"Rain is predictable, calming, stable, and non-threatening," says Dr. Shelby Harris, a behavioral sleep-medicine specialist. It's no secret that rain sounds offer troubled sleepers comfort. "It needs to be the right pitch, the right 'volume' of rain, and consistent, without sudden bursts of lightning and whatnot to ruin the vibe or give me a heart attack while I’m heading to dreamsville." His pitch-perfect soundtrack? Crain & Taylor's “Mountain Rain,” off of an album beloved by new parents: Help Your Baby Sleep Through the Night. "I have, quite literally, spent hours trying to find the perfect rain soundtrack," Rosenzweig tells me. While V Magazine's digital director Mathias Rosenzweig finds similar comfort in nature sounds, not just any rain soundscape will do. "Sometimes I’ll put on a crackling fireplace soundtrack, or a particularly beachy rainstorm track that makes me feel like maybe there isn’t a pandemic raging and I’m on a weekend getaway at a secluded cottage somewhere," she explains. Among her top tracks were "Heavy Thunderstorm Sounds" and "Soothing Rain Sounds in Glastonbury" by Stardust Vibes, a mother-son duo that produces nature sound recordings and relaxation music. In lockdown, when Johnson began experiencing more bouts of insomnia than usual, she started listening to water-centric nature sounds to help clear her mind and quell her longing for a getaway. "Anything pertaining to water sends me to a place of nostalgia and comfort," says Canadian writer Hannah Johnson, who grew up listening to her grandmother's whale sounds cassette tape and spending summers at the beach in Nova Scotia. Who didn't need extra help falling and staying asleep this year? Once several other people I followed revealed that rain sounds dominated their most-played tracks too, I suspected it was more than just a fluke. Earlier this month on her Instagram Stories, she shared that her top song of the year was Lluvia PQ's "Rain All Night," a three and half minute track of rain-soaked ambient sounds that has racked up nearly 25 million listens. It was art-pop musician Grimes who first made me aware of this possibility. Some takeaways, according to my observations? While you can always rely on the feel-good merits of an Ariana Grande bop or the addictive escapism of true crime podcasts, it seems that rain sounds may have been the sleeper hit of 2020 (pun very much intended). But in 2020, a year defined by unprecedented levels of stress and anxiety, it was all the more intriguing to get a peek into the audio offerings that helped get people through it all. Spotify's year-end Wrapped lists are always something to behold a unique and deeply fascinating form of social anthropology.
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“If he doesn’t win it, I’m still gonna give him a hug and tell him he’s the MVP in my eyes.” Only a few guys in NBA history have done that,” Malone said. “If he wins, it, we will be celebrating and very happy for him because it’d be a huge accomplishment - three years in a row. Malone said that's because Jokic isn't motivated by winning more MVPs but by leading the Nuggets to their first NBA title. Jokic shined a night before he learns if he's edged Joel Embiid and Giannis Antetokounmpo for his third consecutive NBA MVP award, recently renamed for Michael Jordan. And that fourth quarter, man, 14 points for that team, 28% from the field, 0-for-9 from 3?”ĭevin Booker led Phoenix with 35 points and Kevin Durant added 24 but they combined to miss a whopping 32 shots, including 14 from long range. I love a guy who's getting to the basket, imposing his will upon the other team. “Nikola's an MVP for a reason,” Malone said. “I love an aggressive Nikola Jokic,” Nuggets coach Michael Malone said after Jokic knocked down 17 shots to offset an off-night by Jamal Murray and Michael Porter Jr., who combined to make miss 17 of 22 shots. All rights reserved.Nikola Jokic's 39 points leads Nuggets past Suns 97-87ĭENVER - Nikola Jokic scored 39 points and pulled down 16 rebounds on the eve of the NBA MVP announcement to rally the Denver Nuggets to a 97-87 win over Phoenix on Monday night, giving them a 2-0 lead over the Suns in the Western Conference semifinals. Terms of Use and Privacy Policy and Safety Information / Your California Privacy Rights are applicable to you. ^ Back to Top ^ © 2023 ESPN Internet Ventures. Nuggets: Host Golden State on Sunday night. Suns: Hosted a 64th straight sellout crowd. Nuggets: Ish Smith shot just 1 of 10 from the field. “She's playing phenomenal basketball, her team is rallying around her, so it's going to be a good championship game.” “Incredible run that she's on,” Durant said. Instead, Durant and Paul were discussing how good Caitlin Clark's been for Iowa in the women's NCAA Tournament.