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Can your dreams predict the future? The intriguing book that examines the psychology of the paranormal

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Can your dreams predict the future? The intriguing book that examines the psychology of the paranormal

By RICHARD WISEMAN,

PROFESSOR OF PSYCHOLOGY AT THE UNIVERSITY OF HERTFORDSHIRE

Aberfan is a small village in South Wales. In the Sixties, many of those living there worked at a nearby colliery that had been built to exploit the large amount of high-quality coal in the area.

Although some of the waste from the mining operation had been stored underground, much of it had been piled on the steep hillsides surrounding the village.

Throughout October 1966, heavy rain lashed down on the area and seeped into the porous sandstone of the hills. Unfortunately, no one realised the water was then flowing into several hidden springs and slowly transforming the pit waste into soft slurry.

Woman sleeping in bed

You have an average of about four dreams each night. They take place every 90 minutes or so, and each one lasts around 20 minutes

Just after nine o’clock on the morning of October 21, the side of the hill subsided and half a million tons of debris started to move rapidly towards the village.

Although some of the material came to a halt on the lower parts of the hill, much of it slid into Aberfan and smashed into the village school. A handful of children were pulled out alive during the first hour or so of the rescue effort, but no other survivors emerged.

In all, 116 schoolchildren and 28 adults lost their lives in the tragedy.

Psychiatrist John Barker visited the village the day after the landslide.

Barker had a long-standing interest in the paranormal and wondered whether the extreme nature of events in Aberfan might have caused large numbers of people to experience a premonition about the tragedy.

To find out, he arranged for a newspaper to ask any readers who thought they had foreseen the Aberfan disaster to get in touch.

He received 60 letters from across England and Wales, with more than half of the respondents claiming their apparent premonition had come to them during a dream.

One of the most striking experiences was submitted by the parents of a ten-year-old child who perished in the tragedy.

The day before the landslide their daughter described dreaming about trying to go to school, but said there was ‘no school there’ because ‘something black had come down all over it’.

In another example, Mrs MH, a 54-year-old woman from Barnstaple, Devon, said the night before the tragedy she had dreamed that a group of children were trapped in a rectangular room.

In her dream, the end of the room was blocked by several wooden bars and the children were trying to climb over the bars.

Another respondent, Mrs GE from Sidcup, Kent, said a week before the landslide she dreamed about a group of screaming children being covered by an avalanche of coal.

Two months before the tragedy, Mrs SB, from London, dreamed about a school on a hillside, an avalanche and children losing their lives. And so the list went on.

Abraham Lincoln
Mark Twain

Abraham Lincoln (left) reportedly dreamed about an assassination two weeks before being shot dead. Mark Twain (right) dreamed of his brother's corpse lying in a coffin just a few weeks before he was killed in an explosion

Believing you have seen the future in a dream is surprisingly common,
with recent surveys suggesting that around a third of the population
experience this phenomenon at some point in their lives.

Abraham
Lincoln reportedly dreamed about an assassination two weeks before being
shot dead. Mark Twain described a dream in which he saw his brother’s
corpse lying in a coffin just a few weeks before he was killed in an
explosion.

And Charles Dickens dreamed of a woman dressed in
red called Miss Napier shortly before being visited by a girl wearing a
red shawl and introducing herself as Miss Napier.

What could
explain these remarkable events? Are people who have prophetic dreams
really getting a glimpse of things to come? Is it possible to see
tomorrow today?
It is only in the past century or so that researchers have managed to solve the puzzle.

In the Fifties, pioneering U.S. psychologist Eugene Aserinsky helped pave the way for a new science of dreaming.

He showed waking up a person after they have spent some time in the REM state — a physiologically altered state during which there is rapid eye movement and irregular patterns in breathing and heart-rate — is very likely to result in them reporting a dream.

The decades of work that followed have yielded many important insights. Almost everyone dreams in colour. Although some dreams are bizarre, many involve everyday chores such as doing the washing-up, filling in tax forms, or vacuuming.

If you creep up on someone who is dreaming and quietly play some music, shine a light on their face or spray them with water, they are very likely to incorporate the stimuli into their dreams.

However, perhaps the most important revelation of the research was that you have many more dreams than you think.

Sleep scientists quickly discovered you have an average of about four dreams each night. They take place every 90 minutes or so, and each one lasts around 20 minutes.

