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2d 266 [1972], the Supreme Court held that a public university may deny campus access to ACADEMIC FREEDOM 49... The Supreme Court ruled in Hazelwood School District v.. The Court also he

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S Ct 568, 50 L Ed 2d 471 [1977]) This precedent seemed to give school authorities ample means to elude LIABILITYfor unconstitu-tional terminations However, neither of the principles helped City University of New York (CUNY) when it was sued by the chair of its black studies department

Professor Leonard Jeffries specialized in black studies and the history of Africa, and his teaching style at CUNY was controversial Some students felt that Jeffries discouraged classroom debate, whereas others applauded him for verbalizing the frustrations of many African Americans Jeffries referred to Europeans as “ice people” and

as “egotistic, individualistic, and exploitative.”

Africans, by contrast, were“sun people” who had

“humanistic, spiritualistic value system[s].”

On July 20, 1991, Jeffries spoke at the Empire State Black Arts and Cultural Festival, in Albany, New York In his speech, he assailed perceived Jewish power, asserting that Jews controlled CUNY and Hollywood and had financed the American slave trade The speech attracted national attention and placed CUNY

on the horns of a dilemma: Either it could punish Jeffries and risk running afoul of the First Amendment and academic freedom prin-ciples, or it could do nothing and risk losing expected income from offended school bene-factors For several months, the university wrestled with the problem Then, in October, the board of trustees voted, without explana-tion, to limit Jeffries’s current appointment as chair to one year instead of the customary three

On March 23, 1992, the CUNY Board of Trustees appointed Professor Edmund Gordon

to the position of black studies chair Jeffries filed suit in federal court on June 5, 1992

Jeffries argued that the defendants violated his First Amendment free speech rights and his

FOURTEENTH AMENDMENTdue process rights when they denied him a full three-year term as chair

of black studies The jury agreed with Jeffries that a substantial motivating factor in his dismissal was his speech in Albany The jury did find, however, that CUNY had reasonably expected the speech to have a detrimental effect

on the school Despite this seemingly justifiable excuse for the school’s action, the jury finally found that CUNY had deprived Jeffries of property (the position of chair) without DUE PROCESS OF LAW The district court judge held that Jeffries’s First Amendment rights had been

violated, and in August 1993 reduced Jeffries’s recovery in damages by $40,000 but awarded him the black studies chair (Jeffries v Harleston,

828 F Supp 1066[S.D.N.Y., 1993])

remanded the case to the Second Circuit with instructions to consider the Court’s RULING in Waters v Churchill (511 U S 661 [1994]) The

CIRCUIT COURT reversed and remanded the case

to the district court The FINAL DECISION con-cluded that Jeffries’s occupation did not afford him“greater protection from state interference with his speech than did the nurse in Waters.”

By taking away Jeffries’s position as chair of the department, the university did not infringe on his ability to speak publicly or to teach in his own style, both of which could have been violations of his First Amendment rights (Jeffries

v Harleston, 52 F 3d 9 [2d Cir 1995]) The Supreme Court has decided several cases that identified more precisely how much control school authorities may exercise over education The Court held in Board of Ed., Island Trees Union Free School Dist No 26 v Pico (457 U.S 853, 102 S Ct 2799, 73 L Ed 2d

435 [1982]), that a school board can control curriculum and book selection, but it may not remove “objectionable” books from public school libraries solely in response to community pressure Among the books that the Island Trees Union Free School District No 26 in New York had banned in the mid-1970s were Slaughter-house Five, by Kurt Vonnegut Jr.; Black Boy,

by Richard Wright; Naked Ape, by Desmond Morris; and The Fixer, by Bernard Malamud School boards and state legislatures generally control public school curriculums, but their control is not complete For instance, a state statute will be struck down if it requires public schools to also teach creationism if they teach evolution and vice versa According to the Court

in Edwards v Aguillard (482 U.S 578, 107 S Ct

2573, 96 L Ed 2d 510[1987]), such a law un-dermines a comprehensive scientific education and impermissibly endorsesRELIGION by advanc-ing the religious belief that a supernatural power created human beings

State legislatures have accommodated court rulings by drafting legislative language intended

to create academic latitude without violating

CONSTITUTIONAL rights In July 2008 Louisiana governor Bobby Jindal signed into law the Louisiana Science Education Act, S.B 733,

48 ACADEMIC FREEDOM

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which (according to the act’s preamble)

pur-ported to “promote students’ critical thinking

skills and open discussion of scientific theories”

in Louisiana classrooms Section §285(B)(1) of

the act states:

The State Board of Elementary and

Second-ary Education, upon request of a city, parish,

or other local public school board, shall

allow and assist teachers, principals, and

other school administrators to create and

foster an environment within public

elemen-tary and secondary schools that promotes

critical thinking skills, logical analysis, and

open and objective discussion of scientific

theories being studied including, but not

limited to, evolution, the origins of life,

global warming, and human cloning

Section §285(C) provides that after teaching

the material contained in a standard textbook

supplied by the school system, a teacher may

use supplemental textbooks and other

instruc-tional materials “to help students understand,

analyze, critique, and review scientific theories

in an objective manner.”

