#all the ways Crow was given a chance to avoid that cruelty

[fdragon-art]

Day 31 (30 Days | Homestuck - Day 17) - Favourite Sprite (Davesprite Crow Strider, as seen in @meraki-sunset's Crow Strider AU)

"Why don't you just ascend?"

A single statement that would alter the course of this timeline to a previously unimagined haven of possibility.

[easyweight101]

L’Oreal Eye Defense Eye Cream Review (UPDATED 2017): Don’t Buy Before You Read This!

L’Oreal Eye Defense Eye Cream is an affordable eye cream made to hydrate the skin and plump skin cells for a younger-looking appearance. According to the makers of this product, this product is designed to erase fine lines and reduce the appearance of dark circles.

L’Oreal Eye Defense Eye Cream features key ingredients like hyaluronic acid and caffeine, which bring moisture and improved blood flow to the area of application. This product is fragrance-free, ophthalmologist tested, and safe for wear with contact lenses.

Kremovage is the best product on the market for reducing wrinkles and fine lines, while firming and restoring the skin around the eye. This product is made with nourishing ingredients like squalane, aloe vera, Matrixyl 3000 and ocean-based retinol—offering a diverse range of benefits you won’t find anywhere else. Click the link to learn more about Kremovage’s skin-nurturing formula.

Do You Know the Best Eye Creams of 2017 ?

L’Oreal Eye Defense Eye Cream Ingredients and Side Effects

While L’Oreal Eye Defense Eye Cream contains a long list of ingredients, we’ve elected to profile the most active components featured in the blend. Here is a quick look at what users can expect from this anti-aging eye cream:

Caffeine Hyaluronic Acid Jojoba Oil Oat Kernel Extract

Caffeine: Caffeine is rich in antioxidants and may improve blood flow with application—reducing the appearance of puffiness and dark circles.

Hyaluronic Acid: Hyaluronic acid is a naturally occurring substance that works to keep eyes moist and joints lubricated. This ingredient is used in skin care products for its ability to hydrate dry cells and for retaining moisture—which reduces the appearance of wrinkles and fine lines with use.

Jojoba Oil: Jojoba oil has the dual benefit of being an antibacterial ingredient, as well as a hydrating oil. Jojoba oil is lightweight and won’t clog pores, so it’s safe for people concerned about acne.

Oat Kernel Extract: Oats have a soothing effect on the skin and may alleviate conditions like eczema, psoriasis, itching and redness. This ingredient has an anti-inflammatory effect and may also help the skin retain moisture.

Click the link to learn more about using Kremovage to treat your crow’s feet, fine lines and more.

L’Oreal Eye Defense Eye Cream Quality of Ingredients

L’Oreal Eye Defense Eye Cream has some good ingredients included in the mix. For example, jojoba oil and hyaluronic acid are great skin soothers—bringing lasting moisture to the under eye area.

Oat kernel extract brings additional soothing to the table and is a great ingredient for people with really dry or sensitive skin.

And finally, caffeine. A great tool for eliminating excess water lingering in the eye area, as well as for improving blood circulation, this antioxidant-rich chemical can be really effective as a topical under eye solution.

So, as you can see, this formula has a lot going for it. But, there are some issues. Being lower cost eye cream, the ratio of active to inactive ingredients is not great, as one might expect. There are only four items included that serve a purpose, while there are a number of ingredients that function as preservatives or to take up space.

Unfortunately, this product contains several types of parabens—preservatives that have been linked to breast cancer. While this link needs to be explored further, many people prefer to avoid parabens altogether.

This product may have some potential, but the fact that contains more inactive ingredients than active ones cheapens the product to some extent.

Smooth out the skin with these top-shelf eye creams — to view, click the link here.

EDITOR’S TIP: Combine this product with a proven eye cream such as Kremovage for better results.

The Price and Quality of L’Oreal Eye Defense Eye Cream

L’Oreal Eye Defense Eye Cream is sold directly on the L’Oreal website for $13.89 for a jar containing 0.5 ounces of product. This product may also be purchased through Walmart, Ulta, Amazon, Walgreens, Target and countless other platforms.

Nearly all of these sites offer this eye cream between $12 and $15 meaning, you’re unlikely to score a major discount, but you can expect a consistently low price.

As far as value is concerned, you can’t argue with a product that contains some decent ingredients and sells for under $15. But, chances are, it doesn’t come with the potency you’d find with some of the higher end products on the market.

If you don’t care about parabens, L’Oreal Eye Defense Eye Cream may be an effective tool for helping users stave off some of the early signs of aging with use. This just may not be effective enough for someone looking for a more aggressive attack on wrinkles.

