title: James Milner

text: When Milner was 10 years old, he joined the Leeds United Academy after being spotted by a scout while playing for Westbrook Juniors in Horsforth. At the academy, Milner played against contemporaries from other clubs in Northern England, including future Manchester United striker Wayne Rooney. His role model was Leeds-born Alan Smith, who was then a Leeds United striker. Milner believed playing with Smith put him through a learning curve, as Smith had done what Milner aspired to do in coming through the academy and playing for the first team. Having made good progress at the Academy, Milner was taken on as a trainee after leaving school. However, his father insisted that he attend college once a week to continue his education.


title: James Milner

text: Milner continued to excel in the youth team, and played for England at under-15 and under-17 levels. He helped the England under-17 team win the 2002 Nationwide summer tournament against Italy, Czech Republic and Brazil, scoring a goal against Brazil.


title: James Milner

text: Milner's first-team debut for Leeds came on 10 November 2002, in a match against West Ham United, when he came on as a substitute for Jason Wilcox for the last six minutes. The appearance made him the second-youngest player ever to play in the Premier League, at the age of 16 years and 309 days. On 26 December 2002, at 16 years and 356 days, he became the youngest player to score in the Premier League, with a goal in a 2–1 win against Sunderland. His record was broken by James Vaughan of Everton in 2005. In a match against Chelsea two days later, Milner scored again, with a deft first touch of the ball and manoeuvre, in order to avoid a tackle from Chelsea defender Marcel Desailly. The manoeuvre created a yard of space for him to deliver a curling shot from . Reporters were impressed by his overall performance in the match, especially by his desire, confidence, and ability with both feet. Chelsea manager Claudio Ranieri remarked after the match that Milner had performed like a much more experienced player. The performance prompted comparisons to England internationals Michael Owen and Wayne Rooney, who had also come to footballing prominence as teenagers.


title: James Milner

text: After more appearances for Leeds, Milner signed a five-year contract with them on 10 February 2003. At the start of the 2003–04 season, Milner was sent on a one-month loan to Second Division club Swindon Town to gain experience as a first-team player. Before the stint, he saw it as a valuable experience as a player. He spent a month with Swindon, playing in six matches and scoring two goals against Peterborough United and Luton Town.


title: James Milner

text: However, Leeds' fortunes were on the decline; the team became the subject of numerous negative stories in the media, and several first-team players were sold. Milner said he believed that this experience made him emotionally stronger and taught him how to deal with team problems. Leeds' eventual relegation to the Championship led to speculation over Milner's future at the club. Tottenham Hotspur, Aston Villa and Everton all expressed an interest in signing him. Ultimately, Villa and Everton did not make offers and Milner rejected an offer from Tottenham as they were based too far from his family home, where he still lived. Leeds insisted that he would not be sold with chairman Gerald Krasner referring to him as "the future of Leeds". Nonetheless, financial problems eventually forced Leeds to sell Milner to Newcastle United for £5 million. Although Milner was not happy to be leaving the club he had supported as a child, he wished to do what was "in the club's best interest" and in July 2004, he agreed a five-year contract with Newcastle.


title: James Milner

text: Milner made his first appearance for Newcastle United during their pre-season tour of Asia, scoring his first goal for the club in a 1–1 draw against Kitchee, in Hong Kong. During this tour, he took the opportunity to observe how Newcastle striker Alan Shearer dealt with attention from fans and the media and said that his association with people like Shearer gave him a better idea of how to deal with the media.


title: James Milner

text: Milner's first Premier League match for Newcastle came against Middlesbrough on 18 August 2004, in which he played on the right of the field as a winger, despite having featured regularly on the left for Leeds. When asked about this after the match, Milner said he had no preference where on the pitch he played. A month later he made his debut in European competition, when Newcastle played in the UEFA Cup against Bnei Sakhnin from Israel, after coming on as a substitute for Shola Ameobi. In the same month, he scored his first competitive goal for the club, also as a substitute, in a 3–1 win against West Bromwich Albion.


title: James Milner

text: The situation changed for Milner after Newcastle manager Bobby Robson, whom Milner considered his mentor, was sacked and replaced by Graeme Souness. Under Souness, he started 13 league matches, but did not play his first full Premier League match for Newcastle until April 2005. Milner said that he was frustrated at not being used as a starter for most of the season.


title: James Milner

text: At the start of the 2005–06 season, Milner scored in Newcastle's 3–1 away win against FK ZTS Dubnica in the UEFA Intertoto Cup, and also set up Alan Shearer for the team's third goal.


title: James Milner

text: A clause in Newcastle's purchase of Nolberto Solano from Aston Villa resulted in Milner being loaned to Villa for the rest of the season. Villa manager David O'Leary, who had managed Milner at Leeds, was happy to acquire Milner in this deal, saying that he believed Villa got the better of the deal and that he hoped to improve him as a player. He made his Villa debut on 12 September 2005 in a Premier League match against West Ham United. Five days later, he scored his first goal for the club in a 1–1 draw against Tottenham Hotspur. In a League Cup match less than a week later, he helped his team recover from being 3–1 down at half-time to win 8–3 against Wycombe Wanderers, scoring two goals in the second half comeback. Throughout the season, Milner was positive about his team. He remained confident that Villa would recover from a poor start to the season and praised the quality of the squad.


title: James Milner

text: Milner was generally seen as a positive signing in a season that was disappointing for Villa. Milner himself also received the loan move positively, saying that he would like to join Villa permanently because of the probability of becoming a regular starter, but said that the possibility of this happening was beyond his control. Manager David O'Leary confirmed during the season that he would like Milner to join the club permanently, but doubted he would be given the opportunity to sign him. He even pulled out of signing Robert Huth so that he would have the funds to sign Milner permanently if the opportunity arose.


title: James Milner

text: The newly appointed Newcastle manager Glenn Roeder appeared to appreciate Milner's ability more than Souness and expressed a desire that he remain a Newcastle player. This, as well as the departure of O'Leary and the shortage of transfer funds at Villa, meant that a deal to sign Milner permanently seemed unlikely. In June, it became even less likely when Villa rejected an offer of Milner as part of a trade for Gareth Barry. However, the deal was resurrected when Villa were taken over by American billionaire Randy Lerner, and Martin O'Neill was appointed as new manager. A move to Villa appeared to have been agreed, but at the last moment Newcastle recalled Milner and the talks broke down.


title: James Milner

text: Newcastle's players and manager Glenn Roeder reacted positively to Milner's return at the start of the 2006–07 season. Milner was a starter in the Newcastle team for the entire season.


title: James Milner

text: Newcastle made a poor start in the 2006–07 Premier League, but in European competition, Milner played a key role in helping Newcastle reach the round of 16 of the UEFA Cup, playing all but one of the Magpies 12 games.<ref name="2006/07"></ref> Rumours began to spread that he would be sold during the transfer window in January, although both Milner and Roeder dismissed these rumours.


title: James Milner

text: On 1 January 2007, Milner scored his first goal of the season in a 2–2 draw with Manchester United. The goal came from a "stunning" shot from away. He scored two more goals during the next three weeks, against Birmingham City and then against West Ham United. During the season, Milner displayed his ability to play comfortably in a range of different positions by scoring and setting up goals with both feet from both sides. As a result, Milner signed a new contract at Newcastle in January, which secured his future at the club until 2011. He signed another four-year contract in May 2007, when Sam Allardyce took over as manager of Newcastle. Milner said later in the year that he was happy about his future at the club and its new manager, saying that the training sessions were "the best since I have been here". Allardyce said during the season that Milner was so keen to play, that he was concerned he would "burn out mentally [and] physically". As a result, Milner played mainly as a substitute in the early part of the season.


title: James Milner

text: In late October, he scored Newcastle's 500th home Premier League goal in a 3–1 win over Tottenham Hotspur. A second Premier League goal of the season came fortuitously in the Tyne–Wear derby from a shot intended as a cross. Allardyce praised Milner during the season, saying he was "a hugely experienced Premier League player".


title: James Milner

text: After missing the final nine matches of the season due to a foot injury, it was rumoured in May 2008 that Milner would be part of a transfer between Newcastle and Liverpool. Despite starting the season for Newcastle and scoring in a League Cup win over Coventry City, it was revealed after the match that Milner had handed in a written transfer request the week before.


title: James Milner

text: Milner signed for Aston Villa on 29 August 2008 for a fee of £12 million, and signed a four-year contract with the club. Milner made his debut for Villa on 31 August 2008 as a second-half substitute against Liverpool. His first goals in his second spell at Villa came in a third round FA Cup tie against Gillingham at Priestfield Stadium on 4 January 2009 on his 23rd birthday, where he scored both goals in a 2–1 win for Villa.


title: James Milner

text: Milner's first Premier League goal in his second spell at Villa came on 17 January 2009 in a 2–1 win against Sunderland at the Stadium of Light. On 7 February 2009, Milner was named to the England senior team squad for the first time, after a run at club level that had impressed England manager Fabio Capello. Milner continued to impress and, on 7 February, scored his second league goal of the season against Blackburn Rovers. This was followed by a 25-yard free kick at home against Everton as Villa came back from a 3–1 deficit to draw 3–3 on 12 April. He stated that his time at Villa is the "most settled" period of his career so far, having played for thirteen managers and caretakers despite being only 23.


title: James Milner

text: At the start of the 2009–10 season, Milner moved into the centre of midfield after the sale of captain Gareth Barry to Manchester City. On 28 February 2010, he scored the opening goal in the 2010 League Cup Final with a penalty. Villa were eventually beaten 2–1 by Manchester United. Milner ended the season with 12 goals and was named Aston Villa's Fan's Player of the Year and PFA Young Player of the Year.