You then forget the vast majority of these episodes when you wake up, leaving you with the impression you dream far less than is the case.

The only exception to this rule occurs when you happen to wake up during a dream. When this happens, you will usually remember the gist of the dream and perhaps some specific fragments. But, unless it is especially striking, you will soon forget all about it. 

There is, however, a set of circumstances that can greatly increase your likelihood of remembering these dreams.

In a process similar to word association, an event that happens to you when you are awake can trigger the memory.

Let’s imagine three nights of disturbed dreaming. On day one, you go to bed after a hard day at work. Throughout the night, you drift through the various stages of sleep and experience several dreams.

At 7.10am, your brain once again bursts into action and presents you with another entirely fictitious episode.

For the next 20 minutes you find yourself visiting an ice-cream factory and falling into a huge vat of raspberry-ripple. Just when you can take no more, your alarm clock sounds and you wake up with fragments of the factory and raspberry-ripple ice cream drifting through your mind.

On day two, you have several dreams. At 2am you are right in the middle of a rather sinister dream in which you are driving along a dark country lane. Eric Chuggers, your all-time favourite rock star, is in the passenger seat.

Suddenly a giant purple frog jumps out in front of the car, you swerve to avoid the frog but go off the road and hit a tree. Back in the real world, you wake up from the dream with a vague memory of Eric Chuggers, a giant purple frog, a tree and impending death.

On the third night, at 4am you experience a rather traumatic dream. It is a surreal affair, with you being forced to audition for the part of an Oompa Loompa in a new film version of Charlie And The Chocolate Factory.

In the morning you wake up, turn on the radio and are shocked to discover that Eric Chuggers was killed in a car accident during the night.

According to the report, he swerved on a city road to avoid a car that had drifted on to the wrong side of the road, and collided with a lamp-post. Bingo! This news acts as a trigger, and the dream about the car accident jumps into your mind. You forget the raspberry-ripple ice cream, and the stressful Oompa Loompa audition.

Instead, you remember the one dream that appears to match events in the real world and so become convinced you may well possess the power of prophecy.

And it doesn’t stop there. Because dreams tend to be somewhat surreal they have the potential to be twisted to match the events that actually transpired. In reality, Chuggers was not driving along a country lane, did not hit a tree and the accident didn’t involve a giant purple frog.

However, a country lane is similar to a city road, and a lamp-post looks a bit like a tree.
And what about the giant purple frog? 

Dark vision: The Nightmare by 18th-century artist Henry Fusell

Dark vision: The Nightmare by 18th-century artist Henry Fusell

Well, maybe it symbolised something unexpected, such as the car that drifted across the road. Or maybe Chuggers’s next album was going to have a frog on the cover. Or maybe he was wearing a purple shirt at the time of the collision.

Provided you are creative and want to believe that you have a psychic link with the recently deceased Mr Chuggers, the possibilities for matches are limited only by your imagination.

You have lots of dreams and encounter lots of events. Most of the time the dreams are unrelated to the events, and you forget about them.

However, once in a while one of the dreams will correspond to one of the events. Once this happens, it is suddenly easy to remember the dream and convince yourself it has magically predicted the future.

In reality, it is just the laws of probability at work. This theory also helps explain a rather curious feature of pre-cognitive dreaming.

Most premonitions involve a great deal of doom and gloom, with people regularly foreseeing the assassination of world leaders, attending the funeral of close friends, seeing planes fall out of the sky, and watching as countries go to war.

People rarely report getting a glimpse of the future and seeing someone deliriously happy on their wedding day or being given a promotion at work.

Sleep scientists have discovered around 80 per cent of dreams are far from sweet, and instead focus on negative events.

Because of this, bad news is far more likely than good news to trigger the memory of a dream, explaining why so many pre-cognitive dreams involve foreseeing death and disaster.

Earlier, I described how John Barker found 60 people who appeared to have predicted the Aberfan mining disaster. In 36 of Barker’s cases the respondents provided no evidence they had recorded their dream prior to the disaster.

These respondents may have had many other dreams before hearing about Aberfan, and then only remembered and reported the one dream that matched the tragedy. Not only that, but the lack of any record made at the time of the dream means they could have inadvertently twisted the dream to better fit events. Vague blackness may have become coal, rooms may have become classrooms, rolling hillsides may have become a Welsh valley.

