Right-wing media rushed to exploit the deadly attack on the French satirical newspaper Charlie Hebdo in Paris. But this is just the latest in right-wing media's long history of politicizing tragedy to push political objectives.
Fox News anchor Gregg Jarrett wrote a column accurately depicting the college sexual assault epidemic and the fears victims face in reporting these crimes, a stark contrast to his colleagues and fellow conservative media figures who have dismissed, mocked, and stigmatized victims.
In a September 25 column for Fox News' website, Jarrett highlighted the high rate of assault on college campuses, and praised student activists for raising awareness of the often insufficient resources and efforts by colleges to address the problem (emphasis added):
Nearly 20 % of female college students have been sexually assaulted, according to a White House task force.
I suspect the true number is significantly higher. Many young women are reluctant to report it. They keep it secret for fear of embarrassment, shame, retribution, and the trauma of reliving the nightmare during legal or disciplinary proceedings. I get it. There are repercussions. Victims are especially afraid of being stigmatized or ostracized within the tight, insular social circles on campus.
Awareness is on the rise driven, in part, by student activism. Columbia University student Emma Sulkowicz, angry over how the school adjudicated her claim of rape, has taken to carrying a mattress around campus. Dubbed "Mattress girl" by fellow students and the media, her visually indelible protest has galvanized a growing demand for honesty and transparency. And why not? Schools should be required to publish accurate information about the frequency of assaults. It can be done without breaching individual students' privacy.
Jarrett's column unfortunately stands out among recent commentary about sexual assault in conservative media, where the fact that one in five women are assaulted at college is regularly dismissed. The Daily Caller has called the statistic "bizarre and wholly false," while the Washington Examiner called it "ridiculous."
Moreover, the trust and respect Jarrett treats the victims of these assaults with is unusual. Instead, their stories are often questioned or critiqued, with media figures suggesting that a large number of victims are lying about their assault, or are partly culpable.
The same day that Jarrett's column was published, some of his Fox News colleagues suggested that intoxicated women who are assaulted at college fraternity parties are responsible for their own assaults. Several co-hosts of Fox's Outnumbered defended a Forbes contributor who was fired after claiming that drunk women were "the gravest threat to fraternities" because the fraternity would be liable if a woman was sexually assaulted at a party.
This past summer, Washington Post columnist George Will came under fire for claiming that college efforts to curb sexual assaults were making "victimhood a coveted status that confers privilege." In his column, Will disputed the story of a college rape on Swarthmore's campus, implying he didn't believe the survivor's story qualified as an actual incident of assault. The survivor, Lisa Sendrow, told Media Matters about the violence she had experienced, how Will's dismissal of her story was triggering and damaging to her, and that she was diagnosed with PTSD and received violent threats after her story was first reported.
Earlier this year, a Weekly Standard contributor blamed feminism for sexual assault, because victims abandoned "feminine modesty" which had provided women "protection" from rape. National Review Online writers claimed rape was "instinctive" among some young men, that assaults involve "a large degree of voluntary behavior" from women, and that women are "being taught to believe they were raped." A New York Post columnist dismissed rape as "regrettable sex."
And Wall Street Journal editor James Taranto went so far as to claim intoxicated sexual assault victims are just as guilty as their attackers.
While Jarrett's column is sadly something of an outlier among conservative commentary on the issue, survivors now have one more voice in the media supporting their efforts to combat this epidemic.
Right-wing media accused President Obama of "advising" and "strategizing" for the terrorist group known as the Islamic State (ISIS or ISIL) in reaction to reports that Obama said the group had made a strategic error in provoking support for U.S. military action against them.
Right-wing media have launched a campaign of mockery, victim-blaming, and denial to dismiss the sexual assault epidemic, particularly on college campuses, and the Obama administration's efforts to curtail the growing problem.
For two years, the National Organization for Marriage (NOM) has been peddling the theory that the IRS intentionally leaked its donor list to a gay rights organization as part of an Obama administration conspiracy. Two separate investigations and a ruling by a Reagan-appointed judge have debunked that theory. But right-wing media, which have widely touted NOM's initial accusations, have largely ignored or denied the conspiracy theory's demise.
