Category Archives: History

by Dennis Crouch

The US Solicitor General has provided her inputarguing that the Supreme Court should grant American Axles petition and decide whether the claimed method of manufacturing a driveshaft is patent eligible. American Axle & Mfg., Inc. v. Neapco Holdings LLC, Docket No. 20-891 (Supreme Court 2022). [USDOJ Brief]

A decade ago, the Supreme Court decidedMayo v. Prometheus, 566 U.S. 66 (2012). Mayo broadened the scope of excluded laws of nature and established a two-step test for judging eligibility. The court followed-up two years later with Alice Corp. v. CLS Bank International, 573 U.S. 208 (2014), extending Mayos holdings to abstract ideas and computer implemented inventions. In the wake of these decisions, the USPTO substantially changed its practices as did the U.S. Courts. Thousands of claims have been denied, cancelled, or invalidated, but those involved still experience substantial uncertainty about the proper application of Section 101. In American Axle, the Federal Circuit reluctantly took the law a further step by finding abstract a method of manufacturing and calibrating a mechanical structure. The USDOJ concludes that the claim at issue here is a paradigmatic examples of the arts or processes that may receive patent protection if other statutory criteria are satisfied.

American Axles US Patent No. 7,774,911 claims a method of manufacturing an automobile driveshaft that operates with reduced vibration & noise. The claims are particular directed to the use of a shaft liner that has been tuned to reduces multiple vibration modes (bending and shell mode vibrations). Prior technology included a shaft liner, but not one tuned to multiple vibration modes. So, the novel feature here is that the liner has been tuned to both resistively absorb shell mode vibrations and reactively absorb bending mode vibrations.

22. tuning a mass and a stiffness of at least one liner wherein the liner is a tuned resistive absorber for attenuating shell mode vibrations and wherein the at least one liner is a tuned reactive absorber for attenuating bending mode vibrations.

The crux of the problem found by the Federal Circuit is that these novel features are claimed functionallyat a fairly high level of abstraction. Rather than claiming the actual steps of tuning, the patentee has endeavored to claim all methods that achieve the claimed result. In some ways, this is like the claimed process in Diehr, but instead of using the Arrhenius equation the inventors here just use an unstated algorithm.

Broad claims like these have been typically dealt-with under the disclosure requirementswritten description and enablement; as well as obviousness. Under those doctrines, broad functional claims are permitted so long as the disclosure is sufficient and the prior art allows. By shifting to eligibility the defense was able cut-off the broad claims straight away. And importantly from a procedure perspective, was able to achieve this without worrying about the strictures of evidence or fact finding because eligibility is a question of law that rarely involves any underlying factual findings.

Substantial Uncertainty: The DOJ brief focuses on uncertainty created by Mayo/Alice framework, both at Step 1 and Step 2.

Clarification of both steps is especially important, both because a courts step-two analysis often finally resolves the determination as to patenteligibility, and because the nature of the initial step-one screen logically depends in part on the inquiry that courts will apply at step two.

DOJ Brief. The original petitioner brief focused on Alice Step 1 asking what is the appropriate standard for determining whether a patent claim is directed to a patent-ineligible concept. The DOJ suggested that the court focus on both steps and ask more generally is it patent eligible?

Preemption: An overarching theme in patent eligibility jurisprudence has been the potential of handing-over exclusive rights to fundamental aspects of human life and building blocks human ingenuity. Avoiding improper preemption is the key goal. But, the Alice/Mayo test does not use preemption in its decision process, and the Federal Circuit has found evidence of no preemption irrelevant to eligibility. Rather, as the DOJ implies, preemption considerations should be fundamental to the eligibility analysis.

Levels of Abstraction: The role of patent attorneys has historically been to help inventors abstract-out their inventions to ensure that the claims cover sufficiently valuable scope. What we know is that some abstraction is OK, too much is not. The DOJ suggests that it would be helpful to have a bit more guidance.

Historic Exceptions: The court wrote in Bilski that these exceptions are historic and based upon longstanding precedent. The suggestion is that they should be guided by the old precedent and not expanded further without congressional input.

Despite my earlier focus on results-based claiming, the DOJ Brief explains that the claims here go far enough in reciting:

a specific sequence of steps taking a hollow shaft; tuning the mass and stiffness of a liner, which the district court construed to mean controlling the liners mass and stiffness to match the relevant frequency or frequencies of vibration of the shaft; and inserting the liner into the shaft, whereupon the liner acts as an absorber of two kinds of vibrations.

DOJ Brief. These sequence of steps make the case look much more like Diamond v. Diehr than OReilly v. Morse.

Regarding Alice Step 2, the DOJ argues that conventional claim elements should not be disregarded. Rather, the focus should continue to be on the claimed invention as a whole.

The petition asks a second question whether eligibility is a question of law. The DOJ suggests that this is a secondary question that can only be addressed once the general doctrine is established. Answering the second question presented thus would be difficult while uncertainty about the substance of the Section 101 inquiry persists.

Read more from the original source:

Keys to Eligibility: Preemption, History, and Levels of Abstraction - Patently-O

Cabin has significant ties to African American history in western Maryland

Updated: 5:12 PM EDT May 24, 2022

It has been two years since a tiny log cabin was discovered in the once-famous Jonathan Street district in downtown Hagerstown. It turns out the cabin -- slated for demolition -- had major ties to the history of African Americans in western Maryland.Now it's been reconstructed -- and will soon be rented out -- as part of a major move to bring homeowners and businesses back to that district. Back in September 2020, 11 News was able to tag along as archaeologists from the Maryland Department of Transportation and Preservation Maryland dug around a small cabin located on Jonathan Street, dating back to the 1830s, discovered when a car accidentally crashed into it."You're seeing a small spark in a community that's growing much larger," said Reggie Turner, Washington County's commissioner of African American History and Culture.Now fast forward two years, turner took 11 News for a tour inside the renovated cabin, with an added 200 square feet and modern amenities.The cabin is located in what was one of the most well-known African American communities on the east coast.In the late 1800s and early 1900s, it was bustling with Black-owned businesses, many of which were listed in the Green Book.Now the tiny little cabin is generating a lot of support for the neighborhood in the form of donations and grants."It's a catalyst for change. We're seeing it already in regard to investment. We've been able to garner for the community close to about $2 million at this point and substantially more interest," Turner said.The cabin has also piqued interest at the Washington County Museum of Fine Arts.An exhibit highlighting the history of Jonathan Street shows what the community looked like when it was thriving, as well as some of the most treasured artifacts discovered in the 2020 dig."Prior to the discovery of the cabin there was another old structure at Jonathan Street that the community was not able to save so preserving this cabin becomes a symbol for valuing The history of the neighborhood," Washington County Museum of Fine Arts Executive Director Sarah Hall said.The cabin will be put on the market soon, with a new owner moving in by fall.The hope is to encourage more homeowners in the neighborhood and at the same time, bring in businesses and the arts."We're excited about what we can do to move this work throughout this entire historic Black community," Turner said.For more information on the Jonathan Street exhibit, which runs through September, click here.

