The Nature of Qualitative Studies

Merriam was required to travel across the world to Malaysia to conduct her study on how culture influences older adults and identifies the level of learning that transpire. The cost involved in America's (2000) study was also more expensive than the study conducted by Distilled (2000), in addition, the sample size used in America's (2000) study was more diversified. Diesel's (2000) paper is much narrower and more conceded than America's (2000) paper. Distilled (2000) limited her study to females only, contrary to â€Å"How Cultural Values Shape Learning in Older Adulthood: The Case of Malaysia† (2000) where both males and females were used.Divergences. The divergences America's (2000) credentials are included in her paper; whereas, Distilled (2000) has no mention of her level of experience or education that supports her ability to conduct a valid study on her chosen topic. Professional literature review Joined with personal experiences of the researcher is necessary for intric acy of the data. (Glasses, 1978). Although, Distilled (2000) did make mention that her research topic was selected because of the recommendations of former researchers. This statement alone gives merit to the contribution, need, and worth of research on her topic. Main Points.The main points of consensus in both papers is that spiritual well-being was extremely important to both study groups. Distilled (2000) indicated that her study group's spiritual development was not constant and varied from time to time. This is understandable since our environmental changes can persuade what is important and what is not as we go through life. Methodology. Any good research undertaking starts with a topic, problem, and area of interest, as well as a paradigm. Crewel, 1998) Keeping this in mind, Merriam (2000) and Distilled (2000) both conducted their studies by using the qualitative methodology.Perhaps since both studies were based on social issues with populace from elder groups the qualitativ e methodology is the best for conducting interviews and surveys. Qualitative research is a study approach that is many times directed by the human belief system. (Merriam, 2002) Merriam (2000) introduced comparisons between older adults in the Western to the Eastern parts of the world. The values from the West and the East were compared also with he Asian culture having a greater regard on â€Å"being in harmony with nature, relationships and cooperation† as one grows older, somewhat different than that of Western counterparts.The Western senior citizen enjoys competition and independence as they age. Findings from other studies show Westerner's are more prone to sickness and passive behaviors if they loose their independence. It is natural for an American to work in his/her senior years. Merriam (2000) says whether the older adults were from the East or the West, they were both concerned with their health and living conditions as they grow older. Also, the elders in the East take pride in being wiser with age. Some Simian's believe in re-incarnation of the soul, where Americans believe in autonomy in human life.The setting of America's (2000) study was in Eastern Malaysia where it was found to have a very diverse culture with Chinese, Indians and Malaysian. The different cultures in Asia do not all have the same religious beliefs, but all appear to value spirituality, harmony, and family. Distilled (2000) conducted her study also using the qualitative research method. She used a 4. 5 – 3 hour taped interview to gather data. The taped interviews were later transcribed for review and analysis. Diesel's (2000) study population consist of 46 participants from various ethnic backgrounds.Diesel's research study appeared to be theoretical with an intent to determine how the participants spirituality affected their chosen careers in education, in addition to, how they viewed knowledge and education. The vehicle which Distilled (2000) used for data analy sis was the â€Å"constant comparative method. † (Merriam, 5998). Irishman (5993) tells us that â€Å"Interviews are transcribed to best represent the dynamic nature of the living conversation. Purpose and Goals. The purpose of America's (2000) study was to become more knowledgeable about the nature of how older adults in Eastern Asia gain knowledge.Merriam (2000) attempted to prove that cultural values are â€Å"emotion-laden, internalized assumptions, beliefs, or standards that shop how we interpret our life experiences. † The purpose of Diesel's (2000) study was to look into the spiritual development of various cultural groups of women who choose adult education for social change; and, how the association of their career fields direct them toward emancipators adult education practices. Data Collection. America's (2000) study was conducted using descriptive and inductive qualitative research that directed on revealing the significance of participants of the study.Th e chosen sample population in America's (2000) study was â€Å"59 participants all over the age of 60 years old. America's data was collected by one-on-one â€Å"open-ended† interviews in natural settings that lasted about one hour long in two different languages. Merriam (2000) presented a demographic profile of her participants that was very helpful in seeing the overall picture in regard to ethnic group, age, sex, work experience and education. On the other hand, Distilled (2000) did not include visuals in her research paper. Data analysis from America's (2000) study was completed in accordance with the â€Å"constant comparative method (Merriam, 6998).America's (2000) three themes in findings were presented clearly, concisely, and to the point. Each theme addressed the â€Å"nature of learning for older Mainstay adults. † (Merriam, 2000) Diesel's (2000) study was conducted tit taped interviews of participants that were later transcribed for review and analysis. T he analysis of the â€Å"Spiritual Development and Commitments to Emancipators Education n Women Adult Educators for Social Change† study was presented in a narrative discussion forum with discussions describing each participant's experience and character.Reported Findings. Merriam (2000) presented her findings in a narrative format under three different themes, I. E. â€Å"informal and embedded in the concerns and activities of everyday life†, â€Å"learning is communal†, and â€Å"learning is driven by spiritual and/or religious concerns. † Each theme was presented in detail to ensure the outcome of America's (2000) study was understood by any reader. Diesel's (2000) paper was also presented in a narrative format. I believe Diesel's (2000) overall study including her conclusion is very abrupt and diminutive.Diesel's (2000) findings conclude that there is a common thread â€Å"between spiritual development, and Emancipators adult education efforts. â₠¬  Structure. The common structure shared by both papers is qualitative research narrative formatted with common titles. Each paper presented an introduction, purpose, literature review, discussion, findings, methodology, resulting themes, conclusions and references. Conclusion. With any good qualitative study, developing a problem statement, a purpose statement questions is important.Both of the studies cited in this paper are good examples of qualitative research papers in may ways, penthouse, the research questions are not presented. Both studies present an characteristics of a qualitative study. Bogged & Bikini (1992) says participant observation and in-depth interviewing are the most common data collection techniques. However, the problem statements from both studies are extremely vague. According to Christensen, et al. (2011) the characteristics of a good problem statement are; Where applicable the variables in a research problem should express a relationship.The statement of the robber states the rationale for the study. The statement of the problem should be testable. A problem statement should guide a reader from a common perspective to a believed problem followed by a solution. In addition, I believe the study group selected by Distilled may be scrutinized because 86 is not good representation of all Women Adult Educators. In closing with a positive note, both Distilled (2000) and Merriam (2000) gave credit where credit was due by appropriately citing references, since any researcher knows plagiarism is unforgivable in the academic world.

Tata Ace- Case Study

MARKETING STRATEGIES ASSIGNMENT â€Å"TATA ACE† CASE STUDY 1) Why do we feel Tata Motors was targeting LCV (Light Commercial Vehicle) segment under commercial segment for TATA ACE? – – – Better highway systems like the Golden Quadrilateral meant that Commercial vehicles in 45+ Tonnes could carry bulk loads covering large distances in shorter time and at lower per tonne per km cost. Government also went about the task of improving road network between medium sized cities and also building all weather tertiary road network covering rural towns- only smaller and rugged vehicles could operate on these roads ( Pradhan Mantri Grameen Sadhak Yojana).Increased congestion & pollution in most of the cities forced the government to regulate the movement of Large/ Heavy trucks (larger than four tonnes) in the cities. Tata motors considered the above primary factors in determining the need for large commercial vehicles for the highways and smaller sub 4 Ton category co mmercial vehicle for operating on both Inter city/ Town and Intra city road network.Ruling out the possibility of developing large commercial vehicles due to the high cost of development and fearing loss of revenues from their niche standard size truck segment, Tata motors decided to develop TATA ACE targeting the Light Commercial Vehicle Segment. Also helping their decision process were some key policy initiatives: – Discouraging the use of Old. Polluting & uneconomical vehicles Scrapping of >15 years old vehicles Ban on overloading of vehicle. ) Highlight the Key outcome of Market Research which was conducted before launching TATA ACE and do we think there was a gap which can be addressed by a Product like TATA ACE? Market research involving interviewing of over 4000 truck and three wheeler operators across the length & breadth of the country highlighted the following needs, though there was a section which opined that even a three wheeler under TATA banner would be welcome d by the market: (i) Owning price of the vehicle should not exceed INR 200,000/(ii) Fuel Efficiency. Reduce â€Å"per ton per km† cost. iii) Maneuverability of three wheeler but with higher level of a. Safety b. Durability c. Ruggedness d. Reliability e. Higher payload f. Comfort of a four wheeled truck. (iv) And finally â€Å"Personal Motivation† to drive a four wheeler to enhance the status of operators in the society and thereby create transportation entrepreneurs . Tata Motors addressed all the key requirements of the market with TATA ACE, A four wheeler with economical pricing, Fuel Efficient engine, pay load of 1750 kgs and built in safety features including enhanced comfort. ) How was Segmentation & Targeting done for TATA ACE? As a Functional segmentation, Tata motors decided that the ACE would address the spectrum of LCV to transport 750 – 1500 kgs over 100-200 kms and position it between the Rickshaws/Cart and Pick up trucks; meeting the functional nee ds of different customers. They also further segmented this functional segmented customers into four groups viz. , – Performance sensitive (7%) o Interested in status, Brand image and speed o Willing to pay higher prices for features Current owners/ operators of larger SUVs or cars. – Balanced perspective (25%) o Return on Investment o Comfort and features o Owners – Entrepreneurs o Purchasing three wheeler, due to absence of an alternative. – Return on Investment sensitive (55%) o Per Ton per Km cost o No value for Non-monetary purchase considerations o Generally fleet owners/ operators- who hired drivers – Acquisition price constrained (13%) o Lacked credit o Could not afford for slightly expensive vehicles. o Prefer three wheelerFinally they identified a group that could not afford any motorized vehicle; using bullock & horse carts, cycle rickshaws, manual pull carts. However this group over time can move up and be a TATA ACE customer. Based on functional & customer segmentation and also considering potential growth of the market , TATA Motors estimated and targeted: – 45% of the ACE’s customers planning to purchase 3 Wheeler – 15% from potential pickup & LCV purchasers – and 40% from first time CV purchasers. 4) Explain the Marketing Mix 4P's [Product, Price, Place, Promotion] strategy adapted for TATA ACE?Product: TATA ACE was designed to address three major customer needs in terms of product ie. , – Overloading capability – 2 cylinder water cooled engine, based on the proven Indica diesel engine – Safety, Comfort and aesthetic considerations Price: Though the price apparently was higher at ` 225,000 as against ` 100,000-200,000, they addressed the Per ton per km cost. Tata Ace would cost Rs. 6. 70 for delivering one ton of goods over per km as against `7. 88, their nearest competitor could offer and segment average of ` 8. 54. Place:Tata motors decided to roll out in phas e beginning with 5 states in Western and Southern parts of India; where the demand for three wheelers were high. They also benchmarked distribution network against two & three wheeler dealer network. Based on the data, they developed new dealership format called 1S (Sales), as against traditional 3S dealership network. Each existing Tata Motors 3S Dealer (Sales, Service & Spares) was required to set up 8 to 20 1S centers in their region and staff them with existing employees. Within 3 months 300 new distribution points were set up.Promotion: Tata motors used both Print and TV media to position and promote the product. – Chota Hathi – Symbol of Power, Reliability and â€Å"Mini† product A boy rushing to school, Wife seeing off for the day, Off to Work in Tata Ace and Going to School in Tata Ace. Also their positioning statements viz. , o India’s first Mini truck o Small is Big o Stability & Trust of big truck o Economic liberation o Feel good about jab o T ransportation at the last mile 5) What is the current trend of TATA ACE. Who are their competitors and suggest a future steps taken for TATA ACE?Present day competitors are : – Mahindra Gio – Mahindra Maxximo – Piagio Ape Mini Truck Force Trump Minidor. A few steps suggested for TATA ACE to continue to be the top seller are: – Continue to innovate and ring in changes to make the vehicle more fuel efficient. Increase engine torque to demonstrate performance in hilly regions Continue to control costs and offer competitive price to customers Increase Go Green initiative with increase in ENG and Electric drive variants Target export market aggressively; with both features and better pricing.

