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Fire Marshal Bill discusses vaccines and autism on The Huffington Post

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After writing about a new low of pseudoscience published in that repository of all things antivaccine and quackery, The Huffington Post (do you even have to ask?), on Tuesday, I had hoped--really hoped--that I could ignore HuffPo for a while. After all, there's only so much stupid that even Orac can tolerate before his logic circuits start shorting out and he has to shut down a while so that his self-repair circuits can undo the damage. Besides, I sometimes think that the twit who created HuffPo, Arianna Huffington, likes the attention that pseudoscience turds dropped onto her blog by quackery boosters of the like of Kim Evans garner. Certainly, the HuffPo editors seem utterly untroubled that, among physicians and medical scientists, HuffPo is viewed with utter contempt and ridicule. Certainly, I view Arianna's vanity project that way whenever it publishes the antivaccine stylings of ignoramuses like Deirdre Imus or cranks like Robert F. Kennedy, Jr., and David Kirby, especially now that HuffPo's decided that antivaccine nonsense isn't enough and that it needs to "kick the pseudoscience up a notch" with its latest quack recruits.

Apparently, HuffPo has decided that even Kim Evans is not enough to bury its reputation when it comes to any form of medical science so deep into the mud that it would require nuclear weapons to blast it out; that is, if you even accept the contention that HuffPo even has a reputation for medical science. What am I talking about? I'm sure many of you know; you've deluged me with copies of links to this article. No, no, don't worry, I'm not annoyed. It tells me that you, my readers, feel that this article is something that so desperately cries out for a heapin' helpin' of not-so-Respectful Insolence and that said Insolence is what you desperately want to see applied to it.

Never let it be said that I don't give the people what they want.

In fact, I so wanted to give the people that what they wanted on this one that I decided to save the post as a web archive and write this on the plane as I was coming home from Denver last night, leaving only the addition of relevant links as necessary upon my arrival home. So, welcome the latest arrogant idiot to the Huffington Post's merry band of antivaccinationists. No, it's not Jenny McCarthy, although I'm surprised that HuffPo didn't recruit Jenny McCarthy to blog for it long ago. Unfortunately, it did recruit her boyfriend, perhaps because his A-list celebrity (as in danger of fading to B- and C-list as it is) far outshines Jenny's D-minus-list celebrity. Yes, I'm talking about Jim Carrey, who applies his "intellectual firepower" (such as it is) to an article entitled The Judgment on Vaccines Is In???

Oh, the stupid, it does so burn.

You know, reading this article, a horrific vision came into my head. What if Jenny and Jim actually had a child? What if they actually reproduced? What would their offspring be like? I fear he would be the Antichrist of Stupid, whose power would suck all intelligence, reason and science out of the world, the better to usher in an Armageddon of Stupid against which the armies of reason might not be able to stand. If that were to happen, it would usher in a new age of dumb, a dumb so deep and profund that it might be thousands of years before humans were able to rub two stones together and make fire again.

But I digress.

In fact, what Carrey reminds me of more than anything else in this post is a character he used to play on his old sketch comedy show from the 1990s In Living Color, namely Fire Marshal Bill. Fire Marshal Bill, as you may recall, was a hideously burned Fire Marshall who would give lectures on fire safety during which he would, to comic effect, demonstrate all the dangerous things you shouldn't do with fire, electricity, water, or whatever household objects or substances that can wreak havoc when people are careless with them, inevitably having things blow up in his face or burn him in the process. This post is a lot like a Fire Marshall Bill sketch in that Carrey lectures us about vaccines but keeps burning himself with flaming stupid every time he tries to make an argument. Before I discuss his HuffPo fiasco, I'd like you to watch this four minute video and then picture Carrey's post being read in the voice of Fire Marshal Bill, especially his characteristic cackle. Trust me, it'll help you take Carrey's post exactly as seriously as it deserves:

In fact, Fire Marshal Bill's warnings about all sorts of horrific dangers in everyday items that can only be produced if he does ridiculously over-the-top things reminds me exactly of his complaints against vaccines in this article. The stupidity starts out right from the first paragraph. Again, read this in a Fire Marshal Bill voice:

Recently, I was amazed to hear a commentary by CNN's Campbell Brown on the controversial vaccine issue. After a ruling by the 'special vaccine court' saying the Measles, Mumps, Rubella shot wasn't found to be responsible for the plaintiffs' autism, she and others in the media began making assertions that the judgment was in, and vaccines had been proven safe. No one would be more relieved than Jenny and I if that were true. But with all due respect to Ms. Brown, a ruling against causation in three cases out of more than 5000 hardly proves that other children won't be adversely affected by the MMR, let alone that all vaccines are safe.

Bill, Bill, Bill, Bill--I mean Jim, Jim, Jim, Jim. How can you be so ignorant of what the test cases for the Autism Omnibus actually were? Here's a hint: They weren't chosen at random. If they were, you might have a point. Unfortunately for your brain dead argument, these were not just any cases picked at random; they were the very best cases the plaintiffs could come up with. The lawyers representing the plaintiffs chose them to put their best foot forward, and if any of them had been found credible by the Vaccine Court, then the rest of the cases would have gone forward. Moreover, these cases were tried in a special court in which the standards of evidence were clearly looser than they were in a standard court. The Daubert standard, which regulates what does and does not constitute acceptable scientific evidence and who can and cannot be used as an "expert" witness, was not in force. Speculation was permitted, and all that was required to potentially win a settlement was a "biologically plausible" mechanism. Under even that lax standard, the "crėme de la crėme" of cases that the antivaccine movement could come up as having had their autism caused by vaccines could not stand. They were roundly rejected, and the Special Masters castigated the autism quacks who had encouraged the parents of these very, very unfortunate children to hold on to the delusion that vaccines had caused their children's autism and that their quackery could cure it.

Next, we get a lesson in "logic" from Jim:

This is a huge leap of logic by anyone's standards. Not everyone gets cancer from smoking, but cigarettes do cause cancer. After 100 years and many rulings in favor of the tobacco companies, we finally figured that out.

