Old Salt Route
The Old Salt Route was a medieval trade route in northern Germany, one of the ancient network of salt roads which were used for the transport of salt and other staples. In Germany it was referred to as Alte Salzstraße. Salt was valuable at that time; the vast majority of the salt transported on the road was produced from brine near Lüneburg, a city in the northern central part of the country and transported to Lübeck, a major seaport on Germany’s Baltic coast. Historians recognize the Old Salt Route as part of a much longer path, which functioned as an important connection between the northern and southern reaches of the country. One of the oldest documents that confirms Lüneburg and its role in refining and transporting salt dates from 956 A. D. According to that document, King Otto I the Great granted the St. Michaelis Monastery in Lüneburg the customs revenue from the saltworks. At those early times, the city’s wealth was based in large part on the salt found in the area. However, the Old Salt Route attained its peak of success between the 16th century.
The trade route led from Lüneburg northward to Lübeck. From that port city, most of the salt was shipped to numerous destinations that lie on the Baltic Sea, including Falsterbo, with boasted a Scania Market. There it was used for the preservation of herring, an immensely important food in the Middle Ages, as well as for other foods; the salt trade was a major reason for the power of the Hanseatic League. Horse-drawn carts brought the salt from Lüneburg to a crossing of the Elbe river at Artlenburg and from there, via Mölln, to Lübeck. However, for the most part, the historic trade route was composed of unsurfaced and muddy roads through heathland and small villages, making the transport of salt an arduous task. In addition, the route was somewhat dangerous, since the valuable cargo attracted thieves and marauders; the dangers faced by those who make the long trek and the fact that only small quantities of the precious crystalline substance could be carried in any single journey, made moving salt via overland routes expensive.
In 1398, the Stecknitz Canal, one of the first manmade waterways in Europe, was completed, making it possible to transport much more salt in a single shipment and to do so with much greater ease and safety. That change helped merchants satisfy the salt requirements of an ever-growing demand. In the 16th Century, for example, about 19,000 tons of the product were carried from Lüneburg to Lübeck each year. Either by land or water, however, it still took about twenty days to complete each trip. In modern times, a trip along the Salt Road promises a rich blend of culture; the trip can be made on foot or on bicycle and part of the distance can be enjoyed on a paddle-wheeled steamer. There are many fascinating sights along the old trade route; these points of interest include the historical towns Lüneburg, Mölln and Lübeck, which are highlighted by beautiful façades and little alleyways, are a major attraction to visitors. As a bicycle route, there are the options of a scenic route; the shorter main route leads bicyclists through many picturesque little towns such as Lauenburg, Büchen, Mölln and Krummsee and passes by the Lüne Monastery.
The scenic route is attractive for nature lovers. The 106-kilometre-long path diverges from the main thoroughfare at Witzeeze, continues on through the Lauenburg Nature Park and rejoins the main route just before Lübeck. Once, the area around Lüneburg was covered in lush woodlands, but because the medieval salt works depended on wood as a fuel used in boiling and purifying the saline water from which the salt was obtained, much of the forest was cut down. Heather covered area, helping it to become the beautiful landscape that now attracts thousands of visitors when that foliage is in full bloom. German Salt Museum Lüneburg Saltworks Sülze Saltworks Lüneburg’s Website Network Old Salt Street – has English and German content. 20.000 tons of white gold – German article
A patent is a form of intellectual property. A patent gives its owner the right to exclude others from making, using and importing an invention for a limited period of time twenty years; the patent rights are granted in exchange for an enabling public disclosure of the invention. In most countries patent rights fall under civil law and the patent holder needs to sue someone infringing the patent in order to enforce his or her rights. In some industries patents are an essential form of competitive advantage; the procedure for granting patents, requirements placed on the patentee, the extent of the exclusive rights vary between countries according to national laws and international agreements. However, a granted patent application must include one or more claims that define the invention. A patent may include many claims; these claims must meet relevant patentability requirements, such as novelty and non-obviousness. Under the World Trade Organization's TRIPS Agreement, patents should be available in WTO member states for any invention, in all fields of technology, provided they are new, involve an inventive step, are capable of industrial application.
