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Euro-Atlantic Partnership Council

The Euro-Atlantic Partnership Council  (EAPC) is a post–Cold War, North Atlantic Treaty Organization (NATO) institution. The EAPC is a multilateral forum created to improve relations between NATO and non-NATO countries in Europe and Central Asia. States meet to cooperate and discuss political and security issues. It was formed on 29 May 1997 at a Ministers’ meeting held in Sintra, Portugal, as the successor to the North Atlantic Cooperation Council (NACC), which was created in 1991.

The EAPC provides an overall political framework for NATO’s cooperation with its partner countries in the Euro-Atlantic area. It works alongside the Partnership for Peace (PfP), which was created in January 1994. There are 50 members, including all 32 NATO member countries and 18 Partnership for Peace countries. Of its members, the United States has had a notable role in the council. In the post-Cold War era, the United States served as one of the key members of the EAPC that continued to push for engagement with Russia, which is an EAPC partner country.

The NACC and PfP
The EAPC serves as a successor of the NACC. The NACC, established in 1991, was created with the intention of being a forum of discussion and cooperation with NATO’s former Warsaw Pact adversaries. The NACC allowed for multilateral political consultation and cooperation, which helped build confidence in the early 1990s. Additionally, the NACC paved the way for the launch of the PfP in 1994. NATO launched the PfP with the goal of forging a real partnership of peace, instead of simply engaging in the dialogue. Its role was to expand and intensify political and military cooperation throughout Europe, increase stability, diminish threats to peace, and build relationships. However, the PfP needed the assistance of another organization, such as the EAPC, to work on these tasks.

By 1997, the Allies involved in the NACC recognized the desire to build a security forum that would include other Western European partners. Partners were beginning to deepen cooperation with NATO, and support for defence reform and transitions towards democracy were increasing. They needed a forum that was larger and better suited for increasingly sophisticated relationships, and therefore the EAPC succeeded the NACC in 1997.

Role and structure
In addition to providing the overall political framework for cooperation, the EAPC provides a framework for the bilateral relationship developed between NATO and individual partner countries under the PfP program. The EAPC’s actions are based on two-year action plans. These focus on consultation and cooperation on a range of political and security related issues. Under the EAPC, the ambassadors meet monthly while the foreign and defense ministers meet annually. The council's role is to maintain long-term consultation and cooperation; do crisis management and peace support operations; deal with regional issues; arms control; issues related to the proliferation of weapons and mass destruction; and international terrorism. On the defence level, the EAPC is responsible for planning, budgeting, policy and strategy, civil emergency planning, disaster preparedness, nuclear safety, air control, and scientific discovery. In addition to this, the EAPC is tasked with promoting and coordinating practical cooperation and exchange of expertise in key areas such as combatting terrorism, border security, and proliferation of weapons of mass destruction and small arms. NATO and EAPC’s policies have agreed to support international efforts in regards to the UN Security Council Resolution 1325 on women, peace and security, and combating human trafficking.

Security forums
On May 24-25th, 2005, the EAPC held its first Security Forum in Are, Sweden. It brought together Ministers and senior decision-makers from NATO and partner countries; and representatives of civil society and think tanks. Its goal was to engage with civil society and recognize the role NGOs play in NATO’s agenda regarding peace-building and reconstruction, particularly in areas of the Balkans and Afghanistan. NATO noted that delegates had the opportunity to hold deeper discussions on Euro-Atlantic issues compared to regular ministerial meetings.

In June 2007, the second Forum was held in Ohrid, Republic of Macedonia. Its focus was finding a comprehensive approach to Afghanistan, energy security, and integrating the Balkans into the Euro-Atlantic structure. The Forum included Ministers, senior officials, parliamentarians, academics, NGOs, and journalists. Jaap de Hoop Scheffer, the Secretary-General of NATO stated that they wanted participants from a range of professional backgrounds to bring about ideas, have open discussions, and understand different perspectives.

Membership
There are 50 member countries of the Euro-Atlantic Partnership Council, this includes:

The 32 NATO member countries:

 * 🇦🇱 Albania
 * 🇧🇪 Belgium
 * 🇧🇬 Bulgaria
 * 🇨🇦 Canada
 * 🇭🇷 Croatia
 * Czechia
 * 🇩🇰 Denmark
 * 🇪🇪 Estonia
 * 🇫🇮 Finland
 * 🇫🇷 France
 * 🇩🇪 Germany
 * 🇬🇷 Greece
 * 🇭🇺 Hungary
 * 🇮🇸 Iceland
 * 🇮🇹 Italy
 * 🇱🇻 Latvia
 * 🇱🇹 Lithuania
 * 🇱🇺 Luxembourg
 * 🇲🇪 Montenegro
 * 🇳🇱 Netherlands
 * North Macedonia
 * 🇳🇴 Norway
 * 🇵🇱 Poland
 * 🇵🇹 Portugal
 * 🇷🇴 Romania
 * 🇸🇰 Slovakia
 * 🇸🇮 Slovenia
 * 🇪🇸 Spain
 * 🇸🇪 Sweden
 * 🇹🇷 Turkey
 * 🇬🇧 United Kingdom
 * 🇺🇸 United States

The 18 partner countries:

Four liberal democracies with capitalist economies that were militarily neutral during, and after, the Cold War:

 * 🇦🇹 Austria
 * 🇮🇪 Ireland
 * 🇲🇹 Malta - Rejoined in 2008, it had initially joined in April 1995 and suspended its participation in October 1996.
 * 🇨🇭 Switzerland

Twelve former Soviet communist republics:

 * 🇦🇲 Armenia
 * 🇦🇿 Azerbaijan
 * 🇧🇾 Belarus
 * Georgia
 * 🇰🇿 Kazakhstan
 * 🇰🇬 Kyrgyzstan
 * 🇲🇩 Moldova
 * 🇷🇺 Russia
 * 🇹🇯 Tajikistan
 * 🇹🇲 Turkmenistan
 * 🇺🇦 Ukraine
 * 🇺🇿 Uzbekistan

Two former Yugoslav communist republics:

 * 🇧🇦 Bosnia and Herzegovina
 * 🇷🇸 Serbia

USA involvement in the EAPC
The USA served as one of the founding members of the NACC, the predecessor of the EAPC, in December 1991. Following the collapse of the NACC and the fusion of the PfP and the EAPC, the United States continued to serve on the EAPC as one of its key members.

In the post-Cold War era, The USA objective was to express more global interests in confronting crises and challenges. USA officials remained hopeful that cooperation with Russia was possible. According to Ingrid Lundestad in, “Turning Foe to Friend? USA Objectives in Including Russia in Post-Cold War Euro-Atlantic Security Co-operation”, the inclusion of Russia within the EAPC was understood to provide reconciliation and stability to the United States and the Euro-Atlantic region.

The promotion of democracy and market economics serves as an incentive for the United States to be involved in the EAPC. Greater European integration in the United States, combined with a persistent transatlantic bond, is one of the greatest motivators for the United States to be involved in the EAPC.

Russia and the EAPC
In the early 1990s, NATO Allies took several steps to engage Moscow in the Euro-Atlantic Partnership. They wished to promote democratic and economic reforms in the Euro-Atlantic area, particularly with Russia following a Cold-War period. Russia serves as a partner country in the EAPC. Their involvement can be traced to the first meeting of the North Atlantic Cooperation Council on December 20, 1991. The meeting took place with NATO, Eastern European nations, and the USSR present. Near the end of this meeting, the Soviet Ambassador received a message that as the meeting was taking place, the Soviet Union would cease to exist the following day. The Soviet Ambassador noted at that point that he would only be representing the Russian Federation, and no longer the Soviet Union.

By 1994, Russia joined the Partnership for Peace (PfP), strengthening the ties between Russia and NATO. Upon the fusion of the PfP and NACC, Russia automatically became a member of the EAPC in 1997. The same year, the NATO-Russia Founding Act was also signed, showing cooperation following a Cold-War era. While Russia primarily rejected the notion of an alliance, rather embracing practical cooperation with NATO and its organizations such as the Euro-Atlantic Partnership, in the 1990s Russia signed and engaged with a number of partnerships with NATO, such as the NATO-Russia Partnership Commission (NRC), which, in 1997, turned into the NATO-Russia Standing Joint Commission.

According to Vladimir Baranovsky, Russia’s objectives with the EAPC fall largely in the desire to promote security. Baranovsky says that Russia’s initiatives include stabilizing Europe, promoting cooperation and interaction between Europe in ‘traditional’ security-related areas and in new ideas, and narrowing differences over political and legal interpretations of Europe’s security. He also says that the most cooperative method to enhance traditional security is a three-way partnership with the United States, Russia, and NATO, and Russia is able to find this in the EAPC. Arms control in Europe is also discussed within the Council, and Russia finds an additional incentive to be a part of the EAPC due to this.

Results
As explored in Russia and the EAPC section, the EAPC has previously served as a ‘reset’ in US-Russia relations, and by extension NATO-Russia relations.

Today, the EAPC members continue to engage in partnership and dialogue. It has maintained a focus on security, stability, and democratic transformation in the Euro-Atlantic region.

title: Euro-Atlantic Partnership Council


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Peter Bonetti

Peter Philip Bonetti (27 September 1941 – 12 April 2020) was an English professional footballer who played as a goalkeeper for Chelsea, the St. Louis Stars, Dundee United and England. He was known for his safe handling, lightning reflexes and his graceful style, for which he was given the nickname "The Cat". He was one of several goalkeepers (Gordon West of Everton was another) who specialised in a one-armed throw which could achieve a similar distance to a drop kick.

