title: Burning Love (TV series)

text: Depending on the season, the show either follows a man or a woman who is looking for the perfect mate from a pool of contestants, or has contestants living together in a mansion competing for a cash prize. Season one showcases fireman Mark Orlando (Ken Marino) as the bachelor. Season two of the series, which premiered in February 2013, stars June Diane Raphael reprising her role as season one contestant Julie, now the bachelorette given the chance to find the perfect man. Season three also premiered in 2013 and starred former contestants from seasons one and two competing for a $900 prize rather than for love (similar to "Bachelor" spin-off, "Bachelor Pad").


title: Burning Love (TV series)

text: The seasons of the show as listed do not match the internally referenced season chronology because of two fictitious seasons. Internally season one references the Joe Rutherford (Ben Stiller) season, and seasons two and three references the Annie (Abigail Spencer) season. Neither of these seasons was produced but occurred within the fiction of the show with events from those seasons being frequently mentioned during the course of various real episodes. Season three also announced a nonexistent season with superfan Hathwell Crisping.


title: Burning Love (TV series)

text: The first season of "Burning Love" had its worldwide television premiere on E! in Australia in January 2013 and E! in America on February 25, 2013. In Canada, the series premiered on Much; a sister to the local version of E!.


title: Burning Love (TV series)

text: The first season premiered in the UK on Netflix in October 2013, edited into a 110-minute movie. The second season premiered on Australia's E! in February 2014, with the third season premiering on March 6, 2014.


title: Burning Love (TV series)

text: Season one was released on DVD on November 12, 2013. A year later, seasons two and three were released together as a two-disc set on September 16, 2014.


title: Burning Love (TV series)

text: A French version of the series premiered on October 12, 2020 on Canal+. Titled "" ( "The Flame"), this version was created by Jérémie Galan, Florent Bernard and Jonathan Cohen, who also starred as the bachelor, Marc, in the first season. Ben Stiller is also one of the executive producers of this adaptation. The first season stars Leïla Bekhti, Adèle Exarchopoulos, Angèle, Géraldine Nakache and Pierre Niney. On October 27, 2020, it was renewed for a second season titled "" ( "The Torch: The Adventurers of Chupacabra"), a spoof of the french version of "Survivor". It premiered on May 23, 2022.


title: Hamnet (novel)

text: Hamnet is a 2020 novel by Maggie O'Farrell. It is a fictional account of Shakespeare's son, Hamnet, who died at age 11 in 1596.


title: Hamnet (novel)

text: In 2020, the book won the Women's Prize for Fiction and National Book Critics Circle Award for Fiction. The following year, it was named "Novel of the Year" at the Dalkey Literary Awards, was shortlisted for the Walter Scott Prize, and longlisted for the Andrew Carnegie Medal for Excellence in Fiction.


title: Hamnet (novel)

text: In 2023, a stage adaptation of the novel by Lolita Chakrabarti will premiere at the Royal Shakespeare Company in Stratford-upon-Avon re-opening the Swan Theatre since the COVID-19 pandemic.


title: Liz Lemon

text: Elizabeth Miervaldis Lemon is a fictional character and the protagonist of the American television series "30 Rock". She created and writes for the fictional comedy-sketch show "The Girlie Show" and later "TGS with Tracy Jordan".


title: Liz Lemon

text: She is portrayed by Tina Fey, who is also the creator of the series and its showrunner. Fey has received a Primetime Emmy Award, two Golden Globe Awards, four Screen Actors Guild Awards, and a Television Critics Association Award for her performance. She is also the first person to win a Critics' Choice, Golden Globe, Primetime Emmy, SAG, and TCA Award for a singular performance.


title: Liz Lemon

text: Liz Lemon was born in November 1970. Raised in the town of White Haven, Pennsylvania, Liz is the daughter and second child to Dick Lemon and Margaret Lemon (née Freeman). Liz's parents are outwardly very optimistic and supportive of her, but privately they actually dislike many of their daughter's attributes and life decisions, as revealed during the climax of "Ludachristmas". On Saturday, December 6, 1985, she made her one appearance as a varsity football player, having forced her high school to lift gender segregation. Though her parents displayed a supportive demeanor, they were too embarrassed to attend her game despite claiming to have been present. Liz's elder brother, Mitch, was the victim of a skiing accident the following day, when he was a high school senior. Afterwards, he experienced anterograde amnesia, remaining "stuck" in the day before the accident, thinking for the next 22 years that he was still 17 and that the year was still 1985. In the episode "The Moms", her mother is said to have worked as a secretary at Sterling Cooper and to have "repeatedly lost [her] virginity" to Buzz Aldrin while the town pervert watched from the bushes.


title: Liz Lemon

text: In the season 3 finale, "Kidney Now!", it is revealed that Liz attended elementary school with musician and actress Sheryl Crow, co-starring with her as one of a pair of kidneys in a 5th grade musical. While Liz believes that the two were great friends, Crow only vaguely remembers her, and refers to Liz as a "loser".


title: Liz Lemon

text: She first saw Jack Donaghy and Tracy Jordan, and spoke with Jack telephonically, in 1986 while watching a live telethon alone in her parents' basement on prom night. Immediately after church choir member Tracy fell and realized his talent for getting laughs as a performer, Liz placed a prank call to the pledge line which was answered by Jack, then a young executive from GE's poisons division. Liz claimed to have been a nurse in the war, who was impregnated by General Electric when he was Colonel Electric. Jack's loyalty to GE and his handsomeness impressed Don Geiss, who transferred Jack to the microwave ovens division.


title: Liz Lemon

text: Liz was inspired to become a writer by Rosemary Howard, the first female head writer of "Laugh-In". She mentioned that she used to teach improv to senior citizens. In high school, Liz believed that she was an unpopular "nerd" that all of her classmates picked on, only to learn two decades later at her 20-year high school reunion that she was, in fact, the universally disliked class bully. She attended the University of Maryland on a partial competitive jazz dance scholarship, studying theater tech and for which she still has an outstanding student loan. She spent her junior year abroad in Frankfurt, Germany, and speaks passable German, which is, in her opinion, "the most beautiful language in the world". She struggles somewhat with the language in "Episode 210", mixing up verbs and misunderstanding a group of German TV executives. In "Gentleman's Intermission" she tries to evade speaking with Avery Jessup on the phone by pretending to be German, but is caught out when Avery speaks fluent German in response. In "Larry King", she sings "99 Luftballons". Liz also has a longtime goal of learning Spanish, at which she eventually makes some progress during a period of community service in "Respawn."


title: Liz Lemon

text: In the episodes "Believe in the Stars" and "Cooter", Liz states that she did not lose her virginity until she was 25 (this would be in 1995 or 1996).


title: Liz Lemon

text: Liz met Jenna Maroney in 1993, when Jenna was studying voice at Northwestern University. By Liz's own words, Jenna was "slutting it up" to get car dealership owners to put her in their commercials. The two shared an apartment in a Chicago neighborhood called "Little Armenia", and together they dreamed of "making it big". While in Chicago, Liz reportedly tried to be an actress, but the only job she was able to book was a phone sex line commercial. Liz and Jenna began "The Girlie Show" at Second City. They worked for years to turn "The Girlie Show" into a television series, which NBC picked up (though only to quell the outrage of women's groups over the misogynistic show "Bitch Hunter"), resulting in the pair moving to New York City for it. Liz became the head writer for "The Girlie Show", while Jenna became the show's main star.


title: Liz Lemon

text: In the pilot, it is announced that Liz's former boss Gary has died and Jack Donaghy takes his place. Neither Jack nor Liz recognizes the other from their brief conversation twenty years earlier. Jack immediately decides to retool the show to make it appeal to a larger demographic, starting by firing Liz's trusted producer Pete Hornberger in order to make room in the budget to hire unpredictable actor Tracy Jordan as the show's new star. Liz manages to convince Jack to re-hire Pete, but Jack is insistent on making the show center around Tracy and, much to her chagrin, he renames the show "TGS with Tracy Jordan".


title: Liz Lemon

text: Since 2005, Liz has lived in an apartment at 160 Riverside Drive (which changes to 168 Riverside Drive in later seasons; the building is fictional, but the address corresponds to the block between 88th and 89th Streets); her apartment number is 3B. When the building is converted to condominiums, Liz purchases both 3B and 4B with her earnings from "Dealbreakers", with the encouragement of both Jack and Jenna. ("Sun Tea")


title: Liz Lemon

text: Liz has also evidently won at least one Emmy Award. In addition to her responsibilities behind the camera, Liz occasionally acts in "TGS" sketches.


title: Liz Lemon

text: Throughout the seasons, several people have questioned Liz's gender. She always replies that she is really a girl and "that doctor was a quack." She serves as best man at the weddings of both her former sex partner Grizz and her mentor Jack (accidentally marrying him in the process). When Gretchen Thomas tells Jack she thinks Liz looks like Jennifer Jason Leigh, Jack initially assumes she means Jason Lee. She also once demonstrates that she is easily able to grow a moustache (which she calls "Tom," in reference to the famous Mr. Selleck) in less than 48 hours.


title: Liz Lemon

text: After "TGS" is cancelled, Liz tries being a stay-at-home mother to her newly adopted children, while her husband Criss works as a dental receptionist. Both soon recognize that they are ill-suited to those roles, and that Liz has considerably greater earning power. With Criss taking care of Terry and Janet, Liz takes over as producer of former lover Griz's series, "Griz & Herz". The children visit her on-set.


title: Liz Lemon

text: In the final episode, as a nod to "St. Elsewhere"s finale, "The Last One" (complete with a replica of the series' namesake building in a snow-globe stared at by a mentally challenged male), Liz's life serves as the inspiration for a sitcom that is pitched by her great-granddaughter 100 years in the future. The series is green-lighted by immortal NBC president Kenneth Parcell ("Last Lunch") – even though the series includes every one of the banned features on the list which Kenneth gave to Liz when beginning his tenure in "Hogcock!".


title: Liz Lemon

text: After a mere glance at her in the pilot, Jack sums up Liz as a "New York third-wave feminist, college-educated, single-and-pretending-to-be-happy-about-it, over-scheduled, undersexed, you buy any magazine that says 'healthy body image' on the cover and every two years you take up knitting for...a week". This is confirmed by Pete to be accurate, commenting that the "knitting" part, in particular, was uncanny.