I discussed this specious analogy in nauseating detail when Jenny's son Evan's pediatrician, an old "friend" of the blog Dr. Jay Gordon, used it, but I'll give you the CliffsNotes version here. First, mass produced cigarettes didn't really become available until the late 1800s/early 1900s. Before that, it was necessary to roll one's own, which naturally limited tobacco consumption, because rolling one's own is a pain. You don't get too many people who can smoke 40 cigarettes (i.e., two packs) a day rolling their own, but if all they have to do is to buy them premade then it becomes easy. Moroever, there is a time lag between smoking exposure and the development of lung cancer of about twenty years. Lo, and behold! That's about how long it took for the increasing prevalence of lung cancer to start to make itself known. These stories may be apocryphal, but in the early 1900s, there were stories of how whenever an autopsy was being done of a person who had died of lung cancer, professors would urge their students to attend because they might not see another case in their careers. By the 1930s and 1940s, lung cancer was becoming a lot more common, and that's when scientists started to notice. So right off the bat, Carrey's "100 years" gambit is profoundly historically ignorant. In 1909, some doctors suspected that smoking may have been unhealthy, but had no clue that it was a cause of lung cancer. Indeed, it wasn't until the late 1930s that such suspicions began to be backed up with evidence, from (of all places) Nazi scientists, which is perhaps why it took another 20 years before American scientists truly started to accept that cigarette smoking was linked with lung cancer. (See Robert N. Proctor's excellent book, The Nazi War on Cancer for a detailed treatment of this topic.)

But what really makes this analogy so brain dead is that it was the very epidemiological methods that have so consistently failed to find any correlation between vaccines and autism that led scientists to realize that smoking is strongly correlated with cancer. Jim, while accepting the epidemiology linking tobacco smoke to cancer, rejects the very same sorts of methodology when it doesn't produce the results he wants to see. Moreover, tobacco companies used the same sorts of denialist tactics that the antivaccine movement uses: Bad studies, pseudoexperts, friendly media contacts, coopted physicians, appeals to emotion twisting and cherry picking scientific studies and dishonest PR campaigns run by a cadre of attack dogs ready to pounce on any new study, looking for any flaws, real or imagined, that they can exploit to sow doubt. Antivaccinationists use the same techniques amplified by the ability of the Internet to spread misinformation even faster than it spreads information. They don't need nearly the level of financial clout that tobacco companies did back in the 1950s, because celebrity and the Internet have become the great levelers, allowing them to spread their message far and wide at much less cost. If anyone resembles the tobacco companies in this analogy, it's the antivaccine movement, which would make Jim Carrey the equivalent of the Marlboro Man, only not as handsome and rugged.

Next, after repeating the "show me the study" nonsense seen in Generation Rescue's odiously dubious "Fourteen Studies" website. Fire Marhsal Bill proceeds to a massive straw man (which, true to form for Fire Marshal Bill, he burns down, destroying his argument in the process) coupled with scientific misinformation:

If we are to believe that the ruling of the 'vaccine court' in these cases mean that all vaccines are safe, then we must also consider the rulings of that same court in the Hannah Polling and Bailey Banks cases, which ruled vaccines were the cause of autism and therefore assume that all vaccines are unsafe. Clearly both are irresponsible assumptions, and neither option is prudent.

No, if we are to believe the ruling of the Vaccine Court, the "test cases," the very best cases the plaintiffs could come up with to convince the Special Masters that vaccines "injured" these children by causing their autism, utterly failed to meet the even the lax scientific standards required by the vaccine court. Moreover, as I've discussed in detail before, the court did not concede that vaccines caused autism in either Hannah Poling or Bailey Banks. This is nothing more than a talking point credulously parroted by the antivaccine movement's Fire Marshal Bill, all to blow up in his face. Indeed, the straw man claiming that vaccine defenders argue that the Vaccine Court ruling means "all" vaccines are "safe" is so massive, that likely it was the burning of this straw man with the white hot flame of stupid that so disfigured our Fire Marshall Bill. And, as was the case for Fire Marshal Bill, Carrey remains utterly unfazed and unaware of just how dumb he's been. The arrogance of ignorance strikes again, and Fire Marshal Bill destroys another building.

The vaccines in the vaccination schedule are not safe because of any Court ruling, as Courts do not determine matters of science except when they intersect with matters of law, and then they all too often don't do such a good job. Vaccines in the current vaccination schedule are safe because they have been shown in scientific studies to be safe, and numerous epidemiological studies have failed to link them with autism. What the Court says about this is irrelevant to the science; it is only relevant to policy and the law. I say this now even though the Court made the right decision based on science, and I would have said exactly the same thing if, as I had originally feared, the emotional stories of the children in the three test cases had swayed the court to rule that vaccines caused their autism.

Next, Fire Marshal Bill trumpets anecdotal evidence:

In this growing crisis, we cannot afford to blindly trumpet the agenda of the CDC, the American Academy of Pediatrics (AAP) or vaccine makers. Now more than ever, we must resist the urge to close this book before it's been written. The anecdotal evidence of millions of parents who've seen their totally normal kids regress into sickness and mental isolation after a trip to the pediatrician's office must be seriously considered. The legitimate concern they and many in the scientific community have that environmental toxins, including those found in vaccines, may be causing autism and other disorders (Aspergers, ADD, ADHD), cannot be dissuaded by a show of sympathy and a friendly invitation to look for the 'real' cause of autism anywhere but within the lucrative vaccine program.

Once again, the plural of "anecdotes" is not "data." It just isn't. This is the same old fallacy that has been parroted again and again by the antivaccine movement. I find it interesting how the "thousands" of parents who think vaccination caused their children to regress has now been pumped up three orders of magnitude to "millions" without a single bit of evidence to support it, not even the sort of incredibly low quality "evidence" that passes for data to Generation Rescue and the antivaccine movement. I also notice how now it's not enough to blame vaccines for autism. Oh, no. The goalposts shift, and the "hypotheses" morph. Now it's not just autism, but ADD, ADHD, and pretty much every neurodevelopmental disorder under the sun. In any case, because the age range during which most cases of autism are diagnosed coincides with the ages during which children receive the bulk of their vaccines, by coincidence alone, there will be children who regress in temporal proximity to receiving vaccinations. Because humans are pattern-seeking animals, we are often too quick to confuse such correlations with causations. Sometimes they are, but often they aren't. The way to answer the question and determine if correlation is likely to mean causation is to use science and epidemiology to control for correlations that occur by random chance alone or because of other confounding factors. These epidemiological studies have been done, and they have failed to find a correlation between vaccination and autism.

Whoosh! Another fire engulfs Fire Marshal Bill, who, utterly unaware of his own incompetence, soldiers on, completely unfazed.