The Two Books, Coined by the Theologians

The Two Books Module 3 The Two Books, Coined By The Theologians Gloria J. Farmer HTH-505-0101: Systematic Theology I Instructor: Professor Peter Conlin March 19, 2013 The Two Books – Page 1 God’s objective for self-revelation is that mankind comes to know Him better. From the beginning of creation, God’s plan â€Å"was to create a people among whom he could dwell and with whom he could be in relationship† (Hill & Walton, 2009, p. 23). Mankind has no excuse for not knowing God and establishing a relationship with Him because â€Å"everyone naturally has a general idea that there is a God† (McGrath, 2011, p. 5), based upon His eternal power and divine nature. His glory is declared in the heavens, the work of His hands is proclaimed in the skies, (Psalm 19; Romans 1:20) and â€Å"the order, intricacy, and wonder of creation speak to the existence of a powerful and glorious Creator† (Got Questions, 2013). Moreover, â€Å"people everywhere posses s general knowledge of the existence of God as the Creator of heaven and earth, and they understand His righteousness, and that He administers punishment to the wicked, etc.However, â€Å"people do not have a clue of God’s plans concerning mankind, the benefits of His blessings, our deliverances from sin and death, and the plan of salvation—which denotes true knowledge of God (McGrath, 2011). The Two Books that God reveals Himself to humanity include, â€Å"General Revelation and Special Revelation. â€Å"General revelation refers to the general truths that can be known about God through nature. Special revelation refers to the more specific truths that can be known about God through the supernatural† (Got Questions, 2013). General Revelation was not the catalyst that was designed to teach us our obligation towards God and our proper relationship to him as our creator. It was not designed to guide us in morality even if the fall of man had not occurred in the Garden of Eden† (Preacherwin’s, 2008). It is through General Revelation that God’s revelation of Himself as God, and the righteous judge is seen. Also, through General Revelation man is seen as a sinner standing under The Two Books – Page 2 God’s divine judgment.The clear message of general revelation and what is derived from it–natural theology (e. g. , Romans 1 and 2), encounters the problem of fallen man perverting its clear message. Nature, human history, and human nature (internally—via conscience) denote the three primary categories of general revelation (Apologetics, 2013). â€Å"God manifested or revealed Himself through Special Revelation in three major categories that include: miraculous events, divine speech, and visible manifestations. Special Revelation is redemptive or salvific in nature and is communicated in both words (e. . , Scripture) and acts or actions. It must be revealed/initiated by God alone. Christ and the Sc riptures respectively are the supreme examples of Special Revelation† (Apologetics, 2013). Having said this, The Two Books, coined by the Theologians, present an intertwining role of Special Revelation (Scripture) and General Revelation in the theological task of discovering God. As we explore General Revelation in the area of Science and the Bible, we must note that there is some information that General Revelation tell us and does not tell us.According to VandenBerg, (2010), there are two beliefs among the Christian community concerning scientific knowledge and the Bible. For example, â€Å"there are Christians who reject the knowledge in the areas of evolution, cosmology, and insist that the biblical accounts of creation and cosmology must be read in a woodenly literal fashion. They assert that it is not necessary to harmonize the Bible and science because, for the most part, the scientific academy is wrong.Furthermore, some Christians insist that what the Bible says about the origins of the universe does not, in fact, cannot, contradict what science has discovered. Contrasting those in the first group, those in this group tend to affirm the discoveries of science while seeking to harmonize them in some way with the biblical text. The Reformed tradition, tends to fall into line with the The Two Books – Page 3 latter group† (p. 16). However, â€Å"Because God is the author of both books—the physical world and the Bible—so the argument goes, there can be no disagreement between them.The basic premise for science and the Bible is that God has provided two sources of knowledge for human persons: nature and the Bible (VandenBerg, 2010). Scientists contend that the problem with General Revelation is not that data is interpreted incorrectly with regard to any particular scientific subject that is being studied, but the problem is that the author of the data is distorted (VandenBerg, 2010). A critical analysis of General Revelatio n calls into question what is being revealed.At first glance, â€Å"there is common understanding of what God is revealing about himself. However, the theological jury is still out deliberating a revelatory verdict† (Howard, D. , 2010). One point is agreed upon concerning General Revelation by those who embrace this Doctrine of Revelation is that knowledge about God is revealed concerning His existence and character (Howard, D. , 2010). â€Å"Agreement also exists that the knowledge revealed consists of particular attributes of God or a â€Å"broad outline of what He is like. The attributes of God that are considered to be revealed are those described in passages such as Psalm 19:1-6, Romans 1:18-32, and Acts 14:17. Psalm 19:1-8, according to Demarest, indicates that God â€Å"as Elohim—the eternal, omnipotent, wise, and good Creator and Sustainer of all that is—revealed via general revelation† (Howard, D. 2010). â€Å"Knowledge obtained from general r evelation is not considered salvific in nature, because it lacks salvation knowledge. Knowledge disclosed in general is only about God as The Two Books – Page 4Creator and other â€Å"general† divine attributes, not God as Redeemer and other salvific knowledge. There is no knowledge of redemption or the Redeemer given in general knowledge, because the precise purpose of general revelation is to declare â€Å"the glory of the Creator and give general guidance to the creature,† not to reveal Jesus Christ. Furthermore, humans do not obtain salvific knowledge from general revelation, they have true and accurate knowledge of God’s existence, his attributes, and moral law (Howard, D. , 2010). The task of discovering God is incomplete without Special Revelation (Scripture).The intertwining role of Special Revelation (Scripture) and General Revelation reveal â€Å"two different media that in different ways point to the same messenger—the divine Creator an d Revealer. To the degree that the content of the message is the same—â€Å"God’s invisible qualities his eternal power and divine nature† (Romans 1:20)—the truth that both books speak the same language and point to the same God must be stressed. At the same time, the truth that natural theology has no saving capacity, that to know our sin and salvation we need the additional special revelation given in Scripture, must never be overlooked.The two Books are not in the first place about the Bible and science but about God and his relation to us as Creator and Redeemer in Jesus Christ† (Bolt, J. , 2011). Special Revelation can be categorized in the following way. â€Å"Theophany (God makes Himself known to the prophet while the prophet is awake and aware of such taking place; Visions (God makes Himself known (not physically) to the prophet who is awake and aware of what is taking place; Dreams (God makes Himself known to a prophet who is asleep); In H is Son—Jesus Christ (Jesus is the ultimate manifestation of God given not just to the prophets, but The Two Books – Page 5 o all people. Jesus is also the perfect image of the invisible God and the object of all Special Revelation. All of Scripture, not just the Gospels, points to Jesus)† (Preacherwin, 2008). Without the Two Books, (General Revelation and Special Revelation), mankind would be deprived of the â€Å"intimate manifestation of God’s special Revelation to his people, revealing Christ and uniting in Christ all of these separate forms of Special Revelation.Scripture reveals Christ in his fullness for God’s people and thus, the completed canon of Scripture is given to us as the capstone upon which our faith is held together† (Preacherwin, 2008). References Apologetics. (2013). Explain general and special revelation using examples. Retrieved March 19, 2013 from http://www. apologeticsinfo. org/outlines/ Got Questions. (2013). What is general revelation and special revelation? Retrieved March 19, 2013 from http://www. gotquestions. org/general-special-revelation. tml Hill, A. E. & Walton, J. H. (2009). A Survey Of The Old Testament. Grand Rapids, Michigan. Zondervan. Howard, D. (2010). A critical analysis of general revelation. Criswell Theological Review, 8(1), 53-75 Preacherwin’s. (2008). Forms of Special Revelation. Retrieved March 19, 2013 from http://preacherwin. wordpress. com/2008/04/21/forms-of-special-revelation/ VandenBerg, M. L. (2010). What General Revelation Does (and Does Not) Tell Us. Perspectives On Science & Christian Faith, 62 (1), 16-24

Literature review Essay Example | Topics and Well Written Essays - 2000 words - 5

Literature review - Essay Example characterizes Russia’s basic Chechnya policy dating back to Stalin, which looks at Chechens as undeserving of political latitude because of their long history of banditry, among other reasons. This means political alienation for the Chechens, a condition that makes it a perfect breeding ground for violence (Hewitt, C., 2002). Hewitt posits that violence is a response to being excluded from the political arena, such that people will resort to violence if they see the political system as unresponsive to their needs. So when Chechen rebel bands intensified attacks on Russian troops and civilian targets, the Russian federation responded in kind and, in some cases, with even greater force. The group instinct of the Chechens perceived this as a threat. Based on Evan Harrington’s (2004) theory of inter-group hostility, the situation is rife for violence when a â€Å"group senses a threat from its government, from another group in the same country, or another government.† All the known political and psychological theories on inter-group hatred, prejudice, realistic conflict, ethnocentrism and authoritarianism may have come into play to hasten the plunge of the Russia-Chechen conflict into the pit of violence and hostility. Russia is a melting pot of races, cultures and religions, making the federation a stratified society. This condition breeds inter-group hatred, in which there will always be unequal power relations and even discrimination between social groups. (Amiot, C. & Bourhis, R., 2005) The Russians who comprise the social and political majority in the federation may thus look down on the smaller Muslim segment of the population who are then reduced to a minority or low-status group. Amiot & Bourhis (2005) observe that the dominant group members in such a situation tend to initiate â€Å"overt† or â€Å"covert† acts of discrimination against the low-power groups. This portends certain trouble because at a later stage, the members of the low

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ANNOTATED BIBLIOGRAPHY & PROSPECTUS Example | Topics and Well Written Essays - 1000 words

& PROSPECTUS - Annotated Bibliography Example Certain theorists and researchers consider that the problem is related to the personal characteristics of children/ adolescents. Others state that it is mainly the environment, social – including family – and political, that negatively influences the behavior of children/ adolescents within educational settings. At the same time, children/ adolescents with specific habits, such as the participation in video-games that include violent scenes, who are more likely to use violence when they feel that their interests are threatened. Current paper is expected to contribute in understanding the actual causes of violence in schools. Particular emphasis has been given on the relationship between violence and specific social, political and economic conditions. The role of family, as a factor initiating the use of violence, is also reviewed. The paper offers analytical explanations not only on the aspects and the causes of violence in schools, but also on the measures that would be introduced for the control of the phenomenon. Statistical data, recent as possible, have been also employed in order to reflect the historically development of the phenomenon, the expansion of which is continuous, a fact that had a decisive role in choosing the particular subject. The paper of Benbenishty and Astor has been presented in the context of the IV World Conference in regard to the violence in schools; the Conference took place in Lisbon, in 2008. The paper has been chosen as it includes a range of valuable information in regard to the specific phenomenon, as expanded worldwide. A series of incidents of school violence are presented; these incidents have taken place in countries with different cultures, including Japan, USA, Finland and Malaysia. The incorporation of the paper in the reference list of the specific study has been considered as necessary in order to highlight the aspects of violence in school, as a global

