The Facade of Tattoos Essay examples -- essays research papers

The Facade of Tattoos In "Parker's Back" by Flannery O'Connor, the tattoos O.E. Parker receives are crucial to the reader’s understanding of him. Furthermore, O'Connor suggests them as major symbols throughout Parker's life. Parker, the main character in this story, goes through the actions of life without really knowing who he is and why he is on the earth. â€Å"Parker gradually experiences religious conversion and, though tattooed all over the front of his body, is drawn to having a Byzantine tattoo of Christ placed on his back†¦, O’Connor was using unusual symbols to convey her sense of the mystery of God’s redemptive power (Shackelford, p 1800).† Because of the tattoos, the reader is able to see O'Connor reveal the major characteristics in Parker's life and sympathize with this man as he searches for his identity and finds God. First of all, in order to understand O’Connor’s short story, the reader must look into the background of her life. â€Å"Parker’s Back† was the last story written by O’Connor before she died at the early age of thirty-nine from the disease of Lupus. Her writings all reflect from her religious background of Catholicism. â€Å"O’Connor wrote brilliant stories that brought the issue of religious faith into clear dramatic focus. She was a devout Roman Catholic living in predominantly Protestant rural Georgia. Her stories are far from pious; in fact, their mode is usually shocking and often bizarre. Yet the religious issues they raise are central to her work (Drake, online vertical file--------------------------------).† â€Å"Time and again in her stories, the spokesmen for a self-satisfied secularism run afoul of representatives of... the God-haunted protagonists†¦they play an indispensable role†¦they act as spiritual cata lysts†¦(CLC, p276†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.).† â€Å"To even the casual reader it would appear that Miss O’Connor really had only one story to tell and really only one main character. This principal character is, of course, Jesus Christ; and her one story is man’s absolutely crucial encounter with Him (Drake, p273).† Being a devout Catholic, O’Connor’s â€Å"faith consciously informed her fiction. The difficulty of her work, she explained†¦is that many of her readers do not understand the redemptive quality of ‘grace,’ and, she added, ‘don’t recognize it when they see it. All my stories are... ... this image O’Connor graphically conveys the suffering of Christ incarnate in humanity, and expresses her belief that convergence with Christ means union with Christ’s suffering, not escape from suffering into some abstract realm of spiritual bliss†¦emphasizing that the rising in consciousness that precedes true convergence is expressed not through external power or dominance over others but, paradoxically, in a descent into vulnerability, into suffering, into weakness, into man’s essential poverty (CLC p 159).† It is in this last scene that the reader becomes sympathetic with Obadiah Elihue, having been driven out of the house by his harridan wife, â€Å"leaning against the tree, crying like a baby.† Through the descriptions of Parker's tattoos, one can make connections between the "pictures" he has "drawn all over him" and what goes on in his actual life. O'Connor uses the tattoo symbols to reveal the growth of the protagonist, for it takes him years to get past his outer image of his body, to examine his own soul. One begins to sympathize with this man, "Obadiah Elihue," as he searches for himself and finds peace with God.

Does The Ecosystem Service Approach Environmental Sciences Essay

Globalization has led to a more reliant society on systems and services. A extremist displacement in sentiments of the ecosystems has occurred, from a really traditional point of view of the land being a manner of life, to a more modern idea ; human high quality is a precedence, comprehending the environment as natural capital. For many people, the modern manner of life has become embedded within society ; populating otherwise is frequently viewed as a battle, restricting possible engagement in activities. The ecosystem services attack considers ecosystems, in footings of, ( do n't cognize about the commas ) the flows of benefits to worlds, and linkages between these services and our wellbeing. The ‘approach ‘ incorporates everything from the conceptual footing of ecosystem services, through to mensurating, valuing and paying for services and links to human wellbeing. The ecosystem services are the benefits people gain from ecosystems, this illustrates? exemplifying our d ependance on ecosystem-based procedures that create the merchandises we need and use day-to-day. Different sums of ecological and economic accent occur when specifying ecosystem services ; ‘the direct and the indirect parts of ecosystems to human wellbeing ‘ ( TEEB Foundations 2010 ) Ecosystem services are besides seen as a bridging construct turn toing the causes and effects of effects ( Ehrlich and Ehrlich 1981. ) These definitions address human wellbeing instead than taking the environment into concern. Can you do this any longer, sentence to short? Promotions towards public-service corporation have occurred. In the yesteryear, the dominant statement was for biodiversity preservation where other species ‘ had the right to populate ( Vitousek et al 1997. ) The creative activity of a new subject of ecological economic sciences is based on the useful construct of nature, where worlds are perceived at an advantage ( Millennium Ecosystem Assessment. ) Society addresses the losingss and additions to themselves alternatively of sing environmental impacts. Ecosystems interact on planetary to local graduated tables ; local graduated table alterations contribute to planetary alterations and frailty versa ( Wilbank. ) Benefits planetary in nature comprise of storage of atmospheric C and maintaining or increasing degrees of biodiversity. Regional benefits consist of watershed protection. Many ecosystem service benefits are local, and frequently are regarded as being the greatest of importance, impacting day-to-day lives straight. As many ecosystem services are locally appreciated ; local dwellers suffer the most when losingss occur ; hence graduated table influences the benefits societies and the environment receive ( . ) Locally, societal mechanism methods from transmittal of cognition, ordinances, and values to patterns are utilized ( Berkes et al 2000. ) These kind of systems used may work on a local degree ; nevertheless degrees of success may non assist globally. On a planetary degree the environment is addressed ; nevertheless on a l ocal degree human wellbeing is of importance. The Millennium Ecosystems Assessment conceptualized ecosystem services into four serving classs ; proviso, ordinance, cultural and back uping, all of which are significantly linked. MEA is based on indexs of ecosystem provinces and biodiversity, human wellbeing, direct and in-direct force per unit areas and ecosystems services flows. The MEA illustrates the trouble in showing nexus between ecosystem alterations and human well-being fluctuations, impacting upon the degrees of benefits society and the environment receive ( Millennium Ecosystem Assessment. ) The environment provides the necessities for life, from clean H2O to climate ordinance. The provisioning service identifies services including ; nutrient, fiber and fuel and the cultural services provides benefits to people through cultural, rational and religious inspiration. Other services provided are uncommonly recognised ; including regulation services, which address clime ordinance and H2O purification, and back uping services which sustain seed dispersion and alimentary cycling ( Kumar et al 2010. ) Food cycling aids the environment, supplying all beings with shelter and nutrient growing, through increased works productiveness. Plant growing sweetening and secondary seed dispersion increases workss growing and output ; supplying society with the benefits of an agricultural economic system. Provisioning services, e.g. harvest pollenation, can increase the output, quality and stableness of merchandises ; hence heightening the diet nutritionally. Economic benefits besides occur ; & A ; lb ; 195 billion yearly is brought in by purveying services. Regulating services, e.g. C segregation, aids the remotion of GHG from the ambiance ; hence profiting society and the environment, through cut downing the figure of negative impacts. Increased information and cognition would avoid farther economic harm. Cultural services aid keep cultural value ( Kumar et al 2010. ) Turning demands for purveying services has have been met at the disbursal of back uping, modulating and cultural ecosystem ser vices.Research by the Millennium Ecosystem Assessment found, at a planetary degree, diminutions in many of