title: James Milner

text: On 19 May 2010, Manchester City made a £20 million offer for Milner which was rejected. On 22 July 2010, Villa manager Martin O'Neill said that Milner had shown a desire to leave Villa for City, but would only be sold at Villa's valuation. On 14 August, despite being on the verge of a move to Manchester City, Milner played in Villa's first match of the season against West Ham United, scoring Villa's third goal. Milner was given a standing ovation when he was substituted near the end of the match.


title: James Milner

text: On 17 August 2010, it was reported that Aston Villa had agreed a deal with Manchester City to sell Milner subject to a medical. The deal was reported to be worth around £26 million, including a player exchange of Stephen Ireland. Milner made his debut for City on 23 August 2010 in a 3–0 home win against Liverpool, where he set up the first goal for former Villa teammate Gareth Barry. Milner scored his first competitive goal for Manchester City in an FA Cup third-round match at Leicester City which ended in a 2–2 draw. The Leicester match was the start of a cup run that saw Manchester City reach the 2011 FA Cup Final. Milner was an unused substitute as Manchester City beat Stoke City 1–0 to win the FA Cup.


title: James Milner

text: Milner scored his first Premier League goal for Manchester City against Everton on 24 September 2011. Two matches later, he scored his second, against former club Aston Villa in a 4–1 win. The following week, Milner had a hand in two goals as Manchester City won the Manchester derby at Old Trafford 6–1, inflicting Manchester United's heaviest home league defeat since 1930. Over the course of the 2011–12 season, Milner made 26 Premier League appearances as Manchester City won the league title for the first time in 44 years.


title: James Milner

text: Milner won his first Community Shield in August 2012, as City beat Chelsea at Villa Park. On 6 October 2012, Milner scored his first goal of the 2012–13 season from a free kick to seal a 3–0 win against Sunderland. On 20 October, he received his first Premier League red card in a 2–1 win at West Bromwich Albion. On 13 January 2013, he scored City's opening goal in a 2–0 away win at Arsenal, which was the first time a City player had scored away at Arsenal in the League since 2007 and City's first win in the league at Arsenal since 1975. On 8 April, he scored in the Manchester derby as City beat Manchester United 2–1 at Old Trafford.


title: James Milner

text: On 10 December 2013, Milner scored the winning goal in a 3–2 win against the reigning European champions Bayern Munich at the Allianz Arena in the UEFA Champions League, becoming the first English player to score for Manchester City in the competition that season. That season would see Milner win a first League Cup winners medal and a second Premier League title.


title: James Milner

text: On 4 June 2015, Milner agreed to join Liverpool on a free transfer from Manchester City. On 7 August 2015, Milner was announced as the vice-captain. Milner played his first competitive match for the club in 1–0 win over Stoke City at the Britannia Stadium. Milner captained Liverpool for the first time on his third appearance for the club, a 0–0 draw at Arsenal. On 26 September 2015, he scored his debut goal for Liverpool in a 3–2 win against his former club Aston Villa at Anfield. He appeared in the 2016 UEFA Europa League Final at the end of his first season with the club. Milner ended his first season with Liverpool scoring seven goals and recording 15 assists in all competitions.


title: James Milner

text: On 19 March 2017, Milner scored in Liverpool's 1–1 draw against former club Manchester City. In doing so, he broke a Premier League record by a player for the most matches scored in without losing (47 matches). On 4 April 2018, he equalled the Champions league assist record (8 assists) by assisting Alex Oxlade-Chamberlain's goal against Man City in the quarter-final first leg. On 24 April 2018, Milner broke that record, becoming the first player in Champions League history to provide 9 assists in a single season, setting up Roberto Firmino's second goal during the 5–2 semi-final, first leg win vs Roma.


title: James Milner

text: In November 2018, Milner scored his 50th Premier League goal during a 1–1 draw at Arsenal. The following month, Milner became just the 13th player (and the 2nd youngest after former Aston Villa, Man City and England teammate Gareth Barry) in Premier League history to reach 500 appearances, during a 4–0 win at Bournemouth.


title: James Milner

text: On 1 June 2019, Milner won his first Champions League title, coming on as a substitute in the final against Tottenham, as Liverpool won 2–0 in the final. On 14 August 2019, Milner won his first UEFA Super Cup, starting the match against Chelsea, as the Champions League holders beat the Europa League winners on penalties in Istanbul.


title: James Milner

text: In December 2019, Milner signed a new contract reportedly keeping him at the club until 2022, although Liverpool did not specify the contract length. Later that month, Milner came on as a substitute as Liverpool won the FIFA Club World Cup for the first time in the club's history, beating Flamengo 1–0 in the final.


title: James Milner

text: Milner was not a regular starter during the 2020–21 season amassing just 11 starts and making 26 appearances in all competitions. As a result, he registered the first goalless season of his career. He still remained an important player as Liverpool overcame multiple difficulties to finish 3rd, qualifying for the following season's Champions League on the final day of the season.


title: James Milner

text: On 16 February 2022, Milner came on as a substitute in a 2-0 UEFA Champions League win against Inter Milan to make his 800th senior appearance at club level.


title: James Milner

text: On 27 February 2022, Milner scored Liverpool's first penalty of the shootout in the 2022 EFL Cup Final victory over Chelsea. On 14 May 2022, Milner once again scored Liverpool's first penalty of the shootout in the 2022 FA Cup Final victory over Chelsea. On 6 June 2022, Milner signed a one-year extension with the club.


title: James Milner

text: On 5 October 2022, he marked his 300th appearance for Liverpool in a 2–0 victory against Rangers F.C. in the Champions League. On 12 November 2022, Milner came on as a substitute against Southampton to make his 600th Premier League appearance.


title: James Milner

text: After representing England at the under-15 and under-17 levels, Milner was promoted to the under-20 level and called up for the 2003 World Youth Championship, but was recalled by Leeds United 4 days before the opening game. Soon after this, under-21 manager Peter Taylor called him up to the England under-21 team and Milner made his debut against Sweden on 30 March 2004.


title: James Milner

text: Milner scored for the England under-21 team during the 2004–05 season in a qualification match for the 2007 UEFA European Under-21 Championship, against Wales. During the match, in which he played in the centre of midfield, he set up a scoring chance for Darren Bent as the Young Lions won 2–0. Despite domestic club troubles, he continued to make progress at international level, scoring the winning goal for the England under-21 team in a 3–2 win over Switzerland. The win secured England a place in the playoff stage of the 2007 UEFA European Under-21 Championship qualifiers.


title: James Milner

text: In June, Milner competed for England at the 2007 UEFA European Under-21 Championship. He played in all four of England's matches and was booked in the semi-final against the Netherlands, which meant he would have missed the final. The match was decided by a penalty shoot-out, in which Milner scored twice and England lost 13–12. Milner was included in the under-21 squad for a friendly against Romania, which ended in a 1–1 draw. A month later, Milner set an England under-21 record by making his 30th appearance for the team in a 3–0 win against Montenegro. Historically, players with several England Under-21 appearances have not progressed to become regulars in the senior team, which has led some to doubt whether Milner would be able to successfully make the transition. In October, he scored his third goal for the under-21 team in a 3–0 win over Republic of Ireland. He scored again in the return match four months later that England also won 3–0.


title: James Milner

text: Milner continued to be a regular and was the only player, along with Joe Hart and captain Steven Taylor, to have played in all the qualifiers for the 2009 UEFA European Under-21 Championship. In the summer of 2009, he was in the final 23-man U21 squad for the 2009 UEFA European Under-21 Championship in Sweden. He helped set up the winning goal for Micah Richards against Finland, and manager Stuart Pearce said after the match, "The modern-day full-back can get up and down the pitch and I knew [Milner] would be comfortable". In England's second match against Spain, Milner had a penalty saved by Sergio Asenjo, and scored England's second goal in a 2–0 win. England faced the hosts Sweden in the semi-finals. After the match ended in a 3–3 draw, it went to a penalty shoot-out. Milner was the only England player to miss in the shoot-out after he slipped just before kicking the ball, causing it to go over the crossbar. England won the shoot-out 5–4 to advance to the final for the first time in 25 years. England lost the final to Germany 4–0 and Milner said after the match that the team was "hurting" and that the way in which the team lost was "not good enough". The final was his last match for the under-21 team. His 46 appearances at under-21 level are a national record.


title: James Milner

text: In August 2009, Milner made his debut for the England senior team, when he came on as a substitute in a friendly match against the Netherlands for the final 23 minutes. The match ended in a 2–2 draw. He played again for England the following month against Slovenia in another friendly and made his competitive debut four days later in a 2010 FIFA World Cup qualifier against Croatia, where he played the final nine minutes. England won the latter match 5–1 to secure qualification for the 2010 FIFA World Cup. He was named in the final 23-man squad for the World Cup finals in South Africa and was selected in the starting eleven for England's first match of the tournament against the United States, although he was substituted after 30 minutes. In England's third match against Slovenia, he set up the only goal of the match with a cross for Jermain Defoe. He captained England for the first time for the final 10 minutes of the match in a 2–1 loss against France on 17 November 2010, when both Rio Ferdinand and Steven Gerrard had been substituted.


title: James Milner

text: Milner played in six matches during qualifying for UEFA Euro 2012, and was named in Roy Hodgson's 23-man squad for the tournament. Milner started Hodgson's first match in charge, a 1–0 friendly win against Norway.


title: James Milner

text: He started all of England's group stage games as the Three Lions finished top of group D and qualified for the quarter finals. He started but was taken off after an hour as England were eliminated by Italy in a penalty shoot-out.


title: James Milner

text: On 7 September 2012, Milner scored his first and only international goal in a 5–0 win away to Moldova during 2014 FIFA World Cup qualifying.


