Chapter III: Social SecurityNo discussion of pension reform can be complet e without an understanding of Social Security, the basis of pension protection for the vast majority of American workers, though certainly not all. On August 14, 1935, Congress passed H. R. 7260, which came to be known as the Social Security Act, signed into law by President Franklin Delano Roosevelt. The intent was to provide a level of economic security in the wake of the Great Depression, providing protection for workers and their dependents against the loss of earnings due to disability, retirement, or death.The preamble of the Social Security Act describes it as, â€Å"An act to provide for the general welfare by establishing a system of Federal old-age benefits, and by enabling the several States to make more adequate provision for aged persons, blind persons, dependent and crippled children, maternal and child welfare, public health, and the administration of their unemployment compensation laws; to establish a Social Security Board; to raise revenue; and for other purposes. When first introduced, Social Security covered most private-sector workers. Excluded from coverage, however, were state and local government employees. Prior to 1951, State and political subdivision government employers were not required to participate in Social Security, due to concerns over the constitutionality of imposing federal taxes upon sovereign state governments. The Social Security Act was amended in 1950 to add Section 218.This amendment authorized voluntary State participation through â€Å"Section 218 Agreements,† so named after Section 218 of the Social Security Act: The Commissioner of Social Security shall, at the request of any State, enter into an agreement with such State for the purpose of extending the insurance system established by this title to services performed by individuals as employees of such State or any political subdivision thereof. [42 U. S. C. 418] (a)(1) Prior to 1983, continued participation under Section 218 Agreements was optional, wit h States having the right to withdraw from those agreements.Beginning in 1983, however, those public employers which were participating in Social Security were required to continue that participation. The city of San Diego was among many local governments that opted out of Social Security in 1982, prior to the effective date of that change in the law. Throughout the United States today there are approximately 86,000 public employers, with 23 million public employees, according to the Social Security Administration’s State and Local Government Employers Information webpage.Approximately 5 million of those government employees work for public entities that do not participate in Social Security, but rather provide coverage under public retirement systems meeting stringent â€Å"safe harbor† requirements. Under current law, Social Security coverage is extended to include employees of state and political subdivisions, unless they are covered under a retirement system that p rovides benefits that are comparable to those available under Social Security.The safe harbor requirements are spelled out in Title 26 of the Code of Federal Regulations, otherwise known as the Internal Revenue Code: Under section 3121(b)(7)(F), wages of an employee of a State or local government are generally subject to tax under FlCA after July 1, 1991, unless the employee is a member of a retirement system maintained by the State or local government entity. This section 31. 3121(b)(7)–2 provides rules for determining whether an employee is a â€Å"member of a retirement system†.These rules generally treat an employee as a member of a retirement system if he or she participates in a system that provides retirement benefits, and has an accrued benefit or receives an allocation under the system that is comparable to the benefits he or she would have or receive under Social Security. In the case of part-time, seasonal and temporary employees, this minimum retirement ben efit is required to be nonforfeitable.In simple terms this means that public employers who do not already voluntarily participate in Social Security under a Section 218 agreement, must now do so unless they provide benefits under a public retirement system which are at least as comprehensive and beneficial as those provided under Social Security. This is not a discretionary item, where a public employer may give its employees an option to participate or not. The employer must either participate in Social Security, or provide its employees with a retirement system that provides benefits which are â€Å"comparable to the benefits he or she would have or receive under Social Security. Another consideration is that Social Security OASDI benefits include a great deal more than a simple retirement plan paying retirement income to its participants. Social Security also offers income to a worker’s dependent children