It has been two years since a tiny log cabin was discovered in the once-famous Jonathan Street district in downtown Hagerstown. It turns out the cabin -- slated for demolition -- had major ties to the history of African Americans in western Maryland.

Now it's been reconstructed -- and will soon be rented out -- as part of a major move to bring homeowners and businesses back to that district.

Back in September 2020, 11 News was able to tag along as archaeologists from the Maryland Department of Transportation and Preservation Maryland dug around a small cabin located on Jonathan Street, dating back to the 1830s, discovered when a car accidentally crashed into it.

"You're seeing a small spark in a community that's growing much larger," said Reggie Turner, Washington County's commissioner of African American History and Culture.

Now fast forward two years, turner took 11 News for a tour inside the renovated cabin, with an added 200 square feet and modern amenities.

The cabin is located in what was one of the most well-known African American communities on the east coast.

In the late 1800s and early 1900s, it was bustling with Black-owned businesses, many of which were listed in the Green Book.

Now the tiny little cabin is generating a lot of support for the neighborhood in the form of donations and grants.

"It's a catalyst for change. We're seeing it already in regard to investment. We've been able to garner for the community close to about $2 million at this point and substantially more interest," Turner said.

The cabin has also piqued interest at the Washington County Museum of Fine Arts.

An exhibit highlighting the history of Jonathan Street shows what the community looked like when it was thriving, as well as some of the most treasured artifacts discovered in the 2020 dig.

"Prior to the discovery of the cabin there was another old structure at Jonathan Street that the community was not able to save so preserving this cabin becomes a symbol for valuing The history of the neighborhood," Washington County Museum of Fine Arts Executive Director Sarah Hall said.

The cabin will be put on the market soon, with a new owner moving in by fall.

The hope is to encourage more homeowners in the neighborhood and at the same time, bring in businesses and the arts.

"We're excited about what we can do to move this work throughout this entire historic Black community," Turner said.

For more information on the Jonathan Street exhibit, which runs through September, click here.

View post:

Cabin has significant ties to African American history in western Maryland - WBAL TV Baltimore

Golden State Warriors superstar Steph Curry has done it all in his NBA career. He has the most 3-pointers made in the history of the game, he has two NBA MVP awards, he has made countless All-Star games and All-NBA appearances, and he has three championships.

A resume like that puts any player in the conversation for being at the top in NBA history.

ESPNs Kendrick Perkins is ready to crown Curry the best point guard of all time if he can deliver a fourth title to The Bay during this current playoff run while also winning Finals MVP. Yes, that means putting him over the great Magic Johnson in the history of the game.

Perkins on ESPNs Get Up:

When it comes down to Steph Curry, if he goes on to win another championship along with the Finals MVP, one its going to put him in the top 10 conversation of greatest player of all time. Two, its going to move him as the number one point going to ever play the game and think about this. I want you to think about this. Steph Curry, Michael Jordan, Kareem Abdul-Jabbar, and Wild Chamberlain are the only players in NBA history to win multiple championships, multiple scoring titles, and multiple MVPs. Steph Curry would imprint and be now on NBA Mount Rushmore. When you think about a generational talent that has changed the game, forever, at the point guard position. He made shots that will put you on the bench cool again and think about this: his three championships. Who have they won against? LeBron James and Steph Curry has been a disruptor, breaking up happy homes. You think about the 3-1 lead the Oklahoma City Thunder team blew against them and all of a sudden he broke up Kevin Durant and Russell Westbrook and KD went and joined him to have to win a championship. So look with Steph Curry, the green eyed assassin. If he goes on to win a fourth NBA title with a Finals MVP, forget the top 10 list, forget the greatest point guard of all time, hes going to be on the NBA Mount Rushmore. Period.

Its hard to disagree with Perkins here. If Curry and the Warriors were to win another title in 2022 and he were to win Finals MVP, what more would he have to do? At this point, this has all been an example of greatness for the Golden State legend.

Read more here:

Kendrick Perkins ready to put Steph Curry over Magic Johnson in history - Warriors Wire

May is Asian American Pacific Islander (AAPI) Heritage Month, which celebrates the histories of the ... [+] fastest-growing racial group in America.

May is Asian American Pacific Islander (AAPI) Heritage Month, which celebrates the histories of the fastest-growing racial group in America. The AAPI population has increased more than 35% between 2010 and 2020 and is expected to quadruple by 2060, according to the Census Bureau. While celebrating the history of this diverse group, its also important to raise awareness about the rise in hate crimes theyve experienced, and to work to break deep-rooted stereotypes and biases by exploring the history theyre rooted in. Below are some of the biases and myths the AAPI community faces, and the history behind them.

The Stereotype: The Forever Foreigner

The AAPI community is not a monolith, but encompasses more than 50 ethnic groups, such as China, Vietnam, Korea, India, Cambodia, Japan, the Philippines, Melanesia, Micronesia, Polynesia, and many others.

Within the Asian American Pacific Islander community, we have very different experiences, but amongst different communities of color, we have different experiences, says Jean Lee, president and CEO of MCCA, an organization focused on hiring, retention, and promotion of diverse legal professionals. The shootings and the events that have happened during the pandemic show that when we do not address hate and racism together as a communitywhite, Black, Asian, Hispanic, Latinx and the likeit will continue to have a negative impact in our communities and on employees within the workplace.

Ingrained biases against the AAPI community in general may be in part rooted in history, with policies such as the Chinese Exclusion Act of 1882, blocking Chinese from testifying in court, banning Chinese from entering the country, and essentially framing them as forever foreigners. The Japanese internment camps during the 1940s contributed to the ongoing othering of the AAPI community.

To combat anti-AAPI discrimination and hate crimes, there is a push for states to require lessons on AAPI history to further the message that AAPI history is American history. Currently 18 states have no AAPI content in their K-12 history curriculum standards.