title: James Milner

text: Milner was included in Hodgson's squad for the 2014 FIFA World Cup. However, Milner failed to secure a regular starting place, coming on as a substitute in the final group game against Costa Rica after England had already been eliminated, with the game ending in a 0–0 draw.


title: James Milner

text: Milner was part of the England squad for EURO 2016, but once again was unable to secure regular playing time. Milner played just five minutes in the group stage, coming on as a late substitute against Russia, and did not play in England's loss to Iceland in the round of 16.


title: James Milner

text: On 5 August 2016, Milner announced his retirement from international duty following discussions with new England manager Sam Allardyce.


title: James Milner

text: The England manager Gareth Southgate enquired Milner's availability at the 2018 World Cup, but Milner politely declined to return to international action.


title: James Milner

text: Milner is renowned for his versatility; across his career, Milner has played as a central midfielder, a defensive midfielder and as an attacking midfielder, as well as on the wing, and as a full-back, with Milner's preferred position being as a central midfielder. During his time at Leeds United, Milner predominantly played as a winger, before moving into central midfield during his time at Aston Villa.


title: James Milner

text: Milner is regarded as being a tenacious footballer. As a result, his main role on the team is as a wide midfielder who creates scoring opportunities. While Milner does not score many goals, he does have a good record at providing assists, with over 80 in the Premier League placing him 8th all time. Nolberto Solano, a former teammate, said that because of his ability, Milner would "become an important team player". After his move to Newcastle, he began playing more as a winger. He has been described as "comfortable on either wing". He has also been used occasionally as a central midfielder, a striker and as an emergency right-back, generally during an injury crisis. Manuel Pellegrini, who managed Milner at Manchester City, described him as the most complete English player in the modern game, praising his all round ability, commitment, performance level and versatility.


title: James Milner

text: Milner has the ability to pass accurately and shoot from a great distance from goal. As a result, he usually goes forward for set pieces and is often a candidate to take corners and free kicks. Critical opinion is divided as to Milner's crossing ability. While some commentators have been critical of his ability in this area, other journalists have said that Milner can produce accurate crosses.


title: James Milner

text: Milner, in his time at the club, was described on the Newcastle United official website as "a good reader of the game". This awareness allows him to pass the ball from a range of positions to teammates making forward runs, as well as giving him the confidence to take on defenders. His awareness and willingness to pass at the age of 17 were seen as mature for a player of his age.


title: James Milner

text: Under Jürgen Klopp, Milner spent all of the 2016–17 season playing at left-back for Liverpool. Milner stated he did not enjoy playing as a left-back but also said: "It's about whatever's best for the team and ultimately I just want to be out there playing games, contributing and helping this football club." He also played in a holding role and in a box-to-box role on occasion, drawing praise in the media for his dynamism, energy, work-rate, and consistent performances. In 2015, "The Telegraph" included him at number seven in their list of "The top 20 most under-rated footballers of all time", describing him as "hard working, reliable and intelligent."


title: James Milner

text: Milner is married to Amy Fletcher. The couple have two children: a daughter and a son. Milner learnt to speak Spanish in order to better communicate with his teammates, and speaks to his children only in Spanish to ensure they too learn the language.


title: James Milner

text: Milner set up the James Milner Foundation, which holds a themed annual ball to raise money for various charitable causes. He is teetotal.


title: James Milner

text: Milner was appointed Member of the Order of the British Empire (MBE) in the 2022 Birthday Honours for services to association football and charity.


title: Longest recorded sniper kills

text: Reports regarding the longest recorded sniper kills that contain information regarding the shooting distance and the identity of the sniper have been presented to the general public since 1967. Snipers have had a substantial history following the development of long distance weaponry. As weapons, ammunition, and aids to determine ballistic solutions improved, so too did the distance from which a kill could be targeted. In mid-2017 it was reported that an unnamed Canadian special forces operator, based in Iraq, had set a new record of , beating the record previously held by an Australian sniper (also unnamed) at .


title: Longest recorded sniper kills

text: Although optical equipment such as rangefinders and ballistic calculators have largely eliminated manual calculations to determine elevation and windage, the fundamentals of accurate and precise long-range shooting remain essentially the same since the early history of shooting, and the skill and training of the shooter, and the shooter's spotter where applicable, are the primary factors. Accuracy and precision of ammunition and firearms are also still reliant primarily on human factors and attention to detail in the complex process of producing maximum performance.


title: Longest recorded sniper kills

text: The modern method of long-distance sniping (shots over ) requires intense training and practice. A sniper must have the ability to accurately estimate the various factors that influence a bullet's trajectory and point of impact, such as the shooter's distance from the target, wind direction, wind speed, air density, elevation, and even the Coriolis effect. Mistakes in estimation compound over distance and can cause a shot to only injure, or to miss completely. Any given combination of firearm and ammunition will have an associated value, known as the circular error probable (CEP), defined as the radius of a circle whose boundary is expected to contain the impact points of half of the rounds fired.


title: Longest recorded sniper kills

text: If the shooter wishes to improve accuracy, increase range, or both, the accuracy of estimates of external factors must improve accordingly. At extreme ranges, highly accurate estimates are required and even with the most accurate estimates, hitting the target becomes subject to uncontrollable factors. For example, a rifle capable of firing a ½ or 0.5 MOA (approximately 0.5 inch center to center of the two holes furthest apart) 5-round group (often referred to as "grouping") at 100 yards will theoretically fire a 12.5 inch group at 2,500 yards (0.5 × 2,500/100 = 12.5). Unless the group is centered perfectly on the target at 100 yards, the 2,500-yard group will be centered 25 times the off-center error at 100 yards. This example ignores all other factors and assumes no-wind shooting conditions, identical muzzle velocities, and identical ballistic performance for each shot.


title: Longest recorded sniper kills

text: USMC Gunnery Sergeant Carlos Hathcock's confirmed kill in the Vietnam War was primarily due to the enemy soldier stopping his bicycle on the spot Hathcock had fired at while sighting in his Browning M2 heavy machine-gun.


title: Longest recorded sniper kills

text: Devices such as laser rangefinders, handheld meteorological measuring equipment, handheld computers, and ballistic-prediction software can contribute to increased accuracy (i.e. reduced CEP), although they rely on proper use and training to realize any advantages. In addition, as instruments of measure, they are subject to accuracy errors and malfunction. Handheld meteorological instruments only measure conditions at the location they are used. Wind direction and speed can vary dramatically along the path of the bullet.


title: Longest recorded sniper kills

text: The science of long-range sniping came to fruition in the Vietnam War. US Marine Gunnery Sergeant Carlos Hathcock held the record from 1967 to 2002 at . He recorded 93 official kills. After returning to the US, Hathcock helped to establish the Marine Corps Scout Sniper School at Quantico, Virginia.


title: Longest recorded sniper kills

text: In addition to his success as a USMC scout-sniper during multiple deployments to Vietnam, Hathcock competed in multiple USMC shooting teams. Hathcock also won the 1966 Wimbledon Cup, which is earned by the winner of the US 1,000-yard high-powered rifle National Championship. Even after being severely burned during an attack on an Amtrac on which he was riding in his efforts to rescue other soldiers, and after being diagnosed with multiple sclerosis, Hathcock continued to serve, shoot and instruct. In Vietnam, Hathcock also completed missions involving a "through the scope" shot which killed an enemy sniper specifically hunting him, and a multiple-day solo stalk and kill of an enemy general.


title: Longest recorded sniper kills

text: Hathcock's record stood until Canadian sniper Arron Perry of Princess Patricia's Canadian Light Infantry exceeded it with a shot of . Perry held the title for only a few days, as another man in his unit, Corporal Rob Furlong, beat Perry's distance with a shot in March 2002. Perry and Furlong were part of a six-man sniper team during 2002's Operation Anaconda, part of the War in Afghanistan.


title: Longest recorded sniper kills

text: Corporal Furlong's record was bested by a British soldier, Corporal of Horse Craig Harrison, of the Blues and Royals, Household Cavalry, who recorded two consecutive shots (confirmed by GPS) in November 2009, also during the War in Afghanistan, in which he hit two Taliban insurgents consecutively. Harrison killed the two Taliban machine gunners with shots that took the 8.59 mm (0.338 inch) rounds almost five seconds to hit their targets, which were beyond the L115A3 sniper rifle’s recommended range. A third shot took out the insurgents' machine gun. The rifle used was made by Accuracy International.


title: Longest recorded sniper kills

text: In June 2017, an unnamed sniper from Canada's Tier 1 special forces unit, Joint Task Force 2, surpassed the 2009 record by over , with a shot in the Iraqi Civil War. As with the previous two Canadian records, a McMillan Tac-50 with .50 BMG ammunition was used.


title: Longest recorded sniper kills

text: This list is not exhaustive, as such data is generally not tracked nor managed under any official procedure. For example, the Canadian Army 2002 sniper team that saw two soldiers (Arron Perry/2,310 m and Rob Furlong/2,430 m) set consecutive new records, also made a number of kills at that are not counted here. The list also shows that, in some cases, an armed force command may choose to withhold the name of the sniper for security reasons.


title: Law

text: Law is a set of rules that are created and are enforceable by social or governmental institutions to regulate behavior, with its precise definition a matter of longstanding debate. It has been variously described as a science and as the art of justice. State-enforced laws can be made by a group legislature or by a single legislator, resulting in statutes; by the executive through decrees and regulations; or established by judges through precedent, usually in common law jurisdictions. Private individuals may create legally binding contracts, including arbitration agreements that adopt alternative ways of resolving disputes to standard court litigation. The creation of laws themselves may be influenced by a constitution, written or tacit, and the rights encoded therein. The law shapes politics, economics, history and society in various ways and serves as a mediator of relations between people.


