Land Law Cases Analysis

Land Law Cases Analysis Kingsnorth Finance v Tizard [1986] 1 WLR 783 Mr and Mrs Tizard owned a matrimonial home on unregistered land. Mrs Tizard had contributed to it although it was in Mr Tizard’s name. Due to the breakdown of the matrimony Mrs Tizard spent time away from the home but returning daily to care for their children and to prepare herself for work and so often spending nights there to care for the children and leaving clothes at the property. Mr Tizard obtained a loan to which it was thought that the property was solely occupied by him and his children. Mr Tizard informing the surveyor that he and his wife were separated and that she was living outside of the property with someone else. The loan was consequently granted and Mr Tiazrd defaulted. The lenders sought to enforce the charge and the question was whether his wife’s equitable interest was defeated. This depended on whether the lender had actual or constructive notice of her rights. It was held that the plaintiff lender did have constructive notice of the wife’s rights. Their agent, the surveyor had been aware that a wife existed even through having been told the applicant was single and should have informed the lender of these contradictory facts. Given the wife’s confirmed existence further investigations should have been carried out by the plaintiffs. The occupation of the children in the house should have further alerted the surveyor as to possible occupation by their mother; Mr Tizard’s wife. Since the plaintiffs should have carried out further investigations as to the matters, they had constructive notice of the wife’s rights. Further, the fact that the inspection had been prearranged did not, in these circumstances, amount to a reasonable inspection. Caunce v Caunce [1969]1 WLR 286 A and B, intended to buy a property as a matrimonial home. It was agreed that a mortgage would be acquired in B’s name and that the property would be conveyed into their joint names. B contributed  £479.00 towards the cost of the property. But in breach of the agreement A obtained a conveyance of the property into his sole name. Without B’s knowledge A effect legal charges in favour of the bank to secure the amount lent to him. A became bankrupt and B commenced proceedings claiming that she had an equitable interest in the property and so that she was entitled to such interest free from the claims both of A’s trustee in bankruptcy and of the bank. The bank as mortgagee issued a summons seeking possession of the property. B claimed that A had held the house on trust for herself and the banks, also that the banks’ mortgages were charged only against the husband’s beneficial interest and that her interest had prior over that of the banks. She further claimed that the bankers had had constructive notice of her equitable interest in her property as she had held an account with them. It was held that the bank took free charge of her interest unless they had constructive notice of it. An enquiry into the wife’s account was not an enquiry the bank ought reasonably to have made and so there were no special facts which should have brought her interest to their attention. Mortgages were not affected with equitable interest of people residing in their property where that residence was not inconsistent with the title offered as security. They were not fixed with contrastive notice by failure to enquire. The mere fact of it being a matrimonial home did not raise a need to enquire; therefore, B’s interest was not free from the legal charge. In older cases the problem had mainly been that that the occupier, usually a wife with a beneficial interest in the family home, had been living with the registered proprietor in circumstances which are not indicative of any hostile claim. But in cases of unregistered land Stamp J in Caunce held that there would not be constructive notice of such a wife’s interests. In Williams Glyn Bank v Boland[1], the House of Lords faced similar facts in registered land. Lord Wilberforce was explicit in rejecting the relevance of the doctrine of notice. He was derisive as to the suggestion that a spouse may be subject to special rules and rejected the suggestions that actual occupation excludes occupation that is consistent with the mortgagor’s title. This test would be difficult to apply in modern circumstances as wives and other occupiers are likely to have proprietary interests. But two things must be distinguished; the first is in regards to a person who is living on land in circumstances illustrated in Caunce and Boland. That person cannot be denied to be in actual occupation in accordance with the interpretation of Stamp J: â€Å"If there is actual occupation, and the occupier had rights, the purchaser takes subject to them†¦..no further element is material.† Stamp J holding favour of the bank, also based his decision on the fact that it was quite unreasonable to expect a bank to make enquiries beyond the legal owner of the property, taking the view that;[2] â€Å"it is not in the public interest that the bank mortgages should be snoopers and busybodies in wholly normal transactions of mortgage.†[3] The courts have already concluded that where there is doubt as to whether there was actual occupation then it is looked to the question of whether the occupation would have been obvious to a purchaser.