text:
NAACP v. Alabama

National Association for the Advancement of Colored People v. Alabama, 357 U.S. 449 (1958), was a landmark decision of the US Supreme Court. Alabama sought to prevent the NAACP from conducting further business in the state. After the circuit court issued a restraining order, the state issued a subpoena for various records, including the NAACP's membership lists. The Supreme Court ruled that Alabama's demand for the lists had violated the right of due process guaranteed by the Fourteenth Amendment to the United States Constitution.

Facts
In 1956, the Attorney General of Alabama, John Patterson, brought a suit to the State Circuit Court of Montgomery, Alabama, challenging the National Association for the Advancement of Colored People (NAACP) for violation of a state statute requiring foreign corporations to qualify before doing business in the state. The NAACP, a nonprofit membership corporation based in New York, had not complied with the statute, as it believed it was exempt. The state suit sought both to prevent the Association from conducting further business within the state and, indeed, to remove it from the state.

Referring to the Association's involvement with the Montgomery bus boycott in 1955 and its role in funding and providing legal assistance to black students' seeking admission to the state university, the suit charged that the Association was "...causing irreparable injury to the property and civil rights of the residents and citizens of the State of Alabama for which criminal prosecution and civil actions at law afford no adequate relief...." On the day this suit was filed, the circuit court agreed to issue an ex parte order restraining the Association from conducting business in the state or taking steps to qualify it to do so.

The Association, represented throughout by Robert L. Carter of the NAACP Legal Defense Fund, responded by moving to dissolve the order on the grounds that its activities within the state did not require its qualification under the statute and that the state's suit was intended to violate its rights to freedom of speech and of assembly as guaranteed by the Constitution of the United States. Before a hearing date was set, the state issued a subpoena for much of the Association's records, including bank statements and leases, but most notably the names and addresses of the "agents" or "members" of the Association in Alabama.

In its response to the lawsuit, the Association admitted that it was in breach of the statute and offered to obtain qualification to continue business if that part of the ex parte order was lifted. Because the Association did not comply with the order to produce its records, that motion was denied and the Association was held in contempt and fined $10,000. The contempt order allowed for the reduction or remission of the fine if the production order was complied with within five days, after which the fine would be raised to $100,000.

Contending that the State could not constitutionally force disclosure of the records, the Association moved to dismiss the contempt judgment once more. According to Alabama case law, however, a petitioner could not seek a hearing or to dissolve an order until it purged itself of contempt.

The United States Supreme Court reversed the first contempt judgment. The Alabama Supreme Court then claimed the U.S. Supreme Court had relied on a "mistaken premise" and reinstated the contempt judgment, which the U.S. Supreme Court reversed again. The NAACP moved to try the case on the merits; this motion was denied and again appealed up to the U.S. Supreme Court, which remanded the case to Alabama, and ordered the Federal district court to try the case on the merits if the Alabama court system continued to refuse to do so.

The Alabama state circuit court finally heard the case on the merits, and decided the NAACP had violated Alabama law and ordered it to stop doing business in the state; the Alabama appeals courts upheld this judgment, refusing to hear the NAACP's appeals on Constitutional grounds. Finally, the fourth time the case was heard by the U.S. Supreme Court, it granted certiorari and decided the case, itself, on the merits rather than remand the case to the balking Alabama court system, which had taken five years to get this far.

Judgment
In an opinion delivered by Justice John Marshall Harlan II, the Supreme Court decided in favor of the petitioners, holding that "Immunity from state scrutiny of petitioner's membership lists is here so related to the right of petitioner's members to pursue their lawful private interests privately and to associate freely with others in doing so as to come within the protection of the Fourteenth Amendment" and, further, that freedom to associate with organizations dedicated to the "advancement of beliefs and ideas" is an inseparable part of the Due Process Clause of the Fourteenth Amendment. The action of the state's obtaining the names of the Association's membership would likely interfere with the free association of its members, so the state's interest in obtaining the records was superseded by the constitutional rights of the petitioners. Harlan said the following.

"It is hardly a novel perception that compelled disclosure of affiliation with groups engaged in advocacy may constitute as effective a restraint on freedom of association as the forms of governmental action in the cases above were thought likely to produce upon the particular constitutional rights there involved. This Court has recognized the vital relationship between freedom to associate and privacy in one's associations. When referring to the varied forms of governmental action which might interfere with freedom of assembly, it said in American Communications Ass'n v. Douds, supra, 339 U.S. at page 402, 70 S.Ct. at page 686: 'A requirement that adherents of particular religious faiths or political parties wear identifying arm-bands, for example, is obviously of this nature.' Compelled disclosure of membership in an organization engaged in advocacy of particular beliefs is of the same order. Inviolability of privacy in group association may in many circumstances be indispensable to preservation of freedom of association, particularly where a group espouses dissident beliefs. Cf. United States v. Rumely, supra, 345 U.S. at pages 56 58, 73 S.Ct. at pages 550–551 (concurring opinion).

