Poes Use Of Lead Characters Essays - Edgar Allan Poe, The Black Cat

Poe's Use Of Lead Characters It is very easy to associate Edgar Allen Poe with thoughts of dreariness and darkness and with good reason as much of his writing does reflect those very downcast moods. Although, authors do like to sometimes break their stereotypes and produce things entirely different from their usual and Poe is no exception. This can be easily observed by comparing the use of his lead characters in the stories ?The Black Cat?, ?Hop-Frog? and ?The Purloined Letter.? Each character is in a different situation and the reader has a different reaction to each one according to their actions. The narrator in ?The Black Cat? is the kind of character one likely comes into contact with most in Poe's works. He is a man who is mad and in his madness commits terrible sins that can only seem justified in their own insane reasoning. He very much denies his madness from the very beginning of the story when he comes right out and says ?My very senses reject their own evidence. Yet, mad I am not.? He makes all the excuses he can come up with for his actions, but they do little more than prove his insanity to the reader. After he viciously gouges out the eye of a cat he is convinced he loves, he admits that his soul is untouched by the guilt he should be overcome with after such an offensive crime. He says ?I experienced a sentiment half of horror, half of remorse, for the crime which I had been guilty; but it was a feeble and equivocal feeling, and the soul remained untouched.? He feels himself overcome with a feeling of perverseness and cannot keep himself from doing things for no other reason than he knows they are wrong. He is not a good man, throughout the story he does multiple evil things without remorse. Hop-Frog, on the other hand, starts off his story as the underdog. ?His value was trebled in the eyes of the king, by the fact of his being also a dwarf and a cripple.? It seems he has everything against him. His sole purpose to the king's court is to be laughed at. He is not treated as though a person, but merely an object for the king's amusement and therefore he is shown respect and pity from absolutely no one excepting his only friend and fellow dwarf Trippetta whom had been captured from the same country as himself. In addition to the constant emotional torture he receives from those around him, he is in constant physical pain whenever he walks, thus the basis of his nickname ?Hop-Frog, through the distortion of his legs, could only move with great pain and difficulty along a road or floor.? Poe uses the first half or so of the story to evoke pity from the reader for Hop-Frog's sad and pathetic position and making him the protagonist and the king and his ministers the antagonist s. Although Hop-Frog does do a terrible and gruesome and terrible thing by tricking the king and his ministers and burning them alive, one finds it hard to hate him for it in light of the actions that had provoked it. In this way he is different from the narrator in our first story as they both committed great evils, but where one the reader hates for his actions the other they are better able to relate to and appreciate the justice that results. Instead of feeling pity for the victims, one finds themselves happy that Hop-Frog and Trippetta are able to get their revenge and leave the place they so hated. Hop-Frog is a good character who does to evil things but with justification. Monsieur Dupin in ?The Purloined Letter? is very much unlike either of the aforementioned characters. This story is very different to the others addressed because there are no gruesome acts of evil, no one dies and no one is subjected to painful torture. It is somewhat uncharacteristic of what one may have come to expect from Poe. Monsieur Dupin's actions are in no way evil but instead well thought out actions of wit and intelligence. He demonstrates his unconventional ways of thinking in solving the crime

Angkor Civilization Timeline and Khmer Empire Kings