Bill next goes on to regurgitate the usual evil big pharma conspiracy mongering (with the CDC, AAP, and the government, of course), in the course repeating the usual lie about Paul Offit and the rotavirus vaccine, which has been refuted time and time again. Other than to acknowledge that it's part of his post, I see no point in a detailed refutation of the paranoid stylings I mean, really. If Fire Marshal Bill can't even get that little fact right, what does that say about the rest of his post?

Next, Fire Marshal Bill tries to dazzle us with his knowledge of....science! The result is painful to watch: After spewing the results of the incompetent and intellectually dishonest Generation Rescue "study" that claims to correlate the number of vaccines mandated by each nation with its autism prevalence and child mortality rate, he writes:

I've also heard it said that no evidence of a link between vaccines and autism has ever been found. That statement is only true for the CDC, the AAP and the vaccine makers who've been ignoring mountains of scientific information and testimony. There's no evidence of the Lincoln Memorial if you look the other way and refuse to turn around. But if you care to look, it's really quite impressive. For a sample of vaccine injury evidence go to www.generationrescue.org/lincolnmemorial.html.>

Which is about as good a description of the antivaccine movement as I've ever seen. No doubt Fire Marshal Bill thinks he's made a slam dunk analogy, but in fact scientists have looked in the direction that the antivaccine movement wants them to. In fact, they've coddled and cajoled the antivaccine fringe far beyond what science would require. The evidence that vaccines don't cause autism was, from a strictly scientific standpoint, more than strong enough to let this line of research drop as being unproductive several years ago. The only reason scientists keep reinventing the wheel and doing the same types of studies over and over again is in the futile hope that either the weight of evidence will finally persuade the foes of vaccination or that they will find something all the other studies have missed. Neither outcome is likely.

Just like what happens with a Fire Marshal Bill sketch, our antivaccine Fire Marshal builds up to a crescendo of mishaps that truly boggles the mind, all the while not having a single clue of how stupid his actions are (or, in this case, Carrey's arguments):

We have never argued that people shouldn't be immunized for the most serious threats including measles and polio, but surely there's a limit as to how many viruses and toxins can be introduced into the body of a small child. Veterinarians found out years ago that in many cases they were over-immunizing our pets, a syndrome they call Vaccinosis. It overwhelmed the immune system of the animals, causing myriad physical and neurological disorders. Sound familiar? If you can over-immunize a dog, is it so far out to assume that you can over-immunize a child? These forward thinking vets also decided to remove thimerosal from animal vaccines in 1992, and yet this substance, which is 49% mercury, is still in human vaccines. Don't our children deserve as much consideration as our pets?

Oh, noes! It's the dreaded "toxins" gambit. At least Fire Marshal Bill didn't mention formaldehyide. Perhaps Dr. Jay warned him that the "formaldehyde" gambit only makes him look even stupider than he already looks. Oh, wait. No, Carrey goes straight for the formaldehyde gambit! Look away:

In all likelihood the truth about vaccines is that they are both good and bad. While ingredients like aluminum, mercury, ether, formaldehyde and anti-freeze may help preserve and enhance vaccines, they can be toxic as well.

I'm too tired to deconstruct that most idiotic of antivaccine misinformation, the "formaldehyde gambit again other than to say that the body makes a fair amount of formaldehyde just from normal metabolism and that Carrey probably breathes more formaldehyde sitting in L.A. traffic for an hour than is contained in every vaccine in the childhood vaccination schedule; so I'll refer you to an old post where I schooled Dr. Jay so hard that he has never--ever--repeated the "formaldehyde gambit" again. Indeed, I haven't even heard Jenny McCarthy use that gambit since then, although I could have missed it. Too bad Dr. Jay apparently neglected to let Fire Marshal Bill know just how dumb using this gambit makes him look or that there is no ether in vaccines. (The whole "ether" thing is the result of ignorance of chemistry; if the word "ether" appears in a chemical name, the idiots who came up with the "ether" gambit think that it means there's ether--as in the ether that used to be used as an anesthetic--in it.) Here's another hint for our intellectually challenged antivaccine spokesactor: There's no antifreeze in vaccines, either. That's another canard cooked up by the chemically clueless.

In any case, note how Carrey plays the usual "we're not 'anti-vaccine,' we're 'pro-safe vaccine'" gambit and seems to want to decided which diseases are "serious" enough to warrant vaccination. How about whooping cough, Jim? Is that "serious enough" for you? What about Hemophilus influenza type b (Hib), a disease that until the development of an effective vaccine in the late 1980s/early 1990s was the scourge of children and a pediatrician's most dread foe, a disease that could cause encephalitis and death in a large proportion of children who contracted it? It's nearly unheard of now, thanks to vaccines, so much so that most younger pediatricians have never seen a case. Is that "serious enough" for you, given that it's arguably more serious a disease than measles? If not, why didn't you mention it?

Truly, the burning stupid burns Fire Marshal Bill yet again.

In any case, vaccinosis is a rather dubious diagnosis. Google it and you'll see what I mean. Even Google Scholar it. The vast majority of the hits come from antivaccine websites or "natural pet health" websites. If you search for the term in PubMed, very little is found--only ten articles, most of which are pre-1970 in foreign language journals and two of which are in the journal Homeopathy (hardly a major endorsement for the scientific validity of the concept). Dr. David Ramey has done a good job of discussing the issues involved in animal vaccination. Suffice it to say that, even if vaccinosis were as horrible as claimed, which it's not, there is a lot of non-evidence-based practice in animal vaccination (for instance, needing such frequent boosters for rabies and other diseases), and animal vaccines are not held to as high a standard of purity as human vaccines are.

The more I read Jim Carrey's HuffPo blog post and contemplate the similarities, the more I think the analogy to Fire Marshal Bill is an apt one. Indeed, I can't read Carrey's post (if in fact Carrey actually wrote it, which I sincerely doubt). We've even already seen the results of what happens when Fire Marshal Bill discusses medicine:

Think of Carrey's HuffPo article as the same sort of thing, only without the comedic intent. Carrey is dead serious about the antivaccine pseudoscience he espouses.

Truly, J.B. Handley must be overjoyed that he's found his very own celebrity spokesperson who is actually still famous (as compared to Jenny McCarthy, whose fame had waned long ago, after her Playboy and MTV days ended and she descended into gross-out comedy before delving deeply into "Indigo" woo). Even better, Jim Carrey has everything that J.B. could want in a celebrity spokesperson: Fame, charisma, and a brain consisting of two neurons connected by a spirochete who's willing to repeat anything he's told by Generation Rescue while making the most the most disingenuous disclaimers, statements such as "no one would be more relieved than Jenny and I" if vaccines were proven safe.

