The gun issue polarizes individuals in our society as few other issues do. Those who value one’s right to keep and bear arms as affirmed by the Second Amendment to the Constitution offer historical quotations, moral and philosophical arguments, and statistics showing the usefulness of firearms for self defense. Others, concerned by the daily acts of violence that seem to have become almost routine, call for “gun control” as a means of returning to a more civil society. They, too, offer moral and philosophical arguments, and statistics showing the dangerous nature of firearms in private citizens’ hands.
Twenty-Seven Simple Words, But What Do They Mean?
A well regulated Militia, being necessary to the Security of a free State, the Right of the People to keep and bear Arms, shall not be infringed.
That’s the entire text of the Second Amendment—the logical place to start, even if it seems far removed from current concerns. It seems so straightforward, doesn’t it? Yet those twenty-seven words have been interpreted in myriad ways, by courts and individuals alike. Many of these interpretations have resulted in fewer choices for women who wish to use firearms to protect themselves. Much of the discussion centers on what the Founders intended by the amendment, and therefore, on some specific words used in it.
The first of these is “militia.” Arguments that the word refers to state militias are often advanced by those who support restrictions on private ownership of firearms. The Supreme Court in 1969 defined the militia to be the National Guard. (1) However, the definition of the term states that a militia is a military force comprised of citizens rather than professional soldiers (today’s National Guard falls under the category of professional soldiers, as they are paid for their service, and are considered part of the Army). And in 1792, the Congress specifically defined ‘the militia’ to be all able-bodied military-age male citizens of the United States. (2) To further distinguish between state militias and private citizens, 10 USC 312 specifically exempts active duty military members from the militia (effectively distinguishing between state and unorganized militias). Thus, despite the rulings of the Court in this century, what the Founders meant by the term “militia” is clear—private
citizens capable of rendering military service.
The Founders’ meaning of “the people” is also challenged. Some argue that these words should be interpreted as a collective right, and that as long as firearms can be legally owned by some individuals—usually the police and military—the 2nd
Amendment will not be violated. This interesting interpretation is generally not extended to the other amendments. What would your reaction be if someone used a similar argument as the basis for limiting an individual’s right of freedom of speech? It’s silly to think that as long as some group—the Ku Klux Klan, for example—has free speech while others do not, the first amendment is intact. One source of confusion stems from the fact that the phrase “the people” means different things today. Frequently it means the state, such as in trials, for example, “the people vs. Larry Flynt.” When the 2nd
Amendment was written, “the people” meant literally that—the citizens of this nation. Indeed, many of the authors of the Constitution and the Bill of Rights are on record as supporting the right of the individual to own firearms. Samuel Adams’ well-known quotation is a good example: “The Constitution shall never be construed to prevent the people of the United States, who are peaceable citizens, from keeping their own arms.” (3)
Others choose to focus on the word “arms.” It is common to hear arguments that the Founders had no idea that weaponry would advance as it has, leading to automatic weapons that can fire hundreds of rounds in seconds, missiles that can strike targets across continents with deadly accuracy, and even nuclear weapons with their capacity for death and destruction on a huge scale. While that may be true—albeit unlikely, as Jefferson and others were clearly men of great minds, seeing beyond their time and circumstances—it is irrelevant. It would surprise me to learn that someone would seriously advance arguments such as, “The Founders didn’t foresee the abilities of modern vehicles, so we must control access to automobiles and jets”, or “Refrigeration is a powerful tool that the Founders couldn’t have predicted would be so important, therefore its use must be highly regulated, with mandatory licenses, training, and permission to refrigerate granted by the state.”
A different tactic concerns not individual words, but the beginning phrases of the 2nd
Amendment. Some gun-control advocates advance the argument that the opening clause limits the ownership of firearms to those who would protect the state. While that might seem a reasonable claim, the analysis above makes it clear that that was not the intent of the Founders. Indeed, the clause gives one reason why
private ownership of firearms is invaluable. An attempted seizure of privately-owned arms by the British at Lexington and Concord led to the Revolution—hardly the action of men who believed, as this argument implies, that the state has a right to limit ownership of firearms.