In the spring of 2012, an IRS employee inadvertently leaked an unredacted list of NOM's donors in response to a public records request. The pro-equality group Human Rights Campaign (HRC) got its hands on the list, highlighting past contributions to NOM by prominent conservatives like then-presidential candidate Mitt Romney.
Noting that key HRC officials were prominent supporters of President Obama's re-election campaign, NOM alleged a conspiracy between the organization and the Obama administration aimed at embarrassing NOM and its supporters.
In April 2012, NOM filed a formal letter of complaint to the IRS. Conservative outlets like The Daily Caller and The Weekly Standard touted the complaint, focusing particularly on the revelation that Romney was one of the group's donors. For most of the next year, however, media interest in the story was scant.
That changed in the spring of 2013. In May, U.S. Attorney General Eric holder ordered the FBI to begin a criminal probe into allegations that the agency had targeted tax-exempt conservative political groups. While the IRS actually scrutinized progressive groups more extensively than conservative ones, the IRS "scandal" became a rallying cry for right-wing media. The controversy also meant newfound interest in NOM's allegations against the agency.
Mainstream and conservative media outlets were quick to pick up on NOM's call for an investigation into the IRS's activities.
The Wall Street Journal 's James Taranto spotlighted NOM's claims in a column on the IRS controversy, asking "How pervasive is the Obama IRS scandal?":
Wall Street Journal editor James Taranto claimed that cases of "'sexual assault' on campus" that involve alcohol are really victimless crimes in which both parties are equally guilty.
In his February 10 WSJ column, Taranto baselessly argued that men are often unfairly accused in sexual assault cases on college campuses, particularly when both men and women involved in the case were drinking (emphasis added):
What is called the problem of "sexual assault" on campus is in large part a problem of reckless alcohol consumption, by men and women alike.
If two drunk drivers are in a collision, one doesn't determine fault on the basis of demographic details such as each driver's sex. But when two drunken college students "collide," the male one is almost always presumed to be at fault. His diminished capacity owing to alcohol is not a mitigating factor, but her diminished capacity is an aggravating factor for him.
As the Foundation for Individual Rights in Education notes, at some campuses the accuser's having had one drink is sufficient to establish the defendant's guilt ... In theory that means, as FIRE notes, that "if both parties are intoxicated during sex, they are both technically guilty of sexually assaulting each other." In practice it means that women, but not men, are absolved of responsibility by virtue of having consumed alcohol.
While it is true that reckless alcohol consumption can play a role in encouraging damaging behavior, and that male and female college students (particularly underage students) could probably benefit from learning to moderate their drinking for a variety of reasons, Taranto's accusation that women who drink -- and then are forced to have sex against their will -- are not only equally at fault for their assault but are guilty of an equivalent crime takes victim blaming to a new and dangerous low.
Taranto's victim-blaming approach furthers his attempts to disingenuously redefine the problem of sexual assault as a problem of alcohol. The problem of sexual assault on college campuses, as elsewhere, is entirely a problem of sexual assault, in which a victim does not consent to sexual relations with the aggressor. Studies have shown that alcohol consumption doesn't cause sexual assault, nor does it serve as a defense. According to a literature review from the National Institutes of Health:
The fact that alcohol consumption and sexual assault frequently co-occur does not demonstrate that alcohol causes sexual assault.
[M]en are legally and morally responsible for acts of sexual assault they commit, regardless of whether or not they were intoxicated or felt that the woman had led them on previously. The fact that a woman's alcohol consumption may increase their likelihood of experiencing sexual assault does not make them responsible for the man's behavior, although such information may empower women when used in prevention programs.
Wall Street Journal editorial board member James Taranto falsely claimed that women have full control over reproduction and are choosing to have "illegitimate" children who grow up without fathers -- furthering his history of sexist and inaccurate attacks on women's rights and reproductive freedom.
