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United States v. Wong Kim Ark

United States v. Wong Kim Ark, 169 U.S. 649 (1898), was a landmark decision of the U.S. Supreme Court which held that "a child born in the United States, of parents of Chinese descent, who, at the time of his birth, are subjects of the Emperor of China, but have a permanent domicile and residence in the United States, and are there carrying on business, and are not employed in any diplomatic or official capacity under the Emperor of China", automatically became a U.S. citizen at birth. This decision established an important precedent in its interpretation of the Citizenship Clause of the Fourteenth Amendment to the Constitution.

Wong Kim Ark, who was born in San Francisco in 1873, had been denied re-entry to the United States after a trip abroad, under the Chinese Exclusion Act, a law banning virtually all Chinese immigration and prohibiting Chinese immigrants from becoming naturalized U.S. citizens. He challenged the government's refusal to recognize his citizenship, and the Supreme Court ruled in his favor, holding that the citizenship language in the Fourteenth Amendment encompassed the circumstances of his birth and could not be limited in its effect by an act of Congress.

The case highlighted disagreements over the precise meaning of one phrase in the Citizenship Clause—namely, the provision that a person born in the United States who is "subject to the jurisdiction thereof" acquires automatic citizenship. The Supreme Court's majority concluded that this phrase referred to being required to obey U.S. law; on this basis, they interpreted the language of the Fourteenth Amendment in a way that granted U.S. citizenship to children born of foreigners (a concept known as jus soli), with only a limited set of exceptions mostly based in English common law. The court's dissenters argued that being subject to the jurisdiction of the United States meant not being subject to any foreign power —that is, not being claimed as a citizen by another country via jus sanguinis (inheriting citizenship from a parent)—an interpretation which, in the minority's view, would have excluded "the children of foreigners, happening to be born to them while passing through the country".

In the words of a 2007 legal analysis of events following the Wong Kim Ark decision, "The parameters of the jus soli principle, as stated by the court in Wong Kim Ark, have never been seriously questioned by the Supreme Court, and have been accepted as dogma by lower courts." A 2010 review of the history of the Citizenship Clause notes that the Wong Kim Ark decision held that the guarantee of birthright citizenship "applies to children of foreigners present on American soil" and states that the Supreme Court "has not re-examined this issue since the concept of 'illegal alien' entered the language". Since the 1990s, however, controversy has arisen over the longstanding practice of granting automatic citizenship to U.S.-born children of illegal immigrants, and legal scholars disagree over whether the Wong Kim Ark precedent applies when alien parents are in the country illegally. Attempts have been made from time to time in Congress to restrict birthright citizenship, either via statutory redefinition of the term jurisdiction, or by overriding both the Wong Kim Ark ruling and the Citizenship Clause itself through an amendment to the Constitution, but no such proposal has been enacted.

Early history of United States citizenship law
United States citizenship law is founded on two traditional principles—jus soli ("right of the soil"; a "common law" doctrine), and jus sanguinis ("right of the blood"; a "civil law" doctrine). Under jus soli, a child's citizenship would be acquired by birth within a country's territory, without reference to the political status or condition of the child's parents. Under jus sanguinis, the citizenship of a child would not depend on their place of birth, but instead follow the status of a parent (specifically, the father—or, in the case of an illegitimate birth, the mother).

Throughout the history of the United States, the dominant legal principle governing citizenship has been jus soli—the principle that birth within the territorial limits of the United States confers automatic citizenship, excluding slaves before the American Civil War. Although there was no actual definition of citizenship in United States law until after the Civil War, it was generally accepted that anyone born in the United States was automatically a citizen. This applicability of jus soli, via the common law inherited in the United States from England, was upheld in an 1844 New York state case, Lynch v. Clarke, in which it was held that a woman born in New York City, of alien parents temporarily sojourning there, was a U.S. citizen.

United States citizenship could also be acquired at birth via jus sanguinis (birth outside the country to a citizen parent), a right confirmed by Congress in the Naturalization Act of 1790. Additionally, alien immigrants to the United States could acquire citizenship via a process of naturalization—though access to naturalization was originally limited to "free white person[s]".

African slaves were originally excluded from United States citizenship. In 1857, the United States Supreme Court held in Dred Scott v. Sandford that slaves, former slaves, and their descendants were not eligible under the Constitution to be citizens. Additionally, American Indians were not originally recognized as citizens, since Indian tribes were considered to be outside the jurisdiction of the U.S. government.

Citizenship clause of the Fourteenth Amendment
After the Civil War and the subsequent abolition of slavery, Congress enacted the Civil Rights Act of 1866. One provision of this law declared as citizens, not only the freed slaves, but "all persons born in the United States and not subject to any foreign power, excluding Indians not taxed".

Concerns were raised that the citizenship guarantee in the Civil Rights Act might be repealed by a later Congress or struck down as unconstitutional by the courts. Soon after the passage of the Act, Congress drafted the Fourteenth Amendment to the Constitution and sent it to the states for ratification (a process which was completed in 1868). Among the Fourteenth Amendment's many provisions was the Citizenship Clause, which entrenched a guarantee of citizenship in the Constitution by stating, "All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside."

The Citizenship Clause was proposed by Senator Jacob M. Howard of Michigan on May 30, 1866, as an amendment to the joint resolution from the House of Representatives which had framed the initial draft of the proposed Fourteenth Amendment. The heated debate on the proposed new language in the Senate focused on whether Howard's proposed language would apply more broadly than the wording of the 1866 Civil Rights Act.

Howard said that the clause "is simply declaratory of what I regard as the law of the land already, that every person born within the limits of the United States, and subject to their jurisdiction, is by virtue of natural law and national law a citizen of the United States." He added that citizenship "will not, of course, include persons born in the United States who are foreigners, aliens, who belong to the families of ambassadors or foreign ministers accredited to the Government of the United States, but will include every other class of persons" —a comment which would later raise questions as to whether Congress had originally intended that U.S.-born children of foreign parents were to be included as citizens. Responding to concerns expressed by Edgar Cowan of Pennsylvania that liberalizing the right to citizenship might result in certain states being taken over by large populations of undesirable foreign immigrants, John Conness of California predicted that the Chinese population in California would likely remain very small, in large part because Chinese immigrants almost always eventually returned to China, and also because very few Chinese women left their homeland to come to the United States.

James R. Doolittle of Wisconsin objected that the citizenship provision would not be sufficiently narrow to exclude American Indians from citizenship, and in an attempt to address this issue, he proposed to add a phrase taken from the Civil Rights Act—"excluding Indians not taxed". Although most Senators agreed that birthright citizenship should not be extended to the Indians, a majority saw no need to clarify the issue, and Doolittle's proposal was voted down. Upon its return to the House of Representatives, the proposed Fourteenth Amendment received little debate; no one spoke in opposition to the Senate's addition of the Citizenship Clause, and the complete proposed amendment was approved by the House on June 13, 1866, and declared to have been ratified on July 28, 1868.

In 2006, Goodwin Liu, then an assistant professor at the Boalt Hall law school of the University of California, Berkeley, and later an Associate Justice of the California Supreme Court, wrote that although the legislative history of the Citizenship Clause is "somewhat thin", the clause's central role is evident in the historical context of the post-Civil War period. Elizabeth Wydra, chief counsel of the Constitutional Accountability Center (a progressive think tank ), argues that both supporters and opponents of the Citizenship Clause in 1866 shared the understanding that it would automatically grant citizenship to all persons born in the United States (except children of foreign ministers and invading armies) —an interpretation shared by Texas Solicitor General James C. Ho. Richard Aynes, dean of the University of Akron School of Law, takes a different view, proposing that the Citizenship Clause had "consequences which were unintended by the framers".

Citizenship of Chinese persons in the United States
Like many other immigrants, Chinese were drawn to the United States—initially to participate in the California Gold Rush of 1849, then moving on to railroad construction, farming, and work in cities. An 1868 treaty (named the Burlingame Treaty after one of the American negotiators) expanded trade and migration between the United States and China. The treaty did not address the citizenship of children born in the United States to Chinese parents, or vice versa. Regarding naturalization (acquisition of citizenship other than at birth), the treaty contained a provision stating that "nothing herein contained shall be held to confer naturalization ... upon the subjects of China in the United States."

Chinese immigrants to the United States were met with considerable distrust, resentment, and discrimination almost from the time of their first arrival. Many politicians argued that the Chinese were so different in so many ways that they not only would never (or even could) assimilate into American culture, but that they represented a threat to the country's principles and institutions. In this climate of popular anti-Chinese sentiment, Congress in 1882 enacted the Chinese Exclusion Act, which placed limits on Chinese immigration to the United States. (The original Chinese Exclusion Act was amended several times —such as by the 1888 Scott Act and the 1892 Geary Act —and as a result, it is sometimes referred to in the plural as the "Chinese Exclusion Acts".) Chinese already in the U.S. were allowed to stay, but they were ineligible for naturalization and, if they left the U.S. and later wished to return, they needed to apply anew and obtain approval again. Chinese laborers and miners were specifically barred from coming (or returning) to the United States under the terms of the law.

Citizenship Clause cases prior to Wong Kim Ark
After the adoption of the Fourteenth Amendment in 1868 and prior to the Wong Kim Ark case, the question of jus soli citizenship for children of aliens arose only with reference to American Indians and Chinese. The Supreme Court ruled in an 1884 case (Elk v. Wilkins) that an Indian born on a reservation did not acquire United States citizenship at birth (because he was not subject to U.S. jurisdiction) and could not claim citizenship later on merely by moving to non-reservation U.S. territory and renouncing his former tribal allegiance. American Indians were subsequently granted citizenship by an act of Congress in 1924.

The question of whether the Citizenship Clause applied to persons born in the United States to Chinese immigrants first came before the courts in an 1884 case, In re Look Tin Sing. Look Tin Sing was born in Mendocino, California in 1870 to Chinese immigrants. In 1879, his merchant father sent him to China; but upon returning from China in 1884 at age 14, he was barred from reentering the United States by officials who objected to his not having met the documentation requirements imposed at the time on Chinese immigrants under the Restriction Acts of 1882 or of 1884. Look's case was heard in the federal circuit court for California by U.S. Supreme Court Associate Justice Stephen J. Field and two other federal judges. Lucy E. Salyer, a history professor at the University of New Hampshire, writes that Justice Field "issued an open invitation to all lawyers in the area to give their opinions on the constitutional questions involved" in the case. Field focused on the meaning of the subject to the jurisdiction thereof phrase of the Citizenship Clause, held that Look was indeed subject to U.S. jurisdiction at the time of his birth irrespective of the alien status of his parents, and on this basis ordered U.S. officials to recognize Look as a citizen and allow him to enter the United States. The Look Tin Sing ruling was not appealed and was never reviewed by the Supreme Court. A similar conclusion was reached by the federal circuit court for Oregon in the 1888 cases of Ex parte Chin King and Ex parte Chan San Hee.

