title: Roger B. Taney

text: As a result of the Petticoat Affair, in 1831 President Jackson asked for the resignations of most of the members of his cabinet, including Attorney General John M. Berrien. Jackson turned to Taney to fill the vacancy caused by Berrien's resignation, and Taney became the president's top legal adviser. In one advisory opinion that he wrote for the president, Taney argued that the protections of the United States Constitution did not apply to free blacks; he would revisit this issue later in his career. Like his predecessors, Taney continued the private practice of law while he served as attorney general, and he served as a counsel for the city of Baltimore in the landmark Supreme Court case of "Barron v. Baltimore".


title: Roger B. Taney

text: Taney became an important lieutenant in the "Bank War," Jackson's clash with the Second Bank of the United States (or "national bank"). Unlike other members of the cabinet, Taney argued that the national bank was unconstitutional and that Jackson should seek to abolish it. With Taney's backing, Jackson vetoed a bill to renew the national bank's charter, which was scheduled to expire in 1836. The Bank War became the key issue of the 1832 presidential election, which saw Jackson defeat a challenge from national bank supporter Henry Clay. Taney's unyielding opposition to the bank, combined with Jackson's decisive victory in the election, made the attorney general one of the most prominent members of Jackson's cabinet.


title: Roger B. Taney

text: Jackson escalated the Bank War after winning re-election. When Secretary of the Treasury William J. Duane refused to authorize the removal of federal deposits from the national bank, Jackson fired Duane and gave Taney a recess appointment as secretary of the treasury. Taney redistributed federal deposits from the national bank to favored state-chartered banks, which became known as "pet banks". In June 1834, the Senate rejected Taney's nomination as secretary of the treasury, leaving Taney without a position in the cabinet. Taney was the first cabinet nominee in the nation's history to be rejected by the Senate.


title: Roger B. Taney

text: Despite Taney's earlier rejection by the Senate, in January 1835 Jackson nominated Taney to fill the seat of retiring Supreme Court Associate Justice Gabriel Duvall. Opponents of Taney ensured that his nomination was not voted on before the end of the Senate session, thereby defeating the nomination. The Democrats picked up seats in the 1834 and 1835 Senate elections, giving the party a stronger presence in the chamber. In July 1835, Jackson nominated Taney to succeed Chief Justice John Marshall, who had died earlier in 1835. Though Jackson's opponents in the Whig Party once again attempted to defeat Taney's nomination, Taney won confirmation in March 1836. He was the first Catholic to serve on the Supreme Court.


title: Roger B. Taney

text: Marshall had dominated the Court during his 35 years of service, and his opinion in "Marbury v. Madison" had helped establish the federal courts as a co-equal branch of government. To the dismay of states' rights advocates, the Marshall Court's rulings in cases such as "McCulloch v. Maryland" had upheld the power of federal law and institutions over state governments. Many Whigs believed that Taney was a "political hack" and worried about the direction in which he would take the Supreme Court. One of Marshall's key allies, Associate Justice Joseph Story, remained on the Court when Taney took office, but Jackson appointees made up a majority of the Court. Though Taney would preside over a jurisprudential shift toward states' rights, the Taney Court did not reject broad federal authority to the degree that many Whigs initially feared.


title: Roger B. Taney

text: "Charles River Bridge v. Warren Bridge" presented one of the first major cases of the Taney Court. In 1785, the legislature of Massachusetts had chartered a company to build the Charles River Bridge on the Charles River. In 1828, the state legislature chartered a second company to build a second bridge, the Warren Bridge, just 100 yards away from the Charles River Bridge. The owners of the Charles River Bridge sued, arguing that their charter had given them a monopoly on the operation of bridges in that area of the Charles River. The attorney for the Charles River Bridge, Daniel Webster, argued that the Commonwealth of Massachusetts had violated the Commerce Clause by disregarding the monopoly that the commonwealth had granted to his client. The attorney for Massachusetts, Simon Greenleaf, challenged Webster's interpretation of the charter, noting that the charter did not explicitly grant a monopoly to the proprietors of the Charles River Bridge. In his majority opinion, Taney ruled that the charter did not grant a monopoly to the Charles River Bridge. He held that, while the Contract Clause prevents state legislatures from violating the express provisions of a contract, the Court would interpret a contract provision narrowly when it conflicted with the general welfare of the state. Taney reasoned that any other interpretation would prevent advancements in infrastructure, since the owners of other state charters would demand compensation in return for relinquishing implied monopoly rights.


title: Roger B. Taney

text: In "Mayor of the City of New York v. Miln" (1837), the plaintiffs challenged a New York statute that required masters of incoming ships to report information on all passengers they brought into the country--"e.g.", age, health, last legal residence. The question before the Taney court was whether or not the state statute undercut Congress's authority to regulate commerce; or was it a police measure, as New York claimed, fully within the authority of the state. Taney and his colleagues sought to devise a more nuanced means of accommodating competing federal and state claims of regulatory power. The Court ruled in favor of New York, holding that the statute did not assume to regulate commerce between the port of New York and foreign ports and because the statute was passed in the exercise of a police power which rightfully belonged to the states.


title: Roger B. Taney

text: In "Briscoe v. Commonwealth Bank of Kentucky" (1837), the third critical ruling of Taney's debut term, the Chief Justice confronted the banking system, in particular state banking. Disgruntled creditors had demanded invalidation of the notes issued by Kentucky's Commonwealth Bank, created during the panic of 1819 to aid economic recovery. The institution had been backed by the credit of the state treasury and the value of unsold public lands, and by every usual measure, its notes were bills of credit of the sort prohibited by the federal Constitution.


title: Roger B. Taney

text: "Briscoe" manifested this change in the field of banking and currency in the first full term of the court's new chief justice. Article I, section 10 of the Constitution prohibited states from using bills of credit, but the precise meaning of a bill of credit remained unclear. In "Craig v. Missouri" (1830), the Marshall Court had held, by a vote of 4 to 3, that state interest-bearing loan certificates were unconstitutional. However, in the "Briscoe" case, the Court upheld the issuance of circulating notes by a state-chartered bank even when the Bank's stock, funds, and profits belonged to the state, and where the officers and directors were appointed by the state legislature. The Court narrowly defined a bill of credit as a note issued by the state, on the faith of the state, and designed to circulate as money. Since the notes in question were redeemable by the bank and not by the state itself, they were not bills of credit for constitutional purposes. By validating the constitutionality of state bank notes, the Supreme Court completed the financial revolution triggered by President Andrew Jackson's refusal to recharter the Second Bank of the United States and opened the door to greater state control of banking and currency in the antebellum period. The opinion given by the majority, which Taney was a part of, fit neatly into the Jacksonian economic plan.


title: Roger B. Taney

text: In the 1839 case of "Bank of Augusta v. Earle", Taney joined with seven other justices in voting to reverse a lower court decision that had barred out-of-state corporations from conducting business operations in the state of Alabama. Taney's majority opinion held that out-of-state corporations could do business in Alabama (or any other state) so long as the state legislature did not pass a law explicitly prohibiting such operations.


title: Roger B. Taney

text: In "Prigg v. Pennsylvania" (1842), the Taney Court agreed to hear a case regarding slavery, slaves, slave owners, and states' rights. It held that the Constitutional prohibition against state laws that would emancipate any "person held to service or labor in [another] state" barred Pennsylvania from punishing a Maryland man who had seized a former slave and her child, and had taken them back to Maryland without seeking an order from the Pennsylvania courts permitting the abduction. In his opinion for the Court, Justice Joseph Story held not only that states were barred from interfering with enforcement of federal fugitive slave laws, but that they also were barred from assisting in enforcing those laws. In a concurring opinion, Taney argued that the constitutional guarantee of slaveholders' rights to ownership and the prohibition in Article IV against preventing slaves' return to their masters in Southern states imposed a positive duty on states to enforce federal fugitive slave laws.


title: Roger B. Taney

text: The Taney Court also presided over the case of slaves who had taken over the Spanish schooner "Amistad". Associate Justice Joseph Story wrote the Court's majority decision and opinion, upholding their right as free men to defend themselves by attacking the crew and trying to gain freedom. Taney joined the majority opinion.


title: Roger B. Taney

text: In the 1847 "License Cases", Taney developed the concept of police power. He wrote that "whether a state passes a quarantine law, or a law to punish offenses, or to establish courts of justice ... in every case it exercises the same power; that is to say, the power of sovereignty, the power to govern men and things within the limits of its dominion." This broad conception of state power helped to provide a constitutional justification for state governments to take on new responsibilities, such as the construction of internal improvements and the establishment of public schools.


title: Roger B. Taney

text: Taney's majority opinion in "Luther v. Borden" (1849) provided an important rationale for limiting federal judicial power. The Court considered its own authority to issue rulings on matters deemed to be political in nature. Martin Luther, a Dorrite shoemaker, brought suit against Luther Borden, a state militiaman because Luther's house had been ransacked. Luther based his case on the claim that the Dorr government was the legitimate government of Rhode Island, and that Borden's violation of his home constituted a private act lacking legal authority. The circuit court, rejecting this contention, held that no trespass had been committed, and the Supreme Court, in 1849, affirmed. The decision provides the distinction between political questions and justiciable ones. The majority opinion interpreted the Guarantee Clause of the Constitution, Article IV, Section 4. Taney held that under this article Congress is able to decide what government is established in each state. This decision was important as an example of judicial self-restraint. Many Democrats had hoped that the justices would legitimize the actions of the Rhode Island reformers.


