Sunday, March 17, 2013

Denying the Role of Radical Islam In Terrorism

The following by Daniel Pipes is reposted here with permission of Middle East Forum:

Explaining the Denial
Denying Islam's Role in Terror

by Daniel Pipes
Middle East Quarterly
Spring 2013, pp. 3-12 (view PDF)

Over three years after Maj. Nidal Malik Hasan's massacre at Fort Hood, Texas, in November 2009, the classification of his crime remains in dispute. In its wisdom, the Department of Defense, supported by law enforcement, politicians, journalists, and academics, deems the killing of thirteen and wounding of forty-three to be "workplace violence." For example, the 86-page study on preventing a repeat episode, Protecting the Force: Lessons from Fort Hood, mentions "workplace violence" sixteen times.[1]

Indeed, were the subject not morbid, one could be amused by the disagreement over what exactly caused the major to erupt. Speculations included "racism" against him, "harassment he had received as a Muslim," his "sense of not belonging," "mental problems," "emotional problems," "an inordinate amount of stress," the "worst nightmare" of his being deployed to Afghanistan, or something fancifully called "pre-traumatic stress disorder." One newspaper headline, "Mindset of Rogue Major a Mystery," sums up this bogus state of confusion.[2]

Eric Holder
U.S. officials' denials of Islam's role in terrorism might be humorous if they were not so frightening. During congressional testimony in May 2010, Attorney General Eric Holder repeatedly sparred with his congressional questioners over the possible part played by "radical Islam" in inciting the actions of domestic terrorists and refused to acknowledge its decisive role.
In contrast, members of congress ridiculed the "workplace violence" characterization and a coalition of 160 victims and family members recently released a video, "The Truth about Fort Hood," criticizing the administration. On the third anniversary of the massacre, 148 victims and family members sued the U.S. government for avoiding legal and financial responsibility by not acknowledging the incident as terrorism.[3]
The military leadership willfully ignores what stares them in the face, namely Hasan's clear and evident Islamist inspirationProtecting the Force mentions "Muslim" and "jihad" not a single time, and "Islam" only once, in a footnote.[4] The massacre officially still remains unconnected to terrorism or Islam.

This example fits in a larger pattern: The establishment denies that Islamism—a form of Islam that seeks to make Muslims dominant through an extreme, totalistic, and rigid application of Islamic law, the Shari'a—represents the leading global cause of terrorism when it so clearly does. Islamism reverts to medieval norms in its aspiration to create a caliphate that rules humanity. "Islam is the solution" summarizes its doctrine. Islam's public law can be summarized as elevating Muslim over non-Muslim, male over female, and endorsing the use of force to spread Muslim rule. In recent decades, Islamists (the adherents of this vision of Islam) have established an unparalleled record of terrorism. To cite one tabulation: counts 20,000 assaults in the name of Islam since 9/11,[5] or about five a day. In the West, terrorist acts inspired by motives other than Islam hardly register.

It is important to document and explain this denial and explore its implications. The examples come predominantly from the United States, though they could come from virtually any Western country—except Israel.

Documenting Denial

The government, press, and academy routinely deny that Islamist motives play a role in two ways, specific and general. Specific acts of violence perpetrated by Muslims lead the authorities publicly, willfully, and defiantly to close their eyes to Islamist motivations and goals. Instead, they point to a range of trivial, one-time, and individualistic motives, often casting the perpetrator as victim. Examples from the years before and after 9/11 include:
  • 1990 assassination of Rabbi Meir Kahane in New York: "A prescription drug for … depression."[6]
  • 1991 murder of Makin Morcos in Sydney: "A robbery gone wrong."
  • 1993 murder of Reverend Doug Good in Western Australia: An "unintentional killing."
  • 1993 attack on foreigners at a hotel in Cairo, killing ten: Insanity.[7]
  • 1994 killing of a Hasidic Jew on the Brooklyn Bridge: "Road rage."[8]
  • 1997 shooting murder atop the Empire State Building: "Many, many enemies in his mind."[9]
  • 2000 attack on a bus of Jewish schoolchildren near Paris: A traffic incident.
  • 2002 plane crash into a Tampa high-rise by an Osama bin Laden-admiring Arab-American (but non-Muslim): The acne drug Accutane.[10]
  • 2002 double murder at LAX: "A work dispute."[11]
  • 2002 Beltway snipers: A "stormy [family] relationship."[12]
  • 2003 Hasan Karim Akbar's attack on fellow soldiers, killing two: An "attitude problem."[13]
  • 2003 mutilation murder of Sebastian Sellam: Mental illness.[14]
  • 2004 explosion in Brescia, Italy, outside a McDonald's restaurant: "Loneliness and depression."[15]
  • 2005 rampage at a retirement center in Virginia: "A disagreement between the suspect and another staff member."[16]
  • 2006 murderous rampage at the Jewish Federation of Greater Seattle: "An animus toward women."[17]
  • 2006 killing by a man in an SUV in northern California: "His recent, arranged marriage may have made him stressed."[18]
This pattern of denial is all the more striking because it concerns distinctly Islamic forms of violence such as suicide operationsbeheadingshonor killings and the disfiguring of women's faces. For example, when it comes to honor killings, Phyllis Chesler has established that this phenomenon differs from domestic violence and, in Western countries, is almost always perpetrated by Muslims.[19] Such proofs, however, do not convince the establishment, which tends to filter Islam out of the equation.