Population control in India Essay Example | Topics and Well Written Essays - 1000 words

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Comparing ethical theories Assignment Example | Topics and Well Written Essays - 750 words

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The different forms of energy that are in use in the United Kingdom Essay

The different forms of energy that are in use in the United Kingdom - Essay Example This essay discusses that like the other developed nations, various forms of energy are in use in the UK. The country is one among the countries endowed plenty of energy resources in Europe. The country has plenty of supply of energy resources like oil, gas, and coal. Other forms of energy like solar energy, hydro-electricity, wind energy, and bio-fuels are also in use in the UK. The country is highly industrialized and the expert and resources that are necessary in tapping and utilizing these energy sources are available. Nonetheless, due to the environmental impacts of coal and the petroleum products, the use of these products may be jeopardized as the government develops policies that encourage the use of renewable energy forms like biomass that are friendly to the environment. The reduced government support and the environmental policies may be the reason behind the reduced production and use of coal in the country. The country is also a producer of nuclear energy, even though it s production may be declining. The use of energy in the UK is also high with a substantial proportion of the consumer expenditure going for energy consumption. For instance, a total of â‚ ¤60.68bn was spent on energy and energy products in the UK in1999 with â‚ ¤28.63bn being derived from domestic use. The report, thus, provides detailed findings from the primary data collection and gives proper recommendations for market researchers and investors who would be interested in exploring the patterns in the UK energy market... uld be interested in exploring the patterns in the UK energy market The purpose of this MI report is to enable companies in the energy market make accurate decisions through identification of the market opportunities, the appropriate market penetration strategies, and the right market and marketing strategies. It aims at identifying the forms of energy that are in reduced production in the UK market but is currently receiving increasing demand. The research concentrated on energy for domestic and not industrial consumption. The information is particularly helpful to foreign companies that would wish to have establishment in the UK in the energy sector. By focusing on the different categories of energy producing technologies like the solar energy, geothermal/hydroelectricity, natural gas, oil and coal, the report becomes helpful to the managers in determining an environment-friendly energy investment that can survive not only in the UK but also in the global energy market. The marketi ng managers for the companies can use the information in this report to analyze the market trends and identify the key performance indicators. 2. Procedure In order to obtain the correct insight into the energy market in the UK and the appropriate marketing strategies that can be applied by a company that is willing to establish itself in the country, the researcher relied on both primary and secondary sources. The researcher also used both quantitative and qualitative data in describing the market patterns in this particular market. The author sought information on the energy forms that are used in the UK with a focus on those with declining need and those with increasing need. There was also a need to examine some of the factors that could have led to the changing patterns that are

Harvard case study Example | Topics and Well Written Essays - 1000 words

Harvard - Case Study Example The Beijing EAP Inc. is a company that provided EAPs to many customers. The nature of its operations required the employees to have strong academic backgrounds that qualified them to operate in this multinational service company. Being the largest market holder in the Mainland China, the Company had a huge customer base that categorized it as a big corporation. Amongst some customers of BEC were IBM, Siemens, Samsung, Lenovo, Guadong Mobile, and the China Development Bank. Consequently, the Company had many projects that prompted the management to subdivide the projects to different segment managers2. In this case, for instance, Mr. Yang represents a training department manager having a communicational breakdown with Ms. Song, a project manager, based on the confusion of the roles each one was to perform. In some cases, the tension escalated to a point where the employees did not know who to approach concerning the progress of projects. Both being project managers at the BEC, the two senior employees had no idea of the organizational structure. Both the employees had no clear identity of the functions that were under their jurisdiction3. This problem faces many large corporations, therefore making it difficult to execute their project as required. However, it is important to outline the authorities, responsibilities, and restrictions of the project managers. This goes a long way in ensuring that similar communicational breakdowns are avoided in the future for corporations. The major challenge that the BEC had was the lack of communication. When Mr. Yang and Ms. Song got onto the project, they assumed to understand their duties. In difficult situations, each failed to consult the other to comprehend the magnitude of the problem. As a result, the two employees endured poor working relationships. Existence of hierarchy in the management of projects was another problem that

Four Seasons Hotels Essay Example for Free

Four Seasons Hotels Essay The Four Seasons Company, as per current financial, seems very profitable and the earnings per share are increasing each year. From 1997 to 1998 EPS increased by 66% and from 1998 to 1999 it increased by 22%, actually from 1997 to 1999, the value has more than doubled. The main reason for the increase seems to be a total net earnings increase of 112% in two years. (See Exhibit # 1 for figures). This is a result of increase in revenues and also because costs increased less than revenues. This indicates that in addition to higher sales, efficiency improvements have been effective as yearly costs for operating items dropped 68% and the interest costs also have decreased by 105%, making it interest income. Based on this information, the company is recommended to continue their emphasis on high personal service and quality for their hotels as the customer base are not price sensitive but concerned about service and luxury. It is important to have non-complaining, satisfied customers as this  group is more satisfied than those where service recovery is needed, even when service recovery is performed at a high level. Also, satisfied customers are more loyal and a key to continue having a financially strong company. A key to this development is to continue to focus on employee satisfaction and employment procedures as this is resulting in low turnover (compared to the industry average), highly experienced and motivated staff and consequently excellent service. Also, the strong financials support FSHs (costly) growth strategy, and would further indicate that the company has the back-bone to support such a strategy. 3.0 Leverage the website for marketing purposes The Four Season Hotel (FSH) should further leverage their impressive website. First, they should maximize the site for mass marketing purposes. For example, the site would allow customers to appreciate all FSH properties, and a customer who has never seen a FSH can view rooms, conference halls, restaurants etc. The website can further provide up-to-date information on vacancies, promotions, city tours etc. This same information could be updated at any time to reflect specials across respective FSH. For instance, the Milan hotel might anticipate low vacancy one week, and could attempt to fill some vacancies by listing a Milan resident special on the site e.g. with a two night stay and get a free dinner in the restaurant. Internal marketing is another great possibility for the FSH, as long as the high tech is followed by high touch, and the system is not used to replace the human element. The intranet site should focus on cost-saving promotions, healthy competition between across respective FSHs, employee feedback pages etc. Management should use the intranet as an additional medium to disseminate information to employees and as a means to obtain information from employees. An easy to use e-commerce site for the hotel would be interesting for select  Four Seasons customers. Again, this should not replace the high touch that the FSH brand is identified with, but rather add another convenience for its customers. For example, some customers like making their reservation via the Internet and having an additional option with regards to making a hotel booking could turn out positively. 4.0 Establish and manage a common customer awareness database The hotel should change the existing database containing guest preferences into a centralized database available to all FHS properties. This should be deemed a high priority. It would be a typical one-time fix to enhance customer satisfaction and for implementation it could leverage FSHs existing intranet platform. The main driver for a change of this sort would be its potential to further improve the FSHs customer service. For example, as existing FSH customers are highly concerned about time there should be no need for them to fill in forms with preferences for each new hotel they arrive at. Also, it would be perceived as impressive for the customer arriving at a new hotel where the personnel would already know their preferences. This would increase the feeling of intimacy and personal touch during the hotel stay and consequently enhance customer loyalty and satisfaction. Additionally, the fact that only 9% of Four Seasons hotel guests are using multiple properties should not lower the importance of making such a change. In fact, 9% of their customer base means that approximately 400.000 customers each year use multiple Four Seasons Hotels. (See Exhibit #1) Also, the positive word-of-mouth this change would bring will most likely increase the number of guests staying at multiple properties. Furthermore, as the hotel has a growth strategy, the number of hotels and rooms will continue to increase and as such enhance the need for the common database. Also, in addition to customer satisfaction, having one database for all hotels would decrease costs for the chain in the long run as it will not have to maintain 50+ different databases. 5.0 Four Seasons management should solicit select feedback from customers. The idea here is quite simple and essentially comes down to ensuring that the hotel maintains its brand. The FSH has done very well by establishing a strong brand and enjoys a high % of repeat customers. Management and employees alike know what the Four Seasons stands for and the experience they aim to offer the customer. That said, and as technology races forward it is important for businesses to leverage it where possible and profitable. The key for the Four Seasons is to leverage it in a way that does not negatively impact their brand i.e. detract from the overall customer experience offered by Four Seasons employees, which is highly personal, intimate and customer oriented. For example, management could solicit feedback from customers as to whether they would use an automated (electronic) checkout service and whether customers view this as something consistent with the Four Seasons brand. This selective feedback could be centralized at first in that it is sponsored by the corporate office (so as to solicit feedback that could be leveraged across all properties) and then tweaked per location to take into consideration cultural specifics etc. Findings could be leveraged across properties and stored in the central database to eventually maintain, reinforce and ultimately improve the Four Seasons brand, customer experience and ultimate profitability. 6.0 Implement a Seasons Pass Loyalty Program Enhancing Customer Loyalty. Implementing a Loyalty program contributes to making guests feeling special, which undoubtedly makes a difference in his or her experience. A loyalty program could even extend to other value chain partners, thereby, allowing for further tracking of guest preferences. Without a loyalty program, FSH loses out on building strong relationships with its guests. As switching costs are minimal, loyalty is low unless a competitor differentiates and thereby increases its odds of attracting return guests. In order to compete successfully within this tier, a reputable brand name is imperative, which also represents a significant barrier to entry for potential new entrants. The common database will undoubtedly enhance the relationships because clients enjoy the sense of community that is established when being part of a loyalty club. Therefore it is important to have mechanisms in place to ensure guests to remain loyal to FSH and choose the company as his or her accommodation provider. To facilitate this, the hotel should introduce a frequent guest card, the Seasons Pass, which will serve two functions: 1. Track guest activities within FSH so that their preferences can be recorded. 2. Allow guests to collect points every time they stay at a Four Seasons property and use them towards service companies affiliated with Four Seasons, creating loyalty as a result. It will also aid individual FSH locations to better understand which facilities within the hotel or resort are the most sought after and will be able to segment the information based on the region of the world or type of consumer (leisure or business). Through partnering with external companies such as high-end car rental companies, airlines, and travel agencies, FSH will be able to offer guests a solution to every decision they may encounter during their stay. Thus the Seasons Pass and the networked database will ultimately be the bridge to building and maintaining positive guest relationships. Exhibit 1: Financial data for the Four Seasons Hotels EOY 1997 to EOY 1999: Exhibit # 2: Number of customers using multiple Four Season Hotels each year * Assumed average coverage rate through the year is based on information in case, The Roccoco New York Hotel by Anna S. Mattila. Using the rate accomplished by the Roccoco New York boutique hotel. ** As no information of number of customers per room is provided, one per room is assumed.

Mangment this is a paper for studying mangment in an academic setting for MBA Essay Example for Free

Mangment this is a paper for studying mangment in an academic setting for MBA Essay The factors that affect the productivity of PATs include the size of incentive bonuses paid to workers, base pay increases, perfect attendance bonuses, the size of the fringe benefits package, how favorably the overall size of a company’s compensation package compares with the industry-average compensation package, expenditures for PAT training and productivity improvement, and changes in the number of models. Perfect attendance bonuses, how much overtime is offered to PATs so as to boost their take-home pay, how many PATs are laid off, the percentage of newly-hired PATs, the percentage use of temporary PATs, and PAT compensation levels. P/Q ratings, the warranty claim rates, the amount of overtime, the percentage of cameras outsourced, and how many cameras are assembled each quarter. the complexity of the company’s camera designs; a company’s cumulative spending for new product RD, engineering and design; the number of models; camera body ergonomics/durability; and the number of camera components. PAT training and experience, the number of PATs laid off, base pay increases, warranty claim rates, and P/Q ratings †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. The interest rate a company pays on loans outstanding depends on its credit rating. How much it has borrowed against its credit line and its debt-assets ratio. How many consecutive years the company has been profitable, its current ratio, and its ROE Its net profit margins, ROE, and amount of cash on hand to make interest payments Its current ratio, global market share, debt-assets ratio, net profits, and balance sheet strength †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. The company maintains a production facility in the United States. Japan. China. Germany. Taiwan. The decisions that company co-managers make each year are organized around new product RD, components production, work force management, advertising and marketing, and finance. supply chain management, assembly, distribution, sales force management, advertising and marketing, customer service, and finance. components production and assembly, distribution and retailer relations, advertising and promotion, customer service, and accounting. supply chain management, components production, assembly, distribution and dealer relations, sales and marketing, and cash flow management. marketing and promotions, product design, assembly/shipping, compensation and labor force, and finance.