In his January 6 Best of the Web Today column, Taranto examined an article about studies which claim that boys who grow up in households without fathers are likelier to have discipline problems in school than boys who grow up in families with both a male and female parent. Taranto argued that this was a problem rooted in "female careerism" and birth control. He claimed that the growing number of children born to unmarried women -- what he termed "widespread illegitimacy" -- was a product of women having full control over reproduction thanks to the introduction of the pill and abortion rights, and thus "the vast majority of children who are growing up without fathers are doing so in large part because of their mothers' choices" (emphasis added):
Under the legal regime that has prevailed for more than four decades, any woman who gives birth out of wedlock does so because she chooses to do so. To assign responsibility is not necessarily to assign blame: One may hold the view, for example, that illegitimate childbirth is morally preferable to abortion, or that widespread illegitimacy is not as bad for society as the decline in fertility that would occur, all else being equal, if sex outside marriage never produced a child.
Nonetheless, the vast majority of children who are growing up without fathers are doing so in large part because of their mothers' choices. In our column last month, we half-facetiously raised "the converse lament that young females are insufficiently interested in 'becoming reliable wives and mothers.' " Let us now raise it half-seriously. It is trivially true that an unmarried woman who bears a child is not a reliable wife. If Hymowitz is correct about the baneful effects of fatherlessness on boys, such a woman also is not a reliable mother, at least to her sons.
Regardless of what kind of household children are raised in, the fact is women have increasingly little control over their reproductive choices, as their rights are under unprecedented threat. A new Guttmacher Institute report stated that in 2013 alone there were 70 different anti-choice restrictions adopted throughout the states. This severely reduced women's reproductive health options and in many cases shut down health clinics in huge areas of the country, blocking women's access to necessary and safe procedures. Indeed, more abortion restrictions were enacted in the past three years than in the entire previous decade.
Taranto's sexism and misinformed attacks on women's reproductive freedom are a regular feature at the Journal, where he has previously argued that a "war on men" began with contemporary feminism in the 1960s, when women dared "to be equal to men" and wanted "sexual freedom." Below, Media Matters has compiled a selection of some of his worst comments:
Video by Coleman Lowndes
Viewing gun rights as under attack after the mass shooting at Sandy Hook Elementary School in Newtown, Connecticut, the National Rifle Association and its backers in conservative media spent 2013 using inflammatory rhetoric to attack critics and promote an uncompromising pro-gun agenda.
Both the NRA and its conservative media allies frequently attempted to draw modern-day parallels between Adolf Hitler's murder of millions during the Holocaust and the Obama administration's post-Newtown proposal to advance gun safety. One ugly event at the NRA's annual meeting saw the NRA's main political opponent illustrated as a Nazi, leading to condemnation from Jewish organizations.
Even victims of gun violence and the families of those killed at Sandy Hook could not escape the wrath of right-wing media, who insultingly called them "props" of the Obama administration, as if they were unable to think for themselves. The NRA similarly politicized the armed protection of President Obama's daughters in a widely criticized TV spot.
Ted Nugent, perhaps the best known member of NRA leadership, turned heads when he dubbed Trayvon Martin a "dope smoking, racist gangsta wannabe" after the deceased Florida teenager's killer was acquitted. Even given his past racially inflammatory rhetoric, Nugent shocked many by piling on his Martin comment with a weeks-long tirade in which he endorsed racial profiling and claimed that the African-American community has a "mindless tendency to violence." The NRA declined to comment.
The year also featured a number of bizarre claims from the NRA, including the host of an NRA-produced television show comparing critics of his elephant hunting to Hitler, NRA head Wayne LaPierre's claim that gun ownership was essential to "survival," and NRA past-president Marion Hammer's comparison of an assault weapons ban to racial discrimination.
What follows are 12 lowlights from a year punctuated by extreme NRA rhetoric:
Media Matters looks back at the best of the worst of right-wing media's treatment of women in 2013.
Men are under threat. Despite the fact that women still make less than men do, are hugely underrepresented in media, and face so much sexism on a daily basis that Republicans actually have to undergo training to learn how to talk to women in non-offensive ways, conservative media would like you to know that it's really men who have it tough.
