Category Archives: 5th Amendment

Before the Court: The Constitutionality of Life Without Parole Sentencing for Juvenile Murderers

Erin Brennan, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Erin Brennan, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

That is the question that is before the U.S. Supreme Court in cases being heard concurrently, Miller v. Alabama and Jackson v. Hobbs. The Supreme Court heard oral arguments on these cases on March 20, 2012. This issue has worked its way into the Supreme Court docket as a response to questions arising from a somewhat recent thread of cases including Roper v. Simmons and Graham v. Florida.

In Roper, the court looked at the constitutionality of the death penalty as a sentence for juveniles who were under the age of 18 when their crimes were committed[1]. The Court ultimately concluded in its 2005 decision that the death penalty for teenagers under the age of 18, was indeed, unconstitutional under the Eighth and Fourteenth Amendment.[2] The court relied on “the evolving standards of decency that mark the progress of a maturing society” in order to make a judgment in regards to which punishments reach the level of “cruel and unusual.”[3] The Court also looked to the fact that a majority of the states disallowed the death penalty for juveniles as indicia (evidence) of general societal views that juveniles are “categorically less culpable than the average criminal.”[4] As an illustration of this, in Justice Kennedy’s opinion, he indicated that “[t]he reality that juveniles still struggle to define their identity means it is less supportable to conclude that even a heinous crime committed by a juvenile is evidence of irretrievably depraved character.”[5]

Furthermore, the Court took this holding a step further in Graham. The Court, in that case, held that life sentences without parole are cruel and unusual under the Eighth Amendment in cases involving juvenile non-homicide offenders. The Supreme Court left unanswered the question of whether sentencing juveniles who committed murder to life without parole is permissible.

            The Court’s stance on this latest question could potentially affect over 2,000 prisoners who committed murder when they were under eighteen and are currently sentenced to life without parole.[6] However, 79 of these prisoners are imprisoned for crimes they committed when they were fourteen years of age or under, the ages of the defendants in Miller and Jackson.[7] Therefore, the repercussions of the Court’s decision could be felt by many more individuals if they broaden their holding to include those under eighteen years of age, or lessen its impact if the Court narrows its holding to preclude this sentence for those fourteen and younger.

            The Court will be facing a potentially difficult task in reaching a conclusion in this instance, as the Miller and Jackson cases present quite varied situations. The facts of the Miller case can be considered rather shocking. Evan Miller took part in (and arguably orchestrated) the killing of his middle-aged neighbor Cole Cannon in Alabama. Miller, fourteen at the time of the murder, and Colby Smith, his sixteen year old co-defendant, brutally beat Cannon in his trailer after attempting to rob him of approximately $300. The boys had already stolen a number of baseball cards from Cannon’s home earlier in the evening. The boys returned to Cannon’s trailer a short time after they left him to die, in order “to cover up the evidence” by setting the trailer on fire.[8] Cannon eventually died due to smoke inhalation from the fire.[9]

            On the other end of the spectrum, the Jackson case involves an arguably more sympathetic defendant. Kuntrell Jackson, also fourteen years old at the time, was charged with felony murder in the state of Arkansas.[10] Jackson did not shoot the victim, rather Jackson was with a group of boys when they robbed and shot a video store clerk with a sawed off shot-gun.[11]

            These two cases illustrate the wide variance of potential scenarios that could lead to a sentence of life without parole for a juvenile who is convicted of murder. It also raises questions about the mandatory nature of some of the states sentencing schemes. Currently, thirty-nine states allow sentences of life without parole for juveniles who commit murder.[12] Both Alabama and Arkansas, the states at issue in these cases, have mandatory requirements of sentences of life without parole for juveniles who are convicted of murder. In fact, around some 2/3 of states which permit life sentences without parole for juveniles require mandatory sentencing.[13]

            There is a good argument that mandatory sentences may also prevent the telling of the whole story involved with a case. If a person is automatically given the sentence of life without parole, it prevents the jury or the judge (whoever is carrying out sentencing) from considering relevant mitigating factors. For instance, just from reading the facts given above in the Miller case, a potential member of the jury may say to themselves it is justified that the young man was given a life sentence without the chance of parole. However, would they feel this same way if they learned that Evan Miller grew up subject to a childhood of abuse? That he was beaten by his alcoholic father? That his mother was a drug addict?[14]  That he turned to drug use and alcohol to cope with his situation at the age of eight?[15]  Even if these facts would change a jury’s mind, they do not play a significant role under the current mandatory sentence guidelines.

Some, including Miller’s defense attorney Bryan Stevenson, argue that sentences of life without parole should be done away with altogether for children under eighteen. In part, this argument hinges on the fact that America has one of the most severe systems of punishment for juveniles when compared to other countries.[16] In addition, Stevenson argues that the Court’s holding in Graham should not be limited to non-homicide cases because “[a]ll children are encumbered with the same barriers that this Court has found to be constitutionally relevant before imposition of a sentence of life imprisonment without parole or the death penalty.”[17]

 On the other hand, a number of legal experts would argue that a constitutional ban on these sorts of sentences for juvenile offenders would not be the most effective means of achieving a just result. As a victim right’s advocate Kent Scheindegger put it, “[A]ge is something to take into consideration in sentencing, but that one factor should not trump everything else.”[18]

At the end of the day the fact that this sentence is permitted by such a majority of the states may weigh heavily on the Court’s analysis in accordance with “the evolving standards of decency” under the Eighth Amendment. As Justice Scalia indicated during oral arguments, “[T]he American people have decided that that’s the rule. They allow it. And the federal government allows it. So I’m supposed to impose my judgment on what seems to be a consensus of the American people?”[19]


[3] Roper, 545 at 551.

[4] Roper,

[5] Roper, 545 at 553.

[17] Oral Arguments, Miller v. Alabama, No. 10-9646,  pg 3. March 20, 2012. http://www.supremecourt.gov/oral_arguments/argument_transcripts/10-9646.pdf

[19] http://www.cnn.com/2012/03/19/opinion/steinberg-juvenile-crime/index.html?iref=allsearch

Disclaimer: The copyright in each article and post is owned by its respective author. Opinions expressed are those of the respective contributor and not presented as the views of the Alabama Civil Rights and Civil Liberties Law Review, its editors, the University of Alabama School of Law or the University of Alabama Board of Trustees or any other entity not specifically mentioned. All statements on this site belong to its writer. In addition, the views, opinions, and conclusions expressed in this page are those of the author and not necessarily those of The University of Alabama or its officers and trustees. The content of this page has not been reviewed or approved by the University of Alabama, and the author is solely responsible for its content.