title: Law

text: Legal systems vary between jurisdictions, with their differences analysed in comparative law. In civil law jurisdictions, a legislature or other central body codifies and consolidates the law. In common law systems, judges may make binding case law through precedent, although on occasion this may be overturned by a higher court or the legislature. Historically, religious law has influenced secular matters and is, as of the 21st century, still in use in some religious communities. Sharia law based on Islamic principles is used as the primary legal system in several countries, including Iran and Saudi Arabia.


title: Law

text: The scope of law can be divided into two domains. Public law concerns government and society, including constitutional law, administrative law, and criminal law. Private law deals with legal disputes between individuals and/or organisations in areas such as contracts, property, torts/delicts and commercial law. This distinction is stronger in civil law countries, particularly those with a separate system of administrative courts; by contrast, the public-private law divide is less pronounced in common law jurisdictions.


title: Law

text: Law provides a source of scholarly inquiry into legal history, philosophy, economic analysis and sociology. Law also raises important and complex issues concerning equality, fairness, and justice.


title: Law

text: The philosophy of law is commonly known as jurisprudence. Normative jurisprudence asks "what should law be?", while analytic jurisprudence asks "what is law?"


title: Law

text: There have been several attempts to produce "a universally acceptable definition of law". In 1972, Baron Hampstead suggested that no such definition could be produced. McCoubrey and White said that the question "what is law?" has no simple answer. Glanville Williams said that the meaning of the word "law" depends on the context in which that word is used. He said that, for example, "early customary law" and "municipal law" were contexts where the word "law" had two different and irreconcilable meanings. Thurman Arnold said that it is obvious that it is impossible to define the word "law" and that it is also equally obvious that the struggle to define that word should not ever be abandoned. It is possible to take the view that there is no need to define the word "law" (e.g. "let's forget about generalities and get down to cases").


title: Law

text: One definition is that law is a system of rules and guidelines which are enforced through social institutions to govern behaviour. In "The Concept of Law," H.L.A Hart argued that law is a "system of rules"; John Austin said law was "the command of a sovereign, backed by the threat of a sanction"; Ronald Dworkin describes law as an "interpretive concept" to achieve justice in his text titled "Law's Empire"; and Joseph Raz argues law is an "authority" to mediate people's interests. Oliver Wendell Holmes said, "The prophecies of what the courts will do in fact, and nothing more pretentious, are what I mean by the law." In his "Treatise on Law," Thomas Aquinas argues that law is a rational ordering of things which concern the common good that is promulgated by whoever is charged with the care of the community. This definition has both positivist and naturalist elements.


title: Law

text: Definitions of law often raise the question of the extent to which law incorporates morality. John Austin's utilitarian answer was that law is "commands, backed by threat of sanctions, from a sovereign, to whom people have a habit of obedience". Natural lawyers on the other side, such as Jean-Jacques Rousseau, argue that law reflects essentially moral and unchangeable laws of nature. The concept of "natural law" emerged in ancient Greek philosophy concurrently and in connection with the notion of justice, and re-entered the mainstream of Western culture through the writings of Thomas Aquinas, notably his "Treatise on Law".


title: Law

text: When having completed the first two parts of his book "Splendeurs et misères des courtisanes", which he intended to be the end of the entire work, Honoré de Balzac visited the Conciergerie. Thereafter, he decided to add a third part, finally named "Où mènent les mauvais chemins" ("The Ends of Evil Ways"), entirely dedicated to describing the conditions in prison. In this third part, he states:


title: Law

text: Hugo Grotius, the founder of a purely rationalistic system of natural law, argued that law arises from both a social impulse—as Aristotle had indicated—and reason. Immanuel Kant believed a moral imperative requires laws "be chosen as though they should hold as universal laws of nature". Jeremy Bentham and his student Austin, following David Hume, believed that this conflated the "is" and what "ought to be" problem. Bentham and Austin argued for law's positivism; that real law is entirely separate from "morality". Kant was also criticised by Friedrich Nietzsche, who rejected the principle of equality, and believed that law emanates from the will to power, and cannot be labeled as "moral" or "immoral".


title: Law

text: In 1934, the Austrian philosopher Hans Kelsen continued the positivist tradition in his book the "Pure Theory of Law". Kelsen believed that although law is separate from morality, it is endowed with "normativity", meaning we ought to obey it. While laws are positive "is" statements (e.g. the fine for reversing on a highway "is" €500); law tells us what we "should" do. Thus, each legal system can be hypothesised to have a basic norm ("Grundnorm") instructing us to obey. Kelsen's major opponent, Carl Schmitt, rejected both positivism and the idea of the rule of law because he did not accept the primacy of abstract normative principles over concrete political positions and decisions. Therefore, Schmitt advocated a jurisprudence of the exception (state of emergency), which denied that legal norms could encompass all of the political experience.


title: Law

text: Later in the 20th century, H. L. A. Hart attacked Austin for his simplifications and Kelsen for his fictions in "The Concept of Law". Hart argued law is a system of rules, divided into primary (rules of conduct) and secondary ones (rules addressed to officials to administer primary rules). Secondary rules are further divided into rules of adjudication (to resolve legal disputes), rules of change (allowing laws to be varied) and the rule of recognition (allowing laws to be identified as valid). Two of Hart's students continued the debate: In his book "Law's Empire", Ronald Dworkin attacked Hart and the positivists for their refusal to treat law as a moral issue. Dworkin argues that law is an "interpretive concept", that requires judges to find the best fitting and most just solution to a legal dispute, given their constitutional traditions. Joseph Raz, on the other hand, defended the positivist outlook and criticised Hart's "soft social thesis" approach in "The Authority of Law". Raz argues that law is authority, identifiable purely through social sources and without reference to moral reasoning. In his view, any categorisation of rules beyond their role as authoritative instruments in mediation are best left to sociology, rather than jurisprudence.


title: Law

text: The history of law links closely to the development of civilization. Ancient Egyptian law, dating as far back as 3000 BC, was based on the concept of Ma'at and characterised by tradition, rhetorical speech, social equality and impartiality. By the 22nd century BC, the ancient Sumerian ruler Ur-Nammu had formulated the first law code, which consisted of casuistic statements ("if … then ..."). Around 1760 BC, King Hammurabi further developed Babylonian law, by codifying and inscribing it in stone. Hammurabi placed several copies of his law code throughout the kingdom of Babylon as stelae, for the entire public to see; this became known as the Codex Hammurabi. The most intact copy of these stelae was discovered in the 19th century by British Assyriologists, and has since been fully transliterated and translated into various languages, including English, Italian, German, and French.


title: Law

text: The Old Testament dates back to 1280 BC and takes the form of moral imperatives as recommendations for a good society. The small Greek city-state, ancient Athens, from about the 8th century BC was the first society to be based on broad inclusion of its citizenry, excluding women and enslaved people. However, Athens had no legal science or single word for "law", relying instead on the three-way distinction between divine law ("thémis"), human decree ("nomos") and custom ("díkē"). Yet Ancient Greek law contained major constitutional innovations in the development of democracy.


title: Law

text: Roman law was heavily influenced by Greek philosophy, but its detailed rules were developed by professional jurists and were highly sophisticated. Over the centuries between the rise and decline of the Roman Empire, law was adapted to cope with the changing social situations and underwent major codification under Theodosius II and Justinian I. Although codes were replaced by custom and case law during the Early Middle Ages, Roman law was rediscovered around the 11th century when medieval legal scholars began to research Roman codes and adapt their concepts to the canon law, giving birth to the "jus commune". Latin legal maxims (called brocards) were compiled for guidance. In medieval England, royal courts developed a body of precedent which later became the common law. A Europe-wide Law Merchant was formed so that merchants could trade with common standards of practice rather than with the many splintered facets of local laws. The Law Merchant, a precursor to modern commercial law, emphasised the freedom to contract and alienability of property. As nationalism grew in the 18th and 19th centuries, the Law Merchant was incorporated into countries' local law under new civil codes. The Napoleonic and German Codes became the most influential. In contrast to English common law, which consists of enormous tomes of case law, codes in small books are easy to export and easy for judges to apply. However, today there are signs that civil and common law are converging. EU law is codified in treaties, but develops through "de facto" precedent laid down by the European Court of Justice.


title: Law

text: Ancient India and China represent distinct traditions of law, and have historically had independent schools of legal theory and practice. The "Arthashastra", probably compiled around 100 AD (although it contains older material), and the "Manusmriti" (c. 100–300 AD) were foundational treatises in India, and comprise texts considered authoritative legal guidance. Manu's central philosophy was tolerance and pluralism, and was cited across Southeast Asia. During the Muslim conquests in the Indian subcontinent, sharia was established by the Muslim sultanates and empires, most notably Mughal Empire's Fatawa-e-Alamgiri, compiled by emperor Aurangzeb and various scholars of Islam. In India, the Hindu legal tradition, along with Islamic law, were both supplanted by common law when India became part of the British Empire. Malaysia, Brunei, Singapore and Hong Kong also adopted the common law system. The eastern Asia legal tradition reflects a unique blend of secular and religious influences. Japan was the first country to begin modernising its legal system along western lines, by importing parts of the French, but mostly the German Civil Code. This partly reflected Germany's status as a rising power in the late 19th century. Similarly, traditional Chinese law gave way to westernisation towards the final years of the Qing Dynasty in the form of six private law codes based mainly on the Japanese model of German law. Today Taiwanese law retains the closest affinity to the codifications from that period, because of the split between Chiang Kai-shek's nationalists, who fled there, and Mao Zedong's communists who won control of the mainland in 1949. The current legal infrastructure in the People's Republic of China was heavily influenced by Soviet Socialist law, which essentially inflates administrative law at the expense of private law rights. Due to rapid industrialisation, today China is undergoing a process of reform, at least in terms of economic, if not social and political, rights. A new contract code in 1999 represented a move away from administrative domination. Furthermore, after negotiations lasting fifteen years, in 2001 China joined the World Trade Organization.


