title: Cannabis use disorder

text: Studies of divalproex have found no significant benefit, though some studies have found mixed results. Baclofen, a GABA-B receptor agonist and antispasmodic medication, has been found to reduce cravings but without a significant benefit towards preventing relapse or improving sleep. Zolpidem, a GABA-A receptor agonist and "Z-hypnotic" medication, has shown some efficacy in treating insomnia due to cannabis withdrawal, though there is a potential for misuse. Entacapone was well tolerated and decreased cannabis cravings in a trial on a small number of patients. Topiramate, an antiepileptic drug, has shown mixed results in adolescents, reducing the volume of cannabis consumption without significantly increasing abstinence, with somewhat poor tolerability. Gabapentin, an indirect GABA modulator, has shown some preliminary benefit for reducing cravings and cannabis use.


title: Cannabis use disorder

text: The agonist substitution approach is one that draws upon the analogy of the success of nicotine replacement therapy for nicotine addiction. Dronabinol, which is synthetic THC, has shown benefit in reducing cravings and other symptoms of withdrawal, though without preventing relapse or promoting abstinence. Combination therapy with dronabinol and the alpha 2 adrenergic receptor agonist lofexidine have shown mixed results, with possible benefits towards reducing withdrawal symptoms. However, overall, the combination of dronabinol and lofexidine is likely not effective for the treatment of cannabis use disorder. Nabilone, a synthetic THC analogue, has shown benefits in reducing symptoms of withdrawal such as difficulty sleeping, and decreased overall cannabis use. Despite its psychoactive effects, the slower onset of action and longer duration of action of nabilone make it less likely to be abused than cannabis itself, which makes nabilone a promising harm reduction strategy for the treatment of cannabis use disorder. The combination of nabilone and zolpidem has been shown to decrease sleep-related and mood-related symptoms of cannabis withdrawal, in addition to decreasing cannabis use. Nabiximols, a combined THC and cannabidiol (CBD) product that is formulated as an oral (buccal) spray, has been shown to improve withdrawal symptoms without improving abstinence rates. Oral CBD has not shown efficacy in reducing the signs or symptoms of cannabis use, and likely has no benefit in cannabis use withdrawal symptoms. The CB-1 receptor antagonist rimonabant has shown efficacy in reducing the effects of cannabis in users, but with a risk for serious psychiatric side effects.


title: Cannabis use disorder

text: Naltrexone, a mu opioid receptor antagonist, has shown mixed results for cannabis use disorder—both increasing the subjective effects of cannabis when given acutely, but potentially decreasing the overall use of cannabis with chronic administration. "N"-acetylcysteine (NAC) has shown some limited benefit in decreasing cannabis use in adolescents, though not with adults. Lithium, a mood stabilizer, has shown mixed results for treating symptoms of cannabis withdrawal, but is likely ineffective. Quetiapine, a second-generation antipsychotic, has been shown to treat cannabis withdrawal related insomnia and decreased appetite at the expense of exacerbating cravings. Oxytocin, a neuropeptide that the body produces, has shown some benefit in reducing the use of cannabis when administered intranasally in combination with motivational enhancement therapy sessions, though the treatment effect did not persist between sessions.


title: Cannabis use disorder

text: Finally, CB1 antagonists such as rimonabant have been tested for utility in CUD. These drugs are effective at blocking the subjective effects of cannabis intoxication as well as the somatic components. This is accomplished by preventing THC binding to the CB1 receptor, effectively eliminating the ability to get high. This is similar to how naloxone and naltrexone are used for opiates. CB1 antagonists may also aid in reducing cravings. Worries of psychological side effects that occur over prolonged exposure have led to the discontinuation of the development of many of these compounds, but several are currently entering clinical trials for the treatment of cannabis intoxication.


title: Cannabis use disorder

text: Over-the-counter sedating Antihistamines such as Doxylamine have sedating and anti-emetic effects and may provide short term relief but should only be used within advised dosages.


title: Cannabis use disorder

text: Research that looks at barriers to cannabis treatment frequently cites a lack of interest in treatment, lack of motivation and knowledge of treatment facilities, an overall lack of facilities, costs associated with treatment, difficulty meeting program eligibility criteria and transport difficulties.


title: Cannabis use disorder

text: According to the 2022 National Survey on Drug Use and Health, cannabis is one of the most widely used drugs in the world. Research by the Pew Research Center from 2012 claims 42% of the US population have claimed to use cannabis at some point. According to the 2019 National Survey on Drug Use and Health, 46% of U.S. adults say they have ever used marijuana. An estimated 9% of those who use cannabis develop dependence.


title: Cannabis use disorder

text: In the U.S., cannabis is the most commonly identified illicit substance used by people admitted to treatment facilities. Most of these people were referred there by the criminal justice system. Of admittees 16% either went on their own, or were referred by family or friends.


title: Cannabis use disorder

text: In the European Union (data as available in 2018, information for individual countries was collected between 2012 and 2017), 26.3% of adults aged 15–64 used cannabis at least once in their lives, and 7.2% used cannabis in the last year. The highest prevalence of cannabis use among 15 to 64 years old in the EU was reported in France, with 41.4% having used cannabis at least once in their life, and 2.17% used cannabis daily or almost daily. Among young adults (15–34 years old), 14.1% used cannabis in the last year.


title: Cannabis use disorder

text: Among adolescents (15–16 years old) in a European school based study (ESPAD), 16% of students have used cannabis at least once in their life, and 7% (boys: 8%, girls: 5%) of students had used cannabis in the last 30 days.


title: Cannabis use disorder

text: Globally, 22.1 million people (0.3% of the worlds population) were estimated to have cannabis dependence.


title: Cannabis use disorder

text: Medications such as SSRI antidepressants, mixed action antidepressants, bupropion, buspirone and atomoxetine may not be helpful to treat cannabis use disorder, but the evidence is very weak and further research is required. THC preparations, gabapentin, oxytocin, and N-acetylcysteine also require more research to determine if they are effective as the evidence base is weak.


title: Cannabis use disorder

text: Heavy cannabis use has been associated with impaired cognitive functioning, however, its specific details are difficult to elucidate due to the potential use of additional substances of users, and lack of longitudinal studies.


title: Kelo v. City of New London

text: Kelo v. City of New London, 545 U.S. 469 (2005), was a landmark decision by the Supreme Court of the United States in which the Court held, 5–4, that the use of eminent domain to transfer land from one private owner to another private owner to further economic development does not violate the Takings Clause of the Fifth Amendment. In the case, plaintiff Susette Kelo sued the city of New London, Connecticut, for violating her civil rights after the city tried to acquire her house's property through eminent domain so that the land could be used as part of a "comprehensive redevelopment plan". Justice John Paul Stevens wrote for the five-justice majority that the city's use of eminent domain was permissible under the Takings Clause, because the general benefits the community would enjoy from economic growth qualified as "public use".


title: Kelo v. City of New London

text: After the Court's decision, the city allowed a private developer to proceed with its plans; however, the developer was unable to obtain financing and abandoned the project, and the contested land remained an undeveloped empty lot.


title: Kelo v. City of New London

text: This case was appealed to the Supreme Court of the United States from a decision by the Supreme Court of Connecticut in favor of the City of New London. The owners, including lead plaintiff Susette Kelo of 8 East Street, sued the city in Connecticut courts, arguing that the city had misused its eminent domain power. The power of eminent domain is limited by the Takings Clause of the Fifth Amendment and the Due Process Clause of the Fourteenth Amendment. The Takings Clause reads, ". . . nor shall private property be taken for public use, without just compensation." Under the Due Process Clause of the Fourteenth Amendment, this limitation also applies to the actions of state and local governments. The plaintiffs argued that economic development, the stated purpose of the taking and subsequent transfer of land to the New London Development Corporation, did not qualify as a public use under the Fifth Amendment.


title: Kelo v. City of New London

text: The Connecticut Supreme Court heard arguments on December 2, 2002. The state court issued its decision (268 Conn. 1, SC16742) on March 9, 2004, siding with the city in a 4–3 decision, with the majority opinion authored by Justice Flemming L. Norcott, Jr., joined by Justices David M. Borden, Richard N. Palmer and Christine Vertefeuille. Justice Peter T. Zarella wrote the dissent, joined by Chief Justice William J. Sullivan and Justice Joette Katz.


title: Kelo v. City of New London

text: The State Supreme Court held that the use of eminent domain for economic development did not violate the public use clauses of the state and federal constitutions. The court held that if a legislative body has found that an economic project will create new jobs, increase tax and other city revenues, and revitalize a depressed urban area (even if that area is not blighted), then the project serves a public purpose, which qualifies as a public use. The court also ruled that the government’s delegation of its eminent domain power to a private entity was constitutional under the Connecticut Constitution.


title: Kelo v. City of New London

text: The United States Supreme Court granted "certiorari" to consider questions raised in "Berman v. Parker," and later in "Hawaii Housing Authority v. Midkiff", . Namely, whether a "public purpose" constitutes a "public use" for purposes of the Fifth Amendment's Taking Clause: "nor shall private property be taken for public use, without just compensation." Specifically, does the Fifth Amendment, applicable to the states through the Due Process Clause of the Fourteenth Amendment (see main article: Incorporation of the Bill of Rights), protect landowners from takings for economic development, rather than, as in "Berman," for the elimination of slums and blight?


title: Kelo v. City of New London

text: "Kelo" was the first major eminent domain case heard at the Supreme Court since 1984. In that time, states and municipalities had slowly extended their use of eminent domain, frequently to include economic development purposes. In the "Kelo" case, Connecticut had a statute allowing eminent domain for "economic development" even in the absence of blight. There was also an additional twist in that the development corporation was ostensibly a private entity; thus the plaintiffs argued that it was not constitutional for the government to take private property from one individual or corporation and give it to another, if the government was simply doing so because the repossession would put the property to a use that would generate higher tax revenue.


title: Kelo v. City of New London

text: "Kelo" became the focus of vigorous discussion and attracted numerous supporters on both sides. Some 40 "amicus curiae" briefs were filed in the case, 25 on behalf of the petitioners. Susette Kelo's supporters ranged from the libertarian Institute for Justice (the lead attorneys on the case) to the NAACP, AARP, the Southern Christian Leadership Conference and South Jersey Legal Services. The latter groups signed an amicus brief arguing that eminent domain has often been used against politically weak communities with high concentrations of minorities and elderly.