title: Roger B. Taney

text: "Genesee Chief v. Fitzhugh" (1852) dealt with the issue of admiralty jurisdiction. This case concerned an 1847 maritime collision on Lake Ontario in which the "Genesee Chief's" propeller struck and sank the schooner "Cuba". Suing under the 1845 act that extended admiralty jurisdiction to the Great Lakes, the owners of the "Cuba" alleged that the negligence of the "Genesee Chief's" crew caused the accident. Counsel for the "Genesee Chief" blamed the "Cuba" and contended that the incident occurred within New York's waters, outside the reach of federal jurisdiction. The key constitutional question was whether the case properly belonged in the federal courts—specifically, whether admiralty jurisdiction extended to the great freshwater lakes. In England, only tidal rivers had been navigable; hence, in English Law, the Admiralty Courts, which had been given jurisdiction over navigable waters, found their jurisdiction limited to places which felt the effect of the tides of the sea. In the United States, the vast expanse of the Great Lakes and stretches of the continental rivers, extending for hundreds of miles, were not tidal; yet upon these waters large vessels could move, with burdens of passengers and cargo. Taney ruled that the admiralty jurisdiction of the US Courts extends to waters which are actually navigable, without regard to the flow of the ocean tides. Taney's majority opinion established a broad new definition of federal admiralty jurisdiction. According to Taney, the 1845 act fell within Congress's power to control the jurisdiction of the federal courts. "If this law, therefore, is constitutional, it must be supported on the ground that the lakes and navigable waters connecting them are within the scope of admiralty and maritime jurisdiction, as known and understood in the United States when the Constitution was adopted." Taney's opinion marked a significant expansion of federal judicial power and an important step in establishing uniform federal admiralty principles.


title: Roger B. Taney

text: The United States increasingly polarized along sectional lines during the 1850s, with slavery acting as the central source of sectional tension. Taney wrote the majority opinion in the 1851 case of "Strader v. Graham", in which the Court held that slaves from Kentucky who had conducted a musical performance in the free state of Ohio remained slaves because they had voluntarily returned to Kentucky. Taney's narrowly constructed opinion was joined by both pro-slavery and anti-slavery justices on the Court. While the Court avoided splitting over the issue of slavery, debates over the status of slavery in the territories, as well as the Fugitive Slave Act of 1850, continued to roil the nation.


title: Roger B. Taney

text: As Congress was unable to settle the debate over slavery, some leaders from both the North and the South came to believe that only the Supreme Court could bring an end to the controversy. The Compromise of 1850 contained provisions to expedite appeals regarding slavery in the territories to the Supreme Court, but no suitable case arose until "Dred Scott v. Sandford" reached the Supreme Court in 1856. In 1846, Dred Scott, an enslaved African-American man living in the slave state of Missouri, had filed suit against his master for his own freedom. Scott argued that he had legally gained freedom in the 1830s, when he had resided with a previous master in both the free state of Illinois and a portion of the Louisiana Territory that banned slavery under the Missouri Compromise. Scott prevailed in a state trial court, but that ruling was reversed by the Missouri Supreme Court. After a series of legal maneuvers, the case finally made its way to the Supreme Court in 1856. Although the case concerned the explosive issue of slavery, it initially received relatively little attention from the press and from the justices themselves.


title: Roger B. Taney

text: In February 1857, a majority of the judges on the Court voted to deny Scott freedom simply because he had returned to Missouri, thereby reaffirming the precedent set in "Strader". However, after two of the Northern justices objected to the decision, Taney and his four Southern colleagues decided to write a much broader decision that would bar federal regulation of slavery in the territories. Like the other Southerners on the Court, Taney was outraged over what he saw as "Northern aggression" towards slavery, an institution that he believed was critical to "Southern life and values". Along with newly elected President James Buchanan, who was aware of the broad outlines of the upcoming decision, Taney and his allies on the Court hoped that the "Dred Scott" case would permanently remove slavery as a subject of national debate. Reflecting these hopes, Buchanan's March 4, 1857, inaugural address indicated that the issue of slavery would soon be "finally settled" by the Court. To avoid the appearance of sectional favoritism, Taney and his Southern colleagues sought to win the support of at least one Northern justice to the Court's decision. At the request of Associate Justice John Catron, Buchanan convinced Northern Associate Justice Robert Cooper Grier to join the majority opinion in "Dred Scott".


title: Roger B. Taney

text: The Court's majority opinion, written by Taney, was given on March 6, 1857. He first held that no African-American, free or enslaved, had ever enjoyed the rights of a citizen under the Constitution. He argued that, for more than a century leading up to the ratification of the Constitution, blacks had been "regarded as beings of an inferior order, altogether unfit to associate with the white race ... and so far inferior, that they had no rights which the white man was bound to respect". To bolster the argument that blacks were widely regarded as legally inferior when the Constitution was adopted, Taney pointed to various state laws, but ignored the fact that five states had allowed blacks to vote in 1788. He next declared that the Missouri Compromise was unconstitutional, and that the Constitution did not grant Congress the power to bar slavery in the territories. Taney argued that the federal government served as a "trustee" to the people of the territory, and could not deprive the right of slaveowners to take slaves into the territories. Only the states, Taney asserted, could bar slavery. Finally, he held that Scott remained a slave.


title: Roger B. Taney

text: The "Dred Scott" opinion received strong criticism in the North, and Associate Justice Benjamin Robbins Curtis resigned in protest. Rather than removing slavery as an issue, it bolstered the popularity of the anti-slavery Republican Party. Republicans like Abraham Lincoln rejected Taney's legal reasoning and argued that the Declaration of Independence showed that the Founding Fathers favored the protection of individual rights for all free men, regardless of race. Many Republicans accused Taney of being part of a conspiracy to legalize slavery throughout the United States.


title: Roger B. Taney

text: Republican nominee Abraham Lincoln won the 1860 presidential election, defeating Taney's preferred candidate, John C. Breckinridge. Several Southern states seceded in response to Lincoln's election and formed the Confederate States of America; the American Civil War began in April 1861 with the Battle of Fort Sumter. Unlike Associate Justice John Archibald Campbell, Taney (whose home state of Maryland remained in the Union) did not resign from the Court to join the Confederacy, but he believed that the Southern states had the constitutional right to secede and he blamed Lincoln for starting the war. From his position on the Court, Taney challenged Lincoln's more expansive view of presidential and federal power during the Civil War. He did not get the opportunity to rule against the constitutionality of the Emancipation Proclamation, the Legal Tender Act, or the Enrollment Act, but he did preside over two important Civil War cases.


title: Roger B. Taney

text: After secessionists destroyed important bridges and telegraph lines in the border state of Maryland, Lincoln suspended the writ of "habeas corpus" in much of the state. That suspension allowed military officials to arrest and imprison suspected secessionists for an indefinite period and without a judicial hearing. After the Baltimore riot of 1861, Union officials arrested state legislator John Merryman, whom they suspected of having destroyed Union infrastructure. Union officials allowed Merryman access to his lawyers, who delivered a petition of habeas corpus to the federal circuit court for Maryland. In his role as the head of that circuit court, Taney presided over the case of "Ex parte Merryman". Taney held that only Congress had the power to suspend the writ of habeas corpus, and he ordered the release of Merryman. Lincoln invoked nonacquiescence in response to Taney's order as well as subsequent Taney orders. He later argued that the Constitution did in fact give the president the power to suspend the writ of habeas corpus saying “Now it is insisted that Congress, and not the Executive, is vested with this power; but the Constitution itself is silent as to which or who is to exercise the power; and as the provision was plainly made for a dangerous emergency, it can not be believed the framers of the instrument intended that in every case the danger should run its course until Congress could be called together, the very assembling of which might be prevented, as was intended in this case, by the rebellion.” Nonetheless, when Lincoln suspended habeas corpus at a far larger scale, he did so only after requesting that Congress authorize him to suspend the writ, which they did by passing the Habeas Corpus Suspension Act of 1863.


title: Roger B. Taney

text: In 1863, the Supreme Court heard the "Prize Cases", which arose after Union ships blockading the Confederacy seized ships that conducted trade with Confederate ports. An adverse Supreme Court decision would strike a major blow against Lincoln's prosecution of the war, since the blockade cut off the crucial Confederate cotton trade with European countries. The Court's majority opinion, written by Associate Justice Grier, upheld the seizures and ruled that the president had the authority to impose a blockade without a congressional declaration of war. Taney joined a dissenting opinion written by Associate Justice Samuel Nelson, who argued that Lincoln had overstepped his authority by ordering a blockade without the express consent of Congress.


title: Roger B. Taney

text: Taney died on October 12, 1864, at the age of 87, the same day his home state of Maryland passed an amendment abolishing slavery. The following morning, the clerk of the Supreme Court announced that "the great and good Chief Justice is no more." He served as chief justice for , the second longest tenure of any chief justice, and was the oldest ever serving Chief Justice in United States history. Taney had administered the presidential oath of office to seven incoming Presidents. Taney's estate consisted of a $10,000 life insurance policy () and worthless bonds from the commonwealth of Virginia.


title: Roger B. Taney

text: President Lincoln made no public statement in response to Taney's death. Lincoln and three members of his cabinet (Secretary of State William H. Seward, Attorney General Edward Bates, and Postmaster General William Dennison) attended Taney's memorial service in Washington. Only Bates joined the cortège to Frederick, Maryland, for Taney's funeral and burial at St. John the Evangelist Cemetery. After Lincoln was re-elected, he appointed Salmon P. Chase, a strongly anti-slavery Republican from Ohio, to succeed Taney.


title: Roger B. Taney

text: After his death, Taney remained a controversial figure. Secretary of the Navy Gideon Welles spoke for many Northerners when he stated that the "Dred Scott" decision "forfeited respect for [Taney] as a man or a judge". In early 1865, the House of Representatives passed a bill to appropriate funds for a bust of Chief Justice Taney to be displayed in the Supreme Court alongside those of his four predecessors. In response, Senator Charles Sumner of Massachusetts said:


title: Roger B. Taney

text: I speak what cannot be denied when I declare that the opinion of the Chief Justice in the case of "Dred Scott" was more thoroughly abominable than anything of the kind in the history of courts. Judicial baseness reached its lowest point on that occasion. You have not forgotten that terrible decision where a most unrighteous judgment was sustained by a falsification of history. Of course, the Constitution of the United States and every principle of Liberty was falsified, but historical truth was falsified also.


title: Roger B. Taney

text: The low point in Taney's reputation came with the 1865 publication of an anonymous sixty-eight-page pamphlet, "The Unjust Judge: A Memorial of Roger Brooke Taney". One scholar speculated in 1964 that Sumner was its author.