Angkor Civilization Timeline and Khmer Empire Kings The Khmer Empire (also called the Angkor Civilization) was a state level society which at its height controlled all of what today is Cambodia, and parts of Laos, Viet Nam and Thailand as well. The Khmer primary capital was at Angkor, which means Holy City in Sanskrit. Angkor city was (and is) a complex of residential areas, temples and water reservoirs located north of Tonle Sap (Great Lake) in northwest Cambodia. Chronology of Angkor Complex Hunter Gatherers ? to ca 3000-3600 BCEarly Farming 3000-3600 BC to 500 BC (Ban Non Wat, Ban Lum Khao)Iron Age 500 BC to AD 200-500Early Kingdoms AD 100-200 to AD 802 (Oc Eo, Funan State, Sambor Prei Kuk), Chenla stateClassic (or Angkorian period) AD 802-1327 (Angkor Wat, Angkor Borei, etc.)Post-Classic AD 1327-1863 (after establishment of Buddhism) The earliest settlement in the Angkor region was by complex hunter-gatherers, at least as early as 3600 BC. The earliest states in the region emerged during the first century AD, as identified through historic documentation of the Funan state. Written accounts suggest that state level activities such as taxation on luxuries, walled settlements, participation in extensive trading, and the presence of foreign dignitaries occurred at Funan by AD 250. It is likely that Funan was not the only operating polity in southeast Asia at the time, but it is currently the best documented. Read more about Funan State By ~500 AD, the region was occupied by several southeast Asian states, including Chenla, Dvarati, Champa, Keda, and Srivijaya. All these early states share the incorporation of legal, political and religious ideas from India, including the use of Sanskrit for the names of their rulers. Architecture and carvings of the period also reflect Indian styles, although scholars believe the formation of states began before close interaction with India. The classic period of Angkor is traditionally marked at AD 802, when Jayavarman II (born c~770, ruled 802-869) became ruler and subsequently united the previously independent and warring polities of the region. Read more about Angkor Civilization Khmer Empire Classic Period (AD 802-1327) The names of the rulers in the classic period, like those of the earlier states, are Sanskrit names. A focus on building temples in the greater Angkor region began in the 11th century AD, and they were built and decorated with Sanskrit texts which acted as both concrete evidence of royal legitimacy and as the archives for the ruling dynasty that built them. For example, the Mahuidharapura dynasty established itself by constructing a large tantric Buddhist-dominated temple complex at Phimai in Thailand between 1080 and 1107. Jayavarman Two of the most important rulers were both named Jayavarman - Jayavarman II and Jajavarman VII. The numbers after their names were assigned to them by modern scholars of the Angkor society, rather than by the rulers themselves. Jayavarman II (ruled 802-835) founded the Saiva dynasty in Angkor, and united the region through a series of conquest battles. He established relative calm in the region, and Saiavism remained the unifying power in Angkor for 250 years. Jayavarman VII (ruled 1182-1218) took power of the regime after a period of unrest, when Angkor was split into competing factions and suffered an incursion from Cham polity forces. He promulgated an ambitious building program, that doubled Angkors temple population within a generation. Jayavarman VII erected more sandstone buildings than all his predecessors combined, at the same time turning the royal sculpting workshops into a strategic asset. Among his temples are Angkor Thom, Prah Khan, Ta Prohm and Banteay Kdei. Jayavarman is also credited with bringing Buddhism to state prominence in Angkor: although the religion had appeared in the 7th century, it had been suppressed by earlier kings. Khmer Empire Classic Period King List Jayavarman II, ruled AD 802-869, capitals at Vyadharapura and Mount KulenJayavarman III, 869-877, HariharalayaIndravarman II, 877-889, Mount KulenYashovarman I, 889-900, AngkorHarshavarman I, 900-~923, AngkorIsanavarman II, ~923-928, AngkorJayavarman IV, 928-942, Angkor and Koh KerHarshavarman II, 942-944, Koh KerRajendravarman II, 944-968, Koh Ker and AngkorJayavarman V 968-1000, AngkorUdayadityavarman I, 1001-1002Suryavarman I, 1002-1049, AngkorUdayadityavarman II, 1050-1065, AngkorHarshavarman III, 1066-1080, AngkorJayavarman VI and Dharanindravarman I, 1080-?, AngkorSuryavarman II, 1113-1150, AngkorDharanindravarman I, 1150-1160, AngkorYasovarman II, 1160-~1166, AngkorJayavarman VII, 1182-1218, AngkorIndravarman II, 1218-1243, AngkorJayavarman VIII, 1270-1295, AngkorIndravarman III, 1295-1308, AngkorJayavarma Paramesvara 1327-Ang Jaya I or Trosak Phaem, ? Sources This timeline is a part of the About.com guide to Angkor Civilization, and the Dictionary of Archaeology. Chhay C. 2009. The Cambodian Royal Chronicle: A History at a Glance. New York: Vantage Press. Higham C. 2008. In: Pearsall DM, editor. Encyclopedia of Archaeology. New York: Academic Press. p 796-808. Sharrock PD. 2009. Garu a, Vajrapa i and religious change in Jayavarman VIIs Angkor. Journal of Southeast Asian Studies 40(01):111-151. Wolters OW. 1973. Jayavarman IIs military power: The Territorial foundation of the Angkor empire. The Journal of the Royal Asiatic Society of Great Britain and Ireland 1:21-30.

