Michigan Church Has the Right to Help Poor People, ACLU Tells Court (ACLU Release)
FOR IMMEDIATE RELEASE
ACLU – http://aclumich.org/issues/religious-liberty/2009-09/1395
September 24, 2009
DETROIT — In a friend-of-the-court brief filed on behalf of the First Baptist Church of Ferndale, the American Civil Liberties Union of Michigan has urged the Oakland County Circuit Court not to interfere with the church’s mission of serving the poor. A group of Ferndale residents, citing a zoning ordinance, recently asked the court to deny the church the ability to use its own building to provide charitable social services to poor people. The ACLU argued in its brief that denying the church permission to help poor people would violate the Religious Land Use Act of 2000.
“Congress enacted the Religious Land Use Act to protect the fundamental right of freedom of religion,” said Dan Korobkin, an ACLU of Michigan staff attorney who is representing the church. “Churches and other religious institutions have the right to use their property to exercise their religious beliefs — which in this case entails providing charitable services to the poor and underprivileged.”
“We take seriously the biblical command that Christians feed the hungry and clothe the poor,” explained Rev. Catherine Feldpausch, pastor of First Baptist Church of Ferndale. “Using our church to help underprivileged citizens is an essential part of our religious mission.”
Last year, the First Baptist Church made arrangements for a charity for homeless persons known as the South Oakland Shelter to occupy an empty wing of the church where it would provide daytime social services including job counseling and access to telephones, the Internet, and personal hygiene facilities. A small group of Ferndale residents who lived near the church asked the City of Ferndale to block the move, and in March the ACLU wrote a letter to the Ferndale Board of Zoning Appeals urging the city not to interfere with the church’s religious exercise. The zoning board agreed with the ACLU and approved the South Oakland Shelter plan, but the residents have appealed the Board’s decision to the Oakland County Circuit Court. Judge Denise Langford Morris is scheduled to hear oral arguments on the appeal on October 21.
In its brief, the ACLU argues that the Ferndale zoning board was correct to side with the church because federal law prohibits land use regulations that substantially burden the ability of a religious institution to advance its religious mission. Zoning boards may not make decisions that burden the free exercise of religion simply because neighbors object.
“After considering the neighbors’ objections and learning about the First Baptist Church’s religious mission, the City of Ferndale made the right call,” said Korobkin. “We’re hopeful that the court, too, will recognize that religious freedom is paramount.”
Marshall J. Widick of the Detroit law firm Sachs Waldman authored the ACLU’s brief on behalf of the church. In addition to Widick and Korobkin, the First Baptist Church of Ferndale is represented by ACLU of Michigan Legal Director Michael J. Steinberg.
To read the brief, click here.
To read the ACLU’s letter to the zoning board, click here.
First religious liberty festival in Jerusalem draws hundreds (ANN)
Source: Adventist News Network
Hundreds of religious liberty proponents from Israel and the Palestinian Territories gathered in Jerusalem Sunday for the symbolic city’s first festival of religious freedom.
The event generated a “climate of good understanding” among attendees that organizers hope will spur increased tolerance in the region, said John Graz, secretary-general for the International Religious Liberty Association (IRLA), which sponsors festivals worldwide to encourage freedoms of religion.
Hosting the event in a city holy to three major world faiths — Judaism, Islam and Christianity — was particularly significant, said Graz, who also directs the Seventh-day Adventist Church’s department of Public Affairs and Religious Liberty (PARL).
While Christians enjoy broad freedoms and are allowed to conduct outreach on a limited basis in largely Orthodox Jewish Israel, treatment of Muslims is a subject of international controversy, according to the Religious Freedom World Report, a PARL publication.
Conservative Jews, who embrace a non-fundamentalist interpretation of the Jewish faith, also face hurdles to religious freedom, said Rabbi Yaacov Lebeau, who spoke at the event. Because of the dominance of Orthodox Judaism, weddings and other ceremonies conducted in Conservative synagogues are not fully recognized, he said.
“It could be very easy to be influenced by extremist groups and fall into exclusivism,” regional Adventist President Richard Elofer said. Given the “multi-cultural and multi-region” makeup of Israel, defending inclusive freedoms is a priority to ensure that doesn’t happen, he added.
Some 300 religious liberty advocates from Jewish and Christian communities attended the event.
