OK Levi you need to present the following in court:
Bristol calling Tripp a lovebug
Bristol hopes Tripp will have a sibling
Bristol's inappropriate picture of Tripp on her blog:
Levi Johnson is kicking ass and taking names!
OK Levi you need to present the following in court:
Bristol calling Tripp a lovebug
Bristol hopes Tripp will have a sibling
Bristol's inappropriate picture of Tripp on her blog:
And Sarah Palin claims to be a journalism major?
Sarah had to have written this post herself, it is meth-fueled
What? Lamestream calls for empathy, even outrage, for a First Amendment violation that's on par with all the abuse we've brought to your attention as Obama stomps on our Constitution. You've IGNORED us, you've marginalized us, you've left us for "destroyed." But when Obama's boot is on YOUR neck you finally wake the h*ll up and cry foul? Good Lord.
http://www.breitbart.com/Big-Government/2014/02/20/White-House-crackdown-press-freedom
I think Nancy French is a Democrat
Seriously I do.
If you read Brancy's latest blog posts, they are so terrible it's not even funny:
Way to Go, Connecticut Gun Owners!
Did you know that quietly–very quietly thanks to a biased media–tens of thousands of American citizens delivered a message about the limits of government?In other words, Connecticut forced people to register their firearms and NO ONE DID IT!
Did you know that citizens of one state engaged in a mass act of civil disobedience that has left statist officials from both parties scratching their heads as an entire regulatory scheme collapsed?
Last week, Connecticut politicians were shocked to find out that only a fraction of Connecticut gun owners obeyed a state directive to come forward, declare their weapons, and register them with the government.
I LOVE that sign that the guy is holding up, too.
Way to go, Connecticut!
AND, THIS ONE IS A PIP:
Lazy Hands
“Lazy hands make a man poor, but diligent hands bring wealth.” Proverbs 10:4
I came across this Scripture and wanted to pass it along. I love it because it reminds me of my parents and the work ethic they instilled in all of us kids. If you want something, you go out and work for it.
No one owes you anything, and I’m embarrassed to be in a generation that doesn’t have that mindset.
Honest, hard work, is the only way to do it right. Don’t rely on anyone to provide for you.
The world doesn’t owe you anything!
That is rich coming from a girl who is only famous because her mom was a one time Vice presidential nominee, a girl who has had everything handed to her-abstinence spokeswoman, book deals, Life's a Tripp, Wife Swap, family court judges in her back pocket etc. And don't get me started on DWTS.
Her family is just as bad, Sarah and Todd grifting, Willow saying in a job interview she didn't want to work Saturdays, Tripp running around like a spoiled brat, Piper running around like a spoiled brat, Track jobless and living in Todd's hangar.
The only ones in the whole Palin saga that have jobs are these two:
I seriously wonder if Nancy is writing shitty on purpose just to embarrass Butthole.
Sarah Palin's selfies
Yet she says this:
Probably because the President did this:
And his daughters did it too:
The Winter Olympics are coming to a close tonight
Seriously though it looks like they are at a shooting range or maybe a race track. As you can see Sarah is wearing earplugs. Why is it OK for Sarah to wear earplugs but this little boy can't?
Question for Todd and Sarah Palin-Update
Sarah why have you not released Trig's birth certificate?
Todd have you ever been with or hung out with hookers in Anchorage?
Update-I know most of you have seen this already, but I would be remiss not to post it. Enjoy!
http://politicalgates.blogspot.com/2014/02/sarah-palins-new-trailer-i-would-do.html
Todd have you ever been with or hung out with hookers in Anchorage?
Update-I know most of you have seen this already, but I would be remiss not to post it. Enjoy!
http://politicalgates.blogspot.com/2014/02/sarah-palins-new-trailer-i-would-do.html
The Palins hate the Obamas so much that hatred extends to the Obama dogs too
Our economy is in the toilet — due largely to Obama’s terrible policies. That’s why I thought the First Lady’s tweet showing her dogs eating off china and drinking out of crystal was a bit much!!
Get over it Butthole and Skanky. The Obama's are dog lovers. This isn't the first time that Bo and Sunny made an appearance.
Christmas 2011 Bo Obama graced the cover of the White House Christmas card:
And Sarah Palin had to make a big fuss about it:
"It's odd," she said, wondering why the president's Christmas card highlights his dog instead of traditions like 'family, faith and freedom.'"
Palin said the majority of Americans can appreciate the more traditional, “American foundational values illustrated and displayed on Christmas cards and on a Christmas tree.”
As for the Obama card, she replied, “It’s just a different way of thinking coming out of the White House.”
I wonder if this girl was a member of the Palmer Colony Girls
From Alaska News
A former Palmer teen charged with murder in Pennsylvania claims to be a inclusive sequence torpedo who got her start in a eerie cult in Alaska.
Miranda Dean Barbour, 19, who lived in North Pole and a Mat-Su though left a state in 2011, is indicted of stabbing to genocide a married electrical operative in a executive Pennsylvania city of Sunbury on Nov. 11.
Barbour gave a jailhouse talk Friday night to a Sunbury Daily Item journal in that she claimed to have killed dozens of people in Alaska, Texas, North Carolina and California over a past 6 years.
“When we strike 22, we stopped counting,” Barbour told a Daily Item.
She is quoted as observant a “majority” of a killings took place in Alaska.
Barbour’s invulnerability profession has sought a psychiatric analysis for his client, according to news reports.
Hundreds of news outlets fast picked adult a pale story of a self-proclaimed satanist who boasted to a contributor of spending her teenage years on a national murdering spree.
The large question: How severely are authorities holding Barbour’s claims?
The FBI in Philadelphia told NBC News that a group “has recently been in hit with a Sunbury Police Department per Miranda Barbour, and will offer any assistance requested in a case.”
Alaska law coercion sources didn’t respond on Sunday to questions about either they’ve launched their possess investigations into her time in Alaska.
Alaska State Troopers mouthpiece Megan Peters pronounced a dialect wouldn’t be means to answer questions about Barbour until after a Presidents’ Day holiday weekend.
A orator for a Anchorage business of a FBI did not immediately respond to phone messages Sunday.
Pennsylvania authorities seem to be holding a 19-year-old mother’s difference seriously.
Police in Pennsylvania told a Daily Item that they had been operative with investigators from other states to examine probable connectors to unsolved murders even before her jailhouse revelations became open this weekend.
Public annals uncover Barbour filed for Alaska Permanent Fund dividends for years from North Pole and Anchorage addresses.
A Facebook page that appears to go to Barbour lists North Pole as her hometown.
