The First American Political Conventions

The First American Political Conventions The history of political conventions in America is so long and steeped in lore that its easy to overlook that it took a few decades for nominating conventions to become part of presidential politics. In the early years of the United States, presidential candidates were usually nominated by a caucus of members of Congress. By the 1820s, that idea was falling out of favor, helped along by the rise of Andrew Jackson and his appeal to the common man. The election of 1824, which was denounced as The Corrupt Bargain, also energized Americans to find a better way to select candidates and presidents. After Jacksons election in 1828, party structures strengthened, and the idea of national political conventions began to make sense. At that time there had been party conventions held at the state level but no national conventions. First National Political Convention: the Anti-Masonic Party The first national political convention was held by a long-forgotten and extinct political party, the Anti-Masonic Party. The party, as the name indicates, was opposed to the Masonic Order and its rumored influence in American politics. The Anti-Masonic Party, which began in upstate New York but gained adherents around the country, convened in Philadelphia in 1830 and agreed to have a nominating convention the following year. The various state organizations chose delegates to send to the national convention, which set a precedent for all later political conventions. The Anti-Masonic Convention was held in Baltimore, Maryland on September 26, 1831, and was attended by 96 delegates from ten states. The party nominated William Wirt of Maryland as its candidate for president. He was a peculiar choice, especially as Wirt had once been a Mason. The National Republican Party Held a Convention in December 1831 A political faction calling itself the National Republican Party had supported John Quincy Adams in his unsuccessful bid for reelection in 1828. When Andrew Jackson became president, the National Republicans became a devoted anti-Jackson party. Planning to take the White House from Jackson in 1832, the National Republicans called for its own national convention. As the party was essentially run by Henry Clay, it was a foregone conclusion that Clay would be its nominee. The National Republicans held their convention in Baltimore on December 12, 1831. Due to bad weather and poor traveling conditions, only 135 delegates were able to attend. As everyone knew the outcome ahead of time, the real purpose of the convention was to intensify anti-Jackson fervor. One noteworthy aspect of the first National Republican Convention was that James Barbour of Virginia delivered an address that was the first keynote speech at a political convention. The First Democratic National Convention Was Held in May 1832 Baltimore was also chosen to be the site of the first Democratic Convention, which began on May 21, 1832. A total of 334 delegates assembled from every state except Missouri, whose delegation never arrived in Baltimore. The Democratic Party at the time was headed by Andrew Jackson, and it was obvious that Jackson would be running for a second term. So there was no need to nominate a candidate. The ostensible purpose of the first Democratic National Convention was to nominate someone to run for vice president, as  John C. Calhoun, against the backdrop of the Nullification Crisis, would not be running again with Jackson.  Martin Van Buren of New York was nominated  and received the sufficient number of votes on the first ballot. The first Democratic National Convention instituted a number of rules which essentially created the framework for political conventions that endures to the present day. So, in that sense, the 1832 convention was the prototype for modern political conventions. The Democrats who had gathered in Baltimore also agreed to meet again every four years, which began the tradition of Democratic National Conventions that extends to the modern era. Baltimore Was the Site of Many Early Political Conventions The city of Baltimore was the location of all three political conventions prior to the 1832 election. The reason is fairly obvious: it was the major city closest to Washington, DC, so it was convenient for those serving in the government. And with the nation still mostly positioned along the east coast, Baltimore was centrally located and could be reached by road or even by boat. The Democrats in 1832 did not formally agree to hold all their future conventions in Baltimore, but it worked out that way for years. The Democratic National Conventions were held in Baltimore in 1836, 1840, 1844, 1848, and 1852. The convention was held in Cincinnati, Ohio in 1856, and the tradition developed of moving the convention to different locations. The Election of 1832 In the election of 1832, Andrew Jackson won easily, garnering about 54 percent of the popular vote and crushing his opponents in the electoral vote. The National Republican candidate, Henry Clay, took about 37 percent of the popular vote. And William Wirt, running on the Anti-Masonic ticket, won about 8 percent of the popular vote, and carried one state, Vermont, in the electoral college. The National Republican Party and Anti-Masonic Party joined the list of extinct political parties after the 1832 election. Members of both parties gravitated toward the Whig Party, which formed in the mid-1830s. Andrew Jackson was a popular figure in America and always stood a very good chance of winning his bid for reelection. So while the election of 1832 was never really in doubt, that election cycle made a major contribution to political history by instituting the concept of national political conventions.