Bonetti played seven times for England, but mainly served the team as a back-up to Gordon Banks; he was part of the winning England squad for the 1966 FIFA World Cup, but did not play. He belatedly received a winners' medal in 2009, after the Football Association led a successful campaign for non-playing members of the squad to be recognised. After Banks fell ill before the 1970 FIFA World Cup quarter-final, Bonetti played as England lost 3–2 to West Germany.

Early life
Bonetti was born in Putney, southwest London. His family moved to Worthing, Sussex in 1948. His parents ran a café on the seafront next to the Dome Cinema. They were Swiss-Italian emigrants from Ticino. Bonetti attended St Mary's Catholic Primary School, Worthing. He shone at an early age, playing for Worthing.

Chelsea
Chelsea signed him from the Reading youth team after his mother had written to manager Ted Drake, requesting that he give her son a trial. Whilst a Chelsea junior, Bonetti made five appearances for Croydon Amateurs in the Surrey Senior League thanks to youth team coach Albert Tennant who was also coaching Croydon at that time. He made his first team debut in 1960, and a few weeks later helped the Chelsea youth team win the FA Youth Cup. From the 1960–61 season onward he was Chelsea's first-choice goalkeeper, a position he held more-or-less constantly for the next nineteen years.

Chelsea were relegated in Bonetti's second full season, which saw the appointment of Tommy Docherty as manager. Bonetti emerged as a key figure in a talented young team which included Bobby Tambling, Terry Venables, John Hollins and Barry Bridges. The team went into the penultimate match of the season needing to beat promotion rivals Sunderland to have a chance of going up. Chelsea won 1–0, with Bonetti making a brilliant last minute save to deny George Mulhall and maintain his team's promotion chances; a 7–0 win over Portsmouth secured instant promotion back to the First Division.

The new Chelsea team challenged for honours during the 1960s, with Bonetti a key figure throughout, although more often than not the team narrowly missed out. The club won the League Cup in 1965 with a 3–2 aggregate victory over Leicester City. Leicester put Chelsea under heavy pressure in the second leg at Filbert Street, but an inspired performance from Bonetti helped secure a 0–0 draw, and thus the trophy for his team. For most of that season Chelsea were on course to add both the league title and the FA Cup, but ultimately missed out. They were beaten by Liverpool in the FA Cup; meanwhile, their title challenge ended with a few matches left, following a bust-up between Docherty and several of his first-team players (though not Bonetti). The disunity behind the scenes meant that a much-weakened team was fielded in a key match against Burnley, in which Bonetti conceded six goals.

Bonetti played in every match of Chelsea's Inter-Cities Fairs Cup run the following season, putting in a series of impressive displays against the likes of Roma, A.C. Milan and Barcelona, though the team was eventually knocked out in the semi-final, as they were in the FA Cup for the second consecutive year. The signing of Alex Stepney at the end of that season briefly threatened his position as Chelsea's first-choice goalkeeper, and he considered putting in a transfer request, but Stepney ultimately made only one appearance for the club and was sold to Manchester United a few months later. Chelsea eventually reached an FA Cup final in 1967, where they faced Tottenham Hotspur, but the team got outplayed on the day and Bonetti could do little to stop Spurs winning 2–1.

That was the closest he came to winning another trophy with Chelsea until 1970, by which time Docherty had been succeeded by Dave Sexton. In 1970, Chelsea again reached the FA Cup final and this time faced reigning league champions Leeds United. Over the two fiercely contested matches, Bonetti had what was perhaps the finest moment of his playing career. Chelsea were outplayed for large spells in the first final at Wembley Stadium and he made a series of crucial saves to help them emerge with a 2–2 draw. Shortly into the replay at Old Trafford, his left knee was badly injured after a challenge from Leeds' Mick Jones. He returned to the field after treatment, but was effectively playing on one leg for the rest of the match and was powerless to stop Jones scoring the opener a few minutes later. In spite of the injury, and being targeted by the Leeds forwards, he made crucial saves throughout the match, denying both Peter Lorimer and Terry Cooper, and resisted more pressure from Leeds after Chelsea had taken the lead in extra time to help secure a 2–1 win. Such were Bonetti's performances that season, he was voted runner-up in the FWA Footballer of the Year awards.

A year later, the team added the European Cup Winners' Cup after another replayed win in the final, this time over Spanish giants Real Madrid in Athens. Chelsea took a 2–0 lead in the replay, but Real dominated for much of the second half and it was another inspired performance from Bonetti that helped them hold on for a 2–1 win.

That was his last trophy with the club, although they narrowly missed out on more in the following years, losing in the 1972 League Cup final to Stoke City and in the semi-final of the same competition to Norwich City a year later. Financial and disciplinary problems within the club prevented them from building on their success.

St Louis Stars
Bonetti left on a free transfer in 1975, joining the St. Louis Stars of the North American Soccer League. That year, he made 21 appearances for the team and helped them top the Central Division that summer and reach the play-off semi-final.

Return to Chelsea
He then returned to Chelsea, where his experience proved invaluable in helping new manager Eddie McCreadie's young team gain promotion in 1976–77. Two years later, in May 1979, he played his final appearance for Chelsea, a 1–1 draw with Arsenal, having made a total of 729 appearances for the club in nineteen years – only Ron Harris has made more – and kept over 200 clean sheets. He conceded one goal or less in two-thirds of his appearances for Chelsea.

International career

Bonetti earned seven caps for England, kept out of the team by Gordon Banks. He was a member of England's successful 1966 FIFA World Cup squad, but did not make an appearance.

Bonetti's England career is largely remembered for one match – the 1970 FIFA World Cup quarter-final against West Germany in Mexico. He was thrust into the starting line-up as a late replacement for Banks, who was suffering from severe food poisoning. During the match England relinquished a 2–0 second-half lead and lost 3–2 after extra time. Bonetti received a large amount of blame from the public for the loss, and never played for England again.

In the 1966 World Cup final only the 11 players on the pitch at the end of the 4–2 win over West Germany received medals. Following a Football Association-led campaign to persuade FIFA to award medals to all winning squad members, Bonetti was presented with his medal by prime minister Gordon Brown at a ceremony at 10 Downing Street on 10 June 2009.

Retirement

After leaving Chelsea, Bonetti moved to the Isle of Mull where he ran a guesthouse and became a postman. While living in Scotland, he briefly came out of retirement to make several appearances for Dundee United as understudy to Hamish McAlpine. Following his retirement from playing, Bonetti moved into coaching and had spells with Chelsea and the England national team, as well as working with Kevin Keegan at Newcastle United, Fulham and Manchester City.

During his time as a Chelsea coach, he was persuaded to play two matches for Isthmian League Division Two club Woking, including an FA Cup debut in a 1–0 win over Football Conference team Weymouth. At one time he held the record for the most appearances for a single club by a goalkeeper, but was overtaken in the 1990s by Portsmouth's Alan Knight.

Since 2005, Bonetti made several appearances for an Old England XI in various charity matches, notably against celebrity teams, usually coming on for the last 10 minutes of each match.

Bonetti died on 12 April 2020, aged 78, following a long illness.

Career statistics

 * Source:

Totals include one Charity Shield appearance in 1970–71.

Honours
Chelsea Youth
 * FA Youth Cup: 1959–60

Chelsea
 * Football League Second Division promotion: 1962–63, 1976–77
 * FA Cup: 1969–70; runner-up: 1966–67
 * Football League Cup: 1964–65
 * European Cup Winners' Cup: 1970–71

St. Louis Stars
 * North American Soccer League Central Division: 1975

England
 * FIFA World Cup: 1966

Individual
 * North American Soccer League All-Star First team: 1975

license: Creative Commons - Attribution Share-Alike - https://creativecommons.org/licenses/by-sa/4.0/

title: Peter Bonetti


text:
Equity (law)

In the field of jurisprudence, equity is the particular body of law, developed in the English Court of Chancery, with the general purpose of providing legal remedies for cases wherein the common law is inflexible and cannot fairly resolve the disputed legal matter. Conceptually, equity was part of the historical origins of the system of common law of England, yet is a field of law separate from common law, because equity has its own unique rules and principles, and was administered by courts of equity.

Equity exists in domestic law, both in civil law and in common law systems, and in international law. The tradition of equity begins in antiquity with the writings of Aristotle (epieikeia) and with Roman law (aequitas). Later, in civil law systems, equity was integrated in the legal rules, while in common law systems it became an independent body of law.

Equity in common law jurisdictions (general)
In jurisdictions following the English common law system, equity is the body of law which was developed in the English Court of Chancery and which is now administered concurrently with the common law. In common law jurisdictions, the word "equity" "is not a synonym for 'general fairness' or 'natural justice, but refers to "a particular body of rules that originated in a special system of courts".

