Tuesday, January 28, 2020

How Successful are Pap Smears?

How Successful are Pap Smears? How successful are pap smears in detecting cervical and uterine cancers? George Nicholas Papanicolaou established the Pap smear in the 18th century when he became intrigued by the guinea pigs vaginal smears as he was studying them. He quickly began to start his research on the female reproductive system, most specifically the different cytology slides he could obtain. His stake in the field was his book published in 1943, â€Å"Diagnosis of Uterine Cancer by Vaginal Smear.† It covered topics like physiological changes of a menstrual cycle, the hormones incorporated, and vaginal smears that led to his classifications of disease and malignancies. This jump started the screening for cervical cancer and can attest to a significant decline in cases of cervical cancer. Later, he published another book specific to just distinguishing between healthy and diseased tissue throughout the entire body. These two publications were just two of the four he finished in his life on top of awards and honorary degrees. (Tan, 2015) Papanicolaou was certainly a huge help in the advancement of cytology reporting. Since then, we have been able to learn and understand more about pap smears, cervical cancer and the role pap smears plays in diagnosing them. Although both cancers begin in the same area, the uterus; we can differentiate them by their pathophysiology’s. The question really stands, how successful are pap smears in detecting these cancers? This can be argued on a few bases, but sticking to the facts we can find out how successful they are, how they can be preventive, and what to expect if a woman does find herself diagnosed. Several factors can be taken into account such as the pathogenesis, level of disease, the manifestations, precipitating factors, and several more. Uterine and Cervical cancers both come with their own etiologies, epidemiology’s and prognosis. There are a few different ways to screen for cervical cancer, and this will look directly into the Pap smear procedure. The Pap smear allows for a better look into the cells in the cervix, the opening of the uterus. The test is looking for cancerous and abnormal cells that could lead to cancerous outcomes. In the test an obstetrician- gynecologist will scrape away a portion of cervix cells. The use of a speculum helps the doctor keep the walls of the cervix open to have a clear view and retrieve a good sample. The specimen will then be tested in a controlled laboratory setting where a technician will observe for abnormalities. An official cytology report will be sent to the doctor and then given back to the patient for further counsel if needed. Results will be abnormal or negative (normal). Several sources believe the Pap smear to be very accurate in the screening of cervical cancer. It also is a very preventive measure to take, as long as the patient is compliant with the doctor’s guidelines. By detecting cervical cancer early, treatment can begin to decrease the risk of spreading and growth of the tumors. Pap smears have been estimated to reduce cervical cancer rates and mortality by 80%. (Weber, 2017) In comparison, up to 80% of women diagnosed with invasive cervical cancer have not received a pap smear in the past 5 years. (Stà ¶ppler) CIN or, cervical intraepithelial neoplasia is a precancerous condition of abnormal cell growth on the cervix. Intraepithelial means that the abnormal cells are growing on the surface or the epithelial tissue of the cervix. Neoplasia is referring to the growth of new cells. Signs and symptoms can be obvious but can also resemble several conditions that females could encounter. These symptoms can include abnormal vaginal bleeding, bleeding after sexual intercourse, pelvic pain, discharge, and pain during sexual intercourse. (Stà ¶ppler) It is recommended that women start getting pap smears at the age or 21. This is most important if you are HIV positive or have a weakened immune system. (Weber, 2017)   These screenings should continue from ages 21 to 29 with cytology alone every 3 years. From ages 30-65, women should continue cytology screening every three years and add HPV testing. After 65 no screening is necessary as long past screenings are normal and no high risk is present. (Boardman, 2018) Over the years professionals have found it difficult to all be on the same page about reporting. Some levels of abnormal results can include atypia, mild, moderate, severe dysplasia, and carcinoma in situ. The creation of the Bethesda System has given one reporting system for all health care professionals. In 1988 the National Cancer Institute held a conference for the creation of this system, it was then re-evaluated in 2001. There are four major classifications that make it easier for this universal system to work. â€Å"ASC-US: This abbreviation stands for atypical squamous cells of undetermined significance. LSIL: This abbreviation stands for low-grade squamous intraepithelial lesion. Under the old system of classification, this category was called CIN grade I. HSIL: This abbreviation stands for high-grade squamous intraepithelial lesion. Under the old system of classification, this category was called CIN grade II, CIN grade III, or CIS. ASC-H: This means atypical cells are present and HSIL cannot be excluded.† (Stà ¶ppler) CIN cases are most always caused by infection with oncogenic types of HPV or, Human Papillomavirus.   There are 12 known types of high risk HPV, which are the most prevalent associations with cervical cancer. Cervical cancer results from a genital infection with HPV, a known human carcinogen. Because most HPV infections are transient or, passing in and out of existence in a patient, it causes only temporary changes in cervical cells. (National Cancer Institute, 2014)   About 90% of HPV infections clear on their own within months to years with no sequelae. (Boardman, 2108) This makes it difficult to catch the HPV infection and in turn cervical cancer. Too frequent of screenings might be problematic for several reasons. One being that treating these abnormalities thinking it was HPV but that went away anyways would cause unnecessary stress on the patient. Also, putting strain on the cervix several times in any period of time can weaken the tissue and could ultimately affect the woman’s fertility. Interestingly enough, it can take up to 20 years for a persistent infection with a high risk HPV to become cancerous. (National Cancer Institute, 2014) Low risk HPV infections rarely or almost never cause cervical cancer. (Boardman, 2018) However if lesions are found and not treated, they are more than likely to turn into cervical cancer. (National Cancer Institute, 2014) There are different levels of cervical cancer that decipher the progression on epithelial tissue. CIN grade 1 is low grade neoplasia involves around one-third of the thickness of the epithelium. CIN 2 refers to the abnormal changes in about one to two-thirds of the layer. CIN 3 is the most severe affecting over two-thirds of the epithelium. 5% of HPV infected patients will acquire CIN grade 2 or 3 lesions with three years of infection. Only 20% of CIN 3 lesions progress to invasive cervical cancer within 5 years. Only 40% of CIN 3 lesions progress to invasive cervical cancer within 30 years. Genetics can also play a role in a woman’s development of cervical cancer; genetic connection holds fewer than only 1% of cervical cancers. â€Å"Women who have an affected first degree biological relative have a two fold relative risk of developing a cervical tumor compared with women who have a nonbiologic first degree relative with a cervical tumor.† Some specific genetic factors have been shown to be in association. The tumor necrosis factor is involved with cell apoptosis and a high incidence of cervical cancer. Polymorphisms, another gene dealing with apoptosis, have been linked to the increased rate of HPV and in turn, cervical cancer. Cervical cancer is the leading cause of cancer related morbidity in developing countries, but is very uncommon in the United States. â€Å"Since 2004 rates have decreased by 2.1% per year in women younger than 50 years and by 3.1 per year in women 50 years of age and older. ACS reports 12,170 new cases of cervical cancer would be diagnosed in 2012.