ECON 4020-001 - Intermed Macroecon Essay Example | Topics and Well Written Essays - 500 words

ECON 4020-001 - Intermed Macroecon - Essay Example Davidson suggests that US increased the national debt during wars and recessionary periods because during those times only spender is government. The spending by the government therefore stimulates the necessary domestic demand which creates more jobs and increases the consumption. He provides evidence of how large deficits by the government during war and recessionary times actually were followed by periods of economic prosperity as well as job creation. Era after World War II was an era which was economically more prosperous than the times before war and one of the most important reasons for this was the government spending during war times by the US government and resulting large deficits. Davidson therefore suggests that actual task of fiscal policy is to act as a balancing wheel to generate sufficient aggregate demand which can stimulate entrepreneurs to create new jobs and deter from imposing or raising taxes to reduce the fiscal deficit and remove the role of government from the economy. Robert J Barrow’s article â€Å"Robin Hood Cant Lead Us Out of the Debt Hole: Obamas obsession with higher tax rates on the rich is not helpful† however focuses upon the argument of raising marginal taxes for rich in America to finance the fiscal deficit of the country. Barrow suggests that the current government in US may be missing the point that by increasing the government expenditure, multiplier effect can have a positive impact on the economy. He presents the recent historical analysis of the financial crisis and how the government actually allowed Lehman Brothers to fail to actually initiate a systematic failure of important institutions. Barrow therefore argues that rather than taxing the rich, the overall composition of the federal government needs to be changed. Government shall increase the maximum age limit for the entitlement of the social security as well as further rationalize the federal government

Modern pricing models Essay Example | Topics and Well Written Essays - 250 words - 1

Modern pricing models - Essay Example Some of the shortcomings experienced with the Black-Scholes model were strike-price bias and return skewness. Consequently, the development of the Heston model came in as the best alternative tool for the purposes of advanced investments (Gilli, Maringer & Schumann 2011, p.257). As any other stochastic volatility model, the Heston model utilizes statistical methods when making calculations or forecasts of the various pricing options in consideration. As such, it also bases on the assumption that the underlying security or trading option has an arbitrary volatility. Therefore, the Heston model falls among the various different models of stochastic volatility such as the GARCH model, the Chen model, as well as the SABR model. Consequently, the Heston Model also falls under the standard smile model category, with â€Å"smile† in this concept referring to the volatility smile. A volatility smile is a graphical representation of various options that have identical expiration date expressing an increasing volatility. This increase in volatility arises often arises when the options become more out of the money or in the money. The concave shape generated by the graph is what gives rise to the name, the smiles model, as it appears like a smile (Wang 2007, p. 3). The Heston Model applies mathematical calculations in describing the process of evolution in volatility that an underlying asset undergoes under the stochastic volatility options. As such, just as other statistical models mentioned above, the Heston Model equally has a number of assumptions, such as the volatility of an asset not being constant, or deterministic, but rather following a random process. Some the of the basic assumptions of the Heston Model is that the stochastic process determines the asset price, St In addition, forms part of the Wiener Process as experienced under the GBM (Geometric Brownian Motion) also considered

There could be a trouble ahead Article Example | Topics and Well Written Essays - 250 words

