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Prior restraint

Prior restraint (also referred to as prior censorship or pre-publication censorship) is censorship imposed, usually by a government or institution, on expression, that prohibits particular instances of expression. It is in contrast to censorship that establishes general subject matter restrictions and reviews a particular instance of expression only after the expression has taken place.

In some countries (e.g., United States, Argentina ) prior restraint by the government is forbidden, subject to exceptions (such as classifying certain matters of national security), by their respective constitutions.

Prior restraint can be effected in a number of ways. For example, the exhibition of works of art or a movie may require a license from a government authority (sometimes referred to as a classification board or censorship board) before it can be published, and the failure or refusal to grant a license is a form of censorship as is the revoking of a license. It can take the form of a legal injunction or government order prohibiting the publication of a specific document. Sometimes, a government or other party becomes aware of a forthcoming publication on a particular subject and seeks to prevent it: to halt ongoing publication and prevent its resumption. These injunctions are considered prior restraint because potential future publications are stopped in advance. It can also take the form of a (usually secret) policy imposed by a commercial corporation upon its employees, requiring them to obtain written permission to publish a given written work, even one authored outside of work hours produced using their own computing resources.

Exceptions to restrictions
Not all restrictions on free speech are a breach of the prior restraint doctrine. It is widely accepted that publication of information affecting national security, particularly in, may be restricted, even when there are laws that protect freedom of expression. In many cases invocation of national security is controversial, with opponents of suppression arguing that government errors and embarrassment are being covered up; examples are given below.

Publication of information on legal cases in progress may be restricted by an injunction. (Otherwise publishing of material which may affect a case is subject to penalties, but not prevented from the outset.) Text and video information containing illegal context, such as pornography involving underage or unwilling individuals are generally censored in order to protect the victim/s of the material, and preserve the legal and ethical standards of the country/state initiating the censorship of the offensive material.

Blackstone and early views
In William Blackstone's Commentaries "Freedom of the Press" is defined as the right to be free from prior restraints. According to Blackstone, a person should not be punished for speaking or writing the truth with good motives and for justifiable ends. Truth alone, however, was not considered a sufficient justification, if published with bad motives.

"The liberty of the press is indeed essential to the nature of a free state; but this consists in laying no previous restraints upon publications, and not in freedom from censure for criminal matter when published. Every freeman has an undoubted right to lay what sentiments he pleases before the public; to forbid this, is to destroy the freedom of the press; but if he publishes what is improper, mischievous or illegal, he must take the consequence of his own temerity. (4 Bl. Com. 151, 152.)"

This view was the common legal understanding at the time the U.S. Constitution was adopted. Only later have the concepts of freedom of speech and the press been extended (in the United States, the United Kingdom, and other countries sharing their legal tradition) to protect honest error, or truth even if published for questionable reasons.

Judicial view
Prior restraint is often considered a particularly oppressive form of censorship in Anglo-American jurisprudence because it prevents the restricted material from being heard or distributed at all. Other forms of restrictions on expression (such as actions for libel or criminal libel, slander, defamation, and contempt of court) implement criminal or civil sanctions only after the offending material has been published. While such sanctions might lead to a chilling effect, legal commentators argue that at least such actions do not directly impoverish the marketplace of ideas. Prior restraint, on the other hand, takes an idea or material completely out of the marketplace. Thus it is often considered to be the most extreme form of censorship. The United States Supreme Court expressed this view in Nebraska Press Assn. v. Stuart by noting:

"The thread running through all these cases is that prior restraints on speech and publication are the most serious and the least tolerable infringement on First Amendment rights. A criminal penalty or a judgment in a defamation case is subject to the whole panoply of protections afforded by deferring the impact of the judgment until all avenues of appellate review have been exhausted. Only after judgment has become final, correct or otherwise, does the law's sanction become fully operative."

"A prior restraint, by contrast and by definition, has an immediate and irreversible sanction. If it can be said that a threat of criminal or civil sanctions after publication 'chills' speech, prior restraint 'freezes' it at least for the time."

Also, most of the early struggles for freedom of the press were against forms of prior restraint. Thus prior restraint came to be looked upon with a particular horror, and Anglo-American courts became particularly unwilling to approve it, when they might approve other forms of press restriction.

Near v. Minnesota
The first notable case in which the United States Supreme Court ruled on a prior restraint issue was Near v. Minnesota,. In that case the Court held prior restraints to be unconstitutional, except in extremely limited circumstances such as national security issues. The ruling came about after Jay Near's newspaper, The Saturday Press, a small local paper that ran countless exposés of Minneapolis's elected officials' alleged illicit activities, including gambling, racketeering, and graft, was silenced by the Minnesota Gag Law of 1925, also known as The Public Nuisance Law. Near's critics called his paper a scandal sheet, and alleged that he tried to extort money by threatening to publish attacks on officials and others. In the Near case the Court held that the state had no power to enjoin the publication of the paper in this way – that any such action would be unconstitutional under the First Amendment. It wrote:

"If we cut through mere details of procedure, the operation and effect of the statute in substance is that public authorities may bring the owner or publisher of a newspaper or periodical before a judge upon a charge of conducting a business of publishing scandalous and defamatory matter — in particular that the matter consists of charges against public officers of official dereliction — and, unless the owner or publisher is able and disposed to bring competent evidence to satisfy the judge that the charges are true and are published with good motives and for justifiable ends, his newspaper or periodical is suppressed and further publication is made punishable as a contempt. This is of the essence of censorship."

And

"The statute in question cannot be justified by reason of the fact that the publisher is permitted to show, before injunction issues, that the matter published is true and is published with good motives and for justifiable ends. ... it would be but a step to a complete system of censorship. ... The preliminary freedom, by virtue of the very reason for its existence, does not depend, as this court has said, on proof of truth."

This was an extension of the Court's earlier views, which had followed Blackstone. In Patterson v. Colorado, the Court had written: "In the first place, the main purpose of such constitutional provisions is 'to prevent all such previous restraints upon publications as had been practiced by other governments,' and they do not prevent the subsequent punishment of such as may be deemed contrary to the public welfare." (quoted in the Near decision). The Near decision was the first time that it was held that even alleged untruth or malicious intent would not be sufficient reason to impose prior restraints.

Near was decided 5–4. The four dissenting justices strongly approved of the "gag law", and felt that the nature of the articles in The Saturday Press, including their recurrent antisemitism, their frequent (allegedly false) accusations of official misconduct, and their disrespectful and confrontational tone, made them unworthy of protection. But this view did not prevail.

After the Near decision, newspapers had a clearly established freedom to criticize public officials without fear of retribution, even when charges made by the papers could not be proven in court. Newspapers could still be punished through libel laws, if they published material found to be untrue. The "Gag Law" was unique in the United States at that time, and even in Minnesota had only been used on two occasions. Indeed, the Court commented on the unusual nature of the proceeding in its decision.

The Court in Near left open the possibility of prior restraints for various exceptional purposes, such as national security, control of obscenity, and the like. It wrote:

Near's dicta suggest that, while a constitutional prior restraint can exist, the high burden of proof necessary to demonstrate constitutionality results in a presumption of invalidity, and the government bears the burden of showing the restraint's constitutionality.

In a later case (Nebraska Press Ass'n v. Stuart), the Court wrote:

"The principles enunciated in Near were so universally accepted that the precise issue did not come before us again until Organization for a Better Austin v. Keefe, . There the state courts had enjoined the petitioners from picketing or passing out literature of any kind in a specified area. Noting the similarity to Near vs. Minnesota, a unanimous Court held:

Here, as in that case, the injunction operates, not to redress alleged private wrongs, but to suppress, on the basis of previous publications, distribution of literature 'of any kind' in a city of 18,000. . ... . Any prior restraint on expression comes to this Court with a 'heavy presumption' against its constitutional validity. Carroll v. Princess Anne, 393 U.S. 175, 181 (1968); Bantam Books, Inc. v. Sullivan, 372 U.S. 58, 70 (1963). Respondent thus carries a heavy burden of showing justification for the imposition of such a restraint."

This shows the strong later acceptance of what had been a disputed decision when it was first handed down.

Kinney v. Barnes
In the 2012 case of Kinney v. Barnes, Kinney, a legal recruiter, was the subject of inflammatory comments on the website of the company who previously employed him. The company claimed he received extra incentives on the job causing his termination. Kinney filed a defamation suit seeking retraction of the comments and a permanent injunction against any similar future comments being made. The Supreme Court of Texas ruling specifically addressed whether future comments could be barred and whether this would constitute prior restraint. Although the court ruled that the statements posted which were judged to be defamatory could be removed, they did not prohibit similar speech from being posted online at a later time. They reasoned that this would constitute prior restraint and risk producing a chilling effect. The court reasoned, in keeping with a prior decision (Hajek v. Bill Mowbray Motors, Inc., 647 S.W.2d 253, 255 (Tex. 1983)), that the appropriate remedy to defamatory speech was penalization of "what is wrongfully spoken" rather "denial of the right to speak".

Wartime censorship
During World War I, and to a greater extent during World War II, war correspondents accompanied military forces, and their reports were subject to advance censorship to preserve military secrets. The extent of such censorship was not generally challenged, and no major court case arose from this issue. In later conflicts the degree to which war reporting was subject to censorship varied, and in some cases it has been alleged that the censorship was as much political as military in purpose. This was particularly true during the Vietnam War and the 1983 invasion of Grenada.

