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Congressional power of enforcement
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A Congressional power of enforcement is included in a number of amendments to the United States Constitution. The language "The Congress shall have power to enforce this article by appropriate legislation" is used, with slight variations, in Amendments XIII, XIV, XV, XIX, XXIII, XXIV, and XXVI. The variations in the pertinent language are as follows: The Thirteenth Amendment leaves out the word "the", the Fourteenth Amendment states "The Congress shall have the power to enforce, by appropriate legislation, the provisions of this article." In addition to the amendments above, the Eighteenth Amendment states "The Congress and the several States shall have concurrent power to enforce this article by appropriate legislation."
Initial creation and use[edit]
These provisions made their first appearance in the Thirteenth, Fourteenth and Fifteenth Amendments, which were adopted during the Reconstruction period primarily to abolish slavery and protect the rights of the newly emancipated African-Americans. The enforcement provisions contained in these amendments extend the powers of Congress originally enumerated in Article One, Section 8 of the Constitution, and have the effect of increasing the power of Congress and diminishing that of the individual states. They led to the "Enforcement Acts" of 1870 and 1871. Congress had only that power delegated (granted, given) to it by the constitution.
Use in the courts[edit]
Interpretation of the Fourteenth Amendment's enforcement provision has been the subject of several important Supreme Court cases, which reflect the tension between the Courts' role of interpreting the Constitution and Congress's power of adopting legislation to enforce specific Constitutional amendments.
Early on, in the Civil Rights Cases decided in 1883, the Supreme Court concluded that the Congressional enforcement power in Section 5 of the Fourteenth Amendment did not authorize Congress to use the Privileges or Immunities Clause of that amendment to ban racial discrimination in public accommodations operated by private persons, such as inns and theaters. The Court stated that since the Fourteenth Amendment only restricted state action, Congress lacked power under this amendment to forbid discrimination that was not sponsored by the state. This ruling has not been overturned, although in modern times, similar civil rights legislation has been upheld under Congress's power to regulate interstate commerce under Article One, Section 8 of the Constitution. See Civil Rights Act of 1964.
In the Katzenbach v. Morgan case, decided in 1966, the Supreme Court concluded that Congress can forbid practices that are not themselves unconstitutional, if the law is aimed at preventing or remedying constitutional violations. On that basis, the Court upheld a provision of the Voting Rights Act that prevented states from using English language literacy tests as qualifications for voting. The Court decided that the law was a valid exercise of Congress's enforcement power under the Equal Protections Clause of Fourteenth Amendment, because it was aimed at remedying state-sponsored discrimination, despite an earlier court finding that a literacy test was not in and of itself a violation of the 14th Amendment.
In 1970, however, in Oregon v. Mitchell, the Court held that Congress had exceeded its power by attempting to require the states to reduce the voting age to 18. This led to adoption of the Twenty-Sixth Amendment to the Constitution in 1971, which provided that the states could not set a minimum voting age higher than 18.
In the 1997 case of City of Boerne v. Flores, the Court again took a narrow view of the Congressional power of enforcement, striking down a provision of the Religious Freedom Restoration Act (RFRA) that sought to forbid the states from placing burdens on religious practice in the absence of a compelling state interest in doing so. In enacting RFRA, Congress had sought to overturn the 1988 Supreme Court decision in Employment Division v. Smith, which had held that the Constitution does not require states to recognize religious exemptions to laws of general applicability. In the Boerne case, the Supreme Court decided that RFRA overstepped Congress's authority, because the statute was not sufficiently connected to the goal of remedying a constitutional violation, but instead created new rights that are not guaranteed by the Constitution. Some observers have suggested that the Supreme Court saw RFRA as a threat to the Court's institutional power and an incursion on its role as final arbiter of the meaning of the Constitution, because that statute was aimed specifically at overturning the Employment Division v. Smith decision. However, the effect of Boerne lasted beyond Boerne itself. The standard announced in that case—that all legislation enacted under section 5 of the Fourteenth Amendment must be "congruent and proportional" to the unconstitutional harm it seeks to remedy—has been followed by every post-Boerne decision on legislation that sought to abrogate the states' sovereign immunity.