until their age 18. There is also a disability income insurance ele ment within Social Security, which is either non-existent or difficult to provide under a typical 401(k) style plan. 401(k) plans are investment vehicles that require the element of time in order to grow. Disability can strike at any time, and may not wait for a worker’s 401(k) plan to gain adequate resources.Disability income insurance costs are occupationally based. The greater the physical demand upon the worker, and the more hazardous an occupation is, the greater the cost to provide insurance coverage. Sanitation workers and safety employees, police officers and firefighters, for example, face physical demands and hazards that do not exist for clerical workers and executive level department heads. To replace the disability benefits guaranteed under Social Security through a plan of insurance, whether self-funded or through commercial insurers, would add a tremendous drain upon the resources of a Defined Contribution plan.In contrast, Social Security spreads that risk acr oss all workers nationally, regardless of occupational hazards. In the private sector nearly all employees are subject to payment of Social Security payroll taxes under the Federal Insurance Contributions Act (FICA), and eligible for coverage under Social Security’s Old-Age, Survivors, and Disability Insurance (OASDI). But approximately 5 million public employees in the United States are exempt from Social Security coverage, since their employers opted out of Social Security before 1983.As discussed above, Public employees may be exempted from Social Security, provided they are members of a retirement system maintained by a state or political subdivision. To be exempt from Social Security coverage, the retirement system must provide certain minimum retirement benefits. To meet the minimum requirement, IRS regulations require that a retirement system provide benefits to the employee that are â€Å"comparable† to those provided in the Old-Age portion of the OldAge, Survi vor, Disability Insurance (OASDI) program under Social Security. IRS Publication 963) Public employees who participate in a retirement system that meets the minimum requirements are said to have safe harbor. Such a retirement plan may be either a defined benefit or a defined contribution plan, but benefits derived from the plan must be comparable to those available under Social Security. In other words, any public pension plan that fails to provide retirement and disability benefits at least as good as those provided under OASDI, also fails to exempt the pubic employer from participating in Social Security.Drastic changes to public retirement systems may disqualify municipalities from continued safe harbor. Another consideration those anxious for reform may be overlooking is that this is an all-or-nothing proposition. Cities imposing major pension reforms limited to new hires may find that the new employee plan fails the safe harbor test, thus requiring Social Security participation from all employees, including those not previously covered. While this remains to be tested in the courts, the law seems pretty clear on this issue. Social Security has had its detractors from its very beginnings.Many people have believed private investment strategies could produce greater financial security than the government run Social Security program. Some have called for Social Security Privatization. In 1997, William Even and David MacPherson published a study that examined 7 public retirement systems not participating in Social Security, referred to as non-FICA plans. The study suggested that these 7 plans would provide greater retirement benefits than Social Security to the million covered employees. (Even ; MacPherson) In 1999, the Cato Institute published the Cato Project on Social Security Privatization.This study examined several other non-FICA public retirement systems administered by local governments, including the San Diego City Employees Retirement System (SDCERS) , the Massachusetts Teachers Retirement System, the Louisiana Police Retirement System, the Louisiana Firefighters’ Retirement System, the Public Employees Retirement System of Ohio, the Alternative Plan for Galveston County Employees. (Lips) At the time of these studies, each of the dozen retirement systems featured in were thriving, and reportedly capable of providing far greater benefits to their beneficiaries than would have been available under Social Security.They were spotlighted to illustrate that such funds were outperforming Social Security as a means of providing retirement security for public employees. In Chapter II we mentioned that as of 2011, according to a report published by the Stanford Institute for Economic Policy Research, the San Diego City Employees Retirement System (SDCERS) only had assets of $4. 4 billion to cover accrued liabilities of $9. 871 billion, an unfunded liability of $5. 