Pentagon Papers case
In the Pentagon Papers case (New York Times Co. v. United States, ), the Nixon administration sought to enjoin The New York Times and The Washington Post newspapers from publishing excerpts from a top-secret United States Department of Defense history of the United States involvement in the Vietnam War from 1945 to 1971. The government tried to use the "national security" exception that had been suggested in the Near decision. The Supreme Court struck down the injunctions. However, the decision was fragmented, with nine separate opinions being filed in the case. It was not clear at the time what the effect would be on future prior restraint cases.

Scientific American
On March 15, 1950 Scientific American magazine published an article by Hans Bethe about thermonuclear fusion, the mechanism by which stars generate energy and emit electromagnetic radiation (light, etc.). Fusion is also the process which makes the hydrogen bomb (H-bomb) possible. The AEC (Atomic Energy Commission) ordered publication stopped. Several thousand copies of the printed magazine were destroyed, and the article was published with some text removed at the direction of the AEC. At this time there existed in the United States no workable design for a hydrogen bomb (the Teller–Ulam design would not be developed for another year), but the U.S. was engaged in a crash program to develop one. Gerard Piel, the publisher of Scientific American, complained that the AEC was "suppressing information which the American People need in order to form intelligent judgments". Bethe, however, declined to support this complaint, and the suppression of the unedited version of the article was never litigated.

The Progressive
In February 1979, an anti-nuclear activist named Howard Morland drafted an article for The Progressive magazine, entitled "The H-Bomb Secret: To Know How is to Ask Why". The article was an attempt by Morland to publish what he thought the "H-Bomb Secret" was (the Teller–Ulam design), derived from various unclassified sources and informal interviews with scientists and plant workers. Through a number of complicated circumstances, the Department of Energy attempted to enjoin its publication, alleging that the article contained sensitive technical information which was (1) probably derived from classified sources, or (2) became a classified source when compiled in a correct way, even if it were derived from unclassified sources, based on the "born secret" provisions of the 1954 Atomic Energy Act. A preliminary injunction was granted against the article's publication, and Morland and the magazine appealed (United States v. The Progressive, et al.). After a lengthy set of hearings (one in camera, another open to the public), and attracting considerable attention as a "freedom of the press" case, the government dropped its charges after it claimed the case became moot when another bomb speculator (Chuck Hansen) published his own views on the "secret" (many commentators speculated that they were afraid the Atomic Energy Act would be overturned under such scrutiny). The article was duly published in The Progressive (in the November 1979 issue) six months after it was originally scheduled, and remains available in libraries. (As an aside, Morland himself decided that he did not have the secret, and published a "corrected" version a month later.)

Judicial gag orders
Frequently a court will impose advance restrictions on lawyers, parties, and on the press in reporting of trials, particularly criminal trials. These restrictions are intended to protect the right to a fair trial, and to avoid interference with the judicial process. Nonetheless, they are a form of prior restraint, and the press in particular has often objected to such orders.

In Nebraska Press Assn. v. Stuart,, the United States Supreme Court overturned such a "gag order". It ruled that alternative methods to help ensure a fair trial, short of prior restraints, might have been used, and that it was not all clear, under the circumstances, that the gag order would have the desired effect even if upheld. It also made a particular point of asserting that orders restricting reporting on events that occur in open court are not permissible. It wrote:

"To the extent that this order prohibited the reporting of evidence adduced at the open preliminary hearing, it plainly violated settled principles: '[T]here is nothing that proscribes the press from reporting events that transpire in the courtroom.' Sheppard v. Maxwell, (384 U.S., at 362–363)."

The Court's conclusion in this case reaffirmed its general opposition to prior restraints, and indicated that judicial gag orders would be sustained only in exceptional cases. It wrote:

"Our analysis ends as it began, with a confrontation between prior restraint imposed to protect one vital constitutional guarantee and the explicit command of another that the freedom to speak and publish shall not be abridged. We reaffirm that the guarantees of freedom of expression are not an absolute prohibition under all circumstances, but the barriers to prior restraint remain high and the presumption against its use continues intact."

In the United Kingdom judicial gag orders are much more frequently employed, and the strong prejudice against them reflected in the above quote does not seem to be felt by British courts. Other countries also employ such orders more freely than the United States does.

DeCSS case
In October 1999 the Motion Picture Association of America (MPAA) learned of the availability on the Internet of DeCSS, a program that allowed people to view the content of DVDs using computers that lacked commercial DVD players, bypassing the encryption system known as the Content Scrambling System (CSS) generally used on commercial DVDs. The MPAA responded by sending out a number of cease and desist letters to web site operators who posted the software. In January 2000, a lawsuit was filed against the publisher of the magazine 2600: The Hacker Quarterly, and others. This case is known as Universal v. Reimerdes,.

The suit asked for an injunction under the U.S. Digital Millennium Copyright Act (DMCA) prohibiting the 2600 site from posting the DeCSS code. It also asked for a prohibition on linking to other sites that posted the code.

The injunction was issued and sustained in an appeal to the U.S. Court of Appeals for the Second Circuit and the constitutionality of the DMCA was upheld. The district court wrote that the computer code "... does more, in other words, than convey a message" and that "... it has a distinctly functional, non-speech aspect in addition to reflecting the thoughts of the programmers." The appeals court later wrote that "Under the circumstances amply shown by the record, the injunction's linking prohibition validly regulates the Appellants' opportunity instantly to enable anyone anywhere to gain unauthorized access to copyrighted movies on DVDs" thus upholding the injunction against publishing links to the DeCSS code in these circumstances.

The appeals court did consider the prior restraint and free expression issues, but treated the DeCSS program primarily as a means of evading copyright protection, and under that theory, held that the 2600 site could be permanently enjoined from posting the DeCSS code, and from linking to sites that posted it in an attempt to make the code available. The case was not taken to the Supreme Court.

Theater and motion pictures
There is a long history of prior restraints on the theater; in the United Kingdom stage plays still required a license until 1968. This attitude was early transferred to motion pictures, and prior restraints were retained for films long after they had been dropped for other forms of publication: in some jurisdictions, a film had to be submitted to a film censor board in order to be approved for showing.

The United States Supreme Court upheld the use of a board of censors in Mutual Film Corporation v. Industrial Commission of Ohio, by deciding that the First Amendment did not apply to motion pictures. The power of such boards was weakened when the Supreme Court later overruled itself and decided that the First Amendment does apply to motion pictures. In the case of Joseph Burstyn, Inc. v. Wilson,, the court decided that giving the power to forbid or restrict a film to a censorship board on the grounds a film was "sacrilegious" was far too damaging to the protections of the First Amendment.

The "death knell" for censorship boards occurred in 1965 when the U.S. Supreme Court found the Maryland law making it a crime to exhibit a film without submitting it to the censorship board was unconstitutional. In Freedman v. Maryland,, the state's requirement that a film be presented to the board was unconstitutional as it lacked adequate procedural safeguards. While it is not necessarily unconstitutional to require films to be submitted to a censorship board, the board has extremely limited options: a censorship board has no power to prohibit a film, and, if the law grants it that power, the law is unconstitutional. The board's only options when a film is presented to it are either to grant a license for the film or immediately go to court to enjoin its exhibition.

Also, state or local censorship boards had been found to have no jurisdiction over broadcasts by television stations, even when located in the state or community where they are grounded, thus eliminating yet another reason for their existence.

Both the state of Maryland and the province of Ontario retained film censor boards to a particularly late date. Maryland abandoned its board in the 1980s, and a 2004 decision of the Ontario Court of Appeal, reversing a previous trend in favor of the Ontario Film Classification Board's right to insist on cuts, ruled that the province had no right to insist on cuts as a condition of release as Canadian federal obscenity laws were sufficient to deal with obscene material. In May 2005, the Ontario government ended the power of the Classification Board to insist on cuts, requiring all films with adult content that were not judged obscene to be rated "R" for adults only.

In many countries, legally effective rating systems are in effect. See History of British Film Certificates for information on film restrictions in the UK.

Industry codes
Many industries have formulated "voluntary" codes limiting the content of expression, generally affecting perceived effects on public morality rather than revelation of secrets. Examples of these include the Hays Code, which affected Hollywood films from the 1930s to the 1950s, and the Comics Code, which was designed to deal with the rise of horror comics in the 1950s and lasted into the 1970s. The movie rating system currently in effect in the United States, run by the Motion Picture Association of America (MPAA) is another such industry code. Such codes have generally been adopted with the twofold purposes of forestalling possible government intervention and avoiding unfavorable publicity or boycotts. While such codes are not generally enforced by governmental action, they are generally enforced on content producers by gatekeepers in the marketing chain: studios in the case of the Hays Code, distributors in the case of the Comics Code and theater chains in the case of the MPAA rating system. Content producers have often objected to these codes and argue that they are, in effect, a form of prior restraint. However, the first amendment prohibition of prior restraint applies to government or court action and does not bind private entities such as theater chains.

Francisco Martorell v. Chile
In April 1993, Francisco Martorell published a book titled 'Impunidad diplomática' (Diplomatic Impunity) in Argentina with Editorial Planeta. The book was about, among other things, the events that led an erstwhile Argentinian ambassador, Oscar Spinosa Melo, to leave Chile. The book -- scheduled to start selling in Chile the day after its launch in Argentina -- met with a protection remedy by a Chilean businessman before the Santiago Court of Appeals, who argued the text injured his right to privacy. Thus, the court issued an interlocutory injunction ('orden de no innovar') that temporarily prohibited the book's entry, distribution and circulation in Chile pending a final ruling on the case. Thereafter, several people filed complaints against Martorell for defamation (injuria) and false imputation of a publicly actionable crime (calumnia).

Subsequently, through an extraordinary remedy, Martorell appealed to the Supreme Court of Chile and invoked the constitutional guarantees of freedom of the press. But in a unanimous decision handed down on June 15, 1993, the Supreme Court denied the appeal and forbade the book's circulation, formally notifying Martorell of its decision some days later.