Ĭlark scored 41 points on Friday night to lead the Hawkeyes over top-ranked South Carolina 77-73. Part of the Suns' postgame chatter in the locker room had nothing to do with beating the Nuggets. “We're trying to find that rhythm and trying to get wins at the same time,” Booker said. The Suns scored just 16 points in the fourth quarter on Friday, but managed to hang on for the victory. 4 spot in the Western Conference playoff race. The 34-year-old star has battled knee and ankle injuries over the past few months, but appears to be getting healthy as the Suns continue to cling to the No. We always want to play hard, get stops.”ĭurant shot 11 of 15 from the field in a dominant performance two days after a rough shooting night in his home debut against Minnesota. “We know we were missing guys but that doesn’t change the culture here. “It was our energy and our effort,” backup guard Peyton Watson said. The overmatched but feisty Nuggets got 22 points from the bench. Bruce Brown scored 16 points and Reggie Jackson had 13. Okogie had 14 points on 5-of-8 shooting, including four 3-pointers, and Chris Paul had 13 assists.Īaron Gordon had 26 points, nine rebounds and six assists to lead the Nuggets. Denver cut it to 97-93 in the final minute, but Josh Okogie nailed a corner 3 to seal it for the Suns. The Suns pushed their advantage to 27 midway through the third quarter, but the Nuggets pulled to 84-74 heading into the fourth quarter. Every reason just to roll over and play dead and get ready for Sunday at home. “You are down 27 points on the road, second half, second night in a row. “I am immensely proud,” Nuggets coach Michael Malone said. But they still showed fight after trailing 60-40 at halftime. The Nuggets rested a big chunk of their starting lineup, including reigning MVP Nikola Jokic, guards Jamal Murray and Kentavious Caldwell-Pope and forward Michael Porter Jr. We've just got to do a better job of sticking with it.” “We just let our foot off the gas a little and they were playing extremely hard. “I like how we played in the first half, but it was a bad second half for us," Durant said. Phoenix traded for the 13-time All-Star in a deadline deal back in February. The Suns improved to 5-0 with Durant in the lineup despite nearly blowing a 27-point lead. PHOENIX - The Phoenix Suns are starting to string together some wins now that Kevin Durant is healthy.Įven so, they're far from a well-oiled machine.ĭurant scored 30 points, Devin Booker added 27 and the Suns won their fourth straight game by beating the short-handed Denver Nuggets 100-93 on Friday night. Durant has 30 points, Suns beat Nuggets for 4th straight win Double-click it to load an instance onto the channel.Click the plugin browser icon at the top. Once scanning finishes, close the plugin manager window. It will find the Serum plugin we just installed. This scans all plugin locations for new content. Click the scanner icon at the bottom left. Step 4: Launch FL Studio and Scan Plugins Click “Install” and Serum will be placed in the FL Studio plugins folder.Įasy as that.C:/Program Files/Image-Line/FL Studio/Plugins. On the next screen, choose the FL Studio VST plugin location we found earlier.Click “I Agree” to the license agreement. Double-click on the Serum installer file you downloaded earlier.We will install the Serum download here soon. This is normally:Ĭ:/Program Files/Image-Line/FL Studio/Plugins Now we need to find where FL Studio loads VST plugins from. This ensures the plugin gets scanned and registered properly on launch. I recommend installing Serum before opening FL Studio. Once you complete the transaction, Xfer will email you a download link. You can buy it on their website for $189. The first step is to purchase Serum from Xfer Records. Here are the steps To Install Serum VST: Step 1: Purchase and Download Serum This will be the first step to get Serum VST into FL Studio. If you’ve got an internet connection, all you’ll need to do is head over to the Xfer Serum website and download the installation file. How To Install Serum Plugin In FL Studio? Wrapping Up – Install Serum VST in FL Studio.
