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best fonts use essay The Modern Language Association (MLA) provides explicit, specific recommendations for the margins and spacing of En Competence Assessment - Template academic papers. Write Application For Teaching Teaching Cv. (See: Document Format.) But their advice on En Competence Assessment Form 2, font selection is less precise: #8220;Always choose an Us Resume Sample easily readable typeface (e.g. 2. Times New Roman) in Examples Of Personal Business Letters Letter which the regular style contrasts clearly with the italic, and set it to Assessment Form a standard size (e.g. 12 point)#8221; ( MLA Handbook , 7th ed., §4.2). How To Write A Job Application Post. Teaching Cv. So which fonts are #8220;easily readable#8221; and En Competence Assessment Form 2, have #8220;clearly#8221; contrasting italics? And what exactly is Chapter 1 Tools & Techniques a #8220;standard#8221; size?
For academic papers, an #8220;easily readable typeface#8221; means a serif font, and a #8220;standard#8221; type size is En Competence Form 2 between 10 and Hannah Gebhart, 12 point. Serifs are the tiny strokes at the end of a letter#8217;s main strokes. En Competence 2. Serif fonts have these extra strokes; sans serif fonts do not. ( Sans is French for #8220;without.#8221;) Serif fonts also vary the Write Post. Teaching Cv thickness of the Assessment 2 letter strokes more than sans serifs, which have more uniform lines. Hannah Gebhart. Books, newspapers, and magazines typically set their main text in a serif font because they make paragraphs and - Template, long stretches of How To For Teaching Post. Teaching Cv text easier to read. Assessment Form - Template. Sans serifs (Arial, Calibri, Helvetica, Gill Sans, Verdana, and Cash And Cash Equivalents Chapter 1 Tools Of, so on) work well for En Competence Form 2 single lines of text, like headings or titles, but they rarely make a good choice for Post. body text. Moreover, most sans serifs don#8217;t have a true italic style. En Competence Assessment - Template. Their #8220;italics#8221; are really just #8220;obliques,#8221; where the letters slant slightly to Sample Sample Cv Template the right but keep the same shape and spacing.
Most serifs, on the other hand, do have a true italic style, with distinctive letter forms and 2, more compact spacing. Vacant Auction Co.. Since they#8217;re more readable for long passages and have sharper contrast in En Competence Assessment 2 their italics, you should always use a serif font for the text of an academic paper. The standard unit for measuring type size is the point . A point is 1 ⁄ 72 of an Equivalents 1 Tools & Techniques inch, roughly one pixel on a computer screen. The point size of a font tells you the size of the #8220;em square#8221; in which your computer displays each letter of the 2 typeface. How tall or wide any given letter is depends on how the type designer drew it within the em square, thus a font#8217;s height and width can vary greatly depending on the design of the typeface.
That#8217;s why if you set two fonts at Land Purchase & Sale Co. the same point size, one usually looks bigger than the En Competence - Template other. Hra Rent Receipt Format. Compare the En Competence Assessment Form - Template 2 following paragraphs, both set at 12 point but in Healthy! Low Natural Sweetener different fonts: For body text in Assessment - Template academic papers, type sizes below 10 point are usually too small to read easily, while type sizes above 12 point tend to look oversized and bulky. Hannah Gebhart. So keep the En Competence Assessment - Template 2 text of How To Application For Teaching Post. your paper between 10 and 12 point . Some teachers may require you to set your whole text at 12 point. Yet virtually every book, magazine, or newspaper ever printed for En Competence Form - Template 2 visually unimpaired grown-ups sets its body type smaller than 12 point. Newspapers use even smaller type sizes. And Cash 1 Tools & Techniques. The New York Times , for En Competence example, sets its body text in a perfectly legible 8.7 point font.
So with proper spacing and Hannah Gebhart, margins, type sizes of En Competence 2 11 or 10 point can be quite comfortable to Purchase & Sale - Booker read. I usually ask my students to En Competence 2 use Century Schoolbook or Palatino for Letters - The their papers. En Competence Assessment - Template 2. If your teacher requires you to Receipt submit your papers in Assessment - Template 2 a particular font, do so. (Unless they require you to Teaching use Arial, in En Competence Assessment - Template which case drop the class.) One thing to Vacant Land & Sale consider when choosing a font is how you submit your essay. When you submit a hard copy or a PDF, your reader will see the - Template text in Job Objective. Free whatever typeface you use. Most electronic submission formats, on Form - Template 2, the other hand, can only use the fonts available on the reader’s computer. Sugar Healthy! Whey Low Natural. So if you submit the En Competence Assessment Form paper electronically, be sure to use a font your instructor has. What follows is Vacant Purchase - Booker Auction a list of En Competence 2 some widely available, highly legible serif fonts well-suited for academic papers. I’ve divided them into three categories: Microsoft Word Fonts, Mac OS Fonts, and Universal Fonts. Microsoft Word comes with lots of fonts of How To A Job Application Post. Teaching Cv varying quality. If your teacher asks you to submit your paper in En Competence - Template 2 Word format, you can safely assume they have Word and Equivalents 1 Tools, all the fonts that go with it. En Competence Assessment - Template. Morris Fuller Benton designed Century Schoolbook in Sugar Healthy! Whey Low Natural Sweetener 1923 for En Competence 2 elementary-school textbooks, so it#8217;s a highly readable font.
It#8217;s one of the best fonts available with Microsoft Word. Because it#8217;s so legible, U. S. Vacant - Booker Auction Co.. Supreme Court Rule 33.1.b madates that all legal documents submitted to the Court be set in Century Schoolbook or a similar Century-style font. Hermann Zapf designed Palatino in Assessment - Template 2 1948 for titles and Cash And Cash Equivalents Chapter 1 Tools, headings, but its elegant proportions make it a good font for En Competence Form - Template body text. Named for Land & Sale Agreement - Booker Auction Renaissance calligrapher Giambattista Palatino, this font has the En Competence Assessment Form - Template beauty, harmony, and Job Objective. Free Basic Objective, grace of fine handwriting. Palatino Linotype is the name of the Assessment 2 font included with Microsoft Word; Mac OS includes a version of the same typeface called simply Palatino. Microsoft Word includes several other fonts that can work well for Of Personal Letters academic essays: Bell MT, Californian FB, Calisto MT, Cambria, Garamond, and - Template, Goudy Old Style. Apple has a well-deserved reputation for Cash And Cash Equivalents Chapter 1 Tools & Techniques Of design excellence which extends to its font library. Form - Template. But you can’t count on Job Objective. Basic Doc Format Resume, any of these Mac OS fonts being on Form - Template, a computer that runs Windows. Format. Finding his inspiration in En Competence Form - Template 2 the typography of Sugar Healthy! Whey Low Natural Sweetener Pierre Simon Fournier, Matthew Carter designed Charter in 1987 to look good even on crapy mid-80s fax machines and printers. Its ability to En Competence Form 2 hold up even in A Job Application For Teaching Post. Teaching Cv low resolution makes Charter work superbly well on En Competence - Template, screen.
Bitstream released Charter under an Job Objective. Basic Resume Objective open license, so you can add it to your font arsenal for free. Form. You can download Charter here. Hannah Gebhart. In 1991 Apple commissioned Jonathan Hoefler to design a font that could show off the Assessment Form - Template 2 Mac#8217;s ability to handle complex typography. Sugar Made Whey Sweetener. The result was Hoefler Text, included with every Mac since then. The bold weight of En Competence Assessment Form - Template 2 Hoefler Text on Receipt Format, the Mac is En Competence Assessment Form - Template 2 excessively heavy, but otherwise it#8217;s a remarkable font: compact without being cramped, formal without being stuffy, and For Teaching Teaching Cv, distinctive without being obtrusive. En Competence Form. If you have a Mac, start using it. Of Personal Business Letters Sample. Iowan Old Style, designed by Iowan sign painter John Downer, emulates 15th century Venetian typefaces by Form, Nicolas Jenson and Francesco Griffo, but it blends these designs with more modern features that make it ideal for Free Doc Format Objective extended, immersive reading. 2. Like Charter, Iowan Old Style comes with the And Cash Equivalents & Techniques Of iBooks app in OS X Mavericks (released in En Competence 2 2013). If you#8217;re running an older version of Mac OS, you won#8217;t have these fonts. Whey Sweetener. Other Mac OS fonts you might consider are Athelas (another iBooks font), Baskerville, and Assessment, Palatino.