The Inter-American Commission on Human Rights (ICHR) had to determine whether the Chilean court's decision to prohibit the entry, circulation and distribution of Martorell's Diplomatic Impunity violated freedom of expression under Article 13 of the American Convention on Human Rights (ACHR), which states: '1. Everyone has the right to freedom of thought and expression. This right includes freedom to seek, receive, and impart information and ideas of all kinds, regardless of frontiers, either orally, in writing, in print, in the form of art, or through any other medium of one's choice. 2. The exercise of the right provided for in the foregoing paragraph shall not be subject to prior censorship but shall be subject to subsequent imposition of liability, which shall be expressly established by law...'

The Commission reaffirmed that freedom of expression, which it averred involves the right to express ideas and thoughts and receive them. As such, when an individual's right to express themself restricted, it also affects the public's right to receive information. The Commission indicated that Article 13.2 of the ACHR allows certain restrictions upon one's exercise of freedom of expression and stipulates the legitimate limits and the requirements for establishing these restrictions. In this sense, the right can only be legitimately restricted through the imposition of subsequent liabilities provided for by law and deemed necessary to ensure the objectives established in the Convention. The Commission recalled that protecting 'the rights or the reputation of others' is a legitimate purpose for the Convention. However, regarding the rights of privacy, honour and dignity outlined in Article 11 of this instrument, 'the organs of the State cannot interpret the provisions of Article 11 in a manner that violates Article 13, which prohibits prior censorship'.

Accordingly, the IACHR stressed that the Convention stipulates that prior censorship is incompatible with the full enjoyment of the rights protected by this instrument. The Commission underscored ACHR as the only human rights instrument containing this prohibition, indicating the veritable importance the Inter-American system placed on the freedom of expression. In May 1993, the Court of Appeals granted the judicial remedy brought by the Chilean businessman and affirmed the measure that 'prohibited the entrance and commercialization of the book in Chile'. A subsequent to the Supreme Court was rejected.

In the case under review, the Commission considered the decision to ban the entry, circulation and distribution of the book Diplomatic Impunity in Chile was contrary to Article 13 of the ACHR. For the Commission, this constituted an act before censorship and, thus, was not a legitimate restriction on the right to freedom of expression.

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Intercession

Intercession or intercessory prayer is the act of praying to a deity on behalf of others, or asking a saint in heaven to pray on behalf of oneself or for others.

The Apostle Paul's exhortation to Timothy specified that intercession prayers should be made for all people. "I urge, then, first of all, that petitions, prayers, intercession and thanksgiving be made for all people—for kings and all those in authority, that we may live peaceful and quiet lives in all godliness and holiness."

In the early Church
The early Christians continued to practice intercessory prayer on behalf of others after Jesus' death. Ignatius of Antioch was one man who exhorted Christians to continue to pray for others, and especially for those who became Docetists or held other heretical beliefs. In his letter to the churches of Smyrna, St. Ignatius exhorts the Christians there to pray for other people: "only you must pray to God for them, if by any means they may be brought to repentance, which, however, will be very difficult. Yet Jesus Christ, who is our true life, has the power of [effecting] this". Throughout all of Ignatius's letters, the word for prayers of intercession appears nineteen times, and Ignatius asks for prayer "for himself (eight times), for the Christian church in Syria (seven times), for persecutors, heretics, and all people generally (once each)".

St. Ignatius and the other church fathers, such as Paul the Apostle, who were keen on intercessory prayer based this practice on Jesus' own teachings which required that one pray for others, especially one's enemies:

"But to you who are listening I say: Love your enemies, do good to those who hate you, bless those who curse you, pray for those who mistreat you."

According to Lionel Swain, of St. Edmund's College, Ware, St. Paul believed intercession to be one of the most important aspects of faith and praying life, as praying for others is a recurring theme in his works. Prayer acts as a way for St. Paul to acknowledge God's power. Intercessory prayer also acts as a way for the Apostle to "share in ... the Father's redemptive love". Paul believed that prayer transformed the person doing the praying, as much as the one being prayed for, which creates a stronger bond between him and God.

Prof. Dr Johannes van Oort, Professor Extraordinarius in the Department of Church History and Church Polity of the Faculty of Theology at the University of Pretoria, South Africa, adds that, in addition to praying for wisdom, the early church was very much involved with different charismas, one of which being healing. Praying for other people's illnesses was another way that intercessory prayer was important in the early church, as healing was a sign of "the power of God's Kingdom". This gift of healing is specifically mentioned, among the other charismata, as a sign of being a true Christian by Irenaeus of Lyons in his text, Against Heresies.

Saints
Intercession of the saints is a doctrine held by the Eastern Orthodox, Oriental Orthodox, and Roman Catholic churches, as well as by some Lutheran and Anglican churches (chiefly those of Evangelical Catholic or Anglo-Catholic churchmanship, respectively). It teaches that saints may be asked to intercede (or pray) for others. The doctrine of requesting intercession from saints can be found in Christian writings from the 3rd century AD, such as from Origen and Clement of Alexandria.

The dead
In addition to praying for each other in life, early Christians would pray for those who had died. There is no unequivocal evidence that Christians began to pray for the dead before the third century AD. G. F. Hamilton argues that the earliest example of Church prayer on behalf of dead Christians is found in the Sacramentary of Serapion of Thmuis (350 AD). Rather than pray for the departed in regular church services on Sunday, these early Christians would hold special commemorative occasions during the week. There was a sharp distinction drawn between remembering and praying on behalf of the dead, and those who were the faithfully' departed", where Christians would only pray for those who had died as believers. The First Epistle of Clement (95 AD) contains a prayer which, while mainly for protection for the living, also includes the dead. Even quite early, a distinction was drawn between those who had died as Christians, and those who had died as unbelievers. In the Martyrdom of Polycarp (155 AD), Polycarp is killed and his bones are taken by fellow Christians and a shrine is set up to him, where they may remember his martyrdom. In contrast, the "Apology of Aristides" shows how those who were not Christians were grieved for, while the dead faithful were rejoiced over.

Theological perspective
In an article in Theological Studies, Catholic theologian Patricia A. Sullivan warns that saints should not be built up in a way that brings down God. Saint Augustine had famously said that we pray not to instruct God but to get our will in line with God's. Sullivan warns away from the dictionary meanings of "intercession" as “intervention, mediation, arbitration, negotiation”, all of which sound like we are dealing with a hostile or unfriendly God, whom we need to manipulate to get what we need. Such is not the meaning of the hapax legomenon in the New Testament of the word for intercession. Sullivan goes on: "When we ask a saint to intercede for us, what is happening at a deeper level is that we are taking refuge in the all-enfolding community of the redeemed, approaching God thru saintly symbols of Christ's victory and of our hope. Saints want always what God wants, what is best for us whether we pray for it or not. They are in a perpetual attitude of praise for God’s love and care, to which we join ourselves, praying, more precisely, with them rather than to them. The value of our petitions is that they turn us in confidence toward the God who loves us, allowing God’s work to be more effective in us, and thru us in others." It would be anathema to ask God to try any harder to do good. By invocation of a saint "we take refuge in faith in the all-enfolding community of all the redeemed," where "each is responsible for all". They are "creative models of holiness".

Islam
Although the idea of intercession or mediation (Arabic: s̲h̲afāʿa) has historically played a very prominent role in Islamic thought, it is not universally accepted by all Muslims in the present day.

The Quran says that the pre-Islamic Arab pagan gods will not be able to intercede with God on behalf of humankind, and that "the guilty" (al-mujrimīn, Q74:41) will not benefit from any intercession on the Day of Judgment. Other passages that deny the efficacy intercession include Q32:4 & Q39:44. Still others say that God is the only intercessor (Q6:51, Q6:70; Q32:4; Q39:44).

However, "intercession is mentioned in the Qurʾān with respect to angels praying for the believers and the Prophet praying for erring but repentant Muslims." Furthermore, it became an orthodox Islamic doctrine or "cardinal belief" that "Muḥammad will intercede for all Muslims on the Day of Resurrection." While this particular tenet practically remained unchallenged throughout Islamic history, the widespread Sunni and Shia practice of asking deceased prophets and saints for intercession by praying at their tombs have become contentious issues in the modern Islamic world, with all these different types of intercession often being labelled by Salafi/Wahhabi Muslims as a type of polytheism, in a manner akin to the attitude of many Protestants towards the Catholic and Eastern Orthodox practice of saint-intercession.

Studies
Some religions claim that praying for somebody who is sick can have positive effects on the health of the person being prayed for.

Meta-studies of the literature in the field have been performed showing evidence only for no effect or a potentially small effect. For instance, a 2006 meta analysis on 14 studies concluded that there is "no discernible effect" while a 2007 systemic review of intercessory prayer reported inconclusive results, noting that 7 of 17 studies had "small, but significant, effect sizes" but the review noted that the most methodologically rigorous studies failed to produce significant findings.

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

title: Intercession


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User talk:Orevo

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Melbourne Storm

The Melbourne Storm is a rugby league club based in Melbourne, Victoria, Australia that participates in the National Rugby League (NRL). The club plays its home games at AAMI Park, and wears a purple and navy blue jersey with gold and white trim.

The Storm was the first fully professional rugby league team based in the state. It debuted in 1997 at the short-lived Super League during the Super League war. Following the Super League collapse, the team became a part of the newly formed, united competition. The Storm have won four premierships since their inception, in 1999, 2012, 2017 and 2020, and have contested several more grand finals. They won the 2007 and 2009 grand finals, but were stripped of those premierships following salary cap breaches.

