Monday, May 18, 2020
Argumentative Essay Topics - Thinking Through Conflict
<h1>Argumentative Essay Topics - Thinking Through Conflict</h1><p>The Middle East is surely one of the most fascinating and discussion filled territories on the planet today. The contentions are once in a while uproarious and now and again enthusiastic. Notwithstanding this, there is likewise a requirement for a center ground. Shockingly, numerous understudies stay away from the Middle East and attempt to find a decent line of work by doing a worldwide examination abroad program, which is essentially a misuse of time.</p><p></p><p>In reality, my college presented a genuine case of contending in exposition points utilizing Middle East issues. Our objective was to open understudies to the pugnacious procedure and improve their capacities to investigate and reach determinations rapidly. They were likewise educated to get struggle and how to utilize it as a venturing stone to a superior comprehension of how individuals see issues.</p><p& gt;</p><p>What I like about the contentious paper subjects from my school was that it was amazingly adjusted. The points were identified with things that most understudies definitely knew, yet they were additionally adjusted by a perspective that most understudies didn't know.</p><p></p><p>Middle East isn't typically a locale that understudies study. Most schools don't generally have any projects that attention on Middle East. This is the reason they will in general make contentions that are solely one-sided or begging to be proven wrong and not adjusted or dependent on research.</p><p></p><p>Not just is this awful for their vocations, yet the understudy regularly wind up being left with poor and terrible training that doesn't set them up for their future undertakings. Of course, when they graduate they will have the option to do things like talk before enormous gatherings of individuals. In any case, it won't convert into any genuine skills.</p><p></p><p>It is essential to understand that regardless of how terrible it is for the understudy, the privilege pugnacious article points from a decent organization can be incredibly advantageous for their future. It is conceivable to state something with power and make an informed contention that is additionally basically considered. The key is to ensure you do this well and to build up a group of people. Understudies take in best by gaining from their friends and their teachers.</p><p></p><p>Middle East is loaded up with entrancing inquiries that we should all be happy to consider. Looking into this region and getting great pugnacious exposition points will open up such huge numbers of entryways for understudies to set out on new and energizing experiences.</p>
Wednesday, May 13, 2020
Online Essay C1 Samples - Do They Really Work?
<h1>Online Essay C1 Samples - Do They Really Work?</h1><p>You can get article C1 tests on the web. These sorts of training expositions are significant on the off chance that you need to be effective in school or in the event that you will be in school. These are the sort of expositions that you write to offer your input on a given point, as a rule utilizing not very many sentences, yet so much data that your peruser will feel just as he has skimmed through it and come out with an informed estimate on the topic.</p><p></p><p>One of the most troublesome pieces of composing paper C is thinking of a subject that you feel that you are well learned about. This can be a subject that you think minimal about, for example, a point in one of your preferred motion pictures, or it tends to be a theme that you don't know about, however that you feel your perusers may. Despite the theme that you pick, ensure that the point is something that will urge your p erusers to recall your exposition and give you criticism on the essay.</p><p></p><p>Having a subject is just 50% of the fight, however. You will likewise need to compose an extraordinary paper. On the off chance that you don't have the composing abilities important to compose an exposition that you feel is elegantly composed, you can generally employ a coach or an essayist to support you. Exposition C1 tests are astounding, and with the correct guide, you can compose an article in minutes that is anything but difficult to peruse and to understand.</p><p></p><p>In request to discover paper C tests, look on the Internet. There are numerous sites that offer a wide range of themes for paper C. You can scan for them and locate the ones that you feel are suitable for your point. These examples can assist you with finding the themes that you feel will be a solid match for your article and for your capacity to compose an essay.</p><p& gt;</p><p>If you are truly short on schedule, you can even search for paper C tests all alone. You should be cautious, in any case, as a portion of these locales expect you to be a part to see their example. Most sites that offer example expositions do necessitate that you be a part so as to see the samples.</p><p></p><p>Essay C is normally around 2 pages in length, albeit some example articles are longer. It is basic that the example you use contains the correct designing for your exposition, as this is the thing that makes the article simple to peruse and comprehend. A portion of the example articles are pre-designed, and this implies you must be certain that you realize how to arrange your paper before you start perusing the sample.</p><p></p><p>You ought to likewise be certain that the examples you take a gander at are organized for the kind of programming that you will utilize when you are composing your exposition. Mo st PC projects will design an example to the details of the program they are being utilized with. On the off chance that an example isn't designed appropriately, it will be difficult to peruse, and you may even end up following your essay.</p><p></p><p>Essay C1 tests are not required to get into school, however they are useful in getting ready for school level composition. On the off chance that you have an inquiry regarding what sorts of paper tests are ideal, check with your nearby school or college. They will likely have a couple of test expositions presented online for you on read.</p>
Saturday, May 9, 2020
Some Easy Steps to Write a College Paper