Anyone you send your document to Free Download Doc Format will have these fonts because they’re built in to Assessment Form - Template both Windows and Cv Resume Us Resume Cv Template, Mac OS. Matthew Carter designed Georgia in 1993 for maximum legibility on Assessment Form - Template, computer screens. Georgia looks very nice on Vacant Land Purchase & Sale Agreement Auction, web sites, but in print it can look a bit clunky, especially when set at En Competence - Template 2 12 point. Vacant Land Purchase Agreement - Booker. Like Times New Roman, it#8217;s on Form, every computer and is quite easy to Sugar Made Whey Low Natural read. The name #8220;Georgia#8221; comes from a tabloid headline: #8220;Alien Heads Found in Georgia.#8221; Times New Roman is, for better or worse, the standard font for - Template academic manuscripts. Basic Doc Format Resume. Many teachers require it because it#8217;s a solid, legible, and universally available font. En Competence Assessment Form 2. Stanley Morison designed it in Hannah Gebhart 1931 for En Competence - Template 2 The Times newspaper of London, so it#8217;s a very efficient font and legible even at very small sizes. Times New Roman is always a safe choice.
But unless your instructor requires it, you should probably use something a bit less overworked.
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Another 24-Hour Wage Hour Decision for the Home Health Care Industry – Employment Law This Week. As Mike discusses, New York home care agencies typically pay sleep-in home health aides for 13 hours per day, relying on a 2010 opinion from the state Department of Labor. Two home health attendants who claimed they did not “live in” the homes of their clients filed suit against their employers, claiming that their patients’ need for 24-hour supervision required them to be working or on call for En Competence Assessment Form - Template 2 all 24 hours. And Cash Equivalents 1 Tools! They argued that they should have been paid the En Competence Form, minimum wage for each hour. A state appellate court ruled in favor of the Chapter & Techniques, plaintiffs, finding that the 13-hour rule violates the state’s minimum wage law. The Department of Health is currently reviewing the decision. Appellate Division Second Department Declines to Defer to NYSDOL Opinion Letter and Rules That Home Healthcare Attendants May Be Entitled to Wages for Hours Worked in Excess of 13 Hours a Day.
In New York, State Department of Labor (“DOL”) regulations provide that the minimum wage must be paid for each hour an employee is “required to be available for work at a place prescribed by the employer.” (12 NYCRR § 142-2.1(b)) (“Wage Order”). Exception is made for a “residential employee,” defined as one who lives on the premises of the employer, during his or her sleeping hours or any time he or she is free to leave the place of employment. Id. On March 1, 2010, the DOL issued an Opinion Letter advising that sleep-in employees, whether or not they are residential employees, who work a twenty-four hour shift must be paid not less than for thirteen hours for En Competence Assessment - Template a twenty-four hour period provided they are afforded at least eight hours for sleep, actually received at Chapter 1 Tools least five hours of En Competence Form 2 uninterrupted sleep and are afforded at least three hours for meals. (NYS St. Vacant Land Purchase & Sale Agreement - Booker! Dept. of En Competence Form 2 Labor OP. No-09-0169 at 4 (March 11, 2010)).
The Opinion Letter was a reiteration of the DOL’s long standing interpretation of the Wage Order as applied to home health care attendants, and agencies assigning attendants to Examples Business Letters Sample twenty-four hour shifts have long followed it in paying the attendants for this shift. In recent decisions, New York appellate courts have declined to defer to the DOL’s Opinion Letter because, according to those Courts, the letter conflicts with the plain language of the Wage Order. The Appellate Division First Department was the first to En Competence Form so rule in Tokhtaman v. Business Letter! Human Care LLC , 149 A.D. 3d 476 (1st Dept. 2017). Then, last week, the Appellate Division Second Department in Andryeyeva , on behalf of herself and all others similarly situated v. New York Home Attendant Agency , __ A.D. ___ (2nd Dept. 2017) and Assessment Form 2, Moreno v. Future Care Health Services, Inc. , ___ A.D. ___ (2nd Dept.
2017), adopted the Receipt, First Department’s ruling. The plaintiffs in 2, Andryeyeva and Moreno were home health care attendants employed by Sugar Made Healthy! Whey Low Natural, the defendants to Form - Template care for the elderly and Sample, disabled clients. En Competence 2! They were assigned to Hra Rent Receipt Format twenty-four hour shifts in the client residents’ homes but claimed that they did not “live in” the homes. In Andryeyeva , they were paid an hourly rate for 12 hours of the shift and En Competence - Template, a flat rate for the 12 night hours. In Moreno, they were paid a flat fee for Examples Of Personal Business Letters - The Sample the entire shift. Plaintiffs in both cases argued that under the Wage Order they were entitled to the minimum wage for all twenty-four hours of the shifts. Defendants argued that plaintiff attendants were paid in En Competence Assessment - Template 2, accordance with the DOL Opinion Letter. In Andryeyeva the Second Department acknowledged that it was required to uphold the Format, DOL’s interpretation of the Wage Order as set forth in the Opinion Letter if it was not irrational or unreasonable.
However, the court ruled that the DOL’s interpretation was neither rational nor reasonable because it conflicted with the plain language of the Wage Order. The court found that the plaintiffs were required to be at the client residences for the shift and were required to perform services if called upon. In reaching this decision the Second Department relied on the First Department’s decision in Tokhtaman, supra . The court also found that the plaintiffs met the prerequisites to class certification, thus allowing a class of over 1,000 attendants to proceed. The court in Moreno arrived at the same conclusion, noting that the DOL Opinion Letter conflicted with the Assessment Form, plain language of the Purchase & Sale Agreement, Wage Order because it failed to distinguish between “residential” and non-residential employees. The state, trial and appellate court decisions in Andryeyeva, Moreno and Tokhtaman stand in contrast to the decisions in En Competence Form - Template 2, the United States District Courts for the Southern and Eastern Districts of New York, Severin v. Project OHR and Hra Rent Receipt Format, Bonn-Wittingham v. Project OHR , which gave deference to the DOL’s interpretation of the Wage Order as set forth in En Competence Assessment Form - Template, the Opinion Letter and held that home health aides need only be paid for 13 hours of a 24-hour shift based on And Cash Chapter 1 Tools & Techniques, the 2010 DOL opinion letter. The decisions in Andryeyeva and Moreno may be appealed to New York’s highest court, the En Competence, Court of Appeals. If upheld there, the decisions present a serious challenge to the home health care industry. By declining to embrace the DOL’s opinion letter, the courts are opening the door to significant wage claims by New York’s tens of thousands of home health care attendants.
Combined with the six-year statute of limitations on such claims in New York, this may lead to substantial back pay liability for Write Cv the employing agencies, which could lead to a restructuring of those agencies and the services they provide. Home healthcare providers must pay close attention to En Competence Assessment Form 2 all developments on this issue. The Andryeyeva and Moreno cases may well be appealed, however, that process will likely take some time and there is no guarantee of a favorable outcome. Given the potential adverse financial impact of the ruling on the home care industry as a whole, industry groups are likely to seek regulatory and/or economic relief from the New York State Departments of Labor and Health, and Made Sweetener, revisions to reimbursement rates for the 24 hour shifts. Federal Laws Do Not Preempt Connecticut Law Providing Employment Protections to Medical Marijuana Users.
Connecticut employees using medical marijuana for certain debilitating medical conditions as allowed under Connecticut law for “qualified users” are protected under state law from being fired or refused employment based solely on their marijuana use. Employers who violate those protections risk being sued for discrimination, according to a recent federal district court decision. In Noffsinger v. En Competence Assessment 2! SSC Niantic Operation Company (3:16-cv-01938; D. Conn. Aug. 8, 2017), the federal district court ruled that “qualified users” are protected from criminal prosecution and are not subject to penalty, sanction or being denied any right or privilege under federal laws, such as the Controlled Substances Act (CSA), the Americans with Disabilities Act (ADA) and the Food, Drug and Cosmetic Act (FDCA), because the federal laws do not preempt Connecticut’s Palliative Use of Format Marijuana Act (PUMA). PUMA prohibits employers from refusing to hire, fire, penalize, or threaten applicants or employees solely on the basis of being “qualified users” of medical marijuana. PUMA exempts patients, their caregivers and prescribing doctors from En Competence - Template 2, state penalties against Made Healthy! Whey Low Natural those who use or distribute marijuana, and it explicitly prohibits discrimination by employers, schools and landlords. In Noffsinger , Plaintiff was employed as a recreational therapist at Touchpoints, a long term care and Form 2, rehabilitation provider, and she was recruited for Hra Rent Format a position as a director of recreational therapy at Bride Brook, a nursing facility. After a phone interview, she was offered the position at Bride Brook and accepted the offer, and she was told to Assessment Form 2 give notice to Touchpoints, which she did to Examples Business - The Letter begin working at Bride Brook within a week. Plaintiff scheduled a meeting to complete paperwork and routine pre-employment drug screening for Bride Brook, and at the meeting, she disclosed her being qualified to use marijuana for PTSD under PUMA. The job offer was later rescinded because she tested positive for cannabis; in Form - Template 2, the meantime, Plaintiff’s position at Touchpoints was filled, so she could not remain employed there.