Thomas Orlina, a Filipino-American recording artist and content creator is looking to increase acceptance for the AAPI community by creating content with diverse representation. It was challenging at first to find my footing in the entertainment business, because growing up a lot of talented artists didnt look like me, Orlina says. I thought I had no chance in this industry. Now we live in a world where the Vice President of the United States identifies as Asian-American, and there are many other entertainers, such as Olivia Rodrigo, who embrace their AAPI heritage. I find that has helped bring the representation of the AAPI community to a new dimension and elevate our community.

Recording artist Thomas Orlina is releasing a music video project called Journey in honor of AAPI ... [+] month.

Representation matters because it can help break down biases and stereotypes, offer role models for marginalized groups, and expand audiences awareness of the diversity that is embedded within our country. Yet a recent Neilson study found that two-thirds of Asian Americans feel there is not enough representation of their identity group on TV, and more than half of Asian American respondents feel the portrayal is inaccurate.

Orlina is trying to change that: He is releasing a music video project called Journey in honor of AAPI month after partnering with AAPI talent, including video editor and graphic artist Danica Orlina Quizon, choreographer Tiara Summer Richards and director Karla Escobar, in an effort to spotlight more diverse talent. The message he wants to spread is, Asian Americans and people of all backgrounds deserve to be represented in this day and age, says Orlina. Ultimately, I would like everyone to be seen as a human being, no matter what race, sexual orientation, gender, or religion you practice.

The Stereotype: The Model Minority

The myth of the model minority perpetuates the narrative that all Asian-Americans excel in math, are non-confrontational, and are successful. This stereotype may have contributed to divisions among Americas marginalized groups and may be a contributing factor for AAPI people who experience discrimination being less likely to speak out. The stereotype also goes against the fact that all AAPI people do not benefit from a high socioeconomic status; the wealth disparity between the richest AAPI members and the poorest is larger than for any other racial group in America.

There is a lack of awareness of the history [behind the model minority myth], not only from the broader society, but also within the Asian American community, says Lee. There was a strategic effort by the federal government in trying to address the race issues during the Civil Rights Movement in the 1960s. The label came about in part to divide [marginalized groups] and to put the U.S. in a more favorable light in addressing some of the racial tensions at that time.

The myth of the model minority was amplified in a New York Times Magazine article in 1966 by sociologist William Petersen called Success Story, Japanese-American Style.

The myth that all Asian Americans are somehow wealthy, smart and good at math or science is so harmful to our communities, because then the people that don't fit that myth are ignored and neglected and made invisible, says Cindy Trinh, a Vietnamese-American photojournalist and creator of Activist NYC.

Trinh, inspired by the 2015 New York Times article that exposed the horrific conditions of nail salon workersa majority of them AAPI womendocumented working class Asian Americans such as street vendors, nail salon workers, store clerks, cooks, and more in the photo essay The Model Minority Reality. It aims to debunk the stereotype that Asians are the model minority and also show their tenacity, hard work, and struggle. For me, it's always been about sharing the stories of our most marginalized and ignored in our society, Trinh says. What I aim to do as a photographer, an artist, and a journalist is to really showcase those stories.

The Stereotype: The Bamboo Ceiling

The bamboo ceiling is a term used to refer to the discrimination AAPI people experience in advancing in the workplace. One recent study revealed that 65% of AAPI managers view the bamboo ceiling as a moderate to serious problem in their careers. For example, Asian Americans made up about 13% of the professional workforce, but just 6% of executive and senior officers and managers, according to Ascend.

The notion of the bamboo ceiling has been a barrier for AAPI employees to advance into leadership positions because the stereotype is that they are good at executing, but not seen as leadership in the current cultural model where the majority of leaders remain white and male.

[Members of the AAPI community] are often seen as worker bees who are really great at executing a lot of work, but never seen as leaders, says Lee. This goes back to the history of the model minority myth and birthright citizenship, because of the fear of being labeled a certain way or being excluded or not being able to remain in this country for the longest time. Culturally, its perpetuated, because we are taught to be much more humble, to be quiet, and to build group consensus. It's very hard to translate that when the American standard of leadership, and especially the white male standard, is about speaking up and being assertive.

Organizations have to expand the idea of what a leader looks like if they truly want to have diverse representation in top positions, which has a proven business case. Were constantly having to fight unconscious biases and racist perceptions within a white male dominated standard in corporate America, says Lee. The system does not allow us to succeed when we try to break that mold, because of the perception of how we should behave. Yet creating a workforce that is sustainable requires you to rethink the status quo.

Lee says the way for organizations to make long-term progress to change the system is to focus on data, be transparent, and create accountability. What are the things you do to provide opportunities for people to remain within your organization, and then ultimately be promoted? The only way to understand what works is by collecting the data, says Lee. Also, if youre having an issue finding diverse talent, ask why. It might be because you're not looking in the right places, but at the same time, maybe your standards should be reevaluated. You might need to rethink how youre evaluating peoplesuch as women and people of colorin those spaces to create opportunities. Use your position of authority, your power, your voicewhether you're a man, a woman, non-binary, Asian, Black, Hispanic, whatever your ethnicity or your statusto really advocate for sustainable change.

Follow this link:

The History Behind Common AAPI Stereotypes - Forbes

Corn and soybean prices for 2022 fall delivery are at high levels. During the first two weeks in May, fall delivery bids in central Illinois averaged $7.39 per bushel for corn and $14.52 for soybeans. Significant changes in prices going into fall are possible. History suggests that there is a 5% chance that cash prices for corn in October will be below $4.60 per bushel. There is a 5% chance of cash prices below $10.56 per bushel for soybeans. Conversely, there also is a chance of higher prices. There is a 5% chance that October cash prices exceed $10.50 per bushel for corn and $18.49 for soybeans.

Our objective is to present possible fall prices for corn and soybeans. To do this, we evaluated changes in both futures and cash prices from May to October. The analysis provides a perspective on both futures and cash markets. While futures and cash prices are highly correlated, cash prices tend to move down more in years of falling prices. Analyses are first presented for corn in the following section and then for soybeans in the second.