489 billion. Due to differences in projected investment returns, the se figures differ dramatically from the official numbers released in SDCERS financial reports.SDCERS reports their unfunded liability at under $2. 2 billion. Either way you slice it, whether $2 billion or $5 billion, this is a great deal of money for any single municipality to come up with. Whichever figure you prefer to accept, the fund is no longer the healthy pension system it was at the time of the 1999 Cato study. The SDCERS fund was then considered among the best public employee retirement systems in the country, an example used to promote the idea of Social Security privatization. Today it has an unfunded pension liability approaching 56%. Select Unfunded Accrued Pension Liabilities Non-FICA Public Retirement System| UAL (billions)| Funded Ratio %| 1| San Diego City Employees Retirement System (SDCERS)| 2. 1| 68. 5| 2| Los Angeles City Employees’ Retirement System (LACERS)| 3. 7| 72. 4| 3| Maine Public Employees Retirement System (Maine PERS)| 4. 1| 66. 0| 4| Ohio Publ ic Employees Retirement System (OPERS)| 67. 8| 63. 0| 5| State Teachers Retirement System of Ohio (STRS Ohio)| 40. 6| 58. 8| 6| Colorado Public Employees Retirement System (PERA)| 30. 0| | 7| Nevada Public Employees Retirement System (NVPERS)| 10. 9| 70. 2| 8| California State Teachers Retirement System (CalSTRS)| 65. | 69. 4| 9| Massachusetts Teachers Retirement System | 13. 6| 58. 7| 10| Louisiana Police Retirement System| 0. 3| 55. 6| 11| Louisiana Firefighters’ Retirement System| 0. 4| 74. 3| 12| The Alternative Plan for Galveston County Employees | 0. 0| 100. 0| | | 239. 0| | With the exception of one, each of the other public retirement systems cited in the 1997 and 1999 studies are today facing massive unfunded liabilities. Based on their own 2010 or 2011 financial reports, 10 of those 11 retirement systems are facing total unfunded accrued actuarial liabilities (UAL) of $239. 0 billion. 1.As of June 30, 2011 the unfunded actuarial liability (UAL) of the San Diego City Employees Retirement System (SDCERS) was 2. 1778 billion, a funding ratio of 68. 5%. Those are SDCERS own estimates. As shown above, however, reducing the assumed investment income rate to 5% changes the funding ratio to 44% and suggests an unfunded liability of between $5 and $6 billion. 2. The Los Angeles City Employees’ Retirement System (LACERS), administers pensions for employees of the City of Los Angeles, a city with an annual budget of near $7 billion. As of April, 2012, the fund reported $27 billion in unfunded pension liabilities. source: http://www. calwatchdog. com/2012/04/30/los-angeles-teeters-on-the-brink-of-bankruptcy/] 3. As of May 24, 2011, the Maine Public Employees Retirement System (MainePERS) reports an unfunded accumulated liability (UAL) of $4. 1 billion in the MainePERS State/Teacher Plan, amortized at a 2-year cost of $689 million on top of normal contributions of $159 million. [as reported by letter to Senator Richard Rosen and Representative Patri ck Flood of Maine’s Joint Standing Committee on Appropriations and Financial Affairs, May 24, 2011] 4.As of April 2, 2011, the Ohio Public Employees Retirement System (OPERS), with its 5 pension plans, including the Highway Patrol Retirement System, the Ohio Police and Fire Pension Fund, the Ohio Public Employees' Retirement System, the State Teachers' Retirement System, and the School Employees' Retirement System, has a total unfunded pension liability of $67. 8 billion, against assets of $115. 5 billion. That makes Ohio’s pensions only 63% funded. [source http://sunshinereview. org/index. php/Ohio_public_pensions] 5. The State Teachers Retirement System of Ohio (STRS Ohio) reported an unfunded liability of 40. 5 billion, as of November 10, 2011. [https://www. strsoh. org/]: On September 26, 2012 Ohio Governor Kaisich signed the Ohio pension reform bill passed by the Ohio Legilature on September 12, intending to improve the financial condition of its five Ohio pension systems. The bill continues to support Ohio’s Defined Benefit Pensions as â€Å"major economic drivers† for the state, and providing â€Å"a stable retirement income for public workers in Ohio. † [https://www. strsoh. org/legislation/main. html] At Ohio State University, faculty contribute 10% of their salary to the retirement plan, while the university contributes 10. % of the faculty member's salary to his or her retirement plan. An additional 3. 5% of salary is contributed to STRS to reduce unfunded liabilities. [http://hr. osu. edu/benefits/rb_strs. aspx] 6. The Colorado Public Employees Retirement System (PERA) faced a 30 billion unfunded liability in 2010. 7. The Nevada Public Employees Retirement System (NVPERS) has assets of $25. 8 billion, and has generated a net return of 9. 3% over its 28 year existence, exceeding its actuarial objective of 8%. That sounds great, until you realize that returns over the past 5 years average closer to 2. %. The Nevada PERS estimates its funded ratio at 70. 