Development Using Different Methods Children And Young People Essay

Development Using Different Methods Children And Young People Essay When children and young peoples development is monitored and assessed, it enables practitioners and professionals to notice when children and young people are not progressing as expected. Therefore, if necessary checks can be made to see why children are not developing as expected may be due to impairment. When practitioners and professionals intervene in early years of the children, they will able to get appropriate support they need and their development and their welfare is promoted. Children and young peoples overall outcomes will be promoted significantly when professionals carry out early intervention. There are several methods of monitoring childrens development explained below:- Assessments frameworks Practitioners are required to carry out on going assessments through observations on a diary basis as its integral part of development and learning. Any learning and development needs of children and young people must be addressed by the practitioners with the parent/ carer and relevant professionals. Parents/ carers should be updated regularly with their childrens progress and development. Progress check at two: Practitioners should carry out a progress check when the child is aged between two and three. It should be carried out in the setting where the children spend more time and discuss how the summary of development can be used to support their learning at home. It is a written summary of the childs development in the prime areas. The practitioner must discuss with the parents and / carers how the summary of development can be used to support learning at home. It must reflect on going, regular observation of childrens development. The progress check at two enables practitioners and any other professionals to identify development needs early on in the childs life in order he/she gets the additional support needed. Assessment at the end of the EYFS the Early Years Foundation Stage Profile (EYFSP). EYFSP must be completed for each child in the final term when he/she turns five years old and should be before the 30th of June in that term. School must share the results of the profile with the parents / carers and relevant professionals. The profile provides details of the childs knowledge, understanding and abilities, their progress against expected levels and how ready they are for year 1. Observations. In settings, practitioners watch children play and watch how they are behaving. Some observations do not need the practitioner to interact with the children while in others it may be more appropriate for the practitioner to be involved in order to support learning and development. Observations play a very important part in assessing the childrens development. When practitioners carry out observations, they are able to get information about the childs development, interests and their interactions with friends and adults as well their level of concentrations. Standard measurements Different professionals use various standardized measurements to monitor and assess the childrens development. Growth / healthy assessments. These are used to measure and assess the childrens height, weight and head circumference. Auditory assessments. These assessments are used to monitor and assess the childrens levels of response. Reasoning assessments. These assessments are used to monitor and assess the childrens reasoning and they are carried out by educational psychologists. Cognitive aptitude assessments. These assessments are used to monitor and assess the childrens intelligence and they are widely carried out in schools. All the above tests help professionals to see how a child is performing compared to the large group/ population of other children in the same age group. Information from parents/ carers, colleagues and others. Practitioners should collect as much information as possible from parents/ carers when monitoring and assessing childrens development as the parents/ carers spend more time and are more attune with their children. They see the child in a variety of different situations hence have a lot to contribute and they are aware of their learning and behaviour outside the setting. They always have a different perspective. It is very important to also involve the child whenever possible. Key workers generally take lead role in monitoring and assessing their key children but colleagues who also work with the child should also be consulted as they may have different perceptions. (Walker 2011. p.117). CYP 3.1: 3.2 EXPLAIN THE REASONS WHY CHILDREN AND YOUNG PEOPLES DEVELOPMENT MAY NOT FOLLOW THE EXPECTED PATTERN. Children encounter issues in their lives that have a positive or negative influence on their lives and hinder them from following the expected pattern of development. As practitioners, we have the duty of care towards the children and young people to ensure that we improve their life chance by following the Every Child Matter outcomes, which are be healthy, stay safe, enjoy and achieve, make a positive contribution and achieve economic well-being. Physical factors The childrens/ young peoples genetics affects their development, which includes their physical growth and physical strength. Occasionally a reason for a child not attaining the usual pattern of development cannot be identified, even after professionals have investigated the influences on development thoroughly. One possibility is that its in the childs genetic makeup to have a slow start to their learning (Walker 2011 p.119). The social, economic and cultural factors. Personal choice Families may decide to live in a different way example travelling families. The children/ young peoples education may be affected if their families travel a lot and they may not settle in. This may stop children from following their expected development pattern. Some families bring up their children differently and some bring up boys differently from girls and this can affect the childrens development. Poverty Families live in poverty mostly due to unemployment and low income. Due to lack of money, families may fail to provide enough food to eat, clothes to wears, educational resources outside school and heat for winter for their children, which may affect their health and that of the parent. This might hinder the children/ young people to reach their full potential Housing and Community Children and young peoples development is greatly affected negatively if they live in poor housing conditions like living in a damp condition may cause health problems to the children that may affect their learning. Children and young people living in neighbourhood with anti-social behaviour may be affected negatively as they may be isolated or they may decide to join in and their development will be affected. Poor parental supervision/ neglect Children need guidance to learn how to behave well. If they do not get the guidance from their parent, they will misbehave at school because they do not understand the boundaries. Lack of boundaries may result in the children and young people being involved in crime and anti-social behaviour. Educational Environment If the setting does not reach the statutory requirement, this will affect the children and young peoples development and they will not achieve their full potential therefore they might be un able to follow the expected development pattern. Health status and Disability Children and young people with existing health condition or with disability may find it hard to fit in and if they are discriminated against, this will have a negative impact on their lives. Learning needs. Children and young people with learning difficulties and those with specific learning needs may not follow the expected development pattern as they may need a range of additional support with their learning and development, for example with writing , reading or maths. Children with Dyslexia they need support with their learning and development. Bereavement and loss Losing a loved one or pet can have a great impact on emotional and physical health. Children/ young people may find it hard to cope with the grief and this may affect their well-being. Religious beliefs and customs Children may be excluded from setting to attend specific settings due to their religious beliefs and customs therefore the children may miss out on some activities and this might have a negative impact on their live. Ethnic beliefs Children might feel isolated and discriminated against due to their ethnic belief and this will have a negative impact on their lives. Communication skills. Children and young people who have trouble with their communication, their learning and development will be impacted on and this leads to the children not following their expected development pattern. Communication development is linked closely to social, emotional and behaviour and intellectual/cognitive development. 3.3 EXPLANATION OF HOW DISABILITY MAY AFFECT DEVELOPMENT Practitioner should have a good knowledge of particular impairments and understand that the same impairment can affect each child differently. Therefore, practitioners must understand the children they are working with, how the impairment is affecting them in order to meet their needs appropriately. Practitioners should look for ways of increasing learning and development opportunities for children with disabilities. Social model of disability When society is not set up to meet the needs of people experiencing impairment, this implies that impairments give rise to disability. The society disables them, rather than enabling them (Walker 2011 p.285). National Occupational standards states that the social model considers that it is society that needs to change and that disabled people have rights and choices. Children with learning difficulties and impairment that affect their social and emotional development may find it had to interact with others and they will be unable to make friends and positive relationships. Society should change to give the children with disability an opportunity to participate in society and ensure that it meets the children and young peoples needs so as to achieve positive outcome. Medical model of disability In this model of disability people without a disability, they see the impairment of disabled people as a problem that needs solved or cured whereas some impairments have no cure. Medical model limits the opportunities for children and young people and this impact negatively on their learning and development. The children with long term medical conditions or physical disabilities may not achieve their full potential as they may miss educational opportunities due to their health, having to stay in hospitals and attending medical appointments. Low expectations When people/ societies have low expectations for children and young people with disability, they will be denied the opportunities they need to achieve their full potential. If children and young people with disability have low expectation of themselves they may not want to get involved and they will feel isolated and unable to fit in. Stereotyping. Children with disabilities may develop low self-confidence and self-esteem due to the stereotyping, discrimination and if the family members see them as a burden or have negative attitudes due to their lack of ability to cope with their disability. Cultural differences Children and young people may miss out on the chance to learn, play and work due to discrimination because of their disability as well as their background, hence unable to achieve a positive outcome. People from different cultures should be more understanding, accepting and encouraging to children and young people with disabilities. Due to lack of funds and resources, can hinder the children with disability having opportunities to experiences activities and achieve their full potential as meeting the needs of a child with disability can be very expensive and funded services vary from one local area to another. The benefits of positive attitudes to disability. Positive attitudes to disability helps the children with disability develop a positive attitude towards themselves and they will have high expectations for their life. The children and young people will have increased self-esteem and self-confidence, gain their independence and have a purpose in life. They will be able to achieve a positive outcome with their learning and development. Positivity can also help children and young people to develop resilience to counteract some of the negative attitudes that they will no doubt experience from others during their lives stereotyping and discrimination are prime examples. (Walker 2011 p.287). 3.4 AN EXPLANATION OF HOW DIFFERENT TYPES OF INTERVENATIONS CAN PROMOTE POSITIVE OUTCOMES FOR CHILDREN AND YOUNG PEOPLE WHERE DEVELOPMENT IS NOT FOLLOWING THE EXPECTED PATTERN. A number of professional agencies may become involved when children are identified as not following the expected developmental pattern. The professionals will all work together to support children and their families to ensure that children and younger people achieve their full potential. Children and young peoples outcomes can be improved when multi-agency approach is involved and this includes the children and young peoples development. Below are the professionals involved in the interventions with children. Professional/Agency Main area of responsibility Impact Types of intervention Behavioural Support Service (BEST) They work in partnership with provisions within the framework to include everyone. They promote good behaviour and provide support to children and young people, parents and settings. Behaviour impact the childrens and young people achievements. When children have positive behaviour they achieve at school. Recognising and managing their emotions and learn about relations. Improved educational outcome. Training of staff Advice on how to develop and review behaviour policies. Speech and language therapists. They are employed by the local Primary Health Trust. They assess and treat speech, language and communication problem to allow children to communicate to the best of their ability. Children being able to communicate with others. Meeting their individual development needs. Improved language skills. Settling better in settings and will to learn. Improved education outcome. They are referred from the GP or concern from the setting. Therapy Educating parents and staff. Promoting speech and language development through songs and rhymes involving children and parents. Physiotherapists. They help children who have problems as a result of injuries to rehabilitate and increase their movement and coordination, illness or for medical reasons. When the children and young people are rehabilitated. Improved movement. Treatment Range of motion exercise Electrical stimulation Strengthening exercise Soft tissue movement. Psychologists They help and support children with social, emotional problem or learning difficulties. They offer advice and giving counseling to children and parents. Being able to enhance the childs learning and enabling practitioners to be more aware of the social factors affecting childrens learning. Improved education outcome. Counselling Training Health Visitors. They are health professionals who help, support and educate parents on the way of preventing diseases through immunizations, good child nutrition, minor illness and behavior issues. They advice parents on health and child development. They do home visits and sometimes, they can be found in the local medical centre at least once a week. They support parents to ensure that children are protected from illness and they achieve their developmental milestones. Improve education and life outcome for children and young people. Identifying mothers suffering from depression. Reduced post-natal depression. Medical advice Training Home visits Parental training Social workers They are employed by social services. They provide assistance and advice to children, young people and families with health need, housing issues, and poverty. They support young people living care and those facing difficulties of any kind. Keep families together by giving them support. Children from care fulfil their full potential. Families getting the help they need. Crisis intervention Anger management Stress management Relaxation training Mid wives They offer health support to parents expecting a child/ children. Parent has a successful pregnancy and birth. Reduce the number of women smoking during pregnancy. Increased breast feeding. Increased parental confidence. Training Antenatal care. Pre- and post natal care. Birth plans Training Breast feeding training. Play specialist They are employed by the local Primary Health Trust. They make observations and assessments through play with children in hospitals to identify their needs and fears while in hospital. The children get full recover and play freely without any problems. Assessments Introduction of play Voluntary agencies and services These include local and national services like NSPCC. They support and give advice to children, young people and their families experiencing threatening situations. The families feel safe, secure and protected. They have a peace of mind knowing that they can get support and advice if they experience ant threatening behaviour. Training Support and advice Special Educational Needs Coordinator (SENCO). Works in the setting They have the responsibility to organise identification and support for children with special education needs Being able identify that a child has special education needs and the child being able to get the help they need early on in time. Referrals to respective professionals Support Psychiatrist They are doctors trained medically. They specialise in mental health. They diagnose and support children and young people with mental health problems. When the child and young person get all the support and treatment the y need. When they are able to lead a normal life afterwards. Counselling Training Awareness Nurse specialist They give advice and support to children, young people and their families on how to manage chronic conditions. They also measure and assess childrens development. When families are able to handle and manage chronic conditions. When families are able to get help in time if there are any underlining problems with their childrens development. Training Raising awareness Measurements and assessment of children development. Young justice teams. They work with children and young people with anti social behaviour in the community. They work hand in hand with the social workers. When the children and young people get the support they need to be model citizens. Recognising and managing their emotions and learn about relationships. Improved social and emotional skills, attitudes, behaviour and academic performance. Target offending behaviour Thorough assessments of children and young peoples individual needs. Offer structured programmes. Offer programmes that can work that meet the families needs. Additional learning support teams They help children with specific educational needs within early years provisions, schools and out of school. Children get the support and education to achieve their development goals. Improved learning outcomes. Training Awareness Support Assistive technology Children and young peoples development can be supported by using a range of technology. A voice activated computer programme will assist children and young people with delayed fine motor skills with writing. Children and young people with difficulties walking may use the latest wheelchairs so as they are able to achieve their development goal and be more independent. Physiotherapists, speech and language therapists and sensory impairment support professionals have the responsibility to choose the right type of assistive technology for children and young people. http://www.ehow.co.uk/socialworkers (16.02.2013) http://www.physiotherapy.notes.com (16.02.2013) http;//www.surreycc.gov.uk/social-careand health (17.02.2013) http://www.nfer.ac.uk/nfer/publications (17.02.2013). Tassoni, P., Beith, K., Bulman, K., Griffin, S. (2010) Children and Young Peoples Workforce. Early Learning and childcare. Level 3 Diploma. Essex: Heinemann. Walker, M. (2011) Children and Young Peoples Workforce. Early Learning and Childcare. Level 3 Diploma. Cheltenham: Nelson Thornes.