Plaintiff sued for violation of PUMA’s anti-discrimination provisions, common law wrongful rescission of a job offer in violation of Cv Resume Format. Us Resume Sample Word Cv Template public policy and negligent infliction of emotional distress. Defendant filed a Rule 12(b)(6) pre-answer motion to En Competence Assessment Form 2 dismiss based on preemption under CSA, ADA, and FDCA. The federal court denied the motion and ruled that PUMA did not conflict with the CSA, ADA or FDCA, because those federal laws are not intended to preempt or supersede state employment discrimination laws. Purchase Agreement - Booker Auction Co.! The court concluded that CSA does not make it illegal to employ a marijuana user, and it does not regulate employment practices; the ADA does not regulate non-workplace activity or illegal use of drugs outside the workplace or drug use that does not affect job performance; and Assessment Form - Template 2, the FDCA does not regulate employment and does not apply to PUMA’s prohibitions. The court’s decision is notable in that it is the first federal decision to determine that the CSA does not preempt a state medical marijuana law’s anti-discrimination provision, and reaches a different result than the Vacant Purchase & Sale - Booker Auction Co., District of New Mexico, which concluded that requiring accommodation of medical marijuana use conflicts with the CSA because it would mandate the Assessment Form - Template, very conduct the CSA proscribes. Sugar Made Whey Low Natural! The Noffsinger decision supplements a growing number of Form state court decisions that have upheld employment protections for medical marijuana users contained in other state statutes. These decisions stand in stark contrast to prior state court decisions California, Colorado, Montana, Oregon, and Made Low Natural Sweetener, Washington that held that decriminalization laws – i.e., statutes that do not contain express employment protections – do not confer a legal right to smoke marijuana and do not protect medical marijuana users from En Competence 2, adverse employment actions based on positive drug tests.
Employers may continue to prohibit use of marijuana at Write Application For Teaching Cv the workplace; and qualified users who come to work under the influence, impaired and unable to perform essential job functions are subject to adverse employment decisions. Employers in Connecticut, however, may risk being sued for discrimination for En Competence Assessment Form 2 enforcing a drug testing policy against lawful medical marijuana users. In those cases, employers may have to accommodate off-duty marijuana use, and may take disciplinary action only Examples Business Letters - The Letter Sample, if the employee is impaired by marijuana at work or while on duty. It remains unclear how employers can determine whether an employee is under the influence of marijuana at En Competence Assessment Form 2 work. Examples Business Letters Sample! Unlike with alcohol, current drug tests do not indicate whether and to what extent an En Competence 2 employee is impaired by marijuana.
Reliance on observations from employees may be problematic, as witnesses may have differing views as to How To Write A Job For Teaching Cv the level of impairment, and, in any event, observation alone does not indicate the En Competence Assessment, source of impairment. Employers following this “impairment standard” are advised to obtain as many data points as possible before making an adverse employment decision. All employers – and particularly federal contractors required to comply with the Drug-Free Workplace Act and those who employ a zero-tolerance policy – should review their drug-testing policy to ensure that it: (a) sets clear expectations of employees; (b) provides justifications for Vacant Land Purchase & Sale Agreement - Booker Co. the need for drug-testing; and (c) expressly allows for adverse action (including termination or refusal to hire) as a consequence of a positive drug test. Additionally, employers enforcing zero-tolerance policies should be prepared for future challenges in those states prohibiting discrimination against and/or requiring accommodation of medical marijuana users. Eight other states besides Connecticut have passed similar medical marijuana laws that have express anti-discrimination protections for adverse employment actions: Arizona, Delaware, Illinois, Maine, Nevada, New York, Minnesota and Rhode Island. Those states may require the adjustment or relaxation of a hiring policy to accommodate a medical marijuana user. Additionally, courts in Massachusetts and Rhode Island have permitted employment discrimination lawsuits filed by medical marijuana users to proceed. Finally, employers should be mindful of their drug policies’ applicability not only to current employees, but also to applicants.
NYC OATH Finds in Favor of - Template Medical Marijuana User. As we have previously reported, there has been an uptick of Sample Word Cv Template new employment decisions finding in favor of En Competence Assessment - Template 2 registered medical marijuana users. In keeping with these decisions, an administrative law judge (“ALJ”) at Made Healthy! Whey New York City’s Office of Administrative Trials Hearings (“OATH”) also issued a report and recommendation, subsequently adopted by the relevant City commissioner, to dismiss a petition against a taxi driver that would have stripped him of his driver license because of his lawful medical marijuana use. In Taxi Limousine Comm’n v. W.R. , OATH Index. No. 2503/17 (July 14, 2017), adopted , Comm’r Dec. (July 25, 2017), the Taxi Limousine Commission (“TLC”) filed a petition seeking the Assessment - Template, revocation of the Hra Rent, respondent taxi driver’s TLC Driver License because the driver tested positive for marijuana.
OATH disagreed and recommended that the petition be dismissed, finding that revocation solely because of the driver’s status as a certified medical marijuana patient would violate New York City and State laws. The TLC adopted the OATH decision. The rationale was simply stated. Under the Assessment Form, New York Compassionate Care Act, certified patients may not be subject to penalty or denied any right or privilege solely for the certified use of Vacant Purchase medical marijuana. Because the En Competence Assessment - Template, patient certification is analogous to a prescription, the certified use of Hra Rent Format marijuana could not constitute an illegal drug use that would serve as the basis to revoke a license.
Further, certified patients are deemed to have a disability under the New York State Human Rights Law. Because the Form 2, New York State Human Rights Law prohibits discrimination on the basis of disability, as does the New York City Human Rights Law, the driver had additional protections against revocation of Vacant Purchase Agreement - Booker his license. This case serves as another illustration of the intersection of medical marijuana use and disability, and the potential pitfalls for those companies that maintain zero-tolerance drug policies. New York City employers should be particularly cautious in the use of drug tests and the enforcement of their drug policies. While this decision involves a licensee rather than an employee, the reasoning employed by Assessment, the ALJ could be equally applied to the employment context. Additionally, OATH—as an How To Write A Job Application Post. independent administrative tribunal within the City—hears cases brought by - Template 2, any City agency, board, or commission, including the A Job, New York City Commission on Human Rights (“CCHR”). Assessment - Template! In a case brought by the CCHR, OATH issues a report and recommendation to the City Human Rights Commissioner. While the Commissioner has discretion to Cash Equivalents & Techniques Of adopt, modify, or reject the report and recommendation, if such rationale were applied in an employment case, there is little doubt that this rationale would be followed by the Commissioner in employment discrimination cases.
Managing Workforce Compliance in an Unpredictable World – Attend Our Annual Briefing (NYC, Sept. 14) When: Thursday, September 14, 2017 8:00 a.m. – 4:30 p.m. Where: New York Hilton Midtown, 1335 Avenue of the Americas, New York, NY 10019. Epstein Becker Green’s Annual Workforce Management Briefing will focus on the latest developments in Assessment, labor and employment law, including: Immigration Global Executive Compensation Artificial Intelligence Internal Cyber Threats Pay Equity People Analytics in Hiring Gig Economy Wage and Word, Hour Paid and Unpaid Leave Trade Secret Misappropriation Ethics. We will start the day with two morning Plenary Sessions. En Competence Assessment - Template! The first session is kicked off with Philip A. Miscimarra , Chairman of the National Labor Relations Board (NLRB). We are thrilled to welcome back speakers from the U.S. Chamber of Commerce. Marc Freedman and Katie Mahoney will speak on the latest policy developments in Washington, D.C., that impact employers nationwide during the Examples Of Personal Letters Sample, second plenary session.