† Age related demographics from 2004-2006 were highest among women from 50-79. But cervical cancer is possible to be present in any sexually active woman. In terms of race, cervical cancer rates per 100,000 women in the US from 2005-2009 are across the board: Hispanic 11.8, African American 9.8, American Indian/ Alaska Native 8.1, White 8.0 and Asian/ Pacific Islander 7.2. Internationally, 500,000 women are diagnosed every year. Prognosis for cervical cancer is very good, especially when caught early. 5 year survival rates: Stage 1 greater than 90%, Stage 2 60-80%, Stage 3 approximately 50%, and stage 4 less than 30%. Treatment for this type of cancer is usually dependent on age, fertility or pregnancy plans. One procedure, LEEP, the loop electrosurgical excision procedure carries an electrical current through a wire to remove abnormal tissue. Cryotherapy freezes the abnormal tissue. Laser therapy uses a beam of light to remove or even destroy the cells. Conization can also be used with a knife and laser. (Boardman, 2018) In severe cases removal of the uterus, hysterectomy is sometimes necessary. Radiation, chemotherapy and surgery can sometimes be performed in other extreme cases. However like any screening test there is always a risk of inaccuracy in false negatives and false positives. (National Cancer Institute, 2014) In some cases a pap smear can be faulty and must be reported in an official capacity. Some examples of this could be â€Å"drying artifact’ or â€Å"excessive blood.† The person reading the smear could feel these are factors that affect the reading. Inflammation can also be a problem in a Pap smear reading. Inflammation can be from infection or irritation. (Stà ¶ppler) Uterine cancer is defined as the any invasive neoplasm of the uterine corpus and is the most common pelvic gynecological malignancy in the United States. Uterine cancer can also be labeled endometrial cancer. The most common type of uterine cancer specifically is endometrioid adenocarcinomas. (Chiang, 2017) It is believed to have two forms; type 1 or estrogen dependent and type 2, which is estrogen independent. (Holman 2012) Uterine cancer can start in small areas or â€Å"a diffuse multifocal pattern.† Health care professionals can usually diagnose this type of cancer by the spreading pattern of the tumor. Usually the tumor will grow from the original location. This can tell the doctor how far along the cancer is. Later tumor growth is seen through myometrial invasion and movement towards the cervix. The cancer itself can take four different routes to spread outside the uterus. Direct or local extends beyond the uterus. Lymphatic, referring to exposure to the pelvic, para-aortic, and sometimes the lymph nodes. Hematologic goes further reaching the lungs, liver, and bone metastatically. Lastly, â€Å"peritoneal/ transtubular spread results in intraperitoneal implants. Staging of Uterine cancer, like most cancers, will depend on the amount of growth and spreading of the tumors. Clinical stage 1, which is the most common for patients, is strict to the uterus. Stage 2 involves a large amount of the cervix. Stage 3 â€Å" vaginal extension, adnexal mass, and/or suspicious retroperitoneal lymphadenopathy.† Stage 4 accesses the bowel and bladder and some other metastases around the body. Although pap smears are prominent for cervical cancer findings, it is not as helpful in uterine cancer. According to my findings, there are actually no screening regimens for asymptomatic women. The only screening mentioned is a transvaginal ultrasound, which â€Å"determines the thickness in postmenopausal women.† In the suspicion of abnormalities, biopsies can be taken. Uterine cancer usually includes both surgery and radiotherapy. Other treatments follow a hormone regimen. Other forms can use estrogen replacement therapy and Tamoxifen, which is usually used for breast cancer but can be used on endometrium tissue as well. (Holman 2012) Because of the early representation of the cancer, treatment is usually successful and most do not progress past stage 1. Recurrences can happen and usually do within 3 years of the original diagnoses, which occurs in half of patients. (Holman 2012)(Uterine Cancer) Symptoms of uterine cancer can range from genital discharge, pain, weight loss, and change in bladder or bowel movements. However, postmenopausal bleeding is said to diagnose up to 90% of endometrial cancers. Another clinical finding would be glandular cells from a pap smear on a postmenopausal woman. Some risk factors are obesity, nulliparity, and late menopause. Diabetes and hypertension are also conditions that. Less than 5% of this cancer is actually diagnosed when the woman is asymptomatic can increase the risk of uterine cancer. (Uterine Cancer) Most of the patients diagnosed with uterine cancer are obese, which can affect estrogen levels. (Holman 2012) Over 50,000 cases of uterine cancer are diagnosed each year, leading up to 10,000 deaths per year. In women alone, it leads to 4% of deaths related to cancer. 70-75% of cases are diagnosed at stage 1. In 2009, the survival rate for uterine cancer was 83.1%. (Chiang, 2017) A large majority of the population diagnosed are postmenopausal and ages 50-65, average age of 61. White women have the largest risk of uterine cancer in the United States compared to African American, Asian and Hispanic women. However, African American women have a larger rate of death. Interestingly, those women living in Asia or Africa have a much smaller rate of uterine cancer than Asian and African American women in the United States. Smoking actually has been shown to decrease your chance of endometrial cancer. The use of contraceptive pills has also been said to be a protective measure for women. (Holman 2012) In conclusion, Pap Smears can be resourceful ways of detecting cervical cancer but not at large uterine cancers. Pap smears are a great screening method for obstetrician- gynecologists and their patients to catch and prevent cervical cancer. By detecting cervical cancer early, prognosis is very good and very likely in most cases. These quick diagnoses from pap smears and other sources has made cervical cancer a very uncommon cancer related death for women in the United States. Unfortunately for developing countries, lack of medical resources and research has made discovering cervical cancer difficult and fatal. With the Bethesda System doctors from all over can classify cervical cancer the same way. Pap smears are very accurate, but like any screening procedure there is always the risk of false negatives or false positives. Although Pap smears haven’t been shown totally reliable to detect uterine cancer, there are several other methods to find uterine cancer. The most obvious can be the presence of postmenopausal bleeding in women, which diagnoses most of the cases. Transvaginal ultra sound can be used to determine the state of the woman’s uterine tissue. These and a few others have been said to be more reliable than Pap smears. Counterpart to ruling out Pap smear findings, one source does tell that if glandular cells are present than it might be uterine cancer. Like cervical cancer, uterine cancer is most always found in early stages or stage 1 to be exact. This early detection makes it only 4% of cancer related deaths in women. In doing my research it was clear to me that Pap smears are in fact helpful in detecting cervical cancer but not as much in uterine cancer. I only found one source that mentioned findings from a Pap smear for uterine cancer. This was entirely interesting to me because they are in very similar areas of the woman’s reproductive system. In doing more research, it makes sense that a pap smear rarely diagnoses uterine cancer because it starts inside the uterus. The cervix being much lower and away from the uterus makes it easier to obtain cells and much more reliable. Finding cervical cancer can be much more direct and easily obtained. Getting to the uterus safely is much more difficult. In further research I believe it would be interesting to look further into minimally invasive ways to detect uterine cancer. Another topic is using the any findings from a Pap smear in detecting cervical cancer to relate to prevention of uterine cancer. Lastly, the result of cervical and uterine cancer on future pregnancy or on currently pregnant women. Works Cited â€Å"Uterine Cancer.