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A mere threat to harm is not an assault; however, a threat combined with a raised fist might be sufficient if it causes a reasonable apprehension of harm in the victim.. In criminal law,

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SUICIDE and a California law that permits the possession of marijuana for medicinal use In addition, Ashcroft filed a brief with the Supreme Court in support of ending the University of Michigan’s affirmative action admission pro-gram While in office, Ashcroft advocated protection for the rights of gun owners while pressing for more severe punishments of those who commited capital crimes using guns or other WEAPONS Despite state moratoriums on capital punishment, exonerations of death row defendants in more than 100 cases, and Supreme Court decisions that banned the execution of mentally retarded inmates and overturned cases where judges rather than juries had imposed the death penalty, Ashcroft overruled U.S attorneys who had decided not to seek the death penalty, and he approved death penalty prosecutions in nearly half of all federal cases where capital punishment might have been applicable

Ashcroft resigned his position as attorney general in November of 2004 He was succeeded

byALBERTO GONZALES On May 18, 2009, a lawsuit

by Pakistani Muslim Javaid Iqbal against Ashcroft and FBI Director ROBERT S MUELLER

III charging abuse after the September 11th terrorist attacks was dismissed by the U.S

Supreme Court due to a lack of evidence Four months later, however, the NinthCIRCUIT COURT

of Appeals ruled against Ashcroft in a similar case, giving Abdullah al-Kidd, a U.S citizen, the right to sue Ashcroft for unlawful detainment

As of late 2009, Ashcroft continues his work with the Kansas City (Missouri) law firm he founded, The Ashcroft Group

FURTHER READINGS Annual Accountability Report 2002 Washington, DC:

Department of Justice.

The Ashcroft Group Available online at http://www.

ashcroftgroupllc.com (accessed August 24, 2009).

Ashcroft, John 1998 Lessons from a Father to His Son.

Nashville: Thomas Nelson Publishers.

Branch-Brioso, Karen March 5, 2003 “Ashcroft Reports Progress against Terrorism with Ridge and Mueller, He Tells Congress of Arrests, Better Information Sharing ”

St Louis Post-Dispatch.

Cloud, John 2001 “General on the March: John Ashcroft Wants to Mobilize the Justice Department to Fight Terror Is He Going Too Far? ” Time (November 19).

Fechter, Michael 2002 “Ashcroft Defends New Wiretap Powers ” The Tampa Tribune (November 21).

ASHWANDER RULES

A principle of constitutional law establishing judicial policy that courts should decide

constitutional questions only when necessary and should decide the case on another basis if possible

In Ashwander v Tennessee Valley Authority,

297 U.S 288, 56 S Ct 466, 80 L Ed 2d 688 (1936), JusticeLOUIS BRANDEISarticulated a series

of seven principles that apply to the Supreme Court’s policy of deciding constitutional ques-tions These principles include the policy that the court: (1) should not decide a constitutional question in a FRIENDLY SUIT; (2) should not anticipate a question of CONSTITUTIONAL LAW; (3) should not create a rule of constitutional law that is broader than that called for by the facts of the case; (4) should not decide a cons-titutional issue if the case can be decided on another ground; (5) should not rule on the constitutionality of a statute unless thePLAINTIFF

is harmed by the statute; (6) should not pass on the constitutionality if the plaintiff has accepted the benefits of the statute; and (7) should not rule on the constitutionality of an act of Congress without first analyzing whether the act can be fairly construed in a way that would avoid the constitutional question

FURTHER READINGS Farber, Daniel A and Suzanna Sherry 2009 Judgment Calls: Principle and Politics in Constitutional Law New York: Oxford University Press.

Marks, Thomas C., Jr 2008 “The Decline of American Culture: The Role of the Federal Judiciary ” Stetson Law Review 37 (spring).