The Storm also competed in the NRL's Under-20s competition (as Melbourne Thunderbolts) from 2008 until its demise in 2017 and in 2018 they entered the (Victorian Thunderbolts) in the Hastings Deering Colts u20s QLD competition. In addition, the club has also expanded into netball with a joint venture with the University of the Sunshine Coast. Since 2017, Sunshine Coast Lightning have played in Suncorp Super Netball.

1997–1999: Establishment and 1st Premiership
Following record attendances at State of Origin fixtures in Melbourne of 87,161 in 1994 at the Melbourne Cricket Ground, the Australian Rugby League (ARL) had planned to establish a Melbourne-based team in the Premiership by 1998. However, the disruption caused by the Super League war caused great change to the game in Australia. By May 1997, Super League boss John Ribot pushed for a Melbourne-based club for his competition, which was the rival of the ARL. Former Brisbane Broncos centre Chris Johns became the CEO of the club and Ribot stepped down from the head of Super League to set up the club, with head of News Limited Ken Cowley as chairman. In September 1997, Melbourne announced that Chris Anderson would be their foundation coach, and then Super League announced that the new team would be named the Melbourne Storm. Melbourne teenager Cameron Duncan came up with the name Storm and his winning entry was chosen from more than 1000 entries received in a competition run in conjunction with the Herald Sun.

The Melbourne club then went forward with signing players, mainly from folding Super League clubs Perth Reds and Hunter Mariners. These players included Rodney Howe, Robbie Kearns, Matt Geyer, Paul Bell, Robbie Ross, Glenn Lazarus, Brett Kimmorley and Scott Hill. With the Super League and ARL joining into one competition for the 1998 season, the Melbourne team became part of the National Rugby League (NRL). The Melbourne Storm Rugby League Club was unveiled at a function at the Hyatt Hotel – Melbourne in February 1998.

In their first game, they defeated the Illawarra Steelers, with Glenn Lazarus as their inaugural captain. Melbourne, in a complete shock to the rest of the competition, won their first four games, before losing to the Auckland Warriors. They went on to make the finals, but were defeated by the eventual premiers, the Brisbane Broncos.

In January 1999, Executive Director John Ribot negotiated a deal that saw Melbourne Storm games televised in China every weekend. The club won eight of their first eleven games of the 1999 NRL season, and went on to make the finals in third position on the Premiership ladder. The team was beaten convincingly 34–10 in the quarter final by St. George Illawarra. After narrow victories against the Canterbury Bulldogs and the Parramatta Eels; however, Melbourne once more faced St. George Illawarra in the grand final. The Storm staged a late comeback in the game to win 20–18, securing their first premiership.

2000–2002: Decline and coaching changes
Melbourne's Premiership defence began relatively slowly losing their first four games of the 2000 NRL season, the club went on to make the finals (finishing 6th), but were eventually knocked out by Newcastle in the quarter-finals. Between 2001 and 2002, the club's on field performances waned, resulting in a 10th-placed finish in 2002. Cracks were starting to appear between John Ribot and Anderson throughout the period, with Anderson quitting as coach after round 7, 2001. He was replaced by Mark Murray. The Melbourne club failed to make the finals in 2001. Johns left the club as CEO at the end of 2002 and coach Murray was sacked due to Melbourne's poor form, with the club missing the finals for the second year in a row.

2003–2006: Craig Bellamy era begins – return to the top
Wayne Bennett's assistant coach at the Brisbane Broncos, Craig Bellamy was announced as the new coach of Melbourne for 2003, and in addition, a new captain in Kiwi international skipper Stephen Kearney. Bellamy's strict coaching had an almost immediate effect and saw the Melbourne Storm get back on track from the previous lean years.

Between 2003 and 2005, Melbourne consistently made the finals, but lost games in the semi-finals which prevented them from reaching the grand final. This period also saw the arrival and rise of young Queenslanders Billy Slater, Cameron Smith and Cooper Cronk. Unheard of at the start of 2003, the steady hooker and dummy-half Smith provided solid support to existing established players in Matt Orford and his forwards and also provided supporters with confidence of the club's future. A notable incident that occurred during 2004 was the 18-game suspension of Danny Williams following a king-hit on Wests Tigers' player Mark O'Neill. It was the longest suspension in Australian rugby league since 1987.

By 2005, Storm coach Craig Bellamy, in his third season as an NRL coach, gained representative honours when he was selected to start coaching the Country Origin team.

Season 2006 saw the retirement of captain Robbie Kearns and the emergence of talented rookie halfback Cooper Cronk who took over the position from Matt Orford and in addition, the recruitment of hard-man Michael Crocker. The club also moved away from a single captain, electing to use a rotating captains policy, including Cameron Smith for the first time. Contrary to expectation, 2006 was a standout year for the Melbourne team, finishing on top of the ladder for the first time. Melbourne only lost four games in the season, making them outright leaders by four wins. They went on to win their two finals matches, and were favourites in the 2006 NRL Grand Final, but lost 15–8 to the Brisbane Broncos, in a match where controversial refereeing decisions against Melbourne caused much media coverage.

2007–2010: Finals success and club turmoil
In 2007, the Storm finished the season on top of the table for the second year in a row. They progressed through the finals series with wins over Brisbane, 40–0, and then Parramatta 26–10, in the preliminary final. This secured a berth in the 2007 NRL Grand Final against the Manly-Warringah Sea Eagles which they won 34–8, with Greg Inglis winning the Clive Churchill Medal for best on ground.

In 2008, foundation player Matt Geyer became the first player to play 250 games for the club. Melbourne finished on top of the ladder after the 26 rounds of regular competition and despite becoming the first minor premiers since the McIntyre final eight system was introduced to lose their opening finals game (15–18 to the New Zealand Warriors), they then defeated the Brisbane Broncos 16–14, scoring in the last minute of their semi-final. Cameron Smith was suspended for two matches for a grapple tackle on Brisbane's Sam Thaiday in the match, seeing him miss the rest of the finals, and Craig Bellamy was fined $50,000 for making scathing remarks against the judiciary's decision. Melbourne convincingly beat the Cronulla-Sutherland Sharks 28–0 to qualify for the grand final, but suffered the heaviest Grand Final defeat in league history, beaten 40–0 by Manly. Greg Inglis, Billy Slater, Cameron Smith and Israel Folau all won awards at the Dally M Awards, and Slater and Smith finished equal second for the Dally M Medal. Billy Slater was awarded the international player of the year Golden Boot award for 2008, following on from Cameron Smith in 2007.

In the 2009 season, Melbourne finished 4th on the ladder; they defeated Manly 40–12 in the first week of the finals and Brisbane 40–10 in the preliminary finals to qualify for a fourth straight grand final (the first since Parramatta from 1981 to 1984). Against Parramatta, who had finished eighth in the home-and-away season but had won ten of its last eleven matches, the Storm led at one stage by 16 points, before finishing 23–16 winners. Slater won the Clive Churchill Medal, and they were named as the NRL Team of the Decade for the 2000s. In the late 2000s the Melbourne Storm were still running at a loss of up to $6M per season, however despite this, they were voted the state of Victoria's most popular sports team by a national Roy Morgan Poll in October 2009.

In 2010, a number of changes were made to senior management of the club, firstly Brian Waldron resigned his position as CEO to take up the same position at the Melbourne Rebels Super Rugby team, he was replaced by Chief Operating Officer, Matt Hanson. In April, following the salary cap revelations, Matt Hanson was then stood down and Ron Gauci appointed.

On field, the Storm's first match of the season was the 2010 World Club Challenge against equally dominant English side, the Leeds Rhinos; in very cold and wet conditions the Storm prevailed 18 – 10.

On 22 April 2010 the club admitted that it had breached the NRL's salary cap. The NRL estimated the breach to be in excess of $1.7 million over five years. As a result of the breach, NRL Chief Executive David Gallop stripped the club of all titles earned in this period including their 2007 and 2009 premierships, three minor premierships between 2006–08, heavily fined the club, deducted all premiership points earned to that point of the season and barred them from receiving any more for the rest of the season. The club ended up winning enough matches to make the finals, but automatically finished in last place due to the penalties. Melbourne did have something to celebrate in 2010 with the opening of their new home ground AAMI Park in May. The stadium was expected to be used right from the beginning of the season, however, construction delays postponed the opening.

2011–2012: Rebuild and Premiership success
Following the salary cap scandal, the club needed to shed a number of players and rebuild. They managed this successfully and over the next two years the Storm returned to the top of the ladder. In 2011 the club won what, after the salary cap penalties, was considered the club's first Minor Premiership and that season also included a club record twelve consecutive wins, however, Melbourne fell just short the grand final, losing the preliminary final against New Zealand. At the 2011 Dally M Awards night, Billy Slater won the Dally M Medal, with Craig Bellamy and Cameron Smith also winning Coach of the year and Captain of the year respectively.

In 2012 the club started very strongly with nine consecutive wins, the club's best start to a season up to that time. A five-game losing streak between Rounds 16 and 21 (the club's second worst losing streak to that time) saw them fall from the top of the ladder. However, from Round 22 forward they recovered their winning form and finished the regular season with five straight wins, ending the regular season in second place on the table. Storm began their finals campaign with a 24–6 win over South Sydney Rabbitohs. Storm played its fifth Preliminary Final in six years, this time defeating Manly-Warringah Sea Eagles 40–12 at AAMI Park. Following this they went on to claim their second official Premiership defeating the Canterbury-Bankstown Bulldogs 14 – 4 in the Grand Final.

