title: 54 (film)

text: After Greg and Anita reconcile following her interrupted debut performance, Anita leaves with Billie for a photo op. Shane discovers G-men raiding Steve’s office and runs back upstairs to warn Greg, but Greg ignores him. Greg then runs to get his things from his locker when he sees Shane being thrown out of the club, but discovers that a G-man has already beat him to it and has found his drugs.


title: 54 (film)

text: After Shane is thrown out of 54, he sees Greg running up behind him. Shane offers him his garbage bag cloak, and Greg begrudgingly accepts. Anita runs to them in a fancy fur coat and cloaks Greg in it with her as they both depart. Greg calls for Shane to come along with them, just as Julie pulls up alongside in her limousine and offers Shane a ride. Shane declines and leaves with Greg and Anita, the three of them staying together as a family instead of drifting apart.


title: 54 (film)

text: Based on two short films Mark Christopher made, Miramax Films persuaded Christopher to direct the full-length feature about Studio 54. He had spent five years researching the club and the time period while working on a screenplay. Miramax purchased a partial screenplay in 1995 and developed the script with the filmmaker for over a year.


title: 54 (film)

text: Christopher shot the film in Toronto over two months in the fall of 1997. However, studio head Harvey Weinstein and Christopher differed on their respective visions of the film. Christopher intended for the film to capture Studio 54’s notoriety as “the epicenter of the gay cultural explosion in New York City,” and wanted the story to be told from the perspective of “Shane, a kid from New Jersey who sleeps his way to the top of the 54 pecking order, which means that he becomes one of the shirtless bartenders for which the club was notorious, golden boys who flexed and preened for the clientele of both sexes, occasionally deigning to grant sexual favors in return for money and drugs”. Conversely, Weinstein wanted a more commercial film in the vein of "Saturday Night Fever", with its gay storyline removed.


title: 54 (film)

text: Weinstein screen tested Christopher’s cut of the film on Long Island in early 1998. Audiences at this screening reacted negatively to the lead character's bisexuality, particularly to a scene where Shane and Greg kiss as well as the happy ending for both characters and Anita. Miramax subsequently requested the film remove any suggestions of bisexuality. The post-production process was a troubled one, with Weinstein hiring a second writing team to flesh out new scenes that play up a romance between Shane and Julie. Christopher was not allowed in the editing room, and though he agreed to shoot the new scenes after initial resistance, he did not get to see the final cut.


title: 54 (film)

text: "54" opened at #4 in its opening weekend (August 28–30, 1998) with $6,611,532 behind "Blade", "There's Something About Mary", and "Saving Private Ryan".


title: 54 (film)

text: The studio cut of the film received almost universally poor reviews but was a modest commercial success, grossing $16 million on an estimated budget of $13 million. Mike Myers, in his first serious dramatic role, garnered some of the film's only positive word-of-mouth. The role was Myers’ only foray into drama until 2009's "Inglourious Basterds" and 2018's "Bohemian Rhapsody".


title: 54 (film)

text: Though some critics noted Christopher manages to “[re-create] the club’s playfully subversive physical details: the glitter confetti and giant silver man-in-the-moon cokehead mobile, the VIP room hidden in the dank basement”, many were particularly disappointed with the film's fictional characters and storyline, believing that Studio 54's notorious, real-life past should have been explored with better detail and more realism.


title: 54 (film)

text: On review aggregator website Rotten Tomatoes, the film holds an approval rating of 15%, based on 67 reviews, and an average rating of 4.10/10. The website's critical consensus reads, "Robbed of its integral LGBTQ themes, "54" is a compromised and disjointed glance at the glory days of disco". Audiences polled by CinemaScore gave the film an average grade of "C" on an A+ to F scale.


title: 54 (film)

text: The 1998 film was nominated for two Razzie Awards, including Worst Actor for Ryan Phillippe and Worst Supporting Actress for Ellen Albertini Dow. Neve Campbell was nominated for Worst Supporting Actress (also for "Wild Things") at the 1998 Stinkers Bad Movie Awards.


title: 54 (film)

text: In the years after the theatrical cut's release, a bootleg VHS version of the two-hour-long rough cut began circulating. Strong word of mouth and support led to New York LGBTQ film festival Outfest screening the rough cut to a sold-out crowd in 2008. Christopher and his co-producer Jonathan King had been lobbying Miramax for years to allow them to remaster the director's cut for DVD. In 2014, the filmmakers received the greenlight to make "54: The Director's Cut" from Zanne Devine, Miramax's then-VP of production. They completed the film in time for a screening in the Panorama section at the 65th Berlin International Film Festival in February 2015. The 105 minute-long cut included 44 minutes of restored footage, with all but a few seconds of the studio-dictated re-shot footage jettisoned.


title: 54 (film)

text: The director's cut has received a much more positive critical response, and the film has a huge cult following among the LGBT community. Of "54: The Director's Cut", critic Louis Jordan wrote, "Driven by character and atmosphere rather than soapy plot, Christopher’s film is permeated by a melancholy that adds depth to the ecstatic party scenes. Mike Myers nails the pathos and charm behind Rubell’s luded-out lechery, while Phillippe’s measured performance, finally given space to breathe, is vulnerable, amoral, and sexy. There are no easy heroes or villains in this "54", only people looking for something they’ll likely never find."


title: 54 (film)

text: A 2012 Blu-ray release features several additional and alternate scenes that were not included in the theatrical release. This extended cut runs 100 minutes, eight minutes of which are not in the studio's 92-minute release. Miramax and Lionsgate Home Entertainment released "54: The Director's Cut" in digital HD on streaming video providers on June 2, 2015. A Blu-ray version of this cut was released in 2016.


title: Prefab Sprout

text: Prefab Sprout are an English pop band from Witton Gilbert, County Durham who rose to fame during the 1980s. Formed in 1978 by brothers Paddy and Martin McAloon and joined by vocalist, guitarist and keyboard player Wendy Smith in 1982, they released their debut album "Swoon" to critical acclaim in 1984. Their subsequent albums, including 1985's "Steve McQueen" and 1990's "", have been described by Paul Lester of "The Guardian" as "some of the most beautiful and intelligent records of their era". Frontman Paddy McAloon is regarded as one of the great songwriters of his time and the band have been credited with producing some of the "most beloved" pop music of the 1980s and 1990s.


title: Prefab Sprout

text: Nine of their albums reached the Top 40 in the UK Albums Chart and one of their singles, "The King of Rock 'n' Roll", peaked at number seven in the UK Singles Chart. The band's other popular songs include "When Love Breaks Down" and "Cars and Girls". In recent years, Paddy McAloon has retained the Prefab Sprout name as a solo project.


title: Prefab Sprout

text: In 1977 brothers Paddy and Martin McAloon formed The Dick Diver Band. By 1978, the name had changed to Prefab Sprout, a name McAloon had created years earlier when, he has said, "all the groups had names like that". The band first played live in 1979, having been joined by drummer Michael Salmon.


title: Prefab Sprout

text: The band recorded their first single "Lions in My Own Garden (Exit Someone)" b/w "Radio Love" on 25 February 1982, and self-released it on their own Candle Records (slogan: "The wax that won't get on your wick"). Songwriter Paddy McAloon wanted a song title where the first letters of the words spelled out Limoges, the French city where his former girlfriend was studying at the time. Music journalist Stuart Maconie described the track as "enigmatic, melancholy, tuneful and therefore perfect for a jobless literature graduate with girlfriend problems". Their lineup expanded shortly after to incorporate vocalist Wendy Smith, and they recorded a second single "The Devil Has All the Best Tunes / Walk On" that September.


title: Prefab Sprout

text: Prefab Sprout were signed by Keith Armstrong's Kitchenware Records in March 1983, after Armstrong heard their music played in the Newcastle branch of HMV he managed. Their two singles were reissued by Kitchenware and attracted notice including laudation from Elvis Costello.


title: Prefab Sprout

text: Following the departure of Michael Salmon as drummer, the band recorded their debut album with session drummer Graham Lant in a 24-track studio in Edinburgh on a budget of £5,000. Entitled "Swoon" (an acronym for Songs Written Out Of Necessity), it was released on the Kitchenware label in March 1984. It was critically acclaimed, with several reviewers highlighting its unorthodox musical style and unconventional lyrics. and it reached No. 22 on the UK Albums Chart. The album attracted the attention of musician Thomas Dolby, who began producing a new batch of what McAloon would describe as simpler songs with the band. Graham Lant's relationship with Prefab Sprout ended soon after recording of "Swoon", so Neil Conti joined the band as drummer. The resulting album, 1985's "Steve McQueen", (released in America as "Two Wheels Good" in anticipation of displeasure from McQueen's estate) was highly praised by critics and gave the band its first hit single on UK Singles Chart, "When Love Breaks Down".


title: Prefab Sprout

text: The band's next project was "Protest Songs", a sparsely-produced and quickly recorded album intended for a limited release in late 1985. The album was put on hold by CBS so as not to stunt sales of "Steve McQueen", finally seeing release in 1989. In 1988, the band released their follow-up to "Steve McQueen", "From Langley Park to Memphis". The album gave the band their biggest commercial success in the UK with the single "The King of Rock 'n' Roll". The song is written from the perspective of a washed-up singer who had a one-hit wonder in the 1950s with a novelty song featuring the chorus "Hot dog, jumping frog, Albuquerque". It reached No. 7 in the UK Singles Chart, their only single to reach the Top 10. "From Langley Park to Memphis" included guest appearances from Stevie Wonder and Pete Townshend, and used multiple producers including Thomas Dolby, who could not commit to working on the entire album.


title: Prefab Sprout

text: In 1990, "", fully produced by Thomas Dolby, was nominated for a BRIT Award. Though the music was more accessible than their earlier material, the lyrics and subject matter remained characteristically oblique and suggestive. McAloon has alluded in interviews to several albums' worth of songs that he has written but are unreleased/unrecorded including amongst others, concept albums based on the life of Michael Jackson, the history of the world ("Earth: The Story So Far") and a fictional superhero ("Zorro the Fox").


title: Prefab Sprout

text: Their greatest hits, "", gave them their biggest US hit, "If You Don't Love Me", which spent several weeks in the Top 10 on the dance chart. McAloon joked in the album liner notes about the band's lack of touring over the past decade.