CROSS REFERENCES Constitutional Law; Jurisprudence

ASPORTATION The removal of items from one place to another, such as carrying things away illegally

Asportation is one of the elements required to establish the crime ofLARCENY In order to prove that asportation has occurred, it is not necessary

to show that the goods were moved a substantial distance, but only that they were moved Asportation was one of the elements neces-sary to establish common-law KIDNAPPING, and

in many states it remains as an element of statutory kidnapping

ASSASSINATION Assassination is murder committed by a perpetra-tor without the personal provocation of the victim, who is usually a government official

388 ASHWANDER RULES

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First used in medieval times to describe the

murders of prominent Christians by the

Hashshashin, a secret Islamic sect, the word

assassination is used in the twenty-first century

to describe murders committed for political

reasons, especially against government officials

Assassination may be used as a political weapon

by a state as well as by an individual; it may be

directed at the establishment or used by it

The term assassination is generally applied

only to political murders—in the United States,

most commonly to attempts on the life of the

president However, the classification of any one

incident as an assassination may be in part a

matter of perception The assassination of the

outlaw Jesse James, in 1882, provides an

ex-ample of the difficulties Thomas T Crittenden,

governor of Missouri, assumed that being seen

as responsible for the death of the notorious

outlaw would be good for his political career For

this reason, Crittenden granted each of the killers

a pardon in addition to a $10,000 reward But the

U.S public spoke vehemently against James’s

killers, dubbing them assassins and his death an

assassination Crittenden was vilified by

Amer-icans, and his political career was destroyed

It is not always easy to guess the motivations

of those who attempt assassinations or to understand the historical and legal implications

of their actions The anti-constitutional nature

of assassination has also made it a focal point for conspiracies and conspiracy theories The first attempt at the assassination of a U.S

president was Richard Lawrence’s attack on

ANDREW JACKSON in 1835 Although a jury acquitted Lawrence on the ground of insanity, Jackson was convinced that the attack was part

of a WHIG PARTYconspiracy

The 1865 assassination of PresidentABRAHAM LINCOLN by John Wilkes Booth prompted its own set of theories In a controversial decision,

a military tribunal convicted nine people of conspiring in Lincoln’s assassination In the case of one of those hanged for the crime, Mary E Surratt, all that could be proved was that she owned the rooming house in which the conspirators plotted Nonetheless, high emotions at the end of the Civil War resulted

in her execution After sentiments cooled and talk of conspiracies calmed, the two surviving conspirators imprisoned for Lincoln’s death gained pardons from PresidentANDREW JOHNSON

President William McKinley was shot by Leon F Czolgosz, on September 6, 1901, at the Pan-American Exposition in Buffalo, New York McKinley died on September 14 LIBRARY OF CONGRESS ASSASSINATION 389

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Even greater controversy was caused when the public was deprived of the opportunity to see Lee Harvey Oswald tried for the assassina-tion, in 1963, of President JOHN F KENNEDY Oswald’s death at the hands of JACK RUBY

sparked theories of conspiracy that ranged from Communist plots to Mafia hits to cover-ups by U.S officials President LYNDON B JOHNSON

appointed a group of national figures, led by Supreme Court Chief Justice EARL WARREN, to investigate the assassination and issue a report

TheWARREN COMMISSIONconcluded that Oswald had acted alone

Despite this conclusion, conspiracy theories remained widespread in books and in films such

as Oliver Stone’s JFK: The Untold Story (released

in 1991) In an attempt to calm public suspicions surrounding the Kennedy assassina-tion, the President John F Kennedy Assassina-tion Records CollecAssassina-tion Act of 1992 (44 U.S.C.A

§ 2107) was passed by Congress The act released much of the Kennedy assassination material in government files As of 2009, its effectiveness at stilling concern over a possible conspiracy remained to be seen

It has become clear that the public demands

a thorough investigation of any attempt on a president’s life Because it is a crime to advocate the assassination of any U.S president, president-elect, VICE PRESIDENT, vice president-elect, or anyone legally acting as president (18 U.S.C

1751), evenTHREATSare carefully investigated In U.S history, four presidents have lost their lives

to assassins: Abraham Lincoln, JAMES GARFIELD,

WILLIAM MCKINLEY, and John F Kennedy

Political Assassination by U.S Government Employees

In 1974 the Congress established a committee

to investigate possible U.S involvement in plots

to assassinate foreign leaders deemed hostile to U.S interests Specifically, the committee inves-tigated the alleged involvement of the CENTRAL INTELLIGENCE AGENCY(CIA) in plots to kill Patrice Lumumba of the Congo, Fidel Castro of Cuba, Rafael Trujillo of the Dominican Republic, Rene Schneider of Chile, and Ngo Dinh Diem of South Vietnam The absence of a written record and the failing memories of principalWITNESSES

prevented the committee from conclusively demonstrating that presidents Eisenhower, Kennedy, or Nixon personally authorized the assassination of any foreign leader However, the evidence did show that between 1960 and