[4] Turning to Tizard, Judge Finaly QC was clear that there was actual occupation as the Boland test was applied even though the fats concerned unregistered land. Although the Mrs Tizard was no longer living there, her daily activities must be regarded sufficient to justify the result. Concluding The case law involving both unregistered and registered land before the 2002 Act suggests that proper enquiries were considered necessary. The leading authority in respect of unregistered land was Caunce where it was thought that notice of the presence of the wife did not of itself give the bank notice of her interest in the property. But in Tizard it was decided that the mortgagee may be fixed with notice of the co-owners interest by her actual occupation. In Tizard it was held that the bank did have constructive knowledge because the inspection took place on a Sunday in dubious circumstances.So far as registered land is concerned it will be a rare case where the beneficiary will both be in actual occupation and unaware of the banks charge. However, there may still be cases where the lender is ignorant of the beneficiarys interest. The Law Commission recommended[5] that occupation of the beneficiary claiming a beneficial interest should have been apparent on reasonably careful inspe ction and this recommendation has now been incorporated in Schedule 3 of the Land Registration Act 2002 in respect of registered dispositions. As emphasised by the Law Commission it was knowledge of the occupation that was important not knowledge of the interest claimed.In conclusion, the law as enacted in the 2002 Act combined with the cases since Boland[6] gives the lender a high degree of protection. Banks are likely to make standard enquiries and any failure to disclose will enable them to take free of the beneficiarys interest where, for example, a wife knows that her husband is charging the property. There may still be exceptional cases where the wife neither knew nor ought to have known of the husbands charge over the property or where the wife is in occupation through an agent[7] whose relationship to her is not obvious to an outsider. However, those cases are likely to remain rare. Considering the facts of these cases from a modern perspective; the problem here is the matter of presumption as well as occupation. The operation of presumptions in English law is problematic. There are situations established by case law in which is it presumed that the transfer of property manifests an intention to create a gift of that property. The two most usually cases are the transfer of property from father to child and from husband to wife. So the use of presumption in society today is questionable. There is no logic behind the reasoning that a presumption may exist behind the transfer between father and child if the transfer may not necessarily exist between mother and child. In the times when presumptions were created it would thought natural for the court to assume that a man would be obliged to provide for his wife and children. So it was presumed that a transfer of property to a wife or child was thought to be part of his obligation to maintain them. Yet this presumptio n did not exist between a wife and her husband as it was thought that women did not usually have a property of their own. At this time husbands and wives were thought to be one person[8]as the wife was merely â€Å"the shadow of her husband†.[9] Caunce very much reflects an era where women were considered to rarely own property of their own and were not often thought of as earning incomes and so were reliant on either their husbands or fathers. The presumption of advancement between husband and wife belonged to era were men were expected to look after women for the above reasons. It was only with Caunce, in 1969, that wives were finally accepted by English law as not being solely shadows of their husbands. This meant that for the first time women were entitled to have separate rights to property outside of the rights of their husbands. In 1970 with the influence of Lord Reid in his enlightened approach to rights of spouses in the matrimonial home, Pettitt v Pettitt[10] considered for the first time all the circumstances in recognising the existence of rights in the home, even at a time when women were not considered to have rights independent of their husbands. The matter of the juxtaposition of a women’s role in society and so her influence upon mortgage transactions due to her possible proprietary rights in property is not the sole principle to be considered in the light of these two cases. Due to the bench mark decision of Boland it was accepted that the restrictive approach taken in Caunce was no longer applicable and the ambit of reasonable enquiries extended to making enquiries of all occupiers of the property, despite the vendor also being in occupation.[11] The full extent of the purchaser’s task, considered in Tizard meant that the idea of investigations into all occupants of the household was now embraced. This meant that recognition was given to those living within a household living with the legal owner of the house may have rights deserving of protection when the property is mortgaged without their consent. Reference list Journals Hanbury, W., Overriding Interests under the Land Registration Act, 2002 – the Lender’s Perspective, 2005. 3 EMIS Property Service. Shea, T., Overriding Interests in Unregistered Land. Journal of International Banking Law. 1 (2), 125 – 127 Thompson, M.P., The Purchaser as Private Detective, 1986. Conveyancer and Property Lawyer, July – August 283 – 28 Bibliography Hudson, A., Equity and Trusts, 2004. Third Edition. Cavendish Publishing, London. Pearce, R Stevens, J., The Law of Trusts and Equitable Obligations, 2002, Third Edition. Butterworths, London. Smith, R. J., Property Law, 2003, Fourth Edition. Longman, London. Thompson, M. p., Modern Land Law, 2003. Second Edition. Oxford University Press Footnotes [1] (1981) AC 487; (1979) Ch 312 [2] Thompson, M. p., Modern Land Law at page 53 [3] Caunce v Caunce [1969]1 WLR 286 at 294 [4] Analysis of Mustill LJ in Lloyds Bank v Rosset (1989) Ch 350 [5] In â€Å"Land Registration for the 21st Century† (Law Com 254). [6] Ibid 1 [7] Per Lord Oliver in Abbey National BS v Cann (1991) 1 AC 56 [8] Hudson, A., Equity and Trusts at page 318 [9] Ibid 3 [10] (1970) AC 777 [11] Midland Bank Ltd v Farmpride Hatcheries Ltd (1981) 2 EGLR 147