title: Prefab Sprout

text: After a five year hiatus, Prefab Sprout released their first new studio album since 1990's "Jordan", "Andromeda Heights", in 1997. After its release, Wendy Smith left the band to pursue a new career as a voice instructor.


title: Prefab Sprout

text: A double album anthology, the "38 Carat Collection" was released by CBS in 1999 as the group was leaving the record label. The group's US label, Epic, belatedly reissued this set as "The Collection" in early 2001. To promote the compilation, in 2000 the band embarked on their first UK tour in ten years.


title: Prefab Sprout

text: In 2001 the band, now reduced to Paddy and Martin McAloon, released "The Gunman and Other Stories", a concept album themed on the American Wild West, produced by Tony Visconti. The opening track "Cowboy Dreams" was a hit for the British actor-singer Jimmy Nail. Though critically acclaimed, neither enjoyed major commercial success.


title: Prefab Sprout

text: After being diagnosed with a medical disorder that seriously impaired his vision, Paddy McAloon released the album "I Trawl the Megahertz" under his own name in 2003 on the EMI Liberty label. Fifteen years later, in autumn 2018, the album was reissued on Sony Music as a Prefab Sprout record, as originally intended.


title: Prefab Sprout

text: As of 2006, McAloon had suffered another setback: his hearing had deteriorated, due to Ménière's disease.


title: Prefab Sprout

text: In early 2007 a remastered edition of "Steve McQueen" was released in a two-CD package, containing new versions of eight of the songs from the original album, in different arrangements performed by McAloon on acoustic guitar.


title: Prefab Sprout

text: Prefab Sprout's first album of new material since 2001, "Let's Change the World with Music", was released on 7 September 2009. The album is actually a collection of McAloon solo demos originally recorded in the early 1990s, intended for an unmade full band Prefab Sprout album. Reviews in the UK press were favourable (e.g. 5/5 in "The Times", 4/5 in "The Guardian", 4/5 in "Record Collector").


title: Prefab Sprout

text: In June 2013, a leak of ten previously unreleased songs on SoundCloud led to speculation that a new Prefab Sprout album was being recorded. "Crimson/Red", consisting of developed versions of tracks from the vaults that was subsequently released on 7 October 2013 on vinyl and CD on the Icebreaker records label. A limited edition box set with an interview CD was also released. The lead single was "The Best Jewel Thief in the World". A video for this track (produced by Tylar Cornak) was originally posted to Vimeo. "Crimson/Red" also confirmed that Prefab Sprout was now in effect a solo project, with Paddy McAloon singing, playing and programming all of the music on the album on his own. In interviews at the time, McAloon explained that his health issues (in particular, the deterioration of his hearing and eyesight) now dictated the way in which Prefab Sprout music was recorded, making it impractical and even impossible for any other musicians to be involved, but that he remained fond of and grateful to his former bandmates.


title: Prefab Sprout

text: On 3 March 2017, McAloon's manager Keith Armstrong, one-time head of Kitchenware Records, posted a short clip on Instagram of McAloon performing a new song "America" to a camcorder; operated by McAloon himself. A longer version appears on Armstrong's YouTube page. To date, no reason has been disclosed if this points to a new album or as the lyrics suggest, it is a commentary on the incumbent US administration and their policy on immigration.


title: Prefab Sprout

text: On 8 November 2018, Rough Trade announced the availability of vinyl LP and CD versions of "I Trawl the Megahertz", including a white vinyl special edition of 1000 copies. On the same day, Sony Music announced the release under their "Legacy" brand. The Sony press release notes that although this was originally a solo album, it is now fitting to classify it as a Prefab Sprout record. Paddy McAloon is quoted as saying: "I thought we could do anything. And Megahertz is true to that spirit. The music here is of a piece with everything I’ve ever written. It’s from the heart". Then on 10 December 2018, Paddy McAloon featured in an interview on the "Today" programme on BBC Radio 4.


title: Prefab Sprout

text: Several interviews have described a significant vault of unreleased material, credited either to Prefab Sprout or to McAloon himself. "Crimson/Red" was based on tracks from the vault, and "Let's Change the World with Music" was released in a form that was substantially similar to its 1993 demo form.


title: Prefab Sprout

text: In the 2018 interview on Radio 4, McAloon explained Sony would be making further releases, and that he was working on an album of unreleased material, 'Femmes Mythologiques', to be issued in September 2019. During the radio appearance, he played a segment of a song called "Cleopatra". However, the album has yet to be released, and as of 2022, no additional information is available about its release.


title: Prefab Sprout

text: Several inaccurate stories have circulated about the origins of the band's unusual name. According to the "Guinness Book of British Hit Singles & Albums", the band's name was a mondegreen from the song "Jackson" ("We got married in a fever, hotter than a pepper sprout"), misheard by frontman Paddy McAloon. McAloon has maintained that the name was entirely made-up, stating in a 1984 interview; "I was asked about the name so many times I used to invent stories about it. The truth of the matter is that I made it up. Around that time all the groups were supposed to mean something ... and when you are 13 you think it's profound, that there must be some secrecy. I liked the idea and so thought of two odd words, put them together and have kept it, basically because it reminds me of how I used to look at things".


title: Equal Protection Clause

text: The Equal Protection Clause is part of the first section of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides ""nor shall any State ... deny to any person within its jurisdiction the equal protection of the laws."" It mandates that individuals in similar situations be treated equally by the law.


title: Equal Protection Clause

text: A primary motivation for this clause was to validate the equality provisions contained in the Civil Rights Act of 1866, which guaranteed that all citizens would have the guaranteed right to equal protection by law. As a whole, the Fourteenth Amendment marked a large shift in American constitutionalism, by applying substantially more constitutional restrictions against the states than had applied before the Civil War.


title: Equal Protection Clause

text: The meaning of the Equal Protection Clause has been the subject of much debate, and inspired the well-known phrase "Equal Justice Under Law". This clause was the basis for "Brown v. Board of Education" (1954), the Supreme Court decision that helped to dismantle racial segregation. The clause has also been the basis for "Obergefell v. Hodges" which legalized same-sex marriages, along with many other decisions rejecting discrimination against, and bigotry towards, people belonging to various groups.


title: Equal Protection Clause

text: While the Equal Protection Clause itself applies only to state and local governments, the Supreme Court held in "Bolling v. Sharpe" (1954) that the Due Process Clause of the Fifth Amendment nonetheless imposes various equal protection requirements on the federal government via reverse incorporation.


title: Equal Protection Clause

text: Though equality under the law is an American legal tradition arguably dating to the Declaration of Independence, formal equality for many groups remained elusive. Before passage of the Reconstruction Amendments, which included the Equal Protection Clause, American law did not extend constitutional rights to black Americans. Black people were considered inferior to white Americans, and subject to chattel slavery in the slave states until the Emancipation Proclamation and the ratification of the Thirteenth Amendment.


title: Equal Protection Clause

text: Even black Americans that were not enslaved lacked many crucial legal protections. In the 1857 Dred Scott v. Sandford decision, the Supreme Court rejected abolitionism and determined black men, whether free or in bondage, had no legal rights under the U.S. Constitution at the time. Currently, a plurality of historians believe that this judicial decision set the United States on the path to the Civil War, which led to the ratifications of the Reconstruction Amendments.


title: Equal Protection Clause

text: Before and during the Civil War, the Southern states prohibited speech of pro-Union citizens, anti-slavery advocates, and northerners in general, since the Bill of Rights did not apply to the states during such times. During the Civil War, many of the Southern states stripped the state citizenship of many whites and banished them from their state, effectively seizing their property.


title: Equal Protection Clause

text: Shortly after the Union victory in the American Civil War, the Thirteenth Amendment was proposed by Congress and ratified by the states in 1865, abolishing slavery. Subsequently, many ex-Confederate states then adopted Black Codes following the war, with these laws severely restricting the rights of blacks to hold property, including real property (such as real estate), and many forms of personal property, and to form legally enforceable contracts. Such codes also established harsher criminal consequences for blacks than for whites.


title: Equal Protection Clause

text: Because of the inequality imposed by Black Codes, a Republican-controlled Congress enacted the Civil Rights Act of 1866. The Act provided that all persons born in the United States were citizens (contrary to the Supreme Court's 1857 decision in "Dred Scott v. Sandford"), and required that "citizens of every race and color ... [have] full and equal benefit of all laws and proceedings for the security of person and property, as is enjoyed by white citizens."


title: Equal Protection Clause

text: President Andrew Johnson vetoed the Civil Rights Act of 1866 amid concerns (among other things) that Congress did not have the constitutional authority to enact such a bill. Such doubts were one factor that led Congress to begin to draft and debate what would become the Equal Protection Clause of the Fourteenth Amendment. Additionally, Congress wanted to protect white Unionists who were under personal and legal attack in the former Confederacy. The effort was led by the Radical Republicans of both houses of Congress, including John Bingham, Charles Sumner, and Thaddeus Stevens. It was the most influential of these men, John Bingham, who was the principal author and drafter of the Equal Protection Clause.


title: Equal Protection Clause

text: The Southern states were opposed to the Civil Rights Act, but in 1865 Congress, exercising its power under Article I, Section 5, Clause 1 of the Constitution, to "be the Judge of the ... Qualifications of its own Members", had excluded Southerners from Congress, declaring that their states, having rebelled against the Union, could therefore not elect members to Congress. It was this fact—the fact that the Fourteenth Amendment was enacted by a "rump" Congress—that permitted the passage of the Fourteenth Amendment by Congress and subsequently proposed to the states. The ratification of the amendment by the former Confederate states was imposed as a condition of their acceptance back into the Union.


title: Equal Protection Clause

text: With the return to originalist interpretations of the Constitution, many wonder what was intended by the framers of the reconstruction amendments at the time of their ratification. The 13th amendment abolished slavery but to what extent it protected other rights was unclear. After the 13th amendment the South began to institute Black Codes which were restrictive laws seeking to keep black Americans in a position of inferiority. The 14th amendment was ratified by nervous Republicans in response to the rise of Black Codes. This ratification was irregular in many ways. First, there were multiple states that rejected the 14th amendment, but when their new governments were created due to reconstruction, these new governments accepted the amendment. There were also two states, Ohio and New Jersey, that accepted the amendment and then later passed resolutions rescinding that acceptance. The nullification of the two state's acceptance was considered illegitimate and both Ohio and New Jersey were included in those counted as ratifying the amendment.