Jim might be, but I highly doubt Jenny would be. Her new fame depends entirely upon the antivaccination hysteria she has been stoking since the fall of 2007. Where would she be without it? I'll tell you: She'd still be peddling her "Indigo" and "Crystal" New Age woo, as she did until when she transformed herself into a "warrior mom" against autism and tried to scrub all evidence of her previous favorite woo (before she moved on to antivaccine and autism quackery) from the Internet.

Meanwhile, the antivaccine echo chamber that is HuffPo should, as always, be ashamed of itself for publishing such copious quantities of dangerous pseudoscience. Unfortunately, the editors of HuffPo, apparently like Jim Carrey, have no shame. Let's put it this way. When celebrity gossip sites like Gawker start making fun of the quackery and antivaccination idiocy being laid down by Carrey on Arianna Huffington's vanity project, you know it's bad.


April Fool's LATE Ed.

"april 1"+pussy

Fools' Pussy

Scholar

#1

©2011 Google


Direct evidence is" evidence of conduct or statements that both reflect directly the alleged discriminatory attitude and that bear directly on the contested employment decision."
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Taylor v. Virginia Union Univ., 193 F. 3d 219 - Court of Appeals, 4th Circuit 1999

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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** Direct evidence is" evidence of conduct or statements that both reflect directly the alleged discriminatory attitude and that bear directly on the contested employment decision."**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
- in Martin v. Scott & Stringfellow, Inc., 2009 and 22 similar citations
**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** -statement that police chief would never send a female to the academy did not "bear directly on the contested employment decision" so as to trigger a mixed motive standard of liability**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** Therefore, to make out a prima facie case of discrimination, Plaintiff must show that:(1) she is a member of a protected class (female);(2) the prohibited conduct in which she engaged was comparable in seriousness to misconduct of employees outside the protected class; and (3) she suffered more severe discipline for her misconduct as compared to employees outside …**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** "A plaintiff qualifies for the more advantageous standard of liability applicable in mixed-motive cases if the plaintiff presents `direct evidence that decision makers placed substantial negative reliance on an illegitimate criterion.'"**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** Under McDonnell Douglas, in order to establish a prima facie case of sex discrimination, the plaintiff must establish that (1) she is a member of a protected class;(2) her employer had an open position for which she applied;(3) she was qualified for the position;(4) she was rejected for the position under circumstance giving rise to an inference of unlawful discrimination.**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** So too, if the factual foundation in the administrative charge is too vague to support a claim that is later presented in subsequent litigation, that claim will also be procedurally barred.**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** "Deliberateness exists only if the actions complained of were intended by the employer as an effort to force the plaintiff to quit."**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** We review this order of the district court de novo and must reverse unless we conclude, viewing the evidence in the light most favorable to Al-Abood, that no reasonable juror could have found for her on the RICO claims.**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** -classifying the Sixth Circuit as following Kotteakos in civil cases, citing Schrand; embracing the same rule**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** -no exhaustion of administrative remedies where facts incorporated into the charge, including after-hours phone calls and touching, were too inconclusive to suggest sexual harassment**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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Cited by

Diamond v. Colonial Life & Acc. Ins. Co.
416 F. 3d 310 - Court of Appeals, 4th Circuit 2005

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290 F. 3d 639 - Court of Appeals, 4th Circuit 2002

Hill v. Lockheed Martin Logistics Mgmt
354 F. 3d 277 - Court of Appeals, 4th Circuit 2004

Spriggs v. Diamond Auto Glass
242 F. 3d 179 - Court of Appeals, 4th Circuit 2001

Fernandes v. Costa Bros. Masonry, Inc.
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all 179 citing documents »

Related documents

[CITATION] Taylor v. Virginia Union Univ.
528 US 1189 - Supreme Court 2000

Brinkley v. Harbour Recreation Club
180 F. 3d 598 - Court of Appeals, 4th Circuit 1999

Fernandes v. Costa Bros. Masonry, Inc.
199 F. 3d 572 - Court of Appeals, 1st Circuit 1999

Munday v. Waste Management of North America, Inc.
126 F. 3d 239 - Court of Appeals, 4th Circuit 1997

Hawkins v. PepsiCo, Inc.
203 F. 3d 274 - Court of Appeals, 4th Circuit 2000

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Text on this, which you can barely read,

is so vile... 
... and funny in a way, that i dared not
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which for Dogmeat...
means it was pretty vile!

 

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April Fool's Day in France is called...1er avril (video)

AFJ

Shorthand for April Fool's Joke, AFJ is a practical joke or hoax performed on the first day of April known as April Fools day. April fools jokes have always been popular and continue to be popular on the Internet and Internet news related sites. For example, Google announced on April 1, 2002 that the technology behind its excellent search results is PigeonRank, a system that relies primarily on trainable domestic pigeons. This webpage can still be found online here.


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Fire Marshal Bill discusses vaccines and autism on The Huffington Post

Category: Antivaccination lunacyAutismEntertainment/cultureMedicineMoviesPopular cultureTelevision
Posted on: April 23, 2009 3:00 AM, by Orac

fire-marshall-bill.jpg

After writing about a new low of pseudoscience published in that repository of all things antivaccine and quackery, The Huffington Post (do you even have to ask?), on Tuesday, I had hoped--really hoped--that I could ignore HuffPo for a while. After all, there's only so much stupid that even Orac can tolerate before his logic circuits start shorting out and he has to shut down a while so that his self-repair circuits can undo the damage. Besides, I sometimes think that the twit who created HuffPo, Arianna Huffington, likes the attention that pseudoscience turds dropped onto her blog by quackery boosters of the like of Kim Evans garner. Certainly, the HuffPo editors seem utterly untroubled that, among physicians and medical scientists, HuffPo is viewed with utter contempt and ridicule. Certainly, I view Arianna's vanity project that way whenever it publishes the antivaccine stylings of ignoramuses like Deirdre Imus or cranks like Robert F. Kennedy, Jr., and David Kirby, especially now that HuffPo's decided that antivaccine nonsense isn't enough and that it needs to "kick the pseudoscience up a notch" with its latest quack recruits.