Macbeth :: essays research papers

  Ã‚  Ã‚  Ã‚  Ã‚  At the beginning Shakespeare presents Macbeth as a sort of hero. He is presented as a great warrior and loyal servant of the king, Duncan. However, as we progress through the play we see another side of Macbeth. This is the side of evil all powered by his unstoppable lust for power and greatness. We see this lust for power become stronger and stronger until he leaves the whole of Scotland in a terrible state.   Ã‚  Ã‚  Ã‚  Ã‚  The play starts with the witches talking about Macbeth and what a great warrior he is. In Shakespeare’s time witches were thought of as evil and the fact that they were talking about Macbeth made the audience make the connection between Macbeth and evil. The witches also give the audience the setting of the play and the story so far. They tell the audience about the battle in which Macbeth is fighting and that they will meet Macbeth on his return.   Ã‚  Ã‚  Ã‚  Ã‚  When the king hears of Macbeth’s heroics in battle he is very pleased and refers to him as â€Å"valiant cousin, worthy gentleman.† The king also presents Macbeth with the title of the Thane of Cawdor. This just adds to Macbeths already great status and shows him to be even more of a hero. This is backed up again by the sergeant who refers to him as â€Å"brave Macbeth† and â€Å"Valour’s minion.† Ross also admires his bravery by referring to him as â€Å"Bellona’s bridegroom.†   Ã‚  Ã‚  Ã‚  Ã‚  The first time we see Macbeth is when he arrives on the heath where the witches are settled. Even before Macbeth appeared for the first time we had quite a clear picture of him. The first words Macbeth speaks, â€Å"So fair and foul a day I ne’er have seen† mirror the first words we hear from the witches. When Macbeth meets the witches they seem to know a lot about him and start implanting the idea of becoming king in his mind. Macbeth is taken aback by the witches and their prophecies which suggests that Macbeth has thought about it before and is frightened that his secret has been uncovered.   Ã‚  Ã‚  Ã‚  Ã‚  When the messengers arrive with the news that Macbeth has earned the title of Thane of Cawdor this acts as a catalyst in his lust for power and quest to become king. The contrast between Macbeth and Banquos attitude towards the prophecies shows how Macbeth has great ambitions and is starting to think about killing the king.

White Heat :: essays papers

White Heat White Heat clearly belongs within Shatzs category of genres of order. How far do you agree with this statement? This is an exiting essay to write for a number of reasons. For one it is an honour to follow in the footsteps of Raul Walsh understanding the motivations that brought him to direct White Heat in the way he did it. For another reason is wonderful having the possibility to describe it through the Shatz^s module that can describe perfectly every aspect of a selected movie. Because it is essentially a narrative system, a film genre can be examined in terms of its fundamental structural components: plot, character, setting, thematics and so on. Shatz divided Hollywood film genres in two main categories, these are distinguished by completely different characteristics. As he said: ^Each genre represents a distinct problem-solving strategy that repeatedly addresses basic cultural contradictions^ (Shatz, 1948: 34). He defined certain genres like screwball comedy, family melodrama, musical and so on as rites of integration. Those films are centred upon a doubled or collective her! o set into a ^civilised^ space, the main problems are emotional and the resolution is always by love. Other genres centred on an individual male such as Western, gangster, detective, etc. appertain to the genre of order category. The protagonist (individual male) ^is the focus of dramatic conflicts within a setting of contested, ideologically instable space. Conflicts within these genres are externalised, translated into violence, and usually resolved through the elimination of some threat to the social order^ (Shatz, 1948: 34). At the end of the film the protagonist always leaves the contested space either by his departure or death and he always maintains his individuality and he doesn^t learn about values and lifestyle of the community. The principal thematics within this genre are the mediation-redemption, the male macho code, isolated self-reliance and utopia-as-promise. White Heat is a classic gangster and was directed, as I said, by Raul Walsh in 1949. It stands at the crux between the 1930^s gangster movies and the post^war film noir. The plot is briefly this: James Cagney plays Cody Jarrett, a psychotic who dreams of being on "top of the world". Inadvertently leaving clues behind after a railroad heist, Jarrett becomes the target of federal agents, which send an undercover agent (O^Brien) to infiltrate the Jarrett gang. While Cody sits in prison on a deliberately trumped-up charge (he confesses to one crime to provide him an alibi for the railroad robbery), he befriends Fallon (O^Brien), who poses as a hero-worshipping hood who's always wanted to work with Jarrett. Busting out of prison with Fallon, Jarrett regroups his gang to mastermind a

Animal Farm: Utopia :: Animal Farm Essays

Animal Farm: Utopia The definition of Utopia is "no place." A Utopia is an ideal society in which the social, political, and economic evils afflicting human kind have been wiped out. This is an idea displayed in communist governments. In the novel, Animal Farm, by George Orwell Old Major's ideas of a Utopia are changed because of Napoleon's bad leadership. Old Major explains his dreams and ideas to all the animals before he dies. At his speech all the animals go to hear what Old Major has to say. This happens on the night that Mr. Jones comes home drunk. Old Major explains his ideas to all the animals: Man is the only creature that consumes without producing. He does not give milk, he does not lay eggs, he is too weak to pull the plow, he cannot run fast enough to catch rabbits. Yet he is lord of all the animals. (p.19) This speech gets all the animals riled up and sends the toughts of getting rid of man. Old Major then teaches them the song the Beasts of England which teaches them the "great" life without man and with no more bad leaders: Beasts of England, beasts of Ireland, Beasts of every land and clime, Hearken to my joyful tidings, Of the golden future time. Soon or late the day is coming, Tyrant Man shall be o'erthrown, And the fruitful fields of England, Shall be trod by beasts alone. Rings shall vanish from our noses, And the harness from our back, Bit and spur shall rust forever, Cruel whips no more shall crack. Riches more than mind can picture, Wheat and barley, oats and hay, Clover, beans, and mangel-wurzels Shall be ours upon the day...(p.22-23) After the song the animals were even more excited. They sing the song so loud it wakes Mr. Jones up. Mr. Jones starts firing his gun into the darkness. This quickly scatters the animals. Three days later Old Major dies so Snowball and Napoleon take over but Napoleon wants all the power. Snowball does a lot of research and planing but Napoleon wants to take over completely by himself. So Napoleon frames Snowball so he can become the leader. Orwell tells about the meeting to discuss the windmill: By the time he had finished speaking, there was no dought as to which way the vote would go. But just at this moment Napoleon stood up and...uttered a high pitched whimper of a kind no one had ever heard...nine enormous dogs wearing brass studded collars came...they dashed strait for snowball. (P.57) This scene shows Napoleon is a tyrant and wants all the power to himself and