The generalized threat inspires more denial. Politicians and others avoid mention of Islam, Islamism, Muslims, Islamists, mujahideen, or jihadists. Instead, they blame evildoers, militants, radical extremists, terrorists, and al-Qaeda. Just one day after 9/11, U.S. secretary of state Colin Powell set the tone by asserting that the just-committed atrocities "should not be seen as something done by Arabs or Islamics; it is something that was done by terrorists."[20]

Another tactic is to obscure Islamist realities under the fog of verbiage. George W. Bush referred once to "the great struggle against extremism that is now playing out across the broader Middle East"[21] and another time to "the struggle against ideological extremists who do not believe in free societies and who happen to use terror as a weapon to try to shake the conscience of the free world."[22] He went so far as to dismiss any Islamic element by asserting that "Islam is a great religion that preaches peace."[23]

In like spirit, Barack Obama observed that "it is very important for us to recognize that we have a battle or a war against some terrorist organizations, but that those organizations aren't representative of a broader Arab community, Muslim community."[24] Obama's attorney general, Eric Holder, engaged in the following exchange with Lamar Smith (Republican, Tex.) during congressional testimony in May 2010, repeatedly resisting a connection between Islamist motives and a spate of terrorist attacks:
Smith: In the case of all three [terrorist] attempts in the last year, … one of which was successful, those individuals have had ties to radical Islam. Do you feel that these individuals might have been incited to take the actions that they did because of radical Islam?
Holder: Because of?
Smith: Radical Islam.
Holder: There are a variety of reasons why I think people have taken these actions. It's one, I think you have to look at each individual case. I mean, we are in the process now of talking to Mr. [Feisal] Shahzad to try to understand what it is that drove him to take the action.
Smith: Yes, but radical Islam could have been one of the reasons?
Holder: There are a variety of reasons why people ...
Smith: But was radical Islam one of them?
Holder: There are a variety of reasons why people do things. Some of them are potentially religious...[25]
And on and on Holder persisted, until Smith eventually gave up. And this was not exceptional: An almost identical denial took place in December 2011 by a senior official from the Department of Defense.[26]
Or one can simply ignore the Islamist element; a study issued by the Department of Homeland Security, "Evolution of the Terrorist Threat to the United States," mentions Islam just one time. In September 2010, Obama spoke at the United Nations and, using a passive construction, avoided all mention of Islam in reference to 9/11: "Nine years ago, the destruction of the World Trade Center signaled a threat that respected no boundary of dignity or decency."[27] About the same time, Janet Napolitano, the secretary of homeland security, stated that the profiles of Americans engaged in terrorism indicate that "there is no 'typical' profile of a homegrown terrorist."[28]

Newt Gingrich, the former speaker of the U.S. House of Representatives, rightly condemns this mentality as "two plus two must equal something other than four."[29]

Exceptions to Denial

Exceptions to this pattern do exist; establishment figures on occasion drop their guard and acknowledge the Islamist threat to the civilized world. Gingrich himself delivered a uniquely well-informed speech on Shari'a in 2010, noting, "This is not a war on terrorism. Terrorism is an activity. This is a struggle with radical Islamists in both their militant and their stealth form."[30]