Effective adjustment to a new environment Essay

Adjusting to College Welcome to college! Attending college is one of the first major life transitions for many young adults. Some students are excited to take on the new experiences of campus life, while others feel apprehensive about making this change. Regardless of your outlook when beginning your first year of college, you may benefit from talking with others who have already made that transition. Making the Transition What are some of the most common changes you can expect in the first year on campus? †¢ New environment and relationships. First year students must adapt to an unfamiliar environment, adjust to different living arrangements, and develop new relationships. Living with roommates may be the first ‘test’ freshmen experience. Students face the challenge of adjusting to roommates who may have very different boundaries and individual needs than family and friends from home. Roommates may or may not develop close friendships, but communication and compromise can build a smoother transition. College brings a unique opportunity to interact and live with students from various backgrounds and cultures. Expanding your worldview by learning about each other’s differences and similarities will likely enhance your college experience. †¢ Greater personal freedom. Living on your own for the first time means that you will gain independence and take charge of the many choices and decisions that your parents and teachers made for you in the past. While this new found freedom can be exciting, it may also feel overwhelming and less predictable than what you are accustomed to. The freedom to manage your daily life is a learning process, but one that can be very satisfying. †¢ Added responsibility. First-year students must manage the important daily responsibilities that accompany their increased personal freedom. Students must manage basic tasks such as eating, sleeping, exercising, and going to class. New students must also address more complex responsibilities such as balancing studying and socializing, participating in clubs and activities, and handling finances. Managing time is a demand  that all first-year students experience. A typical day in college is less structured than high school, and there is more reading and studying that is required outside of class. Some students may feel as if they have no free time to do anything but schoolwork, while others feel like they have too much free time outside of the classroom. †¢ Changing relationships. While there are many changes occurring in your new campus life, there will also be changes in your relationships. New students often face challenges such as best friends going to other universities, beginning new romantic relationships or maintaining existing ones, and juggling newly formed relationships with already established ones. Students must balance a sense of connectedness and separation while at college. Some freshmen feel the need to call or e-mail home several times a week in the first few months away, while others require less frequent communication with their family and friends. Common Stressors The first year of college is a new and exciting adventure, but one that may come with a few challenges along the way. What are some of the most common stressors that first-year students experience? †¢ Time Management. Now that you are in college, there are no more eight hour school days like those in many high schools. You may have class for six, three, or even zero hours a day. The rest of your time must be negotiated between homework, clubs and activities, work, socializing, and self-care. College students often feel as if there is just not enough time to do everything that needs to be done. Using a schedule and some organizational skills will help you to effectively manage your hectic and changing life. †¢ Academic Performance. By nature, college coursework is challenging, and it can be hard to keep up with the increased academic demands. Some students undergo pressure from both themselves and their parents. There may be requirements for scholarships and graduate school admission that you have not previously experienced. In order to manage the increased demands and expectations, it is important to attend class regularly, keep up with  readings and assignments, and ask for help when you need it. Professors and teaching assistants are there to assist you, and want you to succeed. If you need additional help, various organizations on campus offer tutoring services, many of which are free. Alpha Lambda Delta: Freshman Honor Society, Office of Minority Student Affairs, and University Residence Halls Academic Assistance are a few such services that offer tutoring at no cost. †¢ Roommate Conflict. Learning to live with someone new can be one of the most challenging aspects of going to college. Different living habits are the most common source of roommate conflict (i.e. neat vs. messy; quiet vs. noisy; early-to-bed vs. up-all-night). Failure to communicate your expectations about living together can lead to tension and eventually conflict. To avoid â€Å"roommate fallout† you should communicate your needs and expectations respectfully, while recognizing your own habits and quirks that might affect your relationship. If conflict does escalate you should take it to a Resident Advisor, Resident Director, or a Counselor to determine a course of action. †¢ Long Distance Dating Relationships. It is not uncommon for first-year students to begin college in a long distance dating relationship. Where at one time this relationship may have helped you cope with everyday stress, it could now be a source of distress due to the distance between you and your partner. Uncertainty in what the future holds for the relationship is one of the