2% for 2011, its lowest level since its 1992 inception. This leaves the plan with an unfunded liability of 10. 95 billion. 8. California State Teachers Retirement System (CalSTRS), 152. 2 billion in assets, as of June 30, 2011, had an unfunded liability of $65. 5 billion, representing a funding ration of 69. 4%. [source: Pensions ; Investments Research Center, April 9, 2012, available at http://www. pionline. com/article/20120409/REG/120409899] 9. The Massachusetts Teachers Retirement System has one of the lowest cost o taxpayers, with employees required to fund the greatest portion of their own retirement. New employees pay 95% of the cost of their pensions. But the system still faces an unfunded pension liability of $13. 6 billion against assets of 19. 4 billion, in 2009, with a funded ratio of just 58. 7%. 10. The Louisiana Police Retirement System is a small system with assets of only $360. 9 million, but its unfunded liability is $313 mill ion. Its funded ratio is only 55. 6%. 11. The Louisiana Firefighters’ Retirement System, as of June 30, 2011, had an unfunded actuarial accrued liability of $416,177,743, against assets of 1. billion. This fund has a funded ratio of 74. 33%, which is very good compared to the rest of Louisiana’s retirement systems, facing a total shortage of 18. 5 billion, with a funding ratio of 56%. 12. The Alternative Plan for Galveston County Employees is unique among the reviewed plans, claiming no unfunded pension liability. This plan was patterned after Social Security, calling for the same level of contribution as with Social Security, from the employer and the worker alike. The plan also incorporates an insurance element that improves on the theme from Social Security.In addition to retirement benefits that a near double those of Social Security, Galveston’s Alternative Plan pays a death benefit equivalent to four times a worker’s annual salary. Two neighboring T exas counties adopted similar retirement plans in 1983. The Galveston model stands alone among all of the public retirement systems included in the 1997 and 1999 studies used to support the idea of privatizing Social Security. Galveston County’s approach seems worthy of further study and emulation, as a plan fair to participants, employers, and taxpayers alike.Chapter IV: Reform Propositions In the past dozen years, since the disaster of 9/11/2001, and especially since the mortgage industry meltdown in 2008 and 2009, pension reform has become an increasingly pressing issue. Some municipalities, including San Diego, and San Jose, California, have passed ballot measures calling for pension reform. These were known as Proposition B in San Diego, and Measure B in San Jose. San Diego and San Jose are the 8th and 10th largest cities in the U. S. respectively, so what happens in these communities with respect o pension reform will gain the attention of all cities throughout the nati on that are seeking solutions to the problem of unfunded pension liabilities. San Diego's City Charter included a provision that requires a majority vote of all city employees to approve any changes to retirement benefits. Proposition B called for that provision to be eliminated from the City Charter. (Prop. B) The ballot measure was intended to create a voter-supported mandate, granting the Mayor and the City Council authority to modify the City’s pension plans. These make up a major part of the compensation packages of city government workers.If the City denies its employee’s voting rights over control of their pensions, such a move could have serious property right implications. Implementation of such a plan may lead to very costly legal battles – for reasons we have explored in previous chapters. Among the most fundamental of employee benefits upon which the vast majority of U. S. workers have come to rely is the Social Security system, which we discussed in Chapter III. Social Security ensures a degree of financial stability to retired workers, or in the event of a disabling injury or disease that would prevent a worker from earning a living.This basic employee benefit has been a part of American workers’ life since passage of the Social Security Act of 1935. â€Å"The act instituted a system of mandatory old-age insurance, issuing benefits in proportion to the previous earnings . . . and establishing a reserve fund financed through the imposition of payroll taxes on employers and employees. † (Farlex) But what many voters may not have realized when they supported Proposition B in June of 2012, is that participation in Social Security is among the sacrifices San Diego employees made in accepting careers with the City.As explained in Chapter III, while virtually all private sector employers are required by law to participate in Social Security for the benefit of their employees, only