title: Roger B. Taney

text: George Ticknor Curtis, one of the lawyers who argued before Taney on behalf of Dred Scott, held Taney in high esteem despite his decision in "Dred Scott". In a volume of memoirs written for his brother Benjamin Robbins Curtis, George Ticknor Curtis gave the following description of Taney:


title: Roger B. Taney

text: He was indeed a great magistrate, and a man of singular purity of life and character. That there should have been one mistake in a judicial career so long, so exalted, and so useful is only proof of the imperfection of our nature. The reputation of Chief Justice Taney can afford to have anything known that he ever did and still leave a great fund of honor and praise to illustrate his name. If he had never done anything else that was high, heroic, and important, his noble vindication of the writ of "habeas corpus", and of the dignity and authority of his office, against a rash minister of state, who, in the pride of a fancied executive power, came near to the commission of a great crime, will command the admiration and gratitude of every lover of constitutional liberty, so long as our institutions shall endure.


title: Roger B. Taney

text: Biographer James F. Simon writes that "Taney's place in history [is] inextricably bound to his disastrous "Dred Scott" opinion." Simon argues that Taney's opinion in "Dred Scott" "abandoned the careful, pragmatic approach to constitutional problems that had been the hallmark of [Taney's] early judicial tenure". Historian Daniel Walker Howe writes that "Taney's blend of state sovereignty, white racism, sympathy with commerce, and concern for social order was typical of Jacksonian jurisprudence." Law professor Bernard Schwartz lists Taney as one of the ten greatest Supreme Court justices, writing that "Taney's monumental mistake in "Dred Scott" should not overshadow his numerous accomplishments on the Court. Taney was second only to Marshall in laying the foundation of our constitutional law." Taney's mixed legacy was noted by Justice Antonin Scalia in his dissenting opinion in "Planned Parenthood v. Casey":


title: Roger B. Taney

text: There comes vividly to mind a portrait by Emanuel Leutze that hangs in the Harvard Law School: Roger Brooke Taney, painted in 1859, the 82nd year of his life, the 24th of his Chief Justiceship, the second after his opinion in "Dred Scott". He is all in black, sitting in a shadowed red armchair, left hand resting upon a pad of paper in his lap, right hand hanging limply, almost lifelessly, beside the inner arm of the chair. He sits facing the viewer, and staring straight out. There seems to be on his face, and in his deep-set eyes, an expression of profound sadness and disillusionment. Perhaps he always looked that way, even when dwelling upon the happiest of thoughts. But those of us who know how the lustre of his great Chief Justiceship came to be eclipsed by "Dred Scott" cannot help believing that he had that case—its already apparent consequences for the Court and its soon-to-be-played-out consequences for the Nation—burning on his mind.


title: Roger B. Taney

text: Taney's home, Taney Place, in Calvert County, Maryland, was listed on the National Register of Historic Places in 1972. Another property owned by Taney, called the "Roger Brooke Taney House" (although he never lived there), is in Frederick, Maryland. The House and its associated outbuildings were sold to a private party in 2021. In the past the property was open for tours by appointment and interpreted "the life of Taney and his wife Anne Key (sister of Francis Scott Key), as well as various aspects of life in early nineteenth century Frederick County".


title: Roger B. Taney

text: Several places and things have been named for Taney, including Taney County, Missouri, the (although the ship was later renamed during Taney's de-memorialization), and the Liberty ship .


title: Roger B. Taney

text: In 1993, the Roger B. Taney Middle School in Temple Hills, Maryland was renamed for Justice Thurgood Marshall, the Supreme Court's first African American justice. A statue of Taney formerly stood on the grounds of the Maryland State House, but the state of Maryland removed the statue in 2017, two days after Baltimore mayor Catherine Pugh ordered the removal of its replica in Baltimore City.


title: Roger B. Taney

text: In 2020, in the midst of the protests following the murder of George Floyd, the Democratic-led U.S. House of Representatives eventually voted 305–113 to remove a bust of Taney (as well as statues honoring figures who were part of the Confederacy during the Civil War) from the U.S. Capitol and replace it with a bust of Thurgood Marshall. The bill called for removal of Taney's bust within 30 days after the law's passage. The bust had been mounted in the old robing room adjacent to the Old Supreme Court Chamber in the Capitol Building. The bill (H.R. 7573) also created a "process to obtain a bust of Marshall ... and place it there within a minimum of two years". After the bill reached the Republican-led Senate (S.4382), it was referred to the Committee on Rules and Administration, but no further action on it was taken. On June 29, 2021, the U.S. House of Representatives passed a resolution 285 to 120 with sixty-seven Republican Representatives to replace the bust with one of Thurgood Marshall and expel Confederate statues from the U.S. Capitol.


title: Briana Banks

text: Briana Banks (born Briana Bany; 21 May 1978) is a German American pornographic actress and model. She was the "Penthouse" Pet of the Month for June 2001.


title: Briana Banks

text: Banks was born in Munich, Germany to a German father and an American mother. They moved to Britain when she was four, then to the Los Angeles suburb of Simi Valley when she was seven. Her father still lives in Germany. Banks moved out of her mother's house when she was 16, taking her 14-year-old sister with her. She got custody of her sister when she turned 18.


title: Briana Banks

text: Banks modeled as a teenager, appearing on a cover of "Teen" magazine. She entered the industry under the name "Mirage", but began calling herself "Briana Banks" in 1999, after having the first of two breast enlargement operations. Having had aspirations of being a supermodel, she chose the professional surname "Banks" after model Tyra Banks. Her first appearance using the new name was in the film "Decadent Whores 9".


title: Briana Banks

text: On October 13, 2006, Banks reportedly filed a federal lawsuit seeking more than US$75,000 in damages against Doc Johnson Enterprises, charging that they had created unauthorized products from molds of her genitals.


title: Briana Banks

text: Starting in 2006, Banks went on hiatus from performing in videos and returned in 2008. That same year she was also nominated for five AVN Awards at the 25th annual Adult Entertainment Expo in Las Vegas.


title: Briana Banks

text: In 2011, Banks starred in the porn parody version of the Fox animated series "American Dad!", "American Dad XXX: An Exquisite Films Parody". Banks portrayed the character of Francine Smith and was featured on the video's box cover. The video was released in September 2011.


title: Briana Banks

text: On December 28, 2015 Briana Banks announced that she was making a comeback in 2016 after a 5-year hiatus. The same year she was inducted into the XRCO Hall of Fame.


title: Briana Banks

text: Banks was featured in the thirteen episode cable television series "Vivid Valley" produced by World of Wonder that was broadcast in Europe in 2005 and later had a successful run on Playboy TV. The series featured stories about the real lives of then Vivid Girls Jenna Jameson, Savanna Samson, Mercedez, Tawny Roberts, Banks, and others.


title: Briana Banks

text: In 2002 Banks was one of the first porn actresses to have an action figure made in her likeness, by Los Angeles-based Cyber F/X and Sota Toys.


title: Sniper Elite

text: Sniper Elite is a tactical shooter video game series developed by Rebellion Developments. It is a third-person tactical shooter that emphasises a less direct approach to combat, encouraging the player as a sniper to use stealth and keep distance from enemy soldiers.


title: Sniper Elite

text: The games follow Karl Fairburne, a German-American Office of Strategic Services operative battling Axis forces during World War II. Thus far, the series has been met with relatively positive reviews. More than 20 million "Sniper Elite" games have been sold.


title: Sniper Elite

text: "Sniper Elite" is a third-person shooter that involves stealth and first-person shooter game elements. Many of the single player levels allow multiple routes for the players to take in order to avoid direct firefights. Set in World War II, the player character, a German-American OSS operative named Karl Fairburne, utilises appropriate weapons for the era. The sniper rifle is the primary weapon throughout the game, though additional side arms (submachine guns and pistols) can be used depending on the situation. In addition to hand grenades, the player can also deploy tripwire booby traps, land mines and dynamite. The player can also shoot the enemies' own grenades to trigger an explosion. Binoculars are used to tag enemies in view, displaying their position and movements to the player. Different postures such as crouching or lying prone can steady a shot, and the player can take a deep breath to "focus" for increased accuracy. Realistic ballistics are optional, taking into consideration factors such as wind direction and strength and bullet drop, potentially altering the outcome of a shot even with the use of the scope. Introduced in "Sniper Elite V2" is the "X-Ray Kill Cam", a feature where upon a successful and skilled shot will, in slow motion, follow the bullet from the rifle to the target's point of impact, showing an anatomically correct x-ray of the body part being hit and the damage the bullet causes to the organs and/or bones. In Sniper Elite III, stealth mechanics were reworked. An eye icon squints or opens to denote the player's level of detection by the enemy. Enemy soldiers will also have a circle meter over their heads to indicate alert status. Players are then forced to relocate periodically to prevent detection with a white ghost image to mark their last known position and the enemy will search a wider area.


title: Sniper Elite

text: Rebellion Developments' book imprint Abaddon Books released a novel inspired by the game, "Sniper Elite: The Spear of Destiny" written by Jasper Bark. In this book, Karl Fairburne's mission is to stop Nazi SS general Helmstadt from selling a working atomic bomb to the Soviets.


title: Sniper Elite

text: A short story written by Scott K. Andrews titled "Sniper Elite V2 - Target Hitler" was released as an E-Book.


title: Sniper Elite

text: A 2018 comic based on the series, "Sniper Elite: Resistance" written by Keith Richardson and Patrick Goddard. The story follows Karl Fairburne as he parachutes into occupied France on a mission to destroy a secret weapon, but instead of a silent mission of sabotage he finds the local resistance compromised and the SS waiting to play a deadly game of cat and mouse in the terrified streets of an ancient town.


title: Sniper Elite

text: On March 29, 2021, Variety reports that a film adaptation of "Sniper Elite" is in development with Marla Studios' Jean-Julien Baronnet producing along with the game's producer and CEO of Rebellion Jason Kingsley, Gary Graham writing and Brad Peyton directing with the film follows Karl Fairburne engage in a cat-and-mouse chase through the streets of London at the height of the Blitz during World War II, as he tries to save British Prime Minister Winston Churchill from a Nazi assassin.


