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Employee Retirement Income Security Act of 1974

The Employee Retirement Income Security Act of 1974 (ERISA) (, codified in part at ) is a U.S. federal tax and labor law that establishes minimum standards for pension plans in private industry. It contains rules on the federal income tax effects of transactions associated with employee benefit plans. ERISA was enacted to protect the interests of employee benefit plan participants and their beneficiaries by:
 * Requiring the disclosure of financial and other information concerning the plan to beneficiaries;
 * Establishing standards of conduct for plan fiduciaries;
 * Providing for appropriate remedies and access to the federal courts.

ERISA is sometimes used to refer to the full body of laws that regulate employee benefit plans, which are mainly in the Internal Revenue Code and ERISA itself.

Responsibility for interpretation and enforcement of ERISA is divided among the Department of Labor, the Department of the Treasury (particularly the Internal Revenue Service), and the Pension Benefit Guaranty Corporation.

History
In 1961, U.S. President John F. Kennedy created the President's Committee on Corporate Pension Plans. The movement for pension reform gained some momentum when the Studebaker Corporation, an automobile manufacturer, closed its plant in 1963. Its pension plan was so poorly funded that Studebaker could not afford to provide all employees with their pensions. The company created a program in which 3,600 workers who had reached the retirement age of 60 received full pension benefits, 4,000 workers aged 40–59 who had ten years with Studebaker received lump sum payments valued at roughly 15% of the actuarial value of their pension benefits, and the remaining 2,900 workers received no pensions.

In 1963, Senator John L. McClellan (D) of Arkansas began an investigation through the Permanent Investigations Senate Subcommittee into labor leader George Barasch, alleging misuse and diversion of $4,000,000 of union benefit funds. After three years the investigation had failed to find any wrongdoing, but had resulted in several proposed laws, including McClellan's October 12, 1965 bill setting new fiduciary standards for plan trustees. Additionally, due much in part to his "dismay" over Barasch's sole control over union benefit plan funds, Senator Jacob K. Javits (R) of New York also introduced bills in 1965 and 1967 increasing regulation of welfare and pension funds to limit the control of plan trustees and administrators and to address the funding, vesting, reporting, and disclosure issues identified by the presidential committee. His bills were opposed by business groups and labor unions, which sought to retain the flexibility they enjoyed under pre-ERISA law. Provisions from all three bills ultimately evolved into the guidelines enacted in ERISA.

On September 12, 1972, NBC broadcast an hour-long television special, Pensions: The Broken Promise, that showed millions of Americans the consequences of poorly funded pension plans and onerous vesting requirements. In the following years, Congress held a series of public hearings on pension issues and public support for pension reform grew significantly.

ERISA was enacted in 1974 and signed into law by President Gerald Ford on September 2, 1974, Labor Day. In the years since 1974, ERISA has been amended repeatedly.

Pension plans
ERISA does not require employers to establish pension plans. Likewise, as a general rule, it does not require that plans provide a minimum level of benefits. Instead, it regulates the operation of a pension plan once it has been established.

Under ERISA, pension plans must provide for vesting of employees' pension benefits after a specified minimum number of years. ERISA requires that the employers who sponsor plans satisfy certain minimum funding requirements.

ERISA also regulates the manner in which a pension plan may pay benefits. For example, a defined benefit plan must pay a married participant's pension as a "joint-and-survivor annuity" that provides continuing benefits to the surviving spouse unless both the participant and the spouse waive the survivor coverage.

The Pension Benefit Guaranty Corporation was established by ERISA to provide coverage in the event that a terminated defined benefit pension plan does not have sufficient assets to provide the benefits earned by participants. Later amendments to ERISA require an employer who withdraws from participation in a multiemployer pension plan with insufficient assets to pay all participants' vested benefits to contribute the pro rata share of the plan's unfunded vested benefits liability.

There are two main types of pension plans: defined benefit plans and defined contribution plans. Defined benefit plans provide retirees with a certain level of benefits based on years of service, salary and other factors. Defined contribution plans provide retirees with benefits based on the amount and investment performance of contributions made by the employee and/or employer over a number of years.

Health benefit plans
Likewise, ERISA does not require that an employer provide health insurance to its employees or retirees, but it regulates the operation of a health benefit plan if an employer chooses to establish one.

ERISA exempts health insurance plans from various state-specific laws, particularly contract and tort law, to create federal uniformity;, about 60% of insured employees in the US were in self-funded plans subject to ERISA. ERISA has led to tension with reforms which partner with the states, such as the Patient Protection and Affordable Care Act.

There have been several significant amendments to ERISA concerning health benefit plans:
 * The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provides some employees and beneficiaries with the right to continue their coverage under an employer-sponsored group health benefit plan for a limited time after the occurrence of certain events that would otherwise cause termination of such coverage, such as the loss of employment.
 * The Health Insurance Portability and Accountability Act of 1996 (HIPAA) prohibits a health benefit plan from refusing to cover an employee's pre-existing medical conditions in some circumstances. It also bars health benefit plans from certain types of discrimination on the basis of health status, genetic information, or disability.

Other relevant amendments to ERISA include the Newborns' and Mothers' Health Protection Act, the Mental Health Parity Act, and the Women's Health and Cancer Rights Act.

During the 1990s and 2000s, many employers who promised lifetime health coverage to their retirees limited or eliminated those benefits. ERISA does not provide for vesting of health care benefits in the way that employees become vested in their accrued pension benefits. Employees and retirees who were promised lifetime health coverage may be able to enforce those promises by suing the employer for breach of contract, or by challenging the right of the health benefit plan to change its plan documents to eliminate promised benefits.

Pension vesting
Before ERISA, some defined benefit pension plans required decades of service before an employee's benefit became vested. It was not unusual for a plan to provide no benefit at all to an employee who left employment before the specified retirement age (e.g. 65), regardless of the length of the employee's service.

Under the Pension Protection Act of 2006, employer contributions made after 2006 to a defined contribution plan must become vested at 100% after three years or under a 2nd-6th year gradual-vesting schedule (20% per year beginning with the second year of service, i.e. 100% after six years). (ref. 120 Stat. 988 of the Pension Protection Act of 2006.) The Technical Explanation of H.R.4, of the PPA, Page 156 Vesting Rules, states that the PPA amends both the ERISA and Code. Different rules apply with respect to employer contributions made before 2007. Employee contributions are always 100% vested. Accrued benefits under a defined benefit plan must become vested at 100% after five years or under a 3rd-7th year gradual vesting schedule (20% per year beginning with the third year of vesting service, and 100% after seven years). (ref. 26 U.S.C. 411(a)(1)(B), 29 U.S.C. 203(a)(2).)

Pension funding
ERISA established minimum funding requirements for pension plans, which includes defined benefit plans and money purchase plans but not profit sharing or stock bonus plans.

Before the Pension Protection Act of 2006 (PPA), a defined benefit plan maintained a funding standard account, which was charged annually for the cost of benefits earned during the year and credited for employer contributions. Increases in the plan's liabilities due to benefit improvements, changes in actuarial assumptions, and any other reasons were amortized and charged to the account; decreases in the plan's liabilities were amortized and credited to the account. Every year, the employer was required to contribute the amount necessary to keep the funding standard account from falling below $0 at year-end.