Section §285(D) expressly states:“This

Sec-tion shall not be construed to promote any

religious doctrine, promote DISCRIMINATION for

or against a particular set of religious beliefs, or

promote discrimination for or against religion

or non-religion.”

The Louisiana Science Education Act was

one of several similar bills introduced in state

legislatures in 2008 and 2009, including those in

Alabama (HB 300), Florida, Iowa (HF 183),

Michigan, Missouri (HB 656), New Mexico (SB

433), Oklahoma (SB 320), South Carolina, and

Texas (HB 224) Only Louisiana’s was enacted

in 2008 (Oklahoma’s bill, the language of

which closely paralleled that of Louisiana, was

narrowly defeated by a 7-6 vote in the state’s

Senate Education Committee in early 2009.)

The question regarding whether the federal

government can deny grants or funds to

educational institutions which speak out against

federal policies was the issue before the courts

in Rumsfeld v F.A.I.R (Forum for Academic and

Institutional Rights, Inc.) (547 U.S 47, 126 S Ct

1297[2006]) Congress had passed theSOLOMON

requires the U.S.DEPARTMENT OF DEFENSE(DOD)

to deny federal funding to institutions of higher

education that prohibitACCESSto the institution

for military representatives and/or deny or

impede assistance for recruiting purposes

The conflict arose over military policies regarding homosexuality Since at least WORLD WAR I, the U.S military maintained a policy of excluding service members based on evidence of homosexual conduct or orientation (10 U.S.C

654) Unlike the military, many graduate schools (and law schools in particular) have, over the years, maintained formal policies expressly tolerant of expanded personal factors such as sexual orientation Of particular import

in this case was the prevalence of law school policies that withheld career services/career placement services from prospective employers who discriminated on the grounds of sexual orientation as well as the more traditional protected categories such as race, gender, religion

In F.A.I.R v Rumsfeld, No 03-4433 (3d Circuit Court of Appeals, 2004) the two conflicting policies over homosexuality faced-off in court, when a coalition of law schools and law faculty calling itself the Forum for Academic and Institutional Rights (F.A.I.R.) filed PETITION forPRELIMINARY INJUNCTION in the U.S District Court for the District of New Jersey

to enjoin enforcement of the Solomon Amend-ment The Third Circuit Court of Appeals granted injunction against enforcement of the Solomon Amendment, holding that the law violated schools’ First Amendment rights

of expressive association, and forcing them to engage in the expressive act of recruiting It reasoned that Congress could not require the

FORFEITURE of a constitutional right as the basis for receiving federal funds But the U.S Supreme Court unanimously reversed, holding that the government could deny funds to schools that did not permit recruitment; indeed, said the Court, through the U.S Constitution’s “raise and support Armies” clause (Article I, Section 8), Congress could go so far as to force schools

to allow recruiting without even threatening the withholding of funds The Court continued that the Solomon Amendment neither denied the institutions the right to speak nor required them to say anything

Though the concept of academic freedom has traditionally been applied only to teachers, it has affected lower-court opinions involving the rights of students Several Supreme Court cases are cited in support of such rights In Healy v

James (408 U.S 169, 92 S Ct 2338, 33 L Ed 2d

266 [1972]), the Supreme Court held that a public university may deny campus access to

ACADEMIC FREEDOM 49

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provably disruptive groups, but it may not deny access based on the views the students wish to express The Supreme Court ruled in Hazelwood School District v Kuhlmeier (484 U.S 260, 108

S Ct 562, 98 L Ed 2d 592[1988]) that a public school may censor the content of a student newspaper if the newspaper is not an entirely public forum and the reason for CENSURE is related to a legitimate educational concern In Board of Education of Westside Community Schools (Dist 66) v Mergens (496 U.S 226,

110 S Ct 2356, 110 L Ed 2d 191[1990]), the Court approved the establishment of a Christian student group in a public school The Court also held in Mergens that a school’s refusal to permit a religious student group to meet at school and use its facilities violates the federal Equal Access Act (Education for Economic Security Act § 802, 20 U.S.C.A § 4071 et seq

[1984]) if the school provides such access to other extracurricular student groups And in Morse v Frederick (551 U.S 393 [2007]), the Supreme Court held that a student’s free speech rights were not violated when he was suspended for displaying a “Bong Hits 4 Jesus” banner during a school authorized event The Court distinguished the constitutional rights of stu-dents in public schools from adults in other settings, finding that students’ rights could be delineated“in light of the special characteristics

of the school environment.”