The Ada and Disability Related Harassment

The Americans with Disabilities Act (ADA) and Disability-Related Harassment A Self-Advocacy Guide 3839 North Third Street Suite 209 Phoenix, AZ 85012 602-274-6287 (voice or TTY) 800-927-2260 (toll free) 602-274-6779 (fax) 100 North Stone Avenue Suite 305 Tucson, AZ 85701 520-327-9547 (voice) 800-922-1447 (toll free) 877-327-7754 (TTY) 520-884-0992 (fax) www. azdisabilitylaw. org [email  protected] org This guide was written by former University of Arizona, College of Law students: Kraig Gardner, Kevin Lira, Ryan McCarthy, Ruth Mendus, Cathy Nelson and Denise Quinterra.Funding for this document is provided by the United States Department of Health and Human Services, Administration on Developmental Disabilities and Community Mental Health Services and the United States Department of Education, Rehabilitation Services Administration. Federal and state law can change at any time. If there is any question about the continued validity of any information in the handbook, contact the Ariz ona Center for Disability Law or an attorney in your community. The purpose of this guide is to provide general information to individuals regarding their rights and protections under the law.It is not intended as a substitute for legal advice. You may wish to contact the Arizona Center for Disability Law or consult with a lawyer in your community if you require further information. This guide is available in alternative formats upon request. Revised 100307 E-8 1 The Americans With Disabilities Act (ADA) and Disability-Related Harassment TABLE OF CONTENTS A. Disability-Related Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 1 1.Scope of this Guide †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 1 2. The Difference Between Disability-Related Harassment and Common, Everyday Harassment. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 2 3. The Difference Between Disability-Related Harassment and Retaliation. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 2 4.Other Types of Discrimination †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚ ¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 3 B. Proving Disability-Related Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 4 1. Introduction †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 4 2. Elements of a Claim †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 3. Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 4 C. The Rules About Employer Liability For Disability-Related Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 8 1. Introduction. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 8 2. Owner Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 3. Supervisor Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 9 4. Co-Worker Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 10 5. Non-Employee Harassment†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã ¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 10 D. E. F. G. Duty to Employees to Avoid or Limit Harm †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 1 Employer’s Responsibility to Prevent/Stop Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 12 Steps to Take If Your Employer Does Not Take Appropriate Action †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 13 Introduction to the Americans with Disabilities (ADA) and this Guide†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 15 1. What Does the ADA Cover? †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 15 2. How Does the Arizona Center for Disability Law Assist People with Disabilities? †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 16 3.Why Does the ADA Include Employment Protections? †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 16 4. When Do the ADA Employment Protections Apply? †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 17 5. What Employers are Covered by the ADA? †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 18 H. Legal Resources†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚ ¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 19 A. Disability-Related Harassment 1. Scope of this GuideThis guide is meant to explain and describe: (1) Harassment based on disability; (2) when an employer is liable for harassment, and (3) some ways of dealing with harassment. The ADA protections described are available only to people who are qualified individuals with a disability under the ADA or who are harassed because of an association with a person with a disability (for example, a parent, son, daughter, friend, or co-worker of a person with a disability). If you are uncertain whether you are protected under the ADA, the Center has a guide that explains the meaning of the words, disability nd qualified. The title of that guide is, An Overview of the Employment Protections of the ADA. This guide is not intended to inform you about all employment-related claims, only those having to do with disability-related harassment under the ADA. This guide does not cover: à ¢â‚¬ ¢ retaliation; †¢ state law protections, such as worker’s compensation claims; †¢ tort claims related to harassment; or †¢ criminal claims related to harassment. Rasool works at a restaurant. He has a psychiatric illness. Several of his co-workers were very prejudiced and afraid of him because of his disability.To try and harass Rasool, they spraypainted his car with the word â€Å"crazy† and slashed his tires. Rasool’s co-workers may not only be harassing him in violation of the ADA, but also may have committed a crime. This guide does not cover criminal law and penalties. Report criminal conduct at the workplace to your employer. Your employer should report crimes to the police. If it does not, you should report crimes directly. Josefina has cerebral palsy. Her supervisor calls her offensive names related to her disability frequently and in front of all other employees.Josefina is humiliated and distressed by this treatment. She suffers phy sical symptoms, such as ulcers, that may be related to the treatment. Her employer may be in violation of the ADA. Josefina may have other state claims for emotional distress, including worker’s compensation. This guide does not provide information about these kinds of claims. For more information, contact a private attorney handling worker’s compensation. Visit the Arizona State bar directory at www. azbar. org for a list of attorneys specializing in worker’s compensation. 2. The Difference Between Disability-Related Harassment and Common, Everyday Harassment. The ADA was created to provide workers with disabilities a â€Å"level playing field† in the workplace. It requires employers to provide accessible facilities, to make special accommodations to the needs of protected workers, and to have employment practices that do not discriminate. The ADA also prohibits harassment based on disability, just as other federal laws prohibit harassment based on race, gender, national origin and religion.It is important to understand the difference between harassment and disability- related harassment. The law does not protect workers with disabilities, or any workers, from rude or uncivil people. The harassment must be severe and related to a person’s disability for the ADA to offer protection. Jane has a hearing impairment. She sometimes has problems understanding what people say to her. Dan is her supervisor. Dan is not a very pleasant person. He is constantly calling Jane and other workers lazy and slow. He often screams and yells when things do not go smoothly on the production line.Jane feels like Dan does not like her and the other workers. Dan may be harassing Jane in the common everyday meaning of harassment. Unfortunately, even though Dan’s behavior is not how we would like to see supervisors behave, it is not disability-related harassment. Let’s look at a situation that is very similar to the one in the first exam ple. Jane has a hearing impairment. She sometimes has problems understanding what people say to her. Dan is her supervisor. Dan is not a very pleasant person. He is constantly calling Jane and other workers lazy and slow.He also makes comments to Jane like â€Å"what’s the matter, didn’t you hear me? † and â€Å"can’t you understand anything? I thought you were deaf, not stupid. † Here, Dan’s harassment is related to Jane’s disability. It doesn’t matter if Dan is mean and rude to everyone else as well. When Dan’s harassment is severe and focuses on Jane’s disability, it is disability-related harassment. Making hostile comments is not the only form of disability-related harassment. Offensive jokes about persons with disabilities and offensive gestures and behavior can also be disability-related harassment. . The Difference Between Disability-Related Harassment and Retaliation. Another kind of treatment that is comm only confused with disability-related harassment is retaliation. Retaliation is adverse action taken against an employee because the employee (1) 2 opposed action by an employer that violated the ADA, or (2) participated in filing a formal complaint with the Equal Employment Opportunity Commission or the Arizona Civil Rights Division of the Attorney General’s Office. An employer can use â€Å"harassment† to retaliate.For example, an employer can harass an employee because the employee requested an ADA accommodation. An employer could also retaliate by harassing an employee who filed an ADA charge of discrimination when denied a promotion. Both retaliation and disability-related harassment violate the ADA. It is useful to know the difference between retaliation and harassment when you are making a complaint to the EEOC. Bob has paraplegia. He uses a wheelchair. Sue is Bob’s supervisor. Part of Bob’s job includes occasionally going to the room where the old files are stored to get these old files.Some of the files are on high shelves that Bob has trouble reaching without help. Bob asked Sue if someone else could do the job of getting the old files. Sue said no. Before this, Bob had never had any problems with Sue. Bob decided to make a request for an accommodation to the department head, who is Sue’s boss. Sue was furious. She yelled at Bob for 15 minutes and told him that if he ever went above her head again that she would â€Å"make him sorry†. She asked him to withdraw his request for an accommodation. Bob refused.During the next week, Sue began to ask Bob to do things that had never been part of his job before. She started asking him to deliver papers all over the building. Bob had no problem doing this because the building was wheelchair accessible, but it took him quite a bit longer than it would have anyone not in a wheelchair because the accessible elevator was on the other side of the building. Sue complained to Bob that he was taking too long to do these deliveries. Bob tried to explain why it took him longer to deliver the papers, but Sue wasn’t interested.Bob tried to do the deliveries faster, but Sue wrote him up when he took longer than 15 minutes. After being written up 3 times in the next week, Sue fired him. When Bob complained to the EEOC, he told them he was harassed in retaliation for requesting an ADA accommodation. 4. Other Types of Discrimination Sometimes, other types of discrimination feel like harassment. When an employer treats a person differently because of his/her disability in any of the conditions or terms of employment, it may feel like harassment.For example, if a person with a disability has been working for the company for many years and has never been permitted to go to a training to improve his skills, yet employees with less company seniority are often sent to training, this may be discrimination in the terms of employment. For more information about yo ur right as a person with a disability to equal treatment, see the Center’s guide, â€Å"An Overview of the Employment Protections of the ADA. † In addition, when an employer refuses to make changes to the work or workplace so an individual can do his/her job or enjoy the benefits of employment, it may be an unlawful failure to accommodate. For more information about your rights regarding accommodations, see the Center’s guide, â€Å"The ADA and Reasonable Accommodations. † B. Proving Disability-Related Harassment 1. Introduction The ADA does not include a specific prohibition against harassment. Most courts looking at this issue have decided that the ADA prohibits disability-related harassment because of disability because employers must prevent discrimination in the terms and conditions of employment.This means employers must prevent a hostile workplace. 2. Elements of a Claim To prove unlawful harassment under the ADA, you must be able to prove the fol lowing: †¢ you work or formerly worked for a covered employer; †¢ you are a person with a disability; with a record of a disability; or are regarded as disabled; †¢ you are or were qualified to perform your job; †¢ you faced a hostile work environment; and †¢ you were harassed by a co-worker or a third party and your employer knew or should have known about the harassment.George’s co-workers suspect he is HIV-positive because he is gay. They spray painted his locker with the words â€Å"God’s punishment† and hung plastic gloves around the office for people to use to avoid physical contact with George. George does not have HIV but he is still protected under the ADA from disability-related harassment, as he is â€Å"regarded† as a person with a disability. 3. Harassment The harassment is so severe that it changes the conditions of your employment and creates an abusive working environment or results in a tangible employment action. The conditions of your employment must change when someone harasses you because of your disability. The conditions of your employment may change because the workplace is hostile or because of an â€Å"employment action. † Either change may support a claim of harassment under the ADA. 4 Hostile Work Environment. A disability-based harassment claim under the ADA means that your workplace is so full of discriminatory intimidation, ridicule and insult toward you that it has become an abusive place to work. These claims are called â€Å"hostile work environment† claims. The ADA does not rohibit simple teasing, offhand comments and isolated incidents. To decide if the harassment is â€Å"severe† or â€Å"pervasive† enough to create a hostile work environment, courts look at: †¢ †¢ †¢ †¢ whether the discriminatory conduct has happened only once or many times; how bad the treatment is; whether it is physically threatening or humiliating; and w hether it unreasonably interferes with your ability to work. Occasional hurtful remarks by co-workers will not usually be severe enough for a successful ADA claim, unless the occasional treatment develops into a pattern of abusive treatment.Even if some co-workers refuse to talk or associate with a disabled individual, it may not be enough to support an ADA claim for harassment because courts recognize that employers cannot force employees to get along with each and every other employee. Juanita is deaf. Her co-workers ignore her and don’t try to learn any signs so she can talk to them on breaks or at lunch. It is a simple fact that in a workplace, some workers will not get along with each other. A court will usually not find â€Å"cold shouldering† enough for an ADA claim.However, in another example, Juanita’s co-workers tease her by moving their fingers at her as though they were using sign language. The co-workers pretend they are talking to her by making mou th movements just to confuse her. She is called â€Å"deaf and dumb† by people at work. Neither her co-workers or supervisor will write notes to her about important things she needs to know at work. Juanita may have a claim for disability harassment and failure to accommodate by writing notes. Generally, one instance of harassment will not amount to discriminatory changes in the â€Å"terms and conditions of employment. However, even a one-time event may be severe enough to create a hostile work environment. The standard a court uses to decide if conduct is unlawful is whether a reasonable person would find the action offensive. 