The "War on Men" is waged on multiple fronts, from elementary school classrooms to the workplace to men's own marriages. Nowhere is safe. So to help the besieged men out there, here is a list of all the things conservative media said were examples of the "War on Men" in 2013.
1. Kids Don't Play "Tag" Anymore.
In September, National Review Online hosted a debate which asked "Is there a war on women? Or is it a war on men?" An example of the suffering of men, according to the panel, was that "schools are replacing boys' favorite game, 'tag,' with a more female-friendly alternative called 'circle of friends.'" As Alice Munro noted in the New Republic, this isn't true.
2. "Female Sexual Freedom."
The "War on Men" really began with contemporary feminism in the 1960s, according to Wall Street Journal editor James Taranto, when women dared "to be equal to men" and wanted "sexual freedom":
MARY KISSEL: [W]hen did this war on men begin? Can you pinpoint a starting point?
TARANTO: Well, it all goes back to the beginning of contemporary feminism in the early '60s. You know, women wanted to be equal to men, they wanted to be able to do all the sort of professional things including the military that men could do, and --
KISSEL: Was there anything wrong with that, though, James? I mean, that sounds --
TARANTO: Well, that's too long to go into now, the question of what's wrong with that, but in addition they wanted sexual freedom. Well what is female sexual freedom? It means, for this woman, that she had the freedom to get drunk, and to get in the backseat of the car with this guy. There was another woman who accused him, he was acquitted in this case, of sexual assault. This so-called assault happened in his bedroom, to which she voluntarily accompanied him, even the jury said that was consensual.
According to conservative media, the Affordable Care Act's mandate that insurance companies can no longer discriminate is the same as "sticking it to men" and waging a "war on bros." In reality, the law makes sure insurance companies can't force women to pay more for health care just because they are women.
4. "Feminized" Schools Have Rules, Standards.
The "War on Men" starts "as a war on boys," according to NRO's Helen Smith, which manifests when schools "take away recess" and adopt "a feminized approach to schools to the point where it is mainly for those who conform, sit still, and like to follow rules."
5. Sometimes, Men Are Accused Of Sexual Harassment.
Wall Street Journal editor James Taranto fights the "War on Men" on a regular basis. In June, he dismissed the epidemic of sexual assault in the military, claiming that efforts to address the enormous problem contributed to the "war on men" and were an "effort to criminalize male sexuality." Taranto conveniently ignored the fact that many victims of sexual assault in the military are also male, and that most men probably don't agree that "male sexuality" necessarily includes having sex with drunken women in cars.
6. Commercials And Sitcoms Make Men Look Stupid.
In 2012, FoxNews.com columnist Suzanne Venker claimed that a factor in the "War on Men" was that "Women aren't women anymore," because now they have college degrees and have sex outside of marriage. In 2013, she took this probing analysis further, saying that men -- who are "second class citizens" -- are under threat because Title IX forbids discrimination in college sports and because of "sit-coms and commercials that portray dad as an idiot."
7. Women Work Full-Time Jobs.
In December, Venker uncovered yet another layer in the war on men: women these days are "financially independent," and despite the "simply irrefutable" fact that they "prefer part-time work," many continue to insist on working full-time jobs, harming men's ability to fulfil their natural inclination to be primary breadwinner.
8. Women Would Like To Make The Same Amount Of Money Men Do.
At FoxNews.com, Carrie Lukas argued that President Obama's nominee to the Office of Personnel Management was the new "general" in the "war on men's pay," because she was tasked with attempting to close the gender wage gap in government salaries. Lukas baselessly claimed that this would result in men being paid less money in order to make up the difference -- literally the opposite of what was intended, which was to pay women more.
9. "Obama's America."
Finally, WSJ editor James Taranto blamed "Obama's America" for waging the "War on Men" with the sexual harassment regulations under Title IX, which he claimed unfairly police men's sexuality.
Wall Street Journal editor James Taranto is blaming "the war on men" supposedly waged by "Barack Obama's America" for the school suspension of a six-year-old Colorado boy for sexual harassment.
