Saturday, April 25, 2020

The New Age After the 1500s Essay Example For Students

The New Age After the 1500s Essay After 1500 there were many signs that a new age of world history was beginning, for example the discovery of America and the first European enterprises in Asia. This new age was dominated by the astonishing success of one civilization among many, that of Europe. There was more and more continuous interconnection between events in all countries, but it is to be explained by European efforts. Europeans eventually became masters of the globe and they used their mastery to make the world one. That resulted in a unity of world history that can be detected until today. Politics, empire-building, and military expansion were only a tiny part of what was going on. Besides the economic integration of the globe there was a much more important process going on: The spreading of assumptions and ideas. The result was to be One World. The age of independent The history of the centuries since 1500 can be described as a series of wars and violent struggles. We will write a custom essay on The New Age After the 1500s specifically for you for only $16.38 $13.9/page Order now Obviously men in different countries did not like another much more than their predecessors did. However, they were much more alike than their ancestors were, which was an outcome of what we now call modernization. One could also say that the world was Europeanized, for modernization was a matter of ideas and techniques which have an European origin. It was with the modernization of Europe that the unification of world history began. A great change in Europe was the starting-point of modern history.There was a continuing economic predominance of agriculture. Agricultural progress increasingly took two main forms: Orientation towards the market, and technical innovation. They were interconnected. A large population in the neighborhood meant a market and therefore an incentive. Even in the fifteenth century the inhabitants of so called low countries were already leaders in the techniques of intensive cultivation. Better drainage opened the way to better pasture and to a larger animal population. Agricultural improvement favored the reorganization of land in bigger farms, the reduction of the number of small holders, the employment of wage labor, and high capital investment in buildings, drainage and In the late sixteenth century one response to the pressure of expanding population upon slowly growing resources had been the promoting of emigration. By 1800, Europeans had made a large contribution to the peopling of new lands overseas. It was already discernible in the sixteenth century when there began the long expansion of world commerce which was to last until 1930. It started by carrying further the shift of economic gravity from southern to north-western Europe, from the Mediterranean to the Atlantic, which has already been remarked. One contribution to this was made by political troubles and wars such as ruined Italy in the early sixteenth century. The great commercial success story of the sixteenth century was Antwerps, though it collapsed after a few decades in political and economic disaster. In the seventeenth century Amsterdam and London surpassed it. In each case an important trade based on a well-populated hinterland provided profits for diversification into manufacturing industry, services, and banking. The Bank of Amsterdam and The Bank of England were already international economic forces in the in the seventeenth century. About them clustered other banks and merchant houses undertaking operations of credit and finance. Interest rates came down and the bill of exchange, a medieval invention, underwent an enormous extension of use and became the primary financial instrument of international trade. This was the beginning of the increasing use of paper, instead of bullion. In the eighteenth century came the first European paper currencies and the invention of the check. .ub974d31637a6fd9d74cdc15f38eb40f8 , .ub974d31637a6fd9d74cdc15f38eb40f8 .postImageUrl , .ub974d31637a6fd9d74cdc15f38eb40f8 .centered-text-area { min-height: 80px; position: relative; } .ub974d31637a6fd9d74cdc15f38eb40f8 , .ub974d31637a6fd9d74cdc15f38eb40f8:hover , .ub974d31637a6fd9d74cdc15f38eb40f8:visited , .ub974d31637a6fd9d74cdc15f38eb40f8:active { border:0!important; } .ub974d31637a6fd9d74cdc15f38eb40f8 .clearfix:after { content: ""; display: table; clear: both; } .ub974d31637a6fd9d74cdc15f38eb40f8 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .ub974d31637a6fd9d74cdc15f38eb40f8:active , .ub974d31637a6fd9d74cdc15f38eb40f8:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .ub974d31637a6fd9d74cdc15f38eb40f8 .centered-text-area { width: 100%; position: relative ; } .ub974d31637a6fd9d74cdc15f38eb40f8 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .ub974d31637a6fd9d74cdc15f38eb40f8 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .ub974d31637a6fd9d74cdc15f38eb40f8 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .ub974d31637a6fd9d74cdc15f38eb40f8:hover .ctaButton { background-color: #34495E!important; } .ub974d31637a6fd9d74cdc15f38eb40f8 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .ub974d31637a6fd9d74cdc15f38eb40f8 .ub974d31637a6fd9d74cdc15f38eb40f8-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .ub974d31637a6fd9d74cdc15f38eb40f8:after { content: ""; display: block; clear: both; } READ: The Use of Suspense in Julius Caesar Essay Joint stock companies generated another form of negotiable security, their own shares. Quotation of these in London coffee-houses in the seventeenth century was overtaken by the foundation of the London Stock Exchange. By 1800 similar institutions existed in many other countries. It was also the time of some spectacular disastrous investment projects, one of which was the great English South Sea Bubble. But all the time the world was growing more commercial, more used to the idea of employing money to make money, and was supplying itself with the apparatus of modern One effect quickly