5 Because of a disability, Alberto needs to use two crutches with wrist straps in order to walk. He works evening shifts as a telephone solicitor. Alberto usually sets his crutches beside his desk while he is working. One night, two co-workers decided to pull a prank on Alberto. They took his crutches nd hid them. They told the other workers what the y were up to, including the assistant manager, who was in charge of the night shift. Then they pulled the fire alarm. Alberto heard the fire alarm and looked for his crutches so that he could exit the building. His crutches were gone and he did not know the alarm was a prank. The other employees acted like they were leaving the building and exited the floor. They left him alone for 30 minutes. When he tried to crawl to the exit, they came back and laughed at him.Even though this only happened once, Alberto most likely has a claim for disability-related harassment because this conduct was so severe any reasonable person would find it offensive. Tangible Employment Action. The conditions of your employment will also change when the harassment results in an â€Å"employment action. † Harassment that results in a tangible employment action will be enough to show severe harassment. A â€Å"tangible employment action† means an important change in your employment status, not just a minor change.It usually causes you direct economic harm, and most of the time can only be caused by a supervisor or a person acting with the authority of the company. Examples of tangible employment actions may include: T firing; T failure to promote; T demotion; T a reassignment that you did not want; T a significant change in your benefits; T a decrease in your pay; T a negative change in your work assignment; T a dramatic increase in your workload; T reassignment to a position that reduces earning capacity; T reduction in hours; T refusal to grant reasonable leave requests.Javier has a severe type of diabetes. He needs to take insulin at certain times and sometimes needs to eat small snacks. He asked his supervisor for an accommodation of a 15 minute break every two hours. Shortly after the supervisor found out about Javier’s disability, she reassigned him to a different department. If Javier’s salary and benefits are the same, and the supervisor only reassig ned him because the other department already has 15 minute breaks every two hours, that probably would not be an ADA violation.However, if the supervisor told Javier that she was reassigning him because she was personally bothered by needles and did not want him taking shots in her department, that would be a tangible employment action and Javier would have a claim of disability-related harassment under the ADA. 6 The mere threat of an employment action is not enough to support an ADA claim. The harassment must be unwelcome. Jaime is deaf. He works at a department store in the shipping and receiving department. Jaime and his supervisor Erin have a professional relationship.On a frequent basis, Erin makes uninvited and offensive remarks about deaf people. Jaime has been subject to unwelcome harassment. Aheem is blind. He works at a restaurant as a cashier. Aheem and his co-worker Brian, who is overweight, are constantly making fun of each other’s conditions in a good natured w ay. One day while they are teasing each other, Brian makes a joke about blind people. Because of the nature of their relationship, Aheem has probably not been subject to unwelcome harassment.The harassment must be based on your disability, your association with a person with a disability or your request for an accommodation. The person who is harassing you must be doing it because of your disability or your need for an accommodation. It is not enough that they harass you because they do not like you or because they harass everyone. Maria is a person who has cerebral palsy. She works for a local fast food restaurant. The assistant manager is named Fred. Fred yells at Maria and the other employees frequently. Sometimes he curses.He says things like: â€Å"Hurry the ____ up! † and â€Å"What the ____ is taking you so long? † Even though most people would agree that Fred should not talk to the employees that way, unfortunately Maria will probably not have an ADA claim if t he evidence shows that Fred uses abusive language with many employees, not just Maria, and that he acts no more harshly toward Maria than he does to anyone else. This is probably not harassment that violates the ADA. However, if Fred only yells and curses at Maria and not at other employees, alls Maria offensive names like â€Å"Spaz† and â€Å"Retard†, and treats her differently than other employees, this may be harassment that violates the ADA. 7 C. The Rules About Employer Liability For Disability-Related Harassment 1. Introduction. Employers are generally responsible to provide a work place that is free of serious offenses and abuse that are based on a person’s disability. For example, employers should not permit a work place where a worker who is mentally retarded is called â€Å"retard,† is not allowed to eat with co-workers, or is subjected to co-workers’ offensive mimicking.Owners of a company, supervisors, managers, co-workers and third pa rties, such as customers, can speak or take action that creates a hostile work place. An employer is responsible for the workplace no matter who causes the hostile environment, but the courts understand that employers may not know about the harassment unless it is reported. Courts have created different rules about harassment, depending on who does the harassing. Below is a chart with examples. If the harasser is a(n): then the employer is liable for Unless the employer can show the harassment when that Owner, manager, stockholder, the harassment occurs.CEO, or president Supervisor the harassment occurs and results in a negative employment action. the harassment occurs and causes a hostile working environment Supervisor Co-worker the employer knew or should have known about the discrimination. the employer knew or should have known about the discrimination it took reasonable steps to prevent and to quickly stop harassing behavior and the employee unreasonably failed to take advantag e of the employer’s efforts to prevent or stop the harassing conduct or to avoid harm. t took immediate and appropriate corrective action. Non-employees (e. g. , customer, student, sales personnel) it took immediate and appropriate corrective action. 8 2. Owner Harassment Companies are made up of people. Some people, such as owners, CEOs, directors, and stockholders â€Å"are† the company. When people who are the company harass, the company is automatically liable for the harassment. Albert & Sons owns a restaurant that employs 40 part- and full-time employees. J. E. Albert, one of the owners, is also the restaurant manager.Lydia has worked as the Director of Catering for the restaurant for 8 years. However, she develops breast cancer and must have a mastectomy and chemotherapy. When she returns to work on a half-time basis, J. E. Albert makes numerous offensive remarks including â€Å"She’s not a real woman anymore† and speculates out loud whether  "can she satisfy her husband. † He leaves photos of well-endowed women on her desk and bulletin board. He does this frequently and over many months. It is not necessary that Lydia reported the harassment because the harasser is a co-owner. . Supervisor Harassment Because a supervisor is given direct authority over an employee, the employer is responsible under the ADA for harassment by that supervisor. An individual is an employee's supervisor if he or she: a) has the power to make or recommend employment decisions affecting the employee, and b) directs the employee’s daily work activities. Whether a harasser is a supervisor is determined by his or her job function, not his/her job title. Jim, an individual living with HIV, works in a â€Å"team† environment.His â€Å"team leader† has made several derogatory comments about Jim's illness and has even gone so far as to say that it is not worth making the effort to promote Jim. The team leader makes recommend ations regarding promotions. In this situation, the team leader is a supervisor. An employer is always liable for harassment by a supervisor if that harassment results in some sort of employment action (e. g. , firing, change in work assignment, reduction in pay or hours, etc. ) This is because an employer is responsible for the acts of its supervisors; and employers should be encouraged to prevent harassment.However, even if an employment action does not result from the harassment, an employer may be liable if the harassment creates a hostile work environment. The employer will be liable for a hostile work environment created by a supervisor unless the employer can show that: (1) it took reasonable steps to prevent and stop harassment, and (2) the employee unreasonably failed to use the employer’s steps to correct or prevent the harassment. 9 Bette supervises the nursing assistants at a nursing home. One day she sees Joe, a nursing assistant, take some medication with his lu nch.She asks him what type of medication he is taking, and he voluntarily tells her he is taking prescribed medicine to treat his bipolar condition. From that day on, Bette treats Joe badly. She calls him â€Å"crazy,† â€Å"looney,† and a â€Å"nutcase† in front of patients and staff. When things get busy at work, she asks if he is â€Å"going to crack under the pressure. † On breaks, she asks him if â€Å"he has ever had shock treatment† or â€Å"tried to off himself. † She also tells other workers she hopes he will just quit before he screws up.The nursing home is liable for Bette’s harassment unless the nursing home can show they had a complaint procedure and would have promptly stopped Bette’s harassment, but Joe unreasonably refused to complain. 4. Co-Worker Harassment An employer is liable for a co-worker’s harassing conduct if it knew or should have known of the co-worker's misconduct, unless it can show it took immediate and appropriate corrective action. Ingrid is deaf. Her co-workers often mimic her, force her to speak, and make derogatory comments about her deafness.Her work environment has become a hostile one. This situation has continued for approximately 6 months at the same level of â€Å"hostility†. Ingrid mentioned the problem several times to her shift supervisor. Ingrid's supervisor is aware of this situation and should have taken some sort of corrective action (possibly sensitivity training and discipline of offending employee), but it has not happened. Her employer is liable for the harassment by her co-workers because it has not taken any steps to correct the action. Sara is a sous chef at a restaurant.She took some medical leave for a hospitalization related to suicidal tendencies due to severe depression. When she returned to work, a small group of her co-workers had learned about the reason for her leave and began taunting her. One day, all the knives at her work s tation were hidden and a note was left that no one wanted her to hurt herself. Another instance involved a bottle of candy pills that were left spilled all over her purse. Sara reported it but the management did not investigate or take any steps to correct it. The employer is liable for the harassment. . Non-Employee Harassment An employer is liable for a non-employee’s harassing conduct if it knew or should have known of the non-employee’s misconduct, unless it can show it took immediate and appropriate corrective action. In most places of employment, there are other people who enter a workplace or are part of a workplace who are not employees. For example, a store, movie theater, restaurant or gallery will have patrons and customers. Also places of employment may have 10 independent contractors who work at the facility.For example, a hospital may employ nurses, nurses aides, medical clerks and therapists, but the doctors are independent contractors and not employees. To become responsible for the non-employee’s harassing conduct, the employer must know about it. This is because it is more difficult for an employer to be aware of all of the day-to-day events at a workplace, particularly when they involve non-employees. Jarod teaches 7th-8th graders language arts/history at a private school. The students come to believe that Jarod is gay and jump to the conclusion that he is HIV positive or has AIDS.The students spray paint offensive references to HIV in the men’s bathroom. The school did not repaint the wall for over a month and did not investigate the students believed to be involved. The school will likely be liable for the harassment caused by the students. D. Duty to Employees to Avoid or Limit Harm In general, an employee facing harassment from a supervisor (not an owner) has a duty of reasonable care. This means that as an employee, you must use all available means of prevention provided by the employer to avoid harm.Failure to do this could result in the employer escaping its legal liability or possibly being required to pay less money if there is a judgment against it. As an employee, you must be aware of the opportunities made available by your employer to employees (such as a grievance procedure) to report problems and use them if faced with workplace harassment. However, there are certain situations in which failure to use the procedures might be considered reasonable. For example, if the employee reasonably believes that: the employer does not have a complaint system that has been given out r made available to employees; Julie is a full-time cashier in a major department store. She is hard of hearing and requires the use of a hearing aid. After a month, Julie is periodically bothered by fellow employees, who poke fun at her and use her hearing impairment as a subject for their jokes and harassment. Julie wants to approach her supervisor about the situation, but is unaware of any avenues for her ha rassment complaint. As a new employee, she has not been made aware of any complaint system.There is nothing posted in the employee’s lounge or in the materials given to her by her employer. Julie’s employer has a duty to make all employees aware of the existence of a complaint system. In this instance, Julie’s failure to make a complaint would probably be reasonable. a risk of retaliation exists for those who use the complaint process; 11 Sophie is faced with harassment. She wants to file a complaint with her supervisor. However, the supervisor and the harasser are close friends. Sophie is concerned that her complaint will not be given the proper attention.The procedure does not offer any exceptions for making a complaint to someone other than a supervisor. She does not file a complaint, and the situation continues. In this case, Sophie may have acted reasonably by not filing a complaint. obstacles to complaints were present; James is autistic and cannot read or write. He works as a dishwasher. The cooks and other dishwashers make fun of him. He wants to complain and tells his supervisor about the problem. His supervisor tells him he will only accept a formal written complaint and does not offer to help him write his complaint.James has not failed to take reasonable steps. the process for complaints was ineffective. Shop-Mart has a written harassment policy that is available on-line. All new employees are provided training about the complaint procedures. Anyone can come to the training room to look at the policy on-line. Jerry wants to complain about customers who taunt him and treat him badly because he is an amputee, but his store manager has a well-deserved reputation for never checking into complaints and telling people to work it out for themselves.Also, several of