We think that the production order, in the respects here drawn in question, must be regarded as entailing the likelihood of a substantial restraint upon the exercise by petitioner's members of their right to freedom of association. Petitioner has made an uncontroverted showing that on past occasions revelation of the identity of its rank-and-file members has exposed these members to economic reprisal, loss of employment, threat of physical coercion, and other manifestations of public hostility. Under these circumstances, we think it apparent that compelled disclosure of petitioner's Alabama membership is likely to affect adversely the ability of petitioner and its members to pursue their collective effort to foster beliefs which they admittedly have the right to advocate, in that it may induce members to withdraw from the Association and dissuade others from joining it because of fear of exposure of their beliefs shown through their associations and of the consequences of this exposure.

It is not sufficient to answer, as the State does here, that whatever repressive effect compulsory disclosure of names of petitioner's members may have upon participation by Alabama citizens in petitioner's activities follows not from state action but from private community pressures. The crucial factor is the interplay of governmental and private action, for it is only after the initial exertion of state power represented by the production order that private action takes hold.

...

Whether there was 'justification' in this instance turns solely on the substantiality of Alabama's interest in obtaining the membership lists. During the course of a hearing before the Alabama Circuit Court on a motion of petitioner to set aside the production order, the State Attorney General presented at length, under examination by petitioner, the State's reason for requesting the membership lists. The exclusive purpose was to determine whether petitioner was conducting intrastate business in violation of the Alabama foreign corporation registration statute, and the membership lists were expected to help resolve this question. The issues in the litigation commenced by Alabama by its bill in equity were whether the character of petitioner and its activities in Alabama had been such as to make petitioner subject to the registration statute, and whether the extent of petitioner's activities without qualifying suggested its permanent ouster from the State. Without intimating the slightest view upon the merits of these issues, we are unable to perceive that the disclosure of the names of petitioner's rank-and-file members has a substantial bearing on either of them. As matters stand in the state court, petitioner (1) has admitted its presence and conduct of activities in Alabama since 1918; (2) has offered to comply in all respects with the state qualification statute, although preserving its contention that the statute does not apply to it; and (3) has apparently complied satisfactorily with the production order, except for the membership lists, by furnishing the Attorney General with varied business records, its charter and statement of purposes, the names of all of its directors and officers, and with the total number of its Alabama members and the amount of their dues. These last items would not on this record appear subject to constitutional challenge and have been furnished, but whatever interest the State may have in obtaining names of ordinary members has not been shown to be sufficient to overcome petitioner's constitutional objections to the production order.

From what has already been said, we think it apparent that People of State of New York ex rel. Bryant v. Zimmerman, 278 U.S. 63, 49 S.Ct. 61, 73 L.Ed. 184, cannot be relied on in support of the State's position, for that case involved markedly different considerations in terms of the interest of the State in obtaining disclosure. There, this Court upheld as applied to a member of a local chapter of the Ku Klux Klan, a New York statute requiring any unincorporated association which demanded an oath as a condition to membership to file with state officials copies of its '* * * constitution, by-laws, rules, regulations and oath of membership, together with a roster of its membership and a list of its officers for the current year.' N.Y. Laws 1923, c. 664, §§ 53, 56. In its opinion, the Court took care to emphasize the nature of the organization which New York sought to regulate. The decision was based on the particular character of the Klan's activities, involving acts of unlawful intimidation and violence, which the Court assumed was before the state legislature when it enacted the statute, and of which the Court itself took judicial notice. Furthermore, the situation before us is significantly different from that in Bryant, because the organization there had made no effort to comply with any of the requirements of New York's statute but rather had refused to furnish the State with any information as to its local activities.

We hold that the immunity from state scrutiny of membership lists which the Association claims on behalf of its members is here so related to the right of the members to pursue their lawful private interests privately and to associate freely with others in so doing as to come within the protection of the Fourteenth Amendment. And we conclude that Alabama has fallen short of showing a controlling justification for the deterrent effect on the free enjoyment of the right to associate which disclosure of membership lists is likely to have. Accordingly, the judgment of civil contempt and the $100,000 fine which resulted from petitioner's refusal to comply with the production order in this respect must fall."

title: NAACP v. Alabama


text:
Hans Krebs (biochemist)

Sir Hans Adolf Krebs, FRS (, ; 25 August 1900 – 22 November 1981)  was a German-British biologist, physician and biochemist. He was a pioneer scientist in the study of cellular respiration, a biochemical process in living cells that extracts energy from food and oxygen and makes it available to drive the processes of life. He is best known for his discoveries of two important sequences of chemical reactions that take place in the cells of nearly all organisms, including humans, other than anaerobic microorganisms, namely the citric acid cycle and the urea cycle. The former, often eponymously known as the "Krebs cycle", is the sequence of metabolic reactions that allows cells of oxygen-respiring organisms to obtain far more ATP from the food they consume than anaerobic processes such as glycolysis can supply; and its discovery earned Krebs a Nobel Prize in Physiology or Medicine in 1953. With Hans Kornberg, he also discovered the glyoxylate cycle, a slight variation of the citric acid cycle found in plants, bacteria, protists, and fungi.

Krebs died in 1981 in Oxford, where he had spent 13 years of his career from 1954 until his retirement in 1967 at the University of Oxford.