It says she attended Colony High School and Valley Pathways School, in Palmer.
According to Barbour’s account to Daily Item contributor Francis Scarcella, a teen assimilated a eerie cult in Alaska when she was 13 and spent her teenage years murdering during a insistence of a cult leader.
She reportedly changed to North Carolina from Alaska in 2011, when she was profound with her daughter. In North Carolina she met Elytte Barbour, now 22, a Daily Item reported. The dual married in Oct 2013.
Police contend a integrate used a Craigslist ad earnest “companionship” to captivate LaFerrara to a mall parking lot.
After pushing several miles, Miranda Barbour stabbed LaFerrara in a front chair of her automobile while her father hold a cord around his neck, a integrate told police.
Elytte Barbour told investigators they committed a crime since they wanted to kill someone together, according to justice papers.
Prosecutors are seeking a genocide chastisement opposite Barbour and her husband.
From CNN
Alaskan authorities say there's no evidence to back up a 19-year-old Pennsylvania woman's claim that one of the countless killings she carried out was in their state.
Miranda Barbour told a newspaper reporter over the weekend that she killed so many people across so many states in the last six years that she lost count. She told the Daily Item newspaper in Sunbury, Pennsylvania, that the killings spanned from Alaska to North Carolina.
However, Alaska State Troopers said Tuesday Barbour's claims don't bear out -- at least in their state.
"At this time the Alaska State Troopers are not aware of any information -- beyond Barbour's comments quoted in the press -- or evidence that would implicate Barbour with a homicide committed in Alaska," a statement from the agency said.
Miranda is 19, same age as Willow, and attended Colony High so paths might have crossed.
However Willow ran with the Colony Girls the popular group and it sounds like Miranda may have ran with the not-so popular crowd.
Does anyone know out there?
Sarah Palin uses Trig as a human shield to deflect from Todd quitting the Iron Dog
From Sarah's Fecebook:
Hi! For anyone interested, this is Todd and Tyler from Iron Dog Team #11 writing from Sarah’s Facebook page.
Disappointed on the trail today, but keeping everything in perspective. Due to a rare mechanical issue that was impossible to fix ...on the trail, we’ll be cheering on the other teams the rest of the race. I’ve been enjoying this endurance race for decades now, and you never can tell how it’s going to turn out for any team. There’s always inexplicable circumstances arising and you never know what mother nature will challenge you with out there. But it’s always rewarding and worth the effort.
This race, like everything else in life, is a gamble. Our advice is to find your passion, don’t procrastinate, and just do it! This isn't a dress rehearsal. It doesn’t matter how many times you get knocked down, what matters is how many times you get back up. As Sarah likes to say, live life vibrantly! Having the freedom to tackle challenges like this is what makes America amazing.
We’re incredibly grateful for all the supporters that make the world's ultimate snowmachine race happen every year. It wouldn’t be possible without our rural communities that connect the trail, celebrate this event, and cheer on every participant. You keep us going, bush Alaska! You’re our foundation! Thank you so much for all you guys do.
Keep the other racers in your prayers.
Also, thanks so much for pledging in the fund raiser to fight breast cancer with the awesome “Bring Home the Pink” campaign. You can still support the Ski-Doo teams involved in this great cause by pledging here: http://www.gofundme.com/67f7gs
Of course Sarah had to pimp out their charity.
Then later Sarah posts this video on her page:
Has the bitch have no shame? And by the way it looks like Trig had to be coaxed into saying Go Daddy.
Hi! For anyone interested, this is Todd and Tyler from Iron Dog Team #11 writing from Sarah’s Facebook page.
Disappointed on the trail today, but keeping everything in perspective. Due to a rare mechanical issue that was impossible to fix ...on the trail, we’ll be cheering on the other teams the rest of the race. I’ve been enjoying this endurance race for decades now, and you never can tell how it’s going to turn out for any team. There’s always inexplicable circumstances arising and you never know what mother nature will challenge you with out there. But it’s always rewarding and worth the effort.
This race, like everything else in life, is a gamble. Our advice is to find your passion, don’t procrastinate, and just do it! This isn't a dress rehearsal. It doesn’t matter how many times you get knocked down, what matters is how many times you get back up. As Sarah likes to say, live life vibrantly! Having the freedom to tackle challenges like this is what makes America amazing.
We’re incredibly grateful for all the supporters that make the world's ultimate snowmachine race happen every year. It wouldn’t be possible without our rural communities that connect the trail, celebrate this event, and cheer on every participant. You keep us going, bush Alaska! You’re our foundation! Thank you so much for all you guys do.
Keep the other racers in your prayers.
Also, thanks so much for pledging in the fund raiser to fight breast cancer with the awesome “Bring Home the Pink” campaign. You can still support the Ski-Doo teams involved in this great cause by pledging here: http://www.gofundme.com/67f7gs
Of course Sarah had to pimp out their charity.
Then later Sarah posts this video on her page:
Post by Sarah Palin.
Has the bitch have no shame? And by the way it looks like Trig had to be coaxed into saying Go Daddy.
Just like Sarah Palin, her staff was incompetent too
From Alternet.
A former Alaska judge claims he was the victim of "racist and sexist hazing" by his peers after former Governor Sarah Palin thanked him for his "pubic service" in his appointment letter.
Richard Postma Jr. claims the typo in Palin's letter caused him so much grief that he was voted out, had to return to private practice, and is struggling to hold onto his law license Bar.
Richard W. Postma Jr. sued Alaska Bars Counsel Stephen Van Goor and Assistant Bar Counsel Mark Woelber, in Federal Court.
"Plaintiff was a former state district judge in Anchorage who was appointed in 2007 by former Governor Sarah Palin," the 13-page lawsuit states.
"As a judge, he experienced racist and sexist hazing by certain judicial officers and court employees.
"The hazing started because of a typographical error in the judicial appointment letter where the
Governor thanked the plaintiff for his years of 'pubic service,' instead of 'public service.'"
Postma claims in the complaint that his hazers went so far as to suggest he was appointed as a judge "by performing oral sex on former Governor Palin," and that it escalated "to suggest Postma was the biological father of Governor Palin's son, Trig Palin."
When he complained he was retaliated against, Postma says.
Postma claims that none of the jokes were true, but he suffered the harassment from his appointment in 2007 until 2010, when the Alaska Commission on Judicial Conduct "initiated an administrative action to remove Postma from the bench because of stress and medical problems caused by the hazing."
The Commission issued a detailed, "2010 Judicial Appointment Retention Performance Evaluation ," in which Postma received fair to high marks on specific questions, but a rather scathing review from the council itself, which recommended by 5-1 vote that that Postma not be reappointed.