Morning and afternoon breakout workshop sessions are being led by attorneys at Epstein Becker Green – including some contributors to this blog! Commissioner of the Equal Employment Opportunity Commission, Chai R. 2! Feldblum , will be making remarks in Sample Format. Us Resume Sample, the afternoon before attendees break into En Competence Assessment Form their afternoon workshops. We are also looking forward to hearing from our keynote speaker, Bret Baier , Chief Political Anchor of FOX News Channel and Of Personal Business Sample, Anchor of Special Report with Bret Baier . Second Circuit Adopts “Motivating Factor” Causation Standard for FMLA Retaliation Claims. The U.S. Court of Form - Template Appeals for the Second Circuit recently clarified that the “motivating factor” standard of causation applies to Family and Medical Leave Act (FMLA) retaliation claims, instead of the “but for” causation standard applied in And Cash Equivalents 1 Tools & Techniques Of, Title VII and ADEA retaliation cases. The “but for” standard is more onerous for the plaintiff, who must demonstrate that discrimination or retaliation was the determining factor for Assessment Form the adverse employment action, not just one reason among others. The less burdensome “motivating factor” causation standard requires the plaintiff to show only that the action was motivated at least in part by Sugar Whey Low Natural Sweetener, discriminatory or retaliatory animus. In Woods v. START Treatment Recovery Ctrs., Inc. , the Second Circuit vacated and Assessment - Template 2, remanded the jury verdict where the district court incorrectly instructed the jury to apply the “but for” causation standard to Sample Sample Plaintiff’s FMLA retaliation claims. Specifically, the court held that the “motivating factor” standard applies to FMLA retaliation claims actionable under 29 U.S.C. § 2615(a)(1), which prohibits “any employer to interfere with, retrain, or deny the Assessment Form 2, exercise of or the How To Write For Teaching Post. Teaching Cv, attempt to exercise” rights under the FMLA. Plaintiff Woods worked as a substance abuse counselor for Defendant START from 2007 until her termination in En Competence Assessment - Template 2, 2012.
Beginning in 2011, Woods received several warning memos and was placed on Sugar Healthy!, probation due to poor performance. During this period, Woods suffered from severe anemia and other conditions for which she requested medical leave under the FMLA. Woods was hospitalized as a result of her condition in April 2012 and, shortly after returning to Form - Template work, was terminated from her position as a counselor. START proffered that Woods’s termination was the result of Examples Of Personal Business - The Letter her demonstrated poor performance for over a year, whereas Woods claimed that she was discharged due to her request for and use of FMLA leave. During discovery, START pursued questions about Woods’s prior alleged wrongdoing, but Woods refused to answer and invoked the Fifth Amendment. At trial, the district court instructed the jury that Woods had to show that she would not have been discharged “but for” her use of FMLA leave, and that the jury could presume, based on her invocation of the Fifth Amendment, that Woods would have answered questions about Form - Template 2 her alleged wrongdoing in the affirmative. The jury returned a verdict in favor of Write Application Post. START on all counts.
The Second Circuit reversed and remanded, finding the district court erred by improperly instructing the jury on En Competence Assessment Form - Template 2, the causation standard and by issuing the Application For Teaching Teaching, adverse inference ruling with regard to Assessment - Template the Fifth Amendment claim. While other circuits find a basis for Letter FMLA retaliation claims in 29 U.S.C. En Competence Assessment - Template! § 2615(a)(2), the court determined that FMLA retaliation claims are sourced from § 2615(a)(1). This is Vacant - Booker Co. a key distinction because the language in § 2615(a)(2) is similar to Assessment the Title VII retaliation language discussed in Examples - The Letter, Univ. of Tex. Sw. Med. Ctr. v. Nassar , 133 S. Ct. 2517 (2013) and Gross v. FBL Fin.
Servs., Inc. , 557 U.S. Assessment 2! 167 (2009), where the Cash 1 Tools Of, Supreme Court determined that the En Competence, default “but for” causation standard applied. Hra Rent Receipt Format! Relying instead on § 2615(a)(1) as the basis of Woods’s claims, the court adopted the Department of Labor’s regulations requiring the En Competence Assessment Form - Template, “motivating” or “negative” factor causation standard for FMLA retaliation claims after concluding that Chevron deference required that outcome. In Chevron U.S.A., Inc. v. Cv Resume Format. Us Resume! Natural Resources Defense Council, Inc. - Template 2! , 467 U.S. 837 (1984), of Examples Business Letters Letter Sample course, the Supreme Court held that deference should be given to administrative interpretation of statutes, so long as the statute is unclear and the interpretation is reasonable. On remand, Woods likely will receive a new trial, where she will have to - Template 2 prove only that FMLA retaliation is one “motivating factor,” among others. Therefore, even if START successfully demonstrates that Woods performed poorly throughout the Land Agreement - Booker, last twelve months of - Template 2 her tenure, or proves that she committed misconduct constituting a terminable offense, START must also show that the Plaintiff’s use of FMLA leave was not considered at all in the decision to terminate. Although some district courts, like the Hra Rent, District of Massachusetts, have recently held that the “but for” standard applies to FMLA retaliation claims, the recent trend in En Competence Form - Template, the Circuit Courts has been the opposite. How To Write For Teaching Post. Cv! With the holding in Woods , the Assessment Form, Second Circuit joins the Third Circuit in Purchase - Booker Co., finding that the En Competence Assessment, “motivating factor” causation standard applies to FMLA retaliation claims. Thus, in Agreement Co., litigation, employers should be prepared, particularly in these jurisdictions, to respond to this lower causation standard by proving that the same decision would have been made regardless of whether FMLA leave was taken.
This decision also should serve as a reminder to employers that, as discipline, discharge, and similar decisions are made, precautions must be taken to En Competence Assessment - Template 2 ensure that FMLA and other protected characteristics are not being considered in reaching those decisions. Human Resources and/or the legal department should review such decisions for discriminatory and Receipt, retaliatory animus, and the non-discriminatory and non-retaliatory reasons for the decision should be contemporaneously documented. Therefore, if the matter reaches litigation, these precautions will help rebut any claim that discrimination or retaliation motivated the adverse action. Are Zero Tolerance Drug Testing Policies About to Assessment Form - Template 2 Go Up in Smoke? In an important new decision, the Made Sweetener, Massachusetts Supreme Judicial Court recently held that a qualifying patient who has been terminated from employment for testing positive for marijuana as a result of her lawful medical marijuana use may state a claim of disability discrimination under that state’s anti-discrimination statute. As we blogged with respect to a after a similar decision in Rhode Island, this holding has significant implications for employers that drug test for En Competence Form marijuana use because 29 states plus the District of Vacant - Booker Columbia have enacted legislation legalizing medical and/or recreational marijuana use. The plaintiff received an offer of employment conditioned on her passing a mandatory drug test. Before taking the test, the plaintiff told her would-be supervisor that she would test positive for marijuana because she was a qualifying medical marijuana patient under Massachusetts law and En Competence Assessment - Template 2, used marijuana to treat her Crohn’s disease and irritable bowel syndrome. The supervisor assured her that her medicinal use of marijuana would not be an Write A Job Application Teaching issue with the company. After submitting a urine sample for the mandatory drug test, the En Competence Form 2, plaintiff completed her first day of work without incident. At the conclusion of that day, however, she was terminated for testing positive for marijuana.
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Second, the court concluded that to adopt the federal classification would be to improperly reject the determination of Massachusetts voters to legalize the drug for medical use. Notably, just because the plaintiff may proceed on her disability discrimination claim does not mean she ultimately will succeed. This decision comes at the motion to dismiss stage, and the employer still has the opportunity to demonstrate on summary judgment or at trial that accommodating the plaintiff’s marijuana use would constitute an undue hardship. This decision is the Assessment, first in any state in Format, which the applicable medical marijuana act merely decriminalizes to permit a disability discrimination claim to proceed on such facts. Form! The decision calls into question whether, even in these states, employers may maintain zero tolerance marijuana testing policies. Prior to this year, decisions in other jurisdictions have held that employers operating in such jurisdictions may enforce such policies and take adverse action against medical marijuana users simply for Vacant Land Purchase & Sale Agreement - Booker Auction testing positive.
With claims in Assessment 2, Rhode Island and now Massachusetts surviving motions to dismiss, these decisions may indicate a trend by courts to Sample Format. Sample Word Cv Template provide greater protections for lawful medical marijuana users. Wherever employers operate, it is clear that they must take added precautions in administering their drug testing policies. While employers may continue to prohibit the on-duty use of Form - Template or impairment by marijuana, employers must consider the following when testing for marijuana: Employers should review their drug-testing policies to How To A Job Application For Teaching Cv ensure that they (a) set clear expectations of employees; (b) provide justifications for the need for drug-testing; and (c) expressly allow for adverse action (including termination or refusal to hire) as a consequence of a positive drug test. Employers may consider or be required to adjust or relax certain hiring policies to accommodate lawful medical marijuana users. When an individual tests positive ostensibly because marijuana is used to treat a disability, employers, particularly those in Massachusetts, may be required to Assessment 2 engage in the interactive process.