Table 1 shows historical prices from 2001 to 2021. The panel labeled May gives average prices during the month of May and includes three columns. The Dec CME column shows the average settlement prices of the December Chicago Mercantile Exchange (CME) contract. From 2001 to 2021, futures prices averaged $4.00 per bushel. For the first two weeks of May in 2022, the December contract has averaged $7.39, well above the historical averages. The $7.39 average was the highest of all prices since 2001. In May, the fall delivery price for central Illinois averaged $3.74 per bushel from 2001 to 2021 as shown in the Fall Delivery Bid column. The Basis column shows the difference between the futures and fall delivery price averaged -$.26 per bushel. There is variably in the basis, ranging from -$.50 in 2008 to -$.13 in 2012. In 2022, the basis is -$.29 per bushel.

The panel labeled October give an average of daily prices during October and includes three columns. For October, the December contract averaged $3.82 per bushel from 2001 to 2021 as shown in the Dec CME column. The Cash bid column gives the delivery price for grain, while the Basis column gives the difference between the CME and cash bid. From 2001 to 2021, the cash bid average was $3.64 per bushel, $.19 below the average December futures contract. Note that the average May basis of -$.26 per bushel is more negative than the October basis of -$.19 per bushel. A more negative basis in May likely is due to a risk premium built into fall delivery bids.

The final panel, Change, includes two columns showing changes in both futures and cash prices. Over time, the change in the December contract from May to October averaged -4%. The change in May to October cash prices average -2%.

Historical price changes shown in the final two columns of Table 1 are used to calculate the probabilities of low and high prices. These probabilities are calculated by ordering the changes from low to high and then calculating price change percentiles. Results are shown in Table 2. For a .05 probability, the futures price change is -31%. From 2001 to 2021, 5% (or 2 out of 20) of the changes in future prices were at or below -31% (i.e., -34% in 2008 and -31% in 2004). In 5% of years, we would expect price to decrease by at least -31%. From the current $7.39 level, the resulting October futures price would be $5.14 per bushel ($7.39 x (1 .31).

For cash prices, the probabilities in Table 2 suggest:

There also is considerable upside potential. For example, in Table 2, the price that corresponds to a 0.75 probability is $7.59 for cash corn. In other words, there is a 25% chance of prices being above $7.59 in October.

The .95 probability in Table 2 suggest a 5% chance of cash prices exceeding $10.50 per bushel in October.

Historic soybean prices are shown in Table 3. The November CME futures contract is used for soybeans. Highlights are:

The probability of soybean price changes are shown in Table 4. For cash prices:

Higher prices also are possible. Historic price changes suggest that cash prices could exceed $18.49 with a 5% probability.

History suggests that large changes in prices are possible from May to October. We quantified possible price chances using history as a guide.

Originally posted here:

Potential 2022 Fall Prices for Corn and Soybeans Based on History farmdoc daily - University of Illinois Urbana-Champaign

The leaked draft of a Supreme Court opinion that could reverse the constitutional right to abortion has sent shockwaves across the nation. It's also brought renewed attention to Roe v. Wade, the landmark 1973 case that established that constitutional right. Northeastern University law professor and GBH legal analyst Daniel Medwed joined GBH's Morning Edition to take a closer look at the history of Roe v. Wade and abortion law. This transcript has been lightly edited for clarity.

Craig LeMoult: Let's start by setting the stage here, if we could. What was the legal status of abortion before 1973?

Daniel Medwed: Let's take a little foray into legal history here. So in the mid- to late-19th century, abortion was generally legal in the United States, at least during the first trimester, before the quickening of the fetus, before a woman could feel the fetus moving. Things began to change in the 1850s when the American Medical Association came out against abortion. And then later, the Catholic Church announced that it was banning abortion as well. Congress then passed a law called the Comstock Act that prohibited the distribution of contraceptives and abortion-inducing drugs through the mail. So by the 1880s or so, abortion was outlawed nationwide.

Then things shifted again, of course, in the 1960s with the rise of the women's rights movement and targeted litigation efforts designed to improve access to contraceptives. So by 1970, Hawaii had become the first state to legalize abortion, followed quickly by a couple other states: New York, Alaska and Washington. So by 1973, I think it's fair to say that the nation was quite divided on the topic of abortion.

LeMoult: So how did the Roe case come about? Was it a deliberate effort by lawyers to create a right to abortion when they went looking for plaintiffs, or was it something more organic, driven by women who wanted to get an abortion and couldn't?

Medwed: It was largely a conscious, strategic effort spearheaded by two young women lawyers in Texas: Linda Coffee and Sarah Weddington. Coffee, in particular, had spent some time in law school researching ways to challenge abortion restrictions, and she'd reached two key conclusions.

First, she thought that the best path forward substantively was to cite the nascent right to privacy that was a right that the Supreme Court had acknowledged in the 1965 case called Griswold v. Connecticut. Now, there's nothing in the Constitution that explicitly provides for a right to privacy, but the Supreme Court interpreted the document to infer or imply such a right. And this right to privacy had been cited in a really important 1969 California state case that overturned the arrest of a doctor who had performed a number of abortions.

The second conclusion that Coffee reached was more procedural. She thought that the best way to go forward was to file a class action on behalf of all Texas women who may want an abortion in the future. And if you're pursuing a class action, you have to find what's called a named plaintiff, someone who will represent the interests of the class. So essentially, Coffee bided her time waiting for a good plaintiff to emerge.

LeMoult: Tell us a little bit more about the plaintiff who later became known as Jane Roe.

Medwed: In late 1969, a lawyer friend of Coffee's introduced her to a pregnant Texan named Norma McCorvey. She'd already had two children and put them up for adoption. And she was pregnant for a third time and this time actually wanted to terminate the pregnancy. So Weddington and Coffee famously met with McCorvey, I think it was at a Dallas-area pizzeria in which they offered to represent her without charge in this lawsuit. McCorvey agreed, and they filed a lawsuit in federal trial court in the Dallas area. They named Henry Wade, who is the district attorney for Dallas County, as the defendant. And they won at the trial level, but Wade was undeterred. He vowed to continue to criminalize abortion in his county. That led to a number of twists and turns as the case meandered up to the U.S. Supreme Court.

LeMoult: So the case goes up to the Supreme Court, and as we all know it, resulted in an opinion that recognized a federal constitutional right to abortion. What were the parameters of that decision?

Medwed: Weddington actually argued the case. Coffee believed that she was the better of the two as an oral advocate, and she won in a '72 opinion authored by Justice Harry Blackmun. As you noted, Craig, the Supreme Court recognized a federal constitutional right to abortion, but it wasn't unqualified.