The countdown to Expo 2020 Dubai has started and with hours to go The National will help you plan your visit. See all the winners from Capstone Expo below and visit for more projects.Read the latest updates on Expo 2020 Dubai Woodruff School of Mechanical Engineering, it was a protective case for powered wheelchairs that makes them easier to load into airplane cargo holds. Milton Stewart School of Industrial and Systems Engineering. Improving Coca-Cola’s chilled warehouse network received top honors among projects from the H. The idea is to help growers monitor conditions and adjust them as needed. The winning team in the School of Electrical and Computer Engineering created Farm Box, an enclosure with a controlled environment and sensors for temperature, soil moisture, humidity, light intensity, and carbon dioxide. The team’s 30-day mission would include astronauts orbiting above the second planet from the sun. In the Daniel Guggenheim School of Aerospace Engineering, judges awarded the top prize to a proposal that would send a series of low-cost balloons to collect data about Venus’ atmosphere and surface. The winning interdisciplinary team, RoboClose, developed a device to help doctors close arteries after surgery. We talked to a lot of these rural EMTs, and they told us the hospital in their area may have one device - or none.”Īnother top team at the Expo also tackled issues in healthcare settings. “We’re targeting rural emergency medical systems that don’t have access to blood warmers and systems that don’t have access to high-speed blood transfusion. I want to create something that can also be an altruistic endeavor,” team member Kevin Swamy said. “I don’t want to just create something that’s purely commercial. The design also is significantly cheaper. This creates more surface area for warming and results in quicker blood flow than existing devices - about two minutes faster for a full pint of blood. The team’s design uses plastic tubing in a serpentine design nestled in a clamshell case with aluminum plates engraved in the same serpentine pattern. “We worked on a solution that fits in a pocket and is 60% lighter.” They’re too bulky and too pricey,” said Marianne Al Haj, one of the four biomedical engineering students on the team. Currently, the portable blood warmers in the market are too slow. If you want to administer it to someone who’s losing a lot of blood, then you need to warm it to 37 degrees. “Blood is stored at 4 to 10 degrees Celsius. They’re focused on providing a reliable solution in trauma and emergency situations, such as for emergency medical technicians in rural areas or aboard medical helicopters. Sponsored by Emory University doctors, they created a portable, efficient blood warmer to quickly bring blood to the proper temperature before it’s infused into a patient. The other top team, HemoHeaters, also is working on patenting their technology. The team is working with their sponsor, Swella Braid Bar in Atlanta, to patent their design. They worked with salon owners and customers to create their design and make it feasible for salon use, including removable parts that can be sanitized. The team of mechanical and computer engineers and industrial design students forecast the tool could reduce unbraiding time by 25%. “All of the feedback we’ve gotten from people today is that they appreciate how much we’ve thought about safety and making a usable, polished device.” It prevents tugging at the scalp and unravels the full length of the braid,” said team member Rishab Verma, a mechanical engineering student. There’s a tine that moves along the full length of the braid, and it does all of the safety checks that the stylist does. “Our machine emulates the exact motion that stylists use in the unraveling process. The repetitive motions can stress stylists’ hands and wrists, potentially leading to carpal tunnel syndrome. One of the top overall projects, the Unravl Device, is designed to help people who sometimes spend hours having their hair unbraided. The teams designed rovers to hunt for water on the moon, revamped recycling processes for Georgia Tech Dining, and simplified placing stakes for specialty crop farmers. They were among 129 devices and ideas on display at McCamish Pavilion that included everything from a portable sterilizer for surgical instruments to a redesigned logistics system for UPS Healthcare. That’s right: Two teams tied for the best overall project award this semester at the showcase of senior projects by engineering, industrial design, and computer science students. A new tool to help hair stylists quickly unravel braids and a device to rapidly warm blood before it’s transfused into patients shared top honors at the Fall 2023 Capstone Design Expo. You can also rotate the device to use the scientific calculator for advanced problems.