In an 1892 case, Gee Fook Sing v. U.S., a federal appeals court in California for the same circuit (by this time known as the Ninth Circuit Court of Appeals) concluded that a Chinese man would have been recognized as a United States citizen if he could have presented satisfactory evidence that he had in fact been born in the U.S. This case was also never brought before the Supreme Court.

The Supreme Court's 1873 Slaughterhouse Cases decision contained the statement that "The phrase, 'subject to its jurisdiction,' was intended to exclude from its operation children of ministers, consuls, and citizens or subjects of foreign states born within the United States." However, since the Slaughterhouse Cases did not deal with claims of birthright citizenship, this comment was dismissed in Wong Kim Ark and later cases as a passing remark (obiter dictum) lacking any force as a controlling precedent. As to whether the Wong Kim Ark decision was correct on this point or not, modern scholars are divided.

Wong Kim Ark
Wong Kim Ark (Taishanese: Wōng Gim-ak), was born in San Francisco, California, at 751 Sacramento Street, the address of a Chinatown business (Quong Sing) maintained by his merchant parents. Various sources state or imply his year of birth as being 1873, 1871, or 1868. His father, Wong Si Ping, and mother, Lee Wee, emigrated from Taishan, Guangdong, China and were not United States citizens, as the Naturalization Law of 1802 had made them ineligible for naturalization either before or after his birth. Wong did not become a merchant like his father, but worked as a cook in Chinatown restaurants.

In 1889, Wong Kim Ark, then in his late teens, left for China with his parents, who decided to repatriate to China and to their ancestral village in Taishan, Ong Sing. While in Taishan, Wong Kim Ark married Yee Shee from a village near his familial one. Returning to the United States in 1890, he left behind in Taishan not only his parents but also his wife, who gave birth to their first son after he returned to California. Under the Chinese Exclusion Act of 1882, he as a laborer could not bring his wife to the United States. Upon arrival alone at San Francisco in July 1890, he was readmitted on the ground that he was a native-born citizen of the United States, but only after an unnamed Bureau of Immigration official left a note in his file questioning the veracity of his claim of birth in the United States.

In November 1894, Wong sailed to China for another temporary visit, to rejoin his wife at his family's village in Taishan, Guangdong. He met his oldest son for the first time, and his second son was conceived. But when he returned in August 1895 by SS Coptic, he was detained at the Port of San Francisco by the Collector of Customs, who denied him permission to enter the country, arguing that Wong was not a U.S. citizen despite his having been born in the U.S., but was instead a Chinese subject because his parents were Chinese. Wong was confined for five months on steamships off the coast of San Francisco while his case was being tried.

According to Salyer, the San Francisco attorney George Collins had tried to persuade the federal Justice Department to bring a Chinese birthright citizenship case before the Supreme Court. An article by Collins was published in the May/June 1895 American Law Review, criticizing the Look Tin Sing ruling by Judge Field and the federal government's unwillingness to challenge it, and advocating the international law view of jus sanguinis citizenship. Eventually, Collins was able to convince U.S. Attorney Henry Foote, who "searched for a viable test case and settled on Wong Kim Ark".

With the assistance of legal representation by the Chinese Consolidated Benevolent Association, Wong Kim Ark challenged the refusal to recognize his birth claim to U.S. citizenship, and a petition for a writ of habeas corpus was filed on his behalf in federal district court. The arguments presented before District Judge William W. Morrow centered on which of two competing interpretations of the phrase subject to the jurisdiction thereof in the Citizenship Clause should govern a situation involving a child born in the United States to alien parents. Wong's attorneys argued that the phrase meant subject to the laws of the United States,' comprehending, in this expression, the allegiance that aliens owe in a foreign country to obey its laws"—an interpretation, based on the common law inherited by the United States from England, that would encompass essentially everyone born in the U.S. via the principle of jus soli (citizenship based on place of birth). The U.S. government claimed that subject to the jurisdiction thereof meant "to be subject to the political jurisdiction of the United States"—an interpretation, based on international law, which would exclude parents and their children who owed allegiance to another country via the principle of jus sanguinis (citizenship inherited from a parent).

The question of the citizenship status of U.S.-born children of alien parents had, up to this time, never been decided by the Supreme Court. The U.S. government argued that Wong's claim to U.S. citizenship was ruled out by the Supreme Court's interpretation of jurisdiction in its 1873 Slaughterhouse Cases ruling, but the district judge concluded that the language in question was obiter dictum and not directly relevant to the case at hand. The government also cited a similar statement in Elk v. Wilkins, but the judge was not convinced by this argument either.

Wong's attorneys cited the Look Tin Sing case, and the district judge agreed that in the absence of clear direction from the Supreme Court, this case definitively settled the question of citizenship for Wong and others like him as far as federal courts in the Ninth Circuit were concerned. The judge saw the Look Tin Sing holding reaffirmed in the Gee Fook Sing case and noted further that another part of the Supreme Court's Slaughterhouse Cases opinion said that "it is only necessary that [a man] should be born or naturalized in the United States to be a citizen of the Union." Concluding that the Look Tin Sing decision constituted a controlling precedent in the Ninth Circuit, Judge Morrow ruled that subject to the jurisdiction thereof referred to being subject to U.S. law (the first of the two proposed interpretations). On January 3, 1896, the judge declared Wong Kim Ark to be a citizen because he was born in the U.S.

The U.S. government appealed the district court ruling directly to the United States Supreme Court. According to Salyer, government officials—realizing that the decision in this case "was of great importance, not just to Chinese Americans, but to all American citizens who had been born to alien parents", and concerned about the possible effect of an early ruling by the Supreme Court on the 1896 presidential election—delayed the timing of their appeal so as to avoid the possibility of a decision based more on policy concerns than the merits of the case. Oral arguments before the Supreme Court were held on March 5, 1897. Solicitor General Holmes Conrad presented the government's case; Wong was represented before the Court by Maxwell Evarts, former U.S. Assistant Attorney General J. Hubley Ashton, and Thomas D. Riordan.

The Supreme Court considered the "single question" in the case to be "whether a child born in the United States, of parent[s] of Chinese descent, who, at the time of his birth, are subjects of the Emperor of China, but have a permanent domicile and residence in the United States, and are there carrying on business, and are not employed in any diplomatic or official capacity under the Emperor of China, becomes at the time of his birth a citizen of the United States." It was conceded that if Wong was a U.S. citizen, "the acts of Congress known as the 'Chinese Exclusion Acts,' prohibiting persons of the Chinese race, and especially Chinese laborers, from coming into the United States, do not and cannot apply to him."

Opinion of the Court
In a 6–2 decision issued on March 28, 1898, the Supreme Court held that Wong Kim Ark had acquired U.S. citizenship at birth and that "the American citizenship which Wong Kim Ark acquired by birth within the United States has not been lost or taken away by anything happening since his birth." The opinion of the Court was written by Associate Justice Horace Gray and was joined by Associate Justices David J. Brewer, Henry B. Brown, George Shiras Jr., Edward Douglass White, and Rufus W. Peckham.

Upholding the concept of jus soli (citizenship based on place of birth), the Court held that the Citizenship Clause needed to be interpreted in light of English common law, which had included as subjects virtually all native-born children, excluding only those who were born to foreign rulers or diplomats, born on foreign public ships, or born to enemy forces engaged in hostile occupation of the country's territory. The court's majority held that the subject to the jurisdiction phrase in the Citizenship Clause excluded from U.S. citizenship only those persons covered by one of these three exceptions (plus a fourth "single additional exception"—namely, that Indian tribes "not taxed" were not considered subject to U.S. jurisdiction). The majority concluded that none of these four exceptions to U.S. jurisdiction applied to Wong; in particular, they observed that "during all the time of their said residence in the United States, as domiciled residents therein, the said mother and father of said Wong Kim Ark were engaged in the prosecution of business, and were never engaged in any diplomatic or official capacity under the Emperor of China".

Quoting approvingly from an 1812 case, The Schooner Exchange v. M'Faddon, in which Chief Justice John Marshall said, "The jurisdiction of the nation within its own territory is necessarily exclusive and absolute"  —and agreeing with the district judge who had heard Wong's original habeas corpus petition that comments in the Slaughterhouse Cases about the citizenship status of children born to non-citizen parents did not constitute a binding precedent —the Court ruled that Wong was a U.S. citizen from birth, via the Fourteenth Amendment, and that the restrictions of the Chinese Exclusion Act did not apply to him. An act of Congress, they held, does not trump the Constitution; such a law "cannot control [the Constitution's] meaning, or impair its effect, but must be construed and executed in subordination to its provisions." The majority opinion referred to Calvin's Case (1608) as stating the fundamental common law principle that all people born within the King's "allegiance" were subjects, including children of "aliens in amity".

Dissent
Chief Justice Melville Fuller was joined by Associate Justice John Harlan in a dissent which, "for the most part, may be said to be predicated upon the recognition of the international law doctrine". The dissenters argued that the history of U.S. citizenship law had broken with English common law tradition after independence—citing as an example the embracing in the U.S. of the right of expatriation (giving up of one's native citizenship) and the rejection of the contrary British doctrine of perpetual allegiance. The dissenters argued that the principle of jus sanguinis (that is, the concept of a child inheriting his or her father's citizenship by descent regardless of birthplace) had been more pervasive in U.S. legal history since independence. Based on an assessment of U.S. and Chinese treaty and naturalization law, the dissenters claimed that "the children of Chinese born in this country do not, ipso facto, become citizens of the United States unless the fourteenth amendment overrides both treaty and statute."

Pointing to the language of the Civil Rights Act of 1866, an act of Congress which declared to be citizens "all persons born in the United States and not subject to any foreign power, excluding Indians not taxed", and which was enacted into law only two months before the Fourteenth Amendment was proposed by Congress, the dissenters argued that "it is not open to reasonable doubt that the words 'subject to the jurisdiction thereof,' in the amendment, were used as synonymous with the words 'and not subject to any foreign power. In the dissenters' view, excessive reliance on jus soli (birthplace) as the principal determiner of citizenship would lead to an untenable state of affairs in which "the children of foreigners, happening to be born to them while passing through the country, whether of royal parentage or not, or whether of the Mongolian, Malay or other race, were eligible to the presidency, while children of our citizens, born abroad, were not."

