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The First Amendment Anti-Discrimination Law - Free Essay Example

Introduction A baker started his day with a prayer and a cup of coffee. He collects all the ingredients for his cake recipe when a gay couple walks in and asks for a wedding cake, completely unaware of what would come for him after this July afternoon. In Masterpiece Cakeshop Inc. v. Colorado Civil Rights Commission, the court sheds light on the tensions between the First Amendment and Anti-discrimination laws, attempting to draw the line between individual freedoms and discrimination. The outcome of this case would fuel the ongoing fight for LGBTQ rights in the United States, especially under the new administration. The Supreme Court not only decides whether the application of Colorado’s Anti-discrimination law violates Free Speech or Free Exercise Clauses, but also how to balance the conflict between religion and homosexuality in today’s society. Roadmap This paper explains the facts of the Masterpiece Cakeshop case and highlights the relevant law and decision of the Colorado Court of Appeals. The paper discusses the issues at hand and pinpoints what the Supreme Court has to decide. It will provide a detailed explanation of the rationale of the Colorado Court of Appeals and touch upon the petitioner’s argument. Through a close analysis of both sources, this paper will explore the differences of the opposing parties and reveal the strengths and weakness of their arguments. Finally, the paper will conclude by proposing that the Supreme Court should uphold the Colorado Court of Appeals judgement. Statement of facts of the case In Masterpiece Cakeshop Ltd. v. Colorado Civil Rights Commission, the petitioners were Colorado Civil Rights Commission on behalf of Charlie Craig, and David Mullins and the respondents were Masterpiece Cakeshop, Inc. and Jack C. Phillips. In Lakewood, Colorado, Craig and Mullins visited Masterpiece Cakeshop and asked Phillips to design and bake their wedding cake to celebrate their same-sex marriage. Philips politely declined and explained that he does not make wedding cakes for same-sex weddings because of his religious beliefs; however, he willingly offered to provide other baked goods as alternatives. Craig and Mullins filed discrimination charges on the basis of sexual orientation under the Colorado Anti-Discrimination Act. Craig and Mullins also filed a complaint with the Office of Administrative Courts claiming that Masterpiece had discriminated against them in a public accommodation because of their sexual orientation, also in violation of the Colorado Anti-Discrimination Ac t. The parties did not dispute any material facts and therefore filed cross-motions for summary judgement. The Colorado Court of Appeals affirmed the Commission’s decision in favor of the respondents. Masterpiece and Phillips appealed. Recitation of the relevant law There are two laws relevant in this case. The First Amendment prohibits laws â€Å"abridging the freedom of speech† and prevents congress from making laws that â€Å"prohibit the free exercise of religion.† The Colorado Anti-Discrimination Act (CADA) states that it is unlawful for a 2 person to refuse, withhold, or deny to an individual or a group â€Å"because of †¦ sexual orientation †¦ the full and equal enjoyment of goods services, facilities, privileges, advantages, or Masterpiece Cakeshop Ltd. v. Colorado Civil Rights Commission1 U.S. Constitution2 accommodations of a place of public accommodation.† In order to file a discrimination claim 3 under CADA, plaintiffs must prove intent and that the discriminatory action was based in whole or in part on their membership in the protected class. Statement of the issue and holding The issue is whether the application of the public accommodations law to design and bake a cake for a same-sex wedding, which conflicts with religious beliefs, violate the Free Speech or Free Exercise Clauses of the First Amendment. The Colorado Civil Rights Commission found Masterpiece Cakeshop Ltd. in violation of CADA. The Colorado Court of Appeals affirmed on the basis that the Colorado public accommodations law does not violate Phillips’ first amendment rights. The supreme court must decide if the application of the Colorado public accommodations law that compels Phillip to express beliefs that conflict with his religious views violates the Free Speech or Free Exercise Clauses protected under the First Amendment. Another issue is the scope of what constitutes â€Å"symbolically expressive† in warranting First Amendment protections. The court of appeals held that designing and creating a custom cake is a form of conduct and not expressive speech. The Supreme Court m ust also determine whether or not the art of baking constitutes speech or conduct. Explanation of the rationale of the court of appeals The Colorado Court of Appeals referred to previous United States