title: Liz Lemon

text: Liz is generally portrayed as something of a "geek". So, while she is an apparently skilled writer, she seems to have very few social skills (in "Rosemary's Baby", Jack describes her as "socially retarded"). For example, while she was trying to pick up men at a karaoke bar, a man asked her if the seat next to her was taken, leading her to ask him why she should have to move her coat just so he could sit there. Liz is often shown to be generally insecure and holds a strong concern for how she is perceived by others. Liz is sometimes dismissive of others, a personality flaw that can be connected to her lack of social skills. Assessing Liz's personality up to near the end of season 3, Jonah Weinerslav described her as "an eternal 13-year-old tomboy—scared of sex, obsessed with "Star Wars" and meatball subs" and as "cling[ing] to a fantasy of presexual, junk-food-munching adolescence".


title: Liz Lemon

text: Liz has a rather satirical sense of humor. She has frequently been shown to be a stress eater, a trait she shares with Jack. Despite the fact that she often ingests high-amounts of junk food on a daily basis, she seems to keep her weight under control, perhaps because she does not seem to have proper meals. According to Fey, the character is not bulimic; "she just likes to eat". Liz does have some knowledge of cooking, though she admits to only using her oven to warm her jeans in the morning. She is allergic to both dogs and cats, as well as "anything warm and adorable". However, she does believe her allergy to dogs is psychosomatic, as she mentions that a dog bit her during the time of her first period.


title: Liz Lemon

text: Like Fey, Liz is a big fan of the "Star Wars" film franchise, often using events from the original trilogy to explain her feelings and actions in daily life. For example, in the episode "Jack the Writer", she compares Jack to the Sith lord Darth Vader, and contemplates that entering his office is like "stepping onto the Death Star". In "The Source Awards", Liz mentions that for the four past Halloweens in a row, she has dressed up as Princess Leia. She has also dressed as the character during jury selection in order to be disqualified from serving. Liz considers "" to be the worst film of the series. Criss Chros proved his love for her when responding to her "I love you", with "I know", quoting Han Solo's response to Leia in "The Empire Strikes Back". Facing the improbability that she will ever have a daughter, Liz offers the child-sized Leia costume which she had bought sometime in the past, to Jack for his daughter Liddy. Eventually, in "Mazel Tov, Dummies!", Liz gets married wearing a Princess Leia dress with which she had replaced her earlier, highly flammable costume after inadvertently setting it alight in "The Funcooker". She imitates Yoda in response to Jack's lamentations in "Hogcock!"


title: Liz Lemon

text: She is also a fan of the television series "Heroes", in which her favorite character is Hiro Nakamura, "Lost", "Little People, Big World", "Ugly Betty","Top Chef", "Designing Women", "NCIS," and "The Daily Show". Her favorite drink is white wine with ice cubes and Sprite, a blend she calls "Funky Juice". She is obsessed with men in green tights. As of "Cleveland", her ringtone is "Ride of the Valkyries", which she and Jenna consider a reference to "What's Opera, Doc?". Her ringtone for "Future Husband" is "Fuck the Pain Away" by Peaches.


title: Liz Lemon

text: In the episode "The Fabian Strategy", Liz reveals that the three things she likes in the world are Ina Garten, "sweater weather", and when Muppets present at awards shows. Over the course of the series she has shown an aversion to exposing her feet under any circumstances, except when she mistakenly believed that Oprah Winfrey counted high-heeled flip-flops among her new "favorite things". She usually prefers sex to be either non-existent, fast or "only on Saturdays".


title: Liz Lemon

text: Liz appears to be a Philadelphia Phillies fan. In "Reaganing", it is mentioned that at nine years old, she sported a Pete Rose inspired haircut and had posters of Mike Schmidt and Tug McGraw in her bedroom. These three players were active with the Phillies during this period. It is also noted that she uses a "Phillies Sport Wallet" in "It's Never Too Late For Now". In the season 6 finale "What Will Happen to the Gang Next Year?" Liz tells Jack that in payment for officiating at his and Avery's renewal of vows, "I get your Yankees tickets on A-Rod bobble head day. And I'm going to throw that thing in front of a train. Go Phillies!"


title: Liz Lemon

text: By "Christmas Attack Zone", Liz has learned the meanings of body language through watching "The Mentalist" (due to her losing the remote control to her television, thus being unable to change the CBS channel it was on). Because of her newfound talent, she dubs herself "The MentaLiz". She is unaware at that time that "The Mentalist"s original Dutch version, "Van der Hoot: Psychische (De Mentalist)", was based upon Liz's subordinate Sue LaRoche-Van der Hout's former career as a police psychic.


title: Liz Lemon

text: In contrast with her friend and foil Jenna, Liz seems to have little interest in stereotypical female interests, such as fashion. In "Blind Date", her "bi-curious" shoes led Jack to erroneously believe she was gay, and set her up on a blind date with his friend Gretchen Thomas, the "brilliant plastics engineer/lesbian". Except when she is pressured to dress more femininely, Liz typically appears in casual, gender-neutral attire. In earlier episodes, she almost always wore plastic-rimmed glasses, though she started to wear them less frequently over the course of the series. Flashbacks reveal that she has worn glasses since she was around four or five years of age. However, according to Jenna in "The Rural Juror", she does not actually need glasses. (Tina Fey also does not need glasses, except to see far away.)


title: Liz Lemon

text: Some of Liz's social problems stem from past slapstick events that left her with long-suppressed traumas and phobias. For instance, in "Reaganing", Liz reveals to Jack that she once ended up falling while wearing roller skates and with her underwear around her ankles, while covered by a Tom Jones poster (all while she was trying to find a bathroom to use in her house). When Jack learns she also freaked out when hearing a snippet of music in Las Vegas, she realizes that anything that reminds her of Tom Jones triggers her revulsion to sex. She was also unable to eat eggs for a long time, and Kenneth's impromptu therapy helped her understand why: her aunt's husband left her, causing the aunt to feed a pre-teen Liz unappetizing egg-based dishes while making bizarre requests for company.


title: Liz Lemon

text: James Poniewozik of "Time" had this to say about an "Indecent Proposal" type situation involving a former classmate in the episode "Leap Day": "[T]his story is about more than that. It's about nerdy, neurotic Liz recognizing that she is, after all, a legitimate object of desire—a successful, smart woman who looks like Tina Fey—and embracing it rather than being freaked out by it."


title: Liz Lemon

text: Liz also has a tendency to say "blërg!" (the name of her home office furniture from IKEA), "nerds", "what the what?", "nertz", "nerf herder" (quoting Princess Leia in "The Empire Strikes Back"), "whuck?" and "son of a mother" as replacements for curse words; she has also notably used the phrases "shut it down", "I want to go to there", "deal-breaker", "pwomp", and "by the hammer of Thor!".


title: Liz Lemon

text: As demonstrated over the course of her appearances, Liz seems to have liberal political opinions. For instance, she stated that she believes "gay dudes should be allowed to adopt kids and we should all have hybrid cars". She is frequently portrayed as supporting Barack Obama. However, she said that there was an "eighty percent chance" that she would end up secretly voting for John McCain in the 2008 election, possibly a reference to Fey's friendship with former "SNL" host McCain, as well as her impersonation of Sarah Palin.


title: Liz Lemon

text: She is shown to be somewhat burdened with "white guilt," which Tracy uses to manipulate her in the episode "Jack-Tor". She later says that her affliction "is to be used only for good, like over-tipping and supporting Barack Obama". She is often very concerned about not being seen as racist; for example, an African-American man (played by Wayne Brady) she was dating played the "race card" when she no longer wished to see him after realizing that they were not a good match.


title: Liz Lemon

text: When questioned what religion she was, she replied that "I pretty much do whatever Oprah tells me to". She mentions that she previously tried to get her (former) boyfriend Floyd to try out a Unitarian church with her, but he was not interested. In "The Break-Up", Liz compiles a "Pros vs. Cons" list for Dennis, in which his Catholic religion is listed as a negative. When Jack begins referring to her and "TGS"’s humor as "elitist, East Coast, alternative, intellectual, left wing-..." Liz cuts him off, telling him, "Just say 'Jewish'; this is taking forever."


title: Liz Lemon

text: When Liz and Jack first meet, and for several seasons thereafter, neither realised that they had spoken to each other by telephone twenty years before.


title: Liz Lemon

text: In the beginning of the series, Liz and Jack had an antagonistic relationship. As the series progressed, however, this original dislike disappeared, and they are now close friends, with Jack at one point going so far as to tell her, "Lemon, I honestly don't know what I'd do without you". In spite of this, they still occasionally tease each other.


title: Liz Lemon

text: In Season 2, Liz declared that she and Jack "are friends", and seems to be welcome in Jack's office at any time. The two joke often about their various personal and work-related problems, and increasingly offer each other advice. Jack has even surpassed Pete as Liz's most trusted confidant. This relationship culminated when Jack, after being told he was to be the next chairman of General Electric, named Liz as his vice president and successor. In essence, Liz and Jack have developed into each other's best sounding boards. For example, when Liz believed herself to be pregnant, her first reaction was to go to Jack's office (then occupied by the daughter of G.E.'s CEO) and, when ultimately she was unable to speak with him face to face, she left multiple messages on his phone. When Jack heavily embarrassed himself at a business retreat, Liz took the attention away from him by doing improvisation, including holding open her blouse to reveal her white bra. Jack was clearly moved and appreciative of her actions. She has done similar things multiple times, sacrificing her dignity for Jack's overall public appearance, as evidenced when she kissed Jack's business rival Devon Banks on security camera footage so she could extort him. Jack responded to this by saying "Well played". Another example is in the episode "I Do Do", when she stalled for him in front of a church, expanding her small reading to involve a guitar song and random readings from the Bible. Liz has a pregnancy scare in "Cooter", and leaves a series of messages on Jack's voicemail as she goes through a series of emotions. The pregnancy test turns out to be a false reading, and Jack flies from Washington, D.C. to New York, showing up at her door to comfort her. When Liz struggled with intimacy issues, Jack talked her through them and helped her get to the root of the problem. When she wanted to give up on herself and break up with Carol Burnett, Jack didn't allow her to, telling her "You deserve a guy like Carol and he deserves you because, I'll only say this once a decade: you're great".