Apparently, HuffPo has decided that even Kim Evans is not enough to bury its reputation when it comes to any form of medical science so deep into the mud that it would require nuclear weapons to blast it out; that is, if you even accept the contention that HuffPo even has a reputation for medical science. What am I talking about? I'm sure many of you know; you've deluged me with copies of links to this article. No, no, don't worry, I'm not annoyed. It tells me that you, my readers, feel that this article is something that so desperately cries out for a heapin' helpin' of not-so-Respectful Insolence and that said Insolence is what you desperately want to see applied to it.

Never let it be said that I don't give the people what they want.

In fact, I so wanted to give the people that what they wanted on this one that I decided to save the post as a web archive and write this on the plane as I was coming home from Denver last night, leaving only the addition of relevant links as necessary upon my arrival home. So, welcome the latest arrogant idiot to the Huffington Post's merry band of antivaccinationists. No, it's not Jenny McCarthy, although I'm surprised that HuffPo didn't recruit Jenny McCarthy to blog for it long ago. Unfortunately, it did recruit her boyfriend, perhaps because his A-list celebrity (as in danger of fading to B- and C-list as it is) far outshines Jenny's D-minus-list celebrity. Yes, I'm talking about Jim Carrey, who applies his "intellectual firepower" (such as it is) to an article entitled The Judgment on Vaccines Is In???

Oh, the stupid, it does so burn.

You know, reading this article, a horrific vision came into my head. What if Jenny and Jim actually had a child? What if they actually reproduced? What would their offspring be like? I fear he would be the Antichrist of Stupid, whose power would suck all intelligence, reason and science out of the world, the better to usher in an Armageddon of Stupid against which the armies of reason might not be able to stand. If that were to happen, it would usher in a new age of dumb, a dumb so deep and profund that it might be thousands of years before humans were able to rub two stones together and make fire again.

But I digress.

In fact, what Carrey reminds me of more than anything else in this post is a character he used to play on his old sketch comedy show from the 1990s In Living Color, namely Fire Marshal Bill. Fire Marshal Bill, as you may recall, was a hideously burned Fire Marshall who would give lectures on fire safety during which he would, to comic effect, demonstrate all the dangerous things you shouldn't do with fire, electricity, water, or whatever household objects or substances that can wreak havoc when people are careless with them, inevitably having things blow up in his face or burn him in the process. This post is a lot like a Fire Marshall Bill sketch in that Carrey lectures us about vaccines but keeps burning himself with flaming stupid every time he tries to make an argument. Before I discuss his HuffPo fiasco, I'd like you to watch this four minute video and then picture Carrey's post being read in the voice of Fire Marshal Bill, especially his characteristic cackle. Trust me, it'll help you take Carrey's post exactly as seriously as it deserves:

In fact, Fire Marshal Bill's warnings about all sorts of horrific dangers in everyday items that can only be produced if he does ridiculously over-the-top things reminds me exactly of his complaints against vaccines in this article. The stupidity starts out right from the first paragraph. Again, read this in a Fire Marshal Bill voice:

Recently, I was amazed to hear a commentary by CNN's Campbell Brown on the controversial vaccine issue. After a ruling by the 'special vaccine court' saying the Measles, Mumps, Rubella shot wasn't found to be responsible for the plaintiffs' autism, she and others in the media began making assertions that the judgment was in, and vaccines had been proven safe. No one would be more relieved than Jenny and I if that were true. But with all due respect to Ms. Brown, a ruling against causation in three cases out of more than 5000 hardly proves that other children won't be adversely affected by the MMR, let alone that all vaccines are safe.

Bill, Bill, Bill, Bill--I mean Jim, Jim, Jim, Jim. How can you be so ignorant of what the test cases for the Autism Omnibus actually were? Here's a hint: They weren't chosen at random. If they were, you might have a point. Unfortunately for your brain dead argument, these were not just any cases picked at random; they were the very best cases the plaintiffs could come up with. The lawyers representing the plaintiffs chose them to put their best foot forward, and if any of them had been found credible by the Vaccine Court, then the rest of the cases would have gone forward. Moreover, these cases were tried in a special court in which the standards of evidence were clearly looser than they were in a standard court. The Daubert standard, which regulates what does and does not constitute acceptable scientific evidence and who can and cannot be used as an "expert" witness, was not in force. Speculation was permitted, and all that was required to potentially win a settlement was a "biologically plausible" mechanism. Under even that lax standard, the "crėme de la crėme" of cases that the antivaccine movement could come up as having had their autism caused by vaccines could not stand. They were roundly rejected, and the Special Masters castigated the autism quacks who had encouraged the parents of these very, very unfortunate children to hold on to the delusion that vaccines had caused their children's autism and that their quackery could cure it.

Next, we get a lesson in "logic" from Jim:

This is a huge leap of logic by anyone's standards. Not everyone gets cancer from smoking, but cigarettes do cause cancer. After 100 years and many rulings in favor of the tobacco companies, we finally figured that out.

I discussed this specious analogy in nauseating detail when Jenny's son Evan's pediatrician, an old "friend" of the blog Dr. Jay Gordon, used it, but I'll give you the CliffsNotes version here. First, mass produced cigarettes didn't really become available until the late 1800s/early 1900s. Before that, it was necessary to roll one's own, which naturally limited tobacco consumption, because rolling one's own is a pain. You don't get too many people who can smoke 40 cigarettes (i.e., two packs) a day rolling their own, but if all they have to do is to buy them premade then it becomes easy. Moroever, there is a time lag between smoking exposure and the development of lung cancer of about twenty years. Lo, and behold! That's about how long it took for the increasing prevalence of lung cancer to start to make itself known. These stories may be apocryphal, but in the early 1900s, there were stories of how whenever an autopsy was being done of a person who had died of lung cancer, professors would urge their students to attend because they might not see another case in their careers. By the 1930s and 1940s, lung cancer was becoming a lot more common, and that's when scientists started to notice. So right off the bat, Carrey's "100 years" gambit is profoundly historically ignorant. In 1909, some doctors suspected that smoking may have been unhealthy, but had no clue that it was a cause of lung cancer. Indeed, it wasn't until the late 1930s that such suspicions began to be backed up with evidence, from (of all places) Nazi scientists, which is perhaps why it took another 20 years before American scientists truly started to accept that cigarette smoking was linked with lung cancer. (See Robert N. Proctor's excellent book, The Nazi War on Cancer for a detailed treatment of this topic.)

