title: Austro-Hungarian Compromise of 1867

text: On 7 March 1849 an imperial proclamation was issued in the name of the emperor Franz Joseph establishing a united constitution for the whole empire, according to the new proclamation, the traditional territorial integrity of Kingdom of Hungary would be terminated and carved up, and it would be administered by five separated military districts, while Principality of Transylvania would be reestablished. Austrian Prime Minister Prince Felix of Schwarzenberg and his government, operating from November 1848, pursued a radically new imperial policy. It wanted to develop a uniform empire in the spirit of the imperial constitution issued by Franz Joseph I in Olmütz on 4 March 1849, and as a result, Hungary's constitution and territorial integrity would be abolished. The centralist March Constitution of Austria introduced neo-absolutism in Habsburg ruled territories, and it provided absolute power for the monarch. The Austrian constitution was accepted by the Imperial Diet of Austria, in which Hungary had no representation and traditionally had no legislative power in the territory of Kingdom of Hungary; still, it also tried to abolish the Diet of Hungary, which existed as the supreme legislative power in Hungary since the late 12th century. The new Austrian constitution also went against the historical constitution of Hungary and tried to nullify it.


title: Austro-Hungarian Compromise of 1867

text: In the failed Hungarian Revolution of 1848, the Magyars came close to ending ties with the Habsburg Dynasty, but were defeated by the Austrian Empire only by the military intervention of the Russian Empire. After the restoration of Habsburg power, Hungary was placed under martial law. A military dictatorship was created in Hungary.


title: Austro-Hungarian Compromise of 1867

text: German became the official language of public administration. An edict issued on 9 October 1849 placed education under state control, the curriculum was prescribed and controlled by the state, the teaching of national history was restricted and history was taught from a Habsburg viewpoint. Even the bastion of Hungarian culture, The academy, was kept under control: the institution was staffed with foreigners, mostly Germans, and the institution was practically defunct until the end of 1858. Hungarians responded with passive resistance. Anti-Habsburg and anti-German sentiments were strong. In the following years, the empire instituted several reforms but failed to resolve problems.


title: Austro-Hungarian Compromise of 1867

text: After the Hungarian Revolution of 1848–49, the independent customs system of Hungary was abolished. Hungary became part of the unified imperial customs system on 1 October 1851.


title: Austro-Hungarian Compromise of 1867

text: In 1858 already 40 percent of the government's expenditures went to service the state debt. An expensive mobilization during the Crimean War (1853–1856) and a disastrous campaign against Piedmont-Sardinia in 1859 brought the state to the verge of bankruptcy. The threat of fiscal insolvency and the demands of his creditors for an open and credible budgetary process forced the unwilling Franz Joseph to authorize political reform.


title: Austro-Hungarian Compromise of 1867

text: In 1866, Austria was completely defeated in the Austro-Prussian War. Its position as the leading state of Germany ended, and the remaining German minor states were soon absorbed into the German Empire, created by Prussia's Bismarck. Austria also lost much of its remaining claims and influence in Italy, which had been its chief foreign policy interest.


title: Austro-Hungarian Compromise of 1867

text: After a period of Greater German ambitions, when Austria tried to establish itself as the leading German power, Austria again needed to redefine itself to maintain unity in the face of nationalism.


title: Austro-Hungarian Compromise of 1867

text: As a consequence of the Second Italian War of Independence and the Austro-Prussian War, the Habsburg Empire was on the verge of collapse in 1866, as these wars caused monumental state debt and a financial crisis. The Habsburgs were forced to reconcile with Hungary, to save their empire and dynasty. The Habsburgs and part of the Hungarian political elite arranged the Austro-Hungarian Compromise of 1867. The Compromise was arranged and legitimated by a very small part of the Hungarian society (suffrage was very limited: less than 8% of the population had voting rights), and was seen by a very large part of the population as betrayal of the Hungarian cause and the heritage of the 1848–49 War of Independence. This caused deep and lasting cracks in Hungarian society.


title: Austro-Hungarian Compromise of 1867

text: Hungarian statesman Ferenc Deák is considered the intellectual force behind the Compromise. Deák initially wanted independence for Hungary and supported the 1848 Revolution, but he broke with hardline nationalists and advocated a modified union under the Habsburgs. Deák believed that while Hungary had the right to full internal independence, the terms of the Pragmatic Sanction of 1723 made questions of defence and foreign affairs "common" to both Austria and Hungary. He also felt that Hungary benefited from continued union with wealthier, more industrialized Austria and that the Compromise would end the continual pressures on Austria to choose between the Magyars and the Slavs of the Kingdom of Hungary. Imperial Chancellor Beust quickly negotiated the Compromise with the Hungarian leaders. Beust was particularly eager to renew the conflict with Prussia and thought a quick settlement with Hungary would make that possible. Franz Joseph and Deák signed the Compromise, and it was ratified by the restored Diet of Hungary on 29 May 1867.


title: Austro-Hungarian Compromise of 1867

text: Beust's revenge against Prussia did not materialize. When, in 1870, Beust wanted Austria–Hungary to support France against Prussia, Hungarian Prime Minister Gyula Andrássy was "vigorously opposed" and effectively vetoed Austrian intervention.


title: Austro-Hungarian Compromise of 1867

text: The settlement with Hungary consisted then of three parts: the political settlement, which was to be permanent and would remain part of the fundamental constitution of the monarchy; the periodical financial settlement, determining the partition of the common expenses as arranged by the Quota-Deputations and ratified by the parliaments; and the Customs Union and the agreement on currency, a voluntary, reversible arrangement between the two governments and parliaments.


title: Austro-Hungarian Compromise of 1867

text: The power of the monarch significantly increased in a comparison with the pre-1848 status of Hungary. This meant a great reduction in Hungarian sovereignty and autonomy, even in comparison with the pre-1848 status quo.


title: Austro-Hungarian Compromise of 1867

text: The Austro-Hungarian compromise and its supporting liberal parliamentary parties remained bitterly unpopular among the ethnic Hungarian voters, and the continuous successes of these pro-compromise Liberal Party in the Hungarian parliamentary elections caused long lasting frustration for Hungarians. The ethnic minorities had the key role in the political maintenance of the compromise in Hungary, because they were able to vote the pro-compromise liberal parties into the position of the majority/ruling parties of the Hungarian parliament. The pro-compromise liberal parties were the most popular among ethnic minority voters, however i.e. the Slovak, Serb and Romanian minority parties remained unpopular among their own ethnic minority voters. The coalitions of Hungarian nationalist parties – which were supported by the overwhelming majority of ethnic Hungarian voters – always remained in the opposition, with the exception of the 1906–1910 period, where the Hungarian-supported nationalist parties were able to form a government.


title: Austro-Hungarian Compromise of 1867

text: Before the World War I, only three European countries declared ethnic minority rights, and enacted minority-protecting laws: the first was Hungary (1849 and 1868), the second was Austria (1867), and the third was Belgium (1898). In contrast, the legal systems of other pre-WW1 era European countries did not allow the use of European minority languages in primary schools, in cultural institutions, in offices of public administration and at the legal courts.


title: Austro-Hungarian Compromise of 1867

text: The resulting system was maintained until the dissolution of the dual monarchy after World War I. The favoritism shown to the Magyars, the second largest ethnic group in the dual monarchy after the Germans, caused discontent on the part of other ethnic groups like the Slovaks and Romanians. Although a "Nationalities Law" was enacted to preserve the rights of ethnic minorities, the two parliaments took very different approaches to this issue.


title: Austro-Hungarian Compromise of 1867

text: The basic problem in the later years was that the Compromise with Hungary only encouraged the appetites of non-Hungarian minorities in Hungary that were historically within the boundaries of the Hungarian Kingdom. The majority of Hungarians felt they had accepted the Compromise only under coercion. The Hungarian monarchs were always crowned as King of Hungary, due to the Hungarian coronation oath they had to agree to uphold the old constitutional arrangements of the country and preserve the territorial integrity of the Hungarian realm. This coronation oath was obligatory for the Hungarian monarchs during the coronation process since the Golden Bull of 1222. The Hungarians, who were regarded as equal after the Compromise, only partially acquiesced to granting "their" minorities recognition and local autonomy.


title: Austro-Hungarian Compromise of 1867

text: In the Kingdom of Hungary, several ethnic minorities faced increased pressures of Magyarization. Further, the renegotiation that occurred every ten years often led to constitutional crises. Ultimately, although the Compromise hoped to fix the problems faced by a multi-national state while maintaining the benefits of a large state, the new system still faced the same internal pressures as the old. To what extent the dual monarchy stabilized the country in the face of national awakenings and to what extent it alleviated or aggravated the situation is still debated today.


title: Austro-Hungarian Compromise of 1867

text: In a letter on 1 February 1913, to Foreign Minister Berchtold, Archduke Franz Ferdinand said that "irredentism in our country ... will cease immediately if our Slavs are given a comfortable, fair and good life" instead of being trampled on (as they were being trampled on by the Hungarians).


title: Austro-Hungarian Compromise of 1867

text: As early as the mid-1880s, Lord Salisbury, leader of the British Conservative Party, had contemplated using the 1867 Austro-Hungarian example as a model for a reformed relationship between Britain and Ireland. In 1904 Arthur Griffith published the highly influential book "The Resurrection of Hungary: A Parallel for Ireland", setting out a detailed proposal for an Anglo-Irish dual monarchy similar to the Austro-Hungarian one. This dual monarchy model was advocated by Griffith's Sinn Féin party in its early years of existence and had a considerable influence on the development of Irish Nationalism - though after the Easter Rising and subsequent October 1917 Ardfheis, it was dropped in favor of Irish Republicanism.


title: Cress Williams

text: Cress Williams (born July 26, 1970) is an American actor, known for his roles in "Prison Break" and "Close to Home". His most recent roles include Mayor Lavon Hayes on The CW series "Hart of Dixie" and the title character on The CW's "Black Lightning". Williams is also best known for his recurring role as Terrence "Scooter" Williams on Fox's "Living Single" and as Inspector Atwon Babcock on "Nash Bridges".


title: Cress Williams

text: Williams was born in Heidelberg, Baden-Württemberg, West Germany, to American parents. He took courses at Fullerton College and earned a Bachelor of Arts degree in theatre from University of California, Los Angeles.