“Stand Your Ground”: Strike It Down

Kyle Mathis, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Kyle Mathis, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

On February 26, 2012, an African-American teen named Trayvon Martin was found shot to death in a small community north of Orlando. Who was his killer? George Zimmerman, a 28-year-old leader of the Sanford, FL community watch program; a position he had essentially bestowed upon himself.

Zimmerman remains a free man, protected by a Florida law known by many as a ‘Stand Your Ground’ law. Florida was the first of several states to pass a “Stand Your Ground” law which legally allowed someone to take proactive measures and use deadly force as a means of self-protection outside of their own home (which was the previous, traditional limit for such use of force).[1] Prior to the passage of the 2005 law, an individual faced with a situation which may call for self-defense was legally obligated to first and foremost attempt to flee. Because Zimmerman is able to claim that he suspected that Martin was committing a crime and that he “reasonably” believed that he was in personal danger, (it seems) he has been granted a certain level of immunity from being punished for his actions. This has created a good deal of controversy around the country.

Since the incident, bill sponsor, Former State Senator Durrell Peadon (R) and other members of the Florida legislature have started speaking out against this interpretation of their law.[2] They claim the Florida legislature did not intend this kind of result in passing this bill, but simply intended to provide a measure of self-protection for honest Americans. In fact, representatives have said that if the facts show that the alleged actions of Zimmerman on February 26 are true, then he will find no protection in their law. But that is not really their call anymore, is it? Now the matter is in the hands of the Florida justice system.

One provision of the law in question can be found in §776.013 of the Florida statute.[3] Specifically section (1) reads:

A person who is not engaged in an unlawful activity and who is attacked in any other place where he or she has a right to be has no duty to retreat and has the right to stand his or her ground and meet force with force, including deadly force if he or she reasonable believes it is necessary to do so to prevent death or great bodily harm to himself or herself or another or to prevent the commission of a forcible felony.

A few things jump out about the text of this law and the facts of this situation. First, is the question of whether Zimmerman was even attacked. From what is publicly known about Zimmerman’s conversations with the police, they seem to indicate that, in fact, Zimmerman may have been the one who initiated contact with the teen. The second issue is the use of the ever problematic reasonable belief standard in a statute which allows one individual to end the life of another and potentially go unpunished for this action. Another provision of Florida law, §776.012, gives further possible protection to Zimmerman and reads:

 A person is justified in using force, except deadly force, against another when and to the extent that the person reasonably believes that such conduct is necessary to defend himself or herself against the other’s imminent use of unlawful force. However, a person is justified in the use of deadly force and does not have a duty to retreat if: (1) he or she reasonable believes that such force is necessary to prevent imminent death or great bodily harm to himself or herself or another or to prevent the imminent commission of a forcible felony.[4]

This provision may aid Zimmerman in attempting to defend his actions as it does not place a requirement on the individual to have been first attacked. However, even with 776.012, there is still a problem with the reasonable belief standard. A “forcible felony” as stated in both 776.012 and 776.013 is defined under Florida statute §776.08 and includes: “murder; manslaughter; sexual battery; carjacking; home-invasion robbery; robbery; burglary; arson; kidnapping; aggravated assault; aggravated battery; aggravated stalking; aircraft piracy; unlawful throwing, placing, or discharging of a destructive device or bomb; and any other felony which involves the use or threat of physical force or violence against any individual.”[5]

  A classmate put these statutes in a way that really rang out for me: “Authorized Vigilante Justice.” Since hearing that, I have seen others voice a very similar opinion.[6] I grew up in South Central Texas, and I also own multiple firearms. I am a firm believer in an individual’s right to own and bear arms. Similarly, the right to defend yourself and your home are also codified in Florida statute §776.013. However, that right should not eclipse the rights of another individual’s rights.

Under the letter of the law there is a decent chance that a jury could find that Zimmerman reasonably believed that Martin was robbing a home, or any other of the many crimes applicable under §776.08. That is the problem. The state of Florida has allowed the beliefs of an individual with a gun to become a form of justice, and that simply should not be permissible.

There is no claim that Trayvon Martin actually committed a felonious crime or was in the process of committing one before his encounter with George Zimmerman that fateful night. But even if Martin had done something wrong, he is owed several things by our justice system, including the right to have a jury determine whether he is actually guilty of committing any crime. Instead, being a lone outsider in a community late at night seems to have given Zimmerman a right to take on the roles of everyone in our judicial system, from police officer to judge to executioner. The due process rights (not to mention the life) Zimmerman stole from Martin that night show, in and of itself, why the Florida law, as written, is simply unacceptable.

This is not to say that the idea of a “Stand Your Ground” law cannot work. It can. However, no law which gives an individual a right to end the life of another should be based on a standard that they reasonably believed that one thing or another was going to happen. An officer cannot arrest me without some measure of probable cause and a judge cannot sentence me to death until a prosecutor has proved to a jury that I have committed a crime punishable by death beyond a reasonable doubt. However, because Zimmerman was just an average citizen with a gun, he is allowed an almost indefinable standard by which to decide whether Martin had the right to continue living.

For a law of this type to be effective, it will take a clearer statute and standard by which to determine whether a crime is happening and a narrower definition of what allows an individual to initiate the use of deadly force against another. Several of the listed forcible felonies are obviously understandable (such as arson, sexual battery, aircraft piracy, etc.); however, others do not seem to warrant the punishment of potential death by citizen. For example, under Florida law, one is allowed to kill another if one finds it reasonably necessary to prevent them from committing an imminent car-jacking. To save the possession of a third-party from being stolen, it would be ok to kill someone. This is unreasonable.

The Florida courts should have the opportunity to look at Zimmerman’s case, if only for the fact they could have the opportunity to strike the law down and force the legislature to re-assess the how the law is written. Clearer definitions need to be implemented so that an individual must have more than just a subjective belief that a crime is being committed or that someone is threatening them. It may not be as extreme as needing to see a weapon, but a level of accountability must be in place for those who will take it upon themselves to put the words of 776.012 and 776.013 into effect.