title: Liz Lemon

text: Despite their close friendship, Jack rarely addresses her as "Liz", generally preferring to call her by her surname. In the Season 5 episode "Mrs. Donaghy", the minister at Jack and Avery Jessup's wedding accidentally married Jack to Liz. Although they remain platonic, Liz and Jack are required to go to marriage counseling and realize the impact they have had on each other's lives in the past 5 years. In honor of his friendship with Liz and everything she has done for him, Jack gave his first-born daughter the name "Elizabeth", albeit using the nickname "Liddy" vice "Liz" in order to honor Liddy Dole, G. Gordon Liddy and Jack's martial arts instructor Lih De.


title: Liz Lemon

text: Tina Fey has said that Liz's relationship with Jack is "somewhere between Mary Tyler Moore and Lou Grant, and Han Solo and Princess Leia." Fey previously stated that there would not be a romantic relationship between the two, as it would be "too icky." More recently, however, she admitted there is sexual tension between Jack and Liz. Jack passes Liz off as his girlfriend to make ex-wife Bianca jealous and Bianca tells Liz in one scene that "I can tell from the way he [Jack] looks at you that he's serious". Colleen Donaghy, Jack's mother, thinks that Liz is a perfect match for Jack. In "Do-Over", Jack and Liz attempt to win over temporary head of GE, Kathy Geiss by pretending to have a soap opera-style real life relationship, escalating to the point where Geiss wants the two to kiss each other (her shouting "KISS!" marks the only time Kathy Geiss has spoken in the entire series); there is a pause, but Jack and Liz refuse.


title: Liz Lemon

text: Liz and Jenna have known each other since 1993, when they met at an audition for a car dealership commercial in Chicago, although there are many other versions of how they met (At a bachelor party, at a play Jenna was in). Liz stated in the pilot that she and Jenna worked for years to get "The Girlie Show", having formerly been roommates in a Chicago neighborhood called "Little Armenia" around 1996. Given Jenna's insecure nature, Liz is generally forced to act as her rock. This has caused Liz some annoyance, especially after Jack increased Jenna's stress level and paranoia by hiring Tracy Jordan and changing the show's name from "The Girlie Show" to "TGS With Tracy Jordan".


title: Liz Lemon

text: Liz has been seen complaining about Jenna's erratic tendencies behind her back, usually with Pete. Jenna once got mad at Liz when she overheard Liz describe her to Tracy as being "paranoid" and "neurotic." Jenna once slept with Liz's brother Mitch and said he was disgusting in bed. Liz explains this by saying that Mitch has not been right since he was in some kind of skiing accident, because of which he thinks it's still 1985 and he's still a teenager. Nonetheless, Jenna attempts to seduce Mitch once more in the episode "Ludachristmas."


title: Liz Lemon

text: Although Liz is happy to be "TGS"s head writer, she envies Jenna achieving the performing career they both hoped for when working at Second City. Liz confesses to Jenna, "there's still this sad little part of me that wants to be the center of attention ... that wants to be you, I guess". Liz gets the chance to be on camera as host of "Dealbreakers", but the pilot is a failure. Despite their frustrations and occasional rivalries, however, the show often reveals that the two women appreciate their friendship and do their best to be supportive of the other's careers. When the phrase "That's a deal breaker, ladies" is coined by Jenna thanks to Liz's writing, Jenna surrenders the spotlight with a surprisingly short sulking period. She later encourages Liz to write a book and take on a talk show gig based on the catch phrase (though the talk show is very short-lived).


title: Liz Lemon

text: Liz and Pete have known each other since about 1996 and he's possibly the closest thing Liz has to a confidant besides Jack, especially since Jenna, her closest female friend, is far too anxious about her own life to function as such. Pete lived in Liz's apartment for an extended period while separated from his wife. He helps run TGS and serves as the only other responsible adult on the TGS staff.


title: Liz Lemon

text: Liz has not really tried to pursue a relationship of any kind with Tracy, preferring to focus her energies on keeping his craziness in check. She is typically friendly towards him, though mainly to further this end. While Liz will refer to him as either "Tracy" or "Tray", Tracy will most often refer to Liz by her full name "Liz Lemon", "LL", or, less often, just "Lemon".


title: Liz Lemon

text: He often challenges her authority, but always ends up losing out when he does. In "The Natural Order", he cracks under the stress of doing the hard production work that Liz does every week, and in "Into the Crevasse", when Liz allowed him to make a pornographic film about her life as penance for her "Dealbreakers" book messing up Tracy's relationship with his wife, Angie, he was so disgusted that he stopped watching it halfway through. In the series finale she tearfully admits that she will miss him when TGS is over.


title: Liz Lemon

text: Many episodes of the show have dealt with Lemon's ongoing search for love. According to Pete, Liz has had some "really terrible boyfriends" in the ten years that he's known her. It is repeatedly implied (and eventually confirmed) that she once dated Conan O'Brien, first when she identifies the "tall, gangly red-haired guy who played guitar all the time" whom she dated as Conan in "Blind Date"; there seems to be romantic tension between them during a brief encounter. It has become apparent that Lemon has very high standards in men, personified in her imaginary perfect husband, "Astronaut Mike Dexter". She appears to take a somewhat more realistic view of her dream man after learning about her mother's premarital relationship with then-future astronaut Edwin "Buzz" ("Eddie" to her) Aldrin and subsequently conversing with Aldrin. She shares "sexual history" with Grizz who alone addresses her as "Beth", and they are seen passionately kissing in the footage from Kenneth's party in "Greenzo". In season 4, Liz uncharacteristically instigates a one-night stand with James Franco and his Japanese body pillow, Kimiko. At one point in season 5, in the episode "It's Never Too Late For Now", Liz decides to give up on love and embrace spinsterhood by adopting a cat she calls Emily Dickinson, attending book clubs and wearing a fanny pack and baggy sweaters.


title: Liz Lemon

text: Liz has also had several multi-episode onscreen romances. A recurring gag is Liz having relationships with men who share the names of celebrities or fictional characters, including Wesley Snipes (a Caucasian Englishman), commercial airline pilot Captain Carol Burnett (though his surname is pronounced "Burn-it"), Floyd DeBarbour (i.e., Floyd the Barber), Dr. Drew Baird (i.e., Dr. Drew), and Criss Chros. She also "takes her reward" for a time with new subordinate Jack "Danny" Baker (assuming Jack is in this case a diminutive of John or Jon, he shares his name with "CHiPs" character Jon Baker, portrayed by Liz's childhood crush, Larry Wilcox); he was even dressed as Wilcox during one of their assignations. Other boyfriends include Dennis Duffy.


title: Liz Lemon

text: In her longest onscreen relationship, Liz dates Criss Chros (James Marsden), a down-to-earth hot dog vendor named after a 1990s teen rap duo. Their relationship began sometime before season 6 and continued past the 6th-season finale, in which she and Criss finally decide to try to have a baby together. In the 7th and final season, after weeks of unsuccessful attempts at conception, believing it will increase their adoption chances, they get married at city hall. In "A Goon's Deed in a Weary World", Liz and Criss adopt two children, Terry and Janett (who bear an uncanny resemblance to Tracey and Jenna), and, after disastrously attempting to become a stay at home mom, Criss decides to become the at home parent, allowing Liz to continue work in television. ("Hogcock/Last Lunch")


title: Liz Lemon

text: Lemon was ranked No. 1 on Yahoo's Greatest 100 Television Characters since 1990. She appeared in Comcast's list of TV's Most Intriguing Characters. AOL named her the 14th Most Memorable Female TV Character. "Paste" also included her in their list of the 20 Best Characters of 2011, ranking her No. 5. Lemon was also ranked No. 15 in AfterEllen.com's Top 50 Favorite Female TV Characters.


title: Liz Lemon

text: Slate, discussing how the show covers politics and feminism, assessed Lemon's character as being drawn from other genres of comedy in unexpected ways: "the man-child is a venerable comic tradition, from The Jerk to Billy Madison to everything Will Ferrell does, and 30 Rock proves that an eternal 13-year-old tomboy—scared of sex, obsessed with Star Wars and meatball subs—can be just as funny as her male counterpart." In 2015, Yahoo named Lemon the greatest television character since Tony Soprano of "The Sopranos", and "Entertainment Weekly" named Lemon one of the 25 Best TV Characters in the Past 25 Years.


title: Liz Lemon

text: Like Fey, who was head writer of "Saturday Night Live" ("SNL") from 1999 to 2006, the character is head writer for a sketch comedy show. For this reason, Liz Lemon is widely seen by critics as a fictionalized version of Fey herself, which Fey herself has confirmed as being her intention. In a video interview conducted with Fey before the airing of the pilot, she stated that Liz is herself "five or six years ago when I first started at my job and had to figure out how to deal with big, strong personalities and get through the day, being sort-of scared of everyone... but acting like you're not scared of everyone."


title: Liz Lemon

text: Fey has reported incorporating some of her own quirks and history into the character, saying that she tries to "share as many of Liz's habits as possible so it feels truthful". Liz has been seen singing "Maybe" and Fey has noted that she also enjoys singing songs from "Annie". Both were once rejected by a man who later went to "clown college" which had a huge emotional impact on them.


title: Liz Lemon

text: The character also shares her given name with Fey, whose full name is Elizabeth Stamatina Fey. However, Liz Lemon is only very rarely referred to as "Elizabeth" and the character's name is usually given as "Liz Lemon" in official contexts (example, the plaque on the door to her office). It is also worth noting that in Fey's original script for "30 Rock", Lemon's first name was "Lisa". The character's middle name, "Miervaldis," is a Latvian masculine name. Fey has said that, while Lemon's ethnic background is unknown, "Latvian seems to make sense.". She has also, more recently, been suggested to have German ancestry, and speaks at least a little of the language. The character's last name, "Lemon," is apparently intended to imply an acerbic personality and possibly also to make her full name alliterative. Fey has stated that she wanted Liz to have a good last name since she knew the character would often be called by it.


title: Liz Lemon

text: Among the child actors who portrayed Liz in flashbacks to her youth was Fey's own daughter, Alice Richmond, in "Mazel Tov, Dummies!".


title: The Secret Life of Pets (franchise)

text: The Secret Life of Pets is an American animated media franchise created by Illumination. Directed by Chris Renaud, the series stars the voices of Eric Stonestreet, Kevin Hart, Jenny Slate, Ellie Kemper, Lake Bell, Dana Carvey, Hannibal Buress, Bobby Moynihan, Chris Renaud, Tara Strong and Kiely Renaud among others. The first film, "The Secret Life of Pets", was released on July 8, 2016 and received positive reviews from critics. The second film, "The Secret Life of Pets 2", was released on June 7, 2019 in the US and received mixed reviews from critics. The series has grossed $1.3 billion so far.