Here's what it looked like at the time: The court divided pregnancy into three trimesters, and during the first trimester, a woman had the unfettered, autonomous right to decide whether to terminate the pregnancy. But in the second trimester, the court reasoned that the government could regulate abortion procedures so long as it didn't ban abortions entirely. And then in the third trimester, when a fetus might be viable, the court said that states could ban abortion so long as there was a carve-out if the woman's health was in grave danger. So that's effectively how things looked in the immediate aftermath of Roe.

LeMoult: So what happened in the decades between then and now? Did the right to abortion change over time?

Medwed: Well, on the one hand, the Supreme Court kept the core principle of Roe v. Wade intact, that there is a right to abortion at the earlier stages of a pregnancy. But on the other hand, the court whittled away at that core, hollowed it out a little bit because many states started to pass restrictions on access to abortion that limited the time, place and manner of how you could actually get an abortion.

And in 1992, the Supreme Court heard a really important case from Pennsylvania called Casey, which upheld the concept of Roe but acknowledged that government restrictions on abortion procedure are OK as long as they do not pose an "undue burden" on the woman's right to choose. And so for the next three decades, really leading up today, much of the litigation in this area concerned what is or what is not an undue burden on the right to choose.

LeMoult: Thank you so much, Daniel, for that history lesson. There's a lot that goes into this, a lot that's led up to where we are now. And I think still a lot of questions about what's what's coming next.

Medwed: I think you're right. We'll have to see.

Excerpt from:

A legal history of abortion in the US, before and after Roe v. Wade - GBH News

There Are Still Lessons to be Learned from History

Book Review of Edwin Price Ramsey and Stephen J. 1990. Lieutenant Ramsey's War: From Horse Soldier to Guerrilla Commander. Lincoln: Potomac Books, Inc, An imprint of the University of Nebraska Press.

By Pete Reider

Lt. Ramseys War is an autobiographic tale of determination, perseverance, and survival in the Philippines during the Second World War. This is the story of Lt. Edwin Ramsey, told in his own words, of how he transformed from a nave 1st LT in the 26th Cavalry (Cav.) to a leader of 40,000 guerillas and a vital part of U.S. plans to return to the Philippines. He is credited with leading the last U.S. Cavalry charge in American history, surviving the Japanese conquest of the Philippines, establishing himself as a guerilla leader and briefing General MacArthur. Edwin Ramsey recollects his experiences both highs and lows, discusses his motivations, and his work with indigenous forces. It is a harrowing story of one mans fight in a larger conflict, but also offers insights into resistance movements, occupation, and collaboration with indigenous forces.

Lt. Ramsey was at his first duty station at the 26th Cav., Philippines, for only a few months when the Japanese invaded. The U.S. and Pilipino forces situation became ever increasingly dire as the Japanese experienced success after success. Lt. Ramsey exemplified this desperation when he led the last U.S. Cavalry charge into advancing Japanese armor (p. 66). Bravado alone could not repel the Japanese for long and the few survivors of the 26th Cav. were forced to escape and evade into the jungle. From his lowest point in the jungle: sick, starved, and contemplating suicide, Lt. Ramsey decided that he would make the Japanese pay: I had not done this to myself, a voice in my mind was saying, it had been done to me, done by the enemy, the Japanese. They were responsible, and they ought to be made to pay (p. 104). He integrated with a small network of officers to eventually rise to commanding a 40,000-person strong force. This force developed intelligence networks throughout the Philippines which enabled Gen. MacArthurs eventual return.

This story does an excellent job of displaying the ground level realities of guerilla warfare in a denied environment as well as the toll that they take on an individual. Ramsey displays his vulnerability throughout the book from his self-doubt, constant sickness to the point of needing an appendectomy without anesthesia (p. 269), and his need to be carried from meeting to meeting because he physically could not bear movement. In this sense, his dedication to his mission over all else is inspiring. More broadly his success in building and maintaining his forces is also an excellent example of how a guerilla campaign supports conventional operations.

Ramsey understood that the guerilla movement alone would not defeat the Japanese in the Philippines. This in mind, Ramsey focused on civil military relations of different factions and getting them to march in the same direction. He recognized the need for continued training, amassing supplies, and arms, and foremost keeping the force alive and growing under the nose of the Japanese Kenpeitai(Japanese secret police). This operational patience was necessary and enabled him to mass forces in large attacks coordinated with the U.S. return to the Islands. He also needed to contest with the communist guerilla forces known as the Huks. The friction between the Hukbalahap and Ramseys forces eventually led to Ramsey declaring war on the rival guerilla movement. Ramsey displayed the patience of building a force for approximately three years to have them fight for two months.

The book is told from the perspective of Lt. Ramsey; external factors such as how the overall war in the Pacific impacted operations within the Philippines can be sparse. That said, this is not a comprehensive study on the U.S. operations in the Philippines, or the campaign to retake the islands. Nor does Ramsey claim such a mandate. This is a perspective of one man and his struggles to thrive and survive in a hellish combat environment for almost three years. For a wholistic view of the campaign, one would need to look to at testimony or examples from General MacArthurs staff of how Lt. Ramseys guerilla operations impacted the overall invasion

This book has value to individuals working in special operations or those who study special operations. There are many examples within the book that display the importance of continual operational vigilance and how to balance this with the need to show trust in relatively unknown indigenous entities. It is also a great study in the value of the individual and the importance that one individual may provide to an organization and operation. Lt. Ramsey was the interlocking piece in a complex resistance movement which eventually consisted of 40,000 members. His adaptability, inter motivation, and perseverance provide an invaluable inspiration for military leaders as well as unique insight to what drives some men to thrive and conquer the direst of situations. His innovation and development of guerilla warfare informed guidelines in developing special warfare training in the United States. In recognition of his efforts, he was awarded the Special Forces tab and Green Beret in 2001.

See the original post here:

There Are Still Lessons to be Learned from History (Book Review) - smallwarsjournal

There are often two types of teams that first-year head coaches take over. There are the complete tear-downs, like the Chicago Bears and every coach the Jacksonville Jaguars and Houston Texans hire. Then there are the teams that view the head coach as one of a limited number of missing pieces on the roster holding them back from contention. Thats the Denver Broncos and Miami Dolphins this year. Thats also the Minnesota Vikings.

While an argument couldve been made for a complete roster overhaul, ownership and the new regime clearly believe they have the necessary pieces to win immediately. The return of Kirk Cousins and the restructuring of Adam Thielen and Harrison Smiths contract show that. The free-agent signings show that. And to a lesser extent, the draft shows that.

