title: Edmund Bacon (architect)

text: Bacon continued to assert his vision for Philadelphia's future actively in his later years. During the 1990s he proposed new concepts to improve Independence Mall, Penn's Landing, and the Benjamin Franklin Parkway. During the same period, he promoted a design competition for North American cities to design the best "Post-Petroleum" city. Only one municipality, in Ottawa, Canada, committed to it. In 2002, at age 92, he skateboarded in LOVE Park, the plaza he founded and designed at Cornell in 1932, as a protest against the city's ban on the sport. In 2003 he appeared in the documentary "My Architect" about Louis Kahn, a Philadelphia architect. In September 2006, at the northwest corner of 15th Street and J.F.K. Boulevard, by LOVE Park, The Ed Bacon Foundation and the Pennsylvania Historical and Museum Commission dedicated a state historical marker honoring Bacon's memory and commemorating his work.


title: Edmund Bacon (architect)

text: Bacon was the father of six children: two sons, actor Kevin Bacon, musician Michael Bacon, and four daughters, Karin, Elinor, Hilda and Prudence (later Kira). His wife was Ruth Hilda Holmes, a teacher and liberal political activist. His friends included Buckminster Fuller, Steen Eiler Rasmussen, James Rouse, and Konstantinos Apostolos Doxiadis.


title: Indoor American football

text: Indoor American football, or arena football, is a variation of gridiron football played at ice hockey-sized indoor arenas. While varying in details from league to league, the rules of indoor football are designed to allow for play in a smaller arena. It is distinct from traditional American or Canadian football played in larger domed or open-air stadiums, although several early college football games contested on full-sized or nearly full-sized fields at Chicago Coliseum (1890s) and Atlantic City Convention Center (1930s and 1960s) helped to show that football could be played as an indoor game.


title: Indoor American football

text: The first demonstration of football on a small field was actually played outdoors at the original open-air Madison Square Garden. Using nine-man sides, Pennsylvania defeated Rutgers 10–0 at the annual meeting of the Amateur Athletic Union on January 16, 1889.


title: Indoor American football

text: The first documented indoor football game was an exhibition between the Springfield YMCA Training School and a Yale Senior Class team played on December 12, 1890 at Madison Square Garden II. James Naismith scored a touchdown for Springfield, though Yale won the exhibition 16–10. The following day a second exhibition game was played, with Pennsylvania defeating Rutgers 20–12. The field at Madison Square Garden measured 260 feet long and 100 feet wide.


title: Indoor American football

text: The first documented indoor regulation football games were those played at the Chicago Coliseum in the late 1890s. The first such game matched Michigan against Chicago on Thanksgiving Day 1896. The match was "the first collegiate game of football played under a roof." Adding to the novelty, as daylight turned to darkness, the field inside the Coliseum was lit with electric lighting. With seven acres of floor space, the sprawling Coliseum is believed to have not needed any compromises to accommodate an American football field. According to a newspaper account, the field grew dark in the second half, and play was halted for ten minutes to discuss whether play should continue. Play was resumed, and the lights were finally turned on after Michigan scored a touchdown. The press proclaimed the experiment in indoor football to be a success:


title: Indoor American football

text: One thing at least was settled by the game, and that is, that indoor football is literally and figuratively speaking a howling success. The men had no trouble in catching punts, and football was played on its merits, without the handicaps of a wet field or a strong wind. Toward the end of the second half it got very dark, and the spectators were treated to a novelty in the shape of football by electric light."


title: Indoor American football

text: Although both critically and commercially successful, the Coliseum was destroyed in a fire less than two years after its opening, and its replacement could not accommodate an American football field.


title: Indoor American football

text: Later, at Madison Square Garden in 1902 and 1903, there were games known as the "World Series of Pro Football." The games were played on a 70-yard by 35-yard dirt field but otherwise adhered to outdoor rules. Poor attendance led to the tournament being discontinued after two years.


title: Indoor American football

text: The Chicago Bears of the National Football League hosted an experimental game against their crosstown rivals, the Cardinals, after the 1930 NFL season, at the indoor Chicago Stadium. Two years later, poor weather conditions led to the Bears hosting the 1932 NFL Playoff Game against the Portsmouth Spartans (now the Detroit Lions) at the stadium. A dirt and tanbark field measuring 80 yards long (60 yards plus two ten-yard end zones) and 45 yards wide was constructed on the arena's floor. The Chicago Stadium games were notable for introducing several rule changes, including the introduction of hash marks to keep play away from spectators who were seated next to the field (much like modern indoor football), while goal posts were moved to the goal line. To compensate for the smaller field, teams were "penalized" 20 yards upon crossing midfield. (The Bears' official Web site goes further and claims that field goals were outlawed for the 1932 game.)


title: Indoor American football

text: In 1930, the Atlantic City Convention Center constructed a nearly full-size indoor football field, and used it for one to three games a year during the 1930s; the stadium stopped hosting games in 1940 and did not resume hosting football games until 1961. In the 1960s the Boardwalk Bowl, a post-season game involving small college teams, was contested at the convention center. The Bowl was an attempt to make Atlantic City more of a year-round resort in the pre-gambling era as opposed to a single-season one (the Miss America Pageant, also held at the center, likewise began as an attempt to extend the season beyond Labor Day). The Atlantic Coast Football League played its inaugural championship game at the convention center in 1962, but the game only drew 2,000 fans and the game would thereafter move to the home stadium of the team with the best regular season record. The Philadelphia-based Liberty Bowl game, which had been played at Municipal Stadium from 1959–1963, was moved into the Convention Center in 1964 for the contest between Utah and West Virginia. The game drew just over 6,000 fans, though, and the Liberty Bowl moved to Memphis the next year, where it has remained. Unlike modern indoor football, the size of the playing surface and hence the rules were essentially the same as in the standard outdoor game, with rules updated to deal with contingencies for what could happen indoors, such as a punt striking the ceiling. The end zones were slightly shorter—eight yards instead of the standard ten (coincidentally, the eight-yard endzone length is the standard in modern indoor football).


title: Indoor American football

text: While several attempts to create a true indoor football game have been made since shortly after American football was developed, the first version to meet with relatively widespread success and acceptance was devised by Jim Foster, a former executive of the United States Football League and the National Football League. He devised his game while watching indoor soccer, another game derived from a sport played outdoors. He worked on the game in the early 1980s, but put any plans for full development of it on hold while the United States Football League, an attempt to play traditional American football in a non-traditional (spring-summer) season, was in operation in 1983–1985. When the USFL ceased operations, Foster saw his opportunity. He staged a "test" game in Rockford, Illinois in 1986 and put together a four-team league for a "demonstration season" in the spring of 1987, with games televised on ESPN.


title: Indoor American football

text: Foster had to adopt a field that would fit within the smaller playing surfaces found in most arenas and thus created a field that was identical in size to a standard North American ice hockey rink, . This resulted in the field being 50 yards long (half of the length of a standard American football field) with eight-yard end zones (which may, if necessary, be curved in the end zones as hockey rinks are), and the field being slightly over half as wide as a standard football field. Foster adopted short-pile artificial turfs (which were then standard) such as AstroTurf for the field because of its ability to be rolled up when the arena is being used for other sports.


title: Indoor American football

text: Foster adopted a modified version of eight-man football. He also mandated a one-platoon system that required at least six players to play on both offensive and defensive downs. This had the added desirable effect of limiting team payrolls.


title: Indoor American football

text: To further an offensive passing advantage over the defense, Foster also imposed strict restrictions on the defensive formation, mandating that all defenses were required to play a 3-2-Monster formation with three defensive linemen, two linebackers, two cornerbacks, and one safety. Linebackers were not permitted to blitz and were required to stay in boxes behind the line of scrimmage, while defensive linemen were hindered by restrictions that prevented them from using certain techniques to penetrate the offensive line. Quarterbacks and placekickers were exempt from the one-platoon system, allowing two key scoring positions to be more specialized. The AFL also adopted the USFL's concept of playing in the late spring and summer, since this is when most hockey and basketball arenas have the fewest schedule conflicts (only competing with touring stadium rock concerts). The spring schedule has since been adopted by virtually all other professional indoor leagues as of 2010.


title: Indoor American football

text: Within a year of the AFL kicking off, its first challenger, the World Indoor Football League formed. The WIFL planned to play a schedule with six teams beginning in summer of 1988 with its own set of indoor-inspired rules, including an unusual system that would have eight men on offense and seven men on defense. Despite having backing from former NFL players, veteran coaches, and singer John Mellencamp, the league canceled its 1988 season, folded half of its franchises (including Mellencamp's), and made an unsuccessful bid for the remaining three teams to join the AFL.


title: Indoor American football

text: In 1990, Foster patented the rules of arena football, meaning that only persons authorized by him could use his rules and his name for the sport. While the AFL asserted throughout the 1990s that the patent covered virtually every aspect of the game (from the 50-yard field to the eight-man format), a 1998 lawsuit ("Arena Football League v. Professional Indoor Football League") established that the patent specifically covered the rebound net feature, meaning that competitors could not use this aspect of the rules. However, under provisions of U.S. patent law, Foster's patent expired on March 27, 2007, enabling competitors to use rebound nets (at least as originally envisioned, without other innovations that he may have patented).


title: Indoor American football

text: The AFL signed a major network television broadcasting contract with NBC, and eventually launched an official minor league, af2, beginning in 2000. This effort basically served two purposes: one as a developmental league for the AFL, and as a place where former collegiate players could develop while at the same time learning and becoming accustomed to the unique arena rules, and secondly as a pre-emptive way of shutting out potential new indoor football competitors (this was especially important as the 2007 expiration of Foster's patent on the rebound nets approached). At times over forty teams participated in this league, almost uniformly in cities which also had minor league ice hockey teams and hence suitable arenas.


title: Indoor American football

text: Shortly before the end of 2008, the Arena Football League announced that it would not be playing a 2009 spring season. During the previous few years, the league administrators and team owners had allowed player salaries and other costs to rise to the point where the league and many of the teams were losing a substantial amount of money. Late in the summer of 2009, with the team owners unable to agree on a plan for making the league viable again the AFL announced that it was folding, eventually putting its assets up in a Chapter 7 bankruptcy liquidation.