title: Law

text: In general, legal systems can be split between civil law and common law systems. Modern scholars argue that the significance of this distinction has progressively declined; the numerous legal transplants, typical of modern law, result in the sharing by modern legal systems of many features traditionally considered typical of either common law or civil law. The term "civil law", referring to the civilian legal system originating in continental Europe, should not be confused with "civil law" in the sense of the common law topics distinct from criminal law and public law.


title: Law

text: The third type of legal system—accepted by some countries without separation of church and state—is religious law, based on scriptures. The specific system that a country is ruled by is often determined by its history, connections with other countries, or its adherence to international standards. The sources that jurisdictions adopt as authoritatively binding are the defining features of any legal system. Yet classification is a matter of form rather than substance since similar rules often prevail.


title: Law

text: Civil law is the legal system used in most countries around the world today. In civil law the sources recognised as authoritative are, primarily, legislation—especially codifications in constitutions or statutes passed by government—and custom. Codifications date back millennia, with one early example being the Babylonian "Codex Hammurabi". Modern civil law systems essentially derive from legal codes issued by Byzantine Emperor Justinian I in the 6th century, which were rediscovered by 11th century Italy. Roman law in the days of the Roman Republic and Empire was heavily procedural, and lacked a professional legal class. Instead a lay magistrate, "iudex", was chosen to adjudicate. Decisions were not published in any systematic way, so any case law that developed was disguised and almost unrecognised. Each case was to be decided afresh from the laws of the State, which mirrors the (theoretical) unimportance of judges' decisions for future cases in civil law systems today. From 529 to 534 AD the Byzantine Emperor Justinian I codified and consolidated Roman law up until that point, so that what remained was one-twentieth of the mass of legal texts from before. This became known as the "Corpus Juris Civilis". As one legal historian wrote, "Justinian consciously looked back to the golden age of Roman law and aimed to restore it to the peak it had reached three centuries before." The Justinian Code remained in force in the East until the fall of the Byzantine Empire. Western Europe, meanwhile, relied on a mix of the Theodosian Code and Germanic customary law until the Justinian Code was rediscovered in the 11th century, and scholars at the University of Bologna used it to interpret their own laws. Civil law codifications based closely on Roman law, alongside some influences from religious laws such as canon law, continued to spread throughout Europe until the Enlightenment; then, in the 19th century, both France, with the "Code Civil", and Germany, with the "Bürgerliches Gesetzbuch", modernised their legal codes. Both these codes influenced heavily not only the law systems of the countries in continental Europe (e.g. Greece), but also the Japanese and Korean legal traditions. Today, countries that have civil law systems range from Russia and Turkey to most of Central and Latin America.


title: Law

text: Anarchism has been practiced in society in much of the world. Mass anarchist communities, ranging from Syria to the United States, exist and vary from hundreds to millions. Anarchism encompasses a broad range of social political philosophies with different tendencies and implementation.


title: Law

text: Anarchist law primarily deals with how anarchism is implemented upon a society, the framework based on decentralized organizations and mutual aid, with representation through a form of direct democracy. Laws being based upon their need. A large portion of anarchist ideologies such as anarcho-syndicalism and anarcho-communism primarily focuses on decentralized worker unions, cooperatives and syndicates as the main instrument of society.


title: Law

text: Socialist law is the legal systems in communist states such as the former Soviet Union and the People's Republic of China. Academic opinion is divided on whether it is a separate system from civil law, given major deviations based on Marxist–Leninist ideology, such as subordinating the judiciary to the executive ruling party.


title: Law

text: In common law legal systems, decisions by courts are explicitly acknowledged as "law" on equal footing with statutes adopted through the legislative process and with regulations issued by the executive branch. The "doctrine of precedent", or "stare decisis" (Latin for "to stand by decisions") means that decisions by higher courts bind lower courts, and future decisions of the same court, to assure that similar cases reach similar results. In contrast, in "civil law" systems, legislative statutes are typically more detailed, and judicial decisions are shorter and less detailed, because the judge or barrister is only writing to decide the single case, rather than to set out reasoning that will guide future courts.


title: Law

text: Common law originated from England and has been inherited by almost every country once tied to the British Empire (except Malta, Scotland, the U.S. state of Louisiana, and the Canadian province of Quebec). In medieval England, the Norman conquest the law varied shire-to-shire, based on disparate tribal customs. The concept of a "common law" developed during the reign of Henry II during the late 12th century, when Henry appointed judges that had authority to create an institutionalised and unified system of law "common" to the country. The next major step in the evolution of the common law came when King John was forced by his barons to sign a document limiting his authority to pass laws. This "great charter" or "Magna Carta" of 1215 also required that the King's entourage of judges hold their courts and judgments at "a certain place" rather than dispensing autocratic justice in unpredictable places about the country. A concentrated and elite group of judges acquired a dominant role in law-making under this system, and compared to its European counterparts the English judiciary became highly centralised. In 1297, for instance, while the highest court in France had fifty-one judges, the English Court of Common Pleas had five. This powerful and tight-knit judiciary gave rise to a systematised process of developing common law.


title: Law

text: However, the system became overly systematised—overly rigid and inflexible. As a result, as time went on, increasing numbers of citizens petitioned the King to override the common law, and on the King's behalf the Lord Chancellor gave judgment to do what was equitable in a case. From the time of Sir Thomas More, the first lawyer to be appointed as Lord Chancellor, a systematic body of equity grew up alongside the rigid common law, and developed its own Court of Chancery. At first, equity was often criticised as erratic, that it varied according to the length of the Chancellor's foot. Over time, courts of equity developed solid principles, especially under Lord Eldon. In the 19th century in England, and in 1937 in the U.S., the two systems were merged.


title: Law

text: In developing the common law, academic writings have always played an important part, both to collect overarching principles from dispersed case law, and to argue for change. William Blackstone, from around 1760, was the first scholar to collect, describe, and teach the common law. But merely in describing, scholars who sought explanations and underlying structures slowly changed the way the law actually worked.


title: Law

text: Religious law is explicitly based on religious precepts. Examples include the Jewish Halakha and Islamic Sharia—both of which translate as the "path to follow"—while Christian canon law also survives in some church communities. Often the implication of religion for law is unalterability, because the word of God cannot be amended or legislated against by judges or governments. However, a thorough and detailed legal system generally requires human elaboration. For instance, the Quran has some law, and it acts as a source of further law through interpretation, "Qiyas" (reasoning by analogy), "Ijma" (consensus) and precedent. This is mainly contained in a body of law and jurisprudence known as Sharia and Fiqh respectively. Another example is the Torah or Old Testament, in the Pentateuch or Five Books of Moses. This contains the basic code of Jewish law, which some Israeli communities choose to use. The Halakha is a code of Jewish law that summarizes some of the Talmud's interpretations. Nevertheless, Israeli law allows litigants to use religious laws only if they choose. Canon law is only in use by members of the Catholic Church, the Eastern Orthodox Church and the Anglican Communion.


title: Law

text: Canon law (from Greek "kanon", a 'straight measuring rod, ruler') is a set of ordinances and regulations made by ecclesiastical authority (Church leadership), for the government of a Christian organisation or church and its members. It is the internal ecclesiastical law governing the Catholic Church (both the Latin Church and the Eastern Catholic Churches), the Eastern Orthodox and Oriental Orthodox churches, and the individual national churches within the Anglican Communion. The way that such church law is legislated, interpreted and at times adjudicated varies widely among these three bodies of churches. In all three traditions, a canon was originally a rule adopted by a church council; these canons formed the foundation of canon law.


title: Law

text: The Catholic Church has the oldest continuously functioning legal system in the western world, predating the evolution of modern European civil law and common law systems. The 1983 Code of Canon Law governs the Latin Church "sui juris". The Eastern Catholic Churches, which developed different disciplines and practices, are governed by the "Code of Canons of the Eastern Churches". The canon law of the Catholic Church influenced the common law during the medieval period through its preservation of Roman law doctrine such as the presumption of innocence.


title: Law

text: Until the 18th century, Sharia law was practiced throughout the Muslim world in a non-codified form, with the Ottoman Empire's Mecelle code in the 19th century being a first attempt at codifying elements of Sharia law. Since the mid-1940s, efforts have been made, in country after country, to bring Sharia law more into line with modern conditions and conceptions. In modern times, the legal systems of many Muslim countries draw upon both civil and common law traditions as well as Islamic law and custom. The constitutions of certain Muslim states, such as Egypt and Afghanistan, recognise Islam as the religion of the state, obliging legislature to adhere to Sharia. Saudi Arabia recognises Quran as its constitution, and is governed on the basis of Islamic law. Iran has also witnessed a reiteration of Islamic law into its legal system after 1979. During the last few decades, one of the fundamental features of the movement of Islamic resurgence has been the call to restore the Sharia, which has generated a vast amount of literature and affected world politics.


title: Law

text: There are distinguished methods of legal reasoning (applying the law) and methods of interpreting (construing) the law. The former are legal syllogism, which holds sway in civil law legal systems, analogy, which is present in common law legal systems, especially in the US, and argumentative theories that occur in both systems. The latter are different rules (directives) of legal interpretation such as directives of linguistic interpretation, teleological interpretation or systemic interpretation as well as more specific rules, for instance, golden rule or mischief rule. There are also many other arguments and cannons of interpretation which altogether make statutory interpretation possible.


title: Law

text: Law professor and former United States Attorney General Edward H. Levi noted that the "basic pattern of legal reasoning is reasoning by example"—that is, reasoning by comparing outcomes in cases resolving similar legal questions. In a U.S. Supreme Court case regarding procedural efforts taken by a debt collection company to avoid errors, Justice Sotomayor cautioned that "legal reasoning is not a mechanical or strictly linear process".


