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A Brief History of the American Felony Murder Rule

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THE PENNSYLVANIA MURDER GRADING STATUTE

After our American Independence a number of the new states began legislative reforms to codify the crime of murder. One of the earliest states to do so was Pennsylvania. In 1794, that state enacted a murder degree statute which divided murder into first degree capital murder and second degree murder. The Pennsylvania legislature constricted the penalty for felony murder by imposing capital punishment only for such felonies as occurred in the perpetration of arson, rape, robbery or burglary. The statute further provided that all murder in the state other than ones committed in the perpetration of one of the common law felonies specified in their degree statute was to be second degree murder.

Later the felony of kidnapping was added to the list of specified felonies for purposes of felony murder. Only first degree murder served as a basis for hanging. The Pennsylvania statute did not actually formulate a felony murder rule or define the elements of murder. Instead the statute identified participation in certain felonies as a grading element that aggravated murder liability. The statute prescribed that:

All murder, which shall be perpetrated by means of poison, or by laying in wait, or by any other kind of wilful, deliberate and premeditated killing, or which shall be committed in the perpetration or attempt to perpetrate any arson, rape, robbery, or burglary, shall be deemed murder in the first degree; and all other kinds of murder shall be murder in the second degree.

The implication of the statute is that murder in the course of one of the enumerated felonies did not require wilful, deliberate, and premeditated killing. The language of the statute does not suggest that the mere causing of death in the course of any felony was always murder. This idea is much more in line of what Lord Hale was proposing in his writings at the end of the seventeenth century and is similar to Judge Stephen’s jury instruction in the Serne case: that it would be murder only if the felonious act was known to be dangerous to life and likely to cause death. The word “deemed” in the statute implies the notion that a judge or jury could weigh the facts of the case and decide whether the conduct of an accused warranted a charge of murder for which the accused could be hanged.

The Pennsylvania statute was enormously influential, shaping homicide reform statutes in two thirds of the then existing states during the nineteenth century. Twelve states adopted Pennsylvania’s grading scheme with little or no modification, the states which adopted the Pennsylvania statute as drafted were: Virginia in 1796, Kentucky from 1798 to 1801, Maryland in 1810, Louisiana from its admission in1812 to 1855, Tennessee in 1829, Michigan in 1838, Arkansas in 1838, New Hampshire in 1842, Connecticut in 1846, Delaware in 1852, Massachusetts in 1858, and West Virginia, entering the Union with such a statute in 1863.

Another nineteen states adopted a somewhat modified grading scheme. The States that adopted the Pennsylvania statute with a somewhat modified grading scheme were: Ohio in 1815, Maine in 1840, Alabama in 1841, Missouri in 1845, Iowa in 1851, Indiana in 1852, California in 1856, Texas in 1858, New York in 1860, Kansas (entering the Union with such a law in 1861), Oregon in 1864, Nevada (entering the Union with such a law in 1864), Nebraska in 1873, Montana (entering the Union with such a law in 1889), Washington (entering the union with such a law in 1889), Idaho (entering the Union with such a law in 1890), Wyoming (entering the Union with such a law in 1890), North Carolina in 1893, and Utah (entering the Union with such law in 1896).

LATER DEVELOPMENTS IN FELONY MURDER STATUTES

The first true felony murder rule statute was passed in Illinois in 1827. The Illinois statute defined murder as unlawful killing with express malice, or acting with knowledge that the acts will or probably will result in death or great bodily harm, and felony murder. The statute added that an “involuntary killing… in the commission of an unlawful act which in its consequences, naturally tends to destroy the life of a human being, or is committed in the prosecution of a felonious intent… shall be deemed and adjudged to be murder.” Again, we see the influence of Lord Hale and not Lord Coke. Illinois’s statute is a true felony murder statute. Yet, it is not a strict liability statute in that it limits liability for an involuntary killing in the course of a felony that “tends to destroy the life of a human being.” It is not applicable to all felonies. Hale thought that it would be murder only if the felonious act was known to be dangerous to life and likely to cause death.