title: Kelo v. City of New London

text: The case was argued on February 22, 2005. Oral arguments were presented on behalf of the petitioners (plaintiffs) by Scott G. Bullock of the Institute for Justice in Washington, D.C. and on behalf of the respondents (defendants) by Wesley W. Horton of Horton, Shields & Knox in Hartford, CT. The case was heard by only seven members of the court with Associate Justice Sandra Day O'Connor presiding, as Chief Justice William Rehnquist was recuperating from medical treatment at home and Associate Justice John Paul Stevens was delayed on his return to Washington from Florida; both absent Justices read the briefs and oral argument transcripts and participated in the case decision.


title: Kelo v. City of New London

text: During the case, Justice Antonin Scalia, asked whether a ruling in favor of the city would destroy "the distinction between private use and public use." He also asked if private use, which provided merely incidental benefits to the state, was "not enough to justify use of the condemnation power."


title: Kelo v. City of New London

text: On June 23, 2005, the Supreme Court ruled in a 5–4 decision in favor of the City of New London. Justice John Paul Stevens wrote the majority opinion, joined by Justices Anthony Kennedy, David Souter, Ruth Bader Ginsburg and Stephen Breyer. Justice Kennedy wrote a concurring opinion setting out a more detailed standard for judicial review of economic development takings than that found in Stevens's majority opinion. In so doing, Justice Kennedy contributed to the Court's trend of turning minimum scrutiny—the idea that government policy need only bear a rational relation to a legitimate government purpose—into a fact-based test.


title: Kelo v. City of New London

text: In "Romer v. Evans", 517 U.S. 620, 633 (1996), the Court said that the government purpose must be "independent and legitimate." And in "United States v. Virginia", 518 U.S. 515, 533 (1996), the Court said the government purpose "must be genuine, not hypothesized or invented post hoc in response to litigation." Thus, the Court made it clear that, in the scrutiny regime established in "West Coast Hotel v. Parrish", 300 U.S. 379 (1937), government purpose is a question of fact for the trier of fact.


title: Kelo v. City of New London

text: Kennedy fleshed out this doctrine in his "Kelo" concurring opinion; he sets out a program of civil discovery in the context of a challenge to an assertion of government purpose. However, he does not explicitly limit these criteria to eminent domain, nor to minimum scrutiny, suggesting that they may be generalized to all health and welfare regulation in the scrutiny regime. He wrote:


title: Kelo v. City of New London

text: A court confronted with a plausible accusation of impermissible favoritism to private parties should [conduct]... a careful and extensive inquiry into 'whether, in fact, the development plan [chronology]


title: Kelo v. City of New London

text: [1.] is of primary benefit to... the developer... and private businesses which "may" eventually locate in the plan area...


title: Kelo v. City of New London

text: [3.] awareness of... depressed economic condition and evidence corroborating the validity of this concern...


title: Kelo v. City of New London

text: [4.] the substantial commitment of public funds... before most of the private beneficiaries were known...


title: Kelo v. City of New London

text: [6.] [government] chose a private developer from a group of applicants rather than picking out a particular transferee beforehand and...


title: Kelo v. City of New London

text: [7.] other private beneficiaries of the project [were]... unknown [to government] because the... space proposed to be built [had] not yet been rented...


title: Kelo v. City of New London

text: "Kelo v. City of New London" did not establish entirely new law concerning eminent domain. Although the decision was controversial, it was not the first time "public use" had been interpreted by the Supreme Court as "public purpose." In the majority opinion, Justice Stevens wrote the "Court long ago rejected any literal requirement that condemned property be put into use for the general public" (545 U.S. 469). Thus precedent played an important role in the 5–4 decision of the Supreme Court. The Fifth Amendment was interpreted the same way as in "Midkiff" (467 U.S. 229) and other earlier eminent domain cases.


title: Kelo v. City of New London

text: The principal dissent was issued on June 25, 2005 by Justice O'Connor, joined by Chief Justice Rehnquist and Justices Scalia and Thomas. The dissenting opinion suggested that the use of this taking power in a reverse Robin Hood fashion—take from the poor, give to the rich—would become the norm, not the exception:


title: Kelo v. City of New London

text: O'Connor argued that the decision eliminates "any distinction between private and public use of property—and thereby effectively delete[s] the words 'for public use' from the Takings Clause of the Fifth Amendment."


title: Kelo v. City of New London

text: Thomas also issued a separate originalist dissent, in which he argued that the precedents the court's decision relied upon were flawed. He accuses the majority of replacing the Fifth Amendment's "Public Use" clause with a very different "public purpose" test:


title: Kelo v. City of New London

text: Thomas also made use of the argument presented in the NAACP/AARP/SCLC/SJLS amicus brief on behalf of three low-income residents' groups fighting redevelopment in New Jersey, noting:


title: Kelo v. City of New London

text: Following the decision, many of the plaintiffs expressed an intent to find other means by which they could continue contesting the seizure of their homes. Soon after the decision, city officials announced plans to charge the residents of the homes for back rent for the five years since condemnation procedures began. The city contended that the residents have been on city property for those five years and owe tens of thousands of dollars of rent. In June 2006, Governor M. Jodi Rell intervened with New London city officials, proposing the homeowners involved in the suit be deeded property in the Fort Trumbull neighborhood so they may retain their homes. A group of New London residents formed a local political party, One New London, to combat the takings.


title: Kelo v. City of New London

text: The controversy was eventually settled when the city paid substantial additional compensation to the homeowners and agreed to move Kelo's home to a new location. The land was never deeded back to the original homeowners, most of whom have left New London for nearby communities. Three years after the Supreme Court case was decided, the Kelo house was dedicated after being relocated to 36 Franklin Street, a site close to downtown New London. Susette Kelo, however, has moved to a different part of Connecticut.


title: Kelo v. City of New London

text: In spite of repeated efforts, the redeveloper (who stood to get a waterfront tract of land for $1 per year) was unable to obtain financing, and the redevelopment project was abandoned. As of the beginning of 2010, the original Kelo property was a vacant lot, generating no tax revenue for the city. In the aftermath of 2011's Hurricane Irene, the now-closed New London redevelopment area was turned into a dump for storm debris such as tree branches and other vegetation.


title: Kelo v. City of New London

text: Pfizer, whose employees were supposed to be the clientele of the Fort Trumbull redevelopment project, completed its merger with Wyeth, resulting in a consolidation of research facilities of the two companies. Pfizer chose to retain the Groton campus on the east side of the Thames River, closing its New London facility in late 2010 with a loss of over 1,000 jobs. That coincided with the expiration of tax breaks on the New London site that would have increased Pfizer's property tax bill by almost 400 percent.


title: Kelo v. City of New London

text: After the Pfizer announcement, the "San Francisco Chronicle", in November 2009, in its lead editorial called the "Kelo" decision infamous:


title: Kelo v. City of New London

text: The "Chronicle" editorial quoted from "The New York Times": "They stole our home for economic development," ousted homeowner Michael Cristofaro told the "New York Times". "It was all for Pfizer, and now they get up and walk away."


title: Kelo v. City of New London

text: The final cost to the city and state for the purchase and bulldozing of the formerly privately held property was $78 million. The promised 3,169 new jobs and $1.2 million a year in tax revenues had not materialized. As of 2021, the area remains an empty lot.


title: Kelo v. City of New London

text: Opposition to the ruling was widespread, coming from groups such as AARP, the NAACP, the Libertarian Party and the Institute for Justice. The American Conservative Union condemned the decision. Much of the public viewed the outcome as a gross violation of property rights and as a misinterpretation of the Fifth Amendment, the consequence of which would be to benefit large corporations at the expense of individual homeowners and local communities. Many owners of family farms also disapproved of the ruling, as they saw it as an avenue by which cities could seize their land for private developments. Since the opposition to the ruling was so widespread American journalist Charles C. W. Cooke argued in 2015 that a constitutional amendment like the one drafted by law professor Ilya Somin might attract enough support by a non-partisan coalition of progressives, independents and conservatives to undo the Supreme Court ruling in "Kelo v. City of New London".


title: Kelo v. City of New London

text: Some in the legal profession construed the public's outrage as being directed not at the interpretation of legal principles involved in the case, but at the broad moral principles of the general outcome. Federal appeals court judge Richard Posner wrote that the political response to "Kelo" is "evidence of [the decision's] pragmatic soundness." Judicial action would be unnecessary, Posner suggested, because the political process could take care of the problem."


title: Kelo v. City of New London

text: As a result, most states changed their eminent domain laws. Prior to the "Kelo" decision, only seven states specifically prohibited the use of eminent domain for economic development except to eliminate blight. Since the decision, forty-five states have amended their eminent domain laws, although some of these changes are cosmetic.


title: Kelo v. City of New London

text: The "New York Times" editorial board agreed with the ruling, calling it "a welcome vindication of cities' ability to act in the public interest." The "Washington Post"s editorial board also agreed with the ruling, writing, "[t]he court's decision was correct. . . . New London's plan, whatever its flaws, is intended to help develop a city that has been in economic decline for many years."


title: Kelo v. City of New London

text: The "Kelo" fiasco eventually cost the taxpayers tens of millions of dollars, with nothing to show for it. The "carefully vetted" municipal plans that formed the basis for the Supreme Court's decision proved to be illusory. Eventually, the City of New London extended an apology to Susette Kelo and her neighbors. In 2011, Richard N. Palmer, one of the Connecticut Supreme Court justices who voted with the 4–3 majority for the city, also apologized and said that he should've voted differently.


title: Kelo v. City of New London

text: On June 23, 2006, the first anniversary of the original decision, President George W. Bush issued an executive order instructing the federal government to restrict the use of eminent domain However, since eminent domain is most often exercised by local and state governments, the executive order was largely symbolic.


title: Kelo v. City of New London

text: On June 27, 2005, Senator John Cornyn (R-Tex.) introduced legislation, the "Protection of Homes, Small Businesses and Private Property Act of 2005" (S.B. 1313), to limit the use of eminent domain for economic development. The operative language


title: Kelo v. City of New London

text: Similar bills have subsequently been put forth in the House of Representatives by Congressman Dennis Rehberg (R-Mont.), Tom DeLay (R-Tex.), and John Conyers (D-Mich.) with James Sensenbrenner (R-Wisc.). As some small-scale eminent domain condemnations (including notably those in the "Kelo" case) can be local in both decision and funding, it is unclear how much of an effect the bill would have if it passed into law. This bill has been reintroduced several times.