But what really makes this analogy so brain dead is that it was the very epidemiological methods that have so consistently failed to find any correlation between vaccines and autism that led scientists to realize that smoking is strongly correlated with cancer. Jim, while accepting the epidemiology linking tobacco smoke to cancer, rejects the very same sorts of methodology when it doesn't produce the results he wants to see. Moreover, tobacco companies used the same sorts of denialist tactics that the antivaccine movement uses: Bad studies, pseudoexperts, friendly media contacts, coopted physicians, appeals to emotion twisting and cherry picking scientific studies and dishonest PR campaigns run by a cadre of attack dogs ready to pounce on any new study, looking for any flaws, real or imagined, that they can exploit to sow doubt. Antivaccinationists use the same techniques amplified by the ability of the Internet to spread misinformation even faster than it spreads information. They don't need nearly the level of financial clout that tobacco companies did back in the 1950s, because celebrity and the Internet have become the great levelers, allowing them to spread their message far and wide at much less cost. If anyone resembles the tobacco companies in this analogy, it's the antivaccine movement, which would make Jim Carrey the equivalent of the Marlboro Man, only not as handsome and rugged.

Next, after repeating the "show me the study" nonsense seen in Generation Rescue's odiously dubious "Fourteen Studies" website. Fire Marhsal Bill proceeds to a massive straw man (which, true to form for Fire Marshal Bill, he burns down, destroying his argument in the process) coupled with scientific misinformation:

If we are to believe that the ruling of the 'vaccine court' in these cases mean that all vaccines are safe, then we must also consider the rulings of that same court in the Hannah Polling and Bailey Banks cases, which ruled vaccines were the cause of autism and therefore assume that all vaccines are unsafe. Clearly both are irresponsible assumptions, and neither option is prudent.

No, if we are to believe the ruling of the Vaccine Court, the "test cases," the very best cases the plaintiffs could come up with to convince the Special Masters that vaccines "injured" these children by causing their autism, utterly failed to meet the even the lax scientific standards required by the vaccine court. Moreover, as I've discussed in detail before, the court did not concede that vaccines caused autism in either Hannah Poling or Bailey Banks. This is nothing more than a talking point credulously parroted by the antivaccine movement's Fire Marshal Bill, all to blow up in his face. Indeed, the straw man claiming that vaccine defenders argue that the Vaccine Court ruling means "all" vaccines are "safe" is so massive, that likely it was the burning of this straw man with the white hot flame of stupid that so disfigured our Fire Marshall Bill. And, as was the case for Fire Marshal Bill, Carrey remains utterly unfazed and unaware of just how dumb he's been. The arrogance of ignorance strikes again, and Fire Marshal Bill destroys another building.

The vaccines in the vaccination schedule are not safe because of any Court ruling, as Courts do not determine matters of science except when they intersect with matters of law, and then they all too often don't do such a good job. Vaccines in the current vaccination schedule are safe because they have been shown in scientific studies to be safe, and numerous epidemiological studies have failed to link them with autism. What the Court says about this is irrelevant to the science; it is only relevant to policy and the law. I say this now even though the Court made the right decision based on science, and I would have said exactly the same thing if, as I had originally feared, the emotional stories of the children in the three test cases had swayed the court to rule that vaccines caused their autism.

Next, Fire Marshal Bill trumpets anecdotal evidence:

In this growing crisis, we cannot afford to blindly trumpet the agenda of the CDC, the American Academy of Pediatrics (AAP) or vaccine makers. Now more than ever, we must resist the urge to close this book before it's been written. The anecdotal evidence of millions of parents who've seen their totally normal kids regress into sickness and mental isolation after a trip to the pediatrician's office must be seriously considered. The legitimate concern they and many in the scientific community have that environmental toxins, including those found in vaccines, may be causing autism and other disorders (Aspergers, ADD, ADHD), cannot be dissuaded by a show of sympathy and a friendly invitation to look for the 'real' cause of autism anywhere but within the lucrative vaccine program.

Once again, the plural of "anecdotes" is not "data." It just isn't. This is the same old fallacy that has been parroted again and again by the antivaccine movement. I find it interesting how the "thousands" of parents who think vaccination caused their children to regress has now been pumped up three orders of magnitude to "millions" without a single bit of evidence to support it, not even the sort of incredibly low quality "evidence" that passes for data to Generation Rescue and the antivaccine movement. I also notice how now it's not enough to blame vaccines for autism. Oh, no. The goalposts shift, and the "hypotheses" morph. Now it's not just autism, but ADD, ADHD, and pretty much every neurodevelopmental disorder under the sun. In any case, because the age range during which most cases of autism are diagnosed coincides with the ages during which children receive the bulk of their vaccines, by coincidence alone, there will be children who regress in temporal proximity to receiving vaccinations. Because humans are pattern-seeking animals, we are often too quick to confuse such correlations with causations. Sometimes they are, but often they aren't. The way to answer the question and determine if correlation is likely to mean causation is to use science and epidemiology to control for correlations that occur by random chance alone or because of other confounding factors. These epidemiological studies have been done, and they have failed to find a correlation between vaccination and autism.

Whoosh! Another fire engulfs Fire Marshal Bill, who, utterly unaware of his own incompetence, soldiers on, completely unfazed.

Bill next goes on to regurgitate the usual evil big pharma conspiracy mongering (with the CDC, AAP, and the government, of course), in the course repeating the usual lie about Paul Offit and the rotavirus vaccine, which has been refuted time and time again. Other than to acknowledge that it's part of his post, I see no point in a detailed refutation of the paranoid stylings I mean, really. If Fire Marshal Bill can't even get that little fact right, what does that say about the rest of his post?

Next, Fire Marshal Bill tries to dazzle us with his knowledge of....science! The result is painful to watch: After spewing the results of the incompetent and intellectually dishonest Generation Rescue "study" that claims to correlate the number of vaccines mandated by each nation with its autism prevalence and child mortality rate, he writes:

I've also heard it said that no evidence of a link between vaccines and autism has ever been found. That statement is only true for the CDC, the AAP and the vaccine makers who've been ignoring mountains of scientific information and testimony. There's no evidence of the Lincoln Memorial if you look the other way and refuse to turn around. But if you care to look, it's really quite impressive. For a sample of vaccine injury evidence go to www.generationrescue.org/lincolnmemorial.html.>

Which is about as good a description of the antivaccine movement as I've ever seen. No doubt Fire Marshal Bill thinks he's made a slam dunk analogy, but in fact scientists have looked in the direction that the antivaccine movement wants them to. In fact, they've coddled and cajoled the antivaccine fringe far beyond what science would require. The evidence that vaccines don't cause autism was, from a strictly scientific standpoint, more than strong enough to let this line of research drop as being unproductive several years ago. The only reason scientists keep reinventing the wheel and doing the same types of studies over and over again is in the futile hope that either the weight of evidence will finally persuade the foes of vaccination or that they will find something all the other studies have missed. Neither outcome is likely.