We may never have a clear picture of what happened that night between Martin and Zimmerman Sanford, Florida. Instead, we will get a picture that involves a nation displaying a level of rage and debate over the actions taken that night by Zimmerman. Some have called this a race issue, and they may be right.[7] There is not enough known about Zimmerman to know if he would be driven by racial prejudice to act in this way. Others will say this is a gun rights issue, and they may be right, too.[8] There are many issues at play here. But in the end, I see only one solution being the correct one under the United States Constitution, and that is to arrest and try George Zimmerman for murder allowing for him to officially raise his self-defense claim (up to this point it has been the decision of the police and District Attorney’s to not arrest Zimmerman as they have determined he acted within the bounds of Florida statutes §776.013 and §776.012 in a court of law. Then it should be the responsibility of the courts to shoot down the defense and rule this law to be unconstitutional, so that Zimmerman is punished for his actions and the state of Florida’s legislature will be forced to fix this law so that another person will not feel justified by over-zealously taking the life of one of their fellow men.


[8] http://www.thenewamerican.com/opinion/950-bob-confer/11309-qstand-your-groundq-and-self-defense

Disclaimer: The copyright in each article and post is owned by its respective author. Opinions expressed are those of the respective contributor and not presented as the views of the Alabama Civil Rights and Civil Liberties Law Review, its editors, the University of Alabama School of Law or the University of Alabama Board of Trustees or any other entity not specifically mentioned. All statements on this site belong to its writer. In addition, the views, opinions, and conclusions expressed in this page are those of the author and not necessarily those of The University of Alabama or its officers and trustees. The content of this page has not been reviewed or approved by the University of Alabama, and the author is solely responsible for its content.

Trayvon Martin and Southern Justice

Casey Bonner, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Casey Bonner, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

It is August 1955 in Money, Mississippi. A pre-teen boy from Chicago, Illinois is spending part of his summer vacation visiting some relatives in the Delta, and the boys are currently hanging out in a small, local grocery store. An attractive woman walks in, and the boys’ attention is instantly drawn to her.  The Yankee, a visitor to the South, doesn’t know the old customs of the state. He whistles at the beautiful woman. The grocery store briefly falls silent before the boys are thrown out in an uproar. The visitor has made a grievous mistake: the woman at whom he had whistled is the grocery store owner’s wife. She is also white.

Several days later, the visitor goes missing. Rumors start to circulate; word starts flying around that the grocery store owner, Roy Bryant, and two other men have kidnapped the visitor. The sheriff quickly makes an arrest and charges the three men with kidnapping. Three days after the visitor is abducted, two boys fishing in the Tallahatchie River find his body. His body is beaten, bloody, and bruised. His captors had tied his body to a heavy fan blade with barbed wire tied around the neck. His eye is dislodged, and he has a gunshot wound slightly above his ear. The young male visitor, Emmett Till, had been killed for one reason and one reason only: He was Black.[1]

Flash forward to February 2012 in Sanford, Florida. A high school senior is walking home from a nearby grocery store after buying Skittles and some iced tea. He’s crossing through a neighborhood being watched by the Neighborhood Watch Captain, George Zimmerman. Zimmerman notices the young man walking through the neighborhood, and calls and reports the young man’s presence as “suspicious.” The police urge Zimmerman not to pursue the young man, but Zimmerman does not heed their order. What exactly happened next is still unknown, but the end result is clear: 17-year-old Trayvon Martin is dead, shot by George Zimmerman.[2]

Since Trayvon’s death, facts have emerged and allegations have been made that have led some to call Trayvon a “modern-day Emmitt Till.”[3] The 911 call from Zimmerman to Sanford police reveals that Zimmerman told police a Black male, wearing a hoodie, was walking through the neighborhood, which Zimmerman felt was suspicious. Zimmerman told 911 dispatchers that he was following the young man, which they instructed him not to do.  Zimmerman’s own statement to 911 dispatchers contradicts what he told police after they arrived on the scene of the crime – that Trayvon had attacked him, and he had shot Trayvon out of self-defense.[4] When police arrived, Trayvon was unarmed and carrying only his cell phone, a bag of Skittles, and an iced tea. Police did not arrest Zimmerman, nor did they perform any tests to determine whether Zimmerman was intoxicated. Sanford Police Chief Bill Lee stepped down from his duties after the city council passed a no-confidence vote in Lee. The 911 call reveals Trayvon was screaming for help before he was killed.[5]

 Amid calls for justice from not just Trayvon’s parents, but to the President to everyday citizens, the tragedy continues. Trayvon’s girlfriend was on the phone with him when the scuffle began, and she heard someone accost Trayvon shortly before the line went dead. Facts continue to emerge that indicate Zimmerman’s actions against Trayvon were racially motivated. Most recently, reports have emerged that Zimmerman used a racial slur while following Trayvon, which was recorded on the 911 call.[6] On March 23rd, students in Florida high schools participated in a walk out in protest of the lack of arrest in Trayvon’s killing.[7] That same day, President Obama stated at a press conference, “[W]e will get to the bottom of exactly what happened.[8] Trayvon’s parents have attended rallies in honor of their son’s life and have publicly called for justice.[9] Although Zimmerman remains free, his actions will be reviewed by a grand jury, and the FBI and Justice Department have opened their own investigations into the case.[10] Unfortunately, justice may not be served so easily.

 The issue: Florida is among twenty-one states that have a “Stand Your Ground” law that allows people to use deadly force when engaged in a fight.[11] The law reads as follows:

A person who is not engaged in an unlawful activity and who is attacked in any other place where he or she has a right to be has no duty to retreat and has the right to stand his or her ground and meet force with force, including deadly force if he or she reasonably believes it is necessary to do so to prevent death or great bodily harm to himself or herself or another or to prevent the commission of a forcible felony.

Thus, in order to have a successful claim, Zimmerman would only need to prove that he had a right to be where he was at the time and that he believed it was necessary for his to shoot Trayvon in order to protect himself from harm or death. The only real question left is whether Zimmerman had cause to believe Trayvon was going to harm him. Seeing as Trayvon was found holding only a bag of Skittles and an iced tea, Zimmerman will have a difficult time showing he was reasonably fearful of “great bodily harm” or death. When the grand jury reviews the evidence – Zimmerman’s statements, the 911 call, Trayvon’s girlfriend’s testimony about their phone call, and the situation as a whole – they will be able to start the steps of bringing Zimmerman to justice.