In 2008, when the PPA funding rules went into effect, single-employer pension plans no longer maintain funding standard accounts. The funding requirement under PPA is simply that a plan must stay fully funded (that is, its assets must equal or exceed its liabilities). If a plan is fully funded, the minimum required contribution is the cost of benefits earned during the year. If a plan is not fully funded, the contribution also includes the amount necessary to amortize over seven years the difference between its liabilities and its assets. Stricter rules apply to severely underfunded plans (called "at-risk status").

The PPA has different funding requirements for multiemployer pension plans, which preserve most of the pre-PPA funding rules, including the funding standard account. Under PPA, increases and decreases in the plan's liabilities are amortized, but the amortization period for benefit improvements adopted after 2007 are shortened. As with single-employer plans, multiemployer pension plans that are significantly underfunded are subject to restrictions. The restrictions, which may limit the plan's ability to improve benefits or require the plan to reduce employees' benefits, vary depending whether a pension plan's funding status is termed "endangered", "seriously endangered", or "critical". The restrictions accompanying each deficient funding status are progressively more severe as funding status worsens.

ERISA preemption
ERISA Section 514 preempts all state laws that relate to any employee benefit plan, with certain, enumerated exceptions. The most important exceptions (i.e., state laws that survive despite the fact that they may relate to an employee benefit plan) are state insurance, banking, or securities laws, generally applicable criminal laws, and domestic relations orders that meet ERISA's qualification requirements. ERISA also does not govern public pension funds, but it is often looked to for guidance regarding fund duties in addition to state pension codes.

A major limitation is placed on the insurance exception, known as the "deemer clause", which essentially provides that state insurance law cannot operate on employer self-funded benefit plans. The Supreme Court has created another limitation on the insurance exception, in which even a law that regulates insurance is preempted if it purports to add a remedy to a participant or beneficiary in an employee benefit plan that ERISA did not explicitly provide.

A three-part analysis is used to decide whether ERISA preempts state law. First, preemption is presumed if the state law "relates to" any employee benefit plan. Second, a state law relating to an employee benefit plan may be protected from preemption under ERISA if it regulates insurance, banking, or securities. The third step of the ERISA preemption analysis concerns the "deemer" clause. State insurance regulation may be saved only to the extent that it regulates genuine insurance companies or insurance contracts. As a result, a state may not "deem" that an employee benefit plan is an insurance plan in an effort to sidestep preemption if the benefit plan would not otherwise meet the requirements as an insurance company or contract. The "deemer" clause therefore restricts the use of the "savings" clause to conventionally insured employee benefit plans.

The result of ERISA preemption is that the only remedy available to a covered person who has been denied benefits or dropped from coverage altogether is to seek an order from a federal judge (no jury trial is permitted) directing the Plan (in actuality the insurance company that underwrites and administers it) to pay for "medically necessary" care. If a person dies before the case can be heard, however, the claim dies with him or her, since ERISA provides no remedy for injury or wrongful death caused by the withholding of care.

Even if benefits are improperly denied, the insurance company cannot be sued for any resulting injury or wrongful death, regardless of whether it acted in bad faith in denying benefits. Insurers operating ERISA plans enjoy several immunities not available to other types of insurance companies. ERISA preempts all conflicting state laws, including state statutes prohibiting unfair claims practices and causes of action arising under state common law for insurance bad faith. There is no right to a jury trial in ERISA benefits actions. Although Americans normally take for granted the right to testify on their behalf, plaintiffs have no right to present live testimony in ERISA bench trials, in which the judge simply reads through the documents that formed the record originally before the ERISA plan administrator and performs de novo review. Finally, punitive damages are not allowed in actions for ERISA benefits.

It has been argued that in the case of health benefits, the effect of all of this may paradoxically have been to leave plan participants worse off than if ERISA had not been enacted.

Many persons included among the some 29 million people presently without health care coverage in the United States are former ERISA "subscribers", insurance terminology for Plan beneficiaries, who have been denied benefits-usually on the ground that the prescribed care is not medically necessary or is "experimental"-or dropped from coverage, often because they have lost their jobs due to the very illness for which care was denied.

Many consumer and health care advocates have called for a "restoration of the freedom of contract enforcement," to the 75% of Americans insured under these work place group plans-in effect, a repeal of the ERISA preemption. Permitting these insured persons access to customary state remedies (98% of all civil disputes are resolved in state courts) would, they contend, result in a substantial reduction in arbitrary denial of care benefits, simultaneously alleviating a major burden on state Medicaid systems and clogged federal court dockets.

Hawaii Prepaid Health Care Act exemption
ERISA contains an exemption specifically regarding the Hawaii Prepaid Health Care Act (Hawaii Revised Statutes Chapter 393), which was enacted by that state a few months before ERISA was signed into law. As a result, private employers in Hawaii are bound by the rules of that state law in addition to ERISA. The exemption also freezes the law in its original 1974 form, meaning the Hawaii legislature is not able to make non-administrative amendments without Congressional approval.

Title I: Protection of Employee Benefit Rights
Title I protects employees' rights to their benefits. The following are some of the ways in which it achieves that goal:
 * Participants must be provided plan summaries.
 * Employers are required to report information about the plan to the Labor Department and provide it to participants upon request. The information is reported on Form 5500, which is available for public inspection.
 * If a participant requests, the employer must provide the participant with a calculation of her or his accrued and vested pension benefits.
 * Employers have fiduciary responsibility to the participants and to the plan.
 * Certain service providers, such as investment managers, have fiduciary responsibilities to the plan.
 * Certain transactions between the employer and the plan are prohibited.
 * Certain transactions between fiduciary and the plan, or between the plan and certain "parties in interest" are prohibited (unless otherwise exempt).
 * A pension plan is barred from investing more than 10% of its assets in employer securities.

Title I also includes the pension funding and vesting rules described above.

The United States Department of Labor's Employee Benefits Security Administration ("EBSA") is responsible for overseeing Title I, promulgating regulations implementing and interpreting the statute as well as conducting enforcement. Plan fiduciaries and plan participants may also bring certain civil causes of action in Federal Court.

Title II: Amendments to the Internal Revenue Code Relating to Retirement Plans
Title II amended the Internal Revenue Code (IRC). The changes include the following:
 * Addition of various requirements for a pension plan to be tax-favored ("qualified"), including:
 * The plan must offer retirees the option of a joint-and-survivor annuity
 * Plan benefits may not discriminate in favor of officers and highly paid employees
 * Plans are subject to the pension funding and vesting rules described above.
 * Imposition of maximum limits on the annual benefit that may be paid from a qualified defined benefit pension plan and the annual contribution that may be made to a qualified defined contribution pension plan
 * The creation of individual retirement accounts (IRAs).
 * Revision of rules concerning the maximum tax deduction allowed with respect to a contribution to a pension plan
 * Imposition of an excise tax if the employer fails to make a required contribution to a pension plan or engages in transactions prohibited by ERISA

Title III: Jurisdiction, Administration, Enforcement; Joint Pension Task Force, Etc.
Title III outlines procedures for co-ordination between the Labor and Treasury Departments in enforcing ERISA.

It also created the Joint Board for the Enrollment of Actuaries, which licenses actuaries to perform a variety of actuarial tasks required of pension plans under ERISA. The Joint Board administers two examinations to prospective Enrolled Actuaries. After an individual passes the two exams and completes sufficient relevant professional experience, she or he becomes an Enrolled Actuary.

Title IV: Plan Termination Insurance
Title IV created the Pension Benefit Guaranty Corporation (PBGC) to insure benefits of participants in underfunded terminated plans. It also describes the procedures that a pension plan must follow to terminate itself, and for the PBGC to initiate an involuntary termination.