title: Indoor American football

text: The developmental af2, however, played its 2009 season as scheduled. Most of the teams made a sustainable profit and the team owners were eager to see the league continue for another year. However, with the AFL owning 50.1% of the af2, it would fold if the AFL folded. At the end of the 2009 season, a gathering of af2 and remaining AFL team owners set out to form their own organization, originally known as Arena Football 1 (AF1). AF1 went on to purchase all assets of the original AFL and af2, except for a few team names and logos owned by outside parties, in a December 2009 bankruptcy auction. Shortly after the purchase, AF1 adopted the Arena Football League name, and the AFL relaunched in 2010. The "iron man" rule, requiring at least six of the eight players to play on both offense and defense, was dropped, but most other past AFL rules remained unchanged. The relaunched league saw franchises return and renewed interest, but by the end of the 2017 season, almost all of the league's teams had either folded or moved to other leagues, with only the Philadelphia Soul having existed prior to 2016. Five expansion teams, all in the Mid-Atlantic United States, were established over the next two years, before the league announced after the 2019 season that it was dissolving in a second Chapter 7 bankruptcy.


title: Indoor American football

text: Other indoor football leagues have been formed, without the use of the rebound nets at the ends of the field. Like the AFL, their playing seasons are entirely or primarily outside the traditional fall/early winter season of the outdoor sport so as not to be competing with it directly for fan support.


title: Indoor American football

text: Since the first such league, the Professional Indoor Football League, began play in the 1998, there has often been a pattern of instability. Each off-season has seen teams jumping from league to league. In addition, leagues have annually merged, changed names, and separated. The organization that was most recently known as American Indoor Football (AIF) went through three names and two ownership changes in its first three seasons. Several other indoor leagues have been announced without ever actually commencing play, or operating only briefly with a handful of teams. Some were claimed attempts to form a second "major" league of indoor football while others were strictly efforts to form a new "minor" league.


title: Indoor American football

text: A few leagues have achieved a certain level of stability, however. The National Indoor Football League (NIFL) began in 2001 and was the most successful league in the early 2000's. The Indoor Football League (IFL) began in the autumn of 2008 when two already-established leagues (the Intense Football League and United Indoor Football) chose to merge into a single organization. The IFL's expansion model has been based less on establishing new teams and more on acquiring existing teams from other leagues. The IFL has 14 teams as of 2020. Other, regional leagues include Champions Indoor Football (CIF), the American Arena League (AAL) and National Arena League (NAL). Both CIF and the AAL were formed by mergers of existing leagues. The CIF was formed from a merger of the Champions Professional Indoor Football League and the Lone Star Football League in 2015. The AAL was formed in late 2017 as the combination of three leagues that each played one season: the Can-Am Indoor Football League, Arena Pro Football, and Supreme Indoor Football.


title: Indoor American football

text: Fan Controlled Football launched in 2021 following an interactive format inspired by video games, with "power-ups" and fans voting on plays. It generally targeted a higher caliber of player than the typical indoor league, with outdoor football veterans such as Johnny Manziel, Robert Turbin, Quinton Flowers, Quinn Porter, Shawn Oakman and Josh Gordon playing in the league's inaugural season.


title: Indoor American football

text: The best-known indoor women's football league is the Legends Football League (formerly known as the Lingerie Football League). Known for its scantily-clad players and its signature event, the Legends Cup (formerly Lingerie Bowl), the LFL played a variant of indoor rules with most of its games in indoor stadiums, although few teams experimented with playing in outdoor stadiums. The league's brief foray into Australia was played in outdoor stadiums; these teams nevertheless played under indoor football rules. All other women's leagues play on outdoor fields with outdoor rules; there have been several other attempts to form indoor women's football leagues, but none have made it to play.


title: Indoor American football

text: All current indoor football teams play at a minor league or semi-professional level. The average player's salary in the Arena Football League was US$1,800 per game in 2008; this is about one-quarter of the Canadian Football League (adjusted for inflation). Players in af2 were paid $250 per game and the AIFA and IFL had per-game salaries of $200 per game; the AFL paid $885 per game for most players in 2012, with that number rising to $940 per game in 2013 (although players then had to pay for their own housing, which the league previously provided); starting quarterbacks receive a $300 per game bonus. As of 2019, the IFL pays $200–$300 per game, with a $25 bonus for each win. FCF pays $400 to $750 a week.


title: Indoor American football

text: Green Bay Packers head coach Matt LaFleur was a quarterback for the Omaha Beef and the Billings Outlaws in the National Indoor Football League (NIFL). Running back Fred Jackson rushed for over 1,000 yards as the starting running back for the 2009 Buffalo Bills, and his high quality play earned him a spot on "USA Today"'s "All-Joe" Team. Jackson played the early part of his professional football career for the Sioux City Bandits (now of Champions Indoor Football) and Michael Lewis (wide receiver) played for the Louisiana Bayou Beast in 1999 and then with the New Orleans Saints. Probably the most notable player to come out of Arena football into the National Football League is Kurt Warner, MVP quarterback of the Super Bowl XXXIV champion (2000 game, 1999 season) St. Louis Rams, who had previously quarterbacked the former Iowa Barnstormers of the AFL. The National Football League removed a ban that had been in place on any of its owners owning teams in any other sort of football operation with respect to Arena football only, and several of them had bought or started Arena teams at one point. However, the NFL allowed to lapse an option it had negotiated allowing it to purchase up to 49% of Arena football, and as of early 2007 seemed to have backed away from any plan it may have had to use Arena football as a developmental league in any sort of "official" sense, perhaps in the interest of not undermining its then-existing "official" developmental league, NFL Europa.


title: Indoor American football

text: Several NFL owners owned Arena Football League teams in their own cities prior to the league's bankruptcy. At the end of the 2008 season, Jerry Jones and the Dallas Desperados (who had similar colors and logos to the Dallas Cowboys), Arthur Blank's Georgia Force, and the Colorado Crush (whose shareholders included Broncos owner Pat Bowlen and Rams then-minority owner Stan Kroenke) were still in the league. San Francisco 49ers owner Denise DeBartolo York and the Washington Commanders owner Daniel Snyder had future expansion rights to their respective cities. Tom Benson's original New Orleans VooDoo and Bud Adams's Nashville Kats had already folded prior to the bankruptcy and none of the NFL owners with AFL franchises returned to the league after its reformation in 2010, and most favored abolishing the league entirely.


title: Indoor American football

text: Two players and one owner with substantial contributions (at least the majority of one season) have reached the Pro Football Hall of Fame: 2017 inductee Kurt Warner played the first three seasons of his professional career in the AFL, 2018 inductee Terrell Owens played his last professional season with the Indoor Football League in 2012, and the aforementioned Pat Bowlen was inducted into the Hall in 2019.


title: Indoor American football

text: Dozens of former and current professional outdoor football players also have invested money into indoor football franchises.


title: Sunshine of Your Love

text: "Sunshine of Your Love" is a 1967 song by the British rock band Cream. With elements of hard rock, psychedelia, and pop, it is one of Cream's best known and most popular songs. Cream bassist and vocalist Jack Bruce based it on a distinctive bass riff he developed after attending a Jimi Hendrix concert. Guitarist Eric Clapton and lyricist Pete Brown later contributed to the song and drummer Ginger Baker plays a distinctive tom-tom drum rhythm.


title: Sunshine of Your Love

text: The song was included on Cream's best-selling second album "Disraeli Gears" in November 1967. Atco Records, the group's American label, was initially unsure of the song's potential. After recommendations by other label-affiliated artists, it released an edited single version in December 1967. The song became Cream's first and highest charting American single and one of the most popular singles of 1968. In September 1968, it became a modest chart hit after being released in the UK.


title: Sunshine of Your Love

text: Cream performed "Sunshine of Your Love" regularly in concert and several live recordings have been issued, including on the "Royal Albert Hall London May 2-3-5-6, 2005" reunion album and video. Hendrix performed faster instrumental versions of the song, which he often dedicated to Cream. Several rock journals have placed the song on their greatest song lists, such as "Rolling Stone", "Q" magazine, and VH1. The Rock and Roll Hall of Fame included it on its list of the "500 Songs That Shaped Rock and Roll".


title: Sunshine of Your Love

text: In early 1967, Cream were writing and rehearsing songs for a second album. Their December 1966 debut album, "Fresh Cream", was a mix of updated blues numbers and pop-oriented rock songs. Inspired by recent developments in rock music, the group began pursuing a more overtly psychedelic direction. "Sunshine of Your Love" began as a bass phrase or riff developed by Cream bassist Jack Bruce. Cream attended a concert on 29 January 1967 by the Jimi Hendrix Experience at the Saville Theatre in London. Cream guitarist Eric Clapton elaborated in a 1988 "Rolling Stone" magazine interview:


title: Sunshine of Your Love

text: Music writers Covach and Boone describe the riff as blues-derived, which uses a minor blues pentatonic scale with an added flattened fifth note (or common blues scale). The song follows a blues chord progression (I–IV–I) during the first eight bars. Brown had a difficult time writing lyrics that fit the riff. After an all-night session, Bruce played it on a standup bass while lyricist Pete Brown was staring out the window. Slowly, he started to write "It's getting near dawn and lights close their tired eyes", which is used in the first verse. Later, to break up the rhythm, Clapton wrote a refrain which also yielded the song's title. It consists of eight-bar sections using three chords, when the key shifts to the V chord (I = V):


title: Sunshine of Your Love

text: A bootleg recording from the Ricky-Tick club in London before Cream recorded the song in the studio, shows "Sunshine of Your Love" with a beat common to rock for the period. Cream drummer Ginger Baker compared it to the uptempo "Hey Now, Princess", another Bruce/Brown composition Cream recorded in March. He said that he advised Bruce to slow it down and came up with the distinctive drum pattern which emphasises beats one and three (typical rock drumming favours beats two and four and is known as the backbeat). However, Bruce and recording engineer Tom Dowd dispute Baker's claim, which they say he only made much later. Dowd later explained


title: Sunshine of Your Love

text: Cream performed their first American concerts in New York City in 1967. Robert Stigwood, the group's manager, booked them for a Murray the K package show at the RKO Manhattan Theatre from 25 March to 2 April 1967. When it was finished, Stigwood arranged for a recording session with Ahmet Ertegun at Atlantic Studios. Bruce and Brown had a number of new songs in various stages of development and entered the studio on 3 April. Initially, Ertegun assigned Dowd to work with the trio. Dowd had worked with many of the biggest jazz and rhythm and blues musicians in the 1950s and 1960s. However, Cream was his first exposure to extreme volume levels. The group arrived at Atlantic with their concert setup of multiple Marshall amplifiers (each 100 watts). Dowd was surprised by the amount of equipment accompanying the trio: "They recorded at ear-shattering level... Everyone I'd worked with before was using Fender Deluxes [about 20 watts] or Twins [about 80 watts]—six- and seven-piece bands that didn't play as loud as this three piece did."