2013–2017: World Champions, Milestones and 3rd Premiership
The Storm began its 2013 season with a trip to England where they defeated the Leeds Rhinos 18–14 in the World Club Challenge, to be crowned World Champions. Upon their return to Australia, the Storm began the home and away season where it left off in 2012 winning their first seven games, this combined with games won in late 2012 set a new club record for the most consecutive wins, with the streak ending at 15 games with a loss in Round 8. On 21 May 2013 the Storm announced that, News Limited had sold the club to Holding M.S. Australia Pty Limited, an organisation made up of internationally experienced and successful businessmen. This change included replacement of the News Ltd Board and Executive, which included the replacement of Chairman Stephen Rue with Bart Campbell and CEO Ron Gauci with Mark Evans. News Limited had owned the Storm since its inception in 1997. On 9 June 2013 Captain Cameron Smith played his 250th game for the club. The Storm managed to finish 3rd in 2013; however, successive losses to the South Sydney Rabbitohs and Newcastle Knights in the finals saw the Storm miss the Preliminary Finals for the first time since 2005 (excluding 2010).

The 2014 season saw a number of milestones achieved, both Billy Slater and Cooper Cronk played their 250th games and Craig Bellamy reached 300 games as coach. In mid 2014 the Storm also announced a new feeder partnership with the Sunshine Coast Falcons. This would complement their existing relationship with Brisbane Easts with a view to establishing a permanent footprint in the Sunshine Coast Area.

2015 began successfully for the Storm with the club finding itself on top of the ladder by Round 7. In April Storm CEO Mark Evans announced that he was returning to England and completed his tenure as CEO in June of that year. Dave Donaghy was announced as his replacement. In round 19 a major milestone was achieved with Cameron smith playing his 300th game becoming only the 24th player in history to do so. In August 2015 the storm announced that they would create an Academy on the Sunshine Coast to develop and nurture developing talent in the region with a view to progressing through the Storm ranks. Part of the establishment of this Academy meant that the Melbourne Storm Under 20s Team would play all of its home games at the new facility from 2016 onward.

The 2016 season began well for the Storm finding themselves in third place on the ladder after 10 rounds. In Round 5 they scored their 300th NRL win and in Round 9, Craig Bellamy coached his 350th NRL game. On 23 May the Melbourne Storm announced that it had been one of three successful bidders and the only NRL club to gain a licence to field a Netball side in a new expanded Australian Netball League to commence in 2017. The Melbourne club were nominated by Netball Australia as a preferred bidder for one of three new team licences under their expansion plans and on 17 August 2016 it was announced that the new team will be called Sunshine Coast Lightning and be based on the Sunshine Coast at the Storm sports Academy and in effect be a second Queensland Team. The announcement is to establish the Storm as not just a Rugby League club but a sporting and community club.

At the conclusion of the 2016 NRL season Melbourne finished in first place claiming their second legitimate Minor Premiership. They qualified for the NRL Finals series winning their first two finals and thus making it through to the 2016 NRL Grand Final against the Cronulla-Sutherland Sharks. The game was a very hard-fought match, as the game hung in the balance until the dying second but the Cronulla side hung on to win.

2017 was another successful year for the Melbourne Storm, the club's 20th season in the NRL. Following on from the heartbreak of losing the grand final in 2016, the club went from strength to strength recruiting well in the off season and dominated the 2017 NRL season to finish in first place earning them their third legitimate minor premiership. Melbourne won 20 and lost four games throughout the season making it their most dominant season in 10 years. Cameron Smith also broke a number of league, club and personal records throughout the 2017 season including the NRL games record for the most games played, league record for the most wins as a captain, a personal best for the most points in a game and also scored his 2000th career point and 1000th career goal, the first time any player has achieved this. The Storm continued their success into the 2017 NRL finals and won their first two, a home Qualifying final against the Parramatta Eels 18–16 and a home Preliminary Final against Brisbane 30–0 to qualify them for their second consecutive Grand Final. The 2017 NRL Grand Final was played against the North Queensland Cowboys, which Melbourne dominated to earn them their 3rd official Premiership 34–6. Billy Slater won his second Clive Churchill medal. In December 2017, the NRL announced the formation of a women's competition with Melbourne Storm expressing their interest in applying for a licence to participate in the inaugural NRL Women's season.

2018–2022: 20th anniversary and 4th premiership
Following the club's premiership in 2017, the Storm hosted the 2018 World Club Challenge at AAMI Park in February and also defeated the Leeds Rhinos to win the title 38–4. 2018 was also a special year for the club as it celebrated its 20th anniversary and in March announced their team of the first 20 years during a gala evening at Crown Casino. Continuing on from the success in 2017, the Storm once again played very well throughout the year ultimately being pipped for the Minor Premiership on points difference. The Storm once again made the grand final, however, lost to the Sydney Roosters to end the season runner-up.

In 2019, the club returned to the top of the table, winning the Minor Premiership finishing six points ahead of the Sydney Roosters, however, their finals campaign was not as successful with ultimately exiting the finals after a defeat in the preliminary final once again to the Roosters. Club captain Cameron Smith also achieved a number of significant milestones throughout the 2019 season, including captaining his 300th game, becoming the game's highest points scorer and also playing his 400th NRL game – the first NRL player to do so.

The Storm were looking to continue their success into 2020 but 2020 became somewhat of an extraordinary year. The global COVID-19 pandemic hit Australia in late February forcing all games behind closed doors and then a total suspension and reorganization of the season. After the situation in Victoria deteriorated in June, the Storm were forced to relocate to the Sunshine Coast in Queensland to complete their season. Melbourne would go on to finish second on the table at the end of the 2020 regular season behind Minor Premiers Penrith, before beating Penrith in the 2020 NRL Grand Final to win their fourth official premiership, and cementing their status as one of the most successful clubs of the modern NRL era.

In 2021, long term captain Cameron Smith announced his retirement after 430 game and both Jesse Bromwich and Dale Finucane were announced as co-captains. On-field, the Melbourne club had some early hiccups adjusting to life after Smith, however, from round four, began a winning streak that lasted until Round 23 – 19 consecutive wins, becoming the first team since the Sydney Roosters in 1975 to complete this feat. This was made all the more remarkable because for the second consecutive season the club were forced to once again relocate to Queensland from Round 9 onwards due to COVID-19 outbreaks in NSW and Victoria. The winning run helped them to win the Minor Premiership finishing in first place at the end of the season, however the club failed to make the grand final losing the preliminary final to Penrith. The club also broke a number of other points scoring records throughout the season including finishing with the highest ever points differential (499 points). Individually, Josh Addo-Carr also scored a club record six tries in a single game against South Sydney.

Melbourne started the 2022 NRL season strongly winning seven of their opening eight matches with their only defeat coming against Parramatta. In round 10 however, Melbourne were defeated 32–6 by Premiers Penrith. The following week, Melbourne suffered their biggest loss in the competition since round 18 of the 2013 NRL season when they were defeated 36–6 by North Queensland. In round 18 of the 2022 NRL season, Melbourne were defeated 20–16 by Canberra which meant they had lost three straight matches for the first time since the 2015 NRL season. Melbourne would finish the 2022 regular season in fifth place on the table which was their lowest finish since the 2014 NRL season. In the elimination final, Melbourne were upset 28–20 by Canberra which ended their season.

Name
Originally, the club favoured the name Melbourne Mavericks with a gunslinger logo holding a fistful of dollars. The club officials were all set to go with this until News Limited's Lachlan Murdoch told them to go with something else because the Mavericks sounded too American. Trams and Flying Foxes were also some ideas that came up. However, CEO Chris Johns and Executive Director John Ribot decided to go with the themes of lightning, power and following a naming competition, the club eventually settled on the name Melbourne Storm. Melbourne teenager Cameron Duncan came up with the name "Storm", with his winning entry chosen from more than 1000 received.[8]

Colours
The Storm were always going to go with the colours of their state, Victoria (navy blue with a white 'V'), but club consultant at the time, Peter McWhirter of the JAG fashion house, suggested that they should also have purple and gold to make their merchandise more attractive. Therefore, the official colours of the Storm are navy blue and purple (main colours) and white and yellow (minor colours).

All four of these colours appeared in the logo until yellow was removed in 2018. In the home jersey, the colours have varied over the years. Between 1998 and 2004 these four colours appeared on various designs but between 2005 and 2009, gold was completely removed and silver introduced. Between 2010 and 2012, gold returned, silver was omitted and purple became the dominant colour in the jersey. For 2013 a new design was announced featuring a deeper V, with more navy blue in the jersey. Gold disappeared again along with most of the white, and the lightning bolts were changed to purple. During 2015 the jersey changed again, for the first time not featuring a V at all, but the V returned somewhat along with the lightning bolts in 2016 with a manufacturer change. In 2018 and 19 the club wore a traditional V uniform and all colours were present, however, for 2020 the jersey has returned to an all navy blue and purple jersey.

Between 1998 and 2001, Melbourne was the only club to display player names on the back of jerseys. This was because there was no major sponsor for the Storm to display on the chest or back at the time. It also helped supporters new to the game identify the players. In 2001, Melbourne gained its first major sponsor in Adecco, which was displayed on the jersey chest, while maintaining the players' names on the back until the end of 2001. In 2002, the Storm removed the players' names and displayed Adecco's logo on the back. Since then the Storm have had varying sponsors adorning the jersey.