AUDIO: Karen Scott – “Rethinking the Premise of Religious Liberty”
Each year, the Walla Walla University Church in College Place, Washington celebrates religious liberty. On February 28, 2009, Karen Scott delivered an address entitled, “Rethinking the Premise of Religious Liberty.” Scott, an attorney who is a member of both the Provincial Bar of British Columbia and the State Bar of California, is also a member of the ReligiousLiberty.TV Advisory Panel. Scott successfully argued a religious liberty case before the Supreme Court of Canada. The Court decided in her client’s favour, changing the law in Canada for accommodation in the workplace.
In this presentation, Scott examines the ties between religious liberty and the Gospel. Everyone has a conscience and God has given to each the inalienable right to choose for Him or against Him. And yet God offers salvation to everyone, even His enemies (Romans 5:10). We are called to be perfect, even as our Father in heaven is perfect (Matthew 5:48). In other words, those who profess to follow Jesus, ought to love just as He did, which means that we too will grant others the right to choose for or against God and we too will love them as He does.
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VIDEO – BREAKING NEWS: Obama’s Attorney General, Eric Holder, on the Rule of Law
Eric Holder
Today, former Deputy Attorney General under Bill Clinton, Eric Holder accepted President-elect Barack Obama’s invitation to become the next Attorney General.
Holder, who is on the board of the American Constitution Society (ACS) has a fundamental understanding of the role of the law in society, and recognizes the concept that nobody is above or below the law.
Earlier this year, he gave a lecture for the ACS convention regarding the importance of restoring the rule of law. He called upon the United States to reverse “the disastrous course” set by the current administration in the struggle against terrorism, arguing “the next president must move immediately to reclaim America’s standing in the world as a nation that cherishes and protects individual freedom and basic human rights.”
Click here to watch a video of his lecture.
BREAKING NEWS – Russia Moves to Liquidate Fifty-Six Religious Groups
On October 15 the Russian Ministry of Justice took steps to begin liquidating 56 non-Russian Orthodox religious organizations. The groups face dissolution, Russian news sources reported, because they failed to file required annual reports on their activities. Those targeted include a range of non-Russian Orthodox organizations and churches but hardest hit were various Christian groups, both Protestant and Catholic. Baptist groups were prominent on the list, but Methodist, Presbyterian, Lutheran, Seventh-day Adventist and Pentecostal groups were also included. Well known humanitarian groups such as World Vision and Youth with a Mission were also named, as was the Russian branch of the Billy Graham Evangelistic Association. Non-Christian organizations were also named, including Muslim and Buddhist associations.
According to the Slavic Legal Center in Moscow, many of the organizations believe they are in full compliance with filing requirements and are surprised to be included in the list. They are unsure if the posting is a scare tactic or if the Ministry of Justice indeed intends to pursue liquidations on a massive scale. Anatoly Pchelintsev, an attorney for the Slavic Center for Law and Justice, remarked that “such actions fly in the face of official Russian state policy on the freedom of worship and creed.” Pchelintsev believes the responsible officials are unaware of the complicated international ramifications of their actions and cites the possibility of “chaos and destabilization in church-state relations.” He added that in the case of most of the affected organizations, the threatened punishment goes too far. “In Russia there already are more than a dozen cases in which courts rendered decisions in favor of religious organizations since the punishment for their failure to submit information did not formally fit the crime committed.” Moreover, he added, “liquidation for failure to submit information is equivalent to sentencing a jaywalker to the death penalty. After all, liquidation means that the organization’s life is put to an end.” In addition, said Pchelintsev, “such actions are inconsistent with the policy of the Russian government, which guarantees freedom of conscience and religious confessions for each person. The widespread liquidation of religious associations for petty violations will lead to the crudest infringement of human rights in our country and to the self-isolation of the government.”
Pastor Vitaly Vlasenko, Director for External Church Relations of the Russian Union of Christians-Baptists, had a less dramatic reaction. He warned against undue alarm, suggesting that the action by the Ministry of Justice is a mere “wake-up call.” He reported that thousands of religious organizations were registered during the 1990s, and that because a number of them are now defunct, the Ministry is probably only attempting to clear out organizations that no longer function. In some cases, he noted, registered and actual activities no longer match. For example, he said, in one instance, “a Baptist organization registered in Moscow is active only in Siberia.”