Even though the process of determining what really happened that night has finally begun, scrutiny of the police department’s handling of the case is opening them up to harsh criticism. Under the law, police are allowed to determine at the scene of the homicide whether they believe the self-defense claim, which is precisely what the police did in the Martin case. However, can they really be faulted for following the law? An at-the-scene determination of Zimmerman’s truthfulness could easily be believed: he had a bloody nose, scratches on his skin, and grass stains on his shirt, all signs of an apparent scuffle.[12] The police were not obligated to take Zimmerman in for further questioning, nor were they obligated to perform any sort of test to determine whether Zimmerman was intoxicated. Yet some have claimed the police did not do enough; they claim if the situation were reversed and Trayvon had been the one claiming self-defense, there would have been an arrest immediately. Whether that is true we do not know for it is only speculative, unfortunately, statistics suggest that statement may have some truth to it.

 Statistics indicate that prosecutors are three times more likely to seek the death penalty when the perpetrator is Black and the victim is White.  Studies have also shown that prosecutors are less likely to seek the death penalty when the victim is Black, regardless of the perpetrator’s race.[13] Aside from the eventual sentence, Black defendants are incarcerated 5.6 times more than White defendants.[14] Even more shocking, White defendants receive sentences ten percent shorter than those received by Black defendants, even when charged with the same offense.[15] Thirty-two percent of Black men will be incarcerated at some point in their lives, while only six percent of White men will suffer the same fate. For drug offenses specifically, African-Americans are thirty-seven percent of those arrested, although they are only thirteen percent of the United States population as a whole.

Though it clearly shouldn’t, race quite obviously plays a factor in criminal charges and criminal sentencing. It mattered in 1955 with Emmett Till: though Till’s captors were caught and charged, an all-white jury acquitted the defendants in a little over an hour. One juror commented, “If we hadn’t stopped to drink pop, it wouldn’t have taken that long.[16] Some jurors admitted they believed the defendants were guilty, but they did not think the death penalty was appropriate for White men who had killed a Black man.

We as a society have progressed since 1955. We cannot allow people like George Zimmerman to stem that progress. We cannot allow Trayvon’s memory to fade. We cannot allow Trayvon to become a modern-day Emmett Till. We cannot allow justice to pass us by. We must continue to push for change at every chance we are given. We must continue to change the way we see each other and the way we view justice.  We must continue to seek justice for Trayvon — for justice is the reason we study law.


[16]http://en.wikipedia.org/wiki/Emmitt_till#cite_note-75

Disclaimer: The copyright in each article and post is owned by its respective author. Opinions expressed are those of the respective contributor and not presented as the views of the Alabama Civil Rights and Civil Liberties Law Review, its editors, the University of Alabama School of Law or the University of Alabama Board of Trustees or any other entity not specifically mentioned. All statements on this site belong to its writer. In addition, the views, opinions, and conclusions expressed in this page are those of the author and not necessarily those of The University of Alabama or its officers and trustees. The content of this page has not been reviewed or approved by the University of Alabama, and the author is solely responsible for its content.

Amendment 26 Is A Mississippi Bad Idea

Casey Bonner, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Casey Bonner, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Our neighbor to the west and my home state, Mississippi, could become the first state to effectively ban abortions next month if many pro-life supporters have their way. On November 8th, Mississippi voters who approach the voting booth to vote for the state’s next governor will also be faced with the initiative to amend the state constitution to define “personhood” as life that begins at conception – the moment a human egg is fertilized.

The initiative, known as Amendment 26, is backed by the Colorado-based group Personhood USA. Their mission statement declares their mission to be “to serve Jesus by being an Advocate for those who can not [sic] speak for themselves, the pre-born child. We serve by starting / coordinating efforts to establish legal ‘personhood’ for pre-born children through peaceful activism, legislative efforts and ballot-access petition initiatives.” Personhood USA is currently assisting in petition initiatives in several states, including Florida, Montana, Oregon and Ohio. Several states, including Alabama, have had Personhood USA-supported bills presented in their state legislatures, but only Mississippi will have the amendment proposal on their ballots this election year. Similar amendment proposals were defeated by voters in Colorado in both 2008 and 2010.

The language that Mississippi voters will encounter on the ballot reads: “Be it Enacted by the People of the State of Mississippi: SECTION 1. Article III of the constitution of the state of Mississippi is hereby amended BY THE ADDITION OF A NEW SECTION TO READ: SECTION 33. Person defined. As used in this Article III of the state constitution, “The term ‘person’ or ‘persons’ shall include every human being from the moment of fertilization, cloning or the functional equivalent thereof.”

Personhood USA and its Mississippi branch, Personhood Mississippi, hope to have greater success with their proposal in Mississippi, which is one of the most conservative states in the country. If Amendment 26 passes, it would define “person” to “include every human being from the moment of fertilization, cloning or the functional equivalent thereof” – which would make abortions illegal in the state, including those pregnancies that occur as a result of incest or rape.

Of course, the first question that should be asked about Amendment 26’s impact on a woman’s right to choose is “What about Roe v. Wade?”  In the well-known Supreme Court decision, the Court held that there is a fundamental due process right to decide to terminate a pregnancy, although within reason. In Roe, the majority used a strict scrutiny approach to analyze Roe’s challenge to Texas’s criminal abortion statutes. Strict scrutiny is applied when there is a fundamental right involved; in order for Texas’s statutes to survive a strict scrutiny challenge, there must have been a compelling state interest and the means used to regulate abortion must have been narrowly tailored. Texas claimed a compelling interest in ensuring patient safety and protecting prenatal life, but the Court held that a fetus is not a “person,” thus there was no real state interest in protecting the “life” of the fetus. Instead, the court held that the state may have an interest in protecting maternal life, but only at the end of the first trimester of the woman’s pregnancy. Only once the second trimester begins may the state regulate abortion.

To some, the Roe decision should be the nail in the coffin for Amendment 26.  However, Personhood Mississippi views the rationale used in Roe as the reason Amendment 26 will succeed. The Mississippi Personhood Memorandum points to two cases cited by the Court in Roe that recognize a state’s right to define “person” in a manner that is more protective of an unborn child, McGarvey v. Magee-Womens Hospital, 340 F.Supp. 751 (W.D. Pa. 1972) and Byrn v. New York City Health & Hospitals Corp., 31 N.Y.2d 194 (N.Y. 1972).