The structure of the 2nd
important, however. The 2nd
Amendment does not say, “The people have the government’s permission to own arms.” It states that the right to own and carry firearms shall not be limited by the government. This phrasing makes it clear that the Founders are simply affirming the right of firearms ownership. The fundamental right to self-defense was well-established in English common law and its antecedents, upon which the Constitution is based in part. The Founders believed this right to be self-evident, and reflected that in the words chosen for the 2nd
Amendment—“the right of the people to keep and bear arms, shall not be infringed.”
Freedom and Firearms
The Founders’ purpose in enumerating specific rights in the Bill of Rights was not to “grant” those freedoms, but to explicitly limit the federal government’s control over the states and individuals. To paraphrase the preamble to the Declaration of Independence, some things are self-evident, including an individual’s right to life, liberty, and the pursuit of happiness. The rights enumerated in the Bill of Rights help ensure an environment in which an individual is free to maintain her life peaceably, enjoy her liberties, and pursue happiness. Articles IX and X make it clear that an American’s rights are not limited to those listed in the Bill of Rights. (Article IX states that the listing of certain rights in the Constitution does not deny the existence of other rights, and Article X states that the powers not given to the United States government by the Constitution are reserved to the states or the people.)
What does all this have to do with guns? The Founders knew, through their own Revolution as well as observation of other governments, that the state itself is the greatest threat to individual liberty. Without some means of checking the power of the state, any government will inevitably move to exert greater control over individual lives and choices, including those of women. Firearms in the hands of private citizens help to protect against that encroachment on liberty. The 2nd
Amendment affirms the right that allows all other rights, including those not enumerated in the Constitution, to be defended. As George Mason put it, "...to disarm the people (is) the best and most effective way to enslave them.…." (4)
All of the laws a government enacts are backed by the threat of force—“If you don’t obey the law we can and will harm you.”
Without a countervailing threat of force, the state can fairly easily devolve into tyranny. What effective means would a law-abiding citizen have at her disposal to stop the police or an FBI agent—or any of a number of government officials who now routinely carry firearms—from wrongfully seizing her property, without the ability to similarly arm herself? Or, if a well-intentioned government exceeds its bounds and begins to suppress individual freedoms, how would those individuals who cherish freedom attempt to resist that government in toto
? The 2nd
Amendment provides the means for private citizens to preserve and protect liberty from the state, be it foreign invasion or domestic hostility to freedom.
Without the 2nd
Amendment, the Bill of Rights lacks enforcement teeth. The courts may appear to be a means of protecting liberties, but they are administered by the state, and therefore can be used to the state’s purposes. Similarly, voting and other means of enacting or repealing laws only works as long as both sides—private citizens and state agencies—agree to abide by the outcomes of these actions. The only effective means of checking the state’s use of force is for the people to have a significant opposing force available. Thomas Jefferson understood this well: “The strongest reason for the people to retain the right to keep and bear arms is, as a last resort, to protect themselves against tyranny in government.” (5)
Many gun control advocates appear to be much more trusting of the state and its agents than Jefferson was. Most seem comfortable in allowing only law enforcement officials to possess guns. History shows again and again that when this happens, tyranny is the result. In feudal Japan, for example, the warrior class made it a crime for any other individuals to learn to fight or to have access to arms. Hitler began his reign of terror in part by strict enforcement of laws denying private ownership of firearms, and when the citizens were disarmed, he began rounding up Jews, gypsies, blacks, and other non-Aryans. For any age, there is undoubtedly an example.
It may seem unreasonable or crazy to think that such things could happen here—not in America!—but no crystal ball exists that can show what might happen, and this country has already committed its own atrocities. Ask the black men who were infected with syphilis and deliberately left untreated, so that the state could document its effects. Or ask the Japanese Americans—American citizens, not foreigners—who were put in interment camps and whose property was seized during World War II. But it doesn’t have to be such obvious misdeeds; even the most well-intentioned laws can have disastrous results. For example, consider the good intentions of lawmakers who required the installation of airbags in automobiles—a safety feature for adults, but one with deadly consequences for small children riding in the front seat of a car.