Supreme Court decisions to support their rationale. Masterpiece asserted that its refusal to serve Craig and Mullin was solely because of their intended conduct to enter a same-sex marriage, and not â€Å"because of† their sexual orientation. The Supreme Court recognized that distinctions between discrimination based on status and discrimination closely related with status were generally inappropriate. When conduct is so closely correlated with a status, the conduct is predominantly performed by people with that status: Gays, lesbians, and bisexuals predominantly engage in same-sex marriage. Masterpiece admitted that it refused to serve Craig and Mullin because of its opposition to same-sex marriage, which the court established as closely correlated to sexual orientation. Conseq uently, the court can reasonably assume that Masterpiece’s decision involved an intent to discriminate because of sexual orientation. The court of appeals also referred to the Supreme Court decision in Elane Photography, LLC v. Willock 309 P.3d 533, 60-64. In 2006, Vanessa Willock attempted to hire Elane Photography to take pictures during her wedding ceremony; however, Elane Photography refused to provide service due to the owner’s Christian beliefs. In 2012, the New Mexico Supreme Court held that New Mexico’s anti-discrimination law extends to protect â€Å"conduct that is inextricably tied to sexual orientation.† They also referred to Elane Photography, LLC v. 5 Willock to address Masterpiece’s claim that it did not completely refuse service by offering alternative goods. Elane Photography offered other services; however, offering alternatives does not change the fact that it refused to provide services offered to the public. The court also raised the issue of whether the Commission’s cease and desist order violated the First Amendment by requiring Masterpiece to make cakes for same-sex weddings. In order to decide if conduct is â€Å"inherently expressive,† the court must determine if there were any intentions of conveying a message and whether â€Å"the likelihood was great that the message would be understood by those who viewed it.† The conduct in question was the Colorado government’s mandate that Masterpiece must comply with CADA. The court concluded that selling wedding cakes to all customers, regardless of sexual orientation, does not communicate a celebratory message about same-sex weddings to a reasonable observer. It reasoned that the public would have no way of knowing if Masterpiece decided to serve their customers because of its views on same-sex marriage. The court also deduced that the fact that a business charges for its services reduces the likelihood that someone would believe that Masterpiece supports the message reflected in its products. The court made another reference to Elane Photography, LLC v. Willock 309 P.3d 533, 60-64. In 2012, New Mexico Supreme Court held that â€Å"while photography may be expressive, the operation of a photography business is not.† New Mexico’s public accommodations law did not force the 7photographer to convey a message, but rather mandated tha t the business as a public accommodation cannot discriminate against potential clients. By precedence, the court similarly concluded that CADA did not compel expressive conduct. Masterpiece’s argument (that the Commission focused on the conduct rather than the product) prompts the threshold question whether the compelled conduct was â€Å"sufficiently expressive.† The court determined that the Commissions order was not â€Å"sufficiently expressive† to call for First Amendment protections. It recognized that a wedding cake may convey a certain message in some circumstances; however, Philips refused service before discussing the cake’s design and hence, evidence of Craig’s and Mullin’s wedding cake details were not relevant to the case. The court also held that under CADA, Masterpiece is not obligated to agree with the views of its customers and can out rightly say so. By doing so, â€Å"such a message would have the effect of disassociating Masterpiece from its customers’ conduct.† In dealing with Free Exercise of Religion, the court concluded that CADA is a neutral law of general applicability, and hence, does not violate the first amendment. To support its argument, the court referred to Smith, 494 U.S. at 877. In 1990, the court concluded that the Free exercise clause â€Å"does not relieve an individual of obligation to comply with a valid and neutral law of general applicability† on the basis that the law forbids action that the religion requires, and vice versa. If the law burdened a religious practice, the law must be justified with â€Å"compelling government interest.