According to the Memorandum, this right of the state to define terms at its discretion will allow the state to effectively ban abortions in the state while not enacting laws that explicitly state the illegality of abortion. In fact, the Memorandum states, “It cannot be emphasized too strongly that the Amendment does nothing more than define the word ‘person.’ It does not criminalize abortion . . . .” Instead, declaring a fetus to be a person would allow the state courts or legislature to appoint the unborn a representative to advocate for the unborn in a judicial decision regarding whether the pregnancy could be terminated. However, the Memorandum sees the judicial process to terminate the pregnancy a non-issue – the Memorandum states that it would be “difficult, if not impossible to imagine a basis depriving the innocent child of life . . . .”

Oddly enough, the Memorandum also recognizes that if the Initiative passes, it will immediately be met with challenges from individuals and women’s rights groups. The group even “safely assumes” that the federal courts will find the Amendment unconstitutional under Roe. Despite the challenges and likely unconstitutional finding by a federal court, the Personhood USA remains optimistic. Keith Mason, a co-founder of Personhood USA, has said that a positive vote in Mississippi would send shock waves around the country, creating a momentum that could be used to eventually amend the U.S. Constitution.

What is curious about Personhood Mississippi’s faith in the Amendment’s ability to basically defeat the Supreme Court’s reasoning in Roe is that the group utterly ignores the Court’s holding in Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833 (1992). In that case, the Court upheld the following essential parts of Roe: (1) women have a right to abortion before fetal viability; (2) the state does have an interest in restricting abortions after viability; (3) the state does have interests in protecting both the life and health of the mother and the potential life of the fetus. However, unlike in Roe, the Court did not rely on a strict scrutiny test, but rather focused on the burden abortion regulations placed on women. Casey did not overturn the Roe decision, but instead re-emphasized a woman’s right to choose by ensuring that any state restrictions on her choice were not so burdensome as to effectively eliminate her free choice. It is Casey, not Roe, that should concern Personhood advocates.

If Amendment 26 passes in Mississippi, it will be challenged not only on Roe standards and a woman’s right to abort but also under Casey’s undue burden test. Unfortunately for Personhood Mississippi, Amendment 26 probably will not withstand an undue burden examination. The objective of Amendment 26 is to effectively ban abortions in the state of Mississippi. Moreover, the current unavailability of abortions in Mississippi is probably the most burdensome restriction of all.

Nevertheless, perhaps not surprisingly, Amendment 26 has raised issues beyond a woman’s right to choose to terminate her pregnancy. One of the most contentious talking points surrounding Amendment 26 is the effect its passage would have on contraceptives and IVF. Proponents of the measure state while they do not condone the use of contraceptives, the Amendment will not outlaw “the pill.” Another pro-Amendment group, Yes on 26, states on their website that they oppose the use of contraceptives that act as abortifacients, which the group concedes could include some forms of the pill, intra-uterine devices (IUDs) and the “morning-after pill.”  Proponents oppose contraceptives such as these because they do not allow for the implantation of a fertilized egg. If “personhood” begins with fertilization, anything that deprives the “person” of life has violated its due process rights, and anyone who has caused the deprivation could be held liable.

In a similar vein, Yes on 26 promises that IVF would not be banned by the new definition, but it would place limits on the process. During in-vitro fertilization, several fertilized embryos may be created, but usually only one or two embryos are implanted in the woman, as recommended by the American Society for Reproductive Medicine. Any remaining embryos are usually frozen and stored in case the implanted embryos fail to result in a pregnancy. However, if there is a situation when embryos could or would be destroyed at the request of the parents, under Amendment 26, the parents, doctors or technicians could be held liable.

Those opposing the Amendment claim a redefinition of “personhood” would effectively ban many birth control methods, including the pill and IUDs. Parents Against MS 26 argue because many oral contraceptives change the lining of the uterus to keep a fertilized egg from implanting and developing, the new definition of personhood would keep these contraceptives from being available, even when needed for non-contraceptive medical uses. Parents against MS 26 also claims while the Amendment may not facially ban IVF, the definition of personhood would be a de facto ban on the treatment since IVF carries a risk of the destruction of embryos, whether intentional or accidental. Many university newspapers in Mississippi have published opinion articles by students against the Amendment, including an article in the Daily Mississippian, the University of Mississippi’s student newspaper. In the article, the writer wonders if the Amendment would allow women who miscarry to be prosecuted for manslaughter or even murder. While proponents of Amendment 26 denounce this theory as nothing more than a scare tactic, the logical extension of a new definition of personhood could result in such stark repercussions.

On November 8th, the voters of Mississippi will probably pass Amendment 26.  Both gubernatorial candidates have publicly backed the measure and polls conducted by the state’s major newspaper indicate that public sentiment backs the amendment.  Mississippi is widely recognized as one of the most conservative states in the U.S., as well as one of the most religious, and these superlatives will probably be the reason the Amendment passes. I think passing the Amendment will be a mistake and a waste of state resources and time.

Amendment 26 is a mistake, regardless of the good intentions behind the definition change because the repercussions extend beyond banning abortion. While advocates claim the new definition of person would not affect the availability of contraceptives or IVF, if these methods affect the existence of a fertilized egg, the definition will indeed affect contraception and IVF. Again, this is a mistake and a potentially devastating effect of the Personhood movement. Mississippi already has the highest teen pregnancy rate and highest infant mortality rate. By decreasing or even eliminating the availability of contraceptive devices, this measure could prove costly for the state and its taxpayers.

Amendment 26 will result in criminal prosecutions of women who have miscarriages, even though I agree with Yes on 26’s stance that such a claim is nothing more than a scare tactic. I also feel that Yes on 26 presents many distasteful statements of their own – including the declaration that “Planned Parenthood makes millions of dollars every year by killing babies.” Both sides have engaged in offensive smear campaigns, with both sides exaggerating the possible repercussions and ignoring the logical extensions of the plan. Even after reading countless articles and perusing websites by both advocates and opponents, I admit that I still am unsure of the real effects the new  amendment would have – other than changing the definition of “person.” My only hope for Mississippi voters is that they make an effort to discern the truth – because man, woman, mother, father, conservative, liberal, abstinent, indulgent – it will affect them and those they love.