However, according to Joseph K. Grieboski, president of Washington DC’s Institute for Religion and Democracy, “the move to liquidate several organizations can be seen only as a move to limit and control their activity further. Despite recent European Court of Human Rights cases against such activities and registration standards, the Russian Government continues its ongoing tightening of religious activity and continues to threaten free exercise of faith in Russia.”
It is too early to know precisely why the Ministry is threatening dissolution of so many religious groups. Russians are accustomed to a degree of arbitrariness and intimidation as pertains to non-Orthodox religions, but are such threats really necessary? Could not the organizations have been contacted separately and asked to supply needed information for compliance rather than discovering from outside sources that they suffer possible dissolution? According to Pchelintsev, a majority of the organizations named in the list are seriously frightened, if not already in panic mode.
The Ministry of Justice’s action only bolsters the claim by many within Russia that the government is not serious about religious freedom but consistently works in tandem with the Russian Orthodox Church to pester, persecute and eliminate if possible other religions. By most estimates, more than eighty percent of Russians today identify themselves as Orthodox. There is a saying in Russia: “To be Russian is to be Orthodox.” Nevertheless, the restructuring of Russia that began in the late 1980’s was supposed to be about creating a democracy where freedom was ensured for all citizens, and all religions were to have equal standing before the law.
But the Russian Orthodox Church was always a vocal critic of this new policy of religious freedom, and prevailed upon the Duma to pass a highly restrictive new law in 1997 that slowed Russia’s experiment with unlimited religious freedom. This law, which comprehensively regulates church-state relations in Russia, specially acknowledges the unique contributions to Russia’s culture and statehood of several of the nation’s oldest religions––Russian Orthodoxy in particular–but it also discriminates against the Federation’s less traditional religions by requiring special registration procedures and by limiting the scope of the activities in which they can lawfully engage.
Many religious organizations have already been liquidated under this law; frequently it has been used as a tool for officials throughout Russia to remove unwanted religious groups. In the spirit of this sanctioned discrimination, it remains difficult for many religious organizations to buy or even rent property to be used for worship purposes, meet for worship services, conduct schools, disseminate religious literature, or proselytize. “The Russian Orthodox Church is already halfway towards becoming a state church,” the business daily Kommersant wrote recently. Another kind of disquiet was expressed by Anatoly Krasikov, an expert in socio-religious studies at the Russian Academy of Sciences, who warned, “if Orthodoxy becomes a new ideology, we’ll be right back to a totalitarian state.”
”if Orthodoxy becomes a new ideology, we’ll be right back to a totalitarian state.”
The Ministry of Justice’s action against 56 religious organizations might be a genuine but harmless attempt to bring the organizations into compliance with law. But many inside Russia doubt whether there is not something more troublesome at play here. It might well be Russia’s latest attempt to elevate Russian Orthodoxy to a position made prominent by reducing and eliminating the competition. Russia must confront the task of how best to treat religion and religious institutions within an emerging democratic order. Given Russia’s history, the Russian Orthodox Church might expect to have a dominant cultural role long into the future, but it is the Russian people, in democratic course, who must ultimately deny the church a preferred legal position. Their decision is key to the advance, or decline, of freedom in the new Russia.
Derek H. Davis, J.D., Ph.D. is Dean of the College of Humanities and Dean of the Graduate School as well as director of the Center for Religious Liberty at the University of Mary Hardin-Baker in Belton, Texas.
The mission of The University of Mary Hardin-Baylor Center for Religious Liberty is to advance religious liberty for all persons, in all parts of the world, without regard to their religious, ethnic, gender, racial or national background. Religious liberty is a basic human right that must be nourished and protected by all human societies; it is the cornerstone of modern societies’ efforts to build a more peaceful world. The Center advances this mission by publishing relevant literature, hosting and sponsoring lectureships and conferences, sharing its expertise with media and other public information outlets, and partnering with other persons and groups who share the goal of advancing religious liberty. The web site for the Center can be found at www.umhb.edu/academics/crl
Photography by Ryan J. Bell.
The Hijacking of Religion
By Jonathan Gallagher, Ph.D.
Visit http://www.jonathangallagher.com to read Dr. Gallagher’s other writings.