Human Resource Strategy and Organizational Vision and Goals Essay - 2

Human Resource Strategy, Organizational Vision, Goals - Essay Example Since employees are the pillar of the organization, the role of human resource management becomes crucial in the employment of its workforce. In the emerging challenges of the changing business equations, when the labour deployment is undergoing quantitative and qualitative transformations, HR strategy needs to be redefined to create versatility and flexibility of the contemporary work environment. The rapid globalization and technological advancement of the recent time have greatly revolutionized the labour processes. With the advent of technology, the collective production has become more complex. There is a significant paradigm shift in the technical division of labour from direct to indirect model that is focused on regulation, administration, improvement and innovation to meet the challenges of the changing time. The human resource being central to the organizational visions and goals, HR leadership initiatives become a crucial factor for creating and organizing an effective workforce that is able to make the valuable contribution of promoting a sense of togetherness and collective responsibility that reflects in the increased output and improved performance outcome of the organizational goals and objectives. Julie Beardwell and Tim Claydon, in their book, have asserted that the theoretical concept of human resource management has become ‘fuzzy concept’ with abstract empiricism and needs to be looked from a wider perspective of providing the invaluable human capital that can meet the challenges of the rapid globalization and advancing technology. (Beardwell, Claydon, 2007). With the global competition becoming increasingly stiff, the specifications of the job are becoming less rigid and changing the overall perspective of job criteria and employment. The compulsions of the present times require versatility in the working force. Individuals and firms must embrace the culture of multi-skilled professionals that are able to meet the challenges with efficiency and unmatched proficiency.  Ã‚  

Health Care Economics Research Paper Example | Topics and Well Written Essays - 1250 words

Health Care Economics - Research Paper Example on and use of drugs that they don’t even need and also the other side.(CULS, nd) The example practices of health care fraud include billing for services that were not provided, intentional duplicate billing, erroneous prescription etc. Health Care Abuse; Health care abuse is the practice incurred for the sake of earnings out of prescriptions / applications that are not needed. The provision of goods and services that do not meet the standard of professional health care industry is health care abuse. The example of health care abuse include charging of unnecessary services or prescription of unwanted treatments etc Difference between Health Care Fraud and Health Care Abuse; the difference in health care fraud and health care abuse pertains with the nature of act. Hence, an act that results into unnecessary treatment / prescription falls under the category of health care abuse but the acts that deliberately aim to charge an extra cost out of cheating is counted in the definition of health care fraud. Waste; It refers to the provision of goods and services that were intended not to swindle or mislead but the payment methods that unintentionally raised the cost due to organizational errors. Rules and Regulations Related to Health Care related Fraud and Abuse; The various laws related to Health Care fraud and abuses are stated below for an overview; each of the below mentioned code followed by their clauses render a different impact on the case based on the execution. False Claims Act (FCA), 31 U.S.C., s. 3729 Florida False Claims Act, F.S. 817.234 Anti-Kickback Statute 42 U.S.C. s. 1320a-7b(b) Physician Self-Referral (â€Å"Stark†) Statute, 42 U.S.C. s. 1395nn Deficit Reduction Act of 2005 HIPAA of 1996, Title 18, Section 1347 Fraud Enforcement and Recovery Act of 2009... This research paper explores the health care economic system of the United States and it's strategies as well as frauds problem that are becoming a widespread issue at present time that needs immediate attention of authorities for raising preventive measures. In the year 2008 the reporting of United States department of Health and Human service office of inspector general reveals the elimination of around 3,000 personnel against accusation of health care related fraud and abuse. Out of these 575 were criminal graded actions and 342 were the civil action abuses. The estimated loss mentioned in the research paper incurred out of the wastage was around $20.4 billion. Although the benefits of medications when used properly cannot be under estimated but the control of resources will grant the improvement in all the other sectors directly and indirectly. Evidence based training with the utilization of strategy that was proposed in this research paper will support the authorities to raise t he potential of professional staff by rendering compact training with plans based on rationale of evidences. A thorough education of policies and procedures along with the training sessions in support of new practices induced via evidence based evaluation will aid the health care authorities to attain an improved level of control on health care delivery. The researcher states that a mutually cooperative exercise will not only aid the socio economic structure but will further improve the system by contracting the space for illegal practices.

The Most Influential Person in This Era Essay Example for Free

The Most Influential Person in This Era Essay The world in gradually evolving day by day and it is us, the people from all over different countries, who make it happens. But like always, there are those people whose influence, despite the distance, affect others across the nations and whose names stick forever in the history. On the contrary, there are also people who individually change our life. Bill Gates, for instance, has brought us to the whole new level of technology with his invention of Microsoft, which is known to be the most dominated software for computers. Microsoft also became the name of the largest software corporation. There is no doubt that without his role there would not be any work done, there would not be any lists completed. As an ordinary person himself, I believe Bill Gates grew up with the same thing we have today. But what made him what he is today, are inevitably his determination to cross the boundaries, his intrepidity to take a risk, his perseverance to keep trying to reach his goal, and last but not least, his luck. Other experts at that time might time he was doing such an empty gesture, but knowing the truth that he eventually succeed, they might have a bitter pill to swallow. Even today, his name is widely spread. He even made it to the top list of the most influential people all over the world. Despite the fame, he is still willing to care for the needy. His investment in The Bill and Melinda Gates Foundation means not only immediate advances for some, but also a ripple effect to many others. Improving life means a better living condition and a new hope for the future. By his work and donations, he has encouraged people of great and lesser wealth to be more considerate and to work for the good of the world community. We always think that it is formidable to be successful. We think that we should be the number one at school, we have to master some special skills, and whatsoever. But a matter of fact, those things are not really necessary. We do need to learn a lot but our success is not always determined by how many books we read and how adroit we are in certain subjects. I ever read something really interesting about Bill Gates where he quoted â€Å"I failed in some subjects in exam, but my friend passed it all. Now he is an engineer at Microsoft and I am the owner of Microsoft.† You can never predict when you will actually be the future most influential person.