FURTHER READINGS

“Act No 473 (Senate Bill No 733).” Text available online at http://www.legis.state.la.us/billdata/streamdocument.asp?

did=503483; website home page: http://www.legis.state.

la.us (accessed July 10, 2009).

DeGeorge, Richard T 1997 Academic Freedom and Tenure: Ethical Issues Lanham, Md.: Rowman &

Littlefield.

Finkin, Matthew W., and Robert C Post 2009 For the Common Good: Principles of American Academic Freedom New Haven, Conn.: Yale Univ Press.

Hamilton, Neil W 2002 Academic Ethics: Problems and Materials on Professional Conduct and Shared Gover-nance Westport, Conn.: Praeger.

Hiers, Richard H 2002 “Institutional Academic Freedom

vs Faculty Academic Freedom in Public Colleges and Universities: A Dubious Dichotomy ” Journal of College and Univ Law 29 (October): 35-109.

Rahdert, Mark C July 2007 “The Roberts Court and Academic Freedom ” Chronicle of Higher Education 53.

CROSS REFERENCES Censorship; Douglas, William Orville; First Amendment;

Frankfurter, Felix; Freedom of Speech; Loyalty Oath;

Religion; Schools and School Districts; Tenure; Warren, Earl

ACADEMIC YEAR That period of time necessary to complete an actual course of study during a school year

SOCIAL SECURITYbenefits may terminate at the end of an ACADEMIC YEAR, or a deferment from compulsory military service may continue only during an academic year

ACADEMY OF CRIMINAL JUSTICE SCIENCES

The Academy of Criminal Justice Sciences (ACJS) was founded in 1963 to foster professionalism in the criminal justice system by advancing the quality of education and research programs in the field The academy seeks to enrich education and research programs in institutions of higher learning, criminal justice agencies, and agencies

in related fields by improving cooperation and communication, by serving as a clearinghouse for the collection and dissemination of information produced by the programs, and by promoting the highest ethical and personal standards in criminal justice research and education To that end, the ACJS created an ad hoc committee in 1995 to adopt minimum standards for the improvement

of quality in criminal justice higher education The standards, reprinted in 2001, have been widely utilized in the curricular development of associate, undergraduate and graduate degree programs The academy alsoPRESENTSnumerous awards for outstanding contributions by indivi-duals in the field The members of the academy are individual teachers, administrators, research-ers, students, and practitioners

The academy publishes the Journal of Crimi-nal Justice quarterly and a directory annually It holds annual meetings in March

FURTHER READINGS Academy of Criminal Justice Sciences Web site Available online at http://www.acjs.org (accessed July 2, 2009).

“J Journal: New Writing on Justice” New York: John Jay College of Criminal Justice Available online at http:// www.conference2004.jjay.cuny.edu/jjournal/index.asp; website home page: http://www.conference2004.jjay cuny.edu/ (accessed August 28, 2009).

ACCEDE

To consent or to agree, as to accede to another’s point of view To enter an office or to accept a position, as to accede to the presidency

ACCELERATION

A hastening; a shortening of the time until some event takes place

50 ACADEMIC YEAR

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A person who has the right to take