For much of its history, the English common law was principally developed and administered in the central royal courts: the Court of King's Bench, the Court of Common Pleas, and the Exchequer. Equity was the name given to the law which was administered in the Court of Chancery. The Judicature Acts of the 1870s effected a procedural fusion of the two bodies of law, ending their institutional separation. The reforms did not fuse the actual bodies of law however. As an example, this lack of fusion meant it was still not possible to receive an equitable remedy for a purely common law wrong. Judicial or academic reasoning which assumes the contrary has been described as a "fusion fallacy".

Jurisdictions which have inherited the common law system differ in their treatment of equity. Over the course of the twentieth century some common law systems began to place less emphasis on the historical or institutional origin of substantive legal rules. In England and Wales, Australia, New Zealand, and Canada, equity remains a distinct body of law. Modern equity includes, among other things:

 * the law relating to express, resulting, and constructive trusts;
 * fiduciary law;
 * equitable estoppel (including promissory and proprietary estoppel);
 * relief against penalties and relief against forfeiture;
 * the doctrines of contribution, subrogation and marshalling; and
 * equitable set-off.

Black's Law Dictionary, 10th ed., definition 4, differentiates "common law" (or just "law") from "equity". Before 1873, England had two complementary court systems: courts of "law" which could only award money damages and recognized only the legal owner of property, and courts of "equity" (courts of chancery) that could issue injunctive relief (that is, a court order to a party to do something, give something to someone, or stop doing something) and recognized trusts of property. This split propagated to many of the colonies, including the United States. The states of Delaware, Mississippi, South Carolina, and Tennessee continue to have divided Courts of Law and Courts of Chancery. In New Jersey, the appellate courts are unified, but the trial courts are organized into a Chancery Division and a Law Division. There is a difference of opinion in Commonwealth countries as to whether equity and common law have been fused or are merely administered by the same court, with the orthodox view that they have not (expressed as rejecting the "fusion fallacy") prevailing in Australia, while support for fusion has been expressed by the New Zealand Court of Appeal.

For most purposes, the U.S. federal system and most states have merged the two courts.

The latter part of the twentieth century saw increased debate over the utility of treating equity as a separate body of law. These debates were labelled the "fusion wars". A particular flashpoint in this debate centred on the concept of unjust enrichment and whether areas of law traditionally regarded as equitable could be rationalised as part of a single body of law known as the law of unjust enrichment.

History of equity in common law jurisdictions
After the Norman Conquest of England in the 11th century, royal justice came to be administered in three central courts: the Court of King's Bench, the Court of Common Pleas, and the Exchequer. The common law developed in these royal courts, which were created by the authority of the King of England, and whose jurisdiction over disputes between the King's subjects was based upon the King's writ. Initially, a writ was probably a vague order to do right by the plaintiff, and it was usually a writ of grace, issued at the pleasure of the King.

During the 12th and 13th centuries, writ procedure gradually evolved into something much more rigid. All writs to commence actions had to be purchased by litigants from the Chancery, the head of which was the Lord Chancellor. After writs began to become more specific and creative (in terms of the relief sought), Parliament responded in 1258 by providing in the Provisions of Oxford that the Chancellor could no longer create new writs without permission from the King and the King's Council (the curia regis). Pursuant to this authorization, litigants could purchase certain enumerated writs de cursu (as a matter of course) which later became known as writs ex debito justitiae (as a matter of right). Each of these writs was associated with particular circumstances and led to a particular kind of judgment. Procedure in the common law courts became tightly focused on the form of action (the particular procedure authorized by a particular writ to enforce a particular substantive right), rather than what modern lawyers would now call the cause of action (the underlying substantive right to be enforced).

Because the writ system was limited to enumerated writs for enumerated rights and wrongs, it sometimes produced unjust results. Thus, even though the King's Bench might have jurisdiction over a case and might have the power to issue the perfect writ, the plaintiff might still not have a case if there was not a single form of action combining them. Lacking a legal remedy, the plaintiff's only option would be to petition the King.

Litigants began to seek relief against unfair judgments of the common law courts by petitioning the King. Such petitions were initially processed by the King's Council, which itself was quite overworked, and the Council began to delegate the hearing of such petitions to the Lord Chancellor. This delegation is often justified by the fact that the Lord Chancellor was literally the Keeper of the King's Conscience, although Francis Palgrave argued that the delegation was initially driven by practical concerns and the moral justification came later. The moral justification went as follows: as Keeper of the King's Conscience, the Chancellor "would act in particular cases to admit 'merciful exceptions' to the King's general laws to ensure that the King's conscience was right before God". This concern for the King's conscience was then extended to the conscience of the defendant in Chancery, in that the Chancellor would intervene to prevent "unconscionable" conduct on the part of the defendant, in order to protect the conscience of the King.

By the 14th century it appears that Chancery was operating as a court, affording remedies for which the strict procedures of the common law worked injustice or provided no remedy to a deserving plaintiff. Chancellors often had theological and clerical training and were well versed in Roman law and canon law. During this era, the Roman concept of aequitas influenced the development of the distinctly different but related English concept of equity: "The equity administered by the early English chancellors ... [was] confessedly borrowed from the aequitas and the judicial powers of the Roman magistrates." By the 15th century the judicial power of Chancery was clearly recognised.

Early Chancery pleadings vaguely invoked some sort of higher justice, such as with the formula "for the love of God and in way of charity". During the 15th century, Chancery pleadings began to expressly invoke "conscience", to the point that English lawyers in the late 15th century thought of Chancery as a court of "conscience", not a court of "equity". However, the "reasoning of the medieval chancellors has not been preserved" as to what they actually meant by the word "conscience", and modern scholars can only indirectly guess at what the word probably meant. The publication of the treatise The Doctor and Student in the early 16th century marked the beginning of Chancery's transformation from a court of conscience to a court of equity.

Before that point in time, the word "equity" was used in the common law to refer to a principle of statutory interpretation derived from aequitas: the idea that written laws ought to be interpreted "according to the intention rather than the letter" of the law. What was new was the application of the word "equity" to "the extraordinary form of justice administered by the chancellor", as a convenient way to distinguish Chancery jurisprudence from the common law.

A common criticism of Chancery practice as it developed in the early medieval period was that it lacked fixed rules, varied greatly from Chancellor to Chancellor, and the Chancellor was exercising an unbounded discretion. The counterargument was that equity mitigated the rigour of the common law by looking to substance rather than to form.

The early chancellors were influenced by their training in theology and canon law, but the law of equity they applied was not canon law, but a new kind of law purportedly driven by conscience. Whatever it meant in the medieval era, the word "conscience" clearly carried a subjective connotation (as it still does today). Complaints about equity as an arbitrary exercise of conscience by nonlawyer Chancellors became quite frequent under the chancellorship of Thomas Wolsey (1515–1529), who "had no legal training, and delighted in putting down lawyers".

In 1546, Chancellor Thomas Wriothesley, a nonlawyer, was accused of trying to inject the civil law into Chancery. This was a "wild exaggeration", but as a result, the Crown began to transition away from clergy and nonlawyers and instead appointed only lawyers trained in the common law tradition to the position of Lord Chancellor (although there were six more nonlawyer chancellors in the decades after Wriothesley). The last person without training in the common law before 2016 to serve as Lord Chancellor was Anthony Ashley Cooper, 1st Earl of Shaftesbury, who served briefly from 1672 to 1673. (Liz Truss was appointed as Lord Chancellor in 2016, but this was after the position had been stripped of its judicial powers by the Constitutional Reform Act 2005, leaving the Chancellor of the High Court as the highest judge sitting in equity in England and Wales.)

The development of a court of equity as a remedy for the rigid procedure of the common law courts meant it was inevitable that the two systems would come into conflict. Litigants would go 'jurisdiction shopping' and often would seek an equitable injunction prohibiting the enforcement of a common law court order. The penalty for disobeying an equitable injunction and enforcing an unconscionable common law judgment was imprisonment.

The 1615 conflict between common law and equity came about because of a "clash of strong personalities" between Lord Chancellor Ellesmere and the Chief Justice of the King's Bench, Sir Edward Coke. Chief Justice Coke began the practice of issuing writs of habeas corpus that required the release of people imprisoned for contempt of chancery orders. This tension reached a climax in the Earl of Oxford's case (1615) where a judgment of Chief Justice Coke was allegedly obtained by fraud. Chancellor Ellesmere issued an injunction from the Chancery prohibiting the enforcement of the common law order. The two courts became locked in a stalemate, and the matter was eventually referred to the Attorney General, Sir Francis Bacon. Sir Francis, by authority of King James I, upheld the use of the equitable injunction and concluded that in the event of any conflict between the common law and equity, equity would prevail.

Chancery continued to be the subject of extensive criticism, the most famous of which was 17th-century jurist John Selden's aphorism:

"Equity is a roguish thing: for law we have a measure, know what to trust to; equity is according to the conscience of him that is Chancellor, and as that is larger or narrower, so is equity. 'Tis all one as if they should make the standard for the measure we call a foot, a Chancellor's foot; what an uncertain measure would this be? One Chancellor has a long foot, another a short foot, a third an indifferent foot: 'tis the same thing in a Chancellor's conscience."

After 1660, Chancery cases were regularly reported, several equitable doctrines developed, and equity started to evolve into a system of precedents like its common law cousin. Over time, equity jurisprudence would gradually become a "body of equitable law, as complex, doctrinal, and rule-haunted as the common law ever was".