title: The Secret Life of Pets (franchise)

text: The films follow a group of domesticated house pets who embark on various adventures outside the comfort of their apartment complex.


title: The Secret Life of Pets (franchise)

text: Max's luck changes when her owner Katie brings home a new dog named Duke. They have to put their differences aside when they get lost in New York in order to stop a rebellious group of abandoned pets and return home.


title: The Secret Life of Pets (franchise)

text: Max and Duke's owner Katie now has a child named Liam, which causes Max to become excessively protective, but a trip to the countryside will change his mind. Meanwhile, a reformed Snowball helps a white tiger cub find refuge from an abusive circus owner.


title: The Secret Life of Pets (franchise)

text: In June 2022, in an interview on the podcast "The Gary and Kenny Show", Meledandri stated that a third film is in development.


title: The Secret Life of Pets (franchise)

text: Included as a mini-movie on "The Secret Life of Pets"<nowiki>'</nowiki> home media release, the short focuses around Norman from the film as he wanders the vents of Max's apartment and watches various scenarios of the residents.


title: The Secret Life of Pets (franchise)

text: Included as the second mini-movie on "The Secret Life of Pets"<nowiki>'</nowiki> home media release, it features a world of anthropomorphic sausages in which the Mayor shows a little sausage named Timmy how great it is to be a weenie.


title: The Secret Life of Pets (franchise)

text: Included as a mini-movie on "The Secret Life of Pets 2"<nowiki>'s</nowiki> home media release, the plot focuses on the character Gidget imagining herself as a superhero and saving Max from an army of squirrels.


title: The Secret Life of Pets (franchise)

text: A free-to-play mobile game developed by Electronic Arts, titled "The Secret Life of Pets: Unleashed", was released in summer 2016. It was a match-3 game which featured the characters as one has its own level. In the game the players could combine different toys to earn points. The game was removed from the App Store and Google Play Store on May 22, 2017, the same day as "Minions Paradise".


title: The Secret Life of Pets (franchise)

text: In April 2019, Universal Studios Hollywood announced a new dark ride attraction entitled "The Secret Life of Pets: Off the Leash!" which was set to open on March 27, 2020, but the opening was postponed indefinitely due to the novel coronavirus outbreak. The attraction eventually opened on April 16, 2021.


title: Duncan Grant

text: Duncan James Corrowr Grant (21 January 1885 – 8 May 1978) was a British painter and designer of textiles, pottery, theatre sets and costumes. He was a member of the Bloomsbury Group.


title: Duncan Grant

text: His father was Bartle Grant, a "poverty-stricken" major in the army, and much of his early childhood was spent in India and Burma. He was a grandson of Sir John Peter Grant, 12th Laird of Rothiemurchus, KCB, GCMG, sometime Lieutenant-Governor of Bengal. Grant was also the first cousin twice removed of John Grant, 13th Earl of Dysart (b. 1946).


title: Duncan Grant

text: Grant was born on 21 January 1885 to Major Bartle Grant and Ethel Isabel McNeil in Rothiemurchus, Aviemore, Scotland. Between 1887 and 1894 the family lived in India and Burma, returning to England every two years. During this period Grant was educated by his governess, Alice Bates. Along with Rupert Brooke, Grant attended Hillbrow School, Rugby, 1894–99, where he received lessons from an art teacher and became interested in Japanese prints. During this period Grant spent his school holidays at Hogarth House, Chiswick, with his grandmother, Lady Grant. He attended St Paul's School, London (as a boarder for two terms), 1899-1901, where he was awarded several art prizes.


title: Duncan Grant

text: From about 1899/1900 to 1906 Grant lived with his aunt and uncle, Sir Richard and Lady Strachey and their children. When Grant was younger, he accompanied Lady Strachey to "picture Sunday" which gave him the opportunity to meet with eminent painters. Lady Strachey was able to persuade Grant's parents that he should be allowed to pursue an education in art. In 1902 Grant was enrolled by his aunt at Westminster School of Art; he attended for the next three years. While at Westminster, Grant was encouraged in his studies by Simon Bussy, a French painter and lifelong friend of Matisse, who went on to marry Dorothy Strachey.


title: Duncan Grant

text: In the winter of 1904–5 Grant visited Italy where, commissioned by Harry Strachey, he made copies of part of the Masaccio frescoes in the Brancacci Chapel, in the Church of Santa Maria del Carmine, Florence. Grant also made a study of the Portrait of Federigo da Montefeltro, one half of the diptych by Piero della Francesca in the Uffizi and was greatly impressed by the frescoes of Piero in the Basilica of San Francesco, Arezzo. On his return, at the advice of Simon Bussy, Grant made a copy of the Angel musicians in Piero's Nativity in the National Gallery, London.


title: Duncan Grant

text: Grant was introduced to Vanessa Bell (then Vanessa Stephen) by Pippa Strachey at the Friday Club in the autumn of 1905. From 1906, thanks to a gift of £100 from an aunt, Grant spent a year in Paris studying at the "Académie de La Palette," Jacques-Émile Blanche's school. During this period he visited the Musée du Luxembourg and saw, among other paintings, the Caillebotte bequest of French Impressionists.


title: Duncan Grant

text: In January 1907, and again in the summer of 1908, Grant spent a term at the Slade School of Art. In 1908, Grant painted a portrait of John Maynard Keynes, who he had met the previous year, while the two were on holiday in Orkney. A year later, the pair would share rooms on Belgrave Road.


title: Duncan Grant

text: In 1909 Grant visited Michael and Gertrude Stein in Paris and saw their collection that included paintings by, among others, Picasso and Matisse. In the summer, with an introduction from Simon Bussy, Grant visited Matisse himself, then living at Clamart, Paris.


title: Duncan Grant

text: In November 1909, Grant moved to 21 Fitzroy Square, where he occupied two rooms on the second floor of the building on the west side of the square. A few doors away, at 29 Fitzroy Square, lived Adrian and Virginia Stephen (later Virginia Woolf). Grant would later recall: 'a close friendship sprang up between Adrian Stephen and myself and I had only to tap on the window to be let in. The maid told Virginia "that Mr Grant gets in everywhere". But very irregular as my visits were, they became more and more a habit, and I think they soon became frequent enough to escape notice.'


title: Duncan Grant

text: In June 1910 Grant exhibited with the Friday Club at the Alpine Club Gallery. Later that year Grant would visit Roger Fry's "Manet and the Post-Impressionists" exhibition at the Grafton Galleries in Mayfair, which included work by the likes of Gauguin, Matisse and Van Gogh, where he was said to be particularly interested in the paintings of Paul Cézanne.


title: Duncan Grant

text: During the summer of 1911 Grant was invited by Roger Fry to contribute to the redecoration of the dining room at the Borough Polytechnic (now London South Bank University). Grant composed two oil paintings to fit with the theme of illustrating "London on Holiday". Both his paintings, "Football" and "Bathing," bear the influence of early Italian art and Byzantine mosaics. Grant also drew on his exposure to the work of the post-impressionists; "The Times" reported of his depiction of the figures that 'Mr Grant has used all his remarkable powers of draughtsmanship to represent the act of swimming rather than any individual swimmers.’


title: Duncan Grant

text: In February 1910 Grant, along with Horace de Vere Cole, Virginia Stephen, Adrian Stephen and others, disguised themselves as an Abyssinian royal delegation and fooled their way on to HMS "Dreadnought". The delegation was greeted by a band and given a tour of the battleship. As flag ship of the Home Fleet, the "Dreadnought" was a high-profile target for the pranksters, and as such the hoax attracted much attention in the press once discovered.


title: Duncan Grant

text: Grant is best known for his painting style, which developed in the wake of French post-impressionist exhibitions mounted in London in 1910. He often worked with, and was influenced by, another member of the group, art critic and artist Roger Fry. As well as painting landscapes and portraits, Fry designed textiles and ceramics.


title: Duncan Grant

text: After Fry founded the Omega Workshops in 1913, Grant became co-director with Vanessa Bell, who was then involved with Fry. Although Grant had always been actively homosexual, a relationship with Vanessa blossomed, which was both creative and personal, and he eventually moved in with her and her two sons by her husband Clive Bell. In 1916, in support of his application for recognition as a conscientious objector, Grant joined his new lover, David Garnett, in setting up as fruit farmers in Suffolk. Both their applications were initially unsuccessful, but eventually the Central Tribunal agreed to recognise them on condition of their finding more appropriate premises. Vanessa Bell found the house named Charleston near Firle in Sussex. Relationships with Clive Bell remained amicable, and Bell stayed with them for long periods fairly often – sometimes accompanied by his own mistress, Mary Hutchinson.


title: Duncan Grant

text: In 1935 Grant was selected along with nearly 30 other prominent British artists of the day to provide works of art for the RMS "Queen Mary" then being built in Scotland. Grant was commissioned to provide paintings and fabrics for the first class Main Lounge. In early 1936, after his work was installed in the Lounge, directors from the Cunard Line made a walk-through inspection of the ship. When they saw what Grant had created, they immediately rejected his works and ordered it removed.


title: Duncan Grant

text: During World War Two, Grant received a short-term commission from the War Artists' Advisory Committee for two paintings, the most notable of which is an image of St Paul's Cathedral during the 1941 London Blitz as seen from the basement of a nearby bombed building.


title: Duncan Grant

text: In the late 1950s Grant was commissioned to decorate the Russell Chantry of Lincoln Cathedral. Grant modelled the figure of Christ in these murals on his lover Paul Roche. The Cathedral authorities closed the Chantry in the 1960s and it was used as a store room for many years. Grants' murals were eventually restored and the space reopened to the public in the 1990s.


title: Duncan Grant

text: Grant's early affairs were exclusively homosexual. His lovers included his cousin, the writer Lytton Strachey, the future politician Arthur Hobhouse and the economist John Maynard Keynes, who at one time considered Grant the love of his life because of his good looks and the originality of his mind. Through Strachey, Grant became involved in the Bloomsbury Group, where he made many such great friends including Vanessa Bell. He would eventually live with Vanessa Bell who, though she was a married woman, fell deeply in love with him and, one night, succeeded in seducing him; Bell very much wanted a child by Grant, and she became pregnant in the spring of 1918. Although it is generally assumed that Grant's sexual relations with Bell ended in the months before Angelica was born (Christmas, 1918), they continued to live together for more than 40 years. During that time, their relationship was mainly domestic and creative; they often painted in the same studio together, praising and critiquing each other's work.