<h1>Some Easy Steps to Write a College Paper</h1><p>There are such a large number of various parts of the school paper that can influence its prosperity. These angles incorporate how well you do your examination, the amount you need to compose and how you need to make your paper. The two most significant parts of a school paper is that it has a decent theme and that it has a decent article that you can write.</p><p></p><p>How well you examine your point and afterward choose what to compose, are key parts of the examination that you have to do. Despite the fact that there is some significant research that should be done preceding the real paper composing, it is still best to do some starter inquire about on your point. You would prefer not to simply get an irregular subject and compose an exposition about it. Obviously, it is essential to get something out of the paper that you can be pleased with. In any case, you would prefer not to be reluc tant to set aside a little effort to consider the sort of paper that you need to write.</p><p></p><p>When you start your school paper, recall that it is an opportunity to show everybody at your school that you can compose a decent article. In some cases you have to investigate different papers that you have written to perceive what makes them so effective. You can likewise go to different sites and set out to find out about what they are stating about school papers. You can likewise see exposition test locales online that will permit you to perceive what sort of themes you should compose about.</p><p></p><p>You should attempt to be set up for everything that comes your direction when you are composing your article and this incorporates the subject of your paper. Continuously inquire about a subject early in light of the fact that this will spare you a great deal of time and exertion during the creative cycle. On the off chance that you can't compose the subject of your paper because of absence of data, you should investigate different choices, for example, utilizing a portion of the free models accessible to you.</p><p></p><p>When you are wanting to compose your paper, you will find that the title that you pick is another factor that will help decide the accomplishment of your paper. The title of your paper is a significant factor, since you should compose the title for the principal passage. The title will decide whether your article is distributed or not. In this way, your title ought to be something that individuals will need to peruse with the goal that they can get a few thoughts for their own papers.</p><p></p><p>Article accommodation destinations will offer you the chance to submit articles that you can use in your paper. On the off chance that you consider different parts of a school paper, you will see that the exposition is really comprised of a few unique parts that you should remember for your paper. You ought to consistently recall that these various parts are going to should be incorporated and composed with the goal that you can guarantee that the paper you are submitting to a school has the entirety of the vital data for them to distribute your paper.</p><p></p><p>Once you have made sense of the title and article that you need to use for your school paper, the time has come to compose the primary section. The main section is the acquaintance ought to be utilized with present your point. There are numerous authors who find that they compose this passage rapidly and frequently skirt it. The presentation is the place you will present your point such that perusers will discover interesting.</p><p></p><p>There are various approaches to compose your first passage. It is essential to compose it so that individuals won't be confounded by it. It is likewise a smart thought to keep a word m ean your paper so you can know precisely how much space you need to expound on. Utilizing these means should assist you with composing a decent school paper.</p>
Top Five Points to Keep in Mind When Studying Topics That You Dont Need to Research
<h1>Top Five Points to Keep in Mind When Studying Topics That You Don't Need to Research</h1><p>As you plan on composing a decent article, class conversations, or even a book report, it's critical to follow certain focuses so as to keep things basic and to maintain a strategic distance from the entanglements of paper composing. In all actuality a large portion of the subjects that are investigated in class conversations or composed reports include some sort of point or issue. Since such huge numbers of various expositions, books, and papers are composed every year, there is a hazard that your subject will get lost or that it won't fit in with the general tone of the report. Here are a few focuses to consider when you're arranging your exposition topic.</p><p></p><p>First, ensure that your composing is as straightforward as could be expected under the circumstances, while as yet keeping it reliable. One approach to achieve this is to dodge the utilization of sentence structure or spellings that you wouldn't regularly find, all things considered. Try not to let the possibility of a straightforward paper escape from you. Recollect that the general idea ought to continue as before all through your exploration, so don't let the utilization of incorrectly spelled words or ineffectively worded sentences cheapen your efforts.</p><p></p><p>Secondly, in the event that you have any questions about whether your task should be examined or talked about in some other manner, it likely doesn't. Numerous sorts of articles basically can't exist without some kind of verifiable proof or for a particular point to be examined. Remember that the emphasis is on giving your peruser an away from and that the entirety of the data gave ought to be cognizant the remainder of the essay.</p><p></p><p>Third, you need to take a gander at your theme equitably. For whatever length of time that your center i s your perusers and what they need to know, your own thoughts and suppositions ought to have small bearing on the substance of your paper. Research is one of the most well known approaches to expand an article, so ensure that you don't turn out to be so enveloped with inquiring about that you neglect to consider how your contention will influence others.</p><p></p><p>Fourth, remember that you're not composing a book report or doing research for your school expositions. At the point when you compose a run of the mill paper or a history paper, the topic or subject is as of now characterized. You don't have to incorporate any subtleties starting here, yet you do need to think about the foundation of the material. Since there is such a distinction between composing an exposition and composing a paper, ensure that you address your understudy's perspectives on the topic.</p><p></p><p>Fifth, don't imagine that composing an article about a spe cific subject will be simple. Actually, the inverse is valid. It takes a lot of thought, arranging, and a great deal of association so as to get ready and compose an article that will leave your peruser with as much data as possible.</p><p></p><p>Sixth, know that the points that you pick should be anything but difficult to investigate, in light of the fact that they won't be as useful as the ones that you pick. In spite of the fact that you may feel that a particular subject will be very much inquired about, odds are that others won't concur. Along these lines, you have to decide if the subject you pick is going to help the general motivation behind your essay.</p><p></p><p>Finally, ensure that your schoolwork task is as near the point that you have picked as could reasonably be expected. On the off chance that your task includes the historical backdrop of a specific theme, it will be simpler to concentrate on it in the event that you know precisely what you will examine. Recollect that you should have the option to assess your assignments dependent on their own benefits, so pick your point with care.</p>
Wednesday, May 6, 2020
Summary of Max Webers The Protestant Ethic and the Spirit...