It’s also worth noting that the Gun Control Act of 1968—the first round in the big push to limit RKBA—seems to be modeled on the gun control laws Hitler used, including some passed during his rule. For example, it contains the first mention in American firearms law of the concept of “sporting purpose”, which was a European idea, and a direct translation of “Sportzwecke” from the 1938 German statute. The late Senator Thomas Dodd, the author of the Gun Control Act, was known to have a copy of Germany’s Waffengesetz
(Law on Weapons) in his possession about the time he wrote his bill. The Web site of the Jews for the Preservation of Firearms Ownership <http://www.jpfo.org/>
has more details, as well as a book which offers a line-by-line comparison of the two laws. (6)
Government agents do
make mistakes, and they can be corrupted. No matter how unlikely either possibility may seem, the fact that they do happen makes it necessary for private citizens to be able to defend themselves against them. Governments also have a record of stifling personal liberty in favor of state control. The 2nd
Amendment is an individual citizen’s guarantee of having substantial protection against all such possibilities. By including RKBA in the Bill of Rights, the Founders were stressing the importance of a vigilant, armed society, both for individual defense and the defense of freedom.
Tools for Protection? Or Tools of Destruction?
Personal defense is an increasingly important consideration in our troubled society. Imagine yourself in the following situation: It’s a wintry evening, dusk deepening to snowy dark, and you’re a petite woman walking across a mostly-empty parking lot to your car. Just as you hear the shuffling footfalls approach from your right, a hulking figure closes in, grasps your arm, and growls, “This way, babe, and don’t make no noise!” Mr. Thug easily has 10 inches and 100 pounds—most of it muscle from what you can see—on you. A quick scan of the surroundings shows no one nearby. What do you do?
For women, personal defense is a vitally important issue, as men generally outweigh and outmuscle women, and commit most violent crimes. The above example is not simply a stereotype; it reflects the probabilities. Therefore, a woman needs to be able to try to equalize the force she can bring to such encounters. Several options exist for doing so, including martial arts, self-defense courses, pepper spray, and other tools for self-defense. Many who attribute much of today’s violence to guns recommend these as alternatives to gun ownership.
Martial arts and self-defense training, for those who are well-trained and highly-practiced, offer a solid physical as well as mental approach to fending off Mr. Thug. They can help counteract strength and weight advantages men have, but not always—particularly if Mr. Thug also knows how to fight. More importantly, to exercise the maneuvers these methods rely on, the potential victim needs to be close to the person who wants to harm her. This increases her risk of being hurt. There are also occasions when the effectiveness of one’s own body as a tool for self-defense is limited or absent, such as advanced pregnancy or certain injuries.
Other tools for protection, such as a knife or a baseball bat, have challenges and limitations as well. For a knife to be successful, one must know how to use it, and be close enough to Mr. Thug for it to be effective. Again, that increases the risk of injury. Baseball bats and metal pipes also require the bad guy to be in close physical proximity. They have the added disadvantages of being more easily taken away and impractical for concealed carry. Pepper spray is illegal in some places, has a limited range, and can affect its user as well—for example, if the attacker is upwind, it will blow into the defender’s face. A tolerance to the spray can be built up, or Mr. Thug can simply wear protective gear, thereby making it a useless tool for protection.
Firearms offer many advantages that other means of protection cannot. They are a great equalizer of force, enabling a 90-pound grandmother to successfully fend off a 200-pound muscle-bound youth. They do not require brute strength nor close physical proximity, and they often act as a powerful deterrent upon sight. If you actually faced the scenario described above, which would you rather do: use your body as a weapon against Mr. Thug; or pull out a .45 caliber handgun—at which point Mr. Thug would probably take off running? Even if he didn’t, it would only take a couple of flicks of your thumb and index finger—about the same amount of effort required to flip through the pages of a small paperback—to propel a bullet into Mr. Thug’s body.
Gun control advocates point out that there are disadvantages to using a firearm as well. One often stated is that the weapon can be taken away from the victim and used by the bad guy against her. However, this happens very rarely—in about one per cent of such encounters. (7) Another is that an individual who relies on firearms may have a false sense of security, and may freeze up if an attacker does approach her. It is true that just the sight of a firearm may scare off an intruder, so that one needn’t worry about actually aiming and shooting, but it would be extremely foolish to rely on that possibility. To be maximally effective, the gun owner must learn basic firearms safety and use, and practice with her gun regularly. Such training greatly minimizes the risk of firearms-related accidents, and also reduces the likelihood of freezing to the same chance as when any other means of self-defense is used. If a criminal senses fear or hesitation, he will likely try to fight with his victim for the weapon; anyone who has doubts about her ability to use her firearm for its intended purpose during an assault should not carry one.