Standard termination
An employer may terminate a single-employer plan under a standard termination if the plan's assets equal or exceed its liabilities. If the assets are less than the liabilities, the employer must contribute the amount necessary to fully fund the plan. A standard termination is sometimes referred to as a voluntary termination because the employer has chosen to terminate the plan.

In a standard termination, all accrued benefits under the plan become 100% vested. The plan must purchase annuity contracts for all participants. If the plan permits the payment of lump sums, employees may be offered the choice of a lump sum payment or an annuity.

If any assets remain in the plan after a standard termination has been completed, the provisions of the plan control their treatment. In some plans, the excess assets revert to the employer; in other plans, the excess assets must be used to increase participants' benefits.

Distress termination
An employer may terminate a single-employer plan under a distress termination if the employer demonstrates to the PBGC that one of these conditions exists:
 * Employer faces liquidation under bankruptcy proceedings.
 * Costs of continuing the plan will make the business fail.
 * Costs of continuing the plan have become unreasonably burdensome solely because of a decline in the employer's workforce.

If the PBGC finds that a distress termination is appropriate, the plan's liabilities are calculated and compared with its assets. Depending on the difference between the two values, the termination may be treated as if it had been a standard termination or as if it had been initiated by the PBGC.

Termination initiated by the PBGC
PBGC may initiate proceedings to terminate a single-employer plan if it determines one of the following:
 * The employer has not made its minimum required contributions to the plan.
 * The plan will not be able to pay benefits when due.
 * PBGC's long-term cost can be expected to be unreasonably higher if it does not terminate the plan.

A termination initiated by the PBGC is sometimes called an involuntary termination.

The benefits paid by the PBGC after a plan termination may be less than those promised by the employer. See Pension Benefit Guaranty Corporation for details.

Multiemployer plans
A multiemployer plan may be terminated in one of three ways:
 * It may be amended so that participants receive no credit for future service.
 * All contributing employers may withdraw from the plan or stop making contributions to it.
 * It may convert into a defined contribution plan.

Non-ERISA status and bankruptcy
In 2005, the BAPCPA amended the Bankruptcy Code, by exempting most organized retirement plans, even those not subject to ERISA, and accorded them protected status, claimable as exempt property by a debtor declaring bankruptcy under the U.S. Bankruptcy Code.

Now, most pension plans have the same protection as an ERISA anti-alienation clause giving these pensions the same protection as a spendthrift trust. The only remaining unprotected areas are the SIMPLE IRA and the SEP IRA. The SEP IRA is functionally similar to a self-settle trust, and a sound policy reason would exist to not shield SEP IRAs, but many financial planners argue that a rollover (or direct transfer) from a SEP IRA to a rollover IRA would give those funds protected status, too.

Finding statutes
Portions of ERISA are codified in various places of the United States Code, including, and Internal Revenue Code sections and  (relating to the Individual Retirement Account) and sections  through , and ,  and. A cross-reference between the sections of the ERISA law and the corresponding sections in the U.S.Code can be found at http://www.harp.org/erisaxref.htm.


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Tyler Christopher (actor)

Tyler Christopher Baker (November 11, 1972 – October 31, 2023) was an American actor. He was best known for his roles as Nikolas Cassadine (1996–1999, 2003–2011, 2013–2016) and Connor Bishop (2004–2005) on the ABC soap opera General Hospital.

In August 2016, it was announced that Christopher would be joining the cast of the NBC soap opera Days of Our Lives as the son of long-time villains Stefano DiMera and Vivian Alamain. His tenure on the show began December 29, 2017. Christopher left the series on March 20, 2019.

Early life
Tyler Christopher Baker was born in the Chicago suburb of Joliet, Illinois, on November 11, 1972, to Jim and Jimi-Ann Baker and grew up in Delaware, Ohio, the youngest of four children. Though his parents believed they had Native American heritage, a DNA test taken by his father and sister showed no Native American ancestry.

Christopher attended Ohio Wesleyan University for two years.

Career
In 1993, Christopher — then credited as Tyler Baker — auditioned for the role of Stone Cates for the soap opera General Hospital; the role was later cast with actor Michael Sutton. In April 1996, Christopher was cast in the role of Nikolas Cassadine for the serial; he signed a three-year deal and filmed his first scenes in late June 1996. In June 1999, it was announced that Christopher opted not to renew his deal with the soap opera. Following his daytime departure, Christopher made guest appearances on primetime shows including Charmed, Angel, Felicity, and CSI: Crime Scene Investigation. In March 2003, it was announced that Christopher would return to General Hospital; then-executive producer Jill Farren Phelps described Christopher's return as an opportunity the serial could not pass up.

In March 2011, Soap Opera Digest reported on their social media accounts that Christopher had been let go from the serial, due to Christopher's casting on ABC Family's The Lying Game, produced by former General Hospital head writer Charles Pratt Jr. Christopher verified the reports of his firing to ABC Soaps In Depth; he explained that he had been released from his deal on Friday March 18, 2011, and the character of Nikolas was to be written out. Christopher's deal was set to expire in June and the date would have marked the beginning of the last 13 week-cycle period in his deal—at which time the network would notify the actor of their decision to offer another deal. While Christopher had previously admitted he was unsure about renewing his deal, he was open to working both shows and thought it was a likely possibility considering they were both under ABC. Christopher last appeared on June 30, 2011; he later returned for a three-day guest appearance from July 27 to July 30, 2011.

In March 2013, Christopher returned in a recurring capacity at General Hospital, while continuing to appear on The Lying Game. In June 2013, it was announced that Christopher had signed a deal to appear on a regular basis on General Hospital. The following month, it was announced that The Lying Game had been canceled after two seasons. In May 2016, actor Nick Stabile was temporarily cast in the role of Nikolas, with Christopher being unavailable, for an undisclosed amount of time. In September 2016, Soap Opera Digest reported that negotiations between Christopher and the serial had fallen apart, and that he would not be reprising his portrayal of Nikolas. Christopher made his last appearance on June 16, 2016.

In August 2017, it was announced that Christopher had joined the cast of Days of Our Lives in a newly created role. Christopher previously made a one-episode guest appearance on the soap in 2001. He made his first appearance as Stefan DiMera on December 29, 2017. His last episode was March 20, 2019.

Personal life
Christopher was married to Eva Longoria from 2002 to 2004. He was previously engaged to General Hospital co-star Vanessa Marcil and dated Natalia Livingston. He and auto racing reporter Brienne Pedigo publicly announced their engagement in October 2006; Christopher and Pedigo married September 27, 2008. The couple had their first child, a son, on October 3, 2009. In October 2014, it was announced that Christopher and his wife were expecting their second child, due in May 2015. On May 3, 2015, Christopher announced on his official Twitter feed that Brienne Pedigo had given birth to a baby girl. Brienne Pedigo filed for divorce in February 2019.

In later years of his life, Christopher was open about his bipolar disorder and alcoholism. He claimed to have died 3 times in alcohol related instances. In November 2019 while Christopher was going through alcohol withdrawal, he experienced delirium tremens, leading to a fall during which he hit his head on the edge of a bathtub and sustained a traumatic brain injury. He underwent a craniotomy to relieve pressure on his brain.

After recovering from his head injury and ending a medical guardianship under his sister in September 2021, Christopher moved to Hollywood from Ohio to try to find work as an actor where he was homeless for the first six months. Before his death, he was close friends with General Hospital co-star Maurice Benard who is also diagnosed with bipolar disorder and gave support to Christopher.