Now in May, with offseason programs beginning and the Vikings having just over $7 million in effective cap space, the roster we see today will largely look exactly the same come September.

How much success have first-year head coaches in similar spots had? Lets try to find the closest comparisons to the Vikings to see if we can get a glimpse of what 2022 may yield.

Overall record since 2008 of first-year head coaches (including repeat and rookie coaches): 634-822-3 (.435)

Overall record since 2008 of rookie first-year head coaches: 460-598-2 (.435)

There really has been no difference in the success of a veteran head coach or a rookie head coach in their first season. It should be noted that teams overwhelmingly hire rookie head coaches. Since 2008, 72 of the 99 head coaches that have been hired have been rookie head coaches.

If you look at the 91 coaches that have coached one season (basically removing all the 2022 head coaching hires) only 25 made the playoffs in their first season (27.5%). However, unlike overall record, rookie head coaches have made the playoffs much more frequently 18 of the 25 head coaches to make the playoffs in their first year were rookie head coaches (72%).

Thats normally where the success has stopped. Only seven of those rookie head coaches made it past the wild card round, five made it past the divisional round and just one has made it to the Super Bowl (Jim Caldwell).

In short, its difficult. There is a reason teams fire their head coach, and while its often under the guise of being one piece away, thats frequently far from the truth. However, lets look at some of the teams with rookie head coaches that did make the playoffs and see how the Vikings compare.

2021:Philadelphia Eagles - Nick Sirianni - Lost in the Wild Card round

2020:Cleveland Browns - Kevin Stefanski - Lost in the Divisional round

2019:Green Bay Packers - Matt LaFleur - Lost in the NFC Championship game

2018:Indianapolis Colts - Frank Reich - Lost in the Divisional round;Chicago Bears - Matt Nagy - Lost in the Wild Card round

2017:Buffalo Bills - Sean McDermott - Lost in the Wild Card round; Los Angeles Rams - Sean McVay - Lost in the Wild Card round

2016:New York Giants - Ben McAdoo - Lost in the Wild Card round; Miami Dolphins - Adam Gase - Lost in the Wild Card round

2015:None

2014:None

On average, the NFL sees about one of these rookie head coaches take their teams to the playoffs. And for every one of these success stories, there are five or six coaches who failed to make the playoffs. I wont list those out for every year, but in the last three years, this is the group: Brian Flores, Zac Taylor, Vic Fangio, Freddie Kitchens, Kliff Kingsbury, Matt Rhule, Joe Judge, Arthur Smith, Dan Campbell, Brandon Staley, David Culley, Urban Meyer, Robert Salah.

But looking at the rookie head coaches that did make the list, there are two pretty clear factions: Teams with quarterbacks on rookie contracts and teams with a star quarterback.

Scroll to Continue

The 2021 Eagles had inexpensive Jalen Hurts. The 2020 Browns had a cheap Baker Mayfield. The 2018 Bears had Mitch Trubisky in his second season. The 2017 Rams had Jared Goff in his second season. The 2016 Dolphins had Ryan Tannehill in the last year of his rookie deal. None of those quarterbacks have proved to be winning quarterbacks long-term, but their coaches (all offensive-minded) were able to get the most out of them while having enough cap space to supplement the other deficiencies on the roster.

Then there are the 2019 Packers and the 2018 Colts. Those teams were quarterbacked by Aaron Rodgers and Andrew Luck. And I dont think its a coincidence that those are two of the three teams since 2014 to make it out of the first round of the playoffs. These teams proved that a coaching move was actually one of the few missing pieces to their success.

Then, there are the outliers. The 2017 Bills paid Tyrod Taylor $15 million that season and snuck into the playoffs at 9-7. The 2016 Giants went 11-5 despite Eli Manning ranking 24th in PFF passing grade.

The Giants' appearance makes much more sense when you realize they were second in points allowed per game, 10th in yards allowed, and the best red-zone defense in the NFL.

The Bills' appearance is harder to explain, they were a below-average offense and defense in points scored and allowed. In PFF grade they were a bottom-half offense and a bottom-10 defense. But somehow they made the playoffs. That might just show the prowess of Sean McDermott.

The interesting thing about all of these teams is that there is not a clean comparison for the Vikings. They do not have a quarterback on a rookie contract nor a Rodgers or Luck-level star quarterback. And they arent expected to have a top-five defense. Those have been the key cogs for all these successful teams.

The closest comparison is the 2020 Cleveland Browns. The Browns hired a young offensive-minded head coach in Kevin Stefanski, hoping he could help take Baker Mayfield to the next level. The team had underachieved the previous season with a coach (Freddie Kitchens) that clearly didnt connect well with the team. Despite ranking 14th in points scored and 21st in points allowed, they managed to finish the season 11-5 and third in the AFC North. Heading into the season their over/under win total was 8.5 and they were +5000 to win the Super Bowl.

For those looking at this Vikings season through an optimistic lens, much of what Kevin Stefanski did is what they hope Kevin OConnell will do. An 11-5 season is most fans and analysts best-case scenario.

OConnell was hired to find a new level to Kirk Cousins that so many other coaches have tried, and failed, to coax out of him. Mike Zimmer is a far better coach than Freddie Kitchens was, but they undoubtedly struggled in the weeks leading up to their firing. And if you want to get weird, the Vikings' current over/under win total is 8.5 and their odds to win the Super Bowl are also +5000. Exactly the same as the Browns. The Browns also faced an easier-than-average schedule, similar to what the Vikings are expected to face.

Now, there are a few unsuccessful first-year head coaches that entered into similar situations as Kevin OConnell.

The 2018 Lions (6-10), Matt Patricia - This would be a worst-case scenario for the Vikings and one that doesnt seem very likely, but the situations that the new coaches walked into arent drastically different.

The Lions replaced a successful coach in Jim Caldwell looking to get over the hump with Matt Stafford, who was making $26 million. The year prior, they ranked 7th in offense and 21st on defense. Last season, the Vikings ranked 14th in offense and 24th on defense.

The Lions didnt have quite as much talent as Justin Jefferson and Adam Thielen but they had Kenny Golladay, Marvin Jones and Golden Tate. Like the Vikings, they also had several solid pieces along the offensive line in TJ Lang, Taylor Decker, and Ricky Wagner.

