Arizona V Johnson Essays

Arizona V Johnson Essays Arizona V Johnson Paper Arizona V Johnson Paper Arizona v Johnson (2009) 129 S. Ct. 781 Date of Judgment: January 26, 2009 INTRODUCTION In 2002, Lemon Montrea Johnson was the passenger in the backseat of a car stopped for a traffic violation. Johnson was charged with; inter alia, possession of drugs and possession of a weapon by a felon. These items were discovered during a protective pat-down search of Johnson. Johnson was convicted by the trial court. Johnson argued that his conviction should be overturned because the trial court was in error by denying his motion to suppress the evidence. He argued that he had been unlawfully â€Å"seized† because being a passenger in a vehicle does not automatically constitute â€Å"seizure. † He furthered argued that even if he had been â€Å"seized,† that by the time Officer Trevizo searched him he was no longer â€Å"seized† as their conversation had become consensual. Furthermore, the evidence should not be considered because the search violated his Fourth Amendment rights and because the officer had no reasonable suspicion that criminal activity was occurring as mandated by Terry v Ohio. On September 10, 2007, the Arizona Court of Appeals overturned the conviction. The court concluded that Trevizo had no right to pat Johnson down even though she believed he was armed and dangerous. The court held that Johnson, although legally detained, had evolved into consensual conversation with officer Trevizo regarding his gang affiliation. This conversation was not connected to the traffic stop of the driver; therefore, the officer may not conduct a pat-down without reasonable cause to believe that â€Å"criminal activity may be afoot. On appeal to the United States Supreme Court, the state argued that police officers should have the right to conduct a pat-down search if they believe the person may be armed and dangerous. On June 23, 2008 the United States Supreme Court granted the State’s petition for a writ of certiorari. The question presented in this case is do police officers have the authority to â€Å"stop and frisk† a passenger in a motor vehicle temporar ily detained upon police detection of a traffic infraction on the basis they believe the person may be armed and dangerous, even when there is no reasonable suspicion of criminal activity? The Supreme Court decided that yes an officer’s reasonable belief that a person is armed and dangerous is sufficient for performing a pat-down search. They established that a Terry â€Å"stop† is met when police lawfully detain a vehicle and its occupants on a traffic violation. The police do not have to believe anyone in the vehicle is involved in criminal activity. A Terry â€Å"frisk† is justified if police reasonably believe the person may be armed and dangerous. Although this case is based on conditions of a traffic stop, one has to wonder if this will open the door to intrusive searches by officers in varying situations. FACTS On April 19, 2002, Officer Maria Trevizo and Detectives Machado and Gittings, members of Arizona’s gang task force, were patrolling in the Tucson neighborhood Sugar Hill, an area associated with the Crips gang. Around 9 p. m. , they pulled over a vehicle after a license plate check revealed its registration had been suspended for mandatory insurance law. The vehicle had three occupants, the driver, a passenger in the front seat, and Lemon Montrea Johnson, respondent, in the back seat. At the time of the stop, the officers had no reason to suspect anyone in the vehicle of criminal activity. The officers walked toward the car. Machado told the occupants to keep their hands in sight. He inquired if there were any weapons in the vehicle, all three said no. Machado instructed the driver to get out of the car. Gittings talked to the front seat passenger, who remained in the vehicle throughout the duration of the traffic stop. Machado interviewed the driver regarding the insurance and registration. Trevizo dealt with Johnson. As Officer Trevizo approached the vehicle, she noticed Johnson alternately watching the officers and commenting to the front seat passenger. This alerted Officer Trevizo. When she drew closer to the vehicle, she noticed Johnson wearing a blue bandana, the chosen color of the Crips. Additionally, she observed that Johnson had a police scanner in his jacket, which she found to be unusual and cause for concern, as† most people† would not carry a scanner â€Å"unless they’re going to be involved in some kind of criminal activity or [are] going to try to evade the police by listening to the scanner. † Trevizo questioned Johnson, who did not have any identification with him but he did provide his name and date of birth. He also stated he was from Eloy, Arizona, a known home to the Crips. Johnson revealed he was a convicted felon who had served prison time for burglary. These factors led Officer Trevizo to believe Johnson may have been a gang member. Officer Trevizo wanted to gather intelligence about the gang Johnson may have been in, as gathering intelligence was one of her main missions in the task force. Officer Trevizo wished to question Johnson away from the others and asked Johnson to get out of the car. Johnson complied. Officer Trevizo was trained extensively as a gang task force officer and knew gang members generally tend to carry a gun. She was concerned for her safety, but did not have a reasonable indication that â€Å"Johnson was engaged in or about to engaged in criminal activity. † When Johnson got out of the car, Trevizo â€Å"patted him down for officer safety. † While patting Johnson down, Trevizo discovered a gun. At that time, Johnson began to struggle. Officer Trevizo hand cuffed Johnson. PROCEDURAL BACKGROUND A. Trial Court Johnson was charged with possession of a weapon by a prohibited possessor, possession of marijuana, and resisting arrest. On October 31, 2005, Johnson filed a motion to suppress evidence found on his person during the pat-down search. The motion was denied. In November, 2005, Johnson was found guilty of the weapons charge as well as possession of marijuana, but not of resisting arrest. He was sentenced to eight years and one year concurrently. B. Arizona Court of Appeals Johnson appealed. The Arizona Court of Appeals in State v Johnson reversed the conviction. The majority held that Johnson was lawfully detained at the time of the stop; however, the conversation between Trevizo and Johnson had turned into a consensual one that was unrelated to the traffic stop. Since Trevizo had no indication that criminal activity was occurring, she had no right pat Johnson down even if she believed he was armed and dangerous. The court referred to Terry v Ohio finding that a Terry stop allows officers to conduct a pat-down search in order to protect the officers, a consensual search does not as they stated in Ilono H: â€Å"Terry and its Supreme Court progeny addressed the propriety of a pat-down search exclusively in the context of a lawful investigatory stop. We do not read those cases to authorize a pat-down search as part of a mere consensual encountereven hen an officer may have grounds to believe the targets of the encounter are potentially armed and dangerous. † The court also drew upon the Supreme Court’s holding in Brendlin v California to determine if Johnson had been lawfully seized. In Brendlin v California, â€Å"a passenger is seized when the vehicle in which he or she is riding in is lawfully stopped by police. However, Johns on contended that even though he had been seized that was no longer the case because it had turned into a â€Å"consensual encounter before Trevizo patted him down. The court cited cases that stated a traffic stop may become consensual â€Å"when officers return the license or registration to a stopped driver, issue the driver a citation or warning, or tells the driver he or she is free to go† or â€Å"asks questions without further constraining the driver by an overbearing show of authority. † The court could not find any case law to establish that point with a passenger, but they reasoned that common sense suggests that at some point the passenger should be free to walk away. To decide when that point was, they applied a standard of reasonableness. The court elaborated on what was a consensual encounter. They considered a consensual encounter is if a person cooperates with the police voluntarily, answering non-coercive questioning. Additionally, if that person is free to leave at any time, he or she is not seized under the Fourth Amendment. Furthermore, the court stated that the encounter would not be consensual if the person did not feel free to leave. In Johnson’s case, the reason Officer Trevizo wished to speak with Johnson to learn more about his gang affiliation, not about the traffic stop and Trevizo testified that Johnson was free to leave at any time. The court stated that Trevizo could have ordered the passengers out of the car, but she did not. Trevizo had also stated that Johnson could have refused to get out of the car. Arizona case law agrees that a Terry stop can evolve into a consensual encounter as in State v Navarro. In Navarro’s case, a suspect in a shooting was taken into custody during a valid Terry stop, but the court determined it evolved into a consensual encounter because the suspect had not been â€Å"confront[ed] and surround[ed] at the initial detention† His handcuffs were removed and he voluntarily agreed to go (unfrisked and in the officer’s front seat) down town with the officer to talk about the shooting. In comparing the cases, the court believed Navarro was subjected to a greater level of coercion than Johnson. After examining every aspect of Johnson’s encounter with Trevizo, the court determined that Johnson’s getting out of the car to talk to Trevizo was consensual. They stated any â€Å"reasonable person in Johnson’s position and under these circumstances would have felt he could have remained in the vehicle. † They acknowledged that Trevizo had a reason to believe Johnson was armed and dangerous (clothing, scanner, hometown) but that fact alone did not give her the right to pat Johnson down in a consensual encounter. They determined that the trial court made an error when they chose not to suppress the evidence found. They reversed Johnson’s convictions and sentences and remanded the case for further proceedings. Judge Espinosa dissented. He found it unrealistic to conclude that just because Trevizo did not use coercion and Johnson volunteered to talk to her, made the encounter evolve into a consensual encounter. Consequently, Trevizo, fearing for her safety and the safety of others, could not legally conduct a pat-down search. The dissent noted that in Ilono H. the right to conduct a pat-down search should be dependent on the legality of the original Terry stop. Additionally, the dissent stated Arizona courts had many cases affirming the right of an officer to conduct a pat-down search when there is reasonable concern for his safety, as in State v Riley where a passenger was patted down during a traffic stop, in State v Valle where a passenger was patted down after he reached for his waistband when he was asked if he had a weapon, and in Adams v Williams that stated an â€Å"The purpose of this limited search is not to discover evidence of crime, but to allow the officer to pursue his investigation without fear of violence. The dissent continued that this was a legal traffic stop and since Officer Trevizo believed Johnson was armed and was a threat to her as well as the others; therefore she had the right to conduct a pat-down search of Johnson. The Arizona Supreme Court denied review. C. United States Supreme Court The State of Arizona appealed. The United States Supreme Court granted certiorari and reversed the judgment of the Arizona Cou rt of Appeals. They began by looking at Terry v Ohio. The police must have a reasonable belief that a person is engaged in criminal activity in order to stop him or her and a reasonable suspicion that the person temporarily detained is armed and dangerous in order to frisk him or her â€Å"stop and frisk. † â€Å"Because a limited search of outer clothing for weapons serves to protect both the officer and the public, a pat-down is constitutional. † With traffic stops being short in nature, similar to the detention authorized in Terry, the threat of danger to the police officer is heightened who is authorized to reduce the risk by taking â€Å"unquestioned command of the situation. To elaborate on Johnson being in a Terry situation, the court referred to Pennsylvania v Mimms which held that it does not violate the Fourth Amendment â€Å"because the governments legitimate and weighty interest in officer safety outweighs the de minimis additional   [**699]  intrusion of requiring a driver, already lawfully stopped, to e xit the vehicle. † Once outside the vehicle, Terry v Ohio states the driver can be then be patted down if there is suspicion he is armed and dangerous. The Mimms rule pertains to passengers as well as to drivers. They both have the same motivation to steer clear of being arrested for more significant crimes than traffic related offenses they have the same motivation to use violence to avoid such arrest. The safety of the officer outweighs the â€Å"minimal† intrusion of being asked to get out of the car and all the occupants of the vehicle have already been seized by nature of the car stop. The Supreme Court held that the Arizona court was in error in believing that Trevizo and Johnson’s encounter had evolved into a consensual encounter. Trevizo had not told Johnson he was free to leave nor did she inform him he did not have to cooperate with her and answer her questions. In other words, she did not give Johnson any reason to believe that her interrogation was consensual. Furthermore, a lawful roadside stop begins when the vehicle is pulled over and ends when police no longer need to control the situation at which time they inform the driver and passengers they are free to leave. A reasonable passenger would understand that as long as the car was seized, he was seized as well. The fact that Johnson was being interrogated about matters other than traffic would not change that understanding. Nothing had happened in the encounter before the frisk that would lead Johnson to believe he was free to leave without the officer’s permission. In a unanimous decision written by Justice Ruth Bader Ginsburg, the Supreme Court reversed the Arizona Court of Appeals. Arizona v Johnson was reversed and remanded. The Court held that Johnson’s encounter was not consensual and did not violate his Fourth Amendment rights. The court opined: valid traffic stops give officers the right to detain the driver and passengers for the duration of the stop; drivers and passengers may be removed from the vehicle with