title: Law

text: Jurimetrics is the formal application of quantitative methods, especially probability and statistics, to legal questions. The use of statistical methods in court cases and law review articles has grown massively in importance in the last few decades.


title: Law

text: The main institutions of law in industrialised countries are independent courts, representative parliaments, an accountable executive, the military and police, bureaucratic organisation, the legal profession and civil society itself. John Locke, in his "Two Treatises of Government", and Baron de Montesquieu in "The Spirit of the Laws", advocated for a separation of powers between the political, legislature and executive bodies. Their principle was that no person should be able to usurp all powers of the state, in contrast to the absolutist theory of Thomas Hobbes' "Leviathan". Sun Yat-sen's Five Power Constitution for the Republic of China took the separation of powers further by having two additional branches of government—a Control Yuan for auditing oversight and an Examination Yuan to manage the employment of public officials.


title: Law

text: Max Weber and others reshaped thinking on the extension of state. Modern military, policing and bureaucratic power over ordinary citizens' daily lives pose special problems for accountability that earlier writers such as Locke or Montesquieu could not have foreseen. The custom and practice of the legal profession is an important part of people's access to justice, whilst civil society is a term used to refer to the social institutions, communities and partnerships that form law's political basis.


title: Law

text: A judiciary is a number of judges mediating disputes to determine outcome. Most countries have systems of appeal courts, with an apex court as the ultimate judicial authority. In the United States, this authority is the Supreme Court; in Australia, the High Court; in the UK, the Supreme Court; in Germany, the "Bundesverfassungsgericht"; and in France, the "Cour de Cassation". For most European countries the European Court of Justice in Luxembourg can overrule national law, when EU law is relevant. The European Court of Human Rights in Strasbourg allows citizens of the Council of Europe member states to bring cases relating to human rights issues before it.


title: Law

text: Some countries allow their highest judicial authority to overrule legislation they determine to be unconstitutional. For example, in "Brown v. Board of Education", the United States Supreme Court nullified many state statutes that had established racially segregated schools, finding such statutes to be incompatible with the Fourteenth Amendment to the United States Constitution.


title: Law

text: A judiciary is theoretically bound by the constitution, just as all other government bodies are. In most countries judges may only interpret the constitution and all other laws. But in common law countries, where matters are not constitutional, the judiciary may also create law under the doctrine of precedent. The UK, Finland and New Zealand assert the ideal of parliamentary sovereignty, whereby the unelected judiciary may not overturn law passed by a democratic legislature.


title: Law

text: In communist states, such as China, the courts are often regarded as parts of the executive, or subservient to the legislature; governmental institutions and actors exert thus various forms of influence on the judiciary. In Muslim countries, courts often examine whether state laws adhere to the Sharia: the Supreme Constitutional Court of Egypt may invalidate such laws, and in Iran the Guardian Council ensures the compatibility of the legislation with the "criteria of Islam".


title: Law

text: Prominent examples of legislatures are the Houses of Parliament in London, the Congress in Washington, D.C., the Bundestag in Berlin, the Duma in Moscow, the Parlamento Italiano in Rome and the "Assemblée nationale" in Paris. By the principle of representative government people vote for politicians to carry out "their" wishes. Although countries like Israel, Greece, Sweden and China are unicameral, most countries are bicameral, meaning they have two separately appointed legislative houses.


title: Law

text: In the 'lower house' politicians are elected to represent smaller constituencies. The 'upper house' is usually elected to represent states in a federal system (as in Australia, Germany or the United States) or different voting configuration in a unitary system (as in France). In the UK the upper house is appointed by the government as a house of review. One criticism of bicameral systems with two elected chambers is that the upper and lower houses may simply mirror one another. The traditional justification of bicameralism is that an upper chamber acts as a house of review. This can minimise arbitrariness and injustice in governmental action.


title: Law

text: To pass legislation, a majority of the members of a legislature must vote for a bill (proposed law) in each house. Normally there will be several readings and amendments proposed by the different political factions. If a country has an entrenched constitution, a special majority for changes to the constitution may be required, making changes to the law more difficult. A government usually leads the process, which can be formed from Members of Parliament (e.g. the UK or Germany). However, in a presidential system, the government is usually formed by an executive and his or her appointed cabinet officials (e.g. the United States or Brazil).


title: Law

text: The executive in a legal system serves as the centre of political authority of the State. In a parliamentary system, as with Britain, Italy, Germany, India, and Japan, the executive is known as the cabinet, and composed of members of the legislature. The executive is led by the head of government, whose office holds power under the confidence of the legislature. Because popular elections appoint political parties to govern, the leader of a party can change in between elections.


title: Law

text: The head of state is apart from the executive, and symbolically enacts laws and acts as representative of the nation. Examples include the President of Germany (appointed by members of federal and state legislatures), the Queen of the United Kingdom (an hereditary office), and the President of Austria (elected by popular vote). The other important model is the presidential system, found in the United States and in Brazil. In presidential systems, the executive acts as both head of state and head of government, and has power to appoint an unelected cabinet. Under a presidential system, the executive branch is separate from the legislature to which it is not accountable.


title: Law

text: Although the role of the executive varies from country to country, usually it will propose the majority of legislation, and propose government agenda. In presidential systems, the executive often has the power to veto legislation. Most executives in both systems are responsible for foreign relations, the military and police, and the bureaucracy. Ministers or other officials head a country's public offices, such as a foreign ministry or defence ministry. The election of a different executive is therefore capable of revolutionising an entire country's approach to government.


title: Law

text: While military organisations have existed as long as government itself, the idea of a standing police force is a relatively modern concept. For example, Medieval England's system of travelling criminal courts, or assizes, used show trials and public executions to instill communities with fear to maintain control. The first modern police were probably those in 17th-century Paris, in the court of Louis XIV, although the Paris Prefecture of Police claim they were the world's first uniformed policemen.


title: Law

text: Max Weber famously argued that the state is that which controls the monopoly on the legitimate use of force. The military and police carry out enforcement at the request of the government or the courts. The term failed state refers to states that cannot implement or enforce policies; their police and military no longer control security and order and society moves into anarchy, the absence of government.


title: Law

text: The etymology of "bureaucracy" derives from the French word for "office" ("bureau") and the Ancient Greek for word "power" ("kratos"). Like the military and police, a legal system's government servants and bodies that make up its bureaucracy carry out the directives of the executive. One of the earliest references to the concept was made by Baron de Grimm, a German author who lived in France. In 1765, he wrote:


title: Law

text: The real spirit of the laws in France is that bureaucracy of which the late Monsieur de Gournay used to complain so greatly; here the offices, clerks, secretaries, inspectors and "intendants" are not appointed to benefit the public interest, indeed the public interest appears to have been established so that offices might exist.


title: Law

text: Cynicism over "officialdom" is still common, and the workings of public servants is typically contrasted to private enterprise motivated by profit. In fact private companies, especially large ones, also have bureaucracies. Negative perceptions of "red tape" aside, public services such as schooling, health care, policing or public transport are considered a crucial state function making public bureaucratic action the locus of government power.


title: Law

text: Writing in the early 20th century, Max Weber believed that a definitive feature of a developed state had come to be its bureaucratic support. Weber wrote that the typical characteristics of modern bureaucracy are that officials define its mission, the scope of work is bound by rules, and management is composed of career experts who manage top down, communicating through writing and binding public servants' discretion with rules.


title: Law

text: A corollary of the rule of law is the existence of a legal profession sufficiently autonomous to invoke the authority of the independent judiciary; the right to assistance of a barrister in a court proceeding emanates from this corollary—in England the function of barrister or advocate is distinguished from legal counselor. As the European Court of Human Rights has stated, the law should be adequately accessible to everyone and people should be able to foresee how the law affects them.


title: Law

text: In order to maintain professionalism, the practice of law is typically overseen by either a government or independent regulating body such as a bar association, bar council or law society. Modern lawyers achieve distinct professional identity through specified legal procedures (e.g. successfully passing a qualifying examination), are required by law to have a special qualification (a legal education earning the student a Bachelor of Laws, a Bachelor of Civil Law, or a Juris Doctor degree. Higher academic degrees may also be pursued. Examples include a Master of Laws, a Master of Legal Studies, a Bar Professional Training Course or a Doctor of Laws.), and are constituted in office by legal forms of appointment (being admitted to the bar). There are few titles of respect to signify famous lawyers, such as Esquire, to indicate barristers of greater dignity, and Doctor of law, to indicate a person who obtained a PhD in Law.


title: Law

text: Many Muslim countries have developed similar rules about legal education and the legal profession, but some still allow lawyers with training in traditional Islamic law to practice law before personal status law courts. In China and other developing countries there are not sufficient professionally trained people to staff the existing judicial systems, and, accordingly, formal standards are more relaxed.


title: Law

text: Once accredited, a lawyer will often work in a law firm, in a chambers as a sole practitioner, in a government post or in a private corporation as an internal counsel. In addition a lawyer may become a legal researcher who provides on-demand legal research through a library, a commercial service or freelance work. Many people trained in law put their skills to use outside the legal field entirely.


title: Law

text: Significant to the practice of law in the common law tradition is the legal research to determine the current state of the law. This usually entails exploring case-law reports, legal periodicals and legislation. Law practice also involves drafting documents such as court pleadings, persuasive briefs, contracts, or wills and trusts. Negotiation and dispute resolution skills (including ADR techniques) are also important to legal practice, depending on the field.


title: Law

text: The Classical republican concept of "civil society" dates back to Hobbes and Locke. Locke saw civil society as people who have "a common established law and judicature to appeal to, with authority to decide controversies between them." German philosopher Georg Wilhelm Friedrich Hegel distinguished the "state" from "civil society" ("bürgerliche Gesellschaft") in "Elements of the Philosophy of Right".


