Radical media, politics and culture.

The State in Hyper-Drive: the Post-September 11th

Chuck Morse writes "

Review of Silencing Political Dissent: How Post-September 11th Anti-Terrorism Measures Threaten our Civil Liberties by Nancy Chang, The Terrorism Trap: September 11th and Beyond by Michael Parenti, and Terrorism and War by Howard Zinn. From the current issue of The New Formulation: An Anti-Authoritarian
Review of Books (February 2003, Vol. 2, No. 2). See

http://flag.blackened.net/nf/index.htm

 


Paul Glavin

The State in Hyper-Drive: the Post-September 11th U.S.

Silencing Political Dissent: How Post-September 11th Anti-Terrorism Measures Threaten our Civil Liberties

By Nancy Chang

New York: Seven Stories Press, 2002


The Terrorism Trap: September 11th and Beyond

By Michael Parenti

San Francisco: City Lights Books, 2002


Terrorism and War

By Howard Zinn (edited by Anthony Arnove)

New York: Seven Stories Press, 2002


 


“The freedom of working people, the freedom of black people has

always depended on the struggles of people themselves against

the government. So, if we look at it historically, we certainly cannot

depend on governments to maintain our liberties. We have to

depend on our own organized efforts.”

-Howard Zinn, Terrorism and War


 


For those of us living in the United States the world has changed drastically
since the tragic events of September 11th, as it has for millions living in
Afghanistan, Iraq, and elsewhere. The Bush Administration has used the events of
that day to grossly expand the power of the state to intervene in the lives of
people both overseas and here at home.1 There is now public discussion of
initiating a level of surveillance against the U.S. population, using “War is
Peace”-type rhetoric, previously confined to dystopian novels such as 1984. U.S.
citizens are being held virtually incommunicado as “enemy combatants,” denied
all constitutional rights.2 Some six hundred other “enemy combatants” are being
held at Guantanamo Bay, Cuba, outside of international rules established to
govern the treatment of Prisoners of War. And finally, up to two thousand people
(the government will not say exactly how many) have been rounded up and
indefinitely detained.


Prior to the attacks, the movement against capitalist globalization and the
anarchist-wing of this new movement were in ascendancy. The anarchist movement
had been enjoying a revival of activity and visibility not experienced in the
United States since the 1920s. The events of September 11th put the brakes on
both the growing anti-globalization movement in the United States and, with it,
the anarchist movement. We need to regroup and think through what has changed
and what remains the same. We need to figure out the “post-September 11th world”
so we can begin again to move toward our goals. These three books, in varying
ways, help in this process.


Nancy Chang’s book, Silencing Political Dissent, is a detailed analysis of
recent legislation, such as the USA PATRIOT Act, the detention of up to two
thousand immigrants without charges, and various Draconian executive orders and
policy changes. She also analyzes other instances when the U.S. government has
taken repressive measures in history. Parenti’s book, The Terrorism Trap, steps
back from the events of September 11th to look at the historical and
political-economic context in which they took place, including a chapter on
Afghanistan’s recent history. Howard Zinn’s book, Terrorism and War, is based on
a series of interviews conducted by Anthony Arnove, a member of the
International Socialist Organization (ISO). Despite his affiliation with this
authoritarian organization, Arnove asks well-informed, interesting questions
which help to create a well-rounded presentation by Zinn. Of the three, Zinn has
the best politics, being a libertarian socialist or anarchist, Chang is a
liberal who defends the Constitution and the highest ideals of the United
States, and Parenti is an Old Left Marxist.

The Assault on Civil Liberties

Nancy Chang works as a senior litigation attorney for the Center for
Constitutional Rights (CCR), which is basically a left-wing American Civil
Liberties Union. Her work there focuses on protecting the First Amendment rights
of political activists and the constitutional rights of immigrants, as well as
fighting against racial profiling.