The irony in all of this is that regardless of the outcome at the voting booth, the Amendment will not stand. Roe and Casey both held that a woman has a fundamental right to choose and that the state can place no undue burden on her rights. Absent a dramatic reversal of precedent, the long-term effects on the state will be few. Mississippi may enact Amendment 26 and it may change the reproductive rights of women in the state for a short time, but Amendment 26 is sure to be met with a multitude of legal challenges and the clear holdings of Roe and Casey should ensure women’s rights will prevail.

SOURCES:

http://www.lc.org/media/9980/attachments/memo_ms_personhood.pdf

http://parentsagainstms26.com

http://yeson26.net

http://www.msnbc.msn.com/id/44935764/ns/us_news-life/#.Tp3z6nOJv4E

http://www.thedmonline.com/article/facts-about-amendment-26

http://personhoodmississippi.com/

http://www.personhoodusa.com/

http://blogs.wsj.com/law/2011/10/17/life-at-fertilization-measure-has-a-shot-in-miss-supporters-say/

http://www.clarionledger.com/article/20111016/OPINION01/110160304/Personhood-Initiative-bad-policy?odyssey=mod|newswell|text|Opinion|s

 

 

Disclaimer: The copyright in each article and post is owned by its respective author. Opinions expressed are those of the respective contributor and not presented as the views of the Alabama Civil Rights and Civil Liberties Law Review, its editors, the University of Alabama School of Law or the University of Alabama Board of Trustees or any other entity not specifically mentioned. All statements on this site belong to its writer. In addition, the views, opinions, and conclusions expressed in this page are those of the author and not necessarily those of The University of Alabama or its officers and trustees. The content of this page has not been reviewed or approved by the University of Alabama, and the author is solely responsible for its content.

Alabama’s Immigration Law Does No Good

Heather Miller, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Heather Miller, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Alabama House Bill 56 is the latest and most aggressive state immigration law to date. According to Micky Hammon, the bill’s chief sponsor, it was designed to “attack every area of an illegal alien’s life.”  Surpassing the controversial Arizona and Georgia legislation, the bill calls for strict enforcement of its measures, which range from creating a civil cause of action against employers who fire citizens while retaining illegal aliens; requiring public schools to determine the immigration status of all incoming students and their parents;  to requiring police officers to make a reasonable attempt to determine the residency and immigration status of a person stopped, if there is a reasonable suspicion that the person is an illegal immigrant.

The new law, passed in by the Alabama legislature and signed by Governor Robert Bentley, has already been challenged as a preemption of federal power, with mixed results.  But perhaps more interesting is the specter of racism cast by this law. There are illegal immigrants of every color in this country.  However, it is the Hispanic community, both U.S. citizens and illegal immigrants, which has become the focus of this debate.  As such it is only appropriate to consider the effects of the bill on both groups.

Latinos make up approximately 3.9% of the Alabama’s population, or about 185,602 people.[1]  It is estimated that illegal immigrants make up around 64% of the Hispanic population, or around 120,000 people.[2] Moreover, the two groups are often interwoven—i.e. children, who are citizens, may have parents who are here illegally.  The implications of H.B. 56 for Hispanic citizens of Alabama are terrifying.  Already nightly newscasts are broadcasting stories on “How to Stay Safe,” which include tips like always carrying “papers.” After the passage of H.B. 56, Hispanic Americans are forever foreigners in the eyes of the fellow citizens—they must be constantly ready to prove that they belong here as citizens and lawful residents.  However, “showing papers” may be the least of these worries if the Alabama legislature is successful in getting the law enforced in its entirety.

U.S. District Court Judge Sharon Blackburn blocked some portions of the law which made it a criminal offense to conceal, harbor, transport, or shield an illegal immigrant.  If the Alabama legislature is successful in its appeal, many Hispanic families would be confronted with the dilemma of being forced from their home in order to keep their family together, or face criminal charges if they continue to have contact with family members who are illegally in the state. Furthermore, approved portions of the law place children, who are legally in the U.S., whose parents are illegal immigrants, in an untenable position. Also, H.B. 56 section 30 makes it a felony for an illegal immigrant to enter into a business contract with the State of Alabama.  The implications may not be apparent at first glance, but in many parts of the Alabama, utilities, such as water, sewage, and electricity, are only available through the State. Clearly, as claimed in the Federal appeal, Alabama’s new law is “highly likely to expose persons lawfully in the United States, including school children, to new difficulties in routine dealings.”[3]

For those Latinos not lawfully in the U.S., the message is clear—Get Out. The only remaining question is where? Although some families are leaving the country voluntarily, many are simply crossing state lines. Either way, they are moving carefully, since the law became effective on September 29th , many illegal immigrants fear detention, or criminal charges, if they are seen by law enforcement. As Vianey Garcia, an illegal immigrant said, “We have to move. We have to leave everything.  We can’t take anything because I’m afraid they can stop us and say why are you moving?”

The repercussions of H.B. 56 are already apparent.  The Thursday the law went into effect (September 29th) scores of Latino students were absent from schools, and many have never returned.  Although it is too early for reliable statistics, anecdotal evidence from the community suggests many Latino families are fleeing in fear. Proponents of the law have lauded the early signs of success; they are driving immigrant families from the state. However, it is the climate of fear created by H.B. 56 that most worries its opponents.

Fear, it is the one word that cuts through every article, news report, and interview on H.B. 56. After all, the law is an “attack” on illegal immigrants; and by proxy, their family members who are legally in the U.S., and let’s be honest, Latinos in general. The law tried to create criminal and civil sanctions not just against illegal immigrants themselves, but also against anyone who would employ, transport, aid, or even encourage them—they have been cast as lepers by Alabama lawmakers. As the stereotypical face of illegal immigration, Hispanics face suspicion and disdain lest others be exposed to the taint of illegal immigration.

It has been said H.B. 56 and its Arizona and Georgia counterparts are a cry for help—an extreme reaction to the federal government’s inaction to state immigration concerns. And like most extreme measures, it has produced a result, but at what cost? The federal government has cited concerns that extreme state immigration policies interfere with the federal strategy and enforcement—hardly a convincing argument when it was the inaction of the federal government that prompted the passage of H.B. 56 in the first place. Civil rights groups, like the Southern Poverty Law Center, claim the law will lead to racial profiling, chill children’s access to education, and result in violations of the Due Process and Equal Protection clauses. Church leaders have also protested the law, claiming it violates, and in some cases would criminalize actions prompted by Christian values. The agricultural sector says it is unable to find a replacement workforce, that crops are rotting unpicked in the fields. For a state so recently ravaged by tornadoes, contractors are concerned that a dearth of workers will cause long delays in rebuilding the state.