possession of property at some future time

may have that right accelerated if the present

holder loses his or her LEGAL RIGHT to the

property If aLIFE ESTATEfails for any reason, the

remainder is accelerated

The principle of acceleration can be applied

when it becomes clear that one party to a

contract is not going to perform his or her

obligations ANTICIPATORY REPUDIATION, or the

possibility of future breach, makes it possible

to move the right to remedies back to the time

of repudiation rather than to wait for the time

when performance would be due and an actual

breach would occur

ACCELERATION CLAUSE

The provision in a credit agreement, such as a

mortgage, note, bond, or deed of trust, that allows

the lender to require immediate payment of all

money due if certain conditions occur before the

time that payment would otherwise be due

The agreement may call for ACCELERATION

whenever there is a default of any important

obligation, such as nonpayment of principal or

interest, or the failure to pay insurance premiums

ACCEPTANCE

An express act or implication by conduct that

manifests assent to the terms of an offer in a manner

invited or required by the offer so that a binding

contract is formed The exercise of power conferred

by an offer by performance of some act The act of a

person to whom something is offered or tendered by

another, whereby the offeree demonstrates through

an act invited by the offer an intention of retaining

the subject of the offer

In the law of contracts, acceptance is one

person’s compliance with the terms of an offer

made by another Acceptance occurs in the law

of insurance when an insurer agrees to receive a

person’s application for insurance and to issue a

policy protecting the person against certain

risks, such as fire orTHEFT When a person who

is offered a gift by someone keeps the gift, this

indicates his or her acceptance of it

Acceptance also occurs when a bank pays a

check written by a customer who has a checking

account with that bank

In business dealings between merchants,

which is governed by the law of sales, a buyer

demonstrates his or her acceptance of goods that

are not exactly what he or she had ordered from

the seller by telling the seller that he or she will keep the goods even though they are not what was ordered; by failing to reject the goods; or by doing something to the goods inconsistent with the seller’s ownership of them, such as selling the goods to consumers of the buyer’s store

Types of Acceptance

An acceptance may be conditional, express, or implied

Conditional Acceptance A conditional accep-tance, sometimes called aQUALIFIED ACCEPTANCE, occurs when a person to whom an offer has been made tells the offeror that he or she is willing to agree to the offer provided that some changes are made in its terms or that some condition or event occurs This type of accep-tance operates as aCOUNTEROFFER A counteroffer must be accepted by the original offeror before a contract can be established between the parties

Another type of conditional acceptance occurs when a drawee promises to pay a draft upon the fulfillment of a condition, such as a shipment of goods reaching its destination on the date specified in the contract

Express Acceptance An express acceptance occurs when a person clearly and explicitly agrees to an offer or agrees to pay a draft that is presented for payment

Implied Acceptance An implied acceptance is one that is not directly stated but is demon-strated by any acts indicating a person’s assent

to the proposed bargain An implied acceptance occurs when a shopper selects an item in a supermarket and pays the cashier for it The shopper’s conduct indicates that he or she has agreed to the supermarket owner’s offer to sell the item for the price stated on it

FURTHER READINGS Chirelstein, Marvin A 2006 Concepts and Case Analysis in the Law of Contracts 5th ed Eagan, MN: West.

Perillo, Joseph M 2009 Calamari and Perillo’s Hornbook on Contracts 6th ed Eagan, MN: West.

“Silence as Acceptance in Contracts Lawyers.” 2009.

LegalMatch Website Available online at http://www.

legalmatch.com/law-library/article/silence-as-acceptance-in-contracts.html; website home page: http://www.

legalmatch.com (accessed August 28, 2009).

ACCESS Freedom of approach or communication; or the means, power, or opportunity of approaching,

ACCESS 51

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communicating, or passing to and from Sometimes importing the occurrence of sexual intercourse;

otherwise as importing opportunity of communica-tion for that purpose as betweenHUSBAND AND WIFE

In real property law, the term access denotes the right vested in the owner of the land that adjoins a road or other highway to go and return from his own land to the highway without

A sample acceleration

clause

ILLUSTRATION BY GGS

CREATIVE RESOURCES.

REPRODUCED BY

PERMISSION OF GALE,

A PART OF CENGAGE

LEARNING.

FOR VALUE RECEIVED, WE, THE UNDERSIGNED, jointly and severally promise to pay, in lawful money of the United States of America,

to the order of at , ( ) Dollars in installments as follows:

_ on _ , and _ successive payments

of beginning on _ together with a delinquency charge on each installment in default for _ days in an amount equal to _ percent of such installment but not less than $ _

In the event of default in the payment of any of the said installments or said interest when due as herein provided, time being of the essence hereof, the holder of this note may, without notice or demand, declare the entire principal sum then unpaid immediately due and payable.

The holder of this note may, with or without notice to any of us, cause additional parties to be added hereto, or release any party hereto,

or revise, extend, or renew the note, or extend the time for making any installment provided for herein, or accept any installment in advance, all without affecting the liability of us, or any of us, hereon.

If suit be commenced on said note, the parties hereto jointly and severally agree to pay to the holder of said note a reasonable attorney fee.

The borrower agrees to pay a reasonable collection charge should collection be referred to a collection agency or to the payee`s collection facilities.