īrightness: adjust brightness by dragging the brightness control up or down.ĭriving Focus: silence calls, messages, and notifications while driving.ĭo Not Disturb: silence notifications for an hour, until the end of the day, for an event, or while at a location.įlashlight: turns the LED flash on the camera into a flashlight. You may see a person icon for Personal, a bed for Sleep, a car for Driving, etc.Īccessibility: quickly enable accessibility features.Īlarm: create an alarm to wake up or adjust your Sleep Focus settings.Ĭalculator: quickly do calculations. Note: The appearance of this icon will differ depending on which Focus mode you have enabled. Here are some charts of the controls in your iPad or iPhone Control Center. Let's cover some more iPhone icons meaning. What Are the Symbols in the iPad & iPhone Control Center? You can add or take away Low Power Mode, the Flashlight, the Calculator, Voice Memos, and more. Some of the iPhone Control Center icons will always stay the same, but the icons at the bottom of the Control Center are determined by how you choose to customize your Control Center. You're sharing your screen with SharePlay.Īccess the Control Center by swiping up from the bottom of your screen if you have an iPhone 8 or earlier, or down from the upper right corner of your screen if you have an iPhone without a Home button, like the iPhone 14. Note: For iOS 15 and later, the symbol is replaced with the green bubble behind the time. IPhone is connected to the internet through the Personal Hotspot of another iOS device. It will turn red when the level is less than 20%.īattery level of your paired Bluetooth device. IPhone is paired with a wireless headset, headphones, or earbuds. You may see a person icon for Personal, a bed for Sleep, a car for Driving, etc. Orientation Lock is on, and your screen won't rotate until the setting is disabled. Location Services is currently being used by an app or a website.Īn item may receive your location under certain conditions.Īn app you're using is requesting your location. The VPN network you're using is disconnected. Your iPhone is connected to the internet over Wi-Fi. Your carrier also appears next to the icon. Wi-Fi Calling is available for you to use. With Dual SIM capability, you're in range of your cellular network and can make and receive calls."No service" will appear whenever there's no signal. "No service" will appear whenever there's no signal. You're in range of your cellular network and can make in receive calls. GPRS (GSM) network is available through your carrier, and your iPhone can connect to the internet over that network.ĮDGE (GSM) network is available through your carrier, and your iPhone can connect to the internet over that network. Not available in all areas.ĥG network with higher frequency is available through your carrier, and your iPhone can connect to the internet over that network. Note: Works with iPhone 8 and later models. Not available in all areas.ĥG E network is available through your carrier, and your iPhone can connect to the internet over that network. Note: Works with iPhone SE (3rd generation), and iPhone 12 and newer models. Not available in all areas.ĥG network is available through your carrier, and your iPhone can connect to the internet over that network. Note: Works with iPhone 5 and later models. LTE network is available through your carrier, and your iPhone can connect to the internet over that network. 3G network is available through your carrier, and your iPhone can connect to the internet over that network.ĤG or LTE network is available through your carrier, and your iPhone can connect to the internet over that network. There are plenty of options including free icons and paid icons. Now you’ll be able to search through different illustrations to choose icons for your Instagram Story highlight covers. Now you’ll have the perfect sizing for your Instagram Story highlight cover.Ĭhoose “ELEMENTS” from the sidebar and then click “GRAPHICS”. Open your Canva account and type “Instagram Story” into the search bar and scroll to the bottom.Ĭlick on the template for “Instagram Story” when it appears. We personally like Canva, which you can actually access from within your Plann account! Step 1: In order to make custom Instagram Highlights covers, you’ll need access to any free graphic design platform. How to make custom Instagram highlights covers Skip over that for now and just tap “Add.”