no additional justification; occupants may be asked for identification; if the officer reasonably believes the person may be armed and dangerous, he may conduct a pat-down search (even if he does not believe the person has been or is engaged in criminal activity); officers may inquire or converse about matters other than the traffic stop without it turning in to a consensual encounter as long as it does not â€Å"meaningfully prolong† the traffic stop. LEGAL BACKGROUND The Fourth Amendment to the Bill of Rights of the United States Constitution states: â€Å"The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and 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 seized. † When the Fourth Amendment law was created, no one could have predicted the controversy that would follow in this era of mobility. The first time the Court had to address how the Fourth Amendment applies to searches of automobiles was in 1925, Carroll v United States. Two men were suspected of bootlegging. The police pulled them over and discovered illegal liquor in the trunk of their automobile. The defendants argued there was no warrant served allowing police to search their vehicle, therefore, the evidence should be suppressed. The Court disagreed, reasoning it was impractical to obtain a warrant due the mobility of an automobile. The Court noted difference between buildings and automobiles. Automobiles have the ability to leave the jurisdiction, taking the evidence with them, before a warrant could be obtained. The ruling in Carroll v United States enacted warrantless searches of vehicles are permissible if there was â€Å"probable cause† to believe contraband could be in the vehicle and belief that the vehicle could be moved before the officer could get a warrant. This became known as the â€Å"automobile exception. † The Court had created distinct guidelines for searching, with or without warrant. Now they needed to determine a clear definition of seizure. The benchmark case to define seizure is Terry v Ohio. The â€Å"stop and frisk† procedure was formally created in the case of Terry v Ohio. In October, 1963 a police officer observed two suspicious acting men standing on a street corner. One of the men would leave, walk down the street, look carefully in store windows, continue walking, turn around and look in the same windows again, and return to the corner to talk to the other man again. The second man did the same thing. In fact, they went back and forth six times. The police officer found this behavior highly bizarre and believed they were going to rob the store they had been observing. This led him to believe they were probably armed as well. He followed the men around the corner, where they were meeting with a third man. He approached them and asked their names. They mumbled incoherently. The officer grabbed the man in the middle (Terry) and patted down the outside of his clothing. He found a pistol in the left breast pocket of his jacket, but he could not retrieve it, so he asked them to go into the store. He removed Terry’s jacket and retrieved the pistol. The officer patted down the second man and found a pistol on him as well. The third man did not have a weapon on him. The men were taken into custody and charged with carrying a concealed weapon. Terry moved that the evidence should be suppressed as the evidence found was the result of an illegal search which violated his Fourth Amendment rights. The judge denied this motion stating that the officer’s experience granted enough cause to conduct an interrogation. The defense appealed to the Supreme Court. The main issue the Supreme Court had to deal with was whether or not Terry’s Fourth Amendment rights had been violated by unreasonable search and seizure. They held what came to be known as â€Å"stop and frisk,† which contained two parts. First, an officer may stop a person if he has â€Å"reasonable suspicion,† based on articulable facts that the person has committed or is in the process of committing a crime. The existence of reasonable suspicion depends on the overall view of the circumstances, including the† information known to the officer† and any â€Å"reasonable inferences to be drawn at the time of the stop. † This â€Å"investigative stop† does not require â€Å"probable cause† found the Fourth Amendment’s warrant clause. Probable cause in short is a reasonable belief that a person has committed a crime. † In determining what is probable cause . . . [w]e are concerned only with the question whether the affiant had reasonable grounds at the time of his affidavit . . . for the belief that the law was being violated on the premises to be searched; and if the apparent facts set out in the affidavit are such that a reasonably discreet and prudent man would be led to believe that there was a commission of the offense charged, there is probable cause justifying the issuance of a warrant. A person, within the meaning of the Fourth Amendment, is seized â€Å"whenever a police officer accosts an individual and restrains his freedom to walk away. † They also determined that patting down the outer clothing is a â€Å"search† under that Amendment. Second, to proceed from the â€Å"stop† to the â€Å"frisk† â€Å"a reasonably prudent officer must believe that he or others are in d anger, then he may make a reasonable search of the person that he believes is armed and dangerous, regardless if he is certain the person is armed or regardless of whether or not he has cause to arrest the person. They stated that police must have probable cause and when possible have a warrant to search. In on-the-spot cases, however, it is not practical to obtain a warrant. The officer in the Terry case did have reason to suspect the men were armed. Therefore, the Supreme Court affirmed Terry’s conviction. Elaborating on whether or not a person has been seized is found in United States v Mendenhall. The Court held that a person is seized â€Å"if, in view of all the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave. On February 10, 1976, Sylvia Mendenhall flew in to the Detroit Metropolitan Airport on a flight from Los Angeles. DEA agents observed her behavior as suspicious as if she were possibly carrying illegal drugs. The agents approached her and asked for identification and her airline ticket. Her airline ticket showed her name as â€Å"Annette Ford. † When questioned, she responded she just felt like using that name. Agent Anderson asked Mendenhall to go with him to the airport DEA office. She did. He asked her if she would allow him to search her handbag, clearing stating she did not have to if she did not want to. She handed him the handbag. A female officer arrived to search her person. Before proceeding, the officer asked Mendenhall if she consented to being searched which she responded she did. When heroin was found, she was arrested. The District Court denied Mendenhall’s motion to suppress, since she had consented to the search. The question to the Supreme Court was whether or not Mendenhall was â€Å"seized† when the DEA agents first approached her and requested her identification. The Court concluded that a person has been â€Å"seized† if considering all the circumstances, a reasonable person in that situation, would believe he did not have the freedom to leave. According to Mendenhall, without â€Å"reasonable suspicion† law enforcement may make consensual contact with a person. The person does don have to answer any questions. As long as he or she is free to walk away, the encounter does not violate any liberties granted in the Fourth Amendment. In Pennsylvania v Mimms, the Court held that an officer may order a driver out of the car, provided the traffic stop was lawful. Two Philadelphia policemen were patrolling when they noticed a car with an expired license. They pulled the car over to ticket the driver for driving with expired tags. One of the officers asked the driver, Mimms, to step out of the vehicle to provide his license and registration. Upon doing so, the officer noticed a â€Å"bulge under his jacket. † The officer frisked Mimms and found a loaded 38-caliber revolver. Mimms was charged and convicted with carrying a concealed deadly weapon and unlawfully carrying a firearm without a license in the trial court. Mimms moved to suppress the evidence. The Pennsylvania Supreme Court reversed the conviction after determining that the way the gun was discovered was a violation of the Fourth Amendment. They held that the officer’s request for Mimms to get out of the car was an unlawful seizure, protected against in the Fourth Amendment. â€Å"This was so because the officer could not point to â€Å"objective observable facts to support a suspicion that criminal activity was afoot or that the occupants of the vehicle posed a threat to police safety. † They continued that the officer should have never had the opportunity to notice the bulge; therefore, the search should have never taken place. The United States Supreme Court did not agree with the Supreme Court of Pennsylvania. The Court referred to Terry v Ohio as setting the standard of whether the facts available to the officer at the moment of the seizure or the search `warrant a man of reasonable caution in the belief that the action taken was appropriate there is little doubt that the officer was justified. The Court stated â€Å"the officers safety outweighs the additional intrusion of the driver to get out of the car which was â€Å"de minimis† since he was already detained by the traffic stop. The Court reversed the decision of the Pennsylvania Supreme Court. Maryland v Wilson extended the ruling of Pennsylvania v Mimms that an officer may order the driver out of the car, to passengers as well. A Maryland state trooper pulled over a speeding car on I-95 in Baltimore County. The officer noticed the passenger, Wilson, sweating and appearing to be very nervous. The officer ordered Wilson to get out of the car . When he did, a quantity of cocaine fell on the ground. Wilson was charged with possession of cocaine with intent to deliver. The Baltimore County Circuit Court granted the motion to suppress the evidence stating that ordering Wilson to get out of the car violated his Fourth Amendment rights, constituting an unreasonable seizure. The Maryland Court of Special Appeals affirmed. The United States Supreme Court had to decide whether or not the ruling in Mimms should be extended to include passengers. The Court held that the ruling should extend to the passengers as the â€Å"additional intrusion of exiting the vehicle as â€Å"de minimis† in comparison to the officer’s safety. The Court reasoned that a passenger would have the same motivation as a driver prevent additional crimes from being discovered during the stop, thereby, bringing the threat of violence from the passenger. The Arizona Court of Appeals relied on two Arizona cases they felt set precedent in this case, State v Navarro and In re Ilono H. In Navarro, a shooting had taken place. A few hours later, police stopped a car near the sc ene of the shooting. One of the passengers met the description of the shooter. He was handcuffed then questioned by the police. After conversing ith the police, they removed the handcuffs and asked Navarro to go with an officer to the police station. Navarro agreed to go with the officer. He was allowed to sit, unrestrained, in the front seat with the officer. Navarro was not told he was free to go, nor did he express a desire to leave. At the police station, Navarro was left in the interrogation room unattended, while the officer went to buy him a drink. Navarro agreed to have his testimony taped, his photograph taken, and to be fingerprinted. Navarro signed consent forms and admitted he was aware of his Miranda rights. This led to the conviction of Navarro. Navarro argued the evidence was illegally obtained. Navarro argued the legal detention had evolved into an illegal arrest when he went with the officer to the station. The court held that Navarro was neither in custody, nor under arrest when he agreed to go to the police station because â€Å"under the circumstances, a reasonable, innocent person would have felt free to decline the officer’s request to accompany him for questioning downtown. † In Ilono H. , two policemen approached five people in a park who were known for drug activity. They were dressed in red, a color associated with gang activity. After talking with the individuals, officers conducted pat down searches of the youth because gang members often carry weapons. The pat-down revealed Ilono had a 40-ounce beer on him. He was arrested for illegal possession of alcohol. In a search incident to the arrest, cocaine was found in Ilono’s pocket. Ilono was convicted. On appeal to the Arizona Court of Appeals, the court determined that a Terry frisk is only allowed when the officer believes the person is, or will be in the near future, engaged in criminal activity. The court found that this was a consensual encounter, which an officer may initiate but it may be terminated at any point if the person so desires. The court held that the officers did not have a right to make an investigatory stop because they had no reasonable belief Ilono had committed or was committing a crime; therefore, the pat-down search was illegal in this consensual encounter. The two most recent Supreme Court cases setting important precedent in Arizona v Johnson is Knowles v Iowa and Brendlin v California. In Knowles v Iowa, Knowles was pulled over for speeding. In lieu of an arrest, the officer issued Knowles a citation. After issuing the citation, the officer searched the vehicle. He found marijuana along with a pipe and charged him with possession. The issue at hand was, considering the officer had not made an arrest, did he have the authority to conduct the search consistent with the Fourth Amendment? The Court said â€Å"no. † The issue at hand was not the subject referred to by the Court in Arizona v Johnson. The issue brought up was that the Court in that case stated â€Å"that officers who conduct ‘routine traffic stop[s]’ many ‘perform a pat-down of a driver and any passengers upon reasonable suspicion that they may be armed and dangerous. In Brendlin, the Court held that a passenger is seized, according to the Fourth Amendment, just as the driver is seized. On November 27, 2001 in Sutter County, California, Bruce Brendlin was a passenger in a vehicle pulled over for an expired registration. The officer had inquired about the registration earlier in the day while th e car was parked. He had been informed that the renewal was being processed and the temporary registration was displayed in the back window was legal. While addressing the driver, Karen Simeroth, the officer recognized Brendlin as one of the â€Å"Brendlin Brothers. † The officer was certain he was a parole violator. After verifying that indeed Brendlin was a parole