title: Defense of Marriage Act

text: In "Baehr v. Miike" (1993), the Supreme Court of Hawaii ruled that the state must show a compelling interest in prohibiting same-sex marriage. This finding prompted concern among opponents of same-sex marriage, who feared that same-sex marriage might become legal in Hawaii and that other states would recognize or be compelled to recognize those marriages under the Full Faith and Credit Clause of the United States Constitution. The House Judiciary Committee's 1996 Report called for DOMA as a response to "Baehr", because "a redefinition of marriage in Hawaii to include homosexual couples could make such couples eligible for a whole range of federal rights and benefits".


title: Defense of Marriage Act

text: Georgia Representative Bob Barr, then a Republican, authored the Defense of Marriage Act and introduced it in the House of Representatives on May 7, 1996. Senator Don Nickles, (R) Oklahoma, introduced the bill in the Senate. The House Judiciary Committee stated that the Act was intended by Congress to "reflect and honor a collective moral judgment and to express moral disapproval of homosexuality". The Act's congressional sponsors stated, "[T]he bill amends the U.S. Code to make explicit what has been understood under federal law for over 200 years; that a marriage is the legal union of a man and a woman as husband and wife, and a spouse is a husband or wife of the opposite sex."


title: Defense of Marriage Act

text: Nickles said, "If some state wishes to recognize same-sex marriage, they can do so". He said the bill would ensure that "the 49 other states don't have to and the Federal Government does not have to." In opposition to the bill, Colorado Rep. Patricia Schroeder said, "You can't amend the Constitution with a statute. Everybody knows that. This is just stirring the political waters and seeing what hate you can unleash." Barr countered that the Full Faith and Credit Clause of the Constitution grants Congress power to determine "the effect" of the obligation of each state to grant "full faith and credit" to other states' acts.


title: Defense of Marriage Act

text: The 1996 Republican Party platform endorsed DOMA, referencing only Section 2 of the act: "We reject the distortion of [anti-discrimination] laws to cover sexual preference, and we endorse the Defense of Marriage Act to prevent states from being forced to recognize same-sex unions." The Democratic Party platform that year did not mention DOMA or same-sex marriage. In a June 1996 interview in the gay and lesbian magazine "The Advocate", Clinton said, "I remain opposed to same-sex marriage. I believe marriage is an institution for the union of a man and a woman. This has been my long-standing position, and it is not being reviewed or reconsidered." But he also criticized DOMA as "divisive and unnecessary".


title: Defense of Marriage Act

text: The bill moved through Congress on a legislative fast track and met with overwhelming approval in both houses of the Republican-controlled Congress. On July 12, 1996, with only 65 Democrats and then Rep. Bernie Sanders (I-VT) and Rep. Steve Gunderson (R-WI), in opposition, 342 members of the U.S. House of Representatives—224 Republicans and 118 Democrats—voted to pass DOMA. On September 10, 1996, 84 Senators, a majority of the Democratic Senators, including Joe Biden, and all of the Republicans—voted in favor of DOMA. Democratic Senators voted for the bill 32 to 14 (with Pryor of Arkansas absent), and Democratic Representatives voted for it 118 to 65, with 15 not participating. All Republicans in both houses voted for the bill with the sole exception of the one openly gay Republican Congressman, Rep. Steve Gunderson of Wisconsin.


title: Defense of Marriage Act

text: While his stated position was against same-sex marriage, Clinton criticized DOMA as "unnecessary and divisive", and his press-secretary called it "gay baiting, plain and simple". However, after Congress had passed the bill with enough votes to override a presidential veto, Clinton signed DOMA. Years later, he said that he did so reluctantly in view of the veto-proof majority, both to avoid associating himself politically with the then-unpopular cause of same-sex marriage and to defuse momentum for a proposed Federal Amendment to the U.S. Constitution banning same-sex marriage. Clinton, who was traveling when Congress acted, signed it into law promptly upon returning to Washington, D.C., on September 21, 1996; no signing ceremony was held for DOMA and no photographs were taken of him signing it into law. The White House released a statement in which Clinton said "that the enactment of this legislation should not, despite the fierce and at times divisive rhetoric surrounding it, be understood to provide an excuse for discrimination, violence or intimidation against any person on the basis of sexual orientation". Even so, later the same year Clinton ran ads on Christian radio stations nationwide promoting how he'd signed DOMA into force. The ads were pulled after massive blowback from LGBT groups.


title: Defense of Marriage Act

text: In 2013, Mike McCurry, the White House press secretary at the time, recalled that Clinton's "posture was quite frankly driven by the political realities of an election year in 1996." James Hormel, who was appointed by Clinton as the first openly gay U.S. Ambassador, described the reaction from the gay community to Clinton signing DOMA as shock and anger. On Hormel's account, Clinton had been the first President to advocate gay rights, push for AIDS funding, support gay and lesbian civil rights legislation, and appoint open LGBT people to his administration. Thus his signing of DOMA was viewed by much of the community as a great betrayal.


title: Defense of Marriage Act

text: Clinton did not mention DOMA in his 2004 autobiography. However, Sasha Issenberg, the author of "The Engagement: America's Quarter-Century Struggle Over Same-Sex Marriage", has noted that Clinton made no speaking reference to the issue of gay marriage prior to May 1996, but that during to this time, he did make written comments such as “homosexual couples should have the right to get married,” “I’ve taken a very strong stand against any discrimination against gays and lesbians,” and that “but I don’t favor a law to legalize marriages.” Over time, Clinton's public position on same-sex marriage shifted. He spoke out against the passage of California's Proposition 8 and recorded robocalls urging Californians to vote against it. In July 2009, he officially came out in support for same-sex marriage.


title: Defense of Marriage Act

text: On August 13, 2009, during Netroots Nation, when confronted by LGBT activist Lane Hudson, Clinton explained that he had to sign DOMA in order to prevent a constitutional amendment that would proscribe same-sex marriage: "We were attempting at the time, in a very reactionary Congress, to head off an attempt to send a constitutional amendment banning gay marriage to the states. And if you look at the eleven referenda much later—in 2004, in the election—which the Republicans put on the ballot to try to get the base vote for President Bush up, I think it's obvious that something had to be done to try to keep the Republican Congress from presenting that."


title: Defense of Marriage Act

text: In an op-ed written on March 7, 2013, for "The Washington Post", Clinton again suggested that DOMA was necessary in order to preclude, at that time, the passage of a constitutional amendment banning same-sex marriage and urged the Supreme Court, which would shortly hear arguments on "United States v. Windsor", to overturn DOMA.


title: Defense of Marriage Act

text: Clinton's explanation for signing DOMA has been disputed by gay rights activist Elizabeth Birch: "In 1996, I was President of the Human Rights Campaign, and there was no real threat of a Federal Marriage Amendment. That battle would explode about eight years later, in 2004, when President Bush announced it was a central policy goal of his administration to pass such an amendment."


title: Defense of Marriage Act

text: Evan Wolfson, who in 1996 ran the National Freedom to Marry Coalition, while an attorney at Lambda Legal, has also criticized the suggestion that DOMA was stopping something worse: "That's complete nonsense. There was no conversation about something 'worse' until eight years later. There was no talk of a constitutional amendment, and no one even thought it was possible—and, of course, it turned out it wasn't really possible to happen. So, the idea that people were swallowing DOMA in order to prevent a constitutional amendment is really just historic revisionism and not true. That was never an argument made in the '90s."


title: Defense of Marriage Act

text: However, political discussion of the possibility of using a constitutional amendment to restrict marriage rights was not unheard of in the 1990s. In January 1996, for example, the House Judiciary Committee for the state of Hawaii voted 12–1 in favor of passing bill HB 117, which was aimed at amending the constitution of Hawaii to define marriage as involving one man and one woman. In 1998, the first anti-same-sex marriage amendment was added to the constitution of a U.S. state (Alaska), Contrary to the allegations that there was no talk of a Federal Marriage Amendment until 2004, Congressional records show that such an amendment was in fact proposed in the U.S. House of Representatives in 2002.


title: Defense of Marriage Act

text: The General Accounting Office issued a report in 1997 identifying "1,049 federal statutory provisions classified to the United States Code in which benefits, rights, and privileges are contingent on marital status or in which marital status is a factor". In updating its report in 2004, the GAO found that this number had risen to 1,138 as of December 31, 2003. With respect to Social Security, housing, and food stamps, the GAO found that "recognition of the marital relationship is integral to the design of the program[s]." The report also noted several other major program categories that were affected—veterans' benefits, including pensions and survivor benefits; taxes on income, estates, gifts, and property sales; and benefits due federal employees, both civilian and military—and identified specifics such as the rights of the surviving spouse of a creator of copyrighted work and the financial disclosure requirements of spouses of Congress members and certain officers of the federal government. Education loan programs and agriculture price support and loan programs also implicate spouses. Financial aid to "family farms" for example, is restricted to those in which "a majority interest is held by individuals related by marriage or blood."


title: Defense of Marriage Act

text: Because the federal Employee Retirement Income Security Act (ERISA) controls most employee benefits provided by private employers, DOMA removed some tax breaks for employers and employees in the private sector when it comes to health care, pension, and disability benefits to same-sex spouses on an equal footing with opposite-sex spouses. ERISA does not affect employees of state and local government or churches, nor does it extend to such benefits as employee leave and vacation.


title: Defense of Marriage Act

text: Under DOMA, persons in same-sex marriages were not considered married for immigration purposes. U.S. citizens and permanent residents in same-sex marriages could not petition for their spouses, nor could they be accompanied by their spouses into the U.S. on the basis of a family or employment-based visa. A non-citizen in such a marriage could not use it as the basis for obtaining a waiver or relief from removal from the U.S.


title: Defense of Marriage Act

text: Following the end of the U.S. military's ban on service by open gays and lesbians, "Don't ask, don't tell," in September 2011, Admiral Mike Mullen, Chairman of the Joint Chiefs of Staff, noted that DOMA limited the military's ability to extend the same benefits to military personnel in same-sex marriages as their peers in opposite-sex marriages received, notably health benefits. Same-sex spouses of military personnel were denied the same access to military bases, legal counseling, and housing allowances provided to different-sex spouses.