One indicator of equity's evolution into a coherent body of law was Lord Eldon's response to Selden in an 1818 chancery case: "I cannot agree that the doctrines of this court are to be changed with every succeeding judge. Nothing would inflict on me greater pain, in quitting this place, than the recollection that I had done anything to justify the reproach that the equity of this court varies like the Chancellor's foot."

Equity's primacy over common law in England was later enshrined in the Judicature Acts of the 1870s, which also served to fuse the courts of equity and the common law (although emphatically not the systems themselves) into one unified court system.

Statute of Uses 1535
One area in which the Court of Chancery assumed a vital role was the enforcement of uses, a role that the rigid framework of land law could not accommodate. This role gave rise to the basic distinction between legal and equitable interests.

In order to avoid paying land taxes and other feudal dues, lawyers developed a primitive form of trust called 'the use' that enabled one person (who was not required to pay tax) to hold the legal title of the land for the use of another person. The effect of this trust was that the first person owned the land under the common law, but the second person had a right to use the land under the law of equity.

Henry VIII enacted the Statute of Uses in 1535 (which became effective in 1536) in an attempt to outlaw this practice and recover lost revenue. The Act effectively made the beneficial owner of the land the legal owner and therefore liable for feudal dues.

The response of the lawyers to this Statute was to create the 'use upon a use'. The Statute recognized only the first use, and so land owners were again able to separate the legal and beneficial interests in their land.

Australia
Equity remains a cornerstone of Australian private law. A string of cases in the 1980s saw the High Court of Australia re-affirm the continuing vitality of traditional equitable doctrines. In 2009 the High Court affirmed the importance of equity and dismissed the suggestion that unjust enrichment has explanatory power in relation to traditional equitable doctrines such as subrogation.

The state of New South Wales is particularly well known for the strength of its Equity jurisprudence. However, it was only in 1972 with the introduction of reform to the Supreme Court Act 1970 (NSW) that empowered both the Equity and Common Law Division of the Supreme Court of NSW to grant relief in either equity or common law. In 1972 NSW also adopted one of the essential sections of the Judicature reforms, which emphasised that where there was a conflict between the common law and equity, equity would always prevail. Nevertheless, in 1975 three alumni of Sydney Law School and judges of the NSW Supreme Court, Roddy Meagher, William Gummow and John Lehane produced Equity: Doctrines & Remedies. It remains one of the most highly regarded practitioner texts in Australia and England. The work is now in its 5th edition and edited by Dyson Heydon, former Justice of the High Court, Justice Mark Leeming of the New South Wales Court of Appeal, and Dr Peter Turner of Cambridge University.

England and Wales
Equity remains a distinct part of the law of England and Wales. The main challenge to it has come from academic writers working within the law of unjust enrichment. Scholars such as Peter Birks and Andrew Burrows argue that in many cases the inclusion of the label "legal" or "equitable" before a substantive rule is often unnecessary. Many English universities, such as Oxford and Cambridge, continue to teach Equity as a standalone subject. Leading practitioner texts include Snell's Equity, Lewin on Trusts, and Hayton & Underhill's Law of Trusts and Trustees.

Limits on the power of equity in English law were clarified by the House of Lords in The Scaptrade case (Scandinavian Trading Tanker Co. A.B. v Flota Petrolera Ecuatoriana [1983] 2 AC 694, 700), where the notion that the court's jurisdiction to grant relief was "unlimited and unfettered" (per Lord Simon of Glaisdale in Shiloh Spinners Ltd v. Harding [1973] A.C. 691, 726) was rejected as a "beguiling heresy".

Scotland
The courts of Scotland have never recognised a division between the normal common law and equity, and as such the Court of Session (the supreme civil court of Scotland) has exercised an equitable and inherent jurisdiction and called the nobile officium. The nobile officium enables the Court to provide a legal remedy where statute or the common law are silent, and prevent mistakes in procedure or practice that would lead to injustice. The exercise of this power is limited by adherence to precedent, and when legislation or the common law already specify the relevant remedy. Thus, the Court cannot set aside a statutory power, but can deal with situations where the law is silent, or where there is an omission in statute. Such an omission is sometimes termed a casus improvisus.

India
In India the common law doctrine of equity had traditionally been followed even after it became independent in 1947. However, in 1963 the Specific Relief Act was passed by the Parliament of India following the recommendation of the Law Commission of India and repealing the earlier "Specific Relief Act" of 1877. Under the 1963 Act, most equitable concepts were codified and made statutory rights, thereby ending the discretionary role of the courts to grant equitable reliefs. The rights codified under the 1963 Act were as under:
 * Recovery of possession of immovable property (ss. 5–8)
 * Specific performance of contracts (ss. 9–25)
 * Rectification of instruments (s. 26)
 * Recession of contracts (ss. 27–30)
 * Cancellation of instruments (ss. 31–33)
 * Declaratory decrees (ss. 34–35)
 * Injunctions (ss. 36–42)

With this codification, the nature and tenure of the equitable reliefs available earlier have been modified to make them statutory rights and are also required to be pleaded specifically to be enforced. Further to the extent that these equitable reliefs have been codified into rights, they are no longer discretionary upon the courts or as the English law has it, "Chancellor's foot" but instead are enforceable rights subject to the conditions under the 1963 Act being satisfied. Nonetheless, in the event of situations not covered under the 1963 Act, the courts in India continue to exercise their inherent powers in terms of Section 151 of the Code of Civil Procedure, 1908, which applies to all civil courts in India.

There is no such inherent powers with the criminal courts in India except with the High Courts in terms of Section 482 of the Code of Criminal Procedure, 1973. Further, such inherent powers are vested in the Supreme Court of India in terms of Article 142 of the Constitution of India which confers wide powers on the Supreme Court to pass orders "as is necessary for doing complete justice in any cause of matter pending before it".

United States
In modern practice, perhaps the most important distinction between law and equity is the set of remedies each offers. The most common civil remedy a court of law can award is monetary damages. Equity, however, enters injunctions or decrees directing someone either to act or to forbear from acting. Often, this form of relief is in practical terms more valuable to a litigant; for example, a plaintiff whose neighbor will not return his only milk cow, which had wandered onto the neighbor's property, may want that particular cow back, not just its monetary value. However, in general, a litigant cannot obtain equitable relief unless there is "no adequate remedy at law"; that is, a court will not grant an injunction unless monetary damages are an insufficient remedy for the injury in question. Law courts can also enter certain types of immediately enforceable orders, called "writs" (such as a writ of habeas corpus), but they are less flexible and less easily obtained than an injunction.

Another distinction is the unavailability of a jury in equity: the judge is the trier of fact. In the American legal system, the right of jury trial in civil cases tried in federal court is guaranteed by the Seventh Amendment in Suits at common law, cases that traditionally would have been handled by the law courts. The question of whether a case should be determined by a jury depends largely on the type of relief the plaintiff requests. If a plaintiff requests damages in the form of money or certain other forms of relief, such as the return of a specific item of property, the remedy is considered legal, and a jury is available as the fact-finder. On the other hand, if the plaintiff requests an injunction, declaratory judgment, specific performance, modification of contract, or some other non-monetary relief, the claim would usually be one in equity.

Thomas Jefferson explained in 1785 that there are three main limitations on the power of a court of equity: "If the legislature means to enact an injustice, however palpable, the court of Chancery is not the body with whom a correcting power is lodged. That it shall not interpose in any case which does not come within a general description and admit of redress by a general and practicable rule." The US Supreme Court, however, has concluded that courts have wide discretion to fashion relief in cases of equity. The first major statement of this power came in Willard v. Tayloe, 75 U.S. 557 (1869). The Court concluded that "relief is not a matter of absolute right to either party; it is a matter resting in the discretion of the court, to be exercised upon a consideration of all the circumstances of each particular case." Willard v. Tayloe was for many years the leading case in contract law regarding intent and enforcement. as well as equity.

In the United States, the federal courts and most state courts have merged law and equity into courts of general jurisdiction, such as county courts. However, the substantive distinction between law and equity has retained its old vitality. This difference is not a mere technicality, because the successful handling of certain law cases is difficult or impossible unless a temporary restraining order (TRO) or preliminary injunction is issued at the outset, to restrain someone from fleeing the jurisdiction taking the only property available to satisfy a judgment, for instance. Furthermore, certain statutes like the Employee Retirement Income Security Act specifically authorize only equitable relief, which forces American courts to analyze in lengthy detail whether the relief demanded in particular cases brought under those statutes would have been available in equity.

Equity courts were widely distrusted in the northeastern United States following the American Revolution. A serious movement for merger of law and equity began in the states in the mid-19th century, when David Dudley Field II convinced New York State to adopt what became known as the Field Code of 1848. The federal courts did not abandon the old law/equity separation until the promulgation of the Federal Rules of Civil Procedure in 1938.

Three states still have separate courts for law and equity: Delaware, whose Court of Chancery is where most cases involving Delaware corporations (which includes a disproportionate number of multi-state corporations) are decided; Mississippi; and Tennessee. However, merger in some states is less than complete; some other states (such as Illinois and New Jersey) have separate divisions for legal and equitable matters in a single court. Virginia had separate law and equity dockets (in the same court) until 2006. Besides corporate law, which developed out of the law of trusts, areas traditionally handled by chancery courts included wills and probate, adoptions and guardianships, and marriage and divorce. Bankruptcy was also historically considered an equitable matter; although bankruptcy in the United States is today a purely federal matter, reserved entirely to the United States Bankruptcy Courts by the enactment of the United States Bankruptcy Code in 1978, bankruptcy courts are still officially considered "courts of equity" and exercise equitable powers under Section 105 of the Bankruptcy Code.