The parties hereto, jointly and severally, hereby waive presentment, demand, protest, notice of dishonor and/or protest and notice of nonpayment; the right, if any, to the benefit of, or to direct the application of, any security hypothecated to the holder until all indebtedness

of the borrower to the holder shall have been paid; the right to require the holder to proceed against the borrower, or to pursue any other remedy in the holder's power; and agree that the holder may proceed against us directly and independently of the borrower, and that the cessation of liability of the borrower for any reason, other than full payment, or any revision, renewal, extension, forebearance, change of rate of interest, or acceptance, release or substitution of security, or any impairment or suspension of the holder's remedies or rights against the borrower, shall not in anywise affect the liability of any of the parties hereto.

The parties hereto hereby authorize to date this note as of the day when the loan evidenced hereby is made and to complete this note in any other particular according to the terms of the said loan.

It is agreed that if the parties hereto, or any of them at any time fail in business or become insolvent, or commit an act of bankruptcy, or

if any deposit account or other property of the parties hereto, or any of them, be attempted to be obtained or held by writ of execution, garnishment, attachment, or other legal process, or if any assessment for taxes against the parties hereto, or any of them, other than taxes

on real property, is made by the federal or state government, or any department thereof, or if the parties hereto fail to notify you of any material change in their financial condition, then, and in such case all of the obligations of the parties hereto to you, or held by you, shall at your option immediately become due and payable without demand or notice.

Signatures Address _

Borrower

_

Co-Maker

Acceleration Clause

PROMISSORY NOTE INSTALLMENT - WITH ACCELERATION CLAUSE

[amount]

[payee]

[number]

[city, state, date]

52 ACCESS

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obstruction Access to property does not necessarily

carry with it possession

For purposes of establishing element of access

by defendant in COPYRIGHT infringement action,

access is ordinarily defined as opportunity to copy

Prisoners are entitled to have access to

court PRISONofficials cannot prevent prisoners

from filing papers or appearing in court even

if they honestly think that such prevention

would help them maintain discipline and good

order

Owners of real property are entitled to some

means of access to their property from a road or

highway They do not necessarily need to own a

corridor of land from their property to the nearest

road, but they may claim an easement of access

opportunity to have had sexual relations When

there is a question about who is the father of a

certain child, it is appropriate for a court to

determine which man had access to the mother

around the estimated time of conception A

man charged with being the father of an

illegitimate child may plead the defense of

multiple access—that the mother had several

lovers at the time of conception

ACCESSION

Coming into possession of a right or office;

increase; augmentation; addition

The right to all that one's own property

produces, whether that property be movable or

immovable; and the right to that which is united

to it by accession, either naturally or artificially

The right to own things that become a part of

something already owned

A principle derived from theCIVIL LAW, by which

the owner of property becomes entitled to all that it

produces, and to all that is added or united to it,

either naturally or artificially (that is, by the labor or

skill of another) even where such addition extends to

a change of form or materials; and by which, on the

other hand, the possessor of property becomes

entitled to it, as against the original owner, where

the addition made to it by skill and labor is of greater

value than the property itself, or where the change

effected in its form is so great as to render it

impossible to restore it to its original shape

Generally, accession signifies acquisition of

title toPERSONAL PROPERTYby bestowing labor on it

that converts it into an entirely different thing or

by incorporation of property into a union with other property

The commencement or inauguration of a sovereign’s reign

For example, a person who owns property along a river also takes ownership of any additional land that builds up along the riverbank

This right may extend to additions that result from the work or skill of another person The buyer of a car who fails to make scheduled payments cannot get back his new spark plugs after the car is repossessed because they have become a part of the whole car The principle of accession does not necessarily apply, however, where the addition has substantially improved the value and changed the character of the property,

as when by mistake someone else’s grapes were made into wine or someone else’s clay made into bricks In such cases, the original owner might recover only the value of the raw material rather than take ownership of the finished product

In the context of a treaty, accession may be gained in either of two ways: (1) the new member nation may be formally accepted by all the nations already parties to the treaty; or (2) the new nation may simply bind itself to the obligations already existing in the treaty Frequently, a treaty will expressly provide that certain nations or catego-ries of nations may ACCEDE In some cases, the parties to a treaty will invite one or more nations

to accede to the treaty

ACCESSORY Aiding or contributing in a secondary way

or assisting in or contributing to as a subordinate

InCRIMINAL LAW, contributing to or aiding in the commission of a crime One who, without being present at the commission of an offense, becomes guilty of such offense, not as a chief actor, but as a participant, as by command, advice, instigation, or concealment; either before or after the fact or commission

One who aids, abets, commands, or counsels another in the commission of a crime

In common law, an accessory could not be found guilty unless the actual PERPETRATOR was convicted In most U.S jurisdictions, however,

an accessory can be convicted even if the principal actor is not arrested or is acquitted

