Explain why the phrase "by ordinary means" was added to the Law of Conservation of Energy

it's state that energy naither be created nor be destroyed

both the fifth and fourteenth amendments of the united states contain a due process clause. while the fifth amendment describes a legal obligation of the federal government to not deprived of life, liberty or property without due process of law, the fourteenth amendment applies the same obligation to the states to guarantee that all of the states provide fair procedures as well.