1970, the CIA was involved in several assassina-tion plots

The committee reported its findings in 1975

to a dismayed Congress Public outcry was loud and immediate At the urging of both the House

of Representatives and the Senate, President

GERALD R FORD signed an EXECUTIVE ORDER

banning all federal employees from committing assassination as a tool of U.S foreign policy or for any other reason (Exec Order No 11905) The order was extended by President RONALD REAGAN(who survived an assassination attempt)

15 years later to also preclude hired assassins Title 18 U.S.C §§ 2381 and 2385 (1976) prohibits the assassination of any officer of state or federal government

Following the September 11, 2001, terrorist attacks in New York City and Washington, D.C., Congress and the White House revisited the propriety of political assassinations committed

by members of the U.S government In December 2002, according to a Globe and Mail news story, President GEORGE W BUSH gave the CIA written authority to kill about two dozen terrorist leaders if capturing them proved to be impractical and civilian casualties could not be minimized The CIA relied on that authority in using a pilotless Predator aircraft to fire a Hellfire antitank missile at a car in Yemen carrying an al-Qaeda operative The al-Qaeda operative and five other people died in the attack

In July 2009 both the New York Times and Wall Street Journal published articles expound-ing on the CIA’s sequential plans to target and kill identified terrorists The plans were formally abandoned in mid-2009 by CIA director Leon Panetta after he advised congressional intelli-gence committees that he himself had just learned of the scope of the plans; they initially had been kept secret by the CIA’s counterter-rorism center under the order of former vice president Dick Cheney According to the Times article, law professor Kenneth Anderson of American University noted that as far back as

1989 the United States had argued that killing terrorists did not violate federal law as it would constitute a legal act of SELF-DEFENSE under

INTERNATIONAL LAW Such killings would be premised on the condition that authorities in the country where the terrorist was located were either unable or unwilling to prevent the terrorist from proceeding But international

390 ASSASSINATION

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law experts rebutted Anderson’s justification

with their own concerns They cited the

potential for violating the SOVEREIGNTY of

the country where the terrorist was killed, the

differing legal status between the CIA and the

uniformed military, and whether such a killing

would fall under the purview of the law of war

FURTHER READINGS

Allen Chair Symposium 2002 2003 “Political Assassination

as an Instrument of National Policy: An Inquiry into

Operations, Expediency, Morality, and Law ” Univ of

Richmond Law Review (March).

“C.I.A Had Secret Al Qaeda Plan.” 2009 Wall Street Journal,

July 13.

Donoghue, Mary Agnes 1975 Assassination: Murder in

Politics Chatsworth, Calif.: Major Books.

Edwards, William C., and Edward Steers 2009 The Lincoln

Assassination: The Evidence Champaign, Ill.: Univ of

Illinois Press.

Harder, Tyler J 2002 “Time to Repeal the Assassination

Ban of Executive Order 12,333: A Small Step in

Clarifying Current Law ” Military Law Review 172

(June).

Mazetti, Mark, and Scott Shane 2009 “C.I.A Had Plan to

Assassinate Qaeda Leaders ” New York Times, July 14.

McKinley, James 1977 Assassination in America New York:

Harper & Row.

Taylor, Stuart, Jr 1998 “Assassination as Self-defense.” New

York Law Journal (November 30).

CROSS REFERENCE

Lincoln, Abraham, “Lincoln Assassination Conspiracy” (In

Focus).

ASSAULT

At common law, an intentional act by one person

that creates an apprehension in another of an

imminent harmful or offensive contact

An assault is carried out by a threat of bodily

harm coupled with an apparent, present ability

to cause the harm It is both a crime and a tort

and, therefore, may result in either criminal or

civil liability Generally, the COMMON LAW

definition is the same in criminal and TORT

LAW There is, however, an additionalCRIMINAL

LAW category of assault consisting of an

attempted but unsuccessful battery

Statutory definitions of assault in the

various jurisdictions throughout the United

States are not substantially different from the

common-law definition

Elements

Generally, the essential elements of assault

consist of an act intended to cause an

apprehension of harmful or offensive contact

that causes apprehension of such contact in the victim

The act required for an assault must be overt Although words alone are insufficient, they might create an assault when coupled with some action that indicates the ability to carry out the threat A mere threat to harm is not an assault; however, a threat combined with a raised fist might be sufficient if it causes a reasonable apprehension of harm in the victim