The prosecution must establish that the acces-sory in some way instigated, furthered, or concealed the crime Typically, PUNISHMENT for

ACCESSORY 53

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a convicted accessory is not as severe as that for the perpetrator

An accessory must knowingly promote or contribute to the crime In other words, she or he must aid or encourage the offense deliberately, not accidentally The accessory may withdraw from the crime by denouncing the plans, refusing to assist with the crime, contacting the police, or trying to stop the crime from occurring

An accessory before the fact is someone behind the scenes who orders a crime or helps another person commit it Many jurisdictions now refer to accessories before the fact as parties

to the crime or even accomplices This substi-tution of terms can be confusing because accessories are fundamentally different from accomplices Strictly speaking, whereas an

ACCOMPLICE may be present at the crime scene,

an accessory may not Also, an accomplice generally is considered to be as guilty of the crime as the perpetrator, whereas an accessory has traditionally received a lighter punishment

An accessory after the fact is someone who knows that a crime has occurred but nonethe-less helps to conceal it In the early twenty-first century, this action is often termed obstructing justice or harboring a fugitive

An infamous accessory after the fact was

Dr Samuel A Mudd, the physician and Confederate sympathizer who set John Wilkes Booth’s leg after it was broken when the assassin jumped from President Abraham Lincoln’s box

at Ford Theater Despite Mudd’s protestation of innocence, he was tried and convicted as an accessory after the fact in Lincoln’sMURDER He was sentenced to life IMPRISONMENT at Fort

Jefferson in the Dry Tortugas off Key West, Florida President ANDREW JOHNSON pardoned Mudd in 1869, and the U.S Congress gave him

an officialPARDONin 1979

FURTHER READINGS Berg, Alan 1996 “Accessory Liability for Breach of Trust.” Modern Law Review 59 (May).

Blakey, Robert G., and Kevin P Roddy 1996 “Reflections on Reves v Ernst & Young: Its Meaning and Impact

on Substantive, Accessory, Aiding Abetting and Conspiracy Liability under RICO ” American Criminal Law Review 33 Huett, Lisa 2001 “Could You Be an Accessory? Uncertainty and Risk For Lawyers ” Law Institute Journal 75 (March).

ACCIDENT The word accident is derived from the Latin verb accidere, signifying “fall upon, befall, happen, chance.” In its most commonly accepted meaning,

or in its ordinary or popular sense, the word may be defined as meaning: some sudden and unexpected event taking place without expectation, upon the instant, rather than something that continues, progresses or develops; something happening by chance; something unforeseen, unexpected, unusual, extraordinary, or phenomenal, taking place not according to the usual course of things or events, out of the range of ordinary calculations; that which exists or occurs abnormally, or an uncommon occurrence The word may be employed as denoting

a calamity, casualty, catastrophe, disaster, an undesirable or unfortunate happening; any unex-pected personal injury resulting from any unlooked for mishap or occurrence; any unpleasant or unfortunate occurrence that causes injury, loss, suffering, or death; some untoward occurrence aside from the usual course of events An event that takes place without one’s foresight or expectation; an undesigned, sudden, and unexpected event Accident is not always a precise legal term It may be used generally in reference to various types of mishaps, or it may be given a technical meaning that applies when used in a certain statute or kind of case Where it is used in a general sense, no particular significance can be attached to it Where it is precisely defined, as in

a statute, that definition strictly controls any decision about whether a certain event covered

by that statute was in fact an accident

In its most limited sense, the word accident

is used only for events that occur without the intervention of a human being This kind of accident also may be called anACT OF GOD It is

an event that no person caused or could have

Emergency workers

attend to a woman

involved in a

single-car accident Crashes

such as this one are

considered accidents

unless a driver

intentionally causes

the crash.

AP IMAGES

54 ACCIDENT

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prevented—such as a tornado, a tidal wave, or

an ice storm An accident insurance policy can

by its terms be limited to coverage only for this

type of accident Damage by hail to a field of

wheat may be considered such an accident

A policy of insurance, by its very nature,

covers only accidents and not intentionally

caused injuries That principle explains why courts

will read some exceptions into any insurance

policy, whether or not they are expressly stated

For example, life insurance generally will not

compensate for aSUICIDE, and ordinary automobile

insurance will not cover damages sustained when

the owner is drag racing

Accident insurance policies frequently insure

not only against an act of God but also for

accidents caused by a person’s carelessness An

insured homeowner will expect coverage, for

example, if someone drowns in his or her pool,

even though the accident might have occurred

because someone in the family left the gate open

Not every unintended event is an accident

for which insurance benefits can be paid; all the

circumstances in a particular case must first be

considered For example, a policeman who

waded into a surging crowd of forty or fifty

fighting teenagers and then experienced a heart

attack was found to have suffered from an

accident In another case, a man who was shot

when he was found in bed with another man’s

wife was also found to have died in an accident

because death is not the usual or expected result

of ADULTERY However, the family of another

man was not allowed to collect insurance

benefits when he was shot after starting a fight

with a knife In that case, the court ruled that

DEADLY FORCE was a predictable response to a

life-threatening attack, whether the instigator

actually anticipated it or not

Different states apply different standards

when determining if an accident justifies

payment of benefits under workers’