Other objections center on possession of the weapon in the home. An often-cited statistic is that individuals are 43 times more likely to die from a handgun being kept in the home than they are to kill a burglar with it. (8) The study from which this statistic originated is flawed, however. First, that figure includes thirty-seven suicides, which is a very different act from fighting off a would-be attacker. Including those suicides skews the data severely. More importantly, the data examined were only cases where handguns were used and “failed to protect” someone. Thus, the study completely overlooks all cases where a firearm successfully ends an attempted criminal activity. (To be fair, it is impossible to track all cases where firearms scare off a criminal, or where Mr. Thug changes his mind about breaking into a house because he learns the owner is well-armed; however, the fact that no attempt was made to address this side of the issue is revealing about the conclusions the authors probably wished to be able to make.) Another study of gun use for protection found that it is 216 times more likely to be used against a criminal than to cause the death of an innocent person in the household. (9) Comparing resistance with and without firearms, Professor John Lott Jr. found that the odds of a woman sustaining a serious injury from an attack are 2.5 times higher for women resisting without a gun than with a gun. (10)
To many individuals, the use of a firearm as a tool for self-defense seems like too much power. Just pointing a gun at another individual is a very intimidating gesture. (It is also assault with a deadly weapon in many places.) If Mr. Thug is wounded or killed, that’s a pretty serious consequence. And, some would argue, that places his shooter in the position of being judge, jury, and executioner. Consider these questions, though. In what other situation can a person be more certain about what is about to happen to her, than when Mr. Thug is sneaking into her bedroom at 3 a.m.? Would he think twice about using his gun on you? If not, then your use of a gun for protection is simply responding to force with similar force. The moral responsibility for initiating the use of that force rests with Mr. Thug. If protecting yourself isn’t sufficient reason to be armed, isn’t protecting your loved ones? Spouses and children can’t be replaced. Which would you rather do—stop a potential crime from happening, or allow something to happen which can never be undone, and trust in the courts to convict Mr. Thug? Even if justice is served in this manner, you and yours will still have been victimized by someone else’s aggression; nothing can change that. The scene of an attempted attack is not the place for niceties and manners; it’s a place where, if you don’t take firm steps to protect yourself, Something Very Bad will happen.
Many individuals cite drive-by shootings, and shootings in public places—restaurants and public schools seem to be popular venues—as evidence that guns cause violence in today’s society. These activities are
examples of senseless violence and their causes must be addressed. Unfortunately for those who would make banning guns the easy solution, a moment’s careful thought should be enough to demonstrate why it won’t work. Guns have always been part of this society, yet these brutal killings have not. Despite more than 20,000 gun-control laws already in effect, those who seek large-scale destruction are not deterred. Guns do not cause violence—have you ever seen a handgun or shotgun sprout little feet and hands, then start running around a town, pulling its own trigger? Guns are tools that require a person to unleash their deadly force; they have no inherent moral value or will to act. As long as there have been people, there has been violence, and that sad fact will never be legislated away. Instead of blaming the tools that are used in crime, those who deplore mass killings are better served trying to find out why such violent acts occur and counter the true causes.
Why are these places the targets of psychopathic rage, anyway? One reason is that they provide a “target-rich environment”—lots of people to shoot at. Another is that many current gun-control laws make it illegal for an individual to carry her weapon into such places, particularly public schools. When was the last time a police station was the target of a killer’s rampage—or an inner-city school, for that matter? Everyone knows that cops have guns, and will return fire, and the same is true for many of the kids in inner-city schools. Making schools “gun-free zones” means that it’s very unlikely that someone there will be armed and able to return fire when the killing begins. It’s a simple case of Mr. Thug going where the guns aren’t. If that seems too simplistic an answer, consider this: Israel dropped the terrorist attack rate on schools to zero after adult school employees and parent volunteers began carrying their firearms to school. (11)
Girls and Guns: A Good Mix?
Firearms are an important part of preserving our freedoms, both from the power of the state and from bad guys who wish to harm peaceable individuals. For violent encounters, guns are the best equalizer of force between men and women currently available. There are other reasons why it’s particularly important that women carry guns.
Consider another hypothetical example for a moment. As a proud advocate of gun control, you have no firearms in your house, nor even a plan for dealing with Mr. Thug should he come calling. Late one evening, alone with your young daughter, you hear the tinkle of glass shards hitting the floor coming from the direction of your front door. What are your choices?