There are variations on what is patentable subject matter from country to country among WTO member states. TRIPS provides that the term of protection available should be a minimum of twenty years; the word patent originates from the Latin patere, which means "to lay open". It is a shortened version of the term letters patent, an open document or instrument issued by a monarch or government granting exclusive rights to a person, predating the modern patent system. Similar grants included land patents, which were land grants by early state governments in the USA, printing patents, a precursor of modern copyright. In modern usage, the term patent refers to the right granted to anyone who invents something new and non-obvious; some other types of intellectual property rights are called patents in some jurisdictions: industrial design rights are called design patents in the US, plant breeders' rights are sometimes called plant patents, utility models and Gebrauchsmuster are sometimes called petty patents or innovation patents.
The additional qualification utility patent is sometimes used to distinguish the primary meaning from these other types of patents. Particular species of patents for inventions include biological patents, business method patents, chemical patents and software patents. Although there is some evidence that some form of patent rights was recognized in Ancient Greece in the Greek city of Sybaris, the first statutory patent system is regarded to be the Venetian Patent Statute of 1474. Patents were systematically granted in Venice as of 1474, where they issued a decree by which new and inventive devices had to be communicated to the Republic in order to obtain legal protection against potential infringers; the period of protection was 10 years.. As Venetians emigrated, they sought similar patent protection in their new homes; this led to the diffusion of patent systems to other countries. The English patent system evolved from its early medieval origins into the first modern patent system that recognised intellectual property in order to stimulate invention.
By the 16th century, the English Crown would habitually abuse the granting of letters patent for monopolies. After public outcry, King James I of England was forced to revoke all existing monopolies and declare that they were only to be used for "projects of new invention"; this was incorporated into the Statute of Monopolies in which Parliament restricted the Crown's power explicitly so that the King could only issue letters patent to the inventors or introducers of original inventions for a fixed number of years. The Statute became the foundation for developments in patent law in England and elsewhere. Important developments in patent law emerged during the 18th century through a slow process of judicial interpretation of the law. During the reign of Queen Anne, patent applications were required to supply a complete specification of the principles of operation of the invention for public access. Legal battles around the 1796 patent taken out by James Watt for his steam engine, established the principles that patents could be issued for improvements of an existing machine and that ideas or principles without specific practical application could legally be patented.
Influenced by the philosophy of John Locke, the granting of patents began to be viewed as a form of intellectual property right, rather than the obtaining of economic privilege. The English legal system became the foundation for patent law in countries with a common law heritage, including the United States, New Zealand and Australia. In the Thirteen Colonies, inventors could obtain patents through petition to a given colony's legislature. In 1641, Samuel Winslow was granted the first patent in North America by the Massachusetts General Court for a new process for making salt; the modern French patent system was created during the Revolution in 1791. Patents were granted without examination. Patent costs were high. Importation patents protected new devices coming from foreign countries; the patent law was revised in 1844 - patent cost was lowered and importation patents were abolished. The first Patent Act of the U. S. Congress was passed on April 10, 1790, titled "An Act to promote the progress of
Salt in Chinese history
Salt, salt production, salt taxes played key roles in Chinese history, economic development, relations between state and society. The lure of salt profits led to new ways to organize capital. Debate over government salt policies brought forth conflicting attitudes toward the nature of government, private wealth, the relation between the rich and the poor, while the administration of these salt policies was a practical test of a government's competence; because salt is a necessity of life, the tax on it had a broad base and could be set at a low rate and still be one of the most important sources of government revenue. In early times, governments gathered salt revenues by managing production and sales directly. After innovations in the mid-8th century, imperial bureaucracies reaped these revenues safely and indirectly by selling salt rights to merchants who sold the salt in retail markets. Private salt trafficking persisted because monopoly salt was more expensive and of lower quality, while local bandits and rebel leaders thrived on salt smuggling.
Over time, this basic system of bureaucratic oversight and private management yielded revenue second only to the land tax, with considerable regional variation and periodic reworking, remained in place until the mid-20th century. Salt played a role in Chinese society and culture. Salt is one of the "seven necessities of life" mentioned in proverbs and "salty" is one of the "five flavors" which form the cosmological basis of Chinese cuisine. Song Yingxing, author of the 17th century treatise, The Exploitation of the Works of Nature explained the essential role of salt: as there are five phenomena in weather, so are there in the world five tastes… A man would not be unwell if he abstained for an entire year from either the sweet or sour or bitter or hot. In earliest times and island salterns used earthen and iron boiling pans to reduce sea water to salt. By the 3rd century BCE, workers filtered sea water through flat beds of ashes or sand into pits to produce a brine which could be boiled or evaporated by the sun.