violator, the officer called for backup, ordered Brendlin out of the car at gunpoint, and arrested him and the driver. In the search incident to arrest, the officer found a syringe cap on Brendlin, syringes and marijuana on Simeroth, and methamphetamine along with equipment used to manufacture the drug in the vehicle. Brendlin argued to suppress the evidence stating that he was unlawfully seized by the traffic stop because the officer did not have probable cause to make the stop. Brendlin was denied by the trial court as they stated Brendlin was not seized until the officer ordered him out of the car and therefore did not have the right to challenge the legality of the stop. The California Court of Appeals reversed the decision made by the trial court. This court found that Brendlin was seized by the traffic stop; however, they determined the traffic stop was illegal. The United States Supreme Court had to decide whether or not a passenger is seized, according to the Fourth Amendment, in a traffic stop. The Court used the analogy of â€Å"whether a reasonable person in Brendlin’s position when the car was stopped would have believed himself free to ‘terminate the encounter’ between the police and himself. † The Court held â€Å"We think that in these circumstances any reasonable passenger would have understood the police officers to be exercising control to the point that no one in the car was free to depart without police permission. The Court explained that a traffic stop limits the actions of the passenger just as it does the driver and that the officer initiating the traffic stop â€Å"acts with an implicit claim of right based on fault of some sort, and a sensible person would not expect a police officer to allow people to come and go freely. † Therefore, the Court concluded that the Brendlin was seized by t he traffic stop â€Å"despite the fact that he was merely a passenger and not the target of the stop itself,† consequently he did have the right to challenge if his Fourth Amendment rights had been violated. COURT’S RATIONALE Before Johnson, according to Terry v Ohio, law enforcement was allowed to detain a person briefly if they believed he is was in the process of committing a crime or had committed a crime. Additionally, if the officer believed the detainee was armed and dangerous, the officer was allowed to conduct a pat-down of the detainee’s outer clothing to ensure he had no weapons on him. The Arizona Court of Appeals interpreted the Terry ruling did not apply to a person involved in a consensual encounter if the officer did not believe criminal activity was occurring, even if they believed he was armed and dangerous. The question this court asked was Johnson â€Å"seized† when he was frisked or had the encounter turned into a consensual conversation? They did refer to the United States Supreme Court’s ruling in Brendlin v California that a passenger is â€Å"seized† during a traffic stop, however, they noted that the Court did not designate when the seizure ended. They reasoned that â€Å"common sense† would allow that there must be a point in time where the passengers in the vehicle are free to leave and that â€Å"their fate is not entirely tied to that of the driver. They further compared this case to In re Ilono H. and reasoned that since Johnson was engaging in conversation unrelated to the traffic stop with Officer Trevizo, it had evolved into a separate consensual encounter. The court emphasized that Officer Trevizo believed Johnson was free to terminate the encounter at any time. The court also compared Johnson to Navarro. They determined Navarro had been subj ect to a greater level of coercion that Johnson had been and that the reasonable person in Johnson’s position would have believed he was free to stay in the vehicle. Furthermore, since Officer Trevizo had no suspicion that Johnson was involved in criminal activity, she had no right to frisk him, even if she believed he was armed and dangerous. Since the court had determined the encounter was consensual, they held that the evidence found should be suppressed. Judge Philip Espinosa dissented stating that the majority had placed police in greater danger. Judge Espinosa pointed out the language of Ilono H. stated a pat-down search should rely on the legality of the original stop and that in this case the original stop was legal. He also pointed out that Arizona courts had long acknowledged the right of an Arizona officer to conduct pat-down searches when he has a â€Å"reasonable concern for his safety. † Since Officer Trevizo did have a concern for her safety and the stop was legal, the dissent concluded the search was lawful and the evidence should not be suppressed. In a unanimous opinion written by Justice Ginsburg, the Court established that an officer may pat-down a passenger in a vehicle during the course of a traffic stop if the officer has an articulable suspicion to believe that person is armed and dangerous. ANALYSIS The Fourth Amendment is critical when it comes to protecting the rights of individuals from unreasonable seizures and searches. Johnson’s case required the Court to set a balance between these rights and the safety of law enforcement. The Supreme Court had already made exceptions to warrantless searches in Terry v Ohio. This Johnson decision expanded the Terry rule of †stop and frisk† to traffic stops. The Court reasoned that traffic stops indicate to a reasonable passenger that he is â€Å"seized† along with the passenger for the duration of the stop. Additionally, the Court noted that traffic stops are â€Å"fraught with danger to police officers. Unlike Terry, however, no longer do police need to believe the detainee is engaged in or has been engaged in criminal activity, they just need to â€Å"reasonably suspect† the person subjected to the pat-down is armed and dangerous. Conclusion The significance of this holding is that it increased officer safety by allowing them to pat-down a person, â€Å"seized† by a traffic stop (be it driver or passenger), provided the stop is legal and the officer has a reasonable suspicion that the person may be armed and dangerous. The Supreme Court has always faced the challenging job: balancing individual liberties with need for law and order. Fourth street advocates state this is another nail in the coffin of our Fourth Amendment rights. As with any expansion of police authority, there is always the chance of abuse of power. It is possible some police will abuse this power, using pat-downs during routine traffic stops in the hopes of turning a speeding ticket into something more interesting. Could Johnson eventually apply to any person the police may confront and/or detain? Pat-down searches are intrusive, humiliating, and embarrassing. Does this give law enforcement to pat-down anyone, anywhere under the disguise of officer safety? Will this lead to targeting and profiling? Will police be able to ignore the plastic baggie found while searching for weapons? Furthermore, will this prevent individuals from voluntarily interacting with police, knowing they may be frisked? Time will tell. On the other hand, officer safety is paramount. Not allowing officers to search occupants, within the context of a traffic stop, for weapons when there may be a threat to their safety would cripple their ability to perform their job effectively. Johnson was fresh out of prison, wearing gang colors, and carrying a police scanner. Even to an untrained civilian, it would seem common sense to frisk Johnson. In this case, highly trained Officer Trevizo took the chance that the evidence may have been suppressed, but that chance may have saved her life as well as the other officers. If Johnson had been allowed to leave the scene with the weapon, other lives were in jeopardy. The fact that the everyday law abiding citizen may face an intrusive pat-down seems a small price to pay for protecting the law enforcement that are sworn to protect and serve. The bottom line is the Supreme Court unanimously decided that officer safety comes first. It is what it is. 1 ]. State v Johnson, 170 3d 667, 668,674 (Ariz. Ct. App, 2007). [ 2 ]. Id. [ 3 ]. Id. at 669. [ 4 ]. Id. [ 5 ]. Id. at 668. [ 6 ]. Id. at 671. [ 7 ]. Id. [ 8 ]. Bill of Rights Amendment IV, The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by oath or affirmation, and particul arly describing the place to be searched, and the persons or things to be seized. [ 9 ]. Terry v Ohio, 392 U. S. 1, 88 S. Ct. 1868, 20 L. Ed. 2d 889 (1968). The court held that an officer is justified in conducting a limited search of persons whom he suspects may be armed and dangerous in order to discover any weapons which might be used to assault him or others nearby, even if they have no suspicion that the passenger has committed any crime. [ 10 ]. Id. at 667. [ 11 ]. Johnson, 170 P. 3d at 669. [ 12 ]. Id. [ 13 ]. Johnson, 170 P. 3d at 667 (quoting Terry v Ohio, 392 U. S. 1, 30 (1968)). [ 14 ]. Arizona v Johnson, 128 S. Ct. 339, 172 L. Ed. 2d 14 (2008). [ 15 ]. Id. [ 16 ]. Id. [ 17 ]. Id. [ 18 ]. Johnson, 170 P. 3d at 668. [ 19 ]. Id. [ 20 ]. Id. [ 21 ]. Joint Appendix at 29, Johnson, 128 S. Ct. 2961 (No. 07-1122). [ 22 ]. Joint Appendix at 14. [ 23 ]. Id. at 15. [ 24 ]. Id. at 31. [ 25 ]. Id. at 42-43. [ 26 ]. Id. [ 27 ]. Id. at 12. [ 28 ]. Id. at 17. [ 29 ]. Id. at 16. [ 30 ]. Johnson, 170 P. 3d at 667, 669. [ 31 ]. Id. [ 32 ]. Joint Appendix at 19, Johnson, 128 S. Ct. 2961 (No. 07-1122). [ 33 ]. Id. [ 34 ]. Johnson, 170 P. 3d at 669. [ 35 ]. Joint Appendix at 10, Johnson, 128 S. Ct. 2961 (No. 07-1122). [ 36 ]. Id. at 29. [ 37 ]. Id. at 20. [ 38 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 669-670. [ 39 ]. Id. [ 40 ]. Id. at 669-670. [ 41 ]. Id. [ 42 ]. Id. at 668. [ 43 ]. Id. [ 44 ]. Id. at 671. [ 45 ]. Id. at 673. 46 ]. Id. [ 47 ]. Terry v Ohio, 392 U. S. 1 (1968). [ 48 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 671. [ 49 ]. Ilono H. , 210 Ariz. 473, P2, 113 P. 3d at 697. [ 50 ]. Id. at P12. [ 51 ]. Brendlin v California, U. S. 127 S. Ct. 2400, 2410, 168 L. Ed. 2d 132 (2007). [ 52 ]. Id. [ 53 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 671. [ 54 ]. United States v Hernandez, 93 F. 3d 1493, 1498 (10th Cir. 1996). [ 55 ]. United States v Werking, 915 F. 2d 1404, 1408-09 (10th Cir. 1990). [ 56 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 671. [ 57 ]. Id. [ 58 ]. Hernandez, 93 F. 3d at 1498. [ 59 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 672. [ 60 ]. Id. 61 ]. Id. [ 62 ]. State v Navarro, 201 Ariz. 272, 34 P. 3d 971 (App. 2001). [ 63 ]. Id. [ 64 ]. Id. [ 65 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 672. [ 66 ]. Id. [ 67 ]. Johnson, 217 Ariz. 60, 170 P. 3d at 672. [ 68 ]. Id. [ 69 ]. Ilono H. , 210 Ariz. 473, P2, 113 P. 3d at 697. This was a consensual encounter, not a traffic stop between a juvenile and an officer. [ 70 ]. State v Riley, 196 Ariz. 40, P16, 992 P. 2d 1135, 1140 (App. 1999). [ 71 ]. State v Valle, 196 Ariz. 324, P9, 996 P. 2d 125, 128 (App. 2000). [ 72 ]. Adams v Williams, 407 U. S. 143, 146, 92 S. Ct. 1921, 1923, 32 L. Ed. 2d 612 (1972). [ 73 ]. Johnson, 217 Ariz. 0, 170 P. 3d at 672. [ 74 ]. State v Johnson, 2007 Ariz. LEXIS 154 (Ariz. Nov. 29, 2007). [ 75 ] . Arizona v Johnson, 128 S. Ct. 2961, 171 L. Ed. 2d 884, 2008 U. S. LEXIS 5208, 76 U. S. L. W. 3673 (U. S. 2008). [ 76 ]. Arizona v Johnson, 129 S. Ct. 781, 172 L. Ed. 2d 694, 2009 U. S. LEXIS 868, 21 Fla. L. Weekly Fed. S 620 (U. s. 2009). [ 77 ]. Terry v Ohio, 392 U. S. 1 (1968). [ 78 ]. Id. at 24. [ 79 ]. Id. at 23-24, 27, 30-31. [ 80 ]. Berkemer v McCarty, 468, U. S. 420, 439, n. 29, 104 S. Ct. 3138, 82 L. Ed 2d 317 [ 81 ]. Michigan v Long, 463 U. S. 1032, 1047, 103 S. Ct. 3469, 77 L. Ed 2d 1204. [ 82 ]. Maryland v Wilson, 519 U. S. 408, 414, 117 S. Ct. 882, 137 L. Ed 2d 41. [ 83 ]. Pennsylvania v Mimms, 434 U. S. 106, 98 S. Ct. 330, 54 L. Ed. 2d, 331. [ 84 ]. Id. at 111. [ 85 ]. Id. at 110-111. [ 86 ]. Terry v Ohio, 434 U. S. , at 112. [ 87 ]. Pennsylvania v Mimms, 434 U. S. 106 [ 88 ]. Johnson 129 S. Ct. 781, at 698. [ 89 ]. Id. [ 90 ]. Brendlin, 551 U. S. , at 257. [ 91 ]. Johnson 129 S. Ct. 781, at 698. [ 92 ]. U. S. Constitution – Amendment 4. [ 93 ]. Carroll v United States, 267 U. S. 132 (1925). [ 94 ]. Id. at 160. [ 95 ]. Id. at 132. [ 96 ]. Id. at 158. [ 97 ]. Id. at 150-53. [ 98 ]. Id. at 153. [ 99 ]. Id. [ 100 ]. Terry, 392 U. S. at 16. 101 ]. Id. at 4-7. [ 102 ]. Terry, 392 U. S. at 2. [ 103 ]. Id. at 16-20. [ 104 ]. Id. at 24. [ 105 ]. U. S. Constitution – Fourth Amendment. [ 106 ]. lectlaw. com. [ 107 ]. Dumbra v. United States, 268 U. S. 435, 439 , 441 (1925). [ 108 ]. Id. at 16. [ 109 ]. Id. [ 110 ]. Id. at 20-27. [ 111 ]. Id. at 20. [ 112 ]. Id. [ 113 ]. United States v Mendenh all, 446 U. S. 544, 545 (1980). [ 114 ]. Id. at 554. [ 115 ]. Id. at 547-49. [ 116 ]. Id. [ 117 ]. Id. at 555. [ 118 ]. Id. [ 119 ]. Id. at 544. [ 120 ]. Id. at 554. [ 121 ]. Pennsylvania v Mimms, 434 U. S. at 106, 98 S. Ct. 330, 54 L. Ed. 2d 331 (1977). [ 122 ]. Id. [ 123 ]. Id. [ 124 ]. Id. [ 125 ]. Id. [ 126 ]. Id. [ 127 ]. Id. [ 128 ]. Id. [ 129 ]. Id at 106, 108. [ 130 ]. Id. [ 131 ]. Id. [ 132 ]. Id. [ 133 ]. Id. [ 134 ]. Id. at 106, 112 (quoting Terry, 392 U. S. , at 21-22). [ 135 ]. Mimms 434, U. S. 106, at 112. [ 136 ]. Id. at 111. [ 137 ]. Id. [ 138 ]. Maryland v Wilson, 519 U. S. 408 (1997). [ 139 ]. Id. [ 140 ]. Id. [ 141 ]. Id. [ 142 ]. Id. [ 143 ]. Id. [ 144 ]. Maryland v Wilson, 519 U. S. , 408 (1997). [ 145 ]. Id. at 414. [ 146 ]. State v Navarro, 34 P. 3d 971 (Ariz. Ct. App. 2001). [ 147 ]. In re Ilono H. , 113 P. 3d 696 (Ariz Ct. App. 2005). [ 148 ]. Navarro, 34 P. d at 971, 973. [ 149 ]. Id. [ 150 ]. Id. [ 151 ]. Id. [ 152 ]. Id. [ 153 ]. Id. [ 154 ]. Id. at 973-974. [ 155 ]. Id. at 972. [ 156 ]. Id. at 974. [ 157 ]. Id. at 974-975. [ 158 ]. Id. [ 159 ]. Id. [ 160 ]. Ilono H. , 113 P. 3d at 697. [ 161 ]. Id. [ 162 ]. Id. [ 163 ]. Id. [ 164 ]. Id. [ 165 ]. Id. [ 166 ]. Id. [ 167 ]. Id. at 700-701. [ 168 ]. Knowles v Iowa, 52 5 U. S. 113, 117–18 (1998). [ 169 ]. Brendlin v. California, 127 S. Ct. 2400, 2410 (2007). [ 170 ]. Knowles v Iowa, 525 U. S. at 114. [ 171 ]. Idat 113. [ 172 ]. Id. at 118. [ 173 ]. Brendlin, 127 S. Ct. at 2403. [ 174 ]. Id. at 2404. [ 175 ]. Id. [ 176 ]. Id. 177 ]. Id. [ 178 ]. Id. [ 179 ]. Id. [ 180 ]. Id. [ 181 ]. Id. at 2404-05. [ 182 ]. Id. at 2405-06 (quoting Florida v Bostick, 501 U. S. 429, 435-36 (1991)). [ 183 ]. Id. at 2406-07. [ 184 ]. Id. at 2407. [ 185 ]. Id. at 2410. [ 186 ]. Terry, 392 U. S. at 2. [ 187 ]. Johnson, 170 P. 3d at 671. [ 188 ]. Brendlin, 551 U. S. at 262. [ 189 ]. Johnson, 170 P. 3d at 671. [ 190 ]. Id. [ 191 ]. Id. at 672. [ 192 ]. Id. [ 193 ]. Id. at 673. [ 194 ]. Id. [ 195 ]. Id. at 674. [ 196 ]. Id. at 674 (Espinosa, J. , dissenting). [ 197 ]. Id. [ 198 ]. Id. (quoting State v Riley, 992 P. 2d 1135, 1140 (Ariz. Ct. App. 1999)). [ 199 ]. Id.