You can dial 911. If you live in a large city, though, you should start thinking of ways to entertain your way out of Mr. Thug’s evil plans, or make sure your life and health insurance premiums are paid up. The response times to 911 calls in many cities are long enough to virtually guarantee that Mr. Thug will do his worst and be on his way long before any law enforcement official shows up.
You can dial the police directly. Even in smaller towns and rural areas, the result is often the same, unless a policeman on patrol happens to be within a block or two of you. Police forces are generally spread so thin that they have their hands full with traffic stops and other routine patrols. And law enforcement agents aren’t obligated to protect you, anyway. Although many gun-control advocates state that individuals should look to the police and the courts for protection, the courts have declined to put that responsibility on law enforcement officials. The Supreme Court in both 1856 (12) and 1982 (13) stated that individuals should not expect to be protected by law enforcement personnel, and that no right to protection exists.
You can call a muscular neighbor for help. But honestly, if you haven’t chosen to take measures to protect yourself, why should the neighbor trouble himself to help you, and put his safety at risk? Your personal safety is your own responsibility. If you don’t choose to accept this responsibility, why should anyone else bother?
Aside from the fact that in each of these choices you’d be asking someone else to take on a responsibility that is yours, there’s another important consideration for women: law enforcement officers tend to be male. This means that in most cases, you would be asking a man to help you protect yourself. This perpetuates the myth that a woman has to rely on a man for her protection. Despite advances in understanding the causes of rape, and training courses in sensitivity for law enforcement officers, many still cling to old stereotypes. So, you call 911, the cops show up—after
you’ve been raped and beaten—and they swagger around and ask questions like, “What were you wearing at the time of the assault? Did you encourage him in any way, ma’am?” while looking through your bedroom in search of evidence and frightening your daughter—who thankfully was not harmed. This time.
Having a weapon on hand is the best means of self-protection a woman can currently choose. In fact, carrying a concealed weapon offers protection to other women as well. An analogy shows how that works. There are twenty women in a room with one rapist, and he’s told he can choose from among them for his attack. Five of them have a concealed weapon, however, and if he chooses one of them, she will shoot him. He has no way to tell which women are carrying.
Do you think he’ll risk getting shot by making a choice? Despite the stereotype of Mr. Thug being out for blood no matter what, most criminals prefer to stay alive, which is why they try to choose victims who appear least likely to resist or challenge them. If such a victim isn’t easily identified, Mr. Thug will generally move on.
There’s evidence demonstrating that concealed carry does work as described. In a comprehensive study of concealed carry laws, John Lott Jr. and David Mustard found that enacting concealed carry weapons laws resulted in an eight per cent drop in the murder rate, and a five to seven per cent drop in aggravated assault and rape rates. (14) Bad guys know that armed citizens make bad targets, and rather than risking their necks, they’ll go someplace else, or choose a different form of crime that is less risky.
Many people are concerned—and rightly so—about the combination of guns and kids in the home. The reports of children finding guns and playing with them, with disastrous results, get a lot of attention. Some will object to my scenario above, saying that if the woman had a gun in her purse, it’s likely her daughter would have found it and shot herself or a playmate. That is a possibility, but having a firearm for protection doesn’t necessarily create a greater risk for your children. One of the reasons kids play with guns is that they aren’t able to see them—the parents hide them out of reach (or so the parents think), and tell the children to stay away from them. Hiding a firearm from a child is one of the most dangerous things a parent can do with it! The gun becomes a tempting toy in the child’s mind, rather than the potentially lethal object it is.
Handling the firearm responsibly and matter-of-factly in a child’s presence, answering her questions about it honestly, and allowing her to touch it as she wants, under supervision, removes the mystery from the gun, and makes it much less likely that she’ll try to get it when you’re not around. A child, if taught proper gun safety and technique, might also save your life in such a situation. Cases of children shooting would-be attackers are regularly documented in various gun magazines. The child tends to go unnoticed by Mr. Thug, or is dismissed as not dangerous, when in fact children tend to put a gun right up to Mr. Thug’s body in order to make sure Mommy or Daddy isn’t accidentally shot.
The right to keep and bear arms, while being part of our Constitutionally-protected rights, far exceeds its importance as an historical statement for scholars to debate. Ownership of firearms by private citizens remains the best way to defend freedom, from both the state’s encroachment and individual threats to liberty. This includes criminals who threaten an individual’s right to life and liberty by their acts of aggression.