title: Defense of Marriage Act

text: The 2000 Republican Party platform endorsed DOMA in general terms and indicated concern about judicial activism: "We support the traditional definition of 'marriage' as the legal union of one man and one woman, and we believe that federal judges and bureaucrats should not force states to recognize other living arrangements as marriages." The Democratic Party platform that year did not mention DOMA or marriage in this context.


title: Defense of Marriage Act

text: In 2004, President George W. Bush endorsed a proposed constitutional amendment to restrict marriage to opposite-sex couples because he found DOMA to be vulnerable: "After more than two centuries of American jurisprudence and millennia of human experience, a few judges and local authorities are presuming to change the most fundamental institution of civilization. Their actions have created confusion on an issue that requires clarity." In January 2005, however, he said he would not lobby on its behalf, since too many U.S. senators thought DOMA would not survive a constitutional challenge.


title: Defense of Marriage Act

text: President Barack Obama's 2008 political platform endorsed the repeal of DOMA. On June 12, 2009, the Justice Department issued a brief defending the constitutionality of DOMA in the case of "Smelt v. United States", continuing its longstanding practice of defending all federal laws challenged in court. On June 15, 2009, Human Rights Campaign President Joe Solmonese wrote an open letter to Obama that asked for actions to balance the DOJ's courtroom position: "We call on you to put your principles into action and send legislation repealing DOMA to Congress." A representative of Lambda Legal, an LGBT impact litigation and advocacy organization, noted that the Obama administration's legal arguments omitted the Bush administration's assertion that households headed by opposite-sex spouses were better at raising children than those headed by same-sex spouses.


title: Defense of Marriage Act

text: On February 23, 2011, Attorney General Eric Holder released a statement regarding lawsuits challenging DOMA Section 3. He wrote:


title: Defense of Marriage Act

text: After careful consideration, including a review of my recommendation, the President has concluded that given a number of factors, including a documented history of discrimination, classifications based on sexual orientation should be subject to a more heightened standard of scrutiny. The President has also concluded that Section 3 of DOMA, as applied to legally married same-sex couples, fails to meet that standard and is therefore unconstitutional. Given that conclusion, the President has instructed the Department not to defend the statute in such cases.


title: Defense of Marriage Act

text: He also announced that although it was no longer defending Section 3 in court, the administration intended to continue to enforce the law "unless and until Congress repeals Section 3 or the judicial branch renders a definitive verdict against the law's constitutionality."


title: Defense of Marriage Act

text: In a separate letter to Speaker of the House John Boehner, Holder noted that Congress could participate in these lawsuits.


title: Defense of Marriage Act

text: On February 24, the Department of Justice notified the First Circuit Court of Appeals that it would "cease to defend" "Gill" and "Massachusetts" as well. On July 1, 2011, the DOJ, with a filing in "Golinski", intervened for the first time on behalf of a plaintiff seeking to have DOMA Section 3 ruled unconstitutional, arguing that laws that use sexual orientation as a classification need to pass the court's intermediate scrutiny standard of review. The DOJ made similar arguments in a filing in "Gill" on July 7.


title: Defense of Marriage Act

text: In June 2012, filing an amicus brief in "Golinski", two former Republican Attorneys General, Edwin Meese and John Ashcroft, called the DOJ's decision not to defend DOMA Section 3 "an unprecedented and ill-advised departure from over two centuries of Executive Branch practice" and "an extreme and unprecedented deviation from the historical norm".


title: Defense of Marriage Act

text: On March 4, 2011, Boehner announced that the Bipartisan Legal Advisory Group (BLAG) would convene to consider whether the House of Representatives should defend DOMA Section 3 in place of the Department of Justice, and on March 9 the committee voted 3–2 to do so.


title: Defense of Marriage Act

text: On April 18, 2011, House leaders announced the selection of former United States Solicitor General Paul Clement to represent BLAG. Clement, without opposition from other parties to the case, filed a motion to be allowed to intervene in the suit "for the limited purpose of defending the constitutionality of Section III" of DOMA. On April 25, 2011, King & Spalding, the law firm through which Clement was handling the case, announced it was dropping the case. On the same day, Clement resigned from King & Spalding in protest and joined Bancroft PLLC, which took on the case. The House's initial contract with Clement capped legal fees at $500,000, but on September 30 a revised contract raised the cap to $1.5 million. A spokesman for Boehner explained that BLAG would not appeal in all cases, citing bankruptcy cases that are "unlikely to provide the path to the Supreme Court...[E]ffectively defending [DOMA] does not require the House to intervene in every case, especially when doing so would be prohibitively expensive."


title: Defense of Marriage Act

text: Numerous plaintiffs have challenged DOMA. Prior to 2009, all federal courts upheld DOMA in its entirety.


title: Defense of Marriage Act

text: Later cases focused on Section 3's definition of marriage. The courts, using different standards, have all found Section 3 unconstitutional. Requests for the Supreme Court to hear appeals were filed in five cases, listed below (with Supreme Court docket numbers):


title: Defense of Marriage Act

text: "Golinski v. Office of Personnel Management" was a challenge to Section 3 of DOMA in federal court based on a judicial employee's attempt to receive spousal health benefits for her partner. In 2008, Karen Golinski, a 19-year employee of the Ninth Circuit Court of Appeals, applied for health benefits for her wife. When the application was denied, she filed a complaint under the Ninth Circuit's Employment Dispute Resolution Plan. Chief Judge Alex Kozinski, in his administrative capacity, ruled in 2009 that she was entitled to spousal health benefits, but the Office of Personnel Management (OPM) announced that it would not comply with the ruling.


title: Defense of Marriage Act

text: On March 17, 2011, U.S. District Judge Jeffrey White dismissed the suit on procedural grounds but invited Golinski to amend her suit to argue the unconstitutionality of DOMA Section 3, which she did on April 14. Following the Attorney General's decision to no longer defend DOMA, the Bipartisan Legal Advisory Group (BLAG), an arm of the House of Representatives, took up the defense. Former United States Solicitor General Paul Clement filed, on BLAG's behalf, a motion to dismiss raising arguments previously avoided by the Department of Justice: that DOMA's definition of marriage is valid "because only a man and a woman can beget a child together, and because historical experience has shown that a family consisting of a married father and mother is an effective social structure for raising children." On July 1, 2011, the DOJ filed a brief in support of Golinski's suit, in which it detailed for the first time its case for heightened scrutiny based on "a significant history of purposeful discrimination against gay and lesbian people, by governmental as well as private entities" and its arguments that DOMA Section 3 fails to meet that standard.


title: Defense of Marriage Act

text: On February 22, 2012, White ruled for Golinski, finding DOMA "violates her right to equal protection of the law under the Fifth Amendment to the United States Constitution." He wrote that Section 3 of DOMA could not pass the "heightened scrutiny" or the "rational basis" test. He wrote,


title: Defense of Marriage Act

text: The Court finds that neither Congress' claimed legislative justifications nor any of the proposed reasons proffered by BLAG constitute bases rationally related to any of the alleged governmental interests. Further, after concluding that neither the law nor the record can sustain any of the interests suggested, the Court, having tried on its own, cannot conceive of any additional interests that DOMA might further.


title: Defense of Marriage Act

text: While the case was on appeal to the Ninth Circuit, on July 3, 2012, the DOJ asked the Supreme Court to review the case before the Ninth Circuit decides it so it can be heard together with two other cases in which DOMA Section 3 was held unconstitutional, "Gill v. Office of Personnel Management" and "Massachusetts v. United States Department of Health and Human Services". The Supreme Court chose to hear "Windsor" instead of these cases, and following the Supreme Court decision in "Windsor" the Ninth Circuit dismissed the appeal in "Golinski" with the consent of all parties on July 23.


title: Defense of Marriage Act

text: On March 3, 2009, GLAD filed a federal court challenge, "Gill v. Office of Personnel Management", based on the Equal Protection Clause and the federal government's consistent deference to each state's definition of marriage prior to the enactment of DOMA. The case questioned only the DOMA provision that the federal government defines marriage as the union of a man and a woman. On May 6, 2010, Judge Joseph L. Tauro heard arguments in the U.S. District Court in Boston.


title: Defense of Marriage Act

text: On July 8, 2009, Massachusetts Attorney General Martha Coakley filed a suit, "Massachusetts v. United States Department of Health and Human Services", challenging the constitutionality of DOMA. The suit claims that Congress "overstepped its authority, undermined states' efforts to recognize marriages between same-sex couples, and codified an animus towards gay and lesbian people." Tauro, the judge also handling "Gill", heard arguments on May 26, 2010.


title: Defense of Marriage Act

text: On July 8, 2010, Tauro issued his rulings in both "Gill" and "Massachusetts", granting summary judgment for the plaintiffs in both cases. He found in "Gill" that Section 3 of the Defense of Marriage Act violates the equal protection of the laws guaranteed by the Due Process Clause of the Fifth Amendment to the U.S. Constitution. In "Massachusetts" he held that the same section of DOMA violates the Tenth Amendment and falls outside Congress' authority under the Spending Clause of the Constitution. Those decisions were stayed after the DOJ filed an appeal on October 12, 2010.


title: Defense of Marriage Act

text: On November 3, 2011, 133 House Democrats filed an amicus brief in support of the plaintiffs in "Gill" and "Massachusetts", asserting their belief that Section 3 of DOMA was unconstitutional. Included among the members of Congress signing the brief were 14 members who had voted for the bill in 1996. Seventy major employers also filed an amicus brief supporting the plaintiffs. A three-judge panel heard arguments in the case on April 4, 2012, during which the DOJ for the first time took the position that it could not defend Section 3 of DOMA under any level of scrutiny. On May 31, 2012, the panel unanimously affirmed Tauro's ruling, finding Section 3 of DOMA unconstitutional. On June 29, BLAG filed a petition for certiorari with the Supreme Court. The DOJ did so on July 3, while asking the Supreme Court to review "Golinski" as well. The Commonwealth of Massachusetts filed a response to both petitions adding the Spending Clause and Tenth Amendment issues as questions presented. The Supreme Court denied these petitions on June 27, 2013, following its decision in "Windsor".


title: Defense of Marriage Act

text: On November 9, 2010, the American Civil Liberties Union filed "United States v. Windsor" in New York on behalf of a surviving same-sex spouse whose inheritance from her deceased spouse had been subject to federal taxation as if they were unmarried. New York is part of the Second Circuit, where no precedent exists for the standard of review to be followed in sexual-orientation discrimination cases.