Battle of the Coral Sea in World War II

Battle of the Coral Sea in World War II The Battle of the Coral Sea was fought May 4-8, 1942, during World War II (1939-1945) as the Allies sought to halt the Japanese capture of New Guinea. During the opening months of World War in the Pacific, the Japanese won a string of stunning victories which saw them capture Singapore, defeat an Allied fleet in the Java Sea, and force American and Filipino troops on the Bataan Peninsula to surrender. Pushing south through the Dutch East Indies, the Imperial Japanese Naval General Staff had initially desired to mount an invasion of northern Australia to prevent that country from being used as base. This plan was vetoed by the Imperial Japanese Army which lacked the manpower and shipping capability to sustain such an operation. To secure the Japanese southern flank, Vice Admiral Shigeyoshi Inoue, commander of the Fourth Fleet, advocated for taking all of New Guinea and occupying the Solomon Islands. This would eliminate the last Allied base between Japan and Australia as well as would provide a security perimeter around Japans recent conquests in the Dutch East Indies. This plan was approved as it would also bring northern Australia within range of Japanese bombers and would offer jumping off points for operations against Fiji, Samoa, and New Caledonia. The fall of these islands would effectively sever Australias lines of communication with the United States. Japanese Plans Dubbed Operation Mo, the Japanese plan called for three Japanese fleets sortie from Rabaul in April 1942. The first, led by Rear Admiral Kiyohide Shima, was tasked with taking Tulagi in the Solomons and establishing a seaplane base on the island. The next, commanded by Rear Admiral Koso Abe, consisted of the invasion force that would strike the main Allied base on New Guinea, Port Moresby. These invasion forces were screened by Vice Admiral Takeo Takagis covering force centered around the carriers Shokaku and Zuikaku and the light carrier Shoho. Arriving at Tulagi on May 3, Japanese forces quickly occupied the island and set up a seaplane base. Allied Response Throughout the spring of 1942, the Allies remained informed about Operation Mo and Japanese intentions through radio intercepts. This largely occurred as a result of American cryptographers breaking the Japanese JN-25B code. Analysis of the Japanese messages led the Allied leadership to conclude that a major Japanese offensive would occur in the Southwest Pacific during the early weeks of May and that Port Moresby was the likely target. Responding to this threat, Admiral Chester Nimitz, Commander-in-Chief of the US Pacific Fleet, ordered all four of his carrier groups to the area. These included Task Forces 17 and 11, centered on the carriers USS Yorktown  (CV-5)  and USS Lexington  (CV-2) respectively, which were already in the South Pacific. Vice Admiral William F. Halseys Task Force 16, with the carriers USS Enterprise (CV-6) and USS Hornet (CV-8), which had just returned to Pearl Harbor from the Doolittle Raid, was also ordered south but would not arrive in time for the battle. Fleets Commanders Allies Rear Admiral Frank J. Fletcher2 carriers, 9 cruisers, 13 destroyers Japanese Vice Admiral Takeo TakagiVice Admiral Shigeyoshi Inoue2 carriers, 1 light carrier, 9 cruisers, 15 destroyers Fighting Begins Led by Rear Admiral Frank J. Fletcher, Yorktown and TF17 raced to the area and launched three strikes against Tulagi on May 4, 1942. Hitting the island hard, they badly damaged the seaplane base and eliminated its reconnaissance capabilities for the coming battle. In addition, Yorktowns aircraft sank a destroyer and five merchant ships. Steaming south, Yorktown joined Lexington later that day. Two days later, land-based B-17s from Australia spotted and attacked the Port Moresby invasion fleet. Bombing from high-altitude, they failed to score any hits. Throughout the day both carrier groups searched for each other with no luck as cloudy skies limited visibility. With night setting in, Fletcher made the difficult decision to detach his main surface force of three cruisers and their escorts. Designated Task Force 44, under the command of Rear Admiral John Crace, Fletcher ordered them to block the probable course of the Port Moresby invasion fleet. Sailing without air cover, Craces ships would be vulnerable to Japanese air strikes. The next day, both carrier groups resumed their searches. Scratch One Flattop While neither found the others main body, they did locate secondary units. This saw Japanese aircraft attack  and sink the destroyer USS Sims as well as cripple the oiler USS Neosho. American aircraft were luckier as they located Shoho.   Caught with most of its aircraft group below decks, the carrier was lightly defended against the combined air groups of the two American carriers. Led by Commander William B. Ault,  Lexingtons aircraft opened the attack shortly after 11:00 AM and scored hits with two bombs and five torpedoes. Burning and nearly stationary,  Shoho  was finished off by  Yorktowns aircraft. The sinking of Shoho led Lieutenant Commander Robert E. Dixon of Lexington  to radio the famous phrase  scratch one flattop.   On May 8, scout planes from each fleet found the enemy around 8:20 AM. As a result, strikes were launched by both sides between 9:15 AM and 9:25 AM. Arriving over Takagis force,  Yorktowns aircraft, led by Lieutenant Commander William O. Burch,  began attacking Shokaku  at 10:57 AM. Hidden in a nearby squall,  Zuikaku  escaped their attention. Hitting Shokaku  with two 1,000 lb. bombs, Burchs men caused severe damage before departing. Reaching the area at 11:30 AM,  Lexingtons planes landed another bomb hit on the crippled carrier. Unable to conduct combat operations, Captain  Takatsugu Jojima  received permission to withdraw his ship from the area.  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   The Japanese Strike Back While the US pilots were having success, Japanese aircraft were approaching the American carriers.   These were detected by  Lexingtons CXAM-1 radar and F4F Wildcat fighters were directed to intercept.   While some of the enemy aircraft were downed, several commenced runs  on  Yorktown  and  Lexington shortly after 11:00 AM.   Japanese torpedo attacks on the former failed, while the latter sustained two hits by Type 91 torpedoes.   These assaults were followed by dive bombing attacks which scored a hit on  Yorktown  and two on  Lexington.  Damage crews raced to save Lexington and succeeded in restoring the the carrier to operational condition.    As these efforts were concluding, sparks from an electric motor ignited a fire which led to a series of fuel-related explosions. In a short time, the resulting fires became uncontrollable. With the crew unable to extinguish the flames, Captain Frederick C. Sherman ordered Lexington  abandoned. After the crew was evacuated, the destroyer USS  Phelps  fired five torpedoes into the burning carrier to prevent its capture. Blocked in their advance and with Craces force in place, the overall Japanese commander, Vice Admiral Shigeyoshi Inoue, ordered the invasion force to return to port. Aftermath A strategic victory, the Battle of the Coral Sea cost Fletcher the carrier Lexington, as well as the destroyer Sims and the oiler Neosho. Total killed for the Allied forces was 543. For the Japanese, the battle losses included Shoho, one destroyer, and 1,074 killed. In addition, Shokaku was badly damaged and Zuikakus air group greatly reduced. As a result, both would miss the Battle of Midway in early June. While Yorktown was damaged, it was quickly repaired at Pearl Harbor and raced back to sea to aid defeating the Japanese.

Pizza Veloce Term Paper Example | Topics and Well Written Essays - 1250 words

Pizza Veloce - Term Paper Example To provide convenient solutions for ordering and getting different pizzas Products and Services: The main products that will be offered by Pizza Veloce will be the wide variety of pizzas, most which will be based on genuine, Italian recipes that have been used for several centuries. The products will also include side items and other smaller Italian dishes, as well as desserts and drinks that can be served with the foods. The services that will be available by Pizza Veloce will be inclusive of the ways in which the pizza and other food items can be delivered to the home. The first consists of services available online for easy connections and ordering. The second is based on delivery services that are available for those who don’t want to leave their home and are interested in ordering. The third will be in – house services so individuals have the option of a restaurant like atmosphere. Each of these services will be supported by technological structures for fast delive ry and a structure that enhances the making of the pizzas. Organizational Structure: The first part of the structure will be based on different departments and employees that will be able to provide the pizza making services. The first will be a team of employees for making the pizzas. The second will be a team used for the deliveries. There will also be customer service representatives that will be available for the online services and others that will provide in – store services. There will be one manager that overlook all operations at all times, specifically to make sure that there are connections with all deliveries and that workers are effective with the work. The organizational structure will then move into a CEO responsible for overlooking the main components of the operations, a vice president responsible for initiating new developments and a team that overlooks the expansion of the Pizza Veloce. This will consist of an online and offline marketing manager, human resources manager, technology manager and a liaison which will work between the office team and those who are working at the pizza company. Each of the organizational structure components will also consist of supporting technology, specifically which will change the number of employees as well as the needs which are associated with the restaurant. Expected Revenue The expected revenue that comes with the pizza is based on the amount of demand which can grow from the customer expectations. On average, a small pizzeria can expect to make $10,500 to $18,500 per week, if there is continuous demand. However, there are factors to consider with the costs of the pizzeria. For example, the cost of rent is about $8,000 per month. The cost for employees is also an average of $1200 per person per month, with an expected 5 workers per week, which equals $ per month for payment. The technology used as well as the structure is also expected to cost an average of $10,000 to install and $30,000 for yearly maintenance. The profit per year will then be at an average of $180,000 with the expenses averaging $208,000. For the pizzeria to break even, there will need to be three restaurants which open initially, which will increase the profit to $540,000 while maintaining the loss at $544,000. After the second year, the revenue will begin to gain, first by $10,000 because of the installed technology and with the expected increase in profit. There will also be options to expand the chain to continue to gain the profit after