title: Kelo v. City of New London

text: In 2008, land use Professor Daniel R. Mandelker argued that the public backlash against "Kelo" is rooted in the historical deficiencies of urban renewal legislation. In particular, the article cited the failure to incorporate land use planning and a precise definition of blight in urban renewal legislation as problematic. In 2009, Professor Edward J. Lopez of San Jose State University studied passed laws and found that states with more economic freedom, greater value of new housing construction, and less racial and income inequality were more likely to have enacted stronger restrictions sooner.


title: Kelo v. City of New London

text: Severe criticism of the "Kelo" decision came from Professor Gideon Kanner of the Loyola Law School, Los Angeles. Kanner wrote, "The principal failing of the "Kelo" decision is that it misreads the case law on which it purports to rely as a seminal precedent, and by its holding frustrates the usual mode of constitutional analysis." He likened the language in the majority's decision ("'public' means 'private' and 'use' means 'purpose,' or 'prognosticated municipal prosperity'") to the abuse of language in George Orwell's "Nineteen Eighty-Four".


title: Kelo v. City of New London

text: Prior to "Kelo", eight states specifically prohibited the use of eminent domain for economic development except to eliminate blight: Arkansas, Florida, Kansas, Kentucky, Maine, New Hampshire, South Carolina and Washington. , 45 states had enacted some type of reform legislation in response to the "Kelo" decision. Of those states, 22 enacted laws that severely inhibited the takings allowed by the Kelo decision, while the rest enacted laws that place some limits on the power of municipalities to invoke eminent domain for economic development. The remaining five states have not passed laws to limit the power of eminent domain for economic development.


title: Kelo v. City of New London

text: Under pre-existing California law, takings (for conveyance to a private party, as opposed to a public use that may incidentally benefit private parties) were already illegal.


title: Kelo v. City of New London

text: Proposition 90, which attempted to exploit the unpopularity of "Kelo" for a different objective, failed in the November 2006 election. The initiative also included language requiring that government pay financial compensation to any property owners who could successfully argue that regulation caused them significant economic loss. Subsequently, Proposition 99 passed in the June 2008 election. It amends the state constitution to prohibit (subject to some exceptions): In 2012, California abolished its redevelopment agencies.


title: Kelo v. City of New London

text: Florida passed a 2006 ballot measure amending the Florida Constitution to restrict use of eminent domain. The amendment says in part:


title: Kelo v. City of New London

text: The Iowa Legislature passed a 2006 bill restricting the use of eminent domain for economic development. Gov. Tom Vilsack (D) vetoed the bill, prompting the first special session of the Iowa Legislature in more than 40 years. The veto was overridden by votes of 90–8 in the Iowa House and 41–8 in the Iowa Senate.


title: Kelo v. City of New London

text: In response to the "Kelo" decision, the Kansas Legislature enacted K.S.A. 26-501a and K.S.A. 26-501b and amended K.S.A. 26-501.


title: Kelo v. City of New London

text: K.S.A. 26-501a. Eminent domain; limited to public use; transfer to private entity prohibited; exception. On and after July 1, 2007: (a) Private property shall not be taken by eminent domain except for public use and private property shall not be taken without just compensation.


title: Kelo v. City of New London

text: (b) The taking of private property by eminent domain for the purpose of selling, leasing or otherwise transferring such property to any private entity is prohibited except as provided in K.S.A. 2009 Supp. 26–501b, and amendments thereto.


title: Kelo v. City of New London

text: K.S.A. 26-501b. Eminent domain; transfer to private entity authorized, when. On and after July 1, 2007, the taking of private property by eminent domain for the purpose of selling, leasing, or otherwise transferring such property to any private entity is authorized if the taking is:


title: Kelo v. City of New London

text: (a) By the Kansas department of transportation or a municipality and the property is deemed excess real property that was taken lawfully and incidental to the acquisition of right-of-way for a public road, bridge or public improvement project including, but not limited to a public building, park, recreation facility, water supply project, wastewater and waste disposal project, storm water project and flood control and drainage project;


title: Kelo v. City of New London

text: (b) by any public utility, as defined in K.S.A. 66-104, and amendments thereto, gas gathering service, as defined in K.S.A. 55-1,101, and amendments thereto, pipe-line companies, railroads and all persons and associations of persons, whether incorporated or not, operating such agencies for public use in the conveyance of persons or property within this state, but only to the extent such property is used for the operation of facilities necessary for the provision of services;


title: Kelo v. City of New London

text: (d) by any municipality for the purpose of acquiring property which has defective or unusual conditions of title including, but not limited to, clouded or defective title or unknown ownership interests in the property;


title: Kelo v. City of New London

text: (e) by any municipality for the purpose of acquiring property which is unsafe for occupation by humans under the building codes of the jurisdiction where the structure is situated;


title: Kelo v. City of New London

text: (f) expressly authorized by the legislature on or after July 1, 2007, by enactment of law that identifies the specific tract or tracts to be taken. If the legislature authorizes eminent domain for private economic development purposes, the legislature shall consider requiring compensation of at least 200% of fair market value to property owners.


title: Kelo v. City of New London

text: Michigan passed a restriction on the use of eminent domain in November 2006, Proposition 4, 80% to 20%. The text of the ballot initiative was as follows:


title: Kelo v. City of New London

text: A proposed constitutional amendment to prohibit government from taking private property by eminent domain for certain private purposes


title: Kelo v. City of New London

text: The state restricts eminent domain to public use. Minnesota Statute 117.025 Subd. 11(b) (passed in 2006) clearly states: "The public benefits of economic development, including an increase in tax base, tax revenues, employment, or general economic health, do not by themselves constitute a public use or public purpose."


title: Kelo v. City of New London

text: On November 8, 2011, Mississippi Initiative #31 restricting eminent domain, was approved by voters 73–27%. The text of Initiative # 31 is as follows:


title: Kelo v. City of New London

text: On November 25, 2008, a voter-approved amendment to the Nevada constitution, colloquially titled the "People's Initiative to Stop the Taking of Our Land", or "PISTOL", was put into effect following its review by the Nevada State Supreme Court. Among other provisions, the amendment included the following text:


title: Kelo v. City of New London

text: The amendment also modifies the definition of "fair market value"—used to determine the monetary compensation a property owner receives—to represent the highest value the property would be sold for on the open market, and returns seized property to the original property owner "if the property is not used within five years for the original purpose stated by the government."


title: Kelo v. City of New London

text: In New Hampshire, various libertarian activists, in response to the decision, sought to use eminent domain to seize Justice David Souter's farmhouse in Weare, New Hampshire and build a hotel (the "Lost Liberty Hotel") on the site. The proposal was not supported by the town's five-member board of selectmen, and Weare voters rejected the activists' attempt to place a proposal on the local ballot to seize Souter's farm.


title: Kelo v. City of New London

text: In 2006, the New Hampshire Legislature proposed an amendment to the state constitution providing that "no part of a person's property shall be taken by eminent domain and transferred, directly or indirectly, to another person if the taking is for the purpose of private development or other private use of the property." The amendment was overwhelmingly approved by New Hampshire voters in the November 2006 elections. Some New Hampshire commentators suggested that the state had gone too far in restricting the exercise of eminent domain in the "Kelo" backlash.


title: Kelo v. City of New London

text: An attempted use of eminent domain was brought before the Ohio Supreme Court in "City of Norwood v. Horney". In July 2006, the Supreme Court of Ohio unanimously held in favor of the property owners, finding the seizure would violate the Constitution of Ohio.


title: Kelo v. City of New London

text: In 2012, the Virginia General Assembly approved a ballot measure for the November general election that would amend the state constitution to greatly restrict the government's ability to condemn land for private benefit. The measure succeeded with nearly 75% of the electorate in support of the eminent domain reform. The reform resulted in an amendment to Virginia's Bill of Rights seeking to prevent a situation like "Kelo" which read in part: "a taking or damaging of private property is not for public use if the primary use is for private gain, private benefit, private enterprise, increasing jobs, increasing tax revenue, or economic development, except for the elimination of a public nuisance existing on the property. The condemnor bears the burden of proving that the use is public, without a presumption that it is."


title: Kelo v. City of New London

text: On March 29, 2006, Gov. Jim Doyle signed into law 2005 Wisconsin Act 233, which prohibits condemnation of nonblighted property for transfer to a private entity. Nonblighted property is defined by a list of conditions that may make the property a detriment to the "public health, safety, or welfare." Two days earlier the governor signed into law 2005 Wisconsin Act 208, which creates procedures designed to protect property owners including public notice and public hearing requirements.


title: Kelo v. City of New London

text: The Wisconsin law has been criticized as one having little or no real protection for property owners because it provides protection against property condemnation for economic development but does allow property condemnation under a broadly defined description of blighted.


title: Kelo v. City of New London

text: Jeff Benedict wrote an account of the case in a 2009 book, "Little Pink House: A True Story of Defiance and Courage". Benedict's account was adapted into a film, "Little Pink House", released in 2018.


title: Family Guy (season 2)

text: The second season of "Family Guy" first aired on the Fox network in 21 episodes from September 23, 1999, to August 1, 2000. The series follows the dysfunctional Griffin family—father Peter, mother Lois, daughter Meg, son Chris, baby Stewie and their anthropomorphic dog Brian, all of whom reside in their hometown of Quahog. The show features the voices of series creator Seth MacFarlane, Alex Borstein, Seth Green, Lacey Chabert and later Mila Kunis in the roles of the Griffin family. The executive producers for the second production season were David Zuckerman and MacFarlane; the aired season also contained eight episodes which were holdovers from season one.


title: Family Guy (season 2)

text: By the end of the second season, due to low ratings, Fox resorted to canceling "Family Guy". However, following a last-minute reprieve, it returned for a third season in 2001. The series was canceled again in 2002; however, high ratings on Fox and high DVD sales renewed Fox's interest in the series. The series returned for a total of 30 new episodes in 2005.