title: Sunshine of Your Love

text: Ertegun brought in producer Felix Pappalardi, who he believed could work as a go-between with the group and Dowd. They began with "Strange Brew", "Tales of Brave Ulysses", and "Sunshine of Your Love". Ertegun previewed the demos and was unhappy, expecting more blues-based material that was found on "Fresh Cream". Jerry Wexler, Ertegun's Atlantic Records partner, reportedly went as far as to call it "psychedelic hogwash". However, Booker T. Jones (producer and keyboardist of Booker T. & the M.G.'s) and Otis Redding (both whose Stax recordings at the time were distributed by Atco parent Atlantic) gave "Sunshine of Your Love" their wholehearted approval. Differences were smoothed over by the time Cream returned in May 1967 to finish recording the songs for "Disraeli Gears".


title: Sunshine of Your Love

text: With Pappalardi and Dowd, work continued on "Sunshine of Your Love". For his guitar solo, Clapton used a sound known as the "woman tone", which is described as "smooth, dark, singing, sustaining", by author Mitch Gallagher. The actual guitar that Clapton used has been identified as a 1964 Gibson SG, known as "the Fool". It is one of the best-known examples of the woman tone and quotes the melody from the perennial pop standard "Blue Moon". By using the song's major pentatonic scale, Clapton provides a contrast with the riff's blues scale. A writer for the Rock and Roll Hall of Fame describes this as "creating a balance between the sun and the moon".


title: Sunshine of Your Love

text: Baker plays much of the song on the tom-toms, described as sounding African (Schumacher) and Native American (Shapiro). Covach and Boone note he "concentrates on the lower tom sounds and uses an articulation and sound reminiscent of the jazz drumming in the Woody Herman or Benny Goodman bands".


title: Sunshine of Your Love

text: "Sunshine of Your Love" was included as the second track on "Disraeli Gears", which was released in November 1967 by Reaction Records in the UK and Atco Records in the US. At first, Atco did not see the song as a single ("Strange Brew", backed with "Tales of Brave Ulysses" had been released as a single in June 1967). However, in December 1967, the label issued an edited version of the song as the second single from the album, backed with "SWLABR" (the running time was trimmed from 4:08 to 3:03).


title: Sunshine of Your Love

text: It entered "Billboard" magazine's Hot 100 chart on 13 January 1968, reaching number 36 during its initial 14-week run. The record re-entered the chart on 6 July 1968 and reached number five on 31 August 1968. In the UK, the single was not released until September 1968, after Cream had announced their impending breakup. Polydor Records issued the UK single, which reached number 25 in the charts.


title: Sunshine of Your Love

text: The Recording Industry Association of America (RIAA) certified the single gold on 26 September 1968, signifying sales in excess of 1,000,000 copies. In the US, it became one of the best selling singles of 1968 and one of the best-selling at the time for the Atlantic group of labels. As one of Cream's most popular songs, several of the group's compilation albums include the full-length studio recording, such as "Best of Cream", "Heavy Cream", "The Very Best of Cream", and the boxed set "Those Were the Days". In the United Kingdom, the British Phonographic Industry (BPI) certified the song gold in September 2022, denoting sales and streaming figures exceeding 400,000 units.


title: Sunshine of Your Love

text: In 2004, the song ranked number 65 on "Rolling Stone" magazine's list of the "500 Greatest Songs of All Time". In March 2005, "Q" magazine placed "Sunshine of Your Love" at number 19 on its list of the "100 Greatest Guitar Tracks Ever!" In 2009, VH1 included it at number 44 on its list of the "Top 100 Hard Rock Songs". The song is on the Rock and Roll Hall of Fame's list of the "500 Songs That Shaped Rock and Roll".


title: Sunshine of Your Love

text: Ertegun later admitted that, while his tastes ran more to Robert Johnson (Clapton had recorded Johnson's "Ramblin' on My Mind" with John Mayall, "Crossroads" with the Powerhouse, and "Four Until Late" with Cream), Cream's and Pappalardi's vision resulted in songs which had a much larger impact on the rock audiences of the time. Covach and Boone identified "Sunshine of Your Love" as foreshadowing future trends in rock:


title: Sunshine of Your Love

text: Several live recordings of "Sunshine of Your Love" have been issued on Cream albums. These include a 24 October 1967 recording by the BBC ("BBC Sessions"), 9 March 1968 at the Winterland Ballroom ("Live Cream Volume II"), and 26 November 1968 at the Royal Albert Hall ("Cream's Farewell Concert"). A recording from Cream's reunion show on 3 May 2005 is included on "Royal Albert Hall London May 2-3-5-6, 2005". During their post-Cream careers, Clapton and Bruce recorded several live performances of the song.


title: Sunshine of Your Love

text: A variety of musicians have recorded "Sunshine of Your Love". After Cream announced their breakup, Hendrix often performed it in concert as a tribute to the group, apparently unaware that they had dedicated the song to him. He played it as an instrumental and sometimes as part of a medley. A performance by the Experience on 4 January 1969 is one of the best-known. During the live broadcast of "A Happening for Lulu", a music variety show hosted by pop singer Lulu on BBC Television, the Experience suddenly broke with the programme. Hendrix announced, "We'd like to stop playing this rubbish ["Hey Joe"] and dedicate a song to the Cream, regardless of what kind of group they may be in – dedicate this to Eric Clapton, Ginger Baker, and Jack Bruce". As their performance of "Sunshine of Your Love" ran into the time allotted for Lulu's closing number, the show's producer and staff were frantically signalling for the Experience to stop. However, they continued playing and the show ended on a fade. Hendrix later apologised to Lulu, who thought the performance made for a great television moment.


title: MAS-49 rifle

text: The MAS-49 is a French semi-automatic rifle that replaced various bolt-action rifles as the French service rifle that was produced from 1949. It was designed and manufactured by the government-owned MAS arms factory. The French Army formal designation of the MAS-49 is Fusil semi-automatique 7 mm 5 M. 49 ("semi-automatic rifle of 7.5mm model 1949").


title: MAS-49 rifle

text: The initial MAS-49 semi-automatic rifle was produced in limited quantities (20,600 units), whereas the shorter and lighter variant, the MAS-49/56, was mass produced (275,240 units) and issued to all branches of the French military. Overall, the MAS-49 and 49/56 rifles gained the reputation of being accurate, reliable and easy to maintain in adverse environments. All the MAS-49 and 49/56 rifles feature a rail on the left side of their receivers to accommodate a designated rifle scope.


title: MAS-49 rifle

text: The MAS-49 arrived after a series of small, distinct design improvements. Today, this might be termed spiral development, where small elements are changed with successive models, rather than large significant changes. The MAS-49 semi-automatic rifle evolved from the prototype MAS-38/39 and from the MAS-40, and lastly from the post-war MAS-44 and its minor variants 44A, 44B and 44C. Although 50,000 MAS-44 rifles were ordered in January 1945, only 6,200 were delivered to the Marine Nationale. The MAS-49 was formally adopted by the French Army in July 1949. Its final form the MAS 49-56 was the French service rifle until adoption of the FAMAS.


title: MAS-49 rifle

text: As a service rifle, the MAS-49 replaced the diverse collection of aging bolt-action rifles (MAS-36, Lee–Enfield No4, M1903A3 Springfield, U.S. M1917, Berthier, and K98k) which had been absorbed into French service after the end of World War II. It saw significant service with French troops in the latter stages of the First Indochina War, as well as during the Algerian War and the Suez Crisis. The MAS-49 series had a reputation for reliability in conditions of poor maintenance, sometimes being cleaned with nothing more than rags and motor oil. The 49 and 49/56 series could also endure harsh service environments, seeing combat in Algeria, Djibouti, Indochina, French Guiana, and the Battle of Kolwezi.


title: MAS-49 rifle

text: An improved version called the MAS-49/56 was introduced in 1957 and incorporated lessons learned from service in Algeria, Indochina, and the Suez Crisis. The rifle was shortened and lightened to improve mobility for mechanized and airborne troops, and a knife bayonet was added. The MAS-49 built-in rifle grenade launcher was replaced by a combination compensator/rifle grenade launcher that fired NATO-standard 22mm rifle grenades. The rifle also incorporates an integral grenade launching sight that is attached to the front sight block and a gas cutoff that prevents gas from entering the gas tube from the gas port when firing grenade launching blank ammunition.


title: MAS-49 rifle

text: Attempts were made to replace the MAS-49, in the form of the MAS-54 and the FA-MAS Type 62, both 7.62×51mm NATO battle rifles, but neither were successful. The MAS-49/56 ended production in 1978 and was replaced with the 5.56×45mm NATO caliber FAMAS bullpup assault rifle. The MAS-49/56 was withdrawn from service in 1990. Whereas only 20,600 MAS-49 were manufactured, the MAS-49/56 was mass-produced, attaining a total of 275,240 rifles issued between 1957 and 1978.


title: MAS-49 rifle

text: The direct impingement gas system was first applied in 1901 to a 6mm semi-automatic experimental rifle (the ENT B-5) designed by Rossignol for the French military. Although several experimental prototypes using a tilting bolt and direct impingement had been tested by MAS since 1924, the immediate precursor to the MAS 7.5mm semi-automatic rifle series is the MAS-38/39. It was successfully tested in March 1939, just before World War II, and followed in May 1940 by the nearly identical MAS 1940. Similar direct impingement designs include the Swedish semi-automatic Ag m/42 adopted in 1942, and the US M16 select-fire rifle adopted in 1963. In the AG42B and MAS systems, gas is vented from a port on top of the barrel through a small diameter tube to a hollow located on the front face of the bolt carrier. The contained forces of the gases move the carrier to the rear against the operating spring pressure with enough momentum to open the bolt, and within a short distance the end of the tube is exposed vent to the atmosphere. The M16 system vents gas from the barrel through a tube and into the body of the bolt carrier where it expands. Rings on the bolt body form a seal and the expanding gases move the bolt carrier to the rear, which starts the bolt opening cycle. The spent gases then vent through now exposed holes in the side of the bolt carrier.