the ecosystem services have been complimented by increased in human wellbeing and nutrient beginnings. Research identifies worsening services are non relevant to society ; therefore attending should be focused on the improving services ( Raudsepp-Hearne et al 2010 ) doing farther impacts upon environmental benefits. Measuring and valuing ecosystem services is a new construct ; nevertheless ecosystems are dateless. In footings of mensurating ecosystems, indexs are utile when following tendencies and responses. Measuring ecosystem services involves placing the benefits people receive and the ecosystem capacity to present a peculiar service ( Kumar et al 2010. ) The multidimensional attack, of valuing ecosystem services, is socially combative but utile when distinguishing and mensurating tradeoffs between society and nature. Irrespective of ecosystem maps and there debasement effects ; ecosystem services are undervalued by society, as a consequence of? due to a deficiency of consciousness of the relationship between the operation of human support systems and the natural ecosystem. ( Liu et al 2010. ) Research has focussed on understanding human penchants for ecosystem services ; undervaluing the value of modulating and back uping service, this could be why society positions at that place current demands before the environment ( Liu et al 2010. ) The cardinal instance for ecosystem service ratings include, lending towards better decision-making ; taking into history costs and benefits to the environment and society ( Liu et al 2010. ) Environmental concern has dramatically increased, recognizing the value of the natural ecosystems. Through hu man-led force per unit areas, debasement of ecosystems and increased consciousness ; our cognition of exposure to human public assistance and ecosystem alteration, is indispensable for guaranting sustainable development and esteeming the demands of future coevalss. Economic values are easier to see in footings of cost-benefit analysis. Revealed penchant methods, state-preference methods, cost-based method, benefit transportation and nonmonetary methods are manners to value environmental goods. The revealed penchant incorporates ; ratings direct from willingness to pay for goods and services, economic end product impacts and recreational benefits. For illustration, New York faced a pick of put ining a new H2O filtration works bing $ 4-6 billion dollars or non. Valuing the country and biodiversity lead to positive results as the H2O supply improved biodiversity ( Kumar et al 2010. ) Without valuing the nature of this system more negative results could hold occurred, for illustration, increased wellness deductions from imbibing soiled H2O. Society and the environment were proved to derive great benefits, if right determinations are made. Ecosystems services provide us with a utile tool for conveying different subjects together, in footings of taki ng all factors into consideration ( Millennium Ecosystem Assessment. ) Biodiversity and ecosystem services are public goods ; ensuing in large inducements for private development beyond socially optimal degrees ( . ) If a sufficient degree of wealth is achieved, social precedences may underscore the quality of the environment and the services it delivers, therefore could supply greater benefits to the environment as society become more cognizant. On the other manus, a growing in economic returns could take to a reduced concern on the biodiversity of the Earth. Disadvantages to valuing ecosystem services include the usage of stray person values which are frequently so aggregated to stand for a socially-relevant unit, such as a community, province, state or full planet. This scheme of valuing is appropriate when services provided are strictly separately enjoyed but are non suited on a planetary graduated table ( Farber, Costanza and Wilson ) Depending on state of affairss, different valuing techniques need to be utilised in order to derive benefits for the environment and society. A farther disadvantage to valuing ecosystems include ; disregarding the intrinsic value, wrong economic ratings and biodiversity ‘s complexness, uncertainness and irreversibility ( Kumar et al 2010. ) Monetizing of the environmental services can be hazardous, and safeguards need to be taken. Many favour monetising ecosystem services as a determination assistance ; nevertheless due to the complex nature of these services restrictions apply ( Liu et al 2010. ) Many ecosystem services do n't measure up for market trading, as they are non private in nature, for illustration, inundation protection services, one time these services are made available, may indirectly go available to all ( Farber et al 2002. ) The economic invisibleness of nature is debatable as false appraisals are present taking to market failures ( The Economicss of Ecosystems and Biodiversity. ) Economies can fall in without the services of ecological life-support systems and if services are non adapted or managed ( Costonza et al 1997. ) Tiping points, such as, over deforestation and overfishing negatively impacts the environment ; accordingly impacting societies. Deforestation leads to increasing sums of GHG, in the ambiance, heightening planetary heating. Decreased fish stocks affect the nutrient concatenation accordingly impacting available nutrient stocks ( Lenton T.M. et al 2008. ) Both the society and the environment are really closely interlinked, monetising services can either impact positively or negatively. Payment for ecosystem services involves offering inducements to landholders or husbandmans in exchange for pull offing their land to supply ecological services ; hence changing the economic inducements of the land. The transparent system for proviso of environmental services, through voluntary suppliers and conditional payments, purposes to advance the preservation of natural resources in the market place. Poverty relief is of import to PES but should n't be classed as the chief aim ( Wunders 2005. ) For society and the environment to profit from the payment for ecosystem services it must be competitory. PES adapts current patterns to better the environment. Society is less likely to profit impacting supports negatively, in footings of cut downing nutrient resources handiness. Schemes are frequently biased to richer, better-educated, urban-based husbandmans with larger farms ( Zbinden and downwind 2005. ) intending the hapless, undereducated husbandmans remain destitute. Human wellbeing has been impacted, influenced and shaped by the nature and conditions of ecosystems. To bring forth human public assistance, ecosystem services need flows of information, energy and stuff from a scope of beginnings. Ecosystem services contribute to economic public assistance, through income coevals, well-being and the bar of harm that could bring down costs on society. The relationship between ecosystem services and human wellbeing can take on several different signifiers. Rising incomes frequently lead to a diminution in some ecosystem services ( Levy et al 2005. ) For illustration, economic growing from agricultural enlargement has improved human wellbeing, but at the disbursal of dirt quality. Human impacts are now of greater strength and in most instances we can no longer disregard the effects. Human well-being depends on the changeless supply of services attained from ecosystems. Increased human action has changed ecosystems extraordinary. Benefits of alteration are spatially unevenly distributed among persons or even states taking to human and ecological systems under multiple emphasiss. Peoples populating in drylands and cragged countries encounter lower ecosystem productiveness ; hence wellbeing diminishes ( Rehdanz K, Maddison D 2005. ) The negative impacts of urban colonies on ecosystem services and human wellbeing, in flush states, have been delayed and passed onto future coevalss or displaced to different location. Ecosystem services provide direct and indirect benefits for worlds. Direct benefits are obtained, from the ecosystems workss and animate beings, in the signifier of natural stuffs and nutrient. Other direct benefits provided by the universe ‘s ecosystem include familial resources that flow from biodiversity ; hence developing medicine and progressing cognition on the output and opposition of harvests. Indirect benefits ascend from ecosystem interactions. For illustration, eroding control, H2O purification and seed dispersion via animate beings. Other less touchable benefits comprise of the enjoyment of a sundown and the religious significance of countries. Pilgrimages for betterments in human well-being occur, therefore placing that ecosystems are psychologically ingrained into our lives. Many services besides represent a considerable economic resource, occupations associated with touristry and agribusiness are all illustrations of money exchange. Net