There could be a trouble ahead - Article Example From the article, it is clear that different economists have diverse opinion on the way to manage economic crisis. Whereas some argue that expansionary measures are the best to undertake, others view contraction measures feasible in correcting economic anomalies. Whichever the policy adopted, the end result should be recovery of the slow pace of growth (Chinn & Frieden, 2011). The article further compares the mitigation strategies pursued by different economies and the way they messed in the process. From the article, the author tries to justify his version that the lessons learnt in the 1930s depression helped in salvaging the 2008 economic depression. The author elucidates this by giving figures of the rate of unemployment, interest rates, currency rates, and contagion caused in the financial markets in both the depression and the recession (1936, 1938). From the analysis, it is evident that the expansionary policies that were employed in 2008 recession had better impacts than the contractionary policies in the 1930s recession (Krugman, 2009). In all instances, monetary policy was important in controlling the supply of money, exchange rates fluctuations and bringing smooth operations of the financial market. Fiscal policies were also crucial in stimulating growth hence increasing rate of employment and investment (2009). Debt management and control must also be checked in managing the depression. The fact that the author has extensively and concisely dissected the comparison makes me agree that the article is right. The facts have been well substantiated with figures and correct economic theories and knowledge. In my opinion, the periods of recession and depressions demands policies that stimulates growth and controls the level of debt while keeping the financial sector sound. In conclusion, Obama’s administration learned from the failure of the Roosevelt regime thus

Asher Lev :: essays research papers

Asher Lev This story is about a Jewish boy from Brooklyn, who’s talent is painting. He introduces himself as a young man struggling with inner conflict between his religious upbringing and his extraordinary God-given gift that cannot be controlled and seems to possess a spirit all it own. He can not explain why he feels he must paint, and does not like the fact that he hurts everyone he loves, and insults everything he believes in, but continues on his path which seems to have been chosen for him. All throughout the book we see the conflicts between Asher and his family, and grow a hatred towards his father, even though he is a good man and respected highly in the community. As a young boy Asher is told by his father who seems to think that his artistic ability is foolishness and that he needs to focus his attention on his school work. We tend to like his mother, Rivkeh, because, even though she says she doesn’t want Asher to paint, we know that deep down she knows art is where his heart is, and it is the only thing that makes him happy. We can relate with her as she stands by the window worrying and wondering when her loved ones will be home. Asher does not get very much encouragement from other people until he meets the world famous Jacob Kahn, who becomes his inspiration, his teacher, and his link to the great work of art. The two meet at the Rebbe’s office. This meeting was not accidental. It was set up by the Rebbe, who Asher was not very fond of because he is sending his father to Vienna. The Rebbe understands Asher better than his parents do. He knows that Asher has this talent, and wants him to per sew it. When Asher’s dad goes away to Vienna, his mom stays back in Brooklyn with him in hopes that he will studyhard. He studies enough to get by, but still brings to life everything he sees. Jacob Kohn teaches Asher how to become a great painter, cautioning him what he is getting into. As Asher becomes Asher Lev the painter, instead of the son of Reb Aryeh Lev, his father becomes curious and wants to go to one of his shows. Aryeh wants to see some of his work but refuses to go if there are nude paintings.

Tropical Hut