title: MAS-49 rifle

text: The MAS system has the advantage of not depositing gas fouling on the bolt itself, a separate part located underneath the bolt carrier. All the French MAS 7.5mm semi-automatic rifles mentioned herein feature a rear-locking tilting bolt, as on the M1895 Colt–Browning machine gun, the Browning Automatic Rifle (1918), the MAS-1924 to MAS-1928 experimental semi-auto rifles, and the Russian Simonov SVT-38 (1938) and SVT-40 (1940) rifles. The MAS direct impingement design reduced the number of bolt moving parts to only six: the bolt carrier, then the rear locking tilting bolt which carries the extractor, the ejector and the firing pin, and lastly the recoil spring. It takes only a few seconds to disassemble the entire bolt mechanism for cleaning.


title: MAS-49 rifle

text: The same 10-round detachable magazine fits the MAS-44, MAS-49 and MAS-49/56 rifles. The earlier MAS-40 (1940) rifle had a 5-round magazine within the receiver, as on the bolt action MAS-36 rifle. The rifle can still be fed by stripper clips, and have a stripper clip guide built into the bolt face. Lastly, the MAS-49 and MAS-49/56 are equipped with a rail on the left side of the receiver. It allows for the immediate installation of a "Modele 1953" APX L 806 (SOM) 3.85 power telescopic sight by sliding it into place and then locking it in with a small pressure lever. The MAS-49 and MAS-49/56 are capable of consistently hitting individual man-size targets up to 400 meters with the adjustable peep sight and up to 800 meters with the APX L 806 telescopic sight. The bore is counter sunk at the muzzle to protect the rifling and preserve accuracy. The barrel is freely floating.


title: MAS-49 rifle

text: Syria contracted with MAS for 6,000 MAS-49 rifles. These rifles, along with 12,000 MAS-36 rifles and a production facility for 7.5x54mm ammunition were delivered in the early 1950s. The MAS-49 was used until the mid-late 60s when they were replaced with AK-47 assault rifles. Syrian contract rifles differed from the French service model by having a spike bayonet identical to that of the MAS-36, as well as different stocks and metal parts to incorporate this change. These rifles are dated 1953 and features serial numbers in the F33.000 to F39.000 range.


title: MAS-49 rifle

text: Many MAS-49/56 rifles imported as surplus into the United States were rechambered locally by Century Arms International to fire the 7.62mm NATO round. However several user reports have noted that these particular conversions were often unsatisfactory (resulting in numerous action stoppages and misfires) due to imperfect workmanship. Furthermore, the shortening of the barrel to allow rechambering brings the gas vent closer to the chamber hence creating a higher stress on the bolt carrier. In addition to these Century Arms conversions, approximately 250 MAS-49/56 rifles were converted in France to 7.62×51mm NATO for use by the French National Police. These rifles are not known to have the reliability issues that plague the later Century Arms conversions. Some have been able to improve reliability by modifying the gas shutoff pin with a tapped set screw for gas adjustment.


title: MAS-49 rifle

text: Commercial 7.5×54mm "French" ammunition made in countries other than France for current distribution has been known to produce burst fire (2 or 3 rounds at a time) because of more sensitive primers. The original heavy steel firing pins on the MAS-49 and 49/56 can be replaced by commercial titanium firing pins which are much lighter and generally cure the problem of burst fire on these weapons. It is also possible to prevent these slamfires by shortening the firing pin by approximately 0.5 mm, or by modifying the bolt to accommodate a firing pin return spring.


title: MAS-49 rifle

text: Some users have been able to convert 20 round FN-FAL magazines to work in the .308 guns and 25 round FM 24/29 light machine gun or 35 round Reibel machine gun mags for the original 7.5x54 caliber.


title: 100 Greatest of All Time

text: 100 Greatest of All Time was a sports television series of five one-hour episodes, produced and first aired by the Tennis Channel in March 2012. It presented a list of 100 tennis players to be considered the greatest of all time, both men and women. The series was hosted by Jack Nicklaus, Jerry Rice, Wayne Gretzky, Lisa Leslie and Carl Lewis. Many retired tennis luminaries provided commentary, including Rod Laver, Billie Jean King, Chris Evert, Björn Borg, John McEnroe, Martina Navratilova, Pete Sampras, and Andre Agassi.


title: 100 Greatest of All Time

text: An international panel of tennis experts determined this ranking of 62 men and 38 women. The United States was credited with the most great players (38), followed by Australia (17), France (7), Great Britain (6) and Czechoslovakia (5). Forty-three players made the list from the Americas, 39 from Europe and 18 from Oceania.


title: 100 Greatest of All Time

text: Grand Slam singles titles (Australian, French, Wimbledon and US tournaments) column figures reflect number of wins as of March 2012 when the list was published. In addition to that, the pre-Open Era Pro major tournaments (three professional events) were included: the U.S. Pro Championships (first held in 1927), French Pro Championship (first held in 1930) and Wembley Championships (started in 1934). Only male tennis players that turned from amateurs to pros were able to participate in those. The Open Era started in 1968 and all three pro majors tournaments were quickly relegated to lesser events and were all defunct by the 1990s.


title: 100 Greatest of All Time

text: Prior to 1924, the International Lawn Tennis Federation (ILTF) recognized two other events as world championships. The "World Hard Court Championships" (WHCC) and the "World Covered Court Championships" (WCCC). Between 1913 and 1923 Wimbledon was known as the World Grass Court Championships (WGCC), also sanctioned by the ILTF.


title: 100 Greatest of All Time

text: In 1924 ILTF designated the Australasian, French, British and American championship tournaments as the new four majors. 1925 was the first season held with all these four major tournaments opened to all amateurs.


title: 100 Greatest of All Time

text: ‡ The Grand Slam, winning all four Grand Slam tournament singles titles (Australian, French, Wimbledon and US) in one calendar year was achieved six times by five different players: Don Budge in 1938, Maureen Connolly in 1953, Rod Laver in 1962 & 1969, Margaret Court in 1970 and Steffi Graf in 1988.


title: 100 Greatest of All Time

text: ◊ The Pro Grand Slam, winning all three professional slam singles titles (U.S., French and Wembley) in one calendar year was achieved by Ken Rosewall in 1963 and by Rod Laver in 1967.


title: 100 Greatest of All Time

text: † Anthony Wilding is the only Triple World Champion. In 1913, he won all three ILTF singles titles, the World Covered Court Championships (WCCC), the World Hard Court Championships (WHCC) and Wimbledon Championships (also known as World Grass Court Championships or simply WGCC).


title: Ecclesiastical polity

text: Ecclesiastical polity is the operational and governance structure of a church or of a Christian denomination. It also denotes the ministerial structure of a church and the authority relationships between churches. Polity relates closely to ecclesiology, the study of doctrine and theology relating to church organization.


title: Ecclesiastical polity

text: "Ecclesiastical polity" is defined as both the subject of ecclesiastical government in the abstract and the particular system of government of a specific Christian organization. The phrase is sometimes used in civil law.


title: Ecclesiastical polity

text: Questions of ecclesiastical government are first documented in the first chapters of the "Acts of the Apostles" and "theological debate about the nature, location, and exercise of authority, in the church" has been ongoing ever since. The first act recorded after the Ascension of Jesus Christ was the election of Saint Matthias as one of the Twelve Apostles, to replace Judas Iscariot. The Twelve Apostles were the first to instantiate the episcopal polity of Christianity.


title: Ecclesiastical polity

text: During the Protestant Reformation, reformers asserted that the New Testament prescribed an ecclesiastical government different from the episcopal polity maintained by the Catholic Church, and consequently different Protestant bodies organized into different types of polities. During this period Richard Hooker wrote "Of the Laws of Ecclesiastical Polity", the first volumes of which were published in 1594, to defend the polity of the Church of England against Puritan objections. It is from the title of this work that the term "ecclesiastical polity" may have originated. With respect to ecclesiology, Hooker preferred the term "polity" to "government" as the former term "containeth both [the] government and also whatsoever besides belongeth to the ordering of the Church in public."


title: Ecclesiastical polity

text: Though each church or denomination has its own characteristic structure, there are four general types of polity: episcopal, connexional, presbyterian, and congregational.


title: Ecclesiastical polity

text: Churches having episcopal polity are governed by bishops. The title bishop comes from the Greek word , which translates as "overseer". In regard to Catholicism, bishops have authority over the diocese, which is both sacramental and political; as well as performing ordinations, confirmations, and consecrations, the bishop supervises the clergy of the diocese and represents the diocese both secularly and in the hierarchy of church governance.


title: Ecclesiastical polity

text: Bishops in this system may be subject to higher ranking bishops (variously called archbishops, metropolitan or patriarchs, depending upon the tradition; "see also Bishop for further explanation of the varieties of bishops".) They also meet in councils or synods. These synods, subject to presidency by higher ranking bishops, may govern the dioceses which are represented in the council, though the synod may also be purely advisory.


title: Ecclesiastical polity

text: Also, episcopal polity is not usually a simple chain of command. Instead, some authority may be held, not only by synods and colleges of bishops, but by lay and clerical councils. Further, patterns of authority are subject to a wide variety of historical rights and honours which may cut across simple lines of authority.


title: Ecclesiastical polity

text: Episcopal polity is the predominant pattern in Catholic, Eastern Orthodox, Oriental Orthodox, and Anglican churches. It is also common in some Methodist and Lutheran churches, as well as amongst some of the African-American Pentecostal traditions in the United States such as the Church of God in Christ and the Full Gospel Baptist Church Fellowship.


title: Ecclesiastical polity

text: Some religious organizations, for example Seventh-day Adventist, Jehovah's Witnesses, The Salvation Army, and the Church of Jesus Christ of Latter-day Saints, describe their polity as "hierarchical". In practice, such polities are similar to an episcopal polity, but often have a much more complex system of governance, with several dimensions of hierarchy. Leaders are not called "bishops", and in some cases have secular-like titles such as "president" or "overseer". The term "bishop" may be used to describe functionaries in minor leadership roles, such as a leader of an individual congregation; it may also be used as an honorific, particularly within the Holiness movement.