Early life and education
Krebs was born in Hildesheim, Germany, to Georg Krebs, an ear, nose, and throat surgeon, and Alma Krebs (née Davidson). He was of Jewish-Silesian ancestry and was the middle of three children. He had an older sister, Elisabeth, and a younger brother, Wolfgang.

Krebs attended school at the Gymnasium Andreanum in his home town. Near the end of World War I, in September 1918, six months short of completing his secondary school education, he was conscripted into the Imperial German Army. He was allowed to take an emergency examination for his high school diploma, which he passed with such a high score that he suspected the examiners of being "unduly lenient and sympathetic". With the end of the war two months later, his conscription ended.

Krebs decided to follow his father's profession and entered the University of Göttingen in December 1918 to study medicine. In 1919, he transferred to the University of Freiburg. In 1923, he published his first scientific paper on a tissue staining technique. He did this work under the guidance of Wilhelm von Mollendorf starting it in 1920. He completed his medical course in December 1923. To obtain a Doctor of Medicine degree, and a medical license, he spent one year at the Third Medical Clinic in the University of Berlin. By then he had turned his professional goal from becoming a practising physician to becoming a medical researcher, particularly in biochemistry. In 1924, he studied at the Department of Chemistry at the Pathological Institute of the Charité Hospital, in Berlin, for training in chemistry and biochemistry. He earned his MD degree in 1925 from the University of Hamburg.

Career
In 1926, Krebs joined Otto Heinrich Warburg as a research assistant at the Kaiser Wilhelm Institute for Biology in Dahlem, Berlin. He was paid 4800 marks per year. After four years in 1930, with 16 publications to his credit, his mentor Warburg urged him to move on and he took up the position of Assistant in the Department of Medicine at the Municipal Hospital in Altona (now part of Hamburg). The next year he moved to the Medical Clinic of the University of Freiburg. At Freiburg, he was in charge of about 40 patients, and was at liberty to do his own research. Before a year was over at Freiburg, he, with research student Kurt Henseleit, published their discovery of the ornithine cycle of urea synthesis, which is the metabolic pathway for urea formation. It is now known as the urea cycle, and is sometimes also referred to as the Krebs–Henseleit cycle. Together they also developed a complex aqueous solution (a buffer), or perfusion ex vivo, for studying blood flow in arteries, which is now called the Krebs–Henseleit buffer.) In 1932, he published the basic chemical reactions of the urea cycle, which established his scientific reputation.

Krebs's life as a respected German scientist came to an abrupt halt in 1933 because of his Jewish ancestry. With the rise of Hitler's Nazi Party to power, Germany decreed the Law for the Restoration of the Professional Civil Service, which decreed the removal of all non-Germans, and anti-Nazis, from professional occupations. Krebs received his official dismissal from his job in April 1933, and his service was terminated on 1 July 1933. An admirer, Sir Frederick Gowland Hopkins at the University of Cambridge, immediately came to his rescue, and persuaded the university to recruit Krebs to work with him in the Department of Biochemistry. By July 1933, he was settled in Cambridge with financial support from the Rockefeller Foundation.

Although Germany restricted him to bringing only his personal belongings, he was fortunate that the government agents allowed him to take his equipment and research samples to England. They proved to be pivotal to his later discoveries, especially the manometer developed by Warburg specifically for the measurement of oxygen consumption in thin slices of tissues; it was the basis for his research.

He was appointed as Demonstrator in biochemistry in 1934, and in 1935 the University of Sheffield offered him a post of Lecturer in Pharmacology, with a more spacious laboratory and double the salary. He worked there for 19 years. The University of Sheffield opened a Department of Biochemistry, now Department of Molecular Biology and Biotechnology, in 1938 and Krebs became its first Head, and eventually a Professor in 1945. During his time it became one of the leading departments of biochemistry in the world. Krebs took over the running of the Sorby Research Institute in 1943. In 1944, the British Medical Research Council established the MRC Unit for Cell Metabolism Research at Sheffield, and Krebs was appointed the Director. With this, his laboratory became so large that the locals jokingly nicknamed it "Krebs's Empire".

He moved with his MRC unit to the University of Oxford in 1954 as Whitley Professor of Biochemistry, the post he held until his retirement in 1967. The editorial board of Biochemical Journal extended their good wishes on his retirement, but in return he promised to keep them busy, by producing scientific papers. He continued his research, and took his MRC unit to the Nuffield Department of Clinical Medicine at the Radcliffe Infirmary, Oxford. From there he published over 100 research papers.

Personal life
Krebs met Margaret Cicely Fieldhouse (30 October 1913 – May 1993) when he moved to Sheffield in 1935. They married on 22 March 1938. Krebs later described his life in Sheffield as "19 happy years". They had two sons, Paul (born 1939) and John (born 1945), and a daughter, Helen (born 1942). John (Sir John Krebs, and later Baron Krebs) became a renowned ornithologist, Professor at the University of Oxford, Principal of Jesus College, Oxford, and Member of the British House of Lords.

Death
After a brief illness, Krebs died on 22 November 1981 in Oxford, aged 81.