How useful are invertebrate infection models for studying bacterial Assignment

How useful are invertebrate infection models for studying bacterial pathogenisis and therapy - Assignment Example The infection cycle involves the disease causing agent managing entry into the host either through adhesion or penetration, assimilation of nutrients to generate more copies of itself and subvert the defence systems of the host and eventually exit from the host to start another cycle in a different target. Numerous in vitro and in vivo infection models have been developed over the years to identify virulence factors and understand its regulation. The fact that some of the host-pathogen interactions have been evolutionarily conserved has led to the establishment of model systems to understand pathogenesis from both the hosts’ and pathogens’ side. Much remains to be understood about the host-pathogen interaction at the molecular level and model systems that are most informative of this could be systems in which the pathogen and host are both amenable to genetic analysis (Pradel and Ewbank, 2004). A number of non-vertebrate model organisms have been developed in order to study host-pathogen interactions which facilitates not only a better understanding of virulence mechanisms but also permit direct genetic techniques to study host defences while reducing cost and ethical constraints associated with mammalian model systems. Non-vertebrate models have also been more popular in bacterial pathogenesis studies because of the following factors: To understand the complexity of virulence-defence interactions a number of pathogen-host systems are required. Simple easy to handle organism such as D. discoideum, C. elegans, D. melanogaster and G. mellonella helps in identifying virulence factors and understanding their functions. Comparative studies in host models also contribute to the identification of novel elements involved in host susceptibility and resistance. Some of these elements conserved over species may also contribute to our understanding of pathogenesis in vertebrates. The genetic tractability of the simple host models will also make possible refined

Many MNEs may want to start operations in some foreign country Essay Example for Free

Many MNEs may want to start operations in some foreign country Essay Establishment mode means that the MNE starts its operations from scratch in the foreign country usually through a wholly owned subsidiary where as in entry mode; this can be accomplished by a subsidiary or through partnership with a local party which involves shared ownership. In this study the authors examine the effect of same variables on both these choices available to a company. They do it through a series of hypotheses. The first hypothesis measures the positive effect of greater institutional advancement on the choice that the company makes. Institutional advancement is defined in the study as pertaining to changes in formal institutions over a period of time. It is argued that regulatory forces are likely to be a big influence on a decision that an MNE makes with regard to its establishment or entry choice. Regulatory forces or rather Regulative forces as described in the study are not limited to laws and regulations only but also include political and other social factors. The authors conclude that institutional advancement has a positive effect on the choice to establish a subsidiary with shared ownership. The second hypothesis postulated by the authors’ measures the moderating effect of institutional advancement on the tendency of a technologically intense firm to either go for establishment mode or entry mode. It is argued that firms which are technology intense should go for establishment mode because their competitive advantages are embedded in their labor force skills and organizational practices so it is more efficient for them to start from scratch. They should hire and train the local labor force. Furthermore in case of a joint venture or share ownership of the subsidiary, protecting the intellectual rights can be an issue. Protection of such rights is dependent on the judicial system. In transition economics where the judiciary is corrupt and intellectual property rights are not respected, an MNE would be reluctant to transfer its technology. Therefore authors conclude that firm with advanced proprietary technology are likely to prefer establishment mode but level of institutional advancement has a positive moderating effect on such a firm going for entry mode. The third hypothesis measures the moderating effect of institutional advancement on a multidomestic MNE to either go for establishment of entry mode. Multidomestic firms are defined as those which pursue multidomestic strategy and want to establish a sustainable local market presence. For such MNEs acquiring a local company is a more attractive option because such acquisition can provide them with local brands, market knowledge, distribution channels and network relationships with the host country’s other businesses and government. How the restructuring and realignment of the acquired entity can be very challenging. The firms in the host country are likely to be following a different paradigm. But on the other hand if an MNE goes for shared ownership or entry mode, it can accomplish more without facing these difficulties. It is argues that a multidomestic MNE requires lesser control on the subsidiary. If this is so then subsidiaries in the host country can have considerable freedom and operate on their own fully leveraging their local expertise.Hence it is concluded institutional advancement has a positive moderating effect on a multidomestic MNE to go for entry mode. Finally the authors have used an international survey to gather the data to support their findings. The survey consists of a questionnaire with 33 open and close ended questions. Furthermore the MNE’s latest establishment mode choice or entry mode choice has been taken as the dependent variable. Critique This study is no doubt a valuable asset for managers and students alike in studying the behavior of MNEs in making their choices when it comes to Foreign Direct Investment but nevertheless it has a few shortcomings and weaknesses. But the biggest shortcoming of this study is the scope. The authors have primarily taken a sample of European MNEs. And the so called economies in transition are basically east European countries which were once under the iron curtain. Firstly we need to consider the fact that Europeans MNEs may be very different from Japanese or American MNEs and so forth. The establishment or entry mode choice for Japanese firms may be dependent on or moderated by variables other than the ones discussed here. Similarly an MNE whether European or Japanese may decide to invest in some country in Central Asia or North Africa or even South Asia. The market conditions in these countries are very different from those of the transition economies discussed by the authors. This means that the findings in this study are not universally applicable. Nevertheless it is a valuable addition to our knowledge regarding MNE behavior in making Foreign Direct Investment decisions. But for any researcher trying to consult this study, it is very important to keep the above mentioned limitations in mind.

Differing Perspectives of the Caribbean :: Caribbean History Historical Essays

Differing Perspectives of the Caribbean The Caribbean has been an unexplained region throughout the test of time because there are many different depictions of what actually is happening. The ranging cultures in the Caribbean bring about many different points of view. A perfect example is how Cliff, Mintz, and Benitez-Rojo describe their version of the Caribbean. They discuss affairs in the Caribbean from the days of slave trading to present day issues. In analyzing their anecdotes and books, one can find not only similarities between them, but discrepancies as well. All three authors express their thoughts vividly, unleashing ideas about the Caribbean. Among the most important themes of these ideas were that of the plantation, identity, and social hierarchy. The role of the plantation was a prominent issue brought up by all the authors. The plantation played an imperative role in Caribbean society from colonialism to contemporary society. Mintz and Benitez-Rojo gave a number of positive aspects of how plantations were positive in helping the economy whereas Cliff despised the whole plantation system. All authors bring out valid issues on their analysis of plantations. According to Mintz, the emergence of the plantation occurred when there became a decline in miners. This decline brought a new economy and an alternate plan to their mining careers. In addition, it was a new source of production for goods like sugar, rum, coffee and tobacco. Production of goods meant more money to the Caribbean’s economy as well as new materials to give to their colonial powers. Mintz argues that the Caribbean flourished because of the system of plantations. He goes as far as saying, "the plantation system was not only an agricultural device; it also became the basis for an entire societal design" (Mintz, 27). Benitez-Rojo also gives praise to the plantation in his article entitled the Repeating Island. He said how the "modest sugar boom in the Spanish Antilles left an indelible mark on the island’s society" (Benitez-Rojo, 42). The plantations created an economy in the Caribbean when there was previously nothing. It changes the whole course of Caribbean history and this can be incorporated with his Chaos Theory. Benitez-Rojo believes in the physics theory that things in one place certainly have a great effect on something else. However, Cliff significantly differs on her view of the plantation. In Cliff’s Abeng, there is much discussion about the plantation. However, Cliff argues how the sugar plantation actually hurt the economy and made little profits.

Behavioral Implications Of Biological Developmental Changes In The Human Past

Behavioral patterns of the humans are no less influential in its biological development. In fact, one had complemented the other in many ways, and it is a never ending process. It is this process which have manifested in humans the most, after they justified their candidature before natural selection through its various stages of evolution, ranging from bipedalism to the development of language, save the development of brain-size in between.As behavior is found to be mostly species-specific, it speaks of its biological connection; on the other hand, biological development also keeps track of the behavioral changes and adapts to them, all the while environment playing a catalyst between (Descent, 2007). It's like gene-text facilitating the course of behavior and behavior at other times, influenced by the environment, scripting new traits in the gene-text.Some might call humans lucky to find the environment conducive to reach this stage, some would stress on the fact that bipedalism ho lds the key, while some other would stress on the behavior that humans achieved after bipedalism through the development of brain. Thus this essay explores the behavioral implications of biological developmental change, before coming to the conclusion of holding both equally responsible and complementing to each other. Bipedalism Two-legged activities are called bipedalism (bi=two, and pedalism= pedaling acts).It basically covers the four states of movement through a pair of legs, such as standing, walking, running and hopping. It has long evolving history among the vertebrates, ranging from dinosaurs to birds, save the ostrich, who has an estimated speed of 65 km per hour that once matched by the maniraptors, now in the extinct list of dinosaurs (Bipedalism, 2003). However, bipedalism is not a habit of those who have four legs, like the larger section of mammals.However, to match with the uniqueness of nature's diversity, the kangaroos lead in representing the mammals who use biped al movement, through hopping. But it is the humans who provided more variation in their bipedal movements, while the gibbons and giant pangolins prove to be distantly resembling to it. Understandably, bipedalism involves a firm ground beneath the feet; and that takes away the amphibians' scope to earn this scope. More so, it is mostly a reared-up action and barring a few instances of some lizards and cockroaches this action is also unfamiliar in arthropods.Same can be said about the reptilians. With exception being the rule of the nature, two kinds of octopus are seen to resort to bipedal movement at times or some of the animals can be trained to exploit the bipedal movement. , much like the humans who can train themselves to walk on their hands. These are deviations and have no bearing to the mainstream evolution. Bipedalism is considered to be one of the major causes of bringing humans where they are today. The reasons are far too many, as they range from elevation of perception t o the improved condition of survival.Between them lies the factors like utilization of free hands, swimming, faster movement, greater reach, etc. , that speak of several advantages of adapting to the living conditions. This trait has evolved independently, that is, not in a set pattern, having various lineages. As for example, the lizards, the recognized pioneer in bipedalism, have a proven track record of this since 290 million years! Dinosaurs and birds follow closely with their record of 230 million years, much before the groups of extant mammals resorted to bipedalism, mostly evolved independently.However the quest to find the reasons behind this elevation of humans fetch us 12 hypotheses and also points at the fact that the human brain-size could develop only after attaining bipedalism. Brain Development Bipedalism facilitated the humans with a new kind of freedom that they enjoyed with hands, letting them to be more organized in their survival and developmental processes. Howe ver, the gradual manifestation of intelligence in humans has a complex process, and still invites lot of research and observation.Charles Darwin attributed its development in humans as an evolution through the process of natural selection, where humans have become successful in manipulating the brain-body ratio, as well as the development of brain-size for a longer period after birth, rather than other creatures (Creationists, 2007). Overall the situations proved more conducive for the humans to develop their brain-size, like the bipedalism, or front-facing, binocular vision. The work-power of the two hands saved free zone for the brain for them, which led to the exploration of new avenues, thereby increasing the horizons of thinking through more number of activities.Once they adapted to giving birth to their offspring with soft skull that would grow on later, the humans were the decided master of the Earth. The evolution of intelligence always follows a pattern, where, a solution t o a problem takes the solver to another plane, where it faces a new set of problems – upon solving which, it again arrives at another plane to face the similar situation; in the process its thought-processing faculty also fights to gear up for the new challenge, finally succeeding in increasing its ability.Humans, after discovering their new life in the post bipedalism era, when they also had the scope to develop their brain-size in the post-natal period, faced the challenge of securing their offspring, who proved to be totally unfit to survive alone. This situation forced them to remain in groups and explore the ways to enhance the communication among the group members.This state again, commanded for using the brain more than earlier, and responding rightly to that challenge, the humans arrived at a new plain of existence, where they could mastermind their ventures and be joyous with more productivity, with the more secured system for their offspring. The power of interperso nal communication earmarked the new bend in the history of development of humans and finally propelled them to an astoundingly different height from the rest of all other creatures of the earth, with sophisticated set of body and brain complementing each other.Language Faculty The advent of the concept of communication gradually helped humans to shape their behavior, and those acquired traits again worked on their biological evolution apropos their interdependency. As like in its earlier stages where the new solutions fetched new problems which ultimately proved ladder to another developed state of being, the progress of language also had a similar route and is still evolving on with time. It started with signs and sounds and finally followed by the scripture forms, all generated with the intensity to express the ideas bubbling within.The behavioral process at this stage dealt with the urge to create the identity of the individual and the group; another new challenge with the invita tion of reaching another plane of refined existence. They then started identifying various sounds as the representative of various emotions, and needs; with time, these set ideas gave birth to proto-language, which, it could be well-assumed, were influenced and conditioned by the environment, much the way it helped them to achieve bipedalism, and thereafter the larger brain-size.Now it worked on to them find their identity, which generated the races with their certain features distinguishable from one group to another. This tendency of uniqueness gave way to the quest of tracing the uniqueness in an individual greater than ever, and in the process, the started reshaping the language by broadening its base from sound to scriptures, the cuneiforms. These activities also helped to serve the group or the race, helped to maintain the balance in the demand and supply ratio of the resources, it again indicated towards a better state of living with every requisites of it being more organize d and handy (Scientists, 2003).Thus a new avenue of collective living was opened with the cohesion in language. Some also earmark this period as the involuntary manifestation of the desire to form better society or race, a period of precursor of eugenics in the recent times; some attribute this stage as the moment before the giant leap of the civilization. However, concepts apart, there is no doubt that the advent of language among humans helped them to find their ways and means of more comfortable life-style and that attributed further to the evolution of their body that gradually adapted to that newly acquired lifestyle.CONCLUSION The history of the evolution of humans may be counted from the natural selection to the time from when humans started selecting their living conditions. Between these two poles, lie millions of years of graduation or probation period entwined with millions of influencing factors, in which its behavioral patterns and biological developments played stellar roles, both being interdependent and determiner of the development of the other.Likewise, it's the bipedalism facilitating the development of the brain, and then brain's behavior affecting the working pattern of the humans, which in turn influencing the body to adapt to that new working condition, and again that acquired new formation of the body ventures to some new action which is supported by the brain.. this never-ending process of evolution is still on; with body, brain and environment, all the three components achieving new dimensions, nevertheless influencing one another as ever.It can be said, thus, the human past is a fascinating, interactive journey of body and brain (the determiner of behavior), where environment all along served the input for the development of both. In the maze of body-brain communication, any of them can rule over the other, depending on the situation, i. e. , the state of environment, who works on as a stimuli, be in on the mental or on the physical plane. Ends BIBLIOGRAPHY Adaptation by Natural Selection. http://www2. wwnorton. com/college/anthro/bioanth/ch1/welcome. htm. Retrieved on march 28, 2007 Bipedalism http://www. stanford. edu/~harryg/protected/chp15.htm Retrieved on march 28, 2007 â€Å"Creationists Arguments: Brain Sizes† http://www. talkorigins. org/faqs/homs/a_brains. html â€Å"Evolution of Man†, BBC http://www. bbc. co. uk/sn/prehistoric_life/human/human_evolution/index. shtml : Retrieved on march 29, 2007 â€Å"Human evolution†, http://en. wikipedia. org/wiki/Human_evolution , Retrieved on march 29, 2007 Press release. â€Å"Scientists discover hominid cranium in Ethiopia†.. Indiana University (March 27, 2006). Retrieved on march 30, 2007 â€Å"The Descent of Man† http://en. wikipedia. org/wiki/The_Descent_of_Man%2C_and_Selection_in_Relati on_to_Sex Retrieved on march 27, 2007