title: Ecclesiastical polity

text: Many Methodist churches use a derivative of episcopal polity known as connexionalism, or connexional polity. It emphasises essential interdependence, through fellowship, consultation, government and oversight. The traditional United Methodist Church defines "connection" as the principle that "all leaders and congregations are connected in a network of loyalties and commitments that support, yet supersede, local concerns." Some Methodist churches have bishops, but those individuals are not nearly as powerful as in episcopal churches.


title: Ecclesiastical polity

text: Many Reformed churches, notably those in the Presbyterian traditions, are governed by a hierarchy of (or "courts"). The lowest level council governs a single local church and is called the "session" or "consistory"; its members are called "elders". The minister of the church (sometimes referred to as a "teaching elder") is a member of and presides over the session; lay representatives ("ruling elders" or, informally, just elders) are elected by the congregation. The session sends representatives to the next level higher council, called the "presbytery" or "classis". In some Presbyterian churches there are higher level councils (synods or general assemblies). Each council has authority over its constituents, and the representatives at each level are expected to use their own judgment. For example, each session approves and installs its own elders, and each presbytery approves the ministers serving within its territory and the connections between those ministers and particular congregations. Hence higher level councils act as courts of appeal for church trials and disputes, and it is not uncommon to see rulings and decisions overturned.


title: Ecclesiastical polity

text: Presbyterian polity is the characteristic governance of Presbyterian churches, and also of churches in the Continental Reformed tradition. Elements of presbyterian polity are also found in other churches. For example, in the Episcopal Church in the United States of America, governance by bishops is paralleled by a system of deputies, who are lay and clerical representatives elected by parishes and, at the national level, by the dioceses. Legislation in the general convention requires the separate consent of the bishops and of the deputies.


title: Ecclesiastical polity

text: Congregational churches dispense with titled positions such as bishop as a requirement of church structure. The local congregation rules itself, elects its own leaders, both clergy and laity, ordains its own clergy, and as a "self-governed voluntary institution", is a type of religious anarchism. Appointment of local leaders and councils by external authorities derives from a separate bureaucratic or associational polity.


title: Ecclesiastical polity

text: Members may be sent from the congregation to associations that are sometimes identified with the church bodies formed by Presbyterians, Lutherans, Anglicans, and other non-congregational Protestants. Neither the congregations nor the associations exercise any control over each other, other than having the ability to terminate membership in the association. Many congregationalist churches are completely independent in principle. One major exception is ordination of clergy, where even congregationalist churches often invite members of the vicinage or association to ordain their pastors.


title: Ecclesiastical polity

text: It is a principle of congregationalism that ministers do not govern congregations by themselves. They may preside over the congregation, but it is the congregation which exerts its authority in the end.


title: Ecclesiastical polity

text: Churches that traditionally practice congregational polity include congregationalists, Baptists, and many forms of nondenominational Christianity. Because of its prevalence among Baptists, and the prominence of Baptists among Protestant denominations, congregational polity is sometimes called "Baptist polity".


title: Ecclesiastical polity

text: Although a church's polity determines its ministers and discipline, it need not affect relations with other Christian organizations. The unity of a church is an essential doctrine of ecclesiology, but because the divisions between churches presuppose the absence of mutual authority, internal polity does not directly answer how these divisions are treated.


title: Ecclesiastical polity

text: "Plurality" refers to systems of ecclesiastical polity wherein the local church's decisions are made by a committee, typically called elders. The system is in contrast to the "singularity" of episcopal polity systems as used in Roman Catholic, Eastern Orthodox, and Anglican churches, or the pastor/president system of some Protestant churches.


title: Ecclesiastical polity

text: Plurality of elders is commonly encouraged, with variation of practice, among Presbyterians, some Pentecostal churches, and Churches of Christ, the Disciples of Christ and the Plymouth Brethren (who employ congregational polity). The practice claims biblical precedent, acknowledging that churches in the time of the New Testament appear to all have had multiple elders.


title: Ecclesiastical polity

text: In the Church of England, two or more otherwise independent benefices may be 'held in "plurality"' by a single priest.


title: Indians in the United Arab Emirates

text: Indians in the United Arab Emirates ) constitute the largest part of the population of the country. Over 3,420,000 Indian expats are estimated to be living in the UAE, which is over 38 percent of the total population of the UAE.<ref name="Emirates24/7">Profile - Embassy of India, Abu Dhabi UAE</ref> Indian contact with the emirates that now constitute the UAE dates back several centuries, as a result of trade and commerce between the emirates and India. The UAE has experienced a tremendous increase in the population of resident Indians who initially migrated to the country as a result of opportunities in petroleum. Now, Indians are key to the UAE's construction, retail, financial services, healthcare, manufacturing and transport sectors.


title: Indians in the United Arab Emirates

text: A sizeable minority of Indian migrants are involved in professional services and entrepreneurship. Relations between India and the UAE have traditionally been friendly.


title: Indians in the United Arab Emirates

text: Countries in the Persian Gulf region have had a long-established economic and political link with India. Trucial Oman (now UAE), was nominally independent in the 19th century but was administered by the British Raj; trade and banking sectors in the territory were administered by the Khoja and Kutchi communities of India. In 1853, the rulers of the emirates signed a Perpetual Maritime Truce with the British, effectively bringing the region under Britain's sphere of influence. Administered from British India, the emirates developed commonalities with South Asia. Indian Rupees were used as currency, as were Indian stamps (overlaid with the name of the emirate) for postal correspondence. A fairly homogeneous society at the turn of the 20th century, the region that now comprises the UAE experienced an economic boom as a result of the pearling industry; the few Indian traders emigrating to the emirates moved to the coastal towns and remained on the fringes of Emirati society. Dubai had traditionally served as an "entrepôt" for trade between the Middle East and the Indian subcontinent and was dominated by Hindu merchants in both gold and textile trade. Dubai was also an important trading post for Indians prior to the discovery of oil (in commercial quantities) in the UAE in 1959; the emirate had been at the centre of a smuggling route of gold via small boats to India, where the importation of gold was illegal.


title: Indians in the United Arab Emirates

text: Businesses in the largest sheikhdoms in the UAE, Dubai and Abu Dhabi continued to use the Indian Rupee even after India's independence in 1947. But its popularity strained India's foreign reserves, and so in 1959 the Indian government created the Gulf rupee, initially at par with the Indian rupee. It was introduced as a replacement for the Indian rupee for circulation exclusively outside the country, which included apart from the states making up the UAE, the nations of Kuwait, Qatar, Oman and Bahrain.


title: Indians in the United Arab Emirates

text: On 6 June 1966, India devalued the Gulf rupee against the Indian rupee. Following the devaluation, several of the states still using the Gulf rupee adopted their own currencies.


title: Indians in the United Arab Emirates

text: The discovery of oil brought with it an influx of workers from India from the mid-1960s onward. Many came via sea, a trip of about three days from Bombay (now Mumbai) to Dubai. Most of the shopkeepers were from the state of Kerala, or were Indian Arabs, descendants of Arabs who had previously emigrated to India. It was also in the late 1960s that the Hindu Temple and first Indian schools were built for expatriate Indian families. Indian migration to the UAE drastically increased in the 1970s and 1980s, with the expansion of the oil industry and the growth of free trade in Dubai. Annual migration of Indians to the UAE, which stood at 4,600 in 1975, rose to over 125,000 by 1985, and stood at nearly 200,000 in 1999.


title: Indians in the United Arab Emirates

text: In the 3.4 million migrants, 1 million are from Kerala and 450,000 from Tamil Nadu, form the majority in Indian community living in UAE. By 1999, the population of Indian migrants in the UAE, which stood at 170,000 in 1975, was at 750,000. The estimated population of Indians in the UAE as of 2009 is near 2 million. Indians constitute 42% of the total UAE population. There is no pathway to naturalisation and citizenship (yet). A vast majority of Indian migrants are on employment based visas, while others are on business or trade visas. Some are also sponsored by their spouse or parents.


title: Indians in the United Arab Emirates

text: In addition, over 300,000 undocumented migrants, many of whom are Indian, are said to be living in the UAE. Undocumented migrants, if caught, are jailed and then deported to their home countries. A federal law enacted in 1996 in the U.A.E imposed sanctions against undocumented migrants and their employers. The UAE government offers amnesty programs where foreign undocumented workers can voluntarily leave the country without facing imprisonment or having to pay fines. One such three month amnesty program in 2007 benefited 110,000 illegal Indian migrants, all of whom were either legally reabsorbed into the UAE workforce or were allowed to return to India without sanctions or imprisonment.


title: Indians in the United Arab Emirates

text: There is also a sizable population of second or third generation U.A.E-born Indians. They share characteristics with other third culture kids, forming a cultural identity that blends their heritage culture and the myriad of foreign cultures they encounter growing up in the U.A.E, and a more fluid sense of home. Those who grow up in western compounds tend to be well-assimilated into western culture, whereas those who stay in Indian neighborhoods tend to be more in touch with India. Many U.A.E-born Indians further migrate to countries such as the United States, Canada, Australia and New Zealand both for greater economic and lifestyle opportunities, and due to the U.A.E's restrictive citizenship practices; many are forced to leave when no longer deemed valuable by the government, and citizenship is only given to descendants of local Emiratis.


title: Indians in the United Arab Emirates

text: However, in 2020, the COVID-19 pandemic plunged many economies, including the UAE, into a recession. As of September 2020, more than 600,000 Indians applied to be repatriated amid the coronavirus outbreak, of which 400,000 left the country since repatriation flights began in May.


title: Indians in the United Arab Emirates

text: Foreigners comprise 99% of the UAE's labour force, of which Indians are a part. Some of these foreigners have lived in the country for generations. Around 40% of Indians in the UAE are white collar professionals. In addition to employment-based migrants from India, many Indian entrepreneurs in the UAE have established successful national franchises, the notable ones such as Lulu Group International, Landmark Group, Jashanmal, Ajmal Perfumes, Amber Packaging Industries, Jumbo Electronics, Choithram's, Varkey Group, Alukkas and New Medical Centre.