What destroyed this iteration of the Lions was Matt Patricia. He clearly didnt have the right personality to run an NFL franchise and appeared out of his depth. It doesnt appear like OConnell will have those issues, but it shows the cautionary tale of moving on from a stable head coach and swinging for the fences.

The 2017 Chargers (9-7), Anthony Lynn - Again this comparison needs to start with the quarterback, who in this case was 36-year-old Philip Rivers. Rivers is clearly the better all-time quarterback but at that point in his career, hes pretty similar to this iteration of Kirk Cousins. Rivers cap hit ($18 million) was considerably less than Cousins is now, but again the rosters and the situations have several similarities. Rivers had a rising star in Keenan Allen to throw the ball to and the team needed to be rejuvenated after the Mike McCoy era as it still had a solid roster on hand. They also came off a year where they were a fringe top-10 offense and a bottom-of-the-league defense, just like the Vikings. They had several dominant pass rushers and held up OK in pass coverage.

And the result was largely what the Vikings are expected to do, hover around .500. The Chargers barely missed the playoffs after finishing with nine wins. But the positive here was that they went on to take an even bigger step in 2018 and win 13 games.

With this iteration of the Vikings, that is the hope. Theyve pushed money down the road again and have Cousins signed for the next two seasons. They are hoping to give it a run in the next two years. And if they go 13-4 in 2023, it will likely be because they laid the groundwork with a moderately successful first season as the Chargers did in 2017.

My biggest takeaway was that most first-year head coaches dont immediately find success. Just over 25 percent of rookie head coaches make the playoffs. And if they have any aspirations of making it past the first round of the playoffs, they either need to have a star quarterback like Aaron Rodgers and Andrew Luck, or immediately need to show their coaching chops, like Kevin Stefanski.

But whats intriguing is the Vikings dont fit traditionally into what a team with a first-year head coach looks like. Most rookie head coaches are tasked with rebuilding, not retooling. And the retooling teams often have better quarterbacks. So where will the Vikings and Kevin OConnell fall? The best part is we dont know. For much of the Zimmer era, it was almost assured Minnesota would finish right around .500. That is no longer the case, for better or worse.

Read the rest here:

Where will Vikings' Kevin O'Connell fit within the history of rookie head coaches? - Sports Illustrated

Haitis Lost Billions. The Root of Haitis Misery: Reparations to Enslavers. How a French Bank Captured Haiti. Invade Haiti, Wall Street Urged. The US Obliged. Demanding Reparations, and Ending Up in Exile. These were the top headlines in a sprawling package of articlestotaling tens of thousands of words and written primarily by four reporters, with the help of more than a dozen researchers in at least six locations on two continentsthat the New York Times published on Haiti over the weekend, under the rubric The Ransom. The package took the form of a slick multimedia production online and a special section in print, trailed on Sundays front page across four columns under a large illustration of plantations burning during the Haitian Revolution, when enslaved Africans won independence from French colonial rule.

Though the events of the illustration date to 1791, the package really picks up Haitis story in 1825, more than twenty years after it declared independence, when the French returned and demanded that Haiti give them reparations or else face a war, setting the stage for decades of debt and exploitation. For years, as New York Times journalists have chronicled Haitis travails, a question has hovered: What if? What if the nation had not been looted by outside powers, foreign banks and its own leaders almost since birth? How much more money might it have had to build a nation? the paper asked. For more than a year, a team of Times correspondents scoured long-forgotten documents languishing in archives and libraries on three continents to answer that question, to put a number on what it cost Haitians to be free. The paper concludedand fourteen experts agreedthat the payments have cost Haiti at least twenty-one billion dollars in lost growth, and quite possibly much more. The Times described the story as a whole as rarely taught or acknowledged, and claimed that leading historians viewed its efforts to calculate the payments as a first. Monica Drake, a Times editor, described the package as investigative journalism, the documents are just really old.

Related: The bot that saw the Times

Alongside the package, the Times published at least two articles explaining how it came together, one of which offered an extensive, though not exhaustive, methodology and bibliography that itself came to five thousand or so words. Newspapers dont normally do this, Catherine Porter, a reporter on the series, said, but we thought it was important. The paper is also now running a live blog detailing the international reaction to, and impact of, the package. A French bank highlighted by the Times as having exploited Haiti said that it would hire researchers to investigate its history in the country, with the head of its parent company decrying a very sad illustration of the meaning of colonization. The Times also relayed reaction in Haitiwhere radio hosts discussed the package at length and a leading newspaper splashed the findings on its front pageand across the diaspora. The paper translated the package into both French and Haitian Creole, explaining that the latter step, a first for the Times, was particularly significant given the languages dominant yet often stigmatized status in Haiti. It published a piece about the reaction under the headline, Haitian Creole Speakers Welcome The Ransom Translation.

Interestingly, the Times reaction blog also noted less positive reactions to the package among some historians, who took issue not with its historical content but with the way it was framedarguing, in essence, that the paper presented the roots of Haitis present-day poverty as a mystery that its reporters had just solved, without giving sufficient credit to the many historians, many of them people of color, whove been researching the topic for years. The Times quoted Mary Lewis, a Harvard historian who said that the paper hadnt credited her for putting the paper in touch with sources, and Paul E. Cohen, a University of Toronto historian who noted, among other observations, that the papers bibliography was partial and framed in a way that functions to legitimate the journalists claims about the originality and importance of their work. The Times pointed in response to the extensiveness of the bibliography and the uniqueness of its calculation. (Interestingly, the paper also noted, some way into the package, that the total figure it reached was surprisingly close to the very precise amount that Jean-Bertrand Aristide, a former Haitian president, demanded in reparations in 2003, before he was ousted by France and the US.)

Like most historical discussions themselves, the debate as to how journalists ought to credit historians (and vice versa) is not new. (Indeed, the Times described its package as having rekindled the debate.) Views on the matter conflict sharply, but it strikes me that a case-by-case approach is probably best, with the extent of attribution owed depending on factors such as the terms on which a given historian has agreed to engage with a given journalist, the originality of the formers thesis, and the centrality thereof to the latters article. Very deeply reported worka standard to which we should all aspireis usually the tip of an iceberg of detail that would, if included, often serve to weigh down narrative structure and even basic factual clarity, doing the reader a disservice. As various observers have pointed out, academic-style citations typically arent tenable in journalism. Still, there are ways, these days, for journalists to ensure at least a degree of attributionlike hyperlinks, as my CJR colleague Mathew Ingram pointed out in this hyperlinked tweetthat dont infringe on their precious copy. Ironically, the Times bibliography laudably went far beyond this bare minimum, and its a little baffling to me, given its existing level of detail, why it didnt carry on to cite every source the Times consulted. (The Times also deserves to be lauded, to an extent, for quoting some of its critics tweets, especially in light of its recent, dismissive-sounding stance on online feedback. But I digress.)