title: Kristie Mewis

text: Kristen Anne Mewis (born February 25, 1991) is an American professional soccer player who plays as a midfielder for Gotham FC of the National Women's Soccer League (NWSL) and the United States national team.


title: Kristie Mewis

text: Mewis grew up in Hanson, Massachusetts, where she attended Whitman-Hanson Regional High School and played on the soccer team. She finished her high school career with 74 goals and 34 assists. She was a three-time NSCAA All-American, three-time All-New England and All-Massachusetts team honoree and a three-time Eastern Massachusetts Girls Soccer Association Div. 1 First-Team All-Star. In 2008, Mewis was named the NSCAA Youth Player of the Year and the US Soccer Young Female Athlete of the Year. In 2009, she was named to the "Parade" All-America team.


title: Kristie Mewis

text: Mewis played for the Region 1 Olympic Development Program (ODP) team from 2003 to 2007. She played with her younger sister Sam at the 2008 FIFA U-17 Women's World Cup and the 2010 FIFA U-20 Women's World Cup.


title: Kristie Mewis

text: As a freshman at Boston College, Mewis recorded five goals and six assists, and was second on the team in shots taken with 72, bettered only by fellow Eagle and United States U-17 teammate, Vicki DiMartino. Mewis played and started in 23 games and tied for fourth on the team in scoring with five goals and six assists for 16 points. Mewis played midfield and filled in on defense due to injuries. She was named to the All-ACC Freshmen Team, the Top Drawer Soccer All-Rookie team, and Soccer America All-Rookie team and earned NSCAA All-Southeast Region first team honors.


title: Kristie Mewis

text: During her sophomore year in 2010, Mewis started all 25 games on the season and led the Atlantic Coast Conference (ACC) in shots with 101. She scored ten goals, ranking seventh in the ACC and second for Boston. She was first on the team in assists with 14; tied for the ACC lead. She tied for fifth in the ACC in points with 34. Mewis set a school record by recording a goal or assist in 11 consecutive games from August 29 to October tallying seven goals and eight assists during the run. She was awarded ACC Player of the Week and CollegeSoccer360 Team of the Week honors on October 4. Mewis was named New England Soccer News Player of the Year and was an All-ACC first team selection. She was a Hermann Trophy semifinalist and a member of Soccer America MVP's first team. Mewis received NSCAA All-American first team accolades and was named to Top Drawer Soccer's second team. She was also the NSCAA Player of the Week on September 29.


title: Kristie Mewis

text: In 2011, Mewis led the team in scoring eight goals and six assists for 22 points and was named the Offensive Team MVP. Starting and playing in 20 games during the season, Mewis logged 1,545 minutes of play while leading the team in shots with 81. She averaged 4.05 shots per game, ranking second in the ACC and was 11th in the ACC in points, with 22. Mewis was a NSCAA Division 1 All-America third team selection and earned NSCAA Southeast Regional first team honors. She was an all-ACC first team selection, was named to the Soccer America MVP second team, and was named to the Soccer America Preseason All-America list. Mewis was named to the Preseason Hermann Trophy Watch List and was a semifinalist for the award.


title: Kristie Mewis

text: During her senior year, Mewis finished the 2012 season with a career-high 16 goals, 12 assists for a career-high 44 points. She recorded nine multi-point games (three or more points) and had a goal or assist in 15 of 21 games this season. Mewis is the all-time leading scorer in the Boston College program with 116 total points. After opening the season with a nine-game scoring streak, second to her personal and program record of 11 games which she accomplished in 2010, she was named a Division 1 ECAC All-Star and Hermann Trophy Semifinalist. Mewis received NSCAA First Team All-America and All-Southeast Region honors and was named to the TopDrawerSoccer.com Team of the Season – Upperclassmen – first team. She was named to the All-ACC first team and College Sports Madness All-American first team. Mewis tallied her first career hat trick in a match against Harvard. The three goals made her the all-time leader in points at Boston College. She finished her career with 39 goals, 38 assists, nine game-winning goals and 21 multiple-point games. She was the second player in program history to register a goal in five straight games.


title: Kristie Mewis

text: Mewis signed with the Australian W-League team Canberra United FC to finish the final two weeks of the 2012–13 season. She made her first appearance for the club during a 5–0 win against the Western Sydney Wanderers FC on January 8 and scored the team's fifth goal in the 89th minute of the match. Her second and final appearance occurred on January 12 when the team was defeated 5–1 by eventual regular season champions, Brisbane Roar FC. Mewis scored Canberra's only goal of the match in the 45th minute. Canberra United finished fifth during the regular season with a 5–3–4 record.


title: Kristie Mewis

text: In January 2013, Mewis was drafted in the first round (third pick overall) of the 2013 NWSL College Draft to FC Kansas City for the inaugural season of the National Women's Soccer League. She was elevated to U.S. Soccer-subsidized status during the year. She scored her first goal of the season in the 74th minute of the Blues' 3–2 win over Portland Thorns FC on May 8. Mewis made 20 starts as a rookie for FC Kansas City during the regular season helping the team finish second in the standings with an 11–5–6 record. The team advanced to the playoffs but were defeated 3–2 in the semifinals by Portland.


title: Kristie Mewis

text: In November 2013, FC Kansas City traded Mewis to Seattle Reign FC for Amy Rodriguez. Of the trade, Reign FC coach, Laura Harvey said, "Kristie is a young, bright and talented player who we feel can benefit our long-term plan. She has proven that she can be a high-level player in this environment and we feel we have the structure to help push Kristie to the next level." On November 18, 2013, she was traded alongside Michelle Betos and two 2015 NWSL College Draft picks to the Boston Breakers for Sydney Leroux.


title: Kristie Mewis

text: October 2014 Mewis signed a three-month contract with Iga FC Kunoichi of the Japanese Nadeshiko League first division. Wearing number 31 and playing as a forward, Mewis scored five goals in seven games, which included two braces. During matches in which she played, Iga FC compiled a record of 6–1.


title: Kristie Mewis

text: In November 2016, Mewis was traded along with Kassey Kallman from the Boston Breakers to the Washington Spirit for Megan Oyster.


title: Kristie Mewis

text: On August 21, 2017, Mewis was traded to the Chicago Red Stars for their first round draft pick in the 2018 NWSL College Draft. In her first and only game for the Red Stars (against her previous team), she scored a goal in the first half helping to secure a victory for the Red Stars and eliminating the Spirit from playoff contention.


title: Kristie Mewis

text: On August 30, 2017, about a week after being traded to the Chicago Red Stars, Mewis was traded to the Houston Dash for USWNT player Morgan Brian with additional, undisclosed future considerations going to Houston.


title: Kristie Mewis

text: On December 16, 2021, Mewis was selected by NWSL expansion club San Diego Wave FC in the 2022 NWSL Expansion Draft and subsequently traded to Gotham FC in exchange for $200k in allocation money.


title: Kristie Mewis

text: Mewis co-captained the United States U-17 team that was runner-up at the inaugural 2008 FIFA U-17 Women's World Cup in New Zealand. Over the course of the tournament, Mewis scored two goals. She was the recipient of the Bronze Ball as the tournament's third-best player. Mewis also played in the 2010 U-20 Women's World Cup in Germany where the team lost in the quarterfinals. Mewis's younger sister Sam was also a member of both youth World Cup squads.


title: Kristie Mewis

text: In January 2013, Mewis was called to the national training camp by head coach Tom Sermanni in preparation for a friendly match against Scotland. She made her debut for the senior team on February 9, 2013, against Scotland and was placed on the roster for 2013 Algarve Cup. Mewis scored the game-opening goal in the third minute of a friendly match against South Korea on June 15, 2013, near her hometown in Massachusetts.


title: Kristie Mewis

text: After earning 15 caps between 2013 and 2014, Mewis fell off the national team radar. Following a 5-year absence, she was called back up to a USWNT talent identification training camp in December 2019 by new coach Vlatko Andonovski. She was called to the full senior team training camps in both October and November 2020 prior to a friendly against the Netherlands. Mewis came on as a second-half substitute against the Netherlands, marking her first appearance in over six years, and scoring in the 70th minute. Her second international goal came 2,722 days after her first in June 2013, the longest span between goals in team history.


title: Kristie Mewis

text: In October 2020, after winning the Challenge Cup with the Houston Dash, Mewis made some revelation about her ups and downs on getting called back to the National Team in an article titled "I was done being average." published by Seth Vertelney on Goal.com. In this article, Mewis revealed that she had sustained a serious injury sometimes after the 2014 season, and had time to reevaluate herself in terms of quality of play. While rehabbing, Mewis had to build herself back up, both physically and mentally. It was the latter part that proved the most challenging. While playing for the Houston Dash in 2018, Mewis sustained another tear in her Anterior Cruciate Ligament (ACL) in her left knee, and had to sideline for the rest of the 2018 season. In May 2019, Mewis came back with the Dash and looked more like the player of 2013 than the one just before the injury. At the end of the 2019 NWSL season, she was rewarded with her first USWNT call-up in more than three years.


title: Kristie Mewis

text: Since the beginning of 2021, Mewis has been in a relationship with Australian soccer player Sam Kerr.


title: Forensic psychology

text: Forensic psychology is the development and application of scientific knowledge and methods to help answer legal questions arising in criminal, civil, contractual, or other judicial proceedings. Forensic psychology includes both research on various psychology-law topics, such as jury selection, reducing systemic racism in criminal law, and eyewitness testimony, as well as professional practice, such as evaluating individuals to determine competency to stand trial or assessing military veterans for service-connected disability compensation. The field traces its roots to contributions by Wilhem Wundt, Hugo Münsterberg, and Sigmund Freud among others. Contemporary definitions of forensic psychology recognize that several subfields of psychology apply "the scientific, technical, or specialized knowledge of psychology to the law." The American Psychological Association's "Specialty Guidelines for Forensic Psychologists" reference several psychology subdisciplines, such as social, clinical, experimental, counseling, and neuropsychology.


