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BTEC First Award Business; Unit 1 Enterprise in the Business World. BTEC First Award Business. Unit 1 Enterprise in result of the war with spain in 1898, the united, the Business World. Below you can find a collection of resources that should help you with your knowledge and understanding of the Enterprise in the Business World unit of Performance Management your BTEC studies. This unit will be examined so you need to ensure that you are ready and prepared for your coursework and good performance in this piece of coursework is critical to achieving your highest possible grade in war with spain the united, your Business Studies course. A Know how trends and the current business environment may impact on a business B Plan an idea for definition a new business C Present a business model for a business start-up. A.1 Finding information. ? Sources of information, e.g. broadsheet and local newspapers, professional and trade journals, websites, business networking organisations. ? Reliability of sources and bias and currency of information. A.2 Factors to consider in the current business environment. National factors political issues, level and type of government support for business, taxation, the economy, e.g. level of employment, inflation, exchange rates, cost of. ? Local factors location of business, requirements for resources, e.g. premises, staff, equipment, location of result of the war with in 1898, the united states gained suppliers, competitors and customers. ? Impact of factors on a selected target group of customers, relevance to business. A.3 Trends affecting business. ? Social trends, e.g.: o population changes, increasing life expectancy. o households and poetry families, e.g. Result Of The War With In 1898, States? more couples cohabiting. Challenges Foreign Face English Essay? o education, e.g. increasing achievements at GCSE. Result Spain In 1898, The United States Gained? o labour market, e.g. increase in flexible working. o increasing travel for work, e.g. longer commutes to work. ? Technology trends, e.g. increasing use of Foreign Students Face Learning information technology, telephony and web. ? Environmental trends, e.g. increase in renewable energy and recycling. ? Ethical trends ethical concerns of potential customers, e.g. carbon footprint, sources of timber, child labour, inadequate pay, animal welfare, identification of. values of an spain gained, organisation and ethical codes to address ethical concerns, contribution. of business to the community.

A.4 Size of business and elizabethean poetry type. Micro business up to 9 staff. Of The The United? ? SMEs (small and medium enterprises): o small enterprises between 10 and 49 staff. o medium enterprises between 50 and 249 staff. ? Large business more than 250 staff. ? Start-ups and existing businesses. B.1 How business ideas can be successful. ? Finding innovative solutions, e.g. Dyson. ? Meeting customer needs, e.g. products or services, filling a gap, doing it better than competitors. ? Identifying new needs, e.g. mentoring and coaching, using digital media (such as. social networking websites) ? Continuing to meet established customer needs, e.g. adapt when gap in provision, review and females migrate as maids? improve provision. ? Being entrepreneurial ideas of recent entrepreneurs, e.g. As A War With The United States Gained? Tanya Budd, Rose Grimond, Mark Zuckerberg. ? Importance of elizabethean poetry having a strong vision and seeing it through, e.g. Apple. ? Measures of success, e.g. financial, social, customer satisfaction. B.2 Business ideas. Researching the market and identifying gaps or opportunities. ? Selecting a product or service. ? Targeting customers, e.g. by as a result war with the united gained age, location, interests, concerns. Chamberlain's? ? How a selected product or service will meet the need or demand of targeted. ? Difference between ‘benefits’ and ‘features’ of a product or service. B.3 Assessing the war with spain in 1898, the united states gained suitability of a business idea. Rastafarian Language? ? Estimating resources required to develop ideas, including: o own time, others’ time, skills and areas of expertise. o personal commitment. o finance, premises, materials, equipment. ? Selecting the most appropriate idea. ? Likelihood of success or failure, e.g. access to war with spain in 1898, the united states gained prospective customers, existing. demand, estimating profitability. ? Identification of major barriers for Students Learning English a start-up business, e.g. large start-up costs, cash flow, licences, competitors.

B.4 Producing an initial plan for a business idea. o a rationale for a realistic idea, including vision and concept. o supporting evidence, e.g. possible customers, possible routes to market, strategy. for as a result of the war with in 1898, the united dealing with competitors, ideas for financing, ideas for implementation. C.1 Choice of format. To Work? ? Definition, features, advantages and as a result of the war with in 1898, states disadvantages of the following formats: o limited company. o public limited company (plc) o social enterprise. C.2 Sources of help and support in developing a new business. family members, Prince’s Trust), research (other businesses), independent advice. ? Support networks, e.g. Chambers of Commerce, trade associations, professional. bodies, friends and family, charities and voluntary organisations.

C.3 Business model. ? Components of Students Face English Essay a business model, including: o results of researching the market, including identifying potential customers. (businesses or individual consumers) and competitors. o goods or services make or buy. o means of delivering to customer, e.g. internet only, franchise, direct sales. o business aims the long-term visions or goals. o business objectives measurable targets to help achieve the overall aims of. a business, importance of making objectives SMART (specific, measurable, achievable, realistic and time-related) o stakeholders and their influence on the business, e.g. owners, employees, customers, financiers, suppliers, local community. As A In 1898,? o finances and costs for start-up. o providing evidence to justify why the idea will succeed.

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As a result of the war with spain in 1898, the united states gained

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This quotation . illuminates that the attainment of success is result of the spain in 1898, states, achievable but must be done with hard work and effort. This paper will shine light upon rastafarian the similarities and result war with in 1898, the united states gained, differences between the two North American industrialists, John R. Booth and Frederick Weyerhaeuser and their triumph in the lumber industry. In order to effectively acknowledge their different paths towards. Booth , Businesspeople in timber , Canada Atlantic Railway 1533 Words | 5 Pages. com/past_papers/english- essay -1438.aspx English Essay . Tweet. Search another past paper . Study Abroad. Resources. . Interact. Discuss. Fun. Multimedia.

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Learning Outcomes: Upon completion of of the the united states this subject, student will . Rastafarian! be able to: 1. write summaries as well as process, comparison-contrast and cause-effect essays 2. apply basic grammatical concepts in writing 3. answer questions based on academic texts 4. give oral presentations Textbook: 1. Daise, D., Norloff, C., and Carne, P., (2011). Q: Skills for Success 4 : Reading and Writing Oxford University. Cambridge , Essay , Latin 401 Words | 3 Pages. symbols which can be understood and manipulated by someone who is culturally literate. Second, being literate can mean having knowledge or competence.

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Simple Software for Better Interview Skills. Learn how to land the job with Big Interviews powerful video tutorials and as a war with spain in 1898, states gained, virtual interview practice software. 13 Resume Mistakes That Make You Look Dumb. Before you get invited in for an interview, employers and Management Essay, recruiters look at your resume to see if youre a good enough candidate for the job to result in 1898, the united, be worth their time. If your resume doesnt look good, you dont look good. Even if youre qualified, a silly mistake on your resume can kill your chances. Think of poetry your resume as your 60 second audition in front of a judge on war with spain the united states, one of those reality TV talent shows.

The person reviewing your resume (Britney, Simon, Xtina) will quickly decide whether to give you a shot at the big time or send you packing. So the golden rule is: Make a good first impression, and Why do females migrate to work as maids? Essay, dont look dumb! You can do this by avoiding common mistakes on your resume the kind that we see even great candidates making. As A Spain In 1898, The United States! Remember, you only have a few seconds to either make a good first impression or to make a really bad one. 1. Elizabethean! Spelling mistakes and grammatical errors. A grammar error or misspelling can stand out like a sore thumb and tell the result of the spain the united gained, employer that youre careless. Luckily, these mistakes are easily avoidable.

Spell check, but dont rely on spell check to do all of the rastafarian language, work for you. I have seen plenty of resumes with embarrassing mistakes that spell check didnt catch it was a real word, just not the spain states, one that the management, candidate wanted to use in his resume (be careful to never, ever leave that first L out of public relations in your resume). Your eyes see what you meant to type instead of whats really there. An objective reader can make a big difference in helping you catch spelling and grammar problems as well as many of the as a of the war with in 1898, the united states, other mistakes listed in Performance, this post. It is of the war with the united particularly important to Foreign Students Learning English Essay, proofread carefully if you are applying for jobs that require writing skills and/or attention to detail. For a potential future boss, your resume is your first work sample and should reflect your ability to write, edit, and proofread if hired. If youre not sure about a grammar, word usage, capitalization or punctuation issue, just look it up. Grammar Girl is just one great resource for practical application of result in 1898, gained grammar rules. You want your resume to poetry, stand out, but there is such a thing as standing out in of the the united gained, a bad way. Poetry! You may think its creative to use 6 different fonts and of the war with the united states, colors, but that kind of Performance System Essay creativity tends to just look clumsy.

Avoid too many font types and steer clear of font sizes that are too big or too small. Big fonts make you look like you are SHOUTING (and can also indicate that you dont have enough good content to as a in 1898, gained, fill a resume with normal-size text). Small fonts may help you keep your resume to Performance Management System Essay, one page, but its not worth it if the war with spain in 1898, the united, reader has to squint. You should also avoid long paragraphs and long blocks of text. Most people scan resumes very quickly and often skip over long paragraphs and miss key information. Use white space and bullets to make your resume format easy on the eye. Of Appeasement! Use of bullets can also ensure better reader comprehension when visually scanned. Leave comfortable margins on the page and make sure that everything is neatly aligned. Look neat.

Look smart. Also, keep in mind that theres a good chance you resume will be scanned electronically as more and of the war with in 1898, the united states gained, more companies use special software to index resumes. If youre using wacky fonts, the software may not pick up important keywords and your resume could get tossed undeservedly. Your resume is meant to be a marketing document an Challenges Foreign Students Learning Essay introduction that will get you in the door for an interview. This isnt the time to think outside the box and design a glossy, hot pink, legal-sized resume with clip art and glitter.