How religious beliefs are exploited for political and secular ends, and the consequences for religious liberty
When inter-religious violence erupted in Indonesia just a few years ago, the primary response was astonishment. Had not Christians and Muslims, Hindus and Buddhists—in fact believers of just about every faith under the sun—lived together in relative tranquility, with mutual toleration marred only rarely by religious difference?
So where did the sudden animosity come from?
Tracing the waves of massacre and death back, it seems that the trouble began with a minor dispute between two villagers. It just so happened that one was Christian, the other Muslim. But that was not the cause of the disagreement. However, as the situation became inflamed, the opposing families began to exploit the religious difference, until the whole pot boiled over into violence against the other side, ultimately defined purely on the basis of religious persuasion.
The end result? Thousands dead, hundreds of thousands displaced, refugees in their own country. Holy wars, forced conversions, rape and mutilation—all apparently because of “inter-religious conflict.”
Yet this vivid example clearly reveals that the motive forces behind the violence are not primarily based on religious concepts, but on the use of religion to label and define the enemy.
The end of an authoritarian regime, competition for land and resources, employment issues, inter-tribal disputes, economic disparities—all these have a far more significant causes for the communal violence in Indonesia. Religion is just a convenient “identifier” that sanctions war and murder because of the perceived threat to one’s own community.
In the words of Maksum Maksum, chief editor of the Indonesian daily newspaper Jawa Post, “Different communities have difficulty in detaching themselves from religious matters. There can be jealousy and suspicion between religious groups, and a very complex societal problem can develop that is very difficult to resolve.”1
Why does it happen? Why the inter-religious violence? According to Aidir Amir Daud, vice-director of the Indonesian daily newspaper Fajar, “The Indonesian constitution guarantees religious freedom but this is not always applied in practice. Religion is the right of the individual, but other factors such as affluence can cause problems. The key is communication between religious leaders and a working together for socio-economic equality.”2
In other words, the root causes are economic, social and political. Religion is simply the tool that is used to gain control.
For a country to move from general tolerance to extreme intolerance in just a few short years speaks of the power of religion, and its ready exploitation by those seeking political authority and control. The fuel is human competition. For where there is enough food, land, water and other resources, the need to fight other communities is much reduced. But as the world becomes increasingly overpopulated, then such scenarios can only increase. Religion is so close to the heart of how any society defines itself that those seeking political power and worldly goals will readily use such a potent weapon. The exploitation of religious belief is not new—witness the jihads and crusades from history—but its greatly increased impact and extent will be the dominant factors for the foreseeable future.
The extreme militant Taliban militia that controls most of Afghanistan also exemplifies the use of religious dictates as powerful, political tools. Claiming that their interpretation of the Islam mandated their actions, the Taliban have essentially barred women from participation in education and many aspects of society; have decreed death to anyone leaving the Islamic faith or encouraging another to do so; have banned access to the Internet; have destroyed the religious heritage of other faith (e.g. the Buddhist statues); and have required religious minorities to wear a distinguishing label, reminiscent of Hitler’s yellow star requirement for Jews.
Through the total integration of religion and politics in Afghanistan, there is no opportunity for political dissent, for that equates to religious apostasy. Religion is completely hijacked in the service of the state, an unquestionable tool of oppression and discrimination to which there can be no opposition.
So too in Sudan, which was named in the 2000 report of the US Commission on International Religious Freedom as the world’s worst violator of religious liberty. The 2001 report indicates that the situation has not improved, but deteriorated:
“The situation in Sudan has grown worse in the year since the release of the Commission’s report. The government of Sudan continues to commit egregious human rights abuses – including widespread bombing of civilian and humanitarian targets, abduction and enslavement by government-sponsored militias, manipulation of humanitarian assistance as a weapon of war, and severe restrictions on religious freedom.”3
The Islamic government of the north is waging a genocidal war against the south, whose population is mainly Christian and animist. Through a policy of massacre and destruction of villages, the government uses “Islamicization” as a tool to forcibly convert and enslave those captured in the south. Girls are forced into slavery and worse, boys forced to join the army and sent to fight in the south.
The methodology is one designed to eradicate all opposition and to enforce conformity. The tool of choice is religion; religion exploited as a vicious mechanism of destruction and death for all who will not comply.
Many moderates protest that such use of religion is against the fundamental principles of the faith in question. It is undeniably true that all the major religions speak to greater or lesser degrees about tolerance and compassion. Yet when religion becomes aligned with the political extremists, such moderate views are lost in the rhetoric and violence. No one wants to be seen as being in opposition to what is deemed a matter of faith, of being opposed to those who have not only demanded what is Caesar’s, but what is God’s too.