title: Duncan Grant

text: Living with Vanessa Bell was no impediment to Grant's relationships with men, either before or after Angelica was born. Angelica grew up believing that Vanessa's husband Clive Bell was her biological father; she bore his surname and his behaviour toward her never indicated otherwise. Duncan Grant and Vanessa Bell had formed an open relationship, although she herself apparently never had any further affairs. Duncan, in contrast, had many physical affairs and several serious relationships with other men, most notably David Garnett, who would one day marry Angelica and have four daughters with her, including Amaryllis Garnett. Grant's love and respect for Bell, however, kept him with her until her death in 1961.


title: Duncan Grant

text: In Grant's later years, his lover, the poet Paul Roche (1916–2007), whom he had known since 1946, took care of him and enabled Grant to maintain his accustomed way of life at Charleston for many years. Grant and Roche's relationship was strong and lasted even during Roche's marriage and five children he had by the late 1950s. Roche was made co-heir of Grant's estate. Grant eventually died in Roche's home in 1978.


title: Duncan Grant

text: Duncan Grant's remains are buried beside Vanessa Bell's in the churchyard of St Peter's Church, West Firle, East Sussex.


title: Rings of Saturn (band)

text: Rings of Saturn is an American deathcore band from the Bay Area, California. The band was formed in 2009 and was originally just a studio project. However, after gaining a wide popularity and signing to Unique Leader Records, the band formed a full line-up and became a full-time touring band. Rings of Saturn's music features a highly technical style, heavily influenced by themes of alien life and outer space. They have released six full-length albums, with their third, "Lugal Ki En", released in 2014 and peaking at 126 on the American "Billboard" 200 chart while their fourth, "Ultu Ulla" was released in 2017 and peaked at 76 on the "Billboard" 200, making it the band's highest peak to date. "Gidim" was released in October 2019.


title: Rings of Saturn (band)

text: Rings of Saturn was formed in 2009 in high school only as a studio recording project with Lucas Mann on guitars, bass, and keyboards, Peter Pawlak on vocals, and Brent Silletto on drums. The band posted a track titled "Abducted" online and quickly gained listeners. The band recorded their debut album, "Embryonic Anomaly", with Bob Swanson at Mayhemnness Studios in Sacramento, California. The album was self-released by the band on May 25, 2010. Four months after releasing "Embryonic Anomaly", the band signed to Unique Leader Records. In the months following the band's signing, Joel Omans was added as a second guitarist and the band graduated high school which led to their embarking on tours. "Embryonic Anomaly" was re-released through Unique Leader on March 1, 2011, and their two following albums would later also be released through the label. Brent Silletto and Peter Pawlak both left the band in December 2011.


title: Rings of Saturn (band)

text: Rings of Saturn, which at this point only included Lucas Mann and Joel Omans, toured with many different touring members before forming a line-up which added Ian Bearer, Sean Martinez and Ian Baker on vocals, bass, and drums respectively. This line-up recorded their second studio album, "Dingir", with the same producer from "Embryonic Anomaly". The album was originally scheduled to be released on November 20, 2012, but due to legal issues, the album release was pushed back to February 5, 2013. In response to the legal push and a pre-production version of the album leaking on the internet, the vocalist, Ian Bearer, uploaded the finished album on his YouTube channel and put up the entire album for download via Total Deathcore. Ian Baker and Sean Martinez parted ways with the band shortly after the official release of Dingir, the band later took part in The Summer Slaughter Tour of 2013 adding Jesse Beahler for drums until the end of the tour.


title: Rings of Saturn (band)

text: Rings of Saturn went into recording their 3rd studio album in Pittsburgh, Pennsylvania, having Aaron Kitcher of Infant Annihilator and Black Tongue to fill in all drums arrangements as a special guest on the album. Aaron Stechauner later joined as a full-time member for drums after the album was finished. On July 1, 2014, the band released the cover art and track list to their third studio album "Lugal Ki En" which was released on October 14, 2014. They also released their first music video for "Senseless Massacre" directed by Alex T. Reinhard. The band toured the United States, Canada, and for the first time Mexico shortly after but no new songs were played from the newly released album. On December 9, Joel Omans announced his departure from the band, stating on his personal Facebook that he left because Lucas Mann became "a hack of a musician" and "hindered the band from playing new songs from "Lugal Ki En"" during its album release tour. Two weeks later, on December 26, Miles Dimitri Baker was announced as their new second guitarist.


title: Rings of Saturn (band)

text: On April 2, 2015, Rings of Saturn released a live guitar play-through featuring Lucas Mann and Miles Dimitri Baker performing the song "Godless Times" from the album "Lugal Ki En", in response to the allegations. Three months later, on August 28, the band released the single "Seized and Devoured 2.0", a re-recorded track off of their first album "Embryonic Anomaly" featuring Ian Bearer's vocals. Shortly after, the band began touring in North America, with a set-list that consisted of mainly "Lugal Ki En" songs being played for the first time live. Later that year, On December 25, the band released a collaboration single titled "Souls of This Mortality" with its very own side project band Interloper. Rings of Saturn then began its first tour in Europe in early 2016, followed by a North American tour supporting Thy Art Is Murder. On May 17, 2016, the band announced that they signed to Nuclear Blast.


title: Rings of Saturn (band)

text: On July 31, Rings of Saturn announced that they had finished writing their fourth studio album, "Ultu Ulla", and it was released on July 28, 2017. On June 2, 2017, the band released their second music video for the song "Inadequate". On July 7, 2017, the band released a lyric video for the second single off "Ultu Ulla", "Parallel Shift". Drummer Aaron Stechauner & Miles Dimitri Baker announced their departure from Rings of Saturn on May 26, 2018. Soon after the departure of Stechauner and Baker, it was announced via Facebook that former guitarist, Joel Omans, would reunite with the band and that Desecrate the Faith drummer, Mike Caputo, will be joining them as well along with Japanese guitarist Yo Onityan. On February 10, 2019, Rings of Saturn's Facebook page point out that Mike Caputo and Yo Onityan are currently touring members. The band released their fifth studio album titled "Gidim" on October 25, 2019, featuring Marco Pitruzella on drums, as well as a guest solo from Charles Caswell of Berried Alive on the song "Pustules", vocals from Dan Watson of Enterprise Earth on the song "Hypodermis Glitch", and a solo from Yo Onityan on the song "Tormented Consciousness". On September 8, 2020, the band confirmed that Mike Caputo was being made a full-time member of the band. On April 30, the band were dropped from Nuclear Blast following supposed threats from Lucas Mann. On May 14, the band announced the departure of vocalist Ian Bearer, and stated the band would transition towards a strictly instrumental direction. On June 15, 2022, the band released their new self-titled sixth studio album while also announcing physical formats would be released at a future date.


title: Rings of Saturn (band)

text: AllMusic described Rings of Saturn as a "progressive, technical deathcore outfit", writing that they have "humorously deemed their brand of technical death metal 'aliencore.'" The band employs fast riffing with an added harmony effect, fast tempos, ambient elements, djent elements, and lyrics that deal with space invasion and extraterrestrial life.


The United States Foreign Intelligence Surveillance Court (FISC), also called the FISA Court, is a U.S. federal court established under the Foreign Intelligence Surveillance Act of 1978 (FISA) to oversee requests for surveillance warrants against foreign spies inside the United States by federal law enforcement and intelligence agencies.


title: United States Foreign Intelligence Surveillance Court

text: FISA was created by the U.S. Congress based on the recommendations of the Senate's Church Committee, which was convened in 1975 to investigate illicit activities and civil rights abuses by the federal intelligence community. Pursuant to the law, the FISC reviews requests to conduct physical and electronic surveillance within the U.S. concerning "foreign intelligence information" between "foreign powers" and "agents of foreign powers" suspected of espionage or terrorism; such requests are made most often by the National Security Agency (NSA) and the Federal Bureau of Investigation (FBI).


text: From its opening in 1978 until 2009, the court was housed on the sixth floor of the Robert F. Kennedy Department of Justice Building; since 2009, it has been relocated to the E. Barrett Prettyman United States Courthouse in Washington, D.C.


text: Each application for one of these surveillance warrants (called a FISA warrant) is made before an individual judge of the court. The court may allow third parties to submit briefs as "amici curiae". When the U.S. Attorney General determines that an emergency exists, the Attorney General may authorize the emergency employment of electronic surveillance before obtaining the necessary authorization from the FISC, if the Attorney General or their designee notifies a judge of the court at the time of authorization and applies for a warrant as soon as practicable but not more than seven days after authorization of such surveillance, as required by .


text: If an application is denied by one judge of the court, the federal government is not allowed to make the same application to a different judge of the court but may appeal to the United States Foreign Intelligence Surveillance Court of Review. Such appeals are rare: the first appeal from the FISC to the Court of Review was made in 2002 ("In re Sealed Case No. 02-001"), 24 years after the founding of the court.


text: Also rare is for FISA warrant requests to be turned down. During the 25 years from 1979 to 2004, 18,742 warrants were granted, while only four were rejected. Fewer than 200 requests had to be modified before being accepted, almost all of them in 2003 and 2004. The four rejected requests were all from 2003, and all four were partially granted after being submitted for reconsideration by the government. Of the requests that had to be modified, few were before the year 2000. During the next eight years, from 2004 to 2012, there were over 15,100 additional warrants granted, and another seven being rejected. Over the entire 33-year period, the FISA court granted 33,942 warrants, with only 12 denials – a rejection rate of 0.03 percent of the total requests. This does not include the number of warrants that were modified by the FISA court.


text: On May 17, 2002, the court rebuffed Attorney General John Ashcroft, releasing an opinion that alleged that the FBI and Justice Department officials had "supplied erroneous information to the court" in more than 75 applications for search warrants and wiretaps, including one signed by FBI Director Louis J. Freeh. Whether this rejection was related to the court starting to require modification of significantly more requests in 2003 is unknown.