human wellbeing is better served by keeping ecosystems in a status that provides quality services for the present twenty-four hours and future coevalss. It is local dwellers who have the greater inducement to continue the ecosystems they depend on. Local people have possible for pull offing ecosystems sustainably and for damaging them. But local communities seldom control the ecosystems they inhabit ; with the market for ecosystem goods going progressively planetary and regulated by the authorities can overmaster the locals interactions. In decision, the ecosystem service attack provides benefits and limitations to society and the environment. As a society, changing the ways in which we view the environment is hard ; nevertheless with increased policies and more consciousness of the impacts we provide the environment, positions can be altered. At this minute in clip the ecosystem service attack provides greater benefits to the society as seen by the addition in human wellbeing and nutrient beginnings. Fewer benefits are impacting the environment as human high quality and wellbeing is viewed as being a precedence. The authorities, as they have the power to act upon new market solutions, should be the leaders in carry throughing the ecosystem service attack to supply benefits to society without impacting the demands of the environment. The authorities must therefore develop and implement policies and strategies, which have the ability to accomplish benefits for all. Governments have the ability to implement statute law which affect both the benefits society and the environment receive ; nevertheless it is easier to supervise the benefits in which society receive than the of all time altering environment. Human Domination of Earth ‘s Ecosystems 1997Peter M. Vitousek, Harold A. Mooney, Jane Lubchenco, Jerry M. MelilloEconomic and ecological constructs for valuing ecosystem servicesfarber, costanza Wilson 2002Wunders 2005. ) ( TEEB Foundations 2010 Ehrlich and Ehrlich 1981 Millennium Ecosystem Assessment Vitousek et Al 1997 Wilbank Berkes et Al 2000 Kumar et Al 2010 ( Raudsepp-Hearne et Al 2010 Liu et Al 2010 Farber, Costanza and Wilson ( Farber et al 2002 The Economicss of Ecosystems and Biodiversity Lenton T.M. et al 2008 Zbinden and Lee 2005 Wunders 2005 Levy et Al 2005 Rehdanz K, Maddison D 2005

Perspectives on play: learning for life Essay

This paper illustrates in detail how learning can be achieved through play. Depth research has been carried out on the correlation between play and its positive benefits on early childhood learning, growth and development. Through this research it has been established that there is a positive connection between creative language and play and the social development of a child. Play has emotional benefits on a child such as enjoyment, relaxation, and fun, love of life, tension reduction and self expression. Developmental benefits of play include cognitive development where imagination, creativity, problem solving, mastery of concepts and perspective taking improves. Socially the child grows which can be seen through co-operation, sharing, turn-taking, and conflict resolution and leadership skills development. The language of the kid also develops that is in terms of communication skills, vocabulary and narration (Brock 2009 p.6-7) In this issue to bring out the details pretty clear, sharp in-depth look at two chapters has been done, the first chapter being; Authoring books, plays and identities in writing workshops. Key practice: Approximated writing. The first chapter also involves the sub-topic; discourse of creative expression (Gordon 2009 p.23). The second chapter to look at is the: Toy as Identity texts, children as consumers and players. The first chapter mostly handles introduction to writing where kids are taken through a workshop where they mainly engage in writing. The climax of it is when the kid finally authors a book and has a chance to sit on the authors chair and read the book to the class and to be admired and questioned at the end of the writing workshop. The rationale behind choosing this chapter on developing writing is that written communication is a very key skill in life and everyone should have it as a priority developing the skill and becoming an expert in communicating really well thro ugh writing. It is thus a privilege and great pleasure learning how a kid or an individual at large develops this skill and also to reflect and see how probably people did begin at it or ought to begin (Gordon 2009 p.25) Approximated writing is the key arguments in this chapter which symbolizes or represents a range of ways in which children can deliberate within their inner self between their personally invented forms of language understanding and the culturally determined rules for language. Approximated writing is close to the real writing language which embraces errors, incorrect spellings. It is used by children to formulate meaningful messages through their use of their emerging mastery of the language. In the writing workshop the kids initiated their own writing projects and as they wrote they designed and illustrated images and prints for puppet plays, pages for kids-printed books, cards to relatives and friends, storyboards and journals. Graphophonic conventions such as using alphabetic symbols like â€Å"tuk† to represent the word took, putting bigger spaces between words, placing marks on words and organizing them in a pattern are very much use in this case. Authoring in the worksho p happened when the kids wrote, drew, told and dramatized the texts they had written down. Finally in regard to authoring the kids connected texts for the kids-produced books that they presented to the others through reading aloud from the author`s chair or even short plays that were acted for the class and videotaped (Marzollo 2011 p.39-40) A number of realizations came from these workshops or activity that was centered on kid’s literacy. The first one being that children are capable writers who are able to actively create and co-create meaning and such activities can be very instrumental in bringing out their literacy proficiency this is so because it is in such that they are challenged to explore all genres of written communication and also get a chance to freely air their ideas through their conversations and writings (Elkind, 2009; p.46). The idea of getting a chance to sit on the author`s chair, present the book to the class, to be questioned and admired at the end of the writing workshop motivated the kids to really come up with a well-illustrated book. Discourse of creative expression also happens in the conference where free expression of ideas and feelings in the workshop through routine or regular practices is done. The children are always encouraged to share their opinions with their peers and anything they feel the need to air during the workshop. This discourse of creative expression empowers autonomy in writing decisions during the workshop and clearly refers to the kids as a writer mostly because they have written their own creations (Guinagh 2009 p.32). The above situation is really different from a school situation which cannot really be called free expression because the kid is directed, monitored and controlled by the teacher on what to write about. The children also have the permission during the workshop to abandon the projects they were working on at their own discretion without permission from the teacher. In the case of a child also consulting with other children in the case of seeking their assistance and opinions also decides to change their projects and ignore the one they were doing or make revisions on it is still quite appropriate. The methodology used in this chapter or writing workshop to teach the children how to write is something really great and enjoyable both for them and their instructor. The different number of plays that are used to teach them how to write and encourage them to pursue understanding the genres of written communication are very appropriate for them both for their easier understanding and to make it really interesting to the children without boredom at all. Learning writing is presented in a very simplified way that makes the child to want to do it again and again. The above writing activity or workshop further proves the point that learning happens very effectively through play (Silberg 2009 p.23). In the second chapter close attention is paid to the chapter on Toy as Identity texts, children as consumers and players. First it is good to state that the rationale behind picking this chapter as the second one to look at to anyone it would mostly be out of curiosity to know and understand the following questions: The reason why kids and toys are almost inseparable? How comes that children want to spend as much as possible time with their toys, which is the language that really exist if any between toys