title: Cress Williams

text: Williams acted in a 1990 Fullerton College production of William Shakespeare's tragedy, "Othello", which was directed by Tom Blank. He also acted in another production in the same year at Fullerton College called "Red Noses", a black comedy produced by Peter Barnes and directed by Michael Fields.


title: Cress Williams

text: Williams has appeared on many TV series since 1994, including "", "Beverly Hills, 90210", "NYPD Blue", "", "JAG", "Living Single", "Nash Bridges", "Providence", "", "Veronica Mars", "The West Wing", "Close to Home", "ER", and "Grey's Anatomy". He portrayed , a Jem'Hadar leader in the Star Trek series, in a "" episode "The Jem'Hadar". Williams joined the "Prison Break" cast by playing The Company's assassin, Wyatt Mathewson. He appeared in the final season of "Friday Night Lights" as Ornette Howard, father of East Dillon's star quarterback Vince Howard. He also starred alongside Rachel Bilson on The CW series "Hart of Dixie" as former football star turned mayor Lavon Hayes.


title: Cress Williams

text: From 2018 to 2021, he has ventured back into adaptations of DC Comics: As main character Jefferson Pierce / Black Lightning on The CW's superhero TV series "Black Lightning", which was integrated into Arrowverse's prime Earth during "Crisis on Infinite Earths", and as John Henry Irons in the animated film "The Death of Superman" and its 2019 sequel, "Reign of the Supermen". After his "Black Lightning" series concluded, he reprised the role on "The Flash" at the start of its eighth season as part of its "Armageddon" event.


title: Cress Williams

text: On October 14, 2000, Williams married actress Simbi Khali in Malibu, California. The couple had two children and divorced in 2011. Williams married girlfriend Kristen Torrianni in June 2013. Williams and Torrianni also have two children together.


title: Ben Wheatley

text: Benjamin Wheatley (born 7 May 1972) is an English filmmaker and screenwriter. Beginning his career in advertising, Wheatley first gained recognition and acclaim for his commercials and short films, before transitioning into feature films and television programmes. He is best known for his work in the thriller and horror genres, with his films frequently incorporating heavy elements of black comedy and satire. His best-known works include the psychological horror films "Kill List" and "A Field in England", the J. G. Ballard adaptation "High-Rise," and the action comedy "Free Fire."


title: Ben Wheatley

text: Wheatley has received numerous accolades for his work, including an Evening Standard British Film Award, five British Independent Film Award nominations, and numerous awards and honours from film festivals including South by Southwest, Karlovy Vary International, Mar del Plata International, Raindance, Toronto International, and Cannes Film Festival.


title: Ben Wheatley

text: Wheatley was born in Billericay, Essex, England. He went to Haverstock School in North London and it was here during the sixth form that he met Amy Jump, who is now his wife and co-founder of the "Mr and Mrs Wheatley" blog. The couple have a son and live in Brighton.


title: Ben Wheatley

text: Initially a short film maker and animator, Wheatley moved his work to the internet, and was a regular contributor to the b3ta message board. His clip ""cunning stunt"" which shows his friend Rob Hill jumping over a car has had over 10 million views. The hundred or so short animations and games found on the "Mr and Mrs Wheatley" site were noticed by large media companies and Wheatley's work expanded into mainstream media.


title: Ben Wheatley

text: In 2006, Wheatley won a "Lion" award at Cannes advertising festival for directing the AMBX viral, with The Viral Factory. In July 2006 he directed live-action sections of the TV series "Modern Toss", ("i live ere", "Alan", "Drive by abuser", "Customer services", "Accident and emergency", "Citizens advice", "Illegal alphabet"), which was aired on Channel 4. Wheatley has also written and created clips for BBC Two's "Time Trumpet" and has appeared in and directed sketches for BBC Three's "Comedy Shuffle". Between 2007 and 2009 Wheatley directed series 2 of "Modern Toss" and "Ideal" series 5 and 6. In 2008, Wheatley co-created and directed the sketch series "The Wrong Door" for BBC Three.


title: Ben Wheatley

text: In May 2009 he directed the feature film "Down Terrace" in eight days; it won the Next Wave prize at Fantastic Fest in Austin and Best UK Feature at Raindance in London. In 2010 Wheatley completed his second feature, "Kill List" for Warp X. The film received critical acclaim and won Michael Smiley a British Independent Film Award for Best Supporting Actor. The movie holds a 76% rating on Rotten Tomatoes with a critic consensus describing the film as "an expertly executed slow-burn crime thriller that thrives on tension before morphing into visceral horror."


title: Ben Wheatley

text: Wheatley's third film was the black comedy "Sightseers", released in the UK in November 2012. It was written by its stars, Alice Lowe and Steve Oram, with additional material by Amy Jump, and was chosen for the Directors' Fortnight section of the 2012 Cannes Film Festival. Wheatley's fourth film, "A Field in England" was financed through the Film4 talent and ideas hub, Film4.0. It was followed in 2016 by "High Rise", an adaptation of the J. G. Ballard novel of the same name. He has also directed advertisements for Blink Productions and Moxie.


title: Ben Wheatley

text: A sci-fi TV series, "Silk Road", written and directed by Wheatley, has been announced. It is said to be "in the vein of the Patrick McGoohan TV series "The Prisoner"," and will be screened on HBO. In 2014, Wheatley directed the first two episodes of the eighth series of "Doctor Who", a show he has been a fan of since childhood.


title: Ben Wheatley

text: Wheatley wrote and directed "Free Fire" starring an ensemble cast including Cillian Murphy, Brie Larson, Armie Hammer and Sharlto Copley. His film "Happy New Year, Colin Burstead" was made for the BBC 2018 Christmas schedule and remains available to watch on iPlayer.


title: Ben Wheatley

text: In November 2018, Wheatley was set to direct an adaptation of Daphne du Maurier's gothic romance novel "Rebecca," a Working Title Films production. Released on Netflix in October 2020, the film stars Lily James, Armie Hammer, and Kristin Scott Thomas. It received mixed reviews, with a score of 46 on review aggregator site Metacritic.


title: Ben Wheatley

text: In the fall of 2019, Wheatley was announced as the director of the sequel for "Tomb Raider", based on the popular video-game franchise of the same name and starring Academy Award-winning actress Alicia Vikander as Lara Croft, with Amy Jump to pen the script. However, in October 2020 it was announced that the film's March 2021 release had been delayed indefinitely amid a series of production issues related to the COVID-19 pandemic. In January 2021, Wheatley was replaced by "Lovecraft Country" creator Misha Green, and the script was rewritten. As of July 2022, the film is in production.


title: Ben Wheatley

text: In November 2020, it was announced that Wheatley had wrapped production on "In the Earth", a pandemic-set horror film starring Joel Fry, Ellora Torchia, Hayley Squires and Reece Shearsmith. Neon released the film in the U.S. in 2021.


title: Ben Wheatley

text: In October 2020, it was announced that Wheatley would take over to the science-fiction horror film "The Meg", starring Jason Statham and Li Bingbing, based on Steve Alten's eponymous series of novels. Alten confirmed the sequel film will be an adaptation of the second book of the series, "The Trench".


title: Homestead Acts

text: The Homestead Acts were several laws in the United States by which an applicant could acquire ownership of government land or the public domain, typically called a homestead. In all, more than of public land, or nearly 10 percent of the total area of the United States, was given away free to 1.6 million homesteaders; most of the homesteads were west of the Mississippi River.


title: Homestead Acts

text: An extension of the homestead principle in law, the Homestead Acts were an expression of the Free Soil policy of Northerners who wanted individual farmers to own and operate their own farms, as opposed to Southern slave-owners who wanted to buy up large tracts of land and use slave labor, thereby shutting out free white farmers.


title: Homestead Acts

text: The first of the acts, the Homestead Act of 1862, opened up millions of acres. Any adult who had never taken up arms against the Federal government of the United States could apply. Women and immigrants who had applied for citizenship were eligible.


title: Homestead Acts

text: Several additional laws were enacted in the late 19th and early 20th centuries. The Southern Homestead Act of 1866 sought to address land ownership inequalities in the south during Reconstruction. It explicitly included Black Americans and encouraged them to participate, but rampant discrimination, systemic barriers, and bureaucratic inertia slowed Black gains. Despite those hurdles, the 1866 law was not as beneficial as it might have been, but it was part of the reason that by 1900, one quarter of all Southern Black farmers owned their own farms.


title: Homestead Acts

text: The Timber Culture Act of 1873 granted land to a claimant who was required to plant trees—the tract could be added to an existing homestead claim and had no residency requirement. The Kinkaid Amendment of 1904 granted a full section——to new homesteaders settling in western Nebraska. An amendment to the Homestead Act of 1862, the Enlarged Homestead Act, was passed in 1909 and doubled the allotted acreage from in marginal areas. Another amended act, the national Stock-Raising Homestead Act, was passed in 1916 and granted for ranching purposes.


title: Homestead Acts

text: Land-grant laws similar to the Homestead Acts had been proposed by northern Republicans prior to Civil War but they had been repeatedly blocked in Congress by Democrats who wanted western lands open for purchase by slave-owners. The Homestead Act of 1860 passed in Congress but was vetoed by President James Buchanan, a Democrat. After the Southern states seceded from the Union in 1861 (and their representatives had left Congress), the bill passed and was signed into law by President Abraham Lincoln (May 20, 1862). Daniel Freeman became the first person to file a claim under the new act.


title: Homestead Acts

text: Between 1862 and 1934, the federal government granted 1.6 million homesteads and distributed of federal land for private ownership. This was a total of 10% of all land in the United States. Homesteading was discontinued in 1976, except in Alaska, where it continued until 1986. About 40% of the applicants who started the process were able to complete it and obtain title to their homesteaded land after paying a small fee in cash.


title: Homestead Acts

text: Homestead laws depleted Native American resources as much of the land they relied on was taken by the Federal government and sold to settlers.


title: Homestead Acts

text: The Preemption Act of 1841 allowed settlers to claim up to 160 acres of federal land for themselves, and prevent its sale to others including large landowners or corporations; they paid only a low fixed price of $1.25 per acre ($3.09 per hectare). To qualify, a person had to be either 21 years old or a "head of household" (such as a parent or surviving sibling supporting a family), a citizen or an immigrant declaring to become a citizen, and a resident on that land for a minimum of 14 months. To get permanent title to the land, the person had to accomplish specific things, such as continue to reside on it or improve it for at least five years; they could not leave or abandon it for more than six months at a time.