Check out our guide to the best eye creams at every price point — more info by visiting our website.

Business of L’Oreal Eye Defense Eye Cream

L’Oreal Youth Code Eye Cream is made by the company, L’Oreal. Here is their contact information, along with some background:

Address: 41, Rue Martre 92117 Clichy Cedex France

Phone: +33(0) 1 47 56 70 00

L’Oreal has been in business since 1953, and is a well-known cosmetics and skin care company, with an empire that penetrates both online and brick and mortar stores. L’Oreal is known for making a range of affordable makeup products, as well as various creams and anti-aging solutions.

Surprisingly, given that this is a major global company, L’Oreal has a solid e-commerce channel, where consumers can order products directly, sign up for deals and learn a bit more about the various items.

Unfortunately, you’ll have to go elsewhere to find an ingredient label for this particular product—we found this information posted on the Walmart site. We’re not sure why L’Oreal has opted to leave off this critical piece of information, but a little transparency goes a long way with consumers.

What we did like about L’Oreal is, they make sustainability and cruelty-free formulations a priority, which is refreshing, given the reach of this company—as a point of reference, L’Oreal owns Kiehl’s, Maybelline and several other brands.

We believe that consumers can find more effective products than L’Oreal Eye Defense Eye Cream, but it’s worth pointing out that users can expect this brand to be safe and consistent. Should you opt to try a lower cost eye cream, L’Oreal is one of the better brands on the market. With that in mind, we’d suggest users with more pressing under eye concerns invest in a more potent product.

Customer Opinions of L’Oreal Eye Defense Eye Cream

L’Oreal Eye Defense Eye Cream has pretty mediocre reviews. For one, people didn’t find this product to be a very effective tool for reducing the appearance of wrinkles.

Instead, it seems better suited for puffiness and dark circles, though results varied considerably.

Here are some of the comments we found during our research:

“Works pretty good! This product really does reduce the appearance of dark circles. I don’t feel like the anti-aging benefits are there, but I’m more concerned with how I tired I always look. Not bad, L’Oreal!”

“I have sensitive skin and clearly this product is not designed with that in mind. Upon contact, this product gave me an itching, burning sensation.

“I like the pink glowy look this product provides. It offers a slight cooling sensation and really does help me look more awake and less puffy. Not sure about fine lines though.”

“Really feeling neutral about this. It doesn’t provide the benefits advertised—I still have dark circles and fine lines, but I like the way it feels. I don’t think it’s a bad product, but it doesn’t do enough for me.”

It’s hard to make a definitive judgement on this product. Many people did seem to like it, or at least acknowledged it had some benefits.

But, the comments reflected our primary concern; that this didn’t provide the potency needed to solve concerns that extend beyond dark circles.

Restore that youthful glow! Click here to read through our favorite reviews of the best eye creams and serums.

Conclusion – Does L’Oreal Eye Defense Eye Cream Work?

We’re on the fence about L’Oreal Eye Defense Eye Cream. On the one hand, it’s affordable and easy to find. There are some good ingredients present, like hyaluronic acid and caffeine, but we’re not sure this product is going to do enough for consumers with long standing wrinkles, sagging skin or age spots.

The target audience for L’Oreal Eye Defense Eye Cream is a younger consumer—someone with few visible signs of aging, but is looking for a dependable antiaging solution.

In the end, we believe this product just doesn’t cut it. It’s full of filler ingredients and parabens and rather light on the good stuff.

Kremovage is our expert reviewers’ number one choice when it comes to an eye cream that delivers all the right benefits. It’s got a potent defense against crow’s feet and wrinkles, courtesy of Matrixyl 3000 and ocean-based retinol. There’s also the soothing green tea and fruit extracts, bringing repair and protection from environmental damage, as well as a hydrating lineup plant-based oils.

Kremovage was made in an effort to give consumers a high-quality eye cream made from a range of organic ingredients that give skin the nutrition it needs to maintain that youthful appearance. Click this link to take a look at the full formula behind Kremovage.

from Easy Weight Loss 101 http://ift.tt/2hyCwof via The Best Weight Loss Diet In The World

[nancyedimick]

Why Trump’s refugee order is unconstitutional discrimination on the basis of religion

Former New York City, Mayor Rudy Giuliani, the Trump adviser who helped draft the President’s executive order on refugees.

A federal court recently enjoined Donald Trump’s executive order barring refugees and migrants from seven Muslim-majority nations. One of the main issues at stake in the growing legal battle over the order is whether the order qualifies as unconstitutional discrimination against Muslims. Despite a thin veneer of religious neutrality, the order does in fact target Muslims. And that should indeed lead courts to strike it down.