British prime minister Tony Blair offered a stirring and eloquent analysis in 2006:
This is war, but of a completely unconventional kind. … What are the values that govern the future of the world? Are they those of tolerance, freedom, respect for difference and diversity or those of reaction, division and hatred? … It is in part a struggle between what I will call Reactionary Islam and Moderate, Mainstream Islam. But its implications go far wider. We are fighting a war, but not just against terrorism but about how the world should govern itself in the early 21st century, about global values.[31]
The current British prime minister, David Cameron, gave a fine analysis in 2005, long before he reached his current office:
The driving force behind today's terrorist threat is Islamist fundamentalism. The struggle we are engaged in is, at root, ideological. During the last century a strain of Islamist thinking has developed which, like other totalitarianisms, such as Nazism and Communism, offers its followers a form of redemption through violence.[32]
In 2011, as prime minister, Cameron returned to this theme when he warned that "we need to be absolutely clear on where the origins of these terrorist attacks lie. That is the existence of an ideology, Islamist extremism."[33]
The former foreign minister of the Czech Republic, Alexandr Vondra, spoke his mind with remarkable frankness:
Radical Islamists challenge practically everything that our society claims to stand for, no matter what the Western policies were or are. These challenges include the concept of universal human rights and freedom of speech.[34]
George W. Bush spoke in the period after October 2005 about "Islamo-fascism" and "Islamic fascists." Joseph Lieberman, the U.S. senator from Connecticut, criticized those who refuse "to identify our enemy in this war as what it is: violent Islamist extremism"[35] and sponsored an excellent Senate study on Maj. Hasan. Rick Santorum, then a U.S. senator from Pennsylvania, gave a notable analysis:
In World War II, we fought Naziism and Japanese imperialism. Today, we are fighting against Islamic fascists. They attacked us on September 11th because we are the greatest obstacle to their openly declared mission of subjecting the entire world to their fanatical rule. I believe that the threat of Islamic fascism is just as menacing as the threat from Nazism and Soviet Communism. Now, as then, we face fanatics who will stop at nothing to dominate us. Now, as then, there is no way out; we will either win or lose.[36]
Antonin Scalia, an associate justice of the Supreme Court of the United States, observed in an opinion that "America is at war with radical Islamists."[37] A New York Police Department study, Radicalization in the West: The Homegrown Threat, discusses "Islamic-based terrorism" in its first line and never lets up. It contains explicit references to Islamism; it states, "Ultimately, the jihadist envisions a world in which jihadi-Salafi Islam is dominant and is the basis of government."[38]
So, reality does on occasion poke through the fog of denial and verbiage.

The Mystery of Denial

These exceptions aside, what accounts for the persistent denial of Islamic motives? Why the pretense that no elephant fills the room? An unwillingness to face the truth invariably smacks of euphemism, cowardice, political correctness, and appeasement. In this spirit, Gingrich argues that "the Obama Administration is willfully blind to the nature of our enemies and the forces which threaten America. … it's not ignorance; it's determined effort to avoid [reality]."[39]

These problems definitely contribute to denial, but something more basic and more legitimate goes further to explain this reluctance. One hint comes from a 2007 Ph.D. dissertation in politics submitted by Gaetano Ilardi to Monash University in Melbourne. Titled "From the IRA to Al Qa'eda: Intelligence as a Measure of Rational Action in Terrorist Operations," it refers frequently to Islam and related topics; Ilardi has also been quoted in the press on the topic of radicalization. Yet in 2009, as acting senior sergeant of the Victoria police, he was the most vociferous of his twenty law enforcement colleagues insisting to this author that the police not publicly mention Islam in any fashion when discussing terrorism. In other words, wanting not to refer to Islam can come from someone who knows full well the role of Islam.

Confirming this point, Daniel Benjamin, the Obama administration's coordinator for counterterrorism in the U.S. State Department, explicitly refutes the idea that silence about Islam means being unaware of it:
Policymakers fully recognize how al Qaeda's ideologues have appropriated Islamic texts and concepts and fashioned them into a mantle of religious legitimacy for their bloodshed. As someone who has written at length about how al Qaeda and the radical groups that preceded it have picked and chosen from sacred texts, often out of all context, I have no doubt my colleagues understand the nature of the threat.[40]
Ilardi and Benjamin know their stuff; they avoid discussing Islam in connection with terrorism for reasons deeper than political correctness, ignorance, or appeasement. What are those reasons? Two factors have key importance: wanting not to alienate Muslims or to reorder society.