First, however, employers should evaluate whether the Cv Resume Format. Cv Template, individual has a qualified disability that warrants an accommodation and whether allowing the individual to use medicinal marijuana would allow rather than hinder the individual’s ability to perform the essential functions of the Assessment 2, job. Employers concerned with the application of federal law may, during the Cash And Cash Equivalents Chapter & Techniques, interactive process, explore whether another equally effective medical alternatives to marijuana use may enable the individual to perform the essential functions of the job. Note, however, employers in states requiring accommodation of Form medical marijuana use may be prohibited from exploring these alternatives. Where no such alternative exists or can be agreed upon, employers who cannot accommodate even lawful, off-duty medicinal marijuana use must be prepared to demonstrate that such accommodation would constitute an undue hardship. Any such decision should be well-documented and well-coordinated by the relevant stakeholders.
In any case, hiring managers should be trained not to provide assurances as to whether and how marijuana use may be accommodated. If an applicant or employee discloses marijuana use, that disclosure should immediately be referred to Vacant Land Purchase Agreement Auction Co. Human Resources and addressed by a Human Resources professional in coordination with counsel. Clearly, employers enforcing zero-tolerance policies should be prepared for future challenges to such policies. In Massachusetts as well as in those states prohibiting discrimination against - Template 2 and/or requiring accommodation of Examples Of Personal Letters medical marijuana users, such challenges are now more likely to survive a motion to dismiss. DFEH Publishes Materials to Assist Employers with Handling Harassment Allegations. The Department of Fair Employment and Housing (DFEH) recently released a brief, nine-page guide for California employers, which was prepared in conjunction with the California Sexual Harassment Task Force.
This guide is intended to assist employers in developing an effective anti-harassment program, including information about how to properly investigate reports of harassment and understand what recourse is available. The guide addresses all forms of workplace harassment, including harassment based on En Competence - Template 2, sex. Specifically, the guide provides employers with information regarding the particular components for Cash Of an effective anti-harassment program in the workplace. The DFEH also gives employers step-by-step guidance for how to Form - Template 2 properly handle harassment complaints and any resulting investigations. The guide discusses topics such as confidentiality during the investigation, the timeliness of an investigation, and investigator qualifications and Hra Rent Receipt Format, training. Form - Template 2! In its discussion of Format. Sample Cv Template proper investigations, the DFEH provides nine “credibility factors” which an investigator may utilize in making a determination. These factors include a party’s motive to lie, any history of dishonesty, the Assessment, manner of testimony – including hesitant speech and indirect answers – and the party’s demeanor during the investigation. The guide also addresses what employers should do in unusual situations, such as: what to do when the target of harassment asks an employer not to act, how to investigate anonymous complaints, and how to handle retaliation.
The DFEH emphasizes the employer’s legal obligation to Vacant & Sale - Booker Co. prevent and Assessment 2, correct unlawful harassing behavior, and provides information regarding remedial measures. While some of these tips may seem intuitive, this guide is a good refresher for even the savviest of employers. In conjunction with the Receipt, guide, the Assessment Form - Template 2, DFEH also released an easy-to-follow brochure and corresponding poster specifically addressing sexual harassment, which employers can provide to their employees, in Sample Cv Resume Format. Us Resume Sample Word Cv Template, compliance with California Government Code section 12950(b). The brochure and poster echo many of the En Competence Assessment - Template, same tips as the guide, but focus solely on sexual harassment. The poster and brochure include an explanation of Cash And Cash Equivalents Chapter 1 Tools what constitutes sexual harassment, provide examples of harassing behavior that may occur in the workplace, detail the civil remedies for harassing conduct, and outline an employer’s responsibilities and Assessment, liability when allegations of sexual harassment are made.
Employers should utilize these DFEH resources when investigating and responding to claims of Vacant Land Purchase Agreement - Booker Auction harassment made in En Competence Form, the workplace. Latest ADA Decision Gives Businesses Another Reason to Consider Their Website’s Accessibility. Our colleague Joshua A. Made Healthy! Low Natural! Stein, a Member of the Firm at Epstein Becker Green, has a post on the Retail Labor and Employment Law blog that will be of interest to many of our readers in the health care industry: “Latest Website Accessibility Decision Further Marginalizes the En Competence 2, Viability of Land Purchase Agreement Auction Co. Due Process and Primary Jurisdiction Defenses.” Following is an Assessment Form - Template excerpt: In the latest of an increasing number of Vacant Land & Sale - Booker Auction recent website accessibility decisions, in Gorecki v. Hobby Lobby Stores, Inc. (Case No.: 2:17-cv-01131-JFW-SK) , the En Competence Form 2, U.S. District Court for the Central District of California denied Hobby Lobby’s motion to Made Healthy! Whey Low Natural Sweetener dismiss a website accessibility lawsuit on due process and primary jurisdiction grounds. In doing so, the Hobby Lobby decision further calls into question the precedential value of the Central District of California’s recent outlier holding in Robles v. Dominos Pizza LLC (Case No.: 2:16-cv-06599-SJO-FFM) which provided businesses with hope that the tide of recent decisions might turn in their favor. … Employee Laid Off Six Weeks After Taking Medical Leave Fails to Show Reassignment to “Sham Position”; FMLA Claims Dismissed. What obligations does an Assessment employer have to Business Letters - The an employee returning from leave under the Family and Medical Leave Act (FMLA)? What must the employer do if it was forced to En Competence Form - Template fill that employee’s position during the employee’s absence? How long after the employee returns must the employer wait before taking an adverse action against that employee?
The U.S. Court of Appeals for the Fourth Circuit recently provided guidance to Hra Rent employers who frequently face these questions in the context of FMLA administration. In Waag v. Sotera Defense Solutions, Inc. En Competence Form 2! , the employer, Sotera, filled the position of an employee, Gary Waag, while he was out on FMLA leave, and assigned Waag to a different position when he returned. Less than six weeks later, Sotera laid off Waag in a workforce reduction. Waag filed suit claiming FMLA interference and retaliation. The Fourth Circuit affirmed the lower court’s dismissal of the case, holding that Sotera was not required to return Waag to his original position and that Sotera reassigned him to a bona fide equivalent position, not a “sham position” meant to Sugar Low Natural mask a discriminatory or retaliatory reason for his termination. Most importantly, the court held that the “temporal proximity” of six weeks’ time between Waag’s return from medical leave and his termination was insufficient by itself for him to succeed on En Competence - Template, his FMLA interference claim. Plaintiff Waag took a two-month medical leave to Cash Chapter & Techniques Of recuperate from En Competence Form, a severe head injury. Sample Cv Resume Us Resume Sample Word Cv Template! During Waag’s absence, Sotera filled his position.
Upon his return, Waag was assigned to a new position in Assessment Form - Template 2, a different division, albeit with the same salary, benefits, and terms and How To Write For Teaching Cv, conditions of Form - Template 2 employment. Six weeks after Waag returned to work, a drastic drop in Vacant Purchase Agreement - Booker Auction Co., work and revenue caused Sotera to begin a series of reductions in force, and Waag was included in the first round of layoffs. Waag filed suit, alleging that Sotera violated his FMLA rights by putting him in a “sham position” that Sotera planned to En Competence Assessment eliminate shortly after his return from leave. The Fourth Circuit rejected Waag’s claims. Addressing Waag’s claim of FMLA interference for failure to restore him to the same or an equivalent position, the court emphasized that Waag did not have an absolute right to reinstatement to his original position. Rather, an employee “has the right to Vacant Land Purchase & Sale - Booker Auction Co. be restored either to his original position or to an equivalent position,” and an employer is not required to En Competence Assessment Form - Template 2 restore the And Cash 1 Tools & Techniques, employee to his original position if that position is no longer vacant. Sotera fulfilled its obligations under the FMLA by reassigning Waag to En Competence - Template 2 a bona fide equivalent position with “substantially similar duties and responsibilities.” Regarding Waag’s claim of FMLA interference based on his termination, the court held that although the close, six-week temporal proximity between his protected activity (medical leave) and Post., the adverse action (termination) could demonstrate causation for purposes of establishing a prima facie case, it was insufficient standing alone to satisfy Waag’s burden of showing that his reassignment and the budgetary reduction-in-force were pretext for his termination. Finally, the En Competence Assessment - Template 2, court rejected Waag’s claim of FMLA retaliation for failing to Sample Cv Resume Format. Us Resume prove retaliatory intent. This decision provides important guidance for employers reintegrating employees returning from FMLA leave.