A large part of Chang’s book examines the ideological nature of the USA
PATRIOT Act. This legislation (hastily drafted and spanning 342 pages) was
passed overwhelmingly by Congress just over a month after the September 11th
attacks, in the near hysterical climate of the time. Chang summarizes her
critique succinctly: “First, the Act places our First Amendment rights to
freedom of speech and political association in jeopardy by creating a broad new
crime of ‘domestic terrorism’ and denying entry to noncitizens on the basis of
ideology. Second, the act reduces our already low expectations of privacy by
granting the government enhanced surveillance powers. Third, the act erodes the
due process rights of noncitizens by allowing the government to place them in
mandatory detentions and deport them from the Untied States based on political
activities that have been recast under the act as terrorist activities.”3


Just what constitutes “terrorism” and “terrorist activities” is defined
broadly enough to allow the inclusion of just about anyone who might question
unlimited state power or the right of the market to rule all social life.4 The
Act creates the crime of “domestic terrorism,” which applies to “acts dangerous
to human life that are a violation of the criminal laws” if they “appear to be
intended … to influence the policy of a government by intimidation or
coercion.”5


The application of the term terrorist to people using extra-legal means to
influence government—and corporate—policy has a precedent in the case of the
Earth Liberation Front (ELF). The ELF uses illegal means such as arson to cause
economic damage to those they see as profiting from damaging the ecosystem. They
go out of their way to ensure no humans are endangered when they carry out their
acts of economic sabotage, primarily aimed at multinational corporations, yet
they are labeled terrorists by the government and corporations, eco-terrorists,
to be precise.


Of course history is propelled by illegality. The world we live in today has
been shaped by illegal actions, from the Boston Tea Party, to the sit-down
strikes in Flint, Michigan in the 1930s, to the Civil Rights campaigns of the
1950s and 1960s. They all were illegal, and one could argue that some of those
actions would fit the new definition of terrorism.


In the current climate, political repression will go hand in hand with racism
and thus Muslims will be most vulnerable, but so will dissidents in general. As
Chang points out, “the government will use this new crime to target Muslim
nationals of Arab and South Asian countries, political activists, and dissident
organizations for surveillance, infiltration, and prosecution.”6


In fact, the targeting of Muslims began immediately after the attacks, with
the detention of well over one thousand people, perhaps exceeding two thousand.7
As Chang explains: “With little concern for the rule of law, the government has
interrogated without suspicion, arrested without charge, and detained without
justification numerous individuals who are not involved in terrorist activities
but who match this religious and ethnic profile.”8


This is racial profiling with a vengeance. Chang documents several examples
of how these two thousand people wound up behind bars: “a Moroccan youth was
arrested and detained for four months as he sought to enroll in high school when
a guidance counselor reported to the police that his tourist visa had expired.
In another case, a man from Jordan was arrested and detained as he was seeking
to renew his driver’s license. In a third case, an Egyptian man was arrested
when a police officer he had flagged down to ask for directions asked to see his
passport.”9 All these folks and more ended up behind bars.


Traditionally, the constitutional protections enjoyed by American citizens
have also applied to non-citizens. That is no longer the case, and the change
has come about primarily through executive initiative. As Chang reports,
“Freshly minted rules permit the INS to detain noncitizens indefinitely without
charge, exclude the press and the public from immigration hearings of detainees
of special interest, automatically override immigration judges’ decisions
ordering the release of detainees on bond, withhold the names of detainees, and
subject noncitizens and their representatives to protective orders barring them
from disclosing what took place at their immigration hearings.”10 Those held,
some for well over a year, have been subjected to less than humane conditions
while incarcerated: “Untold numbers of detainees with no links to terrorism or
records of violence, charged with no more than minor immigration violations,
have been placed in solitary confinement for months at a stretch. They have been
housed in small windowless cells under bright lights that remain on twenty-four
hours a day.”11


Chang’s book also does an excellent job documenting similar occurrences in
U.S. history, going back to the Sedition Act of 1798, up through the
Counter-Intelligence Program (COINTELPRO) in the 1960s and 1970s, and the FBI’s
campaign against Central American solidarity activists in the 1980s.


Of particular relevance to the current situation are the Palmer Raids during
World War I. Then, like now, an immigrant community was targeted for political
repression. At that time, a bomb went off at the home of Attorney General
Palmer. The administration of Woodrow Wilson used this as a pretext to attack
the radical immigrant community. The U.S. government “interrogated, arrested,
and detained as many as ten thousand resident aliens who had been targeted based
on their political ideology . . . and [this] resulted in the deportation of more
than five hundred immigrants, not one of whom was proved to pose a threat to the
United States.”12 Those deported included anarchists Emma Goldman and Alexander
Berkman.