Originally, the feminist movement was about empowering individual women to choose the paths they wanted for their lives. Self-reliance and personal responsibility were important aspects of the feminist movement, which focused on securing women’s rights, but the movement respected men’s rights as well. Today, feminists are split into various factions, some of which seem to hate all that is male; others would look to the state for protection rather than taking that responsibility themselves. Some proudly maintain the original vision of individualism and feminism—that each individual, irrespective of gender, should have no barriers placed in the way of the pursuit of life, liberty, and happiness. For these feminists, RKBA affirms the inherent human right of self protection, and the right to choose the most effective method of protecting oneself, loved ones, and property.
For some feminists, the RKBA issue seems to be more complicated, as concerns about escalating violence and protecting children weigh in. While these are legitimate issues to be addressed, there are no simple answers. Each person must educate herself as to the risks and benefits of firearms for protection. Should she choose a gun for her self-defense, it is her responsibility to learn how to handle it safely, and to teach those in her household to do the same. Women who advocate gun control are restricting others’ freedoms, and are forcing many women to rely on men to protect them in emergency situations. This is a dangerous and insulting folly. Individuals who advocate gun control “for the children” have helped create the gun-free zones of public schools that become “defenseless victim slaughter zones”. We’ve seen the tragic results, as disturbed individuals make targets of our children in those places—one man used a car in a recent multiple homicide in a California school yard—because they know that the adults charged with the kids’ safety have no effective weapons with which to protect the children or themselves. Making the best tool a woman can have at her disposal to protect herself and her loved ones an illegal choice is almost as anti-woman as a rapist’s vile act.
We now see women in many positions of power and influence in our society—women who are looked up to by many other women. Among them are Senator Dianne Feinstein and talk show host Rosie O’Donnell. Although Feinstein swore an oath to uphold and defend the Constitution, including the 2nd
Amendment, she’s clearly not doing so, as this quotation shows: “If I could have gotten 51 votes in the Senate of the United States for an outright ban, picking up every one of them... ‘Mr. and Mrs. America, turn 'em all in,’ I would have done it.” (15) Among her other anti-gun statements, Rosie has said, “…I don't care if you think it's your right. I say 'sorry'. It is 1999, we have had enough as a nation. You are not allowed to own a gun and if you do own a gun, I think you should go to prison.” (16)
If these are the kinds of role models available for our daughters today—women who ignore their sworn duty and who would limit other individuals’ choices, making easier targets of other women—perhaps we should look back in history for better ones. One I would choose for my children, sons and daughters alike, would be Annie Oakley.
1. Burton v. Sills, 248 A.2d 521 (NJ 1968) appeal dismissed 394 US 812 (1969).
2. First Militia Act, 1 Stat. 271, 1792.
3. Samuel Adams, During Massachusetts’ U.S. Constitution Ratification Convention, 1788.
4. George Mason, During Virginia’s Ratification Convention, 1788.
5. Thomas Jefferson, Proposed Virginia Constitution, 1776.
6. JPFO web site, http://www.jpfo.org/GCA_68.htm.
7. Kleck, G. (1991). Point Blank: Guns and Violence in America. Hawthorne, NY: Aldine de Gruyter.
8. Kellermann, A., & Reay, D. (1986, June). Protection or Peril? An Analysis of Firearm-Related Deaths in the Home. The New England Journal of Medicine, vol. 314, no. 24, pp. 1557-60.
9. Kleck, G. (1991). Point Blank: Guns and Violence in America. Hawthorne, NY: Aldine de Gruyter.
10. Lott, J.R., Jr. (1998). More Guns, Less Crime: Understanding Crime and Gun Control Laws. University of Chicago Press.
11. Proven Solutions to End School Shootings, JPFO, http://www.jpfo.org/school.htm .
12. South v. Maryland, 1856.
13. Bowers v. DeVito, U.S. Court of Appeals, Seventh Circuit, 686F.2d 616 (1982).
14. Lott, J.R. Jr., and Mustard, D.B. (1997).Crime, Deterrence, and Right-to-Carry Concealed Handguns. Journal of Legal Studies, vol. XXVI.
15. U.S. Senator Dianne Feinstein, CBS-TV's 60 Minutes, February 5, 1995.
16. Rosie O’Donnell, April 21, 1999, on public television.
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