Legal issues
On November 11, 2019, Christopher was arrested and charged with public intoxication in Martinsville, Morgan County, Indiana after falling asleep in the back of an Uber car. He pleaded guilty and paid a small fine.

From January 2020 to September 2021, Christopher was placed under the medical guardianship of his sister Susan Asmo Baker following a nearly fatal head injury. After requesting that the guardianship be ended and his sister approving, he filed a lawsuit against her, citing guardianship abuse and alleging that she misused $40,000.

In May 2023, Christopher was arrested on suspicion of public intoxication at the Hollywood Burbank Airport. Police responded to reports of a drunk male and arrived to find him sleeping on the ground near a terminal. He was arrested and fined.

Death
On October 31, 2023, Tyler Christopher was found dead. His cause of death was revealed to be positional asphyxia due to acute alcohol intoxication. He was 50 years old.

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

title: Tyler Christopher (actor)


text:
The Autobiography of Alice B. Toklas

The Autobiography of Alice B. Toklas is a book by Gertrude Stein, written in October and November 1932 and published in 1933. It employs the form of an autobiography authored by Alice B. Toklas, her life partner. In 1998, Modern Library ranked it as one of the 20 greatest English-language nonfiction books of the 20th century.

Before I Came to Paris
Alice B. Toklas, as narrator of the work, tells how she was born into an affluent family in San Francisco, describing her parents' backgrounds and family history. Later she describes meeting Gertrude Stein's sister-in-law during the fires in the aftermath of the 1906 San Francisco earthquake, and decided to move to Paris in 1907.

My Arrival in Paris
Alice writes about the important role of Hélène, Gertrude's housemaid, in their household in Paris. She mentions preparations for an art exhibition. She discusses Pablo Picasso and his mistress Fernande Olivier. Picasso and Fernande end their relationship, and Fernande moves to Montparnasse to teach French. Alice and Gertrude visit her there.

Gertrude Stein in Paris, 1903–1907
Alice tells of Gertrude and her brother Leo Stein buying paintings by Paul Cézanne and Henri Matisse from Ambroise Vollard. They subsequently all become friends. She next discusses spending the summer with Gertrude in Fiesole, Italy, while Picasso goes to Spain. Back in France, Gertrude falls out with Guillaume Apollinaire. Later, Picasso has an argument with Matisse.

Gertrude Stein Before She Came to Paris
Alice tells how Gertrude Stein was born in Allegheny, Pennsylvania, then moved to Vienna, to Passy, and finally to New York City and California. She attended Radcliffe College, where she was taught by William James. She decided to study for a master's degree at Johns Hopkins University but dropped out because she was bored, then moved to London and was bored there too, returned to America, and eventually settled in Paris.

1907–1914
The episode describes the home at 27 rue de Fleurus, noting the layout of the rooms and studio (atelier). Alice tells stories about Matisse, other artists, and the writer Apollinaire. She recounts holidays in Italy and Spain with Gertrude. Finally, they move to England on the eve of World War I to meet with Gertrude's editor, leaving Mildred Aldrich alone in Paris.

The War
Gertrude and Alice begin the war years in England, and then go briefly to France to rescue Gertrude's writings. They then live in Spain for a while, and eventually move back to France. There, they volunteer for the American Fund for the French Wounded, driving through France to help the wounded and homeless. By the end of the war, Paris seems changed.

After the War, 1919–1932
Alice tells of Gertrude's argument with T. S. Eliot after he finds one of her writings inappropriate. She talks about her friendship with Sherwood Anderson and Ernest Hemingway, who helped with the publication of The Making of Americans. There the couple makes friends with a coterie of Russian artists, but they constitute no artistic movement. Later, Gertrude gives a lecture at Oxford University. Alice then mentions more parties with artists. Later, they abridge The Making of Americans to four hundred pages for commercial reasons and devise the idea of writing an autobiography.

Literary significance and criticism
Gertrude Stein admitted to writing the work in six weeks with the aim of making money. However, she did not like writing it for that particular reason, and Alice didn't think it would be a success. It was the first of Stein's writings to be published in the Atlantic Monthly, much to her joy. The magazine published sixty per cent of the book, in four installments.

As for her friends, Carl Van Vechten liked it; Henry McBride thought it was too commercial; Ernest Hemingway called it a "damned pitiful book"; Henri Matisse was offended by the descriptions of his wife; and Georges Braque thought that Stein had misconstrued Cubism. Her brother Leo Stein deemed it a "farrago of lies". The commercial success that came with her book enabled Stein to live a more prosperous lifestyle.

According to Virgil Thomson, who wrote music to libretti written by Stein, the "book is in every way except actual authorship Alice Toklas's book; it reflects her mind, her language, her private view of Gertrude, also her unique narrative powers. Every story in it is told as Alice herself had always told it. ... Every story that ever came into the house eventually got told in Alice's way, and this was its definitive version."

Several critics, including Jeanette Winterson, have noted that in this book Stein created a new literary form, building upon Virginia Woolf's fictional biography Orlando to make her own reinterpretation of the autobiographical genre.

title: The Autobiography of Alice B. Toklas


text:
Carlos Mayans

Carlos Mayans (born July 8, 1948) became mayor of the city of Wichita, Kansas in April 2003. He was born in Havana, Cuba in 1948 and emigrated to the United States through the Operation Peter Pan shortly after the Cuban Revolution of 1959. In addition to serving as mayor, Mayans also served as a Republican representative for Wichita's 100th district in the Kansas House of Representatives for five terms and ran an insurance agency before becoming mayor. He lost a re-election bid for mayor to Carl Brewer by 61% to 37% in 2007.

title: Carlos Mayans


text:
User talk:Fmobus

Welcome
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October 2004
That "about me" page you wrote should go to your user page... :]

Cheers! Omar "Ekevu" Balbuena 20:05, 10 Oct 2004 (UTC)

May 2021
Hi, and thank you for your contributions to Wikipedia. Your recent talk page comments on Talk:List of United States military bases were not added to the bottom of the page. New discussion page messages and topics should always be added to the bottom. Your message may have been moved. In the future you can use the "Add topic" link in the top right. For more details see the talk page guidelines. Thank you. - wolf  21:36, 30 May 2021 (UTC)

Username
If you want to be known by a different username (eg: "hawck"), requests to change your username go right over → here. (fyi) - wolf  21:50, 30 May 2021 (UTC)

title: User talk:Fmobus


text:
User talk:Mr. Billion

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Hello Mr Billion, I just read the Wikipedia page on La Disparation (The Void) I noticed that the paragraph underneath the heading "Plot Summary" didn't use the letter E. I was wondering If this was pure coincidence or a clever hidden easter egg on behalf of the writer of the page. I'd also like to thankyou for your commitment to Wikipedia, I see you have made over 6000 edits. As a student wikipedia is a very useful website for me! Hope to hear from you soon,

Kind Regards,

Thomas Butson

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title: User talk:Mr. Billion


text:
Selective perception

Selective perception is the tendency not to notice and more quickly forget stimuli that cause emotional discomfort and contradict prior beliefs. For example, a teacher may have a favorite student because they are biased by in-group favoritism. The teacher ignores the student's poor attainment. Conversely, they might not notice the progress of their least favorite student. It can also occur when consuming mass media, allowing people to see facts and opinions they like while ignoring those that do not fit with particular opinions, values, beliefs, or frame of reference. Psychologists believe this process occurs automatically.