Japanese literature :: essays research papers

Vernon McCalla Japanese Literature Question #2  Ã‚  Ã‚  Ã‚  Ã‚     Ã‚  Ã‚  Ã‚  Ã‚  2. Individualism has been seen as a characteristic feature of the modern world. How do we see the issue of individualism being dealt with in the works we have read? Discuss examples of individualism in both modern and pre-modern texts.   Ã‚  Ã‚  Ã‚  Ã‚  In the works we have read, the characteristic of individualism has played a strong role in the lives and decisions of three characters in particular. The characters Basho, Chockichi, and Okada all display similar acts of individualism in their own stories as they depart not only from their homes but also the traditions that have helped shape their lives for many years. These characters leave behind the familial and societal values that were vastly present in Japanese tradition. With their decisions to be individuals, they obtain new attitudes and standards that relate to, money, education and security. The new values attitudes are what brought Japan into a modern way of thinking and left old values and traditions behind.   Ã‚  Ã‚  Ã‚  Ã‚  Individualism is the belief in the primary importance of the individual and the virtues of self reliance and personal dependence. Basho shows his independence by leaving his home front and traveling north. He does this in order to see new places, visit sites of earlier poets, and to spread his views. For Basho traveling is a way of life, and because he travels alone one could say that Basho is very much an independent individual. Throughout Basho’s Narrow Road it seems as if there is a lack of people he encounters on such a long journey. The reader does not know if this is because Basho chooses to leave out the people he meets from his story or because he truly does not encounter many. In any way, the lack of people in the story puts the spotlight solely on the main character, Basho. With this, Basho rejoices in his individualism by going against traditional Japanese values and the unknown. Basho can be described as a pre-modern individual. His journeys are not for money or to enhance his social status; they are for his own personal benefit in order to see more of Japan and to become inspired by nature and its beautiful surroundings. Traveling for Basho is his life, unlike many traditions of Japan where supporting a family and working are a way of life, he chooses a different path. By this Basho chooses a life that is centered around himself and based on personal dependence and happiness.

Indian tribe`s inherent sovereign authority Essay

INTRODUCTION: U.S Chief Justice John Marshall, in his milestone trilogy of   his decisions on Indian law in 1] Cherokee Nation v.Georgia 2] Johnson v.Mclntosh and 3] Worcester v. Georgia framed the foundation for Indian law viz. Indian tribes are under the trust protection of the federal government which stands good even today. As such, many tribes are enjoying the quasi-sovereignty status and have organized their own governments together with functional legislative, executive and judicial branches. Indian tribal courts function more or less in their Anglo-American colleagues and offer an intra-tribal tool for dispute resolution. The Supreme Court held in â€Å"Oliphant v.Suquanmish Indian Tribe â€Å"that for want of congressional action, tribes lacks inherent jurisdiction to punish outsiders.   Congress yet to legislatively recognize the Oliphant by extending jurisdiction to tribal courts to try criminally any non-Indians for the felony committed in the Indian regions This research paper will divulge how this jurisdictional predicament causes a practicable problem in United States Judiciary and possible ways and means to address the issue. INDIAN SOVEREIGN AUTHORITY TO EXERCISE CRIMINAL JURISDICTION OVER NON-INDIANS- AN ANALYSIS: Crimes against native Indians are unleashed by non-Indians on daily basis. Crimes committed by non-Indians are cognizable offence that can be prosecuted only by federal district court by federal prosecutors. Unfortunately, many federal prosecutors have abandoned their duty to pursue crimes in Indian country committed by non-Indians due to overburden. The emergence of the Indian courts owed its origin to the tribal justice systems that predate the European settlement of America. On the basis of the age old convention, Congress has recognized the sovereign authority of tribes to maintain their own courts. But, Congress has limited that sovereignty as tribal courts have little jurisdiction over non-Indians .This is mainly intended to ensure that Indians are guaranteed the same constitutional rights as other Americans. As a result, tribal courts over the last two decades have lost their elite authority to try cases involving grave felonies and to enforce criminal penalties on non-Indians. In the year 1990, Supreme Court stripped Indian tribal courts of the power to hear cases involving Indians of a different tribe. But the Senate Select Committee on Indian Affairs later voted to reinstate that right to tribes for the next two years. [1992 to 1994]. In 1968, Congress established the Indian Civil Rights Act to offer on tribes requirements akin to those found in the Bill of Rights. There are about 147 tribal courts that exercise jurisdiction over nearly two million Indians in the United States in the year 1992. Tribal courts have exclusive jurisdiction over civil cases that arise between Indians on the reservations. But, if the plaintiff or defendant is other than Indian, state courts may have a simultaneous or even exclusive exercise rights to hear the case. In, â€Å"Oliphant v.Suquamish Indian Tribe† , 435 U.S, 55 L.Ed , 2d , 98 S.Ct, 48 U.S.L.W .4210 it was held that no inherent rights is ascribed to any Indian tribal courts to prosecute and punish