United States v. Morrison, decided in 2000, is one controversial successor case. In that case, the Supreme Court, applying the congruent-and-proportional Boerne test, overturned provisions of the Violence Against Women Act (VAWA), which criminalized gender-based violence. The Court held that Congress did not have power to forbid discrimination against women in the absence of a connection to state action or interstate commerce. But see Tennessee v. Lane and Nevada Department of Human Resources v. Hibbs.
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Four unities
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The four unities is a concept in the common law of real property describing conditions that must exist in order for certain kinds of property interests to be created. Specifically, these four unities must be met in order for two or more people to own property as joint tenants with right of survivorship, or for a married couple to own property as tenants by the entirety. Some jurisdictions may require additional unities.
Contents
[hide]
1 The four unities
2 A fifth unity
3 A sixth unity
4 References
The four unities[edit]
Unity of time
Interest must be acquired by both tenants at the same time.
In common law, the "time" requirement could be satisfied only by using a "straw man" to create a joint tenancy. The party creating the joint tenancy would have to convey title to a straw man, who would then transfer title to the two parties as joint tenants.
Unity of title
The interests held by the co-owners must arise out of the same instrument.[1]
Unity of interest
Both tenants must have the same interest in the property.
This means that the joint tenants must have the same type of interest, and the interest must run for the same duration. For example, if X and Y create a joint tenancy, both X and Y's interests must be in fee simple absolute. If, for example, X has a fee simple absolute and Y has a life estate, there is no unity of interest.
Unity of possession
Both tenants must have the right to possess the whole property.
If any of the four unities is broken and it is not a joint tenancy, the ownership reverts to a tenancy in common.
The unique aspect of a joint tenancy is that as the joint tenancy owners die, their shares accrue to the surviving owner(s) so that, eventually, the entire share is held by one person.
A fifth unity[edit]
Unity of marriage
In order for there to be a tenancy by the entirety this fifth unity must be present. Marriage combined with the preceding four unities creates a tenancy by the entirety. A tenancy by the entirety gives rise to certain legal rights, such as rights of survivors, when one spouse is deceased that interest automatically passes to the surviving spouse.
A sixth unity[edit]
Unity of unison
In order for the parties to be united, they must be in unison. This has been criticised by the Law Commission in their 283rd report, entitled 'Unity in Leaseholds'.
References[edit]
Jump up ^ Re Murdoch and Barry (1976), 10 O.R. (2d) 626 (H.C.J.).

This legal term article is a stub. You can help Wikipedia by expanding it.
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5.1 surround sound
From Wikipedia, the free encyclopedia
Jump to: navigation, search
Most common speaker configuration for 5.1; used by Dolby Digital, SDDS, DTS, THX, and Pro Logic II. Each black square depicts a speaker. The centre speaker in the top line of the square is used for dialogue. The left and right speakers on either side of the centre speaker are used to create stereo sound for music and other sound effects in the film. The left and right rear speakers create the surround sound effect.
5.1 surround sound ("five point one") is the common name for six channel surround sound audio systems. 5.1 is the most commonly used layout in home cinema.[citation needed] It uses five full bandwidth channels and one low-frequency effects channel (the "point one").[1] Dolby Digital, Dolby Pro Logic II, DTS, SDDS, and THX are all common 5.1 systems. 5.1 is also the standard surround sound audio component of digital broadcast and music.[2]
All 5.1 systems use the same speaker channels and configuration, having a front left and right, a center channel, two surround channels and the low-frequency effects channel designed for a subwoofer.
Contents
[hide]
1 History
2 Application
2.1 Channel order
2.2 Music
3 See also
4 References
History[edit]
A prototype for five-channel surround sound, then dubbed "quintaphonic sound", was used in the 1975 film Tommy.[3]
5.1 dates back to 1976[citation needed] when Dolby Labs modified the track usage of the six analogue magnetic soundtracks on Todd-AO 70 mm film prints. The Dolby application of optical matrix encoding in 1976 (released on the film, Logan's Run) did not use split surrounds, and thus was not 5.1. Dolby's first use of split surrounds was with 70mm film, which received wide release in 1979 with Apocalypse Now. Instead of the five screen channels and one surround channel of the Todd-AO format, Dolby Stereo 70 mm Six Track provided three screen channels, two high-passed surround channels and a low-frequency surround channel monophonically blended with the two surround channels.