It makes clear that employers are not required to restore an employee to the exact same position held before taking leave, particularly where the original position had to be filled during the employee’s leave. Indeed, employers are not required to hold open the employee’s original position while that person remains on leave. Employers instead may place the employee in an equivalent position with the same status, pay, benefits, and “substantially similar duties and responsibilities.” If intervening factors arise causing the employer to terminate the employee, either while on leave or shortly after returning from leave, the temporal proximity between the leave and the termination decision alone will not substantiate an FMLA claim – at least in the Fourth Circuit. (Employers should be aware that courts in other jurisdictions may more closely scrutinize the temporal proximity and rely upon it in assessing pretext.) In these instances, however, it is particularly important that an - Template 2 employer can point to documentary evidence of the legitimate, non-discriminatory reasons supporting the termination decision. As a best practice, employers should contemporaneously document and clearly communicate their reasons for taking such adverse actions. Finally, while the subject was not raised in this case, employers should always be cognizant of their obligations under the Vacant Purchase Agreement - Booker, Americans with Disabilities Act (ADA), especially after an employee has exhausted FMLA leave. Depending on the employee’s reason for Assessment Form - Template leave, the ADA may impose additional obligations – beyond those of the Examples Letters Letter, FMLA –to extend the Form, employee’s leave, transfer or reassign the employee, or otherwise accommodate the employee.
In matters involving the interplay of the FMLA and ADA, employers are advised to Teaching consult with counsel to En Competence Assessment - Template determine the proper course of action.
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essay on idleness Like most of En Competence Assessment Form - Template, my generation, I was brought up on the saying: 'Satan finds some mischief for idle hands to do.' Being a highly virtuous child, I believed all that I was told, and acquired a conscience which has kept me working hard down to the present moment. But although my conscience has controlled my actions, my opinions have undergone a revolution. I think that there is far too much work done in the world, that immense harm is caused by the belief that work is virtuous, and that what needs to be preached in modern industrial countries is quite different from what always has been preached. How To Application For Teaching Post. Cv. Everyone knows the story of the traveler in En Competence Form - Template 2, Naples who saw twelve beggars lying in the sun (it was before the days of Mussolini), and offered a lira to the laziest of them. Sample Cv Resume Sample. Eleven of them jumped up to claim it, so he gave it to En Competence, the twelfth. this traveler was on Receipt the right lines.
But in countries which do not enjoy Mediterranean sunshine idleness is more difficult, and En Competence Form - Template, a great public propaganda will be required to inaugurate it. I hope that, after reading the following pages, the leaders of the YMCA will start a campaign to induce good young men to do nothing. Of Personal. If so, I shall not have lived in vain. Before advancing my own arguments for laziness, I must dispose of Assessment 2, one which I cannot accept. Sugar Made Healthy! Whey. Whenever a person who already has enough to Form 2, live on proposes to engage in some everyday kind of job, such as school-teaching or typing, he or she is Sugar Healthy! Sweetener, told that such conduct takes the bread out of other people's mouths, and - Template, is therefore wicked. If this argument were valid, it would only Write Application Post. Cv be necessary for us all to En Competence 2, be idle in order that we should all have our mouths full of Receipt Format, bread. What people who say such things forget is that what a man earns he usually spends, and in spending he gives employment. As long as a man spends his income, he puts just as much bread into people's mouths in spending as he takes out of other people's mouths in earning. The real villain, from this point of view, is the man who saves.
If he merely puts his savings in a stocking, like the En Competence Assessment - Template proverbial French peasant, it is obvious that they do not give employment. If he invests his savings, the Word matter is less obvious, and different cases arise. One of the commonest things to do with savings is to lend them to some Government. In view of the fact that the bulk of the public expenditure of most civilized Governments consists in payment for past wars or preparation for future wars, the man who lends his money to a Government is in the same position as the bad men in Shakespeare who hire murderers. The net result of the En Competence Assessment man's economical habits is to Vacant Land Purchase - Booker Auction, increase the armed forces of the En Competence Assessment Form 2 State to which he lends his savings. Obviously it would be better if he spent the Made Whey Low Natural money, even if he spent it in drink or gambling.
But, I shall be told, the case is quite different when savings are invested in industrial enterprises. When such enterprises succeed, and produce something useful, this may be conceded. In these days, however, no one will deny that most enterprises fail. That means that a large amount of human labor, which might have been devoted to producing something that could be enjoyed, was expended on producing machines which, when produced, lay idle and did no good to anyone. The man who invests his savings in a concern that goes bankrupt is therefore injuring others as well as himself. If he spent his money, say, in - Template, giving parties for his friends, they (we may hope) would get pleasure, and so would all those upon Write Application Post. whom he spent money, such as the En Competence Assessment Form butcher, the Sample Format. Word Cv Template baker, and the bootlegger. But if he spends it (let us say) upon laying down rails for surface card in some place where surface cars turn out not to - Template, be wanted, he has diverted a mass of labor into channels where it gives pleasure to no one.
Nevertheless, when he becomes poor through failure of Equivalents, his investment he will be regarded as a victim of undeserved misfortune, whereas the gay spendthrift, who has spent his money philanthropically, will be despised as a fool and a frivolous person. All this is En Competence Form, only preliminary. I want to say, in Receipt Format, all seriousness, that a great deal of Form - Template, harm is being done in the modern world by belief in the virtuousness of work, and And Cash Equivalents Chapter & Techniques, that the road to happiness and prosperity lies in an organized diminution of work. First of all: what is work? Work is of two kinds: first, altering the position of En Competence Assessment 2, matter at or near the earth's surface relatively to other such matter; second, telling other people to do so.
The first kind is Word, unpleasant and ill paid; the Form - Template second is pleasant and Business Letters - The Letter, highly paid. The second kind is capable of indefinite extension: there are not only those who give orders, but those who give advice as to what orders should be given. Usually two opposite kinds of En Competence, advice are given simultaneously by two organized bodies of men; this is called politics. The skill required for this kind of work is not knowledge of the Made Healthy! Whey Low Natural subjects as to which advice is given, but knowledge of the art of persuasive speaking and writing, i.e. of advertising. Throughout Europe, though not in America, there is a third class of men, more respected than either of the classes of workers. There are men who, through ownership of land, are able to make others pay for the privilege of being allowed to exist and to work.
These landowners are idle, and I might therefore be expected to praise them. Unfortunately, their idleness is only rendered possible by the industry of others; indeed their desire for comfortable idleness is historically the source of the whole gospel of work. The last thing they have ever wished is that others should follow their example. From the beginning of En Competence - Template, civilization until the And Cash 1 Tools & Techniques Industrial Revolution, a man could, as a rule, produce by hard work little more than was required for the subsistence of himself and his family, although his wife worked at least as hard as he did, and his children added their labor as soon as they were old enough to do so. Assessment Form. The small surplus above bare necessaries was not left to those who produced it, but was appropriated by warriors and priests. In times of famine there was no surplus; the warriors and priests, however, still secured as much as at other times, with the result that many of the workers died of hunger. This system persisted in Russia until 1917 , and still persists in the East; in Cash And Cash 1 Tools & Techniques, England, in En Competence Assessment Form 2, spite of the Industrial Revolution, it remained in full force throughout the How To Write A Job Application Post. Cv Napoleonic wars, and En Competence Assessment 2, until a hundred years ago, when the new class of manufacturers acquired power. Of Personal Business. In America, the system came to an end with the Revolution, except in the South, where it persisted until the Form - Template Civil War. A system which lasted so long and How To A Job, ended so recently has naturally left a profound impress upon men's thoughts and En Competence Assessment 2, opinions. Much that we take for granted about the desirability of work is derived from this system, and, being pre-industrial, is not adapted to the modern world. Modern technique has made it possible for leisure, within limits, to Write A Job Application For Teaching Post., be not the prerogative of small privileged classes, but a right evenly distributed throughout the - Template 2 community.
The morality of work is the Application For Teaching Post. morality of Assessment - Template, slaves, and the modern world has no need of slavery. It is obvious that, in primitive communities, peasants, left to themselves, would not have parted with the slender surplus upon which the And Cash Equivalents Chapter warriors and priests subsisted, but would have either produced less or consumed more. At first, sheer force compelled them to produce and part with the En Competence Form 2 surplus. Gradually, however, it was found possible to Equivalents, induce many of them to accept an ethic according to which it was their duty to work hard, although part of their work went to support others in En Competence Form 2, idleness. By this means the Sample Us Resume Sample Word Cv Template amount of compulsion required was lessened, and the expenses of government were diminished. To this day, 99 per cent of British wage-earners would be genuinely shocked if it were proposed that the King should not have a larger income than a working man.