title: Homestead Acts

text: The Donation Land Claim Act allowed settlers to claim land in the Oregon Territory, then including the modern states of Washington, Oregon, Idaho and parts of Wyoming. The Oregon Donation Land Claim Act was passed in 1850 and allowed white settlers to claim 320 acres or 640 to married couples between 1850 and 1855 when the act was repealed. Before it was repealed in 1855, the land was sold for $1.25 per acre. After the creation of the Oregon territory in 1848, the US government had passed the most generous land distribution bill in US history.


title: Homestead Acts

text: The Oregon Land Donation Act of 1850 had many negative effects on Indigenous people as well as Black people in the Pacific Northwest. Not only did the act use the land taken away from the Indigenous people in the Pacific Northwest, but the act also barred Black citizens from owning land and real estate. The act guaranteed land for white settlers and "half-breed" Indian men to the Oregon territory. This act followed the passing of the 1848 territorial organic act which allowed any white settler to claim a maximum of six hundred and forty acres. The Land Donation Act, however, also acknowledged women’s property rights due to Congress allowing the donation of four hundred acres to settlers—land that could be claimed by heads of households—including women. This act differed from the Homestead Act of 1866 due to the ineligibility of Black citizens from applying.


title: Homestead Acts

text: The "yeoman farmer" ideal of Jeffersonian democracy was still a powerful influence in American politics during the 1840–1850s, with many politicians believing a homestead act would help increase the number of "virtuous yeomen". The Free Soil Party of 1848–52, and the new Republican Party after 1854, demanded that the new lands opening up in the west be made available to independent farmers, rather than wealthy planters who would develop it with the use of slaves forcing the yeomen farmers onto marginal lands. Southern Democrats had continually fought (and defeated) previous homestead law proposals, as they feared free land would attract European immigrants and poor Southern whites to the west.


title: Homestead Acts

text: The intent of the Homestead Act of 1862 was to reduce the cost of homesteading under the Preemption Act; after the South seceded and their delegates left Congress in 1861, the Republicans and supporters from the upper South passed a homestead act signed by Abraham Lincoln on May 20, 1862 which went into effect on Jan. 1st, 1863. Its leading advocates were Andrew Johnson George Henry Evans and Horace Greeley. George Henry Evans famously coined the phrase "Vote Yourself a Farm" in a bid to garner support for the movement.


title: Homestead Acts

text: In addition to the previous requirement in the Preemption Act of being either 21 years old or the head of a family, the 1862 act also allowed for persons under 21 who had served in the regular or volunteer forces of the U.S. army or navy for at least 14 days during "the existence of an actual war domestic or foreign".


title: Homestead Acts

text: The new act also required that the person "has never borne arms against the United States Government or given aid and comfort to its enemies"; unlike the 1948 and 1850 laws, it did not have any provision mentioning race.


title: Homestead Acts

text: The Homestead act expanded, rather than changed, the 1841 Preemption Act. The claimed homestead could include the same land which they had previously filed a pre-emption claim (on up to 160 acres at $1.25 per acre, or up to 80 acres of subdivided and surveyed land at $2.50 per acre), and they could expand their current ownership to contiguous adjacent land up to 160 acres total.


title: Homestead Acts

text: However, the homestead application must be "made for his or her exclusive use and benefit, and that said entry [onto public land] is made for the purpose of actual settlement and cultivation, and not either directly or indirectly for the use or benefit of any other person or persons whomsoever". The acquired land would not be liable for any debts incurred prior to the issuance of the patent for it.


title: Homestead Acts

text: The time requirement for residence or cultivation was set at 5 years; if it was proven "after due notice" that they moved residence or abandoned the land for more than six months at a time, then the land reverted to the government. A homesteader could also pay the $1.25 (or the current rate) per acre price after proof of the less-stringent requirements set in the Preemption Act.


title: Homestead Acts

text: After filing an affidavit with the government's agent, and paying him a $10 fee, the homesteader could begin occupying their claim. The government agent received the same fee for homestead land as he would have received if that land was sold for cash, 1/2 from the homesteader's filing fee and the other half from the patent (certificate) fee. The homesteader did not get a certificate or patent until they or their heirs filed, after 5 years (but before 7 years), further affidavits from two neighbors or "credible witnesses" and an additional $8 fee. Those affidavits affirmed the 5 years of residence or cultivation and that "no part of said land has been alienated [transferred or mortgaged], and that he [the homesteader] has borne true allegiance to the Government of the United States".


title: Homestead Acts

text: If both parents died and all the children were under 21, an executor under state law could sell (for the benefit of the children, and not the estate) an absolute title to the land within two years of the parent's death. The purchaser would pay office fees for a patent to the land.


title: Homestead Acts

text: Enacted to allow poor tenant farmers and sharecroppers in the South to become landowners in the Southern United States during Reconstruction. It was not very successful, as even the low prices and fees were often too much for the applicants to afford.


title: Homestead Acts

text: The Timber Culture Act granted up to 160 acres of land to a homesteader who would plant at least 40 acres (revised to 10) of trees over a period of several years. This quarter-section could be added to an existing homestead claim, offering a total of 320 acres to a settler.


title: Homestead Acts

text: Recognizing that the Sandhills of north-central Nebraska required more than 160 acres for a claimant to support a family, Congress passed the Kinkaid Act, which granted larger homestead tracts, up to 640 acres, to homesteaders in Nebraska.


title: Homestead Acts

text: This act allowed homesteads within Forest Reserves (created from 1891 on) and National Forests (from 1905? on), responding to opponents of the nation's Forest Reserves who felt land suited for agriculture was being withheld from private development. Homestead applications were reviewed by the U.S. Forest Service (created in 1905). While at first five years residency was required (per the 1862 Act), in 1913 this act was amended to allow proving up in just three years.


title: Homestead Acts

text: Because by the early 1900s much of the prime low-lying alluvial land along rivers had been homesteaded, the "Enlarged Homestead Act" was passed in 1909. To enable dryland farming, it increased the number of acres for a homestead to given to farmers who accepted more marginal lands (especially in the Great Plains), which could not be easily irrigated.


title: Homestead Acts

text: A massive influx of these new farmers, combined with inappropriate cultivation techniques and misunderstanding of the ecology, led to immense land erosion and eventually the Dust Bowl of the 1930s.


title: Homestead Acts

text: In 1916, the "Stock-Raising Homestead Act" was passed for settlers seeking of public land for ranching purposes.


title: Homestead Acts

text: Renewed interest in homesteading was brought about by U.S. President Franklin D. Roosevelt's program of Subsistence Homesteading implemented in the 1930s under the New Deal.


title: Homestead Acts

text: In 1938 Congress passed a law, called the Small Tract Act (STA) of 1938, by which it is possible for any citizen to obtain certain lands from the Federal Government for residence, recreation, or business purposes. These tracts may not usually be larger than 5 acres. A 5-acre tract would be one which is 660 feet long and 330 feet wide, or its equivalent. The property was to be improved with a building. Starting July 1955, improvement was required to be minimum of 400 sq. feet of space. 4,000 previously classified Small Tracts were offered at public auction at fair market value, circa 1958, by the Los Angeles Office of BLM.


title: Homestead Acts

text: Settlers found land and filed their claims at the regional land office, usually in individual family units, although others formed closer-knit communities. Often, the homestead consisted of several buildings or structures besides the main house.


title: Homestead Acts

text: The Homestead Act of 1862 gave rise later to a new phenomenon, large land rushes, such as the Oklahoma Land Runs of the 1880s and '90s.


title: Homestead Acts

text: The Federal Land Policy and Management Act of 1976 ended homesteading; by that time, federal government policy had shifted to retaining control of western public lands. The only exception to this new policy was in Alaska, for which the law allowed homesteading until 1986.


title: Homestead Acts

text: The last claim under this Act was made by Ken Deardorff for of land on the Stony River in southwestern Alaska. He fulfilled all requirements of the homestead act in 1979 but did not receive his deed until May 1988. He is the last person to receive a title to land claimed under the Homestead Acts.


title: Homestead Acts

text: The Homestead Acts were sometimes abused, but historians continue to debate the extent. In the 1950s and 1960s historians Fred Shannon, Roy Robbins and Paul Wallace Gates emphasized fraudulent episodes, and historians largely turned away from the issue. In recent decades, however, the argument has mostly been that on the whole fraud was a relatively minor element and that strongly positive impacts regarding women and the family have only recently been appreciated. Robert Higgs argues that the Homestead Act induced no long-term misallocation of resources. In 1995, a random survey of 178 members of the Economic History Association found that 70 percent of economists and 84 percent of economic historians disagreed that "Nineteenth-century U.S. land policy, which attempted to give away free land, probably represented a net drain on the productive capacity of the country."


title: Homestead Acts

text: Although the intent was to grant land for agriculture, in the arid areas just east of the Rocky Mountains, was generally too little land for a viable farm (at least prior to major federal public investments in irrigation projects). In these areas, people manipulated the provisions of the act to gain control of resources, especially water. A common scheme was for an individual, acting as a front for a large cattle operation, to file for a homestead surrounding a water source, under the pretense that the land was to be used as a farm. Once the land was granted, other cattle ranchers would be denied the use of that water source, effectively closing off the adjacent public land to competition. That method was also used by large businesses and speculators to gain ownership of timber and oil-producing land. The federal government charged royalties for extraction of these resources from public lands. On the other hand, homesteading schemes were generally pointless for land containing "locatable minerals," such as gold and silver, which could be controlled through mining claims under the Mining Act of 1872, for which the federal government did not charge royalties.


title: Homestead Acts

text: The government developed no systematic method to evaluate claims under the Homestead Acts. Land offices relied on affidavits from witnesses that the claimant had lived on the land for the required period of time and made the required improvements. In practice, some of these witnesses were bribed or otherwise colluded with the claimant.


title: Homestead Acts

text: It was common practice and not fraudulent for the eligible children of a large family to claim nearby land as soon as possible. After a few generations, a family could build up a sizable estate.


title: Homestead Acts

text: The homesteads were criticized as too small for the environmental conditions on the Great Plains; a homesteader using 19th-century animal-powered tilling and harvesting could not have cultivated the 1500 acres later recommended for dry land farming. Some scholars believe the acreage limits were reasonable when the act was written, but argue that no one understood the physical conditions of the plains.