By the Ming dynasty, salterns in the salt marshes of northern Jiangsu and the eastern seaboard at Changlu, Bohai Bay, near present-day Tianjin, became the largest salt producers and by the late 19th century supplied some 80% of China's salt. Over the course of the 20th century, industrial evaporators replaced these coastal salterns. Well salt: produced in Sichuan, most famously at Zigong, but to some extent in Yunnan. Deep borehole drilling technology tapped subterranean salt pools, sometimes to the depth of half a mile, which produced the natural gas used to boil it; however by the end of the 19th century, Sichuan produced only 8% of China's salt. Lake salt: produced from salt water lakes in Western China and Central Asia using the same evaporative techniques as for sea water. Earth salt: found in sand from the dried beds of ancient inland seas in Western areas and extracted by rinsing it to produce brine. Rock salt: found in caves in Shaanxi and Gansu. Song Yingxing, the Ming dynasty technology writer, explains that in the prefectures where there is no sea salt or salt wells, people find “rocky caves which produce salt by themselves, its color being like that of red earth.
People can obtain it by scraping it off without refining it.” As in other ancient centers of civilization, when agriculture replaced hunting, who ate little meat, needed salt for themselves and for their draft animals. More than a dozen sites on the southwest coast of the Bohai Bay show that the Dawenkou culture was producing salt from underground brine more than 6,000 years ago during the Neolithic. In the same region, the late Shang dynasty produced salt on a large scale and moved it inland in "helmet shaped-vessels"; these pottery jars may have served as "standard units of measurement in the trade and distribution of salt". Oracle bones mention "petty officers for salt", suggesting that the Shang had officials who oversaw salt production and provisioning; the earliest surviving record of salt production in what is now China is a text from 800 BCE which reports that the much earlier Xia dynasty reduced sea water for salt. There are reliable reports of the use of iron salt pans in the 5th century BCE.
Early states located their capital cities near ready sources of salt, a consideration which affected locations in times. In the 3rd century BCE, Li Bing, an official of the expansionist and innovative Qin dynasty, in addition to organizing the Sichuan basin water control system at Dujiangyan, discovered that the salt pools, used for many centuries were fed from deep under the ground, the remnants of an ancient inland sea, he ordered first that the pools be made deeper that wells be dug, that narrower and more efficient shafts be sunk. By the end of the 2nd century CE, workers had devised a system of leather valves and bamboo pipes which drew up both brine and natural gas, which they burned to boil the brine. Before the Qin's wars of unification in 221 BCE, salt was produced and traded and presented as tribute to the courts of the regional states; the Guanzi, a Han dynasty comp
Salt is a mineral composed of sodium chloride, a chemical compound belonging to the larger class of salts. Salt is present in vast quantities in seawater; the open ocean has about 35 grams of solids per liter of sea water, a salinity of 3.5%. Salt is essential for life in general, saltiness is one of the basic human tastes. Salt is one of the oldest and most ubiquitous food seasonings, salting is an important method of food preservation; some of the earliest evidence of salt processing dates to around 6,000 BC, when people living in the area of present-day Romania boiled spring water to extract salts. Salt was prized by the ancient Hebrews, the Greeks, the Romans, the Byzantines, the Hittites and the Indians. Salt became an important article of trade and was transported by boat across the Mediterranean Sea, along specially built salt roads, across the Sahara on camel caravans; the scarcity and universal need for salt have led nations to go to war over it and use it to raise tax revenues. Salt has other cultural and traditional significance.
Salt is processed from salt mines, by the evaporation of seawater and mineral-rich spring water in shallow pools. Its major industrial products are caustic chlorine. Of the annual global production of around two hundred million tonnes of salt, about 6% is used for human consumption. Other uses include water conditioning processes, de-icing highways, agricultural use. Edible salt is sold in forms such as sea salt and table salt which contains an anti-caking agent and may be iodised to prevent iodine deficiency; as well as its use in cooking and at the table, salt is present in many processed foods. Sodium is an essential nutrient for human health via its role as an osmotic solute. Excessive salt consumption may increase the risk of cardiovascular diseases, such as hypertension, in children and adults; such health effects of salt have long been studied. Accordingly, numerous world health associations and experts in developed countries recommend reducing consumption of popular salty foods; the World Health Organization recommends that adults should consume less than 2,000 mg of sodium, equivalent to 5 grams of salt per day.