Summary of Max Webers The Protestant Ethic and the Spirit of Capitalism Max Webers The Protestant Ethic and the Spirit of Capitalism is a study of the relationship between the ethics of ascetic Protestantism and the emergence of the spirit of modern capitalism. Weber argues that the religious ideas of groups such as the Calvinists played a role in creating the capitalistic spirit. Weber first observes a correlation between being Protestant and being involved in business, and declares his intent to explore religion as a potential cause of the modern economic conditions. He argues that the modern spirit of capitalism sees profit as an end in itself, and pursuing profit as virtuous. Webers goal is to understand the source of thisâ⬠¦show more contentâ⬠¦While important, this alone cannot explain the need to pursue profit. One branch of Protestantism, Calvinism, does provide this explanation. Calvinists believe in predestination--that God has already determined who is saved and damned. As Calvinism developed, a deep psychological need for clues about w hether one was actually saved arose, and Calvinists looked to their success in worldly activity for those clues. Thus, they came to value profit and material success as signs of Gods favor. Other religious groups, such as the Pietists, Methodists, and the Baptist sects had similar attitudes to a lesser degree. Weber argues that this new attitude broke down the traditional economic system, paving the way for modern capitalism. However, once capitalism emerged, the Protestant values were no longer necessary, and their ethic took on a life of its own. We are now locked into the spirit of capitalism because it is so useful for modern economic activity. Throughout his book, Weber emphasizes that his account is incomplete. He is not arguing that Protestantism caused the capitalistic spirit, but rather that it was one contributing factor. He also acknowledges that capitalism itself had an impact on the development of the religious ideas. The full story is much more complex than Webers partial account, and Weber himself constantly reminds his readers about his own limitations. The book itself has an introduction and five chapters. The first three chapters make upShow MoreRelatedMax Weber And Durkheim s Views On Religion1250 Words à |à 5 Pagescultural systems that relate humanity to an order of existence. One of the foundations of religion is social orientation that in one way or another influence a society s social stability. Max Weber along with Emile Durkheim were very influential people in the course of social stability in the 19th century. Weber and Durkheim attempted to make comprehensible social changes, particularly in the aspects of religion of a society. Their perspectives on religion differ on some aspects. 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Tuesday, May 5, 2020
E-Commerce System Electronic Commerce Research
Question: Discuss about the E-Commerce System for Electronic Commerce Research. Answer: Introduction The development of business organization has been a result of the introduction of the E-commerce system operations of the organization. The use of the technological advancement and improved tools has helped in easing the operations of the business organization (Chiu et al. 2014). The E-commerce system provides the edge for increasing their business operations. The report has been made for analyzing the functions and development of E-commerce system for the operations of business organization. The study has been conducted by analyzing different journal articles like A case study of E-Commerce Strategies for Retail Businesses, Consumption of E-banking services by consumers in Pakistan and The Adoption of e-Banking: The Case of Omani Banks. A detailed critical analysis has been done in the report on the topic of E-commerce system. Role of E-commerce in expansion of market based business model E-commerce plays a very vital role for the expansion of the business operations and it improves the functionality of the organizations (Fang et al. 2014). The study and evaluation of the journal article A case study of E-Commerce Strategies for Retail Businesses consists of three case studies. The role of E-commerce for the expansion of market based business model has been described below: Capture of Emerging Markets: The Muldoons Mens Wear had been largely assisted for capturing the emerging market by the use of the E-commerce strategies and system. The reach of their products and name increased in nearby markets (Huang and Benyoucef 2013). The E-commerce has helped them to sustain local as well as some global market. Increased Customers: Muldoons Mens Wear has seen the growth of the number of customers with the implementation of the E-commerce and online facilities. The online shopping process has incremented the overall customers interest in the shop and their products. Focus on a specific group: The use of E-commerce strategies and system would help the business organization for focusing on a specific group of customers (Choi et al. 2013). The DetailsDirect have used E-commerce strategies and system for establishing their operations on a niche market and promoting their products for women and children. Variety of products: The E-commerce activities would provide the ease of promoting and marketing any specific product. The DetailsDirect has applied the E-commerce strategies and system to promote specific products and for attracting customers. Management of both online and traditional stores: The advent of E-commerce strategies and system has helped Totally Fun Toys for managing both online operations and traditional sales operation. The use of E-commerce activities would help in aligning the operations of the business organization for the business organization. Market Program Affiliation: The market program affiliation is also carried by the Totally Fun Toys with the assistance of E-commerce strategies and system. It has helped the company for allowing other companies to post and sell their products on the website of the Totally Fun Toys. However, the use of E-Commerce strategies and system has also resulted in bringing strong competitors, privacy issues, and security flaws for the business organization. These issues have to be dealt and overcome for getting the benefit of the E-commerce system and strategies. The growth of technologies has made the process of getting into the system possible (Da Costa 2016). Many cyber criminals and hackers get into the information system of different banks for extracting information from it. The information stolen can be misused for harassing the person and extracting economic benefit from them. Change of Relationship among vendors and suppliers with E-commerce The use of E-commerce would be helpful for establishing the relation between the vendors and the suppliers (Barnes and Hunt 2013). The companies doing E-commerce activities do not buy product and sell it from their inventory. They use the suppliers for delivering the product to the customers. The operations of the companies can be improved by the use of E-commerce processes for communicating with the different suppliers and vendors. The use of E-commerce would be helpful for establishing the relation between the vendors and the suppliers. There are many benefits for the use of E-commerce such as ease of communication, faster services, information sharing, accessibility, and proposals