According to Postma's complaint, it was this evaluation that motivated Alaska voters to vote him out in 2010.
The Judicial Council Recommended, inter alia, that "stressful situations. Judge
Postma has lacked patience, dignity, and courtesy in his communications which has contributed to constant friction between Judge Postma and other judges, court administrators, and court staff. Judge Postma has a tendency to lose his temper. Judge Postma's characterization of past events has often been inconsistent with other documented information. Judge Postma has prioritized his personal needs over his judicial responsibilities."
The Recommendation adds: "An independent mental health expert retained by the Alaska Commission on Judicial Conduct has determined that Judge Postma suffers from a combination of mental health difficulties that is or may become permanent and which render him unable to fulfill the duties of his office."
On a scale of 1 (low) to 5 (highest), "The attorney rating for Judge Postma on overall performance was 3.7. Peace and probation officers gave Judge Postma a rating of 4.1. Jurors rated him 4.9 overall, and court employees gave him 3.1. ... Alaska Judicial Observers rated him 2.86," Recommendation states. Nonetheless, the Council said: "Judges must be fair and judicial in the courtroom and in their conduct off the bench. The Alaska Judicial Council concludes that, while performing acceptably on the bench, Judge Postma demonstrated an inability to function appropriately with other judges and court staff and that he did so in a manner that seriously interfered with the performance of his judicial duties, disrupted the functioning of the Anchorage District Court, and makes him unfit to retain his office. The Judicial Council finds Judge Postma to be Unqualified and recommends with a 5-1 vote that the public vote 'NO' on his retention as a district court judge."
Now, Postma claims in his lawsuit, he has trouble getting fair hearings for his clients, and has had three of five sitting judges "disqualified for cause" from his cases, because they allegedly participated in the alleged hazing and retaliation. (14)
And he claims the Alaska Bar Association tried to revoke his law license in January.
Defendant Van Goor told Courthouse News he could not comment on the lawsuit, which came to his notice on Wednesday.
According to the evaluation, Postma handled civil and criminal cases in the Third District and had more than 20 years of legal experience.
Wasn't Britta an office assistant for Sarah during her reign as governor?
Maybe it was Meg Stapleton who made the typo?
After five years Sarah Palin still doesn't know shit about history
From Sarah's Fecebook page:
God Bless the legacy of our 16th President. He served with honesty and integrity, held our nation together in the worst of times, understood and assured the blessings of liberty for all Americans, and didn’t succumb to the special interests that would destroy our Union for personal gain. With foresight towards developing our natural resources, the man Lincoln appointed as his Secretary of State wisely purchased the territory of Alaska. This President truly understood the heart of the United States. He gave his last full measure of devotion to keep our nation as one and secure the foundation of those truths we still hold self-evident.
To quote his immortal words, it is for us the living to be dedicated to the task remaining before us. The United States deserves leaders that ascribe to the simple principles that guided this great man. From a log cabin in Kentucky to the White House, he espoused the American ideal of truth and honesty. He didn’t shy from controversy, and the fire of freedom burned bright within him and guided him throughout his life.
May all our elected officials take a long look at what made Lincoln a great leader. Our elected officials have from our history the perfect example of selfless leadership.
On this, Abraham Lincoln’s 205th birthday, please take a moment to reflect on what it means to be a God-fearing leader, a great president, and a true American. Ask yourself if our politicians and influential celebrities who shape society live up to Lincoln’s shining example, and if not, hold them accountable instead of rewarding them with continued privilege. It’s our nation, and Lincoln gave his life to assure that it remained the “last best hope on earth.”
Happy Birthday, Honest Abe!
I need to clear up some things here.
For starters yes Lincoln appointed William Seward Secretary of State. However the purchase of Alaska happened TWO YEARS after Lincoln's assassination. Andrew Johnson was the president in 1867. The same Andrew Johnson who was impeached, and was acquitted by just one vote, the same Andrew Johnson who got drunk at Lincoln's inauguration.
Abraham Lincoln is the sort of person Sarah Palin despises. She is all for state's rights but Lincoln wanted to ban slavery in all the US. If Sarah was alive in 1861 she would be jumping up and down screaming, NO, HE CAN'T DO THAT! IT'S UNCONSTITUTIONAL!
He also issued the Emancipation Proclamation which was an executive order freeing all slaves. Sarah sure hates it when President Obama issues one.
Nice try Skank. You need to watch Lincoln again. Lincoln did do some things that would have gotten him impeached if the public found out. But I agree with him on it because it saved the Union.
Todd's days of winning the Iron Dog are gone
Today starts the pro class of the 2014 Iron Dog.
Here is Todd's team profile. He has a new partner in Tyler Huntington.
Todd finished 5th last year. Has not won since 2007. Right now he is on the longest drought in his Iron Dog career, winning in 1995, 2000, 2002.
If he hasn't won that long I guarantee he won't win again cuz I think he is past his prime. Plus with all the distractions from Sarah's copyright lawsuit, Levi no longer taking shit, and possible IRS investigation (Sarah and Chuck Jr ranting about the IRS is my only proof) I'm sure he is quite distracted.
So does Sarah Palin have a gay friend or not?
Twice Sarah Palin has mentioned her best friend is gay. The first time was to Katie Couric during those disasterous interviews back in 2008.
"I have one of my absolute best friends for the last 30 years who happens to be gay and I love her dearly," Palin said, without mentioning names. "And she is not my gay friend, she is one of my best friends who happens to have made a choice that isn't a choice that I have made."
The other time was recently during the whole Duck Dynasty debacle.
"She emailed me to say she is outraged at A&E for the hypocrisy here, for the things that they air on their program that she finds offensive, yet A&E doesn't fire a star or somebody involved in their programming based on what they said but they would when it comes to Phil on Duck Dynasty and this friend, she said that she would boycott A&E and that network, and uh, um, she's not the only one," Palin said.
So where is this best friend? Why hasn't this best friend come out and publically supported Sarah?
Oh that's right she doesn't exist. Unless that best friend is Rebecca Mansour. But Sarah and Rebecca didn't know each other 30 plus years ago so we can rule her out.
University of Idaho
From the University of Idaho web page
On January 30, 1889, the University of Idaho was established as a university. Please join us for a birthday celebration in Moscow with live streams and social gatherings across the state to UI Boise, Coeur d'Alene, and Idaho Falls centers.
Throughout this year the U of I will be holding many events statewide to celebrate their anniversary. But one famous alum will not be invited. Gee I wonder who that could be?
What Sarah Palin did on her birthday yesterday (Guestwritten by GInaM)
SCENE
Baldy is laying in her bed reading her Google Alerts on her IPad.