title: Indians in the United Arab Emirates

text: The Dubai-based Indian billionaires include Micky Jagtiani of the Landmark Group, Yusuff Ali M.A. of Lulu Group International, Ravi Pillai of the Ravi Pillai Group, the Chhabria family of the Jumbo Group, Sunny Varkey of GEMS Education, Tony Jashanmal of the Jashanmal Group and Joy Alukkas of Joyalukkas Jewellery.


title: Indians in the United Arab Emirates

text: Rizwan Sajan of Danube Group, Azad Moopen of Aster DM Healthcare, Ramesh S Ramakrishnan of the Transworld Group, and Shamsheer Vayalil of VPS Health Care are also on the list of Indian millionaires living in Dubai.


title: Indians in the United Arab Emirates

text: The Gulf Medical University founded by Thumbay Moideen is an Indian contribution to the Higher Education scenario in the UAE. Today students from over 68 countries study in their campus in Ajman and the university is well known in the medical education circles.


title: Indians in the United Arab Emirates

text: Adnan Chilwan, Group CEO of Dubai Islamic Bank, and Kamal Puri, Founder President of Skyline University, an influencer in the UAE Education Ecosystem, are also some of the few well known Indians in the UAE.


title: Indians in the United Arab Emirates

text: By 1996, at least 150 Indian companies were operating in the Jebel Ali Free Zone Area (JAFZA), and even today, more than 50% of the work force are Indian, in one of the most successful and model Free Trade Zones of the world. Over 25% of Indian workers in the UAE were engaged in manufacturing, transport and related professions, while 20% were engaged in professional and technical fields. The 2005 Merrill Lynch report estimated that there were approximately 33,000 Indian millionaires living in the UAE. Indian expats typically save most of their earnings through employment benefits on accommodation and transport, and income tax free provisions of the UAE. As a result, a majority of the money is remitted for the maintenance of migrants' households in India. In 2005, an estimated US billion was remitted, about half of which was sent through informal "hawala" channels. About 70% of all remittances from the UAE (or US billion) was sent to India.


title: Indians in the United Arab Emirates

text: A small number of Indian migrants have been involved in criminal activities in the Middle East, including smuggling, trade in narcotics, extortions and other activities. Dubai, in particular has been associated with the smuggling of gold and precious metals. Dawood Ibrahim, head of the organised crime syndicate D-Company, is estimated to have smuggled 20 to 30 tonnes of gold to India.


title: Indians in the United Arab Emirates

text: India and the UAE (United Arab Emirates) have generally enjoyed cordial relations, partly due to their shared history with the British presence in Asia, and partly due to the pre-colonial history of trade, commerce and settlement between the nations. In 1999, the UAE government secured the release of 25 civilian passengers aboard Indian Airlines flight IC-814 that had been hijacked and forced to land in Dubai "en route" to New Delhi from Kathmandu, Nepal. However, several incidents, mainly concerning India's expatriate workforce in the UAE, have caused friction in Indo-Emirati relations.


title: Indians in the United Arab Emirates

text: The large segment of Indian migrants, along with comparatively lenient laws in the UAE have allowed Indian communities to more or less practice their native cultures in the country. Middle class Indians in the UAE have established a network of cultural associations which cater to their needs. Cultural associations such as the India Club, Indian Association, Goan Cultural Society and numerous Keralite associations support cultural networks of the Indian sub-communities in the UAE. Additionally, schools such as the Abu Dhabi Indian School and The Indian High School, Dubai provide Indian curricular education to expatriate students. Dubai is the only emirate in the UAE with a Hindu temple and Sikh Gurudwara. In August 2015, in the backdrop of Prime Minister Narendra Modi's visit of the country, the UAE government decided to allot land for the construction of a temple in Abu Dhabi. Dubai and Sharjah are the only emirates with operating cremation facilities in the Emirates. Official permission must be obtained for their use in every instance. Churches exist in Abu Dhabi, Dubai, Sharjah and Ras Al-Khaimah. In 1998, the government of Dubai donated land for the construction of a facility to be shared by five congregations, four Protestant and one Catholic.


title: Indians in the United Arab Emirates

text: Restaurants serving Indian food are very popular and widely available in the Emirates. Many of the hotels in Dubai and Abu Dhabi have Indian restaurants that serve "Mughlai" or "Tandoor" cuisine, while vegetarian South Indian are available and popular in the larger cities of the UAE.


title: Indians in the United Arab Emirates

text: India-Pakistan cricket matches are widely followed by the Indian diaspora in the UAE. The Sharjah Cricket Association Stadium, established by Abdul Rahman Bukhatir, hosted several India & Pakistan matches and triangular tournaments through the 1980s and 1990s, which attracted Indian and Pakistani cricket spectators from the UAE as well as from India and Pakistan. More recently, the state-of-the-art Sheikh Zayed Cricket Stadium in Abu Dhabi has hosted bilateral and triangular cricket tournaments featuring India and Pakistan. 2014 also marked the official entry of the Indian Premier League (IPL) into UAE with matches held in Abu Dhabi, Dubai & Sharjah.


title: Indians in the United Arab Emirates

text: Bollywood, Tollywood (Telugu), Malayalam cinema and Kollywood are popular among Indian expatriates and are shown in most major theatres in the Emirates' main cities. Award ceremonies such as the International Indian Film Academy Awards, South Indian International Movie Awards, Asianet Film Awards, Filmfare Awards South as well as Filmfare Awards have previously been held in Dubai; the city is also a popular destination for filming Indian films.


title: Habeas corpus in the United States

text: In United States law, habeas corpus () is a recourse challenging the reasons or conditions of a person's confinement under color of law. A petition for "habeas corpus" is filed with a court that has jurisdiction over the custodian, and if granted, a writ is issued directing the custodian to bring the confined person before the court for examination into those reasons or conditions. The Suspension Clause of the United States Constitution specifically included the English common law procedure in Article One, Section 9, clause 2, which demands that "The privilege of the writ of "habeas corpus" shall not be suspended, unless when in cases of rebellion or invasion the public safety may require it."


title: Habeas corpus in the United States

text: United States law affords persons the right to petition the federal courts for a writ of "habeas corpus". Individual states also afford persons the ability to petition their own state court systems for "habeas corpus" pursuant to their respective constitutions and laws when held or sentenced by state authorities.


title: Habeas corpus in the United States

text: Federal "habeas" review did not extend to those in state custody until almost a century after the nation's founding. During the Civil War and Reconstruction, as later during the War on Terrorism, the right to petition for a writ of "habeas corpus" was substantially curtailed for persons accused of engaging in certain conduct. In reaction to the former, and to ensure state courts enforced federal law, a Reconstruction Act for the first time extended the right of federal court "habeas" review to those in the custody of state courts (prisons and jails), expanding the writ essentially to all imprisoned on American soil. The federal "habeas" statute that resulted, with substantial amendments, is now at 28 U.S.C. § 2241. For many decades, the great majority of habeas petitions reviewed in federal court have been filed by those confined in state prisons by sentence of a state court for state crimes (e.g., murder, rape, robbery, etc.), since in the American system, most crimes have historically been a matter of state law.


title: Habeas corpus in the United States

text: The right of "habeas corpus" is not a right against unlawful arrest, but rather a right to be released from imprisonment after such arrest. If one believes the arrest is without legal merit and subsequently refuses to come willingly, he still may be guilty of resisting arrest, which can sometimes be a crime in and of itself (even if the initial arrest itself was illegal) depending on the state.


title: Habeas corpus in the United States

text: Habeas corpus derives from the English common law where the first recorded usage was in 1305, in the reign of King Edward I of England. The procedure for the issuing of writs of "habeas corpus" was first codified by the Habeas Corpus Act 1679, following judicial rulings which had restricted the effectiveness of the writ. A previous act had been passed in 1640 to overturn a ruling that the command of the Queen was a sufficient answer to a petition of "habeas corpus". Winston Churchill, in his chapter on the English Common Law in "The Birth of Britain", explains the process thus:


title: Habeas corpus in the United States

text: The writ of "habeas corpus" was issued by a superior court in the name of the Monarch, and commanded the addressee (a lower court, sheriff, or private subject) to produce the prisoner before the Royal courts of law. Petitions for "habeas corpus" could be made by the prisoner himself or by a third party on his behalf, and as a result of the Habeas Corpus Acts could be made regardless of whether the court was in session, by presenting the petition to a judge.


title: Habeas corpus in the United States

text: The 1679 Act remains important in 21st century cases. This Act and the historical body of British practice that relies upon it has been used to interpret the "habeas" rights granted by the United States Constitution, while taking into account the understanding of the writ held by the framers of the Constitution.


title: Habeas corpus in the United States

text: At the 1787 Constitutional Convention Habeas Corpus was first introduced with a series of propositions on August 20 by Charles Pinckney, a delegate from South Carolina. Habeas Corpus was discussed and voted on substantively on August 28, 1787, where the first vote of the motion in favor of Habeas Corpus passed unanimously, and the second part passed by a vote of 7 to 3, for making Habeas Corpus Constitutionally-recognized.


title: Habeas corpus in the United States

text: The Suspension Clause of Article One does not "expressly" establish a right to the writ of "habeas corpus"; rather, it prevents Congress from restricting it. There has been much scholarly debate over whether the Clause positively establishes a right under the federal constitution, merely exists to prevent Congress from prohibiting state courts from granting the writ, or protects a pre-existing common law right enforceable by federal judges. However, in the cases of "Immigration and Naturalization Service v. St. Cyr" (2001), and "Boumediene v. Bush" (2008) the U.S. Supreme Court suggested that the Suspension Clause protects "the writ as it existed in 1789", that is, as a writ which federal judges could issue in the exercise of their common law authority.


title: Habeas corpus in the United States

text: Regardless of whether the writ is positively guaranteed by the constitution, "habeas corpus" was first established by statute in the Judiciary Act of 1789. This statutory writ applied only to those held in custody by officials of the executive branch of the federal government and not to those held by state governments, which independently afford "habeas corpus" pursuant to their respective constitutions and laws. From 1789 until 1866, the federal writ of "habeas corpus" was largely restricted to prisoners in federal custody, at a time when no direct appeals from federal criminal convictions were provided for by law. "Habeas corpus" remained the only means for judicial review of federal capital convictions until 1889, and the only means for review of federal convictions for other "infamous crimes" until 1891. Until 1983 the writ of "habeas corpus" remained the only way that decisions of military courts could be reviewed by the Supreme Court.