Definition
Selective perception may refer to any number of cognitive biases in psychology related to the way expectations affect perception. Human judgment and decision making is distorted by an array of cognitive, perceptual and motivational biases, and people tend not to recognise their own bias, though they tend to easily recognise (and even overestimate) the operation of bias in human judgment by others. One of the reasons this might occur might be because people are simply bombarded with too much stimuli every day to pay equal attention to everything, therefore, they pick and choose according to their own needs.

Relevant studies
To understand when and why a particular region of a scene is selected, studies observed and described the eye movements of individuals as they go about performing specific tasks. In this case, vision was an active process that integrated scene properties with specific, goal-oriented oculomotor behaviour.

Several other studies have shown that students who were told they were consuming alcoholic beverages (which in fact were non-alcoholic) perceived themselves as being "drunk", exhibited fewer physiological symptoms of social stress, and drove a simulated car similarly to other subjects who had actually consumed alcohol. The result is somewhat similar to the placebo effect.

In one classic study on this subject related to the hostile media effect (which is itself an example of selective perception), viewers watched a filmstrip of a particularly violent Princeton-Dartmouth American football game. Princeton viewers reported seeing nearly twice as many rule infractions committed by the Dartmouth team than did Dartmouth viewers. One Dartmouth alumnus did not see any infractions committed by the Dartmouth side and erroneously assumed he had been sent only part of the film, sending word requesting the rest.

Advertising
Selective perception is also an issue for advertisers, as consumers may engage with some ads and not others based on their pre-existing beliefs about the brand.

Seymour Smith, a prominent advertising researcher, found evidence for selective perception in advertising research in the early 1960s, and he defined it to be "a procedure by which people let in, or screen out, advertising material they have an opportunity to see or hear. They do so because of their attitudes, beliefs, usage preferences and habits, conditioning, etc." People who like, buy, or are considering buying a brand are more likely to notice advertising than are those who are neutral toward the brand. This fact has repercussions within the field of advertising research because any post-advertising analysis that examines the differences in attitudes or buying behavior among those aware versus those unaware of advertising is flawed unless pre-existing differences are controlled for. Advertising research methods that utilize a longitudinal design are arguably better equipped to control for selective perception.

Types
Selective perceptions are of two types:
 * Low level – Perceptual vigilance
 * High level – Perceptual defense

title: Selective perception


text:
Marine Corps Base Camp Lejeune

Marine Corps Base Camp Lejeune ( or  )  is a 246 sqmi United States military training facility in Jacksonville, North Carolina. Its 14 mi of beaches make the base a major area for amphibious assault training, and its location between two deep-water ports (Wilmington and Morehead City) allows for fast deployments. The main base is supplemented by six satellite facilities: Marine Corps Air Station New River, Camp Geiger, Stone Bay, Courthouse Bay, Camp Johnson, and the Greater Sandy Run Training Area. The Marine Corps port facility is in Beaufort, at the southern tip of Radio Island (between the NC State Port in Morehead City, and the marine science laboratories on Pivers Island in Beaufort). It is occupied only during military port operations.

Facilities
Camp Lejeune encompasses 156,000 acres, with 18 kilometers of beach capable of supporting amphibious operations, 32 gun positions, 48 tactical landing zones, three state-of-the-art training facilities for Military Operations in Urban Terrain and 80 live fire ranges to include the Greater Sandy Run Training Area. Military forces from around the world come to Camp Lejeune regularly for bilateral and NATO-sponsored exercises.

Resident commands at Camp Lejeune include:

 * II Marine Expeditionary Force
 * Marine Corps Forces Special Operations Command
 * 2nd Marine Division
 * 2nd Marine Logistics Group
 * 2nd Marine Expeditionary Brigade
 * 22nd Marine Expeditionary Unit
 * 24th Marine Expeditionary Unit
 * 26th Marine Expeditionary Unit
 * 2nd Reconnaissance Battalion
 * 2nd Intelligence Battalion
 * Marine Corps Installations East
 * Marine Corps Engineer School
 * United States Marine Corps School of Infantry
 * Marine Corps Combat Service Support Schools
 * Reserve Support Unit
 * Naval Hospital Camp Lejeune
 * Field Medical Training Battalion (FMTB)
 * Joint Maritime Training Center (USCG)
 * Marine Raider Regiment
 * Marine Special Operations Support Group
 * 10th Marine Regiment

Recreation & Fitness:

Auto Skills Center, Bowling, Community Centers, Golf Course, Inline Hockey, Marinas, Paintball, Movie Theater, Onslow Beach Facilities, Outdoor Adventures Center, Pools, Fishing, Hunting, Beach Camping, Recreational Shooting, E-sports Center, Recreational Equipment Checkout & Rentals, Skate Park, and a large number of Sports and Gym facilities.

Portions of Camp Lejeune are in the Jacksonville city limits while other parts are in unincorporated areas.

History
In April 1941, construction was approved on an 11000 acre tract in Onslow County, North Carolina. On May 1 of that year, Lieutenant Colonel William P. T. Hill began construction on Marine Barracks New River. The first base headquarters was in a summer cottage on Montford Point and then moved to Hadnot Point in 1942. Later that year it was renamed in honor of the 13th Commandant of the Marine Corps, John A. Lejeune, upon his death.

One of the satellite facilities of Camp Lejeune served for a while as a third boot camp for the Marines, in addition to Parris Island and San Diego. That facility, Montford Point, was established after Franklin D. Roosevelt signed Executive Order 8802. Between 1942 and 1949, a brief era of segregated training for black Marines, the camp at Montford Point trained 20,000 African Americans. After the military was ordered to fully integrate, Montford Point was renamed Camp Gilbert H. Johnson and became the home of the Marine Corps Combat Service Support Schools.

On May 10, 1996, two helicopters performing a joint United States/British training exercise collided and crashed into a swampy wooded area, killing fourteen and injuring two.

In mid-September 2018, Hurricane Florence damaged IT systems and over 900 buildings in the camp, leading to a $3.6 billion repair cost. 70 percent of base housing was damaged and 84,000 gallons of sewage were released.

Drinking water contamination
From at least 1953 through 1987, Marines and their families at Lejeune drank and bathed in water contaminated with toxicants at concentrations 240 to 3,400 times permitted by safety standards. A 1974 base order required safe disposal of solvents and warned that improper handling could cause drinking water contamination, yet solvents were dumped or buried near base wells for years. The base's wells were shut off in the mid-1980s but were placed back online in violation of the law. In 1982, volatile organic compounds (VOCs) were found in Camp Lejeune's drinking water supply. VOC contamination of groundwater can cause birth defects and other ill health effects in pregnant and nursing mothers. This information was not made public for nearly two decades, when the government attempted to identify those who may have been exposed.

An advocacy group called The Few, The Proud, The Forgotten was created to inform possible victims of the contamination at Lejeune. The group's website includes an introduction with some basic information about the contamination at Lejeune, including that many health problems such as various types of cancer, leukemia, miscarriages and birth defects, have been noted in people who drank the contaminated water. According to the site, numerous base housing areas were affected by the contamination, including Tarawa Terrace, Midway Park, Berkeley Manor, Paradise Point, Hadnot Point, Hospital Point, and Watkins Village. As many as 2,000,000 people may have been exposed to contaminated water at Camp Lejeune over a period of 30 years.