Logo
The club's original logo of "Storm Man" riding over storm clouds and throwing a bolt of lightning was in place from the club's inception through to the end of the 2017 season. The only variation to this was when an informal logo for the 10th Anniversary was produced however this was only featured on supporter merchandise and not in an official capacity on the jersey. As part of the club's 20th Anniversary, the Storm introduced a new logo used throughout the 2018 season. The logo was a shield based logo with the storm man featured above the words "Melbourne Storm 20 Years". As the celebrations concluded, the club rebranded and replaced the 20th Anniversary logo with another new logo. The current Logo is a derivation of the 20-year logo featuring no shield and a more bold "Melbourne Storm" and the club has also dropped the colour Yellow from the logo. There is also a second official version of this logo in all white which features on the home jersey.

Club song
The Melbourne Storm have a number of club songs that are either played over the PA system or exclusively sung by the players at each game;

The main song, which was written by Jon Mol and Phil Wall, is called "We Are the Storm" and is played over the public address system following each home victory.

In addition, AC/DC song "Thunderstruck" is played at every home game as the team enter the stadium.

Lastly, after each victory, the Storm players also sing "We are the mighty Melbourne Storm" in the dressing rooms. The song is sung to the same tune as the US Marines' Hymn.

St. George Illawarra Dragons
The St. George Illawarra and Melbourne rivalry was at its highest in the years following the 1999 NRL Grand Final. In this game, Melbourne narrowly beat St. George Illawarra, with a late penalty try putting the Melbourne club in front. The following year, Anthony Mundine declared that the Melbourne side were not "worthy premiers" in the run up to their round 5 rematch. Melbourne responded by belting St. George Illawarra 70–10.

However, later that season, St. George Illawarra had a large win defeating Melbourne 50–4. In 2006, Melbourne and St. George Illawarra once again met in a Preliminary Final which Melbourne won. On 21 July 2008, Melbourne won at Olympic Park 26–0, in a match highlighted by several ugly brawls.

In 2009, the Melbourne club defeated St. George Illawarra 17–16 in Round 1 with a field goal in Golden Point extra time.

Brisbane Broncos
The Melbourne Storm has a rivalry with Brisbane, built in large part on the large number of finals games played between the teams, including one final in each year from 2004 to 2009, with the Melbourne club winning all but one of them. The move of Brisbane assistant coach Craig Bellamy to Melbourne has also been attributed to fueling the rivalry, as well as the wide spread of Queensland Origin players across their squads in the better part of the past decade.

Every year since Brisbane's victory over Melbourne in the 2006 Grand Final, Melbourne have ended Brisbane's season by knocking them out of the finals. Melbourne captain Cameron Smith commented on the rivalry prior to their 2009 Preliminary Final at Etihad Stadium.

The Brisbane Broncos defeated Melbourne 15–8 in the 2006 NRL Grand Final. Melbourne sought revenge through a 40–0 thrashing in the 2007 Qualifying Final at Olympic Park Stadium. The 2008 Semi-Final at Suncorp Stadium ended with Melbourne dramatically winning 16–14 with a try on the final play of the game. In 2009, Brisbane were again beaten by eventual premiers Melbourne, this time 40–10 at Etihad Stadium, catapulting the Melbourne club to their 4th consecutive Grand Final Appearance. In 2017, the two sides met in the preliminary final where Melbourne defeated Brisbane 30–0. Since the 2006 Grand Final, Melbourne have only lost to Brisbane five times across 36 matches.

In round 27 of the 2023 NRL season, the two sides met in the final round of the regular campaign. Brisbane and Melbourne both rested several players as each team had qualified for the finals. Melbourne would go on to win the game 32–22 which denied Brisbane their first Minor Premiership since the 2000 NRL season. The two sides met the following week in the 2023 qualifying final with Brisbane defeating Melbourne 26–0 to book a place in the preliminary final. It was the first time Brisbane had beaten Melbourne at Suncorp Stadium since 2009 and the first time that they had defeated Melbourne in 14 attempts.

Manly-Warringah Sea Eagles
The origin of the rivalry stems back the period between 2007 and 2012 when both clubs were consistently at the top of the table.

In the 2007 NRL Grand Final, Melbourne defeated Manly 34–8 and then the following year in the 2008 NRL Grand Final, lost to the Manly club 40 nil. The following season the clubs once again met in the finals series and this time it was Melbourne who ended Manly-Warringah's season, and their bid for back to back titles, with a 40–12 defeat in the 2009 qualifying final.

In 2011 the rivalry escalated when another major chapter was written in what became known as the "Battle of Brookvale". This game involved a massive brawl that began on the field and then continued as the two key players involved were being sent off. The melee ultimately involved interchange players and officials from both clubs as well. What made this worse was that the match was attended by then CEO of the NRL David Gallop who condemned the actions of both clubs.

"The sight of so many players from both teams fighting, of people running in and leaving the bench area, was a horrendous look for the game."

In the years following this match, matches between Manly-Warringah and Melbourne played at Brookvale Oval continued to often be called the "Battle of Brookvale", though there have not been any particularly violent matches between the two sides at this venue since.

In 2012, there was a similar scenario as 2009 when the clubs met in the Preliminary Final, Melbourne again defeated Manly 40–12, again ending their chances of winning back-to-back titles after the Manly-Warringah club won the title in 2011.

The matches between the two sides simmered over the next decade, however, in the 2021 NRL Finals Series the two clubs once again met, this time a Qualifying Final, Melbourne again defeated Manly and curiously, the score line was again 40–12, the third time this had occurred.

New Zealand Warriors
This is more of a traditional game due to the large number of Kiwi internationals Melbourne has fielded in their history. Matches between the two clubs are normally close and low scoring, with the overall head to head (as of 2020) in Melbourne's favour (45 clashes, Melbourne 27 – Warriors 16 and 2 draws). These two sides played an annual ANZAC Day clash each year between 2009 and 2014. In 2015 it was not scheduled so the Warriors could celebrate the 100th anniversary of ANZAC Day at home. From 2016 onwards (with the exception of 2020), it has been played on every ANZAC Day since. Both teams play for the Michael Moore Trophy.

The two sides have met each other twice in the finals series. The first being in week one of the 2008 finals series where New Zealand pulled off one of the biggest finals upsets defeating Melbourne 18–15. New Zealand had finished the season in eighth whilst Melbourne had finished as Minor Premiers. In 2011, the two clubs met in the preliminary final where Melbourne was defeated by New Zealand in a major upset, thus falling one match short of the 2011 NRL Grand Final.

Sydney Roosters
This competitive rivalry began in the 2017 NRL season when the two clubs met in Round 16 at the Adelaide Oval. The Sydney Roosters won a very tight game in Golden Point 25–24 then only seven weeks later, Melbourne won the return game 16–13 at AAMI Park. In this game, the Sydney Roosters were leading 13–12 after 73 minutes after kicking a field goal before Joe Stimson scored a late try to steal the win just before full time. The competitive nature with the Sydney Roosters increased in the off season when long time player Cooper Cronk announced that he was moving to Sydney and joining the club for 2018.

In the 2018 premiership season, the two clubs only played one game, again at the Adelaide Oval. It was another tight game which this time Melbourne won 9–8 with Cameron Smith kicking a late field goal to snatch victory. The two clubs remained neck and neck at the top of the table with the Sydney Roosters pipping Melbourne for the minor premiership on points difference. The two clubs did not meet until the 2018 NRL Grand Final with the Sydney Roosters winning 21–6. In the game, Cooper Cronk playing injured, assumed a virtual on-field player-coach role, using his years of Grand Final experience to help the Roosters defeat the Melbourne side.

In 2019, the teams clashed twice during the season and both games were close. On Good Friday the Roosters defeated Melbourne 21–20 in Golden point overtime before the teams met once again in Adelaide, with Melbourne prevailing 14–12. The third clash of the year was the preliminary final, which the Sydney Roosters won 14–6 at the SCG.

With the 2020 NRL season disrupted by the COVID-19 pandemic, Melbourne's Round 8 "home" game against the Roosters was transferred to Suncorp Stadium in Brisbane. In a game that produced one of the more extraordinary finishes to an NRL game, the Roosters were leading 22–12 with 12 minutes left when Melbourne then scored two tries to take a 24–22 lead. The game was then tied up by a penalty goal to the Roosters before they also scored a 78th minute field goal to lead 25–24. With seconds remaining, Melbourne's Ryan Papenhuyzen scored a field goal of his own to tie scores up again at 25 all and send the game into Golden Point. Melbourne won the game with Cameron Smith kicking a penalty goal.

As of the end of the 2021 NRL season, the clubs met a further three times with Melbourne winning all three games including defeating the Roosters 46–0 in round 16 of the 2021 season.

The fixture re-ignited in 2022 in round 24 when the Sydney Roosters narrowly defeated Melbourne 18–14 after the Roosters lead 14–0. It was a particularly spiteful game that included repeat melees and sin bins for players on both sides. Sydney Roosters player Jared Waerea-Hargreaves was sin binned following the referee repeatedly warning both sides to fall in line. The game also came on the back of Hooker, Brandon Smith, transferring to the club for the 2023 season. The two sides met in the second week of the 2023 NRL finals series. Melbourne were heavy favourites going into the game but with only minutes remaining the Sydney Roosters were in front 13-12. This was until with three minutes to go Melbourne scored a try through William Warbrick to win the match 18-13. The match wasn't without controversy due to Melbourne scoring a try in the first half which came directly after Harry Grant had knocked the ball on from a cross-field kick.

Stadium and attendances
Melbourne's current home ground is AAMI Park and has been since the 2010 season. Prior to this the club played the vast majority of their home matches at the city's now demolished Olympic Park Stadium, which was located next door. Affectionately coined "The Graveyard" by fans due to the incredible 77.2% winning percentage there, it was there that the club played their inaugural home match in the fourth round of the 1998 season on 3 April 1998, having come off the back of three successive away victories. The team recorded a 26–16 victory over the North Sydney Bears, and the crowd of 20,522 was the largest attendance for the club at Olympic Park.