All through history, the availability of salt has been pivotal to civilization. What is now thought to have been the first city in Europe is Solnitsata, in Bulgaria, a salt mine, providing the area now known as the Balkans with salt since 5400 BC; the name Solnitsata means "salt works". While people have used canning and artificial refrigeration to preserve food for the last hundred years or so, salt has been the best-known food preservative for meat, for many thousands of years. A ancient salt-works operation has been discovered at the Poiana Slatinei archaeological site next to a salt spring in Lunca, Neamț County, Romania. Evidence indicates that Neolithic people of the Precucuteni Culture were boiling the salt-laden spring water through the process of briquetage to extract the salt as far back as 6050 BC; the salt extracted from this operation may have had a direct correlation to the rapid growth of this society's population soon after its initial production began. The harvest of salt from the surface of Xiechi Lake near Yuncheng in Shanxi, dates back to at least 6000 BC, making it one of the oldest verifiable saltworks.
There is more salt in animal tissues, such as meat and milk, than in plant tissues. Nomads who subsist on their flocks and herds do not eat salt with their food, but agriculturalists, feeding on cereals and vegetable matter, need to supplement their diet with salt. With the spread of civilization, salt became one of the world's main trading commodities, it was of high value to the ancient Hebrews, the Greeks, the Romans, the Byzantines, the Hittites and other peoples of antiquity. In the Middle East, salt was used to ceremonially seal an agreement, the ancient Hebrews made a "covenant of salt" with God and sprinkled salt on their offerings to show their trust in him. An ancient practice in time of war was salting the earth: scattering salt around in a defeated city to prevent plant growth; the Bible tells the story of King Abimelech, ordered by God to do this at Shechem, various texts claim that the Roman general Scipio Aemilianus Africanus ploughed over and sowed the city of Carthage with salt after it was defeated in the Third Punic War.
Salt may have been used for barter in connection with the obsidian trade in Anatolia in the Neolithic Era. Salt was included among funeral offerings found in ancient Egyptian tombs from the third millennium BC, as were salted birds, salt fish. From about 2800 BC, the Egyptians began exporting salt fish to the Phoenicians in return for Lebanon cedar and the dye Tyrian purple. Herodotus described salt trading routes across Libya back in the 5th century BC. In the early years of the Roman Empire, roads were built for the transportation of salt from the salt imported at Ostia to the capital. In Africa, salt was used as currency south of the Sahara, slabs of rock salt were used as coins in Abyssinia. Moorish merchants in the 6th century traded salt for weight for weight; the Tuareg have traditionally maintained routes across the Sahara for the transportation of salt by Azalai. The caravans
Butter salt is a seasoning developed in the late twentieth century for the purpose of combining the flavours found in salt and butter. It is a fine, golden powder salt, enriched with butter flavouring, it is used as a seasoning for popcorn. It is said to impart a "rich, buttery flavour"; the contents are salt, artificial butter flavoring, yellow food colouring. Butter salt refers to salt, used in the preparation of butter and other dairy products; some manufacturers produce salt for the use in butter, such as "No. 2 butter salt". Salt serves as a preservative for butter. Molly McButter Popcorn seasoning Nagel, C. M.. A.. H.. H.. H.. G.. Bacteriology of Butter: Salt distribution in butter and its effect on bacterial growth. VIII. Bacteriology of Butter: Salt Distribution in Butter and Its Effect on Bacterial Growth. VIII. Agricultural Experiment Station, Iowa State College of Agriculture and Mechanic Arts
Sherman Antitrust Act of 1890
The Sherman Antitrust Act of 1890 was a United States antitrust law, passed by Congress under the presidency of Benjamin Harrison, which regulates competition among enterprises. The Sherman Act broadly prohibits anticompetitive agreements and unilateral conduct that monopolizes or attempts to monopolize the relevant market; the Act authorizes the Department of Justice to bring suits to enjoin conduct violating the Act, additionally authorizes private parties injured by conduct violating the Act to bring suits for treble damages. Over time, the federal courts have developed a body of law under the Sherman Act making certain types of anticompetitive conduct per se illegal, subjecting other types of conduct to case-by-case analysis regarding whether the conduct unreasonably restrains trade; the law attempts to prevent the artificial raising of prices by restriction of supply. "Innocent monopoly", or monopoly achieved by merit, is legal, but acts by a monopolist to artificially preserve that status, or nefarious dealings to create a monopoly, are not.