title: Equal Protection Clause

text: Many historians have argued that 14th amendment was not originally intended to grant sweeping political and social rights to the citizens but instead to solidify the constitutionality of the 1866 Civil rights Act. While it is widely agreed that this was a key reason for the ratification of the Fourteenth Amendment, many historians adopt a much wider view. It is a popular interpretation that the Fourteenth Amendment was always meant to ensure equal rights for all those in the United States. This argument was used by Charles Sumner when he used the 14th amendment as the basis for his arguments to expand the protections afforded to black Americans.


title: Equal Protection Clause

text: Although the equal protection clause is one of the most cited ideas in legal theory, it received little attention during the ratification of the 14th amendment. Instead the key tenet of the Fourteenth Amendment at the time of its ratification was the Privileges or Immunities Clause. This clause sought to protect the privileges and immunities of all citizens which now included black men. The scope of this clause was substantially narrowed following the Slaughterhouse Cases in which it was determined that a citizen's privileges and immunities were only ensured at the Federal level and that it was government overreach to impose this standard on the states. Even in this halting decision the Court still acknowledged the context in which the Amendment was passed, stating that knowing the evils and injustice the 14th amendment was meant to combat is key in our legal understanding of its implications and purpose. With the abridgment of the Privileges or Immunities clause, legal arguments aimed at protecting black American's rights became more complex and that is when the equal protection clause started to gain attention for the arguments it could enhance.


title: Equal Protection Clause

text: During the debate in Congress, more than one version of the clause was considered. Here is the first version: "The Congress shall have power to make all laws which shall be necessary and proper to secure ... to all persons in the several states equal protection in the rights of life, liberty, and property." Bingham said about this version: "It confers upon Congress power to see to it that the protection given by the laws of the States shall be equal in respect to life and liberty and property to all persons." The main opponent of the first version was Congressman Robert S. Hale of New York, despite Bingham's public assurances that "under no possible interpretation can it ever be made to operate in the State of New York while she occupies her present proud position."


title: Equal Protection Clause

text: Hale ended up voting for the final version, however. When Senator Jacob Howard introduced that final version, he said:


title: Equal Protection Clause

text: It prohibits the hanging of a black man for a crime for which the white man is not to be hanged. It protects the black man in his fundamental rights as a citizen with the same shield which it throws over the white man. Ought not the time to be now passed when one measure of justice is to be meted out to a member of one caste while another and a different measure is meted out to the member of another caste, both castes being alike citizens of the United States, both bound to obey the same laws, to sustain the burdens of the same Government, and both equally responsible to justice and to God for the deeds done in the body?


title: Equal Protection Clause

text: The 39th United States Congress proposed the Fourteenth Amendment on June 13, 1866. A difference between the initial and final versions of the clause was that the final version spoke not just of "equal protection" but of "the equal protection of the laws". John Bingham said in January 1867: "no State may deny to any person the equal protection of the laws, including all the limitations for personal protection of every article and section of the Constitution..." By July 9, 1868, three-fourths of the states (28 of 37) ratified the amendment, and that is when the Equal Protection Clause became law.


title: Equal Protection Clause

text: Bingham said in a speech on March 31, 1871 that the clause meant no State could deny anyone "the equal protection of the Constitution of the United States ... [or] any of the rights which it guarantees to all men", nor deny to anyone "any right secured to him either by the laws and treaties of the United States or of such State." At that time, the meaning of equality varied from one state to another.


title: Equal Protection Clause

text: Four of the original thirteen states never passed any laws barring interracial marriage, and the other states were divided on the issue in the Reconstruction era. In 1872, the Alabama Supreme Court ruled that the state's ban on mixed-race marriage violated the "cardinal principle" of the 1866 Civil Rights Act and of the Equal Protection Clause. Almost a hundred years would pass before the U.S. Supreme Court followed that Alabama case ("Burns v. State") in the case of "Loving v. Virginia". In "Burns", the Alabama Supreme Court said:


title: Equal Protection Clause

text: Marriage is a civil contract, and in that character alone is dealt with by the municipal law. The same right to make a contract as is enjoyed by white citizens, means the right to make any contract which a white citizen may make. The law intended to destroy the distinctions of race and color in respect to the rights secured by it.


title: Equal Protection Clause

text: As for public schooling, no states during this era of Reconstruction actually required separate schools for blacks. However, some states (e.g. New York) gave local districts discretion to set up schools that were deemed separate but equal. In contrast, Iowa and Massachusetts flatly prohibited segregated schools ever since the 1850s.


title: Equal Protection Clause

text: Likewise, some states were more favorable to women's legal status than others; New York, for example, had been giving women full property, parental, and widow's rights since 1860, but not the right to vote. No state or territory allowed women's suffrage when the Equal Protection Clause took effect in 1868. In contrast, at that time African American men had full voting rights in five states.


title: Equal Protection Clause

text: In the United States, 1877 marked the end of Reconstruction and the start of the Gilded Age. The first truly landmark equal protection decision by the Supreme Court was "Strauder v. West Virginia" (1880). A black man convicted of murder by an all-white jury challenged a West Virginia statute excluding blacks from serving on juries. Exclusion of blacks from juries, the Court concluded, was a denial of equal protection to black defendants, since the jury had been "drawn from a panel from which the State has expressly excluded every man of [the defendant's] race." At the same time, the Court explicitly allowed sexism and other types of discrimination, saying that states "may confine the selection to males, to freeholders, to citizens, to persons within certain ages, or to persons having educational qualifications. We do not believe the Fourteenth Amendment was ever intended to prohibit this. ... Its aim was against discrimination because of race or color."


title: Equal Protection Clause

text: The next important postwar case was the "Civil Rights Cases" (1883), in which the constitutionality of the Civil Rights Act of 1875 was at issue. The Act provided that all persons should have "full and equal enjoyment of ... inns, public conveyances on land or water, theatres, and other places of public amusement." In its opinion, the Court explicated what has since become known as the "state action doctrine", according to which the guarantees of the Equal Protection Clause apply only to acts done or otherwise "sanctioned in some way" by the state. Prohibiting blacks from attending plays or staying in inns was "simply a private wrong". Justice John Marshall Harlan dissented alone, saying, "I cannot resist the conclusion that the substance and spirit of the recent amendments of the Constitution have been sacrificed by a subtle and ingenious verbal criticism." Harlan went on to argue that because (1) "public conveyances on land and water" use the public highways, and (2) innkeepers engage in what is "a quasi-public employment", and (3) "places of public amusement" are licensed under the laws of the states, excluding blacks from using these services "was" an act sanctioned by the state.


title: Equal Protection Clause

text: A few years later, Justice Stanley Matthews wrote the Court's opinion in "Yick Wo v. Hopkins" (1886). In it the word "person" from the 14th Amendment's section has been given the broadest possible meaning by the U.S. Supreme Court:


title: Equal Protection Clause

text: These provisions are universal in their application to all persons within the territorial jurisdiction, without regard to any differences of race, of color, or of nationality, and the equal protection of the laws is a pledge of the protection of equal laws.


title: Equal Protection Clause

text: Thus, the Clause would not be limited to discrimination against African Americans, but would extend to other races, colors, and nationalities such as (in this case) legal aliens in the United States who are Chinese citizens.


title: Equal Protection Clause

text: In its most contentious Gilded Age interpretation of the Equal Protection Clause, "Plessy v. Ferguson" (1896), the Supreme Court upheld a Louisiana Jim Crow law that required the segregation of blacks and whites on railroads and mandated separate railway cars for members of the two races. The Court, speaking through Justice Henry B. Brown, ruled that the Equal Protection Clause had been intended to defend equality in civil rights, not equality in social arrangements. All that was therefore required of the law was reasonableness, and Louisiana's railway law amply met that requirement, being based on "the established usages, customs and traditions of the people." Justice Harlan again dissented. "Every one knows," he wrote,


title: Equal Protection Clause

text: Such "arbitrary separation" by race, Harlan concluded, was "a badge of servitude wholly inconsistent with the civil freedom and the equality before the law established by the Constitution." Harlan's philosophy of constitutional colorblindness would eventually become more widely accepted, especially after World War II.


title: Equal Protection Clause

text: In the decades after ratification of the Fourteenth Amendment, the vast majority of Supreme Court cases interpreting the Fourteenth Amendment dealt with the rights of corporations, not with the rights of African Americans. In the period 1868-1912 (from ratification of the Fourteenth Amendment to the first known published count by a scholar), the Supreme Court interpreted the Fourteenth Amendment in 312 cases dealing with the rights of corporations but in only 28 cases dealing with the rights of African Americans. Thus, the Fourteenth Amendment was used primarily by corporations to attack laws that regulated corporations, not to protect the formerly enslaved people from racial discrimination. Granting rights under the Equal Protection Clause of the Fourteenth Amendment to business corporations was introduced into Supreme Court jurisprudence through a series of sleights of hands. Roscoe Conkling, a skillful lawyer and former powerful politicians who had served as a member of the United States Congressional Joint Committee on Reconstruction, which had drafted the Fourteenth Amendment, was the lawyer who argued an important case known as "San Mateo County v. Southern Pacific Railroad" before the Supreme Court in 1882. In this case, the issue was whether corporations are “persons” within the meaning of the Equal Protection Clause of the Fourteenth Amendment. Conkling argued that corporations were included in the meaning of the term person and thus entitled to such rights. He told the Court that he, as a member of the Committee that drafted this amendment to the Constitutional, knew that this is what the Committee had intended. Legal historians in the 20th Century examined the history of the drafting of the Fourteenth Amendment and found that Conkling had fabricated the notion that the Committee had intended the term “person” of the Fourteenth Amendment to encompass corporations. This "San Mateo" case was settled by the parties without the Supreme Court issuing an opinion however the Court's misunderstanding of the intention of the Amendment's drafters that had been created by Conkling’s likely deliberate deception was never corrected at the time.


title: Equal Protection Clause

text: A second fraud occurred a few years later in the case of "Santa Clara v. Southern Pacific Railroad", which left a written legacy of corporate rights under the Fourteenth Amendment. J. C. Bancroft Davis, an attorney and the Reporter of Decisions of the Supreme Court of the United States, drafted the “syllabus” (summary) of Supreme Court decisions and the “headnotes” that summarized key points of law held by the Court. These were published before each case as part of the official court publication communicating the law of the land as held by the Supreme Court. A headnote that Davis as court reporter published immediately preceding the court opinion in Santa Clara case stated:


title: Equal Protection Clause

text: In fact, the Supreme Court decided the case on narrower grounds and had specifically avoided this Constitutional issue.