Her bedroom looks like a Madame's paradise! Red curtains...red carpet...red walls. A vanity set with red cushioned chairs sits smack dap in the middle of the room completely out of place!
But the thing that Baldy's family talk about the most is the SIZE of Baldy's bed! It's a huge 4 poster canopy bed with curtains (red of course) that takes up half the room! It even has mirrors embedded in the ceiling!
What's left of her hair is pulled back and held on her head by a hair band....on her night stand is a glass with teeth that look suspiciously like the teeth Baldy was flashing in her last Fake News interview! Wearing her favorite housecoat...the fluffy red Elmo jobby....Baldy reaches for a small mirror and a straw and sniffs.
Baldy goes back to her IPad and thumbs through story after story about her MLK post...then her phone rings*
Baldy: "What"?
CreepyJr stutters: "Hey Baldy...ummm how's it going?"
Baldy looks at her phone and sighs: "Whatta ya want Creepy...I'm real busy here".
CreepyJr says: "Yeah...I hate to bother you...but the check ya gave me...ummm...kind of bounced. Can you just give me a postage money order like you use to?"
Baldy grits her teeth (but stops when they wobble in her mouth): "Look Creepy...I already told ya....BaldyPAC can't give you no more postage money orders...Tim says that the FEC is asking too many goddamn questions so we gotta lay low on that...okay?"
CreepyJr starts whining: "Ummm...that's not good...ya see my son Zelig said that his mom...ya know my ex-wife has been getting text messages from a book publisher and when I confronted the bitch about it...she said she needs more money from me...but ya know my wife is mad about that to the point where she keeps coming home later and later and when I asked her why is she home so late lately she told me that she's tutoring and Yada Yada I'm real tired now!"
Baldy says: "I told ya not to marry that tramp!"
Creepy cringes and whispers in the phone: "Come on Baldy...ya promised you wouldn't call her that....anymore".
Baldy smirks and says: "To her face...remember". Whatever...I'll call the Toad and have him and some of his buddies follow that trampy wife of yours and find out what she's really doing...and tell your ex-wife that I said...."Dar"...she'll know what that means. Anything else?"
CreepyJr gulps and says: Ummm....okay Baldy...thanks...don't ya wanna know about Mom and Dad?"
Baldy: "WHO"?
CreepyJr: "Our parents? Well anyway...did ya like what I said about the IRS harassing dad on my FB page?"
Baldy in a disinterested voice says: "Yeah I saw that...so dad can talk now?"
CreepyJr says: "No...not really...mom says he just sits in his recliner and watches FAKE News all day and he holds a pair of ladies panties...not sure why he does that but mom says if she tries to take it from him he makes this unholy screeching sound."
Baldy says real quickly: "Listen Creepy...Beefy and Wallow are coming by so I gotta go."
She hangs up the phone and sits there staring at the ceiling and her reflection...just then her bedroom door opens and Wallow and Beefy walk in with (at first glance looks like) 10 KIDS!!
Wallow strolls in holding the hand of a little boy of 3...hanging on her hip is a baby girl of undetermined age.Wallow lets the boy hand go and places the baby girl on Baldy's bed*
Wallow smirks and says: "Hi Granny...I need some money".
*Beefy with about 4 kids (two girls and two boys) trailing behind her walks up to Baldy's bed and stands there with her thumb in her mouth and a vague empty look in her eye pushes Wallow in the shoulder*
Beefy stammers: "Wallow...you promised to be nice to Baldy today".
Baldy glares at her offspring and screams: "WHAT DID I TELL YOU TO CALL MEEEEEE?"
Wallow and Beefy say in unison: "Sorry MOMMMM".
Baldy: "Hmmmphff"
*Just then Wallow's baby girl who has crawled across Baldy's bed reaches for her IPad...*.
Baldy snatches it out the baby's reach and screams: "WALLOW grabbed this brat of yours and tell me WTF ya want!!"
Wallow grabs her baby and says sarcastically: "MONEY Baldy...I need MONEY".
Baldy says: "I gave you both a check the other day for 20,000 dollars...whatcha do with it?"
Beefy looks sheepishly down and says: "Joey needed some stuff".
*Wallow starts popping her gum and just looks at Baldy in silence. Baldy looks at her two trampy daughters and shakes her giant head*
Baldy speaking in a defeated tone says: "Call Toad...he'll know what to do".
Wallow grabs her baby girl and calls over to the boy...
Wallow: "Comeon Chris...Granny is busy now...let's go".
*Beefy looks at her mother and realizes how OLD she looks then she remembers that Joey is waiting for her in bed and shrugs her shoulders*
Beefy says: "Come on Tripp...Kyla...Jinger(pronounced Ginger...last name Junker) and Trenton...Grandma needs her rest".
As the bedroom closes...Baldy cusses under her breath and reaches for her phone....
Baldy: "RAM....put the call out...I need a job...I don't care what it is...I need it fast...what...what about Roger...knee pads....hmmmm.....how much did he say and where should I meet him? That's ALL? See if he'll go up 5,000 if I wear my fake tits....okay....call me back and put down that goddamn bbq...I can hear ya smacking from here!"
Baldy is laying in her bed reading her Google Alerts on her IPad.
Her bedroom looks like a Madame's paradise! Red curtains...red carpet...red walls. A vanity set with red cushioned chairs sits smack dap in the middle of the room completely out of place!
But the thing that Baldy's family talk about the most is the SIZE of Baldy's bed! It's a huge 4 poster canopy bed with curtains (red of course) that takes up half the room! It even has mirrors embedded in the ceiling!
What's left of her hair is pulled back and held on her head by a hair band....on her night stand is a glass with teeth that look suspiciously like the teeth Baldy was flashing in her last Fake News interview! Wearing her favorite housecoat...the fluffy red Elmo jobby....Baldy reaches for a small mirror and a straw and sniffs.
Baldy goes back to her IPad and thumbs through story after story about her MLK post...then her phone rings*
Baldy: "What"?
CreepyJr stutters: "Hey Baldy...ummm how's it going?"
Baldy looks at her phone and sighs: "Whatta ya want Creepy...I'm real busy here".
CreepyJr says: "Yeah...I hate to bother you...but the check ya gave me...ummm...kind of bounced. Can you just give me a postage money order like you use to?"
Baldy grits her teeth (but stops when they wobble in her mouth): "Look Creepy...I already told ya....BaldyPAC can't give you no more postage money orders...Tim says that the FEC is asking too many goddamn questions so we gotta lay low on that...okay?"