Urea cycle (Krebs–Henseleit cycle)
In 1932, Krebs worked out the outlines of the urea cycle with a medical student Kurt Henseleit at the University of Freiburg. While working at the Medical Clinic of the University of Freiburg, Krebs met Kurt Henseleit, with whom he investigated the chemical process of urea formation. In 1904, two Germans, A. Kossel and H. D. Dakin, had shown that arginine could be hydrolysed by the enzyme arginase to form ornithine and urea in inorganic reaction. Based on this reaction, Krebs and Henseleit postulated that in living cells, similar reaction could occur, and that ornithine and citrulline could be the intermediate reactions. Krebs started working on the possible method for the synthesis of arginine. Using his Warburg manometer, he mixed a slice of liver with purified ornithine and citrulline. He found that citrulline acted as a catalyst in the metabolic reactions of urea from ammonia and carbon dioxide. He and Henseleit published their discovery in 1932. Thus the urea cycle (or "ornithine cycle") was established, and it was the first metabolic cycle to be discovered.

Citric acid cycle (Krebs cycle)
At the University of Sheffield, Krebs and William Arthur Johnson investigated cellular respiration by which oxygen was consumed to produce energy from the breakdown of glucose. Krebs had earlier suggested to Warburg while they worked together in Germany that by using a manometer it could be possible to detect the oxygen consumption and identify the chemical reaction in glucose metabolism. Warburg had flatly rejected the idea. In Sheffield, Krebs vigorously worked to identify a possible chemical reaction and came up with numerous hypothetical pathways. Using the manometer he tested those hypotheses one by one. One hypothesis involving succinate, fumarate, and malate proved to be useful because all these molecules increased oxygen consumption in the pigeon breast muscle. In 1937, German biochemists Franz Knoop and Carl Martinus had demonstrated a series of reactions using citrate that produced oxaloacetate. Krebs realised that these molecules could be the missing intermediates for such reaction. After four months of experimental works to fill in the gaps, Krebs and Johnson succeeded in establishing the sequence of the chemical cycle, which they called the "citric acid cycle". It is also known as the "Krebs cycle" or "tricarboxylic acid (TCA) cycle".

Krebs sent a short manuscript account of the discovery to Nature on 10 June 1937. On 14 June, he received a rejection letter from the editor, saying that the journal had "already sufficient letters to fill correspondence columns for seven or eight weeks", and encouraging Krebs to "submit it for early publication to another periodical."

Krebs immediately prepared a longer version titled "The Role of Citric Acid in Intermediate Metabolism in Animal Tissues", which he sent to the Dutch journal Enzymologia after two weeks and was published in two months. It was followed by a series of papers in different journals.

Glyoxylate cycle
Krebs continued to add more details to his citric acid cycle. The discovery of acetyl-CoA in 1947 by Fritz Albert Lipmann was another major contribution. However, this new discovery posed a problem in his classic reaction. In 1957, he, with Hans Kornberg, found that there were additional crucial enzymes. One was malate synthase, which condenses acetate with glyoxylate to form malate, and the other was isocitrate lyase, which provides glyoxylate for the reaction by cleaving it from isocitrate. These two reactions did not follow the normal citric acid cycle, and hence the pathway was named the glyoxylate bypass of the citric acid cycle, but is now known as the glyoxylate cycle.

Honours and awards
Krebs became a naturalised British citizen in 1939. He was elected Fellow of Trinity College, Oxford, 1954–1967. He was elected to the Royal Society in 1947. In 1953, he received the Nobel Prize in Physiology or Medicine for his "discovery of the citric acid cycle." (He shared the Nobel Prize with Fritz Lipmann.) For the same reason he was given the Albert Lasker Award for Basic Medical Research in 1953.

The Royal Society awarded him its Royal Medal in 1954, and Copley Medal in 1961. He was elected to the American Academy of Arts and Sciences in 1957.

In 1958, he received the Gold Medal of the Netherlands Society for Physics, Medical Science and Surgery. He was knighted in 1958 and was elected Honorary Fellow of Girton College, Cambridge University, in 1979. He was the Original Member of the Society for General Microbiology, which conferred him Honorary Membership in 1980. He was also an elected member of both the American Philosophical Society and the United States National Academy of Sciences. He received an honorary doctorate from 21 universities.

In July 2015, Krebs's Nobel Prize medal was auctioned off for £225,000 (around $351,225). The proceeds were used to found the Sir Hans Krebs Trust, which provides funding for doctoral students in the biomedical field and support chemists who had to flee their home countries.

Legacy
The University of Oxford had a building named Hans Krebs Tower, which was occupied by the Department of Biochemistry. In 2008, a new building for the Department of Biochemistry was constructed, on which a plaque was placed on 20 May 2013 by the Association of Jewish Refugees. The plaque was unveiled by John, Lord Krebs, and the inscription reads:

"Professor Sir Hans Krebs FRS 1900 – 1981 Biochemist & discoverer of the Krebs cycle Nobel Prize Winner 1953 worked here 1954 – 1967"

The Department of Physiology, Anatomy and Genetics at Oxford University hosts the Sir Hans Krebs Prize Lecture Series. The last three recipients have been: Jeffrey Friedman M.D., PhD (2019) Professor Sir Stephen O'Rahilly MD FRS FMedSci (2022) and in 2023 - Professor Dame Frances Ashcroft FRS FMedSci

The University of Sheffield has The Krebs Institute, founded in 1988. It is a research centre covering interdisciplinary programmes in biochemical research.