Another important historical precedent outlined by Chang is COINTELPRO, which
the USA Patriot Act officially and openly returns us to.13 Originally
established by the FBI in 1956 to investigate the Communist Party, by the 1960s
COINTELPRO widened its targets to include the movements of that era. Today we
are treated to empty assurances that government surveillance is meant simply to
protect Americans, but looking back a mere thirty years—or twenty in the case of
the FBI’s attempt to disrupt and stop the movement against U.S. intervention in
Central America—we can see what happens when the government increases its
attention to those it perceives as a threat. As Chang points out: “In the case
of the FBI’s investigation of the black nationalist movement, agents were
instructed to ‘prevent groups and leaders from gaining “respectability” by
discrediting them’ and prevent the rise of a ‘messiah’ such as Dr. King . . .
‘who could ‘unify and electrify’ the movement.”14 In fact, from 1963 until his
assassination in 1968, Dr. Martin Luther King Jr. was “the target of a ferocious
FBI smear campaign, the goal of which was to ‘neutralize’ him as an effective
civil rights leader.”15


All of this and more came out when a group of citizens used direct action to
uncover the government’s war against dissent. In 1971, the Citizens’ Committee
to Investigate the FBI broke into the FBI Field Office in Media, Pennsylvania
and turned over seized documents to the press. This led, some five years later,
to the Church Committee Congressional Report which “condemned COINTELPRO for
having accumulated, in a manner ‘indisputably degrading to a free society,’
massive intelligence information on lawful activity, including protest activity
and domestic dissent, and on law-abiding citizens, for purposes ‘related only
remotely or not at all to law enforcement and the prevention of violence.’”16


Despite the extensive and well-publicized findings of the Church Committee on
government surveillance and dirty tricks aimed at its own citizens, the new
guidelines proposed by the committee to set limits on the FBI were never
enacted. Instead, the FBI itself established new guidelines, which were loosened
by Attorney General Smith in 1983 and then replaced by even more permissive
guidelines by Attorney General Ashcroft. According to Chang, these new
guidelines have set “the stage . . . for a replay of the worst abuses of the
FBI’s infamous COINTELPRO program.”17


Chang documents with depressing detail every change in the law and its
interpretation that has occurred since September 11th, and the historical and
political context within which these new developments take place, making this
book well worth reading. Ultimately, however, she believes in the U.S. system
and seems to think recent developments are an aberration, rather than the
continuation of a long history of control and, when necessary, outright
repression.


Throughout the book Chang expresses the opinion that those targeted by the
government were “innocent” and not doing anything to deserve the harsh treatment
they encountered. The implication is that the state is justified in violating
some people’s rights, as long as they do something to deserve such treatment.
Chang also seems to subscribe to a liberal belief in the inherent goodness of
the U.S. State and its Constitution, which is simply being perverted by the Bush
Administration. Despite her liberal naiveté about the history and intentions of
the U.S. government, everyone interested in freedom and direct democracy should
read Chang’s book.

The Political Economy of Imperialism

Michael Parenti, on the other hand, is in no way naïve about the nature and
functioning of the U.S. government. His book, The Terrorism Trap, is primarily a
political-economic analysis with a strong anti-imperialist perspective. Its
argument is crystallized by General Gray, commander of the U.S. Marines in 1990,
who said, “The United States must have unimpeded access to established and
developing economic markets throughout the world.”18 Parenti expands and
documents how this frank admission by a representative of the U.S. military
plays out on the world stage.


Parenti does two things in his book. First, he looks at capitalist economic
interests and how they dictate U.S. foreign and domestic policy. Second, he
looks at the history of U.S. military intervention to show why the current “War
on Terrorism” is unlikely to be any different. In this regard, Parenti’s book is
very good. One example may suffice. In 1989, the United States invaded Panama,
ostensibly to arrest someone previously on the CIA payroll—sound familiar?—by
the name of Manuel Noriega. Once the U.S. military was in control, things in
Panama changed: “Unemployment, already high because of the U.S. embargo, climbed
to 35 percent as drastic layoffs were imposed on the public sector. U.S.
occupation authorities eliminated pension rights and other work benefits, ended
public sector subsidies, privatized public services, shut down publicly owned
media, and jailed a number of Panamanian editors and reporters critical of the
invasion. The U.S. military arrested labor union leaders and removed some 150
local labor leaders from their elected positions within their unions. Crime,
poverty, drug trafficking, and homelessness increased dramatically.”19 Through
this and other examples, Parenti demonstrates clearly and con-vincingly that
“far from being wedded to each other, as U.S. leaders and opinion makers would
have us believe, capitalism and democracy are often on a fatal collision
course.”20


On the one hand, Parenti’s book does not offer much that is new to radicals.
For instance, it is the kind of introductory text which points out that while
the United States comprises only five percent of the planet’s population it
spends more on its military than all the powerful countries in the world
combined. On the other hand, it is a decent introduction to the role the United
States plays in the world for those in the dark. But his rhetoric may turn off
many of those not already convinced, thus limiting his ability to reach a larger
audience.