† Uterine Cancer, www.csh.org.tw/dr.tcj/educartion/f/web/Uterine%20Cancer/index.htm. Boardman, Cecelia. â€Å"Cervical Cancer.† Practice Essentials, Background, Pathophysiology, 26 Jan. 2018, emedicine.medscape.com/article/253513-overview. Chiang, Jing. â€Å"Uterine Cancer.† Background, History of the Procedure, Epidemiology, 6 Dec. 2017, emedicine.medscape.com/article/258148-overviewuterine cancer. Holman , Laura. â€Å"The Epidemiology of Endometrial Cancer.† The Epidemiology of Endometrial Cancer, 2012, www.glowm.com/section_view/heading/The%20Epidemiology%20of%20Endometrial%20Cancer/item/236. Stà ¶ppler, Melissa Conrad. â€Å"Pap Smear: Facts About the Procedure, Pain & Guidelines.†MedicineNet, www.medicinenet.com/pap_smear/article.htm#what_is_a_pap_smear_procedure. Tan, Siang Yong, and Yvonne Tatsumura. â€Å"George Papanicolaou (1883–1962): Discoverer of the Pap Smear.† Singapore Medical Journal, Singapore Medical Association, Oct. 2015, www.ncbi.nlm.nih.gov/pmc/articles/PMC4613936/. Weber, Michael. â€Å"Pap Smear (Pap Test): Reasons, Procedure, & Results.† Healthline, Healthline Media, 13 Mar. 2017, www.healthline.com/health/pap-smear. Should Hate Speech Be Protected as Free Speech? Should Hate Speech Be Protected as Free Speech? Question: Should hate speech be protected by the right of free speech? Introduction Hate speech is a controversial and often misinterpreted term for speech intended to degrade, intimidate, or incite violence or prejudicial action against an individual or a group of individuals based on their race, ethnicity, national origin, religion, sexual orientation, or disability. The term has been taken to cover written as well as oral communication. My starting position is that hate speech is not just one thing; there can be at least four categories of hate speech that we can address. By the end of this essay I hope to have shown sufficiently which, if any, types of hate speech could be protected by the right of free speech. Right to free speech and expression Perhaps in a different era, the two could be seen as distinct, not just by name, but also in context.[1] The right of free speech is a human, political or civil right recognised and appreciated by states and their citizens. It is the right to communicate ones opinions and ideas using ones body and property to anyone who is willing to receive them. It was included in the First Amendment to the United States Constitution.[2] Although freedom of expression is sometimes used within an identical context, it nevertheless includes any act of seeking, receiving and imparting information or ideas, regardless of the medium used. Perhaps the most commonly cited definition is the one given by the United Nations in Art.19 of their UDHR[3] adopted in 1948.[4] Along the same lines, Art.10 of theECHR[5]provides the right to freedom of expression, subject to certain restrictions that are in accordance with law and necessary in a democratic society. It is important to appreciate that the two are largely intertwined, and to be read separately would be of no particular value or help. For the purposes of this essay, I shall regard the two rights as two faces on the same side of a coin. Being part of a group of ideals or social goods even, the right of free speech is not specially protected from other ideals. It has to compete with such rights as right to private life, public security and democratic equality amongst others. There is no precedence that the right for free speech must always prevail. The wording of the First Amendment creates a defence for individuals and a difficulty for the state to regulate similar acts in the United States, as well as a desire to abolish the limitations already imposed by other states.[6] When may the right of free speech be limited? It can easily be imagined that the time, place and way of something being said or written or expressed in any other form is subject to scrutiny as to its appropriateness or inappropriateness respectively that is subsequently reflected in regional legislations. This is not normally objected to. There is another controversial excuse for limiting it and that has to do with its content.[7] A classic example is the prohibition of circulation of Nazi ideas in parts of Europe. This is only to be expected, considering that the UDHR was an attempt to stop the terror witnessed during that war from happening again. It is important however to understand that all is meant by limiting free speech or prohibiting hate speech is not preventing someone from exercising the right, but rather a subsequent punishment. Hate speech The prohibition of hate speech is often anathematised by the advocates for the right of free speech. Following Smolla, it can be generically defined as a speech assault based on race, ethnicity, religion and sexual orientation or preference[8]. Brison attempts to colour it even more by defining it as the speech that vilifies individuals or groups on the same basis and which is face to face vilification or constitutes a group libel[9]. Waldron also believes that hate speech is a form of group defamation[10]. I would think that defamation is more suiting as we have already accepted that hate speech can be manifested both verbally and in writing. When can free speech include hate speech? There is, of course, a number of arguments articulated to justify the importance of including hate speech in the right of free speech, however, lacking space, I will address only the four that I consider of greatest importance. Discovery of truth This argument has two distinct streams of interpretation. According to the first, we come to know more truth if we allow a â€Å"free marketplace of ideas†.[11] Advocates of the second stream claim that allowing discussions promote truth and the interests of the right for free speech more than restrictions, as it allows for comparing and contrasting arguments. Scanlon divides the possible participants in a trade of speech into speaker, audience and bystanders. The value protected by both is truth itself; the speaker has an interest in communicating an opinion; the audience and the bystanders have an interest in evaluating and challenging the said opinion. Central to this argument is the importance of reliable and truthful information since it would be detrimental to knowingly spread opinions based on the unreliable and false information.[12] Note that this argument, like the rest, covers not only the promotion of views and opinions, but also of the communication of facts that do not invite evaluation, such as the names of professors in the University of Essex’s Human Rights department. However, as Schauer points out, this value does not have an a priori precedence over other values.[13] Livelier apprehension and personal development According to J. S. Mill we come to apprehend the truth in a more lively way when we confront people who dispute our beliefs or be confronted by them respectively. â€Å"So essential is this discipline to a real understanding of moral and human subjects that, if opponents to all-important truths do not exist, it is indinspensable to imagine them and supply them with the strongest arguments which the most skilful devil’s advocate can conjure up.†[14] Eric Barendt adds: â€Å"Restrictions on what a man is allowed to say and write, or to hear or read, inhibit the growth of his personality. People will not be able to develop intellectually and spiritually, unless they are free to formulate their beliefs and political attitudes through public discussion, and in response to the criticisms of others.