title: Homestead Acts

text: According to Hugh Nibley, much of the rainforest west of Portland, Oregon was acquired by the Oregon Lumber Company by illegal claims under the Act.


title: Homestead Acts

text: The Legislative Assembly of Ontario passed "The Free Grants and Homestead Act" in 1868, which introduced a conditional scheme to an existing free grant plan previously authorized by the Province of Canada in "The Public Lands Act" of 1860. It was extended to include settlement in the Rainy River District under "The Rainy River Free Grants and Homestead Act, 1886", These Acts were consolidated in 1913 in "The Public Lands Act", which was further extended in 1948 to provide for free grants to former members of the Canadian Forces. The original free grant provisions for settlers were repealed in 1951, and the remaining provisions were repealed in 1961.


title: Homestead Acts

text: The Parliament of Canada passed the "Dominion Lands Act" in 1872 in order to encourage settlement in the Northwest Territories. Its application was restricted after the passage of the Natural Resources Acts in 1930, and it was finally repealed in 1950.


title: Homestead Acts

text: The Legislative Assembly of Quebec did not expand the scope of the 1860 Province of Canada Act (which modern day Quebec was part of in 1860), but did provide in 1868 that such lands were exempt from seizure, and chattels thereon were also exempt for the first ten years of occupation. Later known as the "Settlers Protection Act", it was repealed in 1984.


title: Homestead Acts

text: Newfoundland and Labrador provided for free grants of land upon proof of possession for twenty years prior to 1977, with continuous use for agricultural, business or residential purposes during that time. Similar programs continued to operate in Alberta and British Columbia until 1970. In the early 21st century, some land is still being granted in the Yukon Territory under its Agricultural Lands Program.


title: Homestead Acts

text: Despite the 1840 Treaty of Waitangi provisions for sale of land, the Māori Land Court decided that all land not cultivated by Māori was 'waste land' and belonged to the Crown without purchase. Most provinces in colonial New Zealand had Waste Lands Acts enacted between 1854 and 1877. The 1874 Waste Lands Act in Auckland Province used the term Homestead, with allocation administered by a Crown Lands Board. There was similar legislation in Westland. It gave up to , with settlers just paying the cost of a survey. They had to live there for five years, build a house and cultivate a third of the land, if already open, or a fifth if bush had to be cleared. The land was forfeited if they didn't clear enough bush. Further amendments were made in 1877, 1882 and 1885, adding details such as pastoral and perpetual leases and village and special settlements. This contributed to rapid deforestation.


title: Homestead Acts

text: Several selection acts were passed in colonial Australia which were based on the Crown Lands Acts. They were passed in all six of the Australian colonies prior to federation, with the first one, New South Wales, passing such legislation in 1861.


title: Almighty Black P. Stone Nation

text: The Almighty Black P. Stone Nation often abbreviated as (BPS, BPSN, Black Peace Stones, Black P. Stones, Stones, or Moes) is an American street gang founded in Chicago. The gang was originally formed in the late 1950s as the Blackstone Rangers. The organization was co-founded by Eugene Hairston and Jeff Fort. In later years, under Fort's leadership, an Islamic faction of the gang emerged, naming themselves the "El Rukn tribe of the Moorish Science Temple of America" (or simply El Rukn, Arabic for "the pillar" or "the foundation").


title: Almighty Black P. Stone Nation

text: They eventually started describing themselves as Orthodox Sunni Muslims. Jeff Fort changed their fort name from El Rukn Moorish Science Mosque, to El Rukn Sunni Masjid al-Malik.


title: Almighty Black P. Stone Nation

text: Considered by law enforcement authorities to be Chicago's most powerful and sophisticated street gang, the BPSN finances itself through a wide array of criminal activities and is part of the large Chicago gang alliance known as the People Nation. Under Fort's command, the BPSN assumed an increasingly revolutionary outlook as it became associated with the black nationalism movement, eventually attracting the attention of the Nation of Islam leader Louis Farrakhan, who introduced them to Libyan leader Muammar al-Gaddafi and Nicaragua's Sandinistas. In 1986 four of its members were indicted for conspiring to commit terrorist acts in the United States for the Libyan Government. The verdict marked the first time American citizens had been found guilty of planning terrorist acts for a foreign government in return for money.


title: Almighty Black P. Stone Nation

text: The BPSN originated, and is based, on the South Side of Chicago in the Woodlawn neighborhood. The BPSN had then advanced in the North-West Indiana communities of Gary, Merrillville, Crown Point, Portage and Elkhart. It has since emerged in other areas, particularly Wheatley Place, South Dallas Texas in the United States and Meadow Heights, North-West Victoria in Australia.


title: Almighty Black P. Stone Nation

text: There is a set in the West-Side Black P Stones in the Los Angeles area called the Jungles and the Bity another area called Crenshaw & Adams. They were founded by OG T Rodgers from Chicago after he moved to Los Angeles. When he was 13 years old he built his set, with 500 or more in membership. They also are affiliated with the Bloods due to the Bloods and the Piru Bloods protecting BPSN in Los Angeles from the Crips when they began in Los Angeles.


title: Almighty Black P. Stone Nation

text: The Blackstone Rangers were founded at the St. Charles Institution for Troubled Youth by Jeff Fort and Eugene Hairston as a community organization for black youth in the Woodlawn area of South Chicago. Between 1961 and 1963, they evolved into one of the most dangerous and powerful gangs in Chicago. Fort seized upon the gang's changed mission, renaming it the Black P.(Peace) Stone Nation. He transformed the BPSN into a black nationalistic group, and continued to involve the gang in street crime and drug trafficking. BPSN co-founder Eugene Hairston was incarcerated on drug charges in June 1966 and was eventually murdered in 1988. Fort was arrested for mismanagement of government grants totaling $927,000 from the U.S. Office of Economic Opportunity in March 1972. Fort was released in 1976, but was later re-incarcerated on drug charges in the early 1980s. At the same time he was released from prison, Fort converted to Islam and imbued the BPSN with Islamic overtones, and adopted the name Abdul Malik Ka'bah.


title: Almighty Black P. Stone Nation

text: Following meetings during 1986 with Libyan operatives from Colonel Gaddafi's government, Fort was arrested. In 1987, Fort was tried and convicted for conspiring with Libya to perform acts of domestic terrorism. He was sentenced to 80 years imprisonment and transferred to the USP Marion, the federal supermax prison in Marion, Illinois.


title: Almighty Black P. Stone Nation

text: In 1988, Fort was also convicted of ordering the 1981 murder of a rival gang leader and was sentenced to 75 years in prison to be served after the completion of his terror conspiracy sentence. While Fort continues to exercise considerable influence over the BPS from prison, the various Black Stones splinter groups suffer from rampant infighting without a clear leader. There are two major groups that have split with the BPSN: The Mickey Cobras were supporters of Mickey Cogwell, a co-founder of BPSN killed by Jeff Fort. The Titanic Stones were supporters of Eugene Hairston who had a falling-out with Fort.


title: Paper wasp

text: Paper wasps are vespid wasps that gather fibers from dead wood and plant stems, which they mix with saliva, and use to construct nests made of gray or brown papery material. Some types of paper wasps are also sometimes called umbrella wasps, due to the distinctive design of their nests.


title: Paper wasp

text: The name "paper wasps" typically refers to members of the vespid subfamily Polistinae, though it often colloquially includes members of the subfamilies Vespinae (hornets and yellowjackets) and Stenogastrinae, which also make nests out of paper. Twenty-two species of "Polistes" paper wasps have been identified in North America and approximately 300 species have been identified worldwide. The most common paper wasp in Europe is "Polistes dominula". The Old World tribe Ropalidiini contains another 300 species, and the Neotropical tribes Epiponini and Mischocyttarini each contain over 250 more, so the total number of true paper wasps worldwide is about 1100 species, almost half of which can be found in the neotropics.


title: Paper wasp

text: The nests of most true paper wasps are characterized by having open combs with cells for brood rearing, and a 'petiole', or constricted stalk, that attaches the nest to a branch or other structure. Paper wasps secrete a chemical which repels ants, which they spread around the base of the anchor to prevent the loss of eggs or brood.


title: Paper wasp

text: Most social wasps of the family Vespidae make nests from paper, but some stenogastrine species, such as "Liostenogaster flavolineata", use mud. A small group of eusocial crabronid wasps, of the genus "Microstigmus" (the only eusocial wasps outside the family Vespidae), also constructs nests out of chewed plant fibers, though the nest consistency is quite different from those of true paper wasps, due to the absence of wood fibers, and the use of silk extruded by female wasps to bind the fibers.


title: Paper wasp

text: Nests can be found in sheltered areas, such as the eaves of a house, the branches of a tree, on the end of an open pipe, or on an old clothesline. Some species, such as "Ropalidia romandi", will vary their nest architecture depending on where they build their nest.


title: Paper wasp

text: Three species of "Polistes" are obligate social parasites, and have lost the ability to build their own nests, and are sometimes referred to as "cuckoo paper wasps". They rely on the nests of their hosts to raise their brood. A few hornets and yellowjackets are also brood parasites (e.g., "Vespula austriaca").


title: Paper wasp

text: Unlike yellowjackets and hornets, which can be very aggressive, polistine paper wasps will generally only attack if they themselves or their nest are threatened. Their territoriality can lead to attacks on people, and their stings are quite painful and – like all venomous animals – can produce a potentially fatal anaphylactic reaction in some individuals. A study conducted on European paper wasps ("Polistes dominula") concluded that wasps with brighter aposematic colors are more venomous, because they have larger venom glands, and offer a stronger warning signal to organisms threatening the nest.


title: Paper wasp

text: Most wasps are beneficial in their natural habitat, and are critically important in natural biocontrol. Paper wasps feed on nectar and other insects, including caterpillars, flies, and beetle larvae. Because they are a known pollinator and feed on known garden pests, paper wasps are often considered to be beneficial by gardeners.


title: Strategic lawsuit against public participation

text: Strategic lawsuits against public participation (also known as SLAPP suits or intimidation lawsuits), or strategic litigation against public participation, are lawsuits intended to censor, intimidate, and silence critics by burdening them with the cost of a legal defense until they abandon their criticism or opposition.