It was also at this time that Melbourne Storm helped set a Rugby League World record attendance figure of 107,999. This was during the 1999 NRL Grand final, held at Stadium Australia where they defeated the St George Illawarra Dragons, to win their first NRL premiership. As the ground's capacity has since been reduced this record cannot be broken.

The team remained at Olympic Park until the end of the 2000 season, when it was decided that due to attracting larger home crowds which were now averaging 14,622 spectators, they decided to relocate to the much larger capacity Docklands Stadium for the following season. However, due to Docklands stadium being primarily suited to AFL games and in addition the AFL and stadium management being reluctant to reconfigure the seating for Rugby League games and coupled with the team missing the finals that year, crowd numbers declined and it was decided to move the team back to Olympic Park. Docklands stadium was still used by the Storm for home finals until 2010 and this allowed a home final attendance record of 33,427 to be set in 2007 in the Preliminary Final against Parramatta.

From 2002, crowd numbers declined and by 2004 the Storm had their lowest crowd average of 8,886 per home game; however, at this time the Storm also began a strong recruiting drive and with a new and exciting playing roster, crowds steadily rose over the following years, returning to an average of 14,670 by 2010. The Storm played their final game at Olympic Park in round 25 of the 2009 season, 29 August 2009, with a 36–4 thrashing of the Sydney Roosters The intention was to relocate to its new home venue next door at AAMI Park; however, delays in construction meant that the first game could not be played at the venue until Round 9 of the 2010 season, therefore, the first three home games of 2010 were played at Etihad Stadium. Since then all Storm home games (with the exception of a few homes games played interstate), regular season and finals, have been played at AAMI Park.

Following winning the 2012 premiership and having sustained onfield success, crowd numbers continued to rise. The club's highest regular season attendance at AAMI Park, of 28,716, was set on 25 April 2014 for the ANZAC Day match against New Zealand Warriors. Average crowds have continued to increase and by the end of the 2017 season, another premiership year, had reached a record peak of 18,375. The club's highest official "home" attendance of 52,347 occurred in the 2016 season – this was during a doubleheader game at Suncorp Stadium in Brisbane.

For most of the 2020 and much of the 2021 seasons, the Storm played their home games at Sunshine Coast Stadium on Queensland's Sunshine Coast, due to Victoria's strict COVID-19 policies.

Statistics and records
As of Round 15 of the 2022 NRL season, the Storm have won four NRL Premierships (1999, 2012, 2017 and 2020) and five Minor Premierships (2011, 2016, 2017, 2019, 2021). A further two NRL premierships (2007 and 2009) and three minor premierships (2006, 2007, 2008) were withheld due to salary cap breaches. Their current wins percentage of 67.39% is the best in the league. The most capped player is Cameron Smith with 430 NRL appearances in his career. Smith's total is also the current league record and he also the only NRL player in history to reach the 400 game mark. In addition, Smith is also the league's highest point scorer with 2786 career points. Fullback Billy Slater is the club's most prolific try scorer with 190 tries scored during his career. Melbourne Storm players have also won the Dally M medal on five occasions with Smith winning in 2006 and 2017, Slater in 2011 and Cooper Cronk in 2013 and 2016. The Storm have thus far had five Golden Boot award winners, more than any other club (Smith 2007 and 2017, Slater 2008, Greg Inglis 2009 and Cronk in 2016).

Melbourne Storm's winning streak record for the most consecutive matches won stands at 19 matches, between Round 4 and Round 23 of the 2021 NRL season. This is equal to the league record set in 1975 by Eastern Suburbs. The club's all-time highest score is 70 points which they have scored on two occasions, on 3 March 2000 against St. George Illawarra and on 25 April 2022 vs New Zealand Warriors. Their highest winning margin is 64 points which they've achieved twice, first in a 64–0 win over West Tigers in 2001, and then again in a 68–4 win over Canberra Raiders in 2013.

Season summaries
1 This table lists the official Melbourne Storm Club Captains, however, there have been 28 playing captains as of the 2024 season. For a complete list see List of Melbourne Storm records.

2 The Rotating Captains throughout the 2006/2007 seasons were: David Kidwell, Scott Hill, Cameron Smith, Matt Geyer, Michael Crocker, Cooper Cronk, Matt King and Dallas Johnson.

Inaugural team
The first Melbourne Storm team to take to the field in Round 1 of the 1998 NRL season

Team of the decade
As part of their 10-year celebrations in 2007, Melbourne Storm released a team of the decade. The 17-man team was selected by former assistant coach Greg Brentnall, foundation Executive Director John Ribot, and then board member Frank Stanton (all 3 were members of the 1982 Kangaroo tour "Invincibles", Brentnall and Ribot as players with Stanton the coach). The trio were joined by The Daily Telegraph (Sydney) journalist Steve Mascord.

Team of the first 20 years
As part of their 20-year celebrations in 2018, Melbourne Storm announced their team of the first 20 years at a gala night at Crown Casino on 2 March 2018. The 17-man line-up is made up of the greatest players to have pulled on the purple jersey over the last two decades. The team selection panel included Storm Football Director Frank Ponissi, CEO Dave Donaghy, inaugural Executive Director John Ribot, former assistant coach Greg Brentnall, journalist Roy Masters and current coach Craig Bellamy.

Supporters
The Storm have built a loyal supporter base through the years, growing from almost 500,000 in 2004 to almost 800,000 in 2009, making them the fourth most popular NRL team. The club's supporter group, the "Graveyard Crew", make a banner for the team to run through before the start of each game. By 2019, a record membership figure was set with the club having 25,208 people signed up as season ticket holders, a record which was broken in 2021 when over 27,000 members were signed up. In July 2022, the Storm registered 37,237 members, which is the highest membership tally ever recorded by an NRL club.

Notable supporters

 * Dylan Alcott – Former Australian Paralympian Tennis Player
 * Waleed Aly – TV personality The Project
 * Jonny Bairstow – English Cricketer
 * Billy Brownless – Former AFL player and TV/Radio personality
 * Jim Courier — Retired American tennis player, Four time Tennis Grand Slam champion.
 * Sarah De Bono – Australian Musician
 * Mitch Duncan – Australian Rules Footballer
 * Malcolm Fraser − 22nd Prime Minister of Australia
 * Josh Frydenberg − Australian politician
 * Julia Gillard – 27th Prime Minister of Australia
 * Tom Hafey – Australian Rules player and coach
 * Peter Helliar – Australian comedian
 * Dave Hughes- Radio personality
 * Lydia Lassila – Australian Winter Olympian
 * Nicole Livingstone – former Australian Olympic Swimmer

 * Molly Meldrum – music critic, journalist, record producer and musical entrepreneur
 * Sam Newman – former Australian Rules Footballer, now media personality
 * Koti Ngawati – Australian Olympic swimmer
 * Jana Pittman – dual Australian Summer/Winter Olympiad
 * Storm Sanders – Australian tennis player
 * James Sherry — TV presenter
 * Bill Shorten – Minister for the Australian Labor Party
 * Peter Siddle – Australian Test cricketer
 * Bob Skilton – former Australian Rules Footballer
 * Archie Thompson – former Australian Socceroo
 * Mark Viduka – former Australian Socceroo
 * Max Walker – former Australian cricketer and Australian Rules Footballer
 * Shane Watson – Former Australian Test Cricketer
 * Jamie Whincup – Australian motor racing driver
 * Bob Geldof – International Musician

Feeder clubs
In 1998, the Storm established an affiliation with Queensland Cup side the Norths Devils and used the club as a feeder for their first grade team. The relationship would prove to be a fruitful one as 13 of the 17 players to compete for the Storm in the 2006 NRL Grand Final had played for the Devils in previous years. In 2005, the Storm also established an affiliation with the North Sydney Bears in the New South Wales Cup. Melbourne severed ties with both the Bears (end of 2006) and the Devils (end of 2007) and aligned themselves with the Central Coast Storm in the New South Wales Cup. The affiliation lasted two seasons before the Storm decided to establish their own team in the NSW Cup in 2010 which would share its namesake. An unsuccessful venture saw the Storm revert to the Queensland Cup in 2011 when it established a feeder relationship with the Easts Tigers (now known as Brisbane Tigers). Melbourne established a second feeder relationship with the Sunshine Coast Falcons in 2014, also from the Queensland Cup. The Storm further committed to the area in 2015 when it was announced their National Youth Competition U20 side would be based out of the Sunshine Coast from 2016.

History

 * Norths Devils – (Queensland Cup) 1998–2007
 * North Sydney Bears – (New South Wales Cup) 2005–2006, 2024–current
 * Central Coast Storm – (New South Wales Cup) 2008–2009
 * Melbourne Storm – (New South Wales Cup) 2010
 * Cronulla-Sutherland Sharks – (New South Wales Cup) 2011–2014
 * Brisbane Tigers – (Queensland Cup) 2011–current
 * Sunshine Coast Falcons – (Queensland Cup) 2015–current

title: Melbourne Storm


text:
Shield laws in the United States

A shield law is legislation designed to protect reporters' privilege. This privilege involves the right of news reporters to refuse to testify as to the information and/or sources of information obtained during the news gathering and dissemination process. Currently, the U.S. federal government has not enacted any national shield laws, but most of the 50 states do have shield laws or other protections for reporters in place.

More generally the term "shield law" is applied to laws protecting people in one state from prosecution by another state for providing services illegal there, specifically for providing medications causing abortion.