Explaining Denial

Not wanting to offend Muslims, a sincere and reasonable goal, is the reason most often publicly cited. Muslims protest that focusing on Islam, Islamism, or jihad increases Muslim fears that the West is engaged in a "war against Islam." Joseph Lieberman, for example, notes that the Obama administration prefers not to use the term "violent Islamist extremists" when referring to the enemy because using such explicit words "bolsters our enemy's propaganda claim that the West is at war with Islam."[41]

Questioned in an interview about his having only once used the term "war on terror," Barack Obama confirmed this point, stating that "words matter in this situation because one of the ways we're going to win this struggle is through the battle of hearts and minds." Asked, "So that's not a term you're going to be using much in the future?" he replied:
You know, what I want to do is make sure that I'm constantly talking about al Qaeda and other affiliated organizations because we, I believe, can win over moderate Muslims to recognize that that kind of destruction and nihilism ultimately leads to a dead end, and that we should be working together to make sure that everybody has got a better life.[42]
Daniel Benjamin makes the same point more lucidly:
Putting the emphasis on "Islamist" instead of on "violent extremist" undercuts our efforts, since it falsely roots the core problem in the faith of more than one billion people who abhor violence. As one internal government study after another has shown, such statements invariably wind up being distorted in the global media, alienating Muslim moderates.[43]
This concern actually has two sub-parts for two types of Muslims: Those who would otherwise help fight terrorism feel insulted ("a true Muslim can never be a terrorist") and so do not step forward while those who would not normally be involved become radicalized, some even becoming terrorists.

The second reason to inhibit one's talk about Islam concerns the apprehension that this implies a large and undesirable shift away from how secular Western societies are ordered. Blaming terrorist attacks on drugs gone awry, road rage, an arranged marriage, mental cases going berserk, or freak industrial accidents permits Westerners to avoid confronting issues concerning Islam. If the jihad explanation is vastly more persuasive, it is also far more troubling.

When one notes that Islamist terrorism is almost exclusively the work of Muslims acting out of Islamic convictions, the implication follows that Muslims must be singled out for special scrutiny, perhaps along the lines this author suggested in 2003:
Muslim government employees in law enforcement, the military and the diplomatic corps need to be watched for connections to terrorism, as do Muslim chaplains in prisons and the armed forces. Muslim visitors and immigrants must undergo additional background checks. Mosques require a scrutiny beyond that applied to churches and temples.[44]
Implementing such a policy means focusing law enforcement attention on a community that is defined by its religion. This flies in the face of liberal, multicultural, and politically correct values; it also will be portrayed as illegal and perhaps unconstitutional. It means distinguishing on the basis of a person's group characteristics. It involves profiling. These changes have unsettling implications that will be condemned as "racist" and "Islamophobic," accusations that can ruin careers in today's public environment.

Islam-related explanations may offer a more persuasive accounting than turning perpetrators into victims, but the imperative not to tamper with existing social mores trumps counterterrorism. This accounts for police, prosecutors, politicians, and professors avoiding the actual factors behind Islamist attacks and instead finding miscellaneous mundane motives. Those soothing and inaccurate bromides have the advantage of implying no changes other than vigilance against weapons. Dealing with unpleasant realities can be deferred.

Finally, denial appears to work. Just because law enforcement, the military, and intelligence agencies tiptoe around the twin topics of Islamic motivation and the disproportionate Islamist terrorism when addressing the public does not stop these same institutions in practice from focusing quietly on Islam and Muslims. Indeed, there is plenty of evidence that they do just this, and it has led to an effective counterterrorism effort since 9/11 with close scrutiny on everything from mosques to hawalas (informal Muslim financial exchanges). As a result, with rare exceptions (such as the Fort Hood shooter), Islamist terrorist networks tend to be stymied and successful assaults tend to come out of nowhere from perpetrators characterized by sudden jihad syndrome.

Arguing against Denial

While respecting the urge not to aggravate Muslim sensibilities and acknowledging that the frank discussion of Islam can have major consequences for ordering society, this author insists on the need to mention Islam. First, it is not clear how much harm talking about Islam actually does. Genuine anti-Islamist Muslims insist on Islam being discussed; Islamists posing as moderates tend to be those who feign upset about a "war on Islam" and the like.

Second, little evidence points to Muslims being radicalized by mere discussion of Islamism. Quite the contrary, it is usually something specific that turns a Muslim in that direction, from the way American women dress to drone attacks in Somalia, Yemen, and Pakistan.

Third, while conceding that discussion of Islam has costs, ignoring it costs more. The need to define the enemy, not just within the counsels of war but for the public, trumps all other considerations. As the ancient Chinese strategist Sun Tzu observed, "Know your enemy and know yourself and you can fight a hundred battles." Karl von Clausewitz's entire theory of war assumes an accurate assessment of the enemy. Just as a medical doctor must identify and name a disease before treating it, so must politicians and generals identify and name the enemy to defeat it.