title: Forensic psychology

text: Wilhelm Wundt is commonly known for being the first to begin experimentation in the field of psychology and, thus, igniting the flame for future individuals to apply these experimental processes to various contexts, including legal ones. A student of Wundt and the first director of Harvard's psychological laboratory"," Hugo Münsterberg, authored "On the Witness Stand" in the first decade of the 20th century. Münsterberg used this publication to bridge the gap between psychological and legal principles through the introduction of psychological research that could be applied in legal proceedings. Sigmund Freud discussed how psychopathological processes play a role in criminal behavior. Lightner Witmer, William Stern, and William Healy also contributed to the early development of forensic psychology.


title: Forensic psychology

text: This was the first case where the Supreme Court of the U.S. referenced expert opinions by psychologists. After this, the addition of psychological mechanisms within court rooms began to be considered beneficial.


title: Forensic psychology

text: Several years after the ruling of Brown v. Board of Education of Topeka, Justice David Bazelon of the D.C. Circuit Court of Appeals ruled that psychologists had the legal authority to testify as medical experts about mental illness.


title: Forensic psychology

text: The American Psychology-Law Society (AP-LS) was created in 1969 and later converted into Division 41 of the APA in 1980. As the field continued to grow, more organizations supported the study of psychology with application to the law. In 1976 the American Board of Forensic Psychology (ABFP) was chartered and eventually became a part of the American Board of Professional Psychology (ABPP) in 1985. Later, organizations and conferences aided in solidifying the development of forensic psychology, such as the American Academy of Forensic Psychology and the National Invitational Conference on Education and Training in Forensic Psychology (1995). By 2001, the field of Forensic Psychology was recognized as a professional specialty by The American Psychological Association (APA).


title: Forensic psychology

text: Recently, forensic psychology has grown in popularity in the media and among younger generations. For example, many recent docuseries on Netflix feature forensic psychological content, including Making a Murderer and Sins of our Mother. Other TV shows and movies such as Criminal Minds, Manhunter, Mindhunter, and Silence of The Lambs have widely popularized the practice of criminal profiling, particularly within the Federal Bureau of Investigation's (FBI) Behavioral Analysis Unit (BAU). Despite the excitement given to the idea of a career in criminal profiling, students who show an interest in this particular aspect of forensic psychology find that the practice of criminal profiling is rarely used outside of the BAU. They also find that there are many forensic psychology practices outside criminal proceedings.


title: Forensic psychology

text: Forensic psychology involves both elements of basic as well as applied work. Forensic psychologists may hold a Ph.D. or Psy.D. in clinical psychology, counseling psychology, social psychology, organizational psychology, school psychology, or experimental psychology under accredited institutions. Additionally, 2 years of supervised experience in their field is necessary. There are no specific license requirements in the United States to be a forensic psychologist, although U.S. states, territories, and the District of Columbia require licensure for psychologists in the state they intend to practice. Certification specifically in forensic psychology is also available. Psychologists who do not provide healthcare services might not need to be licensed in some U.S. jurisdictions.


title: Forensic psychology

text: In other countries, training and practitioner requirements may vary. In the United Kingdom, for example, a person must obtain the Graduate Basis for Registration with the British Psychological Society – normally through an undergraduate degree. This would be followed by Stages 1 (academic) and 2 (supervised practice) of the Diploma in Forensic Psychology (which would normally take 3 years full-time and 4 years part-time). Assessment occurs via examination, research, supervised practice, and the submission of a portfolio showing expertise across a range of criminological and legal applications of psychology. Once qualified as a "chartered" psychologist (with a specialism in forensic psychology), a practitioner must engage in continued professional development and demonstrate how much and of what kind, each year, in order to renew their practicing certificate.


title: Forensic psychology

text: Evaluations and assessments are completed by forensic psychologists to assess a person's psychological state for legal purposes. Reasons for completing these evaluations can involve acquiring information for criminal court (such as insanity or incompetence), for criminal sentencing or parole hearings (often regarding a potential intellectual disability that prevents sentencing or one's risk of recidivism), for family court (including child custody or parental termination cases), or civil court (involving, for example, personal injury, competence to manage one's financial affairs, and psychological autopsies especially as related to testamentary capacity). Additional assessments that these professionals can perform include school threats. There is great debate about whether these Forensic Psychological evaluations constitute as health care treatment, with the majority of arguments claiming they do not. It is important to note that while a forensic psychologist is responsible for assessing and reporting results of an evaluation, they do not make decisions on "ultimate issues" such as competence to stand trial or service-connected disability for U.S. military veterans. Instead, the information provided by the expert evaluator is analyzed and is ruled on by the court which ordered the evaluation to take place.


title: Forensic psychology

text: Treatment providers may be asked to administer psychological interventions to those who require or request services in both criminal and civil cases. In regard to criminal cases, forensic psychologists can work with individuals who have already been sentenced to reduce recidivism, which refers to one's likelihood of repeating his or her offense. Other interventions that may be implemented in these settings are substance use disorder treatment, sex offender treatment, treatment for a mental illness, or anger management courses. As for civil proceedings, treatment providers may have to treat families going through divorce or custody cases. They may also provide treatment to individuals who have suffered psychological injuries as a result of some kind of trauma. Treatment providers and evaluators work in the same types of settings: forensic and state psychiatric hospitals, mental health centers, and private practices. Often, people who are considered members of ethnic or racial minorities are who forensic psychologists treat due to the overrepresentation of these individuals within the legal system.


title: Forensic psychology

text: Providing consultations allows forensic psychologists to apply psychological expertise and research to help law enforcement, attorneys, and other legal professionals or proceedings better understand human behavior (e.g. criminal, witness, victim, jury), civil processes, effects of trauma or other life events, and so on. If working as a consultant, a forensic psychologist is able to be involved in legal proceedings through responsibilities such as reviewing court records (such as a defendant's psychosocial history or assess mitigating or aggravating factors in a case), serving as a jury consultant (organizing focus groups, shadow juries, mock juries, or helping with the voir dire proceedings), and assessment without testimony (in which results of a defendant's evaluation are not disclosed to the prosecution team, allowing the defense team to develop a defense strategy), among others. Essentially, consultations can take a number of forms, including the common ones below:


title: Forensic psychology

text: Expert testimony about matters relating to psychology is also an area in which forensic psychologists play an active role. Unlike fact witnesses, who are limited to testifying about what they know or have observed, expert witnesses have the ability to express further knowledge of a situation or topic because, as their name suggests, they are presumed to be "experts" in a certain topic and possess specialized knowledge about it. The requirements that must be met for forensic psychologists to be considered expert witnesses include clinical psychology expertise and knowledge of the laws that have jurisdiction over the court they are to testify. Procedural and legal rules guide expert testimony, which include that the evidence must be relevant to the case, the method the expert used must be valid and reliable, and that the evidence will help the trier of fact. An expert can be deposed by opposing counsel to discover what they plan to say in court, and attorneys have the opportunity to raise a challenge to the admissibility of the expert's testimony if there are questions about its relevance, or its validity and reliability (in the United States - the rules vary by country and jurisdiction). Regardless of who calls in the expert, it is the judge who determines whether or not the expert witness will be accepted through a voir dire process of qualification.


title: Forensic psychology

text: Forensic psychology researchers make scientific discoveries relevant to psychology and the law and they also sometimes provide expert witness testimony. These professionals usually have an advanced degree in psychology (most likely a PhD). These professionals may be employed in various settings, which include colleges and universities, research institutes, government or private agencies, and mental health agencies. Researchers test hypotheses empirically regarding issues related to psychology and the law, such as jury research and research on mental health law and policy evaluation. Their research may be published in forensic psychology journals such as "Law and Human Behavior" or "Psychology, Public Policy, and Law", as well as more broadly in basic psychology journals. Some famous psychologists in the field include Scott Lilienfeld who was widely known for his scholarship on psychopathology and psychopathy, Saul Kassin who is widely known for studying false confessions, Jennifer Skeem who is widely known for studying justice-involved people with mental illness, Michael Saks who is known for his contributions to jury research and improvements to forensic science, Barbara Spellman who is known for her cognitive psychology-law work as well as for her open science leadership, and Elizabeth Loftus and Gary Wells who are both known for their research on eyewitness memory.


title: Forensic psychology

text: Academic forensic psychologists engage in teaching, researching, training, and supervision of students, among other education-related activities. These professionals also have an advanced degree in psychology (most likely a PhD) and are most often employed at colleges and universities. In addition to holding professorships, forensic psychologists may engage in education through presenting research, hosting talks relating to a particular subject, or engaging with and educating the community about a relevant forensic psychology topic.


title: Forensic psychology

text: Through advocacy, forensic psychologists can use psychological research to influence laws and policies. These may be related to certain movements, such as Black Lives Matter or the Me Too movement, or may even be related to certain civil rights that are being overlooked.


title: Forensic psychology

text: Competence, in a legal setting, refers to the defendant's ability to appreciate and understand the charges against them and what is happening in the legal proceedings, as well as their ability to help the lawyer understand and defend their case. While competence is assessed by a psychologist, its concern regarding a defendant is typically voiced by the lawyer. Though it is the psychologist's responsibility to assess for competence, it is ultimately up to the judge to decide whether the defendant is competent or not. If the defendant is found incompetent to stand trial, the psychologist must then give a recommendation on whether or not the defendant can be restored to competence through treatment or if the charges should be dropped completely due to incompetence. A couple potential causes of incompetence include certain types of brain damage or the occurrence of a psychotic episode preventing the individual from registering the reality around them.


title: Forensic psychology

text: Several cases were instrumental in developing a standard for competence, as well as for determining the rights of an individual deemed incompetent to stand trial. Youtsey v. United States (1899) was one of the cases that set the standard for competence, with the judge ruling that trying or sentencing an individual deemed incompetent violates their human rights. Despite this ruling, no official guidelines for determining and sentencing matters of competence were developed. In Dusky v. United States (1960), the case upheld the Youtsey v. United States ruling and set specific criteria for competence. These include having a rational and factual understanding of court proceedings and being able to consult with an attorney in a rational manner. The case of Weiter v. Settle (1961) resulted in the decision that a psychologist's opinion in a competency hearing is considered "opinion testimony." Additionally, guidelines were put in place to accurately evaluate competency. The eight guidelines established include requirements that the defendant appreciates one's own presence in relation to time, place, and things; understands that they are in a Court of Justice, charged with a criminal offense; recognizes that there is a Judge who presides over the Court; understands that there is a Prosecutor who will try to convict them of criminal charges; understands that they have a lawyer who will defend them against that charge; knows that they are expected to tell their attorney what they were doing at the time of the alleged offense; understands that a jury will determine whether they are guilty or innocent of the charges; and has sufficient memory to discuss issues related to the alleged offense and the court proceedings. As time has progressed, more cases have added to these guidelines and expectations when evaluating competency.