The dissenters acknowledged that other children of foreigners—including former slaves—had, over the years, acquired U.S. citizenship through birth on U.S. soil. But they still saw a difference between those people and U.S.-born individuals of Chinese ancestry, because of strong cultural traditions discouraging Chinese immigrants from assimilating into mainstream American society, Chinese laws of the time which made renouncing allegiance to the Chinese emperor a capital crime, and the provisions of the Chinese Exclusion Act making Chinese immigrants already in the United States ineligible for citizenship. The question for the dissenters was "not whether [Wong Kim Ark] was born in the U.S. or subject to the jurisdiction thereof ... but whether his or her parents have the ability, under U.S. or foreign law, statutory or treaty-based, to become citizens of the U.S. themselves".

In a lecture to a group of law students shortly before the decision was released, Harlan commented that the Chinese had long been excluded from American society "upon the idea that this is a race utterly foreign to us and never will assimilate with us." Without the exclusion legislation, Harlan stated his opinion that vast numbers of Chinese "would have rooted out the American population" in the western United States. Acknowledging the opposing view supporting citizenship for American-born Chinese, he said that "Of course, the argument on the other side is that the very words of the constitution embrace such a case." Commenting on the Wong Kim Ark case shortly after the issuance of the Court's ruling in 1898, San Francisco attorney Marshall B. Woodworth wrote that "the error the dissent apparently falls into is that it does not recognize that the United States, as a sovereign power, has the right to adopt any rule of citizenship it may see fit and that the rule of international law does not furnish [by its own force] the sole and exclusive test of citizenship of the United States".

Contemporary reactions
In an analysis of the Wong Kim Ark case written shortly after the decision in 1898, Marshall B. Woodworth laid out the two competing theories of jurisdiction in the Citizenship Clause and observed that "[t]he fact that the decision of the court was not unanimous indicates that the question is at least debatable." Woodworth concluded, however, that the Supreme Court's ruling laid the issue to rest, saying that "it is difficult to see what valid objection can be raised thereto". Another analysis of the case, published by the Yale Law Journal (1898), favored the dissenting view.

An editorial published in the San Francisco Chronicle on March 30, 1898, expressed concern that the Wong Kim Ark ruling (issued two days previously) "may have a wider effect upon the question of citizenship than the public supposes"—specifically, that it might lead to citizenship and voting rights not only for Chinese but also Japanese and American Indians. The editorial suggested that "it may become necessary ... to amend the Federal Constitution and definitely limit citizenship to whites and blacks."

Impact on Wong Kim Ark's family
As a result of Wong Kim Ark's U.S. citizenship being confirmed by the Supreme Court, Wong's eldest son came to the United States from China in 1910, seeking recognition as a citizen via jus sanguinis, but U.S. immigration officials claimed to see discrepancies in the testimony at his immigration hearing and refused to accept Wong's claim that the boy was his son. Wong's other three sons came to the United States between 1924 and 1926 and were accepted as citizens. Because of his citizenship, Wong Kim Ark's youngest son was drafted in World War II, and later made a career in the United States Merchant Marine.

Citizenship law since Wong Kim Ark
Current U.S. law on birthright citizenship (citizenship acquired at birth) acknowledges both citizenship through place of birth (jus soli) and citizenship inherited from parents (jus sanguinis). Before Wong Kim Ark, the Supreme Court had held in Elk v. Wilkins (1884) that birthplace by itself was not sufficient to grant citizenship to a Native American; however, Congress eventually granted full citizenship to American Indians via the Indian Citizenship Act of 1924.

Restrictions on immigration and naturalization of Chinese were eventually lifted as a consequence of the Chinese Exclusion Repeal Act of 1943 (also known as the Magnuson Act) and the Immigration and Nationality Act of 1965.

Wong Kim Ark and later cases
In the years since Wong Kim Ark, the concept of jus soli citizenship has "never been seriously questioned by the Supreme Court, and [has] been accepted as dogma by lower courts". Citizenship cases since Wong Kim Ark have dealt mainly with situations falling outside the bounds of the Citizenship Clause —such as citizenship via jus sanguinis for foreign-born children of U.S. citizens, or circumstances under which U.S. citizenship may be lost.

The Wong Kim Ark court's affirmation of jus soli as the primary rule determining United States citizenship has been cited in several Supreme Court decisions affirming the citizenship of U.S.-born individuals of Chinese or Japanese ancestry. The court's holding that the language of the Constitution should be understood in light of the common law has been cited in numerous Supreme Court decisions dealing with the interpretation of the Constitution or acts of Congress. The Wong Kim Ark court's understanding of Fourteenth Amendment jurisdiction was also cited in a 1982 case involving the rights of illegal immigrants.

An unsuccessful effort was made in 1942 by the Native Sons of the Golden West to convince the Supreme Court to revisit and overrule the Wong Kim Ark ruling, in a case (Regan v. King) challenging the citizenship status of roughly 2,600 U.S.-born persons of Japanese ancestry. The plaintiffs' attorney termed Wong Kim Ark "one of the most injurious and unfortunate decisions" ever handed down by the Supreme Court and hoped the new case would give the court "an opportunity to correct itself". A federal district court and the Ninth Circuit Court of Appeals summarily rejected this contention, each citing Wong Kim Ark as a controlling precedent, and the Supreme Court declined to hear the case.

Federal appellate courts have repeatedly rejected attempts to cite the Wong Kim Ark opinion's use of the phrase citizenship by birth within the territory in support of claims that persons born in the Philippines during the period of its history when it was a United States possession were born in the U.S. (and thus entitled to U.S. citizenship via the Citizenship Clause).

Wong Kim Ark and children of illegal immigrants
Since the 1990s, controversy has arisen in some circles over the practice of granting automatic citizenship via jus soli to U.S.-born children of illegal aliens —controversially dubbed the "anchor baby" situation by some media correspondents and advocacy groups. Public debate over the issue has resulted in renewed discussion of the Wong Kim Ark decision.

Some legal scholars, opposed to the idea that jus soli should apply to the children of illegal aliens, have argued that the Wong Kim Ark precedent does not apply when alien parents are in the country illegally. John C. Eastman, a former dean of the Chapman University School of Law, has argued that Wong Kim Ark does not entitle U.S.-born children of illegal aliens to gain automatic citizenship because, in his opinion, being subject to the jurisdiction of the United States requires a status of "full and complete jurisdiction" that does not apply to aliens who are in the country illegally. Eastman further argues that the Wong Kim Ark decision was fundamentally flawed in the way it dealt with the concept of jurisdiction, and that the Indian Citizenship Act of 1924—which followed Wong Kim Ark—would not have been necessary if Congress had believed "that the Citizenship Clause confers citizenship merely by accident of birth." A similar analysis of the jurisdiction question has been proposed by Professor Peter H. Schuck of the Yale School of Law and Rogers M. Smith, political science professor at Yale. According to law professor Lino Graglia of the University of Texas, even if Wong Kim Ark settled the status of children of legal residents, it did not do so for children of illegal residents; Graglia asserts that the case weighs against automatic birthright for illegal immigrants because the Court denied such citizenship for an analogous group, namely "children of alien enemies, born during and within their hostile occupation".

Countering this view, Garrett Epps—a professor of law at the University of Baltimore—has stated that "In the case of United States v. Wong Kim Ark, the United States Supreme Court held that this guarantee [of birthright citizenship] applies to children of foreigners present on American soil, even if their parents are not American citizens and indeed are not eligible to become U.S. citizens." Epps further notes that "as a practical matter, the American-born children receive recognition of their citizenship regardless of the immigration status of their parents." In Epps' opinion, the sponsors of the Fourteenth Amendment "were unwavering in their insistence that the Citizenship Clause was to cover" the children of such "undesirable immigrants" as Chinese and Gypsies, and he views the Wong Kim Ark ruling as an "unexceptionable" matter of reading the drafters' intent.

Cristina Rodriguez, a professor at the New York University School of Law, has argued that Wong Kim Ark's situation was "similar in all meaningful respects" to that of children of illegal immigrants, because "they both involve immigrant parents ineligible for full membership in the polity, or immigrant populations that were tolerated but disdained or considered legally erasable." Rodriguez goes on to claim that the Wong Kim Ark ruling was "a powerful rejection of the idea that one's status depends on his parent's[sic] status." Noting contrary arguments (such as those put forth by Schuck and Smith), Rodriguez says that "For all practical purposes, this debate has been resolved. Though renewed interest over the last few years in immigration reform has prompted the introduction of legislation in Congress to deny the children of the unauthorized jus soli status, these measures have been political non-starters, in large part because of the widespread view that the Supreme Court would strike down any such legislation as unconstitutional."

James C. Ho, currently a judge of the Fifth Circuit Court of Appeals, has expressed a similar view to that of Rodriguez, saying that "Birthright citizenship is guaranteed by the Fourteenth Amendment. That birthright is protected no less for children of undocumented persons than for descendants of Mayflower passengers." Ho also argues that those who claim the Citizenship Clause was not in fact intended to confer citizenship on the children of aliens are disregarding the substance of the 1866 Senate debate over the proposal to add this language to the Fourteenth Amendment.

Eugene Volokh, a professor of law at the UCLA School of Law, wrote in 2018 that "jurisdiction is an entity's power to impose its legal will on someone, and the U.S. unquestionably has the power to do that for children of illegal aliens as much as for children of legal aliens or of citizens." Although Volokh personally disagrees with the concept of "categorical birthright citizenship", he concedes that this was clearly intended by the 14th Amendment's citizenship clause.

The Supreme Court's 1982 Plyler v. Doe decision —in a case involving illegal alien children (i.e., children born abroad who had come to the United States illegally along with their parents, and who had no basis for claiming U.S. citizenship)—has also been cited in support of a broad application of Fourteenth Amendment jurisdiction to illegal aliens and their children. A Texas state law had sought to deny such children a public education, and the Texas government had argued that "persons who have entered the United States illegally are not 'within the jurisdiction' of a State even if they are present within a State's boundaries and subject to its laws." A dictum footnote in the Court's majority opinion remarked that according to Wong Kim Ark, the Fourteenth Amendment's phrases subject to the jurisdiction thereof (in the Citizenship Clause) and within its jurisdiction (in the Equal Protection Clause) were essentially equivalent; that both expressions referred primarily to physical presence and not to political allegiance; and that the Wong Kim Ark decision benefited the children of illegal as well as legal aliens. As a result, the court rejected the claim that Fourteenth Amendment "jurisdiction" depended on whether someone had entered the U.S. legally or not. Although the four dissenting justices disagreed with the opinion of the Court regarding whether the children in question had a right to a public education, the dissenters agreed with the majority regarding the applicability of Fourteenth Amendment jurisdiction to illegal aliens. James C. Ho considers Plyler v. Doe to have "put to rest" any doubt over whether the sweeping language regarding jurisdiction in Wong Kim Ark applies to all aliens, even illegal aliens.