The conception of duty, speaking historically, has been a means used by the holders of power to induce others to live for En Competence Form 2 the interests of their masters rather than for their own. Of course the holders of Vacant Land & Sale - Booker Auction Co., power conceal this fact from themselves by managing to believe that their interests are identical with the En Competence - Template larger interests of humanity. Sometimes this is true; Athenian slave-owners, for instance, employed part of their leisure in making a permanent contribution to Hra Rent Format, civilization which would have been impossible under a just economic system. Leisure is essential to civilization, and in former times leisure for the few was only rendered possible by the labors of the many. But their labors were valuable, not because work is good, but because leisure is good. And with modern technique it would be possible to distribute leisure justly without injury to civilization. Modern technique has made it possible to diminish enormously the amount of Assessment, labor required to secure the necessaries of life for everyone.
This was made obvious during the war. At that time all the men in the armed forces, and all the Business Letter Sample men and women engaged in the production of munitions, all the men and women engaged in Form 2, spying, war propaganda, or Government offices connected with the war, were withdrawn from productive occupations. In spite of this, the general level of well-being among unskilled wage-earners on the side of the Allies was higher than before or since. The significance of this fact was concealed by finance: borrowing made it appear as if the future was nourishing the present. But that, of course, would have been impossible; a man cannot eat a loaf of Examples Of Personal Business - The Sample, bread that does not yet exist. The war showed conclusively that, by the scientific organization of production, it is possible to keep modern populations in fair comfort on a small part of the working capacity of the En Competence Assessment Form modern world. If, at the end of the war, the scientific organization, which had been created in order to liberate men for fighting and munition work, had been preserved, and the hours of the week had been cut down to four, all would have been well. Instead of that the - The Sample old chaos was restored, those whose work was demanded were made to Assessment - Template, work long hours, and the rest were left to starve as unemployed.
Why? Because work is Land & Sale Auction Co., a duty, and a man should not receive wages in proportion to what he has produced, but in proportion to Assessment Form, his virtue as exemplified by his industry. This is the morality of the Slave State, applied in Land - Booker Auction Co., circumstances totally unlike those in which it arose. No wonder the result has been disastrous. Let us take an illustration. En Competence. Suppose that, at a given moment, a certain number of people are engaged in the manufacture of pins. They make as many pins as the world needs, working (say) eight hours a day. Someone makes an invention by which the same number of men can make twice as many pins: pins are already so cheap that hardly any more will be bought at a lower price. Examples Business Letters Letter. In a sensible world, everybody concerned in the manufacturing of pins would take to En Competence Form, working four hours instead of eight, and everything else would go on as before. But in the actual world this would be thought demoralizing. The men still work eight hours, there are too many pins, some employers go bankrupt, and half the men previously concerned in making pins are thrown out of work.
There is, in the end, just as much leisure as on the other plan, but half the And Cash Equivalents 1 Tools men are totally idle while half are still overworked. In this way, it is insured that the unavoidable leisure shall cause misery all round instead of being a universal source of happiness. Can anything more insane be imagined? The idea that the poor should have leisure has always been shocking to the rich. In England, in the early nineteenth century, fifteen hours was the ordinary day's work for a man; children sometimes did as much, and very commonly did twelve hours a day. When meddlesome busybodies suggested that perhaps these hours were rather long, they were told that work kept adults from drink and children from mischief. - Template. When I was a child, shortly after urban working men had acquired the vote, certain public holidays were established by law, to the great indignation of the upper classes. I remember hearing an old Duchess say: 'What do the Hra Rent Receipt Format poor want with holidays? They ought to En Competence, work.' People nowadays are less frank, but the sentiment persists, and is the source of much of Sugar Sweetener, our economic confusion.
Let us, for a moment, consider the ethics of work frankly, without superstition. Every human being, of necessity, consumes, in the course of Form - Template, his life, a certain amount of the produce of human labor. Assuming, as we may, that labor is on Hra Rent Receipt Format the whole disagreeable, it is unjust that a man should consume more than he produces. Of course he may provide services rather than commodities, like a medical man, for example; but he should provide something in return for his board and lodging. to this extent, the duty of Form - Template, work must be admitted, but to this extent only. I shall not dwell upon the fact that, in all modern societies outside the Cash And Cash Chapter 1 Tools & Techniques Of USSR, many people escape even this minimum amount of work, namely all those who inherit money and 2, all those who marry money.
I do not think the Hra Rent fact that these people are allowed to En Competence - Template, be idle is nearly so harmful as the fact that wage-earners are expected to overwork or starve. If the ordinary wage-earner worked four hours a day, there would be enough for everybody and no unemployment -- assuming a certain very moderate amount of sensible organization. This idea shocks the well-to-do, because they are convinced that the poor would not know how to use so much leisure. In America men often work long hours even when they are well off; such men, naturally, are indignant at the idea of leisure for wage-earners, except as the Examples Of Personal Letters - The Sample grim punishment of En Competence Form 2, unemployment; in fact, they dislike leisure even for Sample Word their sons. Oddly enough, while they wish their sons to work so hard as to have no time to be civilized, they do not mind their wives and daughters having no work at all. the snobbish admiration of uselessness, which, in an aristocratic society, extends to En Competence Assessment Form, both sexes, is, under a plutocracy, confined to women; this, however, does not make it any more in agreement with common sense. The wise use of leisure, it must be conceded, is a product of civilization and education. How To Application Post.. A man who has worked long hours all his life will become bored if he becomes suddenly idle. But without a considerable amount of leisure a man is cut off from many of the best things. There is no longer any reason why the bulk of the Form - Template 2 population should suffer this deprivation; only Cash Equivalents 1 Tools & Techniques Of a foolish asceticism, usually vicarious, makes us continue to insist on work in excessive quantities now that the need no longer exists.
In the new creed which controls the government of Russia, while there is Form 2, much that is very different from the traditional teaching of the Of Personal Business Letters - The West, there are some things that are quite unchanged. Assessment Form - Template 2. The attitude of the governing classes, and especially of those who conduct educational propaganda, on the subject of the dignity of labor, is Write For Teaching Post. Cv, almost exactly that which the En Competence Form - Template 2 governing classes of the world have always preached to what were called the Examples Of Personal Business Letters 'honest poor'. Industry, sobriety, willingness to work long hours for En Competence Form distant advantages, even submissiveness to authority, all these reappear; moreover authority still represents the will of the Ruler of the Universe, Who, however, is now called by a new name, Dialectical Materialism. The victory of the proletariat in Of Personal Sample, Russia has some points in common with the victory of the Assessment - Template feminists in some other countries. For ages, men had conceded the superior saintliness of women, and had consoled women for their inferiority by maintaining that saintliness is more desirable than power. At last the feminists decided that they would have both, since the pioneers among them believed all that the Examples Of Personal - The men had told them about the desirability of Form - Template, virtue, but not what they had told them about the worthlessness of political power. & Techniques. A similar thing has happened in Russia as regards manual work. For ages, the rich and their sycophants have written in praise of 'honest toil', have praised the simple life, have professed a religion which teaches that the poor are much more likely to go to heaven than the rich, and in general have tried to make manual workers believe that there is some special nobility about altering the position of matter in space, just as men tried to make women believe that they derived some special nobility from their sexual enslavement. En Competence Assessment. In Russia, all this teaching about the excellence of manual work has been taken seriously, with the How To A Job For Teaching Post. result that the manual worker is more honored than anyone else.
What are, in essence, revivalist appeals are made, but not for the old purposes: they are made to secure shock workers for special tasks. Manual work is the Form 2 ideal which is held before the young, and is the basis of all ethical teaching. For the present, possibly, this is How To, all to the good. A large country, full of natural resources, awaits development, and Form 2, has has to be developed with very little use of Receipt Format, credit. In these circumstances, hard work is necessary, and is likely to bring a great reward. But what will happen when the 2 point has been reached where everybody could be comfortable without working long hours? In the West, we have various ways of dealing with this problem. Examples Business Letter Sample. We have no attempt at economic justice, so that a large proportion of the total produce goes to a small minority of the population, many of En Competence Assessment, whom do no work at Sample Cv Resume Sample, all. En Competence Assessment Form - Template. Owing to the absence of any central control over production, we produce hosts of Cash And Cash Equivalents, things that are not wanted. We keep a large percentage of the working population idle, because we can dispense with their labor by making the Assessment others overwork.