To censor oneself limits one's ability to wage war. Avoiding mention of the enemy's identity sows confusion, harms morale, and squanders strengths. In brief, it offers a recipe for defeat. Indeed, the annals of history record no war won when the enemy's very name and identity may not be uttered; this is all the more so in modern times when defining the enemy must precede and undergird military victory. If you cannot name the enemy, you cannot defeat him.

Fourth, even though law enforcement et al. find that saying one thing in public while doing another in private works, this dishonesty comes at the high price of creating a disconnect between the high-flying words of politicians and the sometimes sordid realities of counterterrorism:
  • Government employees at risk: On the one hand, out of fear of being exposed, public servants must hide or lie about their activities. On the other, to do their work effectively, they must run afoul of studiously impartial government regulations, or even break the law.
  • A confused public: Policy statements piously reject any link between Islam and terrorism even as counterterrorism implicitly makes just such a connection.
  • Advantage Islamists: They (1) point out that government declarations are mere puffery hiding what is really a war against Islam; and (2) win Muslim recruits by asking them whom they believe, straight-talking Islamists or insincere politicians.
  • "Security theater" and other pantomimes: To convince observers that Muslims are not specifically targeted, others are hauled in for show purposes, wasting finite time and resources.[45]
  • An increase in resentments and prejudices: People keep their mouths shut but their minds are working. An open public discussion, in which one could condemn Islamists while supporting moderate Muslims, would lead to a better understanding of the problem.
  • Vigilance discouraged: The campaign of "If You See Something, Say Something" is fine but what are the costs of reporting dubious behavior by a neighbor or a passenger who turns out to be innocent? Althoughvigilant neighbors have been an important source of counterterrorism leads, anyone who reports his worries opens himself up to vilification as a racist or "Islamophobe," damage to one's career, or even a law suit.[46]
Thus does the unwillingness to acknowledge the Islamist motives behind most terrorism obstruct effective counterterrorism and render further atrocities more likely.

When Denial Will End

Denial is likely to continue until the price gets too steep. The 3,000 victims of 9/11, it turns out, did not suffice to shake Western complacency. 30,000 dead, in all likelihood, will also not suffice. Perhaps 300,000 will. For sure, three million will. At that point, worries about Muslim sensibilities and fear of being called an "Islamophobe" will fade into irrelevance, replaced by a single-minded determination to protect lives. Should the existing order someday be in evident danger, today's relaxed approach will instantly go out the window. The popular support for such measures exists; as early as 2004, a Cornell University poll showed that 44 percent of Americans "believe that some curtailment of civil liberties is necessary for Muslim Americans."[47]

Israel offers a control case. Because it faces so many threats, the body politic lacks patience with liberal pieties when it comes to security. While aspiring to treat everyone fairly, the government clearly targets the most violent-prone elements of society. Should other Western countries face a comparable danger, circumstances will likely compel them to adopt this same approach.

Conversely, should such mass dangers not arise, this shift will probably never take place. Until and unless disaster on a large scale strikes, denial will continue. Western tactics, in other words, depend entirely on the brutality and competence of the Islamist enemy. Ironically, the West permits terrorists to drive its approach to counterterrorism. No less ironically, it will take a huge terrorist atrocity to enable effective counterterrorism.

Addressing Denial

In the meantime, those who wish to strengthen counterterrorism by acknowledging the role of Islam have three tasks.

First, intellectually to prepare themselves and their arguments so when calamity occurs they possess a fully elaborated, careful, and just program that focuses on Muslims without doing injustice to them.
Second, continue to convince those averse to mentioning Islam that discussing it is worth the price; this means addressing their concerns, not bludgeoning them with insults. It means accepting the legitimacy of their hesitance, using sweet reason, and letting the barrage of Islamist attacks have their effect.

Third, prove that talking about Islamism does not lead to perdition by establishing the costs of not naming the enemy and of not identifying Islamism as a factor; noting that Muslim governments, including the Saudi one, acknowledge that Islamism leads to terrorism; stressing that moderate Muslims who oppose Islamism want Islamism openly discussed; addressing the fear that frank talk about Islam alienates Muslims and spurs violence; and demonstrating that profiling can be done in a constitutionally approved way.