First-grader Hunter Yelton made national news this week following his suspension from elementary school for sexual harassment after he kissed a female classmate on the hand. While the nation debated the appropriateness of the punishment, Taranto espoused a new theory in a December 11 piece for The Wall Street Journal: Yelton is the "littlest casualty in the war on men."
"In Barack Obama's America, even a small boy can become a sexual suspect," Taranto wrote, claiming the boy's school was "following orders from Washington" when it issued the suspension. As evidence, he cited an April 2011 letter from then-Assistant Secretary of Education, Russlynn Ali, which reminded schools, colleges, and universities receiving federal funds of their obligation under Title IX to respond to allegations of sexual violence and sexual harassment at their facilities.
Taranto decried these sexual harassment regulations as unfairly policing men, going so far as to suggest that sexual harassment is normal male behavior that has become stigmatized (quote marks are his own):
As amusing as the story of Hunter Yelton is, however, it is an example of a dire and widespread problem. "Sexual harassment" rules are ostensibly sex-neutral, but in practice they are used primarily to police male behavior. Feminists like Hanna Rosin note with triumph that girls and women do better in school than their male counterparts. One reason is that normal female behavior is seldom stigmatized or punished in the name of "civil rights."
And while college "justice" is often downright oppressive, the excesses of contemporary feminism know no age limits. As the story of Hunter Yelton demonstrates, the war on men is also a war on little boys.
Taranto's theory quickly made it to Fox News, where The Kelly File devoted an entire segment to speculating whether the Obama administration shares blame in the child's suspension. In response to host Megyn Kelly's question, "does the administration have a hand in this," conservative radio host Dana Loesch repeated Taranto's argument, claiming regulating sexual harassment "polices male behavior, it's the persecution of a guy."
GOP candidates are training to better talk about women and women's issues following the disastrous 2012 elections -- but this new rebranding effort will be difficult, given conservative media's toxic rhetoric on women.
Politico reported on December 5 that the National Republican Congressional Committee (NRCC) is meeting with congressional Republicans and their aides to "teach them what to say -- or not to say -- on the trail, especially when their boss is running against a woman":
While GOP party leaders have talked repeatedly of trying to "rebrand" the party after the 2012 election losses, the latest effort shows they're not entirely confident the job is done.
So they're getting out in front of the next campaign season, heading off gaffes before they're ever uttered and risk repeating the 2012 season, when a handful of comments let Democrats paint the entire Republican Party as anti-woman.
Akin dropped the phrase "legitimate rape" during the 2012 Missouri Senate race, costing himself a good shot at winning his own race and touching off Democratic charges of a GOP "War on Women" that dogged Republicans in campaigns across the country.
This new phase in the GOP's attempt to rebrand the party comes months after the Republican National Committee's (RNC) March 18 post-mortem of the 2012 election, which warned the party was "increasingly marginalizing itself" by alienating women, Hispanics, African Americans, and younger voters.
As Media Matters noted at the time, the rebranding effort always faced a significant obstacle: conservative media. Right-wing talk radio hosts like Rush Limbaugh played a significant role in popularizing the very brand of Republican politics the party leadership now understands is toxic -- and they are unlikely to change their rhetoric on women just because the RNC and NRCC suggest it.
After all, Limbaugh is the man who launched 46 personal attacks on Sandra Fluke in 2012, including calling her a "slut" and a "prostitute" for testifying in favor of affordable contraception, and little has changed since then. Just in the month of November, Limbaugh compared filibuster reform in the Senate to "allow[ing] women to be raped"; suggested that women in the military synchronize their menstrual cycles so they'd be "ready to be banshees"; read from a misogynistic parody site mocking marital rape; claimed ads promoting Obamacare's coverage of birth control told young women "if you like being a prostitute, then have at it"; and claimed Democrats are turning women "into nothing but abortion machines."
Limbaugh is not alone. Wall Street Journal editor James Taranto has mocked efforts to combat the immense problem of sexual assault in the military, and claimed "female sexual freedom" led to a "war on men." Fox News' Bill O'Reilly attempted to tie the "War on Christmas" to "unfettered abortion." Conservative blogger and Fox contributor Erick Erickson has called Texas Gubernatorial candidate Wendy Davis "abortion Barbie" and attempted to smear her campaign by suggesting she was mentally unfit for office. And a Fox Business host recently asked if there is "something about the female brain that is a deterrent" to women working as tech executives.