After US courts merged law and equity, American law courts adopted many of the procedures of equity courts. The procedures in a court of equity were much more flexible than the courts at common law. In American practice, certain devices such as joinder, counterclaim, cross-claim and interpleader originated in the courts of equity.

title: Equity (law)


text:
Rubiaceae

Rubiaceae is a family of flowering plants, commonly known as the coffee, madder, or bedstraw family. It consists of terrestrial trees, shrubs, lianas, or herbs that are recognizable by simple, opposite leaves with interpetiolar stipules and sympetalous actinomorphic flowers. The family contains about 14,100 species in about 580 genera, which makes it the fourth-largest angiosperm family. Rubiaceae has a cosmopolitan distribution; however, the largest species diversity is concentrated in the tropics and subtropics. Economically important genera include Coffea, the source of coffee; Cinchona, the source of the antimalarial alkaloid quinine; ornamental cultivars (e.g., Gardenia, Ixora, Pentas); and historically some dye plants (e.g., Rubia).

Description
The Rubiaceae are morphologically easily recognizable as a coherent group by a combination of characters: opposite or whorled leaves that are simple and entire, interpetiolar stipules, tubular sympetalous actinomorphic corollas and an inferior ovary.

A wide variety of growth forms are present: shrubs are most common (e.g. Coffea, Psychotria), but members of the family can also be trees (e.g. Cinchona, Nauclea), lianas (e.g. Psychotria samoritourei), or herbs (e.g. Galium, Spermacoce). Some epiphytes are also present (e.g. Myrmecodia). The plants usually contain iridoids, various alkaloids, and raphide crystals are common. The leaves are simple, undivided, and entire; there is only one case of pinnately compound leaves (Pentagonia osapinnata ). Leaf blades are usually elliptical, with a cuneate base and an acute tip. In three genera (Pavetta, Psychotria, Sericanthe), bacterial leaf nodules can be observed as dark spots or lines on the leaves. The phyllotaxis is usually decussate, rarely whorled (e.g. Fadogia), or rarely seemingly alternate resulting from the reduction of one leaf at each node (e.g. Sabicea sthenula). Characteristic for the Rubiaceae is the presence of stipules that are mostly fused to an interpetiolar structure on either side of the stem between the opposite leaves. Their inside surface often bears glands called "colleters", which produce mucilaginous compounds protecting the young shoot. The "whorled" leaves of the herbaceous tribe Rubieae have classically been interpreted as true leaves plus interpetiolar leaf-like stipules. The inflorescence is a cyme, rarely of solitary flowers (e.g. Rothmannia), and is either terminal or axillary and paired at the nodes. The 4-5-merous (rarely pleiomerous; e.g. six in Richardia ) flowers are usually bisexual and usually epigynous. The perianth is usually biseriate, although the calyx is absent in some taxa (e.g. Theligonum). The calyx mostly has the lobes fused at the base; unequal calyx lobes are not uncommon, and sometimes (e.g. Mussaenda) one lobe is enlarged and coloured (a so-called “semaphyl”). The corolla is sympetalous, mostly actinomorphic, usually tubular, mostly white or creamy but also yellow (e.g. Gardenia spp., Mycelia basiflora), and rarely blue (e.g. Faramea calyptrata) or red (e.g. Alberta magna, Ixora coccinea). The stamens are alternipetalous and epipetalous. Anthers are longitudinal in dehiscence, but are poricidal in some genera (e.g. Rustia, Tresanthera). The gynoecium is syncarpous with an inferior ovary (rarely secondarily superior, e.g. Gaertnera, Pagamea ). Placentation is axial, rarely parietal (e.g. Gardenia); ovules are anatropous to hemitropous, unitegmic, with a funicular obturator, one to many per carpel. Nectaries are often present as a nectariferous disk atop the ovary. The fruit is a berry, capsule (e.g. Oldenlandia), drupe (e.g. Coffea, Psychotria), or schizocarp (e.g. Cremocarpon). Red fruits are fairly dominant (e.g. Coffea arabica); yellow (e.g. Rosenbergiodendron formosum), orange (e.g. Vangueria infausta), or blackish fruits (e.g. Pavetta gardeniifolia) are equally common; blue fruits are rather exceptional save in the Psychotrieae and associated tribes. Most fruits are about 1 cm in diameter; very small fruits are relatively rare and occur in herbaceous tribes; very large fruits are rare and confined to the Gardenieae. The seeds are endospermous.

Distribution and habitat
Rubiaceae have a cosmopolitan distribution and are found in nearly every region of the world, except for extreme environments such as the polar regions and deserts. The distribution pattern of the family is very similar to the global distribution of plant diversity overall. However, the largest diversity is distinctly concentrated in the humid tropics and subtropics. An exception is the tribe Rubieae, which is cosmopolitan but centered in temperate regions. Only a few genera are pantropical (e.g. Ixora, Psychotria), many are paleotropical, while Afro-American distributions are rare (e.g. Sabicea). Endemic rubiaceous genera are found in most tropical and subtropical floristic regions of the world. The highest number of species is found in Colombia, Venezuela, and New Guinea. When adjusted for area, Venezuela is the most diverse, followed by Colombia and Cuba.

The Rubiaceae consist of terrestrial and predominantly woody plants. Woody rubiaceous shrubs constitute an important part of the understorey of low- and mid-altitude rainforests. Rubiaceae are tolerant of a broad array of environmental conditions (soil types, altitudes, community structures, etc.) and do not specialize in one specific habitat type (although genera within the family often specialize).

Flower biology
Most members of the Rubiaceae are zoophilous, pollinated mainly by insects. Entomophilous species produce nectar from an epigynous disk at the base of the corolla tube to attract insects. Ornithophily is rare and is found in red-flowered species of Alberta, Bouvardia, and Burchellia. Anemophilous species are found in the tribes Anthospermeae and Theligoneae and are characterized by hermaphroditic or unisexual flowers that exhibit a set of specialized features, such as striking sexual dimorphism, increased receptive surface of the stigmas and pendulous anthers.

Although most Rubiaceae species are hermaphroditic, outbreeding is promoted through sequential hermaphroditism and spatial isolation of the reproductive organs. More complex reproductive strategies include secondary pollen presentation, heterostyly, and unisexual flowers.

Secondary pollen presentation (also known as stylar pollen presentation or ixoroid pollen mechanism) is especially known from the Gardenieae and related tribes. The flowers are proterandrous and the pollen is shed early onto the outside of the stigmas or the upper part of the style, which serve as a pollen receptacle. Increased surface area and irregularity of the pollen receptacle, caused by swellings, hairs, grooves or ridges often ensure a more efficient pollen deposition. After elongation of the style, animals transport the pollen to flowers in the female or receptive stage with exposed stigmatic surfaces. A pollen catapult mechanism is present in the genera Molopanthera and Posoqueria (tribe Posoquerieae) that projects a spherical pollen mass onto visiting hawk moths.

Heterostyly is another mechanism to avoid inbreeding and is widely present in the family Rubiaceae. The tribes containing the largest number of heterostylous species are Spermacoceae and Psychotrieae. Heterostyly is absent in groups that have secondary pollen presentation (e.g. Vanguerieae).

Unisexual flowers also occur in Rubiaceae and most taxa that have this characteristic are dioecious. The two flower morphs are however difficult to observe as they are rather morphologically similar; male flowers have a rudimentary pistil with the ovaries empty and female flowers sterile or rudimentary stamens with empty anthers. Flowers that are morphologically hermaphrodite, but functionally dioecious occur in Pyrostria.

Fruit biology
The dispersal units in Rubiaceae can be entire fruits, syncarps, mericarps, pyrenes or seeds. Fleshy fruit taxa are probably all (endo)zoochorous (e.g. tribes Pavetteae, Psychotrieae), while the dispersal of dry fruits is often unspecialized (e.g. tribes Knoxieae, Spermacoceae). When seeds function as diaspores, the dispersal is either anemochorous or hydrochorous. The three types of wind-dispersed diaspores in Rubiaceae are dust seeds (rare, e.g. Lerchea), plumed seeds (e.g. Hillia), and winged seeds (e.g. Coutarea). Long-distance dispersal by ocean currents is very rare (e.g. the seashore tree Guettarda speciosa). Other dispersal mechanisms are absent or at least very rare. Some Spermacoceae having seeds with elaiosomes are probably myrmecochorous (e.g. Spermacoce hepperiana). Epizoochorous taxa are limited to herbaceous Rubiaceae (e.g. Galium aparine fruits are densely covered with hooked bristly hairs).

Associations with other organisms
The genera Anthorrhiza, Hydnophytum, Myrmecodia, Myrmephytum, and Squamellaria are succulent epiphytes that have evolved a mutualistic relationship with ants. Their hypocotyl grows out into an ant-inhabited tuber. Some shrubs or trees have ant holes in their stems (e.g. Globulostylis). Some Rubiaceae species have domatia that are inhabited by mites (viz. acarodomatia; e.g. Plectroniella armata).