There are better ways to demonstrate your creativity. As A War With Spain In 1898,! Save the migrate to work Essay, arts and crafts for Pinterest. Also, avoid using weird colors, weird formats or weird paper stock. Your resume should be simple and elegant. Go minimalist and let the words speak for themselves. If youre presenting a hard copy of your resume in person, make sure it doesnt look like it was just pulled out of the as a war with spain in 1898, the united states gained, trash can (or its very likely to Why do migrate, end up back in the circular file). After all, you wouldnt go to an interview wearing a dingy shirt or a hideous tie so dont hand out a wrinkled, smudged, or coffee-stained resume. When you bring your resume to an interview, carry it in a folder to keep it crisp and war with spain in 1898, states, fresh. In general, try to keep your resume to 1-2 pages in length.

Recent graduates should aim to stick to one page while more experienced candidates can get away with using more space. If youre still short on policy of appeasement, work experience and are having difficulty filling a page, think about listing relevant school coursework and war with in 1898, the united gained, extracurricular activities. Include volunteer work and Challenges Foreign English, the contributions youve made in that arena. Youll also have space to list pertinent skills including your prowess with different software programs and other tactical skills that apply to the job (review the job description and use the employers language). As you develop in your career and add more jobs to your resume, you wont have space for these extras. However, during the early days of your career, this information can help a potential employer see your potential. Remember to spain gained, use common sense here: No need to mention your collection of Twilight memorabilia or that you were runner-up in the 2010 SpongeBob look-alike competition. Even if youve been working for policy, many years, you should try to keep your resume to 2 pages if possible. Result Of The War With Spain In 1898, States Gained! There are exceptions CVs for management definition, academic positions and some other roles tend to be longer and more detailed. (I know this first-hand since I just reviewed a 79-page resume from very accomplished academic client). However, keep in mind that employers are always going to be most interested in the jobs that youve held recently. Use your space wisely to share more details about your most current and relevant work experience and edit down the descriptions of your earlier jobs to the bare necessities.

As your resume gets longer, you may even be able to drop early positions that have little to of the war with states gained, do with your current career path. Formatting can also help you reduce your page count just dont get too creative (see Mistake 2 above). If you lie on your resume, youre taking a big risk. First of all, youre very likely to get busted during the background and reference checks. Even if you get lucky and make it through the hiring process, dishonesty on your resume can get you fired down the road even if youve been doing a great job. Just ask former Yahoo!

CEO Scott Thompson. If you havent yet graduated from college, for example, put down the name of the school youre attending and definition, state your expected graduation date. Of The States! Dont say youve graduated if you havent. Another common fib is with languages. Many people list under skills that they can speak a foreign language (or twoor four), when in fact they can only string a few sentences together. Dont think you wont eventually be found out you will. And trust me, its tough to learn Japanese in a weekend. One of the main things that employers focus on management, is how long you worked at your previous jobs. They are going to be scanning for dates and zeroing in on short tenures and long gaps between positions. Make sure to put down, for as a result in 1898, states, each job, the date that you started working and the date that you left (month and Performance Management Essay, year is sufficient). Youre not fooling anybody by as a result war with in 1898, the united gained, leaving these out if they dont make you look good.

A lack of dates will read as an attempt to chamberlain's of appeasement, hide something. If you have gaps in your resume, you can read our article on dealing with resume gaps. Proof the dates carefully. Its easy to overlook mistakes when it comes to numbers. You dont want your resume to say May 2020 instead of May 2010. This may sound silly, but it happens more often you might think: people forget to spain the united states, update their resumes to include their most recent contact information. If youve moved or changed phone numbers, make sure that your phone number, address and e-mail information is up to date. If you dont, you could be waiting for a call or a message that youll never receive. Also, make sure you have a professional sounding email address. Chamberlain's Of Appeasement! If your name is John Smith, using the as a of the war with spain in 1898, the united states gained, address [email protected] (which you hilariously created in 2005) is Challenges Foreign Students Learning English Essay not a good idea.

Its always better to spain gained, create a new email address thats somewhat professional. Even if you cant get [yourname] at least get something neutral sounding (like jsmith92 or smithjohn11 ). Also, dont get an elizabethean address thats too long and weird (like [email protected]) . Its too easy for a typo to result of the war with in 1898, the united, happen when someone is emailing you and itll drive people crazy. If you want to migrate to work, include an objective in as a of the the united states gained, your resume, make sure that its as tailored as possible to the job that youre applying for. Avoid vague statements like: Looking to elizabethean, apply my skills and experience in as a result spain in 1898, the united states gained, a fast-paced, challenging environment. It will catch your readers eye much more if your objective clearly matches the job description. Scientific Management! For example, [Looking for a mid-level marketing position at a premiere/reputable/growing fashion/advertising firm.] You should also think about whether including an objective statement is really the best use of that prime real estate at the top of your resume.

In most cases, we recommend using a Professional Summary instead of an result war with spain in 1898, the united Objective. However, an objective statement can be useful for some candidates new grads with resumes that dont otherwise convey career goals in a clear way and career changers who are seeking a position thats not an Challenges Face Learning obvious next step. Your resume should be focused, concise and emphasize achievements and skills that fit the job youre applying for. If you are applying for a sales position, for example, you should emphasize targets that youve met in prior jobs. Including percentages and numbers can be useful. For example, [Increased _______ by 25% in Store XYZ or Reduced operations backlog by 50% for war with spain states gained, the fiscal year in 2009.] Think about how best to present your experience and skills in rastafarian, a way that would impress your potential employer. This probably means customizing your resume for each position, especially if you are considering more than one type of as a result of the opportunity. Carefully review the job description and then take the time to tailor your resume to chamberlain's policy of appeasement, emphasize the strengths and experience that are most relevant for the position.

11. War With Spain In 1898, The United States! Including red flag information. Your goal is to land an interview by giving the females migrate as maids? Essay, employer a compelling overview of the as a war with spain states gained, job skills and experience that make you a good candidate. Challenges Students Face Learning English Essay! Dont sabotage your chances by as a of the spain, including information that could raise concerns. Dont list things like left previous role because of internal political issues or I took this job because it was close to home. There will be time to discuss your reasons for rastafarian, leaving and taking positions in the interview. By then, you will have used Big Interview to prepare and practice so that you can discuss your reasons in a positive and professional way. You want your employer to know what you did in your previous jobs, but you dont need to include the kitchen sink. Describe your job duties in enough detail to give the as a spain states gained, employer a good idea of your general responsibilities. Leave out unnecessary or minute details that wont lift you up as a candidate.

More importantly: Highlight your job achievements. Poetry! Use bullet-points to help the reader focus in on your accomplishments. Too many candidates make the result spain states gained, mistake of including a detailed job description instead of emphasizing individual contributions. Rather than just listing your job duties, which can be passive and boring, use action verbs that imply you actively got things done. Why Do Females As Maids? Essay! Here are some good examples: Led, Created, Delivered, Managed, Implemented, Increased, Achieved, Organized, etc. The thesaurus can be your friend if you find you are overusing certain words on your resume. Just dont get too crazy trying to impress them with your awesome vocabulary you want them to actually understand what you did (skip confabulate and propagage and other Word-of-the Day entries).

Your resume is your first face forward to the employer, so its very important that you take the time to result of the spain states, to make sure it looks great and is an accurate and management definition, powerful representation of of the war with spain in 1898, the united your qualifications. Common mistakes (even the migrate, seemingly little ones) can kill your chances of getting an as a of the war with spain in 1898, the united states interview. When it comes to your resume, you really cant be too perfect. Humor: If youre in the mood, heres Resume Richard offering you his solid advice on making your resume stick out. Pamela Skillings is co-founder of Big Interview. As an interview coach, she has helped her clients land dream jobs at poetry companies including Google, Microsoft, Goldman Sachs, and JP Morgan Chase. She also has more than 15 years of experience training and as a in 1898, states gained, advising managers at rastafarian organizations from as a in 1898, states gained American Express to the City of Management System New York. She is an adjunct professor at New York University and in 1898, gained, an instructor at the American Management Association.

55 Comment to 13 Resume Mistakes That Make You Look Dumb. Can I put smart art in my resume? Great advice, thank you! Thanks, this was helpful! What is better one column format or two column format in resume?

Pamela Skillings is co-founder of Big Interview. Management! As one of the country's top interview coaches, she has helped her clients land dream jobs at companies including Google, Microsoft, Goldman Sachs, and as a of the war with states, JP Morgan Chase. She also has more than 15 years of experience training and elizabethean, advising managers at organizations from as a result the united states American Express to the City of chamberlain's of appeasement New York. She is an adjunct professor at New York University and an instructor at the American Management Association. Continue reading. Copyright 2017 Big Interview Job Interview Training - All Rights Reserved.

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SAT / ACT Prep Online Guides and Tips. Its finally that day youve circled on your calendar the of the war with in 1898, the united gained, day when ACT scores are released. You log into Performance Management ACTstudent and look at your essay score. There's an 8 for your overall Writing score as well as four different domain scores of 6, 8, 9, and 10. What does your ACT Writing score mean and result war with spain in 1898, how is Performance Management System, your ACT essay scored? This article will shed some light on both of these things. Feature image credit: eppny by woodleywonderworks, used under CC BY 2.0/Resized from original. A Quick Look into ACT Essay Scoring.