title: Habeas corpus in the United States

text: The authority of federal courts to review the claims of prisoners in state custody was not clearly established until Congress adopted a statute (28 U.S.C. § 2254) granting federal courts that authority in 1867, as part of the post-Civil War Reconstruction. The U.S. Supreme Court in the case of "Waley v. Johnson" (1942) interpreted this authority broadly to allow the writ to be used to challenge convictions or sentences in violation of a defendant's constitutional rights where no other remedy was available.


title: Habeas corpus in the United States

text: The U.S. Congress grants federal district courts, the Supreme Court, and all Article III federal judges, acting in their own right, jurisdiction under 28 U.S.C. § 2241 to issue writs of "habeas corpus" to release prisoners held by any government entity within the country from custody, subject to certain limitations, if the prisoner


title: Habeas corpus in the United States

text: In 1950s and 1960s, decisions by the Warren Court greatly expanded the use and scope of the federal writ largely due to the "constitutionalizing" of criminal procedure by applying the Bill of Rights, in part, to state courts using the incorporation doctrine. This afforded state prisoners many more opportunities to claim that their convictions were unconstitutional, which provided grounds for habeas corpus relief. In the last thirty years, decisions by the Burger and Rehnquist Courts have somewhat narrowed the writ.


title: Habeas corpus in the United States

text: The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) further limited the use of the federal writ by imposing a one-year statute of limitations and dramatically increasing the federal judiciary's deference to decisions previously made in state court proceedings either on appeal or in a state court habeas corpus action. One of AEDPA's most controversial changes is the requirement that any constitutional right invoked to vacate a state court conviction rooted in a mistake of law by the state court must have "resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, "as determined by the Supreme Court of the United States"" (emphasis added). Thus, a U.S. Court of Appeals must ignore its own precedents and affirm a state court decision contrary to its precedents, if the U.S. Supreme Court has never squarely addressed a particular issue of federal law.


title: Habeas corpus in the United States

text: On April 27, 1861, the right of "habeas corpus" was unilaterally suspended by President Abraham Lincoln in Maryland during the American Civil War. Lincoln had received word that anti-war Maryland officials intended to destroy the railroad tracks between Annapolis and Philadelphia, which was a vital supply line for the army preparing to fight the South. Indeed, soon after, the Maryland legislature would simultaneously vote to stay in the Union and to close these rail lines, in an apparent effort to prevent war between its northern and southern neighbors. Lincoln did not issue a sweeping order; it only applied to the Maryland route. Lincoln chose to suspend the writ over a proposal to bombard Baltimore, favored by his General-in-Chief Winfield Scott. Lincoln was also motivated by requests by generals to set up military courts to rein in his political opponents, "Copperheads", or Peace Democrats, so named because they did not want to resort to war to force the southern states back into the Union, as well as to intimidate those in the Union who supported the Confederate cause. Congress was not yet in session to consider a suspension of the writs; however, when it came into session it failed to pass a bill favored by Lincoln to sanction his suspensions. During this period one sitting U.S. Congressman from the opposing party, as well as the mayor, police chief, entire Board of Police, and the city council of Baltimore were arrested without charge and imprisoned indefinitely without trial.


title: Habeas corpus in the United States

text: Lincoln's action was rapidly challenged in court and overturned by the U.S. Circuit Court of Appeals in Maryland (led by the Chief Justice of the Supreme Court, Roger B. Taney) in "Ex parte Merryman". Chief Justice Taney ruled the suspension unconstitutional, stating that only Congress could suspend habeas corpus. Lincoln and his Attorney General Edward Bates not only ignored the Chief Justice's order, but when Lincoln's dismissal of the ruling was criticized in an editorial by prominent Baltimore newspaper editor Frank Key Howard, they had the editor also arrested by federal troops without charge or trial. The troops imprisoned Howard, who was Francis Scott Key's grandson, in Fort McHenry, which, as he noted, was the same fort where the Star Spangled Banner had been waving "o'er the land of the free" in his grandfather's song. In 1863, Howard wrote about his experience as a "political prisoner" at Fort McHenry in the book "Fourteen Months in the American Bastille"; two of the publishers selling the book were then arrested.


title: Habeas corpus in the United States

text: When Congress convened in July 1861 it failed to support Lincoln's unilateral suspension of habeas corpus. A joint resolution was introduced into the Senate to approve of the president's suspension of the writ of habeas corpus, but filibustering by Senate Democrats, who did not support it, and opposition to its imprecise wording by Senator Lyman Trumbull prevented a vote on the resolution before the end of the first session, and the resolution was not taken up again. Trumbull himself introduced a bill to suspend habeas corpus, but failed on getting a vote before the end of the first session.


title: Habeas corpus in the United States

text: Shortly thereafter, on September 17, 1861, the day the Maryland legislature was to reconvene, Lincoln imprisoned pro-Confederate members of the Maryland General Assembly without charges or hearings in further defiance of the Chief Justice's ruling. Thus, the legislative session had to be cancelled.


title: Habeas corpus in the United States

text: On February 14, 1862, the war was firmly in progress and Lincoln ordered most prisoners released, putting an end to court challenges for the time being. He again suspended habeas corpus on his own authority in September that same year, however, in response to resistance to his calling up of the militia.


title: Habeas corpus in the United States

text: When Congress met again in December 1862, the House of Representatives passed a bill indemnifying the president for his suspension of habeas corpus. The Senate amended the bill, and the compromise reported out of the conference committee altered it to remove the indemnity and to suspend habeas corpus on Congress's own authority. That bill, the Habeas Corpus Suspension Act, was signed into law March 3, 1863. Lincoln exercised his powers under it in September, suspending habeas corpus throughout the Union in any case involving prisoners of war, spies, traitors, or military personnel. The suspension of habeas corpus remained in effect until Andrew Johnson revoked it on December 1, 1865.


title: Habeas corpus in the United States

text: General Ambrose E. Burnside had former-Congressman Clement Vallandigham arrested in May 1863 for continuing to express sympathy for the Confederate cause after having been warned to cease doing so. Vallandigham was tried by a military tribunal and sentenced to two years in a military prison. Lincoln quickly commuted his sentence to banishment to the Confederacy. Vallandigham appealed his sentence, arguing that the Enrollment Act did not authorize his trial by a military tribunal rather than in ordinary civilian courts, that he was not ordinarily subject to court martial, and that Gen. Burnside could not expand the jurisdiction of military courts on his own authority. The Supreme Court did not address the substance of Vallandigham's appeal, instead denying that it possessed the jurisdiction to review the proceedings of military tribunals without explicit congressional authorization.


title: Habeas corpus in the United States

text: In 1864, Lambdin P. Milligan and four others were accused of planning to steal Union weapons and invade Union prisoner-of-war camps and were sentenced to hang by a military court. However, their execution was not set until May 1865, so they were able to argue the case after the war ended. In "Ex parte Milligan" (1866), the U.S. Supreme Court decided that Congress's 1863 suspension of the writ did not empower the President to try to convict citizens before military tribunals where the civil courts were open and operational. This was one of the key Supreme Court Cases of the American Civil War that dealt with wartime civil liberties and martial law.


title: Habeas corpus in the United States

text: In the Confederacy, Jefferson Davis also suspended "habeas corpus" and imposed martial law. Shortly after his inauguration as president of the Confederacy, an act of the Confederate Congress of February 27, 1862, was passed authorizing Davis to suspend the writ of habeas corpus and declare martial law "in such towns, cities, and military districts as shall, in his judgment, be in such danger of attack by the enemy". The Confederate Congress passed a limiting act two months to restrict the suspension of the writ "to arrests made by the authorities of the Confederate Government, or for offences against the same" and to add a sunset clause providing that authorization to suspend habeas corpus would expire 30 days after the next meeting of Congress.


title: Habeas corpus in the United States

text: In various proclamations and orders beginning in 1862, Davis suspended the writ and declared martial law in parts of Virginia (including the Confederate capital of Richmond, Norfolk, Portsmouth, Petersburg, and elsewhere). Davis also suspended the writ in East Tennessee; in this region, Thomas A.R. Nelson was arrested by the Confederate military and held as a political prisoner before being released on the condition that he cease criticizing the Confederate government. Suspensions of civil process in the confederacy were used against suspected Unionists, particularly in border states. Historian Barton A. Myers notes that after the Confederacy imposed nationwide conscription, "the difference between arrest for political dissidence and conscription into the military became largely semantic, as anyone accused of Unionism was almost always first taken to a training camp where they were monitored and hazed under guard."


title: Habeas corpus in the United States

text: Davis also suspended the writ in North Carolina (June 1862) and in Atlanta (in September 1862). The Confederate Congress passed re-authorizing legislation twice more, in October 1862 and February 1864. Davis suspended habeas corpus in Arkansas and the Indian Territory in January 1863. Although Davis had initially been resistant to the idea, he suspended the writ after receiving a telegram from General Theophilus Holmes complaining that his region was filed with disloyal persons and deserters, and that he could not enforce conscription.


title: Habeas corpus in the United States

text: At least 2,672 civilians were subject to military arrest in the Confederacy over the course of its history, although this is likely an undercount given the incompleteness of records. Civil War historian Mark E. Neely Jr. suggests that "there seems to be no difference in the arrest rate in those periods when the Confederate Congress refuse to authorization suspension of the writ of habeas corpus and those periods was authorized. ... civilian prisoners trickled into Confederate military prisons whether the writ of habeas corpus was suspended or not."


title: Habeas corpus in the United States

text: The last suspension lapsed in August 1864, amid deep domestic opposition to the suspension, including from the Confederate vice president Alexander H. Stephens, Davis's political rival. Citing "discontent, disaffection, and disloyalty", Davis made entreaties in late 1864 and 1865 about the necessity of suspension, but bills to further suspend habeas corpus failed in the Confederate Senate.