compensa-tion Some states strictly limit benefits to events

that clearly are accidents They will permit

payment when a sudden and unexpected strain

causes an immediate injury during the course of

work but they will not permit payment when an

injury gradually results from prolonged assaults

on the body Under this approach, a worker

who is asphyxiated by a lethal dose of carbon

monoxide when he goes into a blast furnace

to make repairs would be deemed to have

suffered in an accident However, a worker who

contracts lung cancer after years of exposure

to irritating dust in a factory could notCLAIMto have been injured in an accident Because of the remedial purpose of workers’ compensation schemes, many states are liberal in allowing compensation In one state, a woman whose existing arthritic condition was aggravated when she took a job stuffing giblets into partially frozen chickens on a conveyor belt was allowed

to collect workers’ compensation benefits

Insurance policies may set limits to the amount of benefits recoverable for one accident

A certain automobile insurance policy allowed a maximum of only $200 to compensate for damaged clothing or luggage in the event of an accident When luggage was stolen from the insured automobile, however, a court ruled that the event was not an accident and the maximum did not apply The owner was allowed to recover the full value of the lost property

Sometimes the duration of an accident must

be determined For example, if a drunken driver hit one car and then continued driving until he

or she collided with a truck, a court might have to determine whether the two victims will share the maximum amount of money payable under the driver’s LIABILITYinsurance policy or

Septicemia 1.4%

Nephritis, nephrotic syndrome, and nephrosis 1.9%

Alzheimer's 3.0%

Diabetes 3.0%

Influenza and pneumonia 2.3%

Accidents 5.0%

Chronic lower respiratory diseases 5.1%

Heart disease 26.0%

Cancer 23.1%

Cerebrovascular diseases/stroke 5.7%

Ten Leading Causes of Death in the United States in 2006

Total number of deaths: 2,426,264 Number of deaths not accounted for in top ten: 570,654 Percentage of deaths not in top ten: 23.6%

SOURCE: Centers for Disease Control and Prevention, National Center for Health

Statistics, National Vital Statistics Report, vol 57, no 14, April 2009.

ILLUSTRATION BY GGS CREATIVE RESOURCES REPRODUCED BY PERMISSION OF GALE,

A PART OF CENGAGE LEARNING.

ACCIDENT 55

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whether each will collect the full maximum as a result of a separate accident

CROSS REFERENCES Automobiles “No-Fault Automobile Insurance” (In Focus);

Automobiles “What to Do If You Are in an Auto Accident”

(Sidebar); Insurance.

ACCIDENTAL DEATH BENEFIT

A provision of a life insurance policy stating that if the insured—the person whose life has been insured—

dies in an accident, the beneficiary of the policy—the person to whom its proceeds are payable—will receive twice the face value of the policy

The insurance company that is liable for the payment of such a benefit will conduct a thorough investigation into the cause of death

of the insured person before paying theCLAIM Another name for an ACCIDENTAL DEATH BENEFITis aDOUBLE INDEMNITYclause

ACCIDENTAL KILLING

A death caused by a lawful act done under the reasonable belief that no harm was likely to result

Accidental killing is different from INVOLUN-TARY MANSLAUGHTER, which causes death by an

unlawful way

two types of accidental killings: (1) accidental killings resulting from unlawful acts of violence not directed at the victim were punishable as

MANSLAUGHTER (killings resulting from unlawful acts directed at the victim were punishable as

MURDER); and (2) accidental killings resulting from lawful acts of violence were excusable as

HOMICIDEby misadventure

For example, suppose that the DEFENDANT

killed an innocent bystander while carrying out

an ASSAULT, BATTERY, or other violent crime against the intended victim The defendant told police that he intended to injure the victim by hitting him with a club but instead struck the bystander on the skull and killed him The defendant could be prosecuted for manslaugh-ter under the common law of crimes