On its face, the order does not discriminate on the basis of religion. The text does not even mention Muslims or any other religious group by name. But the Supreme Court has long recognized that a seemingly neutral regulation qualifies as unconstitutional discrimination if the true purpose behind it is in fact to target a specific racial, ethnic, or religious group. It applied that principle to racial discrimination as far back as 1886, and more recent decisions apply it to discrimination on the basis of religion, as well. In a 1993 case, the Supreme Court struck down a seemingly neutral law banning cruelty to animals because evidence showed it to have been motivated by hostility to the Santeria religion.

I. Trump’s Order Targets Muslims.

In some cases, it is difficult to figure out the true motive behind a facially neutral law or regulation. But, as Brown University Professor Corey Brettschneider explains in an excellent article, that isn’t a problem here:

[A] closer look at the executive order’s origins makes clear that it is a direct assault on the fundamental constitutional values of equal protection and religious freedom. How do we know this? Because Trump’s adviser, former New York Mayor Rudy Giuliani, told us so.

Interviewed on Fox News on January 28, Giuliani explained how the administration’s immigration policy morphed from one that was obviously unconstitutional to one that is more subtly so. Host Jeanine Pirro asked, “Does the ban have anything to do with religion?” In response, Giuliani said, “When [Trump] first announced it, he said ‘Muslim ban.’ He called me up, he said, ‘Put a commission together, show me the right way to do it legally.’” “It,” in this case, of course, is a ban on Muslims. Giuliani’s admission is a textbook case of drafting an order in a way that avoids overt declaration of animus against a religious or ethnic group, while retaining the motive and much of the effect.

When you combine Giuliani’s admission with Trump’s own numerous statements advocating a Muslim ban, it’s hard to find a clearer case of discriminatory motives hiding behind a vener of neutrality. Even when Trump first shifted his proposal away from a facial ban on Muslims entering the US, he called it “an expansion” of his earlier explicit Muslim ban proposal rather than a repudiation of it. In other words, it was an attempt to target Muslims without saying so explicitly.

It’s hard to find a more blatant smoking gun in a case of this type than the one Trump and his minions have given us here. If this does not count as unconstitutional discrimination covered by a thin smokescreen of neutrality, it’s hard to see what does. Conservatives who may be inclined to support Trump’s order should remember that the same sorts of tactics could be used by blue states or a future Democratic president to target evangelicals or other theologically conservative groups (for example, in response to their refusal to provide services to same-sex weddings).

Some defenders of Trump’s order argue that it isn’t really targeted at Muslims because it only covers migrants from seven countries. Refugees from other Muslim nations are not affected. But a policy can be targeted at a group without sweeping in every member of it. For example, poll taxes and literacy tests in the Jim Crow South were clearly aimed at preventing blacks from voting even though some could get around it by passing the test or paying the tax.

Similarly, the unconstitutional motive behind Trump’s order can’t be sidestepped by pointing out that it blocks some non-Muslim refugees too. Poll taxes and literacy tests excluded a good many poor whites from the franchise, but were still clearly aimed at blacks. Just as the exclusion of some white voters was collateral damage from southern states’ efforts to target African-Americans, so the exclusion of Syrian Christian refugees is tragic collateral damage from Trump’s efforts to target Muslims.

Once the plaintiffs provide evidence that a facially neutral law or regulation may have an unconstitutional discriminatory purpose, the government has the burden of proving that it would still have adopted the policy in question even in the absence of any illicit motive. As the Judge James Robart put it in the oral argument held before he issued the order suspending enforcement of the order, the government must, at the very least, prove that its policy is “grounded in fact instead of fiction.” The administration is highly unlikely to be able to do that because the security rationale for the order is laughably weak. The policy actually undermines our security much more than it protects it. To quote Judge Robart again, “You’re here arguing on behalf of someone who says we have to protect the U.S. from these individuals coming from these countries, and there’s no support for that.”

II. The Plenary Power Doctrine.

If this were an ordinary discrimination case, Trump would have little chance of winning. But his order might still be saved by the so-called “plenary power doctrine,” which holds that the federal government has sweeping power over immigration issues, including overriding constitutional rights that constrain every other type of government policy. The Supreme Court has indeed at times ruled that the plenary power doctrine permits discrimination that would be forbidden in other contexts. But, as leading immigration law scholars Peter Spiro and Adam Cox explain, recent decisions suggest that the plenary power doctrine is not as robust as it once was, and might not stand in the way of invalidating Trump’s order.