Intent is an essential element of assault In tort law, it can be specific intent—if the assailant intends to cause the apprehension of harmful or offensive contact in the victim—or general intent—if he or she intends to do the act that causes such apprehension In addition, the intent element is satisfied if it is substantially certain, to a REASONABLE PERSON, that the act will cause the result A DEFENDANTwho holds a gun

to a victim’s head possesses the requisite intent, because it is substantially certain that this act will produce an apprehension in the victim In all cases, intent to kill or harm is irrelevant

In criminal law, the attempted battery type

of assault requires a SPECIFIC INTENT to commit battery An intent to frighten will not suffice for this form of assault

There can be no assault if the act does not produce a true apprehension of harm in the victim There must be a reasonable fear of injury The usual test applied is whether the act would induce such apprehension in the mind of

a reasonable person The status of the victim is taken into account A threat made to a child might be sufficient to constitute an assault, while an identical threat made to an adult might not

Virtually all jurisdictions agree that the victim must be aware of the danger This element is not required, however, for the attempted battery type of assault A defendant who throws a rock at a sleeping victim can only

be guilty of the attempted battery assault, because the victim would not be aware of the possible harm

Aggravated Assault

AnAGGRAVATED ASSAULT, punishable in all states

as a FELONY, is committed when a defendant intends to do more than merely frighten the victim Common types of aggravated assaults are those accompanied by an intent to kill, rob,

orRAPE An assault with a dangerous weapon is

ASSAULT 391

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aggravated if there is an intent to cause serious harm Pointing an unloaded gun at a victim to frighten the individual is not considered an aggravated assault

Punishment

A defendant adjudged to have committed civil assault is liable for damages The question of the amount that should be awarded to the victim is determined by a jury COMPENSATORY DAMAGES, which are aimed at compensating the victim for the injury, are common NOMINAL DAMAGES, a small sum awarded for the invasion of a right even though there has been no substantial injury, may be awarded In some cases, courts allow PUNITIVE DAMAGES, which are designed to punish the defendant for the wrongful conduct

The punishment for criminal assault is a fine, imprisonment, or both Penalties are more severe when the assault is aggravated Many states have statutes dividing criminal assault into various degrees As in aggravated assault, the severity of the crime, the extent of violence and harm, and the criminal intent of the defendant are all factors considered in deter-mining the sentence imposed

FURTHER READINGS Brewer, James D 1994 The Danger from Strangers:

Confronting the Threat of Assault New York: Insight Books.

Duhaime, Lloyd “Assault.” Duhaime.org Available online

at http://www.duhaime.org/LegalDictionary/A/Assault aspx; website home page: http://www.duhaime.org (accessed August 28, 2009).

National Center for Victims of Crime Web site “Assault Victimization ” Washington, D.C.: Justice Department Available online at http://www.ojp.usdoj.gov/ovc/pub- lications/infores/help_series/pdftxt/assaultvictimiza-tion.pdf; website home page: http://www.ojp.usdoj.gov (accessed August 28, 2009).

ASSAULT AND BATTERY Two separate offenses against the person that when used in one expression may be defined as any unlawful and unpermitted touching of another Assault is an act that creates an apprehension in another of an imminent, harmful, or offensive contact The act consists of a threat of harm accompanied by an apparent, present ability to carry out the threat Battery is a harmful or offensive touching of another The main distinction between the two offenses is the existence or nonexistence of a touching or contact While contact is an essential element of battery, there must be an absence of contact for assault Sometimes assault is defined loosely to include battery Assault and battery are offenses in both criminal andTORT LAW; therefore, they can give rise to criminal or civil liability InCRIMINAL LAW,

an assault may additionally be defined as any attempt to commit a battery

At COMMON LAW, both offenses were mis-demeanors As of the early 2000s, under virtually all criminal codes, they are either misdemeanors

or felonies They are characterized as FELONIOUS

when accompanied by a criminal intent, such as

an intent to kill, rob, orRAPE, or when they are committed with a dangerous weapon

Intent Intent is an essential element of both offenses Generally, it is only necessary for theDEFENDANTto have an intent to do the act that causes the harm

In other words, the act must be done voluntarily Although an intent to harm the victim is likely to exist, it is not a required element of either offense There is an exception to this rule for the attempted battery type of criminal assault If a defendant who commits this crime does not have

an intent to harm the victim, the individual cannot be guilty of the offense

Defenses Consent

In almost all states, consent is a defense to civil assault and battery Some jurisdictions hold that

Victimization Rates for Assaults by Crime and Characteristic, 2006

SOURCE: U.S Bureau of Justice Statistics, Criminal Victimization in the United

States, 2006.