In 1990, the Federation of European Biochemical Societies instituted the Sir Hans Krebs Lecture and Medal, which was endowed by the Lord Rank Centre for Research. It is awarded for outstanding achievements in biochemistry and molecular biology.

The Society of Friends of Hannover Medical School gives the Sir Hans Krebs Prize, which is worth 10,000 euros.

The Biochemical Society offers Krebs Memorial Scholarship to a postgraduate (PhD) student working in biochemistry or an allied biomedical science at any British university. As of 2014, the scholarship is worth £18,500 and is given for a year, but is extendable up to three years.

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

title: Hans Krebs (biochemist)


text:
Fourteenth Amendment

The Fourteenth Amendment may refer to:

 * Fourteenth Amendment to the United States Constitution, which grants citizenship to everyone born in the U.S. and subject to its jurisdiction and protects civil and political liberties
 * Fourteenth Amendment of the Constitution of India, established the union territory of Puducherry (Pondicherry)
 * Fourteenth Amendment of the Constitution of Ireland, which guarantees free access to information on abortion in other countries
 * Fourteenth Amendment to the Constitution of Pakistan, which gave party leaders the power to dismiss dissenting members of parliament
 * Fourteenth Amendment of the Constitution of South Africa, which repealed some of the provisions allowing for floor-crossing, that had been added by the Ninth and Tenth Amendments

title: Fourteenth Amendment


text:
Talk:Klaatu (band)

Movie Character
Klaatu the movie character was based on the character of the same name in the Harry Bates story Farwell to the Master. I am in favor of having separate Klaatu (character) and Klaatu (band) pages, as the character Klaatu is significant enough to have his own page (especially in light of the popularity of the Gort the robot and the movie The Day the Earth Stood Still). I can write the Klaatu character page, but I don't know how to rename a node.

Nuffle 08:26, 12 Apr 2004 (UTC)

Band named after character
Klaatu the band was named after the character in the movie. Should the article on the band be moved to a new article called "Klaatu (band)"? soulpatch

First Album name
There is a potential controversy over the name of the first album. The band's website titles it "3:47 EST", while some Capitol releases call it "Klaatu". I generally would favor the band's decision in these cases.

Brian Rock 00:57, 24 Jan 2004 (UTC)
 * The name of the first album (3:47 EST) was selected by the band. Record executives south of the border assumed the American record buying public would find that title too difficult to comprehend, so they insisted on making the band's first album eponymous. Blame the guys at Capitol Records for the confusion.

Goodnight Vienna
Goodnight Vienna was released in 1974 according to the AMG, and so it could not possibly be a reference to the band Klaatu. Kouban 23:54, 13 April 2006 (UTC)
 * I believe the article is suggesting that some people believed the band name was referencing the album, thus creating a spurious Beatles link (when in fact they were time travellers referencing the later "News of the World" album by Queen! j/k.)LessHeard vanU 22:24, 16 April 2006 (UTC)
 * Ringo Starr was not trying to reference Klaatu, he'd never heard of them. After the release of 3:47 EST, there was a rumor going around that Klaatu was really the Beatles, and that Ringo's album had foreshadowed it.

Fair use rationale for Image:KlaatuSamuelsPromo.jpg
Image:KlaatuSamuelsPromo.jpg is being used on this article. I notice the image page specifies that the image is being used under fair use but there is no explanation or rationale as to why its use in this Wikipedia article constitutes fair use. In addition to the boilerplate fair use template, you must also write out on the image description page a specific explanation or rationale for why using this image in each article is consistent with fair use.

Please go to the image description page and edit it to include a fair use rationale. Using one of the templates at Fair use rationale guideline is an easy way to insure that your image is in compliance with Wikipedia policy, but remember that you must complete the template. Do not simply insert a blank template on an image page.

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BetacommandBot (talk) 20:30, 2 January 2008 (UTC)

External link suggestion: New article about Klaatu
As an editor at Crawdaddy!, and to comply with COI guidelines, I am not posting the link to this new article about Klaatu. However, I would like to recommend it on its merits, and hope that an editor will find the time to examine the piece and—if he or she sees fit—post it to the external links section. The writer, Paul Myers, interviewed Dee Long for the piece. I appreciate your time. Crawdaddy! Mike harkin (talk) 20:00, 10 December 2008 (UTC)
 * The Crawdaddy! link is dead. Varlaam (talk) 22:56, 24 February 2012 (UTC)

Daffodil Records
The Wikipedia page concerns a US jazz label. I think that Klaatu's Daffodil label was Canadian.

Can someone please clarify? Varlaam (talk) 22:53, 24 February 2012 (UTC)

title: Talk:Klaatu (band)


text:
Ambush!