title: Equal Protection Clause

text: Supreme Court Justice Stephen Field seized on this deceptive and incorrect published summary by the court reporter Davis in "Santa Clara v. Southern Pacific Railroad" and cited that case as precedent in the 1889 case "Minneapolis & St. Louis Railway Company v. Beckwith" in support of the proposition that corporations are entitled to equal protection of the law within the meaning of the Equal Protection Clause of the Fourteenth Amendment. Writing the opinion for the Court in "Minneapolis & St. Louis Railway Company v. Beckwith", Justice Field reasoned that a corporation is an association of its human shareholders and thus has rights under the Fourteenth Amendment just as the members of the association.


title: Equal Protection Clause

text: In this Supreme Court case "Minneapolis & St. Louis Railway Company v. Beckwith", Justice Field, writing for the Court, thus took this point as established Constitutional law. In the decades that followed, the Supreme Court often continued to cite and to rely on "Santa Clara v. Southern Pacific Railroad" as established precedent that the Fourteenth Amendment guaranteed equal protection of the law and due process rights for corporations, even though in the Santa Clara case the Supreme Court held or stated no such thing. In the late 19th and early 20th centuries, the Clause was used to strike down numerous statutes applying to corporations. Since the New Deal, however, such invalidations have been rare.


title: Equal Protection Clause

text: In "Missouri ex rel. Gaines v. Canada" (1938), Lloyd Gaines was a black student at Lincoln University of Missouri, one of the historically black colleges in Missouri. He applied for admission to the law school at the all-white University of Missouri, since Lincoln did not have a law school, but was denied admission due solely to his race. The Supreme Court, applying the separate-but-equal principle of "Plessy", held that a State offering a legal education to whites but not to blacks violated the Equal Protection Clause.


title: Equal Protection Clause

text: In "Shelley v. Kraemer" (1948), the Court showed increased willingness to find racial discrimination illegal. The "Shelley" case concerned a privately made contract that prohibited "people of the Negro or Mongolian race" from living on a particular piece of land. Seeming to go against the spirit, if not the exact letter, of "The Civil Rights Cases", the Court found that, although a discriminatory private contract could not violate the Equal Protection Clause, the courts' "enforcement" of such a contract could; after all, the Supreme Court reasoned, courts were part of the state.


title: Equal Protection Clause

text: The companion cases "Sweatt v. Painter" and "McLaurin v. Oklahoma State Regents", both decided in 1950, paved the way for a series of school integration cases. In "McLaurin", the University of Oklahoma had admitted McLaurin, an African-American, but had restricted his activities there: he had to sit apart from the rest of the students in the classrooms and library, and could eat in the cafeteria only at a designated table. A unanimous Court, through Chief Justice Fred M. Vinson, said that Oklahoma had deprived McLaurin of the equal protection of the laws:


title: Equal Protection Clause

text: The present situation, Vinson said, was the former. In "Sweatt", the Court considered the constitutionality of Texas's state system of law schools, which educated blacks and whites at separate institutions. The Court (again through Chief Justice Vinson, and again with no dissenters) invalidated the school system—not because it separated students, but rather because the separate facilities were not "equal". They lacked "substantial equality in the educational opportunities" offered to their students.


title: Equal Protection Clause

text: All of these cases, as well as the upcoming "Brown" case, were litigated by the National Association for the Advancement of Colored People. It was Charles Hamilton Houston, a Harvard Law School graduate and law professor at Howard University, who in the 1930s first began to challenge racial discrimination in the federal courts. Thurgood Marshall, a former student of Houston's and the future Solicitor General and Associate Justice of the Supreme Court, joined him. Both men were extraordinarily skilled appellate advocates, but part of their shrewdness lay in their careful choice of "which" cases to litigate, selecting the best legal proving grounds for their cause.


title: Equal Protection Clause

text: In 1954 the contextualization of the equal protection clause would change forever. The Supreme Court itself recognized the gravity of the Brown v Board decision acknowledging that a split decision would be a threat to the role of the Supreme Court and even to the country. When Earl Warren became Chief Justice in 1953, "Brown" had already come before the Court. While Vinson was still Chief Justice, there had been a preliminary vote on the case at a conference of all nine justices. At that time, the Court had split, with a majority of the justices voting that school segregation did not violate the Equal Protection Clause. Warren, however, through persuasion and good-natured cajoling—he had been an extremely successful Republican politician before joining the Court—was able to convince all eight associate justices to join his opinion declaring school segregation unconstitutional. In that opinion, Warren wrote:


title: Equal Protection Clause

text: Warren discouraged other justices, such as Robert H. Jackson, from publishing any concurring opinion; Jackson's draft, which emerged much later (in 1988), included this statement: "Constitutions are easier amended than social customs, and even the North never fully conformed its racial practices to its professions". The Court set the case for re-argument on the question of how to implement the decision. In "Brown II", decided in 1954, it was concluded that since the problems identified in the previous opinion were local, the solutions needed to be so as well. Thus the court devolved authority to local school boards and to the trial courts that had originally heard the cases. ("Brown" was actually a consolidation of four different cases from four different states.) The trial courts and localities were told to desegregate with "all deliberate speed".


title: Equal Protection Clause

text: Partly because of that enigmatic phrase, but mostly because of self-declared "massive resistance" in the South to the desegregation decision, integration did not begin in any significant way until the mid-1960s and then only to a small degree. In fact, much of the integration in the 1960s happened in response not to "Brown" but to the Civil Rights Act of 1964. The Supreme Court intervened a handful of times in the late 1950s and early 1960s, but its next major desegregation decision was not until "Green v. School Board of New Kent County" (1968), in which Justice William J. Brennan, writing for a unanimous Court, rejected a "freedom-of-choice" school plan as inadequate. This was a significant decision; freedom-of-choice plans had been very common responses to "Brown". Under these plans, parents could choose to send their children to either a formerly white or a formerly black school. Whites almost never opted to attend black-identified schools, however, and blacks rarely attended white-identified schools.


title: Equal Protection Clause

text: In response to "Green", many Southern districts replaced freedom-of-choice with geographically based schooling plans; because residential segregation was widespread, little integration was accomplished. In 1971, the Court in "Swann v. Charlotte-Mecklenburg Board of Education" approved busing as a remedy to segregation; three years later, though, in the case of "Milliken v. Bradley" (1974), it set aside a lower court order that had required the busing of students "between" districts, instead of merely "within" a district. "Milliken" basically ended the Supreme Court's major involvement in school desegregation; however, up through the 1990s many federal trial courts remained involved in school desegregation cases, many of which had begun in the 1950s and 1960s.


title: Equal Protection Clause

text: The curtailment of busing in "Milliken v. Bradley" is one of several reasons that have been cited to explain why equalized educational opportunity in the United States has fallen short of completion. In the view of various liberal scholars, the election of Richard Nixon in 1968 meant that the executive branch was no longer behind the Court's constitutional commitments. Also, the Court itself decided in "San Antonio Independent School District v. Rodriguez" (1973) that the Equal Protection Clause allows—but does not require—a state to provide equal educational funding to all students within the state. Moreover, the Court's decision in "Pierce v. Society of Sisters" (1925) allowed families to opt out of public schools, despite "inequality in economic resources that made the option of private schools available to some and not to others", as Martha Minow has put it.


title: Equal Protection Clause

text: American public school systems, especially in large metropolitan areas, to a large extent are still "de facto" segregated. Whether due to "Brown", or due to Congressional action, or due to societal change, the percentage of black students attending majority-black school districts decreased somewhat until the early 1980s, at which point that percentage began to increase. By the late 1990s, the percentage of black students in mostly minority school districts had returned to about what it was in the late 1960s. In "Parents Involved in Community Schools v. Seattle School District No. 1" (2007), the Court held that, if a school system became racially imbalanced due to social factors other than governmental racism, then the state is not as free to integrate schools as if the state had been at fault for the racial imbalance. This is especially evident in the charter school system where parents of students can pick which schools their children attend based on the amenities provided by that school and the needs of the child. It seems that race is a factor in the choice of charter school.


title: Equal Protection Clause

text: By its terms, the clause restrains only state governments. However, the Fifth Amendment's due process guarantee, beginning with "Bolling v. Sharpe" (1954), has been interpreted as imposing some of the same restrictions on the federal government: "Though the Fifth Amendment does not contain an equal protection clause, as does the Fourteenth Amendment which applies only to the States, the concepts of equal protection and due process are not mutually exclusive." In "Lawrence v. Texas" (2003) the Supreme Court added: "Equality of treatment and the due process right to demand respect for conduct protected by the substantive guarantee of liberty are linked in important respects, and a decision on the latter point advances both interests"


title: Equal Protection Clause

text: Some scholars have argued that the Court's decision in "Bolling" should have been reached on other grounds. For example, Michael W. McConnell has written that Congress never "required that the schools of the District of Columbia be segregated." According to that rationale, the segregation of schools in Washington D.C. was unauthorized and therefore illegal.


title: Equal Protection Clause

text: Despite the undoubted importance of "Brown", much of modern equal protection jurisprudence originated in other cases, though not everyone agrees about "which" other cases. Many scholars assert that the opinion of Justice Harlan Stone in "United States v. Carolene Products Co." (1938) contained a footnote that was a critical turning point for equal protection jurisprudence, but that assertion is disputed.


title: Equal Protection Clause

text: Whatever its precise origins, the basic idea of the modern approach is that more judicial scrutiny is triggered by purported discrimination that involves "fundamental rights" (such as the right to procreation), and similarly more judicial scrutiny is also triggered if the purported victim of discrimination has been targeted because he or she belongs to a "suspect classification" (such as a single racial group). This modern doctrine was pioneered in "Skinner v. Oklahoma" (1942), which involved depriving certain criminals of the fundamental right to procreate:


title: Equal Protection Clause

text: When the law lays an unequal hand on those who have committed intrinsically the same quality of offense and sterilizes one and not the other, it has made as invidious a discrimination as if it had selected a particular race or nationality for oppressive treatment.