WORKING CAPITAL Working capital is a measure of liquidity of a business. It equals current assets minus current liabilities. It is a measure of both a company's efficiency and its short-term financial health. The Company’s working capital during 2011 and 2010 are -P61,608,166. 00 and -P48,921,660. 00 indicating that the Company’s current liabilities are more than its current assets. It tells that the company is expected to suffer from liquidity crunch in near future and that the business may not be able to pay off its current liabilities when due. Status: Weakness of the Company) LIQUIDITY RATIOS| | | | | | Notes| Status| 2011| 2010| Current Ratio| 1| Weakness| 0. 83:1| 0. 85:1| Quick Ratio| 1| Weakness| 0. 37:1| 0. 39:1| Liquidity ratios measure a firm’s ability to meet maturing short-term obligations. Current ratio measures the extent to which a firm can meet its short-term obligations. During 2010, the Company’s current ratio is 0. 85:1 which indicates that the Company’s current assets were not enough to pay its short-term obligations. During 2011, the Company’s current ratio decreases to 0. 3:1 which indicates that its ability to pay its short-term obligations became worse (see Note 1 for computation). Quick ratio measures the extent to which a firm can meet its short-term obligations without relying upon the sales of its inventories. During 2010, the Company’s quick (or acid-test) ratio is 0. 39:1 which shows that its current assets less its inventory is not enough to meet its short-term obligations. During 2011, the Company’s quick ratio decreases to 0. 37:1 which shows that its ability to meet its short-term obligations became worse (see Note 1 for computation).Therefore, Tropical Hut Food Market, Inc as of December 31, 2011 and 2010 is not liquid. LEVERAGE RATIOS| | | | | Notes| Status| Ave of 2011;2010| Debt-to-Total-Assets Ratio| 2| Strength| 0. 56| Debt-to-Equity Ratio| 2| Weakness| 1. 29| Long- Term Debt-to-Equity Ratio| 2| Strength| 0. 0007| Times-Interest-Earned Ratio| 2| Weakness| -19. 36| Leverage ratios measure the extent to which a firm has been financed by debt. Debt-to-Total-Assets Ratio is the percentage of total funds that are provided by creditors. The average Debt-to-Total-Assets Ratio during 2011 and 2010 is 56% (or 0. 6:1) which indicates that the Company is capable to meet outside obligations in full out of its own assets (see Note 2 for computation). Debt-to-Equity Ratio is the percentage of total funds provided by the creditors versus by owners. The average Debt-to-Equity Ratio during 2011 and 2010 is 129% (1. 29:1). This means that for every peso of the company owned by the shareholders, the company owed 1. 29 to creditors. This high debt-to-equity ratio indicates that the Company was not able to generate enough cash  to satisfy its  debt  obligations (see Note 2 for computation).Long-Term Debt-to-Equity Ratio is the balance between debt and equity in a firm’s long-term capital structure. It expresses the degree of protection provided by the owners for the long-term creditors. The average Long-Term Debt-to-Equity Ratio during 2011 and 2010 is . 07% (or 0. 0007:1) which indicates that the Company’s degree of leverage is low (see Note 2 for computation). Times-Interest-Earned Ratio is the extent to which earnings can decline without the firm becoming unable to meet its annual interest costs. The Company’s Times-Interest-Earned Ratio is -19. 6 due to consecutive years of net loss which indicates that the Company was not able to meet its annual interest costs. ACTIVITY RATIOS| | | | | Notes| Status| 2011| 2010| Inventory Turnover| 3| Weakness| 8. 08 | 9. 38| Fixed Assets Turnover| 3| Strength| 10. 88| 10. 19| Total Asset Turnover| 3| Weakness| 3. 06| 3. 32| Accounts Receivable Turnover| 3| Strength| 77. 43| 64. 01| Average Collection Period| 3| Strength| 4. 71| 5. 70| Activity ratios measure how effectively a firm is using its resources. Inventory turnover ratio is used to measure the inventory management efficiency of a business.The Inventory ratio for the year 2011 and 2010 are 8. 08 and 9. 38, respectively. The decreased in the Inventory Turnover ratio indicates that the company is inefficient on controlling their inventory levels (see Note 3 for computation). The fixed-asset turnover ratio measures a company's ability to generate net sales from fixed-asset investments. The Ratios are 10. 88 and 10. 19 for the year 2011 and 2010. The increase in the turnover ratio indicates that the company can generate more sales with its fewer assets which tell that the company is good because it is using its assets efficiently (see Note 3 for computation).The total asset turnover ratio measures the ability of a company to use its assets to efficiently generate sales. The ratios are 3. 