Ambush! is a man-to-man wargame developed by Avalon Hill. It was released under Avalon's Victory Games label and was developed by Eric Lee Smith and John Butterfield. It has been out of print since Avalon Hill was disbanded in 1998.

Ambush! was innovative when it was released in 1983 since it was exclusively designed for single player play. Up to that point, wargames generally required at least two players. This was necessary since a player always had to play and control the opponent. Ambush! solved this problem by having the game scenario itself control the opponent. It accomplished this via tables, charts and a "paragraph book" which the player referred to see how the opponent was reacting.

Having the scenario dictate the actions of the opponent had another advantage: perfectly hiding the enemy. In all previous board based wargames, chits or markers had to be placed on the board representing enemy units. Some chits contained question marks or otherwise hid what was actually on the space, but the opposing player knew where likely areas for the enemy were. With Ambush!, the enemy had no markers on the board at all until they became visible (usually by attacking the player).

One drawback of Ambush!'s design was that it was difficult for players to create their own scenarios. Since each scenario had its own complex set of charts and tables, each cross-referenced to sections in the paragraph book, creating a scenario for the game from scratch could be a daunting undertaking. Players, then, were usually required to purchase Avalon Hill's expansion modules in order to play additional scenarios.

Ambush! could also be played with more than one player, with players playing in different squads or controlling different soldiers.

Expansions
Ambush! spawned several expansion modules:
 * Move Out (1984)
 * Purple Heart (1985)
 * Silver Star (1987)

There was also a Japanese theatre version of Ambush! called Battle Hymn, which had one expansion module called Leatherneck.

Additionally, a solitaire game based on Ambush! called Open Fire! was released by Victory Games which put the player in command of US tanks in WW II. It was less successful and had a less elegant design.

There was, finally, a two-player version of Ambush! called Shell Shock released in 1990.

Computer versions
There have been a number of literal translations of Ambush! to the computer, including a cyberbox module as well as at least one version for the VASSAL game engine.

Reception
In 1984, Ambush! won the Origins Award for Best 20th Century Boardgame of 1983.

Reviews

 * Casus Belli #22 (Oct 1984)
 * 1983 Games 100
 * 1984 Games 100

Legacy
While not the first boxed solitaire board wargame to be produced (Avalon Hill's B-17, Queen of the Skies had preceded it in 1983), Ambush! was probably the most successful. While the additional modules are testament to this successful design, the concept also appears to have been validated by Ambush!, as a fair number of other purpose-designed solitaire games (as opposed to two player games that "could" be played solitaire) followed it shortly after. These include:

 * Tokyo Express (Victory Games, 1988)
 * Open Fire (Victory Games, 1988)
 * London's Burning (Avalon Hill, 1995) - a solitaire game of the Battle of Britain
 * Solitaire Advanced Squad Leader (Avalon Hill, 1995)

title: Ambush!


text:
Talk:Ambush!

Untitled
This is my first stab at a description of the game. I was a little unsure about what to name it. Since the official name of the game is Ambush!, I was tempted to name it that, but I am unsure about whether or not this would conflict with Wikipedia's style rules. If it doesn't conflict, we might want to consider moving it. One other thing I am unsure about is italicising the referenced game. I know the first reference is supposed to be bold (i.e. Ambush!), but what about subsequent references to it? Is it supposed to be Ambush!, Ambush! or Ambush!? TIA -Frecklefoot

Extra Ambush Modules not mentioned
Two modules not mentioned are Battle Hymn and Leather Neck. Battle Hymn is a stand-alone version of Ambush and covers the Pacific during World War 2. The layout and many of the rules are identical and it is basically a module for Ambush built to stand on its own. Instead of a US Army squad you play with a USMC squad against the Japanese. Leather Neck is a module for Battle Hymn.

The main game and its modules are often available on ebay along with brand new modules being released one mission at a time.

 * Battle Hymn is a stand alone game, as you mention, and therefore not a module....:-) Michael Dorosh 03:46, 7 July 2006 (UTC)

Disbanded in 1988?
I believe Ambush! were printed after 1988 as well. One of my copies of the game have parts that are marked "(C) 1983/1991 Victory Games, division of the Avalon Hill Game Co.".

Fair use rationale for Image:Ambushboxtop.jpg
Image:Ambushboxtop.jpg is being used on this article. I notice the image page specifies that the image is being used under fair use but there is no explanation or rationale as to why its use in this Wikipedia article constitutes fair use. In addition to the boilerplate fair use template, you must also write out on the image description page a specific explanation or rationale for why using this image in each article is consistent with fair use.

Please go to the image description page and edit it to include a fair use rationale. Using one of the templates at Fair use rationale guideline is an easy way to insure that your image is in compliance with Wikipedia policy, but remember that you must complete the template. Do not simply insert a blank template on an image page.

If there is other fair use media, consider checking that you have specified the fair use rationale on the other images used on this page. Note that any fair use images lacking such an explanation can be deleted one week after being tagged, as described on criteria for speedy deletion. If you have any questions please ask them at the Media copyright questions page. Thank you.