Wednesday, March 18, 2020

2nd Fact Sheet Essays - Creative Works, Television Series

2nd Fact Sheet Essays - Creative Works, Television Series 2nd Fact Sheet By Dany SADER General Idea: HYPERLINK https://en.wikipedia.org/wiki/Sesame_Street Sesame Street is an American HYPERLINK https://en.wikipedia.org/wiki/Children%27s_television_program children's television program that is known for its use of format and structure to convey educational concepts to its preschool audience, and to help them prepare for school. It utilizes the conventions of television such as music, humor, sustained action, and a strong visual style, and combines HYPERLINK https://en.wikipedia.org/wiki/Jim_Henson Jim Henson's HYPERLINK https://en.wikipedia.org/wiki/Muppets Muppets , animation, short films, humor, and cultural references. The show, which premiered in 1969, was the first to base its contents, format, and production values on laboratory and formative research. According to researchers, it was also the first to include a curriculum detailed or stated in terms of measurab le outcomes " . The format of Sesame Street consisted of a combination of commercial television production elements and educational techniques. It was the first time a more realistic setting, an inner city street and neighborhood, was used for a children's program. At first, each episode was structured like a HYPERLINK https://en.wikipedia.org/wiki/Magazine magazine , but in 1998, as a result of changes in their audience and its viewing habits, the producers researched the reasons for its lower ratings, and changed the show's structure to a more narrative format. The popular, fifteen-minute long segment, HYPERLINK https://en.wikipedia.org/wiki/Elmo%27s_World Elmo's World , hosted by the Muppet HYPERLINK https://en.wikipedia.org/wiki/Elmo Elmo , was added in 1998 to make the show more accessible to a younger audience. The producers of Sesame Street expanded the new format to the entire show in 2002. Who was behind it? Sesame Street was conceived in 1966 during discussions between television producer Joan Ganz Cooney and HYPERLINK https://en.wikipedia.org/wiki/Carnegie_Corporation_of_New_York Carnegie Foundation vice president Lloyd Morrisett. Their goal was to create a children's television show that would master the addictive qualities of television and do something good with them " , such as helping young children prepare for school. After two years of research, the newly formed Children's Television Workshop (CTW) received a combined grant of US$8 million ($55 million in 2018 dollars) from the Carnegie Foundation, the HYPERLINK https://en.wikipedia.org/wiki/Ford_Foundation Ford Foundation , the HYPERLINK https://en.wikipedia.org/wiki/Corporation_for_Public_Broadcasting Corporation for Public Broadcasting and the HYPERLINK https://en.wikipedia.org/wiki/Federal_government_of_the_United_States U.S. Federal Government to create and produce a new children's television show. The program premiered on HYPERLINK https://en.wikipedia.org/wiki/Public_broadcasting public television stations on November 10, 1969. It was the first preschool educational television program to base its contents and production values on laboratory and formative research. Initial responses to the show included adulatory reviews, some controversy, and high ratings. By its 50th anniversary in 2019, there were over 150 versions of Sesame Street , produced in 70 languages. As of 2006, 20 HYPERLINK https://en.wikipedia.org/wiki/Sesame_Street_international_co-productions international versions had been produced. Content: From its first episode, Sesame Street has structured its format by using a strong visual style, fast-moving action, humor, and music, as well as animation and live-action short films. When Sesame Street premiered, most researchers believed that young child ren did not have long HYPERLINK https://en.wikipedia.org/wiki/Attention_span attention spans , therefore the new show's producers were concerned that an hour-long show would not hold their audience's attention. At first, the show's street scenes the action taking place on its set consisted of character-driven interactions and were not written as ongoing stories. Instead, they consisted of individual, curriculum-based segments which were interrupted by inserts consisting of puppet sketches, short films, and animations. This structure allowed the producers to use a mixture of styles and characters, and to vary the show's pace. By season 20, research had shown that children were able to follow a story, and the street scenes, while still interspersed with other segments, became evolving storylines. Advertising strengths of this program: Early in their history Sesame Street and the CTW began to look for alternative funding sources and turned to creating products and writing licensing agreements. They became, as Cooney put it, a multiple-media institution. In 1970, the CTW created a non-broadcast division responsible for creating and publishing books and HYPERLINK https://en.wikipedia.org/wiki/Sesame_Street_Magazine Sesame Street Magazine . They decided that all materials their licensing program created would underscore and amplify the show's curriculum. In 2004, over 68% of Sesame Street 's revenue came from licenses and products such as toys and clothing. By 2008,