title: Forensic psychology

text: Insanity, as opposed to competence, refers to an individual's mental state at the time of the crime rather than at the time of the trial. According to legal principles of insanity, it is only acceptable to judge, find someone criminally responsible, and punish a defendant if that individual was sane at the time of the crime. In order to be considered sane, the defendant must have exhibited both "mens rea" and "actus reus". "Mens rea", translated to "guilty mind", indicates that the individual exhibited free will and some intent to do harm at the time of the crime. "Actus reus" refers to the voluntary committing of an unlawful act. The insanity defense acknowledges that, while an unlawful act did occur, the individual displayed a lack of "mens rea". The burden of proof in determining if a defendant is insane lies with the defense team. A notable case relating to this type of assessment is that of "Ford v. Wainwright", in which it was decided that forensic psychologists must be appointed to assess the competency of an inmate to be executed in death penalty cases.


title: Forensic psychology

text: There are various definitions of insanity acknowledged within the legal system. The M'Naghten/McNaugton rule (1843) defines insanity as the individual not understanding the nature and quality of his or her acts or that these acts were wrong due to a mental disease or defect. This is also referred to as the cognitive capacity test. Meanwhile, the Durham Test (established in Durham v. United States, 1954) states that one can be declared insane if the actions were caused by a mental disorder. The vague nature of this description causes this definition to only be used in one state (New Hampshire). The final definition acknowledged within the courts is the Brawner Rule (U.S. v. Brawner, 1972), also referred to as the American Law Institute Standard. This definition posits that, due to a mental disease or defect, an individual is considered insane if unable to appreciate the wrongfulness of an act and are unable to conform their behavior to the dictates of the law.


title: Forensic psychology

text: Evaluating insanity involves using crime scene analysis to determine the mental state at the time of the crime, establishing a diagnosis, interviewing the defendant and any other relevant witnesses, and verifying impressions of the defendant. Challenges associated with this type of assessment involve defendant malingering, determining the defendant's past mental state, the chance that different experts may come to different conclusions depending on the assessment method used, and the fact that it is very common for society to label any psychological disorder as insane (though few actually fall into this category; insanity primarily involves psychotic disorders).


title: Forensic psychology

text: Violence risk assessment evaluates how dangerous an individual is, or could be, and the risk of them re-offending, also referred to as recidivism. Risk assessments affect the possibility of an inmate receiving parole or being released from prison and are also used in sentencing. Imposition of the death penalty often requires a consideration of "future dangerousness," for which risk assessment can play a vital role. Although there are many advocates for the use of risk assessment in sentencing, sometimes referred to as "evidence-based sentencing," as a method for reducing mass incarceration in the United States, there are others who question whether risk assessments are accurate enough to be relied upon when making these consequential legal decisions. Risk assessment, as with any attempt to understand future behavior, is very difficult, especially because "risk" isn't always defined the same way in different legal settings. There is a wide research literature on risk assessment, but the information is varied and sometimes contradictory, and bias can play a role in risk assessment. It is also difficult to assess the accuracy of risk assessment and for individual clinicians to receive feedback on their risk assessment decisions. Making a false negative decision in the real world (i.e., labeling someone who is actually high-risk as low-risk) tends to have more visible consequences than making a false positive decision (i.e., labeling someone who is actually low-risk as high-risk), and clinicians might never even find out that the latter assessment was incorrect. This risk imbalance in making these types of errors can bias clinicians away from making low-risk classifications. In experimental validation studies, risk assessment accuracy is typically measured using area under the ROC curve (AUC), a statistical method which indicates the likelihood that a random high-risk offender would be classified as higher risk than a random low-risk offender.


title: Forensic psychology

text: While insanity and competency assessments are among the most common criminal assessments administered within the legal system, there are several other types implemented. Some of these include death penalty case assessments, assessments of child sexual abuse, assessments for child custody or divorce cases, civil court assessments, and immigration/asylum cases.


title: Forensic psychology

text: A forensic psychologist's interactions with and ethical responsibilities to the client differ widely from those of a psychologist dealing with a client in a clinical setting.


title: Forensic psychology

text: The ethical recommendations and expectations outlined for forensic psychology specifically are listed in the APA's "Specialty Guidelines for Forensic Psychology". These guidelines involve reminders that forensic psychologists should value integrity, impartiality, and fairness, as well as avoid conflicts of interest when possible. These conflicts of interest may arise in situations in which the psychologist is working as a consultant to one side or another in a court case, when the psychologist is required to testify or evaluate something that collides with their own beliefs or values, or when a psychologist is faced with the decision of choosing between playing the role of an individual's evaluator or treatment provider in a case. This final conflict of interest also relates to the ethical guidelines relating to having multiple relationships with clients. As a standard of ethics, forensic psychologists are expected to offer a certain amount of reduced fee or pro bono services for individuals who may not be able to afford hiring a psychologist for a court case otherwise. Other ethical guidelines involve receiving informed consent from clients before communicating information regarding their treatment or evaluations, respecting and acknowledging privacy, confidentiality, and privilege among clients, remaining impartial and objective when involved in a trial, and weighing the moral and ethical costs of complying with any court orders that may conflict with professional standards.


title: Forensic psychology

text: There is a wide range of pay for individuals in the forensic psychology field. In the United States, the median annual income of clinical-forensic psychologists is $125,000 - $149,999, and the pay can range from $50,000 (entry-level) a year to more than $350,000 a year. There are also pay differences for men and women, where female forensic psychologists earn $0.83 for every $1.00 earned by male psychologists. Forensic psychologists' income varies from one state to another.


title: Aarhus Gymnastikforening

text: Aarhus Gymnastikforening (; commonly known as AGF ), is a professional sports club based in Aarhus, Jutland, Denmark. Founded in 1880, it is one of the oldest clubs in the country and gymnastics and fencing are featured as its main sports. However, AGF is mostly known for its football department, which was established in 1902. Currently, the club's first team plays in the Danish Superliga, the top flight of the Danish football league system.


title: Aarhus Gymnastikforening

text: AGF has won five Danish Football Championships and a record nine Danish Cups. In 1961, AGF reached the quarter-finals of the European Cup where they were knocked out by later winners, Benfica. In 1989, AGF again reached a European quarter-final. This time in the European Cup Winners' Cup, where they lost 1–0 on aggregate to later winners FC Barcelona.


title: Aarhus Gymnastikforening

text: AGF played its first football match against Aarhus Idrætsklub Olympia in November 1902, a 5–2 loss. Six years later, the club won the Jutland Football Championship by winning 3–2 over Ringkøbing IF in the final. AGF won the Jutland Football Championship seven times and was in three finals of the Danish Football Championship before AGF became a member of the newly founded Denmark Tournament in 1927.


title: Aarhus Gymnastikforening

text: In 1911, AGF got its own clubhouse after which the club bought the pitches at Dalgas Avenue. In 1920, AGF began to play its home matches at the newly built Aarhus Stadium, where the club has played ever since. In 1941, the club moved from the clubhouse at Dalgas Avenue to Fredensvang in the suburb of Viby J.


title: Aarhus Gymnastikforening

text: For three seasons in a row from 1949 to 1951 AGF finished in third place in the top division. After spending the 1952–53 season in the 2nd Division, AGF returned strongly to the 1st Division and in the next 12 seasons won four Danish Football Championships and five Danish Cups. AGF also participated in the first edition of the European Cup, where they lost 4–2 on aggregate to French club Reims with three goals scored by Léon Glovacki. In 1961, AGF reached the quarter-final in the same tournament where they lost to eventual tournament winners Benfica. AGF were relegated to the 2nd Division in 1968 and in 1973 but returned to the 1st Division in 1976. This was the start of 30 continuous years in the top division.


title: Aarhus Gymnastikforening

text: The introduction of professional football in Denmark had a major influence on the success AGF experienced from the late 1970s and forward until 1998. With former Real Madrid star Henning Jensen on the team, AGF were close at winning the Danish Football Championship in 1982. AGF drew 2–2 against B.93 in the last game of the season which sent the championship to OB. In 1984, AGF were again close to clinching the championship but lost by a single point to the rivals from Vejle Boldklub. Finally in 1986, AGF won their fifth Danish Football Championship. Flemming Povlsen, Jan Bartram and John Stampe were the key players of the team these years. In 1987, 1988 and 1992 AGF also won the Danish Cup.


title: Aarhus Gymnastikforening

text: In 1996, with players such as Stig Tøfting and Håvard Flo, AGF were again close to winning the Danish Football Championship, but lost the title to Brøndby IF in dramatic fashion on the second to last matchday when opposing goalkeeper Mogens Krogh headed in the 3–3 equaliser. AGF would, however, win the Danish Cup that season by beating Brøndby.


title: Aarhus Gymnastikforening

text: In 1998, AGF finished third in the Danish Superliga but financial problems resulted in poor results the following years. In 2000, Peter Rudbæk was fired after seven years as manager. From 2000 onwards, the club experienced some of its worst ever results, which led to relegations in the 2005–06, 2009–10 and 2013–14 seasons. Each time, however, the club secured a quick return to the top-flight.


title: Aarhus Gymnastikforening

text: In the summer of 2014, AGF appointed Jacob Nielsen as their new director. Nielsen had been successful as director of Randers where he had managed to secure good economic results. AGF also hired a new sporting director and Morten Wieghorst as manager. On 6 December 2015, however, Nielsen announced that Wieghorst was fired and that former Danish champion Glen Riddersholm was hired as his replacement.