BetacommandBot (talk) 18:36, 13 February 2008 (UTC)
 * Done. --Rindis (talk) 00:03, 14 February 2008 (UTC)

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Santa Clara County v. Southern Pacific Railroad Co.

Santa Clara County v. Southern Pacific Railroad Company, 118 U.S. 394 (1886), is a corporate law case of the United States Supreme Court concerning taxation of railroad properties. The case is most notable for a headnote stating that the Equal Protection Clause of the Fourteenth Amendment grants constitutional protections to corporations.

The case arose when several railroads refused to follow a California state law that gave less favorable tax treatment to some assets owned by corporations as compared to assets owned by individuals. The Court's opinions in earlier cases such as Dartmouth College v. Woodward had recognized that corporations were entitled to some of the protections of the Constitution. Associate Justice John Marshall Harlan's majority opinion held for the railroads, but his opinion did not address the Equal Protection Clause. However, a headnote written by the Reporter of Decisions and approved by Chief Justice Morrison Waite stated that the Supreme Court justices unanimously believed that the Equal Protection Clause did grant constitutional protections to corporations. The headnote marked the first occasion on which the Supreme Court indicated that the Equal Protection Clause granted constitutional protections to corporations as well as to natural persons.

Facts
At the California Constitutional Convention of 1878–79, the state legislature drew up a new constitution that denied railroads "the right to deduct the amount of their debts [i.e., mortgages] from the taxable value of their property, a right which was given to individuals." Southern Pacific Railroad Company refused to pay taxes under these new changes. The taxpaying railroads challenged this law, based on a conflicting federal statute of 1866 which gave them privileges inconsistent with state taxation (14 Stat. 292, §§ 1, 2, 3, 11, 18).

San Mateo County, along with neighboring counties, filed suit against the railroads to recoup the massive losses in tax revenue stemming from Southern Pacific's refusal to pay. After hearing arguments in San Mateo County v. Southern Pacific Railroad Company, the California Supreme Court sided with the county.

The Supreme Court of the United States issued an opinion consolidating three separate cases: Santa Clara County v. Southern Pacific Railroad Company, California v. Central Pacific Railroad Company, and California v. Southern Pacific Railroad Company.

Headnote
The headnote, which is "not the work of the Court, but is simply the work of the Reporter, giving his understanding of the decision, prepared for the convenience of the profession", was written by the Reporter of Decisions, former president of the Newburgh and New York Railway Company J.C. Bancroft Davis. He said the following:

"One of the points made and discussed at length in the brief of counsel for defendants in error was that 'corporations are persons within the meaning of the Fourteenth Amendment to the Constitution of the United States.' Before argument, Mr. Chief Justice Waite said: The court does not wish to hear argument on the question whether the provision in the Fourteenth Amendment to the Constitution, which forbids a State to deny to any person within its jurisdiction the equal protection of the laws, applies to these corporations. We are all of the opinion that it does."

So the headnote was a reporting by the Reporter of Decisions of the Chief Justice's interpretation of the Justices' opinions. But the issue of applicability of "Equal Protection to any persons" to the railroads was not addressed in the decision of the Court in the case.

Before publication in United States Reports, Davis wrote a letter to Chief Justice Morrison Waite, dated May 26, 1886, to make sure his headnote was correct:

Dear Chief Justice,

I have a memorandum in the California Cases Santa Clara County v. Southern Pacific &c As follows. In opening the Court stated that it did not wish to hear argument on the question whether the Fourteenth Amendment applies to such corporations as are parties in these suits. All the Judges were of the opinion that it does.

Waite replied:

I think your mem. in the California Railroad Tax cases expresses with sufficient accuracy what was said before the argument began. I leave it with you to determine whether anything need be said about it in the report inasmuch as we avoided meeting the constitutional question in the decision.

C. Peter Magrath, who discovered the exchange while researching Morrison R. Waite: The Triumph of Character, writes "In other words, to the Reporter fell the decision which enshrined the declaration in the United States Reports...had Davis left it out, Santa Clara County v. Southern Pac. R. Co. would have been lost to history among thousands of uninteresting tax cases." At the same time, the correspondence makes clear that the headnote does reflect the Court's thinking, at least before hearing any arguments to the contrary.

Author Jack Beatty wrote about the lingering questions as to how the reporter's note reflected a quotation that was absent from the opinion itself. Why did the chief justice issue his dictum? Why did he leave it up to Davis to include it in the headnotes? After Waite told him that the Court 'avoided' the issue of corporate personhood, why did Davis include it? Why, indeed, did he begin his headnote with it? The opinion made plain that the Court did not decide the corporate personality issue and the subsidiary equal protection issue.

Defense argument
While the decision of the Court did not rest on the Fourteenth Amendment, an argument on this ground had been delivered by the defense:

"That the provisions of the Constitution and laws of California in respect to the assessment for taxation of the property of railway corporations operating railroads in more than one county, are in violation of the Fourteenth Amendment of the Constitution insofar as they require the assessment of their property at its full money value without making deduction, as in the case of railroads operated in one county and of other corporations and of natural persons, for the value of the mortgages covering the property assessed, thus imposing upon the defendant unequal burdens, and to that extent denying to it the equal protection of the laws."