and kids? Dolls in line with toys are texts designed specifically to enable the children to recognise with ease the manner in which it can be used in a play. They are associated with popular children animated films and also television programs which encourage children to play certain character roles and familiar scripts. These toys act as texts calling forth for â€Å"possible worlds† which brings about certain character roles, dialogue and stories (Silberg 2009 p.31) Dolls i n a way are used to communicate identity and expectations in and from the society, for example the text or identity of a â€Å"cool girl† is communicated through the doll`s features such as its hairstyle, clothing and makeup. Popular dolls communicate complex such as concerning taste, social status, culture, roles and position in society and taste. This complex message requires the reader in this case the children to coordinate these messages and understand them (Tizard 2010 p. 55) The methodology of using toys and dolls to communicate certain texts to the children and ensure that they learn something sounds quite funny. It is after pondering about this manner of using play to teach or facilitate learning to the very young ones that a person will come to the conclusion that it is one of the most amazing ways of learning through play which is really an awesome method. Kids are in a position to learn so much through toys and dolls without even their knowledge that they are learning and this knowledge sticks in their minds for the rest of their lives. As a wrap up this paper has made it clear through the above examples how learning is done through play. Therefore one would comfortably conclude that it is a matter of fact that children learn through play and exposure to plays enable them to develop their intellectual, social and emotional skills. Plays should thus be a part and parcel of a child`s life so that the child may grow and develop holistically failure to which the development of the child will be hindered (Wood 2013 p.5). More and more learning and play ought to be embraced and others developed so as to ease learning especially amongst children who are easily bored and has low concentration ability and retention capacity of what they learn. The importance and value of learning through play can therefore not be underestimated. References Brock, A. (2009). Perspectives on play: learning for life. Harlow, England: Pearson/Longman. Elkind, D. (2009). The power of play: learning what comes naturally. Cambridge, Mass.: Da Capo Lifelong ;. Gordon, I. J., Guinagh, B., & Jester, R. E. (2009). Child learning through child play; learning activities for two and three year olds. New York: St. Martin’s Press. Marzollo, J., & Lloyd, J. (2011). Learning through play ([1st ed.). New York: Harper & Row. Silberg, J. (2009). Learning games: exploring the senses through play. Beltsville, Md.: Gryphon House. Tizard, B., & Hughes, M. (2010). Young children learning (2nd ed.). Malden, MA: Blackwell Pub.. Tizard, B., & Hughes, M. (2010). Young children learning (2nd ed.). Malden, MA: Blackwell Pub.. Wood, E. (2013). Play, learning and the early childhood curriculum (3rd ed.). London: SAGE. Source document

Legal Writing

555 P. 2d 696 Supreme Court of New Mexico. Zelma M. MITCHELL, Plaintiff-Appellee, v. LOVINGTON GOOD SAMARITAN CENTER, INC. , Defendant-Appellant. No. 10847. Oct. 27, 1976. Appeal was taken from an order of the District Court, Bernalillo County, Richard B. Traub, D. J. , reversing a decision of the Unemployment Security Commission and awarding benefits to discharged employee. The Supreme Court, Sosa, J. , held that employee’s insubordination, improper attire, name calling and other conduct evidencing wilful disregard of employer’s interests constituted ‘misconduct’ disqualifying her from receiving certain unemployment benefits. Reversed. Attorneys and Law Firms *576 **697 Heidel, Samberson, Gallini & Williams, Jerry L. Williams, Lovington, for defendant-appellant. Gary J. Martone, J. Richard Baumgartner, Joseph Goldberg, Albuquerque, for plaintiff-appellee. OPINION SOSA, Justice. This case presents the issue of whether petitioner’s actions constituted misconduct so as to disqualify her from certain unemployment compensation benefits. On June 4, 1974, petitioner-appellee Zelma Mitchell was terminated for alleged misconduct from the Lovington Good Samaritan Center, Inc. On June 12, 1974, Mrs. Mitchell applied for unemployment compensation benefits. Finding that Mrs. Mitchell’s acts constituted misconduct, a deputy of the Unemployment Security Commission disqualified Mrs. Mitchell from seven weeks of benefits pursuant to s 59-9-6(B), N. M. S. A. 1953. On July 24, 1974, Mrs. Mitchell filed an appeal. The referee of the Appeal Tribunal reversed the deputy’s decision and reinstated these benefits to Mrs. Mitchell on August 28, 1974. On September 13, 1974, the Center appealed the decision of the Appeal Tribunal to the whole Commission pursuant to s 59-9-6(E), N. M. S. A. 1953. The Commission overruled the Appeal Tribunal and reinstated the seven week disqualification period. Mrs. Mitchell then applied for and was granted certiorari from the decision of the Commission to the District Court of Bernalillo County pursuant to s 59-96(K), N. M. S. A. 1953. On January 16, 1976, the District Court reversed the Commission’s decision and ordered it to reinstate the benefits to Mrs. Mitchell. From the judgment of the District Court, the Center appeals. The issue before us is whether Mrs. Mitchell’s actions constituted misconduct under s 59-9-5(b), N. M. S. A. 1953. Mrs. Mitchell started work at the Center in Lovington on July 4, 1972 as a nurse’s aide. After approximately one year on the job in addition to her normal duties she also served as a relief medications nurse two days per week. On June 4, 1974, she was terminated. The testimony concerning the events leading up to her termination that day is somewhat contradictory but basically is the following. Mrs. Mitchell arrived punctually to work at three p. m. The director of the Center, Mr. Smith, questioned her about why she was already filling in her time card. Mrs. Mitchell answered that she filled in eight hours, which she would work that day as long as she did not ‘break a leg or die. ’ Mr. Smith replied, ‘Well, I’m not so sure about that. ’ Mrs. Mitchell then became defensive and stated that she had supported him when the Director of Nurses, Mrs. Mary Stroope, sought to have him fired as director. Mrs. Stroope, in the vicinity, overheard this comment, denied it, and called Mrs. Mitchell a liar. At various times during this exchange Mrs. Mitchell referred to Mr. Smith, Mrs. Stroope, and others as ‘birdbrains. This occurred in a crowded area where the Center’s employees were checking in and out, so Mr. Smith told both to go into his office. There, Mrs. Stroope apologized to Mrs. Mitchell for calling her a liar and Mrs. Mitchell apologized for saying that Mrs. Stroope had circulated a petition to replace Mr. Smith. However, tempers soon flared again and Mr. Smith resolved to fire Mrs. Mitchell. Mrs. Mitchell then demanded her check. Mr. Smith paid her for that day, a week’s vacation, and another week’s salary for being terminated, which he was not required to do since Mrs. Mitchell failed to give him two weeks’ notice. 577 **698 Appellee Mitchell argues that the events of June 4, 1974, do not constitute misconduct within the meaning of s 59-9-5(b), supra. Appellant Center argues that these events were the last of a series of acts of misconduct, and the ‘birdbrain’ incident should be considered the ‘last straw’ resulting in her termination. Mitchell counters that the prior acts of misconduct should not be considered. The alleged acts of prior misconduct are the following. On April 2, 1974, Mrs. Mitchell went to work at the Center out of uniform (she wore gold pants rather than navy blue). On that day the Federal Regulation Inspectors visited the Center. Mrs. Mitchell stated that she did not know that the federal inspectors would be there that particular day. The Director of Nurses reprimanded her and told her to go home and to change into the proper attire, which Mrs. Mitchell refused to do. The following day Mrs. Mitchell again came to work out of uniform but this time she was directed to go and did go home to change. On May 24, 1974, Mrs. Mitchell was switched from medications to the floor routine. Angered, Mrs. Mitchell refused to give medications, even though the charge nurse and Mrs. Stroope explained to her that the reason for the switch was that she was familiar with both jobs whereas the replacement nurse, Carol Skurlock, was unfamiliar with the floor routine. Mrs. Mitchell stated that she did not like being replaced by a ‘white’ nurse’s aide (Carol Skurlock). Mrs. Mitchell considered herself and Carol to be just ‘birdbrain against birdbrain,’ apparently because neither she