06 and 3. 32 for the year 2011 and 2010. The decrease in the turnover ratio indicates that the company is not growi ng in its capacity (see Note 3 for computation). Accounts receivable turnover measures the efficiency of a business in collecting its credit sales. The Accounts Receivable Turnover for the year 2011 and 2010 are 77. 43 and 64. 01, respectively.Increase in the accounts receivable turnover indicates improvement in the process of cash collection on credit sales of the company (see Note 3 for computation). Average collection period measures the average number of days that accounts receivable are outstanding. The Average collection period for 2011 and 2010 are 4. 71 and 5. 70, respectively. The decreasing number of collection days indicates that the accounts receivable of the company is liquid and is being converted to cash quickly compared to the previous year. PROFITABILITY RATIOS| | | | Notes| Status| 2011| 2010| Gross Profit Margin (GPM)| 4| Strength| 30. 4%| 28. 44%| Operating Profit Margin (OPM)| 4| Weakness| -2. 90%| -2. 21%| Net Profit Margin (NPM)| 4| Weakness| -2. 48%| -1. 75%| Return on Total Assets (ROA)| 4| Weakness| -7. 59%| -5. 80%| Return on Shareholders' Equity (ROE)| 4| Weakness| -18. 56%| -12. 52%| Earnings Per Share 4 Weakness -19. 68% -15. 28% Profitability Ratio measure management’s overall effectiveness as shown by the returns generated on sales and investment. Gross Profit Margin is the total margin available to cover operating expenses and yield a profit.During 2011 and 2010 the GPM’s are 30. 24% and 28. 44% respectively which indicates that the company has a reasonable profit margin but it cannot cover up all of its expenses resulting to a net loss (see Note 4 for computation). Operating profit margin is the profitability without concern for taxes and interest. The 2011 and 2010 OPM’s are -2. 90% and -2. 21% respectively. Thus, indicating that the company has poor cost control and/or that sales are insufficient to cover up COS and expenses (see Note 4 for computation). Net profit margin is the profitability after tax a nd interest.The 2011 and 2010 NPM’s are -2. 48% and -1. 75% respectively. This shows that the sales of the company is decreasing with a poor management of expenses (see Note 4 for computation). Return on total assets an indicator of how profitable a company is relative to its total assets. The 2011 and 2010 ROA’s are  -7. 59% and -5. 80% respectively. Thus management is inefficient in using its assets to generate earnings (see Note 4 for computation). Return on Shareholder’s Equity measures a corporation's profitability by revealing how much profit a company generates with the money shareholders have invested.During 2011 and 2010 the ROE’s are -18. 56% and -12. 52% respectively. Thus, indicating that the company is not generating profit by the investment of the shareholders but instead incurring a loss. Earnings Per Share is the earnings per each outstanding share. The 2011 and 2010 EPS are -19. 68% and -15. 28% respectively. Since EPS in considered as one of the factors that an investor considers, it implies that issuance of shares will not generate more money thus, less attractive (see Note 4 for computation). GROWTH RATIOS | Notes| Status| Ratio| |Growth Ratio on Sales| 5| Weakness| -13. 13%| Growth Ratio on Net Income| 5| Weakness| * -20. 06%| Growth Ratio on EPS| 5| Strength| 22. 26%| Growth Ratio on Dividends Per Share| 5| Weakness| -3. 502%| Growth ratio indicates the amount by which a variable increases over a given period of time as a percentage of its previous value. The growth ratios for Sales, Net income, Earnings Per Share, Dividends per Share are -13. 13%, -20. 06%, 22. 26% and -3. 502% respectively. Growth Rates are one of the factors that investors consider in order to extend their resources to generate future cash flows.It indicates that the company’s sales, earnings have not grown that would make its firm value less attractive. Also, it evaluates that the company was not performing good enough in order to generate sales, earnings and returns, hence, occurring losses as resulted. Based on the computation of Growth Ratio on EPS, though it has been reported through financial statements that the sales and income have weaken, still it indicates that the earnings through issuance of shares increases over time. (see Note 5 for computation).