non-Indians for offenses committed on Indian lands. It was the contention of the Indian tribes that jurisdiction is automatically conferred on them for trying any offenses of criminal nature on non-Indians in tribal lands as Supreme court made an opinion describing Indian tribes as â€Å" quasi –sovereign entities’. However, Supreme Court has observed in the present case that whenever efforts have been exercised in the past, it has been observed that there exists no jurisdiction. The tribal is having no authority to try non-Indians as it was established by earlier judicial opinions and also according to the general view of the executive authorities. But Judge Marshall, joined by the Chief justice dissented in the above case by taking the view that the power of preserve order on the reservation was a sine quo non of sovereignty that the Suquamish originally possessed. He further noted that in the absence of positive extraction of such rights by any treaty or statue ,the tribal enjoy as a necessary aspect of their sovereignty the right to try and punish all persons who commit offenses against tribal law within the reservation. In the past years, several Supreme Court rulings have drastically delineated the power of American Indians to govern their territories. The High Court ruled in 1978 that tribal courts cannot prosecute whites or other non-Indians for some felonies committed on tribal land. In one case, the justice held that a tribal court has no jurisdiction over crimes committed on that tribe’s land by members of another tribe. There are certain rulings that restricted Indian authority in taxation and zoning. Tribal leaders argue that U.S government apparent move away from recognizing ‘inherent sovereignty â€Å"of the Indian nations, which predate the arrival of whites to this continent makes them to worry. Though, the tribal leaders were not asking to overturn the Supreme Court’s ruling in Oliphant v. Squamish Indian Tribe but they were demanding to overturn the High Court rulings in Duro V. Reina, which prohibited the Salt River Prima-Maricopa Indian Community in Arizona from prosecuting on a misdemeanor of weapons charge by an Indian man who lived in Salt River but was a member of a tribe in California. Thus, the rulings left a judicial void in states that do not assume jurisdiction over such misdemeanors and Congress temporarily restored jurisdiction to the tribes during 1990. 2.1 CRIMINAL JURISDICTION TO TRY NON –INDIANS TO COMBAT TERRORIST THREAT: In their effort to revive an amendment to the Homeland Security Act that would offer criminal jurisdiction over non-Indians to combat terrorist threats on Indian lands. But opponents were of the view that it will topple a 25-years –old Supreme Court decision â€Å" limiting and defining Indian sovereignty â€Å" and could lead to tribal power grabs which may affect of millions of non-Indians. Further, there is a proposal to reclassify the tribal governments as â€Å"states â€Å"under HSA law which facilitate tribes to receive sufficient federal funding and technical expertise to play a meaningful role in fighting terrorism. During 2003, the Senate Indian Affairs committee tried to add some amendments to homeland security bill but it was not successful as some group hit the panic button claiming that amendment would authorise control over all people for all purposes. The vested group fears that there would be other jurisdictional grabs by the tribal governments and tribes could exert authority over non-Indians by ignoring the fact that non-Indians cannot vote in tribal elections. The proposed amendment which has been officially designated as S.578 and the department itself has supported the first 12 sections of the amendment or those that would authorise the reclassification of tribal governments as states [not local government] in dealing with terrorism. But as per Heffelfinger, who is also chairman of the Attorney General Advisory Committee’s Native American issues subcommittee commented that the departments itself is not supporting section 13 , which would offer tribes the power to â€Å" enforce and adjudicate violations of civil , criminal and regulatory laws committed by any person on land under the jurisdiction of an Indian tribal government. But, as per 2000 census, non –Indians account for more than 48% of reservation residents who live on or near Indian reservations from discrimination â€Å"by state, federal or tribal government or their policies. Some critics view the proposed amendment to the Homeland Security Act violates the 1978 â€Å"Oliphant v.Suquamish Indian Tribe† rulings where Supreme Court observed that tribes do not have criminal jurisdiction to try and punish non-Indians. In real situation, the state or federal government is toothed with the power to arrest and try criminal offenders who are not Indians on Indian lands.   In other words, there is no need to arm the tribal government to initiate criminal proceedings on non-Indians on tribal lands as the state or federal government has adequate power to execute the same. [1] 2.2 OVERBURDENS OF FEDERAL COURTS: One the problem faced by tribal is that some of the felonies committed by non-Indians on tribal have been let off due to overburden of cases in federal courts and Supreme Court judgment which   had declared that non-Indians can not be prosecuted by the tribal courts. For instance, military courts do not have jurisdiction to prosecute the civilians who have infringed military’s interest. In such cases, â€Å"special assistant United States attorneys† [SAUSA’s] have the authority to prosecute such violators who have committed crimes against military personnel and property. The same strategy can be followed in the tribal cases also. Thus, the department should authorize Indian prosecutors to sue in the federal courts for the crimes committed by the non-Indians within Indian country.   