CreepyJr starts whining: "Ummm...that's not good...ya see my son Zelig said that his mom...ya know my ex-wife has been getting text messages from a book publisher and when I confronted the bitch about it...she said she needs more money from me...but ya know my wife is mad about that to the point where she keeps coming home later and later and when I asked her why is she home so late lately she told me that she's tutoring and Yada Yada I'm real tired now!"
Baldy says: "I told ya not to marry that tramp!"
Creepy cringes and whispers in the phone: "Come on Baldy...ya promised you wouldn't call her that....anymore".
Baldy smirks and says: "To her face...remember". Whatever...I'll call the Toad and have him and some of his buddies follow that trampy wife of yours and find out what she's really doing...and tell your ex-wife that I said...."Dar"...she'll know what that means. Anything else?"
CreepyJr gulps and says: Ummm....okay Baldy...thanks...don't ya wanna know about Mom and Dad?"
Baldy: "WHO"?
CreepyJr: "Our parents? Well anyway...did ya like what I said about the IRS harassing dad on my FB page?"
Baldy in a disinterested voice says: "Yeah I saw that...so dad can talk now?"
CreepyJr says: "No...not really...mom says he just sits in his recliner and watches FAKE News all day and he holds a pair of ladies panties...not sure why he does that but mom says if she tries to take it from him he makes this unholy screeching sound."
Baldy says real quickly: "Listen Creepy...Beefy and Wallow are coming by so I gotta go."
She hangs up the phone and sits there staring at the ceiling and her reflection...just then her bedroom door opens and Wallow and Beefy walk in with (at first glance looks like) 10 KIDS!!
Wallow strolls in holding the hand of a little boy of 3...hanging on her hip is a baby girl of undetermined age.Wallow lets the boy hand go and places the baby girl on Baldy's bed*
Wallow smirks and says: "Hi Granny...I need some money".
*Beefy with about 4 kids (two girls and two boys) trailing behind her walks up to Baldy's bed and stands there with her thumb in her mouth and a vague empty look in her eye pushes Wallow in the shoulder*
Beefy stammers: "Wallow...you promised to be nice to Baldy today".
Baldy glares at her offspring and screams: "WHAT DID I TELL YOU TO CALL MEEEEEE?"
Wallow and Beefy say in unison: "Sorry MOMMMM".
Baldy: "Hmmmphff"
*Just then Wallow's baby girl who has crawled across Baldy's bed reaches for her IPad...*.
Baldy snatches it out the baby's reach and screams: "WALLOW grabbed this brat of yours and tell me WTF ya want!!"
Wallow grabs her baby and says sarcastically: "MONEY Baldy...I need MONEY".
Baldy says: "I gave you both a check the other day for 20,000 dollars...whatcha do with it?"
Beefy looks sheepishly down and says: "Joey needed some stuff".
*Wallow starts popping her gum and just looks at Baldy in silence. Baldy looks at her two trampy daughters and shakes her giant head*
Baldy speaking in a defeated tone says: "Call Toad...he'll know what to do".
Wallow grabs her baby girl and calls over to the boy...
Wallow: "Comeon Chris...Granny is busy now...let's go".
*Beefy looks at her mother and realizes how OLD she looks then she remembers that Joey is waiting for her in bed and shrugs her shoulders*
Beefy says: "Come on Tripp...Kyla...Jinger(pronounced Ginger...last name Junker) and Trenton...Grandma needs her rest".
As the bedroom closes...Baldy cusses under her breath and reaches for her phone....
Baldy: "RAM....put the call out...I need a job...I don't care what it is...I need it fast...what...what about Roger...knee pads....hmmmm.....how much did he say and where should I meet him? That's ALL? See if he'll go up 5,000 if I wear my fake tits....okay....call me back and put down that goddamn bbq...I can hear ya smacking from here!"
Sarah Louise Heath Palin, embarrassing America since Feb 11, 1964!
See below a timeline of Skanky's life covering most of her major milestones and controversial moments:
Spring 1963 Sarah is conceived.
2/11/64 Sarah is born in Sandpoint Idaho
5/64 Sarah and her family move to Skagway
9/6/64 Todd is born
1966 Molly is born
1969 the Heaths move to Eagle River
1972 the Heaths move to Wasilla.
Spring 1982 Sarah scores 2 points in the Alaska state basketball championship game
Spring 1982 Sarah graduates from Wasilla High
Fall 1982 Sarah enrolls at Univ of Hawaii, transfers a week later to Hawaii Pacific University
Spring 83 Sarah transfers to North Idaho JC
1984 Sarah wins Miss Wasilla
Aug 84 Sarah enrolls at U of Idaho
Fall 85 Sarah enrolls at Mat-Su Comm College
1986 Todd is arrested for DUI
Jan 86 Sarah returns to U of Idaho
May 87 Sarah graduates from U of Idaho with a degree in communications (allegedly)
Nov 87 Sarah is working at KTUU, mets Glen Rice and sleeps with him
July 88 Track is conceived with either Todd or Curtis Menard Jr
8/29/88 Sarah and Todd elope
4/20/89 Track is born 1989 Sarah has a miscarriage
Winter 89-90 Bristol is conceived
10/18/90 Bristol is born.
1992 Sarah is elected to the Wasilla City Council
Fall 93 Willow is conceived
7/7/94 Willow is born.
1995 Todd registers as a member of the AIP
2/95 Todd wins the Iron Dog for the first time
0ct 96 Sarah defeats John Stein in the Wasilla mayoral race
1998 Sarah has her 2nd miscarriage
1999 Sarah is re-elected as Wasilla Mayor 2000 Molly and Mike Wooten marry 8
8/9/01 Curtis Menard Jr is killed in a plane crash
10/02 Sarah's tenure as mayor ends
2/03 Sarah is named to the Oil and Gas Commission
1/04 Sarah resigns from the Oil and Gas Commission
1/05 Molly and Mike Wooten separate.
4/11/05 Molly files for divorce. judge grants a Domestic Violence Protection Order against Mike. Also the same day, Chuck Heath phoned police to inform them about the DVPO. Then police speak with Molly. She said Mike had threatened to shoot Chuck if he hired an attorney to help in her divorce
12/05 Track and his friends vandalize school buses.
2/08 Sarah and McCain meet for the first time
4/18/08 Trig is supposedly born
7/11/08 Sarah fires Walt Monegan
8/27/08 Sarah visits John McCain at his home in Sedona
8/29/08 McCain announces Sarah as his running mate
9/1/08 Sarah announces Bristol is pregnant and will marry the baby's father Levi Johnston
9/3/08 Sarah delivers her acceptance speech at the RNC Convention in St. Paul
9/19/08 Todd ignores the subpoena.