some local government entities are exe mpt. The City of San Diego elected to withdraw from Social Security participation in 1982, and since then has not paid Social Security payroll taxes. Instead, San Diego and many similarly situated municipalities provide retirement and disability related financial security to its employees through the City’s pension plan.San Diego City employees are only eligible to receive Social Security retirement benefits if they worked in covered employment other than for the City of San Diego, or worked for the City prior to 1982. Instead, San Diego’s employees are covered only by the public retirement system provided by the City. Public employees in many other cities across the nation work under similar circumstances. But since the vast majority of voters are covered by Social Security, it likely does not occur to them that local government workers are not eligible.While pension reform became a political football in San Diego’s 2012 mayoral campaign, pension issues have pl agued the City of San Diego for over a dozen years. One of the four mayoral candidates, City Councilmember Carl DeMaio, wrote and promoted Proposition B, which was placed on the ballot for the presidential primary election held on June 5, 2012. Much controversy surrounded this ballot measure, following allegations that the City had circumvented the legally required process of meeting and conferring with its labor unions.Both outgoing Mayor Jerry Sanders and City Councilmember Carl DeMaio openly claimed authorship of the ballot initiative. Mr. DeMaio made it a key element of his mayoral campaign. But when the City was challenged as to its failure to negotiate with the City’s union concerning proposed reforms, they both claimed the initiative was citizen-initiated, and not an action of the City. Since both the mayor and a prominent member of the City Council each played a major role in the authorship and promotion of the initiative, it seems difficult to legitimize the claim th at this was not an official action of the City.As the ballot measure was presented to the voters, however, supporters of the initiative failed to mention or remind voters that San Diego’s pension plan had replaced Social Security for City employees 30 years before. Had voters understood the full ramifications to City workers, and the fact that they are not covered by Social Security, the election results on Proposition B may have been different. Indeed, had the voters who signed petitions to have the measure placed on the ballot known this vital detail, some may have withheld their signature.Promoters carefully avoided any discussion of Social Security as they cajoled voters to pass the measure, while opponents also failed to adequately stress the Social Security implications. Legal challenges were brought in the courts, charging that the City violated its legal obligation under the Meyers-Milias-Brown Act to meet and confer with the City’s unions regarding provisions of the ballot initiative. The City won the first round in this battle, succeeding in getting the measure placed on the June 2012 ballot. In San Diego Municipal Employees Association v.The Superior Court of San Diego County (San Diego County Superior Court No. 37-2012-00092205-CU-MC-CTL), the Court of Appeal for the Fourth Appellate District overruled that decision, but too late to have any impact. That decision came on June 19, 2012, two weeks after the election. The suggestion that San Diego’s Proposition B had a questionable legislative history, or that it was improperly brought to a public vote, is not to imply that pension reform is unnecessary, in San Diego or anywhere else. But Proposition B may not be the panacea San Diego voters were led to expect.There may be other actions San Diego can take to address its pension problems – actions that would be both more effective and more fair to City employees and taxpayers alike. Several such potentially more sensible app roaches to the problem were mentioned by Congressman Bob Filner, the only one among San Diego’s four mayoral candidates who resisted Proposition B. Congressman Filner recognized the proposition’s shaky legal foundation, and acknowledged that such a reform plan may meet with constitutional challenges we will explore in the next chapter.Proposition B involved several elements. One part of Proposition B imposes a wage freeze. Curiously, however, even after the wage freeze was announced, Mayor Sanders authorized pay raises for several members of his administration, totaling nearly $45,000 per year. Union officials might wonder why austerity measures like wage freezes apply to represented employees, but apparently not to another class of employees. If serious belt-tightening is called for, the City might do well to apply such measures universally.To expect the burden to be borne by the City’s unionized workers, but not by management employees, does not do