India provides a troubling picture of religious trends. The development of “Hindu fundamentalism” correlates with the establishment of the BJP, the “Hindu nationalist” party that now forms the government of India. India has traditionally been a tolerant and pluralistic society as far as religion is concerned. It has welcomed religions from beyond its borders, and Hinduism itself has always promoted toleration and acceptance. That is not to say that there have been no conflicts in the past, but generally India has been free from major religious conflict.
Today that tolerant scenario is fading rapidly. The exclusivistic attitude of the “Hindu national” politicians has encouraged an atmosphere of suspicion and fear, with inter-religious conflict the obvious result. Instead of a being an inclusive expression of religion, Hinduism is now being marketed as the “national faith.” Calls are made from the government to resist the work of Christian missionaries.
Any attempts by other religious groups to share their faith and gain converts is strongly resisted, and legislation is already in place in some areas which requires government permission to convert from one faith to another. Antagonism to Christian missionary work is becoming increasingly intense, and viewed as a threat to national security and identity. Pressure to re-convert to Hinduism is strong.
A note left at the site of three bombings in the northern state of Bihar said, “Stop conversions under the pretext of social service. India is a Hindu nation. Christians leave India.”
Why? Again, this is no accidental process. The role of religion in society is exploited and corrupted to self-serving ends by those who wish to gain power. By equating faith and nationalism, politicians gain support—for who would dare contradict what is presented as an “article of faith”? Religion is once again hijacked, and the threat to religious minorities is ominous. For in situations of crisis, the majority seeks scapegoats. In a country of more than one billion people, with great competition for food and water, with most resources rapidly being depleted, it does not take much imagination to foresee inter-religious conflict of cataclysmic proportions.
When society reaches breaking point, religious toleration is a scarce commodity.
“Militancy” in religion takes many forms, yet is a very “portable” concept. To have suggested, even just a few years ago, that a militant form of Buddhism could be developed, would have seemed absurd. Such an idea is no longer laughable. Even Buddhism, which is so linked with concepts of peace, tranquility and acceptance, has been hijacked to support nationalistic and political concerns.
For example in the Himalayan kingdom of Bhutan, Buddhism is the state religion. Conversion to other religions is illegal. Attacks on minority religious groups are increasing. Christians have been arrested and beaten. Some have been forced to leave the country.
Again, why? Because the religion of the majority—in this case, Buddhism—is viewed as essential to social stability and order. Nothing is to disturb society, and so a hostile and antagonistic attitude is developed towards other religious faiths. The result: severe restrictions on religious freedoms, and the potential for violent conflict.
On the international scene, such exploitation of religion for political and secular objectives does not augur well for the fundamental human rights. The pressures of overpopulation, resource depletion, famine, disease, pollution, crime and so on all impact society in negative ways that contribute to the desire to hijack religion for personal and national purposes.
Consequently the currently accepted norms of religious liberty and freedom of conscience will come under increasing attack. While nations nominally subscribe to such international instruments as the UN Charter, the Universal Declaration on Human Rights, and the Declaration on the Elimination of All Forms of Intolerance and Discrimination Based on Religion or Belief, such documents no longer seem to be well respected. One high-ranking diplomat in a recent conversation at the UN referred dismissively to the Universal Declaration on Human Rights as “western philosophy,” and that her country did not believe it should be bound by such agreements.
Without becoming alarmist, such a situation should be cause for grave concern. When religion is hijacked, so is our fundamental humanity. Religion lies close to the heart of who we claim to be. So in exploiting religion, we exploit ourselves. As a result, multiplied millions are deceived by duplicitous leaders who claim to be speaking in the name of faith. What hope is there for separation of church and state when religion is employed in the service of politicians?