title: Family Guy (season 2)

text: The season received a positive reception from critics, who called the series "extremely witty and darkly hilarious," and was "unfortunately" canceled. The Volume One DVD box set was released in Region 1 on April 15, 2003, and Region 2 on November 12, 2001. All twenty-one of the season's episodes are included in the volume. The first season's seven episodes were also included in the volume.


title: Family Guy (season 2)

text: In 2002, "Family Guy" was canceled after three seasons due to low ratings. The show was first canceled after the 1999–2000 season, but following a last-minute reprieve, it returned for a third season in 2001. During the third season, Fox announced that the show was canceled for good. Fox tried to sell rights for reruns of the show, but it was hard to find networks that were interested; Cartoon Network eventually bought the rights, " basically for free", according to the president of 20th Century Fox Television Production.


title: Family Guy (season 2)

text: When the reruns were shown on Cartoon Network's Adult Swim in 2003, "Family Guy" became Adult Swim's most-watched show with an average 1.9 million viewers an episode. Following "Family Guy"s high ratings on Adult Swim, the first and second seasons was released on DVD in April 2003. Sales of the DVD set reached 2.2 million copies, becoming the best-selling television DVD of 2003 and the second highest-selling television DVD ever, behind the first season of Comedy Central's "Chappelle's Show". The third season DVD release also sold more than a million copies. The show's popularity in both DVD sales and reruns rekindled Fox's interest in it. They ordered 35 new episodes in 2004, marking the first revival of a television show based on DVD sales. Fox president Gail Berman said that it was one of her most difficult decisions to cancel the show, and was therefore happy it would return. The network also began production of a film based on the series.


title: Family Guy (season 2)

text: The second season of "Family Guy" received positive reviews from critics. Aaron Beierle of DVD Talk said "Often brilliant, extremely witty and darkly hilarious, "Family Guy" was unfortunately canceled after Fox bumped it around six or seven different time slots. Fans of the show should definitely pick up this terrific sets , while those who haven't seen it should consider giving it a look." Fewer critics responded negatively to the season, including Ken Tucker of "Entertainment Weekly", who graded the series a "D", and named it the worst show of the 1999–2000 television season. Mark Graham noted "MacFarlane's incredibly rocky relationship with both the magazine and its lead television critic, Ken Tucker" in a blog on the "New York" magazine website. Tucker has also criticized the show for perceived anti-Semitism. L. Brent Bozell III expressed in a column of his written in 1999 that he felt that the episode "Holy Crap" promoted anti-Catholicism.


title: Family Guy (season 2)

text: The Parents Television Council, a watchdog and frequent critic of "Family Guy" had initially speculated that "Family Guy" would be "pushing the envelope" before the series' 1999 premiere. In May 2000, in its weekly "E-Alert" email newsletter, the PTC launched a letter-writing campaign to the Fox network to persuade the network to cancel "Family Guy" following a return from a long hiatus in the show's second season, due to what the PTC claimed were "strong advertiser resistance and low ratings". In addition, "Family Guy" made the PTC's 2000 "worst prime-time shows for family viewing".


title: Family Guy (season 2)

text: The first and second seasons were released under the title "Family Guy Volume One"; this standard four-disc DVD box set debuted in Region 1 on April 15, 2003. Distributed by 20th Century Fox Television, it included several DVD extras such as episode commentaries, behind-the-scenes footage, and online promo spots. The same episodes, without the special features, were released in Region 2 on November 12, 2001, and in Region 4 on October 20, 2003.


title: Battle of Luzon

text: The Battle of Luzon (; ; ) was a land battle of the Pacific Theater of Operations of World War II by the Allied forces of the U.S., its colony the Philippines, and allies against forces of the Empire of Japan. The battle resulted in a U.S. and Filipino victory. The Allies had taken control of all strategically and economically important locations of Luzon by March 1945, although pockets of Japanese resistance held out in the mountains until the unconditional surrender of Japan. While not the highest in U.S. casualties, it is the highest net casualty battle U.S. forces fought in World War II, with 192,000 to 217,000 Japanese combatants dead (mostly from starvation and disease), 8,000 American combatants killed, and over 150,000 Filipinos, overwhelmingly civilians who were murdered by Japanese forces, mainly during the Manila massacre of February 1945.


title: Battle of Luzon

text: The Philippines was considered to be of great strategic importance because their capture by Japan would pose a significant threat to the U.S. As a result, 135,000 troops and 227 aircraft were stationed in the Philippines by October 1941. However, Luzon—the largest island in the Philippines—was captured by Imperial Japanese forces in 1942. General Douglas MacArthur—who was in charge of the defense of the Philippines at the time—was ordered to Australia, and the remaining U.S. forces retreated to the Bataan Peninsula.


title: Battle of Luzon

text: A few months after this, MacArthur expressed his belief that an attempt to recapture the Philippines was necessary. The U.S. Pacific Commander Admiral Chester Nimitz and Chief of Naval Operations Admiral Ernest King both opposed this idea, arguing that it must wait until victory was certain. MacArthur had to wait two years for his wish; it was 1944 before a campaign to recapture the Philippines was launched. The island of Leyte was the first objective of the campaign, which was captured by the end of December 1944. This was followed by the attack on Mindoro, and later, Luzon.


title: Battle of Luzon

text: Before U.S. forces could launch the attack on Luzon, a base of operation needed to be established close to the island. Airbases in particular had to be established in order to provide the advancing troops with air support. Troops under Brigadier General William C. Dunckel captured the island of Mindoro, with the assistance of the 7th Fleet. By 28 December, two airbases were controlled by the U.S. and were ready to assist in the attack on Luzon, which was scheduled to be launched on 9 January 1945. With the capture of Mindoro, U.S. forces were positioned south of Luzon. However, MacArthur intended to land his forces at Lingayen, further north. This would place his troops close to several roads and railways on Luzon, which led to Manila—the main objective—through the plains in the center of the island.


title: Battle of Luzon

text: U.S. aircraft constantly made reconnaissance and bombing flights over southern Luzon, intending to deceive the Japanese forces into believing that the attack on Luzon would come from the south. In addition, transport aircraft were used to make parachute drops with dummies. Minesweepers were used to clear the bays of Balayan, Batangas, and Tayabas, located to the south of Luzon, and Filipino resistance fighters conducted sabotage operations in southern Luzon. These deception operations failed to convince General Yamashita, the leader of the Imperial Japanese Army in the Philippines, and he built significant defensive positions in the hills and mountains surrounding the Lingayen Gulf in Northern Luzon.


title: Battle of Luzon

text: The assault on Luzon was launched, as planned, on 9 January 1945, codenamed S-day. The Japanese forces reported more than 70 Allied warships entering the Lingayen Gulf, though the total Allied invasion force involved that month would equal close to 800 ships. Pre-assault bombardment of Japanese shore positions from roughly 70 battleships and cruisers began at 7:00. The landings were commenced an hour later. The landing forces faced strong opposition from Japanese "kamikaze" aircraft. The escort carrier was destroyed by a "kamikaze" attack, with a total of around 47 ships damaged, and four sunk, from January 3-13, primarily by kamikazes.


title: Battle of Luzon

text: The landings at the Lingayen Gulf on 9 January were carried out by the 6th Army under the command of General Walter Krueger. Approximately 175,000 troops from the 6th Army landed along the beachhead within a few days, while the I Corps protected their flanks. XIV Corps under General Oscar Griswold then advanced south toward Manila, despite Krueger's concerns that his eastern flank was unprotected and vulnerable if the Japanese forces attacked. However, no such attack occurred, and the U.S. forces did not meet much resistance until they reached the Clark Air Base on 23 January. The battle there lasted until the end of January, and after capturing the base, XIV Corps advanced toward Manila.


title: Battle of Luzon

text: A second amphibious landing took place on 15 January, southwest of Manila. On 31 January, two regiments of the 11th Airborne Division made an airborne assault, capturing a bridge, and later advanced toward Manila. On 3 February, the 1st Cavalry Division captured the bridge across Tullahan River leading to the city. They advanced into the city that evening, and the battle for the capture of Manila began. On 4 February, the paratroopers of the 11th Airborne—approaching the city from the south—came to the main Japanese defences south of the city of Manila where their advance was halted by heavy resistance. General Yamashita had ordered his troops to destroy all bridges and other vital installations as soon as the U.S. forces entered the city, and Japanese forces entrenched throughout the city continued to resist U.S. forces. General MacArthur announced the imminent recapture of Manila on the same day. On 11 February, the 11th Airborne Division captured the last Japanese outer defences, thus encircling the whole city. U.S. and Filipino forces carried out clearing operations in the city in the following weeks. Military casualties totalled 1,010 Americans, 3,079 Filipinos and 12,000 Japanese.


title: Battle of Luzon

text: Battles continued throughout the island of Luzon in the following weeks, with more U.S. troops having landed on the island. Filipino and American resistance fighters also attacked Japanese positions and secured several locations. The Allies had taken control of all strategically and economically important locations of Luzon by early March. Small groups of the remaining Japanese forces retreated to the mountainous areas in the north and southeast of the island, where they were besieged for months. Pockets of Japanese soldiers held out in the mountains—most ceasing resistance with the unconditional surrender of Japan, but a scattered few holding out for many years afterwards. Casualties were stunningly high for the Japanese. Japanese losses were 217,000 dead, with 9,050 taken prisoners. U.S. losses were far lower, with 8,310 killed and 29,560 wounded. Civilian casualties are estimated at 120,000 to 140,000 dead.


title: Palaeognathae

text: Palaeognathae (; ) is a infraclass of birds, called paleognaths, within the class Aves of the clade Archosauria. It is one of the two extant infraclasses of birds, the other being Neognathae, both of which form Neornithes. Palaeognathae contains five extant branches of flightless lineages (plus two extinct clades), termed ratites, and one flying lineage, the Neotropic tinamous. There are 47 species of tinamous, five of kiwis ("Apteryx"), three of cassowaries ("Casuarius"), one of emus ("Dromaius") (another became extinct in historic times), two of rheas ("Rhea") and two of ostrich ("Struthio"). Recent research has indicated that paleognaths are monophyletic but the traditional taxonomic split between flightless and flighted forms is incorrect; tinamous are within the ratite radiation, meaning flightlessness arose independently multiple times via parallel evolution.