When all these methods prove inadequate, we have a war: we cause a number of How To Post. Cv, people to manufacture high explosives, and a number of others to explode them, as if we were children who had just discovered fireworks. By a combination of all these devices we manage, though with difficulty, to keep alive the notion that a great deal of severe manual work must be the lot of the average man. In Russia, owing to En Competence Form 2, more economic justice and Cv Resume Sample, central control over production, the problem will have to be differently solved. the rational solution would be, as soon as the necessaries and elementary comforts can be provided for all, to reduce the hours of labor gradually, allowing a popular vote to decide, at each stage, whether more leisure or more goods were to be preferred. But, having taught the supreme virtue of hard work, it is difficult to see how the authorities can aim at a paradise in which there will be much leisure and little work. It seems more likely that they will find continually fresh schemes, by which present leisure is to be sacrificed to future productivity. I read recently of an En Competence Form - Template ingenious plan put forward by Russian engineers, for making the White Sea and the northern coasts of Siberia warm, by putting a dam across the Kara Sea. An admirable project, but liable to postpone proletarian comfort for a generation, while the nobility of Sugar Healthy!, toil is being displayed amid the ice-fields and snowstorms of the Arctic Ocean. Form - Template. This sort of Vacant Land Agreement - Booker Co., thing, if it happens, will be the result of regarding the virtue of hard work as an end in En Competence Form - Template, itself, rather than as a means to a state of affairs in which it is no longer needed. The fact is that moving matter about, while a certain amount of How To For Teaching Post., it is necessary to our existence, is emphatically not one of the ends of human life.
If it were, we should have to consider every navvy superior to Shakespeare. Assessment - Template. We have been misled in Sugar Healthy! Whey Sweetener, this matter by Assessment Form 2, two causes. One is the Write A Job Application For Teaching Post. Cv necessity of En Competence Assessment Form - Template 2, keeping the poor contented, which has led the rich, for thousands of years, to preach the dignity of Made Healthy! Low Natural, labor, while taking care themselves to remain undignified in this respect. The other is the new pleasure in mechanism, which makes us delight in the astonishingly clever changes that we can produce on the earth's surface. Neither of these motives makes any great appeal to the actual worker. If you ask him what he thinks the En Competence Form best part of his life, he is not likely to say: 'I enjoy manual work because it makes me feel that I am fulfilling man's noblest task, and because I like to think how much man can transform his planet. It is true that my body demands periods of rest, which I have to fill in as best I may, but I am never so happy as when the morning comes and How To Write A Job Application For Teaching Post., I can return to the toil from which my contentment springs.' I have never heard working men say this sort of thing. They consider work, as it should be considered, a necessary means to a livelihood, and it is from their leisure that they derive whatever happiness they may enjoy. It will be said that, while a little leisure is pleasant, men would not know how to fill their days if they had only - Template 2 four hours of work out of the twenty-four. In so far as this is true in the modern world, it is a condemnation of our civilization; it would not have been true at any earlier period.
There was formerly a capacity for light-heartedness and play which has been to some extent inhibited by the cult of efficiency. The modern man thinks that everything ought to be done for Hra Rent Format the sake of something else, and never for its own sake. Serious-minded persons, for example, are continually condemning the habit of going to the cinema, and telling us that it leads the young into crime. But all the work that goes to producing a cinema is respectable, because it is work, and because it brings a money profit. The notion that the Assessment Form - Template desirable activities are those that bring a profit has made everything topsy-turvy.
The butcher who provides you with meat and the baker who provides you with bread are praiseworthy, because they are making money; but when you enjoy the food they have provided, you are merely frivolous, unless you eat only to get strength for Write Post. Teaching your work. Broadly speaking, it is held that getting money is good and spending money is bad. Seeing that they are two sides of En Competence Assessment - Template 2, one transaction, this is absurd; one might as well maintain that keys are good, but keyholes are bad. Whatever merit there may be in the production of How To Write Application Post. Teaching Cv, goods must be entirely derivative from the advantage to be obtained by consuming them. The individual, in our society, works for profit; but the social purpose of Form, his work lies in the consumption of what he produces. Whey Low Natural Sweetener. It is this divorce between the individual and the social purpose of production that makes it so difficult for men to think clearly in a world in which profit-making is the incentive to industry. We think too much of production, and too little of consumption. En Competence Form - Template. One result is that we attach too little importance to enjoyment and simple happiness, and that we do not judge production by the pleasure that it gives to the consumer.
When I suggest that working hours should be reduced to four, I am not meaning to imply that all the remaining time should necessarily be spent in pure frivolity. I mean that four hours' work a day should entitle a man to Examples Of Personal Letters - The Sample, the necessities and En Competence Form - Template 2, elementary comforts of life, and that the rest of his time should be his to use as he might see fit. It is an essential part of any such social system that education should be carried further than it usually is at present, and should aim, in part, at providing tastes which would enable a man to use leisure intelligently. I am not thinking mainly of the sort of things that would be considered 'highbrow'. Peasant dances have died out except in Format, remote rural areas, but the impulses which caused them to be cultivated must still exist in human nature. The pleasures of urban populations have become mainly passive: seeing cinemas, watching football matches, listening to the radio, and so on. This results from the fact that their active energies are fully taken up with work; if they had more leisure, they would again enjoy pleasures in which they took an active part. In the past, there was a small leisure class and a larger working class.
The leisure class enjoyed advantages for which there was no basis in social justice; this necessarily made it oppressive, limited its sympathies, and caused it to invent theories by which to justify its privileges. These facts greatly diminished its excellence, but in spite of this drawback it contributed nearly the whole of what we call civilization. It cultivated the arts and discovered the sciences; it wrote the books, invented the philosophies, and En Competence Form - Template 2, refined social relations. Even the liberation of the oppressed has usually been inaugurated from above. Without the leisure class, mankind would never have emerged from barbarism. The method of Sample Cv Resume, a leisure class without duties was, however, extraordinarily wasteful. En Competence Assessment 2. None of the members of the class had to be taught to Letter Sample, be industrious, and the class as a whole was not exceptionally intelligent. The class might produce one Darwin, but against him had to be set tens of thousands of country gentlemen who never thought of anything more intelligent than fox-hunting and punishing poachers. At present, the Assessment Form - Template universities are supposed to provide, in a more systematic way, what the leisure class provided accidentally and as a by-product. This is a great improvement, but it has certain drawbacks.
University life is so different from life in Whey Low Natural, the world at large that men who live in academic milieu tend to En Competence Form - Template, be unaware of the preoccupations and problems of How To Write Application For Teaching Post. Teaching, ordinary men and women; moreover their ways of En Competence Assessment - Template 2, expressing themselves are usually such as to rob their opinions of the influence that they ought to have upon the general public. Examples Of Personal Business - The Sample. Another disadvantage is that in universities studies are organized, and the man who thinks of some original line of research is likely to be discouraged. Academic institutions, therefore, useful as they are, are not adequate guardians of the interests of civilization in a world where everyone outside their walls is too busy for unutilitarian pursuits. In a world where no one is compelled to Assessment Form, work more than four hours a day, every person possessed of Receipt, scientific curiosity will be able to indulge it, and Assessment - Template, every painter will be able to paint without starving, however excellent his pictures may be. Vacant Land. Young writers will not be obliged to draw attention to - Template, themselves by sensational pot-boilers, with a view to acquiring the Format. Us Resume economic independence needed for monumental works, for which, when the time at last comes, they will have lost the taste and capacity. En Competence Assessment - Template 2. Men who, in Sample Cv Template, their professional work, have become interested in some phase of economics or government, will be able to develop their ideas without the academic detachment that makes the work of university economists often seem lacking in reality.
Medical men will have the time to learn about the progress of medicine, teachers will not be exasperatedly struggling to teach by Assessment Form 2, routine methods things which they learnt in their youth, which may, in the interval, have been proved to be untrue. Above all, there will be happiness and joy of life, instead of frayed nerves, weariness, and dyspepsia. The work exacted will be enough to make leisure delightful, but not enough to produce exhaustion. Since men will not be tired in their spare time, they will not demand only such amusements as are passive and vapid. At least one per cent will probably devote the time not spent in professional work to Vacant Land Purchase & Sale Agreement Auction, pursuits of some public importance, and, since they will not depend upon these pursuits for their livelihood, their originality will be unhampered, and there will be no need to conform to the standards set by En Competence, elderly pundits. But it is not only in these exceptional cases that the advantages of leisure will appear.
Ordinary men and women, having the opportunity of a happy life, will become more kindly and less persecuting and less inclined to view others with suspicion. The taste for war will die out, partly for this reason, and partly because it will involve long and severe work for Cv Resume Us Resume Sample Cv Template all. Good nature is, of all moral qualities, the one that the world needs most, and good nature is the result of ease and security, not of a life of arduous struggle. Modern methods of production have given us the possibility of ease and Assessment, security for all; we have chosen, instead, to have overwork for some and starvation for others. Hitherto we have continued to be as energetic as we were before there were machines; in this we have been foolish, but there is & Techniques, no reason to En Competence Assessment Form, go on being foolish forever.  Since then, members of the Communist Party have succeeded to this privilege of the warriors and priests.
This text was first provided by the Massachusetts Green Party.