Ĭongratulations! You’ve made your first Instagram Highlights. Normally here you would pick out your custom Instagram Highlights cover. PSST–> WANT TO KNOW THE BEST TIMES TO POST ON INSTAGRAM? WE’VE GOT YOUR BACK Step 6: You’ll be taken to your Instagram Archive, where you can see all of your past stories.Ĭhoose which Stories you want in this Highlight by tapping the circle in the bottom-right corner. Tap the “+” button to make a new Instagram Story Highlight. Tap the button in the bottom-right to go to your profile. How to Make a New Instagram Highlightįirst, let’s walk through how you can start to create a new Instagram highlight. If you’re a visual learner, you can check out the video above! Otherwise, keep reading for our step-by-step guide. Your step-by-step guide to creating custom Instagram highlight covers Over 2M brands already use our all-in-one creation, scheduling and publishing tool for posts AND stories! LEARN MORE In this article, we’re going to walk you through step by step how to create custom Instagram highlights covers for your feed - plus, some examples of beautiful Instagram highlight covers to inspire your creations. You can also customize your Instagram highlight covers with colors, patterns and graphic to add to the overall aesthetic of your account. Many brands and influencers used Instagram highlight covers (the graphics that sit along your highlights bar) to showcase the different themes their account covers For example: a mommy blogger might have ‘motherhood,’ ‘home’ and ‘style’ as some of her highlight cover icons, Not only can Instagram highlights extend the ‘life’ of your stories content and get more eyeballs on your work, but they’re also a great way to show what your account is all about. Who says your Instagram stories can’t live on your profile forever? Thanks to Instagram highlights, they can be eternalized on your feed for your audience to enjoy over and over again. Instagram highlight cover #1: Instagram highlight cover #2: Instagram highlight cover Instagram highlight cover #4: Instagram higlight cover #5: Instagram highlight cover #6: Instagram highlight cover #7: Instagram highlight cover #8: Instagram highlight cover #9: Instagram highlight cover #10: Ready to grow your business or brand on social media?.10 examples of beautiful Instagram highlight covers.Want a shortcut for creating Instagram highlight covers?.How to make custom Instagram highlights covers.Your step-by-step guide to creating custom Instagram highlight covers. The zebu offered traits that would allow cattle to survive in hot, dry climates, while the taurine provided cattle with the ability to endure humid climates where vector-borne diseases like trypanosomiasis are common. The genome sequencing work conducted by the scientists revealed that indigenous pastoralist herders in the Horn of Africa began breeding the Asian zebu cattle with local taurine breeds about a thousand years ago. The taurine were introduced through North Africa some 8,000 years ago but remained largely confined to isolated belts of land in West and East Africa. These cattle were domesticated independently during the Neolithic era: once in south Asia, leading to the zebu or humped cattle, and the other in the Middle East, leading to taurine cattle. Today’s announcement helps explain how Africa’s cattle acquired such a range of advantages.Īll billion or so cattle today descend from ancient aurochs, an extinct species of large wild cattle that once inhabited large swaths of Eurasia. They also provide manure for crops and some African breeds can survive in conditions that can’t support food crops.īut to thrive in Africa’s diverse settings, cattle need an array of traits like heat and drought-tolerance, the capacity to control inflammation and tick infestations, and resistance to devastating livestock diseases like trypanosomiasis. They provide a critical source of protein and micronutrients alongside income to pay for things like school fees. For many rural households, cattle are among the family’s most valuable assets. Today, cattle play a central role in human livelihoods in Africa. They wanted to learn how-after spending thousands of years confined to a shifting patchwork of sub-regions in Africa-cattle rapidly evolved traits during the last millennia that allowed them to spread across the continent. The findings, published in the October issue of Nature Genetics, emerged from an effort to sequence