In his latest annual report, Professor Abdelfattah Amor, United Nations Special Rapporteur on Religious Intolerance writes:
“The worldwide trend as regards religion and belief is towards increased intolerance and discrimination against minorities and a failure to take account of their specific requirements and needs…. Sadly, intolerance and discrimination based on religion or belief are ever-present in the world…. An appraisal of the status of freedom of religion and belief in the world today reveals a somewhat negative and disturbing picture.”4
There is no question that the intermixing of religion and politics will become and even greater part of this “negative and disturbing picture.” Amor goes on to describe what he calls “the ever-worsening scourge of extremism. This phenomenon, which is complex, having religious, political and ethical roots, and has diverse objectives (purely political and/or religious), respects no religion. It has hijacked Islam (as in Afghanistan, Egypt, India, Indonesia, Jordan, Lebanon, Pakistan, the Philippines and Turkey), Judaism (in Israel), Christianity (in Georgia) and Hinduism (in India)… The casualties of this aberration are… religions themselves.”5
The casualties are religions themselves. And, it should be added, the freedom to believe, practice and worship that go along with religious tolerance and freedom of conscience.
The irony of the hijacking of religion is that the aim—to create a unified society based on the enforcement of one religion—is an illusion. The result is the complete opposite: the fracturing and destruction of society, and the degrading and debasing of humanity. For as any individual’s religious freedom is violated, we are all violated. For there can be no truth in force and imposition, in hatred and violence. In the words of Thomas Clarke, “All violence in religion is irreligious, and that whoever is wrong, the persecutor cannot be right.”6
That is the true tragedy—that in enforcing religion, hijacking the belief system—then truth is turned to error, right becomes wrong, and the whole set of moral and ethical values are debased and corrupted. The result for religious liberty is devastating.
For hijacked religion is no religion at all.
1. Personal interview, February 14, 2001.
2. Personal interview, February 14, 2001.
3. USCIRF report 2001, p.123.
4. E/CN.4/2001/63, pp.46-47, available at: http://www.unhchr.ch/huridocda/huridoca.nsf/(Symbol)/E.CN.4.2001.63.En.
5. Ibid, p. 46.
6. Thomas Clarke, History of Intolerance (1819 ed.), Vol. 1, p. 3, available at http://www.preparingforeternity.com/br/br101.htm
© Jonathan Gallagher. Visit http://www.jonathangallagher.com
Registrar wins same-sex tribunal (BBC)
From the BBC -
A marriage registrar was harassed for refusing to conduct same-sex ceremonies, a tribunal has ruled.
Lillian Ladele, who said the civil partnership ceremonies went against her Christian faith, hailed the decision as a “victory for religious liberty”.
The tribunal ruled that Miss Ladele was discriminated against on grounds of religious beliefs and was harassed.
Islington council said it was “disappointed” and was considering an appeal against the ruling.
…
Miss Ladele said she was being effectively forced to choose between her religion and her £31,000-a-year job as a result.
She said she was picked on, shunned and accused of being homophobic for refusing to carry out civil partnerships.
Read the full story at
http://news.bbc.co.uk/2/hi/uk_news/england/london/7499248.stm
The New Blue Laws – Slate.com
Slate contributor and labor union attorney, Paul L. Edenfield, asks the questions as to workers have the right to have Sundays off. This may be the forerunner of additional trends in this area:
The New Blue Laws
They’re about giving workers a break, not forcing church attendance.
By Paul L. Edenfield
Updated Monday, April 7, 2008, at 7:39 AM ET
Do workers have a right to Sundays off?
In a recent night-shift ad, Hillary Clinton promised that she would work hard to help workers who toil after hours. Barack Obama, for his part, has issued a call for relief for people “juggling work and parenting.” The candidates’ concern about the demands of employment comes at a time when businesses increasingly try to stay open for most of the hours of the day, seven days a week. While keeping our shopping malls abuzz, these frenetic routines also make it harder for workers to get the weekend off to relax or spend time with their families. The ramped-up pace is due in part to the success businesses have had in attacking laws that improve workers’ lives—like mandatory-closing laws, which require many stores to close on Sundays or holidays.
Mandatory-closing laws sound, yes, like another name for “blue laws,” the Colonial-era restrictions in the name of morality that also closed stores on Sunday (and even banned frivolous dress). Their original purpose was to encourage church attendance. Because of this history, these laws are often still thought of as paternalistic intrusions that impose one Christian version of morality. It doesn’t help that they had a brief resurgence during the teetotaling era of Prohibition, courtesy of the temperance movement. But mandatory-closing laws have since shed their old cloak and taken on a new purpose: protecting the interests of workers who otherwise could not rely on a regular, guaranteed day off.
Read more at http://www.slate.com/id/2188240/