title: Defense of Marriage Act

text: New York Attorney General Eric Schneiderman filed a brief supporting Windsor's claim on July 26, 2011.


title: Defense of Marriage Act

text: On June 6, 2012, Judge Barbara Jones ruled that based on rational basis review Section 3 of DOMA is unconstitutional and ordered the requested tax refund be paid to Windsor. The plaintiff commented, "It's thrilling to have a court finally recognize how unfair it is for the government to have treated us as though we were strangers." Windsor's attorneys filed a petition of certiorari with the Supreme Court on July 16, asking for the case to be considered without waiting for the Second Circuit's review. On October 18, the Second Circuit Court of Appeals upheld the lower court's ruling that Section 3 of DOMA is unconstitutional. According to an ACLU press release, this ruling was "the first federal appeals court decision to decide that government discrimination against gay people gets a more exacting level of judicial review". In an opinion authored by Chief Judge Dennis Jacobs, the Second Circuit Court of Appeals stated:


title: Defense of Marriage Act

text: Our straightforward legal analysis sidesteps the fair point that same-sex marriage is unknown to history and tradition, but law (federal or state) is not concerned with holy matrimony. Government deals with marriage as a civil status—however fundamental—and New York has elected to extend that status to same-sex couples.


title: Defense of Marriage Act

text: On December 7, 2012, the Supreme Court agreed to hear the case. Oral arguments were heard on March 27, 2013. In a 5–4 decision on June 26, 2013, the Court ruled Section 3 of DOMA to be unconstitutional, declaring it "a deprivation of the liberty of the person protected by the Fifth Amendment."


title: Defense of Marriage Act

text: On July 18, 2013, the Bipartisan Legal Advisory Group (BLAG), which had mounted a defense of Section 3 when the administration declined to, acknowledged that in "Windsor" "[t]he Supreme Court recently resolved the issue of DOMA Section 3's constitutionality" and said "it no longer will defend that statute."


title: Defense of Marriage Act

text: "Pedersen v. Office of Personnel Management" is a case filed by GLAD in Connecticut on behalf of same-sex couples in Connecticut, Vermont, and New Hampshire, in which GLAD repeats the arguments it made in "Gill".


title: Defense of Marriage Act

text: On July 31, 2012, Judge Vanessa Lynne Bryant ruled that "having considered the purported rational bases proffered by both BLAG and Congress and concluded that such objectives bear no rational relationship to Section 3 of DOMA as a legislative scheme, the Court finds that that no conceivable rational basis exists for the provision. The provision therefore violates the equal protection principles incorporated in the Fifth Amendment to the United States Constitution." She held that "laws that classify people based on sexual orientation should be subject to heightened scrutiny by courts" but determined Section 3 of DOMA "fails to pass constitutional muster under even the most deferential level of judicial scrutiny." The case was appealed to the Second Circuit, and on August 21, 2012, Pedersen asked the Supreme Court to review the case before the Second Circuit decides it so it can be heard together with "Gill v. Office of Personnel Management" and "Massachusetts v. United States Department of Health and Human Services". The Supreme Court denied these petitions on June 27, 2013, following its decision in "Windsor".


title: Defense of Marriage Act

text: On October 13, 2011, Carmen Cardona, a U.S. Navy veteran, filed a lawsuit in the United States Court of Appeals for Veterans Claims seeking disability benefits for her wife that the Veterans Administration and the Board of Veterans Appeals had denied. Cardona is represented by the Yale Law School Legal Services Clinic. At the request of BLAG, which is defending the government's action, and over Cardona's objections, the court postponed oral argument in "Cardona v. Shinseki" pending the Supreme Court's disposition of writs of certiorari in other DOMA cases.


title: Defense of Marriage Act

text: On October 27, 2011, the Servicemembers Legal Defense Network (SLDN) brought suit in federal court on behalf of several military servicemembers and veterans in same-sex marriages. In a November 21 filing in the case of "McLaughlin v. Panetta", they wrote, "Any claim that DOMA, as applied to military spousal benefits, survives rational basis review is strained because paying unequal benefits to service members runs directly counter to the military values of uniformity, fairness and unit cohesion." The benefits at issue include medical and dental benefits, basic housing and transportation allowances, family separation benefits, visitation rights in military hospitals, and survivor benefit plans. The case was assigned to Judge Richard G. Stearns. One of the plaintiffs in the case, lesbian Charlie Morgan, who was undergoing chemotherapy, met with an assistant to Boehner on February 9, 2012, to ask him to consider not defending DOMA. The case is on hold at the request of both sides in anticipation of the outcome of two other First Circuit cases on appeal, "Gill v. Office of Personnel Management" and "Massachusetts v. United States Department of Health and Human Services". On February 17, the DOJ announced it could not defend the constitutionality of the statutes challenged in the case. In May 2012, the parties filed briefs arguing whether BLAG has a right to intervene. On June 27, Stearns asked the parties to explain by July 18 why given the decision in "Windsor" he should not find for the plaintiffs. On July 18, BLAG's response acknowledged that "[t]he Supreme Court recently resolved the issue of DOMA Section 3's constitutionality" and asked to be allowed to withdraw from the case. It took no position on the two statutes at issue in the case, which define a "spouse" as "a person of the opposite sex", except to say that "the question of whether [that definition] is constitutional remains open".


title: Defense of Marriage Act

text: Tracey Cooper-Harris, an Army veteran from California, sued the Veterans Administration and the DOJ in federal court on February 1, 2012, asking for her wife to receive the benefits normally granted to spouses of disabled veterans. BLAG sought a delay in "Cooper-Harris v. United States" pending the resolution of "Golinski", which the attorneys for Cooper-Harris, the Southern Poverty Law Center, opposed. The court denied BLAG's motion on August 4. In February 2013, Judge Consuelo Marshall rejected the DOJ's argument that the case could only be heard by the Board of Veterans' Appeals and allowed the case to proceed. BLAG asked to withdraw from the lawsuit on July 22.


title: Defense of Marriage Act

text: In May 2011, DOMA-based challenges by the Department of Justice to joint petitions for bankruptcy by married same-sex couples were denied in two cases, one in the Southern District of New York on May 4 and one in the Eastern District of California on May 31. Both rulings stressed practical considerations and avoided ruling on DOMA.


title: Defense of Marriage Act

text: On June 13, 2011, 20 of the 25 judges of the U.S. Bankruptcy Court for the Central District of California signed an opinion in the case "in re Balas and Morales" that found that a same-sex married couple filing for bankruptcy "have made their case persuasively that DOMA deprives them of the equal protection of the law to which they are entitled." The decision found DOMA Section 3 unconstitutional and dismissed BLAG's objections to the joint filing:


title: Defense of Marriage Act

text: Although individual members of Congress have every right to express their views and the views of their constituents with respect to their religious beliefs and principles and their personal standards of who may marry whom, this court cannot conclude that Congress is entitled to solemnize such views in the laws of this nation in disregard of the views, legal status and living arrangements of a significant segment of our citizenry that includes the Debtors in this case. To do so violates the Debtors' right to equal protection of those laws embodied in the due process clause of the Fifth Amendment. This court cannot conclude from the evidence or the record in this case that any valid governmental interest is advanced by DOMA as applied to the Debtors.


title: Defense of Marriage Act

text: A spokesman for House Speaker Boehner said BLAG would not appeal the ruling, On July 7, 2011, the DOJ announced that after consultation with BLAG it would no longer raise objections to "bankruptcy petitions filed jointly by same-sex couples who are married under state law".


title: Defense of Marriage Act

text: Bi-national same-sex couples were kept from legally living in the United States by DOMA's Section 3, which prevented one spouse from sponsoring the other for a green card. Following some uncertainty after the Obama Administration determined Section 3 to be unconstitutional, the United States Citizenship and Immigration Services (USCIS) reaffirmed its policy of denying such applications. With respect to obtaining a visitor's visa, Bureau rules treated bi-national same-sex spouses the same as bi-national opposite-sex unmarried partners under the classification "cohabiting partners".


title: Defense of Marriage Act

text: Tim Coco and Genesio J. Oliveira, a same-sex couple married in Massachusetts in 2005, successfully challenged this policy and developed a model since followed by other immigration activists. The U.S. refused to recognize their marriage, and in 2007 Oliveira, a Brazilian national, accepted "voluntary departure" and returned to Brazil. They conducted a national press campaign A "Boston Globe" editorial commented, "Great strides toward equality for gays have been made in this country, but the woeful fate of Tim Coco and Genesio Oliveira shows that thousands of same-sex couples, even in Massachusetts, still aren't really full citizens." The editorial gained the attention of Senator John F. Kerry, who first lobbied Attorney General Eric Holder without success. He then gained the support of Homeland Security Secretary Janet Napolitano, who granted Oliveira humanitarian parole, enabling the couple to reunite in the U.S. in June 2010. Humanitarian parole is granted on a case-by-case basis at the Secretary's discretion.


title: Defense of Marriage Act

text: On September 28, 2011, in "Lui v. Holder", U.S. District Court Judge Stephen V. Wilson rejected a challenge to DOMA, citing "Adams v. Howerton" (1982). The plaintiffs in that case had unsuccessfully challenged the denial of immediate relative status to the same-sex spouse of an American citizen. Early in 2012, two bi-national same-sex couples were granted "deferred action" status, suspending deportation proceedings against the non-U.S. citizen for a year. A similar Texas couple had a deportation case dismissed in March 2012, leaving the non-citizen spouse unable to work legally in the United States but no longer subject to the threat of deportation.


title: Defense of Marriage Act

text: On January 5, 2012, the U.S. District Court for the Northern District of Illinois in Chicago decided the suit of a same-sex binational couple. Demos Revelis and Marcel Maas, married in Iowa in 2010, sought to prevent the USCIS from applying Section 3 of DOMA to Revelis's application for a permanent residence visa for Maas and, in the court's words, "that their petition be reviewed and decided on the same basis as other married couples." Judge Harry D. Leinenweber, a Reagan appointee, denied the government's motion to dismiss. BLAG has argued for the suit to be dismissed. In July the court stayed proceedings until mid-October because the USCIS was considering denying the plaintiffs' request on grounds unrelated to DOMA.