† The court held that CADA was generally applicable because 9 it did not exclusively exempt secular conduct. In response to Masterpiece’s claim that CADA was not generally applicable because of its exemptions for bona fide relationships, the court mentioned that such circumstances do not discriminate on the basis of religion, and on face value, apply to both religious and secular conducts. CADA only exempts public accommodations that are principally used for religious purposes. The court also concluded that CADA was neutral. Masterpiece argued that CADA was not neutral because it exempts entities used for religious purposes, but not Masterpiece. The court held that Masterpiece was not exempt because the bakery was not primarily used for religious purposes. The court also added that, logically, the existence of an exemption for religious entities undermined the claim that the law discriminated against Masterpiece’s religious standpoint. The court of appeal concluded by establishing that the hybrid rights claim did not apply because the court had already decided that the Commissions cease and desist order did not violate Masterpiece’s right to expression. The court also held that, although the Colorado Constitution requires that it reviews neutral laws of general applicability under strict scrutiny, Colorado appellate courts have consistently relied on federal precedent when reviewing free exercise claims. The court concluded that CADA is â€Å"rationally related† to Colorado’s interest in eliminating discrimination in public accommodations. It mentioned that discrimination based on sexual orientation, especially in places of public accommodation, have adverse economic effects. Explanation of the petitioner’s argument The Petitioner focused on four main arguments against the holdings of the Colorado Court of Appeals. First, the petitioner claimed that the court reasoning conflicted with the Supreme Court’s compelled speech precedent, in that the court of appeals held that the state can compel Phillips to create a wedding cake that promotes a message he did not agree with and rob him of ownership over any message portrayed in his art. In other words, Phillip’s custom wedding cakes constitute speech and therefore, the state cannot compel him to create speech. Secondly, the petitioner argued that the holding that Phillip’s art was conduct and not speech directly conflicts with rulings by the Ninth and Eleventh Circuits. The Ninth and Eleventh courts essentially determined that the art of tattooing was pure expression â€Å"entitled to full constitutional protection.† The petitioner argued that the Ninth and Eleventh Circuit would have concluded that Phillip’s custom wedding cakes were pure speech. By minimizing the â€Å"creative process† as merely actions, the court of appeals avoided strong precedent against compelled speech. Alongside arguing that the court’s decision (that artistic cakes are non-expressive) fuels conflict in what is considered expressive, the petitioner believed that the ruling that Phillips violated CADA conflicts with the Supreme Court’s free-exercise precedent and the decisions by the Third, Sixth, and Tenth Circuits. The petitioner argued that by rejecting religious beliefs as a valid reason for declining an order, the Commission â€Å"singled out† Phillips’ religion for â€Å"discriminatory treatment.† In similar cases, the Commission considered the baker’s objection as â€Å"message-based† except of Phillips . Analysis The biggest difference in interpretation lies in logical versus emotional approach of the opposing parties. The court of appeals argued that the commissions order, â€Å"even if compelled by the government,† did not warrant first amendment protections because it was not sufficiently expressive. However, the petitioner argued that the mere idea that the government can compel conduct, even if it is justified, violated the constitution. Hence, the compelled speech doctrine should cease to exist on the basis that historically and in this case, the government had overstepped and â€Å"magnified the intrusiveness† of its order. Like the state cannot force people to recite the Pledge of Allegiance, it cannot force Phillips to conceive and form art that delivers a message that he does not agree with. Yet, the court of appeals explicitly stated that the compelled conduct was just that Masterpiece act in accordance with CADA by not basing its decision to serve a client on sexual orientation. If Masterpiece wishes to sell wedding cakes to heterosexual couple, it must also sell wedding cakes to same-sex couples in the same manner. Though the appeal of the petitioner’s argument lied in the idea that Colorado expects him to develop a custom design that celebrates homosexual marital union and physically create a wedding cake, which is typically very labor-intensive, the argument falls short by not distinguishing Phillips as a cake artist from that of a hairdresser or caterer. To add, the petitioner did not take into consideration that Phillips declined to serve Craig and Mullins before even discussing what they wanted in their wedding cake. As reflected in the explanation of the rationale of the court, the court of appeals took a very logical and organized approach when ruling that Phillips’ custom wedding cakes was conduct. The court could not determine if Craig’s and Mullin’s desired wedding cake constituted symbolic speech because, again, Philips declined Craig’s and Mullin’s request before any discussion about the cakes design. The petitioner responded by referring to the Ninth Circuit holding in Anderson v. City of Hermosa Beach, where the Ninth Circuit ruled that a tattoo is a form of expression â€Å"entitled to full constitutional protection.