title: Palaeognathae

text: There are three extinct groups that are undisputed members of Palaeognathae: the Lithornithiformes, the Dinornithiformes (moas) and the Aepyornithiformes (elephant birds), the latter two of which became extinct in the last 1000 years. There are other extinct birds which have been allied with the Palaeognathae by at least one author, but their affinities are a matter of dispute.


title: Palaeognathae

text: The word "Paleognath" is derived from the ancient Greek for 'old jaws' in reference to the skeletal anatomy of the palate, which is described as more primitive and reptilian than that in other birds. Paleognathous birds retain some basal morphological characters but are by no means living fossils as their genomes continued to evolve at the DNA level under selective pressure at rates comparable to the Neognathae branch of living birds, though there is some controversy about the precise relationship between them and the other birds. There are also several other scientific controversies about their evolution (see below).


title: Palaeognathae

text: No unambiguously paleognathous fossil birds are known until the Cenozoic (though birds occasionally interpreted as lithornithids occur in Albian appalachian sites ), but there have been many reports of putative paleognathes, and it has long been inferred that they may have evolved in the Cretaceous. Given the northern hemisphere location of the morphologically most basal fossil forms (such as "Lithornis", "Pseudocrypturus", "Paracathartes" and "Palaeotis"), a Laurasian origin for the group can be inferred. The present almost entirely Gondwanan distribution would then have resulted from multiple colonisations of the southern landmasses by flying forms that subsequently evolved flightlessness, and in many cases, gigantism.


title: Palaeognathae

text: One study of molecular and paleontological data found that modern bird orders, including the paleognathous ones, began diverging from one another in the Early Cretaceous. Benton (2005) summarized this and other molecular studies as implying that paleognaths should have arisen 110 to 120 million years ago in the Early Cretaceous. He points out, however, that there is no fossil record until 70 million years ago, leaving a 45 million year gap. He asks whether the paleognath fossils will be found one day, or whether the estimated rates of molecular evolution are too slow, and that bird evolution actually accelerated during an adaptive radiation after the Cretaceous–Paleogene boundary (K–Pg boundary).


title: Palaeognathae

text: Other authors questioned the monophyly of the Palaeognathae on various grounds, suggesting that they could be a hodgepodge of unrelated birds that have come to be grouped together because they are coincidentally flightless. Unrelated birds might have developed ratite-like anatomies multiple times around the world through convergent evolution. McDowell (1948) asserted that the similarities in the palate anatomy of paleognathes might actually be neoteny, or retained embryonic features. He noted that there were other feature of the skull, such as the retention of sutures into adulthood, that were like those of juvenile birds. Thus, perhaps the characteristic palate was actually a frozen stage that many carinate bird embryos passed through during development. The retention of early developmental stages, then, may have been a mechanism by which various birds became flightless and came to look similar to one another.


title: Palaeognathae

text: Hope (2002) reviewed all known bird fossils from the Mesozoic looking for evidence of the origin of the evolutionary radiation of the Neornithes. That radiation would also signal that the paleognaths had already diverged. She notes five Early Cretaceous taxa that have been assigned to the Palaeognathae. She finds that none of them can be clearly assigned as such. However, she does find evidence that the Neognathae and, therefore, also the Palaeognathae had diverged no later than the Early Campanian age of the Cretaceous period.


title: Palaeognathae

text: "Vegavis" is a fossil bird from the Maastrichtian stage of Late Cretaceous Antarctica. "Vegavis" is most closely related to true ducks. Because virtually all phylogenetic analyses predict that ducks diverged after paleognathes, this is evidence that paleognathes had already arisen well before that time.


title: Palaeognathae

text: An exceptionally preserved specimen of the extinct flying paleognathe "Lithornis" was published by Leonard et al. in 2005. It is an articulated and nearly complete fossil from the early Eocene of Denmark, and thought to have the best preserved lithornithiform skull ever found. The authors concluded that "Lithornis" was a close sister taxon to tinamous, rather than ostriches, and that the lithornithiforms + tinamous were the most basal paleognaths. They concluded that all ratites, therefore, were monophyletic, descending from one common ancestor that became flightless. They also interpret the paleognath-like "Limenavis", from Early Cretaceous Patagonia, as possible evidence of a Cretaceous and monophyletic origin for paleognathes.


title: Palaeognathae

text: Mysterious large eggs from the Pliocene of Lanzarote in the Canary Islands have been attributed to ratites.


title: Palaeognathae

text: An ambitious genomic analysis of the living birds was performed in 2007, and it contradicted Leonard et al. (2005). It found that tinamous are not primitive within the paleognathes, but among the most advanced. This requires multiple events of flightlessness within the paleognathes and partially refutes the Gondwana vicariance hypothesis (see below). The study looked at DNA sequences from 19 loci in 169 species. It recovered evidence that the paleognathes are one natural group (monophyletic), and that their divergence from other birds is the oldest divergence of any extant bird groups. It also placed the tinamous within the ratites, more derived than ostriches, or rheas and as a sister group to emus and kiwis, and this makes ratites paraphyletic.


title: Palaeognathae

text: A related study addressed the issue of paleognath phylogeny exclusively. It used molecular analysis and looked at twenty unlinked nuclear genes. This study concluded that there were at least three events of flightlessness that produced the different ratite orders, that the similarities between the ratite orders are partly due to convergent evolution, and that the Palaeognathae are monophyletic, but the ratites are not.


title: Palaeognathae

text: Beginning in 2010, DNA analysis studies have shown that tinamous are the sister group to extinct moa of New Zealand.


title: Palaeognathae

text: A 2020 molecular study of all bird orders found Palaeognaths to have diverged in the Late Cretaceous or earlier, before 70 million years ago. However, all modern orders only originated in the latest Paleocene and afterwards, with ostriches diverging in the latest Paleocene, rheas in the early Eocene, kiwis (and presumably elephant birds) very shortly after in the early Eocene, and finally Casuariiformes and tinamous (and presumably moas) diverging from one another in the mid-Eocene.


title: Palaeognathae

text: In the history of biology there have been many competing taxonomies of the birds now included in the Palaeognathae. The topic has been studied by Dubois (1891), Sharpe (1891), Shufeldt (1904), Sibley and Ahlquist (1972, 1981) and Cracraft (1981).


title: Palaeognathae

text: Merrem (1813) is often credited with classifying the paleognathes together, and he coined the taxon "Ratitae" (see above). However, Linnaeus (1758) placed cassowaries, emus, ostriches, and rheas together in "Struthio". Lesson (1831) added the kiwis to the Ratitae. Parker (1864) reported the similarities of the palates of the tinamous and ratites, but Huxley (1867) is more widely credited with this insight. Huxley still placed the tinamous with the Carinatae of Merrem because of their keeled sterna, and thought that they were most closely related to the Galliformes.


title: Palaeognathae

text: Pycraft (1900) presented a major advance when he coined the term Palaeognathae. He rejected the Ratitae-Carinatae classification that separated tinamous and ratites. He reasoned that a keelless, or "ratite", sternum could easily evolve in unrelated birds that independently became flightless. He also recognized that the ratites were secondarily flightless. His subdivisions were based on the characters of the palatal skeleton and other organ systems. He established seven roughly modern orders of living and fossil paleognaths (Casuarii, Struthiones, Rheae, Dinornithes, Aepyornithes, Apteryges, and Crypturi – the latter his term for tinamous, after the Tinamou genus "Crypturellus").


title: Palaeognathae

text: The Palaeognathae are usually considered a superorder, but authors have treated them as a taxon as high as subclass (Stresemann 1927–1934) or as low as an order (Cracraft 1981 and the IUCN, which includes all palaeognaths in "Struthioniformes").


title: Palaeognathae

text: Cloutier, A. "et al". (2019) in their molecular study places ostriches as the basal lineage with the rhea as the next most basal.


title: Palaeognathae

text: An alternative phylogeny was found by Kuhl, H. "et al." (2020). In this treatment, all members of Palaeognathae are classified in Struthioniformes, but they are still shown as distinct orders here.


title: Palaeognathae

text: Paleognathes are named for a characteristic, complex architecture of the bones in the bony palate. Cracraft (1974) defined it with five characters.


title: Palaeognathae

text: Paleognathes share similar pelvis anatomy. There is a large, open ilio–ischiatic fenestra in the pelvis. The pubis and ischium are likely to be longer than the ilium, protruding out beneath the tail. The postacetabular portion of the pelvis is longer than the preacetabular portion.


title: Palaeognathae

text: Paleognathes share a pattern of grooves in the horny covering of the bill. This covering is called the rhamphotheca. The paleognath pattern has one central strip of horn, with long, triangular, strips to either side.


title: Palaeognathae

text: In Paleognathes, the male incubates the eggs. The male may include in his nest the eggs of one female or more than one. He may also have eggs deposited in his nest by females that did not breed with him, in cases of nest parasitism. Only in ostriches and the great spotted kiwi does the female also assist in incubating the eggs.


title: Palaeognathae

text: The tinamous of Central and South America are primarily terrestrial, though they fly weakly. Tinamous have very short tail feathers, giving them an almost tailless aspect. In general, they resemble galliform birds like quails and grouse.


title: Palaeognathae

text: Tinamous have a very long, keeled, breastbone with an unusual three-pronged shape. This bone, the sternum, has a central blade (the Carina sterni), with two long, slender lateral trabeculae, which curve to either side and nearly touch the keel posteriorly. These trabeculae may also be thought of as the rims of two large foramina that incise the posterior edge of the sternum, and extend almost its whole length. Tinamous have a proper semicircular furcula, with no trace of a hypocleidium. There is an acute angle between the scapula and coracoid, as in all flying birds. The pelvis has an open ilio–ischiatic fenestra that incises the posterior edge between the ilium and ischium, as in all paleognathes. Tinamous have no true pygostyle, their caudal vertebrae remain unfused, as in ratites.


title: Palaeognathae

text: Tinamou feathers look like those of volant birds in that they have a rachis and two vanes. The structure of tinamou feathers is unique, however, in that they have barbs that remain joined at their tips. Thus the parallel barbs are separated only by slits between them.