title: Defense of Marriage Act

text: On April 2, 2012, five bi-national same-sex couples represented by Immigration Equality and Paul, Weiss filed a lawsuit, "Blesch v. Holder", in the District Court for the Eastern District of New York, claiming that Section 3 of DOMA violated their equal protection rights by denying the U.S. citizen in the relationship the same rights in the green card application process granted a U.S. citizen who is in a relationship of partners of the opposite sex. On July 25, Chief Judge Carol Amon stayed the case pending the resolution of "Windsor" by the Second Circuit.


title: Defense of Marriage Act

text: Immigration rights advocate Lavi Soloway reported on June 19, 2012, that the Board of Immigration Appeals (BIA) had in four cases responded to green card denials on the part of the U.S. Citizenship and Immigration Services (USCIS) by asking the USCIS to document the marital status of the same-sex couples and determine whether the foreign national would qualify for a green card in the absence of DOMA Section 3. He said the BIA is "essentially setting the stage for being able to approve the petitions in a post-DOMA universe."


title: Defense of Marriage Act

text: On April 19, 2013, U.S. District Judge Consuelo Marshall ordered that a suit brought in July 2012 by Jane DeLeon, a Philippine citizen, and her spouse, Irma Rodriguez, a U.S. citizen, could proceed as a class action. The plaintiffs, represented by the Center for Human Rights and Constitutional Law, contended that DeLeon was denied a residency waiver because of DOMA Section 3.


title: Defense of Marriage Act

text: On June 28, 2013, the USCIS notified U.S. citizen Julian Marsh that it had approved the green card petition for his Bulgarian husband Traian Popov. Both are residents of Florida. On July 3, the USCIS office in Centennial, Colorado, granted Cathy Davis, a citizen of Ireland, a green card based on her marriage to U.S. citizen Catriona Dowling.


title: Defense of Marriage Act

text: In 2009, United States Court of Appeals for the Ninth Circuit Judge Stephen Reinhardt declared DOMA unconstitutional in "in re Levenson", an employment dispute resolution tribunal case, where the federal government refused to grant spousal benefits to Tony Sears, the husband of deputy federal public defender Brad Levenson. As an employee of the federal judiciary, Levenson is prohibited from suing his employer in federal court. Rather, employment disputes are handled at employment dispute resolution tribunals in which a federal judge hears the dispute in their capacity as a dispute resolution official.


title: Defense of Marriage Act

text: Section 2 of DOMA states to give legal relief to any state from recognizing same-sex marriages performed in other jurisdictions. Section 2 posits a conflict between states' rights and civil rights. Various federal lawsuits, some filed alongside challenges to Section 3, have challenged Section 2.


title: Defense of Marriage Act

text: On June 26, 2015, the U.S. Supreme Court ruled in "Obergefell v. Hodges" that the 14th Amendment requires all U.S. state laws to recognize same-sex marriages. This left Section 2 of DOMA as superseded and unenforceable.


title: Defense of Marriage Act

text: On September 15, 2009, three Democratic members of Congress, Jerrold Nadler of New York, Tammy Baldwin of Wisconsin, and Jared Polis of Colorado, introduced legislation to repeal DOMA called the Respect for Marriage Act. The bill had 91 original co-sponsors in the House of Representatives and was supported by Clinton, Barr, and several legislators who voted for DOMA. Congressman Barney Frank and John Berry, head of the Office of Personnel Management, did not support that effort, stating that "the backbone is not there" in Congress. Frank and Berry suggested DOMA could be overturned more quickly through lawsuits such as "Gill v. Office of Personnel Management" filed by Gay & Lesbian Advocates & Defenders (GLAD).


title: Defense of Marriage Act

text: Following Holder's announcement that the Obama Administration would no longer defend DOMA Section 3 in court, on March 16, 2011, Senator Dianne Feinstein introduced the Respect for Marriage Act in the Senate again and Nadler introduced it in the House. The Senate Judiciary Committee voted 10–8 in favor of advancing the bill to the Senate floor, but observers believed it would not gain the 60 votes needed to end debate and bring it to a vote.


title: Defense of Marriage Act

text: After the Supreme Court struck down DOMA Section 3 on June 26, 2013, Feinstein and Nadler reintroduced the Respect for Marriage Act as and . The Respect for Marriage Act cleared the 60 vote filibuster hurdle on November 16, 2022, when the Senate voted 62–37 to advance it. Joe Biden signed the repeal on December 13, 2022.


title: Alexandra Park (actress)

text: Alexandra Park is an Australian actress. She is known for her role as Claudia Hammond in the Australian soap opera "Home and Away" in 2009. She also starred in the E! drama series "The Royals" as Princess Eleanor from 2015 to 2018.


title: Alexandra Park (actress)

text: Park made her acting debut in the Australian television series "The Elephant Princess" in 2011, playing Veronica.


title: Alexandra Park (actress)

text: In 2009, Park played Claudia Hammond in the soap opera "Home and Away". During that time, she appeared in an episode of "Packed to the Rafters" in 2011. Park appeared as Sienna in the 2012 short film "Arc".


title: Alexandra Park (actress)

text: She also appeared in a 2013 episode of the television series "Wonderland" as Jodie. From 2015 to 2018, Park portrayed Princess Eleanor in the E! original series "The Royals".


title: Alexandra Park (actress)

text: Park plays a filmmaker in the horror thriller film "Carnifex", which screens at the in October 2022. It is South Australian film editor Sean Lahiff's debut film as director. In the film, Park's character and two conservationists encounter a terrifying new species, after huge bushfires have ravaged the land. Filmed in Kuitpo Forest, the film has large-scale special effects, and also stars Sisi Stringer and Harry Greenwood, son of actor Hugo Weaving.


title: Effect size

text: In statistics, an effect size is a value measuring the strength of the relationship between two variables in a population, or a sample-based estimate of that quantity. It can refer to the value of a statistic calculated from a sample of data, the value of a parameter for a hypothetical population, or to the equation that operationalizes how statistics or parameters lead to the effect size value. Examples of effect sizes include the correlation between two variables, the regression coefficient in a regression, the mean difference, or the risk of a particular event (such as a heart attack) happening. Effect sizes complement statistical hypothesis testing, and play an important role in power analyses, sample size planning, and in meta-analyses. The cluster of data-analysis methods concerning effect sizes is referred to as estimation statistics.


title: Effect size

text: Effect size is an essential component when evaluating the strength of a statistical claim, and it is the first item (magnitude) in the MAGIC criteria. The standard deviation of the effect size is of critical importance, since it indicates how much uncertainty is included in the measurement. A standard deviation that is too large will make the measurement nearly meaningless. In meta-analysis, where the purpose is to combine multiple effect sizes, the uncertainty in the effect size is used to weigh effect sizes, so that large studies are considered more important than small studies. The uncertainty in the effect size is calculated differently for each type of effect size, but generally only requires knowing the study's sample size ("N"), or the number of observations ("n") in each group.


title: Effect size

text: Reporting effect sizes or estimates thereof (effect estimate [EE], estimate of effect) is considered good practice when presenting empirical research findings in many fields. The reporting of effect sizes facilitates the interpretation of the importance of a research result, in contrast to its statistical significance. Effect sizes are particularly prominent in social science and in medical research (where size of treatment effect is important).


title: Effect size

text: Effect sizes may be measured in relative or absolute terms. In relative effect sizes, two groups are directly compared with each other, as in odds ratios and relative risks. For absolute effect sizes, a larger absolute value always indicates a stronger effect. Many types of measurements can be expressed as either absolute or relative, and these can be used together because they convey different information. A prominent task force in the psychology research community made the following recommendation:


title: Effect size

text: As in statistical estimation, the true effect size is distinguished from the observed effect size, e.g. to measure the risk of disease in a population (the population effect size) one can measure the risk within a sample of that population (the sample effect size). Conventions for describing true and observed effect sizes follow standard statistical practices—one common approach is to use Greek letters like ρ [rho] to denote population parameters and Latin letters like "r" to denote the corresponding statistic. Alternatively, a "hat" can be placed over the population parameter to denote the statistic, e.g. with formula_1 being the estimate of the parameter formula_2.


title: Effect size

text: As in any statistical setting, effect sizes are estimated with sampling error, and may be biased unless the effect size estimator that is used is appropriate for the manner in which the data were sampled and the manner in which the measurements were made. An example of this is publication bias, which occurs when scientists report results only when the estimated effect sizes are large or are statistically significant. As a result, if many researchers carry out studies with low statistical power, the reported effect sizes will tend to be larger than the true (population) effects, if any. Another example where effect sizes may be distorted is in a multiple-trial experiment, where the effect size calculation is based on the averaged or aggregated response across the trials.


title: Effect size

text: Smaller studies sometimes show different, often larger, effect sizes than larger studies. This phenomenon is known as the small-study effect, which may signal publication bias.


title: Effect size

text: Sample-based effect sizes are distinguished from test statistics used in hypothesis testing, in that they estimate the strength (magnitude) of, for example, an apparent relationship, rather than assigning a significance level reflecting whether the magnitude of the relationship observed could be due to chance. The effect size does not directly determine the significance level, or vice versa. Given a sufficiently large sample size, a non-null statistical comparison will always show a statistically significant result unless the population effect size is exactly zero (and even there it will show statistical significance at the rate of the Type I error used). For example, a sample Pearson correlation coefficient of 0.01 is statistically significant if the sample size is 1000. Reporting only the significant "p"-value from this analysis could be misleading if a correlation of 0.01 is too small to be of interest in a particular application.


title: Effect size

text: The term "effect size" can refer to a standardized measure of effect (such as "r", Cohen's "d", or the odds ratio), or to an unstandardized measure (e.g., the difference between group means or the unstandardized regression coefficients). Standardized effect size measures are typically used when:


title: Effect size

text: In meta-analyses, standardized effect sizes are used as a common measure that can be calculated for different studies and then combined into an overall summary.


title: Effect size

text: Whether an effect size should be interpreted as small, medium, or large depends on its substantive context and its operational definition. Cohen's conventional criteria "small", "medium", or "big" are near ubiquitous across many fields, although Cohen cautioned:


title: Effect size

text: "The terms 'small,' 'medium,' and 'large' are relative, not only to each other, but to the area of behavioral science or even more particularly to the specific content and research method being employed in any given investigation...In the face of this relativity, there is a certain risk inherent in offering conventional operational definitions for these terms for use in power analysis in as diverse a field of inquiry as behavioral science. This risk is nevertheless accepted in the belief that more is to be gained than lost by supplying a common conventional frame of reference which is recommended for use only when no better basis for estimating the ES index is available." (p. 25)


title: Effect size

text: In the two sample layout, Sawilowsky concluded "Based on current research findings in the applied literature, it seems appropriate to revise the rules of thumb for effect sizes," keeping in mind Cohen's cautions, and expanded the descriptions to include "very small", "very large", and "huge". The same de facto standards could be developed for other layouts.