most common stressors experienced by college students in long distance dating relationships. There are a few key efforts that each partner can make to lessen the sting of separation. Verbal communication, openness, and assurance of one another can reduce stress associated with being separated. It is also essential for each partner to seek social support from others and remain active in their individual lives while apart. †¢ Body Image. Many college students also struggle with body image. Our culture pays a great deal of attention to the appearance of our bodies, particularly during young adulthood. Media representations of the ideal body, messages from peers, and other cultural factors shape what we perceive as â€Å"normal† or â€Å"good†. It can be difficult to have a clear, healthy  perspective on ourselves and our bodies when our culture sends so many confusing, conflicting, and sometimes unhealthy messages. This can be stressful at a time when many are trying to â€Å"fit in† with others and make new, exciting relationships. If you find yourself preoccupied with how you look or become distressed about your body, discussing your concerns and ideas with someone can be extremely helpful in creating, developing, and maintaining a body image that is healthful and fulfilling. Recommendations for First-Year College Students What steps can you take to have a great first year of college? †¢ Be patient. While campus may seem new and overwhelming for new students, it becomes more familiar with time. Refer to the many resources available to assist you in navigating your surroundings. Maps, your R.A., upper-level students, and the university Website are all useful tools to get you through the initial transition to campus. †¢ Connect with other students. If you talk to other students, you are likely to discover that they share similar questions and concerns. Your R.A. is an excellent person to go to when issues arise. She or he is equipped to help you solve problems and refer you to appropriate resources. †¢ Get involved. Student organizations are a fun way to interact with other students and faculty. Meeting people with similar interests and goals is an exciting way to make friends and participate in social activities. †¢ Utilize resources. There are numerous resources on campus designed to create a rewarding college experience. A range of offices and programs, such as cultural houses and the LGBTQ office, are offered to assist the diverse campus’s needs. In addition, there are numerous sources of support such as the Office of Dean of Students, the Counseling Center, the Career Center, your Academic Advisor, financial aid programs, and mentoring/tutoring programs offered to address various student needs. †¢ Care for yourself. The foundation for a productive college career is a healthy lifestyle. Take the necessary steps for nurturance, getting adequate rest, socializing, and physical activity. Campus Recreation offers several resources that students can utilize to work towards wellness. The ARC, CRCE, and the Wellness Center are just a few campus facilities that strive to promote healthy practices and to educate  the campus community on various health topics.

Utilization of Wind Energy

Energy is essential in all aspects of human life, this is the main reason why scientific inventions on energy are more recognized that inventions in other spheres. Upon discovery, there must be regular innovations to spice up the invention so that it does not run out market or become inefficient. This is what has led to major improvements on development of wind energy all over the world. This has been catalyzed by global efforts to reduce emission of green house gases; a vision 2030 project that is to be implemented throughout the world. Wind energy has come in the limelight after researches noted that it is most underutilized type of energy (Henderson-2003). This is because the developers have been focusing on the wrong directives; their focus was mainly on the demand and not the supply side. Even with innovations, investors have been reluctant to in funding of wind energy researches as there are many laws and policies around this sphere that can turn the venture unproductive economically. Wind energy is one of the renewable sources of energy that is currently in practical use in the developed countries; developing countries are also picking up the momentum. Just like the hydroelectric generation of power, where enormous water currents are used to rotate the large turbines that convert potential energy to kinetic energy, strong wind currents mostly found in the deserts, along coastlines and open plain areas are used to rotate the turbines suspended in open areas. This generates electricity by converting potential energy into kinetic energy. I decided to carry out a research on wind type of energy; this was in a bid to learn the steps that have been made so far, the loopholes in the steps and factors that are impeding the implementation of the wind energy across the world. The resources I used were mainly academic journals that talk about the whole process of setting up wind energy plants, the policies around the activity and also the steps most of the developing counties are taking towards achievement of their wind energy plans. The journals and articles I used were ones written from 1988 during a United Nations Environmental meeting; Paris COP21 to the ones written in 2018 when President Donald Trump reduced the chains on Environmental Policy Act in 2017. By learning these policies and logistics around them I was able to draw my own map to the road of reliance on wind energy to help ease the stress on the hydro-electric grids we have in the country. The policies that will help in implementation of my plans were also found in the journals, the appropriate modes of transmission and the stakeholders that play a