Monday, March 2, 2020

When and How People Learned to Make Cloth

When and How People Learned to Make Cloth Textiles, to archaeologists anyway, can mean woven cloth, bags, nets, basketry, string-making, cord impressions in pots, sandals, or other objects created out of organic fibers. This technology is at least 30,000 years old, although preservation of the textiles themselves is rare in prehistory, so it may be quite a bit older still. Because textiles are perishable, often the oldest evidence of the use of textiles is implied from impressions left in burned clay or the presence of weaving-related tools such as awls, loom weights, or spindle whorls. Preservation of intact fragments of cloth or other textiles has known to occur when archaeological sites are in extreme conditions of cold, wet or dry; when fibers come into contact with metals such as copper; or when textiles are preserved by accidental charring. Discovery of Early Textiles The oldest example of textiles yet identified by archaeologists is at the Dzudzuana Cave in the former Soviet state of Georgia. There, a handful of flax fibers was discovered that had been twisted, cut and even dyed a range of colors. The fibers were radiocarbon-dated to between 30,000-36,000 years ago. Much of the early use of cloth began with making string. The earliest string-making to date was identified at the Ohalo II site in modern Israel, where three fragments of twisted and plied plant fibers were discovered and dated to 19,000 years ago. The Jomon culture in Japan - believed to be among the earliest pottery makers in the world - shows evidence of cord-making in the form of impressions in ceramic vessels from Fukui Cave that are dated to roughly 13,000 years ago. Archaeologists chose the word Jomon to refer to this ancient hunter-gather culture because it means cord-impressed. The occupation layers discovered at Guitarrero Cave in the Andes mountains of Peru contained agave fibers and textile fragments that were dated to about 12,000 years ago. Thats the oldest evidence of textile use in the Americas to date. The earliest example of cordage in North America is at Windover Bog in Florida, where the special circumstances of the bog chemistry preserved textiles (among other things) dated to 8,000 years ago. Silk making, which is made from thread derived from insect cases rather than plant material, was invented during the Longshan period in China, ca 3500-2000 BCE. Finally, one extremely important (and unique in the world) use of string in South America was as quipu, a system of communication composed of knotted and dyed cotton and llama wool string used by many South American civilizations at least 5,000 years ago.