title: Equal Protection Clause

text: Until 1976, the Supreme Court usually ended up dealing with discrimination by using one of two possible levels of scrutiny: what has come to be called "strict scrutiny" (when a suspect class or fundamental right is involved), or instead the more lenient "rational basis review". Strict scrutiny means that a challenged statute must be "narrowly tailored" to serve a "compelling" government interest, and must not have a "less restrictive" alternative. In contrast, rational basis scrutiny merely requires that a challenged statute be "reasonably related" to a "legitimate" government interest.


title: Equal Protection Clause

text: However, in the 1976 case of "Craig v. Boren", the Court added another tier of scrutiny, called "intermediate scrutiny", regarding gender discrimination. The Court may have added other tiers too, such as "enhanced rational basis" scrutiny, and "exceedingly persuasive basis" scrutiny.


title: Equal Protection Clause

text: All of this is known as "tiered" scrutiny, and it has had many critics, including Justice Thurgood Marshall who argued for a "spectrum of standards in reviewing discrimination", instead of discrete tiers. Justice John Paul Stevens argued for only one level of scrutiny, given that "there is only one Equal Protection Clause". The whole tiered strategy developed by the Court is meant to reconcile the principle of equal protection with the reality that most laws necessarily discriminate in some way.


title: Equal Protection Clause

text: Choosing the standard of scrutiny can determine the outcome of a case, and the strict scrutiny standard is often described as "strict in theory and fatal in fact". In order to select the correct level of scrutiny, Justice Antonin Scalia urged the Court to identify rights as "fundamental" or identify classes as "suspect" by analyzing what was understood when the Equal Protection Clause was adopted, instead of based upon more subjective factors.


title: Equal Protection Clause

text: Because inequalities can be caused either intentionally or unintentionally, the Supreme Court has decided that the Equal Protection Clause itself does not forbid governmental policies that unintentionally lead to racial disparities, though Congress may have some power under other clauses of the Constitution to address unintentional disparate impacts. This subject was addressed in the seminal case of "Arlington Heights v. Metropolitan Housing Corp." (1977). In that case, the plaintiff, a housing developer, sued a city in the suburbs of Chicago that had refused to re-zone a plot of land on which the plaintiff intended to build low-income, racially integrated housing. On the face, there was no clear evidence of racially discriminatory intent on the part of Arlington Heights's planning commission. The result was racially disparate, however, since the refusal supposedly prevented mostly African-Americans and Hispanics from moving in. Justice Lewis Powell, writing for the Court, stated, "Proof of racially discriminatory intent or purpose is required to show a violation of the Equal Protection Clause." Disparate impact merely has an evidentiary value; absent a "stark" pattern, "impact is not determinative."


title: Equal Protection Clause

text: The result in "Arlington Heights" was similar to that in "Washington v. Davis" (1976), and has been defended on the basis that the Equal Protection Clause was not designed to guarantee equal outcomes, but rather equal opportunities; if a legislature wants to correct unintentional but racially disparate effects, it may be able to do so through further legislation. It is possible for a discriminating state to hide its true intention, and one possible solution is for disparate impact to be considered as stronger evidence of discriminatory intent. This debate, though, is currently academic, since the Supreme Court has not changed its basic approach as outlined in "Arlington Heights".


title: Equal Protection Clause

text: For an example of how this rule limits the Court's powers under the Equal Protection Clause, see "McClesky v. Kemp" (1987). In that case a black man was convicted of murdering a white police officer and sentenced to death in the state of Georgia. A study found that killers of whites were more likely to be sentenced to death than were killers of blacks. The Court found that the defense had failed to prove that such data demonstrated the requisite discriminatory intent by the Georgia legislature and executive branch.


title: Equal Protection Clause

text: The “Stop and Frisk” policy in New York allows officers to stop anyone who they feel looks suspicious. Data from police stops shows that even when controlling for variability, people who are black and those of Hispanic descent were stopped more frequently than white people, with these statistics dating back to the late 1990s. A term that has been created to describe the disproportionate number of police stops of black people is “Driving While Black.” This term is used to describe the stopping of innocent black people who are not committing any crime.


title: Equal Protection Clause

text: In addition to concerns that a discriminating statute can hide its true intention, there have also been concerns that facially neutral evaluative and statistical devices that are permitted by decision-makers can be subject to racial bias and unfair appraisals of ability.' As the equal protection doctrine heavily relies on the ability of neutral evaluative tools to engage in neutral selection procedures, racial biases indirectly permitted under the doctrine can have grave ramifications and result in 'uneven conditions.' ' These issues can be especially prominent in areas of public benefits, employment, and college admissions, etc.'


title: Equal Protection Clause

text: The Supreme Court ruled in "Nixon v. Herndon" (1927) that the Fourteenth Amendment prohibited denial of the vote based on race. The first modern application of the Equal Protection Clause to voting law came in "Baker v. Carr" (1962), where the Court ruled that the districts that sent representatives to the Tennessee state legislature were so malapportioned (with some legislators representing ten times the number of residents as others) that they violated the Equal Protection Clause.


title: Equal Protection Clause

text: It may seem counterintuitive that the Equal Protection Clause should provide for equal voting rights; after all, it would seem to make the Fifteenth Amendment and the Nineteenth Amendment redundant. Indeed, it was on this argument, as well as on the legislative history of the Fourteenth Amendment, that Justice John M. Harlan (the grandson of the earlier Justice Harlan) relied on in his dissent from "Reynolds". Harlan quoted the congressional debates of 1866 to show that the framers did not intend for the Equal Protection Clause to extend to voting rights, and in reference to the Fifteenth and Nineteenth Amendments, he said:


title: Equal Protection Clause

text: Harlan also relied on the fact that Section Two of the Fourteenth Amendment "expressly recognizes the States' power to deny 'or in any way' abridge the right of their inhabitants to vote for 'the members of the [state] Legislature.'" Section Two of the Fourteenth Amendment provides a specific federal response to such actions by a state: reduction of a state's representation in Congress. However, the Supreme Court has instead responded that voting is a "fundamental right" on the same plane as marriage ("Loving v. Virginia"); for any discrimination in fundamental rights to be constitutional, the Court requires the legislation to pass strict scrutiny. Under this theory, equal protection jurisprudence has been applied to voting rights.


title: Equal Protection Clause

text: A recent use of equal protection doctrine came in "Bush v. Gore" (2000). At issue was the controversial recount in Florida in the aftermath of the 2000 presidential election. There, the Supreme Court held that the different standards of counting ballots across Florida violated the equal protection clause. The Supreme Court used four of its rulings from 1960s voting rights cases (one of which was Reynolds v. Sims) to support its ruling in Bush v. Gore. It was not this holding that proved especially controversial among commentators, and indeed, the proposition gained seven out of nine votes; Justices Souter and Breyer joined the majority of five—but only for the finding that there was an Equal Protection violation. Much more controversial was the remedy that the Court chose, namely, the cessation of a statewide recount.


title: Equal Protection Clause

text: Originally, the Fourteenth Amendment did not forbid sex discrimination to the same extent as other forms of discrimination. On the one hand, Section Two of the amendment specifically discouraged states from interfering with the voting rights of "males", which made the amendment anathema to many women when it was proposed in 1866. On the other hand, as feminists like Victoria Woodhull pointed out, the word "person" in the Equal Protection Clause was apparently chosen deliberately, instead of a masculine term that could have easily been used instead.


title: Equal Protection Clause

text: In 1971, the U.S. Supreme Court decided "Reed v. Reed", extending the Equal Protection Clause of the Fourteenth Amendment to protect women from sex discrimination, in situations where there is no rational basis for the discrimination. That level of scrutiny was boosted to an intermediate level in "Craig v. Boren" (1976).


title: Equal Protection Clause

text: The Supreme Court has been disinclined to extend full "suspect classification" status (thus making a law that categorizes on that basis subject to greater judicial scrutiny) for groups other than racial minorities and religious groups. In "City of Cleburne v. Cleburne Living Center, Inc." (1985), the Court refused to make the developmentally disabled a suspect class. Many commentators have noted, however—and Justice Thurgood Marshall so notes in his partial concurrence—that the Court did appear to examine the City of Cleburne's denial of a permit to a group home for intellectually disabled people with a significantly higher degree of scrutiny than is typically associated with the rational-basis test.


title: Equal Protection Clause

text: The Court's decision in "Romer v. Evans" (1996) struck down a Colorado constitutional amendment aimed at denying homosexuals "minority status, quota preferences, protected status or [a] claim of discrimination." The Court rejected as "implausible" the dissent's argument that the amendment would not deprive homosexuals of general protections provided to everyone else but rather would merely prevent "special treatment of homosexuals." Much as in "City of Cleburne", the "Romer" decision seemed to employ a markedly higher level of scrutiny than the nominally applied rational-basis test.


title: Equal Protection Clause

text: In "Lawrence v. Texas" (2003), the Court struck down a Texas statute prohibiting homosexual sodomy on substantive due process grounds. In Justice Sandra Day O'Connor's opinion concurring in the judgment, however, she argued that by prohibiting only "homosexual" sodomy, and not "heterosexual" sodomy as well, Texas's statute did not meet rational-basis review under the Equal Protection Clause; her opinion prominently cited "City of Cleburne", and also relied in part on "Romer". Notably, O'Connor's opinion did not claim to apply a higher level of scrutiny than mere rational basis, and the Court has not extended suspect-class status to sexual orientation.


title: Equal Protection Clause

text: While the courts have applied rational-basis scrutiny to classifications based on sexual orientation, it has been argued that discrimination based on sex should be interpreted to include discrimination based on sexual orientation, in which case intermediate scrutiny could apply to gay rights cases. Other scholars disagree, arguing that "homophobia" is distinct from sexism, in a sociological sense, and so treating it as such would be an unacceptable judicial shortcut.


title: Equal Protection Clause

text: In 2013, the Court struck down part of the federal Defense of Marriage Act, in "United States v. Windsor". No state statute was in question, and therefore the Equal Protection Clause did not apply. The Court did employ similar principles, however, in combination with federalism principles. The Court did not purport to use any level of scrutiny more demanding than rational basis review, according to law professor Erwin Chemerinsky. The four dissenting justices argued that the authors of the statute were rational.


title: Equal Protection Clause

text: In 2015, the Supreme Court held in "Obergefell v. Hodges" that the fundamental right to marry is guaranteed to same-sex couples by both the Due Process Clause and the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution and required all states to issue marriage licenses to same-sex couples and to recognize same-sex marriages validly performed in other jurisdictions.