Furthermore, proponents of the immigration law claim it is designed to protect the residents of Alabama from bearing the costs of illegal immigrants; but there is no clear evidence that illegal immigration creates a financial burden.[4] Moreover, evidence exists that illegal immigrants may be an economic boon. It is estimated that in 2010 illegal immigrants in Alabama paid $130.3 million in state and local taxes.[5] Furthermore, “if all unauthorized immigrants were removed from Alabama, the state would lose $2.6 billion in economic activity, $1.1 billion in gross state product, and approximately 17,819 jobs.”[6]

I am not contesting the importance of resolving illegal immigration. It is an important issue that begs resolution, but H.B. 56 is not the solution; moreover, it creates more problems.Furthermore, I recognize that illegal immigrants are not United States citizens, and therefore not entitled to all of the rights and privileges guaranteed by the Constitution. However, this “attack” is not well executed, and both legal and illegal residents of Alabama have been harmed by its carelessness. H.B. 56 is so poorly crafted, and that is evident in that it has created enormous hardships without serving any of its stated interests. The problem of illegal immigration deserves more consideration than reactionary legislation.  History is filled with examples of minorities whose rights and liberties have been trampled because they are the scapegoat for a larger problem. The state of Alabama has a chance to choose a different road; to draw on its history and turn from the, perhaps popular, path of segregation and instead draft legislation that actually addresses the needs of its citizens.

Sources:

http://news.yahoo.com/obama-administration-appeals-alabama-immigration-law-220502628.html

http://blog.al.com/birmingham-news-commentary/2011/10/viewpoints_undocumented_doesnt.html

http://www.csmonitor.com/USA/2011/0929/Alabama-life-already-changing-under-tough-immigration-law

http://www.splcenter.org/get-informed/news/splc-civil-rights-groups-file-emergency-request-to-block-key-provisions-of-alabama

http://abcnews.go.com/blogs/headlines/2011/10/latino-students-withdraw-from-alabama-schools-after-immigration-law-goes-into-effect/

http://www.scribd.com/doc/66701706/Summary-Opinion-on-Alabama-Immigration-Law

http://blog.al.com/breaking/2011/09/federal_judge_throws_out_xxxx.html

http://www.immigrationpolicy.org/just-facts/new-americans-yellowhammer-state

Disclaimer: The copyright in each article and post is owned by its respective author. Opinions expressed are those of the respective contributor and not presented as the views of the Alabama Civil Rights and Civil Liberties Law Review, its editors, the University of Alabama School of Law or the University of Alabama Board of Trustees or any other entity not specifically mentioned. All statements on this site belong to its writer. In addition, the views, opinions, and conclusions expressed in this page are those of the author and not necessarily those of The University of Alabama or its officers and trustees. The content of this page has not been reviewed or approved by the University of Alabama, and the author is solely responsible for its content.

Obama Administration Justified in Targeted-Killing

Jared Miller

Jared Miller, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Anwar al-Awlaki (Awlaki) is dead. Before September 29, 2011, this leader was relatively unknown to most citizens of the United States. However, Awlaki’s story has quickly developed and been publicized due to America’s demand for instantaneity and aggressiveness from its news sources. Why Awlaki was killed, who killed him, and the nature of his killing was exposed in two days. The covert operations penetrating his life, the intelligence leading to his demise and the subsequent blow to his constituency has been plastered across various print and electronic media. Everything from his religious beliefs, the way he lived his life, schools he attended, and the scope of his marriages are in steady conversation rotation across the country. As these facts continue to come to light, it is Awlaki’s citizenship which will most likely have the most significant impact in the foreseeable future.

Awlaki was an admitted member of al-Qaeda. He had every right to join al-Qaeda and promote the beliefs of his organization. Awlaki had free will to support al-Qaeda and encourage their direction. He routinely expressed his hatred for America and Western Civilization. Awlaki used his radical influence to cause harm and continue a jihadist “holy war” against America.  U.S. military officials have called him a master propagandist and said he had immense ability to harm our country.  Subsequently, his dedication led him to become a supremely powerful figure within their ranks. However, it was Awlaki’s actions, not beliefs, which led to his being targeted. Al-Qaeda’s destructive actions and operational tactics have been widely held as terroristic in America. Their attacks on American soil and around the world have led the U.S. government to classify them as a legitimate threat to our national security. Awlaki’s speeches indicate he knew of al-Qaeda’s extremist reputation and he used his position to perpetuate these actions himself. He publicly praised numerous attacks on the nation and was charged with plotting attacks. President Obama even described Awlaki as the “leader of external operations for Al-Qaeda.”  Awlaki was perceived as such a threat that he was approved for targeted killing by the Central Intelligence Agency (CIA). Naturally, he met the same fate as most do when they are placed on this list.

The death of Awlaki came early Friday morning while he was hopping into a pickup truck.  He was caught in the crosshairs of an armed CIA drone and there was nothing he could do.  His death was carried out in Yemen and has been widely praised by their government. It is broadly speculated that the Yemeni Government helped carry out this military operation. Nonetheless, the U.S. Government has not given the exactness of their intelligence. Yemeni officials have commented that Awlaki was a threat to all and that his death was the direct consequence of his actions.  This rationale aligns with the comments being made by United States officials.  However, there is an increasingly growing underlying conversation being had in America about this military action.  Anwar al-Awlaki was born in New Mexico, making him an American citizen.

The conversation being had is the legality of the U.S. government killing an American citizen without judicial process.  The critics of Awlaki’s killing point to the Fifth Amendment to the Constitution that states no one shall be “deprived of life, liberty, or property, without due process of law.” These critics argue that there was not a single legal process that led to Awlaki becoming the first U.S. citizen placed on the CIA’s targeted killing list. They argue that this is America and in America actions such as these have to be fulfilled through a legal process. Further, critics point to the potential precedent this targeted listing and killing imposes. It is believed this opens the door to expanded executive authority to the killing of Americans. The American Civil Liberties Union’s (ACLU) Deputy Legal Director Jameel Jaffer said, “It is a mistake to invest the President — any President — with the unreviewable power to kill any American whom he deems to present a threat to the country.” Decriers say Awlaki’s murder goes against the framework of our country and has severely eroded the power of the judiciary.  The ACLU filed a lawsuit last year challenging the constitutionality of adding an American citizen to the targeted killings list. The lawsuit was dismissed and the federal judge noted that Awlaki had shown no interest in pursuing a claim in a U.S. justice system “he despised.” However, these conflicting views on the legality of the targeted killing of Americans has not been limited to the parties involved in litigating the preceding laws.