text: On December 16, 2005, "The New York Times" reported that the Bush administration had been conducting surveillance against U.S. citizens without specific approval from the FISA court for each case since 2002. On December 20, 2005, Judge James Robertson resigned his position with the court, apparently in protest of the secret surveillance, and later, in the wake of the Snowden leaks of 2013, criticized the court-sanctioned expansion of the scope of government surveillance and its being allowed to craft a secret body of law. The government's apparent circumvention of the court started prior to the increase in court-ordered modifications to warrant requests.


text: In 2011, the Obama administration secretly won permission from the Foreign Intelligence Surveillance Court to reverse restrictions on the National Security Agency's use of intercepted phone calls and e-mails, permitting the agency to search deliberately for Americans' communications in its massive databases. The searches take place under a surveillance program Congress authorized in 2008, under Section 702 of the Foreign Intelligence Surveillance Amendment Act (Section 1881a et seq in FISA). Under that law, the target must be a foreigner "reasonably believed" to be outside the United States, and the court must approve the targeting procedures in an order good for one year. But a warrant for each target would thus no longer be required. That means that communications with Americans could be picked up without a court first determining that there is probable cause that the people they were talking to were terrorists, spies or "foreign powers". The FISC also extended the length of time that the NSA is allowed to retain intercepted U.S. communications from five years to six years with an extension possible for foreign intelligence or counterintelligence purposes. Both measures were done without public debate or any specific authority from Congress.


text: Because of the sensitive nature of its business, the court is a "secret court" – its hearings are closed to the public. While records of the proceedings are kept, they also are unavailable to the public, although copies of some records with classified information redacted have been made public. Due to the classified nature of its proceedings, usually only attorneys licensed to practice in front of the US government are permitted to appear before the court. Because of the nature of the matters heard before it, court hearings may need to take place at any time of day or night, weekdays or weekends; thus, at least one judge must be "on call" at all times to hear evidence and decide whether or not to issue a warrant.


text: A heavily redacted version of a 2008 appeal by Yahoo! of an order issued with respect to NSA's PRISM program had been published for the edification of other potential appellants. The identity of the appellant was declassified in June 2013.


text: There has been growing criticism of the court since the September 11, 2001 attacks. This is partly because the court sits "ex parte" – in other words, in the absence of anyone but the judge and the government present at the hearings. This, combined with the minimal number of requests that are rejected by the court has led experts to characterize it as a rubber stamp (former National Security Agency analyst Russ Tice called it a "kangaroo court with a rubber stamp"). The accusation of being a "rubber stamp" was rejected by FISA Court president Reggie B. Walton who wrote in a letter to Senator Patrick J. Leahy: "The annual statistics provided to Congress by the Attorney General ... – frequently cited to in press reports as a suggestion that the Court's approval rate of application is over 99% – reflect only the number of "final" applications submitted to and acted on by the Court. These statistics do not reflect the fact that many applications are altered to prior or final submission or even withheld from final submission entirely, often after an indication that a judge would not approve them." He added: "There is a rigorous review process of applications submitted by the executive branch, spearheaded initially by five judicial branch lawyers who are national security experts and then by the judges, to ensure that the court's authorizations comport with what the applicable statutes authorize." In a following letter Walton stated that the government had revamped 24.4% of its requests in the face of court questions and demands in time from July 1, 2013 to September 30, 2013. This figure became available after Walton decided in the summer of 2013 that the FISC would begin keeping its own tally of how Justice Department warrant applications for electronic surveillance fared – and would track for the first time when the government withdrew or resubmitted those applications with changes. Some requests are modified by the court but ultimately granted, while the percentage of denied requests is statistically negligible (11 denied requests out of around 34,000 granted in 35 years – equivalent to 0.03%). The accusation that the FISC is a "rubber stamp" court was also rejected by Robert S. Litt (General Counsel of Office of the Director of National Intelligence): "When [the Government] prepares an application for [a section 215 order, it] first submit[s] to the [FISC] what's called a "read copy", which the court staff will review and comment on. [A]nd they will almost invariably come back with questions, concerns, problems that they see. And there is an iterative process back and forth between the Government and the [FISC] to take care of those concerns so that at the end of the day, we're confident that we're presenting something that the [FISC] will approve. That is hardly a rubber stamp. It's rather extensive and serious judicial oversight of this process."


text: A 2003 Senate Judiciary Committee "Interim Report on FBI Oversight in the 107th Congress by the Senate Judiciary Committee: FISA Implementation Failures" cited the "unnecessary secrecy" of the court among its "most important conclusions":


text: In a July 2013 interview, Senator and privacy advocate Ron Wyden described the FISC warrant process as "the most one-sided legal process in the United States". "I don't know of any other legal system or court that really doesn't highlight anything except one point of view", he said. Later in the interview he said Congress should seek to "diversify some of the thinking on the court".


text: Elizabeth Goitein, a co-director of the Liberty and National Security Program of the Brennan Center for Justice at the New York University School of Law, has criticized the court as being too compromised to be an impartial tribunal that oversees the work of the NSA and other U.S. intelligence activities. Since the court meets in secret, hears only the arguments of the government prior to deciding a case, and its rulings cannot be appealed or even reviewed by the public, she has argued that: "Like any other group that meets in secret behind closed doors with only one constituency appearing before them, they're subject to capture and bias."


text: A related bias of the court results from what critics such as Julian Sanchez, a scholar at the Cato Institute, have described as the near certainty of the polarization or groupthink of the judges of the court. Since all of the judges are appointed by the same person (the Chief Justice of the United States), hear no opposing testimony and feel no pressure from colleagues or the public to moderate their rulings, Sanchez claims that "group polarization is almost a certainty", adding that "there's the real possibility that these judges become more extreme over time, even when they had only a mild bias to begin with".


text: The court's judges are appointed solely by the Chief Justice of the United States without confirmation or oversight by the U.S. Congress. This gives the chief justice the ability to appoint like-minded judges and create a court without diversity. "The judges are hand-picked by someone who, through his votes on the Supreme Court, we have come to learn has a particular view on civil liberties and law enforcement", Theodore Ruger, a professor at the University of Pennsylvania Law School, said with respect to Chief Justice John Roberts. "The way the FISA is set up, it gives him unchecked authority to put judges on the court who feel the same way he does." And Stephen Vladeck, a law professor at the University of Texas School of Law, added, "Since FISA was enacted in 1978, we've had three chief justices, and they have all been conservative Republicans, so I think one can worry that there is insufficient diversity." Since May 2014, however, four of the five judges appointed by Chief Justice Roberts to the FISA Court were appointed to their prior federal court positions by Presidents Bill Clinton and Barack Obama.


text: There are some reform proposals. Senator Richard Blumenthal from Connecticut proposed that each of the chief judges of the 12 major appeals courts select a district judge for the surveillance court; the chief justice would still pick the review panel that hears rare appeals of the court's decisions, but six other Supreme Court justices would have to sign off. Another proposal authored by Representative Adam Schiff of California would give the president the power to nominate judges for the court, subject to Senate approval, while Representative Steve Cohen proposed that Congressional leaders pick eight of the court's members.


text: Stephen Vladeck, a professor at the University of Texas School of Law, has argued that, without having to seek the approval of the court (which he has said merely reviews certifications to ensure that theyand not the surveillance itself – comply with the various statutory requirements), the U.S. Attorney General and the Director of National Intelligence can engage in sweeping programmatic surveillance for one year at a time. There are procedures used by the NSA to target non-U.S. persons and procedures used by the NSA to minimize data collection from U.S. persons. These court-approved policies allow the NSA to do the following:


text: Jameel Jaffer, the ACLU's deputy legal director, said in light of revelations that the government secured telephone records from Verizon and Internet data from some of the largest providers that safeguards that are supposed to be protecting individual privacy are not working. Elizabeth Goitein, co-director of the Liberty and National Security Program at the Brennan Center for Justice in New York, wrote in the Wall Street Journal that when courts make mistakes, the losing party has the right to appeal and the erroneous decision is reversed. "That process cannot happen when a secret court considers a case with only one party before it."


text: According to "The Guardian", "The broad scope of the court orders, and the nature of the procedures set out in the documents, appear to clash with assurances from President Obama and senior intelligence officials that the NSA could not access Americans' call or email information without warrants". Glenn Greenwald, who published details of the PRISM surveillance program, explained:


text: Deputy Attorney General James M. Cole and NSA Deputy Director John C. Inglis cited the court's oversight in defending the constitutionality of the NSA's surveillance activities before during a hearing before the House Judiciary Committee in July 2013. Representative Jerrold Nadler, challenged Cole's defense of the program's constitutionality, and he said the secrecy in which the court functioned negated the validity of its review. "The fact that a secret court unaccountable to public knowledge of what it's doing ... may join you in misusing or abusing the statutes is of no comfort whatsoever", Nadler said. Orin Kerr, a law professor at George Washington University, said the secrecy that comes along with national security makes it difficult to evaluate how the administration carries out the wide authority Congress has given it. "FISA court judges hear all of this and they think it's legal," Kerr said. "What we really don't know, though, are what the FISA court's opinions say."


text: In July 2013, "The New York Times" published disclosures from anonymous government whistleblowers of secret law written by the court holding that vast collections of data on all Americans (even those not connected in any way to foreign enemies) amassed by the NSA do not violate the warrant requirements of Fourth Amendment to the U.S. Constitution. It reported that anyone suspected of being involved in nuclear proliferation, espionage or cyber-attacks, according to the court, may be considered a legitimate target for warrantless surveillance. Acting like a parallel U.S. Supreme Court, the court greatly broadened the "special-needs" exception to do so.