text: In a typical SLAPP, the plaintiff does not normally expect to win the lawsuit. The plaintiff's goals are accomplished if the defendant succumbs to fear, intimidation, mounting legal costs, or simple exhaustion and abandons the criticism. In some cases, repeated frivolous litigation against a defendant may raise the cost of directors and officers liability insurance for that party, interfering with an organization's ability to operate. A SLAPP may also intimidate others from participating in the debate. A SLAPP is often preceded by a legal threat. SLAPPs bring about freedom of speech concerns due to their chilling effect and are often difficult to filter out and penalize because the plaintiffs attempt to obfuscate their intent to censor, intimidate, or silence their critics.


text: To protect freedom of speech, some jurisdictions have passed anti-SLAPP laws (often called SLAPP-back laws). These laws often function by allowing a defendant to file a motion to strike and/or dismiss on the grounds that the case involves protected speech on a matter of public concern. The plaintiff then bears the burden of showing a probability that they will prevail. If the plaintiffs fail to meet their burden their claim is dismissed and the plaintiffs may be required to pay a penalty for bringing the case.


text: Anti-SLAPP laws sometimes come under criticism from those who believe that there should not be barriers to the right to petition for those who sincerely believe they have been wronged, regardless of ulterior motives. Hence, the difficulty in drafting SLAPP legislation, and in applying it, is to craft an approach which affords an early termination to invalid, abusive suits, without denying a legitimate day in court to valid good faith claims. Anti-SLAPP laws are generally considered to have a favorable effect, and many lawyers have fought to enact stronger laws protecting against SLAPPs.


text: SLAPP is a form of strategic litigation or impact litigation. SLAPPs take various forms. The most common used to be a civil suit for defamation, which in the English common law tradition was a tort. The common law of libel dates to the early 17th century and, unlike most English law, is reverse onus, meaning that once someone alleges a statement is libelous, the burden is on the defendant to prove that it is not. In England and Wales, the Defamation Act 2013 removed most of the uses of defamation as a SLAPP by requiring the proof of special damage. Various abuses of this law including political libel (criticism of the political actions or views of others) have ceased to exist in most places, but persist in some jurisdictions (notably British Columbia and Ontario) where political views can be held as defamatory.


text: A common feature of SLAPPs is forum shopping, wherein plaintiffs find courts that are more favourable towards the claims to be brought than the court in which the defendant (or sometimes plaintiffs) live.


text: Other widely mentioned elements of a SLAPP are the actual effectiveness at silencing critics, the timing of the suit, inclusion of extra or spurious defendants (such as relatives or hosts of legitimate defendants), inclusion of plaintiffs with no real claim (such as corporations that are affiliated with legitimate plaintiffs), making claims that are very difficult to disprove or rely on no written record, ambiguous or deliberately mangled wording that lets plaintiffs make spurious allegations without fear of perjury, refusal to consider any settlement (or none other than cash), characterization of all offers to settle as insincere, extensive and unnecessary demands for discovery, attempts to identify anonymous or pseudonymous critics, appeals on minor points of law, and demands for broad rulings when appeal is accepted on such minor points of law. In some instances it is clear that plaintiffs are attempting to drain defendants of their financial resources by making the lawsuit as costly as possible, and in these cases the plaintiff's motive may not be legal victory, but merely to waste the defendant's time and money.


text: The acronym was coined in the 1980s by University of Denver professors Penelope Canan and George W. Pring. The term was originally defined as "a lawsuit involving communications made to influence a governmental action or outcome, which resulted in a civil complaint or counterclaim filed against nongovernment individuals or organizations on a substantive issue of some public interest or social significance." The concept's originators later dropped the notion that government contact had to be about a public issue to be protected by the right to petition the government, as provided in the First Amendment. It has since been defined less broadly by some states, and more broadly in one state (California) where it includes suits about speech on any public issue.


text: The original conceptualization proffered by Canan and Pring emphasized the right to petition as protected in the United States under the US Constitution's specific protection in the First Amendment's fifth clause. It is still definitional: SLAPPs are civil lawsuits filed against those who have communicated to government officialdom (in its entire constitutional apparatus). The right to petition, granted by Edgar the Peaceful, King of England in the 10th century, antedates Magna Carta in terms of its significance in the development of democratic institutions. As currently conceived, the right claims that democracy cannot properly function in the presence of barriers between the governed and the governing.


text: New York Supreme Court Judge J. Nicholas Colabella said in reference to SLAPPs: "Short of a gun to the head, a greater threat to First Amendment expression can scarcely be imagined." In the United States a number of jurisdictions have made such suits illegal, however the conditions that a defendant must satisfy for a dismissal of the suit vary from state to state. In some states, such as California, defendants may be entitled to counter-sue SLAPP plaintiffs under some circumstances. This is commonly referred to as SLAPPback.


text: In the Australian Capital Territory, the "Protection of Public Participation Act 2008" (ACT) protects conduct intended to influence public opinion or promote or further action in relation to an issue of public interest. A party starting or maintaining a proceeding against a defendant for an improper purpose may be ordered to pay a financial penalty to the Territory.


text: Some political libel and forum shopping incidents, both relatively uncommon in Canada, have been called SLAPPs, because such suits load defendants with costs of responding in unfamiliar jurisdictions or at times (typically elections) when they are extremely busy and short of funds. Both types of suit are unusual in Canada, so there is little academic concern or examination of whether political subject matter or remote forums are a clear indicator of SLAPP.


text: Canada's three most populous provinces (Quebec, British Columbia, and Ontario) have enacted anti-SLAPP legislation.


text: One of the first cases in Canada to be explicitly ruled a SLAPP was "Fraser v. Saanich" (see [1999] B.C.J. No. 3100 (B.C. S.C.)) (QL), where the British Columbia Supreme Court struck out the claim of a hospital director against the District of Saanich, holding that it was a meritless action designed to silence or intimidate the residents who were opposed to the plaintiff's plan to redevelop the hospital facilities.


text: Following the decision in "Fraser v. Saanich", the Protection of Public Participation Act (PPPA) went into effect in British Columbia in April 2001. The legislation was repealed in August 2001. There was extensive debate on its merits and the necessity of having hard criteria for judges and whether this tended to reduce or increase process abuse. The debate was largely formed by the first case to discuss and apply the PPPA, "Home Equity Development v. Crow". The defendants' application to dismiss the action against them was dismissed. The defendants failed to meet the burden of proof required by the PPPA, that the plaintiffs had no reasonable prospect of success. While it was not the subject of the case, some felt that the plaintiffs did not bring their action for an improper purpose, and the suit did not inhibit the defendants in their public criticism of the particular project, and that the Act was, therefore, ineffective in this case.


text: Since the repeal, BC activists especially the BCCLA have argued repeatedly for a broad understanding of SLAPP and a broad interpretation of judicial powers especially in intervener applications in BC and other common law jurisdictions and when arguing for new legislation to prevent SLAPPs. The activist literature contains extensive research on particular cases and criteria. The West Coast Environmental Law organization agrees and generally considers BC to lag other jurisdictions.


text: In March 2019, the legislature voted unanimously to pass another anti-SLAPP bill, the Protection of Public Participation Act.


text: A private member's bill introduced in 2001 by Graham Steele (NDP, Halifax Fairview) proposed a "Protection of Public Participation Act" to dismiss proceedings or claims brought or maintained for an improper purpose, awarding punitive or exemplary damages (effectively, a "SLAPP back") and protection from liability for communication or conduct which constitutes public participation. The bill did not progress beyond first reading.


text: In Ontario, the decision in "Daishowa v. Friends of the Lubicon" [1996] O.J. No. 3855 Ont. Ct. Gen. Div. (QL) was instructive on SLAPPs. A motion brought by the corporate plaintiff Daishowa to impose conditions on the defendant Friends of the Lubicon Indian Band that they would not represent Daishowa's action as a SLAPP was dismissed.


text: By 2010, the Ontario Attorney-General had issued a major report which identified SLAPP as a major problem but initially little to nothing was done.


text: In June 2013, the Attorney General introduced legislation to implement the recommendations of the report. The bill proposed a mechanism for an order to dismiss strategic lawsuits which attack free expression on matters of public interest, with full costs (but not punitive damages) and on a relatively short timeframe, if the underlying claims had no reasonable prospect of success.


text: The bill enjoyed support from a wide range of groups including municipalities, the Canadian Environmental Law Association, EcoJustice, Environmental Defence, Ontario Clean Air Alliance, Ontario Nature, Canadian Civil Liberties Association, Canadian Journalists for Free Expression, Citizens Environment Alliance of Southwestern Ontario, The Council of Canadians, CPAWS Wildlands League, Sierra Club Ontario, Registered Nurses' Association of Ontario and Greenpeace Canada.


text: The legislation was re-introduced following the 2014 Ontario election as Bill 52, and on 3 November 2015, Ontario enacted it as the Protection of Public Participation Act, 2015.


text: The bill was adopted by the National Assembly of Quebec on 3 June 2009. Quebec's amended Code of Civil Procedure was the first anti-SLAPP mechanism in force in Canada.


text: Prior to Ontario enacting its own Anti-SLAPP law the bill was invoked there (and then Supreme Court of Canada docket 33819). In the case of Les Éditions Écosociété Inc., Alain Deneault, Delphine Abadie and William Sacher vs. Banro Inc., in which the publisher Écosociété pleaded (supported by the BCCLA) that it should not face Ontario liability for a publication in Quebec, as the suit was a SLAPP and the Quebec law explicitly provided to dismiss these. The court denied the request, ruling it had jurisdiction. A separate 2011 decision in Quebec Superior Court had ruled that Barrick Gold had to pay $143,000 to the book's three authors and publisher, Les Éditions Écosociété Inc., to prepare their defence in a "seemingly abusive" strategic lawsuit against public participation. Despite the Québec ruling, a book "Noir Canada" documenting the relationship between Canadian mining corporations, armed conflict and political actors in Africa was never published as part of a settlement which, according to the authors, was only made for the sole purpose of resolving the three-and-a-half-year legal battle.


text: The Quebec law is substantially different in structure than that of California or other jurisdictions, however, as Quebec's Constitution generally subordinates itself to international law, and as such the International Covenant on Civil and Political Rights applies. That treaty only permits liability for arbitrary and unlawful speech. The ICCPR has also been cited, in the BC case "Crookes v. Newton", as the standard for balancing free speech versus reputation rights. The Supreme Court of Canada in October 2011, ruling in that case, neither reiterated nor rescinded that standard.