In 1829 a statute enacted in New Jersey included within murder killing ” in committing, or attempting to commit, sodomy, rape, arson, robbery, or burglary, or any unlawful act against the peace of this state, of which the probable consequence may be bloodshed… ” During that same year New York passed the strictest of the new felony murder rule statutes. Their statute defined murder as killing “without any design to effect death, by a person engaged in the commission of any felony.” At the end of the nineteenth century, nineteen states had adopted such differing kinds of felony murder statutes. These states were: Illinois in 1827), New Jersey in 1829, Georgia in1833, Mississippi in 1839, Alabama in 1841, Missouri in 1845, Wisconsin in 1849, California in 1850, Texas in 1857, Minnesota (entering the Union with such a law in 1858), Nevada (entering the Union with such a law in 1864), Oregon in 1864, Nebraska in 1866, though repealing the law in 1873, Florida in 1868, Colorado (entering the Union with such a law in 1876), Idaho and Montana (both entering the Union with such laws in 1889), and Utah (entering the Union with such a law in 1896).

The twentieth century began with most states having various ways for defining felony murder: predicating murder liability on implied malice, as well as a felony; predicating murder liability on dangerous felonies, sometimes called enumerated felonies, or predicating murder liability on any felony. Throughout the twentieth century and into the twenty-first century we continue to see American states defining felony murder in the same ways. The growth of felony murder in the United States had more to do with Pennsylvania’s 1794 murder grading statute than it did with Lord Coke’s notion in the seventeenth century that a death caused by an unlawful act is murder.

The felony murder rule in the United States has been more expansive than that employed in England due to the pairing of two concepts. One, the concept of felony murder itself and the ways it may be defined by statute and two, the concept of vicarious liability used to hold all co-conspirators liable for the substantive crimes committed by any one of the conspirators in the course of executing the unlawful agreement that may have led to the American felony murder rule.

Such a situation may obtain when Bonnie and Clyde decide to rob the local liquor store and they enlist Clyde’s brother Buck to drive them to the liquor store, stay outside to act as a look out and to be their getaway driver. Buck agrees. If during the robbery the store clerk reaches for his.38 revolver under the counter causing Bonnie to fire her tommy gun at him but she misses and her bullets kills an innocent patron of the store, then Bonnie, Clyde, and Buck would all be held liable for and could each be convicted of conspiracy to rob, armed robbery, and felony murder. The felony murder rule was never applied this way in England.

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Source by Leonard Birdsong

The Definition of Confidence

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Self-confidence is essentially an attitude which allows us to have a positive and realistic perception of ourselves and our abilities. It is characterised by personal attributes such as assertiveness, optimism, enthusiasm, affection, pride, independence, trust, the ability to handle criticism and emotional maturity.

Confidence is learned, it is not inherited. If you lack confidence, it probably means that, as a child, you were criticised, undermined, or suffered an inexplicable tragic loss, for which you either blamed yourself or were blamed by others. A lack of confidence isn’t necessarily permanent but it can be if it isn’t addressed. Our religion, the influence of the culture which formed our perspectives, our gender, social class and our parents, in particular, are all factors which influence and contribute to our level of confidence and esteem.

Confident people have deep faith in their future and can accurately assess their capabilities. They also have a general sense of control in their lives and believe that, within reason, they will be able to do what they desire, plan and expect, no matter what the foreseeable obstacle. But this faith is guided by more realistic expectations so that, even when some of their goals are not met, those with confidence continue to be positive, to believe in themselves and to accept their current limitations with renewed energy. However, having high self-confidence does not mean they will be able to do everything they want. That view is unrealistic, one for the perfectionists. A desire to be good at everything we do in order to impress others stems from a competitive instinct and lack of personal reinforcement. Any truly successful life has both rewards and the ability to learn from any setbacks, which increase our resilience, self- belief and determination. Real confidence requires that we face the possibility of failure constantly and deal with it. However, if we consistently lose out on both achievement and validation, even our identity is called into question.

Self-esteem is the opinion you have of yourself. It is based upon how you perceive your value as a person, particularly with regard to the work you do, your status, achievements, purpose in life, your perceived place in the social order, potential for success, strengths and weaknesses; how you relate to others and your ability to stand on your own feet. Because esteem is a perception of your worth, your own value of yourself dictates how others perceive you too. Buddhists classify low self-esteem as “a negative emotion or delusion, which exaggerates one’s limitations in capacity, quality and potential for growth”. It results from having a poor self-image according to personal experience in all the elements of life mentioned above. People with poor esteem never feel in charge of their lives. They often feel like victims, or outsiders – ignored, excluded, unimportant, insignificant and unloved. As they spend their lives internalising the criticism of others, taking it to heart while searching constantly for that elusive acknowledgment, their personal assessment will reflect itself in the appraisal of others – no more, no less. But if we allow others to take control of decisions we should make, we gradually become dependent upon them too, abdicating responsibility for our lives, which tends to lead to us being doormats for other people’s benefit.