2.3 USE OF MEHTAMPHETAMINE: Another issue encountered by the American tribes and tribal groups is their relentless fight against use of methamphetamine which they regard an epidemic on tribal lands. Lummi Nation of Washington, an American tribe is waging war with meth by imposing rigorous punishment to offenders. Some tribes are addressing the issue through new drug courts. Methamphetamine production and trafficking on tribal reservation with huge geographic areas or tribes adjacent to the U.S. –Mexico border is rampant. As the tribal states enjoy sovereign status, criminals are generally not subject to state jurisdiction in most of the cases. As the local law enforcement authorities have no jurisdiction in Indian country and tribal law enforcement agencies take the responsibility to enforce the relevant law enforcement functions. To combat the use of meth in tribal areas, Indian Tribes Methamphetamine Act of 2007 and Indian Tribes Methamphetamine Reduction Grants Act of 2007 were introduced in January 2007.   The legislation would permit Indian tribes to be eligible for funding through the department of Justice to exterminate the scourge of meth production, sale and usage in Native American communities. Enough safeguard measures are built in to avoid any potential misrepresentation of the above legislations. It has been clearly stated in section 2 [a] [4] of the bill , the Department of Justice’s Bureau of Justice Assistance is toothed with power to award grant funds to a state ,territory or Indian tribe to â€Å" explore ,detain and indict individuals â€Å"   involved in illegal meth activities. Further, it does not authorize a grantee state, Indian tribe or state to pursue law enforcement activities that it otherwise has short of jurisdictional authority to pursue. 2.4 PUBLIC LAW 280 Normally, states do not have jurisdiction over the internal legal of the sovereign tribal governments. Under certain circumstances, Congress has extended special exceptions this general principle. Under Public Law 280, six states were given exclusive jurisdiction over the Indian country within the state borders. Thus, states like New York, Kansas have the exclusive right over to prosecute the crime committed within the Indian country as the federal government has ceded its jurisdiction. Federal government ceded their prosecuting authority to states in these states. But it has created unfavorable situations as most states are reluctant and intransigence to cognize crime on Indian reservations seriously. Many state district attorneys are reluctant to exercise their limited resources on Indian crime. Thus, Public Law 280 has resulted in lawlessness in almost all Indian reservations. Ceding the federal authority over Indian territories to states has ended in a lacuna. It is painful to note that even if a state government has inherent authority in a particular Indian region, it sometimes lacks institutional strength to exercise authority in that region. Further, there exists always simmering tension between Indians and state governments. It is to be observed that since Worcester v.Georgia, states have no authority or very little authority over Indian country. The real reason for tension between tribal and state government is the criticism of action of state police department as they always rubbing on the wrong side of the tribal cultural practices. A study conducted by Carole Goldberg Ambrose[2] revealed that relationships between state and tribal are often got off to potholed and sometime unfeasible. Frequently, California tribal members complained that when state police tried to solve the tribal problems, they often failed as they were disrespectful to tribal sovereignty, lacked cultural compassion and always deployed excessive force. Further, if the alleged offence is a violation of generally applicable federal statutes like sedition and mail theft, the federal government is alone having exclusive jurisdiction to try the offence and natives are not exempted from such offence 2.5 OLIPHANT V. SUQUAMISH INDIAN TRIBE’- AN ANALYSIS: In, ‘Oliphant v. Suquamish Indian Tribe’ case, Supreme Court held   that as the tribal court lacks inherent jurisdiction to prosecute non-Indians for the felonies committed on Indian jurisdiction and recommended that it is the Congress to decide whether Indians tribes should finally be authorized to try non-Indians . Thus, Supreme Court decision may not be final and binding since Congress retains authority in exercise of its plenary power. Oliphant case centered around the incidents that happened on the Suquamish Reservation located near Port Madison, Washington. Indian tribes had waived all of their land claims in Washington state under the Treaty of Point Elliott which was signed in 1855 and accepted to settle on a 7300 –acre reservation located near Seattle. The tribes adopted a criminal code in 1973 and any infringement of tribal’s criminal code is prosecuted in the Suquamish Indian provisional Court. It is the claim of the tribes that they have jurisdiction to try non-Indians for any violation or infringement in their land. In support of their claim, they have displayed billboards in prominent places at the entrances to the Port Madison Reservation warning the public that entry onto the Reservation would be deemed implied consent to the criminal jurisdiction of the Suquamish tribal court and one may hilarious to note that Suquamish tribal specifically excluded non-Indians from serving on tribal court as juries. Supreme Court had placed the burden of proof on the tribe to substantiate its contention of jurisdiction. The tribe argued that its jurisdiction over non-Indians emerged involuntarily from the Tribe’s retained innate powers of government