Unfortunately the book also has some serious content problems. For instance,
Parenti defends the Soviet invasion of Afghanistan and criticizes Noam Chomsky
for opposing it.21 Further, he claims Washington was opposed to the Soviet Union
because of “the alternative class system they represented.”22


Granted, Parenti’s examination of the history of Afghanistan does away with
the myth that the United States was simply responding to the Soviet invasion, by
pointing out that the CIA was actively destabilizing Afghanistan before the
Soviets invaded. But this in no way legitimates Soviet actions, as Parenti
implicitly asserts. In his presentation of the Taliban, Yugoslavia, and the
Soviet Union, it is not so much that he takes a third camp position, which
criticizes both sides, but rather he criticizes the United States vis-à-vis
these regimes, with the implicit message that they are good while the United
States is bad. Parenti is far too apologetic towards regimes that, while outside
of U.S. control, do not offer a viable social alternative.

History, From the Bottom Up

One thing we do not have to worry about with Howard Zinn is his being soft on
authoritarians, whether or not they are for or against U.S. foreign policy.
Zinn’s take on history and the current crisis is refreshingly clear headed,
rational, and optimistic. He is very anti-authoritarian in his outlook and
extremely critical of the actions of the U.S. both before and after the attacks.
His message is very simple: “If we want real security, we will have to change
our posture in the world—to stop being an intervening military power and to stop
dominating the economies of other countries.”23


One of the impacts of the September 11th attacks was to give those of us
living in the United States the type of experience usually reserved for those
targeted by U.S. power, either directly or via proxies. As Zinn points out: “The
horror of the terrorist attacks we experienced on September 11th is something
that people in other parts of the world—Southeast Asia, Iraq, Yugoslavia—have
experienced as a result of our bombings, of terrorism carried out by people we
have backed and armed. Knowing this should have a sobering effect on any desire
to continue with military solutions.”24 Of course by now we know no such
sobering up took place and any goodwill the U.S. enjoyed following the attacks
has been hopelessly squandered by the Bush Administration.


Zinn is completely opposed to the attacks on Afghanistan: “We are terrorizing
Afghanistan.”25 He cites the estimate of Professor Marc Harold who, based on
worldwide news reports, calculated more than 3,700 civilian deaths from U.S.
bombings.26 And this was in the first months of the U.S. attacks, prior to the
attacks on hostile wedding parties and the like, which occurred in 2002. Zinn
quickly dispenses with the notion that the attacks of 2001 were directed at the
United States because terrorists oppose our freedom and democracy. He correctly
points to the political dimensions of the conflict, namely United States’ policy
in the Middle East. He points out that prior to 1990, bin Laden was a U.S. ally,
a friend going back to the Soviet invasion of Afghanistan. Only with the
stationing of U.S. troops in Saudi Arabia did bin Laden turn his attention to
the United States. Up to that point he obviously had no problem with any
supposed freedom and democracy in the United States.27


As for the U.S.’s War on Terrorism, Zinn makes two points. First, this “war”
will not succeed because it is not possible to stop terrorism simply by bombing
and invading countries. And, second, if you take this strategy at face value and
judge its success based on the Bush Administration’s rationale, it has not been
a success at all: “They say they are after bin Laden, and he becomes the focus;
but they can’t find bin Laden. And then they say they want the Taliban leaders;
yet now they can’t get the Taliban leaders. So, even from their own stated
objectives—getting the Taliban’s leaders or al Qaeda or bin Laden—they have
failed.”28 Of course Zinn questions these objectives, asserting that even if
they were fulfilled, the “war” would not be won. He further points out that the
countries the United States chooses to bomb (Afghanistan and soon Iraq) are
those countries in the region not under U.S. control, unlike Saudi Arabia or
Turkey for example, which are in effect “client states,” and therefore highly
responsive to U.S. foreign policy. He also emphasizes that expanding the war to
include Iraq “gives the government a perpetual war and a perpetual atmosphere of
repression. And it generates perpetual profits for corporations. But it’s going
to make the world a far more unstable and dangerous place.”29