title: Effect size

text: Lenth noted for a "medium" effect size, "you'll choose the same "n" regardless of the accuracy or reliability of your instrument, or the narrowness or diversity of your subjects. Clearly, important considerations are being ignored here. Researchers should interpret the substantive significance of their results by grounding them in a meaningful context or by quantifying their contribution to knowledge, and Cohen's effect size descriptions can be helpful as a starting point." Similarly, a U.S. Dept of Education sponsored report said "The widespread indiscriminate use of Cohen’s generic small, medium, and large effect size values to characterize effect sizes in domains to which his normative values do not apply is thus likewise inappropriate and misleading."


title: Effect size

text: They suggested that "appropriate norms are those based on distributions of effect sizes for comparable outcome measures from comparable interventions targeted on comparable samples." Thus if a study in a field where most interventions are tiny yielded a small effect (by Cohen's criteria), these new criteria would call it "large". In a related point, see Abelson's paradox and Sawilowsky's paradox.


title: Effect size

text: About 50 to 100 different measures of effect size are known. Many effect sizes of different types can be converted to other types, as many estimate the separation of two distributions, so are mathematically related. For example, a correlation coefficient can be converted to a Cohen's d and vice versa.


title: Effect size

text: These effect sizes estimate the amount of the variance within an experiment that is "explained" or "accounted for" by the experiment's model (Explained variation).


title: Effect size

text: Pearson's correlation, often denoted "r" and introduced by Karl Pearson, is widely used as an "effect size" when paired quantitative data are available; for instance if one were studying the relationship between birth weight and longevity. The correlation coefficient can also be used when the data are binary. Pearson's "r" can vary in magnitude from −1 to 1, with −1 indicating a perfect negative linear relation, 1 indicating a perfect positive linear relation, and 0 indicating no linear relation between two variables. Cohen gives the following guidelines for the social sciences:


title: Effect size

text: A related "effect size" is "r", the coefficient of determination (also referred to as "R" or ""r"-squared"), calculated as the square of the Pearson correlation "r". In the case of paired data, this is a measure of the proportion of variance shared by the two variables, and varies from 0 to 1. For example, with an "r" of 0.21 the coefficient of determination is 0.0441, meaning that 4.4% of the variance of either variable is shared with the other variable. The "r" is always positive, so does not convey the direction of the correlation between the two variables.


title: Effect size

text: Eta-squared describes the ratio of variance explained in the dependent variable by a predictor while controlling for other predictors, making it analogous to the r. Eta-squared is a biased estimator of the variance explained by the model in the population (it estimates only the effect size in the sample). This estimate shares the weakness with r that each additional variable will automatically increase the value of η. In addition, it measures the variance explained of the sample, not the population, meaning that it will always overestimate the effect size, although the bias grows smaller as the sample grows larger.


title: Effect size

text: This form of the formula is limited to between-subjects analysis with equal sample sizes in all cells. Since it is less biased (although not "un"biased), "ω" is preferable to η; however, it can be more inconvenient to calculate for complex analyses. A generalized form of the estimator has been published for between-subjects and within-subjects analysis, repeated measure, mixed design, and randomized block design experiments. In addition, methods to calculate partial "ω" for individual factors and combined factors in designs with up to three independent variables have been published.


title: Effect size

text: Cohen's "ƒ" is one of several effect size measures to use in the context of an F-test for ANOVA or multiple regression. Its amount of bias (overestimation of the effect size for the ANOVA) depends on the bias of its underlying measurement of variance explained (e.g., "R", "η", "ω").


title: Effect size

text: The formula_8 effect size measure for sequential multiple regression and also common for PLS modeling is defined as:


title: Effect size

text: Cohen's formula_13 can also be found for factorial analysis of variance (ANOVA) working backwards, using:


title: Effect size

text: In a balanced design (equivalent sample sizes across groups) of ANOVA, the corresponding population parameter of formula_15 is


title: Effect size

text: wherein "μ" denotes the population mean within the "j" group of the total "K" groups, and "σ" the equivalent population standard deviations within each groups. "SS" is the sum of squares in ANOVA.


title: Effect size

text: Another measure that is used with correlation differences is Cohen's q. This is the difference between two Fisher transformed Pearson regression coefficients. In symbols this is


title: Effect size

text: where "r" and "r" are the regressions being compared. The expected value of "q" is zero and its variance is


title: Effect size

text: The raw effect size pertaining to a comparison of two groups is inherently calculated as the differences between the two means. However, to facilitate interpretation it is common to standardise the effect size; various conventions for statistical standardisation are presented below.


title: Effect size

text: A (population) effect size "θ" based on means usually considers the standardized mean difference (SMD) between two populations


title: Effect size

text: where "μ" is the mean for one population, "μ" is the mean for the other population, and σ is a standard deviation based on either or both populations.


title: Effect size

text: In the practical setting the population values are typically not known and must be estimated from sample statistics. The several versions of effect sizes based on means differ with respect to which statistics are used.


title: Effect size

text: This form for the effect size resembles the computation for a "t"-test statistic, with the critical difference that the "t"-test statistic includes a factor of formula_20. This means that for a given effect size, the significance level increases with the sample size. Unlike the "t"-test statistic, the effect size aims to estimate a population parameter and is not affected by the sample size.


title: Effect size

text: SMD values of 0.2 to 0.5 are considered small, 0.5 to 0.8 are considered medium, and greater than 0.8 are considered large.


title: Effect size

text: Cohen's "d" is defined as the difference between two means divided by a standard deviation for the data, "i.e."


title: Effect size

text: The table below contains descriptors for magnitudes of "d" = 0.01 to 2.0, as initially suggested by Cohen and expanded by Sawilowsky.


title: Effect size

text: Other authors choose a slightly different computation of the standard deviation when referring to "Cohen's "d"" where the denominator is without "-2"


title: Effect size

text: With two paired samples, we look at the distribution of the difference scores. In that case, "s" is the standard deviation of this distribution of difference scores. This creates the following relationship between the t-statistic to test for a difference in the means of the two groups and Cohen's "d":


title: Effect size

text: Cohen's "d" is frequently used in estimating sample sizes for statistical testing. A lower Cohen's "d" indicates the necessity of larger sample sizes, and vice versa, as can subsequently be determined together with the additional parameters of desired significance level and statistical power.


title: Effect size

text: For paired samples Cohen suggests that the d calculated is actually a d', which doesn't provide the correct answer to obtain the power of the test, and that before looking the values up in the tables provided, it should be corrected for r as in the following formula:


title: Effect size

text: In 1976, Gene V. Glass proposed an estimator of the effect size that uses only the standard deviation of the second group


title: Effect size

text: The second group may be regarded as a control group, and Glass argued that if several treatments were compared to the control group it would be better to use just the standard deviation computed from the control group, so that effect sizes would not differ under equal means and different variances.


title: Effect size

text: Hedges and Olkin refer to this less-biased estimator formula_33 as "d", but it is not the same as Cohen's "d".


title: Effect size

text: A similar effect size estimator for multiple comparisons (e.g., ANOVA) is the Ψ root-mean-square standardized effect:


title: Effect size

text: This essentially presents the omnibus difference of the entire model adjusted by the root mean square, analogous to "d" or "g".


title: Effect size

text: Provided that the data is Gaussian distributed a scaled Hedges' "g", formula_36, follows a noncentral "t"-distribution with the noncentrality parameter formula_37 and ("n" + "n" − 2) degrees of freedom. Likewise, the scaled Glass' Δ is distributed with "n" − 1 degrees of freedom.


title: Effect size

text: In some cases large sample approximations for the variance are used. One suggestion for the variance of Hedges' unbiased estimator is


title: Effect size

text: Mahalanobis distance (D) is a multivariate generalization of Cohen's d, which takes into account the relationships between the variables.


title: Effect size

text: Commonly used measures of association for the chi-squared test are the Phi coefficient and Cramér's V (sometimes referred to as Cramér's phi and denoted as "φ"). Phi is related to the point-biserial correlation coefficient and Cohen's "d" and estimates the extent of the relationship between two variables (2 × 2). Cramér's V may be used with variables having more than two levels.


title: Effect size

text: Phi can be computed by finding the square root of the chi-squared statistic divided by the sample size.


title: Effect size

text: Similarly, Cramér's V is computed by taking the square root of the chi-squared statistic divided by the sample size and the length of the minimum dimension ("k" is the smaller of the number of rows "r" or columns "c").


title: Effect size

text: φ is the intercorrelation of the two discrete variables and may be computed for any value of "r" or "c". However, as chi-squared values tend to increase with the number of cells, the greater the difference between "r" and "c", the more likely V will tend to 1 without strong evidence of a meaningful correlation.


title: Effect size

text: Cramér's "V" may also be applied to 'goodness of fit' chi-squared models (i.e. those where "c" = 1). In this case it functions as a measure of tendency towards a single outcome (i.e. out of "k" outcomes). In such a case one must use "r" for "k", in order to preserve the 0 to 1 range of "V". Otherwise, using "c" would reduce the equation to that for Phi.


title: Effect size

text: where "p" is the value of the "i" cell under "H", "p" is the value of the "i" cell under "H" and "m" is the number of cells.


title: Effect size

text: The odds ratio (OR) is another useful effect size. It is appropriate when the research question focuses on the degree of association between two binary variables. For example, consider a study of spelling ability. In a control group, two students pass the class for every one who fails, so the odds of passing are two to one (or 2/1 = 2). In the treatment group, six students pass for every one who fails, so the odds of passing are six to one (or 6/1 = 6). The effect size can be computed by noting that the odds of passing in the treatment group are three times higher than in the control group (because 6 divided by 2 is 3). Therefore, the odds ratio is 3. Odds ratio statistics are on a different scale than Cohen's "d", so this '3' is not comparable to a Cohen's "d" of 3.