Total

Aggravated

Simple

Rate per 1,000 persons age 12 years or older

22.6 18.9

6.3 4.6

16.3 14.3

Male Female

ILLUSTRATION BY GGS

CREATIVE RESOURCES.

REPRODUCED BY

PERMISSION OF GALE,

A PART OF CENGAGE

LEARNING.

392 ASSAULT AND BATTERY

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in the case of mutual combat, consent will not

suffice and either party may sue the other

Jurisdictions also differ on the question of

whether consent is a defense to criminal assault

and battery

Consent must be given voluntarily in order

to constitute a defense If it is obtained byFRAUD

or duress or is otherwise unlawful, it will not

suffice When an act exceeds the scope of the

given consent, the defense is not available A

person who participates in a football game

implies consent to a certain amount of physical

contact; however, the individual is not deemed

to consent to contact beyond what is commonly

permitted in the sport

Self-Defense Generally, a person may use

whatever degree of force is reasonably necessary

for protection from bodily harm Whether this

defense is valid is usually determined by a jury

A person who initiates a fight cannot claimSELF

-DEFENSEunless the opponent responded with a

greater and unforeseeable degree of force When

an aggressor retreats and is later attacked by the

same opponent, the defense may be asserted

The use ofDEADLY FORCEin response may be

justified if it is initially used by the aggressor

The situation must be such that a REASONABLE

PERSONwould be likely to fear for his or her life

In some states, a person must retreat prior to

using deadly force if the individual can do so in

complete safety A majority of states, however,

allow a person to stand his or her ground even

though there is a means of safe escape

Whether the degree of force used is

reasonable depends upon the circumstances

The usual test applied involves determining

whether a reasonable person in a similar

circumstance would respond with a similar

amount of force Factors such as age, size, and

strength of the parties are also considered

Defense of Others Going to the aid of a

person in distress is a valid defense, provided

the defender is free from fault In some states,

the defender is treated as though he or she

stands in the shoes of the person protected The

defender’s right to claim defense of others

depends upon whether the person protected

had a justified claim of self-defense In a

minority of jurisdictions, the defense may be

asserted if the defender reasonably believed the

THIRD PARTYwas in need of aid

Defense of Property Individuals may use a reasonable amount of force to protect their property The privilege to defend one’s property

is more limited than that of self-defense because society places a lesser value on property than on the integrity of human beings Deadly force is usually not permitted In most states, however, deadly force might be justified if it is used to prevent or stop a FELONY An owner of real property or a person who rightfully possesses it, such as a tenant, may use force against a trespasser Generally, a request to leave the property must be made before the application

of force, unless the request would be futile The amount of force used must be reasonable, and, unless it is necessary for self-defense, the infliction of bodily harm upon an intruder is improper Courts have traditionally been more liberal in allowing the use of force to protect one’s dwelling Subsequent cases, however, indicated that there must be a threat to the personal safety of the occupants

The states are divided on the question of whether a person who is legally entitled to property may use force to recover possession of

it In most jurisdictions, a landowner is not liable for assault and battery if the owner forcibly expels someone who is wrongfully on the property The owner must not, however, use excessive force, and the fact that the person may not be held civilly liable does not relieve the owner of criminal liability In some states, the use of force against a person wrongfully in possession of land is not permitted unless such person has tortiously dispossessed the actor or the actor’s predecessor in title

If possession of real orPERSONAL PROPERTYis

in dispute, the universal rule is that force cannot

be used The dispute must be settled by a court

With respect to personal property, the general view is that an owner may not commit

an assault or battery upon the wrongdoer in order to recover property A majority of jurisdictions recognize the right of an owner

in HOT PURSUIT of stolen property to use a reasonable amount of force to retrieve it In some states, stolen property may be taken back peaceably wherever it is found, even if it is necessary to enter another’s premises In all cases, the infliction of an unreasonable amount

of harm willVITIATEthe defense

Performance of Duty and Authority A per-son may useREASONABLE FORCEwhen it becomes

ASSAULT AND BATTERY 393

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necessary in the course of performing a duty.