title: Aarhus Gymnastikforening

text: With Riddersholm as manager AGF finished the 2015–16 season in tenth place having won three games, drawn seven, and lost five in the remainder of the season. AGF qualified for 2016 cup final, in which they lost 2–1 to FC Copenhagen. In the 2016–17 season, AGF finished 11th after having played relegation play-off matches in the new league structure introduced that season.


title: Aarhus Gymnastikforening

text: On 30 September 2017, Riddersholm was fired due to inconsistent results. At that point AGF was seventh in the league having started the 2017–18 season with four wins, five defeats, and two draws. Riddersholm's last match was a 5–1 win against FC Helsingør. New manager was David Nielsen who started with four consecutive league defeats but finished the season in seventh place after losing a European play-off final against FC Copenhagen 4–1. After reaching eighth place in 2018–19 season, the club managed to win the bronze medal in the 2019–20 season.


title: Aarhus Gymnastikforening

text: Their home ground is Aarhus Stadium, renamed Ceres Park for sponsorship reasons since 2015, which has a capacity of 19,433.


title: Aarhus Gymnastikforening

text: AGF's first competitive European match was on September 21, 1955, in the 1955–56 European Cup, losing 0–2 at home to France's Stade Reims & eventually losing on aggregate 2–4 in the first round. Since then, the club has participated in numerous UEFA competitions, advancing as far as the quarter-finals of the 1960–61 European Cup and 1988–89 UEFA Cup Winners' Cup.


title: Tiku Weds Sheru

text: Tiku Weds Sheru is an upcoming Indian Hindi-language romantic drama and a dark satire film. The film is produced by Kangana Ranaut, written and directed by Sai Kabir under the banner of Manikarnika Films. It stars Avneet Kaur and Nawazuddin Siddiqui in lead roles. The film is Kangana's maiden production after the launch of her production house in 2020. The film is scheduled to premiere on Amazon Prime Video.


title: Tiku Weds Sheru

text: Ranaut wanted to make this film with Irrfan Khan. However, after his demise, she decided to cast Nawazuddin Siddiqui for the male lead and Avneet Kaur was finalized as the female lead.


title: Tiku Weds Sheru

text: Besides the fresh pairing, casting brought to the fore the old debate of the huge age gap between the male and the female actor. On this, Ranaut expressed that she overlooked 27-year age gap between the stars as the pair seemed her well-suited for the storyline, and Kaur stated that she does not see the age gap as a problem as it was a requirement for the film.


title: Tiku Weds Sheru

text: The film's pre-production began in October. Principal photography began on 8 November 2021 in Mumbai, outdoor schedule began on 20 December 2021 in Bhopal and its last schedule began on 22 January 2022 back in Mumbai. The film wrapped up on 1 February 2022.


title: Michael Howard

text: Michael Howard, Baron Howard of Lympne (born Michael Hecht; 7 July 1941) is a British politician who served as Leader of the Conservative Party and Leader of the Opposition from November 2003 to December 2005. He previously held cabinet positions in the governments of Margaret Thatcher and John Major, including Secretary of State for Employment, Secretary of State for the Environment and Home Secretary.


title: Michael Howard

text: Howard was born in Swansea to a Jewish family, his father from Romania and his mother from Wales. He studied at Peterhouse, Cambridge, following which he joined the Young Conservatives. In 1964, he was called to the Bar and became a Queen's Counsel in 1982. He first became a Member of Parliament at the 1983 general election, representing the constituency of Folkestone and Hythe. This quickly led to his promotion and Howard became Minister for Local Government in 1987. Under the premiership of John Major, he served as Secretary of State for Employment (1990–1992), Secretary of State for the Environment (1992–1993) and Home Secretary (1993–1997).


title: Michael Howard

text: Following the Conservative Party's landslide defeat at the 1997 general election, he unsuccessfully contested the leadership, and subsequently held the posts of Shadow Foreign Secretary (1997–1999) and Shadow Chancellor of the Exchequer (2001–2003). In November 2003, following the Conservative Party's vote of no confidence in Iain Duncan Smith, Howard was elected to the leadership unopposed.


title: Michael Howard

text: At the 2005 general election, the Conservatives gained 33 new seats in Parliament, including five from the Liberal Democrats; but this still gave them only 198 seats to Labour's 355. Following the election, Howard resigned as Leader of the Conservative Party and was succeeded by David Cameron. Howard did not contest his seat of Folkestone and Hythe in the 2010 general election and entered the House of Lords as Baron Howard of Lympne. Prior to Brexit he was supportive of the Eurosceptic pressure group Leave Means Leave.


title: Michael Howard

text: Howard was born Michael Hecht in Gorseinon, Swansea, son of Bernat Hecht (died 1966), who was born in Romania and came to Britain in 1939, and Hilda (), who had lived in Wales from the age of six months where her father was a draper at Llanelli. She was a cousin of the Landy family who had helped Bernat Hecht come to Britain. Both of Howard's parents were from Jewish families. Howard's grandmother was murdered at Auschwitz.


title: Michael Howard

text: Bernat Hecht was a synagogue cantor who worked for his wife's family drapery business, later establishing himself as a prominent local businessman, owning three shops in Llanelli. When Howard was six, his parents became naturalised as British subjects and the family name was changed to Howard.


title: Michael Howard

text: Howard passed his eleven-plus exam in 1952 and then attended Llanelli Boys' Grammar School. He joined the Young Conservatives at age 15. He gained a place at Peterhouse, Cambridge, where he was President of the Cambridge Union in 1962. After taking a 2:1 in the first part of the economics tripos, he switched to law and graduated with a 2:2 in 1962.


title: Michael Howard

text: He was one of a cluster of Conservative students at Cambridge University around this time, sometimes referred to as the "Cambridge Mafia", many of whom held high government office under Margaret Thatcher and John Major (see: Cambridge University Conservative Association).


title: Michael Howard

text: Howard was called to the Bar at the Inner Temple in 1964 and specialised in employment and planning law. He continued his career at the Bar, becoming a practising Queen's Counsel in 1982 (unlike some barrister-MPs who were awarded the title as an honorific despite no longer practising at the Bar).


title: Michael Howard

text: In the late 1960s Howard gained promotion within the Bow Group, becoming Chairman in April 1970. At the Conservative Party conference in October 1970, he made a notable speech commending the government for attempting to curb trade union power and also called for state aid to strikers' families to be reduced or stopped altogether, a policy which the Thatcher government pursued over a decade later.


title: Michael Howard

text: In the 1970s, Howard was a leading advocate of British membership of the Common Market (EEC) and served on the board of the cross-party Britain in Europe group.


title: Michael Howard

text: At the 1966 and 1970 general elections, Howard unsuccessfully contested the safe Labour seat of Liverpool Edge Hill; reinforcing his strong support for Liverpool F.C. which he has held since childhood.


title: Michael Howard

text: In June 1982, Howard was selected to contest the constituency of Folkestone and Hythe in Kent after the sitting Conservative MP, Sir Albert Costain, decided to retire. Howard won the seat at the 1983 general election.


title: Michael Howard

text: Howard gained quick promotion, becoming Parliamentary Under-Secretary of State at the Department of Trade and Industry in 1985 with responsibility for regulating the financial dealings of the City of London. This junior post became very important, as he oversaw the Big Bang introduction of new technology in 1986. Following the 1987 general election, he became Minister for Local Government. Following a proposal from backbench MP David Wilshire, he accepted the amendment which would become Section 28 (prohibiting local governments from the "promotion" of homosexuality) and defended its inclusion.


title: Michael Howard

text: Howard guided the 1988 Local Government Finance Act through the House of Commons. The act brought in Margaret Thatcher's new system of local taxation, officially known as the Community Charge but almost universally nicknamed the "poll tax". Howard personally supported the tax and won Thatcher's respect for minimising the rebellion against it within the Conservative Party. After a period as Minister for Water and Planning in 1988–89, during which he was responsible for implementing water privatisation in England and Wales, Howard was promoted to the Cabinet as Secretary of State for Employment in January 1990 following the resignation of Norman Fowler. He subsequently guided through legislation abolishing the closed shop, and campaigned vigorously for Thatcher in the first ballot of the 1990 Conservative leadership election, although he told her a day before she resigned that he felt she was not going to win and that John Major was better placed to defeat Michael Heseltine.


title: Michael Howard

text: He retained his Cabinet post under John Major and campaigned against trade union power during the 1992 general election campaign. His work in the campaign led to his appointment as Secretary of State for the Environment in the reshuffle following the election. In this capacity he encouraged the United States to participate in the Earth Summit in Rio de Janeiro, but shortly afterwards he was appointed Home Secretary in a 1993 reshuffle precipitated by the sacking of Norman Lamont as Chancellor.


title: Michael Howard

text: As Home Secretary he pursued a tough approach to crime, summed up in his sound bite, "prison works". During his tenure as Home Secretary, recorded crime fell by 16.8%. In 2010 Howard claimed a 45% decrease in crime since a 1993 study by Home Office criminologist Roger Tarling proved that prison worked though the prison population rose from 42,000 to nearly 85,000. Ken Clarke disagreed, pointing to a 60% recidivism rate amongst newly released prisoners and hinting that factors such as better household and vehicle security and better policing could be influencing crime rates, not just the incapacitation effect of removing offenders to prison.


title: Michael Howard

text: Howard repeatedly clashed with judges and prison reformers as he sought to clamp down on crime through a series of 'tough' measures, such as reducing the right to silence of defendants in their police interviews and at their trials as part of 1994's Criminal Justice and Public Order Act. Howard voted for the reintroduction of the death penalty for the killing of police officers on duty and for murders carried out with firearms in 1983 and 1990. In 1993, he changed his mind and became opposed to the reintroduction of the death penalty and voted against it again in February 1994.


title: Michael Howard

text: In 1993, following the murder of James Bulger, two eleven-year-old boys were convicted of his murder and sentenced to be detained at Her Majesty's pleasure, with a recommended a minimum term of eight years. Lord Taylor of Gosforth, the Lord Chief Justice, ordered that the two boys should serve a minimum of ten years. The editors of "The Sun" newspaper handed a petition bearing nearly 280,000 signatures to Howard, in a bid to increase the time spent by both boys in custody. This campaign was successful, and the boys were kept in custody for a minimum of fifteen years, meaning that they would not be considered for release until February 2008, by which time they would be 25 years of age.