When digital sound was applied to 35 mm release prints, starting with Batman Returns in 1992, the 5.1 layout was adopted. The ability to provide 5.1 sound had been one of the key reasons for using 70 mm for prestige screenings. The provision of 5.1 digital sound on 35 mm significantly reduced the use of the very expensive 70 mm format. Digital sound and the 5.1 format were introduced in 1990, by KODAK and Optical Radiation Corporation, with releases of "Days of Thunder" and "The Doors" using the CDS (Cinema Digital Sound) format.
5.1 digital surround, in the forms of Dolby Digital AC3 and DTS, started appearing on several mid 90s Laserdisc releases, with among the earliest being Clear and Present Danger and Jurassic Park (the latter having both AC3 and DTS versions). Many DVD releases have Dolby Digital tracks up to 5.1 channels, due to the implementation of Dolby Digital in the development of the DVD format. In addition, some DVDs have DTS tracks with most being 5.1 channel mixes (a few releases, however, have 6.1 "matrixed" tracks). Blu-ray and digital cinema both have eight-channel capability which can be used to provide either 5.1 or 7.1 surround sound. 7.1 is an extension of 5.1 that uses four surround zones: two at the sides and two at the back.
A system of digital 5.1 surround sound has also been used in 1987 at the Parisian cabaret the Moulin Rouge, created by French engineer Dominique Bertrand. To achieve such a system in 1985 a dedicated mixing console had to be designed in cooperation with Solid State Logic, based on their 5000 series, and dedicated speakers in cooperation with APG.[4] The console included ABCDEF channels. Respectively: A left, B right, C centre, D left rear, E right rear, F bass. The same engineer had already developed a similar 3.1 system in 1973, for use at the official International Summit of Francophone States in Dakar.
Application[edit]
Channel order[edit]
The order of channels in a 5.1 file is different across file formats. The order in WAV files is (not complete) Front Left, Front Right, Center, Low-frequency effects, Surround Left, Surround Right.[5]
Music[edit]
Suggested configuration for 5.1 music listening.
Regarding music, the main goal of 5.1 surround sound is a proper localization and equability of all acoustic sources for a centered positioned audience. Therefore, ideally five matched speakers should be used.
For play-back of 5.1 music recommendations of the International Telecommunication Union (ITU) have been released and propose the following configuration (ITU-R BS 775):[6]
five speakers of the same size for front, center and surround
identical distance from the listeners for all five speakers
angle adjustment regarding viewing direction of audience: center 0°, front ±22.5° for movies ±30° for music, surround ±110°
See also[edit]
7.1 surround sound
Ambisonics
Timeline of audio formats
References[edit]
Jump up ^ "Understanding Surround Sound Formats". Crutchfield.com. 2009-09-23. Retrieved 2011-03-07.
Jump up ^ "What is 5.1". Archived from the original on 2012-03-17.
Jump up ^ Mosely, John (Jan 1977). "Quintaphonic Sound". Journal of the SMPTE. l86.
Jump up ^ "Recherche & Développement". Archived from the original on August 3, 2008. Retrieved 2015-12-17.
Jump up ^ "Multiple channel audio data and WAVE files". Retrieved 2015-11-19.