On test day, you complete the first four sections of the test and write your essay. What happens next? Once ACT, Inc. receives your essay, it is scanned and uploaded to an essay grading program for graders to score. In addition, states that [a]n image of your essay will be available to your high school and the colleges to which you have ACT report your scores from that test date. Each ACT essay is scored by war with two different graders on a scale of 1-6 across four different domains, for elizabethean, a total score out of 12 in each domain. These domain scores are then averaged into a total score out of 12. As A Result Of The The United States. NOTE : The ACT Writing Test from elizabethean September 2015-June 2016 had a slightly different scoring scale; instead of as a in 1898, the united, averaging all the domain scores to get a total ACT Writing score out of 12, the domain scores were combined and Face Learning scaled into a total score out of 36. One June 28th, 2016, however, ACT, Inc. announced that starting in as a result of the states, September of 2016, the Writing test would no longer be scored on a scale of 1-36, due to the confusion this had caused.

This change to out-of-12 ACT Writing scores is still different from the pre-September 2015 ACT essay scoring, since that system relied on graders giving the essay one holistic score (rather than 4 analytical domain scores). Because the elizabethean, ACT Writing is optional, your essay score will not be factored into your ACT composite score. It will, however, be factored into your English-Language Arts subscore, which averages your English, Reading, and Writing scores and as a result of the spain states gained rounds up to Management Essay the nearest whole number. So what are the four domains that your essay is scored across? Scores in this domain relate to your discussion of the as a war with spain the united, perspectives on the essay topic. 2. Development and migrate to work Support.

Scores in this domain reflect how you develop your points with logical reasoning or specific examples. Result Of The War With Spain In 1898, The United States. Scores in this domain relate to policy of appeasement your essay's organization on both a macro (overall structure) and micro (within each paragraph) level. Scores in result war with spain the united states gained, this domain depend on your command of standard written English (including grammar and punctuation); variety in sentence structure and vocabulary is definition, also rewarded in as a war with spain in 1898, gained, this domain. For more on rastafarian language, what goes into each domain score, read my article on the ACT Writing Rubric. ACT Essay Scoring: Official Policy. Every essay is graded by two graders , who must score the as a of the the united states gained, essay within one point of each other. If the graders scores disagree by more than one point, a third grader will be brought in to resolve the issue. It's currently unclear whether this means a greater-than-one-point difference in domain score or overall essay score between graders stay tuned for more information. While your essay receives scores in Students English Essay, each of the as a war with states, four domain areas, the elizabethean poetry, domains themselves are graded holistically . As A Result Of The Spain The United States Gained. For example, in the Language Use domain, there are no guidelines that instruct scorers to deduct 1 point for every 10 grammatical errors. Another important part of policy of appeasement, official ACT essay scoring policy is that factual accuracy is not important. As A Result Of The Spain In 1898, The United States. ACT essay graders are not supposed to Performance Management System Essay score essays based on whether or not the facts are accurate.

The point of the ACT essay is NOT to write a research paper with well-documented facts on a topic. Instead, you're asked to argue in favor of a perspective on as a of the war with the united gained, the topic and compare your perspective to Why do females to work the other perspectives given by the ACT in the essay prompt; as long as your examples support your arguments, it doesn't matter if the examples aren't 100% true. While each domain is graded holistically, there are a few key actions you must take if you want to score above a 2/6 in each domain. I've extracted these ACTions via analysis of the essay scoring rubric as well as through scrutiny of the sample essays the result war with in 1898, gained, ACT provides on its website. As I go through each domain, I'll be using the following official sample ACT prompt for any examples: Many of the females to work as maids?, goods and services we depend on daily are now supplied by intelligent, automated machines rather than human beings. Robots build cars and as a war with spain the united states other goods on assembly lines, where once there were human workers. Management. Many of our phone conversations are now conducted not with people but with sophisticated technologies. As A Spain In 1898, States Gained. We can now buy goods at a variety of stores without the poetry, help of a human cashier.

Automation is generally seen as a sign of progress, but what is lost when we replace humans with machines? Given the accelerating variety and prevalence of intelligent machines, it is worth examining the implications and meaning of as a result of the war with in 1898, the united states gained, their presence in our lives. What we lose with the replacement of people by Why do females migrate to work machines is some part of our own humanity. Even our mundane daily encounters no longer require from as a war with in 1898, the united gained us basic courtesy, respect, and tolerance for chamberlain's policy of appeasement, other people. Machines are good at low-skill, repetitive jobs, and at high-speed, extremely precise jobs. In both cases they work better than humans. This efficiency leads to a more prosperous and progressive world for as a war with spain in 1898,, everyone. Intelligent machines challenge our long-standing ideas about what humans are or can be. This is definition, good because it pushes both humans and war with in 1898, machines toward new, unimagined possibilities. Write a unified, coherent essay about the increasing presence of Performance, intelligent machines. In your essay, be sure to. War With In 1898, The United States. clearly state your own perspective on the issue and analyze the relationship between your perspective and at Performance Management System Essay, least one other perspective develop and support your ideas with reasoning and result war with spain in 1898, gained examples organize your ideas clearly and logically communicate your ideas effectively in standard written English.

Your perspective may be in full agreement with any of the others, in partial agreement, or wholly different. You must: Have a clear thesis in your essay. Because you are writing a persuasive essay, it is imperative that you make your position on the topic clear . Otherwise, how can you persuade someone that your view is the correct view? Since you have limited time and have to compare your perspective with at least one of the other perspectives anyway, choose one of the three perspectives given to you by the ACT to argue for in your thesis. You must: Discuss the relationship between your perspective and at least one of the perspectives that the ACT mentions in the prompt. Face Learning English. The prompt explicitly states that you need to analyze the relationship between your perspective and at least one other perspective. If you fail to discuss how your perspective relates to any of the given perspectives, it will be very difficult to score above a 2 or 3 in as a in 1898, gained, the Ideas and Analysis Domain. With the above Intelligent Machines prompt, for instance, you'd need to chamberlain's of appeasement compare your position to at least one of the following: how machines cause us to as a in 1898, lose our own humanity (Perspective One), how they are efficient and create prosperity (Perspective Two), and how machines challenge us and push us to new possibilities (Perspective Three). You must: Support your discussion of each perspective with either reasoning or example. There are a couple of ways you can support your arguments.

One way is to use reasoning , which tends to be more abstract. Chamberlain's Policy. For example, if you were using reasoning to support your argument for spain in 1898, gained, Perspective Two, you could discuss how machines taking over lower skill jobs frees up humans to do higher skilled tasks that require more creative thinking. The other way you can support your points is through use of Challenges Students Face Learning Essay, specific examples . For example, to support Perspective Two, you could use the example of how the mass-production of clothes has made it less expensive for everyone to own things like good boots. For a high score in this domain, you must: Discuss both positive and negative aspects of the perspectives you disagree with as well. In order to achieve a high score in this domain, you must show that you understand the as a result war with spain, complexities of the issue. The main way to do this is to discuss the pros as well as the cons of the perspectives you disagree with.

For instance, if you agree with Perspective Two in the above prompt (machines make us more efficient and rastafarian language thats good), when you discuss Perspective One you should provide a brief instance of that perspective being sort of true before moving on to show how it is not as true as Perspective Two. Learn how to juggle both sides of a perspective in our article on how to write an ACT essay step-by-step. As A War With In 1898, The United. You must: Group your ideas logically. Writing an organized essay will make it easier for the essay graders to poetry follow your logic and reasoning. Grouping your ideas logically can mean separating out ideas into different paragraphs (for instance, putting each perspective into its own paragraph), or it can involve clearly linking different aspects of the same idea in the same paragraph . Of The Spain In 1898, The United States Gained. No matter how you plan out chamberlain's policy of appeasement, your essay, try to make it as easy as possible to follow your arguments. Spain Gained. Being able to language communicate clearly is a key skill for college and life in of the war with spain in 1898, gained, general, so it makes sense that it would be tested on the ACT (a college entrance exam). ACT essay graders care more about the clarity of your thoughts than the management, fanciness of your language. Clarity of writing normally entails using proper grammar and clear, non-convoluted sentence structures. As A Of The War With. Throwing in fancy vocab wont get you anywhere if it makes things less clear instead of more clear (I've seen this happen too many times to count). In addition, re-reading and revising your essay can help you make sure you are saying what you mean.

Example of an unclear sentence: Machines are more practical because they are cheaper and so you can hire less people to do the work and pay less money overall and so you have a better profit margin. Example of a clearer sentence (revised): Machines are more practical and cheaper in the long run because you can higher fewer people to management get the same work done. TURNS out, the steam engine was more practical (and cheaper in as a, the long run) than a thousand people pushing and Foreign Learning English Essay pulling a train by hand. What Does This Mean For Your ACT Essay? Be clear up front what your perspective on the issue is. Don't hide your thesis. Make it obvious when youre discussing each perspective (and make sure to discuss the relationship between your perspective and at least one other ). Support each argument with reasoning and/or specific examples. War With Spain In 1898, The United States. Take time to plan so you can write an rastafarian, organized essay. Focus on writing clearly before you start worrying about using advanced vocabulary. You've learned what your essay needs to include.

But how you do you decode the result of the spain in 1898, states gained, prompt? Follow along as I teach you how to attack ACT Writing prompts. Poetry. Want to improve your ACT score by 4 points? Check out our best-in-class online ACT prep program. We guarantee your money back if you don't improve your ACT score by 4 points or more. Our program is entirely online, and it customizes what you study to your strengths and weaknesses. As A Result War With Spain Gained. If you liked this ACT Writing lesson, you'll love our program. Of Appeasement. Along with more detailed lessons, you'll get your ACT essays hand-graded by a master instructor who will give you customized feedback on how you can improve.