The purpose of the Sherman Act is not to protect competitors from harm from legitimately successful businesses, nor to prevent businesses from gaining honest profits from consumers, but rather to preserve a competitive marketplace to protect consumers from abuses. In Spectrum Sports, Inc. v. McQuillan 506 U. S. 447 the Supreme Court said: According to its authors, it was not intended to impact market gains obtained by honest means, by benefiting the consumers more than the competitors. Senator George Hoar of Massachusetts, another author of the Sherman Act, said the following: At Apex Hosiery Co. v. Leader 310 U. S. 469, 310 U. S. 492-93 and n. 15: At Addyston Pipe and Steel Company v. United States, 85 F.2d 1, affirmed, 175 U. S. 175 U. S. 211. The Sherman Act is divided into three sections. Section 1 delineates and prohibits specific means of anticompetitive conduct, while Section 2 deals with end results that are anti-competitive in nature. Thus, these sections supplement each other in an effort to prevent businesses from violating the spirit of the Act, while technically remaining within the letter of the law.
Section 3 extends the provisions of Section 1 to U. S. territories and the District of Columbia. Section 1: Every contract, combination in the form of trust or otherwise, or conspiracy, in restraint of trade or commerce among the several States, or with foreign nations, is declared to be illegal. Section 2: Every person who shall monopolize, or attempt to monopolize, or combine or conspire with any other person or persons, to monopolize any part of the trade or commerce among the several States, or with foreign nations, shall be deemed guilty of a felony The Clayton Antitrust Act, passed in 1914, proscribes certain additional activities, discovered to fall outside the scope of the Sherman Antitrust Act. For example, the Clayton Act added certain practices to the list of impermissible activities: price discrimination between different purchasers, if such discrimination tends to create a monopoly exclusive dealing agreements tying arrangements mergers and acquisitions that reduce market competition.
The Robinson–Patman Act of 1936 amended the Clayton Act. The amendment proscribed certain anti-competitive practices in which manufacturers engaged in price discrimination against equally-situated distributors; the federal government began filing cases under the Sherman Antitrust Act in 1890. Some cases were successful and others were not. Notable cases filed under the act include: United States v. Workingmen's Amalgamated Council of New Orleans, the first to hold that the law applied to labor unions. Chesapeake & Ohio Fuel Co. v. United States, in which the trust was dissolved Northern Securities Co. v. United States, which reached the Supreme Court, dissolved the company and set many precedents for interpretation. Hale v. Henkel reached the Supreme Court. Precedent was set for the production of documents by an officer of a company, the self-incrimination of the officer in his or her testimony to the grand jury. Hale was an officer of the American Tobacco Co. Standard Oil Co. of New Jersey v. United States, which broke up the company based on geography, contributed to the Panic of 1910–11.
United States v. American Tobacco Co. which split the company into four. Federal Baseball Club v. National League in which the Supreme Court ruled that Major League Baseball was not interstate commerce and was not subject to the anti-trust law. United States v. National City Lines, related to the General Motors streetcar conspiracy. United States v. AT&T Co., settled in 1982 and resulted in the breakup of the company. United States v. Microsoft Corp. was settled in 2001 without the breakup of the company. Congress claimed power to pass the Sherman Act through its constitutional authority to regulate interstate commerce. Therefore, federal courts only have jurisdiction to apply the Act to conduct that restrains or affects either interstate commerce or trade within the District of Columbia; this requires that the plaintiff must show that the conduct occurred during the flow of interstate commerce or had an appreciable effect on some activity that occurs during interstate commerce. A Section 1 violation has three elements: an agreement.
A Section 2 monopolization violation has two
Wiley Blount Rutledge
Wiley Blount Rutledge Jr. was an American educator and Associate Justice of the Supreme Court of the United States and was a Associate Justice of the United States Court of Appeals for the District of Columbia. Rutledge was born in Cloverport, Kentucky to Wiley Blount Rutledge Sr. a Southern Baptist minister, Mary Lou Wigginton Rutledge. After a brother died in infancy, Wiley's sister Margaret was born in 1897, his family moved about. He attended Maryville College and the University of Wisconsin–Madison, graduating from there in 1914 with a Bachelor of Arts degree. Rutledge taught high school in Indiana while attending the present-day Indiana University Maurer School of Law part-time, he moved to Colorado, received a Bachelor of Laws in 1922 from the University of Colorado Law School in Boulder. While matriculating at Colorado, Rutledge joined the Pi Chapter of Alpha Sigma Phi Fraternity; the year he graduated from law school, on August 28, 1917, Rutledge married Annabel Person. The couple had three children: Mary Lou, Jean Ann, Neal.