Just like what happens with a Fire Marshal Bill sketch, our antivaccine Fire Marshal builds up to a crescendo of mishaps that truly boggles the mind, all the while not having a single clue of how stupid his actions are (or, in this case, Carrey's arguments):

We have never argued that people shouldn't be immunized for the most serious threats including measles and polio, but surely there's a limit as to how many viruses and toxins can be introduced into the body of a small child. Veterinarians found out years ago that in many cases they were over-immunizing our pets, a syndrome they call Vaccinosis. It overwhelmed the immune system of the animals, causing myriad physical and neurological disorders. Sound familiar? If you can over-immunize a dog, is it so far out to assume that you can over-immunize a child? These forward thinking vets also decided to remove thimerosal from animal vaccines in 1992, and yet this substance, which is 49% mercury, is still in human vaccines. Don't our children deserve as much consideration as our pets?

Oh, noes! It's the dreaded "toxins" gambit. At least Fire Marshal Bill didn't mention formaldehyide. Perhaps Dr. Jay warned him that the "formaldehyde" gambit only makes him look even stupider than he already looks. Oh, wait. No, Carrey goes straight for the formaldehyde gambit! Look away:

In all likelihood the truth about vaccines is that they are both good and bad. While ingredients like aluminum, mercury, ether, formaldehyde and anti-freeze may help preserve and enhance vaccines, they can be toxic as well.

I'm too tired to deconstruct that most idiotic of antivaccine misinformation, the "formaldehyde gambit again other than to say that the body makes a fair amount of formaldehyde just from normal metabolism and that Carrey probably breathes more formaldehyde sitting in L.A. traffic for an hour than is contained in every vaccine in the childhood vaccination schedule; so I'll refer you to an old post where I schooled Dr. Jay so hard that he has never--ever--repeated the "formaldehyde gambit" again. Indeed, I haven't even heard Jenny McCarthy use that gambit since then, although I could have missed it. Too bad Dr. Jay apparently neglected to let Fire Marshal Bill know just how dumb using this gambit makes him look or that there is no ether in vaccines. (The whole "ether" thing is the result of ignorance of chemistry; if the word "ether" appears in a chemical name, the idiots who came up with the "ether" gambit think that it means there's ether--as in the ether that used to be used as an anesthetic--in it.) Here's another hint for our intellectually challenged antivaccine spokesactor: There's no antifreeze in vaccines, either. That's another canard cooked up by the chemically clueless.

In any case, note how Carrey plays the usual "we're not 'anti-vaccine,' we're 'pro-safe vaccine'" gambit and seems to want to decided which diseases are "serious" enough to warrant vaccination. How about whooping cough, Jim? Is that "serious enough" for you? What about Hemophilus influenza type b (Hib), a disease that until the development of an effective vaccine in the late 1980s/early 1990s was the scourge of children and a pediatrician's most dread foe, a disease that could cause encephalitis and death in a large proportion of children who contracted it? It's nearly unheard of now, thanks to vaccines, so much so that most younger pediatricians have never seen a case. Is that "serious enough" for you, given that it's arguably more serious a disease than measles? If not, why didn't you mention it?

Truly, the burning stupid burns Fire Marshal Bill yet again.

In any case, vaccinosis is a rather dubious diagnosis. Google it and you'll see what I mean. Even Google Scholar it. The vast majority of the hits come from antivaccine websites or "natural pet health" websites. If you search for the term in PubMed, very little is found--only ten articles, most of which are pre-1970 in foreign language journals and two of which are in the journal Homeopathy (hardly a major endorsement for the scientific validity of the concept). Dr. David Ramey has done a good job of discussing the issues involved in animal vaccination. Suffice it to say that, even if vaccinosis were as horrible as claimed, which it's not, there is a lot of non-evidence-based practice in animal vaccination (for instance, needing such frequent boosters for rabies and other diseases), and animal vaccines are not held to as high a standard of purity as human vaccines are.

The more I read Jim Carrey's HuffPo blog post and contemplate the similarities, the more I think the analogy to Fire Marshal Bill is an apt one. Indeed, I can't read Carrey's post (if in fact Carrey actually wrote it, which I sincerely doubt). We've even already seen the results of what happens when Fire Marshal Bill discusses medicine:

Think of Carrey's HuffPo article as the same sort of thing, only without the comedic intent. Carrey is dead serious about the antivaccine pseudoscience he espouses.

Truly, J.B. Handley must be overjoyed that he's found his very own celebrity spokesperson who is actually still famous (as compared to Jenny McCarthy, whose fame had waned long ago, after her Playboy and MTV days ended and she descended into gross-out comedy before delving deeply into "Indigo" woo). Even better, Jim Carrey has everything that J.B. could want in a celebrity spokesperson: Fame, charisma, and a brain consisting of two neurons connected by a spirochete who's willing to repeat anything he's told by Generation Rescue while making the most the most disingenuous disclaimers, statements such as "no one would be more relieved than Jenny and I" if vaccines were proven safe.

Jim might be, but I highly doubt Jenny would be. Her new fame depends entirely upon the antivaccination hysteria she has been stoking since the fall of 2007. Where would she be without it? I'll tell you: She'd still be peddling her "Indigo" and "Crystal" New Age woo, as she did until when she transformed herself into a "warrior mom" against autism and tried to scrub all evidence of her previous favorite woo (before she moved on to antivaccine and autism quackery) from the Internet.

Meanwhile, the antivaccine echo chamber that is HuffPo should, as always, be ashamed of itself for publishing such copious quantities of dangerous pseudoscience. Unfortunately, the editors of HuffPo, apparently like Jim Carrey, have no shame. Let's put it this way. When celebrity gossip sites like Gawker start making fun of the quackery and antivaccination idiocy being laid down by Carrey on Arianna Huffington's vanity project, you know it's bad.