title: Effect size

text: The relative risk (RR), also called risk ratio, is simply the risk (probability) of an event relative to some independent variable. This measure of effect size differs from the odds ratio in that it compares "probabilities" instead of "odds", but asymptotically approaches the latter for small probabilities. Using the example above, the "probabilities" for those in the control group and treatment group passing is 2/3 (or 0.67) and 6/7 (or 0.86), respectively. The effect size can be computed the same as above, but using the probabilities instead. Therefore, the relative risk is 1.28. Since rather large probabilities of passing were used, there is a large difference between relative risk and odds ratio. Had "failure" (a smaller probability) been used as the event (rather than "passing"), the difference between the two measures of effect size would not be so great.


title: Effect size

text: While both measures are useful, they have different statistical uses. In medical research, the odds ratio is commonly used for case-control studies, as odds, but not probabilities, are usually estimated. Relative risk is commonly used in randomized controlled trials and cohort studies, but relative risk contributes to overestimations of the effectiveness of interventions.


title: Effect size

text: The risk difference (RD), sometimes called absolute risk reduction, is simply the difference in risk (probability) of an event between two groups. It is a useful measure in experimental research, since RD tells you the extent to which an experimental interventions changes the probability of an event or outcome. Using the example above, the probabilities for those in the control group and treatment group passing is 2/3 (or 0.67) and 6/7 (or 0.86), respectively, and so the RD effect size is 0.86 − 0.67 = 0.19 (or 19%). RD is the superior measure for assessing effectiveness of interventions.


title: Effect size

text: One measure used in power analysis when comparing two independent proportions is Cohen's "h". This is defined as follows


title: Effect size

text: where "p" and "p" are the proportions of the two samples being compared and arcsin is the arcsine transformation.


title: Effect size

text: To more easily describe the meaning of an effect size, to people outside statistics, the common language effect size, as the name implies, was designed to communicate it in plain English. It is used to describe a difference between two groups and was proposed, as well as named, by Kenneth McGraw and S. P. Wong in 1992. They used the following example (about heights of men and women): "in any random pairing of young adult males and females, the probability of the male being taller than the female is .92, or in simpler terms yet, in 92 out of 100 blind dates among young adults, the male will be taller than the female", when describing the population value of the common language effect size.


title: Effect size

text: The population value, for the common language effect size, is often reported like this, in terms of pairs randomly chosen from the population. Kerby (2014) notes that "a pair", defined as a score in one group paired with a score in another group, is a core concept of the common language effect size.


title: Effect size

text: As another example, consider a scientific study (maybe of a treatment for some chronic disease, such as arthritis) with ten people in the treatment group and ten people in a control group. If everyone in the treatment group is compared to everyone in the control group, then there are (10×10=) 100 pairs. At the end of the study, the outcome is rated into a score, for each individual (for example on a scale of mobility and pain, in the case of an arthritis study), and then all the scores are compared between the pairs. The result, as the percent of pairs that support the hypothesis, is the common language effect size. In the example study it could be (let's say) .80, if 80 out of the 100 comparison pairs show a better outcome for the treatment group than the control group, and the report may read as follows: "When a patient in the treatment group was compared to a patient in the control group, in 80 of 100 pairs the treated patient showed a better treatment outcome." The sample value, in for example a study like this, is an unbiased estimator of the population value.


title: Effect size

text: Vargha and Delaney generalized the common language effect size (Vargha-Delaney A), to cover ordinal level data.


title: Effect size

text: An effect size related to the common language effect size is the rank-biserial correlation. This measure was introduced by Cureton as an effect size for the Mann–Whitney "U" test. That is, there are two groups, and scores for the groups have been converted to ranks. The Kerby simple difference formula computes the rank-biserial correlation from the common language effect size. Letting f be the proportion of pairs favorable to the hypothesis (the common language effect size), and letting u be the proportion of pairs not favorable, the rank-biserial r is the simple difference between the two proportions: "r" = "f" − "u". In other words, the correlation is the difference between the common language effect size and its complement. For example, if the common language effect size is 60%, then the rank-biserial r equals 60% minus 40%, or "r" = 0.20. The Kerby formula is directional, with positive values indicating that the results support the hypothesis.


title: Effect size

text: A non-directional formula for the rank-biserial correlation was provided by Wendt, such that the correlation is always positive. The advantage of the Wendt formula is that it can be computed with information that is readily available in published papers. The formula uses only the test value of U from the Mann-Whitney U test, and the sample sizes of the two groups: "r" = 1 – (2"U")/("n" "n"). Note that U is defined here according to the classic definition as the smaller of the two "U" values which can be computed from the data. This ensures that 2"U" < "n""n", as "n""n" is the maximum value of the "U" statistics.


title: Effect size

text: An example can illustrate the use of the two formulas. Consider a health study of twenty older adults, with ten in the treatment group and ten in the control group; hence, there are ten times ten or 100 pairs. The health program uses diet, exercise, and supplements to improve memory, and memory is measured by a standardized test. A Mann-Whitney "U" test shows that the adult in the treatment group had the better memory in 70 of the 100 pairs, and the poorer memory in 30 pairs. The Mann-Whitney "U" is the smaller of 70 and 30, so "U" = 30. The correlation between memory and treatment performance by the Kerby simple difference formula is "r" = (70/100) − (30/100) = 0.40. The correlation by the Wendt formula is "r" = 1 − (2·30)/(10·10) = 0.40.


title: Effect size

text: Cliff's delta or formula_41, originally developed by Norman Cliff for use with ordinal data, is a measure of how often the values in one distribution are larger than the values in a second distribution. Crucially, it does not require any assumptions about the shape or spread of the two distributions.


title: Effect size

text: where the two distributions are of size formula_44 and formula_45 with items formula_46 and formula_47, respectively, and formula_48 is the Iverson bracket, which is 1 when the contents are true and 0 when false.


title: Effect size

text: formula_41 is linearly related to the Mann–Whitney U statistic; however, it captures the direction of the difference in its sign. Given the Mann–Whitney formula_50, formula_41 is:


title: Effect size

text: Confidence intervals of standardized effect sizes, especially Cohen's formula_53 and formula_15, rely on the calculation of confidence intervals of noncentrality parameters ("ncp"). A common approach to construct the confidence interval of "ncp" is to find the critical "ncp" values to fit the observed statistic to tail quantiles "α"/2 and (1 − "α"/2). The SAS and R-package MBESS provides functions to find critical values of "ncp".


title: Effect size

text: For a single group, "M" denotes the sample mean, "μ" the population mean, "SD" the sample's standard deviation, "σ" the population's standard deviation, and "n" is the sample size of the group. The "t" value is used to test the hypothesis on the difference between the mean and a baseline "μ". Usually, "μ" is zero. In the case of two related groups, the single group is constructed by the differences in pair of samples, while "SD" and "σ" denote the sample's and population's standard deviations of differences rather than within original two groups.


title: Effect size

text: One-way ANOVA test applies noncentral F distribution. While with a given population standard deviation formula_66, the same test question applies noncentral chi-squared distribution.


title: Effect size

text: In case of formula_72 for "K" independent groups of same size, the total sample size is "N" := "n"·"K".


title: Effect size

text: The "t"-test for a pair of independent groups is a special case of one-way ANOVA. Note that the noncentrality parameter formula_74 of "F" is not comparable to the noncentrality parameter formula_75 of the corresponding "t". Actually, formula_76, and formula_77.


title: Shreyas Talpade

text: Shreyas Talpade (born 27 January 1976) is an Indian actor, film director and producer who appears in Hindi and Marathi films. He has appeared in several critically and commercially successful films. He is better known for his role as Shah Rukh Khan's friend Pappu Master in "Om Shanti Om" (2007), the grand reincarnation melodrama of Farah Khan. He appeared in the comedies "Golmaal Returns" (2008), "Welcome to Sajjanpur (2008), "Golmaal 3" (2010), "Housefull 2" (2012) and "Golmaal Again" (2017). Talpade dubbed for Allu Arjun in the Hindi version of "".


title: Shreyas Talpade

text: Shreyas Talpade was born in Mumbai, Maharashtra on 27 January 1976. His father is the brother of actresses Meena T. and Jayshree T. (full name "Jayshri Talpade"). Shreyas attended Shree Ram Welfare Society’s High School in Andheri West followed by Mithibai College in Vile Parle. He is married to Deepti Talpade, a psychiatrist.


title: Shreyas Talpade

text: Talpade began his acting career appearing in Marathi soap operas and doing stage shows across Maharashtra. He also appeared in the Zee TV soap opera "Woh" (1998) in which he was the main lead. He has also acted in mini-serials for the production "Adhikari Brothers". His role, in a very popular Marathi serial "Damini", as the character Tejas was very popular among Marathi audiences. He also appeared in "Jaane Anjaane" (2001) aired on doordarshan where he played the role of a son who dislikes his father because he felt that his father was the reason for his accident. Viewers liked the content of the same. Fame arrived after he made his Bollywood debut in Nagesh Kukunoor's "Iqbal" which was written by Vipul K Rawal in which he played the role of a deaf & mute youngster aspiring to be a cricketer. The film and his performance were well received by both audiences and critics. His next film was Kukunoor's "Dor" in which he played the comic role of a behroopiya, a man with many disguises. This film was also well received by critics.


title: Shreyas Talpade

text: In 2006, he starred in the comedy, "Apna Sapna Money Money" and in 2007, he starred in Farah Khan's blockbuster movie, "Om Shanti Om", with Shah Rukh Khan, where he played the role of Pappu Master. In 2008, he was seen in Kukunoor's cross-cultural comedy film, "Bombay To Bangkok". He also produced a Marathi film, "Sanai Chaughade", which was released the same year. He also did movies like Shyam Benegal's "Welcome to Sajjanpur", along with "Golmaal Returns" and Sangeeth Sivan's horror flick, "Click". Shreyas was also seen in the horror film, "Help". Shreyas next appeared in the movie "Will You Marry Me?" which released in 2012.


title: Shreyas Talpade

text: Shreyas has produced a Marathi film, titled "Poshter Boyz", under his home production banner, Affluence Movies. The movie which released on 1 August 2014 was launched by Bollywood veteran Subhash Ghai. The film is directed by Sameer Patil and the music for it is composed by Lesle Lewis.


title: Shreyas Talpade

text: "Poshter Boyz" was remade in Hindi as "Poster Boys" and Shreyas made his directorial debut with this film which released on 8 September 2017. The film stars Shreyas himself along with Sunny Deol and Bobby Deol.