Friday, February 14, 2020

Biological effects of the use of dirty bombs Essay

Biological effects of the use of dirty bombs - Essay Example The purpose of this report is to comprehensively examine these effects by assessing relevant scientific studies, researches and literature. Introduction As stated in the preceding section of the report, the focus of this assessment is directed towards conducting an analysis of the biological effects of the use of dirty bombs that are a type of a radiological dispersal device (RDD) which also incorporates the detonation of conventional explosives. The discussion topics that have been identified as primary and key considerations of this report include 1) an introduction to dirty bombs as a type of RDD 2) examination of the use of dirty bombs by military armies 3) identification of the determinants that govern the extent or degree of biological impact of dirty bomb detonation 4) assessment of an organism’s biological response to the detonation of dirty bombs and 5) the biological effects of the use of dirty bombs. ... he quantity and kinds of physical damage linked with the detonation of a dirty bomb would be comparable to that of an attack which is conducted by devices or bombs that are not radioactive in nature (Horoho 224). While, this statement postulates that the impact or effects of a dirty bomb are similar to that of a conventional bomb, the fundamental distinction in this case is that the detonation of a dirty bomb, as a radiological dispersal device (RDD) would result in the likelihood of victims and rescuers coming into contact with radioactive materials by the means of inhalation or through the embedment of radioactive materials in the injured party (Horoho 224). Thus, Lifshitz understands that the adverse effects of dirty bombs can be categorized on the basis of the direct impact of the explosion and the consequences that the victims may experience as a result of being exposed to radiation (710). The military application of dirty bombs involves their utilization as bunker busters in or der to break through fortified targets or targets that are present in underground compounds. Even though, the detonation of dirty bombs has proven to be effective in this regard the key issue of concern is linked with the harmful dispersal of radiation that is caused by the explosion which has the ability to adversely impact indigenous peoples. According to Lifshitz, the extent of the impact of a dirty bomb explosion on the victims can be viewed on a scale which constitutes of high-level radiation and low-level radiation (710). The impact of high-level radiation comprises of the onset of severe illness and radiation sickness, which emerge in a brief period ranging from days to weeks and can be identified as the cause of victim’s death, in most cases (Lifshitz 710). On the contrary, low

Saturday, February 1, 2020

Good Will Assignment Example | Topics and Well Written Essays - 250 words

Good Will - Assignment Example The total of fair values includes liabilities assumed and the recognized intangible assets. When the amount of goodwill is negative, that is when the purchase consideration is less than the total fair value of acquired assets, the excess is said to be profit (Deloitte 2014). 1. The firm calculates the fair value of a reporting unit. It compares the fair value with the carrying amount of the unit. When the carrying amount is more than the fair value, the firm proceeds to the second step (Brice 2014). Accountants who perform personal tax returns are the de facto first line in the implementation of the individual mandate. Insurance accountants will question clients if they possess health insurance. The accountants calculate fines for clients who lack the insurance as per the law. The new healthcare puts insurance accountants in political conversations that did not exist before. It requires them to remain privy regarding their clients compliance with the law (White 2014). Brice, Steven. "Procedural Differences in Impairment Testing." American Institute of CPA. N.p., 23 Mar. 2009. Web. 14 Apr. 2014. . Tilly, Baker. "FASB issues simplified standards for goodwill impairment testing." insights. N.p., 1 Jan. 2011. Web. 14 Apr. 2014. . White, Dennis. "CPAs Examine Impact of Health Care Decision." AccountingWEB. N.p., 25 July 2012. Web. 14 Apr. 2014.