Developing Common Law In Environmental Law Policy - Free Essay Example

Sample details Pages: 9 Words: 2803 Downloads: 7 Date added: 2017/06/26 Category Ecology Essay Type Narrative essay Did you like this example? Common law actions have in recent years proved to be a fertile ground for environmental litigation, although the judiciary have demonstrated a rather lukewarm response to attempts to use torts as a mechanism to control the adverse impacts of pollution on people, property and the wider environment. The courts have shown a preference for specific pollution legislation, such as the Environmental Protection Act 1990, and have shown minimal support for attempts to develop the common law as a means for resolving modern-day environmental problems (Wolf and Stanley, 2010). Introduction Common law is a Judge-declared law, a law which exists and applies to a group on the basis of customs and legal precedents developed over hundreds of years in Britain. Common law is split into two sectors: case law and legislation. Legislation is an act passed by a Parliament or legislature, whereas case law is the law that accumulates as a result of court decisions. There has been much discussion when regarding the issue of common law. Don’t waste time! Our writers will create an original "Developing Common Law In Environmental Law Policy" essay for you Create order For The easiest way to deduce whether the courts have shown a lack of support for the development of common law legislation to counter present day people, property and environmental problems is to analyse well known environmental cases, and make judgements to whether more could have been accomplished by the courts. First the difference between must be defined. Rylands v Fletcher [1868] Rylands v Fletcher is one of the most pivotal cases in Tort law, due to the implications it had on future Tort law cases. Rylands possessed a piece of property over mines and veins of coal. However, he didnt own the rights to these. Nearby coal mines were owned by Fletcher. Rylands built a reservoir, unaware of the abandoned mine left underneath, which led to the overflow of water into Fletchers nearby cave. Fletcher sued Rylands under the tort of trespass, which was deemed inapplicable, as at the time of the case, one-off events werent classed as trespass, and therefore leading to the case being b rought under the tort of nuisance. The arbitrator ruled that Rylands was not guilty of negligence as they had no way of knowing about the shafts under the reservoir. The case was appealed, and ruled in favour of Fletcher, due to Rylands causing mischief by not keeping control of the reservoir. Although he acted without negligence, he was still liable due to the mischief he caused. Due to the reversal in charge, this case became extremely important in regard to Tort law, with some considering Rylands v Fletcher as the fourth Tort. Cambridge Water Co Ltd v Eastern Counties Leather plc  [1994] The most prominent case to consider when agreeing the statement is most probably the Cambridge Water Co Ltd v Eastern Counties Leather plc, which is an important English Tort Law case. It is a case strongly linked to the Rylands v Fletcher case (1868), due to the nature of the case. In 1976, Cambridge Water Co purchased Sawston Mill, which had a borehole from which water could be pumped from. The water was tested at the time, and was declared suitable. Nearby, ECL plc owned a tannery, in which PCE was used within the process. Over the years, the PCE leaked in small quantities and mixed with the groundwater, eventually travelling down, and percolating in the borehole of Sawston Mill, affecting the quality of the water. PCE in water was not a major problem at this, which meant Cambridge Water neglected to test for it. When the European Directive was introduced, the water was tested, and high levels of PCE were found, leading to the shutdown of pumps. CWC then sought damages against ECL, demanding  £1 million in damages due to the requirement of finding a new borehole, and covering the cost of the attempted cleanup of the old borehole. CWC stated they were liable under three of the four Torts; nuisance, negligence and Rylands v Fletcher. The case reached the High Court, but the action was dismissed in both nuisance and negligence. The reasoning behind this was that at that time, there was no possible way of ECL of knowing that PCE release were occurring, and could not have foreseen the damage done to the aquifer. The Rylands v Fletcher rule was considered also, which states the person who for his own purposes brings on his lands and collects and keeps there anything likely to do mischief if it escapes, must keep it at his peril, and, if he does not do so, is prima facie answerable for all the damage which is the natural consequence of its escape and that with a requirement that this use of land be non-natural. The Judge Ian Kennedy disagreed that PCE was non-natural as it was on an industrial site, rendering the claim under Rylands v Fletcher invalid. CWC appealed to the High Courts, and the decision was reversed, due to the decision being based on the nuisance Tort and the case Ballard v Tomlinson (1885). The argument that ECL was interfering with CWCs right to abstract uncontaminated water, which itself was regarded as an action able nuisance. Although the appeal was also claimed under Rylands v Fletcher, this was disregarded. CWC was awarded  £1 million in damages plus costs. This caused uproar within industry, with fears that many companies would be liable for historical contamination. The case was appealed again, this time to the House of Lords. The judgement of the case made important statements regarding the connection between nuisance