nor Carol was a licensed nurse. From May 24 to June 4 Mrs. Mitchell refused to perform her duties as a relief medications aide. On May 15, 1974, and other days, Mrs. Mitchell sang while counting medications and was not very co-operative, which caused Betty Clarke, R. N. , to complain that Mrs. Mitchell’s actions were unethical and time-consuming. The term ‘misconduct’ is not defined in the Unemployment Compensation Law. The Wisconsin Supreme Court in Boynton Cab Co. v. Neubeck, 237 Wis. 249, 259-60, 296 N. W. 636, 640 (1941) examined the misconduct subsection of its unemployment compensation act, found no statutory definition of misconduct, and formulated the following definition: . . ‘misconduct’ . . . is limited to conduct evincing such wilful or wanton disregard of an employer’s interests as is found in deliberate violations or disregard of standards of behavior which the employer has the right to expect of his employee, or in carelessness or negligence of such degree or recurrence as to manifest equal culpability, wrongful intent or evil design or to show an intenti onal and substantial disregard of the employer’s interests or of the employee’s duties and obligations to his employer. On the other hand mere inefficiency, unsatisfactory conduct, failure in good performance as the result of inability or incapacity, inadvertencies or ordinary negligence in isolated instances, or good faith errors in judgment or discretion are not to be deemed ‘misconduct’ within the meaning of the statute. We adopt this definition. Applying this definition of misconduct to the facts of the case before us, we hold that Mrs. Mitchell’s acts constituted misconduct. *578 **699 Mrs. Mitchell’s insubordination, improper attire, name calling, and other conduct evinced a wilful disregard of the interests of the Center. Although each separate incident may not have been sufficient in itself to constitute misconduct, taken in totality Mrs. Mitchell’s conduct deviated sufficiently to classify it as misconduct under the above test. Appellee’s argument that the ‘last straw’ doctrine should not be used is hereby rejected. The district court is reversed and the decision of the Commission is reinstated. McMANUS and EASLEY, JJ. , concur. 764 P. 2d 1316 Supreme Court of New Mexico. Billie J. RODMAN, Petitioner–Appellant, v. NEW MEXICO EMPLOYMENT SECURITY DEPARTMENT and Presbyterian Hospital, Respondents– Appellees. No. 17721. Nov. 30, 1988. The District Court, Bernalillo County, Ross C. Sanchez, D. J. , upheld administrative decision denying unemployment compensation to claimant. Claimant appealed. The Supreme Court, Ransom, J. , held that incident precipitating claimant’s termination demonstrated willful disregard for her employer’s interests. Affirmed. Stowers, J. , specially concurred and filed opinion. Attorneys and Law Firms **1317 *759 Juan A. Gonzalez, Legal Aid Society of Albuquerque, Inc. , Albuquerque, for petitioner-appellant. Connie Reischman, New Mexico Employment Sec. Dept. , Albuquerque, for respondents-appellees. OPINION RANSOM, Justice. An administrative decision of the New Mexico Employment Security Department denying unemployment compensation to Billie J. Rodman was reviewed on certiorari by the district court. Rodman now appeals to this Court from the order of the district court affirming the administrative decision. Rodman had been employed by Presbyterian Hospital as a unit secretary for nearly eight years when, on February 17, 1987, she was terminated under hospital personnel policies following a â€Å"third corrective action† notice. Prior restrictions had been placed on Rodman’s conduct due to personal problems adversely impacting upon her place of work. At issue is whether the misconduct which warranted termination from employment rose to the level of misconduct which would warrant denial of unemployment compensation under NMSA 1978, Section 51–1–7 of the Unemployment Compensation Law. The Department reasonably summarizes the substantial evidence as follows: Rodman was reprimanded in June of 1986 for receiving an inordinate number of personal telephone calls and visitors at her work station, which was disruptive to her own work and to her co-workers. The formal reprimand set forth conditions to prevent further corrective action. Rodman was to have no personal telephone calls during work hours outside of a designated break or dinner time, in which event they were to occur in an area not visible to patients, physicians, or other department staff. When leaving the department for dinner, Rodman was to report to her immediate supervisor and was not to leave the hospital. Rodman was to make every effort to resolve the matters in her personal life that were causing problems at work. Nevertheless, according to the testimony of her supervisor, extremely disruptive telephone calls continued. The doctors were beginning to comment on it. The staff was getting more distressed. According to her supervisor, â€Å"[A]gain we talked about the visits, the behavior at the desk. When it got pretty bad with the phone calls, Billie would slam charts, push chairs and be a little abrupt with the people she worked with. † Another written reprimand in November of 1986 warned Rodman that her job was in jeopardy if the disruptive behavior continued. The supervisor established restrictions prohibiting the claimant from having visitors at the department and instructed her to notify security if there was a potential problem. On February 15, 1987, Rodman began work at 1:00 o’clock in the afternoon. She had spoken to her boyfriend’s mother earlier in the day to tell her that she did not want him to use her car as she had broken off their relationship. The boyfriend’s mother called her at work and told her the boyfriend had her car keys. Rodman told the mother to have the boyfriend call her at work. When he did, she informed him that she could not talk to him at her duty station, and he hung up on her. He called her back and left a number where he could be reached. She left the work area and went to the break room to call him. After returning to her duty station, Rodman got another telephone call from her boyfriend who told her to go downstairs to the lobby to meet him and pick up the keys. When she refused, he told her that if she did not come down he would come up to her department. Claimant eft the department to confront her boyfriend, and, because her supervisor was at lunch in the hospital cafeteria, Rodman notified a co-worker, a registered nurse, that she was leaving. Rodman testified, â€Å"I didn’t want any kind of confrontation at the desk, so I went downstairs. † Before she left her desk, Rodman called the employer’s security guard and asked him to meet her in the lobby because she anticipated that a problem could develop. When Rodman got to the l obby, her boyfriend started yelling and forced her outside. In doing so, he tore her shirt. At this point the security guard arrived and observed them arguing. Rodman was in the passenger seat of her car. The security guard instructed the boyfriend to return the keys, but the boyfriend jumped into the driver’s seat, locked the doors and drove off. About thirty-five minutes later, Rodman returned to her work station, after having changed her torn shirt. She resumed working, but, as the shift progressed, more telephone calls were received for her in the department. The supervisor became frustrated with the volume of calls and the behavior of Rodman. It was determined that Rodman should be sent home. Thereafter she was terminated. The Appeals Tribunal of the Department of Employment Security found on the basis of the evidence that the appellant had proven unwilling to restrict her personal contacts while at work, as requested by her employer. The hearing officer dismissed as without **1319 *761 merit Rodman’s contention that she could not stop her acquaintances from calling or visiting her at work. The hearing officer concluded that Ms. Rodman’s behavior was unreasonable, had caused many problems for her work section, and constituted misconduct connected with work under Section 51–1–7(B). The Meaning of â€Å"Misconduct† in New Mexico’s Unemployment Compensation Law. Given the remedial purpose of the Unemployment Compensation Law, New Mexico courts, like most jurisdictions, interpret the provisions of the law liberally, to provide sustenance to those who are unemployed through no fault of their own, and who are willing to work if given the opportunity. Wilson v. Employment Sec. Comm’n, 74 N. M. 3, 14, 389 P. 2d 855, 862–63 (1963); Parsons v. Employment Security Comm’n, 71 N. M. 405, 409, 379 P. 2d 57, 60 (1963). Like most states, New Mexico also provides that an employee who is determined to have been discharged for â€Å"misconduct† is ineligible for unemployment compensation benefits. 