title: Shreyas Talpade

text: In a series of sting operations carried out by Cobrapost code-named Operation Karaoke, Shreyas Talpade has been named as one of many celebrities who can be seen agreeing to promote the agenda of parties on social media platforms in exchange for money, on camera.


title: Piñata

text: A piñata (, ) is a container, often made of papier-mâché, pottery, or cloth, that is decorated, filled with candy, and then broken as part of a celebration. Piñatas are commonly associated with Mexico. The idea of breaking a container filled with treats came to Europe in the 14th century. The Spanish brought the European tradition to Mexico, although there were similar traditions in Mesoamerica, such as the Aztecs' honoring the birthday of the god Huītzilōpōchtli in mid-December. According to local records, the Mexican piñata tradition began in the town of Acolman, just north of Mexico City, where piñatas were introduced for catechism purposes as well as to co-opt the Huitzilopochtli ceremony. Today, the piñata is still part of Mexican culture, the cultures of other countries in Latin America, as well as the United States, but it has mostly lost its religious character.


title: Piñata

text: The Spanish word probably derives from the Italian 'fragile pot,' itself from It may also come from Spanish


title: Piñata

text: Although today, piñatas are typically used for a fun activity at parties, their origins lie in other customs. There is some debate but it appears that their origin is not Spanish but Chinese. The Chinese version was in the shape of a cow or ox and used for the New Year. It was decorated with symbols and colors meant to produce a favorable climate for the coming growing season. It was filled with five types of seeds and then hit with sticks of various colors. After the piñata was broken, the remains were burned and the ashes kept for good luck.


title: Piñata

text: The tradition arrived in Europe in the 14th century where it was associated with the Christian celebration of Lent; in Spain, the First Sunday of Lent, "Piñata Sunday", became a celebration known as the Dance of the Piñata. As the word's Italian origin indicates, "pignatta" (also "pignata" and "pignàta") meaning "earthenware cooking pot", the Spanish initially used a plain clay container, before starting to decorate it with ribbons, tinsel and colored paper. The origin of the Italian word is thought to be linked to the Latin word "pinea", "pine cone".


title: Piñata

text: The European piñata tradition was brought to Mexico in the 16th century; however, there was a similar tradition in Mesoamerica already. The Mayan tradition was similar to the modern piñata tradition, including blindfolding the participant hitting the piñata. The Aztec tradition commemorated the birthday of Huitzilopochtli. Priests would decorate a clay pot with colorful feathers. When the pot was broken with a stick or club, the treasures inside would fall to the feet of the idol as an offering. According to local records, the piñata was first used for the purposes of evangelism in 1586, in Acolman, in the modern State of Mexico, just north of Mexico City. The Augustinian monks there modified European piñatas and created the Las Posadas tradition to co-opt the celebration of the birth of Huitzilopochtli, which was celebrated in mid December.


title: Piñata

text: The Mexican Catholic interpretation assigned meanings related to the Catholic doctrine of struggle against temptation, and used for catechism purposes. In this tradition, the seven points represent the seven deadly sins, the pot represents evil, and the seasonal fruit and candy inside the temptations of evil. It was said that person with the stick is blindfolded to represent faith, and the turning, singing and shouting represent the disorientation that temptation creates. In some traditions, the participant is turned thirty three times, one for each year of Christ's life. As the participant beats the piñata, it is supposed to represent the struggle against temptation and evil. When the piñata breaks, some say (contrary to other interpretations) the treats inside then represent the rewards of keeping the faith.


title: Piñata

text: However, since this time the piñata has all but lost its religious significance and has become popular in many types of celebrations, not just during December's Las Posadas. The clay pot has been replaced with a papier-mâché container. The creation of piñatas has even taken on an artistic aspect in some areas. David Gamez and Cecilia Meade sponsored a showing of piñatas as art rather than just as a party favor. The event was called Piñatarama, with 25 piñatas made of papier-mâché at the Vértigo Galería in Mexico City, all original works of art by graphic illustrators, from 23 countries including Australia. Some of the illustrators who participated include 1000 Changos, Allan Sieber, Apak, Ben Newman, Cecy Meade, Cristian Turdera, Cupco and Daniel Berman. In Tepatitlán, the world's largest traditional seven-pointed piñata was created in 2010. It measures 11.2 meters, is made of fiberglass and weighs 350 kilograms. It surpasses the former Guinness record holder which was made in 2008 in Pennsylvania.


title: Piñata

text: The piñata is most strongly identified with Mexico. The art of making modern piñatas falls under the Mexican craft heading of "cartonería", which refers to the making of items from paper and cardboard. This puts piñatas in the same category as amate paper craft, Judas figures and Mexico City style alebrijes. The Museo de Arte Popular held the first "Concurso de Piñatas Mexicanas" (Mexican Piñata Contest) in 2007 with prizes of 15,000, 10,000 and 5,000 pesos. The purpose of the contest is to help retain this tradition and help it to be continued to be valued. The Museo del Caracol in Mexico City held a workshop on how to make traditional piñatas, as part of its outreach program to the public.


title: Piñata

text: While the religious significance has been mostly lost, the ceremony that occurs with it has remained mostly intact. Piñatas remain most popular during Las Posadas with birthday parties coming in second. Each participant, usually a child, will have a turn at hitting the piñata, which is hung from above on a string. The participant is blindfolded, given a wooden stick, and then spun a number of times. As the participants works to hit the piñata, another moves it to make it harder to hit. There is a time limit to any one person's attempts, which is marked out by the singing of a traditional song.


title: Piñata

text: Piñatas were traditionally made with a clay pot base and many artisans make a living selling just the pot for people to decorate as they wish. However, clay pot piñatas have mostly been replaced by those made with cardboard and papier-mâché, usually fashioned over balloons. One reason for this is that broken pot pieces can be dangerous to children. These are then decorated with crepe paper, other colored paper and other items. Piñatas today come in all shapes and sizes, with many representing cartoon or other characters known to most children. Popular shapes today can include Batman, Superman, Spider-Man or characters based on popular movies and television shows such as Nemo, the Lion King and more. For Christmas, the traditional style with the points is popular as it is associated with the Star of Bethlehem. However, for the most part, piñata designs have been completely commercialized.


title: Piñata

text: Traditionally in Mexico, especially at Christmas, piñatas are filled with fruit and candies such as guavas, oranges, jicamas, pieces of sugar cane, tejocotes and wrapped candies. Some piñatas are "traps" filled with flour, confetti or water. Special baskets of treats may be given to children who come up empty handed after a piñata is broken. These are called colaciónes and are given to prevent hurt feelings.


title: Piñata

text: There are a number of localities in Mexico that specialize in the making of piñatas for sale. Acolman, the origin of piñatas, along with neighboring Otumba are one. Acolman hosts an annual National Piñata Fair. This event includes cultural events, workshops on the making of piñatas, piñata contests and traditional Posadas. The event has attracted as many as 100,000 visitors over the days that it is held, many of whom come from Mexico City.


title: Piñata

text: About 400 families in the town of San Juan de la Puerta, in the south of the Cuerámaro municipality in Guanajuato, are dedicated to the creation of piñatas, and produce about 16,000 pieces each month. The making of piñatas supports about half of the people in the town. It is the second most important economic activity after agriculture. This tradition began in 1960 by Juan Remigio Anguiano, who brought the craft to the town after living in Mexico City. Today, piñatas from the town are sold in various parts of the state.


title: Piñata

text: In the penal facility of Huajuapan de León, prisoners make piñatas to sell. This began when several prisoners brought the craft with them when they were incarcerated about twenty years ago. These piñatas have become traditional for the population of the city for Christmas.


title: Piñata

text: The busiest time for the sale of piñatas in Mexico is December for posadas. During bad economic times, sales of piñatas can fall as much as thirty percent as they did in 2008.


title: Piñata

text: The star shape, or ball with points, still remains popular for the Christmas season, but for other events, traditional designs such as donkeys have almost entirely been replaced by cartoon characters based on U.S. movies and television shows. However, most of the piñatas produced based on these images are not following copyright law, which has caused problems. Copyright holders such as Marvel Comics have complained about infringement by piñata makers in Mexico. Federal authorities have responded by seizing such merchandise in stores in various areas of Mexico City. Vendors complain that they have sold these piñatas for decades and never have had problems. Those who have run into problems with copyright law state that it is difficult to sell other types as most customers prefer to buy those based on popular characters. Mexico exports piñatas to the United States and other parts of the world, but copyright has been an issue there as well. Piñatas based on Disney and other characters have been seized at the border for violating U.S. copyright law. Some have also been seized and destroyed by customs agents under suspect of hiding drugs.


title: Piñata

text: One niche market for piñatas in Mexico is of those themed for adults. These include political figures, especially those who are not particularly liked. Another type for the adult market are sexually-themed piñatas, mostly those in the form of exotic dancers and strippers. Of the female of this type, the most popular are blondes. For the male, darker shades are preferred. These piñatas will be filled with adult items such as condoms in addition to candy.


title: Piñata

text: Piñatas have also become popular in Mexican-American and other Hispanic and Latino communities in the United States, as well as non-Hispanic populations. They are used for birthday parties, Christmas and Cinco de Mayo celebrations.


title: Piñata

text: The 2006 video game "Viva Piñata" is about a world where piñatas compete to be chosen for children's birthday parties. A spinoff television show, also titled "Viva Piñata" was created to push sales of the Xbox game created by Microsoft.


title: Piñata

text: A similar tradition in Denmark is slå katten af tønden ("hit the cat out of the barrel") in which a wooden barrel is struck to release candy.


title: Piñata

text: In Catalonia, a Christmastide tradition known as "fer cagar el tió" ("making the log defecate") is observed. A log is wrapped with a blanket several days in advance of Christmas and is "fed" grass. On Christmas Eve, the log is repeatedly struck with sticks in order to make the log "defecate". The blanket is then removed to reveal the gifts that have been "expelled" by the log.


title: Piñata

text: In Italy feasts with a game similar to "piñata", called "pentolaccia", used to be celebrated the first Sunday of Lent.


title: Piñata

text: In Maharashtra, India, another similar tradition called Dahi Handi is observed on the festival of Janmashtami, Lord Krishna's birthday. The iconography represents Lord Krishna's childhood portrayal as the mischievous "Maakhan Chor" (butter thief). Clay pots filled with buttermilk, money or treats, in lieu of butter, are hung in public squares or on streets at a height implicitly challenging youngsters to break them. Teams put in great planning, skill and effort to form human pyramids, each higher than the other, in an attempt to break the pot and claim the prize.