Zinn addresses the ideological nature of the War on Terrorism, drawing
parallels to the 1950s, McCarthyism, and the Cold War: “Terrorism has replaced
Communism as the rationale for the militarization of the country, for military
adventures abroad, and for the suppression of civil liberties at home. It serves
the same purpose, serving to create hysteria.”30 Zinn, ever the historian,
brings up what happened during the Cold War against Communism, which led to “the
deaths of millions of people in Southeast Asia and hundreds of thousands of
people in Central America.” For example, “in 1954, the United States overthrew
the government in Guatemala, which was not Communist but which was expropriating
the United Fruit Company. In 1973, the government in Chile was overthrown in the
name of fighting Communism. The government was not Communist, but it was not
serving the interests of Anaconda Copper and ITT. We have to bring up this
history and relate it to what is happening today.”31


In examining the historical record, Zinn responds to Bush’s assertion that
“We are a peaceful nation” by noting that “since World War II, there has not
been a more warlike nation in the world than the United States.”32 This brings
us to I.F. Stone, described by Zinn as “one of the great journalists of our
time.” When speaking to journalism students he would say to them, “‘Among all
the things I’m going to tell you today about being a journalist, all you have to
remember is two words: governments lie.’” Zinn believes it is “very important to
know that. Otherwise we are victims of whatever the authorities say.”33


As the United States prepares for another war against Iraq, it is important
to look at the last Gulf War. At that time, Pentagon briefers showed video
footage of pinpoint strikes against Iraqi targets, although Zinn points out
that, in fact, “pinpoint bombing is a fraud. They discovered after the Gulf War
that 93 percent of the bombs turned out not to be so-called smart bombs and that
the ‘smart’ bombs often missed their targets. Overall, 70 percent of our bombs
missed their targets.”34


Further is the myth of “collateral damage:” The United States dropped 88,500
tons of bombs on Iraq during a forty-three day period, “with the goal of, as the
Washington Post put it, ‘disabling Iraqi society at large.’ According to the
reporter Barton Gellman . . . ‘damage to civilian structures and interests,
invariably described by briefers during the war as “collateral” and unintended,
was sometimes neither.’”35


Another example comes from the bombing of Afghanistan, when the United States
intentionally bombed a Red Cross complex three times, “but, according to the New
York Times, ‘One of the American aircraft that had been ordered to hit the Red
Cross supply warehouses missed its target and hit a residential neighborhood
instead.’” Is this an example of collateral damage from intentional collateral
damage? Of course, all this talk of pinpoint accuracy is intended to make the
bombing of a largely defenseless people more palatable to the U.S. population.
Zinn argues that if the majority of the American people “knew that we were
killing large numbers of people, and displacing hundreds of thousands of people
from their homes, they would not take such a benign view of the Afghan war.”36


Finally Zinn asks, “If the deaths of civilians are inevitable in bombing, as
Donald Rumsfeld acknowledged, it is not an accident. The people prosecuting this
war are committing murder. They are engaging in terrorism.”37 Zinn calls for
doing “away with the terrorism of fanatic sects and the terrorism of
governments.”38 Ultimately, Zinn shares a point of view with the classical
anarchists who believed in the intrinsic goodness of people, which leads to his
sense of optimism in these dark times: “I do feel hopeful in this time that
seems to lack hope, and I suppose that is based on a fundamental belief in the
fact that there is a moral good sense in the American people that comes to the
fore when the blanket of propaganda begins to be lifted. I think there will be a
reassessment, and people who have been calling the war immoral will be
vindicated at some point.”39 Only time will tell if Zinn’s optimism is
warranted.

The Need for a Movement

As depressing as the changes in U.S. law and the political climate are for
anti-authoritarians, Christian Parenti (Michael’s son) points out that there is
a difference between the letter of the law and its lived practice. His point is
that the government can only get away with what the people allow it—there is a
give and take between the state and the people, and a mobilized citizenry is the
best defense against further encroachments.40 Chang, Parenti, and Zinn all
advocate citizen mobilization, although different kinds with different ends.