The United States Department of State (the federal government agency responsible for international relations) considers U.S.-born children of illegal aliens to be subject to U.S. jurisdiction, and thus to have citizenship at birth. The State Department's Foreign Affairs Manual takes the position that this issue was settled by the Wong Kim Ark ruling.

Some legal scholars still argue that the Wong Kim Ark ruling should be overturned through legislative means. Richard Posner, a judge of the Seventh Circuit Court of Appeals, has criticized the granting of citizenship to U.S.-born children of illegal immigrants, suggesting that Congress can and should act to change this policy. Charles Wood, former counsel to the Senate Judiciary Committee's subcommittee on immigration, has also opposed the practice, urging (in 1999) that it be stopped as quickly as possible, either by an act of Congress or a constitutional amendment.

However, in the words of Lucy Salyer, "the birthright citizenship doctrine of Wong Kim Ark has remained intact for over a century, still perceived by most to be a natural and well-established rule in accordance with American principles and practice. It is unlikely to be uprooted easily."

Legislative attempts to overturn Wong Kim Ark
In response to public reaction against immigration and fears that U.S.-born children of illegal immigrants could serve as links to permit legal residency and eventual citizenship for family members who would otherwise be ineligible to remain in the country, bills have been introduced from time to time in Congress which have challenged the conventional interpretation of the Citizenship Clause and have sought (thus far unsuccessfully) to actively and explicitly deny citizenship at birth to U.S.-born children of foreign visitors or illegal aliens.

As one example among many, the "Birthright Citizenship Act of 2009"—introduced in the House of Representatives of the 111th Congress as H.R. 1868, by Representative Nathan Deal of Georgia—was an attempt to exclude U.S.-born children of illegal immigrants from being considered subject to the jurisdiction of the United States for purposes of the Citizenship Clause. A similar proposal—named the "Birthright Citizenship Act of 2011"—was introduced in the House as H.R. 140 in the (112th) Congress on January 5, 2011 by Representative Steve King of Iowa, and in the Senate as S. 723 on April 5, 2011 by Senator David Vitter of Louisiana. Neither bill was discussed in Congress prior to the end of the session.

Since an act of Congress challenging the accepted interpretation of the Citizenship Clause might very possibly be ruled unconstitutional by courts choosing to rely on Wong Kim Ark as a precedent, proposals have also been made to amend the Constitution so as to override the Fourteenth Amendment's language and deny citizenship to U.S.-born children of illegal aliens or foreign visitors. For example, Senator Vitter of Louisiana introduced Senate Joint Resolution (S.J.Res.) 6 in the 111th Congress, but like H.R. 1868, it failed to reach the floor of either house of Congress before the 111th Congress adjourned on December 22, 2010. Vitter reintroduced this same proposed amendment as S.J.Res. 2 in the 112th Congress on January 25, 2011; it was not brought up for discussion or voted upon in either house of Congress.

In 2010 and 2011, state legislators in Arizona introduced bills proposing to deny regular birth certificates to children born in Arizona whose parents could not prove they were in the United States legally. Supporters of such legislation reportedly hoped their efforts would cause the issue of birthright citizenship for U.S.-born children of illegal aliens to reach the Supreme Court, possibly resulting in a new decision narrowing or overruling Wong Kim Ark.

On October 30, 2018, President Donald Trump announced his intention to issue an executive order abolishing birthright citizenship for U.S.-born children of non-citizens. On this same date, Senator Lindsey Graham of South Carolina said he would introduce legislation in Congress to accomplish the same thing. Jon Feere, of the Center for Immigration Studies (CIS), has said that "Several legal scholars and political scientists who have delved into the history of the 14th Amendment have concluded that 'subject to the jurisdiction thereof' has no plain meaning". Commenting on Trump's idea of an executive order, Speaker of the House Paul Ryan said "you obviously cannot do that.... I think in this case the 14th Amendment is pretty clear, and that would involve a very, very lengthy constitutional process." Mark Krikorian, executive director of the CIS, said that if Trump follows through on his plan, "This will set up the court fight.... the order will be enjoined, [and the] case will eventually reach [the Supreme Court], which then will finally have to rule on the meaning of 'subject to the jurisdiction'." Neither Trump's promised executive order nor Graham's planned bill materialized before Trump left office in January 2021.

Cases
At the United States Supreme Court:
 * The Schooner Exchange v. M'Faddon,
 * Dred Scott v. Sandford,
 * Slaughterhouse Cases,
 * Elk v. Wilkins,
 * United States v. Wong Kim Ark,
 * Hennessy v. Richardson Drug Co.,
 * Schick v. United States,
 * Kwock Jan Fat v. White,
 * Weedin v. Chin Bow,
 * Morrison v. California,
 * Perkins v. Elg,
 * Regan v. King, (certiorari denied)
 * Reid v. Covert,
 * Nishikawa v. Dulles,
 * Kennedy v. Mendoza-Martinez,
 * Rogers v. Bellei,
 * Plyler v. Doe,

At the United States courts of appeals:
 * In re Look Tin Sing, 21 F. 905 (Cir.Cal. 1884)
 * Ex parte Chin King and Ex parte Chan San Hee, 35 F. 354 (Cir.Ore. 1888)
 * Gee Fook Sing v. U.S., 49 F. 146 (9th Cir. 1892)
 * Regan v. King, 134 F.2d 413 (9th Cir. 1943)
 * Rabang v. INS, 35 F.3d 1449 (9th Cir. 1994)
 * Valmonte v. INS, 136 F.3d 914 (2nd Cir. 1998)
 * Oforji v. Ashcroft, 354 F.3d 609 (7th Cir. 2003)
 * Nolos v. Holder, 611 F.3d 279 (5th Cir. 2010)

At United States district courts:
 * In re Wong Kim Ark, 71 F. 382 (N.D.Cal. 1896)
 * Regan v. King, 49 F. Supp. 222 (N.D.Cal. 1942)

In state courts:
 * Lynch v. Clarke, 3 N.Y.Leg.Obs. 236 (N.Y. 1844)

title: United States v. Wong Kim Ark


text:
Epigoni

In Greek mythology, the Epigoni or Epigonoi (from Ἐπίγονοι, meaning "offspring") are the sons of the Argive heroes, the Seven against Thebes, who had fought and been killed in the first Theban war, the subject of the Thebaid, in which Polynices and his allies attacked Thebes because Polynices' brother, Eteocles, refused to give up the throne as promised. The second Theban war, also called the war of the Epigoni, occurred ten years later, when the Epigoni, wishing to avenge the death of their fathers, attacked Thebes.

List of Epigoni
According to the mythographer Apollodorus, they were:
 * Aegialeus, son of Adrastus
 * Alcmaeon, son of Amphiaraus
 * Amphilochus, son of Amphiaraus
 * Diomedes, son of Tydeus
 * Euryalus, son of Mecisteus
 * Promachus, son of Parthenopaeus
 * Sthenelus, son of Capaneus
 * Thersander, son of Polynices

To this list, the geographer Pausanias also adds:
 * Polydorus, son of Hippomedon
 * Adrastus and Timeas, sons of Polynices

Hyginus also makes note of:
 * Biantes and Tlesimenes, sons of Parthenopaeus

The war
Both Apollodorus and Pausanias tell the story of the war of the Epigoni, although their accounts differ in several respects. According to Apollodorus, the Delphic oracle had promised victory if Alcmaeon was chosen their leader, and so he was. Aegialeus was killed by Laodamas, son of Eteocles, but Alcmaeon killed Laodamas. The Thebans were defeated and, by the counsel of the seer Teiresias, fled their city. However, Pausanias says that Thersander was their leader, that Laodamas fled Thebes with the rest of the Thebans, and that Thersander became king of Thebes.

As a poetic theme
Epigoni was an early Greek epic on this subject; it formed a sequel to the Thebaid and therefore was grouped by Alexandrian critics in the Theban cycle. Some counted it not as a separate poem but as the last part of the Thebaid. Only the first line is now known:

 * Now, Muses, let us begin to sing of younger men ...

Epigoni was a lost Greek tragedy by Sophocles. A few lines from this text have long been known because they were quoted in commentaries and lexica by ancient scholars. An additional fragment of several lines was discovered in 2005.

In art
There were statues of the Epigoni at Argos and Delphi.

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

title: Epigoni


text: User talk:68.54.148.47

title: User talk:68.54.148.47


text: User talk:68.123.10.76

title: User talk:68.123.10.76


text:
Talk:Bibliography of Ayn Rand and Objectivism

comments
Good idea -- and nice job merging the criticisms section of the Objectivism page.

I think I can probably pull some additional titles out of my literature review and add them here. Alternatively, if somebody else wants to see my review, I'll send it to you on rquest.