A police officer, for example, may use force when apprehending a criminal In some jur-isdictions, private citizens may also use reason-able force to stop a crime being committed in their presence Certain businesses, such as restaurants or nightclubs, are authorized to hire employees who may use reasonable force to remove persons who disturb other patrons

Court officers, such as judges, may order the removal of disruptive persons who interfere with their duties

Persons with authority in certain relation-ships, such as parents or teachers, may use force

as a disciplinary measure, provided they do not exceed the scope of their authority Punishment may not be cruel or excessive

Punishment The law considers an assault and battery to be

an invasion of the personal security of the victim for which the wrongdoer is required to pay for damages The determination of the amount of damages to which a victim might be entitled if a defendant is found civilly liable is usually made by a jury Generally, aPLAINTIFFis entitled toCOMPENSATORY DAMAGESthat compen-sate for injuries that are both directly and indirectly related to the wrong Examples of compensatory damages include damages for pain and suffering, damages for medical expenses, and damages for lost earnings result-ing from the victim’s inability to work.NOMINAL DAMAGES, given although there is no harm at all,

or merely a slight one, may also be awarded in

an assault and battery action Some jurisdictions allow the award of PUNITIVE DAMAGES They are often given when the offense was committed wantonly or maliciously to punish the defen-dant for the wrongful act and to deter others from engaging in similar acts in the future The defendant might additionally be subject to criminal liability

If a defendant is found criminally liable, the punishment is imprisonment, a fine, or both

The amount of time a defendant must serve in prison depends upon the statute in the particu-lar jurisdiction When the offense is committed with an intent toMURDERor do serious harm, it

is called AGGRAVATED ASSAULT and battery An aggravated assault and battery is often commit-ted with a dangerous weapon, and it is punishable as a felony in all states

FURTHER READINGS Brewer, J D 1994 The Danger from Strangers: Confronting the Threat of Assault New York: Insight.

The Henry Law Firm (Philadelphia) Web site 2009 “Assault

& Battery ” Available online at http://www.henryfirm com/CM/FSDP/PracticeCenter/Criminal-Law/Assault asp?focus=topic&id=1; website home page: http://www henryfirm.com (accessed August 28, 2009).

Larson, Aaron 2003 “Assault and Battery.” ExpertLaw Library Available online at http://www.expertlaw.com/ library/personal_injury/assault_battery.html; website home page: http://www.expertlaw.com (accessed August

28, 2009).

CROSS REFERENCE Hot Pursuit; Nominal Damages; Personal Property; Puni-tive Damages; Real Property.

ASSEMBLY The congregation of a number of persons at the same location

Popularly-elected political assemblies are those mandated by the Constitution and laws, such as the general assembly The lower, or more populous, arm of the legislature in several states is also known as the House of Assembly or the Assembly

Under the FIRST AMENDMENT to the United States Constitution, “Congress shall make no law abridging the right of the people peaceably to assemble.” When a governmental unit sets aside property for the public use, the property is designed as a “public forum” for First Amendment purposes, and the govern-mental unit must properly allow the exercise by the public of constitutional rights, including freedom of assembly Examples of public forums include sidewalks, parks, and libraries The right to assemble includes the right to

PROTEST, although rights of assembly are gener-ally balanced with the need for public order The Supreme Court has held that local govern-ments may constitutionally require those par-ticipating in public parades first to obtain a permit to do so However, the Court has held that an organizer of a parade cannot constitu-tionally examine the content of a message of a parade applicant in determining whether to grant to parade permit Forsyth County, Ga v Nationalist Movement, 505 U.S 123, 112 S Ct

2395, 120 L Ed 2d 101 (1992)

CROSS REFERENCES First Amendment; Freedom of Speech; Public Lands.

394 ASSEMBLY

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An intentional approval of known facts that are

offered by another for acceptance; agreement;