Definition
A shield law is a law that gives reporters protection against being forced to disclose confidential information or sources in state court. There is no federal shield law and state shield laws vary in scope. In general, however, a shield law aims to provide the protection of: "a reporter cannot be forced to reveal his or her source". Thus, a shield law provides a privilege to a reporter pursuant to which the reporter cannot be forced by a subpoena or other court order to testify about information contained in a news story and/or the source of that information. Several shield laws additionally provide protection for the reporter even if the source or information is revealed during the dissemination of the news story, that is whether or not the source or information is confidential. Depending on the jurisdiction, the privilege may be total or qualified, and it may also apply to other persons involved in the news-gathering and dissemination process as well, such as an editor or a publisher. However, shield laws do not ensure absolute protection.

Origins
The issue of whether or not journalists can be subpoenaed and forced to reveal confidential information arose in 1972 with the United States Supreme Court case Branzburg v. Hayes. Paul Branzburg was a reporter for The Courier-Journal in Louisville, Kentucky and wrote an article about the drug hashish. In creating the article, he came in contact with two local citizens who had created and used the drug. Because their activity was illegal, Branzburg promised the two individuals that he would not reveal their identities. After the article was published, Branzburg was subpoenaed by a local grand jury and ordered to reveal the identity of his sources. Branzburg refused and cited the provisions for freedom of the press from the First Amendment of the Constitution, in his defense.

The Supreme Court decided in a five to four decision that the press did not have a Constitutional right of protection from revealing confidential information in court. The court acknowledged, however, that the government must "convincingly show a substantial relation between the information sought and a subject of overriding and compelling state interest." While this ruling did not set a precedent for journalistic rights in court, it did define a more stringent set of requirements for when a journalist could be subpoenaed in court.

This ruling was limited in nature, did not set a clear federal precedent regarding journalistic privileges from revealing confidential information, and thus has been interpreted and cited differently by courts over the years. The Third Circuit Court of Appeals, for instance, has gleaned a qualified First Amendment privilege from the Branzburg decision. In Riley v. City of Chester, the Court held that a reporter's right to protect his sources from disclosure could be overcome by a party who, by a preponderance of the evidence, demonstrated that he has made an effort to obtain the information elsewhere, that the only access to the information sought is through the journalist and his or her source, and that the information sought is crucial to the case. 612 F.2d 708 (3rd Cir. 1979).

State laws
States differ on their approach to protecting reporter's privilege. , 49 states and the District of Columbia offer some form of protections Forty states (plus D.C.) have passed shield laws. These laws vary from state to state. Some protections apply to civil but not to criminal proceedings. Other laws protect journalists from revealing confidential sources, but not other information. Many states have also established court precedents which provide protection to journalists, usually based on constitutional arguments. Only Wyoming lacks both legislation and judicial precedent to protect reporter's privilege.

Current issues
Proponents of shield laws argue that they ensure that news gatherers may do their jobs to their fullest ability and that they help avoid a dichotomy between state laws and journalistic ethics, but the differences between states' laws has raised questions regarding which laws apply where in regard to national reporting. Proponents argue that a federal shield law should exist to eliminate contradictions between state laws.

Opponents argue that shield laws afford extra privileges to journalists and that no citizen should be able to ignore a court ordered subpoena. Opponents also cite problems with defining who is considered a journalist or news gatherer and who is not, and note that if journalists get special protection from the government, then they are getting special journalistic benefits from the government instead of acting in complete independence. Some opponents also argue that journalists are often forced to testify by federal courts only in cases where a federal shield law likely would not protect them anyway. Finally, the federal government may not have constitutional right to enforce a shield law on state courts.

Many journalists, however, are subpoenaed to testify in criminal and civil cases for coverage of a variety of matters that do not involve questions of national security. In recent years, there have been bills for federal shield laws in the United States Congress; however, none of these bills have passed the Senate. A primary objection to recent efforts to pass a federal shield law has been concern about leaks of classified information, particularly given the modern potential of such leaks to be published globally on the Internet by non-traditional recipients, such as WikiLeaks, who might claim to be "journalists" under an unqualified shield law.

Sometimes, the press is not even immune from its sources, such as when the source wishes to remain anonymous and the journalist wishes to disclose it. Such was the case in Cohen v. Cowles Media Co. (1991). The Supreme Court upheld that a source may have a right to confidentiality if an agreement was made with the reporter. Unfortunately, the bigger issue of source disclosure gets even more confusing, since the Cohen and Branzburg decisions could allow for the possibility of a journalist being subpoenaed by a court to disclose the name of a source, and being sued by a source under promissory estoppel laws for that disclosure. The current laws of the land, and the gray areas of forecasting potential consequences of publishing a story with confidential sources places the press in a very precarious situation. The current shield laws in some states give the press somewhat of an upper hand. However, since federal law does not recognize reportorial privilege in most cases, it is understandable how the press might feel muzzled.

The shield law privilege may also be waived by a reporter, as the New Jersey Supreme Court recently found in the case of In re Michael G. Venezia. In that case, a New Jersey newspaper published an article containing defamatory statements about the plaintiff. The article attributed the statements to a source who was identified by name in the article; the source later denied making the defamatory statements. The plaintiff filed a defamation lawsuit against the newspaper, the reporter and the alleged source of the defamatory statements. When the plaintiff sought to question the newspaper reporter about the article, the reporter and his newspaper refused, claiming protection under New Jersey's shield law. It was discovered, however, that the reporter had already given a statement under oath concerning the article—and, most important, the alleged source of the statement and exactly what that source said—to a local county prosecutor's office. The reporter also talked about his source and what the source said with a local municipal attorney. The Venezia court unanimously held that, while New Jersey has arguably the most protective shield law in the United States, a reporter waives the privilege when he talks about his sources and information outside of the newsgathering process, as did the reporter in Venezia. The Venezia court stated: "The privilege holder is not permitted to step from behind the shield as he pleases, sallying forth one moment to make a disclosure to one person and then to seek the shield's protection from having to repeat the same disclosure to another person.  A reporter cannot play peek-a-boo with the privilege." Thus, the Venezia court ordered that the reporter must submit to the plaintiff's deposition request. Venezia is highly significant because it marks the first time that a reporter has ever been found to have waived the privilege under New Jersey's current shield law, and because it explores the issue of what is or is not a "newsgathering activity," and, thus, what activities are subject to protection under the law.

Currently, courts are struggling to define the standards for when shield laws should apply to non-traditional media outlets, particularly in the context of blogs and Internet publishing. In Obsidian Finance Group, LLC v. Cox, the United States District Court for the District of Oregon found that to qualify as a reporter, a standard of professionalism must be met, including but not limited to being associated with a traditional news print or television media outlet or obtaining a journalism degree. A subsequent opinion in the same case clarified that these were examples and not requirements; bloggers could qualify, and the denial of media status in the Cox case appears to have been largely motivated by the defendant reportedly offering to remove accusations for a substantial fee. Conversely, in The Mortgage Specialists, Inc. v. Implode-Explode Heavy Industries, Inc. the New Hampshire Supreme Court adopted a much broader definition of media that applies to blogs and website curators, reiterating that "freedom of the press is a fundamental personal right which is not confined to newspapers and periodicals."

In July 2013 the White House was pushing for a federal media shield law named the Free Flow of Information Act authored by U.S. Senators Charles Schumer and Lindsey Graham. Under the bill, the scope of protection for reporters would vary according to whether it was a civil case, an ordinary criminal case or a national security case. The greatest protection would be given to civil cases, in which litigants seeking to force reporters to testify or trying to obtain their calling information would be required to show why their need for the information outweighed the public's interest in unfettered news gathering. Ordinary criminal cases would work in a similar fashion, except the burden would be on the reporter seeking to quash the subpoena to show by a "clear and convincing" standard that the public interest in the free flow of information should prevail over the needs of law enforcement. Cases involving the disclosure of classified information would be more heavily tilted toward the government. Judges could not quash a subpoena through a balancing test if prosecutors presented facts showing that the information sought might help prevent a terrorist attack or other acts likely to harm national security. The legislation would create a presumption that when the government is seeking calling records from a telephone carrier, the news organization would be notified ahead of time, allowing it to fight the subpoena in court. But the bill would also allow the government to seek a 45- to 90-day delay in notification if a court determines that such notice would threaten the integrity of the investigation. The legislation would also include an exception where journalists could be subpoenaed if it means national security is at risk.

Related issues
In recent years, a larger effort by journalists to press for federal shield laws formed following the Plame affair, in which reporters who released the name of Valerie Plame were asked who their sources were. One of the reporters, Judith Miller of The New York Times, was jailed for 85 days in 2005 for refusing to disclose her source in the government probe.

There is also a question about whether or not journalists should be exempt from national security laws.

Shield laws for medical practitioners
In 2023 a paper was published in the Columbia Law Review about ways in which shield laws could protect medical practitioners providing abortion who treated patients in US states that prohibited abortion. Following publication of the paper, several states passed shield laws for medical practitioners. fifteen states had such shield laws, and five had telemedicine provisions, specifically protecting a provider who prescribed and mailed abortion pills to a patient in a state where abortion was banned. From 18 June 2023 Aid Access mailed medication to patients throughout the US with providers licensed in the five states with telemedicine provisions, with no need to ship from other countries as had been necessary before. It was expected that legal battles would follow as the shield laws were tested in court. Patients themselves were not protected by the shield laws, and remained subject to prosecution for self-managing abortions.

title: Shield laws in the United States


text:
User:Whitfield Larrabee

My full name is John Whitfield Larrabee, III. I am known as Whit.

I live in Massachusetts, USA.

title: User:Whitfield Larrabee


text: User talk:67.168.254.236

title: User talk:67.168.254.236