title: Palaeognathae

text: Ratite birds are strictly flightless and their anatomy reflects specializations for terrestrial life. The term "ratite" is from the Latin word for raft, "ratis", because they possess a flat breastbone, or sternum, shaped like a raft. This characteristic sternum differs from that in flighted birds, where the pectoral musculature is disproportionately large to provide the power for wingbeats and the sternum develops a prominent keel, or carina sterni to anchor these muscles. The clavicles do not fuse into a furcula. Instead, if present at all, each is splint-like and lies along the medial border of the coracoid, attached there by a coraco–clavicular ligament. There is an obtuse angle between the scapula and coracoid, and the two bones fuse together to form a scapulocoracoid. Ratites have reduced and simplified wing structures and strong legs. Except in some rhea wing feathers, the barb filaments that make up the vanes of the feathers do not lock tightly together, giving the plumage a shaggier look and making it unnecessary to oil their feathers. Adult ratites have no preen gland (uropygial gland) that contains preening oil.


title: Palaeognathae

text: Paleognaths as a whole tend to have proportionally small brains, and are among the living birds with the most limited cognitive abilities. Kiwis are exceptional, however, and have large brains comparable to those of parrots and songbirds, though evidence for similar levels of behaviour complexity is currently lacking.


title: Palaeognathae

text: Living members of Palaeognathae range from to and weight can be from . Ostriches are the largest struthioniforms (members of the order Struthioniformes), with long legs and neck. They range in height from and weigh from . They have loose-feathered wings. Males have black and white feathers while the female has grayish brown feathers. They are unique among birds in that they retain only the third and fourth toe on each foot. Ostrich wings have claws, or unguals, on the first and second fingers (and, in some individuals, also on the third). Ostriches differ from other paleognathes in that they have a reduced vomer bone of the skull.


title: Palaeognathae

text: Rheas are and weigh . Their feathers are gray or spotted brown and white. They have large wings but no tail feathers. They have no clavicles.


title: Palaeognathae

text: Cassowaries are in height and weigh . They have rudimentary wings with black feathers and six stiff, porcupine-like, quills in the place of their primary and secondary feathers.


title: Palaeognathae

text: Kiwis are the smallest of ratites, ranging in height from and weight . They have shaggy brown feathers.


title: Palaeognathae

text: Many of the larger ratite birds have extremely long legs and the largest living bird, the ostrich, can run at speeds over 35 mph (60 km/h). Emus have long, strong legs and can run up to . Cassowaries and rheas show a similar likeness in agility and some extinct forms may have reached speeds of 45 mph (75 km/h).


title: Palaeognathae

text: Today, the ratites are largely restricted to the Southern Hemisphere, though across the Cenozoic they were also present in Europe, North America and Asia. In the Cretaceous, these southern continents were connected, forming a single continent called Gondwana. Gondwana is the crucial territory in a major scientific question about the evolution of Palaeognathae, and thus about the evolution of all of the Neornithes.


title: Palaeognathae

text: There are two theories regarding the evolution of paleognathes. According to the Gondwana vicariance hypothesis, the paleognathes evolved once, from one ancestor, on Gondwana during the Cretaceous, and then rode on the daughter landmasses that became today's southern continents. This hypothesis is supported most strongly by molecular clock studies, but it is weakened by the lack of any Cretaceous or southern fossil paleognaths, as well as the early radiation of paleognaths in Laurasian landmasses. According to the Tertiary radiation hypothesis, they evolved after the Cretaceous–Paleogene extinction event from multiple flying ancestors on multiple continents around the world. This hypothesis is supported by molecular phylogeny studies and matches the fossil record, but it is weakened by morphological phylogenetic studies. Both hypotheses have been supported and challenged by many studies by many authors.


title: Palaeognathae

text: A 2016 study of both genetic and morphological divergence concludes that the group had a Laurasian origin.


title: Palaeognathae

text: Cracraft (2001) gave a comprehensive review to the data and strongly supported the Gondwana vicariance hypothesis with phylogenetic evidence and historical biogeography. He cites molecular clock studies that show a basal divergence date for neornithes being around 100 Mya. He credits the authors of the molecular clock studies with the observation that the lack of southern paleognath fossils may correspond to the relatively scarce southern Cretaceous deposits, and the relative lack of paleontological field work in the southern hemisphere. Moreover, Cracraft synthesizes the morphological and molecular studies, noting conflicts between the two, and finds that the bulk of the evidence favors paleognath monophyly. He also notes that not only the ratites, but other basal groups of neognathous birds, show trans-Antarctic distribution, as would be expected if the paleognaths and neognaths had diverged in Gondwana.


title: Palaeognathae

text: Geological analyses have suggested that New Zealand may have been entirely under water as recently as 28 Mya, making it impossible for flightless birds to have survived. However, the discovery of a "Sphenodon" fossil dating to the Early Miocene 19–16 Mya raises question as to whether the island mass was completely submerged. This finding offers further evidence that ancient "Sphenodon" species lived on some portion of the land mass since it separated from Gondwana approximately 82 Mya. Evidence of a sea level rise submerging much of New Zealand is generally accepted, but there is a debate about how much of New Zealand was submerged. A "Sphenodon" species surviving on a remnant part of the island suggests that larger species may have survived as well.


title: Palaeognathae

text: Ultimately, the earliest recorded paleognaths are flying, presumably plesiomorphic lithornithids, found quite possibly as early as the Late Cretaceous in North America, while some of the earliest flightless ratites occur in Europe. The vicariance hypothesis relies on the assumption southern landmasses were more relevant to ratite evolution than the northern ones.


title: Palaeognathae

text: Feduccia (1995) emphasized the extinction event at the Cretaceous-Paleogene boundary as the probable engine of diversification in the Neornithes, picturing only one or very few lineages of birds surviving the end of the Cretaceous. He also noted that birds around the world had developed ratite-like anatomies when they became flightless, and saw the affinities of modern ratites, especially kiwis, as ambiguous. In this emphasis on the Cenozoic, rather than Cretaceous period, as the time of basal divergences between neornithines, he follows Olson.


title: Palaeognathae

text: Houde demonstrated that the Lithornithiformes, a group of flying birds that were common in the Cenozoic of the northern hemisphere, were also paleognaths. He argues that the lithornithiform bird "Paleotis", known from fossils in Denmark (northern hemisphere), shared unique anatomical features of the skull that make it a member of the same order as the ostriches. He also argued that the kiwis should not have reached New Zealand, which moved away from the mainland in the Early Cretaceous, if their ancestor was flightless; this claim at least has been vindicated by the discovery of the possibly volant "Proapteryx". He therefore deduced that lithornithiform ancestors could have reached the southern continents some 30 to 40 million years ago, and evolved flightless forms which are today's ratites. This hypothesis is contradicted by some later molecular studies, but supported by others.


title: Palaeognathae

text: The human lineage evolved in Africa in sympatry with ostriches. After "Homo" appeared and left Africa for other continents, they continued to encounter ostriches in Arabia and much of southern and central Asia. No contact was made with other palaeognath genera until the Papuan and Aboriginal Australian peoples populated New Guinea and Australia. Subsequently, Paleo-Indians encountered tinamous and rheas in Central and South America, Austronesian settlers encountered and exterminated the elephant birds of Madagascar, and the Maori did likewise to the moa of New Zealand. The giant ratites of Madagascar and New Zealand had evolved with little or no exposure to mammalian predators, and were unable to cope with predation by humans; many other oceanic species met the same fate (as apparently had the Australian dromornithids earlier). Worldwide, most giant birds became extinct by the end of the 18th century and most surviving species are now endangered and/or are decreasing in population. However, the co-existence between elephant birds and human beings appears to have been longer than previously thought.


title: Palaeognathae

text: Today, ratites such as the ostrich are farmed and sometimes even kept as pets. Ratites play a large role in human culture; they are farmed, eaten, raced, protected, and kept in zoos.


title: Planet of the Apes (TV series)

text: Planet of the Apes is a 1974 American science fiction television series that was broadcast on CBS. The series features Ron Harper, James Naughton, Roddy McDowall, Mark Lenard, and Booth Colman. It is based on the 1968 movie "Planet of the Apes" and its sequels, which were, in turn, based on the 1963 novel "La Planète des singes" (translated as "Planet of the Apes") by Pierre Boulle.


title: Planet of the Apes (TV series)

text: The series begins with the crash of an Earth spaceship that encountered a time warp while approaching Alpha Centauri on August 19, 1980. The spaceship is crewed by three astronauts, one of whom has died in the crash. The other two astronauts, Colonel Alan Virdon and Major Peter J. Burke, are unconscious but are rescued by a old man who carries them to an old bomb shelter. After the old man opens a book containing historical text and pictures of Earth circa 2500, the two astronauts are convinced that they are indeed on a future Earth.


title: Planet of the Apes (TV series)

text: The crash is also witnessed by a young chimpanzee who tells his father, a village official who alerts the authorities. Ape councilor Zaius (an analog of the character from the original movie), notes that another such incident occurred ten years earlier. He orders the chief gorilla, Security Chief Urko, to find the humans and bring them back alive. Zaius wants to find out as much as he can about the humans before they are eventually killed. Zaius doesn't trust Urko to follow his orders and bring back any surviving humans, so he sends along his newly hired chimpanzee assistant, Galen.


title: Planet of the Apes (TV series)

text: Both Virdon and Burke go back to their ship to check the ship's chronometer. They are more than 1000 years in the future from when they left Earth. Virdon insists on retrieving the ship's flight log in the hopes that they will be able to analyze it and be able to return to their own time period, but while they are at the ship, they are captured, and the old man is subsequently killed by a group of apes.


title: Planet of the Apes (TV series)

text: Galen finds the human book that the old man had been carrying. He reads parts of the book and begins to doubt the history that he has been told: apes have always been dominant, and humans have always been inferior and subservient. When Galen finds out that Urko has arranged for the two astronauts to escape and be killed in the attempt, he stops the shooter and helps the humans escape. During the escape, a guard is killed, and Galen is found standing over him with a gun in his hand.


title: Planet of the Apes (TV series)

text: Galen discusses the book that he found with Zaius, who then accuses him of heresy. Galen is sentenced to death for his crime. Then Virdon and Burke find out about his sentence and rescue Galen. They are all then declared enemies of the state and become fugitives. The three fugitives thereafter wander around the territory that used to be the western United States having various encounters with apes, humans, and old human civilization ruins.