51–1–7(B). Two purposes are served by this statutory bar: first, it prevents the dissipation of funds for other workers; second, it denies benefits to those who bring about their own unemployment by conducting themselves with such callousness, and deliberate or wanton misbehavior that they have given up any reasonable expe ctation of receiving unemployment benefits. Given the remedial purpose of the statute, and the rule of statutory construction that its provisions are to be interpreted liberally, the statutory term â€Å"misconduct† should not be given too broad a definition. Accordingly, in adopting the majority definition of the term, this Court wrote in Mitchell v. Lovington Good Samaritan Center, Inc. , 89 N. M. 575, 577, 555 P. 2d 696, 698 (1976): â€Å"[M]isconduct† * * * is limited to conduct evincing such wilful or wanton disregard of an employer’s interests as is found in deliberate violations or disregard of standards of behavior which the employer has the right to expect of his employee, or in carelessness or negligence of such degree or recurrence as to manifest equal culpability * * *. M]ere inefficiency, unsatisfactory conduct, failure in good performance as the result of inability or incapacity, inadvertencies or ordinary negligence in isolated instances, or good faith errors in judgment or discretion are not to be deemed â€Å"misconduct† within the meaning of the statute. Where an employee has not acted with the requisite degree of â€Å"fault† under Mitchell, he or she has not sacrificed a reasonable expectati on in continued financial security such as may be afforded by accrued unemployment compensation benefits. It is therefore possible for an employee to have been properly discharged without having acted with such willful or wanton disregard for an employer’s interests as would justify denial of benefits. This Court recognized in Alonzo v. New Mexico Employment Security Department, 101 N. M. 770, 689 P. 2d 286 (1984), that even an act of willful disobedience which leads to termination will not always rise to the level of â€Å"misconduct† when the act is an isolated incident in an otherwise favorable employment history and the incident does not cause a significant disruption of the employer’s legitimate interests. Trujillo v. Employment Sec. Dep’t, 105 N. M. 467, 472, 734 P. 2d 245, 250 (Ct. App. 1987) (where employment contract gave employer the right to draft employees to work overtime in emergency situations significantly affecting the employer’s interests, it was â€Å"misconduct† for appellees to have refused to report for overtime work). Alonzo and Trujillo demonstrate that there are two components to the concept of misconduct sufficient to justify denial of benefits. One is the notion that the employee has acted with willful or wanton disregard for the employer’s interests; the other is that this act significantly infringed on legitimate employer expectations. *1320 *762 Totality of circumstances and the â€Å"last straw† doctrine. Often, the courts have been confronted with a series of minor infractions by the employee, where each incident showed a willful disregard of the employer’s interests, but no single incident was serious enough to justify denial of benefits. In su ch cases, courts have applied a â€Å"totality of circumstances† or â€Å"last straw† test to determine whether, taken together, this series of incidents constitutes misconduct sufficient to disqualify the claimant from receiving benefits. Mitchell v. Lovington Good Samaritan Center, Inc. 89 N. M. 575, 555 P. 2d 696 (1976). Rodman recognizes the â€Å"last straw† doctrine, but contends that the district court erred in applying the rule in this case because her infractions of February 15 were the result of acts of third parties over whom she had no physical or legal control. Appellant contends that she may not be denied unemployment benefits where the â€Å"last straw† which led to her termination was not willful or intentional, especially where, under the employer’s personnel policy, she could not have been discharged at all before this final incident. The Department contends that it is immaterial whether the precipitating act was a willful or intentional violation of the employer’s rules, where the record indicates that the claimant had a history of previous acts which demonstrate a willful or wanton disregard for the employer’s interests, and the employer discharged the employee for the accumulation of events, including the precipitating event. Fort Myers Pump & Supply v. Florida Dep’t of Labor, 373 So. 2d 429 (Fla. Dist. Ct. App. 1979). Although Fort Myers does offer support for the appellee’s position, we believe termination for a series of incidents which, taken together, may constitute â€Å"misconduct† is distinguishable from termination for a single incident following one or more corrective action notices. In the latter event, as here, we hold that the â€Å"last straw† must demonstrate a willful or wanton disregard for the employer’s interests for unemployment benefits to be denied. If substantial evidence existed that Rodman’s conduct on February 15, considered in light of the totality of ircumstances including her previous history of personal phone calls and unauthorized visitors, showed a willful or wanton disregard for her employer’s interests, then Rodman’s benefits were properly denied. Although the evidence in this case is amenable to more than one reasonable interpretation, we conclude that there was a substantial basis for the district court to decide t hat Rodman’s actions on February 15, when considered in light of the restrictions which had been placed upon her and her previous failure to comply with those restrictions, demonstrated a willful disregard for her employer’s interests. Therefore, the decision of the district court is affirmed. IT IS SO ORDERED. WALTERS, J. , concurs. STOWERS, J. , specially concurs. 769 P. 2d 88 Supreme Court of New Mexico. In re Claim of Lucy APODACA. IT’S BURGER TIME, INC. , Petitioner–Appellee, v. NEW MEXICO DEPARTMENT OF LABOR EMPLOYMENT SECURITY DEPARTMENT, BOARD OF REVIEW and Lucy Apodaca, Respondents–Appellants. No. 17952. Feb. 22, 1989. Employer filed writ of certiorari to challenge Employment Security Department’s award of unemployment compensation to fast-food restaurant employee who refused to retint her purple hair. The District Court, Dona Ana County, Lalo Garza, D. J. reversed award of benefits. Employee appealed. The Supreme Court, Ransom, J. , held that evidence supported Department’s award of benefits. Reversed and remanded. Attorneys and Law Firms **89 *176 Jose R. Coronado, Southern New Mexico Legal Services, Inc. , Las Cruces, Connie Reischman, New Mexico Dept. of Labor, Albuqu erque, for respondents-appellants. Kelly P. Albers, Lloyd O. Bates, Jr. , Las Cruces, for petitioner-appellee. OPINION RANSOM, Justice. A determination by the Board of Review of the New Mexico Employment Security Department awarding unemployment compensation to Lucy Apodaca was reversed by the district court on certiorari. Apodaca appeals the district court decision, arguing that the court erred in finding the administrative determination was unsupported by substantial evidence and was contrary to law. We conclude substantial evidence supports the Board of Review decision that the conduct leading to Apodaca’s termination did not constitute misconduct warranting denial of unemployment compensation under Section 51–1–7(B) of the Unemployment Compensation Law. Accordingly, we reverse the district court. Apodaca was employed as a counter helper from August 1986 to August 1987 with It’s Burger Time, Inc. Apodaca’s supervisors had no complaints concerning the performance of her work. Several times during the summer of 1987, Apodaca approached the store manager, John Pena, to ask how the owner, Kevin McGrath, would react if she were to dye her hair purple. Pena did not at first take the question seriously. When Apodaca persisted, Pena told her that he would have to ask McGrath. Apparently, he never did so. After several weeks, Apodaca went ahead and dyed her hair. McGrath saw Apodaca’s tinted hair for the first time at work two days later. He instructed Pena to give Apodaca a week to decide whether she wanted to retain her new hair color or her job. In a letter to the Board of Review, McGrath wrote that he had a good sense for community standards and believed he could not afford to wait until â€Å"this incident [took] it’s [sic] toll on my business. † Apodaca had signed the company handbook upon being hired, which instructed employees about acceptable hygiene and appearance. The handbook said nothing specific about hair color. Pena relayed McGrath’s message to Apodaca and suggested she make up her mind quickly so he could find someone to replace her if necessary. Two days later, Apodaca told Pena she had decided to keep her hair the way it was. She was then terminated and applied for unemployment benefits. The Department initially determined that Apodaca was ineligible