and offers that has changed the relation and operations between the vendors and suppliers (Zou et al. 2014). They are- Ease of communication: The development of business operations with the aid of E-commerce has resulted in increasing the efficiency of communications with different vendors and suppliers (Einav et al. 2014). The E-commerce acts as a platform for storage of data and information of the business organizations. These data can be sent to respective supplier and vendor for easing the process of communication with them. Hence, the process of the communication has been largely benefited with the assistance from the E-commerce system. Faster services: The most important benefit of the E-commerce system is the provision for faster services for the operations of business organizations (Campbell, Wells and Valacich 2013). The E-commerce system had assisted the organization for improving their operations and for getting faster services from the suppliers and providing faster services to the vendors. The relationship with the vendors and suppliers has been largely improved with the help of E-commerce activities. Information sharing: The E-commerce acts as a platform for storage of data and information of the business organizations (Sila 2013). The data storage in the E-commerce system is automatic and the data can be updated faster than traditional business organizations. These data can be sent to respective supplier and vendor as a mean for information exchange. The information includes data like stock requirements, order details, estimated price and profit margin required. It would help the company for getting the services with minimum chances of error. Accessibility: The E-commerce has acted as the platform for accessing information and data (Da Costa 2016). Even the operations of the business organization and strategies can be improved by the help of access to prior records and data. The use of the E-commerce platform would assist the business organization for large set of data access and preparation for future outcomes. Proposals and offers: The use of E-commerce system has helped in providing various offers, schemes and proposals to the vendors or suppliers. It has helped in making a friendly relation with the suppliers and vendors and increasing the transactions. Barriers of E-banking for customers and banks E-banking refers to the term used for the process of using the Internet as a source of banking operations (Goi 2015). The transactions such as payment, balance enquiry, and mini statement can be completed with the help of online options on the bank site. The growth and development of the e-commerce has been possible with the help of implementation of the e-banking processes. The technology acceptance model has been specifically used for describing the relationship among the system designs and its operations. There are three main predictors for the use of internet as an option for the banking activities and they are Trust, Compatibility, and Ease of Use (Chong, Seow and Lee 2015). The barriers to the use of E-banking are primarily the security issues. Some other barriers are lack of knowledge and complexity. They have been explained in the following points: Security issues: Security is the most primary issue that plays a major role for development or uproot of any system (Fonseca 2014). The E-banking system includes the operations of banks such as payment, balance enquiry, and statements. These operations require the storage of huge amount of data and information such as account and personal details of the customers. Hence it is very important for keeping these information and data secured and confidential. The different security designs and features like firewall and IDS are used for protecting the system from any external infiltration (Liebana-Cabanillas, Munoz-Leiva and Rejon-Guardia 2013). However, the growth of technologies has made the process of getting into the system possible. Many cyber criminals and hackers get into the information system of different banks for extracting information from it. The information stolen can be misused for harassing the person and extracting economic benefit from them. Lack of Knowledge: The other barriers for the development and implementation of E-banking system for all the banking operations include the lack of knowledge (Mermod 2015). The technology has been in state of forever modifications and there is always scope for development of their functions. It has been seen that every year some new technology (latest technology discovered is Nano Technology) has been developed and is made ready for implementation in the commercial operations (Kumar and Sriram 2016). However, the human insights are limited for understanding all aspects of technology in whole. Complexity of operations: The other barriers for the development and implementation of E-banking system for all the banking operations include the barrier of complexity (Fatima 2015). The system defined for the operations of E-banking system include a system structure where all the processes take place systematically. The advancement of the technology has increased the operations of the business organization and brought about a number of functions in the E-banking system (Jaiswal, Awasthi and Bhasin 2015). It has resulted in increasing the level of complexities of understanding the system and operations. Hence, the small scale industries avoid the system due to its complex structure and operations. Dependency on Internet: The E-commerce system has to be dependent on the Internet services that might not work all time due to any technical errors (Pham et al. 2013). The E-banking transactions can fail due to server crash and run time errors. Hence the E-banking system lacks the operation functionality in case of Internet issues. Absence of training programs: The lack of advanced training programs for the operations of E-commerce system has resulted in limiting the scope for the development of the E-commerce system. The overall benefits of the use of E-banking include the features of time saving, easy to use, and cost efficient (Fonchamnyo 2013). Hence, a strong E-banking structure must be made for dealing with the security flaws and other barriers. Recommendations for E-banking system The business organization has been using the technological advancement and improved tools for easing their operations. They have incorporated E-banking for optimizing their banking operations such as transactions of payment, balance enquiry, and mini statement. The e-commerce has been possible with the help of implementation of the e-banking processes. However there are some barriers to the use of E-banking like the security issues, lack of knowledge and complexity. These barriers have affected the utilization of the E-banking system for the business organization. The suggestions for the business organization are- Improved security: The improved security designs of the E-banking system would assist in easing the operations and implementation of the E-banking system. The improvement of the security features could be achieved by the use of the technological development. The different security designs and features like firewall and IDS are used for protecting the system from any external infiltration. Secured Design of operations: The secured designs would ease the process for implication of the E-banking system. The secured design would help in