Camp LeJeune Justice Act of 2022
Efforts to create a Camp LeJeune Justice Act in 2021 failed, but the effort was renewed in 2022 when Camp LeJeune Justice Act became Section 706 of the SFC Heath Robinson Honoring Our PACT Act, H.R. 3967. The U.S. House passed H.R. 3967 on March 3, 2022, by a vote of 256–174. The U.S. Senate passed H.R. 3967 with some minor amendments on June 16, 2022, by a vote of 84–14. Following the bill's passage in the U.S. Senate, President Biden's White House made a celebratory statement that included mention of Camp LeJeune victims. There were constitutional taxation problems with the amended version and a "blue slip" was issued causing the matter to return to the U.S. House. The U.S. House made the changes necessary to avoid the constitutional issue and passed the PACT Act on July 13, 2022, by a vote of 342–88. This new PACT Act was repackaged as S. 3373 with the Camp LeJeune Justice Act set as Section 804. Some Republican senators changed their votes and refused cloture on July 27, 2022, by a vote of 55–42. After several days of veterans protesting at the Capitol, there was another vote on S. 3373 and this time it passed by a vote of 86–11 on August 2, 2022. The bill was signed into law by President Biden on August 10, 2022.

The language of Section 804 provides for monetary relief for those injured by exposure to the Camp Lejeune base and its toxic water. Thirty days of "living" or "working" or "otherwise" being exposed between 1953 and 1987 is the prerequisite for compensation. This includes in-utero exposure. Harms must be demonstrated and they must be associated with some condition caused by the base toxicants. Some of the possible conditions may include those listed for the Janey Ensminger Act of 2012. 38 C.F.R. 17.400(b).

Litigation
At least 850 former residents filed claims for nearly $4 billion from the military. The multi-district litigation, MDL-2218, was dismissed on North Carolina statute of repose grounds on December 5, 2016, and the appeal to the 11th Circuit failed (Straw, et. al. v. United States, 16–17573). The U.S. Supreme Court refused certiorari. A U.S. Supreme Court ruling in June 2014 potentially curbed groundwater contamination lawsuits by families at Camp Lejeune. Federal law, which imposes a two-year statute of limitations after the harm is discovered, preempts North Carolina's 10-year statute of repose law, but this was not followed by the 11th Circuit. State lawmakers tried to eliminate the state prohibition on lawsuits being filed 10 years after the last pollution occurred or from the time a polluted property was sold. The Camp LeJeune Justice Act of 2022, Section 804(b) of the PACT Act, S. 3373, provide an entirely new means for justice to the victims and removes normal tort defenses. Public Law 117-168, SEC. 804(b), 136 Stat. 1802–1804.

Disability activist, lawyer, columnist, and politician, Andrew U. D. Straw,   has appealed his cases unsuccessfully. He has also pursued claims at the U.S. Court of Federal Claims, stating that the U.S. Marine Corps' UCMJ responsibilities imply a contract to protect U.S. Marine Corps family members (Straw v. United States, 1:17-cv-00560, U.S. COFC). This case was dismissed and denied on appeal. Straw has advocated for legislative reform to avoid the legal arguments of the Department of Justice. The main chemicals involved were trichloroethylene (TCE, a degreaser), perchloroethylene (PCE, a dry cleaning solvent), vinyl chloride, and benzene; however, more than 70 chemicals have been identified as contaminants at Lejeune. Andrew Straw is pursuing his own infant brain injury pro se and as estate executor for the wrongful death of his mother from a Camp LeJeune cancer. Straw v. United States,  7:23-cv-1475-FL (E.D.N.C.)

Straw has sought not only compensation, but he also has sought health care under the Janey Ensminger Act of 2012. He litigated for that benefit for seven years. He was rejected at the VA, the BVA, the U.S. Court of Veterans Claims, and finally in 2021 at the Federal Circuit. Despite Straw being born at Camp LeJeune in 1969, his having 19 months of base access while his father worked there as a U.S. Marine, the language of the Janey Ensminger Act was interpreted narrowly so as to deny Straw this benefit. Straw's parents had a home off base at the time of his birth and this is where they slept, even while using and working at the base during the day from 1968–1970. The fact that Straw's mother died from one of the cancers listed in the Act and Straw having neurobehavioral effects listed in the Act was irrelevant to the Federal Circuit. The Federal Circuit also refused to consider the misapplication of the North Carolina Statute of Repose as being a taking of private property. Straw v. Wilkie, 843 F. App’x 263 (Fed. Cir. 1/15/2021); Straw v. United States, 4 F.4th 1358 (Fed. Cir. 2021). The narrow construction of the Janey Ensminger Act of 2012 in Straw's case led to the Camp LeJeune Justice Act of 2022 having no such on-base limitation. Straw suggested that change to Attorney Ed Bell, the author of the CLJA, and Bell agreed. The new 2022 law provides a catch-all "otherwise exposed" inclusive provision so such exclusion for sleeping off base cannot be used to deny the relief.

On March 8, 2010, Paul Buckley of Hanover, Massachusetts, received a 100 percent, service connected disability from the Department of Veterans Affairs for cancer (multiple myeloma), which was linked to toxic water exposure on Camp Lejeune. This is believed to be the first time the government has admitted the link between the contamination and illnesses.

In 2007, Jerry Ensminger, a retired Marine master sergeant, found a document dated 1981 that described a radioactive dump site near a rifle range at the camp. According to the report, the waste was laced with strontium-90, an isotope known to cause cancer and leukemia. According to Camp Lejeune's installation restoration program manager, base officials learned about the document in 2004. Ensminger served in the Marine Corps for $24 1/2$ years and lived for part of that time at Camp Lejeune. In 1985, his nine-year-old daughter, Janey, died of cancer. Straw's mother died in 1997 from breast cancer.

On July 6, 2009, Laura Jones filed suit against the U.S. government over the contaminated water at the base. Jones previously lived at the base where her husband, a Marine, was stationed, and she has since been diagnosed with lymphoma. Twenty former residents of Camp Lejeune—all men who lived there during the 1960s and the 1980s—have been diagnosed with breast cancer. In April 2009, the United States Agency for Toxic Substances and Disease Registry withdrew a 1997 public health assessment at Camp Lejeune that denied any connection between the toxicants and illness.

On August 10, 2022, President Biden signed the Camp Lejeune Justice Act of 2022, allowing victims to sue for sicknesses related to water contamination at Camp Lejeune.

Straw has renewed his several claims for compensation. Straw v. United States, 7:23-cv-162-BO-BM (E.D.N.C.) (Camp LeJeune Justice Act lawsuit, docketed 2/21/2023). The Estate of Straw's mother also has a claim pending at U.S. Navy JAG Code 15 for her wrongful death from breast cancer. CLS23-5185. Straw is appealing the denial of his motion for health care and education benefits. Straw v. United States, 23-2156 (4th Cir. 2024) (DENIED)

One of the DOJ lawyers involved in denial of relief under FTCA in MDL-2218, Adam Bain, has appeared again in CLJA case filings. Estate of Jane Ensminger v. United States, 7:23-cv-161 (E.D.N.C.)

A review of the backgrounds of 4th Circuit judges on Ballotpedia.org reveals that half of the 14 judges worked for the Justice Department or federal government prior to appointment to the bench and several were JAG attorneys for the Military previously.