†[15] Greenawalt provides further input: â€Å"By affording people an opportunity to hear and digest competing positions and to explore options in conversations with others, freedom of discussion is thought to promote independent judgment and considerate decision, what might be characterized as autonomy.†[16] The speaker here has an interest in influencing the thought and conduct of others through speech. Furthermore, according to Joseph Raz, the audience has an interest in hearing expressed ideas that may potentially reassure and validate their lifestyles. [17] Democratic participation This has been elaborated best by Cass Sunstein. â€Å"Free speech is to be protected because it facilitates the democratic articulation, aggregation and balancing of interests, and is necessary if the people are to be able to decide for themselves the candidates they think most suitable for public office and the policies that public officials should pursue. This argument links free expression with a ‘commitment to political equality’ and a ‘belief in democratic deliberation’.[18] The argument presupposes that the citizens of a democratic state have the right of free speech and are not negligent in exercising it fully. Democracy translates – loosely – into power of the people and by definition, for the sovereignty of the people to be effective, public opinions should be formulated free of any control or intervention by the government. As such, the speaker’s interest is in providing an opinion on matters of public-political life, while the main audience has an interest in hearing the views of others, and gaining an understanding of political views and preferences. The argument of the right of autonomy In considering a law that prohibits speech, Scanlon writes: â€Å"In order to be protected by such a law a person would†¦ have to concede to the state the right to decide that certain views were false and, once it had so decided, to prevent him from hearing them advocated even he might wish to†[19] He goes on to argue that that since an autonomous person’s reason is sovereign over her own decisions, it is incompatible with her autonomy to be shielded from certain evaluative views, or factual information, even if only to avoid the harm to her of coming to have false beliefs.[20] Greenwald describes such intervention as viewpoint discrimination[21], the very thing that the First Amendment is employed to counter. This corresponds to the right of the audience not to have restrictions on their range of options to choose from in order to formulate an autonomous decision. Let us now examine the kinds of hate speech Targeted vilification Speech directed at specific individuals or small group and with the intention to harm and insult the audience. The speaker consciously selects the wording for its potential to achieve just that.[22] Contrary to what Brison argues, I would argue that it should include non-face-to-face acts, such as cases when is not direct but sufficiently specific.[23] The content itself does not usually qualify adequately as an assertion of fact, expression of an evaluative opinion or even of a valid political preference, since it is usually based on false accusations. Also, the speaker cannot barricade behind the right of autonomy and argue that non-racists are privileged over racists, since having a right of autonomy does not imply having the right to be racist and furthermore clashes with the rights of others to be equally autonomous. It does not encompass the essence of the right, it does not promote the interests that the right seeks to, and it is not what is meant when the right for free speech is interpreted; therefore we can conclude that targeted vilification should not be protected by the right to free speech. Diffuse vilification This is speech directed at a friendly or of mixed sentiments but larger audience than targeted vilification, but nevertheless has the same intentions; to assault individuals based on the group they adhere to, or even the group itself, although they may not be the immediate audience.[24] It usually employs symbols or banners with group specific insults. An example would be the Nazi march in Skokie, a village with a notable population of holocaust survivals and younger Jews. There is an evident intention to cause emotional distress and so, any speech or acts employed and political symbols used could not be excused as such, but as insulting, harmful and intimidating.[25] A fair excuse would be that the allegedly distressed could avoid the march. To what extent this is possible depends on other factors such as prior sufficient advertising and the financial or effort overbearing on the victim’s part. This becomes more apparent when the cost to pay to avoid the distress would mean losing one’s work or avoiding communing areas or even becoming antisocial. This would clearly outweigh the interests of the speaker. Evidently, diffuse vilification promotes free speech interests at a far higher level than targeted vilification; it can take the form of honest – albeit mistaken at times – expression of political and evaluative opinions, precisely because it is not targeted but addressed to a wider audience, which could be proactively met and discussed with an opposing group. Although in its honest and fair form it should be protected by the right of free speech, in my opinion, the government has enough justification to intervene and attempt to control the manner in which it is expressed, and specifically by regulating the prohibition of speech, acts and symbols used for their potential to offend and/or to incite hatred and violence towards another social group. Advocating exclusionary policies Exclusionary policies are those that attempt to exclude certain social groups from equal participation in decision making and full enjoyment of their citizen and political rights. In its extreme form, this could include advocating genocide and ethnic cleansing.[26] The harm caused by a possible adoption and enactment of such policies is not easily outweighed, especially by the arguments for the discovery of truth and of personal development – for obvious reasons. Following the argument for democratic participation, such cases constitute political speech, or part of, which the right of free speech clearly intents to protect. However, allowing the advocating of non-democratic ideals in a democratic society brackets democracy itself. I do not accept that democracy should succumb to such hypocritical arguments. I agree with what Rosenblum terms as militant democracy who attempts to defend itself. [27] Even though state controls on political speech is restricting political equality, a democratic value, it is acceptable to do so when the speaker advocates anti-democratic values, even more so when they are advocating restriction on the political equality of others. From the perspective of the argument for autonomy, it can be argued that people should be allowed to exercise their right as rational sentient beings and consider, reflect upon, and decide for themselves which political speeches to support and which to strike down, without the need to cede their right to do so to any government.