consent

Express assent is manifest confirmation of a

position for approval Implied assent is that

which the law presumes to exist because the

conduct of the parties demonstrates their

intentions Mutual assent, sometimes called the

meeting of the minds of the parties, is the

reciprocal agreement of each party to accept all

the terms and conditions in a contract

ASSESS

To determine financial worth To ascertain the

amount of damages To fix and adjust the

individual shares to be contributed by several

persons toward a common beneficial objective in

proportion to the benefit each person will receive

To tax by having qualified experts estimate the

value of property by considering the nature of the

property, its size, the value of other comparable

property, and the proportionate share of services

that is used by that property To levy a charge on

the owner of property that has been improved at

the expense of the local government unit, such as

when sewers or sidewalks are installed

ASSESSED VALUATION

The financial worth assigned to property by taxing

authorities that is used as a basis or factor against

which the tax rate is applied

A prescribed amount of the value of each

unit must be paid as taxes in the future In most

cases, the assessed value is not representative of

theFAIR MARKET VALUEof the property

ASSESSMENT

The process by which the financial worth of

property is determined The amount at which an

item is valued A demand by the board of directors

of a corporation for the payment of any money that

is still owed on the purchase of capital stock The

determination of the amount of damages to be

awarded to a plaintiff who has been successful in a

lawsuit The ascertainment of the pro rata share of

taxes to be paid by members of a group of taxpayers

who have directly benefited from a particular

common goal or project according to the benefit

conferred upon the individual or his or her

property This is known as a special assessment

The listing and valuation of property for purposes

of fixing a tax upon it for which its owner will be liable The procedure by which the Internal Revenue Service, or other government department

of taxation, declares that a taxpayer owes additional tax because, for example, the individual has understated personal gross income or has taken deductions to which he or she is not entitled This process is also known as a deficiency assessment

ASSET Real or personal property, whether tangible or intangible, that has financial value and can be used for the payment of its owner’s debts

An accrued asset is one that arises from revenue earned but not yet due For example, an accrued dividend is a share of the net earnings

of a corporation that has been declared but has not yet been paid out to its shareholder(s)

In BANKRUPTCY, an asset is any form of property owned by a debtor who is insolvent that is not exempt from being used to repay debts

For INCOME TAX purposes, a capital asset is property held by a taxpayer for personal enjoyment or investment, such as a home, furniture, stocks and bonds, or an automobile, but does not include inventory, commercial accounts, and notes receivable, depreciable property, commercial property, copyrights, and short-term government obligations When

a capital asset is sold, any gain received is given preferential tax treatment

A current, liquid, or quick asset is an item that can be readily converted to cash, such as stocks and bonds

A fixed asset is one of a permanent or long-term nature used in the operation of a business and not intended for sale

A frozen asset is one that cannot be easily converted into cash, such as REAL ESTATE when there is no market, or that cannot be used because of a legal restriction, such as a

SPENDTHRIFT TRUST

An intangible asset is one to which an arbitrary dollar value is attached because it has

no intrinsic MARKET VALUEbut represents finan-cial value, such as the GOOD WILLof a business,

TRADEMARKS, orPATENTS

ASSIGN

To transfer to another, as to assign one’s right to receive rental income from property to another To

ASSIGN 395

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designate for a particular function, as to assign an attorney to defend an indigent in a criminal prosecution To specify or point out, as to assign errors in a lower court proceeding on a writ of error that is submitted to request a court to reverse the judgment of the lower court

ASSIGNED ACCOUNT

A type of secured transaction whereby an account receivable is pledged to a bank, factor, or other lender to secure the repayment of a loan

It is common commercial practice for a manufacturer or wholesaler to sell inventory on

OPEN ACCOUNT, a debt owed to the seller of inventory that is to be repaid by its buyer as the merchandise is sold This arrangement creates

an ACCOUNT RECEIVABLE that the seller uses as collateral for a loan

ASSIGNED RISK

A danger or hazard of loss or injury that an insurer will not normally accept for coverage under a policy issued by the insurer, but that the insurance company is required by state law to offer protection against by participating in a pool of insurers who are also compelled to provide coverage

ASSIGNED RISK PLAN

An insurance plan created and imposed by state statute under which persons who normally would

be denied insurance coverage as bad risks are permitted to purchase insurance from a pool

of insurers who must offer coverage to such individuals

ASSIGNMENT

A transfer of rights in real property or personal property to another that gives the recipient—the transferee—the rights that the owner or holder of the property—the transferor—had prior to the transfer

An assignment of wages is the transfer of the right to collect wages from the wage earner to his or her creditor Statutes regulate the extent

to which an assignment may be made

ASSIGNMENT FOR BENEFIT

OF CREDITORS The voluntary transfer of all or most of a debtor’s property to another person in trust so that he or

she will collect any money that is owed to the debtor, sell the debtor’s property, and apply the money received to the payment of the debts, returning any surplus to the debtor