10/2/08 Sarah debates Joe Biden.
10/4/08 Sarah attacks Barack Obama at a rally in Carson CA, she states that Barack Obama is not a man who sees America as you see it
10/10/08 the Branchflower Report, in which investigator Stephen Branchflower found that firing Monegan "was a proper and lawful exercise of her constitutional and statutory authority," but that Palin abused her power as governor and violated the state's Executive Branch Ethics Act when her office pressured Monegan to fire Wooten
10/18/08 Sarah appears on SNL.
11/3/08 the bi-partisan Alaska State Personnel Board released the findings of its own investigation which concluded that Palin did not violate any ethics laws.
11/3/08 Sarah releases letter from Dr. Cathy Baldwin Johnson stating she gave birth to five kids.
11/4/08 Election Day Barack Obama defeats John McCain for president. Sarah tries to deliver a concession speech but is rejected by McCain's staff.
11/5/08 Sarah returns to Alaska.
12/27/08 Bristol gives birth to Tripp Easton Mitchell Johnston She and Levi break up shortly after
1/19/09 Sarah appears on Glenn Beck's show on FOX stating she would support Barack Obama
1/20/09 Barack Obama is sworn in as the 44th President of the United States.
1/31/09 Sarah tries to confront President Obama at the Alfalfa Dinner
7/3/09 Sarah announces her resignation in Wasilla.
7/26/09 Sarah officially resigns as governor of Alaska.
7/27/09 SarahPac is formed.
8/2009 Sarah coins the term "death panel” This wins Politifact's Lie of the Year.
9/18/09 Todd quits BP.
11/18/09 Sarah begins the Going Rogue book tour in Grand Rapids MI
11/19/09 In IN Sarah leaves a book signing with 300 people in line. She apologizes via Facebook.
11/20/09 Sarah is in OH for the book tour.
11/21/09 is in PA and NY for the book tour.
11/22/09 is in VA for the book tour.
11/23/09 is at Fort Bragg NC and Birmingham AL for the book tour.
11/24/09 Wraps up book tour in Orlando
12/12/09 Willow and her friends break into the Morlocks empty home, have a wild booze and sex party and vandalize the place.
12/13/09 The Morlocks report the damage to the police.
12/14/09 Sarah Todd Trig go to Hawaii.
12/17/13 Sarah, Todd, and Trig return to Alaska. She said she cut the trip short due to paparazzi.
2/6/10 Sarah appears at the inaugural Tea Party convention in Nashville with notes written on her hand.
3/10 Sarah begins production of Sarah Palin's Alaska.
3/10/10 Sarah, Willow and their entourage arrive at an Oscar swag suite and cleaned the place out
3/23/10 Sarah puts her crosshairs map on her Facebook page.
5/4/10 Sarah, Todd and Piper attend the Time 100 Gala in NYC.
6/25/10 Sarah gives speech at Cal State Stanislaus, says Ronald Reagan went to college in CA when it was IL
8/1/10 Sarah says Obama does not have the cajones to go after illegal immigrants even though he has deported more illegals than his predecessor.
8/8/10. Sarah, Todd and Bristol get into it with Homer teacher Kathleen Gustafson during filming of SPA.
8/17/10 Todd tries to bully a traveler at the Valdez airport who tried to take a picture of Sarah.
11/14/10 Willow calls her classmate a "faggot" on HIS Facebook page after he criticized SPA.
11/24/10 During an interview with Glenn Beck Sarah says we need to stand by our North Korea allies.
12/01/10 SPHASH's blog is launched therefore being a perpetual pain in the ass to the Palins and Heaths.
1/8/11 Jared Loughner opens fire in Tucson AZ wounding AZ Dem Rep Gabby Giffords, killing seven people including nine year old Christina Taylor Green
1/12/11 Sarah makes her blood libel comment.
3/11 Sarah and Todd tour India and Israel.
4/30/11 Sarah attends the White House Correspondence Dinner
5/1/11 Bin Laden is killed by Navy Seals.
5/2/11 Sarah begrudgingly thanks President Obama for finding bin Laden.
5/11 Sarah and Todd attend Tracks wedding to Britta Hanson.
5/29/11 Sarah starts her bus tour by hijacking Rolling Thunder rally benefiting veterans.
6/2/11 says Paul Revere warned the British when he was actually warned the colonists.
6/5/11 Sarah tells Chris Wallace on FOX that she didn't get Paul Revere screwed up and that she does know her American History.
6/22/11 Sarah quits one nation bus tour.
8/6/11 Track and Britta become parents to daughter Kyla Grace.
9/5/11 Sarah speaks at Tea Party Express Rally in Manchester NH.
10/5/11 Sarah announces she will not run for president.
10/24/12 Sarah slams Obama using the term shuck and jive.
10/25/12 Sarah defends her use of the term shuck and jive. 11/06/12 President Obama is reelected president. Sarah goes ape shit on FOX.
11/12 Track and Britta divorce
1/20/13 Obama is sworn in for a 2nd term.
02/12/13 Sarah and Todd attend Chris Kyle's funeral at Texas Stadium
3/16/13 Sarah speaks at C-PAC and drinks a Big Gulp
4/27/13 Sarah calls the White House Correspondence Dinner a nerd prom even though she attended the event in 2011
7/8/13 Sarah announces she is contemplating a run for Senate
01/17/14 Sarah accuses Obama of playing the race card on MLK Jr day
The Palins are actually doing something charitable?
From Sarah's Fecebook page:
It's almost IRON DOG time! This is one of the busiest times of the year for us with lots of guys wrenching in the shop and training on the trails and frozen rivers. Todd and his partner are full speed ahead gearing up for the world’s longest and toughest snowmachine race traversing over 2,000 miles of frozen Alaska.
This year we’re very excited that Todd’s SkiDoo team and three other teams riding SkiDoo are racing for a very worthy cause! They’re launching the “Bring Home the Pink” campaign to raise money and awareness in the fight against breast cancer. All the money goes directly to help women in need. In fact, they’re working with Breast Cancer Focus, an Alaska-based organization run entirely by volunteers, in order to ensure that the donations go to fund efforts that will directly help women.
Apparently this charity is legit, however it has not been around very long.
So how much is it in for Todd and Sarah? I bet 99%.
Blanche Kallstrom
Blanche Kallstrom is Todd Palin's mother. She is a real piece of work. Read below:
From Case Law
KALLSTROM v. UNITED STATES
Blanche KALLSTROM, Appellant, v. UNITED STATES of America, Appellee.
No. S-9332.