text: On 25 November 2020, the European Parliament passed a resolution expressed "its continued deep concern about the state of media freedom within the EU in the context of the abuses and attacks still being perpetrated against journalists and media workers in some Member States because of their work" and called on the European Commission to "establish minimum standards against SLAPP practices across the EU". In 2021 the European Union was considering adopting an anti-SLAPP directive to protect the freedom of speech of European citizens.


text: Thirty-two states, the District of Columbia, and Guam have enacted statutory protections against SLAPPs.


text: These states are Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii, Illinois, Indiana, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Minnesota, Missouri, Nebraska, Nevada, New Mexico, New York, Oklahoma, Oregon, Pennsylvania, Rhode Island, Tennessee, Texas, Utah, Vermont, Virginia, and Washington. In Colorado and West Virginia, the courts have adopted protections against SLAPPs. These laws vary dramatically in scope and level of protection and the remaining states lack specific protections.


text: There is no federal anti-SLAPP law, but legislation for one has been previously introduced, such as the SPEAK FREE Act of 2015. The extent to which state laws apply in federal courts is unclear, and the circuits are split on the question. The First, Fifth and Ninth circuits have allowed litigants from Maine, Louisiana and California, respectively, to use their state's special motion in federal district courts in diversity actions. The D.C. Circuit has held the reverse for D.C. litigants.


text: It has been argued that the lack of uniform protection against SLAPPs has encouraged forum shopping; proponents of federal legislation have argued that the uncertainty about one's level of protection has likely magnified the chilling effect of SLAPPs.


text: In December 2009, Rep. Steve Cohen (D–Tennessee) introduced the Citizen Participation Act in the U.S. House. This marks the first time the Congress has considered federal anti-SLAPP legislation, though the Congress enacted the SPEECH Act on the closely related issue of libel tourism. Like many state anti-SLAPP laws, H.R. 4364 would allow the defendant of a SLAPP to have the suit quickly dismissed and to recover fees and costs.


text: California has a unique variant of anti-SLAPP legislation. In 1992 California enacted Code of Civil Procedure § 425.16, a statute intended to frustrate SLAPPs by providing a quick and inexpensive defense. It provides for a special motion that a defendant can file at the outset of a lawsuit to strike a complaint when it arises from conduct that falls within the rights of petition or free speech. The statute expressly applies to any writing or speech made in connection with an issue under consideration or review by a legislative, executive, or judicial proceeding, or any other official proceeding authorized by law, but there is no requirement that the writing or speech be promulgated directly to the official body. It also applies to speech in a public forum about an issue of public interest and to any other petition or speech conduct about an issue of public interest.


text: In May 2015, the Washington Supreme Court struck down the state's 2010 anti-SLAPP statute. However, in 2021, a new anti-SLAPP law was enacted.


text: The SLAPP penalty stands as a barrier to access to the courts by providing an early penalty to claimants who seek judicial redress. In recent years, the courts in some states have recognized that enforcement of SLAPP legislation must recognize and balance the constitutional rights of both litigants. It has been said:


text: Since Magna Carta, the world has recognized the importance of justice in a free society. "To no one will we sell, to no one will we refuse or delay, right or justice." (Magna Carta, 1215.) This nation's founding fathers knew people would never consent to be governed and surrender their right to decide disputes by force, unless government offered a just forum for resolving those disputes.


text: The right to bring grievances to the courts, in good faith, is protected by state and federal constitutions in a variety of ways. In most states, the right to trial by jury in civil cases is recognized. The right to cross-examine witnesses is considered fundamental to the American judicial system. Moreover, the first amendment protects the right to petition the government for a redress of grievances. The "right to petition extends to all departments of the Government. The right of access to the courts is indeed but one aspect of the right of petition."


text: Because "the right to petition is 'among the most precious of the liberties safeguarded by the Bill of Rights', ... the right of access to the courts shares this 'preferred place' in [the United States'] hierarchy of constitutional freedoms and values."


text: This balancing question is resolved differently in different states, often with substantial difficulty.


text: By the nature of their subject matter, anti-SLAPP statutes require meticulous drafting. On the one hand, it is desirable to seek to shield citizens from improper intimidation when exercising their constitutional right to be heard with respect to issues of public concern. On the other hand, it is important that such statutes be limited in scope lest the constitutional right of access to the courts (whether by private figures, public figures, or public officials) be improperly thwarted. There is a genuine double-edged challenge to those who legislate in this area.


text: The most challenging balancing problem arises in application to SLAPP claims which do not sound (give rise to a claim) in tort. The common law and constitutional law have developed in the United States to create a high substantive burden to tort and tort-like claims which seek redress for public speech, especially public speech which addresses matters of public concern. The common law in many states requires the pleader to state accurately the content of libelous words. Constitutional law has provided substantive protection which bars recovery against a first amendment defense except upon clear and convincing evidence that there has been deliberate or reckless falsehood. For this reason, ferreting out the bad faith SLAPP claim at an early stage of litigation should be accomplished with relative ease. Extension of the SLAPP penalties to factually complex cases, where the substantive standard of proof at common law is lower presents special challenges.


text: A Minnesota Supreme Court case, "Middle-Snake-Tamarac Rivers Watershed Dist. v. Stengrim", 784 N.W.2d 834 (Minn. 2010) establishes a two-step process to determine whether SLAPP procedure should be applied. The decision arises in the context of an effort to enforce a settlement agreement between a local government and an opponent of a flood control project. The landowner had accepted a significant monetary settlement in settlement of his opposition to land acquisition. The landowner agreed as part of the settlement to address no further challenges to the project. When the local government sued the landowner for breach of settlement, the landowner contended that enforcement of the settlement was a strategic lawsuit against public participation. The Supreme Court rejected that claim and affirmed the District Court's denial of SLAPP relief, holding "The District Court properly denied a motion to dismiss where the underlying claim involved an alleged breach of a settlement agreement that potentially limited the moving party's rights to public participation." The Supreme Court explained:


text: Preexisting legal relationships, such as those based on a settlement agreement where a party waives certain rights, may legitimately limit a party's public participation. It would be illogical to read sections 554.01-.05 as providing presumptive immunity to actions that a moving party may have contractually agreed to forgo or limit.


text: Under the Minnesota approach, as a preliminary matter, the moving party must meet the burden of showing that the circumstances which bring the case within the purview of SLAPP protection exists. Until that has been accomplished, no clear and convincing burden has been shifted to the responding party.


text: Belgian law recognizes the concept of "tergend geding" (bullying litigation), any litigation of which the underlying aim is to cause discomfort to the opposing party, and hence increase the possibility of its redrawal from the law suit. Qualification of litigation as such by a judge can lead to its dismissal.


text: In 2016, the real-estate investment company Pro Kapital Ltd sued urbanist Teele Pehk who expressed her opinion about the company's development plans in the Kalasadam area of Tallinn, Estonia. The accusations were based on an interview given for the article "The battle for the Estonian coastline", published by the monthly newspaper "The Baltic Times". Initially, instead of clarifying the questionable quotes in the article with the "Baltic Times" editors, Pro Kapital sent a legal demand to Pehk demanding that she publish a pre-written explanation and pay €500 to cover their legal advice expenses. Pehk provided proof to the lawyer that she had not lied to the journalist of "The Baltic Times", and the newspaper published a clarification online that Pehk's words were misinterpreted. Few months later Pro Kapital sued Pehk for damaging their reputation by spreading lies about the detailed plan of the Kalasadam area. Teele Pehk had been involved with the detailed plan of Kalasadam since 2011, as a member of the neighbourhood association Telliskivi selts and caretaker of the Kalarand beach, situated on the edge of the Kalasadam area.


text: Half a year into the court case, Pro Kapital began negotiations and settled with a compromise before the court hearing. Pro Kapital paid for Pehk's legal costs and both parties agreed not to disparage each other in the future. Teele Pehk is still active in Tallinn urban development and continues to spread the word about SLAPP suits.


text: This case took place at the end of the 12-year process of planning the Kalasadam area, which over the years had witnessed exceptionally high public interest regarding the planned residential development and most importantly, the public use of the seaside and the beach. The planning system in Estonia allows anyone to express their opinion, present suggestions or objections to any detailed plan. Many Estonian civic organisations were raising concerned voices about the case and the Chancellor for Justice of Estonia condemned that practice many times in public appearances.


text: In September 2017, a naturopath in Arizona named Colleen Huber filed a defamation lawsuit, preceded by two cease and desist letters, against Britt Marie Hermes, a naturopathy whistleblower. The lawsuit was filed for Hermes' blog post criticizing Huber for using naturopathic remedies to treat cancer and speculating that Hermes' name was being used without her permission in several registered domain names owned by Huber. The lawsuit was filed in Kiel, Germany where Hermes was residing to pursue her PhD in evolutionary genomics. Jann Bellamy of Science-Based Medicine speculates that this is "due to good old forum shopping for a more plaintiff-friendly jurisdiction" as there are no protections against SLAPP lawsuits in Germany. Britt Hermes is a notable scientific skeptic and the organization Australian Skeptics set up a fund to help with legal costs on the case. In an interview at CSICon 2019, Britt Hermes told Susan Gerbic that she had won her case on 24 May 2019. According to Britt Hermes, "the court ruled that my post is protected speech under Article 5 (1) of the German constitution".


text: In 2022, in the wake of revelations that Greece's National Intelligence Service (Greece) was spying on the leader of PASOK, the third largest party, Nikos Androulakis, the executive director of NIS, Grigoris Kontoleon, and the Secretary General to prime minister Kyriakos Mitsotakis, Grigoris Dimitriadis (also a close relative of Kyriakos Mitsotakis) resigned from office. Grigoris Dimitriadis filed lawsuits against two journalists who had helped uncover the scandal, Thodoris Chondrogiannos and Nikolas Leontopoulos, demanding 150,000 euros as damages for false publications and the removal of those publications, but also against Thanassis Koukakis, a journalist who during 2021 was spied upon because of his investigations on Greek businessmen.


text: In 2020, Karan Bajaj, the founder of WhiteHat Jr., now owned by Byju's, filed a 2.6 million dollar lawsuit against Pradeep Poonia, an engineer who publicly accused the company of having a toxic work environment and unethical business practices. The Delhi High Court issued an interim order requiring Poonia to remove certain tweets from his account. In 2021, Bajaj rescinded the lawsuit.