text: The newspaper reported that in "more than a dozen classified rulings, the nation's surveillance court has created a secret body of law giving the National Security Agency the power to amass vast collections of data on Americans". It also wrote, with respect to the court:


text: The "special-needs" doctrine is an exemption to the Fourth Amendment's Warrants Clause which commands that "no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be and seized". The U.S. Supreme Court has recognized an exemption to the Warrants Clause "outside the foreign intelligence context, in so-called 'special-needs' cases. In those cases, the Court excused compliance with the Warrant Clause when the purpose behind the governmental action went beyond routine law enforcement and insisting upon a warrant would materially interfere with the accomplishment of that purpose. See, "Vernonia School District 47J v. Acton", 515 U.S. 646, 653 (1995) (upholding drug testing of highschool athletes and explaining that the exception to the warrant requirement applied "when special needs, beyond the normal need for law enforcement, make the warrant and probable-cause requirement[s] impracticable (quoting "Griffin v. Wisconsin", 483 U.S. 868, 873 (1987))); "Skinner v. Ry. Labor Execs. Ass'n", 489 U.S. 602, 620 (1989) (upholding regulations instituting drug and alcohol testing of railroad workers for safety reasons); cf. "Terry v. Ohio", 392 U.S. 1, 23-24 (1968) (upholding pat-frisk for weapons to protect officer safety during investigatory stop)". The U.S. Foreign Intelligence Surveillance Court of Review concluded on August 22, 2008, in the case "In re Directives [redacted text] Pursuant to Section 105B of the Foreign Intelligence Surveillance Act", that the "special-needs" doctrine applied by analogy to justify a foreign intelligence exception to the warrant requirement for surveillance undertaken for national security purposes and directed at a foreign power or an agent of a foreign power reasonably believed to be located outside the U.S.


text: James Robertsona former judge for the U.S. District Court for the District of Columbia, who, in 2004, ruled against the Bush administration in the "Hamdan v. Rumsfeld" case, and also served on the FISC for three years between 2002 and 2005said he was "frankly stunned" by the newspaper's report that court rulings had created a new body of law broadening the ability of the NSA to use its surveillance programs to target not only terrorists but suspects in cases involving espionage, cyberattacks and weapons of mass destruction. Geoffrey R. Stone, a professor of constitutional law at the University of Chicago, said he was troubled by the idea that the court is creating a significant body of law without hearing from anyone outside the government, forgoing the adversarial system that is a staple of the American justice system. He said, "That whole notion is missing in this process".


text: The court concluded that mass collection of telephone metadata (including the time of phone calls and numbers dialed) does not violate the Fourth Amendment as long as the government establishes a valid reason under national security regulations before taking the next step of actually examining the contents of an American's communications. This concept is rooted partly in the special needs doctrine. "The basic idea is that it's O.K. to create this huge pond of data", an unnamed U.S. official said, "but you have to establish a reason to stick your pole in the water and start fishing". Under the new procedures passed by the U.S. Congress in the FISA Amendments Act of 2008, even the collection of metadata must be considered "relevant" to a terrorism investigation or other intelligence activities. The court has indicated that while individual pieces of data may not appear "relevant" to a terrorism investigation, the total picture that the bits of data create may in fact be relevant, according to U.S. officials with knowledge of the decisions.


text: A secret ruling made by the court that redefined the single word "relevant" enabled the NSA to gather phone data on millions of Americans. In classified orders starting in the mid-2000s, the court accepted that "relevant" could be broadened to permit an entire database of records on millions of people, in contrast to a more conservative interpretation widely applied in criminal cases, in which only some of those records would likely be allowed. Under the Patriot Act, the Federal Bureau of Investigation can require businesses to hand over "tangible things", including "records", as long as the FBI shows it is reasonable to believe the things are "relevant to an authorized investigation" into international terrorism or foreign intelligence activities. The history of the word "relevant" is key to understanding that passage. The Supreme Court in 1991 said things are "relevant" if there is a "reasonable possibility" that they will produce information related to the subject of the investigation. In criminal cases, courts previously have found that very large sets of information did not meet the relevance standard because significant portionsinnocent people's informationwould not be pertinent. But the court has developed separate precedents, centered on the idea that investigations to prevent national-security threats are different from ordinary criminal cases. The court's rulings on such matters are classified and almost impossible to challenge because of the secret nature of the proceedings. According to the court, the special nature of national-security and terrorism-prevention cases means "relevant" can have a broader meaning for those investigations, say people familiar with the rulings.


text: People familiar with the system that uses phone records in investigations have said that the court's novel legal theories allow the system to include bulk phone records, as long as there are privacy safeguards to limit searches. NSA analysts may query the database only "when there is a reasonable suspicion, based on specific facts, that the particular basis for the query is associated with a foreign terrorist organization", according to Director of National Intelligence James Clapper. The NSA database includes data about people's phone calls numbers dialed, how long a call lastedbut not the actual conversations. According to Supreme Court rulings, a phone call's content is covered by the Constitution's Fourth Amendment, which restricts unreasonable searches, but the other types of data are not.


text: "Relevant" has long been a broad standard, but the way the court is interpreting it, to mean, in effect, "everything", is new, said Mark Eckenwiler, a lawyer who until December 2012 was the Justice Department's primary authority on federal criminal surveillance law. "I think it's a stretch" of previous federal legal interpretations, said Eckenwiler. If a federal attorney "served a grand-jury subpoena for such a broad class of records in a criminal investigation, he or she would be laughed out of court". Given the traditional legal definition of relevant, Timothy Edgar, a former top privacy lawyer at the Office of the Director of National Intelligence and the National Security Council in the Bush and Obama administrations, noted it is "a fair point" to say that someone reading the law might believe it refers to "individualized requests" or "requests in small batches, rather than in bulk database form". From that standpoint, Edgar said, the reinterpretation of relevant amounts to "secret law".


text: In June 2013, a copy of a top-secret warrant, issued by the court on April 25, 2013, was leaked to London's "The Guardian" newspaper by NSA contractor Edward Snowden. That warrant orders Verizon Business Network Services to provide a daily feed to the NSA containing "telephony metadata" – comprehensive call detail records, including location data – about all calls in its system, including those that occur "wholly within the United States, including local telephone calls". The Obama administration published on July 31, 2013 a FISA Court ruling supporting an earlier order requiring a Verizon subsidiary to turn over all of its customers' phone logs for a three-month period, with rules that must be followed when accessing the data.


text: The document leaked to "The Guardian" acted as a "smoking gun" and sparked a public outcry of criticism and complaints that the court exceeded its authority and violated the Fourth Amendment by issuing general warrants. "The Washington Post" then reported that it knew of other orders, and that the court had been issuing such orders, to all telecommunication companies, every three months since May 24, 2006.


text: Since the telephone metadata program was revealed, the intelligence community, some members of Congress, and the Obama administration have defended its legality and use. Most of these defenses involve the 1979 Supreme Court decision "Smith v. Maryland" which established that people do not have a "reasonable expectation" of privacy for electronic metadata held by third parties like a cellphone provider. That data is not considered "content", theoretically giving law enforcement more flexibility in collecting it.


text: On July 19, 2013, the court renewed the permission for the NSA to collect Verizon customer records en masse. The U.S. government was relying on a part of American case law known as the "third-party doctrine". This notion said that when a person has voluntarily disclosed information to a third party – in this case, the telephony metadata – the customer no longer has a reasonable expectation of privacy over the numbers dialed nor their duration. Therefore, this doctrine argued, such metadata can be accessed by law enforcement with essentially no problem. The content of communications are, however, subject to the Fourth Amendment. The Foreign Intelligence Surveillance Court held in October 2011, citing multiple Supreme Court precedents, that the Fourth Amendment prohibition against unreasonable searches and seizures applies to the contents of all communications, whatever the means, because "a person's private communications are akin to personal papers".


text: Former FISC judge Colleen Kollar-Kotelly, who provided the legal foundation for the NSA amassing a database of all Americans' phone records, told associates in the summer of 2013 that she wanted her legal argument out. Rulings for the plaintiff in cases brought by the ACLU on September 10 and 12, 2013, prompted James Clapper to concede that the government had overreached in its covert surveillance under part 215 of FISA and that the Act would likely be amended to reflect Congressional concern.


text: The American Civil Liberties Union, a customer of Verizon, asked on November 22, 2013 a federal district court in Lower Manhattan, New York to end the NSA phone call data collection program. The ACLU argued that the program violated the U.S. Constitution's guarantees of privacy and information as well as exceeding the scope of its authorizing legislation, Section 215 of the Patriot Act. The U.S. government countered that the program is constitutional and that Congress was fully informed when it authorized and reauthorized Section 215. Moreover, a government lawyer said, the ACLU has no standing to bring the case because it cannot prove that its members have been harmed by the NSA's use of the data.


text: In November 2016, Louise Mensch reported on the news website "Heat Street" that, after an initial June 2016 FBI request was denied, the FISA court had granted a more narrowly focused October request from the FBI "to examine the activities of 'U.S. persons' in Donald Trump's campaign with ties to Russia". On 12 January 2017, BBC journalist Paul Wood reported that, in response to an April 2016 tip from a foreign intelligence agency to the CIA about "money from the Kremlin going into the US presidential campaign", a joint taskforce had been established including representatives of the FBI, the Department of the Treasury, the Department of Justice, the CIA, the Office of the Director of National Intelligence and the National Security Agency. In June 2016, lawyers from the Department of Justice applied to the FISA court for "permission to intercept the electronic records from two Russian banks". According to Wood, this application was rejected, as was a more narrowly focused request in July, and the order was finally granted by a different FISA judge on 15 October, three weeks before the presidential election. On January 19, "The New York Times" reported that one of its sources had claimed "intelligence reports based on some of the wiretapped communications had been provided to the White House".


text: On 13 March, the Senate Intelligence Committee demanded that the Trump administration provide evidence to support the President Trump's claim that former President Obama had wiretapped Trump Tower. On 16 March, the Committee reported that they had seen no evidence to support Trump's accusation that the Obama administration tapped his phones during the 2016 presidential campaign.


text: On Fox News on 14 March, commentator Andrew Napolitano said, "Three intelligence sources have informed Fox News that President Obama went outside the chain of command. ... He used GCHQ. What is that? It's the initials for the British intelligence spying agency. Simply by saying to them, 'The president needs transcripts of conversations involving candidate Trump's conversations' he's able to get it and there's no American fingerprints on this." Two days later, on 16 March, White House press spokesperson, Sean Spicer, read this claim to the press. A GCHQ spokesman responded: "Recent allegations made by media commentator Judge Andrew Napolitano about GCHQ being asked to conduct 'wiretapping' against the then president elect are nonsense. They are utterly ridiculous and should be ignored." On 17 March, the U.S. issued a formal apology to the United Kingdom for the accusation.


text: On April 11, "The Washington Post" reported that the FBI had been granted a FISA warrant in the summer of 2016 to monitor then-Trump foreign policy adviser Carter Page. According to the report, "The FBI and the Justice Department obtained the warrant targeting Carter Page's communications after convincing a Foreign Intelligence Surveillance Court judge that there was probable cause to believe Page was acting as an agent of a foreign power, in this case Russia, according to the officials." The report also states that the warrant has been renewed multiple times since its first issue. These warrants were criticized in the controversial Nunes memo for allegedly being issued on the basis of evidence gathered by politically motivated sources.