For Chang, this takes the form of grassroots mobilization and education,
which ultimately is aimed at pressing the judiciary and Congress to put checks
on abuses of power exercised by the executive.41 For Parenti, we need to “move
away from liberal complaints about how bad things are and toward a radical
analysis that explains why they are so.” Further, we need “a global
anti-imperialist movement that can challenge the dominant paradigm with an
alternative one.”42 Zinn wants an oppositional movement: “We can engage in civil
diso-bedience, in strikes and boycotts. We can all do what was done at other
times in American history when it was necessary to build a national movement to
say to the government, “No, you don’t speak for us. You’re not doing this for
us. You aren’t doing this in our name.”43


If we needed a bottom-up, anti-statist, and anti-capitalist movement prior to
September 11th, the need since then has only grown. As anti-authoritarians, we
need to stand side by side with immigrant communities targeted by the
government. We need to challenge the racist practices of the War on Terrorism
which play out both at home and abroad. We also need to assert our right to
affiliate, organize, and confront the state while not jeopardizing more
vulnerable communities through more militant actions. We need to oppose the war
on Iraq while using it as an opportunity to put forward a radical analysis of
war and its causes, while connecting our analysis to efforts already underway to
develop an understanding of capitalist globalization. Finally we should seek out
allies in these dark times and argue against attempts by the government—and
unfortunately many liberals—to make distinctions between “good protestors” and
“bad protestors,” arguing for a movement which utilizes a diversity of tactics.


In addition to opposing the state, part of the agenda of this movement must
be the change from an oil-based economy to one based on renewable, ecological
energy sources. The need for oil not only demands Middle East military
interventions, but it is also destroying the planet’s ecology by contributing to
the Greenhouse Effect and air pollution. As Parenti points out, “Only a
substantial effort to develop solar, tidal, and wind energies can make the
country more self-sufficient. These alternative sources are readily available,
infinitely renewable, [and] ecologically sound. . . . Indeed, if developed to
any great extent, alternative sustainable energy sources could destroy the
multi-billion dollar oil industry, which is why they remain relatively
underdeveloped.”44


Oil is key to the capitalist economy. Those in power will do anything to
maintain their control over its supply. These three books begin to tear away the
façade of the War on Terrorism and reveal what it really is: a war to maintain
U.S. global hegemony, increase control over Middle Eastern oil reserves, and
guard against the rise of any internal movement which may threaten these
objectives.


From the current issue of The New Formulation: An Anti-Authoritarian Review
of Books (February 2003, Vol. 2, No. 2). See

http://flag.blackened.net/nf/index.htm

Notes


1. The list of foreign military interventions since September 11th is
extensive. It includes not only Afghanistan, but also Uzbekistan and Kyrgyzstan.
The U.S. military has also returned to the Philippines with 660 Special Forces
troops meant to train the Philippine Army ostensibly to fight Abu Sayyaf, a
guerrilla force of some one hundred to two hundred fighters. The U.S. military
and the CIA have returned to the Horn of Africa, with some eight hundred Special
Forces and over 1,500 troops, who are conducting exercises in the impoverished
nation of Djibouti. It is from here that the CIA launched its Predator Drone
equipped with a Hellfire missile that killed five people in a car in Yemen,
including a supposed member of Al Qaeda and a U.S. citizen. Also, the U.S.
military is conducting exercises in Kuwait, a country which has turned over one
quarter of its territory to the U.S. military, closing it off to its own
citizens.


2. I refer here to Jose Padilla and Yaser Esam Hamdi.


3. Nancy Chang, Silencing Political Dissent: How Post-September 11th
Anti-Terrorism Measures Threaten our Civil Liberties (New York: Seven Stories
Press, 2002), 44.


4. One need not qualify as a “terrorist” to warrant government investigation,
even under the broad new definition. The government must now simply state that
the proposed surveillance is part of an “ongoing criminal investigation” to be
granted powers which previously required the showing of probable cause.


5. Nancy Chang, Silencing Political Dissent, 44. (These acts must also occur
primarily within the United States)


6. Ibid., 45.


7. This number comes from David Cole as reported in his "Enemy Aliens,"
Stanford Law Review 54 (2002): 951, 958; cited in Chang, Silencing Political
Dissent, 69.


8. Chang, Silencing Political Dissent, 67.


9. Ibid., 71.


10. Ibid., 68.


11. Ibid., 85.


12. Ibid., 39.