Jump up ^ Thomas Lund (2000-09-01), Enhanced Localization in 5.1 Production, Audio Engineering Society, retrieved 2015-11-19, (Subscription required (help))
Retrieved from "https://en.wikipedia.org/w/index.php?title=5.1_surround_sound&oldid=832054995"
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Indian general election, 1967
From Wikipedia, the free encyclopedia
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Indian general election, 1967
← 1962 17–21 February 1967 1971 →
All 520 seats in the Lok Sabha
261 seats were needed for a majority
First party
Second party
Leader
Indira Gandhi C. Rajagopalachari
Party
INC Swatantra Party
Leader's seat
Rae Bareli None
Seats won
283 44
Seat change
78 26
Percentage
40.78% 8.67%
Swing
3.94% 0.78%
Prime Minister before election
Indira Gandhi
INC
Subsequent Prime Minister
Indira Gandhi
INC
The Indian general election of 1967 elected the 4th Lok Sabha of India and was held from 17 to 21 February. The 27 Indian states and union territories were represented by 520 single-member constituencies (an increase of 26).[1]
Under the leadership of Indira Gandhi, the Indian National Congress won a fourth consecutive term in power and over 54% of the seats, while no other party won more than 10% of the votes or seats. However, the INC's victory was significantly lower than the results they had achieved in the previous three elections under Jawaharlal Nehru. By 1967, economic growth in India had slowed – the 1961–1966 Five-Year Plan gave a target of 5.6% annual growth, but the actual growth rate was 2.4%. Under Lal Bahadur Shastri, the government's popularity was boosted after India prevailed in the 1965 War with Pakistan, but this war (along with the previous 1962 War with China) had helped put a strain on the economy. Internal divisions were emerging in the Indian National Congress and its two popular leaders Nehru and Shastri had both died. Indira Gandhi had succeeded Shastri as leader, but a rift had emerged between her and Deputy Prime Minister Morarji Desai, who had been her rival in the 1966 party leadership contest.[2]
The INC suffered significant losses in 7 states which included: Gujarat where INC won 11 out of 24 seats while Swatantra Party won 12 seats. Madras where INC won 3 out of 39 seats and DMK won 25 seats. Orissa where INC won 6 out of 20 seats and Swatantra Party won 8 seats. Rajasthan where INC won 10 out of 20 seats Swatantra Party won 8 seats. West Bengal where INC won 14 out of 40. Kerala where INC won only 1 out of 19. Delhi where INC won 1 out of 7 while remaining 6 were won by Bharatiya Jana Sangh.[1] The decline in support for Congress was also reflected by the fact it lost control of six state governments in the same year. The party's electoral losses led to Gandhi becoming assertive and opting for a series of choices that put her against the rest of the party establishment, eventually leading to a split in the party.
Results[edit]
Results by Party[edit]
Lok Sabha elections 1967
Electoral participation: 61.04%
Code
%
Won
(total 520)
Bharatiya Jana Sangh BJS 9.31 35
Communist Party of India CPI 5.11 23
Communist Party of India (Marxist) CPI(M) 4.28 19
Indian National Congress INC 40.78 283
Praja Socialist Party PSP 3.06 13
Samyukta Socialist Party SSP 4.92 23
Swatantra Party SP 8.67 44
Akali Dal – Master Tara Singh ADM 0.13 0
Akali Dal – Sant Fateh Singh ADS 0.66 3
All India Forward Bloc AIFB 0.43 2
Bangla Congress BC 0.83 5
Dravida Munnetra Kazhagam DMK 3.79 25
Democratic National Conference DNC 0.02 0
Indian Union Muslim League IUML 0.28 2
Kerala Congress KC 0.22 0
Naga Nationalist Organisation NNO 0.00 0
Peasants and Workers Party of India PWPI 0.71 2
Republican Party of India RPI 2.47 1
United Goans (Furtado Group) UG(F) 0.00 0
United Goans (Sequiera Group) UG(S) 0.07 1
Jana Kranti Dal JKD 0.13 1
Jammu & Kashmir National Conference NC 0.14 1
Independents - 13.78 35
Nominated Anglo-Indians - - 2
See also[edit]
Election Commission of India
Indian presidential election, 1967
References[edit]
^ Jump up to: a b "General Election of India 1967, 4th Lok Sabha" (PDF). Election Commission of India. p. 5. Archived from the original (PDF) on 18 July 2014. Retrieved 13 January 2010.
Jump up ^ "politics since independence". The Age. 2 June 1970. Retrieved 29 March 2014.
[hide]
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