† It held that speech should not lose First Amendment protections based on the kind of surface it is applied. The petitioner argues that Phillip’s cakes are no less art than tattoos, composed of words, abstract or realistic images, and symbols, â€Å"all of which are protected forms of expression.† Although the petition er claims that the court of appeals â€Å"evaded strong precedent† by declaring the art of baking wedding cakes as conduct, there is doubt whether the Ninth Circuit holding can even apply. The tattoo parlor did not violate any law, where Masterpiece cake shop ran into conflict with the public accommodations act. At this point, the petitioner seems to be picking at strings in efforts to work around the structured approach of the court of appeals, perhaps attempting to draw sympathy from the Supreme Court. It is also interesting to note the emotional, descriptive, emotional diction in the petitioner’s argument as contrasted to concise, stern diction of the court of appeals. Conclusion The Supreme Court should affirm the Court of Appeals decision that the Colorado public accommodations law does not violate Phillips’ first amendment rights. Although a grey area exists in where to draw the line between discrimination and freedom of speech or religion, the Court of Appeals proposed the stronger argument. At the end of the day, CADA is not telling Masterpiece to completely alter his views on same-sex marriage, but rather, to simply offer service to all people, regardless of sexual orientation, if it wishes to operate as a public entity. As mentioned earlier, this case plays a huge role in ongoing fight for LGBTQ rights.

Education, Poor Health Care Services, And Lack Of Modern...

Lack of education, poor health care services, and lack of modern technology, are all global issues that lead to today’s health care crisis in South Africa. There are many negative images of Africa and its people that are learned by reading and listening to documentaries and following the news. Everything negative from the genocide in Rwanda to child sex trafficking, extreme poverty, high mortality rates and government corruption. Taking aside the legacy of colonialism and racial and ethnic inequalities in some of these countries, a number of other factors explain the continuing disparities in learning between rural and urban schoolchildren in sub-Saharan Africa. In light of the implication of rural poverty throughout the continent, it should come as no surprise that rural schoolchildren are the most deprived from a socioeconomic viewpoint when it comes to the path to a good education. Rural schools usually have less qualified teachers and an insufficient number of teachers for the number of children enrolled in school. This is very noticeable in the diminished number of teachers-per-school and the overflow of students per teacher in most rural African regions. The rationale for these low numbers in rural Africa are numerous and greatly linked to poverty and other discriminatory and socioeconomic conditions. For example, teachers generally choose urban to rural schools because urban areas offer greater opportu nities and higher incomes. There is also a better quality of lifeShow MoreRelatedComparing City Life with Countryside Life Essays869 Words   |  4 Pagesof better education. In fact, people live in urban areas because they want to have good jobs to get more money, and one of the best ways to achieve that is education. Nowadays, there are a lot of good universities and college that are totally located in big cities. 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Making College More Affordable For Students - 1000 Words

Jennifer Barksdale Professor Bonner HUM 101 May 8, 2016 Making College More Affordable For Students The continuous rising cost of higher education is frequently spoken about today and deserves much more attention then it receives. College tuition for students is a rather large investment and considered to be one of the most expensive to make. As college tuition prices are continuously increasing so is the cost of housing. The average American family is finding it more and more difficult to be able to have a fair shot at affording to go to college. Although there are numerous possibilities, the cost of higher education for student is still too high and implementing a solid accreditation process and examining the student loan crisis happening could help improve a lot of problems. Young people continue to work hard to get good grades in high school in order for them to get accepted and enter a college. 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Economic and Quantitative Analysis