An intimate association between bacteria and plants is found in three rubiaceous genera (viz. Pavetta, Psychotria, and Sericanthe). The presence of endophytic bacteria is visible by eye because of the formation of dark spots or nodules in the leaf blades. The endophytes have been identified as Burkholderia bacteria. A second type of bacterial leaf symbiosis is found in the genera Fadogia, Fadogiella, Globulostylis, Rytigynia, and Vangueria (all belonging to the tribe Vanguerieae),  and in some species of Empogona and Tricalysia (both belonging to the tribe Coffeeae), where Burkholderia bacteria are found freely distributed among the mesophyll cells and no leaf nodules are formed. The hypothesis regarding the function of the symbiosis is that the endophytes provide chemical protection against herbivory by producing certain toxic secondary metabolites.

Systematics
The family Rubiaceae is named after Rubia, a name used by Pliny the Elder in his Naturalis Historia for madder (Rubia tinctorum). The roots of this plant have been used since ancient times to extract alizarin and purpurin, two red dyes used for coloring clothes. The name rubia is therefore derived from the Latin word ruber, meaning red. The well-known genus Rubus (blackberries and raspberries) is unrelated and belongs to Rosaceae, the rose family.

Taxonomy
The name Rubiaceae (nomen conservandum) was published in 1789 by Antoine Laurent de Jussieu, but the name was already mentioned in 1782.

Several historically accepted families are included in Rubiaceae: Aparinaceae, Asperulaceae, Catesbaeaceae, Cephalanthaceae, Cinchonaceae, Coffeaceae, Coutariaceae, Dialypetalanthaceae, Galiaceae, Gardeniaceae, Guettardaceae, Hameliaceae, Hedyotidaceae, Henriqueziaceae, Houstoniaceae, Hydrophylacaceae, Lippayaceae, Lygodisodeaceae, Naucleaceae, Nonateliaceae, Operculariaceae, Pagamaeaceae, Psychotriaceae, Randiaceae, Sabiceaceae, Spermacoceaceae, Theligonaceae.

Subfamilies and tribes
The classical classification system of Rubiaceae distinguished only two subfamilies: Cinchonoideae, characterized by more than one ovule in each locule, and Coffeoideae, having one ovule in each locule. This distinction, however, was criticized because of the distant position of two obviously related tribes, viz. Gardenieae with many ovules in Cinchonoideae and Ixoreae with one ovule in Coffeoideae, and because in species of Tarenna the number of ovules varies from one to several in each locule. During the 20th century, other morphological characters were used to delineate subfamilies, e.g. stylar pollen presentation, raphides, endosperm, heterostyly, etc. On this basis, three or eight subfamilies were recognised. The last subfamilial classification solely based on morphological characters divided Rubiaceae into four subfamilies: Cinchonoideae, Ixoroideae, Antirheoideae, and Rubioideae. In general, problems of subfamilies delimitation in Rubiaceae based on morphological characters are linked with the extreme naturalness of the family, hence a relatively low divergence of its members.

The introduction of molecular phylogenetics in Rubiaceae research has corroborated or rejected several of the conclusions made in the pre-molecular era. There was support for the subfamilies Cinchonoideae, Ixoroideae, and Rubioideae, although differently circumscribed, and Antirheoideae was shown to be polyphyletic. For a long time, the classification with three subfamilies (Cinchonoideae, Ixoroideae, and Rubioideae) was followed. However, an alternative opinion existed with only two subfamilies: an expanded Cinchonoideae (that includes Ixoroideae, Coptosapelteae, and Luculieae) and Rubioideae. Finally, more and more evidence pointed towards a two-family classification. The adoption of the Melbourne Code for botanical nomenclature had an unexpected impact on many names that have been long in use and are well-established in literature. According to the Melbourne Code, the subfamilial name Ixoroideae had to be replaced by Dialypetalanthoideae. This means that the two subfamilies in Rubiaceae now are: Dialypetalanthoideae and Rubioideae. The monogeneric tribes Coptosapelteae, Acranthereae, and Luculieae are not placed within a subfamily and are sister to the rest of Rubiaceae. The following overview shows the latest classification of the family, with two subfamilies and 71 tribes. The approximate number of species and genera are indicated between brackets (species/genera).

Genera
The family Rubiaceae contains about 14,100 species in 580 genera. This makes it the fourth-largest family of flowering plants by number of species and fifth-largest by number of genera. Although taxonomic adjustments are still being made, the total number of accepted genera remains stable. In total, around 1338 genus names have been published, indicating that more than half of the published names are synonyms. Psychotria, with around 1630 species, is the largest genus within the family and the third-largest genus of the angiosperms, after the legume Astragalus and the orchid Bulbophyllum. However, the delimitation of Psychotria remains problematic and its adjustment might reduce the number of species. In total, 30 genera have more than 100 species. However, 197 genera are monotypic, which account for a third of all genera, but only for 1.4% of all species.

Phylogeny
Molecular studies have demonstrated the phylogenetic placement of Rubiaceae within the order Gentianales and the monophyly of the family is confirmed. The relationships of the two subfamilies of Rubiaceae together with the tribes Acranthereae, Coptosapelteae, and Luculieae are shown in the phylogenetic tree below. The placement of these three tribes relative to the two subfamilies has not been fully resolved.

Evolution
The fossil history of the Rubiaceae goes back at least as far as the Eocene. The geographic distribution of these fossils, coupled with the fact that they represent all three subfamilies, is indicative of an earlier origin for the family, probably in the Late Cretaceous or Paleocene. Although fossils dating back to the Cretaceous and Palaeocene have been referred to the family by various authors, none of these fossils has been confirmed as belonging to the Rubiaceae.

The oldest confirmed fossils, which are fruits that strongly resemble those of the genus Emmenopterys, were found in the Washington and are 48–49 million years old. A fossil infructescence and fruit found in 44 million-year-old strata in Oregon was assigned to Emmenopterys dilcheri, an extinct species. The next-oldest fossils date to the Late Eocene and include Canthium from Australia, Faramea from Panama, Guettarda from New Caledonia, and Paleorubiaceophyllum, an extinct genus from the southeastern United States.

Fossil Rubiaceae are known from three regions in the Eocene (North America north of Mexico, Mexico-Central America-Caribbean, and Southeast Pacific-Asia). In the Oligocene, they are found in these three regions plus Africa. In the Miocene, they are found in these four regions plus South America and Europe.

Food
No staple foods are found in the Rubiaceae, but some species are consumed locally and fruits may be used as famine food. Examples are African medlar fruits (e.g. V. infausta, V. madagascariensis), African peach (Nauclea latifolia), and noni (Morinda citrifolia).

Beverage
The most economically important member of the family is the genus Coffea used in the production of coffee. Coffea includes 124 species, but only three species are cultivated for coffee production: C. arabica, C. canephora, and C. liberica.

Medicinal
The bark of trees in the genus Cinchona is the source of a variety of alkaloids, the most familiar of which is quinine, one of the first agents effective in treating malaria. Woodruff (Galium odoratum) is a small herbaceous perennial that contains coumarin, a natural precursor of warfarin, and the South American plant Carapichea ipecacuanha is the source of the emetic ipecac. Psychotria viridis is frequently used as a source of dimethyltryptamine in the preparation of ayahuasca, a psychoactive decoction. The bark of the species Breonadia salicina have been used in traditional African medicine for many years. The leaves of the Kratom plant (Mitragyna speciosa) contain a variety of alkaloids, including several psychoactive alkaloids and is traditionally prepared and consumed in Southeast Asia, where it has been known to exhibit both painkilling and stimulant qualities, behaving as a μ-opioid receptor agonist, and often being used in traditional Thai medicine in a similar way to and often as a replacement for opioid painkillers like morphine.

Ornamentals
Originally from China, the common gardenia (Gardenia jasminoides) is a widely grown garden plant and flower in frost-free climates worldwide. Several other species from the genus are also seen in horticulture. The genus Ixora contains plants cultivated in warmer-climate gardens; the most commonly grown species, Ixora coccinea, is frequently used for pretty red-flowering hedges. Mussaenda cultivars with enlarged, colored calyx lobes are shrubs with the aspect of Hydrangea; they are mainly cultivated in tropical Asia. The New Zealand native Coprosma repens is a commonly used plant for hedges. The South African Rothmannia globosa is seen as a specimen tree in horticulture. Nertera granadensis is a well-known house plant cultivated for its conspicuous orange berries. Other ornamental plants include Mitchella, Morinda, Pentas, and Rubia.

Dyes
Rose madder, the crushed root of Rubia tinctorum, yields a red dye, and the tropical Morinda citrifolia yields a yellow dye.