April Fool's LATE Ed.

"april 1"+pussy

Fools' Pussy

Scholar

#1

©2011 Google


Direct evidence is" evidence of conduct or statements that both reflect directly the alleged discriminatory attitude and that bear directly on the contested employment decision."
  Read this case   How cited

Taylor v. Virginia Union Univ., 193 F. 3d 219 - Court of Appeals, 4th Circuit 1999

How this document has been cited

**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** Direct evidence is" evidence of conduct or statements that both reflect directly the alleged discriminatory attitude and that bear directly on the contested employment decision."**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
- in Martin v. Scott & Stringfellow, Inc., 2009 and 22 similar citations
**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** -statement that police chief would never send a female to the academy did not "bear directly on the contested employment decision" so as to trigger a mixed motive standard of liability**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
- in Robertson v. Mylan Laboratories, Inc., 2004 and 16 similar citations
**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** Therefore, to make out a prima facie case of discrimination, Plaintiff must show that:(1) she is a member of a protected class (female);(2) the prohibited conduct in which she engaged was comparable in seriousness to misconduct of employees outside the protected class; and (3) she suffered more severe discipline for her misconduct as compared to employees outside …**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
- in Scott v. Potter, 2009 and 17 similar citations
**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** "A plaintiff qualifies for the more advantageous standard of liability applicable in mixed-motive cases if the plaintiff presents `direct evidence that decision makers placed substantial negative reliance on an illegitimate criterion.'"**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
- in Pathways Psychosocial v. Town of Leonardtown, MD, 2002 and 18 similar citations
**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** Under McDonnell Douglas, in order to establish a prima facie case of sex discrimination, the plaintiff must establish that (1) she is a member of a protected class;(2) her employer had an open position for which she applied;(3) she was qualified for the position;(4) she was rejected for the position under circumstance giving rise to an inference of unlawful discrimination.**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
- in Mackey v. Shalala, 2004 and 15 similar citations
**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** So too, if the factual foundation in the administrative charge is too vague to support a claim that is later presented in subsequent litigation, that claim will also be procedurally barred.**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
- in Bonds v. Leavitt, 2009 and 12 similar citations
**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** "Deliberateness exists only if the actions complained of were intended by the employer as an effort to force the plaintiff to quit."**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** We review this order of the district court de novo and must reverse unless we conclude, viewing the evidence in the light most favorable to Al-Abood, that no reasonable juror could have found for her on the RICO claims.**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
- in Al-Abood ex rel. Al-Abood v. El-Shamari, 2000 and 8 similar citations
**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** -classifying the Sixth Circuit as following Kotteakos in civil cases, citing Schrand; embracing the same rule**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
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**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)** -no exhaustion of administrative remedies where facts incorporated into the charge, including after-hours phone calls and touching, were too inconclusive to suggest sexual harassment**Fools' Pussy Scholar #1 ©2011 Google Legal Scholar Search (can only mean one thing)**
- in Chacko v. Patuxent Institution, 2005 and 9 similar citations

(cuz you never know what posterous is gonna strip next) 


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Cited by

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all 179 citing documents »

Related documents

[CITATION] Taylor v. Virginia Union Univ.
528 US 1189 - Supreme Court 2000

Brinkley v. Harbour Recreation Club
180 F. 3d 598 - Court of Appeals, 4th Circuit 1999

Fernandes v. Costa Bros. Masonry, Inc.
199 F. 3d 572 - Court of Appeals, 1st Circuit 1999

Munday v. Waste Management of North America, Inc.
126 F. 3d 239 - Court of Appeals, 4th Circuit 1997

Hawkins v. PepsiCo, Inc.
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HARASSMENT
HARBOUR
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HIS
HOURS
I
IDENTICAL
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INFERENCE
INITIALLY
INS
INSTITUTION
INTENDED
ISLAND
IT
ITS
JOEL
JUROR
KADEN
KEYBARS
KNOW
KOTTEAKOS
LABORATORIES
LATE
LATER
LATHAM
LEAVITT
LEGAL
LEONARDTOWN
LIFE
LIGHT
LITIGATION
LOCKHEED
LOGISTICS
LOOK
MACKEY
MAKE
MAKERS
MATVIA
MCDONNELL
MD
MEAN
MEANS
MEDICAL
MGMT
MORE€�
MOST
MUNDAY
MYLAN
NAME
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NEXT
NORTH
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OLD
ONE
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PATENTED
PATHWAYS
PATUXENT
PEPSICO
PERSONAL
PHONE
PLACED
POLICE
POSTEROUS
POTTER
PRACTICAL
PRESENTED
PRESENTS
PRETTY
PROCEDURALLY
PROHIBITED
PROPORTIONALLY
PSYCHOSOCIAL
QUALIFIED
QUALIFIES
QUIT
REASONABLE
RECREATION
REGULAR
REJECTED
REL
RELIANCE
REMEDIES
REMINGTON
REPLACED
REPLACEMENTS
REQUIRES
REVERSE
REVIEW
RICO
RIGHTS
RISE
ROBERTSON
RULE
SCHRAND
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SERIOUSNESS
SEVERE
SEX
SEXUAL
SHALALA
SHAMARI
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SUBSEQUENT
SUBSTANTIAL
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SUGGEST
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TONY
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TRIGGER
TYPEFACE
TYPEWRITERS
UNLAWFUL
UNLESS
UP
US
USE
USED
UTILIZED
VAGUE
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VIEWING
WASTE
WAY
WHAT
WHEEL
WHERE
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Text on this, which you can barely read,

is so vile... 
... and funny in a way, that i dared not

speak its name...
color wheel
which for Dogmeat...
means it was pretty vile!

 

About this font family

The typewriter was patented in 1868 by Christopher Latham Sholes, who sold his rights to the Remington Arms Company in 1873. The first typewriters were initially thought to be replacements for printing and so typewriter keybars utilized printing types; monospaced typefaces, that is, those designed so every letter takes up the same amount of space were a more practical alternative and soon replaced printing types.

Monospaced designs are still in use as typewriter typefaces today. In 1974, Joel Kaden and Tony Stan adapted the friendliness and immediacy of typewriter letter styles into a proportionally spaced typeface, ITC American Typewriter. More…

ITC American Typewriter can be used for business correspondence or in any work that requires an old-fashioned, personal look. The "A" faces are identical to the regular ones, except for alternate versions of the following characters: &, $, R, e.

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