text: During 2016, Amir Bramly, who at the time was being investigated and subsequently indicted for an alleged Ponzi scheme, sued for libel Tomer Ganon, a Calcalist reporter, privately for ₪1 million in damages, due to a news item linking him to Bar Refaeli. In addition Bramly sued Channel-2 News and its reporters and managers for ₪5 million in damages due to an alleged libel in an in-depth TV news item and interview with the court appointed liquidator of his companies, and has threatened to sue additional bodies. The sued individuals and bodies have claimed that these are SLAPP actions.


text: In 2006, Oricon Inc., Japan's music chart provider, sued freelance journalist Hiro Ugaya due to his suggesting in an article for business and culture magazine "" that the company was fiddling its statistics to benefit certain management companies and labels, specifically Johnny and Associates. The company sought ¥50 million and apology from him. He found allies in the magazine's editor-in-chief Tadashi Ibi, lawyer Kentaro Shirosaki, and Reporters Sans Frontières (RSF).


text: He was found guilty in 2008 by the Tokyo District Court and ordered to pay one million yen, but he appealed and won. Oricon did not appeal later. His 33-month struggle against Oricon and his research on SLAPPs through his self-expense trip in the United States was featured on the TBS program "JNN" "Reportage", titled as "Legal Intimidation Against Free Speech: What is SLAPP?"


text: On 17 May 2018, a non-profit project rettspraksis.no challenged a perceived monopoly on the publication of pre-2009 Supreme Court of Norway decisions by publishing a large back catalogue of historical decisions. To prevent publication, the government-established Lovdata foundation demanded an immediate injunction against two project volunteers, Håkon Wium Lie and Fredrik Ljone, that the website be shut down. The foundation claimed that rettspraksis.no had "developed or used software to systematically download rulings from Lovdatas online services" in order to publish the rulings in violation of Lovdata's rights according to the Norwegian Copyright Act section 43, the Database Rights Section. The District Court granted the injunction without a hearing based on finding that the volunteer actions was in violation of section 43, and that the publication on rettspraksis.no would enable other commercial actors to exploit the material in violation of Lovdata's rights even if the project itself did not. A postjudgement hearing on 30 and 31 August 2018 resulted in a reduction in the injunction's effects, most significantly that the Database Rights Section did not extend to rulings published before 2005. Appeals from Ljone and Wium Lie to the Appeals Court and the Supreme Court were denied.


text: In the late 1990s, many SLAPP cases against independent and pro-opposition media ensued after adoption of the infamous media law, proposed by then minister of information, Aleksandar Vučić. The main characteristic of these cases were quick trials and extremely high fines, most of which were unaffordable for journalists and their media houses.


text: While SLAPP cases became, more or less, rare after the Overthrow of Slobodan Milošević, they gradually reappeared in the late 2010s, and especially in the early 2020s, during SNS-led cabinets. Notably, Aleksandar Vučić is current president of Serbia, the most influential figure of the regime, and he is often accused of suppression of media freedoms.


text: A 2021 libel action brought against the publisher HarperCollins and the author and journalist Catherine Belton over the latter's book "Putin's People" was described by former Conservative cabinet minister David Davis as a SLAPP. Despite winning the legal case brought by several Russian oligarchs, including Roman Abramovich, Belton was left facing legal costs of £1.5 million. UK Government justice minister James Cartlidge said, "the Ministry of Justice is monitoring SLAPP threats against journalists and announced that the UK will be a member of the Council of Europe’s inaugural working group on SLAPPs with an anti-SLAPP draft recommendation for member states due in December 2023. I will be giving SLAPPs in UK courts urgent consideration. I want to make it clear that the Government are committed to a robust defence of transparency and freedom of speech. We will not tolerate anything that risks tarnishing the integrity of our judicial and legal profession".


text: Ministers later said that they would reform the legal system to prevent "intimidation lawsuits"; amendments to this effect were proposed for an anti-corruption economic crime bill before Parliament in March 2022.


title: 1872 Cavite mutiny

text: The Cavite mutiny (; ) was an uprising of Filipino military personnel of Fort San Felipe, the Spanish arsenal in Cavite, Philippine Islands (then also known as part of the Spanish East Indies) on January 20, 1872. Around 200 locally recruited colonial troops and laborers rose up in the belief that it would elevate to a national uprising. The mutiny was unsuccessful, and government soldiers executed many of the participants and began to crack down on a burgeoning Philippines nationalist movement. Many scholars believed that the Cavite mutiny was the beginning of Filipino nationalism that would eventually lead to the Philippine Revolution of 1896.


title: 1872 Cavite mutiny

text: The causes of the Cavite Mutiny can be identified through examining the different accounts in this historic event.


title: 1872 Cavite mutiny

text: Jose Montero y Vidal is a Spanish Historian, who interpreted that the Mutiny was an attempt to remove and overthrow the Spanish Colonizers in the Philippines. His account, corroborated with the account of Governor - General Rafael Izquidero y Gutierrez, the governor-general of the Philippine Islands during the Mutiny. They mentioned that the mutiny was powered by a group of native clergy.


title: 1872 Cavite mutiny

text: The Cavite Mutiny is an aim of natives to get rid of the Spanish government in the Philippines, due to the removal of privileges enjoyed by the laborers of the Cavite arsenal such as exemption from the tribute and forced labor. The democratic and republican books and pamphlets, the speeches and preaching of the apostles of these new ideas in Spain and the outburst of the American publicists and the cruel policies of the insensitive governor whom the reigning government sent to govern the country. Filipinos put into action these ideas where the occurring conditions which gave rise to the idea of achieving their independence.


title: 1872 Cavite mutiny

text: He insisted that the mutiny is stimulated and prepared by the native clergy, mestizos and lawyers as a signal of objection against the injustices of the government such as not paying provinces for tobacco crops, pay tribute and rendering of forced labor. It is not clearly identified if Indios planned to inaugurate a monarchy or a republic because they don't have a word in their own language to describe this different form of government, whose leader in Filipino would be called "hari". However, it turned out that they would set at the supreme of the government a priest, that the leader selected would be Jose Burgos or Jacinto Zamora which is the plan of the rebels who guided them, and the means they counted upon its realization.


title: 1872 Cavite mutiny

text: The event is just a simple mutiny since up to that time the Filipinos have no intention of separation from Spain but only secure materials and education advancements in the country. However, the mutiny was used at a powerful level. Also, in this time, the central government deprived friars of the powers of involvement in civil government and in governing and handling universities. This resulted in the friars afraid that their leverage in the Philippines would be a thing in the past, took advantage of the mutiny and reported it to the Spanish government as a broad conspiracy organized throughout the archipelago with the object of abolishing Spanish sovereignty. The Madrid government without any attempt to investigate the real facts or extent of the alleged revolution reported by Izquierdo and the friars believed the scheme was true.


title: 1872 Cavite mutiny

text: He traced the immediate cause to a peremptory order from the governor, Izquierdo, exacting personal taxes from the Filipino laborers in the engineering and artillery corps in the Cavite arsenal, and requiring them to perform forced labor like ordinary subjects. Until then, these workers in the arsenal had been enjoying exemptions from both taxes and forced labor. January 20, the day of the revolt, was payday and the laborers found the amount of taxes as well as the corresponding fee in lieu of the forced labor deducted from their pay envelopes. It was the last straw. That night they mutinied. Forty infantry soldiers and twenty men from the artillery took over command of the Fort of San Felipe and fired cannonades to announce to the world their moment of triumph. It was a short-lived victory. Apparently, the mutineers had expected to be joined by their comrades in the 7th infantry company assigned to patrol the Cavite plaza. They became terror-stricken, however, when they beckoned to the 7th infantry men from the ramparts of the fort and their comrades did not make any move to join them. Instead, the company started attacking them. The rebels decided to bolt the gates and wait for morning when support from Manila was expected to come. He gave a dispassionate account of it and its causes in an article published in the Revue des Deux Mondes in 1877. He traced that the primary cause of the mutiny is believed to "be an order from Governor-General Carlos to subject the soldiers of the Engineering and Artillery Corps to personal taxes, from which they were previously exempt. The taxes required them to pay a monetary sum as well as to perform forced labor called, "polo y servicio". The mutiny was sparked on January 20, 1872 when the laborers received their pay and realized the taxes as well as the "falla", the fine one paid to be exempt from forced labor, had been deducted from their salaries.


title: 1872 Cavite mutiny

text: Different accounts in the Cavite mutiny also highlighted other probable causes of the "revolution" which includes Spanish Revolution which overthrew the secular throne, dirty propagandas proliferated by unrestrained press, democratic, liberal and republican books and pamphlets reaching the Philippines, and most importantly, the presence of the native clergy who out of animosity against the Spanish friars, "conspired and supported" the rebels and enemies of Spain.


title: 1872 Cavite mutiny

text: In addition, accounts of the mutiny suggest that the Spanish Revolution in Spain during that time added more determination to the natives to overthrow the current colonial Spanish government.


title: 1872 Cavite mutiny

text: On February 15, 1872, the Spanish colonial authorities sentenced three martyr Fathers Jose Burgos, Mariano Gomez and Jacinto Zamora to death by garrote at Bagumbayan, Philippines and charged with treason and sedition, and subversion. Two days after their verdict, they were executed. The charges against Fathers Gomez, Burgos and Zamora was their alleged complicity in the uprising of workers at the Cavite Naval Yard. It was believed by Governor Rafael Izquierdo that the Filipinos will create its own government and allegedly, the three priests were nominated as the leader of the planned government in order to break free of the Spanish government.


title: 1872 Cavite mutiny

text: The death of Gomburza awakened strong spirits of anger and resentment among the Filipinos. They grilled Spanish authorities and demanded reforms due to the prejudicial governance of the Spanish Authorities. The martyrdom of the three priests, ironically, assisted in the creation of the Propaganda Movement which aimed to seek reforms and inform the Spanish people on the abuses of its colonial authorities in the Philippine Islands.