[28] However, how empirically justified is, or can, that be? What assures us that citizens will in fact make the right choices? What assures us that citizens will even bring themselves to consider such important and hard matters? Is it not the case that people who do concern themselves with such issues have a prior long time interest in them? How can we be sure that the citizens actually have the necessary mental capacities to fully comprehend the speech and its consequences? A democratic society is successful not only because of alleged equality, but also, because of alleged intellect. Following the notion of militant democracy not only there should be intervention to prohibit anti-democratic elements from exploiting democratic values, but also, there should be intervention to debunk, rebut and expose anti-democratic speeches. If the body of citizens is not able to comprehend it fully, the democratic government, assuming it is able to comprehend it, should step in. In my opinion, although this category is part of the general category of political speech, which the right of free speech intents to protect, it can take the form of anti-democratic speeches and incitement of hatred that may lead to horrid results. To this end, I conclude that this form of speech could be protected under the right of free speech, but the states should reserve their right to intervene in such circumstances that put into danger and jeopardize their very democratic nature. Harmful assertions of fact The notion that free speech should include the right to speak words that insult others, or saying what others do not like hearing, has become part of the modern society’s pop wisdom heirlooms. The combined promotion of the values of truth, democratic participations and autonomy is indispensable, even though we cannot deny that even these assertions can cause grave harm to individuals or groups. A fair objection to protecting these kinds of assertions I have found is what Margalit and Raz call the self-respect and dignity of group members, which are being threatened by such assertions.[29] This links to a reversed interest for personal development on the part of the group members, especially when it comes to social groups identified by ethnicity, where self-dignity and self-respect depends on the dignity and respect assigned to that group by others. However, can it not be said that a Kurdish minority in Turkey or the UK should be exposed for their practice of FGM[30] and to evaluative opinions and scrutiny from the rest of society about it, independently of their other dignity recognition and respect issues? In their extreme form, such factual assertions and evaluative opinions may lead to unjustified hate crimes and violence against innocent members of targeted groups. A classic example is the growing contempt that locals feel against immigrants in most countries. Even if top level surveys manage to prove that economic crisis, health system deterioration or other social harms are caused by immigrants, there is a huge leap from an empirical observation to undemocratic acts of violence. Militant democracy should step in here once again, not only to prohibit and punish such actions, but also, I would argue, to better regulate the matters revealed by such surveys.[31] Despite all these, harmful assertions of fact can be seen as promoting the interests embraced by the right of free speech. Even with harmful – but not extreme – assertions, an available remedy would be counter speech instead of restriction. This is possible because they are not mere vilification, but truthful and empirical assertions of honest intentions and therefore do not cause emotional distress.[32] In my opinion, a government should not be able to intervene by prohibiting the expression of such assertions, but they should be allowed to prohibit and punish individuals who misinterpret such assertions from resulting to hate crimes such as racial attacks. By saying this, one may think that I refuse to consider what some call group libel as hate speech worthy of being punished. This is not the case, since libel, defamation in general, is harmful yet untrue assertion. Even though some may disagree as to the context of vilification, I take it to also have an element of faulty accusations. Conclusion I do not see hate speech to have just one singular face. As I have shown, it can be manifested in many different ways, which can in turn be judged on different grounds. Therefore it is inapplicable to argue that it should be either protected under the right for free speech in its entirety, or not at all. I am of the opinion that some forms of hate speech should be protected by the right of free speech, because of the benefits bestowed to society. Some other forms should not be protected; states should take steps to better inform citizens about the different shades of hate speech and democratically establish legal frameworks to punish the ones that fall on the negative side of the spectrum. [1] Due to the frustratingly large portion of the first draft of my essay spent on citing relevant treaties and articles defining the two rights, and assuming that the reader is familiar with them already, I have decided to include the definitions in footnotes, as they do not count towards the total word count. I do realise that this is inelegant, but I am exercising my right of autonomy to promote my personal interest, namely of not being penalised. Forgive me. [2] First Amendment to the United States Constitution reads as follows â€Å"Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.† [3] United Declaration of Human Rights [4] Article 19 of the UDHR states that â€Å"Everyone has the right to freedom of opinion and expression; this right Includes freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers.† [5] European Convention on Human Rights [6] UK: Sec. 18 (1) of thePublic Order Act of 1986; France: Sec 24 of the Press Law of 1881; Denmark: Article 266 (b) of the Danish Criminal Code; The Netherlands: Articles 137 (c) and 137 (d) of the Dutch Criminal Code [7] i.e. the grounds cited in ICCPR and ECHR are content relevant. [8] Smolla, 1991, 152 [9] Brison, 1998, 313 [10] Waldron, 2009, 1600-1601 [11] Justice Holmes’ obiter dictum in Abrams v. United States, 250 U. S. 616 (1919). [12] Cohen (1993: 211, 229). [13] Schauer (1982: 23, 33). [14] Mill [15] Barendt (1985: 14). [16] Greenawalt (1989a: 143-5). [17] Raz (1991: 311). [18] Sunstein (1993: xvi-xvii). [19] Scanlon (1972: 217). [20] Ibid. [21] Greenawalt (1995: 32). [22] Greenawalt (1995: 49). [23] i.e. threatening letters, vandalism and so on and so forth. [24] But may be bystanders. [25] The fact that a march in virtually every other village or even a march in the same place but without the symbols would not constitute diffuse vilification but would rather be political speech only proves the dishonest intentions of the marchers. (Feinberg 1985: 86). [26] With notable examples the anti-Semitic speeches in Nazi Germany, anti-Greek and anti-Armenian speeches in Turkey, 1910-1922 [27] Nancy Rosenblum (2008: 412-455). [28] i.e. the ban of Nazi parties from political life in Denmark [29] Margalit and Raz (1990: 119). [30] Female Genital Mutilation [31] Although not relevant to this essay, I would argue that the right of free move and work is a lot like the right to free speech in the sense that it is important but militant democracy should intervene to prevent it from harming a democratic state. A failed example of this would be Italy’s policy which only allowed a very limited percentage of immigrants. Surely, a middle position would be more successful. [32] For example, a Kurdish should have been able to reflect upon the issue of FGM before encountering an adversary of the practice.

Monday, January 20, 2020

Analysis of Pauline Puyat’s Tracks­ Essay -- Tracks

Analysis of Pauline Puyat’s Tracks ­ One of the most striking characteristics of Pauline Puyat is her devout Catholicism and her desire to be disconnected from the Ojibwa people. Throughout Tracks, she openly chooses Catholicism over her native religion and abandons her native ways almost completely. When Pauline tries to help Fleur prevent a miscarriage, she is literally held back by her conscious separation from the Ojibwa culture. There are many things that Pauline fails to do to effectively prevent Fleur from miscarrying. The most obvious is her failure to efficiently put together the herbal steep made of Alder: â€Å"And I could not remember the plant’s configuration, even though its use was common enough for bleeding problems† (156). Although Pauline could be nervously forgetting the properties of Alder, this forgetfulness of a basic remedy stresses her abandonment of Ojibwa society and its practices. The array of stored plants makes Pauline even more nervous: â€Å"Plant after Plant! Some were shaped like a man’s forked legs and some were rolled in balls...I put fort...