title: Law

text: Hegel believed that civil society and the state were polar opposites, within the scheme of his dialectic theory of history. The modern dipole state–civil society was reproduced in the theories of Alexis de Tocqueville and Karl Marx. In post-modern theory, civil society is necessarily a source of law, by being the basis from which people form opinions and lobby for what they believe law should be. As Australian barrister and author Geoffrey Robertson QC wrote of international law, "one of its primary modern sources is found in the responses of ordinary men and women, and of the non-governmental organizations which many of them support, to the human rights abuses they see on the television screen in their living rooms."


title: Law

text: Freedom of speech, freedom of association and many other individual rights allow people to gather, discuss, criticise and hold to account their governments, from which the basis of a deliberative democracy is formed. The more people are involved with, concerned by and capable of changing how political power is exercised over their lives, the more acceptable and legitimate the law becomes to the people. The most familiar institutions of civil society include economic markets, profit-oriented firms, families, trade unions, hospitals, universities, schools, charities, debating clubs, non-governmental organisations, neighbourhoods, churches, and religious associations. There is no clear legal definition of the civil society, and of the institutions it includes. Most of the institutions and bodies who try to give a list of institutions (such as the European Economic and Social Committee) exclude the political parties.


title: Law

text: All legal systems deal with the same basic issues, but jurisdictions categorise and identify their legal topics in different ways. A common distinction is that between "public law" (a term related closely to the state, and including constitutional, administrative and criminal law), and "private law" (which covers contract, tort and property). In civil law systems, contract and tort fall under a general law of obligations, while trusts law is dealt with under statutory regimes or international conventions. International, constitutional and administrative law, criminal law, contract, tort, property law and trusts are regarded as the "traditional core subjects", although there are many further disciplines.


title: Law

text: International law can refer to three things: public international law, private international law or conflict of laws and the law of supranational organisations.


title: Law

text: Constitutional and administrative law govern the affairs of the state. Constitutional law concerns both the relationships between the executive, legislature and judiciary and the human rights or civil liberties of individuals against the state. Most jurisdictions, like the United States and France, have a single codified constitution with a bill of rights. A few, like the United Kingdom, have no such document. A "constitution" is simply those laws which constitute the body politic, from statute, case law and convention. A case named "Entick v Carrington" illustrates a constitutional principle deriving from the common law. Entick's house was searched and ransacked by Sheriff Carrington. When Entick complained in court, Sheriff Carrington argued that a warrant from a Government minister, the Earl of Halifax, was valid authority. However, there was no written statutory provision or court authority. The leading judge, Lord Camden, stated:


title: Law

text: The great end, for which men entered into society, was to secure their property. That right is preserved sacred and incommunicable in all instances, where it has not been taken away or abridged by some public law for the good of the whole ... If no excuse can be found or produced, the silence of the books is an authority against the defendant, and the plaintiff must have judgment.


title: Law

text: The fundamental constitutional principle, inspired by John Locke, holds that the individual can do anything except that which is forbidden by law, and the state may do nothing except that which is authorised by law. Administrative law is the chief method for people to hold state bodies to account. People can sue an agency, local council, public service, or government ministry for judicial review of actions or decisions, to ensure that they comply with the law, and that the government entity observed required procedure. The first specialist administrative court was the "Conseil d'État" set up in 1799, as Napoleon assumed power in France.


title: Law

text: A subdiscipline of constitutional law is election law. It deals with rules governing elections. These rules enable the translation of the will of the people into functioning democracies. Election law addresses issues who is entitled to vote, voter registration, ballot access, campaign finance and party funding, redistricting, apportionment, electronic voting and voting machines, accessibility of elections, election systems and formulas, vote counting, election disputes, referendums, and issues such as electoral fraud and electoral silence.


title: Law

text: Criminal law, also known as penal law, pertains to crimes and punishment. It thus regulates the definition of and penalties for offences found to have a sufficiently deleterious social impact but, in itself, makes no moral judgment on an offender nor imposes restrictions on society that physically prevent people from committing a crime in the first place. Investigating, apprehending, charging, and trying suspected offenders is regulated by the law of criminal procedure. The paradigm case of a crime lies in the proof, beyond reasonable doubt, that a person is guilty of two things. First, the accused must commit an act which is deemed by society to be criminal, or "actus reus" (guilty act). Second, the accused must have the requisite malicious intent to do a criminal act, or "mens rea" (guilty mind). However, for so called "strict liability" crimes, an "actus reus" is enough. Criminal systems of the civil law tradition distinguish between intention in the broad sense ("dolus directus" and "dolus eventualis"), and negligence. Negligence does not carry criminal responsibility unless a particular crime provides for its punishment.


title: Law

text: Examples of crimes include murder, assault, fraud and theft. In exceptional circumstances defences can apply to specific acts, such as killing in self defence, or pleading insanity. Another example is in the 19th-century English case of "R v Dudley and Stephens", which tested a defence of "necessity". The "Mignonette", sailing from Southampton to Sydney, sank. Three crew members and Richard Parker, a 17-year-old cabin boy, were stranded on a raft. They were starving and the cabin boy was close to death. Driven to extreme hunger, the crew killed and ate the cabin boy. The crew survived and were rescued, but put on trial for murder. They argued it was necessary to kill the cabin boy to preserve their own lives. Lord Coleridge, expressing immense disapproval, ruled, "to preserve one's life is generally speaking a duty, but it may be the plainest and the highest duty to sacrifice it." The men were sentenced to hang, but public opinion was overwhelmingly supportive of the crew's right to preserve their own lives. In the end, the Crown commuted their sentences to six months in jail.


title: Law

text: Criminal law offences are viewed as offences against not just individual victims, but the community as well. The state, usually with the help of police, takes the lead in prosecution, which is why in common law countries cases are cited as ""The People" v ..." or ""R" (for Rex or Regina) v ...". Also, lay juries are often used to determine the guilt of defendants on points of fact: juries cannot change legal rules. Some developed countries still condone capital punishment for criminal activity, but the normal punishment for a crime will be imprisonment, fines, state supervision (such as probation), or community service. Modern criminal law has been affected considerably by the social sciences, especially with respect to sentencing, legal research, legislation, and rehabilitation. On the international field, 111 countries are members of the International Criminal Court, which was established to try people for crimes against humanity.


title: Law

text: Contract law concerns enforceable promises, and can be summed up in the Latin phrase "pacta sunt servanda" (agreements must be kept). In common law jurisdictions, three key elements to the creation of a contract are necessary: offer and acceptance, consideration and the intention to create legal relations. In "Carlill v Carbolic Smoke Ball Company" a medical firm advertised that its new wonder drug, the smokeball, would cure people's flu, and if it did not, the buyers would get £100. Many people sued for their £100 when the drug did not work. Fearing bankruptcy, Carbolic argued the advert was not to be taken as a serious, legally binding offer. It was an invitation to treat, mere puffery, a gimmick. But the Court of Appeal held that to a reasonable man Carbolic had made a serious offer, accentuated by their reassuring statement, "£1000 is deposited". Equally, people had given good consideration for the offer by going to the "distinct inconvenience" of using a faulty product. "Read the advertisement how you will, and twist it about as you will", said Lord Justice Lindley, "here is a distinct promise expressed in language which is perfectly unmistakable".


title: Law

text: Consideration indicates the fact that all parties to a contract have exchanged something of value. Some common law systems, including Australia, are moving away from the idea of consideration as a requirement. The idea of estoppel or "culpa in contrahendo", can be used to create obligations during pre-contractual negotiations.


title: Law

text: Civil law jurisdictions treat contracts differently in a number of respects, with a more interventionist role for the state in both the formation and enforcement of contracts. Compared to common law jurisdictions, civil law systems incorporate more mandatory terms into contracts, allow greater latitude for courts to interpret and revise contract terms and impose a stronger duty of good faith, but are also more likely to enforce penalty clauses and specific performance of contracts. They also do not require consideration for a contract to be binding. In France, an ordinary contract is said to form simply on the basis of a "meeting of the minds" or a "concurrence of wills". Germany has a special approach to contracts, which ties into property law. Their 'abstraction principle' ("Abstraktionsprinzip") means that the personal obligation of contract forms separately from the title of property being conferred. When contracts are invalidated for some reason (e.g. a car buyer is so drunk that he lacks legal capacity to contract) the contractual obligation to pay can be invalidated separately from the proprietary title of the car. Unjust enrichment law, rather than contract law, is then used to restore title to the rightful owner.


title: Law

text: Certain civil wrongs are grouped together as torts under common law systems and delicts under civil law systems. To have acted tortiously, one must have breached a duty to another person, or infringed some pre-existing legal right. A simple example might be unintentionally hitting someone with a cricket ball. Under the law of negligence, the most common form of tort, the injured party could potentially claim compensation for their injuries from the party responsible. The principles of negligence are illustrated by "Donoghue v Stevenson". A friend of Donoghue ordered an opaque bottle of ginger beer (intended for the consumption of Donoghue) in a café in Paisley. Having consumed half of it, Donoghue poured the remainder into a tumbler. The decomposing remains of a snail floated out. She claimed to have suffered from shock, fell ill with gastroenteritis and sued the manufacturer for carelessly allowing the drink to be contaminated. The House of Lords decided that the manufacturer was liable for Mrs Donoghue's illness. Lord Atkin took a distinctly moral approach and said:


title: Law

text: The liability for negligence [...] is no doubt based upon a general public sentiment of moral wrongdoing for which the offender must pay. [...] The rule that you are to love your neighbour becomes in law, you must not injure your neighbour; and the lawyer's question, Who is my neighbour? receives a restricted reply. You must take reasonable care to avoid acts or omissions which you can reasonably foresee would be likely to injure your neighbour.