Scottryan 22:30, 5 May 2004 (UTC)

Some descriptions of the critiques describe their utility, which is very subjective unless one has an agenda to refute Ayn Rand, in which case it's POV. I'm considering removing the judgments of the quality of the articles, unless someone can tell me why they belong there. --24.118.77.253 00:01, 28 Mar 2005 (UTC)

Works by Objectivists vs. Works on Objectivism
Looking at the list of of "Works by other Objectivist writers," there appear to be a number of items that are by authors who may happen to be Objectivists, but which are not about Rand or Objectivism. For example, the first work listed, Martin Anderson's The Federal Bulldozer does not contain the word 'Rand' or the word 'Objectivism' according to Google book search, nor have I ever seen it included on a list of works about Objectivism anywhere except here. Perhaps I'm missing the point of this article, but it is titled "Bibliography of work on Objectivism." I think including works by "Objectivist writers" is only appropriate if the work itself discusses Rand and/or Objectivism. Does anyone disagree? --RL0919 (talk) 19:35, 20 May 2009 (UTC)
 * Perhaps we need a new title, one that suggests the inclusion of Peikoff's Ominous Parallels and excludes Anderson's The Federal Bulldozer. --Karbinski (talk) 21:34, 20 May 2009 (UTC)

 * The Ominous Parallels does discuss Objectivism and has an introduction by Rand, so I think it would be included in any list of books by/about Rand/Objectivism. Anderson's book (and some others) seems out of place, but I wanted to make sure I wasn't missing anything about the intention of the list. --RL0919 (talk) 22:23, 20 May 2009 (UTC)

Article Divisions
I'd like to solicit input on the current division of the non-Rand works between "Objectivist" and "Critiques." There are POV issues with this arrangement. Some Objectivists would object to (for example) David Kelley's later works being included as the work of an Objectivist. Others might not consider some of the "critiques" to be particularly critical (e.g., Scibarra's Ayn Rand: The Russian Radical). There also doesn't seem to be a place for works by non-Objectivists that are not critiques, such as Mimi Reisel Gladstein's The Ayn Rand Companion (which isn't listed but should be). So my thought is to scrap the division and just list every book except Rand's in an "Other Books about Objectivism" section. Then have separate sections or subsections for other media (periodicals, articles, films, etc.). Thoughts? (I know, I'm not very bold.) --RL0919 (talk) 00:57, 23 May 2009 (UTC)
 * I decided to take the plunge and reorganize along the lines I discussed above. Because the different lists weren't formatted the same way, the current list is transitional. Stuff to do:
 * Switch the entries originally on the "critiques" list to use the same citation format as the other entries. done
 * Add missing entries. done for books; more articles/book chapters/pamphlets/etc. could be added if desired
 * Add details (ISBN numbers, etc.) for individual entries. done

--RL0919 (talk) 15:43, 23 May 2009 (UTC)
 * Updated above. --RL0919 (talk) 23:17, 27 May 2009 (UTC)

Inclusion criteria
Per discussion on the cross-talk page, this article needs more clarity around the criteria for what works should or should not be included. So here are some thoughts.

General:
 * Since this is the English Wikipedia, only works in English.
 * No duplications. For books, this means that books with two differently-named versions (such as Nathaniel Branden's memoirs or the Ellis book) should only have one version appear on the list. I'd say the most recent would be appropriate. For other works, this means no items included in other sources, such as anthology books or periodicals, that are mentioned elsewhere in the article.

Books about Ayn Rand or Objectivism:
 * Only books from academic or commercial publishers; no vanity/self-published works.

Other works about Ayn Rand or Objectivism - This is the section that I personally think needs the most consideration and change from what it has currently:
 * Only items explicitly about Rand or Objectivism. That means no articles related only by being written by someone who is/was an Objectivist, citing Rand without making her the specific topic of discussion, or expressing "Objectivist" ideas without identifying them openly as such.
 * I think we should consider restricting the inclusion of essays/articles to only be items published in academic journals or books. The number of articles appearing in non-academic sources is too great to track and many would be of dubious usefulness for readers.

The current lists follow some, but not all, of these criteria to varying degrees, but not consistently or explicitly. Other ideas for inclusion/exclusion would be greatly appreciated. --RL0919 (talk) 00:15, 7 September 2009 (UTC)
 * Looks like a good starter set to me.-RLCampbell (talk) 00:39, 7 September 2009 (UTC)
 * Another criterion: Only serious, non-fiction works. That means no satires or books where Rand is a fictional character. The list currently doesn't have any of these (there are a few), but it should be an explicit criterion. --RL0919 (talk) 01:44, 8 September 2009 (UTC)
 * FAQ-ified. (See top of talk). --Cyber cobra (talk) 04:11, 8 September 2009 (UTC)
 * I made a first pass at weeding the books and "other works" lists based on the criteria above. I think the books list is pretty much in line now. I'm less sure on the other works because a few of the criteria are content-based and I don't have every item readily at hand to confirm them. --RL0919 (talk) 04:34, 8 September 2009 (UTC)

 * Good work on the criteria, all. I would question whether the "only academic" criterion (in the FAQ) is too high – given the historical antipathy between Oism and academia this might exclude some of the more important works on the topic. Skomorokh  15:00, 8 September 2009 (UTC)
 * My concern is that the number of non-academic essays and articles could be unworkably large, so the "Other works" section needs a stricter standard than what we have for books. (The "academic-only" standard is only supposed to apply to the "Other works," although that might not be clear enough in the FAQ.) But the standard doesn't have to be that one in particular. I was just shooting for something objective that would limit the numbers. Alternative suggestions would be welcomed. --RL0919 (talk) 16:22, 8 September 2009 (UTC)
 * Its not clear to me. If someone collected essays explicitly on Objectivism and published them in a book via a university press, would they make it onto the list as the criteria stands right now? --Karbinski (talk) 16:32, 8 September 2009 (UTC)
 * In that case the book should appear on the list of books, but the individual essays should not appear in the list of other works, because of the "no redundancy" criterion. --RL0919 (talk) 16:37, 8 September 2009 (UTC)
 * Ok, that makes sense. How about for standalone articles/essays we require that they be notable, that is - discussed in a secondary source? --Karbinski (talk) 17:15, 8 September 2009 (UTC)
 * It's a possibility, depending on what "discussed in" means. Gladstein's Companion book contains lengthy lists of articles, but doesn't subject most of them to any significant discussion (that is, talking about them beyond including them on a list). So if the standard is discussion, not just listing or citation, that should be relatively limiting. --RL0919 (talk) 17:25, 8 September 2009 (UTC)

Another possible criterion occurs to me: Should explicitly exclude items that are reviews of Rand's books? There are hundreds of those, and most would not be particularly illuminating with regard to her life or ideas. --RL0919 (talk) 17:25, 8 September 2009 (UTC)

Self-published works
The exclusion of self-published/vanity-published works from this bibliography has had unanimous support in the past, so I've continued that exclusion by removing the self-published entries recently added by. There was a question raised about Enclair Publishing, listed by Redthoreau as the publisher of Reconsidering Ayn Rand by Michael Yang. After a bit of checking I discovered that the original publisher of this book was Winepress Publishing, a known vanity publisher. It was switched to Enclair Publishing subsequently. A check on Enclair's barely-working website shows Reconsidering Ayn Rand to be their only publication, and a whois on the domain shows that Michael Yang is its admin. It seems likely that Enclair is just a self-publishing brand adopted as an alternative to the previous vanity publisher. So I've removed it as well. --RL0919 (talk) 22:44, 8 June 2010 (UTC)

 * RL0919, ironically I initially got the titles from --> your own site. I don't see why you would want a Wikipedia bibliography to be less inclusive than your own personal "Objectivism Reference Center"? Additionally, I understand the rationale behind staying away from self-published works as references in articles (if possible), but what would be the rationale of not even including them in a bibliography, even under the sub-title of "self published works"? Certainly Wiki readers can decide the level of credibility to lend to such texts.   Red thoreau  -- (talk) 23:06, 8 June 2010 (UTC)

 * There is often more detail on specialty sites than there is in a Wikipedia article, but really it makes little difference to me personally whether self-published works are included or not. When I first started revamping this page last year, I left them in, but another editor removed them and there seemed to be agreement from everyone else who commented that removing them was the right way to go. I'm just maintaining that prior consensus. If a new consensus forms to include them, I'll follow it instead. However, if self-published works are to be included, then there are a bunch more than the ones you added. We should at least be consistent: exclude them all or include them all. --RL0919 (talk) 23:15, 8 June 2010 (UTC)

 * RL0919, certainly I would want all of the SP's to be included to be consistent. My vote would be for inclusion (as I believe a bibliography should be as inclusive as possible), but I'll let that be a matter of WP:Consensus if you would rather wait.   Red thoreau  -- (talk) 23:53, 8 June 2010 (UTC)


text:
CRA

CRA is an abbreviation for:

Companies

 * Conestoga-Rovers & Associates, a consulting engineering firm in Waterloo, Ontario, Canada
 * Convenience Retail Asia, Hong Kong
 * Conzinc Riotinto of Australia
 * CRA International, a consultancy

Credit reporting

 * Credit bureau, known as consumer reporting agency (CRA) in the US, and credit rating agency (CRA) in the UK

Job titles

 * Certified Research Administrator
 * Clinical research associate or Clinical Research Assistant in clinical trial
 * Commander, Royal Artillery

Laws

 * Civil Rights Act (disambiguation), multiple US legislation
 * Community Reinvestment Act of 1977 (US)
 * Congressional Review Act of 1996 (US)
 * Constitution Restoration Act of 2004/2005
 * Cyber Resilience Act, EU, 2022

Australia

 * Christian Research Association
 * Commercial Radio Australia

Canada

 * Canada Revenue Agency, administering tax laws
 * Canadian Rheumatology Association, the national professional association for Canadian rheumatologists

Colombia

 * Potable Water and Basic Sanitation Regulation Commission

Morocco

 * Chabab Rif Al Hoceima, a football club
 * Chabab Rif Al Hoceima (basketball)

Singapore

 * Casino Regulatory Authority of Singapore

United Kingdom

 * Cambridgeshire Rowing Association
 * Congo Reform Association

United States

 * Congress of Russian Americans, Russian émigré organization
 * Champion Racing Association, auto racing sanctioning body
 * Community redevelopment agency, urban renewal body
 * Computing Research Association, academic department association
 * Corn Refiners Association, trade association
 * Critical Research Academy, a College of Education graduate program
 * California Roadster Association, a racing governing body

Other

 * Community reinforcement approach to therapy for addiction
 * Corona Australis (CrA), a constellation in the Southern Hemisphere

title: CRA


text: User talk:69.193.133.81

title: User talk:69.193.133.81


text:
WODC

WODC (93.3 FM) – branded as 93.3 The Bus – is a commercial classic hits radio station licensed to Ashville, Ohio, serving Columbus and the Columbus metro area. Owned by iHeartMedia, Inc., the WODC studios are located in Downtown Columbus, while its transmitter resides near Obetz. In addition to a standard analog transmission, WODC broadcasts over three HD Radio channels, and streams online via iHeartRadio.

Early years (1961–2004)

Originally located at 94.3 FM, WFCB was called "WFCB-94.3", but to clear a 2002 move from Chillicothe to Ashville, frequencies were to be exchanged between WFCB and WKKJ. WKKJ was a sister Clear Channel station also in Chillicothe, but operating at 93.3 MHz, playing country music. After the switch, WFCB was re-imaged as "Mix 93.3", but continued to run and be staffed from Chillicothe.