Of course, those who believe in paranormal matters might argue that they are convinced by instances when people tell their friends and family about a dream, or describe it in a diary, and then discover it matches future events.

In the late Sixties, researchers found the content of our dreams is not only affected by events in our surroundings, but also often reflects whatever is worrying our minds.

This may explain one of the most striking examples of alleged precognition about the Aberfan disaster.

We have heard how one of the young girls who would later perish told her parents that she had dreamed about ‘something black’ coming down over her school and the school no longer being there.

For several years before the disaster the local authorities had expressed considerable concern about the wisdom of placing large amounts of mining debris on the hillside, but their worries had been ignored.

Three years before the disaster, the borough engineer wrote to the authorities noting his concern — and that of local residents — about the safety of the slurry perched above the school. There is  no way of knowing for sure, but it is possible the girl’s dream may have been reflecting these anxieties after she heard adults discussing them.

But what about the other 23 cases in which people produced evidence they had described their dream before the tragedy occurred, and where the dream did not seem to reflect their anxieties and concerns?

To investigate, we need to move away from the science of sleep and into the heady world of statistics.

Let’s take a closer look at the numbers associated with these seemingly supernatural experiences. First, let’s select a random person from Britain and call him Brian. Next, let’s make a few assumptions about Brian.

Let’s assume Brian dreams each night of his life from age 15 to 75. There are 365 days in each year, so those 60 years of dreaming will ensure Brian experiences 21,900 nights of dreams.

Let’s also assume an event like the Aberfan disaster will happen only once in each generation, and randomly assign it to any one day.

Now, let’s assume Brian will remember dreaming about the type of terrible events associated with such a tragedy only once in his entire life. The chances of Brian having his ‘disaster’ dream the night before the actual tragedy is about a massive 22,000 to one.

However, here comes the sneaky bit. In the Sixties, there were around 45 million people in Britain, and we would expect one person in every 22,000, or roughly 2,000 people, to have this amazing experience in each generation.

The principle is known as the Law of Large Numbers, and states unusual events are likely to happen when there are lots of opportunities for that event.

Our example concerned only people dreaming about the Aberfan tragedy. In reality, national and international bad fortune happens on an almost daily basis. Aeroplane crashes, tsunamis, serial killings, earthquakes and so on.

Given that people dream about doom and gloom more often than not, the numbers quickly stack up and acts of apparent prophecy are inevitable.

Extracted from Paranormality: Why We See What Isn’t There by Professor Richard Wiseman, published by Macmillan on March 4, 2011, at £12.99.

© Richard Wiseman 2011. To order a copy (P&P free), call 0845 155 0720.

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Darpa’s Cheetah-Bot Designed to Chase Human Prey

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Darpa’s Cheetah-Bot Designed to Chase Human Prey

Perhaps you thought the four-legged BigDog robot wasn’t eerily lifelike enough. That’ll change soon. BigDog’s makers are working on a new quadruped that moves faster than any human and is agile enough to “chase and evade.”

Boston Dynamics, maker of the Army’s BigDog robotic mule, announced today that Darpa has awarded it a contract to build a much faster and more fearsome animal-like robot, Cheetah.

As the name implies, Cheetah is designed to be a four-legged robot with a flexible spine and articulated head (and potentially a tail) that runs faster than the fastest human. In addition to raw speed, Cheetah’s makers promise that it will have the agility to make tight turns so that it can “zigzag to chase and evade” and be able to stop on a dime.

Cheetah builds off work on the company’s previous four legged animal bot, BigDog.  It was built as a kind of unmanned pack mule, designed to carry equipment for troops on the battlefield. The robotic donkey could carry 300 lbs. over 13 miles on flat ground, take a swift kick and keep on moving. It’s creepy, lifelike movement can be seen on a number of videos online, climbing over hills and snow and hiking alongside soldiers, using GPS coordinates as its waypoints.

Aside from its unspecified military applications, Cheetah’s makers see it galloping to the rescue and building a brave new future in the fields of “emergency response, firefighting, advanced agriculture and vehicular travel.”

Think that’s creepy? Wait till you see its humanoid, Terminator look-alike buddy.

Meet Atlas, Cheetah’s humanoid pal. Atlas is supposed to look more or less like the T-800 series of Terminators, minus the head. Its designers say it’ll be able to walk like a human over rough terrain, crawling on its hands and knees when necessary and turning itself sideways to slip through any narrow passages it encounters. Headless, with a torso and two arms, it’s a step up from Boston Dynamics’ other biped, the lower-body-bot Petman.