title: Equal Protection Clause

text: Affirmative action is the consideration of race, gender, or other factors, to benefit an underrepresented group or to address past injustices done to that group. Individuals who belong to the group are preferred over those who do not belong to the group, for example in educational admissions, hiring, promotions, awarding of contracts, and the like. Such action may be used as a "tie-breaker" if all other factors are inconclusive, or may be achieved through quotas, which allot a certain number of benefits to each group.


title: Equal Protection Clause

text: During Reconstruction, Congress enacted race-conscious programs primarily to assist newly freed slaves who had personally been denied many advantages earlier in their lives. Such legislation was enacted by many of the same people who framed the Equal Protection Clause, though that clause did not apply to such federal legislation, and instead only applied to state legislation. Likewise, the Equal Protection Clause does not apply to private universities and other private businesses, which are free to practice affirmative action unless prohibited by federal statute or state law.


title: Equal Protection Clause

text: Several important affirmative action cases to reach the Supreme Court have concerned government contractors—for instance, "Adarand Constructors v. Peña" (1995) and "City of Richmond v. J.A. Croson Co." (1989). But the most famous cases have dealt with affirmative action as practiced by public universities: "Regents of the University of California v. Bakke" (1978), and two companion cases decided by the Supreme Court in 2003, "Grutter v. Bollinger" and "Gratz v. Bollinger".


title: Equal Protection Clause

text: In "Bakke", the Court held that racial quotas are unconstitutional, but that educational institutions could legally use race as one of many factors to consider in their admissions process. In "Grutter" and "Gratz", the Court upheld both "Bakke" as a precedent and the admissions policy of the University of Michigan Law School. In dicta, however, Justice O'Connor, writing for the Court, said she expected that in 25 years, racial preferences would no longer be necessary. In "Gratz", the Court invalidated Michigan's undergraduate admissions policy, on the grounds that unlike the law school's policy, which treated race as one of many factors in an admissions process that looked to the individual applicant, the undergraduate policy used a point system that was excessively mechanistic.


title: Equal Protection Clause

text: In these affirmative action cases, the Supreme Court has employed, or has said it employed, strict scrutiny, since the affirmative action policies challenged by the plaintiffs categorized by race. The policy in "Grutter", and a Harvard College admissions policy praised by Justice Powell's opinion in "Bakke", passed muster because the Court deemed that they were narrowly tailored to achieve a compelling interest in diversity. On one side, critics have argued—including Justice Clarence Thomas in his dissent to "Grutter"—that the scrutiny the Court has applied in some cases is much less searching than true strict scrutiny, and that the Court has acted not as a principled legal institution but as a biased political one. On the other side, it is argued that the purpose of the Equal Protection Clause is to prevent the socio-political subordination of some groups by others, not to prevent classification; since this is so, non-invidious classifications, such as those used by affirmative action programs, should not be subjected to heightened scrutiny.


title: Mary Ann Mobley

text: Mary Ann Mobley (February 17, 1937 – December 9, 2014) was an American actress, television personality, and Miss America 1959.


title: Mary Ann Mobley

text: Mobley was born in 1937 in Biloxi, Mississippi. After her reign as Miss America 1959, Mobley embarked on a career in both film and television. She signed a five-year contract with MGM. She made her first television appearances on "Be Our Guest" in 1960, followed by five appearances on "Burke's Law" from 1963 to 1965. In 1966 she was the female guest star on the first two-part episode of "", in the episode “Old Man Out.” She went on to make multiple appearances on "Perry Mason," "Love, American Style," and "Fantasy Island." She played a recurring role as Maggie McKinney Drummond on "Diff'rent Strokes" in the final season of the series, having taken over the role from Dixie Carter. She also played Arnold’s teacher on "Diff'rent Strokes" in season 2, episode 24. In Carter's later series, "Designing Women", Mobley guest-starred as Karen Delaporte, the snide head of a historical society, who crosses swords with Carter's character, Julia Sugarbaker. She made two films with Elvis Presley in 1965, "Girl Happy" and "Harum Scarum."


title: Mary Ann Mobley

text: She was given the Golden Globe Award for New Star of the Year – Actress in 1965. She was active in many charitable causes and was awarded the Outstanding Young Woman of the Year Award in 1966 by Lady Bird Johnson.


title: Mary Ann Mobley

text: Mobley also made occasional appearances on "Match Game" as one of the celebrity panelists from 1973 to 1977. From 1984 to 1988, Mobley joined husband Gary Collins in co-hosting the Pillsbury Bake-Off on CBS.


title: Mary Ann Mobley

text: She appeared in the documentary film "Miss America", which PBS aired as the January 27, 2002, episode of "American Experience".


title: Mary Ann Mobley

text: Mobley is briefly depicted in the third season of the Amazon Prime series "The Marvelous Mrs. Maisel", played by Amanda Dela Cruz.


title: Mary Ann Mobley

text: Mobley was crowned Miss America 1959, the first Mississippian to achieve this honor, winning the national talent award.


title: Mary Ann Mobley

text: Mobley joined husband Gary Collins as co-host of the 1989 Miss America pageant in September 1988, the 30th anniversary year of her own Miss America victory.


title: Mary Ann Mobley

text: Mobley grew up in Brandon, Mississippi, and graduated from Brandon High School. She was a member of Chi Omega sorority at the University of Mississippi, and in 1981 was inducted into the University of Mississippi Alumni Hall of Fame.


title: Mary Ann Mobley

text: The couple separated in 2010 but reconciled and were living in Biloxi when Collins died on October 13, 2012. Collins and Mobley had one daughter together, Mary Clancy Collins. Mobley was also stepmother to Melissa Collins and Guy William Collins, children from his first marriage.


title: Mary Ann Mobley

text: She was treated in 2009 for Stage III breast cancer. Mobley died at her home in Beverly Hills, California, on December 9, 2014, aged 77, from breast cancer.


title: Joe Judge (American football)

text: Joseph Francis Judge (born December 31, 1981) is an American football coach who is an offensive assistant and quarterbacks coach for the New England Patriots of the National Football League (NFL). Judge served as the head coach of the New York Giants from 2020 to 2021. Prior to joining the Giants, Judge served as an assistant coach for the Patriots from 2012 to 2019. The Patriots appeared in four Super Bowls, winning three of them, during Judge's tenure.


title: Joe Judge (American football)

text: Judge was born in Philadelphia, Pennsylvania. Growing up in Doylestown, Pennsylvania, he graduated from Lansdale Catholic High School in Lansdale, Pennsylvania. Judge played for Mississippi State from 2000 to 2004, earning three letters. He was also named to the SEC Academic Honor Roll and made the Dean's List.


title: Joe Judge (American football)

text: In 2005, he joined his alma mater, Mississippi State University, as a graduate assistant for the Bulldogs. He next served briefly as the linebackers coach for the Birmingham–Southern Panthers in 2008 and then as a special teams assistant for Alabama. In 2012, he joined the New England Patriots as a special teams assistant and served in that role through the 2014 season. Following Super Bowl XLIX, which the Patriots won, Judge was promoted to special teams coordinator following the retirement of Scott O'Brien. On February 5, 2017, Judge was part of the Patriots' coaching staff that won Super Bowl LI. In the game, the Patriots defeated the Atlanta Falcons by a score of 34–28 in overtime.


title: Joe Judge (American football)

text: On February 6, 2018, it was reported that Judge was leaving the Patriots to join the Indianapolis Colts' new head coach Josh McDaniels in Indianapolis; when McDaniels spurned the Colts and chose to stay with the Patriots, Judge made the same decision. After wide receivers coach Chad O'Shea left New England to become offensive coordinator for the Miami Dolphins, Judge was tapped to fill O'Shea's role while continuing to serve as special teams coordinator; according to ESPN, he was the only coach in the NFL with both special teams and wide receiver duties.


title: Joe Judge (American football)

text: On January 8, 2020, Judge was hired to become the 21st head coach of the New York Giants. According to "Sports Illustrated"'s Rick Gosselin, he is only the second NFL head coach to have been hired directly from a special teams coaching job, after Frank Gansz.


title: Joe Judge (American football)

text: On September 13, 2020, Judge lost his head coaching debut against the Pittsburgh Steelers by a score of 26–16. After an 0–5 start to the season, Judge received his first career win as a head coach in a 20–19 win against the Washington Redskins on October 18, 2020. On November 18, 2020, there was a coaching controversy when Judge fired his offensive line coach Marc Colombo and replaced him with former Dolphins offensive line coach Dave DeGuglielmo after Week 10, due to a verbal altercation. In his first season as the head coach of the Giants, Judge led them to a 6–10 record, finishing second in the NFC East. At the end of the season he was criticized for comments he made about the Philadelphia Eagles not putting in effort, causing the Giants to miss the playoffs.


title: Joe Judge (American football)

text: The Giants regressed during Judge's second season, going 4–13 and finishing last in the NFC East. Judge recorded the most losses by a Giants head coach with 13 surpassing the mark of 12 by Jim Fassel in 2003. Judge was fired on January 11, 2022, finishing his tenure in New York with an overall record of 10–23 (.303). Judge's season suffered from questionable calls, such as a coach's challenge on a non-reviewable scoring play during Week 1 versus the Denver Broncos, a controversial post-game locker room rant after a loss to the Chicago Bears, and a quarterback sneak on 3rd and 9 against their own goalline during a Week 18 matchup against the Washington Football Team.


title: Joe Judge (American football)

text: On February 8, 2022, the Patriots announced that Judge was hired as an offensive assistant. On July 21, 2022, the Patriots announced that he will also be the Quarterbacks coach.


title: Joe Judge (American football)

text: Judge's father, Joseph, played football at Temple and professionally with the Hamilton Tiger-Cats of the Canadian Football League. Judge's wife, Amber, was an All-SEC soccer player at Mississippi State, and they have four children together.


title: Tom Sawyer

text: Thomas Sawyer () is the titular character of the Mark Twain novel "The Adventures of Tom Sawyer" (1876). He appears in three other novels by Twain: "Adventures of Huckleberry Finn" (1884), "Tom Sawyer Abroad" (1894), and "Tom Sawyer, Detective" (1896).