critical role in the sector. The problems I faced when finding inference to the research is that most of them either lacked proper guidelines or lacked good recommendations hence could not be so useful. The reasons behind the researches and geographical areas they were taken in rendered some of the researches impractical. The questions that guided me through that whole process are; who are the stakeholders to team up? What are the policies for the transmission? When will the implementation begin? What is the timeline for setting up and maintaining of the whole transmission process?Goals and objectivesGoalsReduce green house emission from manufacturing companies by 16%Lower the cost of power supply Make wind energy a common preferenceRemedy power interruptions in manufacturing industries. The vision 2030 states that all countries should cut their carbon emissions by 30%. In my research I realized that it's the manufacturing companies that produce a large amount of this gas. Most of these companies are directed by the federal environmental protection agency to fit sieves that will filter carbon from their chimneys; lack of proper follow up by the agency has made them relax and I discovered that most of them have diesel powered generators to supplement the power interruptions they face. My wind energy is mainly customized to target manufacturing companies as primary consumers thus hasten the achievement of vision 2030.There has overreliance on the hydroelectric plants because there is a high demand of the end product in homes. This has led to public outcry due to regular interruptions and inconsistent supply. This projects aims to fit customized turbines for specific regions and hence give them a reliable option.ObjectivesImprove the current design of wind turbinesCarry out campaigns to sensitize the public on the use of wind energyDevelop an overlapping cycle of turbines that will maximize wind farms across the countryInduce the federal government to reduce the laws on implementation of wind projectsThe major improvement I want to put on the current turbines is to reduce their mass and size but affect their performance. The reason behind this is so that they can be able to fit on rooftops or even suspended at different heights on skyscrapers. The campaigns are aimed at sensitizing the masses about the projects benefits and educating them on the importance of it. Through that we will be lowering risks that come about when the turbines fall or even vandalism. The current turbine sizes are large hence occupy lot space during installation. I have developed turbine stand that can 3 turbines of different sizes to be fitted at different heights of the towers. This state of art of art innovation will help reduce overlapping that leads underperformance and underutilization of wind farms. There so many regulations and policies for stakeholders to pass through before initiating wind projects. The many agencies that overlook all the regulations require fees; this is one issue that has scared investors away. We plan to involve the government and make it reduce the regulations, the bodies that oversee it or the fees charged for turbine set up and maintenance. Policies and Problems in the wind energy sectorMotor noise; there has been an environmental concern that the turbines produce a lot of noise thus leading to severe headaches and sometimes depression in the residents around the farm. We plan to curb this by using the latest turbine models that are noise free.Destruction of the ecology system; this is attributed to the number of birds that are chopped by the blades. Most affected birds are bats, owls and eagles. This will be combated by making the edges of the blades blunt.Congestion on wind line; this is a problem I had touched on earlier and stated that our state of equipment will be used to counter it.Policies around this project are; state permitting, this is the first step that has to be met before setting of the off shore and in land turbines. This is one of the policies we plan to counter after starting as the permitting discrepancies between organizations leads to delay of the projects. Federal permitting; this will oversee the setting up and maintenance of inland turbines to make sure they are in line with the environmental laws.We see a positive impact in the society despite the inevitable changes. There will be satisfaction as the customers will be able to get electricity when they need it most. If the implementation takes place as planned then there will be lesser electricity interruptions as time goes by. There will be lesser diseases in the community; water borne and air borne diseases caused by harmful industry emissions and disposal.Strategies and resourcesAnalytical researches have claimed that installation and maintenance of wind energy power plants is expensive than all other types of energy. This claim forgot to mention that the benefits are perpetual as wind never expires. The high cost is not only attributed to set up capital but also the high fees charged by federal agencies if the turbines underperform. The design of our turbines is expected to be so efficient that our transmission company won't have to be subjected to the underperformance fees. Only the human and financial resources are fundamental in the set up stage of the project. Due to its huge implementation budget; I plan to call on board different stakeholders after proposing a comprehensive compensation plan for the funds they are going to pour on the project. Manufacturing companies are my main investor target as the plan will mainly benefit them, reaching out will be an easy task as I will use emails as my main communication mode. Having different stakeholders with different set of contacts will help us get federal environmental permits faster than if we were to do it alone. Collective bargaining of our force