Friday, January 24, 2020

Free Essays - Animal Farm :: Animal Farm

Animal Farm By George Orwell The theme of Animal Farm is not difficult to follow with in the book. The allegory of history that was during the time of the books development, Orwell intended to criticize the communist regime he saw sweeping through Russia and spreading to Europe and even the United States.   Though he agreed with many Marxist principles, Orwell was unable to accept the communist interpretation of socialism because he saw many similarities between the communist governments and the previous czarist regimes in old Russia.   Communism, he thought, was inherently hypocritical. In his book, Orwell uses his allegorical farm to symbolize the communist system.   Though the original intention of overthrowing Mr. Jones (who represents the Czars), is not inherently evil in itself, Napoleon’s subsequent adoption of nearly all of Mr. Jones’ principles and harsh mistreatment of the animals proves to the reader that indeed communism is not equality, but just another form of inequality.   The pigs and dogs take most of the power for themselves, thinking that they are the best administrators of government.   Eventually the power corrupts them, and they turn on their fellow animals, eliminating competitors through propaganda and bloodshed.   This is of course a reference to Stalin, who murdered many of his own people in order to maintain his dictatorship of Russia.   Because Animal Farm was written, it opened the eyes of the Western world to finally realize the danger of communism.   Soon a Cold War began between the world’s greatest superpowers— the Soviet Union and the United States.   In the end, America would prove that capitalism and democracy could outlive a system of government-mandated equality. As Orwell’s presentation within in the book, many animals were used to symbolize different public figures in that time frame. Each animal had an outstanding role through out this book from the pigs to the pigeons each with their own mischief characters. Mr. Jones: Mr. Jones is Orwell’s chief villain in Animal Farm. Of course Napoleon is also the major villain, however much more indirectly. Orwell says that at one time Jones was actually a decent master to his animals. At this time the farm was thriving. But in recent years the farm had fallen on harder times (symbol of the world-wide Great Depression of the 30’s) and the opportunity was seen to revolt. The worldwide depression began in the United States when the stock market crashed in October of 1929. Free Essays - Animal Farm :: Animal Farm Animal Farm By George Orwell The theme of Animal Farm is not difficult to follow with in the book. The allegory of history that was during the time of the books development, Orwell intended to criticize the communist regime he saw sweeping through Russia and spreading to Europe and even the United States.   Though he agreed with many Marxist principles, Orwell was unable to accept the communist interpretation of socialism because he saw many similarities between the communist governments and the previous czarist regimes in old Russia.   Communism, he thought, was inherently hypocritical. In his book, Orwell uses his allegorical farm to symbolize the communist system.   Though the original intention of overthrowing Mr. Jones (who represents the Czars), is not inherently evil in itself, Napoleon’s subsequent adoption of nearly all of Mr. Jones’ principles and harsh mistreatment of the animals proves to the reader that indeed communism is not equality, but just another form of inequality.   The pigs and dogs take most of the power for themselves, thinking that they are the best administrators of government.   Eventually the power corrupts them, and they turn on their fellow animals, eliminating competitors through propaganda and bloodshed.   This is of course a reference to Stalin, who murdered many of his own people in order to maintain his dictatorship of Russia.   Because Animal Farm was written, it opened the eyes of the Western world to finally realize the danger of communism.   Soon a Cold War began between the world’s greatest superpowers— the Soviet Union and the United States.   In the end, America would prove that capitalism and democracy could outlive a system of government-mandated equality. As Orwell’s presentation within in the book, many animals were used to symbolize different public figures in that time frame. Each animal had an outstanding role through out this book from the pigs to the pigeons each with their own mischief characters. Mr. Jones: Mr. Jones is Orwell’s chief villain in Animal Farm. Of course Napoleon is also the major villain, however much more indirectly. Orwell says that at one time Jones was actually a decent master to his animals. At this time the farm was thriving. But in recent years the farm had fallen on harder times (symbol of the world-wide Great Depression of the 30’s) and the opportunity was seen to revolt. The worldwide depression began in the United States when the stock market crashed in October of 1929.