If all this ties into a much broader industry debate about attribution to experts, it also ties into long-standing industry gripes about the Times, specifically, and its track record of prominently crediting the work of other journalists, with something like them at issue again here; Michael Harriot, for example, pointed to his past coverage for The Root headlined As Haiti Burns, Never Forget: White People Did That. Politicos Jack Shafer tweeted yesterday that the genuine scrimmage isnt journalists vs. historians but the New York Times vs. everybody else, elaborating in a column that no subject exists or matters until it receives the Times treatmentthats the papers code. The Haiti package is only the latest expression of this mindset. (Though Shafer, too, noted that broader industry dynamics are at play here.)

As I see it, the most interesting and complicated issue at stake here doesnt involve the relationship between historians and journalists, but between history and journalism, as disciplines. The former, fundamentally, is seen as being expansive and about the past, whereas the latter concerns whats new, often tied to a rigid news peg; their demands are different and thus rightly draw on different practices, as I wrote eighteen months ago, amid another Times-driven controversy. But the two disciplines arent conceptually separable either, given how deeply the past informsor should informour understanding of the present, and excellent journalism can form a bridge between the two, as the Times itself did with its 1619 Project asserting the centrality of slavery to the American story. Even that project had a pegthe four hundredth anniversary of the first enslaved Africans arriving in Virginiabut it didnt claim to be new scholarship, as Nikole Hannah-Jones, its lead journalist, noted over the weekend. What the project achieved, she said, was helping to usher a particular understanding into the culture.

It seems to me that we have to work to do, as an industry, to better define the boundaries of this type of engagement. As various journalists argued with regard to the Haiti package, the idea that a story must say something new in order to be news, while generally a good principle, is inflexible as a hard rule. At the very least, we could expand our definition of the news peg beyond new facts, seeing broad current problems as an opportunity to scrutinize how they came to be. The Haiti package certainly does contain some important new facts, but its much greater service, in my view, lies in focusing global attention on a shameful chapter of history with an ongoing legacy that many readers dont understand. (Old facts are usually new to someone.) The packages more sweeping claims of originality, in this light, werent just contrived, but also unnecessary. We need more nuanced understandings of how to slot the past into our present stories, beyond mirroring round-number dates and straining the boundaries of novelty.

As a global and growing news juggernaut, the Times, perhaps more than any other outlet, has the resources to commit to seriously ambitious historical storytelling, and the reach to put it in front of readers and open up debates, both old and new. With that global dominance, though, should come a responsibility to be a generous and humble steward of such debates. Again, the bibliography the Times published here was a step toward that. But its not a misunderstanding that the way it presented the package rankled so many people to such an extent.

If theres a timing problem with the Haiti package, it isnt any want of a current news peg, but the fact that its taken so much time for such a clear-eyed way of seeing the legacies of slavery and colonialism to routinely get such extensive treatmentand here, the Times is not a lone offender. The originality framing is not only not true, but also allows the NYT to be self-satisfied that its doing incredible work. It means you dont ask what took you so long? Kendra Pierre-Louis, a former Times journalist who is now at Gimlet, wrote over the weekend. What took them so long is white supremacy. White supremacy is why we expect a Black country founded in revolution and self-determination to be poor, so predominantly white institutions dont have to look at how they helped create that poverty.

Below, more on the Times and Haiti:

Other notable stories:

ICYMI: Three months of press threats in Ukraine

TOP IMAGE: (Photo by API/Gamma-Rapho via Getty Images)

Here is the original post:

The Times, Haiti, and the treacherous bridge linking history and journalism - Columbia Journalism Review

Kennedys and Reagans first ladies were both tightly encircled by gay courtiers, though loyalty in both directions could easily waver. Kirchick writes of Nancy Reagan: Her own persona is inescapably, irrepressibly gay, embodied by the retinue that designed, dressed, escorted, entertained, flattered, housed, humored, pampered, styled and titillated her.

The grimness of AIDS, though, was simply incompatible with the administrations message that it was morning again in America. One of the starker documents in Secret City is a draft of the presidents statement when his prominent friend Rock Hudson died of the disease, the word profoundly scribbled out before saddened, along with the line we will miss him greatly. Kirchick also reproduces in full a long, poignant letter from Bob Waldron, loyal aide to Lyndon B. Johnson, to the friend who betrayed his confidences about his sexuality and ruined his career.

Secret City is a luxurious, slow-rolling Cadillac of a book, not to be mastered in one sitting. It would be best read at the violet hour with a snifter of brandy in a wood-paneled library, one of those with a rolling ladder to bring down some of the faded midcentury best-sellers resurfaced in these pages, like Vidals The City and the Pillar the narrative perks up considerably whenever this contentious, urbane writer arrives on the premises Washington Confidential, by Jack Lait and Lee Mortimer (1951), with its fabled Garden of Pansies; and Advise and Consent, by Allen Drury (1959), which won a Pulitzer and was made into a movie by Otto Preminger.

Its also a Baedeker of important places (map included): the rollicking Chicken Hut bar where Teboe met his murderers; the Fruit Loop of theDupont Circle pickup scene that developed in the 1960s; the Cinema Follies, the pornographic theater where nine men died in a 1977 fire; the gay corner of the Congressional Cemetery; and, more hopefully, the Lambda Rising bookstore.

This is overwhelmingly a gallery of the white male gaytriarchy, with lesbians and people of color mostly on the sidelines. And Kirchick seems to run out of gas toward the end, as the gay situation improves. Though he addressed the defeat of the Defense of Marriage Act in a triumphalist essay for The Atlantic in 2019 that drew ire from some on the left, theres only the briefest mention of it here; nothing about the presidential candidacy and subsequent cabinet appointment of Pete Buttigieg; little about the rise of the L.G.B.T.Q. rainbow. But as an epic of a dark age, complex and shaded, Secret City is rewarding in the extreme.

Read more from the original source:

Secret City, an Epic Narrative History of the Closet in the Capital - The New York Times