title: Michael Howard

text: A former Master of the Rolls, Lord Donaldson, criticised Howard's intervention, describing the increased tariff as "institutionalised vengeance ... [by] a politician playing to the gallery". The increased minimum term was overturned in 1997 by the House of Lords, which ruled it was substantively "ultra vires", and therefore "unlawful", for the Home Secretary to decide on minimum sentences for young offenders. The High Court and European Court of Human Rights have since ruled that, though Parliament may set minimum and maximum terms for individual categories of crime, it is the responsibility of the trial judge, with the benefit of all the evidence and argument from both prosecution and defence counsel, to determine the minimum term in individual criminal cases.


title: Michael Howard

text: Howard's reputation was damaged on 13 May 1997 when a critical inquiry into a series of prison escapes was published. In advance of the publication, Howard made statements blaming the prison service. In a television interview on "Newsnight," Jeremy Paxman asked Howard whether he had intervened when Derek Lewis sacked a prison governor. Paxman asked "Did you threaten to overrule him?" twelve times. Howard repeatedly said that he "did not instruct him", ignoring the "threaten" part of the question. Paxman asked him again in another interview in 2004. Howard responded: "Oh come on, Jeremy, are you really going back over that again? As it happens, I didn't. Are you satisfied now?" Secret Home Office papers partially vindicated Howard, but show that Howard asked a top civil servant if he had the power to overrule the Prison Service Director General.


title: Michael Howard

text: Shortly after the 1997 "Newsnight" interview, Ann Widdecombe, his former minister of state at the Home Office, made a statement in the House of Commons about the dismissal of then-Director of the Prison Service, Derek Lewis, and remarked of Howard that there is "something of the night" about him. This much quoted comment is thought to have contributed to the failure of his 1997 bid for the Conservative Party leadership, including by Howard and Widdecombe, and led to him being caricatured as a vampire, in part due to his Romanian ancestry. Such characterisations caused discontent among members of Britain's Jewish community.


title: Michael Howard

text: In 1996 Howard, as Home Secretary, ordered the release of John Haase and Paul Bennett with royal pardons after 10 months of their 18-year prison sentences for heroin smuggling, after they had provided information leading to the seizure of firearms. In 2008 Haase and Bennett were convicted of having set up the weapons finds to earn them their release, and sentenced to 20 and 22 years in prison respectively.


title: Michael Howard

text: Following the 1997 resignation of John Major, Howard and William Hague ran on the same ticket, with Howard as leader and Hague as Deputy Leader and Party Chairman. The day after they agreed this, Hague decided to run on his own. Howard also stood but his campaign was marred by attacks on his record as Home Secretary.


title: Michael Howard

text: Howard came in last out of five candidates with the support of only 23 MPs in the first round of polling for the leadership election. He then withdrew from the race and endorsed the eventual winner, William Hague. Howard served as Shadow Foreign Secretary for the next two years but retired from the Shadow cabinet in 1999, though continued as an MP.


title: Michael Howard

text: Following the Conservative defeat at the 2001 general election, Howard was recalled to frontline politics when the Conservative Party's new leader, Iain Duncan Smith, appointed him Shadow Chancellor of the Exchequer. His performances in the post won him much praise; indeed, under his guidance, the Conservatives decided to debate the economy on an 'Opposition Day' for the first time in several years. After Duncan Smith was removed from the leadership, Howard was elected unopposed as leader of the party in November 2003. As leader, he faced much less discontent within the party than any of his three predecessors and was seen as a steady hand. He avoided repeating such managerial missteps as Duncan Smith's firing of David Davis as Conservative Party Chairman and imposed discipline quickly and firmly: for example, he removed the party whip from Ann Winterton after she joked about 23 Chinese migrants' deaths.


title: Michael Howard

text: In February 2004, Howard called on then-Prime Minister Tony Blair to resign over the Iraq War, for failing to ask "basic questions" regarding WMD claims and misleading Parliament. In July, the Conservative leader stated that he would not have voted for the motion that authorised the Iraq War had he known the quality of intelligence information on which the WMD claims were based. At the same time, he said he still believed in the Iraq invasion was right because "the prize of a stable Iraq was worth striving for". However, Howard's criticism of Blair was not received favourably in Washington, D.C., where President of the United States George W. Bush refused to meet him. Bush's advisor Karl Rove reportedly told Howard, "you can forget about meeting the president. Don't bother coming."


title: Michael Howard

text: Howard was named 2003 Parliamentarian of the Year by "The Spectator" and Zurich UK. This was in recognition of his performance at the dispatch box in his previous role as Shadow Chancellor. However, twelve months after he became party leader, neither his personal popularity nor his party's with the public had risen appreciably in opinion polls from several years before.


title: Michael Howard

text: Howard was part of discussions for British Airways to resume flights to Pakistan in 2003, this was until their final departure in 2008 the only European airline serving the nation.


title: Michael Howard

text: In November 2004, "Newsnight" again concentrated on Howard with coverage of a campaign trip to Cornwall and an interview with Jeremy Paxman. The piece, which purported to show that members of the public could not identify Howard and that those who recognised him did not support him, was the subject of an official complaint from the Conservative Party. The complaint argued that the "Newsnight" team spoke only to people who held opinions against either Michael Howard or the Conservatives and that Paxman's style was bullying and unnecessarily aggressive. In this programme, Paxman also returned to his question from 1997. Howard returned briefly to "Newsnight" on Jeremy Paxman's final episode on 18 June 2014 for a cameo.


title: Michael Howard

text: At the 2005 general election, Howard's Conservative Party suffered a third consecutive defeat, although the Conservatives gained 33 seats (including five from the Liberal Democrats) and Labour's majority shrank from 167 to 66. The Conservatives were left with 198 seats to Labour's 355. The Conservative share of the national vote increased by 0.6% from 2001 and 1.6% from 1997. The party ended with 32.4% of the total votes cast, which was within 3% of Labour on 35.2%.


title: Michael Howard

text: The day after the election, Howard stated in a speech in the newly gained Conservative seat in Putney that he would not lead the party into the next general election as, already aged 63, he would be "too old" by that stage, and that he would stand down "sooner rather than later", following a revision of the Conservative leadership electoral process. Despite Labour winning a third term in government, Howard described the election as "the beginning of a recovery" for the Conservative Party following Labour's landslide victories in 1997 and 2001.


title: Michael Howard

text: Howard's own constituency of Folkestone and Hythe had been heavily targeted by the Liberal Democrats as the most sought after prize of their failed "decapitation" strategy of seeking to gain seats from prominent Conservatives. Yet Howard almost doubled his majority to 11,680, while the Liberal Democrats saw their vote fall.


title: Michael Howard

text: During the 2005 general election campaign, Howard was criticised by some commentators for conducting a campaign which addressed the issues of immigration, asylum seekers, and travellers. Others noted that the continued media coverage of such issues created most of the controversy and that Howard merely defended his views when questioned at unrelated policy launches.


title: Michael Howard

text: Some evidence suggested that the public generally supported policies proposed by the Conservative Party when they were not told which party had proposed them, indicating that the party still had an image problem. Conservative John Major's 30% lead in 1992 amongst the sought after ABC1 voters (professionals) had all but disappeared by 2005.


title: Michael Howard

text: The campaign focus on immigration may have been influenced by Howard's election adviser Lynton Crosby, who had run similar tactics in Australian elections earlier. Crosby was later re-hired by the Conservative Party to run their successful campaign in the 2008 London mayoral election.


title: Michael Howard

text: In the lead up to the election campaign, Howard continued to impose strong party discipline, controversially forcing the deselection of Danny Kruger (Sedgefield), Robert Oulds and Adrian Hilton (both Slough) and Howard Flight (Arundel & South Downs).


title: Michael Howard

text: Despite his impending resignation following the 2005 general election, Howard performed a substantial reshuffle of the party's front bench in which several rising star MPs were given their first shadow portfolios, including George Osborne and David Cameron. This move cleared the way for David Cameron (who had worked for Howard as a Special Advisor when the latter was Home Secretary) to run for the Conservative Party leadership.


title: Michael Howard

text: The reforms to the party's election process took several months and Howard remained in his position for six months following the election. During that period, he enjoyed a fairly pressure-free time, often making joking comparisons between himself and Tony Blair, both of whom had declared they would not stand at the next general election. He also oversaw Blair's first parliamentary defeat, when the Conservative Party, the Liberal Democrats and sufficient Labour Party rebels voted against government proposals to extend to 90 days the period that terror suspects could be held for without charge. Howard stood down as Leader in December 2005 and was replaced by David Cameron.


title: Michael Howard

text: Howard announced on 17 March 2006 that he would stand down as MP for Folkestone and Hythe at the 2010 general election. On 19 June 2006 it was reported that Howard would become chairman of Diligence Europe, a private intelligence and risk assessment company founded by former CIA and MI5 members.


title: Michael Howard

text: On 23 October 2006, Howard said that he had voluntarily been questioned as a potential witness as part of the investigation into the Cash-for-Honours scandal relating to fundraising for the 2005 election campaign. He was not suspected of any criminal activity, was not accused of any criminal activity and gave evidence purely as a witness in an investigation focusing primarily on the Labour Government's use of the peerages system and their party fundraising.


title: Michael Howard

text: Howard was appointed a Conservative life peer in the 2010 Dissolution Honours with the title of Baron Howard of Lympne, of Lympne in the County of Kent. On 20 July 2010, he was formally introduced into the House of Lords by past colleague Norman Lamont, and attended Questions and debate later that day.<ref>


title: Brochure

text: A brochure is originally an informative paper document (often also used for advertising) that can be folded into a template, pamphlet, or leaflet. A brochure can also be a set of related unfolded papers put into a pocket folder or packet or can be in digital format. Brochures are promotional documents, primarily used to introduce a company, organization, products or services and inform prospective customers or members of the public of the benefits.