title: Habeas corpus in the United States

text: Following the end of the Civil War, numerous groups arose in the South to oppose Reconstruction, including the Ku Klux Klan. In response, Congress passed the Enforcement Acts in 1870–71. One of these, the Civil Rights Act of 1871, permitted the president to suspend habeas corpus if conspiracies against federal authority were so violent that they could not be checked by ordinary means. That same year, President Ulysses S. Grant suspended the writ of habeas corpus in nine South Carolina counties; the Act's sunset clause ended that suspension with the close of the next regular session of Congress.


title: Habeas corpus in the United States

text: In response to continuing unrest, the Philippine Commission availed itself of an option in the Philippine Organic Act of 1902, , and on January 31, 1905, requested that Governor-General Luke Edward Wright suspend the writ of habeas corpus. He did so the same day, and habeas corpus was suspended until he revoked his proclamation on October 15, 1905. The suspension gave rise to the United States Supreme Court case "Fisher v. Baker", .


title: Habeas corpus in the United States

text: Immediately following the attack on Pearl Harbor, the governor of Hawaii Territory, Joseph Poindexter, at the specific request by Lieutenant General Walter Short, US Army, invoked the Hawaiian Organic Act, (1900), suspended habeas corpus, and declared martial law. Short was recalled to Washington, D.C. two weeks after the attack and subsequently Hawaii was governed by US Army Lieutenant Generals Delos Emmons and Robert C. Richardson Jr. for the remainder of the war. In "Duncan v. Kahanamoku", , the United States Supreme Court held that the declaration of martial law did not permit the trial of civilians in military tribunals for offenses unrelated to the military (in this case, public drunkenness).


title: Habeas corpus in the United States

text: In 1942, eight German saboteurs, including two U.S. citizens, who had secretly entered the United States to attack its civil infrastructure as part of Operation Pastorius, were convicted by a secret military tribunal set up by President Franklin D. Roosevelt. In "Ex parte Quirin" (1942), the U.S. Supreme Court decided that the writ of "habeas corpus" did not apply, and that the military tribunal had jurisdiction to try the saboteurs, due to their status as unlawful combatants.


title: Habeas corpus in the United States

text: The period of martial law in Hawaii ended in October 1944. It was held in "Duncan v. Kahanamoku" (1946) that, although the initial imposition of martial law in December 1941 may have been lawful, due to the Pearl Harbor attack and threat of imminent invasion, by 1944 the imminent threat had receded and civilian courts could again function in Hawaii. The Organic Act therefore did not authorize the military to continue to keep civilian courts closed.


title: Habeas corpus in the United States

text: After the end of the war, several German prisoners held in American-occupied Germany petitioned the District Court for the District of Columbia for a writ of "habeas corpus". In "Johnson v. Eisentrager" (1950), the U.S. Supreme Court decided that the American court system had no jurisdiction over German war criminals who had been captured in Germany, and had never entered U.S. soil.


title: Habeas corpus in the United States

text: In 1996, following the Oklahoma City bombing, Congress passed (91–8 in the Senate, 293–133 in the House) and President Clinton signed into law the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The AEDPA was intended to "deter terrorism, provide justice for victims, provide for an effective death penalty, and for other purposes." The AEDPA introduced one of the few limitations on "habeas corpus". For the first time, its Section 101 set a statute of limitations of one year following conviction for prisoners to seek the writ. The Act limits the power of federal judges to grant relief unless the state court's adjudication of the claim has resulted in a decision that


title: Habeas corpus in the United States

text: It barred second or successive petitions generally but with several exceptions. Petitioners who had already filed a federal "habeas" petition were required first to secure authorization from the appropriate United States Court of Appeals, to ensure that such an exception was at least facially made out.


title: Habeas corpus in the United States

text: The November 13, 2001, Presidential Military Order purported to give the President of the United States the power to detain non-citizens suspected of connection to terrorists or terrorism as enemy combatants. As such, that person could be held indefinitely, without charges being filed against him or her, without a court hearing, and without legal counsel. Many legal and constitutional scholars contended that these provisions were in direct opposition to "habeas corpus", and the United States Bill of Rights and, indeed, in "Hamdi v. Rumsfeld" (2004) the U.S. Supreme Court re-confirmed the right of every American citizen to access "habeas corpus" even when declared to be an enemy combatant. The Court affirmed the basic principle that "habeas corpus" could not be revoked in the case of a citizen.


title: Habeas corpus in the United States

text: In "Hamdan v. Rumsfeld" (2006) Salim Ahmed Hamdan petitioned for a writ of habeas corpus, challenging that the military commissions set up by the Bush administration to try detainees at Guantanamo Bay "violate both the UCMJ and the four Geneva Conventions." In a 5-3 ruling the Court rejected Congress's attempts to strip the court of jurisdiction over habeas corpus appeals by detainees at Guantánamo Bay. Congress had previously passed the Department of Defense Appropriations Act, 2006 which stated in Section 1005(e), "Procedures for Status Review of Detainees Outside the United States":


title: Habeas corpus in the United States

text: On September 29, the U.S. House and Senate approved the Military Commissions Act of 2006, a bill which suspended habeas corpus for any alien determined to be an "unlawful enemy combatant engaged in hostilities or having supported hostilities against the United States" by a vote of 65-34. (This was the result on the bill to approve the military trials for detainees; an amendment to remove the suspension of "habeas corpus" failed 48-51.) President Bush signed the Military Commissions Act of 2006 (MCA) into law on October 17, 2006. With the MCA's passage, the law altered the language from "alien detained ... at Guantanamo Bay":


title: Habeas corpus in the United States

text: The Supreme Court ruled in "Boumediene v. Bush" that the MCA amounts to an unconstitutional encroachment on "habeas corpus" rights, and established jurisdiction for federal courts to hear petitions for "habeas corpus" from Guantanamo detainees tried under the Act. Under the MCA, the law restricted "habeas" appeals for only those aliens detained as enemy combatants, or awaiting such determination. Left unchanged was the provision that, after such determination is made, it is subject to appeal in federal courts, including a review of whether the evidence warrants the determination. If the status was upheld, then their imprisonment was deemed lawful; if not, then the government could change the prisoner's status to something else, at which point the "habeas" restrictions no longer applied.


title: Habeas corpus in the United States

text: There is, however, no legal time limit which would force the government to provide a Combatant Status Review Tribunal hearing. Prisoners were, but are no longer, legally prohibited from petitioning any court for any reason before a CSRT hearing takes place.


title: Habeas corpus in the United States

text: In January 2007, Attorney General Alberto Gonzales told the Senate Judiciary Committee that in his opinion: "There is no express grant of "habeas" in the Constitution. There's a prohibition against taking it away." He was challenged by Sen. Arlen Specter who asked him to explain how it is possible to prohibit something from being taken away, without first being granted. Robert Parry wrote in the Baltimore Chronicle & Sentinel:


title: Habeas corpus in the United States

text: The Department of Justice in the George W. Bush administration took the position in litigation that the Military Commissions Act of 2006 does not amount to a suspension of the writ of habeas corpus. The U.S. Court of Appeals for the D.C. Circuit agreed in a 2-1 decision, on February 20, 2007, which the U.S. Supreme Court initially declined to review. The U.S. Supreme Court then reversed its decision to deny review and took up the case in June 2007. In June 2008, the court ruled 5-4 that the act did suspend "habeas" and found it unconstitutional.


title: Habeas corpus in the United States

text: On June 11, 2007, a federal appeals court ruled that Ali Saleh Kahlah al-Marri, a legal resident of the United States, could not be detained indefinitely without charge. In a two-to-one ruling by the U.S. Court of Appeals for the Fourth Circuit, the Court held the President of the United States lacks legal authority to detain al-Marri without charge; all three judges ruled that al-Marri is entitled to traditional habeas corpus protections which give him the right to challenge his detainment in a U.S. Court. In July 2008, the U.S. Court of Appeals for the Fourth Circuit ruled that "if properly designated an enemy combatant pursuant to the legal authority of the President, such persons may be detained without charge or criminal proceedings for the duration of the relevant hostilities."


title: Habeas corpus in the United States

text: The Habeas Corpus Restoration Act of 2007 failed to overcome a Republican filibuster in the United States Senate in September, 2007.


title: Habeas corpus in the United States

text: On October 7, 2008, U.S. District Judge Ricardo M. Urbina ruled that 17 Uyghurs, Muslims from China's northwestern Xinjiang region, must be brought to appear in his court in Washington, DC, three days later:


title: Habeas corpus in the United States

text: "Because the Constitution prohibits indefinite detentions without cause, the continued detention is unlawful."


title: Habeas corpus in the United States

text: On January 21, 2009, President Barack Obama issued an executive order regarding the Guantanamo Bay Naval Base and the individuals held there. This order stated that the detainees "have the constitutional privilege of the writ of habeas corpus."


title: Habeas corpus in the United States

text: Following the December 1, 2011, vote by the United States Senate to reject an NDAA amendment proscribing the indefinite detention of U.S. citizens, the ACLU has argued that the legitimacy of "Habeas Corpus" is threatened:


title: Habeas corpus in the United States

text: "The Senate voted 38-60 to reject an important amendment [that] would have removed harmful provisions authorizing the U.S. military to pick up and imprison without charge or trial civilians, including American citizens, anywhere in the world... We're disappointed that, despite robust opposition to the harmful detention legislation from virtually the entire national security leadership of the government, the Senate said 'no' to the Udall amendment and 'yes' to indefinite detention without charge or trial." "The New York Times" has stated that the vote leaves the constitutional rights of U.S. citizens "ambiguous," with some senators including Carl Levin and Lindsey Graham arguing that the Supreme Court had already approved holding Americans as enemy combatants, and other senators, including Dianne Feinstein and Richard Durbin, asserting the opposite.


title: Habeas corpus in the United States

text: On March 20, 2015, a New York Supreme Court justice issued an order to "show cause & writ of "habeas corpus"" in a proceeding on behalf of two chimpanzees used in research at Stony Brook University. The justice, Barbara Jaffe, amended her order later in the day by striking the reference to "habeas corpus".


title: Habeas corpus in the United States

text: Habeas corpus is an action often taken after sentencing by a defendant who seeks relief for some perceived error in his criminal trial. There are a number of such post-trial actions and proceedings, their differences being potentially confusing, thus bearing some explanation. Some of the most common are an appeal to which the defendant has as a right, a writ of certiorari, a writ of coram nobis and a writ of habeas corpus.