Analysing the change in the role of the management accountant

This work is focused on critically measuring the doggedness of the alteration in the function of the direction comptroller from traditional accounting maps to that of a strategic contriver and concern spouse. The work of Johnson and Kaplan ( 1987 ) , titled â€Å" Relevance doomed † has prompted a drill-down on this research country. Though most of the research workers agree to the altering function of the direction comptroller ( Burns and Baldvinsdottir, 2005 ; Cooper and Dart 2009 ; Allot 2000 ; Chenhall and Langfield-Smith2007 ; Siegel1999 ; Kerby and Romine 2005 ; Vaivio1999 ; Ittner and Lacker2001 ; Ax and Bjornenak 2007 ; Bhimani 2006 ; Roslender and Hart 2002 ) . The importance the traditional function still remains critical to others, and should function to complement the new techniques or the alteration. ( Bromwich and Bhimani 1998 ; Burns et Al. 1999 ) . Others are of the position that history is still a relevant portion of the hereafter or the altering tendency. ( Fleischman and Funnell 2006 ; Luft 1997 ; Beaman and Richardson2007 ) .The type of organisation every bit good as the direction may besides find the nature of alteration. Yazdifar and Tsamenyi ( 2005 ) . This a lteration does non take the same signifier in organisations, but differs in form. Sulaiman and Mitchell ( 2005 ) . With the present economic miasma, some research workers are even recommending a return to the old ways: the traditional function, ( Baldvinsdottir et al ( 2009 ) . The first subdivision of this work will therefore reexamine these positions presented and seek to pull a comparing between these positions to see if the function of the direction comptroller has really changed and to what extent. This will be done pulling support from literatures. It will instantly be followed with some of the new roles the direction comptroller is taking up in organisations. Thereafter the place of traditional accounting pattern in this new tendency of events will be discussed. This will enable us to cognize where to put the traditional accounting function, whether it has lost its utility and should be wholly cast-off or should function to congratulate the new functions. Following to that, some of the new techniques in direction accounting that organisations are following, the factors that are driving the alteration in function every bit good as their significance to the new function will be discussed. Decisions will so be drawn as to the direction comptroller ‘s functions change.The altering function of the direction comptroller.Johnson and Kaplan ( 1987 ) are deemed to hold set the canvas in this statement with their book titled â€Å" Relevance lost: the rise and autumn of direction accounting. † These strong footings used by them has prompted or necessitated a batch of research work in this way. They argue that the bing signifier of direction accounting lacked the know-how to run into up with the dynamic concern environment. Their statement was supported by mentioning technological promotions, information engineering, every bit good as planetary and domestic competition as grounds doing the bing patterns inadequate. Harmonizing to an article published in the Journal of Accountancy ( Most Companies Want Their Certified public accountant to Be Business Strategists, Survey Says, 1996 ) , much more is now being demanded of the direction comptrollers within organisations. Their occupations are traveling beyond the readying of fiscal statements as accounts and reading are now required of them of the information they provide. The direction comptroller is consequently a â€Å" high-ranking determination support specializer † . Kerby and Romine ( 2005 ) argue that for direction comptrollers to stay a relevant portion of their organisations, there must be a alteration in accent from the traditional accounting patterns which involves the numeration, analysis, reading and presentation of fiscal information. They advocate that the direction comptroller should be versed with cognition about alterations impacting the concern of his organisation and imbibe qualities that would enable them map as fully fledged concern spouses. Smith ( 2007 ) opined that the focal point of the direction comptroller within organisations is now switching to the external environment. That the direction comptroller is no more uniformed of what happens externally to his organisation, He now looks both inwards and outwards. Cooper and Dart ( 2009 ) , give support to this position that, direction comptrollers are traveling from being information suppliers to back uping the determination devising. Siegel ( 1999 ) , noted that direction comptrollers were earlier now non involved in the existent decision-making procedure, but acted in support of the determination shapers and subsequently got informed of facts. But the function of the direction comptroller had changed and greater portion of their clip was being spent as internal advisers or concern analyst within their companies. Like most of the other authors he attributes this altering function to the promotion in engineering which he states has freed the direction comptroller from what he describes as â€Å" mechanical accounting † . He stated that the new function of the direction comptroller now involves a batch of direct contacts with people throughout their organisations, and that they are more involved in determination devising and cross-functional squads. This he termed development from functioning internal clients to being concern spouses.The direction comptroller as strategic contriver and concern spouse.The cardinal message of this work has been on the direction comptroller presuming the function of strategic contriver and concern spouse as opposed to the traditional function of corporate bull and bean counter. The direction comptroller ‘s function has evolved and is determining up into a strategic fiscal contriver and director of information. The direction comptroller is said to be h olding less to make with the everyday accounting pattern. ( Siegel 2000, Cooper and Dart, 2009, Latshaw, A. and Choi, Y. , 2000 ) . New countries of focal point of the direction accountant include the development of fiscal programs, information engineering systems direction, assisting in the formation of concern aims every bit good as monitoring consequences and maintaining up with selling aims. Others are direction and organisation of work force, playing consultative function in operational determinations, programmes and undertakings. ( Feeney and Pierce, 2007 ) . For the direction comptroller to work efficaciously as concern spouse, certain accomplishments must be acquired. This will include the quality of analysing and treating unwritten and numeral informations into meaningful information. This should be buttressed by the ability to work efficaciously in a squad. ( Curruth, 2004 ) As concern spouse, the direction comptroller combines both the traditional function of protecting the assets of the concern with a new function of analysis and engagement in determination devising in the concern disposal. ( Kennedy and Sorensen, 2006 ) . Caron ( 2006 ) , defined stairss that should be taken for the direction comptroller to presume the place of a concern spouse. They include: Acting as operation and cognition expert. He/she should be able to supply best pattern information and strategic accomplishments. Should be able to set to pattern the cognition acquired in developing strategic direction programs. He/she should be able to mobilise the human resources at his disposal. He/she should be able to circulate accounting information efficaciously.Management accounting the place of the traditional function.Although Johnson and Kaplan ( 1987 ) opined that the traditional accounting function of the direction comptroller had lost its value and have argued that it is no more relevant to the dynamism of today ‘s universe, non everyone believe their sentiment is best for direction accounting, and have therefore expressed their reserves. ( Bromich and Bhimani 1989 ; Burns et Al 1999 ; Yazdifar and Tsamenyi 2005 ) . Baldvinsdottir et Al. ( 2009 ) are of the sentiment that a return to the traditional or â€Å" mechanical † accounting methods is of great importance particularly at this period of economic down-turn. They argue that although the ballyhoo about the altering function of the direction comptroller, a batch of the traditional accounting function has comparatively remained the same over several decennaries. Luft ( 1997 ) is of the position that history serves as a platform for understanding the present ; that the oversights of the nowadays could really be alleviated by mentioning back to history. Fleischman and Funnell ( 2006 ) , while holding with Johnson and Kaplan, that it is of import that direction accounting studies provide direction with information that will help them in minimising cost and improved productiveness, argue that although these activities are frontward looking, they have to be based on what they described as â€Å" intimate dependance between the past and future † . They insist this is necessary because of the uncertainnesss and instabilities associated with commercial environments, coupled with the intricatsies of direction. That, direction comptrollers in the class of seeking to do the information they provide more utile to their organisations should bear in head that this should be done in observation of necessary ethical issues. Beaman and Richardson ( 2007 ) found out in their research that accounting patterns within organisations are being confined to the traditional function, alternatively of the expected function of determination support and job resolution. There has been the recognition of the broad usage of traditional accounting techniques in most organisations as opposed to the supposed outlook of radically new advanced accounting techniques being adopted by these organisations. ( Burns and Scapens, 2000 ) .Emerging techniques in direction accounting.Some comparatively new trends/techniques have emerged with the purpose of undertaking the insufficiencies of the traditional accounting methods. Some of them have been lauded as the new title-holders of direction accounting solution suppliers in organisations. ( Cooper and Kaplan, 1991 ) . Although these techniques are extremely praised, their acceptance and execution may non hold been as widely accepted as the ballyhoo associated with them. ( Collier and Gregory, 1995 ; Roslender and Hart, 2003 ) . These techniques include: Activity based costing ( ABC ) ; The coming of ABC has changed the pattern of cost allotment necessitating that direction accountants develop more analytical accomplishment to undertake the complexnesss of apportioning operating expenses to different cost objects utilizing cost drivers. ( Burns and Yazdifar, 2001 ; Byrne and Pierce, 2007 ; Anderson, 1995 ) . ABC made the direction comptroller an indispensable portion of the determination doing procedure by concentrating on pertinent information needed to better steadfast public presentation financially and market wise. ( Kennedy and Affleck-Graves, 2001 ) . Kaplan and Anderson ( 2004 ) nevertheless noted that organisations have abandoned ABC because of its failure to capture the complex nature of their operations, the holds of execution and the cost consequence which are normally excessively expensive. Balanced scorecard ( BSC ) : The balanced scorecard enables the direction comptroller to strategically mensurate public presentation and develop a model for the strategic measuring and direction systems ( Kaplan and Norton, 2007 ) . It changes accent from fiscal facet to encompassing client, internal and every bit good as acquisition and growing factors of organisations. ( Kaplan and Norton, 1996 ) . This has altered the function of the direction accountant puting him strategically as a determination support specializer. ( Latshaw and Choi, 2002 ) . BSCs are adopted by houses for strategic public presentation measuring, but the result of these steps is normally developed to encompass operational scheme, nevertheless it was noted that organisations frequently fail in seeking to set BCS into a peculiar usage ( Wiersma, 2009 ) . Atkinson ( 2006 ) noted that the BSC has been found deficient from empirical consequences of its benefits.Strategic direction accounting:Strategic direction acc ounting ( SMA ) : SMA shifts the focal point of direction comptroller to non-financial factors external to the organisation. ( Simmonds,1981 ) . It demands that the direction comptroller be knowing in subjects like public presentation indexs development, value concatenation analysis every bit good as capacity cost direction. It broadens the range of the direction accountant beyond the house to strategizing for competitory market and chances. ( Whiteley, 1995 ) . SMA requires the direction comptroller as a member of the cross functional squad which his function now embraces to convey to bear relevant information and expertness that will help determination devising. ( Roslender and Hart, 2001 ) . The direction comptroller now addresses the impact of other non-financial activities, the cost place of rivals, and rating of rival merchandises and services. These activities have placed the direction comptroller in the important function of strategic contriver and concern spouse. ( Whiteley , 1995 ; Langfield-Smith, 2008 ) . However, Roslender and Hart ( 2003 ) , noted that what constitutes strategic direction accounting is still non clearly defined. Collier and Gregory, ( 1995 ) opined that the degree of execution of strategic direction accounting may postpone in different economic systems. That is, the economic system determines the scheme and functionality of the direction comptrollers. Enterprise resource planning ( ERP ) : ERP requires the direction comptroller to hold sound cognition that will enable him to supply information that will technically run into the demands of the house. It besides demands that the MA be versed with cognition of concern maps related to production, selling and information engineering. For the direction comptroller to acquire traveling with all these maps, he needs to construct a sound inter-personal and societal accomplishments. ( Barton, 2009 ; Pierce and O'Dea, 2003 ) . It may nevertheless cut down occupations, making unemployment. Enterprise resource planning ( ERP ) : enables the direction comptroller to track â€Å" production by occupation, work centre, and activity † ( Zimmerman, 2009:720 ) . However, respondents to research carried out by Knnerley and Neely ( 2001 ) were non certain the debut of ERP to their organisations had made any noticeable impact.Factors driving the alteration in the function of direction accounting.The utility of direction accounting has come under examination following factors like: mechanization of mill procedures and processs, information engineering, competition, and globalisation, complexness of concern among others. Some of these factors and their significance will be discussed briefly. Information Technology: ( Carruth, 2004 ; Beaman and Richardson, 2007 ) , noted that information engineering has enabled direction comptrollers to take more responsible functions in their organisations. The direction comptroller is now able to salvage clip in his analysis and reading of information. The direction comptroller helps in showing informations in a signifier that makes them relevant and utile for managerial intent. This involves strategizing and being involved in the determination devising procedure. Granlund, M. and Malmi, T. ( 2002 ) It has changed the nature of information and placed determination doing on information provided by the direction comptroller. ( Atkinson et al. 1999 ) . Automation ; requires the direction comptroller to develop more analytical accomplishments and to be able to supply such information that will enable houses take determinations and follow such schemes that will assist them remain in competition. ( Kerremans et al. , 1991 ) . Automation is advantageous in take downing labor cost, but may make occupation losingss. ( Mantripragada and Sweeney, 1981 ) .Other factors:Other noteworthy factors driving the function alteration in direction accounting include ; the accent on quality, rational capital, more client focused organisations, addition in overhead cost, less of direct labor cost, and precedence on environmental and external issues. These factors have helped orient the direction comptroller ‘s function to that of a strategic contriver and a concern spouse. The direction comptroller now takes a more proactive function in cognizing and supplying solutions to strategic issues in his organisation. The issue of competitory concern env ironment which is closely related to globalisation is another major factor impacting the manner direction accounting maps are handled in organisations.DecisionAlthough there have been demands for the alteration in accent on the function of direction comptroller, this alteration has non been absolute. This is because the cost and complexness of using these new techniques have made their acceptance slow. The debut of new techniques in direction accounting and the impact of assorted factors have made the direction comptroller more focussed on non-financial facets of organisations and has widened the range of activities external to the organisation, doing him a utile portion of the determination devising procedure. However recent issues ‘ following the economic downswing has suggested keeping of portion of the traditional function in combination with new techniques might be more utile. ( Balvinsdottir et al. , July/Aug. 2009 ) Furthermore, the importance of these new techniques and the benefit they provide to organisations can non be overemphasized. These new inventions have made the direction comptroller more flexible, a solution supplier and an of import portion of the organisation as concern spouse and strategian, reconstructing relevancy. ( Johnson, 1992 ) . It is notable that though many are the advantages of implementing these new techniques, some organisations still stick to traditional accounting because it is less complex to implement, salvaging clip.