The debtor is the assignor, the transferor; and the person who takes LEGAL TITLE to the property is the assignee

Types There are three types of assignments that are categorized according to the limitations im-posed upon the arrangement A general assign-ment is one involving the transfer of all the debtor’s property for the benefit of all his or her creditors A partial assignment is one in which only part of a debtor’s property is transferred to benefit all the creditors When property is assigned to benefit only designated creditors, it

is a special assignment

The assignment results in the property being beyond the control of the debtor It is different from agency arrangements, pledges, or mortgages Trust Law

Unless otherwise expressly provided, trust law governs assignments for the benefit of creditors The assignee is considered a trustee and his or her duties and responsibilities to the debtor’s creditors are the same as a trustee’s to the beneficiaries of a trust The document that embodies the terms of the assignment authorizes the assignee to liquidate the debtor’s property in satisfaction of the creditors’ claims against the debtor as quickly as possible UnderCOMMON LAW, this was the assign-ee’s chief function Even if the assignment instrument does not expressly empower an assignee to sell the property, the assignee still has the power to do so in order to pay the creditors Creation

It is not necessary for a debtor to obtain the consent of creditors before making an assign-ment for their benefit An owner of property has a right to transfer legal title to it by virtue of ownership The limitation derived from com-mon law that is placed upon its creation is that

it cannot be done to dishonestly deprive a debtor’s creditors of their rights to have property sold to repay debts When an assign-ment for the benefit of creditors is intended

by the debtor to place his or her property beyond the legal reach of creditors, it is called a

FRAUDULENT CONVEYANCE This type of assignment

is void, or legally ineffective, under statutes that

396 ASSIGNED ACCOUNT

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prohibit such arrangements An assignment by

which the assignor-debtor retains any interest,

benefit, or advantage from the conveyance, such as

keeping the right to revoke the assignment, made

toDEFRAUDcreditors is also a fraudulent

convey-ance, as is an assignment by which the assignee is

required to delay liquidation of the assets

In some jurisdictions, a partial assignment is

considered a fraudulent conveyance because the

creditors are hindered and delayed in receiving

payment if they must seek payment from the

debtor after first being referred to the assignee

Other jurisdictions treat any assignment by a

solvent debtor as fraudulent on the theory that

such an arrangement prevents the immediate

sale of the property so that creditors are delayed

and hindered

Deficiency

A debtor is still liable to pay his or her creditors if

the proceeds from the sale of personal and real

property pursuant to an assignment for the

benefit of creditors are not sufficient to

complete-ly repay the debts When, however, creditors agree

to accept the proceeds in satisfaction of the

debtor’s obligations, such an agreement is called a

COMPOSITION WITH CREDITORS For this reason, assignments for the benefit of creditors are used

by corporate, rather than individual, debtors

Because preferences are permissible under common law, a common-law assignment for the benefit of creditors that provides for preferential payments to designated creditors is not a fraudu-lent conveyance Most courts have held that debtors cannot use preferences to obtain dis-charges from creditors by conditioning prefer-ences on their release from unpaid portions of their debts To do so is considered a fraudulent conveyance, because a creditor would have to accept virtually any condition that the debtor decided upon if the creditor were to receive any money from the assignee

Legality of Assignments Most states have enacted statutes that regulate assignments for the benefit of creditors Some states require that an assignment must comply with statutory requirements or be invalid, whereas in others the debtor may make a common-law assignment, which is regulated by

Assignment for the Benefit of Creditors

This agreement is made between _ [name of assignor] ("Assignor"),

residing at [address], and

_[name of assignee(s)] ("Assignee(s)"),

residing at [address].

The Assignor is unable to pay in full and desires to assign all of [his/her] property to Assignee for the purpose of the payment of this debt.

Therefore, the Assignor hereby assigns, conveys, grants, and transfers to Assignee all of Assignor's property and interests in property,

whether real or personal, tangible or intangible (except property exempt by law from levy and sale under execution) wherever situated, in

trust for the benefit of the Assignee.

[Include description of the property and assets conveyed to the Assignee]

DATED on , 20 at:

_

Assignor

ACCEPTED BY:

_

Assignee

A sample assignment for the benefit of creditors ILLUSTRATION BY GGS CREATIVE RESOURCES REPRODUCED BY PERMISSION OF GALE,

A PART OF CENGAGE LEARNING.

ASSIGNMENT FOR BENEFIT OF CREDITORS 397

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