The lead attorneys for the plaintiffs have set up a website to inform the victims and the public of happenings in the case. The Court ordered these attorneys to submit a Master Complaint that will apply to all lawsuits and plaintiffs. The Master Complaint is now online. Each plaintiff is required to submit a short form complaint using a template provided by the Court at pages 14–18 of its Case Management Order #2. The government had until November 20, 2023, to answer. The consolidated case is meant to streamline prosecution of the matter. The government told the Court in November 2023 that there were over 1,300 cases in federal court along with 117,000 claims at Navy JAG under Camp LeJeune Justice Act (CLJA), amounting to $3.3 trillion in claims.

Janey Ensminger Act
In July 2012, the U.S. Senate passed a bill, called the Janey Ensminger Act in honor of retired Marine Master Sergeant Jerry Ensminger's daughter Janey who died of cancer at age 9, authorizing medical care to military and family members who had resided at the base between 1957 and 1987 and developed conditions linked to the water contamination. The measure applies to up to 750,000 people. The bill applies to 15 specific ailments believed to be linked to the contamination, including cancer of the esophagus, lung, breast, bladder or kidney; leukemia; multiple myeloma; myleodysplasic syndromes; renal toxicity; hepatic steatosis; female infertility; miscarriage; scleroderma; and/or neurobehavioral effects or non-Hodgkin's lymphoma. The Department of Veterans Affairs is assigned to provide the medical care. To fund the medical care, the bill extended higher fees for VA home loan guarantees through 2017. This health coverage was worded to require the victim to have lived on the base and any civilian dependent who slept off base was excluded regardless of getting the illnesses on the list. Straw v. Wilkie, 843 F. App’x 263 (Fed. Cir. 1/15/2021). (Straw was born at Camp LeJeune Naval Hospital and had base access for 19 months but was denied health care for a condition—bipolar disorder—PCE doubles the chance of contracting).

A 2023 cohort study of 172,128 American veterans who were stationed in Lejeune and 168,361 who were stationed in Pendleton found that the rates of Parkinson's disease were 70% higher in Lejeune as compared to Pendleton, suggesting that exposure to trichloroethylene in the water may increase risk of Parkinson's disease.

A Cancer Incidence Study was delayed at ATSDR when this information may be critical to the victims in obtaining compensation. The Cancer Incidence Study was released at the end of January 2024 after about 8 years of work. It showed more evidence that the water increased the risk of various cancers. Another ATSDR mortality study showed that the risk of death from Camp LeJeune exposure and diseases was elevated. ATSDR provides a FAQ about Camp LeJeune toxic exposure andvarious studies done or to be done.

Education
Residents are zoned to schools of the Department of Defense Education Activity (DoDEA). Different housing areas are zoned to the following:

 * Heroes Elementary School: Heroes Manor and parts of Berkeley Manor and Paradise Point
 * Johnson Primary School and Bitz Intermediate School: Courthouse Bay, Hospital Point, Watkins Grove, Watkins Village, and parts of Berkeley Manor and Paradise Point
 * Tarawa Terrace Elementary School: Knox Cove, Knox Landing, Midway Park, and Tarawa Terrace

All residents of Camp Lejeune and of Marine Corps Air Station New River (which has Delalio Elementary) are zoned to Brewster Middle School and Lejeune High School.

title: Marine Corps Base Camp Lejeune


text:
Coloma

Coloma may refer to:

People

 * Noble Spanish House of Coloma:
 * Carlos Coloma de Saa, 1st Marquess of Espinar
 * Alfonso Coloma, bishop of Barcelona
 * Emmanuel Coloma y Escolana
 * Jean Alphonse, 1st Count de Coloma
 * Francisco Coloma y Maceda
 * Juan II Coloma, 1st Lord of Elda
 * Juan IV Coloma y Cardona, 1st Count of Elda
 * Pedro Coloma, Baron of Bornhem
 * Pierre Coloma, Viscount of Dourlens
 * Carlos Coloma Nicolás
 * Eugenie Santa Coloma Sourget, French composer, pianist and singer
 * Luis Coloma
 * Meredith Coloma, Canadian musician and luthier

United States

 * Coloma, California
 * Coloma, Indiana
 * Coloma, Michigan
 * Coloma, Missouri
 * Coloma, Wisconsin
 * Coloma (town), Wisconsin
 * Coloma Township, Whiteside County, Illinois
 * Coloma Charter Township, Michigan

Elsewhere

 * La Coloma, Cuba
 * Santa Coloma, Asturias, Spain
 * Santa Coloma d'Andorra
 * Coloma Park, Sint-Pieters-Leeuw, Belgium

Other uses

 * Coloma (barquentine), a sailing ship; see Minnie Patterson

title: Coloma


text:
Inclinometer

An inclinometer or clinometer is an instrument used for measuring angles of slope, elevation, or depression of an object with respect to gravity's direction. It is also known as a tilt indicator, tilt sensor, tilt meter, slope alert, slope gauge, gradient meter, gradiometer, level gauge, level meter, declinometer, and pitch & roll indicator. Clinometers measure both inclines and declines using three different units of measure: degrees, percentage points, and topos. The astrolabe is an example of an inclinometer that was used for celestial navigation and location of astronomical objects from ancient times to the Renaissance.

A tilt sensor can measure the tilting in often two axes of a reference plane in two axes. In contrast, a full motion would use at least three axes and often additional sensors. One way to measure tilt angle with reference to the earth's ground plane, is to use an accelerometer. Typical applications can be found in the industry and in game controllers. In aircraft, the "ball" in turn coordinators or turn and bank indicators is sometimes referred to as an inclinometer.

History
Inclinometers include examples such as Well's in-clinometer, the essential parts of which are a flat side, or base, on which it stands, and a hollow disc just half filled with some heavy liquid. The glass face of the disc is surrounded by a graduated scale that marks the angle at which the surface of the liquid stands, with reference to the flat base. The zero line is parallel to the base, and when the liquid stands on that line, the flat side is horizontal; the 90 degree is perpendicular to the base, and when the liquid stands on that line, the flat side is perpendicular or plumb. Intervening angles are marked, and, with the aid of simple conversion tables, the instrument indicates the rate of fall per set distance of horizontal measurement, and set distance of the sloping line.

Al-Biruni, a Persian polymath, once wanted to measure the height of the sun. He lacked the necessary equipment to measure this height. He was forced to create a calibrated arc on the back of a counting board, which he then used as a makeshift quadrant with the help of a plumb line. He determined the location's latitude using the measurements taken with this rudimentary tool. This quadrant was most likely an inclinometer based on the quarter-circle panel.

The Abney level is a handheld surveying instrument developed in the 1870s that includes a sighting tube and inclinometer, arranged so that the surveyor may align the sighting tube (and its crosshair) with the reflection of the bubble in the spirit level of the inclinometer when the line of sight is at the angle set on the inclinometer.

One of the more famous inclinometer installations was on the panel of the Ryan NYP "The Spirit of St. Louis"—in 1927 Charles Lindbergh chose the lightweight Rieker Inc P-1057 Degree Inclinometer to give him climb and descent angle information.

Uses
Hand-held clinometers are used for a variety of surveying and measurement tasks. In land surveying and mapping, a clinometer can provide a rapid measurement of the slope of a geographic feature, or used for cave survey. In prospecting for minerals, clinometers are used to measure the strike and dip of geologic formations. In forestry, tree height measurement can be done with a clinometer using standardized methods including triangulation. Major artillery guns may have an associated clinometer used to facilitate aiming of shells over long distances.

Permanently-installed tiltmeters are emplaced at major earthworks such as dams to monitor the long-term stability of the structure.