Rutledge was the great-great-grandson of Edward Rutledge, South Carolina politician and the youngest signer of the Declaration of Independence. Edward Rutledge's brother, John Rutledge, was a South Carolina delegate to the 1787 Constitutional Convention and twice nominated by President George Washington to the United States Supreme Court. Rutledge entered private practice in Boulder from 1922 to 1924, he was an Associate Professor of Law at the University of Colorado from 1924 to 1926. He was a Professor of Law at Washington University School of Law from 1926 to 1935, serving as Acting Dean in 1930 and as Dean from 1931 to 1935; that school's Wiley Rutledge Moot Court Competition is named in his honor. He was a Professor of Law and Dean of the University of Iowa College of Law from 1935 to 1939. From this position, Rutledge was a vocal supporter of Franklin Roosevelt's plan to pack the Supreme Court. Rutledge was nominated by President Franklin D. Roosevelt on March 21, 1939, to the United States Court of Appeals for the District of Columbia, to a new Associate Justice seat authorized by 52 Stat. 584.
He was confirmed by the United States Senate on April 4, 1939, received his commission on May 2, 1939. His service terminated on February 1943, due to his elevation to the Supreme Court. Rutledge was nominated by President Roosevelt on January 11, 1943, to the Supreme Court of the United States, to an Associate Justice seat vacated by Associate Justice James F. Byrnes, he was confirmed by the Senate on February 8, 1943, received his commission on February 11, 1943. He served as Circuit Justice for the Eighth Circuit and Tenth Circuit from March 1, 1943 to September 10, 1949. Rutledge was less conservative than Byrnes and he remained a steady ally of Roosevelt throughout his court career, his service terminated on September 1949, due to his death. Rutledge articulated strong liberal positions in his interpretation of the due process clause of the Fourteenth Amendment, he wrote for the court in 1946 in Kotteakos v. United States that "our Government is not one of mere convenience or efficiency, it too has a stake, with every citizen, in his being afforded our historic individual protections, including those surrounding criminal trials.
About them we dare not become careless or complacent when that fashion has become rampant over the earth."Rutledge extended this position to dissent from the Court's decision in Yamashita v. Styer, in which Japanese general Tomoyuki Yamashita filed for habeas corpus to appeal his conviction for war crimes in World War II, he wrote: More is at stake than General Yamashita's fate. There could be no possible sympathy for him if he is guilty of the atrocities for which his death is sought, but there can be and should be justice administered according to the law... It is not too early, it is never too early, for the nation steadfastly to follow its great constitutional traditions, none older or more universally protective against unbridled power than due process of law in the trial and punishment of men, that is, of all men, whether citizens, alien enemies or enemy belligerents. According to Justice Frankfurter, Rutledge was part of the more liberal "axis" of justices on the Court, along with Justices Murphy and Black.
Douglas and Rutledge were the first justices to agree with Black's notion that the Fourteenth Amendment incorporated the Bill of Rights protection into it. One of Rutledge's law clerks, John Paul Stevens, was appointed to the Supreme Court in 1975, his tenure on the Court influenced Justice Stevens, who had helped Rutledge draft his dissent in Ahrens v. Clark. In 1948, a 6-3 majority of the Supreme Court ruled that unless detained persons are within the physical jurisdiction of the District Court when they petition for a writ of habeas corpus, that court has no jurisdiction to hear the case. Rutledge dissented, arguing that instead of the jurisdiction deriving from the location of the prisoner, it should instead derive from the custodian, the person responsible for the imprisonment. John Paul Stevens tracked this case and its application to case law. In 1973, the Supreme Court overturned Ahrens, ruling to how Rutledge would have. Justice Rutledge's views were formally endorsed by the Supreme Court in 2004, when Justice John Stevens ruled in Rasul v. Bush that courts were to consider the location of the custodian, rather than the physical location of the pris