assisting the privacy of information and data stored. The secured design would require the implementation of the security features mentioned above. The IDS and IPS works in pair for detecting any intrusion in the system or network. The IDS would alert the system for intrusion by sending a signal or message to the main server for ceasing all the operations of the system or server. However, IPS would be helpful for keeping the extrusion away from the main system. Training of members: The E-banking system has the disadvantage of members of the organization not understanding the system and its operations. The E-banking technology has developed with the vast stretch of technology and techniques. The advancement of the technology has resulted in increasing the level of complexities of understanding the system and operations. The lack of understanding can be dealt by training the employees to deal with the problems faced in using the E-banking system. Limitation of Access: The private and confidential information like account and personal details of the customers and bank records is very confidential and it is important for keeping these information and data secured and private. The limitation of the access to information and data would assist in keeping the data privacy checked and regulated from infiltration. It can be implemented by using authorization and verification of user with the help of password system. App Development: The modern technology like Smartphone can also be used for improving the operations of the E-banking. An app for Smartphone must be used for improving the operations of the e-banking system. Hence, it can be said that the use of E-banking can be improved by integrating the operations of the business organization with improved security features and secured designs. The E-banking structure and operational features has to be incorporated and made clear to the members of the organization. Conclusion It can be concluded from the report that the E-commerce and E-banking plays a major role for the operations of present business structure. The report has been made for the analysis of the E-commerce system and its role in operations of the business organization. The study has been done by researching the provided. The role of the E-Commerce and E-banking in the business organizations are for capture of emerging markets, increasing customers, focusing on a specific group, introducing variety of products and services, management of both online and traditional stores, market program affiliation, transactions of payment, balance enquiry, and mini statement. The recommendations for the security and successful implementation of E-banking are improved security features, training to users, and secured designs. References Chiu, C.M., Wang, E.T., Fang, Y.H. and Huang, H.Y., 2014. Understanding customers' repeat purchase intentions in B2C e?commerce: the roles of utilitarian value, hedonic value and perceived risk.Information Systems Journal,24(1), pp.85-114. Fang, Y., Qureshi, I., Sun, H., McCole, P., Ramsey, E. and Lim, K.H., 2014. Trust, Satisfaction, and Online Repurchase Intention: The Moderating Role of Perceived Effectiveness of E-Commerce Institutional Mechanisms.Mis Quarterly,38(2), pp.407-427. Huang, Z. and Benyoucef, M., 2013. From e-commerce to social commerce: A close look at design features.Electronic Commerce Research and Applications,12(4), pp.246-259. Choi, H., On, R. and Varian, H.R., Google Inc., 2013.E-commerce price index. U.S. Patent 8,374,907. Da Costa, E., 2016.Global e-commerce strategies for small businesses. Mit Press. Barnes, S. and Hunt, B. eds., 2013.E-commerce and v-business. Routledge. Zou, H.M., Qureshi, I., Fang, Y., Lim, K.H., Ramsey, E. and McCole, P., 2014. Investigating the Nonlinear Effects of Trust on Online Repurchase Intention--The Role of E-Commerce Institutional Contexts. Einav, L., Levin, J., Popov, I. and Sundaresan, N., 2014. Growth, adoption, and use of mobile E-commerce.The American economic review,104(5), pp.489-494. Campbell, D.E., Wells, J.D. and Valacich, J.S., 2013. Breaking the ice in B2C relationships: Understanding pre-adoption e-commerce attraction.Information Systems Research,24(2), pp.219-238. Sila, I., 2013. Factors affecting the adoption of B2B e-commerce technologies.Electronic Commerce Research,13(2), pp.199-236. Goi, C.L., 2015. E-Banking in Malaysia: Opportunity and challenges.The Journal of Internet Banking and Commerce,2005. Fatima, A., 2015. E-Banking Security Issues? Is There A Solution in Biometrics?.The Journal of Internet Banking and Commerce,2011. Chong, Y.L., Seow, A.N. and Lee, E.H., 2015. The adoption of e-banking among rural SME operators in Malaysia: An integration of TAM and TPB.The Josai Journal of Business Administration,11(1), pp.39-49. Libana-Cabanillas, F., Munoz-Leiva, F. and Rejn-Guardia, F., 2013. The determinants of satisfaction with e-banking.Industrial Management Data Systems,113(5), pp.750-767. Mermod, A.Y., 2015. Customer's Perspectives and Risk Issues on E-Banking in Turkey; Should We Still be Online?.The Journal of Internet Banking and Commerce,2011. Pham, L., Cao, N.Y., Nguyen, T.D. and Tran, P.T., 2013. Structural models for e-banking adoption in Vietnam.International Journal of Enterprise Information Systems (IJEIS),9(1), pp.31-48. Jaiswal, B., Awasthi, M. and Bhasin, S., 2015. An Evaluation of Indian E-Banking Industry (A Case Study of State Bank of India: Lucknow Circle, Uttar Pradesh).Asian Journal of Research in Banking and Finance,5(4), pp.45-55. Kumar, P.M. and Sriram, B., 2016. Customer Satisfaction on E-banking Services QualityAn Analytical Study on Banks in Oman.Asian Journal of Research in Banking and Finance,6(10), pp.10-29. Fonseca, J.R., 2014. e-banking culture: A comparison of EU 27 countries and Portuguese case in the EU 27 retail banking context.Journal of Retailing and Consumer Services,21(5), pp.708-716. Fonchamnyo, D.C., 2013. Customers' perception of E-banking adoption in cameroon: an empirical assessment of an extended TAM.International Journal of Economics and Finance,5(1), p.166.
Use of Force and the Constitution free essay sample
U. S. Constitution and Use of Force David Baxter CJ400 Constitutional Law in Criminal Justice Park College September 25th, 2010 Table of Contents Introduction 3 Ideologies Affecting Police Use of Force 4-6 Public Climate Regarding Use of Force 6-8 Law Enforcementââ¬â¢s Position Regarding Use of Force 8-12 Societal Implications 12-13 References 14-15 Introduction The prison escapee broke into the house while the owner was away and stole some food, pain pills, and a loaded handgun. During the night, he dodged the sounds of hounds approaching. He was dead set on getting away at any cost, even if it meant he had to kill an approaching officer. After a few days, the officers finally had him cornered, he had nowhere to run. The run from the law that had started with a break from prison was about to end on a city street. The man on the run sees the officers in broad daylight and as he turns to run, he is met by a hail of gun fire and falls over dead. At the scene, law enforcement quickly converges on the scene, trying to keep onlookers away. It is determined that the man was shot by as many as 17 rounds, but there is no public outcry, no claim of excessive force, and no one suing the officers. The story illustrates a use of police force in America, at a different time, a time when the United States Constitution was still young and the political scales was tipped toward justice, preservation of peace for the community, and punishment for those who breached that peace. How the times have changed, the political correctness that exists in ur modern times shows a societal shift of epic proportions, for the safety and greater good of society has been trumped by the rights of individuals and the due process of the law . There are many issues that come to mind when thinking about police use of force, the Constitution, and the political and societal climate of today. This work seeks to examine four matters in which the U. S. Constitution has played an important part in defining and creating: 1) Ideologies affecting police use of force. 