for compensation because she had been terminated â€Å"for refusing to conform to the standards of personal grooming compatible with the * * * work [she was] performing. † The claims officer concluded this constituted misconduct under Section 51–1–7(B). Apodaca appealed to the Appeals Tribunal, which affirmed the denial of her benefits after a hearing. She appealed the Tribunal’s decision **90 *177 to the Department’s Board of Review. After reviewing the record of the hearing, the Board concluded that the employer failed to show how the color of Apodaca’s hair affected its business; therefore, her refusal to return her hair to its original color did not rise to the level of â€Å"misconduct† required for denial of her benefits. For review of the Board’s decision, the employer filed a writ of certiorari with the Dona Ana County District Court. The district court determined Burger Time’s request to Apodaca to change the color of her air was reasonable and enforceable and Apodaca’s refusal of that request was misconduct. The court concluded that the Board of Review’s decision was not supported by substantial evidence and was contrary to the law and reversed the decision granting Apodaca her benefits. This appeal followed. In reviewing the district court decision, we look first to see whether the court erred in concluding that the Department’s decision was unsupported by substantial evidence. Because we conclude that the court erred in this determination, it is unnecessary for us to examine the findings and conclusions adopted by the court. Misconduct and the employer’s interest. Both Apodaca and Burger Time agree that the definition of â€Å"misconduct† as used in Section 51–1–7(B) is to be found in this Court’s opinion in Mitchell v. Lovington Good Samaritan Center, Inc. , 89 N. M. 575, 577, 555 P. 2d 696, 698 (1976): â€Å"[M]isconduct† * * * is limited to conduct evincing such wilful or wanton disregard of an employer’s interests as is found in deliberate violations or disregard of standards of behavior which the employer has the right to expect of his employee, or in carelessness or negligence of such degree or recurrence as to manifest equal culpability. * * [M]ere inefficiency, unsatisfactory conduct, failure in good performance as the result of inability or incapacity, inadvertencies or ordinary negligence in isolated instances, or good faith errors in judgment or discretion are not to be deemed â€Å"misconduct† within the meaning of the statute. Apodaca d oes not deny that her refusal to redye her hair was an intentional and deliberate act. At issue in this case is whether an employee who refuses to alter her personal appearance in conformity with the employer’s personal beliefs about acceptable community standards has engaged in misconduct. The employer argues, and the district court apparently agreed, that so long as the request is reasonable and the employee is given adequate time to comply, refusal amounts to â€Å"insubordination and misconduct. † We disagree. In Alonzo v. New Mexico Employment Security Department, 101 N. M. 770, 772, 689 P. 2d 286, 288 (1984), we recognized that termination for an isolated incident which does not â€Å"significantly affect[ ] the employer’s business† may not form the basis for denial of benefits on the grounds of misconduct. In Alonzo, an employee was terminated after refusing to wear a smock when working at the cash register as required by company policy. Id. at 771, 689 P. 2d at 287. As here, the employee’s previous work history was completely satisfactory, and there was no evidence that the employer’s business interests had been affected. Alonzo should be compared with Trujillo v. Employment Security Department, 105 N. M. 467, 471–72, 734 P. 2d 245, 249–50 (Ct. App. 987), which held that failure to report for overtime work pursuant to an employment contract provision allowing the employer to draft employees in emergency situations constituted misconduct, when the evidence demonstrated that the orders directing employees to report early to work were explicit and not confusing. In Trujillo, unlike Alonzo, failure to comply with the employer’s request was recognized as having significantly affected the employer’s interest. See also Thornton v. Dep’t of Hum an Resources Dev. , 32 Cal. App. 3d 180, 107 Cal. Rptr. 92 (1973) (refusal of restaurant employee to shave beard immediately or be terminated was not misconduct when employer failed to show that beard was unsanitary or otherwise detrimental to business); cf. Lattanzio v. Unemployment Comp. Bd. of Rev. , 461 Pa. 392, 336 A. 2d 595 (1975) (claimant’s refusal to report back to work was for good cause when employer demanded he shave beard but no evidence supported contention that requested alteration in appearance was essential to performance of duties other than employer’s vague assertion that claimant’s â€Å"modish† appearance might reflect unfavorably on business). In this case, there is absolutely no evidence that the color of Apodaca’s hair significantly affected Burger Time’s business. McGrath and Pena both testified they received no customer complaints regarding the color of Apodaca’s hair. Apodaca’s immediate supervisor, testifying in her behalf, reported that the only comments she heard were compliments and that Burger Time’s customers had readily registered complaints in the past when they found something amiss. Under these circumstances, the Board of Review could properly decide that Apodaca’s refusal to retint her hair did not rise to the level of misconduct. Burger Time argues that none of our previous cases require an employer to demonstrate its business was affected by an employee’s refusal to comply with a request from the employer. However, it is well established in New Mexico that the party seeking to establish the existence of a fact bears the burden of proof. See Newcum v. Lawson, 101 N. M. 48, 684 P. 2d 534 (Ct. App. 1984); Carter v. Burn Constr. Co. , 85 N. M. 27, 508 P. 2d 1324 (Ct. App. ), cert. denied, 85 N. M. 5, 508 P. 2d 1302 (1973); Wallace v. Wanek, 81 N. M. 478, 468 P. 2d 879 (Ct. App. 1970); cf. Moya v. Employment Sec. Comm’n, 80 N. M. 39, 450 P. 2d 925 (1969) (when claimant sought to establish that he ought not be disqualified from receiving benefits because the position for which he refused to interview was not suitable employment, he bore burden of proof on this issue). In this case, pursuant to Department regulations requiring an employer to report why a claimant was fired or have that claimant’s benefits charged against the employer’s account, Burger Time submitted a letter stating that Apodaca refused to comply with company grooming standards. At each subsequent stage of the administrative process and before the district court, Burger Time sought to establish that Apodaca was terminated for misconduct. It therefore fell upon Burger Time to show that Apodaca’s refusal to change the color of her hair amounted to misconduct under the standard considered in Alonzo and Trujillo. This, Burger Time failed to do and thus failed to meet its burden of proof. Moreover, Apodaca presented uncontroverted testimony that no customers complained, and some complimented her for her hair. We do not question Burger Time’s right to establish a grooming code for its employees, to revise its rules in **92 *179 response to unanticipated situations, and to make its hiring and firing decisions in conformity with this policy. However, as we noted in Rodman, â€Å"It is * * * possible for an employee to have been properly discharged without having acted [in a manner] as would justify denial of benefits. † 107 N. M. at 761, 764 P. 2d at 1319. 2 Definition of misconduct and the right to terminate. Although not directly presented on appeal in this case, we note that in their decision letters both the Appeals Tribunal and the Board of Review used the following definition: â€Å"The term ‘misconduct’ connotes a material breach of the contract of employment or conduct reflecting a willful disregard of the employer’s best interests. (Emphasis added. ) We rejected this definition in Rodman, 107 N. M. at 763, 764 P. 2d at 1321, as inconsistent with the Mitchell standard requiring a willful or wanton disregard of the employer’s interests. The use of the term â€Å"or† implies that any breach of the employment contract sufficient to warrant discharge of the employee serves as adequate grounds for denial of benefits, whether or not the employee acted in a willful or wanton manner. Where an employee has not acted with the requisite degree of ‘fault’ under Mitchell, he or she has not sacrificed a reasonable expectation in continued financial security such as may be afforded by accrued unemployment compensation benefits. † Id. at 761, 764 P. 2d at 1319. The decision of the trial court is reversed, and this case is remanded for entry of judgment consistent with the decision of the Board of Review. IT IS SO ORDERED.