Question: Instructions Prepare a 2,000 word report that addresses the following questions: (a) Provide a descriptive analysis of the two variables (e.g., mean, standard deviation, minimum and maximum). (b) Develop a scatter diagram with retention rate as the independent variable. What does the scatter diagram indicate about the relationship between the two variables? (c) Develop and estimate a regression equation that can be used to predict the graduation rate (%) given the retention rate (%). (d) State the estimated regression equation and interpret the meaning of the slope coefficient. (e) Is there a statistically significant association between graduation rate (%) and retention rate (%). What is your conclusion? (f) Did the regression equation provide a good fit? Explain. (g) Suppose you were the president of South University. After reviewing the results, would you have any concerns about the performance of your university compared to other online universities? (h) Suppose you were the president of the University of Phoenix. After reviewing the results, would you have any concerns about the performance of your university compared to other online universities? Answer: Introduction: This report aims at highlighting the two key variables in the industry of education, namely graduation rate as well as retention rate. This report includes a detailed analysis that is helpful in establishing a stable relationship amidst the two mentioned variables(FOLSOM et al., 2005). This report emphasizes upon representing the level of relationship amidst graduation as well as retention rate for around twenty nine institutes that are based in the United States of America. Also, this report provides a vivid recommendations depending upon the findings of the research analysis conducted in this report. Background Overview: On analyzing the prevailing economic conditions of the world, it may be identified that the extent of the global competition has been on a tremendous rise across all nations. In almost every industry, business firms have been facing increased rivalry as well as emphasizing upon adopting innovative strategies and techniques for achieving competitive advantage and staying ahead of all competitions. Microeconomic studies have been demonstrating that several factors are there that impact considerably upon the customers, and are said to control the overall market demands. Technological enhancement and development have impacted upon the extent of global competition within the market since it is impacting on the consumer tastes as well as preferences. The current prevailing educational trend reflects that the growing demands for online academic studies and that of educational programs have been extensive because of its convenience and feasibility. The increased evolution of the concept of o nline education has been threatening the age-old system of education(The Low College Graduation Rate of Black Students Is Not Due to Racial Factors, 2005). It is reported that the sector higher education has been facing certain key challenges since online educational programs have been gaining increased popularity. The main target of the Online Education Database is to create a preferred list of the mentioned accredited online institutes. The knowledge about the graduation as well as retention rate for all 29 colleges in the United States has been mentioned in this report. The collected information are analyzed economically and this provided a notion to the current situation of the online educational industry followed by recommendations. Methodology: Some of the effective methods are taken up to analyze the connection between the two mentioned variables. A detailed analysis of these variables may be carried on with the support of statistical functions as well as techniques (Almeida, 2007). The excel program along with its various functions have been used to provide scatter images of the variables. In the report, independent variable is the retention rate. The relationship amidst the two variables, graduation rate and that of retention rate may be clearly demonstrated with the help of regression equation that can be utilized to predict the rate of graduation while the retention rate is constant. The link between the mentioned variables may be depicted in support of some statistical tools. In addition, the report also identifies if the regression is appropriate or not. Results: This part of the report depicts the outcomes achieved from the analysis of the variables with consideration of the relevant statistical tools. It highlights the retention rate as well as the graduation rate of all twenty nine online colleges