Sunday, January 12, 2020

Reduced scale

The reforms aimed at the eradication of poverty and unemployment challenges through substantial recovery and improvement or productivity of investment economizing the private sector as the main engine of growth. In discussing the issues of the liberalizing of cooperative policies practices and legislation its clear that the societies have both successes and failures.Successes of the liberalizing of cooperatives up to date To the cooperative movement, liberalizing measures were put in place with a view to create commercially autonomous member-based cooperatives that would be democratically and professionally managed; self-controlled; and self-reliant. To this effect in 1997 government published Session Paper No. 6 of 1997 on â€Å"Co-operatives n a Liberalized Economic Environment† to provide the new policy framework for the necessary reforms.To date the role of the government was redefined from control to regulatory and facilitative in nature. The Ministry of Co-operative Deve lopment duties were confined to registration and liquidation of co-operative societies; enforcement of the Co-operative Societies Act; formulation of co-operative policy; advisory and creation of conducive environment for co-operative growth and development; registration of co-operative audits; and carrying out of inquiries, investigations and inspections which is still applicable today.Successfully also was the enforcement of co-operative principles of voluntary and open Membership; democratic member control; member-economic participation; autonomy and independence; education, training and information; co-operation among cooperatives; and concern for community. The reforms have given autonomy to individuals will to Join or leave the cooperatives, which is still effectively being practiced, up to date. The 1966 Co- operative Societies Act was repealed and replaced by the Co-operative Societies Act, No. 2 of 1997 the new Co-operative Societies Act served to reduced government involve ment in the day-to-day management of co-operatives. Cooperatives were granted authority to rule over themselves from the previous state controls by transferring the management duties in co-operatives from the Commissioner for Co- operative Development to the members through their duly elected management committees. This trend is still applicable up to date where by members have the discretion to make policies through Coco's that benefit them. Co-operatives were no longer required to seek the permission of the Commissioner to invest, spend or borrow.They were now free to borrow against part or the whole of their properties if heir by-laws allowed, provided the annual general meeting approved such borrowing which is still applicable today. The reforms have also given cooperatives the power to hire and fire grade staff without the commissioners consent. The cooperative movement as a result of liberalizing has seen a growth in the cooperative movement with a growth in 2004 of 10,642 coo peratives in Kenya and currently the number is increasing rapidly with the inception of other better laws such as the new constitution.Despite the reducing trend of membership surprisingly there's an increase in member registration in Coco's over the years up to date new CACAOS are being formed even among the self-employed persons in the informal AU Kali) and agricultural sectors, which is a complete departure from the past where these co-operatives were only formed among the employed persons in the urban areas.To this extent, it can be said that liberation has transformed the cooperative movement and that many citizens are appreciative of it. Liberalizing of the cooperative movement has transformed the structural organization of cooperatives. The inefficient cooperative unions are increasingly loosing their members, for cooperative societies now have the freedom to seek better service provision from there organizations or make provision for such services on their own.Another advant age is that Agricultural co-operative unions have particularly been affected through monopoly. For instance, in the dairy sub-sector, co-operative societies were affiliated to the Kenya Cooperative Creameries (KC) that monopolized the processing and marketing of milk up to the early sass's. It is in these circumstances that some of them like Guthrie and Lemur dairy co-operative societies have put up their own milk processing plants that are still running up to date.With this, vertical integration f cooperatives in the dairy sector has virtually collapsed as cooperative societies now have the freedom to sell their produce to any willing buyer rather than KC and some of the societies have put up their own milk processing plants to offer the services previously provided by KC. Despite all that, non-agricultural co-operative unions have remained vibrant, particularly those in the financial sector, and have subsequently maintained the vertical structure of the cooperative movement.For ex ample, to date Kenya Union of Savings and Credit Cooperative (COUSCOUS) brings gather over 2,600 active COCO societies with a membership of over two million while the Kenya Rural Savings and Credit Cooperative Societies Union KEIRETSU has 45 active rural COCO societies with a membership of 1. 5 million. These unions serve as the mouthpieces of the respective CACAOS in the country; a feat that has helped the unions continue to attract rather than loose membership.COUSCOUS also provides common shared services like education and training; business development, consultancy and research; risk management; and the inter-lending program for CACAOS called Central Finance Program. These services have attracted CACAOS to main loyal members of COUSCOUS, and helping it attain the status of the largest COCO movement in Sub-Sahara Africa. Successfully with the current liberalizing of cooperatives most of the cooperative organizations are functioning without reference to the apex organization.The r ole of spokesperson and representative of the cooperative movement is increasingly being played by national cooperative organizations and cooperative unions. As an example, COUSCOUS being the mother of all Coco's now stands out as the mouth-piece and advocate of CACAOS in all matters that affect the development and growth of these cooperatives. COUSCOUS has been vibrant in the recent past by being vocal, in opposing the retrenchment of employee's as that would affect the membership of Cacaos.Even more significantly, COUSCOUS was recently involved in the formulation of the yet to be debated and enacted COCO Act that sets out to make special provisions for the registration and licensing of Cacaos, prudential requirements, standard forms of accounts, co-operate governance, amalgamations, divisions and liquidations; establishment of a COCO Regulatory Authority, savings protection insurance, and setting up a Central Liquidity Fund, among others. In the circumstances, the collapse of the vertical organization of the cooperative movement in the country is increasingly becoming evident.Another success of the liberalizing is that with liberalizing of the economy, banks such as The Cooperative Bank of Kenya have opened shareholding to individual members of co-operative societies as was duly recommended by their societies in 1996. The bank has however, retained its association with the co-operative movement by restricting 70% of the shares to co-operatives while individual members of societies hold only 30% of the shares and are not entitled to attend the annual general meeting of the ann.. This has helped to keep out private shareholders who might have bought out the bank as has been the case in other African countries.The coming of this policy framework also saw the International Cooperative Alliance's (CA) cooperative principles of voluntary and open membership, democratic member control; member- economic participation, autonomy and independence, education, training, cooperation among cooperatives; and concern for community became formally incorporated in the cooperative policy. The 1997 policy failed to provide for the separation of the responsibilities of elected management committees from managerial staff responsibilities.Consequently, management decisions were still made by elected leaders that may not be qualified managers. In such response to the inadequacies of the 1997 policy, the Ministry formulated a revised policy framework titled â€Å"Kenya Cooperative Development Policy 2008†. The 2008 policy themed at ‘expanding the economic space for sustainable cooperative growth in Kenya', focused on restructuring, strengthening and transforming cooperatives into vibrant economic entities that can confront the challenges of wealth creation, employment creation and poverty reduction as private business ventures.To date the policy is still up and running. After the fall of Kenya National Federation of Cooperatives KNIFE, the interim Board started developing the strategy in 2007 by holding provincial consultative meetings that focused on how to revive the organization. This culminated in the National Cooperative Leaders Conference in November in 2007, which endorsed a new governance structure, revised By-Laws (2008) and a new funding strategy.The revised By-Laws (Kenya National Federation of Cooperatives, Bibb) proposed a governance structure consisting of a secretariat composed of the Executive Director ND four heads of sections; a technical committee comprising of the Chief Executive Officers of Nachos; the General Assembly as the supreme authority consisting of 75 elected delegates; and the National Governing Council as the executive authority comprising of eight Chairmen of Nachos, seven elected regional representatives, the Commissioner for Cooperative Development and the Executive Director.The By-Laws also address the need for strengthening of the financial capacity of KNIFE, as they propose a graduated sc ale of annual contribution by members based on the type of cooperative organization and annual turnover. This amends have helped to shape the federation up to date with increased number of people. The revitalization program has charted a new direction for the organization, as it restricted its activities to the core objective for which it was formed. That is, to be the mouth-piece of the cooperative movement in Kenya by engaging in advocacy, lobbying, collaboration and networking activities.At the end of the revitalization process, the investment in institutional capacity building of KNIFE should has enabled it to address wealth creation and poverty alleviation of the cooperative movement. Liberalizing has rough about growth of banks such as the Cooperative Bank of Kenya. The Bank has not only been instrumental in providing banking services to cooperatives, but has also been the source of affordable credit for the cooperative movement. For instance, today it lends approximately EKES 3. 