and Rylands v Fletcher. Lord Goff considered forseeability (only liability where interference was foreseeable by a person in the defendants position belief that damage was unforseeable), non natural use (storage of substantial chemicals should be considered non-natural freed up restriction on liability under Rylands v Fletcher) and the courts and environmental protection (referring to common law as environmental protection aiming to create a statutory regime of liability for environmental damage). The decision was once again reversed in favour of ECL. The main r eason for this was the issue of forseeability of the damage suffered by CWC, as it was believed at the time that any spilt solvent would be evaporated. There are major criticisms of the how the case ended. Most environmentalists believe the judgement was restrictive due to the introduction of the requirement of forseeability of the type of damage as a component of the rule in Rylands v Fletcher. Another criticism of the judgement is that only very rarely will it impose liability for pollution cases such as this one. To some, it is believed that not enough impetus was placed on the safety of the environment when regarding the case in general. The reaction from Lord Goff seemed to be one of timidity and uninterest in correcting a wrongdoing. The fact that the judges felt the case should be dealt with by Parliament rather than the courts seem to be a statement that disregards the importance of dealing with pollution to the environment. Fairchild v Glenhaven Funeral Services [2 002] The next case of interest is the Fairchild v Glenhaven Funeral Services Ltd. The case involved Mr Fairchild, a subcontractor who worked for a number of different employers, all of which inadvertently exposed him to asbestos. Fairchild then died of Mesothelioma, which resulted in his wife suing the employers under the Tort of negligence. This lead to other people affected with similar situations suing the companies as well. The problem with determining whether the employers were to blame for Mr Fairchilds death was that a single fibre of asbestos can lead to the contraction of Mesothelioma, and was therefore very difficult to determine which employer was completely to blame for the death. Unlike asbestosis, Mesothelioma is a single indivisible disease, therefore the claimant cannot deduce when the asbestos fibre was inhaled leading to the mesothelioma cell becoming malignant. The question was if the defendants had overexposed Mr Fairchild to the asbestos. All employers wer e equally liable. However, this lead to the question of probability, as it was difficult to determine which employer had exposed Mr Fairchild to more asbestos. Due to this uncertainty, the Court ruled that the claimant was unable to judge if the breaches of duty were a cause to the deceased death. In other words, no damages were paid to Mrs Fairchild. This is another classic case of the Courts washing their hands of a difficult decision. Instead of implementing legislation regarding asbestos, the claimant ended up with nothing. In 2001, the case Edwin Matthews v The Associated Portland Cement Manufacturers (1978) Ltd was brought to court, with the same problem of exposure of asbestos the cause. Mr Matthews had been exposed while working for several contractors, contracted Mesothelioma, and had sued two of the employers. However, unlike Fairchild v Glenhaven, Mr Justice Mitting had an alternate opinion on the case.He concluded: I can see no substantial difference between saying th at what the defendant did materially increased the risk of injury to the claimant, and saying that what the defendants did made a material contribution to the injury. It seems to me wholly artificial to require a claimant to prove which fibre, or fibres, inhaled in whose employment, in precisely what circumstances, caused or set off or contributed to the process by which one or more mesothelial cells became malignant.  [i] Mr Justice Mitting The court ruled in favour of Mr Matthews, who received damages from both employers, with the reasoning that even though it could not be determined which employer exposed him to the actual asbestos resulting in the Mesothelioma, it could be deduced that they had both increased the risk of him doing so. This leads to the question: How can two such similar cases end so differently? Hunter v Canary Wharf The Hunter v Canary Wharf Ltd [1997] involved the construction of Canary Wharf Tower. However, the construction of the tower, which w as situated near to BBCs primary television transmitter, which affected the reception of local residents television. Also, action was brought against the London Docklands Development Corporation under nuisance also, due to the dust created from the road construction. Over 500 residents filed cases, including Patricia Hunter, against Canary Wharf under the Tort of nuisance, arguing that their television license was now wasted and loss of enjoyment. Originally they filed under negligence too, but the Tort was abandoned soon after. During the case, it was stated that the nuisance in question must be substantial, and that only householders with a right to a property could file anything under the Tort of nuisance. It was Lord Goffs judgement that a building being built in the near vicinity does not apply as nuisance. Initially, the case of Khorasandjian v Bush [1993] was brought up, in order to show that the occupation of a property as a home was enough to constitute action in private nuisance. However, this was rejected in the House of Lords, with the point being that when dealing with private nuisance, the right to sue can only be exercised by those with rights to the land affected (freehold owners, tenants