text: When the court was founded, it was composed of seven federal district judges appointed by the Chief Justice of the United States, each serving a seven-year term, with one judge being appointed each year. In 2001, the USA PATRIOT Act expanded the court from seven to eleven judges, and required that at least three of the Court's judges live within of the District of Columbia. No judge may be appointed to this court more than once, and no judge may be appointed to both the Court of Review and the FISA court.


title: Criminal Tribes Act

text: Since the 1870s, various pieces of colonial legislation in India during British rule were collectively called the Criminal Tribes Act (CTA), which criminalized entire communities by designating them as habitual criminals. Under these acts, ethnic or social communities in India were defined as "addicted to the systematic commission of non-bailable offences" such as thefts, and were registered by the government. Adult males of the groups were forced to report weekly to local police, and had restrictions on their movement imposed.


title: Criminal Tribes Act

text: The first CTA, the Criminal Tribes Act 1871, applied mostly in North India, before it was extended to the Bengal Presidency and other areas in 1876, and updated to the Criminal Tribes Act 1911, which included the Madras Presidency. The Act went through several amendments in the next decade, and, finally, the Criminal Tribes Act 1924 incorporated all of them.


title: Criminal Tribes Act

text: At the time of Indian independence in 1947, thirteen million people in 127 communities faced search and arrest if any member of the group was found outside the prescribed area. The Act was repealed in August 1949 and former "criminal tribes" were denotified in 1952, when the Act was replaced with the Habitual Offenders Act 1952. In 1961 state governments started releasing lists of such tribes.


title: Criminal Tribes Act

text: Today, there are 313 Nomadic Tribes and 198 Denotified Tribes of India, yet the legacy of the past continues to affect the majority of 60 million people belonging to these tribes, as their historical associations have meant continued alienation and stereotyping by the police and the media as well as economic hardships. Many of them are still described as "Ex-Criminal Tribes".


title: Criminal Tribes Act

text: Sociologist Meena Radhakrishna writes that after the revolt of 1857, many tribal chiefs such as Avantibai Lodhi, and Dhan Singh Gurjar were labelled traitors and considered rebellious.


title: Criminal Tribes Act

text: The colonial government found the demarcation between wandering criminal tribes, vagrants, itinerants, travelling tradesmen, nomads and gypsies difficult to manage, so they were all, even eunuchs (hijras), grouped together, and their subsequent generations were labelled a "law and order problem" for the state.


title: Criminal Tribes Act

text: Historian David Arnold has suggested that because many of these tribes were small communities of poor, low-caste and nomadic people living on the fringes of the society, living as petty traders, pastoralists, gypsies, hill and forest dwelling tribes, they did not conform to the prevailing European standards of living, which involved settled agriculture and waged labour. Those with nomadic lifestyles were seen as a menace to 19th century society and required control, or at least surveillance.


title: Criminal Tribes Act

text: The measure was a part of a wider attempt at social engineering which saw, for example, the categorisation of castes as being "agricultural" or "martial" as a means of facilitating the distribution of property or recognising which groups were loyal to the colonial government and therefore suitable for military recruitment, respectively.


title: Criminal Tribes Act

text: Elsewhere the concept of Reformatory Schools for such people had already been initiated by mid-19th century by social reformers, such as Mary Carpenter (1807–1877), who was the first to coin the term "dangerous classes".


title: Criminal Tribes Act

text: Because it came to be thought that behavior was hereditary rather than learned, crime became ethnic, and what was merely social determinism till then became biological determinism.


title: Criminal Tribes Act

text: The colonial government prepared a list of "criminal castes", and all members registered in these castes by caste-census were restricted in terms of regions they could visit, move about in or people they could socialise with. In certain regions, entire caste groups were presumed guilty by birth, arrested, children separated from their parents, and held in penal colonies or quarantined without conviction or due process.


title: Criminal Tribes Act

text: The Criminal Tribes Act was one of the many laws passed by the British colonial government that applied to Indians based on their religion and caste identification. The Criminal Tribes Act and its provisions used the term "Tribes", which included castes within their scope. This terminology was preferred for various reasons, including Muslim sensitivities that considered castes by definition Hindu, and preferred "Tribes" as a more generic term that included Muslims.


title: Criminal Tribes Act

text: When the Bill was introduced in 1871 by British official T.V. Stephens, he said: "... people from time immemorial have been pursuing the caste system defined job-positions: weaving, carpentry and such were hereditary jobs. So there must have been hereditary criminals also who pursued their forefathers’ profession."


title: Criminal Tribes Act

text: James Fitzjames Stephen testified, "When we speak of professional criminals, we...(mean) a tribe whose ancestors were criminals from time immemorial, who are themselves destined by the usage of caste to commit crime, and whose descendants will be offenders against the law, until the whole tribe is exterminated or accounted for in manner of thugs".


title: Criminal Tribes Act

text: The castes and tribes "notified" under the Act were labelled as "Criminal Tribes" for their so-called "criminal tendencies". As a result, anyone born in these communities across the country was presumed as a "born criminal", irrespective of their criminal precedents. This gave the police sweeping powers to arrest them, control them, and monitor their movements.


title: Criminal Tribes Act

text: Once a tribe was officially notified, its members had no recourse to repeal such notices under the judicial system. From then on, their movements were monitored through a system of compulsory registration and passes, which specified where the holders could travel and reside, and district magistrates were required to maintain records of all such people.


title: Criminal Tribes Act

text: The British government was able to summon a large amount of public support, including the nationalist press, for the excesses committed, because the Criminal Tribes Act was posed widely as a social reform measure which reformed criminals through work. However, when they tried to make a living like everybody else, they did not find work outside the settlement because of public prejudice and ostracisation.


title: Criminal Tribes Act

text: An inquiry was set up in 1883, to investigate the need for extending the Act to the rest of India, and received an affirmative response. 1897 saw another amendment to the Act, wherein local governments were empowered to establish separate "reformatory" settlements, for tribal boys from age four to eighteen years, away from their parents.


title: Criminal Tribes Act

text: Eventually, in 1911, it was enacted in Madras Presidency as well, bringing entire India into the jurisdiction of this law, in 1908, special ‘settlements’ were constructed for the notified tribes where they had to perform hard labour. With subsequent amendments to the Act, punitive penalties were increased, and fingerprinting of all members of the criminal tribe was made compulsory, such tight control according to many scholars was placed to ensure that no future revolts could take place.


title: Criminal Tribes Act

text: Many of the tribes were "settled" in villages under the police guard, whose job was to ensure that no registered member of the tribe was absent without notice. Also imposition of punitive police posts on the villages with history of "misconduct" was also common.


title: Criminal Tribes Act

text: to deal with the so-called criminal tribes of the Madras presidency, including Veppur Parayars and Piramalai


title: Criminal Tribes Act

text: Kallar, in South Arcot district. Some of the peoples of Veppur Paraiyar and Piramalai Kallar were arrested under the Criminal Tribes Act and formed the Aziz Nagar settlement. The oppressed people in the Aziz Nagar settlement were without even basic facilities and food. T. M. Jambulingam Mudaliar visited the Aziz Nagar settlement unofficially and provided food and basic necessities to affected people there. Jambulinga Mudaliar vehemently opposed the Criminal Tribes Act, but only the Criminal Tribes Act against the Vanniyar Padayachi of the South Arcot was repealed.


title: Criminal Tribes Act

text: In the coming decades, to evade prosecution under the Act, many of these notified tribes took up nomadic existence, living on the fringes of society.


title: Criminal Tribes Act

text: Professor of history Ramnarayan Rawat states that the criminal-by-birth castes under this Act included initially Gujjar ,Gadriya , Ahir but expanded by the late 19th century to include most of Chamars, as well as Sanyasis and hill tribes. Other major British census based caste groups that were included as criminal-by-birth under this Act included Bowreah, Budducks, Bedyas, Domes, Dormas, Gujjar, Rebari, Pasi, Dasads, Nonias, Moosaheers, Rajwars, Gahsees Boayas, Dharees, Sowakhyas.


title: Criminal Tribes Act

text: Hundreds of Hindu communities were brought under the Criminal Tribes Act. By 1931, the colonial government listed 237 criminal castes and tribes under the act in the Madras Presidency alone.


title: Criminal Tribes Act

text: Though it was primarily directed at tribal communities, various incarnations of the Criminal Tribes Act also included provisions limiting the rights of transgender and gender non-conforming individuals and communities in India. "Hijras" in particular were targeted under the Act.


title: Criminal Tribes Act

text: The Criminal Tribes Act of 1871 created the category of "eunuch" to refer to the many, often unrelated gender non-conforming communities in India, including "hijras", "khwajasarais", and "kotis". The label "eunuch" was used as a catchall term for anyone thought not to conform to traditional British ideals of masculinity, though in reality most of the communities classified as "eunuchs" did not identify as male or female.


title: Criminal Tribes Act

text: Under the Criminal Tribes Act, a eunuch could be either "respectable" or "suspicious." Respectable eunuchs did not engage in "kidnapping, castration or sodomy," while suspicious eunuchs performed in public and wore what British officials classified as female clothes. The Criminal Tribes Act banned all behaviour considered "suspicious," warning that anyone found engaging in traditional "hijra" activities like public dancing or dressing in women's clothing would be arrested and/or forced to pay a fine.


title: Criminal Tribes Act

text: Colonial authorities claimed that it was necessary for "eunuchs" to be registered under the Act to prevent them from kidnapping children and/or engaging in sodomy. In reality, there was little official evidence of any gender non-conforming communities in India kidnapping children, or of many children living in gender non-conforming communities. The few children that were found to be living with "hijras" were removed from their care, despite the fact that most of the children did not have any other legal guardians and had been adopted into the "hijra" community because they were orphans or unwanted by their biological families.


title: Criminal Tribes Act

text: This practice became controversial and did not enjoy the support of all British colonial officials. Henry Schwarz, a professor at Georgetown University specialising in the history of colonial and postcolonial India, wrote that this decades-long practice was reversed at the start of the 20th century with the proclamation that people "could not be incarcerated indefinitely on the presumption of [inherited] bad character".