Petman was built to test out chemical weapons protective suits for the Army by “walking, crawling and doing a variety of suit-stressing calisthenics” and “simulat[ing] human physiology.” Designers made it capable of walking heel-to-toe at 3.2 miles per hour and staying upright even after it gets pushed.

As the new models go into development, let’s hope Cheetah never develops a taste for human flesh and that Atlas doesn’t have any hard feelings about its predecessor being a poison-gas guinea pig for the Army.

Images: Boston Dynamics

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QUEERLY BELOVED: County clerk launches defense of Prop 8 traditional marriage

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QUEERLY BELOVED

County clerk launches defense of Prop 8 traditional marriage

Claims standing in court war over constitutional definition

By Bob Unruh




© 2011 WorldNetDaily


A newly elected county clerk in California says he has the answer to the question of "standing" being considered right now by the state Supreme Court in response to a query from the 9th U.S. Circuit Court of Appeals, which is considering Proposition 8 – the constitutional amendment that defines marriage as between one man and one woman only.

"I took an oath of office to uphold the California Constitution, and Prop 8 is part of the Constitution," said Chuck Storey, the new county clerk for the County of Imperial, in a statement released by officials with the Advocates for Faith & Freedom.

The organization has been involved in the arguments over homosexual "marriage" since Proposition 22, a California law defining traditional marriage, was ignored by San Francisco Mayor Gavin Newsom in 2004 when he issued same-sex "marriage" licenses.

Vaughn Walker

The dispute over "standing" is critical in the battle over the voter-approved definition of marriage as being between one man and one woman because the then-attorney general, Jerry Brown, who now is governor, and then-Gov. Arnold Schwarzenegger, both refused to fulfill their state office obligations and defend what now is one section of the state constitution.

Those who organized the petition through which voters adopted the definition have been working with a number of law firms in defense of the law, but the U.S. District Court judge, Vaugh Walker, an open homosexual, who struck down the law, raised the question about "standing."

That would involve the question of exactly who has the right to mount a defense of the law, and Walker suggested that since the state, which is the defendant in the lawsuit, refused to provide a defense, the case essentially is finished.

That very question was raised when the 9th Circuit started considering the dispute, and judges there asked the state Supreme Court to decide whether those interested in the dispute, but not named as defendants, could provide a defense.

The state Supreme Court has not yet released its opinion on the question, but officials with Advocates for Faith & Freedom say in a motion to the 9th Circuit that the county clerk should have "standing" – no matter what the state Supreme Court would decide.

Rally on Prop 8

The organization's motion to intervene on behalf of Storey brings a "new perspective" to the case, officials said.

"This is a very significant development," said Robert Tyler, one of the Advocates' lawyers who have been working on the issue. "Our filing now provides a party that we believe should unquestionably have legal standing to defend Prop 8."

The legal team earlier had sought to intervene on behalf of a deputy clerk, but the 9th Circuit refused permission. The status of Storey as an elected official, Advocates said, should change that.

"The court did leave open the question as to whether a county clerk has sufficient standing," Tyler said. "It certainly seems to indicate it believes the county clerk would be appropriate."

"Twice the voters of California have voted to uphold Proposition 8 and defend marriages," said Tyler, "and twice they have been challenged in the courts. We believe we have a government defendant who has a sufficient and compelling interest in defending Prop 8."

"This case is not only important for influencing nationwide law regarding marriage," added Jennifer Monk, associate general counsel for Advocates. "But it is also important for the people of California to have their vote respected."

The California Supreme Court

It was Walker who inserted a barb in his opinion, which concluded, among other startling statements, "Religious beliefs that gay and lesbian relationships are sinful or inferior to heterosexual relationships harm gays and lesbians."

He noted the organization that assembled the ballot issue perhaps should be thrown out of the case. With that recommendation, the 9th Circuit panel promptly asked the state Supreme Court for a ruling on the issue of "standing."

According to a statement from the Alliance Defense Fund, which has been working on behalf of Proposition 8's supporters, that decision would, in effect, allow a politician to overrule the voters' will on a constitutional amendment simply by refusing to do his or her job.