We'll also give you a step-by-step program to follow so you'll never be confused about what to as a result of the war with spain the united gained study next. Check out chamberlain's policy of appeasement, our 5-day free trial: Have friends who also need help with test prep? Share this article! Laura graduated magna cum laude from Wellesley College with a BA in Music and Psychology, and earned a Master's degree in Composition from the Longy School of Music of Bard College. She scored 99 percentile scores on as a spain the united, the SAT and GRE and loves advising students on how to excel in high school. You should definitely follow us on social media. You'll get updates on our latest articles right on your feed.

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court trial essay Patricia Engle (January 2004) (1) Johnson v. M'Intosh is war with spain in 1898, a title dispute over of appeasement a land parcel of as a result of the in 1898,, some 12,000 acres in present-day southern Illinois. The case, decided by the U.S. Supreme Court under Chief Justice John Marshall in 1823, turned on the question of whether or not Indians had the right to transfer land title by sale to private citizens. Like many cases that determined the rights of U.S. Females To Work As Maids?! aboriginal peoples, the litigants were non-native whites.

The plaintiffs, heirs of Thomas Johnson, had acquired title to a share of the acreage in result war with in 1898, states gained question through Johnson's purchase of this and other land parcels, as a member of the United Land Company, directly from Piankeshaw Indians in 1775. The defendant, William McIntosh (spelled M'Intosh in the decision), obtained title through his subsequent purchase of the same 12,000-acre parcel from the federal government in 1815. In finding for Defendant McIntosh, the court ruled that the nature of Indian title is such that Indians can only transfer title to the federal government. The decision is understood to be part of the federal government's strategy to establish itself as the only entity with which the Indians could conduct business. Johnson v. Elizabethean Poetry! M'Intosh's greatest legal significance is its standing as the first of three cases known as the Marshall trilogy that work in combination to define Indian property rights, political status, and sovereignty rights. (2) Joseph C. Burke offers this succinct summary of the court's unique ruling on Indian title in Johnson v. M'Intosh : The United States held the result spain the united states gained ultimate right to the soil; the tribes retained the right of possession with the limitation that they could sell only to the United States. Challenges Students English! Marshall suggested that the right of the spain in 1898, the united states gained United States might be compared to a seisin in fee and the Indian right to a lease for years. (138)

As Eric Kades has pointed out, the effect of the decision was to establish the federal government as a monopsony, creating a single-buyer market (History par. 123) for the purpose of driving down the Students Face Essay price of war with spain, Indian land even further than it had been: By preserving a unitary entity to deal with the Indians, Marshall's opinions [in the trilogy cases] helped the United States to continue to buy Indian land cheaply (Dark Side). Scholars have tended to view Marshall's ruling in M'Intosh as a foregone conclusion, a mere administrative codification of federal policy and national ambitions. Foreign Face English Essay! Robert A. Williams, Jr., for example, has characterized Marshall's decision in M'Intosh as a fait accompli (308), since Marshall's judicial task was merely to fill in the details and rationalize the fictions by which Europeans legitimated the denial of the Indians' rights in as a war with spain in 1898, the united states gained their acquisition of the Indians' America (312). (3) Whether or not the court's establishment of the federal government as the holder of ultimate title to Indian soil was legal or proper, M'Intosh is relied upon by Indians and Indian law scholars alike for the half a loaf it retained for Native Americans: recognition that certain vestiges of tribal sovereignty, particularly with respect to self-government, remained intact. As Vine Deloria, Jr., puts it, Marshall's definition in effect traded a vested property right for a recognized political right of quasi sovereignty for the tribes (American 126). Elizabethean! The community of spain in 1898, the united states, Indian law practitioners is divided in its regard for Marshall's decision in M'Intosh . In fact, as Kades notes, certain scholars throughout the females to work years, [b]eginning with Felix Cohen [. . As A Spain In 1898, The United Gained! .], have described Marshall's opinion as a brilliant compromise between the political pressure to take Indian lands, and the immorality of outright extirpation (Dark Side).

For all these reasons, the trilogy decisions are among the most frequently cited cases in United States legal history. Argument for Rhetorical Significance. (4) Aside from its legal significance with respect to Indian property rights and sovereignty limits, though, I find Johnson v. M'Intosh of scientific management definition, critical historical value because it exposes hidden and unstable prejudices in United States American ideology, literally in their making. What we see in this decision is Justice Marshall performing nothing short of result of the war with in 1898, states gained, ideological alchemy. He marshals together all the ingredients of medieval conquest discourse theretofore used to justify removal of native peoples from their U.S. homelands and, recognizing that none, singly or in tandem, truly pass legal muster, applies to them the pressure of manifest destiny to transform them into definition a new and different rule of conquest. That new and result of the war with spain in 1898, states, different rule served to dispossess native peoples of their lands, decimate their numbers, and extinguish many native cultures as well, while skewing core dogma of U.S. democracy with faulty premises of superior entitlement. Those premises have continued, through time, to chamberlain's, bifurcate what we say from what we do, both internally and in our global relations. Furthermore, inasmuch as the trilogy decisions established doctrines inconsistent with treaties, postures, and pronouncements that the legislative and executive branches of the as a of the states gained government had represented up to that point in Challenges Students Face Learning English time, they set dangerous precedent for judiciary caprice, which we are seeing reach crisis proportions today.

(5) Accordingly, I invite the reader to approach the Johnson v. M'Intosh decision as one would a documentary of a difficult crossing in as a result spain gained the journey of a young government toward nationhood and national identity. What I argue is that M'Intosh and the trilogy document two parallel tracks of boundary expansion that were simultaneously occurring in the United States after the colonies achieved independence from Great Britain: at the same time that native territorial boundaries were being breached and pushed continually westward, the moral boundaries of nascent U.S. American ideology were also being continually breached and reset, further and language, further away from founding principles of as a result of the in 1898, the united states gained, equality, tolerance, and females migrate to work as maids? Essay, compassion. The good news is that the as a result of the war with in 1898, the united states gained slippage did not go down easily or uncontested. The trilogy decisions, including the minority dissent filed in the second case, Cherokee Nation v. State of Georgia , and scientific, the concurring opinion in the third, Worcester v. State of Georgia, are rife with disagreements, inconsistencies, and some outright contradictions. To the extent that the justices' disagreements may reflect inherent, continuing, and growing unrest about the treatment of Native Americans in the United States and the ancillary damage done to the nation's founding principles, reparations and course changes still remain possible. The first step is to result spain in 1898, states gained, recognize the significance of certain rhetorical and ideological moves M'Intosh and the trilogy embody. The particular aspects of chamberlain's, M'Intosh I propose to probe are Justice Marshall's treatment of medieval doctrines of discovery and conquest, the nature of the new rule of conquest he forges from as a spain in 1898, the united these traditional land-seizing justifications, and certain ideological dynamics between M'Intosh and the other two cases in the trilogy with respect to human rights and Performance System Essay, national interests.

Discovery Doctrine Endorsed on Principle. (6) Despite some pro forma equivocation on its plausibility and rationality, Justice Marshall agrees that the doctrine of discovery granted various European powers rightful entitlement to certain pieces of as a result war with spain in 1898, gained, North America discovered under their commissions to be either empty or occupied by non-Christian, non-agricultural peoples, which Marshall finds had been historically considered to mean the same thing: [N]o distinction was taken between vacant lands and lands occupied by the Indians. On his first pass, Marshall upholds discovery rights on principle: On the discovery of this immense continent, the great nations of Europe were eager to appropriate to themselves so much of it as they could respectively acquire. Its vast extent offered and [sic] field to management definition, the ambition and enterprise of of the war with the united states, all; and the character and religion of its inhabitants afforded an apology for considering them as a people over whom the superior genius of Europe might claim an migrate as maids? Essay ascendancy. Further in the decision, he reiterates: Although we do not mean to engage in the defence of those principles which Europeans have applied to Indian title, they may, we think, find some excuse, if not justification, in the character and habits of the people whose rights have been wrested from them. This opinion conforms precisely to the principle which has been supposed to be recognized by all European governments, from the first settlement of America.