In brief, even without an expectation of effecting a change in policy, there is much work to be done.
Daniel Pipes ( is president of the Middle East Forum. He initially delivered this paper at the Institute for Counter-Terrorism in Herzliya, Israel.
[1] Protecting the Force: Lessons from Fort Hood, Department of Defense, Washington, D.C., Jan. 2010.
[2] The Australian (Sydney)Nov. 7, 2009.
[3] Associated Press, Nov. 5, 2012.
[4] Protecting the Force: Lessons from Fort Hood, p. 18, fn. 22.
[5] "List of Islamic Terror Attacks,", accessed Dec. 19, 2012.
[6] The New York TimesNov. 9. 1990.
[7] The Independent (London), Sept. 19, 1997.
[8] Uriel Heilman, "Murder on the Brooklyn Bridge," Middle East Quarterly, Summer 2001, pp. 29-37.
[9] The Houston ChronicleFeb. 26, 1997.
[10] Time MagazineJan. 21, 2002.
[11] "Terror in LA?Honest Reporting (Toronto), July 8, 2002.
[12] Los Angeles Times, Oct. 26, 2002.
[13] Daniel Pipes, "Murder in the 101st Airborne," The New York Post, Mar. 25, 2003.
[14] Brett Kline, "Two Sons of France," The Jerusalem Post Magazine, Jan. 21, 2010.
[15] "Italy: McDonald's Jihad Foiled," Jihad Watch, Mar. 30, 2004.
[16] The Washington Post, Jan. 11, 2005.
[17] Los Angeles TimesJuly 30, 2006.
[18] San Francisco Chronicle, Aug. 30, 2006.
[19] Phyllis Chesler, "Are Honor Killings Simply Domestic Violence?" Middle East Quarterly, Spring 2009, pp. 61-9.
[20] Dateline, NBC, Sept. 21, 2001.
[21] Remarks, The Islamic Center of Washington, D.C., June 27, 2007.
[22] Remarks, UNITY 2004 Conference, Washington D.C., Aug. 6, 2004.
[23] Al-Arabiya News Channel (Dubai), Oct. 5, 2007.
[24] Anderson Cooper 360 DegreesFeb. 3, 2009.
[25] Testimony before the U.S. House Judiciary Committee, Washington, D.C., May 13, 2010.
[26] Testimony before the U.S. House Committee for Homeland Security, Washington, D.C., Dec. 13, 2011.
[27] Remarks, U.N. General Assembly, New York, Sept. 23, 2010.
[28] "Nine Years after 9/11: Confronting the Terrorist Threat to the Homeland," statement to the U.S. Senate Committee on Homeland Security and Governmental Affairs, Washington, D.C., Sept. 22, 2010.
[29] Newt Gingrich, "America Is at Risk," American Enterprise Institute, Washington, D.C., July 29, 2010.
[30] Ibid.
[31] Speech to the Los Angeles World Affairs Council, Aug. 1, 2006.
[32] Speech at the Foreign Policy Centre, London, Aug. 25, 2005.
[33] Munich Security Conference, Feb. 5, 2011.
[34] Alexandr Vondra, "Radical Islam Poses a Major Challenge to Europe," Middle East Quarterly, Summer 2007, pp. 66-8.
[35] Joseph Lieberman, "Who's the Enemy in the War on Terror?The Wall Street Journal, June 15, 2010.
[36] "The Great Test of This Generation," speech to the National Press Club, Washington, D.C., National Review Online, July 20, 2006.
[37] Scalia J., dissenting, Lakhdar Boumediene, et al., Petitioners, Supreme Court of the United States v. George W. Bush, President of the United States, et al.; Khaled A. F. Al Odah, next friend of Fawzikhalid Abdullah Fahad Al Odah, et al., Petitioners v. United States, et al., June 12, 2008.
[38] New York: 2007, p. 8.
[39] Gingrich, "America Is at Risk."
[40] Daniel Benjamin, "Name It and Claim It, or Name It and Inflame It?The Wall Street Journal, June 24, 2010.
[41] Lieberman, "Who's the Enemy in the War on Terror?"
[42] Anderson Cooper 360 DegreesFeb. 3, 2009.
[43] Benjamin, "Name It and Claim It, or Name It and Inflame It?"
[44] Daniel Pipes, "The Enemy Within and the Need for Profiling," The New York Post, Jan. 24, 2003.
[45] Daniel Pipes, "Security Theater Now Playing at Your Airport," The Jerusalem Post, Jan. 6, 2010.
[46] M. Zuhdi Jasser, "Exposing the 'Flying Imams,'Middle East Quarterly, Winter 2008, pp. 3-11.
[47] "Fear Factor," Cornell News (Ithaca), Dec. 17, 2004.

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