ESRM 101 Quiz 2 Essays

ESRM 101 Quiz 2 Essays ESRM 101 Quiz 2 Paper ESRM 101 Quiz 2 Paper Q1. List and describe one of the five Principles of Sustainability that you heard about in class. Why is the practice of sustainability so challenging to achieve? 1. Societies and environments are dynamic (decision today may not be relevant tomorrow)2. Sustainability is contingent on where you live.3. Complex problems lead to artificial decisions4. Bad choices are only revealed in the future5. A bad choice for one person may not be for someone else Hard to achieve because you need to be industrialized and have excess materials, otherwise being sustainable risks your own survival. Q2. How dynamic or stable are vegetative communities and the animals inhabiting these ecosystems at decadal to 1,000 year time scales? Depending on how you answered the first part of the question, how would you explain your answer? Use an example when answering this question. Very dymanic Unless they adapt or leave, they face extinctionex) climate, Florida shift from grassland to spruce and jack pine to hardwoods, black hills grasslands into forests Q3. Where do you find the largest intact contiguous areas of frontier forests today? Why do you think this pattern has emerged? Why do you think we need to know about where frontier forests are found today? Canada/Alaska, South America, Asia Areas that value forests and protecting biodiversity Q4. Why is a spider’s web a good analogy to describe sustainability? Many factors to include when making sustainable choices. If we ignore one, it affects the web as a whole. Q5. How do we recognize when we are making unsustainable choices? Do you have your own idea of how societies can make sustainable choices in resource consumption? Hard to recognize unsustainable choice until future, but generally occurs when we overconsume our own resources or take them from somewhere else. Best idea would be either to use less or find new more efficient ways. Q6. Why can two communities, located on the opposite sites of a river in the Amazon River Basin, have to make a different choice about selling their timber to international buyers? HINT: both communities need to be able to continue to harvest and sell trees from their forests in a sustainable manner. Community 1: sandy soil from river deposits long time to grow back=greater impact of lost resources COmmunity 2: clay soils due to the river holding more nutrients, allowing forest to grow back more quickly Q7. Why is it difficult to label ‘invasive species’ as being always BAD? Name a benefit and a negative of an invasive species (HINT: use the Kudzu as an example)? Where do invasives species come from? They provide communities resources (sometimes all the resources) Introduced by people living in industrialzed countries because they like something Benefits: Livestock eat it, stabilizes soil, chinese medicine, pretty and fragrant Negatives: spreads into undisturbed sites, grows over everything very quickly, reduces value of site Q8. When and from where was kudzu introduced to the US? What was the public view of this plant when it was first introduced to the US? What was the major original benefit of kudzu in the US? 1876 Centennial Exhibition in Philadelphia; from Japan Public view: smelled good and had beautiful flowers; home owners loved the quick growth to cover areas for protection from sun Major benefit: great at erosion control Q9. Based on what you heard during the last two weeks, speculate how past civilizations able to satisfy the resource consumption demands of their societies? Mention a repercussion of past efforts to acquire resources. Collapsed when they over exploited their own resources and were unable to access new supplies. Repercussion: exploited someone elses resources and were able to continue to get new supplies to consume Q10. Based on what you have heard and your own background, speculate on how human societies make unsustainable choices on products that come from forests? Be creative. Our value for pretty, cool products trigger disturbances that degrade natural ecosystems (externalities of industrialization) Political objectives can lead to unhealthy ecosystems, leaving societies who depend on them unhealthy, also makes them more vulnerable to disturbances Q1. Describe the Human Development Index? How does it differ from the traditional approach to evaluate how well a country is developing its economy? Why is it being used by international organizations to rank countries? Groups countries by their social or human capital. Focuses on attention to social development potential, based on education, health, income, role of women Useful to compare patterns in resource consumption based on groups of people, improves health, and identifies why a country developed a particular way Q2. What is the relationship between the amount of forest cover a country has and its ranking as a high, medium or low human development index (HDI) country? Based on how you answered the first part of the question, which countries do you think the international communities are most interested in funding to retain their forest cover? Which countries are losing their forest cover most rapidly and can you speculate why? High: Low forest coverMedium: Highest forest coverLow: low forest cover (decreasing rapidly) International communities interested in funding the medium because they have the most frontier forests remaining. Low HDI countries are losing their forests rapidly because they are most dependent for survival Q3. Three sustainability myths were mentioned in class. Describe one of these myths and why you think it needs to be debunked. Highly developed countries are making more environmental choices: Iceland and hydropowerHigh population densitities make unsustainable choices: Japan and Holland making conscious choices (unlike India exact opposite) People in rural landscapes are not sustainable: consuming local resources kills biodiversity for food Q4. Historically, what have been the industrialized world or high HDI country myth of high population densities and our resource consumption decisions and practices? Use an example when answering this question. Why is this not a valid view? High HDI = unsustainable choices Wrong bc japan and Holland have high HDI but make good choices. Choice of how they consume resources, not how many people Q5. Define what it means to be an outlier? Why is it relevant to think about outliers when ranking resource consumption patterns? Are energy outliers more commonly found in the High HDI country group or in a Low HDI country group? Outlier: consuming more or less than a comparable group of people living under similar environmental and or climatic condiitons Patterrns: identify groups that need to decrease use of a resource, identify a group that can consume more Found more in high HDI countries bc they have they money to consume significantly higher amounts of energy compared to others Q6. What is the relationship between a countries HDI rank, how much of their forests are privately owned and how much wood they consume as part of their primary energy production? Based on what you know and heard in class, speculate whether you think a country can improve their HDI ranking if it has a HIGHER private ownership of forests? High: more under private (dont need wood for energy)Low: governments own most Can improve HDI ranking because if govt control there is not enough to be divided amongst all people who would have rights Q7. Present an example of how globalization of resource consumption and production can be linked to local conservation efforts? What is the take home message from your example? Use an example when answering this question. Globalization shifts suppliers to satisfy market demand ex) finland and china increase cutting in Russia to increase their forest protection without decreasing wood Take home message: decisions in an ecosystem contest Q8. Why is it easier for industrialized or high HDI countries to appear to be making more sustainable choices compared to many of the less industrialized or low HDI countries? Mention 2 factors that explain this. Less industrialized: less income, lots of people in rural areas, most people work in agriculture, no agriculture imports, budget spent on food, population is undernourished. High HDI: less in rural areas, work in industrial sectors, high import of agriculture, less money spent on food, healthy populations, fossil fuels for energy Q9. What is the dominant labor or employment opportunities available in industrialized versus developing countries? What do you think are the repercussions of these employment patterns on the ability of these countries to pursue their sustainable resource consumption goals? Industrialized: service transferring impacts, less apparant Developed: subsistence survivors, dependent on agriculture. Imacts readily seen. Impacts: less agriculture and forestry, more service industry, difficult to sustainably consume resources when most of labor force is in agriculture or forestry Q10. What is the general relationship between ‘pimples’ erupting on a human face and how we make decisions in forests? If we continue to treat symptoms of ‘forest change’, i.e., stop deforestation in the tropics, do you think that countries can increase their ranking in the human development index (HDI)? We treat the symptom instead of the causes We dont know a problem exists or where it will exist until it arises (on your face) NO, this index focuses on social development potential. Treating symptoms does not address underlying problems (ex: health, income) Deforestation is a symptom of other probelsm Q1. What is the medieval global warming? How did the medieval global warming impact England, the Amazon and also the Maya civilization?Why was Europe the ideal location to live during the medieval global warming period? From 800-1200 England flourished economically major period of explorationAmazon and mayan collapsed from droughts (unable to grow food, lacked sufficient fresh water) Europe ideal bc 4-5 centuries of good climate brought good harvests to Europe, Rise of European civilizations, could grow food for everyone Q2. In class it was mentioned that European settlers moving into the forest regions of the western Pacific Northwest US found it difficult to survive by collecting resources to eat or to hunt in these forests. What made it difficult for humans to survive in these coniferous forests? Biological deserts. No large animals that could be hunted for foods, only small mammals such as rodents or squirrels Q3. What is the analogy between a theater’s stage and soils? Stage: limits what actors can doSoils determine what supplies or resources available to maintain survival Q4. How easy is it for people living in the United States to make sustainable decisions and to survive compared to the global average? Explain your answer. Much easier bc and condiitons allow for food and resources to be aquired (only 14% desert) Ice rock and desert are bad for producing and are common elsewhere Q5. Define keystone species? In class you heard about a cold landscape that has several keystone species. What keystone species were found in this ecosystem and what are the implications of losing one of these keystone species from the ecosystem? Keystone species are species that all other animals eat to survive, their loss would have a major impact on the continued persistence of these ecosystems ex) crane flies and other insects and the brown lemming Loss leads to not enough food leading to extinction or migration Q6. Today, what 2 locations and forest types have the most areas of intact forests? What is the relationship between those locations where intact forest areas are found today and whether they were good locations for people to live and survive? Why do some regions of the world have large intact areas of forests today? South America (too hot and rainy)Russia (cold and the growing season is short, so no food production) Location of largest forests today are where it was difficult to find or grow food because of climate/soil conditions (hard to survive)Degraded forests were easy to collect resources and survive Q7. How did people and animals survive in regions with extremely cold winters? Are people healthy living in extremely cold climates? Animals: hibernate/migratePeople need to migrate or follow animal herds Q8. If you are living under the same climatic conditions, would you prefer living in grassland areas or in forests? Justify your answer? Forests because theyre more disturbed, have better climate, and more conducive to humans because animals arent domesticated or balanced/nutritious Q9. Define geophagy? Why does this practice occur? What is the element most missing from soils where geophagy occurs? Geophagy: Animals licking or eating soil to get the nutrients not in vegetation that they eat Leads to health problems because no sodium in soils Q10. Based on what you heard during this class, using the broad biome categories of ecosystems (e.g., forests, deserts, grasslands, tundra, etc) and using scientific rationales, identify a location in the world that you would not be able to live and explain why? Try to think of 2 reasons why you would not be able to live in an area. Desert and Tundra because you cant grow food and theres no water Desert: no WaterTundra: cant grow food in ice, difficult to stay warm. Animals migrate, and thats your