Culture

 * Cinchona officinalis is the national tree of Ecuador and Peru.
 * Coffea arabica is the national flower of Yemen.
 * Ixora coccinea is the national flower of Suriname.
 * Warszewiczia coccinea is the national flower of Trinidad and Tobago.

title: Rubiaceae


text:
Gambier

Gambier may refer to:

Given name

 * Gambier Bolton (1854–1928), English photographer

Surname

 * Edward John Gambier (1794–1879), British colonial judge
 * Gloucester Gambier (1812–1872), English first-class cricketer and British Army officer
 * James Gambier (Royal Navy officer) (1723–1789), British vice-admiral
 * James Gambier, 1st Baron Gambier (1756–1833), British admiral also known as Lord Gambier
 * Maurice Gambier d'Hurigny (1912– - 2000), French sculptor

Places

 * Gambier Islands (South Australia), Australia
 * Gambier Island, British Columbia, Canada
 * Gambier Islands, French Polynesia
 * Gambier (commune), French Polynesia
 * Gambier, Ohio, United States

Other uses

 * Uncaria gambir, a species of tropical shrub
 * Gambier (extract), made from Uncaria gambir

title: Gambier


text:
Uncaria

Uncaria is a genus of flowering plants in the family Rubiaceae. It has about 40 species. Their distribution is pantropical, with most species native to tropical Asia, three from Africa and the Mediterranean and two from the neotropics. They are known colloquially as gambier, cat's claw or uña de gato. The latter two names are shared with several other plants. The type species for the genus is Uncaria guianensis.

Indonesian Gambier (U. gambir) is a large tropical vine with leaves typical of the genus, being opposite and about 10 cm long. The South American U. tomentosa is called Uña de Gato. Uncaria sinensis is common in China.

Uncaria was named in 1789 by Johann von Schreber in his Genera Plantarum edition 8[a] (not to be confused with books of the same title by Linnaeus, Jussieu, and others). The genus name is derived from the Latin word uncus, meaning "a hook". It refers to the hooks, formed from reduced branches, that Uncaria vines use to cling to other vegetation.

Uncaria is a member of the tribe Naucleeae, but its position within that tribe remains unresolved.

Description
Woody lianas; climbing by hooks formed from reduced, modified branches. Stipules entire or bifid. Inflorescences are compact heads at the ends of horizontal, very reduced branches. Corolla lobes without appendages. Seeds with a long wing at each end, the lower wing deeply bifid.

Species
, Plants of the World Online accepted the following species:

 * Uncaria acida (W.Hunter) Roxb.
 * Uncaria africana G.Don
 * Uncaria angolensis (Havil.) Welw. ex Hutch. & Dalziel
 * Uncaria attenuata Korth.
 * Uncaria barbata Merr.
 * Uncaria bernaysii F.Muell.
 * Uncaria borneensis Havil.
 * Uncaria callophylla Blume ex Korth.
 * Uncaria canescens Korth.
 * Uncaria cordata (Lour.) Merr.
 * Uncaria donisii E.M.A.Petit
 * Uncaria elliptica R.Br. ex G.Don
 * Uncaria gambir (W.Hunter) Roxb.
 * Uncaria guianensis (Aubl.) J.F.Gmel.
 * Uncaria hirsuta Havil.
 * Uncaria homomalla Miq.
 * Uncaria kunstleri King
 * Uncaria laevigata Wall. ex G.Don
 * Uncaria lancifolia Hutch.
 * Uncaria lanosa Wall.
 * Uncaria longiflora (Poir.) Merr.
 * Uncaria macrophylla Wall.
 * Uncaria nervosa Elmer
 * Uncaria orientalis Guillaumin
 * Uncaria ovata R.Br. ex Hook.f.
 * Uncaria perrottetii (A.Rich.) Merr.
 * Uncaria rhynchophylla (Miq.) Miq.
 * Uncaria rhynchophylloides F.C.How
 * Uncaria roxburghiana Korth.
 * Uncaria scandens (Sm.) Wall.
 * Uncaria schlenckerae S.Moore
 * Uncaria sessilifructus Roxb.
 * Uncaria sinensis (Oliv.) Havil.
 * Uncaria sterrophylla Merr. & L.M.Perry
 * Uncaria talbotii Wernham
 * Uncaria tomentosa (Willd. ex Schult.) DC.
 * Uncaria velutina Havil.

Uses
Diplomat Edmund Roberts noted that, upon his visit to China in the 1830s, Chinese were using U. gambir for tanning, and noted that the U. gambir made "leather porous and rotten." He also noted that Chinese would chew it with areca nut. The plant extract contains some 150 identified phytochemicals, including catechins, proanthocyanins, and chalcone-flavan-3-ol dimers, called gambiriins. Cat's claw (U. tomentosa) and the Chinese Uncaria species are used in traditional medicine, although there is no high-quality clinical evidence they have any medicinal properties.

Adverse effects
Although cat's claw appears to be safe for human use below 350 milligrams per day over 6 weeks, its adverse effects may include nausea, diarrhea, upset stomach, and an increased risk of bleeding if used with an anticoagulant drug.

title: Uncaria


text:
Cubomania

Cubomania is a Surrealist technique of making collages by cutting an image into squares and reassembling without regard for the original image at random to create something new.

The technique was invented by the Romanian surrealist Gherasim Luca. Luca introduced cubomania at two exhibitions in Bucharest, in 1945 and 1946, and in small publications. Luca positioned cubomania as a mix of Karl Marx's and André Breton's ideas. It was a critique of the alleged objectivity of social conditions and rejected the tyranny over liberty.

It has been described as a "statistical method".

Penelope Rosemont and Joseph Jablonski have suggested that cubomania can "subvert the enslaving 'message' of advertising and to free images from repressive contexts."

title: Cubomania


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Vanilla Sky

Vanilla Sky is a 2001 American science fiction psychological thriller film directed, written, and co-produced by Cameron Crowe. It is an English-language remake of Alejandro Amenábar's 1997 Spanish film Open Your Eyes, which was written by Amenábar and Mateo Gil. The film stars Tom Cruise, Penélope Cruz, Cameron Diaz, Jason Lee, and Kurt Russell. It follows a magazine publisher who begins to question reality after being disfigured in a car crash.

Vanilla Sky grossed over $203 million against a production budget of $68 million and received mixed reception from critics. Diaz's performance was widely praised, earning her a Screen Actors Guild and a Golden Globe Award nomination. The song "Vanilla Sky" by Paul McCartney was nominated for an Academy Award for Best Original Song. The film later gained a cult following.

Plot
David Aames, the owner of a large publishing company he inherited from his father, is in prison. Wearing a prosthetic mask, David tells his life story to court psychologist Dr. Curtis McCabe. In flashbacks, David leaves the duties of the publisher to his father's trusted associates while living as a playboy in Manhattan. He is introduced to Sofia Serrano by his best friend, Brian Shelby, during a party.

David and Sofia spend the night together at Sofia's apartment and fall in love, unaware that David's current lover, Julie Gianni, has followed them there. As David leaves, Julie offers him a ride and soon reveals her jealousy of Sofia. She purposely crashes the car, killing herself and disfiguring David. Doctors cannot repair his face using plastic surgery, forcing David to wear a prosthetic mask, and the mental and physical scarring from the accident causes him to become withdrawn and depressed. David joins Brian and Sofia at a club, but they all leave after David starts an argument while drunk. After David insults them and they part ways, David passes out on the street outside the club.

The next day, Sofia returns and apologizes to David. She takes him home, the two form a relationship and he slowly begins to recover. After surgeons find a way to repair David's face despite their prior prognosis, he is plagued by bizarre experiences, such as brief flashbacks of his disfigurement and an encounter with a mysterious man at a bar who informs him that David is omnipotent, demonstrated by the entire bar falling silent at David's command. One day, while at Sofia's, David awakens to find himself in bed with Julie, whose face has replaced Sofia's in their photographs. In shock, he suffocates Julie. David is arrested and imprisoned and his facial disfigurement is mysteriously restored.

McCabe conducts several more interviews, which serve to help David to recall the name "Life Extension". Seeing a company with that name nearby, McCabe arranges to take David there under guard. Rebecca Dearborn, a company representative, explains how Life Extension uses cryonic suspension to save those with terminal illnesses until a cure can be found, keeping them in a lucid dream state to otherwise exercise their mind. David realizes that he is in cryonic suspension and that the world he inhabits is his lucid dream, which has become a nightmare. He escapes McCabe and the guards while calling for "tech support", and rushes for the building's lobby, which is suddenly empty. An elevator opens, revealing the strange man from the bar. As the elevator climbs to the top of an impossibly tall building, the man explains that he is Tech Support and that David has been in suspension for 150 years.

Unable to face the twin traumas of the loss of his love, Sofia, and his facial injuries, he had opted for Life Extension, to be awakened when technology could repair his face, and left the publishing company in the hands of his father's associates, ultimately overdosing on medication and causing Brian to arrange a three-day memorial for him in his home. As part of the program, David had chosen to experience a lucid dream, in which his life would resume the morning after Sofia left him, however, a glitch in the software had caused other elements of his subconscious to distort his dream.

David and Tech Support emerge on the rooftop, high above the clouds. There, Tech Support tells David that while they have corrected the flaw, he now has a choice of either being returned to the dream or being restored to life, requiring a literal leap of faith off the roof that will wake him from his sleep. David chooses the latter, despite McCabe warning him against it. Before jumping, David envisions Brian and Sofia to say his goodbyes. He leaps from the edge of the building, and his life flashes before him. David snaps awake as a female voice invites him to open his eyes.

Development
After the American debut of Alejandro Amenábar's 1997 Spanish film Abre los ojos (Open Your Eyes) at the 1998 Sundance Film Festival, Tom Cruise and his producing partner Paula Wagner optioned the remake rights. Hoping to entice director Cameron Crowe, who collaborated with Cruise on Jerry Maguire, Cruise invited Crowe over to his house to view the film. Cruise has stated:

"I've been offered a lot of films to buy and remake, and I never have because I felt it was too connected with the culture of that place, whatever country it was from. But this was a universal story that was still open-ended, that still felt like it needed another chapter to be told."