-- March 15, 2002
Before: FABE, Chief Justice, MATTHEWS, EASTAUGH, BRYNER, and CARPENETI, Justices.
Kristen D. Pettersen, Mauri Long, and Ray R. Brown, Dillon & Findley, Anchorage, for Appellant.Kenneth S. Roosa, Assistant United States Attorney, and Robert C. Bundy, United States Attorney, Anchorage, for Appellee.
OPINION
I. INTRODUCTION
We accepted certification in this case to decide whether a Negligent Infliction of Emotional Distress (NIED) cause of action exists under Alaska law for a plaintiff who becomes a participant in the infliction of another's injuries through the negligence of the defendant. Because we think that such an extension is inadvisable, we hold that an NIED claim is not available to such an “unwitting instrument.”
II. FACTS1 AND PROCEEDINGS
On November 27, 1993, Blanche Kallstrom and other members of the public attended a social function and dance at Jake's Place, an alcohol abuse transitional care facility in Dillingham. The lights at the facility had been dimmed for the dance. Non-alcoholic drinks were available to guests in the kitchen area adjacent to the dance floor. During the dance, Kallstrom went to the kitchen at the request of her young cousin to get a drink for nine-year-old Lori Dee Wilson. Kallstrom poured a drink from a pitcher sitting on the counter which she believed to contain fruit juice and gave it to Lori Dee. In fact, the pitcher contained a lye-based caustic detergent that caused severe, permanent internal injuries to Lori Dee when she drank it.
Kallstrom was not related to Lori Dee, but was friendly with Lori Dee and her mother and would see them every two to three months in Kallstrom's store. As a result of her mistake, Kallstrom claims that she sustained severe shock and emotional distress that has persisted in the months following the tragic incident.
Marilyn Wilson, Lori Dee's mother, on her own behalf and as guardian of Lori Dee, filed a complaint in federal court against the United States for negligence. Although Kallstrom was not named as a defendant by Wilson, the government brought a third-party complaint against her for negligence, seeking an allocation of fault. Kallstrom then filed a counterclaim against the government for her injuries allegedly caused by the government's negligence.
The federal district court granted summary judgment in favor of Lori Dee and against the government, concluding that it was negligent as a matter of law to allow an employee or resident of the facility to leave the caustic detergent in the pitcher near the sink. Wilson then settled her claim against the government and her claims were dismissed. The government dismissed its third-party claim against Kallstrom for an allocation of fault, leaving only Kallstrom's counterclaim against the government.
Kallstrom next moved for partial summary judgment against the government on her claim, and the government moved to dismiss Kallstrom's claim for failure to state a claim for relief for NIED under Alaska law. The district court granted the government's motion to dismiss and denied Kallstrom's motion for partial summary judgment.
Kallstrom then appealed to the Ninth Circuit Court of Appeals. The court of appeals certified this question to the Alaska Supreme Court pursuant to Rule 407(a) of the Alaska Rules of Appellate Procedure 2 because, as it noted, the facts of this case are not directly addressed by Alaska case law.3 Specifically, the court of appeals asks:
Whether a plaintiff, who has not suffered physical injury, may recover damages for the negligent infliction of emotional distress when the plaintiff, without any negligence on her part, becomes the unwitting instrument through which the defendant, because of its negligence, causes injury to an innocent victim.[4 ]
We agreed to accept certification and now answer the question certified to us.
III. STANDARD OF REVIEW
A decision by this court to accept a certified question from another court under Appellate Rule 407(a) involves determinative questions of Alaska law for which there is no controlling precedent. Therefore, we exercise our independent judgment and select the rule of law that is most persuasive in light of precedent, reason, and policy.5
IV. DISCUSSION
A. Kallstrom Does Not Have a Claim for Emotional Distress under Established Alaska Law.
There are two causes of action under current Alaska law that may permit some unwitting instruments who do not suffer physical injury to recover for their emotional distress: Negligent Infliction of Emotional Distress and Intentional Infliction of Emotional Distress. However, neither one is available in Kallstrom's specific situation.
1. Negligent Infliction of Emotional Distress
Persons in Alaska can recover for the emotional distress that they suffer under limited circumstances. Generally, damages are not awarded for NIED in the absence of physical injury.6 However, there are two established exceptions to that rule in Alaska. The Ninth Circuit properly found that neither of the two established exceptions to the requirement of physical injury permits a claim for NIED by Kallstrom.7
a. The bystander exception
The first exception to the physical injury requirement involves those properly characterized as “bystanders” under the three-part test in Dillon v. Legg.8 The test, which is used to determine whether the risk of harm to the plaintiff was reasonably foreseeable, requires that: (1) the plaintiff is located near the scene of the accident, (2) the shock results from a direct emotional impact from the sensory and contemporaneous observance of the accident, and (3) a close relationship exists between plaintiff and victim.9
Alaska courts have taken a liberal approach in applying the Dillon factors.10 In Tommy's Elbow Room, Inc. v. Kavorkian, we considered a NIED claim by a father who observed his severely injured daughter a few minutes after she had been hit by a drunk driver. Even though the father did not contemporaneously observe the accident itself, as required under a strict reading of the Dillon factors, we held that recovery was still available.11
But we have not yet taken a similarly liberal approach to the third requirement of a “close relationship.” In Alaska, this relationship has always involved a blood relationship between plaintiff and victim.12 Other states that have expanded the “close relationship” requirement have been very cautious to expand beyond a victim's immediate family, if they have done so at all.13
Even if Alaska's liberal interpretation of Dillon applied to the “close relationship” requirement, it would not encompass Kallstrom. She has no blood relation to the victim and had only passing involvement with the victim prior to the night of the injury, so such extension is unwarranted. Kallstrom cannot recover under the bystander theory.
b. The preexisting duty exception
The second exception to the requirement of physical injury arises when the defendant owes the plaintiff a preexisting duty, as recognized in Chizmar v. Mackie.14 If such preexisting duty exists, then the potential emotional distress to the particular plaintiff is considered sufficiently foreseeable to permit recovery. A defendant must stand in either a fiduciary or contractual relationship with the plaintiff in order to create such a preexisting duty.15
The preexisting duty exception does not apply to Kallstrom either, since the relationship between her and the government was neither contractual nor fiduciary. Kallstrom could only claim that defendant owed her the same general duty of care owed to all other members of the public. Such a duty is not specific enough to meet the requirements of Chizmar.
2. Intentional Infliction of Emotional Distress (IIED)
Another cause of action is available to those who suffer emotional distress without accompanying physical injury-IIED. This cause of action differs from NIED in that the plaintiff must show that the defendant's actions leading to the complained of emotional distress were intentional, outrageous, or reckless and extreme.16 It does not appear that Kallstrom has made such a claim in this case.