Adult contemporary (2004–2011)
When WFCB's transmitter was officially moved to Obetz on January 1, 2004, the station was flipped to "93.3 Lite FM" and the calls were changed to WLZT. The positioner eventually transitioned from "93.3 Lite FM" to "93.3 WLZT" when the station switched to a more gold-based adult contemporary or classic hits format. After several musical changes, the station re-imaged as "Soft Rock 93.3" in May 2010.

Classic hits (2011–2015)
On September 2, 2011, on Labor Day weekend, the station began stunting with "America's Top 500." The following Tuesday at 9 a.m., following the holiday, after playing "American Pie" by Don McLean, the station switched to classic hits as "Oldies 93.3." On September 29, 2011, the callsign was changed from WLZT to WODC. In February 2014, 1980s music was added and the "Oldies 93.3" moniker was dropped, and was rebranded as "93.3 WODC."

Adult hits (2015–2021)
At midnight on December 28, 2015, WODC relaunched with an adult hits format, and rebranded as "93.3 The Bus".

A couple of times each year, mostly on holiday weekends that start on Friday and end on Monday (Memorial Day and Labor Day), WODC does an "All-80's Weekend".

Every November, WODC switches over to Christmas music and plays it continuously through Christmas Day.

Classic hits (2021–present)
In August 2021, WODC repositioned itself as “Columbus’ Classic Hits” and added on-air staff, while retaining the “Bus” branding. The station transitioned back to a classic hits format, with a more focused playlist on music from the 1970s through 1990s.

In late January 2022, WODC brought back Casey Kasem's American Top 40 every Sunday mornings from 8am to 12 noon. The station previously aired the show with episodes from the 70s and 80s on Sunday mornings from April 2011 to February 2019.

title: WODC


text:
Bipolar violation

A bipolar violation, bipolarity violation, or BPV, is a violation of the bipolar encoding rules where two pulses of the same polarity occur without an intervening pulse of the opposite polarity. This indicates an error in the transmission of the signal.

T-carrier and E-carrier signals are transmitted using a scheme called bipolar encoding, a.k.a. Alternate Mark Inversion (AMI), where ONE is represented by a pulse, and a ZERO is represented by no pulse. Pulses (which represent ones) always alternate in polarity, so that if, for example two positive pulses are received in succession, the receiver knows that an error occurred (a violation) in that one or more bits were either added or deleted from the original signal.

Reliable transmission of data using this scheme requires a regular stream of pulses; too many zero bits in succession can cause a loss of synchronization between transmitter and receiver. To ensure that this is always present, there exist a number of modified AMI codes which use judiciously placed bipolar violations to encode long strings of consecutive zeroes.

title: Bipolar violation


text:
Nosebleed

A nosebleed, also known as epistaxis, is an instance of bleeding from the nose. Blood can flow down into the stomach, and cause nausea and vomiting. In more severe cases, blood may come out of both nostrils. Rarely, bleeding may be so significant that low blood pressure occurs. Blood may also be forced to flow up and through the nasolacrimal duct and out of the eye, producing bloody tears.

Risk factors include trauma, including putting the finger in the nose, blood thinners, high blood pressure, alcoholism, seasonal allergies, dry weather, and inhaled corticosteroids. There are two types: anterior, which is more common; and posterior, which is less common but more serious. Anterior nosebleeds generally occur from Kiesselbach's plexus while posterior bleeds generally occur from the sphenopalatine artery or Woodruff's plexus. The diagnosis is by direct observation.

Prevention may include the use of petroleum jelly in the nose. Initially, treatment is generally the application of pressure for at least five minutes over the lower half of the nose. If this is not sufficient, nasal packing may be used. Tranexamic acid may also be helpful. If bleeding episodes continue, endoscopy is recommended.

About 60% of people have a nosebleed at some point in their life. About 10% of nosebleeds are serious. Nosebleeds are rarely fatal, accounting for only 4 of the 2.4 million deaths in the U.S. in 1999. Nosebleeds most commonly affect those younger than 10 and older than 50.

Cause
Nosebleeds can occur due to a variety of reasons. Some of the most common causes include trauma from nose picking, blunt trauma (such as a motor vehicle accident), or insertion of a foreign object (more likely in children). Low relative humidity (such as in centrally heated buildings), respiratory tract infections, chronic sinusitis, rhinitis or environmental irritants can cause inflammation and thinning of the tissue in the nose, leading to a greater likelihood of bleeding from the nose.

Most causes of nose bleeding are self-limiting and do not require medical attention. However, if nosebleeds are recurrent or do not respond to home therapies, an underlying cause may need to be investigated. Some rarer causes are listed below:

Coagulopathy
 * Thrombocytopenia (thrombotic thrombocytopenic purpura, idiopathic thrombocytopenic purpura)
 * Von Willebrand's disease
 * Hemophilia
 * Leukemia
 * HIV
 * Chronic liver disease—cirrhosis causes deficiency of factor II, VII, IX,& X

Dietary
 * Sulfur dioxide (sulphur dioxide) E220 (as a food preservative used particularly in wines, dried fruits, etc. )
 * Sulphites as food preservatives
 * Salicylates naturally occurring in some fruits and vegetables

Inflammatory
 * Granulomatosis with polyangiitis
 * Systemic lupus erythematosus

Medications/Drugs
 * Anticoagulation (warfarin, heparin, aspirin, etc.)
 * Insufflated drugs (particularly cocaine)
 * Nasal sprays (particularly prolonged or improper use of nasal steroids)

Neoplastic
 * Squamous cell carcinoma
 * Adenoid cystic carcinoma
 * Melanoma
 * Nasopharyngeal carcinoma
 * Nasopharyngeal angiofibroma
 * Nosebleeds can be a sign of cancer in the sinus area, which is rare, or tumors starting at the base of the brain, such as meningioma. Due to the sensitive location, nosebleeds caused by tumors are typically associated with other symptoms, such as hearing or vision problems.

Traumatic
 * Anatomical deformities (e.g. septal spurs)
 * Blunt trauma (usually a sharp blow to the face such as a punch, sometimes accompanying a nasal fracture)
 * Foreign bodies (such as fingers during nose-picking)
 * Digital trauma (nose picking)
 * Middle ear barotrauma (such as from descent in aircraft or ascent in scuba diving)
 * Nasal bone fracture
 * Septal fracture/perforation
 * Intranasal tumors (e.g. Nasopharyngeal carcinoma or nasopharyngeal angiofibroma)
 * Nasal cannula O2 (tending to dry the olfactory mucosa)
 * Nasal sprays (particularly prolonged or improper use of nasal steroids)
 * Surgery (e.g. septoplasty and functional endoscopic sinus surgery)
 * Leech infestation
 * Nasal bleeds may be due to fracture of facial bones namely maxilla and zygoma.

Vascular
 * Hereditary hemorrhagic telangiectasia (Osler–Weber–Rendu disease)
 * Angioma
 * Aneurysm of the carotid artery

Pathophysiology
The nasal mucosa contains a rich blood supply that can be easily ruptured and cause bleeding. Rupture may be spontaneous or initiated by trauma. Nosebleeds are reported in up to 60% of the population with peak incidences in those under the age of ten and over the age of 50 and appear to occur in males more than females. An increase in blood pressure (e.g. due to general hypertension) tends to increase the duration of spontaneous epistaxis. Anticoagulant medication and disorders of blood clotting can promote and prolong bleeding. Spontaneous epistaxis is more common in the elderly as the nasal mucosa (lining) becomes dry and thin and blood pressure tends to be higher. The elderly are also more prone to prolonged nosebleeds as their blood vessels are less able to constrict and control the bleeding.

The vast majority of nosebleeds occur in the front anterior (front) part of the nose from the nasal septum. This area is richly endowed with blood vessels (Kiesselbach's plexus). This region is also known as Little's area. Bleeding farther back in the nose is known as a posterior bleed and is usually due to bleeding from Woodruff's plexus, a venous plexus situated in the posterior part of inferior meatus. Posterior bleeds are often prolonged and difficult to control. They can be associated with bleeding from both nostrils and with a greater flow of blood into the mouth.

Sometimes blood flowing from other sources of bleeding passes through the nasal cavity and exits the nostrils. It is thus blood coming from the nose but is not a true nosebleed, that is, not truly originating from the nasal cavity. Such bleeding is called "pseudoepistaxis" (pseudo + epistaxis). Examples include blood coughed up through the airway and ending up in the nasal cavity, then dripping out.

Prevention
People with uncomplicated nosebleeds can use conservative methods to prevent future nosebleeds such as sleeping in a humidified environment or applying petroleum jelly to the nasal nares.

Individuals who suffer from nosebleeds regularly, especially children, are encouraged to use over-the-counter nasal saline sprays and avoid vigorous nose-blowing as preventative measures.

Treatment
Most anterior nosebleeds can be stopped by applying direct pressure, which helps by promoting blood clots. Those who have a nosebleed should first attempt to blow out any blood clots and then apply pressure to the soft anterior part of the nose (by pinching the nasal ala; not the bony nasal bridge) for at least five minutes and up to 30 minutes. Pressure should be firm and tilting the head forward helps decrease the chance of nausea and airway obstruction due to blood dripping into the airway. When attempting to stop a nosebleed at home, the head should not be tilted back. Swallowing excess blood can irritate the stomach and cause vomiting. Vasoconstrictive medications such as oxymetazoline (Afrin) or phenylephrine are widely available over the counter for treatment of allergic rhinitis and may also be used to control benign cases of epistaxis. For example, a few sprays of oxymetazoline may be applied into the bleeding side(s) of the nose followed by application of direct pressure. Those with nosebleeds that last longer than 30 minutes (despite use of direct pressure and vasoconstrictive medications such as oxymetazoline) should seek medical attention.

Chemical Cauterization
This method involves applying a chemical such as silver nitrate to the nasal mucosa, which burns and seals off the bleeding. Eventually the nasal tissue to which the chemical is applied will undergo necrosis. This form of treatment is best for mild bleeds, especially in children, that are clearly visible. A topical anesthetic (such as lidocaine) is usually applied prior to cauterization. Silver nitrate can cause blackening of the skin due to silver sulfide deposit, though this will fade with time. Once the silver nitrate is deposited, saline may be used to neutralize any excess silver nitrate via formation of silver chloride precipitate.

Nasal packing
If pressure and chemical cauterization cannot stop bleeding, nasal packing is the mainstay of treatment. Nasal packing is typically categorized into anterior nasal packing and posterior nasal packing. Nasal packing may also be categorized into dissolvable and non-dissolvable types.