Presidential candidate Ron Paul has even expressed skepticism. He stated U.S. leaders must analyze “assassinating American citizens without charges” even if they do have strong terrorist ties and affiliations. Individuals with similar views of Ron Paul and the ACLU argue that there is no nexus between Awlaki’s actions and superseding the constitution. It is clear that he was implicated in various terrorist acts around the world, but Awlaki never was convicted in an American courtroom. It is this point that is fueling the debate. The critics of the killing argue that the Fifth Amendment requires a trial and conviction in court in order to kill any American citizen.

A quick resolution to this debate seems bleak since no real precedent exists.  Members of the legal community have tried to compare it to the detention of Americans who sided with our enemies in World War II. The precedent established by the actions taken in that point in history is unlikely to gain popularity because a lot of people do not accept America’s conflict with al-Qaeda as a real war. Robert Chesney, a law professor at the University of Texas who specializes in national security law, said that he does not believe “there has ever been a case quite like this.” With that said, most people opposed to Awlaki’s killing are not contentious about the circumstances surrounding his death. These people understand that he was a radical man and did not view America in the best light. However, they are worried about the slippery slope his placement on the targeted list has created.

Nevertheless, the Obama administration has heard the critics and has taken a position to rebut them. The Obama administration claims they were justified in placing Awlaki on the CIA’s targeted killing list because of his shifted focus and subsequent actions. They claim he went from a role of propagandist to operationally active during wartime. They point to Awlaki’s influence within the al-Qaeda sector in the Arabian Peninsula and his role in al-Qaeda in developing terrorist plots against America. The administration focused on three elements to support their argument when they rebutted ACLU’s lawsuit. First, they established that Awlaki was an imminent threat to American citizens. They produced evidence of his participation in plots to blow up specific American based airliners and cargo planes. Next, the administration relied upon the fact Awlaki was fighting with the enemy in armed conflicts against American forces. This was said to further his direct threat against America. Finally, and most importantly, the administration pinpointed the fact that they could not find a feasible way to arrest him. Awlaki’s dual citizenship, allegiance of followers, fleeing ability and pure determination to avoid capture made him “a hard target.” A hard target that was inevitably hit.

“If you’re a terrorist, you’re a terrorist,” exclaimed Secretary of Defense Leon Panetta when commenting on Awlaki’s killing. Anwar al-Awlaki was a terrorist.  He was a threat to anyone in this country and anyone whose religious and cultural views did not align with his. His preaching of violence and hate was heard around the world and became more threatening every day. He was just one man, but his influence inspired countless. My views support the officials around the globe acknowledging a safer world without him in it. A stereotype of the al-Qaeda network does not lead me to believe this way. My reasoning comes solely from the words out of his mouth. Awlaki’s destructive words and slant towards violence against America is unacceptable. And I fully agree with the Obama administration legal justification.

It is the federal government’s duty to protect the sovereignty of our nation and provide safety from threats.  Awlaki’s influence and his own hands were an immediate threat to American citizens. He preached for our deaths and took up arms against our troops. His actions were a direct threat against every citizen in the United States and considered treason in the U.S. Constitution (Article 3, §3). The Constitution further signifies that treacherous behavior is punishable by death.  Although Awlaki was not convicted of treason, his words and admittance to crimes made his traitorous stance clear. Furthermore, he was a wanted man and could have turned himself in to clear his name. Awlaki made the choice to elude law enforcement and forgo the judicial process.  America gives any citizen charged with a crime an opportunity to turn themselves in. Clearly, rectifying actions have to be taken when a charged party neglects this right, especially when federal organizations classify this party as a threat. It is true, Awlaki was not given a trial and this seems to cut against the Fifth Amendment. However, the Constitution has to be read and interpreted in the aggregate when the situation warrants. We know of at least three constitutional arguments that arise from Awlaki’s killing. His killing was executed without the exercise of the judicial process. Awlaki was thought to have committed treason. And it is the federal government’s duty to protect its citizens from foreign and domestic threats.

The Obama administration fulfilled their duty by adding Awlaki to the targeted killing list and executed their agenda. Taking away a President’s authority to order someone placed on the targeted killing list would not make America safer. I believe it would impede the national government’s duty to keep its citizens safe. Extreme measures are needed when time is of the essence and threats are imminent. The country elects our leaders to make the hard choices and sometimes they have to be made for our protection. It is a fallacy to demand constitutional protection from threats as an American citizen but chip away at the weapons used to protect us. I am sure the administration would have loved to minimize the Awlaki threat in a more judicially sound way, but CIA drones do not carry handcuffs.

Sources:

http://www.usatoday.com/news/washington/story/2011-09-30/awlaki-legal/50620240/1

http://www.bendbulletin.com/article/20111001/NEWS0107/110010372/

http://www.washingtonpost.com/world/national-security/yemeni-al-qaeda-took-a-blow-but-remains-a-threat-to-us/2011/10/01/gIQAw9OmDL_story.html

http://en.wikipedia.org/wiki/Anwar_al-Awlaki

http://globalpublicsquare.blogs.cnn.com/2011/10/01/killing-awlaki-was-illegal-immoral-and-dangerous/

http://www.denverpost.com/nationworld/ci_19022223

http://nationalinterest.org/blog/paul-pillar/the-killings-yemen-the-rule-law-5963

http://en.wikipedia.org/wiki/Treason

http://cnnpressroom.blogs.cnn.com/2011/09/30/panetta-if-youre-a-terrorist-youre-a-terrorist/

Disclaimer: The copyright in each article and post is owned by its respective author. Opinions expressed are those of the respective contributor and not presented as the views of the Alabama Civil Rights and Civil Liberties Law Review, its editors, the University of Alabama School of Law or the University of Alabama Board of Trustees or any other entity not specifically mentioned. All statements on this site belong to its writer. In addition, the views, opinions, and conclusions expressed in this page are those of the author and not necessarily those of The University of Alabama or its officers and trustees. The content of this page has not been reviewed or approved by the University of Alabama, and the author is solely responsible for its content.

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