Judgment
A unanimous decision, written by Justice Harlan, ruled on the matter of fences, holding that the state of California illegally included the fences running beside the tracks in its assessment of the total value of the railroad's property. As a result, the county could not collect taxes from Southern Pacific that it was not allowed to collect in the first place. This meant that the more significant question of the Equal Protection Clause was never actually addressed.

"The special grounds of defense by each of the defendants were:

 * 1) That its road is a part of a continuous postal and military route, constructed and maintained under the authority of the United States by means in part obtained from the general government; that the company having, with the consent of the state, become subject to the requirements, conditions, and provisions of the acts of Congress, it thereby ceased to be merely a state corporation and became one of the agencies or instrumentalities employed by the general government to execute its constitutional powers, and that the franchise to operate a postal and military route, for the transportation of troops, munitions of war, public stores, and the mails, being derived from the United States, cannot without their consent be subjected to state taxation.
 * 2) That the provisions of the Constitution and laws of California in respect to the assessment for taxation of the property of railway corporations operating railroads in more than one county, are in violation of the Fourteenth Amendment of the Constitution insofar as they require the assessment of their property at its full money value without making deduction, as in the case of railroads operated in one county and of other corporations and of natural persons, for the value of the mortgages covering the property assessed, thus imposing upon the defendant unequal burdens, and to that extent denying to it the equal protection of the laws.
 * 3) That what is known as § 3664 of the Political Code of California, under the authority of which, in part, the assessment was made, was not constitutionally enacted by the legislature, and had not the force of law.
 * 4) That no void assessment appears in fact to have been made by the state board.
 * 5) That no interest is recoverable in this action until after judgment.
 * 6) That the assessment upon which the action is based is void because it included property which the State Board of Equalization had no jurisdiction under any circumstances to assess, and that as such illegal part was so blended with the balance that it cannot be separated, the entire assessment must be treated as a nullity.

The record contains elaborate opinions stating the grounds upon which judgments were ordered for the defendants. Mr. Justice Field overruled the first of the special defenses above named, but sustained the second. The circuit judge in addition held that § 3664 of the Political Code had not been passed in the mode required by the state constitution, and consequently was no part of the law of California. These opinions are reported as the Santa Clara Railroad Tax Case, 18 F. 385.

The propositions embodied in the conclusions reached in the circuit court were discussed with marked ability by counsel who appeared in this Court for the respective parties. Their importance cannot well be over-estimated, for they not only involve a construction of the recent amendments to the national Constitution in their application to the constitution and the legislation of a state, but upon their determination, if it were necessary to consider them, would depend the system of taxation devised by that state for raising revenue from certain corporations for the support of her government. These questions belong to a class which this Court should not decide unless their determination is essential to the disposal of the case in which they arise. Whether the present cases require a decision of them depends upon the soundness of another proposition upon which the court below, in view of its conclusions upon other issues, did not deem it necessary to pass. We allude to the claim of the defendant in each case that the entire assessment is a nullity upon the ground that the State Board of Equalization included therein property which it was without jurisdiction to assess for taxation.

The argument in behalf of the defendant is that the state board knowingly and designedly included in its assessment of 'the franchise, roadway, roadbed, rails, and rolling stock' of each company, the value of the fences erected upon the line between its roadway and the land of coterminous proprietors; that the fences did not constitute a part of such roadway, and therefore could only be assessed for taxation by the proper officer of the several counties in which they were situated, and that an entire assessment which includes property not assessable by the state board against the party assessed, is void, and therefore insufficient to support an action, at least when -- and such is claimed to be the case here -- it does not appear with reasonable certainty from the face of the assessment or otherwise what part of the aggregate valuation represents the property so illegally included therein.

If these positions are tenable, there will be no occasion to consider the grave questions of constitutional law upon which the case was determined below, for in that event the judgment can be affirmed upon the ground that the assessment cannot properly be the basis of a judgment against the defendant."

Significance
Thus the Supreme Court's actual decision never hinged on the equal protection claims. Nevertheless, the case has been allowed to have clear constitutional consequences, as it has been subsequently cited as affirming the protection of corporations under the Fourteenth Amendment. At the very least, this is an unusual exception to the normal understanding of the workings of the Court's rule of stare decisis – the reliance on precedent. It is an instance in which a statement which is neither part of the ruling of the Court, nor part of the opinion of a majority or dissenting minority of the Court has been cited as precedent in subsequent decisions of the Court.

In his dissent in the 1938 case of Connecticut General Life Insurance Company v. Johnson, Justice Hugo Black wrote "in 1886, this Court in the case of Santa Clara County v. Southern Pacific Railroad, decided for the first time that the word 'person' in the amendment did in some instances include corporations. [...] The history of the amendment proves that the people were told that its purpose was to protect weak and helpless human beings and were not told that it was intended to remove corporations in any fashion from the control of state governments. [...] The language of the amendment itself does not support the theory that it was passed for the benefit of corporations."

Justice William O. Douglas wrote in 1949, "the Santa Clara case becomes one of the most momentous of all our decisions. [...] Corporations were now armed with constitutional prerogatives."