5 billion (USED $46. Million) annually to Cacaos, in order to increase their liquidity levels so that they can meet member demands for loans associated with school fees. Moreover, the Cooperative Bank still serves as a mechanism through which most donors to the agricultural sector, particularly those that produce coffee, can channel their support. This has allowed the Cooperative Bank to network with many donors, such as Food Aid Organization (FAA), and the European Union, among others. In the financial sector, CACAOS are also increasingly becoming innovative by developing new products to enhance their income.For instance there's some diversification of traditional products of savings and credit of Coco's by introducing Front Surviving liberalizing: the cooperative movement in Kenya Front Office Service Activity (FOSS). FOSS offers services that members can use to process their monthly salary, while having access to instant cash advances (based n their salary) and maintaining wi thdrawal savings deposits. Currently, slightly over 250 CACAOS operate with this activity in Kenya.In addition, the COCO movement is quickly spreading from its traditional urban and wage employment strongholds into the agricultural sector in rural areas and informal economy. As a success liberalizing has enabled the setup of free market cooperative entities that have led many people to derive their Jobs from marketing products produced by cooperatives. For instance, dairy cooperatives produce various products such as fresh ilk, ghee, butter and yoghurt; while other agricultural cooperatives market coffee, fish, pyrometer and eggs. These products are then passed on to other entities to market to retailers, wholesalers and consumers.To date this trend continues and has helped reduce poverty and provide employment as it was the expectation of the 1996 framework policy paper. Liberalizing has made Cooperatives to be sources of income by generating opportunities for many people, particul arly members of cooperatives. In 2007, primary cooperatives in the agricultural sector had a membership of 1 approximately 50% of whom were estimated to be active. The CACAOS had 6,286,894 members, 98% whom were active in the lending activities of their cooperatives. The other non-agricultural primary cooperatives had a total membership of 334,000, with approximately 50 per cent active.These figures are clear pointers to the significant contribution of cooperatives to poverty reduction and poverty prevention in Kenya to date. This is particularly true as most of the income generated from cooperatives is mainly used to address long-term poverty prevention measures. Liberalizing has brought focus on cooperatives to the core activities of operatives, including agribusiness, entrepreneurship, savings and credit advancement regulations, leadership and governance of cooperatives, and the economic benefits of membership in cooperatives, among others.It is apparent that any cooperative that doesn't provide Economic gains in Kenya tends to be deserted by the members. This is evidenced by dormancy that cooperatives are currently experiencing. A few activities of such successful cooperative ventures could be viewed as attempts at offering social protection to the members and this has brought the growth in some cooperatives in the country. As an advantage the framework policy has seen transformation of the cooperative movement where benevolent funds have been introduced in most CACAOS to which members contribute regularly and only draw from them when they are bereaved.The schemes define the relatives in whose death the member would get assistance to meet the burial expenses, as well as the respective amount of money to which he/ she would be entitled. Gracefully the institutionalizing of the framework paper policy and liberalizing has seen the transformation of the Cooperative Insurance Company(ClC). This company has the ore business of giving protection against risks ass ociated with operation of cooperative enterprise, as well as cooperators themselves.Significant ICC has also developed a micro-finance insurance scheme specifically for covering savings of micro-finance institutions (Miff) in case a person with a loan passes away before completing repayment. Negative aspects of the liberalizing of cooperatives Consequently, the immediate impact on most co-operatives was mainly negative. The elected leaders abused the freedom bestowed on them and to the detriment of many cooperative societies.Corruption cases; gross mismanagement by officials; theft of operative resources; split of viable co-operatives into small uneconomic units; failure by employers to surrender members' deposits to co-operatives (particularly Cacaos); failure to hold elections in co-operatives; favoritism in hiring and dismissal of staff; refusal by co-operative officials to vacate office after being duly voted out; conflict of interest among co-operative officials; endless litiga tion; unauthorized co- operative investments; and illegal payments to the management committees were increasingly reported in many co-operatives and up to date the trend is till continuing though at a reduced scale.Though there's a surge of cooperative societies the indication is that up to date there's recorded numbers of dormant cooperative societies. In 2004, the Kenya Union of Savings and credit cooperatives actually estimated that 42% of the cooperative societies were dormant. The number is still increasing and this isn't beneficial to the eradication of poverty through employment and innovation. The relative poor performance of agricultural cooperatives could also be attributed to the liberalizing of the co-operative sector without adequately preparing the co-operatives. There's also the element of over dependence of the agriculture sector, which leads to failure unexpectedly. Liberalizing has brought about immense changes in the cooperative movement.The Kenya National Federat ion of Cooperatives was the national apex of cooperative movements in Kenya. Its dominance declined drastically due to corruption and mismanagement reason being that poor management over the years saw KNIFE deviate from its core business into other activities, such as auditing, education and training as well as research and consultancy. Such activities were already being performed by some of its members, and subsequently KNIFE ended up competing with some of its members hat were offering the same services to the cooperative movement. In the circumstances some cooperatives found no reason for being members of a federation that they saw as a competitor.However its quick revival was established in 2005 after the then minister of cooperatives dissolved Knife's Board of Directors and replaced it with an interim board (Kenya National Federation of Cooperatives, AAA). Interim Board of Directors that was appointed by the Minister in May 2005 immediately embarked upon developing strategies f or reform and restructuring to revivalist the organization (Kenya National Federation of Cooperatives, 2007). As a active impact KNIFE has largely been ineffective in representing the cooperative movement during policy and legal processes. As an example, it failed to effectively participate and influence changes to the 1997 Cooperative Societies Act that produced the Cooperative Societies (Amendment) Act, 2004.KNIFE started monopolizing donor support after the ACT had been enacted to hold consultations on the implications of the Act, which was too late to achieve any impact. Perhaps this also explains the absence of cooperatives in national development debates. KNIFE has lacked even up to date the urge to influence policy and legislative debates in Kenya, aging it difficult to improve the visibility of the cooperative movement. This is surely a liberalizing downfall a thing that the paper framework couldn't expect to happen. As a negative effect liberalizing has reduced government s upport since autonomy was given to the private sector this free market approach has unfortunately brought to the decline of, the number of trainees from Cooperative college of Kenya.Cooperatives attending the college have been reducing since the liberalizing due to the tremendous reduction in government sponsorship to the cooperative movement for training purposes. Left on their own, most cooperatives, especially in the agricultural sector, have been unable to raise the required fees for their staff to train at the college. CONCLUSION In conclusion, the impact of liberalizing has seen cooperatives survive the market forces and open up more enterprising innovations that secure the welfare of employees. Successfully much legislation has been put in place that is still working up to date and this has helped to attract more members to cooperatives. On the downside corruption is still rampant as the societies grow new schemes are being hatched to hamper the progress of the cooperatives.

