States may not exercise certain powers reserved for the federal government: they may not enter into treaties, alliances or confederations, grant letters of marque or reprisal, coin money or issue bills of credit (such as currency). Furthermore, no state may make anything but gold and silver coin a tender in payment of debts, which expressly forbids any state government (but not the federal government) from "making a tender" (i.e., authorizing something that may be offered in payment) of any type or form of money to meet any financial obligation, unless that form of money is coins made of gold or silver (or a medium of exchange backed by and redeemable in gold or silver coins, as noted in "Farmers & Merchants Bank v. Federal Reserve Bank"). Much of this clause is devoted to preventing the States from using or creating any currency other than that created by Congress. In Federalist no. 44, Madison explains that "... it may be observed that the same reasons which shew the necessity of denying to the States the power of regulating coin, prove with equal force that they ought not to be at liberty to substitute a paper medium in the place of coin. Had every State a right to regulate the value of its coin, there might be as many different currencies as States; and thus the intercourse among them would be impeded." Moreover, the states may not pass bills of attainder, enact "ex post facto" laws, impair the obligation of contracts, or grant titles of nobility.
The Contract Clause was the subject of much contentious litigation in the 19th century. It was first interpreted by the Supreme Court in 1810, when "Fletcher v. Peck" was decided. The case involved the Yazoo land scandal, in which the Georgia legislature authorized the sale of land to speculators at low prices. The bribery involved in the passage of the authorizing legislation was so blatant that a Georgia mob attempted to lynch the corrupt members of the legislature. Following elections, the legislature passed a law that rescinded the contracts granted by the corrupt legislators. The validity of the annulment of the sale was questioned in the Supreme Court. In writing for a unanimous court, Chief Justice John Marshall asked, "What is a contract?" His answer was: "a compact between two or more parties." Marshall argued that the sale of land by the Georgia legislature, though fraught with corruption, was a valid "contract". He added that the state had no right to annul the purchase of the land, since doing so would impair the obligations of contract.
The definition of a contract propounded by Chief Justice Marshall was not as simple as it may seem. In 1819, the Court considered whether a corporate charter could be construed as a contract. The case of "Trustees of Dartmouth College v. Woodward" involved Dartmouth College, which had been established under a Royal Charter granted by King George III. The Charter created a board of twelve trustees for the governance of the College. In 1815, however, New Hampshire passed a law increasing the board's membership to twenty-one with the aim that public control could be exercised over the College. The Court, including Marshall, ruled that New Hampshire could not amend the charter, which was ruled to be a contract since it conferred "vested rights" on the trustees.
The Marshall Court determined another dispute in "Sturges v. Crowninshield". The case involved a debt that was contracted in early 1811. Later in that year, the state of New York passed a bankruptcy law, under which the debt was later discharged. The Supreme Court ruled that a retroactively applied state bankruptcy law impaired the obligation to pay the debt, and therefore violated the Constitution. In "Ogden v. Saunders" (1827), however, the court decided that state bankruptcy laws "could" apply to debts contracted after the passage of the law. State legislation on the issue of bankruptcy and debtor relief has not been much of an issue since the adoption of a comprehensive federal bankruptcy law in 1898.
Still more powers are prohibited of the states. States may not, without the consent of Congress, tax imports or exports except for the fulfillment of state inspection laws (which may be revised by Congress). The net revenue of the tax is paid not to the state, but to the federal Treasury.
Under the Compact Clause, states may not, without the consent of Congress, keep troops or armies during times of peace. They may not enter into alliances nor compacts with foreign states, nor engage in war unless invaded. States may, however, organize and arm a militia according to the discipline prescribed by Congress. (Article I, Section 8, enumerated powers of Congress.) The National Guard, whose members are also members of the militia of the United States as defined by , fulfill this function, as do persons serving in State Militias with federal oversight under .
The idea of allowing Congress to have say over agreements between states traces back to the numerous controversies that arose between various colonies. Eventually compromises would be created between the two colonies and these compromises would be submitted to the Crown for approval. After the American Revolutionary War, the Articles of Confederation allowed states to appeal to Congress to settle disputes between the states over boundaries or "any cause whatever". The Articles of Confederation also required Congressional approval for "any treaty or alliance" in which a state was one of the parties.
There have been a number of Supreme Court cases concerning what constitutes valid congressional consent to an interstate compact. In "Virginia v. Tennessee", , the Court found that some agreements among states stand even when lacking the explicit consent of Congress. (One example the court gave was a state moving some goods from a distant state to itself, it would not require Congressional approval to contract with another state to use its canals for transport.) According to the Court, the Compact Clause requires congressional consent only if the agreement among the states is "directed to the formation of any combination tending to the increase of political power in the States, which may encroach upon or interfere with the just supremacy of the United States". The congressional consent issue is at the center of the current debate over the constitutionality of the not yet effective National Popular Vote Interstate Compact entered into by several states plus the District of Columbia.
Victory Day
Victory Day (also shortened as "V-Day") is a common name of many different public holidays in various countries. In most cases it is to commemorate victories in important battles or wars in the countries' history. For example, in Russia, it is celebrated on May 9th for the defeat of Nazi Germany in what Russia calls "The Great Patriotic War" (World War II). For the United States and Britain, the victory in Europe (celebrated as Victory in Europe Day or V-E Day) was only part of the victory. It is celebrated on May 8th (May 7th in the United Kingdom). The war in the Pacific did not end for the US and Britain until the Japanese surrender on Sept. 2, 1945. This is celebrated as Victory over Japan Day or V-J Day. This part of the war is usually not studied by Russians. In France, their Victory Day also celebrated the end of World War II and is celebrated on May 8, 1945, when Charles de Gaulle announced the end of the war.
Collard greens
Collard greens (or collards) are loose leafed cultivars of "Brassica oleracea". Collard greens are part of the acephala group of the species, which includes kale and spring greens.
Collard greens are known for their large, dark colored and edible leaves. They are also known as a garden ornamental.
Collard greens are available year round. They are tastier and more nutritious in cold months, after the first frost.
Elizabeth Garrett