food Q1. Who is given the credit for developing agriculture as we know it today? Was the early agriculture practiced using organic or intensive management practices? Explain your answer. Do you remember what happened to the civilization that invented agriculture? Sumerians (practiced year round agriculture)Intensive techniques: cultivation of land, monocropping organized irrigation, use of specialized labor force Sumerians died out after severe deforestation depleted their food sources Q2. What did the development of intensive agriculture allow early civilizations to accomplish that would not have been possible without this agriculture? Allowed civilizations to form in once please, instead of constantly having to migrate to find crops. Allowed much greater density of population to be supported by crops which also increased labor force and ability to expand Q3. If you see large trees growing in an area, does it mean that it is good for agriculture? How does a tree differ from an agricultural crop in what kind of conditions they grow well? What do these plants get from the soil? Not necessarily. Trees can live for a thousand years, whereas a crop grows very quickly. Trees thus wouldnt be as affected by one bad drought or something. Plants get nutrients such as iron and other minerals from the soil Q4. Can you cut down any forest and be able to get good agricultural land? Why No because some forests such as tropical forests have very little nutrition, so cutting down one of these forests would not provide good agricultural land because of lack of nutrition in the soil Q5. What is the petroleum link to agriculture? Modern agriculture is totally reliant on petroleum energy. ex) Haber Bosch fertilizer creation process. Natural gas is used because its the cheapest currently available source of hydrogen Q6. Why can we make the statement that what you eat is only as good as the soil that it grew in? Use an example to answer this question. We eat plants and animals, animals eat plants, eventually it all comes down to someone ate the plants, and the plants get nutrients from the soil Q7. What is the difference between dirt and soil? Why do we care Soil is a mixture of dirt and organic material from dead animals/plants and living organisms. We definitely want soil over dirt because it provides nutrients Q8. What is the major impact of conventional or intensive agriculture and organic farming on soils? How does organic farming attempt to mediate this change? Leaches nutrients out of the soil. Intensive agriculture speeds up the process. Organic uses pesticides that are not chemically made and also adds organic material to help plants grow Q9. Can you have too much organic matter in a soil? What happens when the organic matter increases in a soil to levels higher than what is normally found in the soil? Use an example when answering this question. Yes. When that happens, pH level is lowered and there is less oxygen and more CO2 as microorganisms feed off the organic material and breath in oxygen and exhale co2. Ex biosphere in AZ Q10. Describe terra preta soils? Why were these soils important in many tropical areas? Terra Preta is a black earthlike man made soil, with enhanced fertility. Loaded with nutrients such as nitrogen, phosphorus, potassium, calcium Importat in many tropical areas because tropical areas have poor soil with few nutrients whereas terra preta can be 3x as effective Q1. People living in tropical forests face several issues that impact their survival. Describe one characteristic that makes it particularly difficult for humans to survive in the tropical region. What is one of the most persistent problems faced by people living in tropical forests? Nutrient quality in soil, hot, river that floods seasonally Persistent problems: heat, floods Q2. What one single factor is unique to the tropical regions from other areas in the world? Why is it important to know this fact? It is very hot, at least 24 degrees celcius. important to know that because it is going up so we need to know how to deal with Q3. Discuss the reason presented in class for why plants and animals need to be highly adaptive to living in the wet tropical forests of the Amazon. Describe one adaptation used by plants and by animals to survive what you described for the first part of the question? How do these plant adaptations impact human survival in these forests? Floods: Need to learn some adaptation in case of flood (swimming, climbing, etc) One adaptation: many species and plants are posionous or have sharp horns, making it harder to survive because vegeration is either not edible or is poisonous Q4. Why was the practice of shifting agriculture developed in wet tropical forests? Define shifting agriculture and what is about this practice that allows people to grow food crops in the soils found here. Tropics have nutrient poor soils. They burn down trees, which puts more nutrients in the soil. However, it only lasts for 10-15 years, nutrients then used up and they need to move Q5. List and describe one of the fallacies for tropical forests that is held by people living in the industrialized countries? Do you see a problem with accepting any one of these fallacies as being true? -lush, highly productive-soil hasnt been impacted by human activities-plant diversity occurs naturally-Forest is fragile and can be degraded easily-No fires in wet tropics Believing these can lead to people doing something uncharacteristically which could lead to destruction of the tropics. Q6. In the Amazon region, what parts of the landscape are more suitable for people to survive and why? How diverse are the food options for people living in the areas that are more suitable for human survival? River (more than 80% live along it) because they can grow food crops Called riparian zones and have the most productive soils Q7. Discuss what is the role of cassava or manioc in the diet of indigenous communities living in the American, Asian and African tropics? How is cassava made into a food source? Discuss the trade-offs that local people make by eating cassava. They are the most widely eaten food in the Amazon and most of Africa. It is a starchy root containing cyanide compounds. In order to prepare it, it must be retted in a river. Retting it for 4-5 days allows fermentation to get rid of the cyanide Q8. What is the myth related to the pink dolphin in the Brazilian Amazon? Why do you think that they would develop these myths? Dolphins turn into handsome men and impregnate women of the tribes. Done to warn against outsiders, also because the pink dolphins were very strange. Why would you eat a cabybara (rodent) if you lived in the forests of the American tropics? Explain your answer. High in protein and there were limited sources of protein, especially if there was a flood or drought Q10. What two factors created problems when the first global Debt-for-Nature swap was established in Bolivia? Has the Debt-for-Nature swap improved the livelihoods of people living in the reserve or just outside of the reserve? No consideration of its impacts on local communities ability to provide for themselves Local communities not involved in setting boundaries or limis Hasnt improved livelihood of people living inside Q1. Why were community based forests established in the Nepal case study during the 1970s? Who owns these forests? What are the implications of who owns the forests? Define community forests when answering this question. Community based forests are forest user groups that manage forests for subsistence and commercial purposes In Nepal, 80% of people live in rural areas and depend on forests for subsistence, so they have a vested interest Government owns forests and gives communitis 5 year rights that they can reclaim at any time Q2. In Nepal, what is the primary subsistence material collected from forests? List another product also collected from these forests. Who is excluded from collecting forest materials in community forests? the primary subsistence material in Nepal is timber. They also collect fuelwood, grass, herbal medicines, pine resin. Women collect the products, indegeous groups excluded Q3. In the Nepal case study, what factor is driving the continued illegal selling of timber by forest user groups? Based on what you know, do you think giving land tenure to the community members will stop illegal selling of timber? The factor driving illegal sale of timber is its value. It i very valuable so people go in and cut down trees and sell the timber for a lot of money. Giving land tenure wouldnt decrease it (ex people still sell illegal drugs) All about the benjamins Q4. How have indigenous people unintentionally altered the forests of central Himalaya? Why has this change occurred? converted pine into oak because: pine was bad for livestock, high risk of soil erosion bc of the fires, and oak trees provide more water in streams Q5. Describe one benefit local people derive from having Banj oak growing in their forests in central Himalaya? Describe one reason why pine species are not the preferred tree species for people living in central Himalaya? Local people benefit from oak growing in their forest because cattle can eat oak leaves but not pine, less probelm with erosion because oak forests are denser, and believe that oak forests allow more water to get into the rivers Q6. What caused local peasants to lose their traditional user rights to forests in the central Himalaya? Did the local peasants accept this change? Indian forest act 1878. Local peasants didnt accept it: we cant have it and neither can you so they burnt it down Q7. What is the Machu Picchu Historic Sanctuary fuelwood policy and what is driving this policy? Discuss the social contracts that fuel wood has for villagers living in the Machu Picchu Historic Sanctuary? Is the policy compatible with the community social contracts for wood? Policy: local people cant cut down trees, only collect dead pieces from the ground.Social contracts: everyone in the family has to get wood to contribute Local people think its compatible by the government does not Q8. Is the Machu Picchu Historic Sanctuary area a pristine environment since its abandonment? Explain your answer. How do villagers living in the Machu Picchu Historic Sanctuary make money? What is their main subsistence mode? No. Tons of tourism. They make money by selling souvenirs, and the train is a tourist magnet Q9. What did the natural environment look like in Iceland when the first settlers arrived more than 1,000 years ago? What does the Icelandic landscape look like today? Iceland has been totally transformed from massive desertification. From 65-75% cover to 25% upon the arrival of settlers 1000 years ago. Today, ICeland has only 1% forest cover and grasslands have been heavily degraded due to large numbers of sheep and other animals grazing Q10. What caused the changes in the natural environment in Iceland? Why did the birch forests and willow disappear from Iceland? Why is it a problem if Iceland loses its birch forests? Desertification. Occured as Iceland was deforested to build ships. Once settlers left, sheep were free to graze and eat birch and willow. Birch forests were very populous and also tasty to sheep, so their loss is huge. Q1. How was the landscape of the once lush Loess Plateau converted into a barren unfertile land? How has this degradation affected the local communities? Overexploited the land and killed nutrients in the soil. Rain and no vegetation led to soil in the river, leading to the people going poverty, stuck on subsistence living. Q2. How does the yellow river get its name and why do some call it China’s Sorrow? How did the restoration change the River? Yellow because muddy. WHen muddy, seen as an omen for bad things to come. Clear means good stuff ahead. Restoration kept water form going quickly into stream and carrying soot into it Q3. How do restoration projects benefit climate change? More vegetation slowed the rate at which water entered the stream as well as takes carbon out of the air, countering greenhouse effects Q4. Why were the local people of the Loess Plateau hesitant to restoration project? Howdid the Chinese government convince them? Didnt see the benefit as they wanted the land to farm The chinese government paid them off to not farm that land and keep their animals chained up Q5. What caused the famine in Ethiopia? What did the farmers do to that restored theirfood? In what other way was there community benefited? Drought they now retain water in the fields to irrigate Q6. According to Professor Legesse Negash, How does the restoration restore streamswhere flash floods used to occur? What is the most important thing for Africa to dofor the environment and their people? Streams stayed because of vegetation cover, but when deforested, streams dry up. So restoration of forests also stops sreams from drying up Q7. In Rwanda, what did the local community do when their land was no longer fertile fromover farming? How did this affect neighboring communities like Kigali? They moved into protected areas, which damaged the ecosystem Dried out wetlands in Kigali, so they couldnt get energy from hydrology Q8. What are the environmental and monetary repercussions of the diesel generators inKigali? Is this still a problem? Explain your answer. Have to pay 65,000 plus to keep energy generators going Not a problem anymore because people cant pay it