Comic elements in the first act of “much ado about nothing”

In the era in which â€Å"much ado about nothing† was set the wealth and power of someone was far more credible than their personality and this is portrayed in the first few lines of the play when Leonato asks â€Å"how many gentleman have you lost in this action† and the messenger replies â€Å"but few of any sort, and none of name† he segregates the wealthy from the poor as though they are two different beings and doesn’t tell us how many lower class people died as if it is irrelevant. Vanity and hypocrisy are prominent themes that occur throughout the play, in the times of â€Å"much ado about nothing† the people were so focused on how they looked towards other people that their extravagant clothes, over the top mannerisms and the contrast in language in comparison to modern day were all somewhat outrageous and in turn humorous. Don John, the typical villain, only says one thing in act 1 scene 1 â€Å"I thank you, I am not of many words, But I thank you† this is quite a disappointing first line, the audience expects him to stamp his authority on the play but instead he stays relatively quiet, it Is an anti-climax with no climax accept the anticipation of how he will be portrayed in the play. The main comical relationship in this play is between Beatrice and Benedick and they also feature hugely in act 1scene 1. Beatrice first speaks of Benedick when she refers to him as â€Å"Signor Mountanto† which basically means ladies’ man; this is the first bit of intentional comedy in the whole play, you could argue its sarcasm or the mocking of his inability to bed down a relationship, which is ironic because Beatrice is in pretty much the same situation as Benedick. As a result of Beatrices complex humour the messenger gets somewhat confused â€Å"I know none of that name, lady, there was none such in the army of any sort† this is humorous at the messenger’s expense because of his confusion, an audience tends to like it when they are in the know and the people on stage are somewhat lost. Beatrice’s constant insulting almost seems uncontrollable, with everything she says comes some sort of insult towards Benedick. Benedick is extremely against marriage, because of the possibility of an unfaithful wife, and in lines 145 to 147 this becomes very evident, saying married men whose wives whom are unfaithful should wear caps â€Å"Is’t come to this? In faith, hath not the world one man, but he will wear his cap with suspicion?† Although Beatrice and Benedick argue every time they see each other, it can’t go unnoticed that Benedick is all Beatrice talks about, which makes it so painstakingly obvious that they will get married, it’s funny, it is also Dramatic irony because the audience know what is going to happen and Beatrice and Benedick don’t.

Early Modern Athens and Early Travellers to Greece Essay

Early Modern Athens and Early Travellers to Greece - Essay Example Since its formation in the Mycenaean Period, there have been several different civilizations that have brought new changes and new eras to the Athenian and Greek society as a whole. Each new era ushered in important societal changes that brought differing levels of modernization to the city as Greece continued to grow in importance throughout Europe and eastern civilizations. Though unified under a single ruler for many centuries, Greece not once in its long history ever unite all of its city-states to form what we now recognize as a nation until modern times (Wilson). In ancient Greece, each city-state was placed under a ruler as a territory who was governed by the emperor or king with no other unity among them. The people could relate to one another through their culture. For example, they all spoke the same language and worshipped the same gods, though they did not recognize themselves as belonging to the same union (Constantine). The ideals of a united Greek society began under t he rule of Phillip of Macedon and ended when the empire was pulled apart after the death of his son, Alexander, in 323 B.C. The Hellenic ideal of a united empire began in 338 B.C. with the Battle of Chaeronea, where Athens fell to the invading Macedonian king, Phillip (Constantine). It was after this battle that the city-states, most notably including Athens, lost their independence, eventually leading toward the unification of the Greek territories. This marked an important milestone in Greek history as Phillip of Macedon defeated the Persians, thus freeing the Greek people from slavery. Phillip ushered in the Classical Age of Greece, a time marked both by war and significant literary and cultural advances to the Greek society. His ideals of a Hellenic Greece were spread by his son, Alexander the Great, who took the throne in 336 B.C. Phillip also brought with him a new ruling class of Greeks, the Macedonians (Martin). The strength of their armies and their immense wealth set the Macedonians apart from the other Greek races. Their superiority in education and military expertise set the stage for the con quests of Alexander the Great. Alexander and his armies spread the ideals of a united Greek empire as they set out and conquered the Persians, India, and parts of Asia within a seven year period. The young ruler's goal was to spread the Greek empire to the sea, believing that in reaching the ocean he would reach the edge of the world. In each conquered land, Alexander set up new Greek cities, promoting them as centers of culture and civilization. He spread the Greek language into Asia, making it the predominant language of trade at the time. During the rule of Alexander, Athens lost its place as a dominant city in the empire (Martin). Alexander's new cultural cities were designed to enhance the education of the people, particularly in the sciences, as well as to end the Macedonian racial views of the supposed barbarians who occupied the lands to the east. The growing importance of these new cities as cultural centers left Athens obsolete in the new empire. The city still retained its importance as a wealthy learni ng center. Alexander passed away suddenly in 323 B.C. before his dream was realized. The true beginning of the Hellenic period in Greek history is marked with the

New Zealand Milk Powder problem Essay Example | Topics and Well Written Essays - 1250 words

New Zealand Milk Powder problem - Essay Example The paper discusses food security and sovereignty in New Zealand. I choose New Zealand because it has experienced various instances of food insecurity especially from the dairy sector. There have existed several instances of hunger and malnourishment in New Zealand. The paper looks into the causes of food insecurity in New Zealand and discusses the political, social and economic issues related to food insecurity. The major issue considered by the paper is the problem faced by milk powder production in New Zealand, having been the largest country in milk powder export. This country is suited in the Southwest Pacific Ocean and constitutes three major islands; Stewart, North and South Islands. It constitute of about half a million of Maori (The People) together with two million Pakeha (New Zealand European) in the north, and about 800,000 Pakeha in the south. The group is culturally a subdivision between the English and Scottish. The population recorded in 1996 was 3,681, 546 people with the North Island having 2,749, 980 and South island constituting about 931, 566 people. The urban dwellers were approximated to occupy about 85% with the city of Auckland constituting about 1 million people (Finfer et al 2004: 589). The European origin provided about 80% of the population majorly from Poland, Germany, UK, Australia and Sweden; with 14.5 stating to be from Maori decent and Pacific islanders forming the remaining. The country is under the British Commonwealth, and the head of the government is the governor general. The country is under the House of Re presentatives with 120 members and six parties. The country is no longer seen as a welfare state with all people in the same classes. Three are evidence of ethnic poverty in the areas with slums around large cities with large numbers occupied by the Maori. The country has a society that is well organized when it comes