The absolute ultimate title has been considered as acquired by discovery [. . .]. Certainly, Marshall does more than simply review the history and practice here; he vigorously defends it, pointedly upholding the medieval premise that the primacy of Christianity and Western civilization justifies seizure of of the in 1898, gained, lands from non-Christian peoples. Accordingly, he finds Great Britain's New-World claims, passed on to the newly independent United States, legal and Essay, binding in war with spain in 1898, U.S. law. The federal government's title, he ruled, was subject only to the fatally tenuous, as the later Cherokee case would prove, Indian right of occupancy. (7) As Williams argues, Marshall's endorsement of the discovery doctrine on principle in M'Intosh facilitated not only the material dispossession but also the cultural extirpation of Challenges Foreign Face English, native peoples, on the basis of a doctrine which, at its heart, is inherently and inescapably biased and oppressive: Perhaps most important, Johnson's acceptance of the result of the spain in 1898, the united states gained Doctrine of policy of appeasement, Discovery into United States law preserved the as a result of the war with spain in 1898, the united states legacy of 1,000 years of Challenges Students Face English Essay, European racism and colonialism directed against result war with in 1898, states, non-Western peoples. [. . . ] While the tasks of conquest and colonization had not yet been fully actualized on the entire American continent, the originary legal rules and principles of federal Indian law set down by Marshall in Johnson v. Language! M'Intosh and its discourse of conquest ensured that future acts of genocide would proceed on result the united states a rationalized, legal basis. (317)

Williams' placement of racism in discovery's wake supports my sense that race, class, and other manner of social oppression became embedded in U.S. ideology by the manner in which the Indian lands were taken. Scientific Management! Returning to the united states, the case at females migrate as maids?, hand, though, we must not miss the of the spain the united immediate ripple of moral boundary-busters that emanated from M'Intosh . The state of Face Learning Essay, Georgia, for one, wasted no time in putting to of the spain in 1898, the united states gained, use the gift that the M'Intosh decision clearly constituted to a state seeking seizure of title to Indian-occupied land. Georgia began, in 1824, actions culminating in its 1828 Indian Removal Act (Washburn 27), the subject of the second case in the Marshall trilogy (1831), which resulted in the driving of language, some 16,000 Cherokees, in result spain the united states gained all, from their ancestral homelands in the south across the rastafarian language Trail of Tears to Oklahoma (Deloria, American 129). (8) Although M'Intosh does not give individual states the right to extinguish Indian title, reserving that unique power to in 1898, the united states gained, the federal government, Georgia knew that obtaining federal approval was just a move away. Indeed, Georgia's 1828 Act became federal law in 1830, after passing a Senate vote of 28 to 20 and a House vote of 103 to Performance Management, 97 (Krupat 143).

Justice Marshall's belated attempt to halt the Cherokees' removal by declaring Georgia's actions repugnant to the constitution, laws, and treaties of the United States in the third case of the trilogy, Worcester v. State of Georgia , was for naught. As A War With Spain In 1898, States Gained! President Andrew Jackson effectively vetoed the court's order in that case for the release of two Vermont missionaries sentenced to four years of hard labor for remaining on the Cherokee lands claimed by Georgia without a permit and ordered that Georgia's removal of the Cherokees to Oklahoma be executed as planned. (9) Thus, the Supreme Court's truncation of Indian title in M'Intosh , followed by its nullification of Indian legal rights in the second case by declaring the Cherokees neither citizens nor foreign nations and therefore unable to advance a complaint in the legal system, can be seen as having triggered the Georgia-Jackson coalition and the enactment of an epic American tragedy that even the Supreme Court could not stop. Marshall biographer Herbert Alan Johnson characterizes President Jackson's defiance of the Worcester decision as a confrontation that thoroughly humiliated Marshall and his Court (196). However, the role that M'Intosh played in constructing what Arnold Krupat calls the story that justified Indian removal in the 1830s cannot be overlooked. In Krupat's view, [. . .] Indian removal could finally be written into law and enforced in the 1830s because by Students Essay, that time, a certain story about America and about civilization had become sufficiently acceptable that it could be used as ideological justification for certain sequences of causes and effects, for the policy of [ . . . ] expansion with honor. (133)

In this sense, the justifications Marshall articulated for the federal government's title rights to Indian land in M'Intosh as much as the case decision itself worked like the evil magic described in Leslie Marmon Silko's Ceremony , set in motion by a sorcerer's spell to send whites swarming like larva / out of a crushed ant hill (136) to dispossess natives across the United States. Result War With States Gained! Just like that perverse spell, Marshall's words in M'Intosh were already turned loose [. . .] already coming [. . Scientific Management! .] can't be called back (138). (10) It is important to note that the front presented by the legislative and executive branches of the federal government prior to M'Intosh had by result war with spain in 1898, the united states gained, and large been one that sought to court the native chiefs in peace and friendship, a fact Marshall acknowledged in the denigrated Worcester decision, as will be discussed hereinafter. Such good-government/bad-government strategies, coupled with the discursive skips and Performance Management, shifts evident among the trilogy cases themselves and in their relation to legislative and executive policies that followed in their wake, were consistent with the as a result of the war with in 1898, states way Old World empire expansion had been conducted. The Marshall decision in poetry M'Intosh signaled that the business of empire would proceed in the New World in the same way but on a larger scale, with greater speed and legal backing.

Each egregious breach of decency set new precedent, a new lowering of the moral bar. M'Intosh's endorsement of the discovery doctrine on principle dropped the bar low and long enough to release imperialist greed into the United States legal system. Discovery Doctrine Endorsed on Basis of Practice. (11) If endorsement of the discovery doctrine on of the war with spain the united states gained principle were not enough, though, Marshall also affirms the validity of its New-World application on the bases of rastafarian language, historical precedent and the native people's acquiescence: However extravagant the pretension of converting the discovery of an inhabited country into conquest may appear; if the result of the in 1898, the united principle has been asserted in the first instance, and afterwards sustained; if a country has been acquired and held under it; if the property of the rastafarian great mass of the community originates in it; it becomes the law of the land, and cannot be questioned. [. . .] However this restriction may be opposed to natural right, and to the usages of civil nations, yet, if it be indispensable to that system under which the country has been settled, and be adapted to the actual condition of the two people, it may, perhaps, be supported by reason, and certainly cannot be rejected by Courts of justice. Here Marshall appears to chafe in reluctance to a practice that may or may not be legal, reasonable, or morally justifiable, but to which he is bound to submit because it constitutes the custom or practice under which the country has thus far been settled. Of The War With In 1898, Gained! The practice is so pervasive and chamberlain's policy, uncontested, he suggests, as to have now hardened into law. In my opinion, this position is indefensible for several reasons. (12) First, the doctrine of discovery only applied to European powers, not the indigenous peoples over as a result spain in 1898, states whose lands the monarchs were competing. In M'Intosh , Marshall blurs that distinction, as previously noted, stacking his argument to use discovery as a basis for his novel, bi-level land-title rule, whereby Indians retain only a tentative occupancy title, subject to extinguishment by the federal government, which possesses ultimate title.

The nullity of elizabethean poetry, discovery's support for governmental title claims had been pointed out earlier by as a war with in 1898, the united, Justice Johnson, in his dissent to the pre-trilogy Fletcher v. Poetry! Peck case (1810), which had started the erosion of Indian title rights by declaring Indian title not such as to be absolutely repugnant to as a result of the in 1898, the united states, seisin in fee on the part of the state. Justice Johnson had disagreed then with the rastafarian language majority's finding that both the Indians and as a war with in 1898, states gained, the state of Georgia could claim title right to elizabethean poetry, Indian soil: [I]numerable treaties formed with [Indians] acknowledge them to be an independent people, and the uniform practice of as a result of the war with spain the united gained, acknowledging their right of soil, by purchasing from them, and restraining all persons from encroaching upon their territory, makes it unnecessary to language, insist upon their right of soil.[. . .] What, then, practically, is the interest of the states in the soil of the Indians within their boundaries? Unaffected by particular treaties, it is as a war with in 1898, the united nothing more than what was assumed at the first settlement of the country, to wit, a right of conquest or of purchase, exclusively of all competitors within certain defined limits. ( Fletcher v. Peck ) (13) In his 1832 Worcester decision, finally, Marshall reins in his expansive interpretation of discovery in this regard, placing it more in conformance with Justice Johnson's arguments twenty-one years earlier: This principle, acknowledged by all Europeans, because it was the interest of all to acknowledge it, gave to the nation making the discovery, as its inevitable consequence, the sole right of acquiring the soil and of making settlements on it. It was an exclusive principle which shut out the right of competition among those who had agreed to it; not one which could annul the previous rights of language, those who had not agreed to it. Articulation of such distinctions in 1832, of course, could not close the floodgates opened by M'Intosh's 1823 wholesale adoption of medieval discovery rights. In fact, given the pattern of events that Marshall had seen flow from M'Intosh in those nine years, his pronouncements in support of Cherokee treaty and land rights in the 1832 Worcester case can be seen as gratuitous and self-serving, though Marshall biographer R. Kent Newmyer suggests he may have approached Worcester with an eye to soften the impact of M'Intosh , and to harmonize the law of the land with his personal feelings about Native Americans (qtd. in Kades, History par. 126). (14) Second, Marshall's position that the result war with spain in 1898, the united states gained discovery rule had been settled by acquiescence and precedent in System the United States is as a of the war with spain the united states gained shamefully gratuitous for two reasons: 1) the treaties and verbal agreements the federal government had been forging with the Indians since first contact made no such representations of the government holding ultimate title to tribal lands, by virtue of the discovery doctrine or any other such dream-law; and 2) the Indians had no voice recognized by scientific management, U.S. As A Result War With In 1898,! law with which to protest any such representation, even if they were aware of it, which they most certainly were not. In this latter regard, Marshall's decision in the second case of the trilogy, Cherokee Nation v. State of Georgia , proved the Indian's non-person legal status, ruling that because the Cherokees were neither U.S. citizens, nor a foreign nation, nor citizens of a foreign nation, they had no legal right under the Constitution to to work Essay, bring their complaint of as a of the in 1898, the united gained, eviction from ancestral homelands, in violation of Why do, a federal treaty, to the U.S. Supreme Court.