Low self-esteem usually has three sides. The first is exhibited by the individual who always seems to be the underdog, the under-achiever, the negative one who says “I couldn’t”, “I shouldn’t”, “I can’t”, “I have no choice” and “I have to”. The opposite side to that, and the second type, is the person who seems very confident superficially, a take-charge type of person, appearing to be much in control, very opinionated and often found in leadership positions. But this is usually a mask for low self-esteem because he/she is likely to be tense, serious, anxious and finicky. When things go wrong that’s when the low esteem comes to the fore. Often perfectionists, they find crises difficult to handle and tend to blame others for everything. They are usually demanding, self-centred, very independent, markedly self-sufficient in their distrust of others and slow to take criticism, instruction or direction. Locked in their own narrow world, they dread new experiences, always going by the book and resenting innovation. In effect, occupying leadership positions without being true leaders. This type of low self-esteem will often deny that anything is wrong, because their belief in being totally in charge and more competent than their bosses or subordinates, is their main protection. Yet being fully in charge of your life actually eliminates the need for anger, insecurity and the desire to judge, control or denigrate others.

Fun Seekers

The third type of personality is the one who is always seeking fun and happiness from others, especially partners and love interests. Laughter becomes a mask for the low opinion these people have of themselves, so everything is done with an emphasis on ‘fun’ to make them feel worthy – either finding it or giving it. Sensitive and thin-skinned, fun people have very low self-esteem, hiding their anxieties behind a bland mask of cheerful superficiality that tends to grate on others after a time because they don’t know when to stop being happy and playing the fool. Like the office clown who tries terribly hard to show how ‘happy’ she is, yet is anything but that; the practical joker who likes to laugh at the expense of others, particularly through racist, sexist or offensive quips – anything to feel superior; the lad who is always hanging out with friends because he cannot stand his own face or company for any length of time; the type who loves a dare, particularly in doing outrageous things, to show his bravado, talent and machismo, and the ones who boast to potential dates about being able to make them laugh and keep them happy.

In relationships, fun people find it hard to commit to others because of their acute social fears. The main desirable attribute they offer to potential partners is ‘fun’, always seeking laughter, sex and good times to hide their insecurity and pain. However, as ‘fun’ people always try too hard, they are in fact the most boring, mirthless people around, the type who have little humour themselves. It then becomes heavy work for their partners. This is because laughter has to be found within us. No one can make us happy, only enhance that happiness. Fun people’s method of feeling significant is to be the centre of attention in a more positive way. But, as their activity is often not genuine, more to hide their low confidence than to enhance it, their effort isn’t really effective. They never openly address their personal pain or hurt. They are reluctant to trust others and are even more reluctant to commit themselves to anyone, which makes them feel insignificant if they are not being perennially happy lads or laddettes. To behave otherwise would deny them the attention they crave.

Many people with low self-esteem gravitate towards the uniformed and public services where they can use the power invested in them, while being validated by the uniform and authority, to boost their self- confidence and ego. The strict hierarchy affords the security of a given status, reinforces the ‘traditions’ to be maintained, and the consistent feedback they require. However, that is also what makes change so difficult to introduce in these occupational fields. The fear of innovation and the lack of self-belief to carry it out foil them every time. Very confident people tend to become scientists, engineers, entrepreneurs, writers or creative, artistic types, preferring to control their own environment and destiny. The commercial, media and technology spheres also appear to provide the freedom of expression and the font of opportunity they actively seek.

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Source by Elaine Sihera

Chiropractic and Webster Technique for Breech Presentation During Pregnancy

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The normal position for a 36 week fetus is the vertex position which means the fetus’ head is down towards the pelvic bowel. Breech presentation is a malpresentation of the fetus in which the buttock or lower limb present first into the maternal pelvis. There are three types of breech presentation which are: footling, complete, and frank. Footling occurs when one or both of the fetus’ feet point down and will come out first. Complete is when the buttock is down with the legs folded at the knees and the feet are near the buttock. Frank occurs when the fetus’ buttock is aimed toward the birth canal and the legs stick up in front of the body with the feet near the head. The probability that a fetus will be in the breech presentation is as follows: 3-4% at term, 7% at 32 weeks, and 25% at less than 28 weeks. There are big risk factors involved in the vaginal delivery of a breeched baby. For example, the baby’s head is the largest part and can be difficult to pass which would be quite dangerous if it were stuck inside, while the rest of the body were outside of the mother’s birth canal. The doctor would be unable to use forceps if needed. There is also the possibility of cord prolapse, which means the cord would be squeezed as the baby ascends into the canal. This would slow the supply of oxygen and blood and could cause fetal distress.