title: Tom Sawyer

text: Sawyer also appears in at least three unfinished Twain works, "Huck and Tom Among the Indians", "Schoolhouse Hill", and "Tom Sawyer's Conspiracy". While all three uncompleted works were posthumously published, only "Tom Sawyer's Conspiracy" has a complete plot, as Twain abandoned the other two works after finishing only a few chapters. It is set in the 1840s in the Mississippi.


title: Tom Sawyer

text: The fictional character's name may have been derived from a jolly and flamboyant chief named Tom Sawyer, with whom Twain was acquainted in San Francisco, California, while Twain was employed as a reporter at "The San Francisco Call". Twain used to listen to Sawyer tell stories of his youth, "Sam, he would listen to these pranks of mine with great interest and he'd occasionally take 'em down in his notebook. One day he says to me: ‘I am going to put you between the covers of a book some of these days, Tom.’ ‘Go ahead, Sam,’ I said, ‘but don’t disgrace my name.’" Twain himself said the character sprang from three people, later identified as: John B. Briggs (who died in 1907), William Bowen (who died in 1893) and Twain; however Twain later changed his story saying Sawyer was fully formed solely from his imagination, but as Robert Graysmith says, "The great appropriator liked to pretend his characters sprang fully grown from his fertile mind."


title: Nick Park

text: Nicholas Wulstan Park (born 6 December 1958) is a British animator who created "Wallace and Gromit", "Creature Comforts", "Chicken Run", "Shaun the Sheep", and "Early Man". Park has been nominated for an Academy Award a total of six times and won four with "Creature Comforts" (1989), "The Wrong Trousers" (1993), "A Close Shave" (1995) and "" (2005).


title: Nick Park

text: He has also received five BAFTA Awards, including the BAFTA for Best Short Animation for "A Matter of Loaf and Death", which was also the most watched television programme in the United Kingdom in 2008. His 2000 film "Chicken Run" is the highest-grossing stop motion animated film.


title: Nick Park

text: For his work in animation, in 2012, Park was among the British cultural icons selected by artist Peter Blake to appear in a new version of Blake's most famous artwork—the Beatles' "Sgt. Pepper's Lonely Hearts Club Band" album cover—to celebrate the British cultural figures of his life.


title: Nick Park

text: Nicholas Wulstan Park was born on 6 December 1958 in Preston, Lancashire, to seamstress Mary Cecilia ("née" Ashton; born 1930) and Roger Wulstan Park (1925–2004), an architectural photographer. The middle child of five siblings, he grew up on Penwortham; the family later moved to Walmer Bridge. His sister Janet lives in Longton, Lancashire. He attended Cuthbert Mayne High School (now Our Lady's Catholic High School).


title: Nick Park

text: Park grew up with a keen interest in drawing cartoons, and as a 13-year-old made films with the help of his mother and her home film camera and cotton bobbins. He also took after his father, an amateur inventor, and would send homemade items like a bottle that squeezed out different coloured wools in to "Blue Peter".


title: Nick Park

text: He studied Communication Arts at Sheffield City Polytechnic (now Sheffield Hallam University) and then went to the National Film and Television School, where he started making the first Wallace and Gromit film, "A Grand Day Out".


title: Nick Park

text: In 1985, Park joined the staff of Aardman Animations in Bristol, where he worked as an animator on commercial products (including the music video for Peter Gabriel's "Sledgehammer", where he worked on the dance scene involving oven-ready chickens). He also had a part in animating the Penny cartoons from the first season of "Pee-wee's Playhouse", which featured Paul Reubens as his character Pee-wee Herman.


title: Nick Park

text: Along with all this, he had finally completed "A Grand Day Out", and with that in post production, he made "Creature Comforts" as his contribution to a series of shorts called "Lip Synch". "Creature Comforts" matched animated zoo animals with a soundtrack of people talking about their homes. The two films were nominated for a host of awards. "A Grand Day Out" beat "Creature Comforts" for the BAFTA Award, but it was "Creature Comforts" that won Park his first Oscar.


title: Nick Park

text: In 1990, Park worked alongside advertising agency GGK to develop a series of highly acclaimed television advertisements for the "Heat Electric" campaign. The "Creature Comforts" advertisements are now regarded as among the best advertisements ever shown on British television, as voted (independently) by viewers of the United Kingdom's main commercial channels ITV and Channel 4.


title: Nick Park

text: Two more Wallace and Gromit shorts, "The Wrong Trousers" (1993) and "A Close Shave" (1995), followed, both winning Oscars. He then made his first feature-length film, "Chicken Run" (2000), co-directed with Aardman founder Peter Lord. He also supervised a new series of "Creature Comforts" films for British television in 2003.


title: Nick Park

text: His second theatrical feature-length film and first Wallace and Gromit feature, "", was released on 5 October 2005, and won Best Animated Feature Oscar at the 78th Academy Awards, 6 March 2006.


title: Nick Park

text: On 10 October 2005, a fire gutted one of Aardman Animations' archive warehouse. The fire resulted in the loss of some of Park's creations, including the models and sets used in the movie "Chicken Run". Some of the original Wallace and Gromit models and sets, as well as the master prints of the finished films, were elsewhere and survived.


title: Nick Park

text: In 2007 and 2008, Park's work included a United States version of "Creature Comforts", a weekly television series that was on CBS every Monday evening at 8 pm ET. In the series, Americans were interviewed about a range of subjects. The interviews were lip-synced to Aardman animal characters.


title: Nick Park

text: In September 2007, it was announced that Park had been commissioned to design a bronze statue of Wallace and Gromit, which will be placed in his home town of Preston. In October 2007, it was announced that the BBC had commissioned another Wallace and Gromit short film to be entitled "Trouble at Mill" (retitled later to "A Matter of Loaf and Death").


title: Nick Park

text: Park studied at Preston College, which has since named its library for the art and design department after him: the Nick Park Library Learning Centre. He is the recipient of a gold "Blue Peter" badge.


title: Nick Park

text: By the beginning of 2010, Park had won four Academy Awards, and had the distinction of having won an Academy Award every time he had been nominated (his only loss being when he was nominated twice in the same category). This streak ended in the 2010 Oscars when "A Matter of Loaf and Death" failed to win the best animated short Academy Award.


title: Nick Park

text: Park had his first acting role in February 2011, voicing himself in a cameo on "The Simpsons" episode "". In the episode, the fictional Park's new Willis and Crumble short, "Better Gnomes and Gardens", is a parody of "Wallace and Gromit".


title: Nick Park

text: In the end of 2011, Park directed a music video for "Plain Song"—a song by Native and the Name, a Sheffield band led by Joe Rose, the son of an old university friend. The video was filmed at Birkdale School, Sheffield, and Park also selected the track as one of his "Desert Island Discs" when he went on the show in 2011, which led to suggestions that Park was using his fame to give a friend a leg up in his career. Park denied these claims, insisting it had become one of his favourite songs. The song and video can be found on YouTube.


title: Nick Park

text: In April 2013, Park was involved in the British stage adaptation of Hayao Miyazaki's animated film, "Princess Mononoke". He was the executive producer of "Shaun the Sheep Movie" and he also voiced himself in a cameo.


title: Nick Park

text: For 2018, he directed another Aardman Animations stop-motion film, titled "Early Man", which tells a story of a caveman who unites his tribe against the Bronze Age while unintentionally inventing football.


title: Nick Park

text: On 21 May 2019, Park announced that a new Wallace and Gromit project is currently in the works, with no projected release date. In January 2022, Park announced that a new untitled television film is currently in production for release at Christmas 2024 for the BBC and Netflix.


title: Nick Park

text: "The Daily Telegraph" remarked Park has taken on some attributes of Wallace, just "as dog owners come to look like their pets", overexpressing himself, possibly as a result of having to show animators how he wants his characters to behave.


title: Nick Park

text: Park married Mags Connolly at the Gibbon Bridge Hotel near Chipping on 16 September 2016. Although by his own admission, he was not especially interested in football growing up, he has always nominally supported his hometown's local team, Preston North End.


title: Nick Park

text: In 2016, and following a vote by students on a number of nominated 'Preston Legends', the University of Central Lancashire named one of three new meeting rooms in the students' union after Park, who was born in the city where it is based. In response, Park sent the university a message to say how honoured he was by it.


title: Nick Park

text: Nick Park has stated that his main influences have been Ray Harryhausen, Oliver Postgate, Peter Firmin, Chuck Jones, Yuri Norstein, Richard Williams, Terry Gilliam, and Bob Godfrey. He is a Gerry Anderson fan.


title: Nick Park

text: He is a fan of "The Beano" comic, and guest-edited the 70th-anniversary issue dated 2 August 2008. He also contributed to "Classics from the Comics" at the same time, picking his favourite classic stories for the comic reprint magazine's new Classic Choice feature.


title: Nick Park

text: His film-making ideas were encouraged by his old English teacher; however, Park has denied that the character of Wallace was based on him.


title: Surrogates

text: Surrogates is a 2009 American science fiction action film based on the 2005–2006 comic book series "The Surrogates". Directed by Jonathan Mostow, it stars Bruce Willis as Tom Greer, an FBI agent who ventures out into the real world to investigate the murder of surrogates (humanoid remote-controlled robots). It also stars Radha Mitchell, Rosamund Pike, Boris Kodjoe, Ving Rhames, and James Cromwell.


title: Surrogates

text: The film's main concept centers on the mysterious murder of a college student linked to the man who helped create a high-tech surrogate phenomenon that allows people to purchase remote-controlled humanoid robots through which they interact with society. These fit, attractive, remotely controlled robots ultimately assume their life roles, enabling people to experience life vicariously from the comfort and safety of their own homes. "Surrogates" was released on September 25, 2009, in the United States and Canada. It received mixed reviews from critics and grossed over $122 million.


title: Surrogates

text: In the near future, widespread use of remotely controlled androids called "surrogates" enables everyone to live in idealized forms from the safety of their homes. Compared to their surrogates, the human operators are depicted as slovenly and homebound. Protected from harm, a surrogate's operator feels no pain when the surrogate is damaged, and can do acrobatics that a normal person couldn't. In Boston, FBI agent Tom Greer has been estranged from his wife Maggie since their son's death in a car crash several years before. He never sees her outside of her surrogate and she criticizes his desire to interact via their real bodies.