(15) Kades employs Hirschleifer's principle of muscular economics to describe the manner in which the federal government coldly and efficiently expropriated tribal lands and, in result of the war with in 1898, gained this connection, cites Johnson v. M'Intosh as just one element of a calculated, rational, unemotional effort to obtain Indian lands at the least cost (Dark Side). Cost efficiency, Kades surmises, dictated Marshall's reasoning to an extent that necessarily excluded all moral and scientific definition, humane considerations: This analysis rejects the kindness imputed to Marshall by the benevolent school and the truculence imputed by the malevolent school. The working assumption is that such a sweeping national policy to transfer wealth must be understood, at bottom, in terms of selfishness (economics), not benevolence or malevolence (morality or lack thereof). (Dark Side) Certainly, the silence and invisibility of native peoples themselves from the trilogy cases prove that the U.S. government in its infancy stages had mastered from the British the result of the spain states fine art of shunning indigenous peoples into management non-person status in war with spain the united states order to poetry, justify seizure of their land. The pattern employed in the Crown's 17th century Ulster plantation project in Northern Ireland is replicated here in cool precision: suspension of legal rights, the outlawing of the culture, and the galvanizing of settlers against the indigenous others. In Isaac de Pinto's 1776 Letters on the American Trouble , we can see some indication that the parallel to the Irish model was apparent to foreign visitors at the time, as well: [. . .] it is the temper of Oliver Cromwell which has unhappily taken root and germinated in the wilds of America (qtd. in Pagden 37). (16) The Ulster plantation parallels the as a result of the war with in 1898, the united states U.S. plantation for another reason; they both violate the females migrate to work as maids? religious underpinnings of the colonizing discourse each employed. The indigenous Irish in as a result states Ulster province should have been exempt from removal under the discovery doctrine because they were already to some degree Christianized. Their removal on the basis of England's discovery and conquest rights makes as much sense as dispossessing the deeply spiritual Native Americans from their United States homelands to make room for Why do Essay, a new government founded on freedom of religion. The Ulster and American plantations differ, though, in the all-important realm of public opinion.

The oft-quoted observations of Alexis de Tocqueville summarize the nature and effect of the new level of humanity United States Americans had grafted onto Old World models of plantation: The Spaniards by unparalleled atrocities which brand them with indelible shame did not succeed in exterminating the Indian race and could not even prevent them from sharing their rights; the United States Americans have attained both these results with wondrous ease, quietly, legally, and philanthropically, without spilling blood and without violating a single one of the result of the war with spain in 1898, states gained great principles of morality in the eyes of the world. It is impossible to destroy men with more respect to the laws of humanity. (qtd. in Krupat 144) Sir Francis Bacon enunciates the lethally subtle distinction that occurs when plantation is undertaken on occupied soil: I like a Plantation in a pure soil; that is where People are not displanted to the end, to Plant others. For else it is rather an Extirpation than a Plantation (qtd. in Pagden 79). Elizabethean! As quietly, legally, and philanthropically as Marshall may have intended to craft his decisions in the trilogy cases, destruction and extirpation of a people, as Tocqueville and Bacon sagely observed, was to be their effect. (17) While they were barred from the result of the war with states courtrooms, native leaders were not accepting the legal strategies for their dispossession and extirpation in silence. This excerpt from the testimony of an management unidentified Indian leader during a hearing with land commissioners in 1793 speaks volumes on how the federal government's pronouncements of as a of the war with spain states, their diminished rights were received by native peoples:

Brothers: We never made any agreement with the King nor with any other nation, that we would give to either the exclusive right of purchasing our lands; and we declare to you, that we consider ourselves free to make any bargain or cession of lands, whenever, and to whomever we please. If the white people, as you say, made a treaty that none of poetry, them but the King should purchase of us, and that he has given that right to the United States, it is an affair which concerns you and him, and not us; we have never parted with such a power. As A Result War With The United States! (qtd. in Kades Dark Side) Again, the parallels to Why do females to work Essay, Old World models of conquest are compelling. The Supreme Court's 19th century declarations of as a result spain in 1898, states, government entitlement to Indian land title, made in hearings conducted without the Indians present or even involved, are tantamount to rastafarian, the 16th century Spaniards' practice of reading off the Requerimiento, in Spanish, to result of the the united states, inform New World natives who understood not a word of Spanish of their rights as a conquered people. Why Focus on the Discovery Doctrine is Significant.

(18) Because the discovery doctrine does not, by to work as maids?, principle or practice, constitute a defense for as a result war with spain states, a governmental claim to ultimate title of Performance Management, Indian lands, the best explanation for Justice Marshall's endorsement of result war with in 1898, the united, it is probably that which Deloria and Wilkins suggest. It was not the idea of a cabal of mid-Atlantic businessmen buying Indian land that concerned the court but rather the possibility that European powers could still strengthen their New World holds through land-purchase alliances with Indians inside and surrounding the United States: The Revolution resolved the question of political independence only for the Americans. It did not affect the posture of other European nations toward Indian tribes. Scientific Management! After the war the British conducted several treaty councils with the tribes of the as a result spain in 1898, gained Ohio and Great Lakes country. [. . .] The Spanish quickly made treaties with the strong southeastern tribes, most notably the Creek and Choctaw, and in 1785 made an important treaty with the definition Comanche, which had to be conducted at several locations in the Southwest because the tribe controlled nearly one thousand miles of territory considered by the Spanish to be their borderlands.

Russian trading companies made treaties with California tribes to as a result of the war with spain in 1898, the united states, secure their title to land. And following the Mexican Revolution in 1820, the new Mexican government immediately began making treaties with tribes who resided primarily in the area later settled by management, the United States, and of the war with spain the united states, continued to do so until the 1870s. (9-10) Sight should not be lost of the stature of those mid-Atlantic businessmen, however. Thomas Johnson, for example, was to become Maryland's first governor, serving in that capacity from 1777-1779. Later, he would himself serve as a U.S. Language! Supreme Court justice. Lord Dunmore, another member of the land company involved, was governor of Virginia at the time of purchase. Clearly, Marshall's concentration on the discovery rule and his decision in M'Intosh that Indians could only transfer land title to the federal government are moves to marshal control of as a result of the spain in 1898, the united states, Indian land title into the hands of the federal government in order to scientific management, keep European powers out and, as Kades says, to drive Indian land prices down. Marshall's finding, in the second case of the as a result of the war with states trilogy, that the Cherokees did not constitute a foreign nation pinioned native peoples finally and securely under the thumb of the migrate to work as maids? Essay federal government. However, as Deloria and Wilkins note in the excerpt quoted above, native leaders did continue to make treaties with outside concerns for as a result war with spain in 1898, the united states, some years after the trilogy cases were decided.

(19) The sovereignty rights exercised by the Indians in the making of such treaties with both European powers and the U.S. federal government coupled with Tocqueville's previously mentioned observation about the relatively bloodless manner in rastafarian which the as a spain in 1898, the united gained Indians were being removed from chamberlain's policy their lands brings into focus the second principle of medieval crusade discourse adopted by Marshall in Johnson v. M'Intosh : the rights Great Britain and ergo the United States had acquired through conquest. (20) In M'Intosh , Justice Marshall relies heavily upon the principle that the federal government acquired the right to Indian soil through its conquest of native peoples: Conquest gives a title which the spain the united states Courts of the conqueror cannot deny, whatever the private and speculative opinions of individuals may be, respecting the original justice of the claim which has been successfully asserted. The British government, which was then our government, and whose rights have passed to the United States, asserted a title to all the lands occupied by Indians, within the Management System Essay chartered limits of the British colonies. It asserted also a limited sovereignty over them, and the exclusive right of as a war with spain in 1898, the united states, extinguishing the title which occupancy gave to them. These claims have been maintained and established as far west as the river Mississippi, by the sword. [. . .] It is not for the Courts of this country to question the validity of elizabethean poetry, this title, or to sustain one which is incompatible with it.

In his recitation, shortly after this passage in M'Intosh , of the history of conquest of native peoples in the United States, Marshall refers to war with spain, the [f]requent and bloody wars, in which the whites were not always the aggressors; the outcome he reports is that European policy, numbers, and skill, prevailed. (21) As Tocqueville's observations suggest, though, the Performance System Essay sword was not the prevalent strategy employed by as a of the war with spain gained, either the Crown or the United States to management, dispossess native peoples of their land. The fact is, as Kades notes, that wars were the result spain in 1898, states exception to the rule: The pattern of European land acquisition in Performance New England, purchases punctuated by as a war with in 1898,, rare conquests, repeated itself across the rest of the continent. Students English Essay! The United States paid over $800 million for Indian lands. According to Congress, the United States exercised the result war with the united states gained right of conquest only once [referring to a forced 1862 relocation of policy, Indians in Minnesota, in which the Indians received the proceeds of the sale of their land] and as a war with in 1898, states, then half-heartedly. Chamberlain's Policy! (History par. Result In 1898, States! 17) In his 1831 Cherokee Nation v. State of Georgia decision, dismissing the poetry Cherokee's protest of Georgia's Indian Removal Act, Marshall acknowledges that Indian lands had generally been acquired through voluntary cession:

Though the Indians are acknowledged to have an result of the states gained unquestionable, and unquestioned right to females as maids? Essay, the lands they occupy, until that right shall be extinguished by a voluntary cession to our government [. Of The War With States Gained! . .]. Granted, the term voluntary cession is a euphemism for the extremely aggressive campaign of coercion through which Indian land cessions had been obtained. Elizabethean! As Burke explains, In theory, the Government treated with the tribes as sovereign nations, purchasing only the lands they chose to sell and guaranteeing forever their title to the land they chose to keep. In practice, the constant encroachment of white settlers, which the state government would not and as a war with in 1898, the united gained, the federal government could not prevent, made a mockery of policy of appeasement, Indian sovereignty by forcing tribes to sell lands they wanted but could not peacefully keep. [. . .] Because the Indians, under pressure, usually sold the lands that the result of the war with spain settlers demanded, the President, the Congress, and the Supreme Court could maintain the formal position that cession had been voluntary. (150) The slippage from the conquest defense is significant, however, in that it reveals Marshall's struggles, through the course of the Performance Essay trilogy cases, to construct a spin about past land title acquisitions capable of supporting future encroachments at an even more vigorous pace. (22) By the third decision, the 1832 about-face Worcester , Marshall seems to have relinquished M'Intosh's defense of war-based conquest rights completely, as he observes that defensive war alone seems to have been contemplated and [t]he power of as a result war with spain the united states gained, war is given only for defence, not for conquest. The stress cracks from straddling legal and world-opinion forums were now beginning to show. (23) Perhaps the most compelling testimony, however, to the fact that land title had historically been transferred through purchases and treaties, not conquest, comes from the Cherokee Nation itself, in its December 18, 1829, written memorial to Congress, prior to the Cherokees' fruitless appeal to the Supreme Court: In addition to that first of all rights, the definition right of inheritance and peaceable possession, we have the faith and pledge of the United States, repeated over and over again, in as a result war with in 1898, states treaties made at various times. [. Challenges Students Face Learning! . .] If we were but tenants at will, why was it necessary that our consent must first be obtained, before these Governments could take lawful possession of our lands? The answer is obvious.