will make the state see the urgency and importance of the project. This whole project will be initiated by getting the state permits and environmental agency permits before reaching out to the investors. This is a plan to keep everything in check and reduce delay once the permitting process is done. We plan to carry out a site study to know the precise location of our times and the accurate number of turbines needed per site; this will reduce excess set up costs. Off shore and on shore sites will be studied concurrently. The original plan is that we set up a collection plant for our electricity before adding it to the national grid. This will help us in the maintenance and billing process, we hope to achieve more profits from this. Buying of all the essential equipments will follow the turbines, electricity transmission cables and storage devices. My team plans to use two manufacturers for the whole process, they will partly invest in us using seed money (manwell-2010). This is a good investment plan as it has reliable end users; we hope to bring the desired people on board. Benefits of this step are stretched towards fostering partnerships towards the attainment of sustainable development goals that are envisioned in the vision 2030 blueprint.Every business has a number of risks attached to it; the risks on our court are, theft of equipment at the installation site, pulling out of partners due to uncertainty and getting under qualified stuff to install the equipments. The plans we have to counter these are; hiring of professional security services to safeguard our equipment until the installation process is done. We plan to acquire a loan to supplement the money lost if an investor pulls out in the initial stages, this plan will help motivate the remaining members and thus reduce the risk of more pulling out after the project stalls abruptly. We will be deploying the services of a hiring farm to help us get professionals that will act as the human resource. We will be sure to seal and counter all seen and unseen risks to avoid disappointments and loses.Decision making process of this whole plan factored in the time, scope and cost. I knew that by bringing in different stakeholders to partner on it will reduce the implementation timeline and the cost that will arise from it. It would be easier convincing different stakeholders to channel in small amounts than getting to convince one investor to fund the whole project. The few limitations and lack of innovation also led me to choose now as the specific time to start. There are less wind energy transmission companies than there are hydroelectric transmission plants. I will stress on the societal management level as it is through it that we can bring on board more investors, shareholders and donors. I decided on this because our expansion plan will touch on civilian lives; we plan to convince farmers with large tracts of land to allow us install the turbine towers on their properties at a fee. Incentives we plan to use to effect this are providing electricity for them at lower rates and equipping if not build social libraries as our cooperate social responsibility.Environmental protection agency will oversee all our stages of the project to make sure we comply with all the regulations. We hope to not get interferences as wind energy posses' minor and controllable risks to the environment unlike other types of energy production. Our future goal will be increasing the number of turbines across all geographical areas so as to meet the ever rising demand of electricity. I will motivate my team to come up with other innovations to boost performance and not stick our turbines along congested coastal lines and rural areas alone. This will be in a bid to lower the greenhouse emissions from companies and later reduce the electricity cost.ReferencesAR Henderson 2003Offshore wind energy in Europe; a review of the state of artJF Manwell 2010Wind energy explained; theory, design and application

Health And The Focal Organizational Behavior - 3293 Words

In this team paper, our group’s focal organization is Legacy Health and the focal Organizational Behavior topic is Feedback. This paper will cover not only how this organization handles feedback and our recommendations to improve upon our findings, yet will cover the importance of feedback in the healthcare industry. In an attempt to understand how feedback is used at Legacy, three interviews were conducted and each interviewee was asked roughly the same questions. The findings of this research and the interviews have given insight into good practices and practices that need improvement within the organization of Legacy Health. Before understanding how Legacy Health handles feedback, it is important to understand what feedback is and how it is important to the healthcare industry. Feedback, as defined by the textbook, is â€Å"the degree to which people learn how effective they are being at work† (Bauer, 2014). This definition may seem vague, yet within the concept of feedback, are multiple ways for people to learn of their work efficacy. In an organization, feedback can come in various forms, whether on a performance based approach, a three hundred and sixty degree approach, goal setting and feedback upon the goals, or a multitude of other forms. In any industry, it is important for people to understand the efficacy of their work, yet in the healthcare industry feedback becomes a crucial component in patient safety. In an article in the journal Advances in PatientShow MoreRelatedUngar, M. (2010). Families as navigators and negotiators: Facilitating1385 Words   |  6 Pagesinto consideration make resilience more or less likely to occur. This article expands on the foundational concepts of strengthening family resilience by Froma Walsh (1998) (2006). 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