Dissolvable nasal packing materials stop bleeding through use of thrombotic agents that promote blood clots, such as surgicel and gelfoam. The thrombogenic foams and gels do not require removal and dissolve after a few days. Typically, dissolvable nasal packing is first attempted; if the bleeding persists, non-dissolvable nasal packing is the next option.

Traditionally, nasal packing was accomplished by packing gauze into the nose, thereby placing pressure on the vessels in the nose and stopping the bleeding. Traditional gauze packing has been replaced with other non-dissolvable nasal packing products such as Merocel and the Rapid Rhino. The Merocel nasal tampon is similar to gauze packing except it is a synthetic foam polymer (made of polyvinyl alcohol and expands in the nose after application of water) that provides a less hospitable medium for bacteria. The Rapid Rhino stops nosebleeds using a balloon catheter, made of carboxymethylcellulose, which has a cuff that is inflated by air to stop bleeding through extra pressure in the nasal cavity. Systematic review articles have demonstrated that the efficacy in stopping nosebleeds is similar between the Rapid Rhino and Merocel packs; however, the Rapid Rhino has been shown to have greater ease of insertion and reduced discomfort. Posterior nasal packing can be achieved by using a Foley catheter, blowing up the balloon when it is in the back of the throat, and applying anterior traction so that the inflated balloon occludes the choanae. Patients who receive non-dissolvable nasal packing need to return to a medical professional in 24–72 hours in order to have packing removed. Complications of non-dissolvable nasal packing include abscesses, septal hematomas, sinusitis, and pressure necrosis. In rare cases toxic shock syndrome can occur with prolonged nasal packing. As a result, any patient who has non-dissolvable nasal packing should be given prophylactic antibiotic medication to be taken as long as the nasal packing remains in the nose.

Surgery
Ongoing bleeding despite good nasal packing is a surgical emergency and can be treated by endoscopic evaluation of the nasal cavity under general anesthesia to identify an elusive bleeding point or to directly ligate (tie off) the blood vessels supplying the nose. These blood vessels include the sphenopalatine, anterior and posterior ethmoidal arteries. More rarely the maxillary or a branch of the external carotid artery can be ligated. The bleeding can also be stopped by intra-arterial embolization using a catheter placed in the groin and threaded up the aorta to the bleeding vessel by an interventional radiologist. There is no difference in outcomes between embolization and ligation as treatment options, but embolization is considerably more expensive. Continued bleeding may be an indication of more serious underlying conditions.

Tranexamic acid
Tranexamic acid helps promote blood clotting. For nosebleeds it can be applied to the site of bleeding, taken by mouth, or injected into a vein.

Other
The utility of local cooling of the head and neck is controversial. Some state that applying ice to the nose or forehead is not useful. Others feel that it may promote vasoconstriction of the nasal blood vessels and thus be useful. In Indonesian traditional medicine, betel leaf is used to stop nosebleeds as it contains tannin which causes blood to coagulate, thus stopping active bleeding.

Society and culture
In the visual language of Japanese manga and anime, nosebleeding often indicates that the bleeding person is sexually aroused. In Western fiction, nosebleeds often signify intense mental focus or effort, particularly during the use of psychic powers.

In American and Canadian usage, "nosebleed section" and "nosebleed seats" are common slang for seating at sporting or other spectator events that are the highest up and farthest away from the event. The reference alludes to the propensity for nasal hemorrhage at high altitudes, usually owing to lower barometric pressure.

The oral history of the Native American Sioux tribe includes reference to women who experience nosebleeds as a result of a lover's playing of music, implying sexual arousal.

In the Finnish language, "picking blood from one's nose" and "begging for a nosebleed" are commonly used in abstract meaning to describe self-destructive behaviour, for example ignoring safety procedures or deliberately aggravating stronger parties.

In Filipino slang, to "have a nosebleed" is to have serious difficulty conversing in English with a fluent or native English speaker. It can also refer to anxiety brought on by a stressful event such as an examination or a job interview.

In the Dutch language, "pretending to have a nosebleed" is a saying that means pretending not to know anything about something.

Etymology
The word epistaxis is from ἐπιστάζω epistazo, "to bleed from the nose" from ἐπί epi, "above, over" and στάζω stazo, "to drip [from the nostrils]".

title: Nosebleed


text: User talk:67.33.98.139

title: User talk:67.33.98.139


text:
Los Angeles Express (USFL)

The Los Angeles Express was a team in the United States Football League (USFL) based in Los Angeles, California. Playing at the Los Angeles Memorial Coliseum, the Express competed in all three of the USFL seasons played between 1983 and 1985.

History
Cable television pioneers Alan Harmon and Bill Daniels were awarded a USFL franchise for San Diego when the league announced its formation in 1982. However, the city refused to grant the team a lease to play at Jack Murphy Stadium under pressure from the stadium's existing tenants—baseball's Padres, the NFL's Chargers, and the NASL's Sockers. The only other outdoor facility available in the area was Balboa Stadium, the original home of the Chargers. However, it was a relatively antiquated facility (built in 1915) that had not had a major tenant since the Chargers moved into Jack Murphy in 1967, and was now largely used by high school teams. This was an untenable situation for a team that was aspiring to be part of a major sports league.

With only eight months before the season was to start, Harmon and Daniels decided to move to Los Angeles with the league's blessing. League officials believed that Harmon and Daniels' ties to the cable industry could help the league get exposure; David Dixon's blueprint for the league depended heavily on television coverage. They forced Jim Joseph, second owner of the Los Angeles USFL franchise, to give up his rights to Los Angeles in favor of Harmon and Daniels. Joseph relocated his franchise to Phoenix, Arizona as the Arizona Wranglers.

1983 season
The Los Angeles Express drafted Dan Marino as the first pick in USFL history. Marino made some appearances on behalf of the Express before signing with the Miami Dolphins.

The Express also made a serious run at Eric Dickerson, and actually matched the Los Angeles Rams' offer for him. However, Dickerson signed with the Rams, apparently because family members were skeptical about the USFL.

Television star Lee Majors became part owner in April 1983.

The Express ownership lured Canadian Football League legend Hugh Campbell, head coach of the Edmonton Eskimos, to be their first head coach. (Campbell had taken over the Eskimos in 1977 and in his six years had taken the team to six straight Grey Cup games, winning the last five.)

The 1983 Express team was a competitive team headed by quarterbacks Tom Ramsey and Mike Rae and led by an above average defense. Despite losing two defensive backs to knee injuries, the Express finished fifth in the league in total defense.

However, a patchwork offensive line limited the team's offensive firepower. The Express had the worst rushing attack in the league. Herschel Walker rushed for 72 more yards than the entire Express team in 1983. Despite this, the Pacific Division was so weak that the Express were actually in contention for the division title with two weeks to go in the season. However, upset losses to the New Jersey Generals and Washington Federals in weeks 16 and 17 respectively cost the Express the Pacific Division title and allowed the Oakland Invaders to claim the last 1983 playoff berth.

Southern Californians viewed the Express largely with indifference. They only drew 19,000 people per game, failing to top 17,000 in their last four games. The crowds looked even smaller than that due to the cavernous size of the Coliseum, which seated almost 95,000 people at the time, far and away the largest stadium in pro football. However, it was far too big for an NFL team (the Los Angeles Raiders, and the Rams before them, were plagued with local blackouts even in their best years), let alone a USFL team. It was so spread out that even crowds of 25,000 —a decent-sized crowd by USFL standards— were swallowed up in the environment.

While Harmon and Daniels knew that the Express were going to be a hard sell, the poor gate surprised even them. Additionally, television ratings for USFL games in the Los Angeles market were so low that they significantly held down the league's average television ratings.

1983 schedule and results
Sources

1984 season
Harmon and Daniels grew alarmed at their fellow owners' increasingly reckless spending. They had also tired of commuting from their base in Denver to Los Angeles for games. They put the Express up for sale, and found a buyer in mortgage banker J. William Oldenburg, who bought the team for $7.5 million. Soon after taking over, Oldenburg hired veteran NFL executive Don Klosterman as general manager and former Chargers and Los Angeles Rams quarterback John Hadl as head coach.

Oldenburg told Klosterman that money was no object, and he was to sign the best 40-man roster he could find. As Klosterman put it, Oldenburg wanted to "design a car to go 180 miles an hour." Klosterman signed 31 players in two months for a total of $12 million. Among other things, he spent a total of $8 million to sign four of the best offensive linemen in college football, giving the Express the most expensive offensive line in all of professional football. One of the new signees, kicker Tony Zendejas, recalled being stunned at the number of luxury cars in the players' parking lot.

Klosterman and Oldenburg's biggest prize was Steve Young, a quarterback who had played at the namesake university of his lineal ancestor, Brigham Young University. Agent Leigh Steinberg negotiated for Young what was then reported to be the largest professional sports contract ever signed – a 10-year deal worth over US$40 million. The payments were to be in the form of an annuity set up to pay him $1 million annually for the next 42 years, so the value of the contract was considerably less than stated.

The NFL also noticed the Express' stockpiling of talent: in the 1984 NFL Supplemental Draft of USFL and CFL players, no fewer than twenty Express players were picked, including four of the first six selections and eleven in just the opening round. But despite the all-star lineup, the team struggled to compete with the popularity of the Raiders (who had just won the Super Bowl) and the Rams: the Express only drew 15,361 people per game, down from 19,713 a year earlier. On three occasions, the team drew crowds of fewer than 11,000 people. Largely due to the poor attendance, they reportedly lost $15 million.

In spite of its overwhelming talent and one of the league's highest payrolls, the young team struggled with adjusting to the pro game and several injuries, losing their first four home games and only finishing two games over .500 at 10–8; however, this was enough to tie the Wranglers for first place in the Pacific Division. The Express won the division title on a tiebreaker, and got to play the Michigan Panthers, who had limped into the playoffs with a 4–8 record in their last 12 games since losing star wide receiver Anthony Carter for the season, while Arizona got Jim Kelly's red hot 13–5 Houston Gamblers. The playoff game against the Panthers drew only 7,964 fans, which looked tiny in the huge Coliseum. As it turned out, the contest was the longest in professional football history: a three-overtime, 93 minute and 33 second marathon won by the Express 27–21 on a touchdown run by Mel Gray. (This proved painful for both teams: Gray broke his arm on the play, and the Panthers never played again, merging over the winter with the Oakland Invaders.)