title: Surrogates

text: Tom and his partner, Agent Jennifer Peters, investigate the death of two people who were killed when their surrogates were destroyed at a Fort Point club. Jared Canter, one of the victims, is the son of Dr. Lionel Canter, the inventor of surrogates and the former head of their manufacturing company, Virtual Self Industries (VSI). The two determine that a human, Miles Strickland, used a new type of weapon to overload the surrogates' systems and kill their operators. After locating Strickland, Tom attempts to bring him into custody. Strickland uses the weapon and injures Tom during the chase; Tom inadvertently crash-lands into an anti-surrogate zone known as the Dread Reservation (one of many throughout the US). A mob helps Strickland and destroys Tom's surrogate. The Dread leader, a man known as the Prophet, kills Strickland and confiscates the weapon.


title: Surrogates

text: With his surrogate destroyed, Tom is forced to interact in the world without one. He learns that VSI originally produced the weapon, designed to load a virus that overloads a surrogate's systems, thus disabling it, under a government contract. Unexpectedly, the weapon also disabled the fail-safe protocols protecting operators. The project was promptly scrapped and all prototypes supposedly destroyed. Tom also learns that Andrew Stone, his FBI superior, supplied the weapon to Strickland and ordered Dr. Canter's assassination, upon VSI's request, for his criticism of surrogate use. Jared, using one of his father's many surrogates, was killed instead. Jennifer is murdered in her own home by an unknown man who hijacks her surrogate, and the Prophet orders the weapon delivered to her. During a military raid on the reservation, the Prophet is shot, revealing he was actually a surrogate, with Canter himself as the operator. Tom steals the weapon's codes from Stone, but "Jennifer" escapes with the codes.


title: Surrogates

text: Immediately travelling to Canter's home, Tom discovers that Canter has been controlling not only the Prophet, but also Jennifer and the surrogate he used to kill Jennifer as well. Using Jennifer's surrogate in FBI Headquarters, Canter uses the weapon to kill Stone and proceeds to upload the virus to all surrogates, which will destroy them and kill their operators. Canter reveals that he only wanted to empower the disabled to live normal lives, but after he was fired from VSI, they capitalized on surrogacy for profit. Convinced his plan is unstoppable, Canter disconnects from Jennifer's surrogate and swallows a cyanide pill. Tom takes control of Jennifer's surrogate and, with the assistance of the network's system administrator, Bobby Saunders, insulates the virus so the operators will survive, but a second step is required to save the surrogates. After a moment of consideration, Tom chooses to let the virus permanently disable surrogates worldwide. With all the surrogates disabled, people emerge from their homes, confused and afraid.


title: Surrogates

text: Returning home, Tom shares an emotional embrace with Maggie in her real form. The film ends with an aerial view of the collapsed surrogates along with overlapping news reports of downed surrogates all over the world and how people are now "on their own" again.


title: Surrogates

text: In March 2007, Disney acquired feature film rights to the 2005–2006 comic book series "The Surrogates" with the intent to distribute under Touchstone Pictures. The project was conceived by Max Handelman and Elizabeth Banks through Brownstone Productions, and they enlisted producer Todd Lieberman to move it forward. Under Disney, Jonathan Mostow was attached to direct the film based on an adapted screenplay by Michael Ferris and John Brancato. The following November, Bruce Willis was cast to star in the lead role. Filming was scheduled to begin in February 2008 in Lynn, Massachusetts. It was delayed, beginning on April 29, 2008 in Woburn. Filming then took place in the Massachusetts cities of Lynn, Worcester, Milford, Hopedale, Taunton, Lawrence and Wayland. Visual effects were handled by Sandbox FX, Brickyard VFX, Industrial Light and Magic and Moving Picture Company.


title: Surrogates

text: Surrogates: Original Motion Picture Soundtrack was orchestrated by composer Richard Marvin. "Surrogates" is the fifth film on which director Jonathan Mostow and composer Richard Marvin have collaborated. Marvin recorded his score with the 120-piece Hollywood Studio Symphony. Although it was not featured in the soundtrack, the song "I Will Not Bow," performed by Breaking Benjamin, was played during the film's ending credits and the song's music video features footage from the film. The soundtrack was released on November 23, 2009.


title: Surrogates

text: "Surrogates" hosted its world premiere at the El Capitan Theatre in Hollywood, California on September 24, 2009. It was released the next day in North American cinemas by Touchstone Pictures to lukewarm reviews from film critics.


title: Surrogates

text: The Motion Picture Association of America gave the film a PG-13 rating for "intense sequences of violence, disturbing images, language, sexuality and a drug-related scene."


title: Surrogates

text: The DVD and Blu-ray were released on January 26, 2010. The Blu-ray version features four deleted scenes, a commentary by director Jonathan Mostow, and 2 featurettes. The movie has sold 713,851 units, which gives it a total gross of $12,052,466 in DVD sales.


title: Surrogates

text: "Surrogates" played at 2,992 theaters. On its opening weekend, it grossed to $14,902,692, averaging $5,050 per theater, ranking #2 at the U.S. box office, behind "Cloudy with a Chance of Meatballs". For the second weekend of Oct 2–4, it saw a 45% decrease where it dropped down to 4th place at the box office only to gross $7,241,054. The third domestic weekend release saw a 36% decrease, which was 9% less than its last weekend. The film went on to gross $38,577,772 domestically and $83,867,000 internationally, giving it a worldwide gross of $122,444,772.


title: Surrogates

text: "Surrogates" was not pre-screened for critics. , the review aggregator Rotten Tomatoes reported an approval rating of 37%, based on 115 reviews, and an average rating of 5.33/10. The website's critical consensus reads, "Though it sports a slick look and feel, "Surrogates" fails to capitalize on a promising premise, relying instead on mindless action and a poor script". Metacritic gave the film an average score of 45 out of 100 based on 21 critic reviews, indicating "mixed or average reviews". Audiences polled by CinemaScore gave the film an average grade of "C" on an A+ to F scale.


title: Surrogates

text: IGN gave the film a 6.0/10, saying that "it provides a competently made, relatively predictable and slickly presented piece of genre entertainment, offering just the right amount of action beats and futuristic visuals to keep the viewer engaged without ever having an actual thought. It's good, escapist fun". Yahoo! Movies gave it a grade "C+" based on 10 reviews.


title: Surrogates

text: "Entertainment Weekly" Lisa Schwarzbaum concluded her positive review saying that "there's fun robot stuff, some good philosophical ideas, and a brief, nutty Willis–Ving Rhames reunion 15 years after "Pulp Fiction"". Roger Ebert of the "Chicago Sun-Times" gave the film 2½ stars out of 4. Ebert wrote that "while more ambitious than it has to be, the film descends into action scenes too quickly. … "Surrogates" is entertaining and ingenious, but it settles too soon for formula." He also says, "The concept, based on a graphic novel by Robert Venditti and Brett Weldele, would lead naturally to intriguing considerations." Some critics, however, were not too favorable to the film: Claudia Puig of "USA Today" called it "a poor substitute of sci-fi thriller saying that the tone of the movie is rarely satirical and that it's more concerned with political intrigue involving pockets of anti-surrogate protesters that enjoy bludgeoning the machines." Roger Moore of the "Orlando Sentinel" gave it a negative review, writing "watchable, but obvious… Surrogates never manages to be anything more than a poor substitute for the real thing."


title: Surrogates

text: Jordan Hoffman of UGO Entertainment gave "Surrogates" a B+ rating, saying it is intellectually stimulating enough to keep you intrigued while never forgetting its obligation as B movie fun. Todd McCarthy of "Variety" described it as an intense and eerily plausible science fiction thriller.


title: 22 (Taylor Swift song)

text: "22" is a song by American singer-songwriter Taylor Swift, taken from her fourth studio album, "Red" (2012). It was released as the album's fourth single on March 12, 2013, by Big Machine Records. Written and produced by Swift, Max Martin, and Shellback, "22" combines pop styles such as dance-pop and bubblegum with disco and 1990s rock. The track begins with an acoustic guitar riff and progresses into an upbeat refrain which incorporates pulsing synthesizers and syncopated bass drums. The lyrics celebrate being 22 years old while acknowledging the heartache that the narrator experienced in the past.


title: 22 (Taylor Swift song)

text: Upon "Red" release, critics complimented the production of "22" as catchy but some found the lyrics weak and the song repetitive. Retrospectively, some have considered it one of Swift's best pop songs. "22" peaked at number 20 on the US "Billboard" Hot 100 and was certified triple platinum by the Recording Industry Association of America (RIAA). It received platinum or higher certifications in Australia, Canada, and the United Kingdom, peaking in the top 10 on the singles chart in the lattermost country. The accompanying music video was shot in Malibu, California, depicting Swift having a house party with friends. Swift included the song in the set list of the Red Tour (2013–2014) and performed it live at the 2013 "Billboard" Music Awards.


title: 22 (Taylor Swift song)

text: Media outlets dub "22" a cultural phenomenon resulting in the prominence of 22nd birthdays. A re-recorded version of "22", titled "22 (Taylor's Version)", was released as part of Swift's second re-recorded album "Red (Taylor's Version)" on November 12, 2021, by Republic Records. "22 (Taylor's Version)" peaked within the top 40 on singles charts of Australia, Canada, and Singapore; it also peaked at number 52 on the US "Billboard" Hot 100.


title: 22 (Taylor Swift song)

text: Swift released her third studio album, the self-written "Speak Now", in October 2010. Produced by Swift and Nathan Chapman, "Speak Now" expands on the country-pop production style of its predecessor, "Fearless" (2008). On her fourth studio album, "Red" (2012), Swift wanted to experiment with other musical styles. To this end, she approached different producers beyond her career base in Nashville, Tennessee. She went to Los Angeles to meet with Swedish producer Max Martin, citing his songs for "how [they] can just land a chorus" as an inspiration.


title: 22 (Taylor Swift song)

text: Martin and Shellback, another Swedish producer, co-wrote and co-produced three songs with Swift on "Red"—"22", "We Are Never Ever Getting Back Together", and "I Knew You Were Trouble"—all of which feature a pop production and programmed keyboards. Michael Ilbert and Sam Holland recorded "22" at MXM Studios in Stockholm and Conway Recording Studios in Los Angeles, with engineers John Hanes, Eric Eylands, and Tim Roberts. Serban Ghenea mixed "22" at MixStar Studios in Virginia Beach. The instruments used on the track include acoustic guitar (Swift, Shellback), bass (Shellback), electric guitar (Shellback), and keyboards (Martin, Shellback).