The title of the film is a reference to depictions of skies in certain paintings by Claude Monet. In addition to Monet's impressionistic artwork, the film's tone was derived from the acoustic ballad "By Way of Sorrow" by Julie Miller and a line from an early interview of Elvis Presley in which he said, "I feel lonely, even in a crowded room."

Filming
Principal photography for Vanilla Sky began in late 2000 and lasted six weeks. On November 12, 2000, shooting for the scene of the deserted Times Square in New York took place in the early hours of the day. A large section of traffic was blocked off around Times Square while the scene was shot. "There was a limit on how long the city would let us lock everything up even on an early Sunday morning when much of NYC would be slow getting up," said Steadicam operator Larry McConkey. "Several times we rehearsed with Steadicam and Crane including a mockup of an unmovable guardrail that we had to work the crane arm around. [Cruise] participated in these rehearsals as well so we shared a clear understanding of what my limitations and requirements would be."

Filming lasted for six weeks around the New York City area, which included scenes in Central Park, the Upper West Side, SoHo, and Brooklyn. One prominent location in the area was the Condé Nast Building that served as Aames Publishing and David's office. After filming finished in New York, production moved to Los Angeles, where the remaining interior shots were completed at Paramount Studios. Crowe intentionally left in shots of the World Trade Center after the September 11 attacks as a tribute.

Despite the film's distorted aspects of reality, the style of cinematography remains grounded for much of the film. "I didn't do anything that was overtly obvious, because the story revolves around the main character not knowing whether he's in a state of reality, a dream or a nightmare, so we want it to feel a little ambiguous," said cinematographer John Toll. "We want the audience to make discoveries as [Cruise]'s character does, rather than ahead of him." American Cinematographer magazine wrote a feature story on the lighting designer Lee Rose's work on the film.

Alternate ending
The 2015 Blu-ray release offers the option to watch the film with an alternative ending. This ending expands on the details at the end of the film. While it all leads to the same conclusion, there are additional scenes, alternative takes, and alternative dialogue.

After Rebecca describes the lucid dream, David rushes out of the room but does not immediately dash towards the elevator. He meets McCabe in the restroom who tries to convince him that this is all a hoax and a con and that his case is going to trial. David tells him that he's only in his imagination. Much like in the theatrical cut, the Beach Boys' "Good Vibrations" plays, but this version makes it clear that David hears the music and that he chose it; meanwhile, McCabe tries to convince him there is no music.

At this point, David dashes out of the restroom for the elevator the way he does in the theatrical cut, but the scene in the lobby is expanded: David shoots the police officer who is firing at him and is then surrounded by a SWAT team whom McCabe tries to talk down, but the SWAT team fires at both of them. They black out and wake up in the emptied lobby where McCabe continues to applaud what he believes is a performance while David gets into the elevator with Ventura, who tells him what happened at the end of his real life.

Once they reach the roof, McCabe reenters again and his pleas to David not to believe Ventura become more and more desperate until he collapses onto the ground in despair. David's interaction with Sofia is extended as he tells her he loves her but "can't settle for a dream". He then jumps off the building, screaming "I want to wake up!" as images from his life flash before his eyes. He wakes up in bed and a voice tells him "Open your eyes. You're going to be fine."

Music
Vanilla Sky 's score was by Crowe's then wife, Nancy Wilson, who also scored Jerry Maguire and Almost Famous. Wilson spent nine months on the film's music, which was done through experimentation of sound collages. "We were trying to balance out the heaviness of the story with sugary pop-culture music," she said. "We made sound collages of all kinds. We were channeling Brian Wilson to a large extent. I was recording things through hoses, around corners, playing guitars with cello bows, and with [music editor] Carl Kaller, we tried all kinds of wacky stuff. In the murder–sex scene sound collage, Cameron even used Brian Wilson's speaking voice from a Pet Sounds mix session."

The eponymous song from the soundtrack, written and recorded by Paul McCartney, was nominated for an Academy Award for Best Original Song. Additional songs featured included Radiohead's song "Everything in Its Right Place", and "Svefn-g-englar" by the Icelandic group Sigur Rós.

Interpretations
According to Cameron Crowe's commentary, there are five different interpretations of the ending:
 * 1) "Tech support" is telling the truth: 150 years have passed since Aames killed himself and subsequent events form a lucid dream.
 * 2) The entire film is a dream, evidenced by a sticker on Aames's car that reads "2/30/01" (February 30 does not occur in the Gregorian calendar).
 * 3) The events after the crash are a dream Aames has while comatose.
 * 4) The entire film is the plot of the book that Brian is writing.
 * 5) The entire film after the crash is a hallucination caused by drugs administered during Aames's reconstructive surgery.

Crowe notes that the presence of a "Vanilla Sky" during the morning reunion after the nightclub scene marks the first lucid dream scene and that everything that follows is a dream.

Box office
Vanilla Sky opened at number one at the box office in the United States when it was first presented on December 14, 2001. The opening weekend took in a gross income of $25,015,518 (24.9%). The final domestic gross income was $100.61 million while the international gross income was slightly higher at $102.76 million for a total worldwide gross income of $203.39 million.

Critical response
On Rotten Tomatoes, 43% of 174 critic reviews are positive and the average rating is 5.3/10. The site's consensus states: "An ambitious mix of genres, Vanilla Sky collapses into an incoherent jumble. Cruise's performance lacks depth, and it's hard to feel sympathy for his narcissistic character." On Metacritic, the film has a weighted average score of 45 out of 100 based on 33 reviews, indicating "mixed or average reviews". Audiences polled by CinemaScore gave the film a grade "D−" on a scale from A to F.

Roger Ebert's printed review of Vanilla Sky awarded the film three out of four stars:

Think it all the way through, and Cameron Crowe's Vanilla Sky is a scrupulously moral picture. It tells the story of a man who has just about everything, thinks he can have it all, is given a means to have whatever he wants, and loses it because—well, maybe because he has a conscience. Or maybe not. Maybe just because life sucks. Or maybe he only thinks it does. This is the kind of movie you don't want to analyze until you've seen it two times.

Ebert interpreted the ending as an explanation for "the mechanism of our confusion", rather than a device that tells "us for sure what actually happened." Film critic Richard Roeper ranked the film the second best of 2001.

Stephen Holden of The New York Times calls Vanilla Sky a "highly entertaining, erotic science-fiction thriller that takes Mr. Crowe into Steven Spielberg territory", but then says: "As it leaves behind the real world and begins exploring life as a waking dream (this year's most popular theme in Hollywood movies with lofty ideas), Vanilla Sky loosens its emotional grip and becomes a disorganised and abstract if still-intriguing meditation on parallel themes. One is the quest for eternal life and eternal youth; another is guilt and the ungovernable power of the unconscious mind to undermine science's utopian discoveries. David's redemption ultimately consists of his coming to grips with his own mortality, but that redemption lacks conviction."

Salon.com called Vanilla Sky an "aggressively plotted puzzle picture, which clutches many allegedly deep themes to its heaving bosom without uncovering even an onion-skin layer of insight into any of them." The review rhetorically asks: "Who would have thought that Cameron Crowe had a movie as bad as Vanilla Sky in him? It's a punishing picture, a betrayal of everything that Crowe has proved he knows how to do right. ... But the disheartening truth is that we can see Crowe taking all the right steps, the most Crowe-like steps, as he mounts a spectacle that overshoots boldness and ambition and idiosyncrasy and heads right for arrogance and pretension—and those last two are traits I never would have thought we'd have to ascribe to Crowe." Edward Guthmann of the San Francisco Chronicle gave the film 2/4 and wrote: "The film's aim—to dazzle and inspire—is sapped by Cruise's vein-popping, running-the-marathon performance."

Peter Bradshaw of The Guardian and Gareth Von Kallenbach of the publication Film Threat compared Vanilla Sky unfavorably to Open Your Eyes. Bradshaw says Open Your Eyes is "certainly more distinctive than" Vanilla Sky, which he describes as an "extraordinarily narcissistic high-concept vanity project for producer-star Tom Cruise." Other reviewers extrapolate from the knowledge that Cruise had bought the rights to do a version of Amenábar's film. A Village Voice reviewer characterized Vanilla Sky as "hauntingly frank about being a manifestation of its star's cosmic narcissism".

Kenneth Turan of the Los Angeles Times called Cameron Diaz "compelling as the embodiment of crazed sensuality" and The New York Times reviewer said she gives a "ferociously emotional" performance. Edward Guthmann of the San Francisco Chronicle similarly says of the film, "most impressive is Cameron Diaz, whose fatal-attraction stalker is both heartbreaking and terrifying." For her performance, Diaz won multiple critics' groups awards, as well as being nominated for the Golden Globe Award, Screen Actors Guild Award, Critics' Choice Movie Award, Saturn Award, and AFI Award. Penélope Cruz's performance earned her a Razzie Award nomination for Worst Actress (in addition to her roles in Blow and Captain Corelli's Mandolin).

Home media
Vanilla Sky was released on DVD and VHS on May 21, 2002, Blu-ray in 2015, and Ultra HD Blu-ray in 2023.

title: Vanilla Sky