2) Public climate regarding use of force. 3) Law enforcementââ¬â¢s position regarding use of force. ) Societal implications. Ideologies Affecting Police Use of Force The U. S. Constitution was created by the people, for the people. Regardless, the founding fathers of this country saw fit to adopt many of the century old practices and laws of their common law brethren. Whether done out of respect, need, or reasons unknown, the Constitution is the successor, however evolved, of the laws that governed England. The idea of individual liberty and the effect of governmental intrusion were stated best in a speech by President Woodrow Wilson: Liberty has never come from the government. Liberty has always come from the subjects of government. The history of liberty is the history of resistance. The history of liberty is a history of the limitation of governmental power, not the increase of it (Woodrow Wilson, speech, Sep. 1912). While the government can intrude on individual rights, it is up to the people to ensure that certain rights are protected from such intrusions. The Constitution has attempted to keep with the aforementioned ideology, but it has seen many changes since the inception of this country. No changes have been more apparent within our society than the changing ideas of police use of force. As early as the twelfth century, common law allowed the use of deadly force to capture a felony suspect (Amendment IV to the Constitution, West Encyclopedia of American law, as cited in Answers. com). This law was in place for several reasons. The main reason was because not many felonies were committed at that time and the ones that were, were usually punishable by death, therefore, killing a felon was seen more as ââ¬Å"â⬠¦ implementation of the eventual penalty for their offensesâ⬠(Ferdico et al. 2009, p. 338). The other reason had more to do with lack of trained police forces, technology, and weapons. (Amendment IV to the Constitution, West Encyclopedia of American law, as cited in Answers. com). This changed however, fast forward to our modern age and a large number of crimes are now considered felonies and the majority of these crimes are not punishable by death. Mod ern weapons and trained police forces are now in place to deal with criminals on all levels (Ferdico et al. , 2009, p. 338). The defining moment for how law enforcement perceived and used force against resisting or fleeing felons came with the decision in Tennessee v. Garner, 471 U. S. 1 (1985). This decision set the tempo for, not only restricted use of deadly force by law enforcement, but a change in the overall premise of what is considered the righteous use of force by law enforcement officers. Garner, a burglary suspect fleeing from a Memphis Police officer, was shot and killed and from the common law approach the use of force would have been completely justifiable (Ferdico et al. , 2009, p. 39) However, the lawsuit broke ground, because it asserted that Garner was ââ¬Å"â⬠¦unconstitutionally seized in violation of the Fourth Amendment because the use of deadly force against him was unreasonable under the facts and circumstances of the caseâ⬠(Ferdico et al. , 2009, p. 339). The court ruled in favor of Garner, thus forever changing the common law premise. The premise that arises from the Gar ner ruling is that the stateââ¬â¢s interest in capturing a felon does not trump the unarmed and non- dangerous interest the suspect has in living. Therefore, Law enforcement across the country had to change the way they did business. Following the Garner decision, another important chapter in use of force ideology development was Graham v. Connor. In Graham v. Connor, 490 U. S. 386 (1989), the court held that law enforcement officers have to be judged under the standard of reasonableness as set forth from the 4th Amendment. The decision determined that the ââ¬Å"reasonablenessâ⬠of an officerââ¬â¢s actions should be determined by the severity of the crime, the immediate threat that the suspect poses to citizens and/or the officers, and whether the suspect is actively resisting or fleeing (Graham v. Connor, 490 U. S. 386 (1989)). One innate problem with the reasonableness standard exists. If 20 people were asked to determine what is a reasonable amount of force to affect an arrest or detain an individual; there may very well be 20 different opinions on what is reasonable and what is not. In fact, Graham even notes the ambiguity, Because the test of reasonableness under the Fourth Amendment is not capable of precise definition or mechanical application ts proper application requires careful attention to facts and circumstances of each case (Graham, 490 U. S. , at 396). In addition to establishing the reasonableness standard, Graham v. Connor and other cases such as, Illinois v. Gates, 462 U. S. 213 (1983), helped decide ââ¬Å"all uses of force, deadly and non-deadly, are to be judged by the totality of the circumstanceâ⬠and ââ¬Å"â⬠¦those circumstances known to the officer at the time the force was used without the benefit of 20/20 hindsightâ⬠(Ryan, 2009, p. 6). Nevertheless, this standard continues to be applied today and is used to help determine whether or not an officerââ¬â¢s actions are within the boundaries of the Constitution and the 4th Amendment. The evolution from common law to todayââ¬â¢s modern standard of how police use force has led to increased sensitivity within the political arena and the publicââ¬â¢s opinion. Public Climate Regarding Use of Force As the police sergeant sat listening, the woman explained that she was a single mom, in her mid-forties, with two kids. He continued to take her complaint as she described how threatened she felt by all the officers. She demanded something be done about how she was treated. The grievance filed against the officers was not for racial profiling, harassment, or even the slightest violation of her Constitutional rights; the complaint was because she felt threatened by more than one police unit behind her while she was being written a ticket for running a stop sign. This scenario illustrates, on a small scale, the publicââ¬â¢s general perception of police use of force. There are many underlying factors at the core of todayââ¬â¢s viewpoint on use of force. First, police have maltreated the publicââ¬â¢s trust. There exist a great number of cases involving police use of excessive force. Of course the Rodney King incident comes to most peopleââ¬â¢s mind when discussing the misuse of police force. This incident shocked the conscience of a city, nation, and perhaps the world. The subsequent aftershocks of Kingââ¬â¢s beating resulted in the LA Riots ultimately cost over a billion dollars and the deaths