over the Port Madison Indian Reservation. Tribe has argued that flow of criminal jurisdiction is automatic over all persons on a reservation –Indian or non-Indian and is arising out of a ‘sine qua non ‘of tribal sovereignty. Supreme Court has rejected the argument of tribal claiming inherent jurisdiction on multiple grounds. Supreme Court concluded that Congress had positively expressed its intention not to grant Indian tribes the power to punish non-Indian after thoroughly examining the opinions of attorney generals, history of treaties, legislative history and district court decisions. Supreme Court once again asserted that Congress which is being law making authority is having sole discretion to decide whether the tribal can prosecute non-Indians for felonies in their land. In the Oliphant’s case, Justice Marshall joined by Chief Justice Burger took the opposite view as the Marshall believed that tribes processed the innate jurisdiction over non-Indians and that congressional action was necessary to strip off Indians of that jurisdiction. Oliphant decision was a major set back to Indian community claim of sovereignty in the following respect: It publicized that Indians were toothless to dissuade non-Indians from committing crimes against them. Tribes viewed that Supreme Court decision had indeed handcuffed their law enforcement activities. Tribes viewed the decision as a major blow on their powers to safeguard their own people. Decision culminated to an awkward situation to tribes by restricting their power to judge, prosecute or punish with tribal law and tribal courts, the non-Indians who commit felonies on tribal land. 2.6 DURO V.REINA- AN ANALYSIS: Duro v.Reina is a subsequent case after Oliphant. This case has further minimized the power of the tribal court to punish â€Å"outsiders â€Å", people who are not members of the tribe. Albert Duro was the member of one sect of Indian tribe namely Torres-Maritinez Band of Cahuilla Mission Indians. It was alleged that Duro killed a boy on the Salt River Indian reservation. Salt River Indian tribes attempted to prosecute Duro in their tribal court. The federal district court restrained the Salt River Prima –Maricopa Indian Tribe to prosecute Duro who belongs to Torres tribe. Thus, Supreme Court also concurred the federal district court view and held that Indian tribes did not have jurisdiction over Indians who were members of other Indian tribes. This made the Congress to exercise its plenary power and Supreme Court decision was amended or altered by the Congress through amendment U.S.C 1301 to authorize the tribal courts to exercise â€Å"criminal jurisdiction over all Indian and not just member of Indians. Critic’s view that Supreme Court had crushed the Indian rights is a bit of hypocritical as the Congress can always make use of its plenary power –a-type of legislative veto –to correct the intrinsic relationship as articulated by the Court. 2.7 ANALYSIS OF SURVEY OF U.S. JUSTICE DEPARTMENT: According to survey conducted by Justice Department of U.S., American Indians suffer from certain violent crimes like robbery, rape at a rate twice the national average. About 30,000 crimes of violence are committed against Indians each year. Native Indians complained that their attackers were under the influence of alcohol or meth at a greater than the national average. It is alarming to note that Indians were fatalities of interracial violence at a startling rate of 72% and 91% of sexual assaults against the tribal members. Further, offenders against Indian tribes were about 70% It is to be noted that a crime committed against an Indian by non-Indian which occurs outside of Indian country is subject to state jurisdiction and therefore is not reported in the above statistics. Thus, the above statistics reveal a disturbing picture of crimes against Indians and Indians face a disproportionately higher rate of violent crimes than any other races in U.S.A. For instance, Indian victims are reporting about 30,000 possible violent crimes to police each year and out of this, police could not solve more than 28,000 incidents or about 94% of the crimes reported remain uninvestigated or go unpunished. Further, Indians are also affected by the property crimes and victimless crimes committed by the non-Indians and these were not included in the above statistics since these were of civil nature.   The main reason for such alarming rates of criminal reports are being uninvestigated is mainly due to great distance between federal courts and tribes and overburdened law enforcing department. One of the allegations against Indian judiciary is that Indian courts do not bestow equal justice to non-Indians. For example, in Oliphant case, the Court took note of the fact that non-Indians were excluded from occupying juries’ role in Suquamish.   Thus, a doubt arises whether non-Indian constitutional right to be tried by an Indian jury could deliver unquestionable justice to the accused. The Indian Civil Rights Act of 1968 ensures basic due process protections to Indians who are tried in tribal courts and to ensure non-Indians offenders rights, the same process of protection can be extended to non-Indians. As such, non-Indians allegation that tribal courts are iniquitous may not hold good. 2.8 POSSIBLE SUGGESTIONS FOR AVOIDING OLIPHANT TYPE OF INCIDENTS IN FUTURE: Federal court is already overburdened with cases like violations under a]Patriotic Act , b]Money Laundering Act 3] RICO 4] Narcotic Offenses 5] Interstate Crimes 6] National Security Offenses 7] Stock Exchange Commission 8] Other type of Crimes .Whereas , offenses committed by non-Indian in tribal areas are of nature of minor offences like 1] reckless or speed driving 2] drunk driving 3] petty assault 4] petty theft 5] Vandalism 6] Littering   7] Parking Violations . Naturally federal prosecutors do not give more importance to these offenses and hence lion’s share of these offenses went unpunished. To instill confidence on tribal community, Congress should seriously think of creating exclusive federal courts which may be designated as â€Å"special courts â€Å" for prosecuting offenses committed on tribal by non-Indians in tribal areas.   