Thursday, January 16, 2020

Actus Reas and Men Rea

Actus Reus and Mens Rea Actus reus and mens rea are two of the five elements of a crime that the prosecution may have to prove to get a conviction in a criminal case. Actus reus is the criminal act. Mens rea is the intent to commit the crime. In general, the more serious a crime is, the more important it is for the prosecution to prove that both a criminal act was committed and that there was criminal intent. These more serious crimes are also known as conduct crimes. Not surprisingly, conduct crimes involve the proof of criminal conduct. Criminal conduct is often confused with criminal acts.The distinction is that criminal conduct involves both actus reus and mens rea, whereas a criminal act only involves actus reus. In the most severe of crimes, such as criminal homicide, three more elements of crime must be proven: concurrence, attendant circumstances and a bad result. Actus reus and mens rea are important because both elements are necessary to get a conviction beyond a reasonable doubt in a criminal case (Samaha, 2008, chap. 3). In order to qualify as actus reus, the act must be deemed a bodily movement that was voluntary.The reason for this is that the law is intended to punish people who meant to commit the act or can be blamed for the act. Only then are they responsible for the criminal acts they commit. Criminal law does not intend to punish people who are not responsible for the acts they committed. The problem is that most criminal codes provide vague descriptions of what a voluntary act is. Many times, the definition needs to be inferred by looking at the list of exceptions (involuntary acts) to voluntary acts. An appeal in case of Brown v.State centered around whether the jury should be given specific instructions by the judge on how to ascertain whether an act was voluntary. The defendant in that case, Alfred Brown, was bumped with a moholding was that the defendant was entitled to have the jury consider the voluntariness of his acts (Samaha, 2008, chap. 3). In order to have Mens Rea, one of two kinds of fault need to be established: subjective or objective fault. Subjective fault is more easily identifiable. Subject fault is having a bad mind, or doing something that you knew to be wrong.Objective fault does not involve a purposeful or conscious bad mind. Objective fault involves establishing that the act should have been known to be wrong by the average person. In the appeal of the case of State v. Stark, the defendant, Calvin Stark, challenged a second degree assault conviction on the grounds that he did not intend to inflict bodily harm by having unprotected sex after he was knowingly HIV positive. Mr. Starks’ appeal was on the grounds that subjective fault could not be established for the crime he was alleged to have committed.Mr. Starks lost the appeal in large part because objective fault was undeniably present in this case since the average person knows that HIV can be passed to another person by having unprote cted sex (Samaha, 2008, chap. 4). Good Samaritan Rule and American Bystander Rule The Good Samaritan Rule and the American Bystander Rule both address the requirements of what a person has to do if they are witnessing and incident where a situation requires assistance. There are really no other similarities between these rules.The Good Samaritan Rule is only used in a few jurisdictions. This rule makes a person legally responsible to either help or call for help when a person is in need. In contrast, the American Bystander Rule states that there is no legal duty to help someone in need, even if it the bystander is risking nothing by helping someone or calling for help. Even in cases where it is clearly morally wrong to stand by and watch someone suffer, the bystander is not violating any criminal law by doing nothing (Samaha, 2008, p. 91). In the case of Commonwealth v.Pestinakas, the defendants, Helen and Walter Pestinakas were convicted of third degree murder in Pennsylvania for n eglecting to care for an elderly man who was terminally ill. In the appeal to this case, the judgments of sentence (five to ten years in prison for each defendant) were upheld because the court ruled that there was a legally binding oral contract in place for the Pestinakases to provide care for the victim, Joseph Kly. The Good Samaritan Rule does not apply in Pennsylvania and the American Bystander Rule does apply.The dissenting opinion was interesting in that it was pointed out that the legislature may not have intended for a contractual duty to be a duty imposed by law. If indeed that were not the intent of the legislature, then the Pestinakases may very well have won their appeal based on the American Bystander Rule. Although neglecting an elderly