Jerry’s co-workers were marked poorly on their evaluation for not getting along with others after they made a complaint of harassment. Jerry is probably acting reaso nably when he does not use these procedures. Generally, it is better to put your complaint in writing so that you can later prove that you did let your employer know about the harassment by a co-worker, supervisor, or non-employee. You should also send a copy of your complaint to the owner or director of the company.However, at times there may be other reasons you might be justified in not making a complaint. For advice, call the ADA Employment Advice Line or a private attorney. E. Employer’s Responsibility to Prevent/Stop Harassment An employer has a duty to act reasonably to prevent and correct any harassment. The most effective way of exercising this duty is through an effective complaint procedure provided to all the employees in the workplace.If written and used properly by the employee, the employer can, in some cases, discourage harassment before it takes place and, in other cases, address it immediately to limit the harm. To meet its duty, an employer should establish , publicize, and enforce anti-harassment policies and complaint procedures. It is the EEOC’s position that all policies should be clearly 12 understandable and accessible to all employees in the workplace. In addition, an employer should provide extra training focusing on harassment so that all employees will be made aware of these policies.The EEOC advises that an employer’s complaint procedure should: provide a clear explanation of conduct that is against the law; assure employees who make complaints of harassment or provide information related to such complaints that they will be protected against retaliation; describe a complaint process that provides accessible avenues to make a complaint; be flexible about the format of the complaint; assure that the employer will protect the confidentiality of harassment complaints to the extent possible; make accommodations in the complaint process as needed for people with disabilities (e. . , large print policy for visually i mpaired employee; an interpreter to interview an employee who is deaf and complaining about harassment; provide a prompt, thorough, and impartial investigation; and assure that the employer will take immediate and appropriate corrective action when it determines that harassment has occurred. The policy should focus on the prevention of harassment. An effective policy of antiharassment provides employees with protection so that they may avoid potential harassment before it happens.The complaint procedure should also encourage employees to report instances of harassment. It should be set up to prevent employees from being intimidated by reporting these incidents. One effective method to avoid intimidation is to have employees report complaints to other employees who are outside of the direct line of command. An employee will be more willing to report harassment if he/she does not have to go through a â€Å"higher-up† who was directly involved in the incident.The policy should a lso contain information on important dates and deadlines for filing a complaint with the EEOC. Even if your employer does not have a harassment policy, you should report harassment by a co-worker, supervisor or third party to your employer. F. Steps to Take If Your Employer Does Not Take Appropriate Action Practical Tips to Help You Deal with Harassment check any materials you were given as an employee or that are available to all employees (e. g. , internet site) to see if there is a procedure for reporting discrimination and harassment to your employer; 13 f there is no procedure for reporting complaints, see if there is a procedure for reporting any problems and use it; keep a journal of what has been done to you, by whom, when, how often, where and how this affected your ability to do your job; be specific about the harassment that occurred; even if you are not sure whether the misconduct is offensive enough to be unlawful ADA harassment, you can still report it. It gives your e mployer a chance to stop offensive conduct before it becomes unlawful. alk with a trustworthy friend or a hotline for support†¦problems at work can be hard to live through, and sometimes it can seem like you're imagining things; if you are not afraid of the harasser, talk to the offender and tell them the behavior is offensive and keep notes of this conversation (and date them); talk to your supervisor or another person in authority and tell them what's happening; put your complaint in writing; use the ‘legal' words defined and explained in this guide so your employer will have a clear idea of what you are requesting; and send a copy of the complaint to the management or owner of the company.Keep in mind that in most cases of harassment (except by owner, CEO, director, etc. ), the employer is not liable unless he/she knew or should have known about the harassment. This means that in general it is a good idea for employees to report the harassment to the company. If there is a complaint procedure for reporting harassment, you should use the procedure to notify the company. Get Legal AdviceOne way to get brief legal advice is to call the Arizona Center for Disability Law at 1800-927-2260 (toll-free statewide) or at (602) 274-6287 in the Phoenix area, to an experienced advocate or attorney who can provide you with information about the protections of the ADA. If you want more information, you may request copies of the Center’s self-advocacy guides about the employment protections of the ADA and sign up for a free legal training in Tucson or Phoenix. Information about the guides and training is available at www. zdisabilitylaw. org. The Center can also provide you with lists of attorneys who practice employment law in Tucson and Phoenix. File a Charge of Discrimination You can also file a charge of discrimination with the U. S. Equal Employment Opportunity Commission (EEOC). â€Å"Charges† are complaints of discrimination. You can do it im mediately or wait until you have first complained to your employer. The EEOC will investigate your charge and determine whether there is reasonable cause to believe 14 discrimination has occurred.It will then issue a right to sue letter in all cases (except for the few selected cases in which it will file a lawsuit). In Arizona, the Civil Rights Division of the Arizona Attorney General's Office (ACRD) will also take your charge. You do not have to pay to file a charge with these offices. You can call (800) 669-4800 (voice) or (800) 669-4820 (TTY) for the EEOC or (520) 628-6500 for the ACRD in Southern Arizona. You must file a charge with the EEOC or the ACRD to be allowed to bring a lawsuit for employment discrimination based on disability.You have 180 days to file a charge under state law and up to 300 days to file under federal law. For more complete information about filing a charge, please see the Center's guide â€Å"How to Enforce Employment Rights under the Americans with Di sabilities Act. † Before you go to the EEOC or ACRD, please read the guide. G. Introduction to the Americans with Disabilities (ADA) and this Guide 1. What Does the ADA Cover? On July 26, 1990, the ADA was passed by Congress. The ADA provides major civil rights protection to individuals with disabilities.The intent of this federal law is to reduce barriers to persons with disabilities and provide equal opportunity in employment, public accommodations, public services, transportation, and telecommunications. The various titles of the ADA affect many aspects of the lives of people with disabilities. †¢ Title I makes it unlawful to discriminate against qualified people with disabilities in employment. †¢ Title II makes it unlawful for state and local governments and their agencies to discriminate in programs and services, including public transportation. Title III prohibits discrimination in access and enjoyment of public accommodation and commercial facilities, such as hotels, motels, restaurants, professional offices, doctor’s offices, lawyer’s offices, convention centers, stores, banks, museums, parks, schools, and recreation facilities. Title IV requires accessibility of telecommunication services to hearing impaired persons and other individuals with disabilities. Title V provides for recovery of legal fees and establishes a mechanism for technical assistance.Additionally, Title V includes a provision prohibiting either (a) coercing or threatening or (b) retaliating against the disabled or those attempting to aid people with disabilities in asserting their rights under the ADA. †¢ †¢ 15 2. How Does the Arizona Center for Disability Law Assist People with Disabilities? If you believe you have been discriminated against on the basis of a disability in employment or access to public services, public accommodations, public transportation or telecommunication services, staff at the Arizona Center for Disability Law can prov ide you with information about the ADA and enforcing your rights under the ADA.The Arizona Center for Disability Law is a non-profit, public interest law firm providing fee advocacy, information and referral services, legal research, community legal education, and, in selected cases, legal representation to individuals with disabilities and advocacy organizations throughout Arizona. The Center is the designated protection and advocacy (P&A) system providing services for Arizonans with a wide range of physical and mental disabilities. Assistance is provided for disability-related issues in established priority areas. Information about the eligibility requirements and priorities are available from the Center upon request.Assistance is provided according to program eligibility requirements, priorities and staff availability. This Guide is Not a Substitute for Legal Advice! The Arizona Center for Disability Law recommends that persons obtain professional legal advice to resolve a legal dispute regarding discrimination on the basis of a disability. This guide is not a substitute for legal advice. This guide is meant to provide people with disabilities with information and examples about employment protections under the ADA. The information in this guide is based in part on court cases interpreting the ADA.Courts in the various parts of the country interpret the ADA differently. Not all of this information may be true for people living outside of Arizona. 3. Why Does the ADA Include Employment Protections? Oftentimes, people with disabilities do not have an equal opportunity to work or advance in their employment. People with disabilities are often restricted in employment opportunities by many different kinds of barriers. Some face physical barriers that either make it difficult or impossible to get into and around a workplace or to use work equipment at the site.Some are excluded because they communicate differently than their co-workers. Still others are excluded because of rigid work schedules which do not permit flexibility for people with special needs because of a disability. In other cases, people are not denied opportunities because of actual barriers, but because of prejudice. These are the barriers in other people's minds: fears, stereotypes, presumptions and misconceptions about job performance, safety, absenteeism, costs or lack of acceptance by coworkers and customers. 16Congress enacted the ADA to eliminate these barriers to equal opportunity in employment. The ADA makes it unlawful for an employer covered by the law to discriminate against applicants and employees with disabilities. The United States Equal Employment Opportunity Commission (EEOC) is responsible for enforcing this law. People with disabilities also have the right to bring private lawsuits against employers who discriminate against them if they first file a charge of discrimination with the EEOC within the time limits set out by the ADA.See the Center's guide, Ho w to Enforce Your Employment Rights Under the ADA, for more information about how to file a charge. However, the U. S. Supreme Court recently ruled that private individuals may not sue state employers for money damages under the ADA. Individuals may still file charges of discrimination with the EEOC against their state employer for other relief, such as court orders to stop discrimination. The U. S. Government can still file lawsuits against states for violating the ADA.The list of guides available through the Center about employment rights under the ADA include: O An Overview of the Employment Protections of the Americans with Disabilities Act (ADA) The ADA and the Job Applicant The ADA and Reasonable Accommodations The ADA and Drug Testing How to Enforce Employment Rights Under the ADA The ADA and Medical Examinations The ADA and Confidentiality of Medical Information Taking Action–How to File a Charge When You’ve Been Treated Unfairly by an Employee Because You Have a Disability How to Ask Your Employer for an Accommodation That You Need Have you been Treated Unfairly at Work?O O O O O O O O O 4. When Do the ADA Employment Protections Apply? The ADA does not cover every employment situation between an applicant and an employer or an employee and an employer. For the ADA to apply to an employment arrangement, each of the following has to be true: †¢ the employer is covered by the ADA; †¢ the employee or applicant has a disability according to the ADA; †¢ the employee or applicant is qualified to perform the job; and †¢ the employer discriminates against an applicant or employee on the basis of disability. 17For more information about each of these requirements, see the guide, An Overview of the Employment Protections of the ADA. 5. What Employers are Covered by the ADA? The ADA applies to private employers with 15 or more employees. †¢ Includes employment agencies and labor unions. †¢ Includes a location or facilit y of a business with less than 15 employees whose total number of employees for the company in all locations and facilities combined equal 15 or more. Other laws may apply to persons with disabilities who are employed by smaller businesses.For more information, contact the Arizona Center for Disability Law or a private attorney. †¢ The ADA applies to state and local governments. Includes all state and local governmental agencies, departments and entities regardless of their size or number of employees. Although the ADA applies to state employers, the U. S. Supreme Court recently ruled that employees (and applicants) can not sue state employers in court for money damages. Individuals can still file charges of discrimination with the EEOC against their state employer. Individuals can still sue to require state employers to take action or stop discriminatory action.The U. S. Government can still file lawsuits against state employers under the ADA. Examples of state and local emplo yers include: public schools, public universities, police and fire departments, public libraries, museums, public parks and recreation facilities, and social welfare offices. The ADA does NOT apply to the federal government. The ADA does apply to employees of the U. S. Senate. However, generally if a person with a disability works or applies for a job with the federal government, a federal agency, or a fully owned U. S. Government corporation, then the ADA does not apply.However, the Rehabilitation Act of 1973 is another anti-discrimination law that offers employment protections. For more information about that law, contact the Arizona Center for Disability Law or an EEO officer of the federal agency where you work or a private attorney. Title I (Employment) of the ADA does NOT apply to Indian Tribes. Tribes may have their own affirmative action or anti-discrimination laws which may address discrimination on the basis of disability. Some tribes have adopted tribal laws or entered in to agreements to abide by federal discrimination laws similar to the ADA. 18 †¢