Saturday, January 4, 2020

Immigration and U.S. Citizenship - Free Essay Example

Sample details Pages: 4 Words: 1259 Downloads: 6 Date added: 2019/04/12 Category Society Essay Level High school Tags: Citizenship Essay Did you like this example? Citizenship is hard to come by for immigrants currently living in the United States. Immigrants, whether here illegally or not, make up for about thirty-five million of the population. Each individual or family came to the United States for their own reasons. Some left their own country due to war or hard times while others better lives. The immigrants who are already in the United States have an opportunity to become a citizen, but the process may take years. Should both legal and illegal immigrants be able to get citizenship? Currently, there are two different types of immigrants. Those who came to the United States lawfully and those who came undocumented or illegally. Nearly 34 million lawful immigrants live in the United States (Krogstad 1) and in addition, roughly 1 million unauthorized immigrants have temporary permission to live and work in the U.S. (Krogstad 1). There is a program going on that is directed to the families who have lasting residency that allows a person from the outside to have a green card as long as they have immediate family members living as an actual U.S. citizen. This helps secure rights to safely live in the United States. Without it, becoming a citizen would become harder. Don’t waste time! Our writers will create an original "Immigration and U.S. Citizenship" essay for you Create order Illegal immigrants may have come for no bad intentions at all, but at the White House, they are [considered] [outsiders], criminals who [risk] American neighborhoods, take American jobs, [take] American resources and [take advantage of] American generosity (Yee 2). Those illegal immigrants just wanted to come to the country to get to a better place. To the people in the office, the immigrants are no more than taking everything America has to offer. The most common type people to be associated with immigration are the Mexicans. This is not true as almost a quarter are not even Hispanic (Yee 2). Despite all this, these immigrants tend to follow the laws and doing everything a typical American family does. The Trump administration still says just being in the United States without any clear authorization is illegal. The Obama administration had a different approach to this. Any illegal immigrant who did not do any major crimes would be allowed to stay; as long as those same immigrants c heck in with an immigration agent every year, they are free to stay and continue working. The Trump administration is still going to deport immigrants with severe criminal records, but the new policies also take aim at immigrants whose offenses are limited to living here without permission or minor crimes that enable immigrants to work (Yee 6). The immigrants had no choice in getting what they need to work. They may have used fake Social Security numbers, but what other way would they get what they need to work without risking going back to where they originated? The immigrants have also been driving without a drivers license. They may have been doing something illegal, but they did it to support their families. To prevent this, visas are given to the immigrants that register for it. Visas tend to expire. Once they do, it may be difficult to renew them. Nothing may be done and [s]ome people think [the immigrants] come [to the United States] and overstay their visas intentionally (Yee 9). Overstaying the visas causes all the current families to risk deportation. There is l ittle that can be done to prevent going back to where they originated. A person may have an expired visa despite having a good job and a steady life. Rebeca, whose last name remains hidden for personal concerns, was one of these victims of having her visa expired. She was originally from Venezuela working as a television reporter. In the United States, she found work as a nanny, then got a job as a designer at a clothing business in Southern California (Yee, 9). The only reason why she left Venezuela was so she can avoid all the death threats and attacks she was receiving. This is an example of how just one person, who got a better life, can have everything taken away from them. One proposal to stop anyone from immigrating to their family for a green card is a sort of point-based system. How the system works is it prioritizes the admission of immigrants with certain education and employment qualifications (Krogstad 2). The system would favor more immigrants who would have a higher education than most other immigrants. Without a proper qualification in education, it is most likely they will not make it into citizenship. Being an optimal worker may counter education, but no matter the case there will always be someone left out. This system would help the American people keep their jobs by limiting the number of immigrants that come in. With constant complaints about immigrants taking their jobs, they wouldnt have to worry about it if the point-based system passes under the current administration. Another method for immigrants receiving green cards is the visa lottery. This sort of lottery lets about 50,000 people receive green cards (Krogstad 3). Immigrants that benefit more from this are the ones who came from countries that arent represented well. This means more well-known countries cant benefit from it. Two of these countries that cant benefit from it are Mexico and China. They are unable to gain any visas through the lottery because they have a bigger presence in America. Such situation isnt so bad as the population would go on to being diverse with lesser known countries. President Trump wants this sort of lottery to be gone. Removing a random lottery would stop more immigrants coming into the United States. Simply decreasing the population of the immigrants would be increasing any sort of jobs available. The Trump administration is focusing on making more jobs for the available public. Cutting out programs that are in place brings those jobs for the American people. Simply getting a visa takes from ten to twenty years. During the 18th century, there were no illegal immigrants in the United States (Cohen 1). The only ones there who would be close to being illegal were the British Loyalists. These Loyalists were the very same ones who fought back the Americans during the Revolutionary War. When America was formed, the Loyalists wanted to be citizens. Surprisingly, they and their families made up approximately 20 percent of the population (Cohen 1). A case was held in the Supreme Court in the year of 1805. This case made the Loyalists citizens. Not only did the case provide citizenship for the Loyalists, they also provided the foundation to creating citizenship to the immigrants who would come into the United States on their own free will. This may be the case as of now, but the American people still dont want the illegal immigrants to be citizens. They are afraid that the undocumented or temporary workers who have lived [in America] for years will trivialize [the] immigration laws (Cohen 3). With so many undocumented immigrants and temporary workers in the country, immigration laws would start to seem irrelevant. Immigrants should be given their opportunities to get citizenship. It shouldnt matter if they came to the United States illegally or not. These immigrants have left their countries to be able to escape their past or get away from war. Visas are helpful, but it would only last for a limited time; once that visa expires, deportation would be imminent. Everything they have worked for during the visa would be gone. Coming to the United States illegally is a risk in itself, so earning the right to become a citizen for both legal and illegal immigrants should be rewarding.