The legal battle over the order is still in its early stages, and the ultimate outcome remains very much in doubt. But, so far, Cox and Spiro’s optimism has been vindicated by the string of preliminary victories those challenging the order have secured in several federal district courts.

I would add that the plenary power doctrine is ultimately indefensible and should be overruled by the Supreme Court. Nothing in the text or the original meaning of the Constitution indicates that immigration law is an exception to the constitutional rights that constrain every other type of government policy. The text does limit a few specific constitutional rights to American citizens, such as those protected by the Privileges or Immunities Clause of the Fourteenth Amendment. But this only underscores the fact that other constitutional rights extend to everyone. There would be no need to explicitly limit some rights to citizens if there were a general presumption that non-citizens are excluded.

Moreover, most of the rights enumerated in the Constitution are stated as generalized limitations on government power, not as privileges reserved to some specific group of people, such as American citizens or permanent residents. That is certainly true of the religious Free Exercise Clause of the First Amendment, the Equal Protection Clause of the Fourteenth Amendment, and the Due Process Clause of the Fifth Amendment, the three provisions at issue in the litigation over Trump’s order. Indeed, It is highly questionable whether the original meaning gives the federal government any general power to restrict immigration at all, much less one so sweeping that it unconstrained by individual rights that restrict every other type of government action.

Some immigration restrictionists cite the Preamble of the Constitution as proof that the document does not protect aliens. I rebutted that claim here.

The origins of the plenary power doctrine lie not in the text of the Constitution but in the racial and ethnic prejudice of the same era that gave us Jim Crow and Plessy v. Ferguson. The Court should consign it to the same dustbin of history where Plessy has gone.

But striking down Trump’s order would not require the courts to overrule the plenary power doctrine completely. They need only rule that the doctrine is not so sweeping as to permit blatant religious discrimination unsupported by any reasonable security rationale.

Originally Found On: http://www.washingtonpost.com/news/volokh-conspiracy/wp/2017/02/05/why-trumps-refugee-order-is-unconstitutional-discrimination-on-the-basis-of-religion/

[wolfandpravato]

Why Trump’s refugee order is unconstitutional discrimination on the basis of religion

Former New York City, Mayor Rudy Giuliani, the Trump adviser who helped draft the President’s executive order on refugees.

A federal court recently enjoined Donald Trump’s executive order barring refugees and migrants from seven Muslim-majority nations. One of the main issues at stake in the growing legal battle over the order is whether the order qualifies as unconstitutional discrimination against Muslims. Despite a thin veneer of religious neutrality, the order does in fact target Muslims. And that should indeed lead courts to strike it down.

On its face, the order does not discriminate on the basis of religion. The text does not even mention Muslims or any other religious group by name. But the Supreme Court has long recognized that a seemingly neutral regulation qualifies as unconstitutional discrimination if the true purpose behind it is in fact to target a specific racial, ethnic, or religious group. It applied that principle to racial discrimination as far back as 1886, and more recent decisions apply it to discrimination on the basis of religion, as well. In a 1993 case, the Supreme Court struck down a seemingly neutral law banning cruelty to animals because evidence showed it to have been motivated by hostility to the Santeria religion.

I. Trump’s Order Targets Muslims.

In some cases, it is difficult to figure out the true motive behind a facially neutral law or regulation. But, as Brown University Professor Corey Brettschneider explains in an excellent article, that isn’t a problem here:

[A] closer look at the executive order’s origins makes clear that it is a direct assault on the fundamental constitutional values of equal protection and religious freedom. How do we know this? Because Trump’s adviser, former New York Mayor Rudy Giuliani, told us so.

Interviewed on Fox News on January 28, Giuliani explained how the administration’s immigration policy morphed from one that was obviously unconstitutional to one that is more subtly so. Host Jeanine Pirro asked, “Does the ban have anything to do with religion?” In response, Giuliani said, “When [Trump] first announced it, he said ‘Muslim ban.’ He called me up, he said, ‘Put a commission together, show me the right way to do it legally.’” “It,” in this case, of course, is a ban on Muslims. Giuliani’s admission is a textbook case of drafting an order in a way that avoids overt declaration of animus against a religious or ethnic group, while retaining the motive and much of the effect.

When you combine Giuliani’s admission with Trump’s own numerous statements advocating a Muslim ban, it’s hard to find a clearer case of discriminatory motives hiding behind a vener of neutrality. Even when Trump first shifted his proposal away from a facial ban on Muslims entering the US, he called it “an expansion” of his earlier explicit Muslim ban proposal rather than a repudiation of it. In other words, it was an attempt to target Muslims without saying so explicitly.