Now suppose that the defendant was lawfully defending himself or his property from attack, and in the process killed an innocent bystander The defendant told police that lethal force was necessary to thwart an attack upon his person, and he tried to shoot the attacker but

instead killed a nearby pedestrian, who had nothing to do with the attack The common law would have treated the bystander’s death as an excusable accidental killing, so long as reason-able grounds existed for the defendant’s belief that lethal force was necessary for self-defense Although most states have abolished the common law of crimes, some of the concepts underlying the common law distinctions be-tween manslaughter and accidental killings continue to appear in statutory classifications

of manslaughter

Most states recognize at least two classes of manslaughter, voluntary and involuntary In these states voluntary manslaughter is defined as act of murder reduced to manslaughter because

ofEXTENUATING CIRCUMSTANCES such as adequate

in the heat of passion) or DIMINISHED CAPACITY Involuntary manslaughter is defined in these states as a homicide that is committed with

CRIMINAL NEGLIGENCE or during the commission

of a crime that is not included within the

FELONY-MURDER RULEbut for which the prosecu-tion has no proof that the defendant intended to kill the victim or do grievous bodily harm Accidental killings that do not result from the defendant’s criminalNEGLIGENCEand do not occur during the commission of a crime are not criminal offenses in these jurisdictions Some jurisdictions expressly classify accidental killings

as excusable or justifiable homicides, such as the state of California, which provides that

“[h]omicide is excusable [w]hen committed

by ACCIDENT and misfortune, or in doing any other lawful act by lawful means, with usual and ordinary caution, and without any unlawful intent” (CA PENAL § 195) Other states simply omit this class of homicide from their statutes defining prosecutable offenses

CROSS REFERENCES Common Law; Diminished Capacity; Homicide; Involun-tary Manslaughter; Murder.

ACCIDENTAL VEIN

An imprecise term that refers generally to a continuous body of a mineral or mineralized rock filling a seam other than the principal vein that led

to the discovery of the mining claim or location CROSS REFERENCES

Mine and Mineral Law.

56 ACCIDENTAL DEATH BENEFIT

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ACCIDENTS OF NAVIGATION

Mishaps that are peculiar to travel by sea or

to normal navigation; accidents caused at sea by the

action of the elements, rather than by a failure to

exercise good handling, working, or navigating of

a ship Such accidents could not have been avoided

by the exercise of nautical skill or prudence

CROSS REFERENCES

Admiralty and Maritime Law; Navigable Rivers.

ACCOMMODATION ENDORSEMENT

The act of a third person—the accommodation

party—in writing his or her name on the back of a

commercial paper without any consideration, but

merely to benefit the person to whom the paper is

payable or to enable the person who made the

document—the maker—to obtain money or credit

on it

An accommodation endorsement is a loan

of the endorser’s credit up to the face amount of

the paper

ACCOMMODATION PAPER

A type of commercial paper (such as a bill or note

promising that money will be paid to someone)

that is signed by another person—the

accommodation party—as a favor to the promi-sor—the accommodated party—so that credit may be extended to him or her on the basis of the paper

An accommodation paper guarantees that the money lent will be repaid by the

fails to repay it A lender often uses an accommodation paper when the person who

is seeking a loan is considered a poor credit risk, such as a person who has a history of being delinquent in the payment of installment loans

By having a person who is a good credit risk cosign the PROMISSORY NOTE, the lender’s finan-cial interests are protected

An accommodation bill and an accommo-dation note are two types of commercial papers

ACCOMMODATION PARTY One who signs a commercial paper for the purpose of lending his or her name and credit to another party to the document—the accommo-dated party—to help that party obtain a loan or

an extension of credit

A person wanting to obtain a car loan, for example, may offer a finance company a

PROMISSORY NOTEfor the amount of the requested

Accommodation Note

Agreement of an Accommodation Party to Modifications in an Accommodation Note

This agreement is made between _ [name of the holder of the note] ("holder")

and [name of the accommodation party] ("accommodation party").

On [date of execution], _ [name of maker] ("maker"), of

_ [address of maker] executed and issued a promissory note ("note") to the holder as payee,

by which the maker promised to pay to the order of the holder [amount] [include any other specific

payment terms, including days after the date of execution].

On [date], the accommodation party signed the note as co-maker in order to accommodate the maker at the request of the maker.

The accommodation party and the holder agree that the holder may modify the terms of the note without notice to or the consent of

the accommodation party.

[Signature of holder], holder

[Signature of Accommodation Party], accommodation party

A sample accomodation note

ILLUSTRATION BY GGS CREATIVE RESOURCES REPRODUCED BY PERMISSION OF GALE,

A PART OF CENGAGE LEARNING.

ACCOMMODATION PARTY 57

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