"Politicians should not be able to nullify a democratic act of the people by refusing their duty to defend it," said ADF Litigation Counsel Jim Campbell. "The people of California have the right to be defended, and thus the official proponents of Proposition 8 must have standing to defend that law.

"Otherwise, the governor and attorney general will succeed in indirectly invalidating a measure that they had no power to strike down directly. With this recent development, the Alliance Defense Fund and the rest of the Protectmarriage.com legal team remain confident that the right of the people of California to protect marriage in their constitution will ultimately be honored," he said.

Voters originally approved a state law defining marriage as one man and one woman back in 2000, only to see it undermined by the state legislature. In fact, the state Supreme Court only months before the 2008 election had struck the state law from the books, opening the door for same-sex "marriage."

But the voters overturned that court decision in the 2008 election, and the dispute has resided in court files ever since.

Earlier, when the California Supremes created same-sex "marriage," Justice Marvin Baxter was alarmed in his dissent.

"The bans on incestuous and polygamous marriages are ancient and deeprooted, and, as the majority suggests, they are supported by strong considerations of social policy," Baxter warned. "Our society abhors such relationships, and the notion that our laws could not forever prohibit them seems preposterous. Yet here, the majority overturns, in abrupt fashion, an initiative statute confirming the equally deeprooted assumption that marriage is a union of partners of the opposite sex. The majority does so by relying on its own assessment of contemporary community values, and by inserting in our Constitution an expanded definition of the right to marry that contravenes express statutory law.

"Who can say that, in 10, 15 or 20 years, an activist court might not rely on the majority's analysis to conclude, on the basis of a perceived evolution in community values, that the laws prohibiting polygamous and incestuous marriages were no longer constitutionally justified?" Baxter wrote.

That argument, in fact, is being made now in a court case in Canada, where the acknowledgement of "marriage rights" for same-sex duos is being cited as a reason to strike polygamy laws.

Those arguing officially on behalf of marriage are from ProtectMarriage.com, which was the group behind Proposition 8 when voters adopted it in 2008.

The ADF said the case has the potential to create "years of chaos and confusion in the legal battle to preserve marriage. It could impact marriage laws in up to 45 other states – including the … states where voters overwhelmingly adopted state constitutional amendments…"

The ADF report said also at stake is:

  • The common sense idea that every child should have a right to be raised in a home with both a mom and a dad



  • Whether America will be forced to accept the bizarre, court-invented claim that men and women are interchangeable


  • Whether Americans will be forced to surrender their freedom to set public policy to a small group of wealthy activists who wish to impose their will on a state or an entire nation


  • Whether marriage will remain a unique institution that promotes the important interests of children and society…


  • Whether voters may freely consider their own moral and religious views about marriage … or be forced by violence and intimidation to remain silent


  • Whether voters may collectively decide through the democratic process that marriage between one man and woman should be protected

Traditional marriage advocates are trying to turn back the stunning conclusions of Walker, an open homosexual, who trashed the votes of more than seven million Californians in his decision.

His 136-page ruling said, "Proposition 8 fails to advance any rational basis in singling out gay men and lesbians for denial of a marriage license. Indeed, the evidence shows Proposition 8 does nothing more than enshrine in the California Constitution the notion that opposite-sex couples are superior to same-sex couples."

Walker also wrote:


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Deputies seek protection after threatening family

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Deputies seek protection after threatening family

Claim 'immunity' for telling parents their children would be confiscated

YOUR GOVERNMENT AT WORK

By Bob Unruh




© 2011 WorldNetDaily


Several Maricopa County, Ariz., deputies are seeking protection from the courts after threatening to take children away from their parents because the homeschooling family was unwilling to allow social workers inside their home for an inspection based on an unsubstantiated anonymous rumor.

But officials with the Home School Legal Defense Association have responded to the court filing by the deputies, explaining that they must answer for their actions in a court of law.

A judge previously ruled that their lawsuit over civil rights violations by the social workers and the deputies can move forward. But the deputies appealed to the 9th U.S. Circuit Court of Appeals that they should be exempted from liability.

Social workers, told earlier by the court that they must respect the U.S. Constitution regarding privacy and parental rights, did not appeal that ruling, and the case, pending in the 9th U.S. Circuit Court of Appeals, will move forward at the district court level once again when the deputies' requests have been resolved.