For instance , in the District of North Dakota , Chief Judge Rodney Webb to address the problem faced   by Indians against felonies committed by non-Indians held meetings with the officials for their prosecution As per ICRA [Indian Civil Rights Act], Indian tribes may not impose any penalty or punishment which is longer than for a term of one year and a fine of $ 5000 or both. This clearly demonstrate that tribal courts have limited authority to try minor offenses like less serious felonies or misdemeanors there by leaving serious crimes to the federal government . Further, there is a misconception among non-Indians that tribal courts are not like Anglo-American tribunals. It is pertinent to note the remarks made by Justice Rehnquist in Oliphant that â€Å"some Indian trial court systems have become progressively much classy and resemble in many ways their state counter parts†. Hence, non-Indians should be properly educated and Congress should see that they are convinced by drafting a new legislation extending tribal courts power to prosecute non-Indians within the parameters designed by the Congress in this regard. One another remedy is to depute special law enforcement officer to investigate or prosecute the crime. A â€Å"special assistant district attorney â€Å"may be appointed to represent the district attorney for a particular case or a special investigating officer may be deputed to execute restricted law enforcement functions. Thus, the power to deputize is also known as a statutory grant. A statutory grant is having inherent power to specially deputize any higher officials. The deputization will be more advantageous as it would satisfy the interest of the all concerned including tribal and non-Indian offenders though the offenders will be punished under federal or state laws not under the tribal laws. CONCLUSION: De-facto immunity is being used as scapegoat by non-Indian offenders against Indians. It is really a shame that American judicial system is dissuading Indians to punish the non-Indian offenders who have committed felony in their lands under tribal criminal laws. It is real predicament that majority of the crimes against Indians by non-Indians escape punishment. The Oliphant v Suquamish Indian Tribe case is a severe blow to the Indian legitimate rights which Congress should come forward to redress. Congress should exercise its plenary power as it had done in Supreme Court decision in Duro v.Reina which was later amended or altered by the Congress through amendment U.S.C 1301 to authorize the tribal courts to exercise â€Å"criminal jurisdiction over all Indian and not just member of Indians. Further , to instill confidence on tribal community, Congress should seriously think of creating exclusive federal courts which may be designated as â€Å"special courts â€Å" for prosecuting offenses committed on tribal by non-Indians in tribal areas. One another remedy is to depute special law enforcement officer to investigate or prosecute the crime. The deputization will be more advantageous as it would satisfy the interest of the all concerned including tribal and non-Indian offenders though the offenders will be punished under federal or state laws not under the tribal laws. Deputization will assimilate all law enforcement agencies together to work unitedly.   Deputization is the need of the hour as it will bring all the parties involved under a single umbrella within the current jurisdictional. Further, as in the case of military courts which do not have jurisdiction to prosecute the civilians who have infringed military’s interest and in such cases, â€Å"special assistant United States attorneys† [SAUSA’s] have the authority to prosecute such violators who have committed crimes against military personnel and property. The same strategy can be followed in the tribal cases also. Thus, the department should authorize Indian prosecutors to sue in the federal courts for the crimes committed by the non-Indians within Indian country. BIBILIOGRAPHY Chiu, Elaine M. â€Å"Culture as Justification, Not Excuse.† American Criminal Law Review 43, no. 4 (2006): 1317+. 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Lawson, Paul E. â€Å"When States’ Attorneys General Write Books on Native American Law: A Case Study of Spaeth’s American Indian Law Desk book.† American Indian Quarterly 19, no. 2 (1995): 229-236. Nielsen, Marianne O. and Robert A. Silverman, eds. Native Americans, Crime, and Justice. Boulder, CO: Westview Press, 1996 Nourse, V.F. â€Å"Reconceptualizing Criminal Law Defenses.† University of Pennsylvania Law Review 151, no. 5 (2003): 1691+. Parman, Donald Lee. Indians and the American West in the Twentieth Century. Bloomington, IN: Indiana University Press, 1994. Pevar, Stephen L. The Rights of Indians and Tribes: The Basic ACLU Guide to Indian and Tribal Rights. 2nd ed. Carbondale, IL: Southern Illinois University Press, 1992. Prucha, Francis Paul. The Great Father: The United States Government and the American Indians. Lincoln, NE: University of Nebraska Press, 1984. Ramirez, Deborah A. â€Å"A Brief Historical Overview of the Use of the Mixed Jury.† American Criminal Law Review 31, no. 4 (1994): 1213-1224. [1] â€Å"Indian Wants Jurisdiction to Combat Terrorism Threat â€Å", Washington Times, Jan 26, 2004. [2] Carole Goldberg –Ambrose, â€Å"Public Law 280 and the problem of Lawlessness in California Indian Country, 44 UCLA L.Rev. 1405 [1997].