much to pro mote labor peace. The proposition also modifies the police pension plan, raising the retirement age and lower the maximum benefit. Pension benefits for newly hired public safety workers would be reduced from a maximum of 90% to a lower cap of 80% of pre-retirement earnings. Key among the changes imposed by Proposition B is replacing the City’s Defined Benefit pension plan with a 401(k) style Defined Contribution plan that make no financial security guarantees.These would be for all new employees who are not a part of the Police Department. As to Social Security, close reading of Proposition B reveals that its author acknowledges the fact that City employees are not presently covered. It is suggested that the City may open the option for employees to become covered by Social Security, but that it is the intention of the City to maintain its safe harbor exemption from Social Security participation. In this respect San Diego’s Proposition B approach to pension reform may have a fatal flaw.Recall from our discussion of Social Security that municipalities can maintain exemption from participation in Social Security, but only if its pension plan provides benefits comparable to those available under Social Security. For the past 30 years the City’s Defined Benefit pension plan has fulfilled that requirement. The question is, will the 401 (k) style Defined Contribution plan proposed under Proposition B, meet the same stringent requirements? Unless the plan provides a level of benefits at least as comprehensive as Social Security’s Old-Age, Survivors, and Disability Insurance (OASDI), the answer is likely no.Defined Benefit Pension plans base pension benefits as a guaranteed fixed percentage of pre-retirement income, determined by a benefit formula that considers both rates of pay and years of service. These benefits are paid for by employer and employee contributions to the pension fund, and also by the investment income derived from the fu nd. When fund investments do well, contributions required from the employer are lessened. When investment income suffers, greater contributions are required from the employer to meet fund obligations.Defined Contribution Plans, in contrast, do not feature benefit guarantees, but rather base their security in a known fixed cost for the amounts paid into the plan. (Bennett-Alexander, p. 774) Defined Contribution plans may seem attractive from the point of view of the employer, but for the worker it means financial uncertainty. Eliminating the financial security features of Defined Benefit plans is a major change from long-standing past practice in San Diego and in cities similarly situated.The principle of past practice may give yet another basis upon which unions may mount a challenge to such a drastic change as to eliminate participation in Defined Benefit plans. Defined Benefit Pension Plans account for nearly 73% of union-negotiated retirement plans across the Nation, particularly in the public sector. (Carrell, p. 329) Income maintenance plans – pensions and other employee benefits such as severance pay, death and disability insurance, wage guarantees, supplemental unemployment plans, and the like – have generally been negotiated over long periods of collective bargaining by employee organizations and unions. Carrell, p. 328). In many cases, such as for San Diego city employees, these negotiated income maintenance plans take the place of programs made available to other workers through Social Security. Based upon one’s term of employment and level of earnings, Social Security’s OASDI provides guaranteed disability and retirement income to covered individuals and their families. Defined Benefit pension plans can be designed to be as good or better than Social Security. Benefits under Social Security are not in any way dependent upon investment returns, and the same is true, by definition, in Defined Benefit pension plans.The very nature of a Defined Benefit plan is that what is defined is the benefit, not the contribution. Benefits are established, and contributions may vary to meet the scheduled benefits. If investment returns fail to fund the plan at sufficient levels to meet plan obligations, the shortfall is simply overcome by making greater contributions to the plan. In a Defined Contribution plan, however, what is guaranteed is not the benefit, but rather the amounts to be contributed. Costs are fixed; benefits are contingent upon the fund’s resources, which come both from contributions and investment earnings.Simply put, benefits are directly dependent upon investment returns, which cannot be guaranteed. Highly compensated employees (HCE) see another attractive feature of 401(k) style retirement plans. Participating in such a plan offers very significant tax benefit, allowing voluntary contributions to accrue free of income taxes. Those workers whose income is lower, however, can neither afford voluntary