The Scoop on DirtJones (2006) believes that soil microbes are critical to soil maintenance. These microbes have multiple functions in soil. Jones notes that soil microbes are critical in carbon recycling. Soil apparently contains twice as much carbon as the atmosphere. These microbes help bind carbon in the soil, which in return helps maintain soil structure. Without carbon, the soil would break down, making it nearly impossible for plants to thrive and for microbes and other soil-living organisms to exist in such an environment. Water and air would be limited and this would affect overall soil health. Microbes play a critical role in recycling dead animal and plant matter (Jones, 2006). Without these microbes and their critical function, no dead or leafless animal or plant would ever decompose. This would lead to an accumulation of plants and animals which would lead to waste in the environment. The function of microbes on dead plant and animal matter leads to the conversion of intrinsic nutrients, which in return build the soil and thus complete the nutritional cycle (Ashman and Puri, 2002). Research by Kertesz and Mirleau (2004) indicates that microbes are essential in binding sulfur to carbon in the soil to form inorganic sulfate. This is followed by microbes conducting rapid immobilization of this sulfate to form sulfate esters and carbon-bound sulfur. While research has yet to identify any particular microbial species responsible for sulfur conversion and recycling, evidence indicates that the rate of sulfur conversion depends on the number of microbes in the soil and their rate of metabolism. The Fifth Amendment and uncompensated hiring. ..... half of the paper ...... Ferrous Land Use, Planning and Management: Creating Sustainable Communities, Watersheds and Ecosystems – 2nd Edition. Island Press: Washington. ISBN 1-59726-730-9. Scherer, D. (1990). Upstream/Downstream: environmental ethical issues. Philadelphia: Temple University Press.Stop the Beach Renourishment Inc. v. Florida Department of Environmental Protection. (2014). The Oyez project as IIT Chicago-Kent College of Law. Retrieved May 28, 2014, from http://www.oyez.org/cases/2000-2009/2009/2009_08_1151Sulzman, E. W. (2000). Understanding Global Change: Earth Science and Human Impacts - The Carbon Cycle. Global Change Instruction Program - University Society for Atmospheric Research: Boulder, CO. Treanor, W. M. (1985). The origins and original meaning of the fair compensation clause of the Fifth Amendment. Georgetown: Georgetown University Law Center.