Lê Sáng develop Vovinam. In 1954, Le Sang accompanied Nguyễn Lộc to Saigon to open a Vovinam school. He opened additional Vovinam schools, and as of 2007, was still teaching the higher-ranked students. In 1960, Nguyễn Lộc passed the leadership of Vovinam to Le Sang. After the fall of Saigon he spent several periods in prison. Leadership passed to Trần Huy Phong (1938-1997). He was born in Hanoi, Vietnam and died in Saigon. Lê Sáng Lê Sáng (1920 – September 27, 2010) was the Chairman of the Vovinam Vietnamese Martial Arts World Federation, a position he held from 1960 until his death.
Martial law in the United States Civil Rights Movement, but these acts are not tantamount to a declaration of martial law. The distinction must be made as clear as that between martial law and military justice: deployment of troops does not necessarily mean that the civil courts cannot function, and that is one of the keys, as the Supreme Court noted, to martial law. In United States law, martial law is limited by several court decisions that were handed down between the American Civil War and World War II. In 1878, Congress passed the Posse Comitatus Act, which forbids military involvement in domestic law enforcement without