reductions in pay, nor benefit to the same degree from 401(k) plan participation.From the perspective of lower paid workers, particularly those younger workers who do not sense retirement planning as being pertinent, every dollar an employer pays into a pension plan is a dollar that is not available in this week’s paycheck. While equally true for the highly compensated, that dollar has less significance. As explained in a recent study by the Center for Retirement Research at Boston College, high income workers benefit disproportionately due to higher participation rates, higher contribution rates, and higher tax benefits. Toder and Smith, p. 7) Defined Contribution plans may appear attractive to public employer budget analysts and some highly compensated employees, but they almost certainly fall short of being comparable to Social Security. To make them comparable, contribution rates would likely have to be set so high as to make investment returns unimportant. Sud denly then, Defined Contribution plans lose their attraction, as they may cost even more than the Defined Benefit plans they are intended to replace.That may be even more true considering the attorney and court fees taxpayers may be required to suffer to defend legal and constitutional challenges. During the San Diego mayoral race, candidate Congressman Bob Filner, noted that should Proposition B be implemented, there is a strong likelihood that much of the perceived savings might be spent instead on legal fees defending the lawsuits that would likely follow. Discussing the pension reform problem on the National scene, and the move toward cutting back on pension benefits, Stuart Buck, J. D. as noted, â€Å"[T]he problem is how to do this in a way that is most fair to workers and in a way that is consistent with state or federal Constitutional provisions that prohibit states from impairing the obligations of contracts. † (Buck. ) Chapter V: Legal and Constitutional Hurdles Pow er to grant pensions is not controverted, nor can it well be, as it was exercised by the States and by the Continental Congress during the war of the Revolution; and the exercise of the power is coeval with the organization of the government under the present Constitution, and has been continued without interruption or question to the present time.Justice Nathan Clifford United States Supreme Court United States v. Hall 98 U. S. 343 (1879) The establishment of pensions in recognition of public service is a practice so steeped in tradition as to be considered a right of passage. Any proposal that suggests taking such benefits away from public servants will be met with stern opposition in the courts. There are well-founded statutory, contractual, and constitutional protections that make it difficult for cities or other political subdivisions to impose pension reforms. The U. S.Constitution has several clauses that can be interpreted to protect pensions. Numerous State constitutions of fer similar protections. San Diego Pension Issues: The City of San Diego, California, presents an interesting backdrop for the discussion of the legal and constitutional implications of pension reform. During the past decade the City of San Diego incurred millions of dollars in legal expenses dealing with lawsuits stemming from scandalous pension dealings and futile attempts to make unilateral changes to its pension plans.Such money enriched a few lawyers, but only worked against the interests of the City and its taxpayers. Attempts by the City of San Diego to impose pension reforms again gained attention during the 2012 election year. One of the City’s mayoral candidates, City Councilmember Carl DeMaio, wrote a ballot proposition known as the â€Å"Comprehensive Pension Reform Initiative,† making pension reform the basis of his campaign. Of the four candidates in the 2012 San Diego mayoral race, only Congressman Filner seemed to acknowledge the legal and constitutiona l issues applicable to pension reform.During the campaign, candidate Bob Filner, a 20 year veteran of the U. S. House of Representatives, predicted that should Mr. DeMaio’s Proposition B pass voter approval, its implementation would be met by legal and constitutional challenges that may cost the City dearly to defend. Mr. Filner also noted that, â€Å"Proposition B does nothing to reduce the current pension deficit, it takes retirement security from employees who are not in the Social Security system – and it will result in years and years of more political wrangling and litigation over its legality and implementation. (Filner) Specifically, the legal implications of Proposition may involve charges of breach of contract. Under California law, employers enter into an implied and enforceable contract with employees as of the date of hire, with respect to the terms and conditions of employment. Employee benefits, including pensions, that are promised as an inducement to accept em