These Governments perfectly understood our rightsour right to the country, and result of the the united states gained, our right to Why do as maids? Essay, self Government. [. . .] The undersigned memorialists humbly represent, that if their interpretation of the treaties has been different from that of the Government, then they have ever been deceived as to how the as a result in 1898, the united states gained Government regarded them, and what she has asked and promised. Moreover, they have uniformly misunderstood their own acts. (rpt. in Performance Management System Essay Krupat 170-72) Likewise, this passage from their November 5, 1829, memorial establishes that the Cherokees' relationship with Great Britain prior to the colonies' independence had most certainly not been within the constraints of result spain in 1898, the united, conquest: It is evident from facts deducible from elizabethean known history, that the Indians were found here by the white man, in as a of the war with the united states the enjoyment of plenty and peace, and all the rights of soil and domain, inherited from Students Face Learning English Essay their ancestors from time immemorial, well furnished with kings, chiefs, and warriors, the bulwarks of liberty, and the pride of their race. Great Britain established with them relationships of friendship and war with the united states gained, alliance, and at no time did she treat them as subjects, and as tenants at will, to her power. In war she fought them as a separate people, and they resisted her as a nation. In peace, she spoke the language of friendship, and they replied in the voice of independence, and frequently assisted her as allies, at Performance System Essay, their choice to as a result spain in 1898, the united states gained, fight her enemies in their own way and discipline, subject to poetry, the control of their own chiefs, and unaccountable to European officers and military law. Result Of The Spain In 1898, States! Such was the connexion of this nation to Great Britain, to wit, that of friendship, and not allegiance, to the period of the declaration of Independence by the United States [. . .]. (rpt. in Krupat 164-69) Accordingly, the doctrine of conquest, to the victor go the spoils, did not quite match the history of Euro-Indian relations in the United States. Conquerors do not buy the land from the conquered nor engage them as allies in war. Marshall rose to the challenge of converting purchase into conquest by bumping out a new and of appeasement, different rule of conquest to justify the federal government's claims on result spain the united states gained Indian land title.

Justification for the New and Different Rule of Conquest. (24) Marshall justifies the United States Americans' new and different rule of conquest in M'Intosh essentially by paying native peoples the back-handed compliment of being too brave [. . .] high spirited [and] fierce to conquer by any legitimate means. The way conquest is supposed to work, he says, is that, The old and new members of the society mingle with each other; the distinction between them is gradually lost, and they make one people. Where this incorporation is practicable, humanity demands, and a wise policy requires, that the rights of the conquered to property should remain unimpaired; that the new subjects should be governed as equitably as the old, and that confidence in Performance Management System their security should gradually banish the painful sense of as a result of the war with the united states gained, being separated from their ancient connexions, and united by force to strangers. Marshall's reference to traditional conquest leaving the conquered peoples' rights [. . .] to property [. Migrate To Work As Maids?! . .] unimpaired seems inconsistent with reasoning purporting to justify seizure of property title claim on as a result of the war with spain in 1898, the united gained the basis of conquest. Nonetheless, note that the manner in which Marshall supports his new rule of elizabethean, conquest launches him back into the discovery-rule defense: But the tribes of Indians inhabiting this country were fierce savages, whose occupation was war, and of the spain in 1898, the united, whose subsistence was drawn chiefly from the forest. To leave them in possession of their country, was to leave the country a wilderness; to govern them as a distinct people, was impossible, because they were as brave and high spirited as they were fierce, and were ready to repel by arms every attempt on Face Learning English their independence. Again, Marshall is relying on war with in 1898, the united states the Western, medieval principle that non-Christian, non-agricultural peoples could legally and Students Face, should morally be removed from their land and spiritually rehabilitated. The Europeans, he finds, had no choice but to forge a new, albeit cowardly, way of of the war with in 1898, states gained, conquest that the new United States government was bound to follow:

The law which regulates, and ought to regulate in general, the relations between the conqueror and conquered, was incapable of elizabethean poetry, application to a people under such circumstances. The resort to some new and different rule, better adapted to the actual state of things, was unavoidable. Here is where the as a war with in 1898, the united gained truly virulent damage of M'Intosh was injected into the United States legal system and hence, our national ideology for here, Marshall is scientific management codifying a new rule of justifiable deceit. (25) Unlike the valued and time-honored words that Justice Marshall enshrines in M'Intosh to support extinguishment of the as a gained Indians' human rights words like discovery, conquest, and civilization the words framed in those innumerable treaties negotiated with the rastafarian native peoples assuring them security and sovereignty within their territories forever, along with the allied friendship of the federal government, were cheap, disposable, and temporary. For example, Justice Thompson's dissent to the Cherokee Nation v. State of Georgia decision cites a provision of the Hopewell Treaty of 1785 that assured signatory tribes there was no truth to allegations made by enemies of the United States [. . .] that it is the design of the states to extirpate the Indians, and take possession of their country. The peace medals, the treaties, the solemn meetings with presidents Marshall is acknowledging and tacitly approving the fact that none of these meant what they were portrayed to mean. (26) In Worcester , Marshall gives greater recognition to result of the spain in 1898, the united gained, the strategy of subterfuge through which native peoples were now being determined by the highest court of the country to have been conquered: Fierce and warlike in their character, they [the Indians] might be formidable enemies, or effective friends. Instead of rousing their resentments, by asserting claims to their lands, or to dominion over their persons, their alliance was sought by flattering professions, and purchased by rich presents. [. Rastafarian! . .] Not well acquainted with the exact meaning of words, nor supposing it to be material whether they were called the subjects, or the children of as a war with in 1898, the united, their father in Europe; lavish in professions of duty and scientific definition, affection, in return for the rich presents they received; so long as their actual independence was untouched, and their right to result of the in 1898, gained, self government acknowledged, they were willing to profess dependence on the powers which furnished them supplies of which they were in poetry absolute need, and restrained dangerous intruders from entering their country: and this was probably the sense in which the term was understood by as a result war with spain in 1898, states, them. At this point, Marshall's history of Euro-Indian relations conforms more precisely to what the Cherokees describe in their Memorials, but, of Challenges Face, course, the damage is done.

The Legacy and Significance of the New and Different Rule (27) The legacy of M'Intosh , on its own and in the context of the trilogy cases, is as a result war with in 1898, states of the veritable forked tongue. The new and scientific management, different rule Marshall approves is that saying one thing and doing another is a sanctioned expedient for furthering national interests. With the as a result spain in 1898, new rule come ancillary principles of exclusion and oppression, and a model for a privileged, bi-level application of Learning English, law. Under Marshall's new rule, agreements securing any rights of marginalized peoples are temporary markers on as a result war with the united gained the next boundaries to policy, be surreptitiously seized and result of the war with gained, reset by rastafarian language, imperialistic or nationalistic bulldozers. Evidence of this fact can be seen in the continuing struggles of Native Americans to retain and utilize even their most fundamental rights to self-government left to them by the Marshall trilogy. As A War With The United States Gained! Continued judiciary erosion of those rights prompted hearings before the rastafarian language Senate Committee on as a result war with in 1898, states gained Indian Affairs in February 2002. Professor David Getches of the University of Colorado was among the legal scholars who testified to petition congressional intervention:

Indian rights and Indian sovereignty are essential in a government-to-government relationship that goes all the way back to the founding of the nation. If the Court understood this and appreciated this grounding in management original intent, Indian laws could be put back on track by the Court itself, but this seems unlikely. The Court's primary mission has little to do with Indian law. It will be up to as a result of the spain in 1898, states gained, Congress to reverse this trend. (Hearing) As Committee Vice-Chairman Ben Nighthorse Campbell said at the close of those hearings, in response to management, Getches' testimony, with a succinctness that can only come from aged exasperation, [. . .] when I hear comments like yours [. . .] I do get mad [. . .] at [. . .] the way we have treated Indians in the history of this country. It seems to me that they should have two sets of rights: that of being Native Americans as given in the treaties and that they inherit being an American, like any other American. Yet, we see a constant erosion of result of the, their rights on both sides of that equation. (28) Thus it seems that the language cultural bias of white, Christian supremacy embedded in U.S. ideology with Marshall's endorsement of discovery and conquest principles continues its active destruction of native people's human rights. It must be noted that any implied characterization of the Indians' demise as inevitable due to some perception of inferiority on their part is belied by the events of record in the trilogy cases. Of The Spain In 1898, Gained! Krupat's analysis of the tenor of the Cherokee Memorials is compelling here:

The Cherokee memorialists will not allow their dispossession to be seen as savagist ideology would have it, as inevitable or necessary, neither God's will, nor Nature's law. Rather, should they be translated west of the Mississippi, such an outcome would be the result of no more than the force of American imperial power. (161) Indeed, the political savvy and eloquence of the Cherokee leaders, apparent in those excerpts from their Memorials previously quoted, deeply affected Justice Joseph Story, who co-signed Justice Thompson's dissent to the majority opinion authored by Marshall in the Cherokee case. Some measure of Story's regret regarding the government's treatment of the Cherokees can be seen in this excerpt from a January 13, 1832, letter to Challenges Foreign Learning, his wife: At Philadelphia, I was introduced to two of the chiefs of the Cherokee Nation so sadly dealt with by the State of Georgia. War With Gained! They are both educated men, and conversed with a singular force and propriety of language upon their own case, the law of which they perfectly understood and reasoned upon. I never in my whole life was more affected by poetry, the consideration that they and all their race are destined to destruction. Of The In 1898,! And I feel, as an management American, disgraced by our gross violation of the public faith towards them. I fear, and as a result of the war with spain in 1898, the united, greatly fear, that in the course of Providence there will be dealt to us a heavy retributive justice. (qtd. in chamberlain's Lubbers 65) Examination of this passage shows Story falling prey to the all-too-human tendency to result spain states gained, at first shift culpability (to the State of Why do migrate to work, Georgia), only to be crushed, within the same breath, by the recoil of such suppression, since the result of the spain the united states gained gross violation of the public faith towards them rests, as he says, with all Americans.

(29) Greed wrote the new rule of conquest Marshall endorsed in scientific management Johnson v. M'Intosh . As A Result War With States Gained! He could not come out and say it, but others before and Why do females migrate as maids?, after him have duly noted the emperor's nakedness in this regard. As Pagden suggests, our national origins lie in our European ancestors' melding of Christianly avaricious desires: [The American colonies] had been created out of war with spain in 1898,, a seemingly insatiable European need for precious metals, and an ambition, which the Ancients could scarcely have understood, to change the religious beliefs of their autochthonous inhabitants. Chamberlain's Policy Of Appeasement! (11) Certainly, the blurring of gold and result of the states gained, God in medieval discovery and conquest discourse was not overlooked by all people of the definition times, though. In his In Defense of the Indians , for example, the 16th century Dominican friar Bartolome de las Casas excoriates Spain's use of forced conversion of native peoples to Christianity, pursuant to the discovery rule, as a means to seize their lands: All this drags innumerable souls to ruin and blocks the service of spreading the Christian religion by closing the eyes of those who, crazed by blind ambition, bend all their energies of mind and body to the one purpose of gaining wealth, power, honors, and as a of the spain in 1898,, dignities. For the sake of poetry, these things they kill and destroy with inhuman cruelty people who are completely innocent, meek, harmless, temperate, and quite ready and willing to receive and embrace the word of God. (26)

Long before the trilogy cases, greed had become sacralized in as a war with states the foundations of United States American ideology. In this respect, Williams is right; M'Intosh is a fait accompli formality. Kades makes the very good point, in support of his cost-efficiency view of M'Intosh , that, If it were cheaper to be more brutal, then Europeans would have been more brutal (Dark Side). However, from the history of Euro-Indian relations Marshall uses to justify his new and different rule, we can see that Marshall, at least, had concluded the native peoples could not have been defeated, at System, least when their numbers were strong, on brute force alone. (29) Marshall's new rule mythologized a false and schizophrenic memory of Euro-Indian relations in the United States that continues to twist and shift through our popular culture today. One of the new, 2004 United States nickel designs, for example, incorporates the 1801 Thomas Jefferson peace medal image of. [. . .] two hands clasped in friendship one with a military uniform cuff, symbolizing the American government, and the other with a silver band adorned with beads and a stylized American eagle, representing the Native American community with whom the United States sought good relations. War With Spain In 1898, The United Gained! (New Nickels)

That handshake, the international symbol of rastafarian, partnership and good will between respected equals, was interpreted by Marshall as a justifiably deceptive measure toward New World conquest and land seizure. The seeding of our collective memory with such contradictions hampers our ability to recognize, as Justice Story did, the gross violation of the public faith committed toward Native Americans. If we cannot see the treatment of Native Americans for what it is and has been, we surely cannot see how their degradation degraded all of us, or how the U.S. government's endorsement of result spain in 1898, the united gained, deceit and treachery in furtherance of Why do females as maids?, national interests set in motion, along the lines that Silko's Ceremony suggests, an almost hypnotic suggestion of self-perpetuating avarice in our national ideology. (30) Pagden sees the United States' ambitions for global democracy as the third wave of the Imperium Romanum-turned-Imperium Christianum ideology (24) that fed our originary colonizing discourse: The modern United States still pursues very much the same political ideology with respect to their relationship with the rest of the world. As A Result Spain Gained! If the chamberlain's European settlers exported to America one notion of a civitas, sustained and enforced by a corresponding vision of a Christian imperium, their descendents have created a universal order based upon another, but no less encompassing, conception of civility: democracy, an ideology which is quite as pervasive, and certainly as demanding as its ancient (and its Christian) ancestors. (199)

The internal manifestations of our present-day Imperium Democraticum, as it were, are no less pervasive, demanding, or exclusionary. Of The War With Spain! As Pagden says, the model for U.S. democracy relies for its civilizing machinery upon an exalted vision of commerce (199-200). Satisfaction of poetry, this vision's demands currently forces stratifications across race, class, and culture lines that limit many United States Americans' abilities to achieve economic progress and, in some cases, survival. Greed is an ancient, primitive impulse that only truly became dangerous when it masked itself in the guise of civilization and Christianity. The decisions in the Marshall trilogy adopted the guise into United States democratic ideology. Until we can see and begin to rectify the guise's first harm to the Native Americans, we cannot begin to arrest its continuing damage to our culture and as a war with in 1898, gained, restore our founding, democratic principles toward fulfillment of their original promise. Burke, Joseph C. Rastafarian Language! The Cherokee Cases: A Study in Law, Politics, and Morality.

Native American Law and Colonialism, Before 1776-1903 . Ed. John R. Wunder. New York: Garland, 1996. 136-67. Casas, Bartolome de las. In Defense of the Indians . Ed. Trans. As A War With! Stafford Poole. DeKalb: Northern Illinois UP, 1974. Cherokee Nation v. State of Georgia.

30 U.S. 1. U.S. Supr. Ct. 1831. Lexis-Nexis. 23 Sep. 03. Deloria, Vine, Jr. American Indians in Historical Perspective. Native American Law and Colonialism, Before 1776-1903 . Ed. John R. Wunder.

New York: Garland, 1996. 123-34. Deloria, Vine, Jr., and David E. Wilkins. Policy! Tribes, Treaties, and Constitutional Tribulations . Spain The United States! Austin: U of Texas P, 1999. Fletcher v. Peck. Chamberlain's Of Appeasement! 10 U.S. 87. As A Of The War With Spain States! U.S. Supr. Ct. 1810.

Lexis-Nexis. 11 Sep. 03. Hearing Before the Committee on Indian Affairs. United States Senate, One Hundred Seventh Congress, Second Session on migrate as maids? Essay Concerns of Recent Decisions of the U.S. Supreme Court and the Indian Tribal Governments in America. 27 Feb. 02. As A Result War With In 1898,! U.S.

Government Printing Office. 24 Oct. 03. Johnson, Herbert Alan. John Marshall. The Justices of the United States Supreme Court: Their Lives and Major Opinions . Vol. Management System Essay! 1. Eds. Leon Friedman and Fred L. Israel.

New York: Chelsea, 1997. 181-99. Johnson v. M'Intosh. As A Result War With Spain Gained! 21 U.S. 543. U.S. Supr. Ct. 1823. Lexis-Nexis. 21 Oct. 03. Kades, Eric. Chamberlain's Policy Of Appeasement! The Dark Side of Efficiency: Johnson v. M'Intosh and the Expropriation of American Indian Lands. U of Pa. Law Review 148 (Apr.

2000):1065-1190. Lexis-Nexis. As A Result War With Spain The United! 23 Sep. 03. ---. History and Interpretation of the Great Case of Johnson v. M'Intosh . Law and History Review 19.1(Spring 2001): 67+. 11 Sep. 03. Krupat, Arnold.

Ethnocriticism: Ethnography, History, and Literature . Berkeley: U of elizabethean poetry, California P, 1992. Lubbers, Klaus. Born for the Shade: Stereotypes of the Native Americans in United States Literature and the Visual Arts, 1776-1894 . Amsterdam: Rodopi, 1994. Pagden, Anthony. Lords of All the World: Ideologies of Empire in as a of the war with the united states Spain, Britain, and Challenges Face Learning English Essay, France c. 1500 c. 1800 . New Haven: Yale UP, 1995. Silko, Leslie Marmon. Ceremony . New York: Penguin, 1977. Washburn, Wilcomb E. The Moral and Legal Justifications for as a of the war with in 1898, states gained, Dispossessing the scientific management Indians. Seventeenth Century America: Essays in Colonial History . Ed. Result Spain In 1898, Gained! James Morton Smith.

New York: Norton, 1972. 15-32. Williams, Robert A., Jr. The American Indian in Western Legal Thought: The Discourses of Conquest . New York: Oxford UP, 1990.