in possession). The question of dust was rejected as personal injury doesnt apply under the Tort of nuisance. Due to the connection made between property rights and nuisance, the development of greater protection of the wider environmental problems has been halted. It was Lord Hopes opinion that not enough had been stated within the case to make a change to the law in regard to a nuisance. Against When considering the argument against the original statement, there are also many cases to represent this opinion. The argument will be fought with examples where the Courts place more impetus on protecting the environment than on themselves from a tough decision. Empress Car Company Ltd v National Rivers Authority [1998] The case in question focused on the prosecution of Empress Car Company being sued by the National Rivers Authority, due to the release of red diesel fuel into a river. An oil tank owned by Empress, was surrounded by a protective bund, in case of a spill. However, a pipe leading to a smaller oil tank outside the bund was installed to make oil use easier. However, the oil tap was vandalised by a trespasser, which led to the oil overflowing from the secondary tank, which in turn led to the contamination of a local river. When the case reached the Courts, the defendant tried to place the blame on the trespasser who caused the tap to be open, and had only crea ted the circumstances which led the trespasser entering the grounds. He also argued that the involvement of the trespasser broke the chain of causation. The argument was rejected by Lord Hoffman, who found Empress Car Company Ltd guilty. Another point brought up was the act of prevention of a chance of contamination. It seemed that Empress had a lack of a valid backup plan if a spill occurred. The question of liability was resolved in 1991 when the WRA was created, which states that escapes of pollutants into controlled waters will lead to absolute liability. This is a prime case when deciding whether or not the original statement is true. Empress v National Rivers Authority reflects that proper incite was made into the environmental effect when determining the judgement of the case. It showed that even though the defendant had not directly led to the release of the oil, he was still liable as he didnt take enough care in ensuring that if a spill occurred, it would be dealt wi th accordingly. Wheeler v Saunders [1994] In the case Wheeler v Saunders [1994], Mr Wheeler was a veterinary surgeon who owned Kingdom Farm House. The farm as owned by J.J Saunders, who used it to raise pigs. Wheeler filed a complaint regarding the smell of the pigs, under the Tort of nuisance. The court agreed with Wheeler, in regard to the smell nuisance affecting his use and enjoyment of the land. The decision was appealed by Saunders, who stated that the allowance of planning permission changed the nature of the area, which then would lead to the nuisance Tort being allowable, thus throwing the case out. He referred to the case of  Gillingham Borough Council v Medway (Chatham) Dock Co Ltd, which allowed the building of a commercial dock. However, the appeal was disregarded, with the reasoning that the case of pig houses would affect the surrounding area more dramatically than it would have regarding the Gillingham case. This decision goes against the original sta tement as it directly supports the avoidance of the environmental effect of the pig farms. Transco v Stockport The Transco v Stockport Metropolitan Borough Council [2003] involved the collection of a large amount of water under a block of flats, due to an undetected leak. The leak then spread to a nearby embankment, which led to the embankment collapsing. This in turn led to a gas pipe becoming exposed and unsupported, due to the ground underneath the pipe being washed away. The gas company, Transco, then sued the Stockport Council under the Rylands v Fletcher Tort, in regard to the repairs necessary. The Courts judgement was that the council was not liable as the amount of water from the pipe is not considered a dangerous amount. When considering the Rylands case, which showed that excessive amounts of water can lead to risk of damage, the case seemed to have justification. However, Lord Hoffman judged that a burst water pipe does not does not count as something excessive or dangerous. When considering section 209 of the Water Industry Act (1991), which states that although the water undertaker is considered liable when causing damage or loss, they would not incur any liability if the case in question is regarding a specific claimant, such as Public Gas Suppliers, who must insure themselves. Due to this, the Court supported the Council. Conclusion In regard to the original statement, there are several cases supporting and disregarding the claim. On one hand, there are several examples (many more than stated) that show a lack of will to combat environmental problems by developing the common law. On the other hand, there are also examples where the courts have supported the use of legislation to help protect the environment. There seems to be a pattern when regarding the cases supporting the original claim. It seems when the case in question offers a dilemma in ethics, the courts are more than willing to sweep it under the rug, rather than finding a better way of dealing with the same kind of problem in the future. When referring to Cambridge Water Co Ltd v Eastern Counties Leather plc, it seemed the Judge was more than happy passing the problem over to Parliament than finding a constructive method of dealing with it correctly. The fact that forseeability was considered more of an issue than the non-natural use of land also re presents this opinion.