of the US. To explain the two variables it can be referred that graduation rate is the percentage of overall undergraduate students enrolling in the institute and also graduated from the very institute (De Vos, 2007). The rate of retention refers to the percentage of the students who are likely to continue with the program in the next year as well. The link between these two variables may be indicated. The outcomes derived with the help of various statistical tools are depicted and interpreted within this part. Descriptive Analysis: The descriptive analysis of both graduation rate as well as retention rate involves the estimation of standard deviation, mean, minimum, and maximum. The following table representation shows the required calculation of the statistical measures. As depicted from the above table, it is identified that mean retention rate of all twenty nine online colleges of the nation is approximately 57.41379. On the other side, average of graduation rate is lesser that that of the retention rate which is 41.75862. Here, standard deviation is needed to be identified (Dorn, n.d.). The standard deviation of the retention is calculated around 23.24023 and the same for the graduation rate of all 29 institutes is quite less that is 9.865724. For identifying the range, it is important to identify the minimum as well as maximum values of the two variables. It has been identified that the minimum as well as maximum retention rate is supposedly 4 and 100 respectively. For graduation rate, minimum as well as maximum is estimated approx 25 and 61 respectively. Scatter Diagram: This diagram is represented in this part of the report to demonstrate the extent of dependence as well as nature of correlation amidst the two mentioned variables graduation rate as well as retention rate. In this report, rate of retention is taken on X axis and that of the graduation rate on vertical Y axis. All plotted values reflect the data given for all of the colleges of the United States. From this, the direction of the plot shows that increased values of the rate of retention are associated with greater value of the rate of graduation(Dropouts in America: confronting the graduation rate crisis, 2005). Thus, it may be stated that these variables have a favorable correlation. The pattern of the scatter diagram depicts that a linear link exists between the mentioned variables. If the potential strength of the scatter figure is analyzed it may be inferred that a moderate correlation exists amidst the both graduation rate as well as retention rate. Regression Analysis: The regression equation of both graduation rate and that of the retention rate of all 29 colleges of the country is depicted within this part. This would aid in analyzing the link amidst retention as well as graduation rate. The table below shows the outcomes of the regression analysis: The rate of retention is independent and that of the graduation rate is a dependent variable. So, the equation of regression is shown below: Y = Intercept (Coefficient) + X (Variable Coefficient) Y = 25.4229 + X * 0.2845 Y = 25.4229 + 0.2845X Coefficient of Slope: As reflected in the equation of regression, the coefficient of slope may be suitably estimated. It is identified that the result for this slope coefficient is around 0.2845. This variable shows the slope of the best fitted line upon the scatter diagram. Link amidst both the variables: The table representing regression analysis distinctly reflects the existence of a significant link amidst the two variables, retention rate and graduation rate of the selected colleges of the nation. The value for R square is estimated approx 0.44922. This refers that the two mentioned variables are correlated positively(FOLSOM et al., 2005). The magnitude of this value R is greater and this shows that the extent of dependence amidst the two variables, graduation rate as well as retention rate of online colleges is considerably high. Goodness of Fit: This concept of goodness of fit supports explanation of the level of correctness of the statistical model that fits properly to observational sets. Generally, it supports to summarize the inconsistency amidst the observed as well as expected value of the model. The R square value enables determination of the goodness of fit here. This value R square is estimated approx 0.44922. Thus, it is reflected that equation of regression is not most effective for the link between graduation rate as well as retention rate of all the online institutes(Heckman and LaFontaine, 2010). It is witnessed from the analysis that equation of regression is fit to certain extent if not completely. The diagram below shows the trend line. Discussion: From the statistical analysis, the findings regarding both retention rate and that of the graduation rate is reflected and also highlights upon the significant link between the two. Firstly, as per the given descriptive analysis, standard