of 58 people along with as many as 2,000 injuries (Time, 2007). Another incident that highlights a sadistic misuse of public trust is the incident involving the sexual abuse of Abner Louima by NYPD officer Justin Volpe and other officers. Officer Volpe was sentenced to 30 years in for the assault and the attack incited angry demonstrations by thousands of people (BBC News Online, 1999). These misuses of police force are not only crimes against the U. S. Constitution, but crimes against humanity and the human spirit. When these violations of peopleââ¬â¢s rights occur, it slowly tears down what little trust has been built between the police and the community. These incidents of police abuse, in the digital age, have instant coverage in all parts of the globe. The ability for people to instantly see police using force is another factor that has contributed to the court of public opinion. In todayââ¬â¢s society, the media influences every part of modern life, from the publicââ¬â¢s intrigue of watching real-life entertainment to helping sway the outcome of presidential elections. Policing in the modern video age has changed the publicââ¬â¢s perception of police and how they do their job. Most everyone has seen countless use of forces, arrests, police shootings, and pursuits, the issue with this is that none of it is real; it is TV shows and movies (Johnson, 2007). After repeated exposure to fictional scenarios of force, such as bullets knocking people down and seeing suspects knocked out with a simple punch, the public gets condidtioned to seeing the nice , clean cut police arrest with little collateral damage. The publicââ¬â¢s obsession with ââ¬Å"real lifeâ⬠on film , has everyone becoming an expert and an arm chair quarterback . Warren Richey, a staff writer of The Christian Science Monitor, exhibits an attitude that is prevalent among many persons in the United States when he states: To what extent police may use a stun gun against someone who is not actively resisting arrest but who is passively refusing to obey a police command. To some officers, such refusal is a form of resisting arrest and constitutes grounds to shoot 50,000 volts of electricity into that persons body in five-second bursts (Richey, 2009, p. 2). The public also knows that the courts have a loathing for seconding guessing a police officerââ¬â¢s decision, because of the uncertainty of the stressful situations that they deal with and concern over setting legal precedent that might influence or steal Constitutional police power. This has added fuel to the fire of public opinion. The public has valid concerns over the ever increasing, illegal use of police force. The pervasive attitude that now exists is seen in peaceful demonstrations, violent riots, and never-ending lawsuits against police officers. This attitude toward use f force is only one side of the controversy, police officers deal with the issue first hand, everyday. Law Enforcementââ¬â¢s Position Regarding Use of Force There is no doubt that law enforcement officers have a dangerous and difficult job. The public expects officers to be tough and aggressive enforcers of the law, yet have complete control of their emotions and actions. Officers are aware of this sta ndard, yet they are human and they make mistakes. The U. S. Commission on Civil Rights, in 1981, noted that: Police officers possess awesome powers. They perform their duties under hazardous onditions and with the vigilant public eye upon them. Police officers are permitted only a small margin of error in judgment under conditions that impose high degrees of physical and mental stress (U. S. Commission on Civil Rights, (1981), as cited in the Journal of Criminal Law and Criminology, 1994). The fact is that in many circumstances, a small margin for error has cost many officers their jobs and has caused some to do prison time. This error in judgment or inability of the officer to shut down the emotions and adrenaline is exemplified in the Rodney King incident. Although Kingââ¬â¢s 4th Amendment rights were violated, the vast majority of the officerââ¬â¢s use of force was ruled legal and well within permissible use of force parameters. While substantial force was used to get king to comply and to lie in the prone position, only the last few blows were actually ruled illegal and lead to criminal liability. This was the case, because King had finally complied with the order to assume a prone position and submit to handcuffing when the last few blows were thrown (United States v. Koon, 833 F. Supp. 769 (C. D. Cal. 1993), affââ¬â¢d in part, 518 U. S. 81 (1996)) as noted in (Wallentine, 2007). Once again for police officers doing their job, the line between rigteous use of force and criminal liabilty was very fine. A look into an officerââ¬â¢s perception of use of force would not be complete without the opinion of an experienced street officer who knows first hand about the application of Constitutional righteous use of force when effecting an arrest. Take for instance the real world example of Steve. Steve has been a police officer for 10 years and a defensive tactics trainer for five of those years. He works for a large size city in Arkansas and his interview gives the reader a glimpse of the kind of reality that exists for law enforcement on a day to day basis. Interviewer: What do you consider a use of force? Steve C. : For me, police use of force is simply me being there in uniform or pulling up in my patrol car. This is when use of force starts, because that is when citizens start to perceive you and the fact that you are in charge of a situation. Interviewer: I see, so you believe use of force starts the minute people recognize you as a police officer. How often do you have to use force in a police situation? Steve C. : All the time, because like I said, an officer in uniform is force, but the average Joe public doesnââ¬â¢t think that is use of force. I definitely articulate my presence and peopleââ¬â¢s demeanor in my reports. Interviewer: Ok, I get what you are saying, so how often do you use physical force? Steve C. : Not very often, in general, people think that the police constantly have to wrestle, fight, and use a large amount force, but the honest truth is our professional demeanor, articulate use of communication, and safety in numbers reduces the amount and the number of times we have to use force. Interviewer: Ok, you mention safety in numbers, what is that? Steve C: A citizen may be pulled over for a traffic violation, simple speeding. The initial officer notices the windows a little more tinted than normal and he radios for another officer to provide back up. There just happens to be a third officer who is not busy, so two other units stand by while the initial officer writes the ticket. That is safety in numbers. Interviewer: I see, but the general public may view that differently than the officer in general, correct? Steve C. Yes they always do, they think they are getting picked on, but the truth is we donââ¬â¢t know who we are stopping. I could have just stopped two cars earlier in my shift that had felony warrants on them. Sometimes you have days like that, so you are always cautious. Interviewer: Do you ever think about making the right decisions and applying Constitutional requirements when using force? Steve C. : Every officer, that is a professional, wants to do the right thing, but I donââ¬â¢t think they think of applying