Factors which influence the use of inclinometers
(Overall accuracy varies depending on the type of tilt sensor (or inclinometer) and technology used)
 * Gravity
 * Temperature (drift), zero offset, linearity, vibration, shock, cross-axis sensitivity, acceleration/deceleration.
 * A clear line of sight between the user and the measured point is needed.
 * A well defined object is required to obtain the maximum precision.
 * The angle measurement precision and accuracy is limited to slightly better than one arcsec.

Accuracy
Certain highly sensitive electronic inclinometer sensors can achieve an output resolution to 0.0001°; depending on the technology and angle range, it may be limited to 0.01°. An inclinometer sensor's true or absolute accuracy (which is the combined total error), however, is a combination of initial sets of sensor zero offset and sensitivity, sensor linearity, hysteresis, repeatability, and the temperature drifts of zero and sensitivity—electronic inclinometers accuracy can typically range from ±0.01–2° depending on the sensor and situation. Typically in room ambient conditions the accuracy is limited to the sensor linearity specification.

Sensor technology
Tilt sensors and inclinometers generate an artificial horizon and measure angular tilt with respect to this horizon. They are used in cameras, aircraft flight controls, automobile security systems, and speciality switches and are also used for platform leveling, boom angle indication, and in other applications requiring measurement of tilt.

Important specifications to consider for tilt sensors and inclinometers are the tilt angle range and the number of axes. The axes are usually, but not always, orthogonal. The tilt angle range is the range of desired linear output.

Common implementations of tilt sensors and inclinometers are accelerometer, Liquid Capacitive, electrolytic, gas bubble in liquid, and pendulum.

Tilt sensor technology has also been implemented in video games. Yoshi's Universal Gravitation and Kirby Tilt 'n' Tumble are both built around a tilt sensor mechanism, which is built into the cartridge. The PlayStation 3 and Wii game controllers also use tilt as a means to play video games.

Inclinometers are also used in civil engineering, for example, to measure the inclination of land to be built upon.

Some inclinometers provide an electronic interface based on CAN (Controller Area Network). In addition, those inclinometers may support the standardized CANopen profile (CiA 410). In this case, these inclinometers are compatible and partly interchangeable.

Two-axis digital inclinometer

Traditional spirit levels and pendulum-based electronic leveling instruments are usually constrained by only single-axis and narrow tilt measurement range. However, most precision leveling, angle measurement, alignment and surface flatness profiling tasks essentially involve a two-dimensional surface plane angle rather than two independent orthogonal single-axis objects. Two-axis inclinometers that are built with MEMS tilt sensors provides simultaneous two-dimensional angle readings of a surface plane tangent to earth datum.

Typical advantages of using two-axis MEMS inclinometers over conventional single-axis "bubble" or mechanical leveling instruments may include:
 * Simultaneous measurement of two-dimensional (X-Y plane) tilt angles (i.e. pitch & roll), can eliminate tedious swapping back-and-forth experienced when using a single-axis level, for example to adjust machine footings to attain a precise leveling position.
 * Digital compensation and precise calibration for non-linearity, for example for operating temperature variation, resulting in higher accuracy over a wider measurement range.
 * The accelerometer sensors may generate numerical data in the form of vibration profiles to enable a machine installer to track and assess alignment quality in real-time and verify a structure's positional stability by comparing leveling profiles before and after it is set up.

Inclinometer with gyroscope
As inclinometers measure the angle of an object with respect to the force of gravity, external accelerations like rapid motions, vibrations or shocks will introduce errors in the tilt measurements. To overcome this problem, it is possible to use a gyroscope in addition to an accelerometer. Any of the abovementioned accelerations have a huge impact on the accelerometer, but a limited effect on the measured rotation rates of the gyroscope. An algorithm can combine both signals to get the best value out of each sensor. This way it is possible to separate the actual tilt angle from the errors introduced by external accelerations.

Applications
Inclinometers are used for:
 * Determining latitude using Polaris (in the Northern Hemisphere) or the two stars of the constellation Crux (in the Southern Hemisphere).
 * Determining the angle of the Earth's magnetic field with respect to the horizontal plane.
 * Showing a deviation from the true vertical or horizontal.
 * Surveying, to measure an angle of inclination or elevation.
 * Alerting an equipment operator that it may tip over.
 * Measuring angles of elevation, slope, or incline, e.g. of an embankment.
 * Measuring slight differences in slopes, particularly for geophysics. Such inclinometers are, for instance, used for monitoring volcanoes, or for measuring the depth and rate of landslide movement.
 * Measuring movements in walls or the ground in civil engineering projects.
 * Determining the dip of beds or strata, or the slope of an embankment or cutting; a kind of plumb level.
 * Some automotive safety systems.
 * Indicating pitch and roll of vehicles, nautical craft, and aircraft. See turn coordinator and slip indicator.
 * Monitoring the boom angle of cranes and material handlers.
 * Measuring the "look angle" of a satellite antenna towards a satellite.
 * Adjusting a solar panel to the optimal angle to maximize its output.
 * Measuring the slope angle of a tape or chain during distance measurement.
 * Measuring the height of a building, tree, or other feature using a vertical angle and a distance (determined by taping or pacing), using trigonometry.
 * Measuring the angle of drilling in well logging.
 * Measuring the list of a ship in still water and the roll in rough water.
 * Measuring steepness of a ski slope.
 * Measuring the orientation of planes and lineations in rocks, in combination with a compass, in structural geology.
 * Measuring range of motion in the joints of the body
 * Measuring the inclination angle of the pelvis. Numerous neck and back measurements require the simultaneous use of two inclinometers.
 * it measures the angle of elevation, and ultimately computing the altitudes of, many things otherwise inaccessible for direct measurement.
 * Measuring and fine tuning the angle of line array speaker hangs. Confirmation of the angle achieved via use of a laser built into the remote inclinometer.
 * Setting correct orientation of solar panels while installing
 * Setting firing angle of a cannon or gun (determines projectile range)
 * Electronic games
 * Help prevent unsafe working conditions.
 * The USDA Forest Service uses tilt sensors (or inclinometers) to measure tree height in its Forest Inventory and Analysis program.
 * Logistics and transport also use tilt indicators, it is a specific system for single use. They are attached to the products during the shipping process.

Games
Nintendo used tilt sensor technology in five games for its Game Boy series of hand-held game systems. The tilt sensor allows players to control aspects of the game by twisting the game system. Games that use this feature:
 * Yoshi's Universal Gravitation (Game Boy Advance)
 * WarioWare: Twisted! (Game Boy Advance)(not released in Europe)
 * Koro Koro Puzzle Happy Panechu! (Game Boy Advance)(Japan only)
 * Kirby Tilt 'n' Tumble (Game Boy Color)(not released in Europe)
 * Command Master (Game Boy Color)(Japan only)

Tilt sensors can also be found in game controllers such as the Microsoft Sidewinder Freestyle Pro and Sony's PlayStation 3 controller.

However, unlike these other controllers in which the tilt sensor serves as a supplement to normal control methods, it serves as one of the central features of Nintendo's Wii Remote and the Nunchuk attachment. Along with accelerometers, the tilt sensors are a primary method of control in most Wii games.

It is now being used in many different aspects, instead of just games like motocrossing and flight simulators. It can be used for sport gaming, first-person shooter, and other odd uses such as in WarioWare: Smooth Moves

Another example is a virtual version of a wooden maze with obstacles in which you have to maneuver a ball by tilting the maze. A homebrew tilt sensor interface was made for the Palm (PDA).

title: Inclinometer