deviation, mean, minimum and maximum values are calculated. Mean aids in identifying the central tendency of the prescribed distribution values. It is identified that the average of retention rate is greater than that of the graduation rate. Additionally, it is essential to measure dispersion of the particular value set from the mean that supports assessment of the consistency of distribution(Izumi, Shen and Xia, 2013). For retention rate, the standard deviation is considerably greater than the standard deviation of rate of graduation. It distinctly shows that variation or even inconsistency is greater in case of retention rate as compared to that of the rate of graduation of all online institutes in US. Maximum as well as minimum values show the ra nge which is quite broader in case of retention rate as compared to that of the graduation rate. This also reflects increased inconsistency of retention rate values. As referred to the scatter diagram, the firm, direction and that of the strength has been analyzed that helps to understand the form of link amidst the given two variables. It is identified that a positive, linear, and moderate correlation exists amidst graduation as well as retention rate. As per the regression analysis, the value of the R square is approx 0.44922 and this equation is fit in a moderate way. Besides, it has also been identified that the slope of the line is considerably low. After analysis of the correlation it is identified that a positive favorable correlation exists amidst the two variables (Miller, 2014). Therefore, it may be inferred that on increasing the retention rate, the rate of graduation would also get enhanced. But the interdependence amidst the given two variables is quite low. Thus, certain other factors besides retention rate are hence responsible to influence the rate of graduation. With context to South University, it is identified that the rate of retention is around 51% and so as the graduation rate to be 25%. This reflects that the rate of retention is higher but rate of graduation is quite low. As per the outcomes of all 29 colleges of the United States, it has been found that trend is alike. Thus, no such concern is related to the performance of the South University. With respect to Phoenix, rate of retention is 4% whereas the rate of graduation is 28%. This does not favor the findings of all 29 colleges. A positive favorable link has been identified amidst both the variables. Thus, after reviewing of the results it is concluded that a significant concern exists about performance of the university. Recommendations: This part of the report provides the recommendations. It is identified that on increasing the rate of retention, the rate of graduation also gets enhanced. These online colleges must take certain measures to increase the rate of retention. Distinctly, with increase in retention rate the rate of graduation would also enhance(When Transfer Students Are Included in the Count, the College Graduation Rate Gap between Blacks and Whites Gets Worse, 2003). The regression analysis identifies a moderate fit amidst both the variables. It has also been identified that certain factors exist that impact upon the variables. Thus, further study and analysis may be conducted for identifying those factors apart from the retention rate that influence the rate of graduation. References Almeida, R. (2007). Local Economic Structure and Growth.Spatial Economic Analysis, 2(1), pp.65-90. De Vos, M. (2007). Everybody Happy in Graduate School: Empowering Graduate Students, Supporting Their Advisers, and Increasing the Graduation Rate for PhDs in the Humanities at Utrecht University.ADE, pp.24-31. Dorn, S. (n.d.). Quasicohort and Period Measures are Weak Proxies for the New Federal Graduation Rate: Florida Data, 2003-2009 Graduation Years.SSRN Journal. Dropouts in America: confronting the graduation rate crisis. (2005).Choice Reviews Online, 43(01), pp.43-0450-43-0450. FOLSOM, B., PETERSON, G., REARDON, R. and MANN, B. (2005). IMPACT OF A CAREER PLANNING COURSE ON ACADEMIC PERFORMANCE AND GRADUATION RATE.Journal of College Student Retention: Research, Theory and Practice, 6(4), pp.461-473. Heckman, J. and LaFontaine, P. (2010). The American High School Graduation Rate: Trends and Levels.Review of Economics and Statistics, 92(2), pp.244-262. Izumi, M., Shen, J. and Xia, J. (2013). Determinants of Graduation Rate of Public Alternative Schools.Education and Urban Society. Miller, N. (2014). Nontraditional Student Graduation Rate Benchmarks.The Journal of Continuing Higher Education, 62(3), pp.141-151. Surprise: When Transfer Students Are Included in the Count, the College Graduation Rate Gap between Blacks and Whites Gets Worse. (2003).The Journal of Blacks in Higher Education, (39), p.50. The Low College Graduation Rate of Black Students Is Not Due to Racial Factors. (2005).The Journal of Blacks in Higher Education, (48), p.9.