It’s hard to find a more blatant smoking gun in a case of this type than the one Trump and his minions have given us here. If this does not count as unconstitutional discrimination covered by a thin smokescreen of neutrality, it’s hard to see what does. Conservatives who may be inclined to support Trump’s order should remember that the same sorts of tactics could be used by blue states or a future Democratic president to target evangelicals or other theologically conservative groups (for example, in response to their refusal to provide services to same-sex weddings).

Some defenders of Trump’s order argue that it isn’t really targeted at Muslims because it only covers migrants from seven countries. Refugees from other Muslim nations are not affected. But a policy can be targeted at a group without sweeping in every member of it. For example, poll taxes and literacy tests in the Jim Crow South were clearly aimed at preventing blacks from voting even though some could get around it by passing the test or paying the tax.

Similarly, the unconstitutional motive behind Trump’s order can’t be sidestepped by pointing out that it blocks some non-Muslim refugees too. Poll taxes and literacy tests excluded a good many poor whites from the franchise, but were still clearly aimed at blacks. Just as the exclusion of some white voters was collateral damage from southern states’ efforts to target African-Americans, so the exclusion of Syrian Christian refugees is tragic collateral damage from Trump’s efforts to target Muslims.

Once the plaintiffs provide evidence that a facially neutral law or regulation may have an unconstitutional discriminatory purpose, the government has the burden of proving that it would still have adopted the policy in question even in the absence of any illicit motive. As the Judge James Robart put it in the oral argument held before he issued the order suspending enforcement of the order, the government must, at the very least, prove that its policy is “grounded in fact instead of fiction.” The administration is highly unlikely to be able to do that because the security rationale for the order is laughably weak. The policy actually undermines our security much more than it protects it. To quote Judge Robart again, “You’re here arguing on behalf of someone who says we have to protect the U.S. from these individuals coming from these countries, and there’s no support for that.”

II. The Plenary Power Doctrine.

If this were an ordinary discrimination case, Trump would have little chance of winning. But his order might still be saved by the so-called “plenary power doctrine,” which holds that the federal government has sweeping power over immigration issues, including overriding constitutional rights that constrain every other type of government policy. The Supreme Court has indeed at times ruled that the plenary power doctrine permits discrimination that would be forbidden in other contexts. But, as leading immigration law scholars Peter Spiro and Adam Cox explain, recent decisions suggest that the plenary power doctrine is not as robust as it once was, and might not stand in the way of invalidating Trump’s order.

The legal battle over the order is still in its early stages, and the ultimate outcome remains very much in doubt. But, so far, Cox and Spiro’s optimism has been vindicated by the string of preliminary victories those challenging the order have secured in several federal district courts.

I would add that the plenary power doctrine is ultimately indefensible and should be overruled by the Supreme Court. Nothing in the text or the original meaning of the Constitution indicates that immigration law is an exception to the constitutional rights that constrain every other type of government policy. The text does limit a few specific constitutional rights to American citizens, such as those protected by the Privileges or Immunities Clause of the Fourteenth Amendment. But this only underscores the fact that other constitutional rights extend to everyone. There would be no need to explicitly limit some rights to citizens if there were a general presumption that non-citizens are excluded.

Moreover, most of the rights enumerated in the Constitution are stated as generalized limitations on government power, not as privileges reserved to some specific group of people, such as American citizens or permanent residents. That is certainly true of the religious Free Exercise Clause of the First Amendment, the Equal Protection Clause of the Fourteenth Amendment, and the Due Process Clause of the Fifth Amendment, the three provisions at issue in the litigation over Trump’s order. Indeed, It is highly questionable whether the original meaning gives the federal government any general power to restrict immigration at all, much less one so sweeping that it unconstrained by individual rights that restrict every other type of government action.

Some immigration restrictionists cite the Preamble of the Constitution as proof that the document does not protect aliens. I rebutted that claim here.

The origins of the plenary power doctrine lie not in the text of the Constitution but in the racial and ethnic prejudice of the same era that gave us Jim Crow and Plessy v. Ferguson. The Court should consign it to the same dustbin of history where Plessy has gone.

But striking down Trump’s order would not require the courts to overrule the plenary power doctrine completely. They need only rule that the doctrine is not so sweeping as to permit blatant religious discrimination unsupported by any reasonable security rationale.

Originally Found On: http://www.washingtonpost.com/news/volokh-conspiracy/wp/2017/02/05/why-trumps-refugee-order-is-unconstitutional-discrimination-on-the-basis-of-religion/