So far the court has suggested the social workers, accompanied by Maricopa County deputy sheriffs, made unsupported threats to place a family's children in custody and arrest the parents if they were not allowed to make what ended up being an allegedly illegal search of the family's home.

"No intellectually serious argument can be made to support the [deputies] incredulity about why an innocent man would wish to keep a government official from intruding into his home without legal authority," the HSLDA brief in opposition to the deputies' requests said.

"The deputies were not merely bystanders. They were active participants in coercing consent to search. It was clearly established law that the threatening presence of several officers is an important factor in determining whether consent to search is voluntary and whether a person is seized," the HSLDA said.

"They cannot claim that they were merely present or merely 'standing by.' Indeed, the physical presence of a single uniformed law enforcement officer is considered to be the use of 'force,'" the brief said.

"After Sgt. [Joseph] Sousa arrived on the scene he determined that there were no grounds for arrest … and that there was no justification to enter the Loudermilks' home without a search warrant. The written policy of the Maricopa County Sheriff's Office about consent searches further put Sgt. Sousa and the rest of the MCSO defendants on notice that, 'any consent to search must be voluntary, without fear, threats or promise.'

"Sgt. Sousa was the patrol sergeant. He had the authority to order the deputies to leave the Loudermilks' home, but he did not do so. Each of the deputies individually and all of them together were active participants in the violation of the Loudermilks' constitutional rights," the brief argues. "Their conduct was contrary to clearly established law; it was contrary to their training; and it was contrary to the sheriff's written policy about 'consent searches.'"

"Deputies argue that the district court erred in denying their motion for summary judgment and that they should be granted qualified immunity. This is wrong," the brief said. "The law of the Fourth Amendment in relation to warrantless searches in child protective investigations is clearly established and has been since at least 1999.

"There was a clear violation of the Loudermilks' constitutional rights to be protected from unreasonable searches and seizures," the brief said.

Earlier, U.S. District Judge Earl H. Carroll decided that the lawsuit by the family against the social workers, sheriff and deputies, would be allowed to continue, because the social workers' concerns were based on "an anonymous tip that the … Loudermilk children were being neglected and that plaintiffs' home was uninhabitable."

However, the judge said that under federal law, an anonymous tip, "without more, does not constitute probable cause."

The Loudermilks are members of the Home School Legal Defense Association, a Virginia-based organization leading their defense.

"Social workers and sheriff's deputies had come to the home … demanding entry based on a six-week-old anonymous tip that the newly constructed home was unsafe for children," the organization said.

The judge's ruling had directed the case toward a jury trial, except the process was interrupted by the deputies' demand for protection from the courts against accusations of civil rights violations.

Authorities have alleged the Loudermilks voluntarily allowed the search of their home, which produced no evidence that the rumor, in fact, was true.

The HSLDA said, however, that "assertion ... ignores the fact the social worker had said the Loudermilk children would be removed for 72 hours if the parents did not permit entry."

According to the HSLDA, social workers responding to the six-week-old tip demanded entry into the home.

"After an escalating confrontation at the front door that lasted 40 minutes, the social workers, backed by no fewer than four deputies, threatened to take the Loudermilks' children into custody and place them in foster care if the Loudermilks continued to deny them entry into their home. An assistant attorney general repeated this threat to HSLDA Attorney Thomas Schmidt, who was assisting the Loudermilks by phone during the confrontation.

"Under this duress, Mr. and Mrs. Loudermilk allowed the social workers and sheriff's deputies inside. Within five minutes, the social workers determined that the anonymous tip was false and left," the HSLDA said.

The family's subsequent lawsuit filed by the HSLDA alleged violations of the Fourth and 14th Amendments.

The lawsuit names Maricopa County Sheriff Joe Arpaio, deputies Joshua Ray, Joseph Sousa, Richard Gagnon and Michael Danner, social workers Rhonda Cash and Jenna Cramer, and Assistant Attorney General Julie Rhodes.

The judge, in handing authorities a previous courtroom loss, noted that the social workers misrepresented that they had a court order for an inspection of the home. He also noted the deputies were uncooperative, refusing to provide their cell phone number so the HSLDA attorney could talk to them.

The judge ruled that verbal threats generally are not actionable in a federal civil rights proceeding, but in this case, "courts have held that a threat constitutes an actionable constitutional violation in certain circumstances, including 'when the threat is so brutal or wantonly cruel as to shock the conscience.'"

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