The Webster Technique relieves the musculoskeletal cause of intrauterine constraint which can prevent fetus vertex position and in turn prevent a vaginal birth. When used correctly, this technique has been found to be 82% effective. The Webster Technique is most often used in the 8th month of pregnancy because at this point, the fetus is unlikely to convert to the vertex position on its own. When dealing with breech presentation, 34 weeks gestation is the magic number to remember. After 34 weeks, the fetus is unlikely to convert on its own. There are three ligaments that suspend the uterus: uterosacral, ovarian, and round. The uterosacral originates at the posterior wall of the uterus and inserts on the anterior surface of the sacrum at the S2/3 level. This ligament creates tension on the cervix dorsally and prevents an anterior/inferior displacement of the uterus. The round ligament originates at the fundus of the uterus and proceeds inferior/laterally to the labia majora and joins with the inguinal ligament about one halfway through its course. This ligament provides uterine support and limits posterior movement of the uterus, thus maintaining anterior uterine position.

The mother to be is examined for an anterior/inferior (AI) sacrum, a posterior sacrum (AKA fixated SI joint), and a contracted round ligament. The combination of these three findings will lead to the torsion of the uterus which constricts fetal movement and interferes with the fetus’ ability to convert to the vertex position. In order to assess the pregnant patient both of her knees are flexed simultaneously and a light pressure pushes the feet toward their ipsilateral buttock. A fixated SI joint can be identified by a resistance near the end of motion of one of the feet. The foot on the side to the fixated SI would not travel as far as the foot on the other side. Lets say that the fixated SI is on the left. The AI sacrum and the contracted round ligament would then both be found on the patient’s right side.

The Webster Technique includes two steps. First is the adjustment and second is to decrease abdominal muscle spasm and tension. The purpose of the adjustment is to relieve tension on the uterus due to sacral rotation and restore proper perimetry and biomechanics of the pelvic bowel. The adjustment also frees the SI joint (the posterior sacrum). A very common technique used is the sacral unlock technique from the Logan Basic Technique. To do this the doctor uses the superior hand to straddle the locked SI using the thenar eminence on the sacral ala and the hypothenar on the iliac bone. The inferior hand will be firmly positioned at the bottom of the opposite buttock. The purpose of the inferior hand is to block any excess pelvic movement on that side. The patient is instructed to “walk” by moving hips alternately superiorly and inferiorly as if they were walking. The patient is told to “walk” 4-6 times to unlock the fixated SI and then I the SI joint is reassessed. The patient then lies down in the supine position so that the doctor can relax the round ligament. To do this, the doctor must first locate it by drawing an imaginary line inferior and lateral 45 degrees from the umbilicus and another line inferior and medial 45 degrees from the ASIS. The round ligament should be found at the junction of these two lines. At this point in a woman’s pregnancy, the ligament is about the thickness of the woman’s index finger and is easy to palpate through the skin. Using the inferior hand and the doctor lightly hooks their thumb under the round ligament (similar to the Logan Basic thumb contact) and holds. The direction of correction is superior and toward the opposite shoulder. The doctor holds this contact until the ligament relaxes and possibly rolls under the thumb which usually takes about 1-3 minutes. The frequency of the care depends on the urgency of the individual patient. The closer the patient is to her due date, the more aggressive the approach should be. A patient may be seen every day, every other day, or three days a week depending on the severity of the condition. Some babies flip to the vertex position after only 1-2 adjustments but it can take longer.