B. We Decline To Extend a Claim for NIED to Unwitting Instruments.
The Ninth Circuit asks whether we would permit an unwitting instrument exception to the limitation on claims of NIED in the absence of physical injury. For the reasons discussed below, we decline to add such an exception.
1. This issue is not clearly resolved by existing precedent.
The government contends that we have given sufficient treatment to the policy considerations surrounding NIED claims and stated the law clearly in Chizmar and M.A. v. United States.17 It argues that the two exceptions noted in those cases (bystander, preexisting duty) were intended to be the only such exceptions available for claims of NIED unaccompanied by physical injury, so the mere consideration of an additional exception in this case is excluded by well-established case law.
There are two reasons why we find that existing cases are not meant to cover the entire field and preclude further consideration. First, the government's argument relies on an absolute reading of the specific language of Chizmar, which the government reads as limiting recovery for NIED without physical injury only to those owed a preexisting duty. However, our decision in that case later recognizes that the requirement of a preexisting duty is not absolute: “Our holding today does not modify the requirements for ‘bystander’ recovery.” 18
Second, the government's reading of Chizmar and M.A. is inconsistent with decisions subsequent to those cases. In two other cases, Hawks v. State, Department of Public Safety19 and Karen L. v. State, Department of Health & Social Services,20 we considered whether new factual situations merited imposition of a duty under NIED despite the fact that there was no preexisting duty between the parties. The government's own brief acknowledges that Chizmar has not rendered policy analysis irrelevant in new NIED cases, but only that it is of “limited applicability.”
Although additional exceptions to the prohibition of claims for NIED in the absence of physical injury will not be easily established, we clarify that our decisions in Chizmar and M.A. do not completely preclude consideration of such extensions in the future.
2. Plaintiffs in the “participant” or “unwitting instrument” scenario vary so widely that we decline to recognize an exception for them.
The bystander and preexisting duty exceptions permit recovery for NIED in the absence of physical injury because they “represent isolated situations where courts have found that the special circumstances surrounding a claim for emotional damages serve as a sufficient guarantee that the claim is neither false nor insubstantial.” 21 We do not think that such certainty arises in the case of an unwitting instrument. Factual circumstances creating the participant or unwitting instrument scenario can vary so widely that such a characterization adds very little to the claim.
When deciding whether a novel action for negligence can be maintained under the common law, we consider whether a duty exists.22 “ ‘Duty’ is not sacrosanct in itself, but is only an expression of the sum total of those considerations of policy which lead the law to say that the particular plaintiff is entitled to protection.” 23 We apply the factors recognized in D.S.W. v. Fairbanks North Star School District24 to determine whether an actionable duty of care exists when the facts under consideration are not covered by statute, regulation, contract, or case law.25
In the present case, Kallstrom proposes that we recognize a duty of due care to protect “unwitting instruments” from emotional harm. But such a duty would run afoul of D.S.W.'s first and most important factor, foreseeability of harm to the plaintiff.
We can imagine a potentially endless variety of factual circumstances that may give rise to an unwitting instrument claim: the friend who mails a defective toy to a child who later chokes on a small part of the toy, the owner who lends his car to a friend unaware that the car has faulty brakes, the cook whose customers develop a disease ten years after he served them food containing a carcinogenic preservative, and the driver who sues parents for negligent supervision after hitting a child who chases a ball into the street. Although all might be labeled “unwitting instruments,” these scenarios vary widely with regard to the relevant considerations of duty, including foreseeability, certainty of injury, and ability to prevent future harm.
The cases cited by both parties also offer a variety of factual circumstances and legal outcomes that confirm our conclusion that unwitting instruments are a diverse group. In Kately v. Wilkinson,26 a mother was allowed compensation for her claims of emotional distress resulting from witnessing the death of her daughter's friend as she waterskied behind the defective boat that the mother was driving. Similarly, in Althoff v. Consolidated Rail Corp.,27 the court permitted a claim of emotional distress by the operator of a defective crane that dropped a wood timber and killed a bystander. However, in Straub v. Fisher & Paykel Health Care,28 the court denied a respiratory therapist's claims of emotional distress after witnessing a defective ventilator kill a patient. Other cases that we have found show a similar variance.29
The parties attempt to distinguish cases reaching opposing outcomes by claiming that they are based on alternate legal causes (product liability or employer's liability) or that related aspects of the ruling state's common law differs in some significant way. Regardless, these divergent opinions make clear that it cannot be said with regard to the unwitting instrument, as Professor Prosser has said with regard to the bystander exception, that “[a]ll ordinary human feelings are in favor of [an] action against the negligent defendant.” 30
Viewing these cases as a class of “unwitting instrument” situations, we find that the relationship between the plaintiff and the victim, the nature of the participant's involvement, and the uncertain mix of potential emotions, including guilt, shock or indifference, fall well short of creating the same “compelling proposition” that led the court in Dillon to allow recovery for a mother who witnesses the infliction of death or injury to her child.31
In particular, an unwitting instrument might be expected to feel very different depending on the nature of the person's instrumentality. For example, one instrument may be the exclusive cause of injury while another may be only a contributing or partial cause. Even more important is the type of action giving rise to an unwitting instrument; one unwitting instrument may exercise discretion or choice of action in the role as instrument while another's involvement may be completely involuntary and unthinking. Each difference will contribute in important ways to the plaintiff's feelings of guilt and will control the emotional distress.
Our existing exceptions to the NIED rule's requirement of physical injury define combinations of factors that we consider to be useful and reliable in identifying claims involving foreseeable danger of serious emotional harm-factors such as physical or temporal proximity of the plaintiff to the infliction of the victim's injury and the relationship between the participant and the victim. But we do not think that the broad range of situations encompassed by the term “unwitting instrument” would be useful in the same way.
Kallstrom's case is compelling because she comes close to so many of the relevant factors for establishing NIED in the absence of physical injury. However, she fails to plead an existing cause of action because her personal relationship to Lori Dee is not close enough and the government owed her no preexisting duty. Yet even assuming that the other requirements of the bystander exception remained, we would decline to accept unwitting instrument status-that is, mere innocent presence in the causal chain-as a substitute for the existing requirement of close personal relationship. Such a factor is so variable that it does not meaningfully distinguish between claims that should be allowed and those that should not.
V. CONCLUSION
We hold that a claim of NIED in the absence of physical injury is not available to a plaintiff solely because she or he is made the unwitting instrument of death or serious injury to another through the negligence of the defendant.
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