The Wranglers upset the Gamblers 17–16 on a late rally, which normally would have given the Express the right to host the conference championship game against the Wranglers. But since the Coliseum was being readied for the 1984 Summer Olympics, the game was shifted to the Wranglers' home, Sun Devil Stadium in Tempe, Arizona. However, moving the game created another problem: with daytime temperatures in Arizona well above 100 degrees on that July day, local doctors and other officials implored the league to move the contest to nighttime, which they did. Unfortunately, this meant the game would be aired starting at 11:30pm on the east coast, which didn't exactly help TV ratings (and, even after sundown, temps were still in the nineties at game time). League officials were nonetheless relieved when the game attracted a solid crowd of 33,188, which would have looked extremely sparse in the Coliseum. (Arizona won, 35–23, and advanced to the USFL title game, which they lost to Philadelphia.)

1984 schedule and results
Sources

Offseason disaster
Then, just as quickly as the Express rose, they fell. Midway through the season, the FBI began investigating Oldenburg's financial dealings. Multiple exposés by The Wall Street Journal and The New York Times revealed Oldenburg not only had a habit of luring savings and loans into questionable deals, but was also nowhere near as well off as he had long claimed.

In its bid to gain credibility with the sporting public, the USFL stressed that it required potential owners to undergo an exhaustive due diligence and meet strict capitalization requirements. However, it emerged that the owners largely dispensed with these normal procedures after the 1983 season, largely because as they were determined to expand the league to eighteen teams. The league was desperate to ensure an apparently solid owner in the nation's second-largest market, and with no other serious bidders for the Express they did not conduct any meaningful vetting of Oldenburg's finances. While Oldenburg had gained a reputation as the enfant terrible of the league, no one even suspected that he was a fraud until the FBI and newspaper investigations revealed that he had virtually no money. When he applied to buy the Express, he claimed to have net worth of $100 million, which on paper would have given him more than enough net worth to buy the team. Subsequent investigations suggested that much of that figure came from buying a piece of property for a discount, then selling it to a small bank that he owned for ten times its actual worth.

Late in the season, just days after the Times article, Oldenburg told league officials that he could no longer afford to pay the Express' bills. The league required all owners to post a $1.3 million letter of credit for just such an emergency; it tapped into the Express' letter of credit to cover expenses. The owners also agreed to chip in $500,000 to keep the team going through the playoffs. Even this wasn't enough to prevent their equipment from being confiscated after the Western Conference title game because Oldenburg had failed to pay an equipment company $13,000. By the time that Oldenburg had walked away from the team, office employees and landscaping contractors were going unpaid.

Real estate magnate and Houston Gamblers minority owner Jay Roulier got preliminary approval to take over the team in October. Despite this, the turmoil surrounding the Express led league insiders and reporters to wonder when, not if, the team would implode, even with the trove of talent on the roster. That implosion happened in February 1985, when Roulier's lawyer sounded wary about discussing her boss's finances with league executive director and general counsel Bill McSherry. Suspecting that Roulier was less than advertised, league officials launched an investigation. It turned out that Roulier, like Oldenburg, had deceived league officials about his net worth. He was using the remaining money in the team's league-controlled checking account to send the team to training camp. In short order, league officials pushed Roulier out and took control of the team.

The league could not fold the team because of a clause in its television contract with ABC Sports requiring the league to have teams in the nation's three largest markets. While ABC had not concerned itself with the demise of the Chicago Blitz after the 1984 season, the league's owners feared that ABC would pull its contract if the Express were shut down—an action that would have probably killed the league. Unfortunately, potential buyers were scared off by the prospect of having to assume the burden of the Express' massive payroll.

Under the circumstances, the other owners had no option but to operate the Express as a ward of the league for the 1985 season. McSherry became nominal team president. The owners were required to contribute $500,000 apiece to fund the Express–enough to meet payroll, but little else. Notably, no money was allocated for replacing injured players.

1985 season
The league found itself operating a team for the second year in a row; it had been forced to take over the Blitz after new owner James Hoffman walked away from the team during training camp. However, as bad as the situation with the Blitz had been for the league in 1984, the Express were even worse in 1985. Not only did the Express' roster costs dwarf Chicago's due to the large contracts, but the league had contracted in the off-season and there were only 13 other teams to contribute to supporting the Express.

In what proved to be a harbinger of things to come, the team was evicted from its hotel during training camp after the bill went unpaid. The players were forced to room with each other for the remainder of camp. They also went without water for much of camp after a $136 bill went unpaid. A bank won an attachment on the franchise as part of a lawsuit against Oldenburg after he defaulted on a loan. However, the attachment was withdrawn when bank officials learned they would be responsible for $1.3 million in player salaries that week.

After three close losses to start the season, including the season-opening game against the Houston Gamblers nicknamed "The Greatest Game No One Saw" after the Express surrendered a 20-point lead to the Gamblers to lose 34–33, they went 3–5 in their next eight games. Just when it looked like the season could be salvaged, the injury bug bit the team hard, decimating the roster. Young was among the more prominent casualties. At that point, the season turned into a complete fiasco, and the Express would not win another game. The nine-game losing streak was the second-longest in league history, behind only the Wranglers' 10-game losing streak in 1983. One of those games was a 51–0 thrashing by the Denver Gold—the largest margin of defeat in league history.

The Express' on-field collapse was all the more stunning since this was essentially the same team that had gone all the way to the Western Conference title game a year earlier. However, the rash of injuries made a shambles of the depth chart. At one point late in the season, the team was so short of healthy offensive linemen that one player had to back up the entire starting line. Even without this to consider, the young Express players suspected that the team wouldn't be around for the planned move to the fall in 1986, even if the league managed to survive the 1985 season. With this in mind, they played tentatively, fearing injuries that might diminish their future NFL prospects.

With no money to replace injured players, Klosterman and Hadl had to resort to creative measures to field a team. In one game, they signed a 39-year-old truck driver to start at tackle. For the season finale against Orlando, Young had to line up at running back for most of the second half because the Express didn't have any healthy running backs.

If possible, the off-field situation was even worse. No money was allocated to pay office bills or buy tape for players' ankles. They went for much of the offseason without postage, and had to talk a local company into processing season ticket renewals through their postage meter. The lights and phones were sometimes turned off. They were forced to fire the cheerleaders in a cost-cutting move. Late in the season, there wasn't even a public address announcer.

Even as the team's infrastructure fell apart, the players still got paid, thus avoiding a repeat of situations in Portland, Arizona, Houston and San Antonio. In a bizarre scene, the players rolled into team headquarters in Manhattan Beach in luxury cars and toting Gucci bags, but the grass on the practice fields went uncut for much of the season because the landscapers hadn't been paid.

Attendance continued to plummet; the club drew just 67,533 fans for their eight dates at the Coliseum combined – well short of the stadium's capacity for even a single game – or 8,442 per contest. League commissioner Harry Usher was under fire to find an owner and fix the Express' problem. Desperate for a solution, Usher had the team try a smaller stadium for its final home game: John Shephard Stadium on the campus of Los Angeles Pierce College, a junior college in the San Fernando Valley. The stadium, which had already hosted an Express preseason game in February, increased its capacity to 16,000 for the contest. Usher and the league owners hoped if the game did well they might have some ammunition to land a potential owner.

That game almost didn't occur when the team's bus driver refused to take them to Pierce College without being paid up front, in cash. Young passed a hat around, but no one was willing to chip in. Finally, the trainer offered to cash his check, and the driver took them to the game. However, the contest was still not a sellout; only 8,200 people (barely half of the stadium's capacity, and actually less than their average in the Coliseum) saw Young and the Express lose 21–10 to Doug Williams and the Outlaws. The playing conditions left much to be desired; the field was strewn with rocks and potholes, and some areas were merely painted dirt. The scoreboard was positioned at an angle that made it useless once the sun began setting. While the game drew double what the Express had drawn for their previous two home games at the Coliseum, the experiment was so embarrassing that Usher nearly lost his job.

A week later, they lost to the Renegades, 17–10; as mentioned above, Young had to play part of the game at running back. They were almost stranded in Orlando when the pilot of their charter plane insisted on being paid in advance before allowing the players to board. The team's final record was 3–15, last in the league.

1985 schedule and results
Sources

Demise of the franchise and the league
Unable to find a new owner for the Express, the USFL announced the team would suspend operations for the 1986 season. However, many of the very issues that plagued the Express in 1985 made it very likely the team would not have returned even if the league had succeeded in winning a large payoff from the NFL to finance a move to a fall schedule in 1986. Additionally, the Express would have had to compete against two NFL teams and, if they had returned to the Coliseum, would have had to share their home with one of them (the Raiders) and the University of Southern California's team. In the end, the USFL cancelled its 1986 season, never to return.

Aftermath
After trying all season in 1985, Steve Young and Gary Zimmerman were finally able to buy their way out of the USFL. Both went on to Hall of Fame careers in the NFL.

The "Los Angeles Express" name was briefly revived in 2013 for a proposed A-11 Football League team, but those plans fell through in April 2014 due to California's workers compensation situation.

Single-season leaders

 * Rushing yards: 830 (1984), Kevin Nelson
 * Receiving yards: 889 (1984), Jojo Townsell
 * Passing yards: 2361 (1984), Steve Young

Season-by-season
!Totals || 22 || 34 || 0
 * 1983 || 8 || 10 || 0 || 2nd Pacific || –
 * 1984 || 10 || 8 || 0 || 1st WC Pacific || Won quarterfinal (Michigan) Lost Semifinal (Arizona)
 * 1985 || 3 || 15 || 0 || 7th WC || –
 * 1984 || 10 || 8 || 0 || 1st WC Pacific || Won quarterfinal (Michigan) Lost Semifinal (Arizona)
 * 1985 || 3 || 15 || 0 || 7th WC || –
 * 1985 || 3 || 15 || 0 || 7th WC || –
 * colspan="2"| (including playoffs)

Trivia

 * One last marketing move by the Express just before the league folded was a solicitation to students at USC (located adjacent to the Coliseum) of season passes for $100.
 * The chief operating officer of the Express was former NFL star Fred "Curly" Morrison.
 * The "LAX" pun from the team's pseudo-initials – "LAX" is the well-known International Air Transport Association (IATA) airport code for Los Angeles International Airport – would later be used by the Los Angeles Xtreme of the XFL.
 * While playing for the Express, Steve Young became the first quarterback in professional football history to pass for 300 or more yards and rush for 100 or more yards in a single game.
 * Lisa Moretti was a cheerleader for the team before becoming a professional wrestler.

title: Los Angeles Express (USFL)


text: User talk:157.134.185.122

title: User talk:157.134.185.122