title: Piñata

text: In South Indian villages, festivals feature a competition called Uri adithal (Pot breaking with blindfold) which closely resembles the piñata event.


title: Piñata

text: In the Philippines, a similar game called "hampas-palayok" or "pukpok-palayok" (hit-the-pot) is played during Filipino fiestas and traditional parties (e.g., birthdays), in which a clay pot filled with treats and/or prizes is used. Also "đập nêu" (pot-hitting) appears in Vietnamese traditional custom.


title: Neeraj Pandey

text: Neeraj Pandey (born 17 December 1973) is an Indian film director, producer and screenwriter who works in Hindi cinema. Pandey made his directoral debut in "A Wednesday!", which was largely praised by critics and which later became a recipient of many accolades. His second film was "Special 26" (2013), which was followed by "Baby" (2015), the latter of which received critical acclaim and became a huge commercial success. He served as a producer in "Rustom" (2016). Pandey returned to directing in 2016 helming the biopic movie "" based on Indian cricketer M.S.Dhoni which fared well critically and commercially. Besides being a filmmaker, Pandey is also a writer and has written a novel named "Ghalib Danger" in 2013.


title: Neeraj Pandey

text: In 2016, his production house Friday Filmworks entered into a joint venture with Reliance Entertainment and formed Plan C Studios.


title: Neeraj Pandey

text: He has also directed a Web Short 'Ouch' with Manoj Bajpayee and Pooja Chopra which is nominated for Filmfare Short Film Award 2017. He was the co-producer of the film "Toilet- Ek Prem Katha". His next release was "Aiyaary" which starred Sidharth Malhotra and Manoj Bajpayee and was both critically and commercially unsuccessful, becoming his first failed venture.


title: Neeraj Pandey

text: In March 2020, Neeraj Pandey presented and directed his first web series "Special Ops" on "Hotstar". The eight episode series, the first production of Friday Storytellers, the digital arm of Friday Filmworks, was extremely well received by the critics. He is currently working on his next feature film "Chanakya".


title: Neeraj Pandey

text: Pandey was born and brought up in Howrah, West Bengal. His father, who originally came from Arrah, Bihar and worked for Bosch in Calcutta. He did his schooling from St. Aloysius High School, Howrah (till Class X) and then St. Thomas' High School, Dasnagar, Howrah (Class XI and XII). Pandey moved to New Delhi, where he graduated in English from Sri Aurobindo college(University of Delhi)


title: Neeraj Pandey

text: Pandey started his career working with Delhi-based 'Legacy Entertainment', a company started by the Dalmia Group to make television programs.


title: Neeraj Pandey

text: In 2000, he moved to Mumbai, where a friend got a grant to produce a documentary, and offered him the project. Soon he started making documentaries and ad films. Thereafter, he formed a production company 'Quarter Inch Productions', along with his colleague Shital Bhatia which specialized in making television programmes, ad films and documentaries. In 2008, Neeraj and Shital Bhatia formed a production house named Friday Filmworks, which was the original producer of his debut film, "A Wednesday!". The film's script was inspired by the 11 July 2006 Mumbai train bombings.


title: Neeraj Pandey

text: After directing his first movie in 2008, Pandey directed his second movie Special 26 in 2013, starring Akshay Kumar and Kajal Aggrawal. Neeraj is very fluent in Bengali and also produced a Bengali film, The Royal Bengal Tiger in 2014. In the same year he also produced the film Total Siyappa starring Yami Gautam and Ali Zafar. In 2015, he directed the movie "Baby" starring Akshay Kumar. In 2016, he produced the film "Saat Uchakkey" which was a comedy film starring Manoj Bajpayee, Kay Kay Menon and Aditi Sharma.


title: Neeraj Pandey

text: In 2016, Anil Ambani-owned Reliance Entertainment announced a joint venture with Pandey and Friday Filmworks to form Plan C studios for production of films. Akshay Kumar starrer "Rustom" was the first film for the company. It is an equal partnership joint venture between the two.


title: Neeraj Pandey

text: Pandey has also written his debut novel titled Ghalib Danger which was launched on 6 December 2013. The novel is soon going to be made into a motion picture.


title: Neeraj Pandey

text: In 2017, having co-produced "Toilet- Ek Prem Katha", a satirical take on the open defecation scenario in India went on to become a critically acclaimed movie.


title: Neeraj Pandey

text: He has also directed the short film "Ouch" with Manoj Bajpayee and Pooja Chopra which is nominated for the Filmfare Short Film Award 2017.


title: Neeraj Pandey

text: His next release was "Aiyaary" which starred Sidharth Malhotra and Manoj Bajpayee and was both critically and commercially flop emerging as his first failure. This film was written, directed by himself and produced under the banner of Plan C Studios, the film was an action thriller on the Indian borders. Malhotra and Bajpayee played the lead characters Jai Bakshi and Abhay Singh respectively. Naseeruddin Shah reunited with the filmmaker after their first venture, "A Wednesday!". The film was based on true incidents, a theme seen in several of his previous films as well.


title: Neeraj Pandey

text: In March 2020, Pandey presented and directed his first web series "Special Ops" on "Hotstar". The eight episode series, the first production of Friday Storytellers, the digital arm of Friday Filmworks, was extremely well received by the critics.


title: Neeraj Pandey

text: Currently, he is working on his next film, a full length feature film, "Chanakya". This will be his first association with Ajay Devgn.


title: Charlie Chan

text: Charlie Chan is a fictional Honolulu police detective created by author Earl Derr Biggers for a series of mystery novels. Biggers loosely based Chan on Hawaiian detective Chang Apana. The benevolent and heroic Chan was conceived as an alternative to Yellow Peril stereotypes and villains like Fu Manchu. Many stories feature Chan traveling the world beyond Hawaii as he investigates mysteries and solves crimes.


title: Charlie Chan

text: Chan first appeared in Biggers' novels and then was featured in a number of media. Over four dozen films featuring Charlie Chan were made, beginning in 1926. The character, featured only as a supporting character, was first portrayed by East Asian actors, and the films met with little success. In 1931, for the first film centering on Chan, "Charlie Chan Carries On", the Fox Film Corporation cast Swedish actor Warner Oland; the film became popular, and Fox went on to produce 15 more Chan films with Oland in the title role. After Oland's death, American actor Sidney Toler was cast as Chan; Toler made 22 Chan films, first for Fox and then for Monogram Studios. After Toler's death, six films were made, starring Roland Winters.


title: Charlie Chan

text: Readers and moviegoers of America greeted Chan warmly. Chan was seen as an attractive character, portrayed as intelligent, heroic, benevolent, and honorable; this contrasted the common depiction of Asians as evil or conniving which dominated Hollywood and national media in the early 20th century. However, in later decades critics increasingly took a more ambivalent view of the character. Despite his good qualities, Chan was also perceived as reinforcing condescending Asian stereotypes such as an alleged incapacity to speak idiomatic English and a tradition-bound and subservient nature. No Charlie Chan film has been produced since 1981.


title: Charlie Chan

text: The character of Charlie Chan was created by Earl Derr Biggers. In 1919, while visiting Hawaii, Biggers planned a detective novel to be called "The House Without a Key". He did not begin to write that novel until four years later, however, when he was inspired to add a Chinese-American police officer to the plot after reading in a newspaper of Chang Apana and Lee Fook, two detectives on the Honolulu police force. Biggers, who disliked the Yellow Peril stereotypes he found when he came to California, explicitly conceived of the character as an alternative: "Sinister and wicked Chinese are old stuff, but an amiable Chinese on the side of law and order has never been used."


title: Charlie Chan

text: The "amiable Chinese" made his first appearance in "The House Without a Key" (1925). The character was not central to the novel and was not mentioned by name on the dust jacket of the first edition. In the novel, Chan is described as "very fat indeed, yet he walked with the light dainty step of a woman" and in "The Chinese Parrot" as being " … an undistinguished figure in his Western clothes. According to critic Sandra Hawley, this description of Chan allows Biggers to portray the character as nonthreatening, the opposite of evil Chinese characters, such as Fu Manchu, while simultaneously emphasizing supposedly Chinese characteristics such as impassivity and stoicism.


title: Charlie Chan

text: The first film featuring Charlie Chan, as a supporting character, was "The House Without a Key" (1926), a ten-chapter serial produced by Pathé Studios, starring George Kuwa, a Japanese actor, as Chan. A year later Universal Pictures followed with "The Chinese Parrot", starring Japanese actor Kamiyama Sojin as Chan, again as a supporting character. In both productions, Charlie Chan's role was minimized. Contemporary reviews were unfavorable; in the words of one reviewer, speaking of "The Chinese Parrot", Sojin plays "the Chink sleuth as a Lon Chaney cook-waiter … because Chaney can't stoop that low."


title: Charlie Chan

text: For the first film to center mainly on the character of Chan, Warner Oland, a white actor, was cast in the title role in 1931's "Charlie Chan Carries On", and it was this film that gained popular success. Oland, a Swedish actor, had also played Fu Manchu in an earlier film. Oland, who claimed some Mongolian ancestry, played the character as more gentle and self-effacing than he had been in the books, perhaps in "a deliberate attempt by the studio to downplay an uppity attitude in a Chinese detective." Oland starred in sixteen Chan films for Fox, often with Keye Luke, who played Chan's "", Lee Chan. Oland's "warmth and gentle humor" helped make the character and films popular; the Oland Chan films were among Fox's most successful. By attracting "major audiences and box-office grosses on a par with A's" they "kept Fox afloat" during the Great Depression.


title: Charlie Chan

text: Oland died in 1938, and the Chan film "Charlie Chan at the Ringside" was rewritten with additional footage as "Mr. Moto's Gamble", an entry in the Mr. Moto series, another contemporary series featuring an East Asian protagonist; Luke appeared as Lee Chan, not only in already shot footage but also in scenes with Moto actor Peter Lorre. Fox hired another white actor, Sidney Toler, to play Charlie Chan, and produced eleven Chan films through 1942. Toler's Chan was less mild-mannered than Oland's, a "switch in attitude that added some of the vigor of the original books to the films." He is frequently accompanied, and irritated, by his Number Two Son, Jimmy Chan, played by Sen Yung.