the genomes of 172 indigenous cattle by scientists at the Nairobi and Ethiopia-based International Livestock Research Institute (ILRI) and Korea’s Seoul National University. The resulting crossbreed retained advantages from each subspecies, giving the admixture the ability to adapt to the continent’s diverse and challenging ecosystems. The event, dubbed an ‘evolutionary jolt’ by one of the scientists, brought together zebu (humped) and taurine (unhumped) cattle in the Horn of Africa some 750-1050 years ago. Centre for tropical livestock genetics and health.Poverty reduction, livelihoods and jobs.Gender, equality, youth and social inclusion. Loud_hissing Fandoms: The Owl House (Cartoon) The One Time Hooty Betrayed Duolingo (and the One Time He Didn’t) Language: English Words: 857 Chapters: 1/1 Comments: 3 Kudos: 23 Bookmarks: 1 Hits: 490 I wrote this because I haven't wrote on Ao3 for a long time also because I love The Owl House and wanted to write a fluffy fic with lots of humor(attempted) Series While Gus Porter and Matt Tholomule are in the human realm, they discover YouTube by an accident and they decide to start a YouTube channel, cause why not? Creator Chose Not To Use Archive Warnings.Choose Not To Use Archive Warnings, Major Character Death.Xemcharms Fandoms: The Owl House (Cartoon) Language: English Words: 645 Chapters: 8/? Comments: 7 Kudos: 39 Bookmarks: 3 Hits: 440 Njdgvdhowlvdhbvibnwivgiunbdufvuegbuvdubvuvbdsuvbuew idk how to summery Series yoooooooo minecraft but wait shit im a truck.Lil Nas X/Satan (MONTERO (Call Me By Your Name)).Graphic Depictions Of Violence, Major Character Death.Language: English Words: 9,118 Chapters: 4/? Collections: 1 Comments: 16 Kudos: 78 Bookmarks: 3 Hits: 3,378 This fic is technically on hiatus, and will be updated with sillier, unfinished, or low effort pieces. Some chapters written before I finished the series. What more could you ask for?ĭONT WORRY about the hooty/duolingo tags! I just wanted to jumpscare y'all lol It's just a collection of ships and kinks. I heard you like magic, I've got a wand and a rabbit! So baby, let's get freaky, get kinky, let's make this bed get squeaky! (I originally published this on Wattpad back during the times of S2 E11, so Odalia's behavior isn't fully canon) Language: English Words: 3,422 Chapters: 5/? Comments: 2 Kudos: 6 Bookmarks: 1 Hits: 349 Belos has been defeated already, and Hunter was adopted by Eda. Ed and Hunter are 20/21, and Luz and Amity are 18/19. Odalia is trying to set Edric up with a suitor, but Ed doesn't want that, so he asks Hunter to pretend to be his boyfriend for one night, but things get out of hand.ĪU taking place 4 years after the series. Trans Hunter | The Golden Guard (The Owl House).Hunter | The Golden Guard (The Owl House).Hunter | The Golden Guard & Willow Park & Gus Porter.Amity Blight & Edric Blight & Emira Blight.SlytheringGaySnake Fandoms: The Owl House (Cartoon) Language: English Words: 8,265 Chapters: 8/8 Comments: 15 Kudos: 31 Bookmarks: 3 Hits: 2,521 I am not personally responsible for any copyright issues. Any resemblance to real life figures, is PURELY coincidental. Here, in this tasteful work of mine, I will be releasing my masterpieces revolving around different characters and personas I fancy. April Showers: An Omorashi/Piss Week 2021.Toothless (How to Train Your Dragon)/Original Female Character(s).Hiccup Horrendous Haddock III/Toothless.Father Garcia & John Ward (FAITH Video Game).Duolingo Owl (Anthropomorphic)/Hooty (The Owl House). Mishka_111 Fandoms: Politics - Fandom, trump - Fandom, Shrek (Movies), Duolingo, FAITH (Airdorf Video Game), Rick and Morty, How to Train Your Dragon (Movies), Fairly OddParents Mental Health Issues: Depression, bipolar disorder, post-traumatic stress disorder (PTSD), and other mental health disorders can affect sleep patterns and quality.Medical Conditions: Certain medical conditions, such as chronic pain, sleep apnea, restless leg syndrome, or hormonal imbalances, can disrupt your sleep.Environmental Factors: Uncomfortable sleeping environment, excessive noise, extreme temperatures, or inadequate lighting can interfere with your ability to fall asleep or stay asleep.Poor Sleep Habits: Irregular sleep patterns, inconsistent bedtime routines, excessive caffeine or alcohol consumption, and engaging in stimulating activities before bed can disrupt your sleep.Racing thoughts, worry, or an overactive mind can keep you awake at night. Stress and Anxiety: High levels of stress or anxiety can make it difficult to