the Constitution in every situation. Sometimes, you are just reacting and surviving, especially in high stress use of force situations. Interviewer: Officer thank you for your time and providing insight for this paper. Steve C. : No problem. In general, the courts have sided with officers, knowing that they may face extreme circumstances. The courts have held that even during the use of excessive force, good faith immunity may still be available under some circumstances (Finnegan v. Fountain, 915 F. 2d 817 (2d Cir. 1990)). The revelation that officer Steve B. made in the interview, regarding the infrequency that actual physical force is used is relevant and is backed by proof. In a published study by the Department of Justice, data revealed, ââ¬Å"Known with substantial confidence is that police use force infrequently. The data indicate that a small percentage of police-public encounters involve forceâ⬠(Department of Justice, 1999). The study further goes on to report that the majority of police use of force ââ¬Å" occurs at the lower end of the force spectrum, involving grabbing, pushing, or shovingâ⬠and that the use of deadly force is the force that is used the least (Department of Justice, 1999). Officers have stated that the ability to utilize good communication skills defuses more people than actually hitting them with batons or shooting them with 50,000 volts of electricity. Rarely does the public perceive it this way. The perception of the officer and that of the general public is vastly different and seems to create a divide , a gap that pits the ââ¬Å"us against themâ⬠mentality from advocates on both sides of the issue. What does the difference in indealogies mean for our society? Can this divide be bridged and if so how? Societal Implications The U. S. Constitution has sought stability between individual rights and the security of our society. These lines, at times, have been undeniably blurred. The honest truth is that this is the best we have and most Americans will argue that this is the best system in the world. The Constitution is a living document that is continually evolving to match the demands of our modern society. The changes can be seen by the restrictions placed law enforcement officers use of force on fleeing felons to the changes we see today regarding further 4th Amendment seizures. The public outcry, resulting from shocking use of force abuse and blatant 4th Amendment violation of some peopleââ¬â¢s rights, has been loud and clear. While police departments, internal affairs, supervisors, and everyday street officers themselves have and will publicly denounce blatant misuses of police power, they know that there exists only a small margin of miscalculation. Departments across the country have sought to bridge the gap that exists among the community and police. New Orleans police department, a department riddled with bad cops, corruption, and Constitutional violations, is seeking to change its culture and is doing so by bringing the public on board (McCarthy, 2010). Police have to have an open door policy and for the most part show transparency in the dealings with itââ¬â¢s citizens. Another idea to help bridge the gap would be to openly publish not only crime statistics, but use of force incidents and why they occur. Secrecy breeds suspicion, leading to distrust by the public. Many times a department is involved with using deadly force and fails to communicate to the public why this occurred. Presenting true facts, once the investigation is done, helps the community accepts and heal. Mistakes are unavoidable and when mistakes are made, it is crucial that departments admit error and move on. The public wants to see progress and if errors in judgment, tactics, or for any other reason are made, the department must quickly move to admit and correct the mistake. Sometimes this means more and better training for officers. The court of public opinion is a hard case to win, but educating the public about why officers do what they do will help. Many departments have Citizenââ¬â¢s Police Academyââ¬â¢s for this very reason. Offering basic educational classes on 4th Amendment rights is also another option. Perhaps Woodrow Wilson was correct all along. In order to protect our own freedoms it is the right and privilege of every citizen to be aware of their own rights and to ensure that those rights are protected, not violated. It is clear that no matter what use of force situation law enforcement officers are faced with, it will involve a split-second decision. The public perception is that the officer must be right every single time, but no officer has the time nor means to ensure that an objective test is met every time, under every stressful situation. References Alpert, G P,à ;à Smith, W Cà (Fall 1994). How reasonable is the reasonable man? : police and excessive force. Journal of Criminal Law and Criminology,à 85,à n2. p. 481-501. Retrievedà September 02, 2010,à fromà Criminal Justice Collectionà viaà Gale: http://find. galegroup. com. pegleg. park. edu/gtx/start. do? prodId=PPCJ;userGroupName=morenetpark Amendment IV to the Constitution, West Encyclopedia of American law, as cited in Answers. com). http://www. answers. com/topic/amendment-iv-to-the-u-s-constitution BBC News Online. (1999, Dec 13). NYPD officer jailed for brutality. Retrieved Sep 04, 2010, from http://news. bbc. co. uk/2/hi/americas/563441. stm Department of Justice. (1999, Oct). Use of Force by Police: Overview of National and Local Data. Retrieved Sep 06, 2010, from National Criminal Justice Reference Service: Ferdico. J. , Fradella, H. , Totten, C. (2009). Criminal Procedure for the Criminal Justice Professional, Tenth Edition. Belmont, CA: Wadsworth Cengage Learning. Finnegan v. Fountain, 915 F. 2d 817 (2d Cir. 1990), http://www. ncjrs. gov/pdffiles1/nij/176330-1. pdf Graham v. Connor, 490 U. S. 386 (1989), http://supreme. justia. com/us/490/386/ http://ftp. resource. org/courts. gov/c/F2/915/915. F2d. 817. 89-7832. html Illinois v. Gates, 462 U. S. 213 (1983), http://www. 4lawnotes. com/showthread. php? t=1173 Johnson, J. (2007, April). Use of Force and The Hollywood Factor. Retrieved Sep 04, 2010, from AELE Law Enforcement Legal Center: http://www. aele. org McCarthy, B. a. (2010, May 06). Incoming NOPD superintendent Ronal Serpas faces daunting assignment. Retrieved Sep 06, 2010, from NOLA. com : www. NOLA. com Richey, W. (May 28, 2009). Police Tasers: excessive force or necessary tool?. The Christian Science Monitor,à p. 2. Retrievedà September 02, 2010,à fromà Criminal Justice Collectionà viaà Gale: http://find. galegroup. com. pegleg. park. edu/gtx/start. do? prodId=PPCJ;userGroupName=morenetpark Ryan, J. (2009). Legal Issues: Use of Force/Deadly Force. Indianapolis, IN: Public Agency Traininig Council. Tennessee v. Garner, 471 U. S. 1 (1985), http://supreme. justia. com/us/471/1/case. html Time. (2007). The L. A. Riots: 15 Years After Rodney King. Retrieved Sep 04, 2010, from http://205. 188. 238. 181/time/specials/2007/article/0,28804,1614117_1614084_1614831,00. html Wallentine, K. (2007, Sep 05). How to ensure use of force is reasonable and necessary and avoid claims of excessive force. Retrieved Sep 05, 2010, from PoliceOne . com : http://www. policeone. com Woodrow Wilson (U. S. President, 1913ââ¬â1921, Speech at New York Press Club 9th September 1912); http://isocracy. org/node/43.
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