title: Planet of the Apes (TV series)

text: Discussions for a "Planet of the Apes" television series were made by producer Arthur P. Jacobs as early as 1971. Because of the success of the movies, the idea of a television series was delayed until after the completion of "Battle for the Planet of the Apes" during the first half of 1973. However, soon after the premiere of "Battle", Jacobs died, and his production company APJAC Productions sold all "Planet of the Apes" rights and privileges to 20th Century Fox. Subsequently, television rights for the first three "Planet of the Apes" movies were sold to CBS and broadcast successfully during September 1973. Based largely on high viewership of "movie-of-the-week" television broadcasts of the first few movies, CBS began to disfavor other contenders for a new science-fiction series, including Gene Roddenberry's "Genesis II" (1973) and favor proposals for a "Planet of the Apes" television series. Fox and CBS then continued Jacob's plans of a series the next year.


title: Planet of the Apes (TV series)

text: CBS ordered 14 episodes of "Planet of the Apes" to be produced. The series was filmed for the most part on location at what is now Malibu Creek State Park, with a budget of about $250,000 for each episode. Originally scheduled to be broadcast during CBS's Tuesday night family hour, the first regular episode of the series was broadcast on Friday, September 13, 1974 from 8:00-9:00 PM. The remainder of the series was broadcast during this same time slot until December 27, 1974, when its 14th and final broadcast was shown as a result of a premature cancellation of the series due to poor ratings.


title: Planet of the Apes (TV series)

text: The series' main theme music was composed by Lalo Schifrin; Schifrin also scored three episodes of the series - "Escape From Tomorrow," "The Gladiators" and "The Good Seeds" (the latter, though not the premiere episode, was the first to be scored). Earle Hagen composed the scores for "The Legacy" and "Tomorrow's Tide," while Richard LaSalle wrote an original score for "The Trap." In addition, three episodes received partial scores - Hagen composed one for "The Surgeon," LaSalle composed "The Deception," and music supervisor Lionel Newman composed his only music for the series with "The Interrogation" (those last three, like the other episodes, were otherwise tracked with the music composed previously).


title: Planet of the Apes (TV series)

text: In 2005, Intrada released an album featuring Lalo Schifrin's beginning and ending music along with all three of Schifrin's scores and Earle Hagen's "The Legacy." The album also includes the logo music for Twentieth Century-Fox Television by Alfred Newman.


title: Planet of the Apes (TV series)

text: In 2015, La-La Land Records issued a remastered and expanded limited edition album, featuring all six original scores plus the Newman material.


title: Planet of the Apes (TV series)

text: The scripts for "Episode One", "Episode Two", "Hostage" and "A Fallen God" are available online at Hunter's Planet of the Apes Archive. Details regarding "The Trek," "Freedom Road," "The Mine," and "The Trial" were provided in issue 12 of Simian Scrolls (a Planet of the Apes-based magazine), reprinted from the television series writer's bible.


title: Planet of the Apes (TV series)

text: The series was broadcast in the U.S. from September 13 to December 20, 1974. The show was canceled after half a season because of poor ratings due at least partly to direct competition by NBC's "Sanford and Son" and "Chico and the Man". Only thirteen of its fourteen episodes were broadcast; all 14 episodes were later included in the DVD box set. It was later shown in reruns on the Sci Fi Channel. It also appeared on Monday nights on the Seven Network in Australia during 1975, then was repeated at 7:30pm Saturday evenings from 3 January 1976 and this was followed by subsequent screenings.


title: Planet of the Apes (TV series)

text: The series was broadcast in Britain by 13 of the 14 ITV companies from 13 October 1974 each Sunday, until 18 January 1975. Scottish Television (STV) never broadcast it during 1974/75, opting to broadcast "Sale of the Century" instead. The show was repeated in many regions from September 1975 until 1978, but was still not broadcast by STV. The series then received its first UK-wide transmissions on Channel 4 in 1994, and later the Sci Fi Channel. The television movie compilations have also been screened on Sky Movies, True Movies, True Entertainment (which also broadcast the show in original form) and Horror Channel.


title: Planet of the Apes (TV series)

text: During 2019, MeTV began broadcasting the series as part of its late Saturday Night "Red Eye Sci-Fi" block.


title: Planet of the Apes (TV series)

text: When the "Planet of the Apes" telefilms began syndication, ABC's owned and operated stations, who bought them for their afternoon movie programs (with titles such as ""), asked Roddy McDowall to re-create his role of Galen in a series of new beginnings and endings specifically for these stations, billed as "The New Planet of the Apes". The introductions created originally by 20th Century Fox to begin each film were replaced by a now-aged Galen (McDowall) examining the events of the telefilms. The beginnings and endings revealed Virdon and Burke's final fates: "They found their computer in another city and disappeared into space as suddenly as they’d arrived". According to "TV Zone Special #17" (1995 issue) McDowall filmed these "two years after the demise of the first run episodes of the Planet of the Apes television series", which would be December 1976. The ABC openings and closings of these telefilms were neither broadcast by other stations nor included on any home media release.


title: Planet of the Apes (TV series)

text: Most of the books and comics based on "Planet of the Apes" are based on the movies, not the television series. However, there are some titles that do involve the television show characters:


title: Planet of the Apes (TV series)

text: Novelizations: Four novelizations of episodes, written by George Alec Effinger, were published by Award Books. Their titles are:


title: Planet of the Apes (TV series)

text: British Annuals: Brown Watson Books published three hardcover annuals featuring original stories about Virdon, Burke and Galen. These stories are a combination of comic strips and short fiction.


title: Planet of the Apes (TV series)

text: Argentine Comics: Seven Spanish-language comics were published in Argentina, written by Jorge Claudio Morhain and Richard Barreiro and illustrated by Sergio Mulko and T. Toledo. Released only in Argentina, they have never been published officially in English. However, PDFs of the comics, translated to English by fans, are available at Kassidy Rae's site (see link below).


title: Planet of the Apes (TV series)

text: Filmstrip Story: Chad Valley, a U.K. toy company, produced 32 short film-based comic strips containing an original TV-series-era story, presented as the Chad Valley Picture Show Planet of the Apes Sliderama Projector (very similar to the many Give-a-Show projector sets of the 1970s). These strips are extremely rare and difficult to find.


title: Planet of the Apes (TV series)

text: Audio Adventures—Power Records produced four audio-only adventures based on the TV show. Their titles were:


title: Dana Winner

text: In 1990 she released her first single "Op het dak van de wereld", (Dutch: "On the roof of the world"), a cover of The Carpenters' "Top of the World" from 1973. In 1993 she became really popular with "Woordenloos" (Dutch: "Without words"). However, it was only in 1995 that she released her only hit single so far to reach the Dutch Top 40, "Westenwind". This was a cover of the former hit "One Way Wind" by the Volendam group The Cats.


title: Dana Winner

text: After her first success, Dana Winner also became well known in Germany and South Africa. At the end of the 1990s, she began singing in other languages and did not release an album in Dutch between 2000 and 2006.


title: The Valley (London)

text: The Valley is a 27,111 capacity sports stadium in Charlton, London, England and has been the home of Charlton Athletic Football Club since the 1920s, with a period of exile between 1985 and 1992. It is served by Charlton railway station, which is less than a five-minute walk away from the stadium. An alternative route is the Jubilee line; exiting at North Greenwich, and changing for route 161, 472 and 486 buses, which stop outside the stadium.


title: The Valley (London)

text: In Charlton's early years, the club had a nomadic existence using several different grounds between its formation in 1905 and the beginning of World War I in 1914. The ground dates from 1919, at a time when Charlton were moderately successful and looking for a new home. The club found an abandoned sand and chalk pit in Charlton, but did not have sufficient funds to fully develop the site. An army of volunteer Charlton supporters dug out a flat area for the pitch at the bottom of the chalk pit and used the excavated material to build up makeshift stands. The ground's name most likely comes from its original valley-like appearance. The club played its first game at the ground before any seats, or even terraces, were installed; there was simply a roped-off pitch with the crowd standing or sitting on the adjoining earthworks. The unique circumstances of the ground's initial construction led to an unusually intense bond between the club's supporters and the site that exists to this day. In the 1923–24 season, Charlton played at The Mount stadium in Catford but in a much more highly populated area. A proposed merger with Catford South End FC fell through and thus Charlton moved back to the Valley.


title: The Valley (London)

text: In 1967, Len Silver the promoter at Hackney made an application to open Charlton as a British League speedway club, and plans were put forward to construct a track around the perimeter of the football pitch. The application to include speedway at the Valley was enthusiastically supported initially, but was eventually ruled out on the grounds of noise nuisance.


title: The Valley (London)

text: For many years, the Valley was one of the largest Football League grounds in Britain, although its highest maximum capacity of 75,000 was only half the capacity of Glasgow's Hampden Park. However, Charlton's long absence from the top level of English football prevented much-needed renovation, as funds dried up and attendances fell. Charlton were relegated from the First Division in 1957 and did not return until 1986, and in 1972 were relegated to the Third Division for the first time in the postwar era.


title: The Valley (London)

text: Eventually, the club's debts led to it almost going out of business in the early 1980s. A consortium of supporters successfully acquired the club in 1984, but the Valley remained under the ownership of the club's former owner. However, the club was unable to finance the improvements needed to make the Valley meet new safety requirements. Shortly after the start of the 1985–86 season, Charlton left the Valley, entering into an agreement with Crystal Palace to share the latter's Selhurst Park facilities, the first official groundsharing arrangement in the Football League in 36 years.


title: The Valley (London)

text: In 1988, the ownership of the club and the Valley was again united, and in a "grass roots" effort that harkened back to the ground's initial construction, thousands of supporters volunteered to clean the ground, eventually burning the debris in a huge bonfire on the pitch. By this time, however, the large terraces were no longer seen as desirable or safe. Charlton Athletic supporters then proposed to completely rebuild the stadium in order for Charlton to return there at the beginning of the 1990s. However, the Greenwich Borough Council overwhelmingly turned down plans to renovate the ground. Club supporters formed their own local political party, the Valley Party, in response to the council's decision. The party ran candidates for all but two Greenwich Council seats, sparing the two councillors who had approved the new stadium plans. The party won almost 15,000 votes in the 1990 local elections, successfully pressuring the council to approve the plans for the new stadium.