man while serving as his caretaker is probably morally wrong in the eyes of most, the American Bystander Rule would have protected the Pestinakases from legal prosecution (Samaha, 2008, p. 92-93). In the case of State v.Kuntz, the defe ndant, Bonnie Kuntz stabbed her boyfriend, Warren Becker, and then did not call for help, so he bled to death. In addition to being convicted of negligent homicide, the defendant was also charged with a separate crime for failure to summon for medical aid. Ms. Kuntz appealed the latter conviction with the American Bystander Rule as her basis. There are some exceptions to the American Bystander Rule that do make a bystander criminally liable for a failure to act. In the opinion of the court, this case met one of those exceptions, since Ms.Kuntz had a duty to summon for help because she created the peril. In other words, if you mortally wound someone, you are criminally liable if you don’t summon for aid, notwithstanding the American Bystander Rule (http://www. soc. umn. edu). The Good Samaritan Rule is also not always so â€Å"cut and dry†. Although the rule requires that you help someone in need or summon for help, but a recent ruling, Van Horn v. Watson, held that a s tate statute only protects people who attempt to provide medical care to someone who needs it.In Van Horn v. Watson, court held that the co-defendant, Lisa Torti was held liable for rendering the defendant, Alexandra Van Horn, paraplegic after pulling Van Horn from a vehicle that Torti thought was going to explode (Miller, 2009). Although this was not a criminal case, this shows that the Good Samaritan Rule does not provide protection against every scenario of helping a victim in need, just as the American Bystander Rule does not the bystander from needing to help or summon for help for a person in need.Although the rules seem to be opposites, each has exceptions that make them more similar. Constructive and Actual Possession Constructive possession is when someone has control of a banned substance, but it is not on his/her person. In other words, it may be in or on something he/she owns, such as a vehicle, a place they live, such as their house, or another area he/she controls, suc h as his/her office. Actual possession is when someone has physical control of the banned substance. In other words in might be in their shoe.Constructive and active possession both need to meet the two aspects of possession. In order to constitute possession as a criminal act, there needs to be both control of the items and awareness of the control. The main difference between constructive and active possession is that with active possession, the substance is found on the person, whereas with constructive possession, the substance is found in an area in which the person is responsible (Samaha, 2008, p. 97). The case of Miller v.State provides a good discussion in the court’s opinion on constructive possession. In that case, a passenger in a car was convicted of possession of marijuana and cocaine. The defendant, James Luther Miller, appealed the case on the grounds that he did not knowingly possess the drugs. Other passengers in the car were smoking marijuana and they had cr ack cocaine stashed in the car. In the appeal, the court affirmed the marijuana possession conviction and reversed and dismissed the cocaine possession conviction.According to the court opinion, in order to constitute constructive possession in a case involving multiple occupants in an automobile, there are several things that need to be considered. These factors include whether the drugs were in plain view of the accused, whether they were found on the accused, whether they were in close proximity to the accused, whether the accused is the owner of the car and whether the accused acted suspiciously.In this case, many of these factors were probably true in the case of the marijuana, but none of them were definitively true in the case of the cocaine. In the case of the cocaine, the court found that Mr. Miller did not have knowing possession of the cocaine and instead had mere possession. Only Montana and Washington do not require knowing possession to charge someone with criminal pos session. Since this case was in Arkansas, the appeal was successful for Mr.Miller on the cocaine possession charge (Samaha, 2008, pp. 97-98). References Did she have a legal duty to report or intervene? Retrieved from http://www. soc. umn. edu/~samaha/cases/state_v_kuntz_omission. htm. Miller, C. (2009, January 14). Calif. lawmakers rush to rescue good samaritans in wake of court ruling. The Recorder. Retrieved from http://www. law. com/jsp/article. jsp? id=1202427434865&slreturn=1&hbxlogin=1. Samaha, J. (2008). Criminal Law. (9th ed. , chap. 3-4). Belmont, CA: Thomson Learning, Inc.