title: 1872 Cavite mutiny

text: Besides from Gomburza execution, on January 28, 1872 the military court sentenced 41 mutineers to death. However, on the next day Governor Rafael Izquierdo pardoned 28 mutineers and the rest were confirmed to sentence. On February 6, 1872, 11 mutineers were sentenced to death but Governor Izquierdo commuted their death sentences to life imprisonment. Together with execution of garrotte to the three martyrs was Enrique Paraiso, Maximo Innocencio and Crisanto Delos Reyes were imposed to ten years imprisonment.


title: 1872 Cavite mutiny

text: Furthermore, there were people being sentenced by the military court of Spain to exile them to the Marianas (now Guam): Fr. Pedro Dandan, Fr. Mariano Sevilla, Toribio H. del Pilar (brother of Marcelo H. del Pilar), Agustin Mendoza, Jose Guevara, Miguel Lasa, Justo Guazon, Fr. Aniceto Desiderio, Fr. Vicente del Rosario, Joaquin Pardo de Tavera, Antonio Ma. Regidor, Jose Basa y Enriquez, Mauricio de Leon, Pedro Carillo, Gervasio Sanchez, Jose Ma. Basa, Pio Basa, Balvino Mauricio, Maximo Paterno (father of Pedro Paterno), and Valentin Tosca.


title: 1872 Cavite mutiny

text: Their leader was Fernando La Madrid, a mestizo sergeant with his second in command Jaerel Brent Senior, a moreno. They seized Fort San Felipe and killed eleven Spanish officers. The mutineers thought that fellow Filipino indigenous soldiers in Manila would join them in a concerted uprising, the signal being the firing of rockets from the city walls on that night. Unfortunately, what they thought to be the signal was actually a burst of fireworks in celebration of the feast of Our Lady of Loreto, the patron of Sampaloc. The plan was to set fires in Tondo in order to distract the authorities while the artillery regiment and infantry in Manila could take control of Fort Santiago and use cannon shots as signals to Cavite. All Spaniards were to be killed, except for the women. News of the mutiny reached Manila, supposedly through the lover of a Spanish sergeant, who then informed his superiors, and the Spanish authorities feared for a massive Filipino uprising. The next day, a regiment led by General Felipe Ginovés besieged the fort until the mutineers surrendered. Ginovés then ordered his troops to fire at those who surrendered, including La Madrid. The rebels were formed in a line, when Colonel Sabas asked who would not cry out, ""Viva España"", and shot the one man who stepped forward. The rest were imprisoned.


title: 1872 Cavite mutiny

text: In the immediate aftermath of the mutiny, some Filipino soldiers were disarmed and later sent into exile on the southern island of Mindanao. Those suspected of directly supporting the mutineers were arrested and executed. The mutiny was used by the colonial government and Spanish friars to implicate three secular priests, Mariano Gomez, José Burgos, and Jacinto Zamora, collectively known as Gomburza. They were executed by garrote in "Luneta", also known in Tagalog as "Bagumbayan", on February 17, 1872. These executions, particularly those of the Gomburza, were to have a significant effect on people because of the shadowy nature of the trials. José Rizal, whose brother Paciano was a close friend of Burgos, dedicated his work, "El filibusterismo", to these three priests.


title: 1872 Cavite mutiny

text: On January 27, 1872, Governor-General Rafael Izquierdo approved the death sentences on forty-one of the mutineers. On February 6, eleven more were sentenced to death, but these were later commuted to life imprisonment. Others were exiled to other islands of the colonial Spanish East Indies such as Guam, Mariana Islands, including Joaquin Pardo de Tavera, Antonio M. Regidor y Jurado, Pio Basa, and José María Basa. The most important group created a colony of Filipino expatriates in Europe, particularly in the Spanish capital of Madrid and Barcelona, where they were able to create small insurgent associations and print publications that were to advance the claims of the seeding Philippine Revolution.


title: 1872 Cavite mutiny

text: Finally, a decree was made, stating there were to be no further ordinations/appointments of Filipinos as Roman Catholic parish priests. In spite of the mutiny, the Spanish authorities continued to employ large numbers of native Filipino troops, carabineros and civil guards in their colonial forces through the 1870s–1890s until the Spanish–American War of 1898.


title: 1872 Cavite mutiny

text: During the short trial, the captured mutineers testified against José Burgos. The state witness, Francisco Zaldua, declared that he had been told by one of the Basa brothers that the "government of Father Burgos" would bring a navy fleet of the United States to assist a revolution with which Ramón Maurente, the supposed field marshal, was financing with 50,000 pesos. The heads of the friar orders held a conference and decided to get rid of Burgos by implicating him to a plot. One Franciscan friar disguised as Burgos and suggested a mutiny to the mutineers. The senior friars used an "una fuerte suma de dinero" or a banquet to convince Governor-General Rafael Izquierdo that Burgos was the mastermind of the coup. Gómez and Zamora were close associates of Burgos, so they too were included in the allegations. Also, Francisco Zaldua had been the principal informer against the three priests. His statement had been the main basis for the convictions and he had been promised pardon in exchange for his testimony, however, he was condemned along with the three. He was the first to be executed among them on February 17, 1872.


title: 1872 Cavite mutiny

text: The Central Government of Madrid proclaimed that they want to deprive the friars of all the power of intervention in matters of civil government and direction and management of educational institutions. The friars feared that their dominance in the country would become a thing of the past, and that they needed something to justify their perpetuation, with the mutiny providing such an opportunity. However, the Philippine Institute was introduced by the Spanish government as an educational decree fusing sectarian schools once ran by the friars. This decree aimed to improve the standard of education in the Philippines by requiring teaching positions in these schools to be filled by competitive examinations, an important step welcomed by most Filipinos.


title: Sleeping with Other People

text: Sleeping with Other People is a 2015 American romantic comedy film directed and written by Leslye Headland. The film stars Jason Sudeikis, Alison Brie, Natasha Lyonne, Amanda Peet, and Adam Scott. Premiering at the 2015 Sundance Film Festival on January 24, 2015, the film was released theatrically on September 11, 2015, by IFC Films. "Sleeping with Other People" received generally positive reviews from critics.


title: Sleeping with Other People

text: In 2002, Lainey causes a scene in a dorm at Columbia University. Taking pity on her as she is about to be kicked out by security, Jake claims her as his guest. He learns that Lainey was there in order to lose her virginity to her T.A., Matthew, who Jake thinks is the most boring guy in the world. Lainey eventually realizes that Jake is also a virgin, and the two lose their virginity to each other.


title: Sleeping with Other People

text: Years later, Lainey breaks up with her long-term boyfriend Sam after telling him she has been cheating on him. On the advice of her therapist she attends a sex addicts meeting, where she runs into Jake, who is there because of his inability to commit. Lainey schedules an appointment with Matthew to end their affair; he agrees and tells her that he is engaged, but they end up having sex.


title: Sleeping with Other People

text: On the advice of a friend Lainey contacts Jake, and they go on one date where they confess their sexual problems to one another. At the end of the date Jake confesses that he wants to sleep with her; however, Lainey insists that they should just be friends and Jake agrees with the safe word "mousetrap" to be used to deflate sexual tension between them.


title: Sleeping with Other People

text: They hang out more and eventually become best friends, confiding in each other about their dating lives as they try to move past their commitment issues. Strangers mistake them for a couple and their friends begin to think they are in a relationship as well. Jake learns that Lainey is going to re-enroll in medical school and possibly move to Michigan. He brings her to the birthday party of his friend's child where she meets Chris and begins seeing him to Jake's chagrin. Jake decides to move on and asks his boss Paula on a date.


title: Sleeping with Other People

text: A date with Chris leads Lainey to run into Matthew and his now-pregnant wife. At the same time, Jake has sex with Paula and calls her Lainey. After their nights out, Jake and Lainey spend the night together where they realize that they are in love with each another; however, they do nothing about it, afraid to mess up their relationship.


title: Sleeping with Other People

text: Lainey moves to Michigan and Jake devotes himself to Paula. Two months after she has left, during brunch with Paula, Jake sees Matthew and punches him in the face. Paula breaks up with Jake after he refers to Lainey as "my girl" and Jake is arrested. He calls Lainey from the police station and confesses he is still in love with her, and wants to pursue a relationship even if it fails. She tells him she feels the same way.


title: Sleeping with Other People

text: Some time later, Matthew is suing Jake for emotional distress and refuses every settlement he offers. Lainey goes to see him and tells him she will tell his wife about their relationship if he does not drop the case. After leaving his office, Lainey meets with Jake and the two rush off to be married.


title: Sleeping with Other People

text: After the debut of her last film, "Bachelorette", Headland became what she would later define as "suicidally depressed" noting that at one point "I was literally wondering, Should I check myself into a psych ward?" To help cope with this she went to Big Sur where she "wrote all day and all night". She realized she wanted to write a movie about sex addiction after entering into a relationship with someone who was already seeing another person, recalling that at one point she drove to his house "I just started crying hysterically. I pulled over and just kept crying. It was sort of like, What is my problem right now? Is it that I'm in love with him? Is it that I feel guilty? Is it that I'm doing something I don't want to do?" From the start she did not set out to make a romantic comedy although when she realized she was making one she wanted to make sure "that it all felt very believable".


title: Sleeping with Other People

text: For research purposes she attended sexual addiction meetings as well as read many books about the subject, including "Your Brain on Sex" and the relationship addiction book "Leaving the Enchanted Forrest".


title: Sleeping with Other People

text: The film had its world premiere at the Sundance Film Festival on January 24, 2015. On February 6, 2015, IFC Films had acquired distribution rights to the film. The film premiered at the Sarasota Film Festival on April 17, 2015. The film went on to premiere at the Tribeca Film Festival on April 21, 2015. and then the Montclair Film Festival on May 8, 2015. The Seattle International Film Festival on June 5, 2015 and the Provincetown Film Festival on June 27, 2015. The film had its European premiere at the Edinburgh International Film Festival on June 18, 2015.


title: Sleeping with Other People

text: On Rotten Tomatoes, the film has an approval rating of 63% based on 133 reviews, with an average score of 6.1/10. The site's critical consensus reads: ""Sleeping with Other People" has likable leads and flashes of inspiration, but seems unwilling or unable to surround them with the truly subversive rom-com they deserve." On Metacritic, the film has a weighted average score of 64 out of 100, based on 27 critics, indicating "generally favorable reviews".


title: Sleeping with Other People

text: "Indiewire" gave the film a positive review, describing it as "a refreshingly funny and romantic feature that is more than worth falling in love with (again and again)".