title: The Valley (London)

text: In 1991, construction began on the new Valley, and the club moved from Selhurst Park to West Ham's Upton Park. It was originally hoped that the club would return to the stadium before Christmas that year, but the re-opening of the stadium faced a series of delays before finally opening in December 1992. Since then, the ground itself has undergone some remarkable changes. The north, east and west sides of the ground have almost been completely rebuilt, giving the ground a capacity of over 27,000 by December 2001, when Charlton were in the second season of a stay in the FA Premier League which would last for seven seasons. The club have ambitions to extend the ground's capacity to over 40,000 by expanding the east side and completely rebuilding the south side, but it remains uncertain if or when the plans will be implemented after the club's relegation from the Premier League in 2007 and from the Championship two years later.


title: The Valley (London)

text: The North Stand was built as a replacement for the 'covered end', and is still called by this name. It was built during the 2001–02 season as part of the developments to bring the Valley's capacity to 26,500 after promotion to the Premier League in 2000. The North Stand houses the most vocal supporters in the ground in particular the upper tier alongside a drum, along with restaurants and executive suites.


title: The Valley (London)

text: The East Stand was constructed during the 1993–94 season and fully completed in 1994. As part of the first development to the ground since the return in 1992, it replaced the massive east terrace, which had remained closed and prohibited from use since the mid-1980s after the Bradford City stadium fire. The East Stand consists of a single tier of seats and houses the television gantry, and also has numerous executive boxes. Occasionally, for FA and League Cup matches, part of the East Stand is used to house away supporters if the demand for away team tickets is high. On 9 April 2021, the club announced that from the start of 2021/22 season, the stand would be renamed to the Alan Curbishley Stand in honour of the former player and manager and to celebrate the 30th anniversary of when Curbishley was appointed manager of the club - a role he held from 1991 to 2006.


title: The Valley (London)

text: The West Stand was built in 1998 after Charlton's first promotion to the Premier League and is also two tiered. This is the main stand at the Valley with the largest capacity, and also houses the club's offices, as well as the director's box, board room dug-outs, changing rooms and the commercial centre (ticket office). There are also many conferencing rooms in this stand which are used for official and community events. There is a large statue of Sam Bartram, (considered to be Charlton's finest player) at the entrance of the West Stand.


title: The Valley (London)

text: The Jimmy Seed (or South) Stand is the oldest part of the ground, and dates from the early 1980s. This stand is named after Charlton's manager, Jimmy Seed (1895–1966) – with whom Charlton won the FA Cup in 1947. This stand has a capacity of around 3,000 and hosts the away supporters at games. It is also the only part of the Valley with a supporting pillar.


title: The Valley (London)

text: The Valley's highest average attendance came in the 1948–49 season when crowds averaged 40,216, making Charlton one of only thirteen clubs in English football to achieve a seasonal average of 40,000+. The Valley's lowest average attendance is 5,108 from the 1984–85 season.


title: The Valley (London)

text: Average attendance for every season since 1993–94, the first full season since Charlton returned to the Valley.


title: The Valley (London)

text: <nowiki>**</nowiki>Due to the COVID-19 pandemic all home matches were played behind closed doors except for two matches which had limited crowds.


title: Design of the FAT file system

text: A FAT file system is a specific type of computer file system architecture and a family of industry-standard file systems utilizing it.


title: Design of the FAT file system

text: The FAT file system is a legacy file system which is simple and robust. It offers good performance even in very light-weight implementations, but cannot deliver the same performance, reliability and scalability as some modern file systems. It is, however, supported for compatibility reasons by nearly all currently developed operating systems for personal computers and many home computers, mobile devices and embedded systems, and thus is a well suited file system for data exchange between computers and devices of almost any type and age from 1981 through the present.


title: Design of the FAT file system

text: Originally designed in 1977 for use on floppy disks, FAT was soon adapted and used almost universally on hard disks throughout the DOS and Windows 9x eras for two decades. Today, FAT file systems are still commonly found on floppy disks, USB sticks, flash and other solid-state memory cards and modules, and many portable and embedded devices. DCF implements FAT as the standard file system for digital cameras since 1998. FAT is also utilized for the EFI system partition (partition type ) in the boot stage of EFI-compliant computers.


title: Design of the FAT file system

text: For floppy disks, FAT has been standardized as ECMA-107 and ISO/IEC 9293:1994 (superseding ISO 9293:1987). These standards cover FAT12 and FAT16 with only short 8.3 filename support; long filenames with VFAT are partially patented. According to Google Patents the status of "Common name space for long and short filenames" (US5758352A) was expired in 2019, which may mean that the patent has expired completely.


title: Design of the FAT file system

text: The name of the file system originates from the file system's prominent usage of an index table, the "File Allocation Table", statically allocated at the time of formatting. The table contains entries for each "cluster", a contiguous area of disk storage. Each entry contains either the number of the next cluster in the file, or else a marker indicating end of file, unused disk space, or special reserved areas of the disk. The "root directory" of the disk contains the number of the first cluster of each file in that directory; the operating system can then traverse the FAT table, looking up the cluster number of each successive part of the disk file as a "cluster chain" until the end of the file is reached. In much the same way, "sub-directories" are implemented as special files containing the "directory entries" of their respective files.


title: Design of the FAT file system

text: Originally designed as an 8-bit file system, the maximum number of clusters has been significantly increased as disk drives have evolved, and so the number of bits used to identify each cluster has grown. The successive major versions of the FAT format are named after the number of table element bits: 12 (FAT12), 16 (FAT16), and 32 (FAT32). Except for the original 8-bit FAT precursor, each of these variants is still in use. The FAT standard has also been expanded in other ways while generally preserving backward compatibility with existing software.


title: Design of the FAT file system

text: FAT uses little-endian format for all entries in the header (except for, where explicitly mentioned, for some entries on Atari ST boot sectors) and the FAT(s). It is possible to allocate more FAT sectors than necessary for the number of clusters. The end of the last sector of each FAT copy can be unused if there are no corresponding clusters. The total number of sectors (as noted in the boot record) can be larger than the number of sectors used by data (clusters × sectors per cluster), FATs (number of FATs × sectors per FAT), the root directory (n/a for FAT32), and hidden sectors including the boot sector: this would result in unused sectors at the end of the volume. If a partition contains more sectors than the total number of sectors occupied by the file system it would also result in unused sectors, at the end of the partition, after the volume.


title: Design of the FAT file system

text: On non-partitioned storage devices, such as floppy disks, the Boot Sector (VBR) is the first sector (logical sector 0 with physical CHS address 0/0/1 or LBA address 0). For partitioned storage devices such as hard disks, the Boot Sector is the first sector of a partition, as specified in the partition table of the device.


title: Design of the FAT file system

text: Common structure of the Boot Sector used by most FAT versions for IBM compatible x86 machines since DOS 2.0 are:


title: Design of the FAT file system

text: Common structure of the first 25 bytes of the BIOS Parameter Block (BPB) used by FAT versions since DOS 2.0 (bytes at sector offset to are stored since DOS 2.0, but not always used before DOS 3.2, values at to are used since DOS 3.0):


title: Design of the FAT file system

text: The following extensions were documented since DOS 3.0, however, they were already supported by some issues of DOS 2.11. MS-DOS 3.10 still supported the DOS 2.0 format, but could use the DOS 3.0 format as well.


title: Design of the FAT file system

text: Officially, MS-DOS 3.20 still used the DOS 3.0 format, but codice_1 and codice_2 were adapted to support a 6 bytes longer format already (of which not all entries were used).


title: Design of the FAT file system

text: Officially introduced with DOS 3.31 and not used by DOS 3.2, some DOS 3.2 utilities were designed to be aware of this new format already. Official documentation recommends to trust these values only if the logical sectors entry at offset is zero.


title: Design of the FAT file system

text: A simple formula translates a volume's given cluster number codice_3 to a logical sector number codice_4:


title: Design of the FAT file system

text: On unpartitioned media the volume's number of hidden sectors is zero and therefore codice_4 and codice_15 addresses become the same for as long as a volume's logical sector size is identical to the underlying medium's physical sector size. Under these conditions, it is also simple to translate between codice_16 addresses and codice_17 as well:


title: Design of the FAT file system

text: codice_18, where the sectors per track codice_19 are stored at offset , and the number of sides codice_20 at offset . Track number codice_21, head number codice_22, and sector number codice_23 correspond to Cylinder-head-sector: the formula gives the known CHS to LBA translation.


title: Design of the FAT file system

text: Further structure used by FAT12 and FAT16 since OS/2 1.0 and DOS 4.0, also known as Extended BIOS Parameter Block (EBPB) (bytes below sector offset are the same as for the DOS 3.31 BPB):


title: Design of the FAT file system

text: In essence FAT32 inserts 28 bytes into the EBPB, followed by the remaining 26 (or sometimes only 7) EBPB bytes as shown above for FAT12 and FAT16. Microsoft and IBM operating systems determine the type of FAT file system used on a volume solely by the number of clusters, not by the used BPB format or the indicated file system type, that is, it is technically possible to use a "FAT32 EBPB" also for FAT12 and FAT16 volumes as well as a DOS 4.0 EBPB for small FAT32 volumes. Since such volumes were found to be created by Windows operating systems under some odd conditions, operating systems should be prepared to cope with these hybrid forms.


title: Design of the FAT file system

text: Versions of DOS before 3.2 totally or partially relied on the media descriptor byte in the BPB or the FAT ID byte in cluster 0 of the first FAT in order to determine FAT12 diskette formats even if a BPB is present. Depending on the FAT ID found and the drive type detected they default to use one of the following BPB prototypes instead of using the values actually stored in the BPB.


title: Design of the FAT file system

text: Originally, the FAT ID was meant to be a bit flag with all bits set except for bit 2 cleared to indicate an 80 track (vs. 40 track) format, bit 1 cleared to indicate a 9 sector (vs. 8 sector) format, and bit 0 cleared to indicate a single-sided (vs. double-sided) format, but this scheme was not followed by all OEMs and became obsolete with the introduction of hard disks and high-density formats. Also, the various 8-inch formats supported by 86-DOS and MS-DOS do not fit this scheme.