relax and fall asleep.Here are a few common factors that can contribute to sleep difficulties: There can be various reasons why you may be experiencing trouble sleeping. If you're dealing with stress and anxiety, it's recommended to seek support from a mental health professional who can provide personalized guidance. It's important to note that not everyone experiences stress and anxiety in the same way. Uncertainty and change: Experiencing frequent change (even positive change!) or feeling uncertain about the future can be a common cause of anxiety.Traumatic experiences: Experiencing a traumatic event, such as an accident, abuse or even a natural disaster can lead to anxiety-related conditions.Health concerns: Managing chronic illness, physical pain or battling a health condition can be a cause, as well.Relationships: Whether romantic, familial or social, strain or conflict in relationships can cause stress and anxiety.Financial challenges: Job loss, debt, or just struggling to make ends meet can be a significant source of stress and anxiety.Work or school pressure: High workloads, tight deadlines, challenging bosses, or work pressure can lead to stress and anxiety.Major life changes: Significant life events such as moving, getting married (or divorced), starting a new job or experiencing the loss of a loved one can trigger it.Here are a few common factors that contribute to stress and anxiety: Stress and anxiety can have various causes and can differ greatly from person to person. Surely, African Americans are a suspect class and the victims of discrimination throughout the history of the United States. Pure racism is not a compelling government purpose, and even if the government would try and suggest a non-racially motivated purpose, it is likely that that such a blanket action is not narrowly tailored to anything compelling.But in other contexts, it can be more difficult to determine if a government classification is constitutional. Today, if a local government singled out African Americans and forbid them from serving as firemen, this would be almost certainly be considered unconstitutional. If the answer to either of these two questions is no, then the classification is an unconstitutional violation of the Equal Protection Clause.Some government actions easily fit this mold. In this instance, the Court will ask if the government’s purpose for the classification of the suspect class is compelling and whether the action taken is narrowly tailored to that purpose. This low-level standard of review is known as “Rational Basis Review,” and is further explained below.If, however, the government classification does single out a suspect class, the Court will probably give the action what is known as “Strict Scrutiny,” or the Court’s least deferential standard of review. The Court may still examine the government action, but it will do so while being as deferential to the legislature as possible. If no such group is being singled out, then the Court will likely not consider there to have been a violation of the Equal Protection Clause. (1938), a suspect class of people is one that is a “discrete and insular minorit.” These are generally groups that have been historically discriminated against. The group being singled out must be what is known as a “suspect class.” As best defined by a famous footnote in United States v. Second, there needs to be some classification, some action taken by the government to single out one group from another.However, a government classification does not necessarily mean than a violation of the Equal Protection Clause has occurred. A federal, state, or local government may not be able to discriminate, but your neighbor is under no such restraint. First, it must be determined if there has been government action in this instance. While slavery is specifically dealt with in the 13th Amendment, inequality is dealt with here.Though race and racial discrimination are still at the heart of the Equal Protection Clause, any unjust government classification – the singling out of one group or another – can be a violation of the Constitution.A modern analysis of an Equal Protection claim requires several steps within a larger framework. After all, this amendment was passed in the wake of the Civil War in attempts to remedy some of injustices that led up to that war, like racial inequality and slavery. It can perhaps be said that the Equal Protection Clause is at the core of the 14th Amendment. |
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