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Source by Dr Collin Dolan

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Dream Yoga or Milam (Standard Tibetan: rmi-lam or nyilam; Sanskrit: स्वप्नदर्शन, svapnadarśana)—the Yoga of the Dream State—is a suite of advanced tantric sadhana of the entwined Mantrayana lineages of Dzogchen (Nyingmapa, Ngagpa, Mahasiddha, Kagyu and Bönpo). Dream Yoga are tantric processes and techniques within the trance Bardos of Dream and Sleep (Standard Tibetan: mi-lam bardo) Six Yogas of Naropa. In the tradition of the tantra, Dream Yoga method is usually passed on by a qualified teacher to his/her students after necessary initiation. Various Tibetan lamas are unanimous that it is more of a passing of an enlightened experience rather than any textual information.
In a footnote on ‘Zhitro’ (Tibetan: zhi khro) Namdak & Dixey, et al. (2002: p. 124) identify that the ‘dream body’ and the ‘bardo body’ is the ‘vision body’ (Tibetan: yid lus):

In the bardo one has…the yilu (yid lus), the vision body (yid, consciousness; lus, body). It is the same as the body of dreams, the mind body.”

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Colleen Saidman is an American yoga instructor and yoga celebrity. She is the cofounder and codirector of Yoga Shanti in Sag Harbor, New York, and teaches along with her husband, yoga teacher Rodney Yee, in the Gaiam Yoga Club online yoga club/virtual yoga studio. A yoga practitioner for over 20 years and a graduate of Jivamukti’s Teacher Training, Saidman has been teaching for 12 years. She is also certified in Shiatsu.

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Christy Nicole Turlington Burns (born January 2, 1969) is an American supermodel. She first represented Calvin Klein’s Eternity campaign in 1989 and again in 2014 and also represents Maybelline. Turlington was named one of Glamour’s Women of the Year in 2013, and was named as one of Time’s 100 Most Influential People of 2014. Turlington gained fame in the late 80s and early 90s as a supermodel and was during the peak of her career a top designer favourite. She, Naomi Campbell and Linda Evangelista are called the “Trinity” because of the power and fame that all three gained.
In 2010, Turlington founded Every Mother Counts, a non-profit 501(c)(3) organization dedicated to making pregnancy and childbirth safe for every mother. Every Mother Counts informs, engages, and mobilizes new audiences to take actions and raise funds that support maternal health programs around the world. It was founded after the completion of Turlington’s documentary, No Woman, No Cry, a film about pregnant women and their caregivers in Tanzania, Bangladesh, Guatemala, and the United States. In 2013, Turlington directed the documentary film, Every Mile, Every Mother which explores Every Mother Counts’ participation in long distance running to highlight distance as a barrier for women to receive quality care.

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This article refers to orthopedic contractures, i.e., permanent shortening of muscles, tendons, and/or ligaments. For short-term contraction of muscles, including the normal action and function of muscles, see Muscle contraction. For non-orthopedic types of contractures, see the “See Also” section below.
A muscle contracture is a permanent shortening of a muscle or joint. It is usually in response to prolonged hypertonic spasticity in a concentrated muscle area, such as is seen in the tightest muscles of people with conditions like spastic cerebral palsy.
Contractures are essentially muscles or tendons that have remained too tight for too long, thus becoming shorter. Once they occur, it is often argued that they cannot be stretched or exercised away (they must be released with orthopedic surgery). Most of the physical therapy, occupational therapy, and other exercise regimens targeted towards people with spasticity focuses on trying to prevent contractures from happening in the first place. However, research on sustained traction of connective tissue in approaches such as adaptive yoga has demonstrated that contracture can be reduced, at the same time that tendency toward spasticity is addressed.
Contractures can also be due to ischemia, as in Volkmann’s contracture.
Excessive matrix metalloproteinase and myofibroblast accumulation in the wound margins can result in contracture.

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Vaasi yoga (vasi yoga) is a form of yoga that concentrates on the breath naadi (nadi), the cycle of the distribution of oxygen throughout the body, that occurs as part of the breathing process. Indian philosophy describes prana (life force) as flowing in channels called naadis. Vaasi yoga attempts to heal the body and sprirt by cleansing the breath naadi, and thus prepare for balance, true consciousness of self and then enlightenment. As such it is one of the kaya kalpa, the class of ancient yogic rejuvenation therapies. As a yogic practice it is an art of living taught by siddhars for over 3000 years ago, as initiated by Lord Shiva. Like other advanced types of yoga which should be practiced only under the guidance of Guru. Vaasi yoga is practiced by very few.
Vaasi yogam is the attainment of consciousness about the silent sound in our breath. To attain this consciousness, the body should be devoid of any waste. To remove all the waste from one’s body, one should be taught with asanas by a guru who should be in a position to analyze the naadi functionality of one’s body. A guru who has the capacity to analyze the naadi functionality is called Siva Sithan.

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