title: Law

text: This became the basis for the four principles of negligence, namely that (1) Stevenson owed Donoghue a duty of care to provide safe drinks; (2) he breached his duty of care; (3) the harm would not have occurred but for his breach; and (4) his act was the proximate cause of her harm. Another example of tort might be a neighbour making excessively loud noises with machinery on his property. Under a nuisance claim the noise could be stopped. Torts can also involve intentional acts such as assault, battery or trespass. A better known tort is defamation, which occurs, for example, when a newspaper makes unsupportable allegations that damage a politician's reputation. More infamous are economic torts, which form the basis of labour law in some countries by making trade unions liable for strikes, when statute does not provide immunity.


title: Law

text: Property law governs ownership and possession. Real property, sometimes called 'real estate', refers to ownership of land and things attached to it. Personal property, refers to everything else; movable objects, such as computers, cars, jewelry or intangible rights, such as stocks and shares. A right "in rem" is a right to a specific piece of property, contrasting to a right "in personam" which allows compensation for a loss, but not a particular thing back. Land law forms the basis for most kinds of property law, and is the most complex. It concerns mortgages, rental agreements, licences, covenants, easements and the statutory systems for land registration. Regulations on the use of personal property fall under intellectual property, company law, trusts and commercial law. An example of a basic case of most property law is "Armory v Delamirie" [1722]. A chimney sweep's boy found a jewel encrusted with precious stones. He took it to a goldsmith to have it valued. The goldsmith's apprentice looked at it, sneakily removed the stones, told the boy it was worth three halfpence and that he would buy it. The boy said he would prefer the jewel back, so the apprentice gave it to him, but without the stones. The boy sued the goldsmith for his apprentice's attempt to cheat him. Lord Chief Justice Pratt ruled that even though the boy could not be said to own the jewel, he should be considered the rightful keeper ("finders keepers") until the original owner is found. In fact the apprentice and the boy both had a right of "possession" in the jewel (a technical concept, meaning evidence that something "could" belong to someone), but the boy's possessory interest was considered better, because it could be shown to be first in time. Possession may be nine-tenths of the law, but not all.


title: Law

text: This case is used to support the view of property in common law jurisdictions, that the person who can show the best claim to a piece of property, against any contesting party, is the owner. By contrast, the classic civil law approach to property, propounded by Friedrich Carl von Savigny, is that it is a right good against the world. Obligations, like contracts and torts, are conceptualised as rights good between individuals. The idea of property raises many further philosophical and political issues. Locke argued that our "lives, liberties and estates" are our property because we own our bodies and mix our labour with our surroundings.


title: Law

text: Equity is a body of rules that developed in England separately from the "common law". The common law was administered by judges and barristers. The Lord Chancellor on the other hand, as the King's keeper of conscience, could overrule the judge-made law if he thought it equitable to do so. This meant equity came to operate more through principles than rigid rules. Whereas neither the common law nor civil law systems allow people to split the ownership from the control of one piece of property, equity allows this through an arrangement known as a trust. Trustees control property whereas the beneficial, or equitable, ownership of trust property is held by people known as beneficiaries. Trustees owe duties to their beneficiaries to take good care of the entrusted property. In the early case of "Keech v Sandford" [1722], a child had inherited the lease on a market in Romford, London. Mr Sandford was entrusted to look after this property until the child matured. But before then, the lease expired. The landlord had (apparently) told Mr Sandford that he did not want the child to have the renewed lease. Yet the landlord was happy (apparently) to give Mr Sandford the opportunity of the lease instead. Mr Sandford took it. When the child (now Mr Keech) grew up, he sued Mr Sandford for the profit that he had been making by getting the market's lease. Mr Sandford was meant to be trusted, but he put himself in a position of conflict of interest. The Lord Chancellor, Lord King, agreed and ordered Mr Sandford should disgorge his profits. He wrote: "I very well see, if a trustee, on the refusal to renew, might have a lease to himself few trust-estates would be renewed. [...] This may seem very hard, that the trustee is the only person of all mankind who might not have the lease; but it is very proper that the rule should be strictly pursued and not at all relaxed."


title: Law

text: Lord King LC was worried that trustees might exploit opportunities to use trust property for themselves instead of looking after it. Business speculators using trusts had just recently caused a stock market crash. Strict duties for trustees made their way into company law and were applied to directors and chief executive officers. Another example of a trustee's duty might be to invest property wisely or sell it. This is especially the case for pension funds, the most important form of trust, where investors are trustees for people's savings until retirement. But trusts can also be set up for charitable purposes, famous examples being the British Museum or the Rockefeller Foundation.


title: Law

text: Law spreads far beyond the core subjects into virtually every area of life. Three categories are presented for convenience, although the subjects intertwine and overlap.


title: Law

text: In the 18th century, Adam Smith presented a philosophical foundation for explaining the relationship between law and economics. The discipline arose partly out of a critique of trade unions and U.S. antitrust law. The most influential proponents, such as Richard Posner and Oliver Williamson and the so-called Chicago School of economists and lawyers including Milton Friedman and Gary Becker, are generally advocates of deregulation and privatisation, and are hostile to state regulation or what they see as restrictions on the operation of free markets.


title: Law

text: The most prominent economic analyst of law is 1991 Nobel Prize winner Ronald Coase, whose first major article, "The Nature of the Firm" (1937), argued that the reason for the existence of firms (companies, partnerships, etc.) is the existence of transaction costs. Rational individuals trade through bilateral contracts on open markets until the costs of transactions mean that using corporations to produce things is more cost-effective. His second major article, "The Problem of Social Cost" (1960), argued that if we lived in a world without transaction costs, people would bargain with one another to create the same allocation of resources, regardless of the way a court might rule in property disputes. Coase used the example of a nuisance case named "Sturges v Bridgman", where a noisy sweetmaker and a quiet doctor were neighbours and went to court to see who should have to move. Coase said that regardless of whether the judge ruled that the sweetmaker had to stop using his machinery, or that the doctor had to put up with it, they could strike a mutually beneficial bargain about who moves that reaches the same outcome of resource distribution. Only the existence of transaction costs may prevent this. So the law ought to pre-empt what "would" happen, and be guided by the most efficient solution. The idea is that law and regulation are not as important or effective at helping people as lawyers and government planners believe. Coase and others like him wanted a change of approach, to put the burden of proof for positive effects on a government that was intervening in the market, by analysing the costs of action.


title: Law

text: Sociology of law is a diverse field of study that examines the interaction of law with society and overlaps with jurisprudence, philosophy of law, social theory and more specialised subjects such as criminology. The institutions of social construction, social norms, dispute processing and legal culture are key areas for inquiry in this knowledge field. Sociology of law is sometimes seen as a sub-discipline of sociology, but its ties to the academic discipline of law are equally strong, and it is best seen as a transdisciplinary and multidisciplinary study focused on the theorisation and empirical study of legal practices and experiences as social phenomena. In the United States the field is usually called law and society studies; in Europe it is more often referred to as socio-legal studies. At first, jurists and legal philosophers were suspicious of sociology of law. Kelsen attacked one of its founders, Eugen Ehrlich, who sought to make clear the differences and connections between positive law, which lawyers learn and apply, and other forms of 'law' or social norms that regulate everyday life, generally preventing conflicts from reaching barristers and courts. Contemporary research in sociology of law is much concerned with the way that law is developing outside discrete state jurisdictions, being produced through social interaction in many different kinds of social arenas, and acquiring a diversity of sources of (often competing or conflicting) authority in communal networks existing sometimes within nation states but increasingly also transnationally.


title: Law

text: Around 1900 Max Weber defined his "scientific" approach to law, identifying the "legal rational form" as a type of domination, not attributable to personal authority but to the authority of abstract norms. Formal legal rationality was his term for the key characteristic of the kind of coherent and calculable law that was a precondition for modern political developments and the modern bureaucratic state. Weber saw this law as having developed in parallel with the growth of capitalism. Another leading sociologist, Émile Durkheim, wrote in his classic work "The Division of Labour in Society" that as society becomes more complex, the body of civil law concerned primarily with restitution and compensation grows at the expense of criminal laws and penal sanctions. Other notable early legal sociologists included Hugo Sinzheimer, Theodor Geiger, Georges Gurvitch and Leon Petrażycki in Europe, and William Graham Sumner in the U.S.


title: Rhinoceros

text: A rhinoceros (; ; ), commonly abbreviated to rhino, is a member of any of the five extant species (or numerous extinct species) of odd-toed ungulates in the family Rhinocerotidae. (It can also refer to a member of any of the extinct species of the superfamily Rhinocerotoidea.) Two of the extant species are native to Africa, and three to South and Southeast Asia.


title: Rhinoceros

text: Rhinoceroses are some of the largest remaining megafauna: all weigh at least one tonne in adulthood. They have a herbivorous diet, small brains (400–600 g) for mammals of their size, one or two horns, and a thick (1.5–5 cm), protective skin formed from layers of collagen positioned in a lattice structure. They generally eat leafy material, although their ability to ferment food in their hindgut allows them to subsist on more fibrous plant matter when necessary. Unlike other perissodactyls, the two African species of rhinoceros lack teeth at the front of their mouths; they rely instead on their lips to pluck food.


title: Rhinoceros

text: Rhinoceros are killed by poachers for their horns, which are bought and sold on the black market for high prices, leading to most living rhinoceros species being considered endangered. The contemporary market for rhino horn is overwhelmingly driven by China and Vietnam, where it is bought by wealthy consumers to use in traditional Chinese medicine, among other uses. Rhino horns are made of keratin, the same material as hair and fingernails, and there is no good evidence of any health benefits. A market also exists for rhino horn dagger handles in Yemen, which was the major source of demand for rhino horn in the 1970s and 1980s.