That's just a few of the most recent examples. The list goes on.
If the NRCC is concerned about Republicans being labeled "anti-women," Todd Akin and his "legitimate rape" comments are perhaps the least of their concerns. Conservative media's daily drumbeat of demeaning attacks on women could do more damage to the party's efforts than any single gaffe.
After all, the GOP rebranding effort also included a call for greater Latino outreach, to which conservative media responded with increased anti-immigrant demagoguery and a full-throated effort to destroy immigration reform. At the moment, it seems the conservative media is successfully thwarting the Republican "rebrand" -- leaving the GOP right back where they were in November 2012.
Wall Street Journal columnist James Taranto again downplayed the sharp rise of reported sexual assaults in the military, even as military leaders agree that sexual assaults are a real problem.
The New York Times reported on November 7 that sexual assault complaints in the military rose "nearly 50 percent increase over the same period a year earlier." The report noted:
The numbers included sexual assaults by civilians on service members and by service members on civilians. Sexual assault was defined in the report as rape, sodomy and other unwanted sexual contact, including touching of private body parts. It did not include sexual harassment, which is handled by another office in the military.
But Taranto ridiculed the Times report, claiming the Pentagon was "exaggerating the problem of military sexual assault." Taranto claimed the report should be treated with "skepticism" because it included reports of military members assaulted by civilians and those assaulted before entering the military:
The National Review Online continues to misinform on a civil rights case in front of the Supreme Court, and its right-wing talking points on the supposed harm of affirmative action to students of color have now found their way into oral arguments by the conservative justices.
In an October 15 blog post discussing Schuette v. Coalition to Defend Affirmative Action, frequent NRO contributor Roger Clegg and attorney Joshua P. Thompson mischaracterized race-conscious admissions policies as a "racial preference" program for the unqualified. NRO has a long record of misinforming on affirmative action in general and Schuette in particular. Clegg and Thompson continued that trend in their piece, which recommended that the Court uphold a Michigan state constitutional amendment that effectively banned affirmative action by selectively making it more difficult for minorities to participate in the political process, a clear violation of decades-old precedent that prohibits this type of political restructuring. The NRO not only advocated for the conservatives on the Court to strike down these civil rights precedents, but to also reach beyond the four corners of the case and decide legal questions that aren't even at issue:
Today the U.S. Supreme Court heard oral argument in Schuette v. BAMN, a case in which a federal appellate court held -- astonishingly -- that Michigan voters somehow violated the U.S. Constitution's Equal Protection Clause by endorsing equal treatment for everyone regardless of race or sex.
At issue is Proposal 2 (the Michigan Civil Rights Initiative), a 2006 ballot measure that amended the state constitution to provide that state and local government agencies (including public universities) "shall not discriminate against, or grant preferential treatment to, any individual or group on the basis of race, sex, color, ethnicity, or national origin in the operation of public employment, public education, or public contracting."
[T]he Court should take this opportunity to make some amends to those who have been fighting for the principle of colorblind law but have been thwarted by bad judicial decisions. It can do so by reaffirming the strong presumption against any government use of racial and ethnic preferences -- not only in education, but also in contracting and employment, the two other arenas in which they are commonly found, and which are also addressed by Proposal 2.
The lower-court decision here complained that Proposal 2 makes it harder for some groups to lobby for preferential treatment. But the Equal Protection Clause is in the Constitution precisely because racial preference is not to be left to everyday politics, academic or otherwise. The United States has seen institutionalized discrimination in favor of whites be replaced with institutionalized discrimination against whites (and Asians) in less than a generation, and racial spoils will always be attractive to many politicians and other state and local actors.
It is not at all clear that Proposal 2 hurts African Americans (especially in light of the mismatch problem it removes -- that is, the fact that admitting students with significantly lower qualifications simply sets them up for failure since they are more likely to flunk out, drop out, get poor grades, and switch majors); and it clearly helps other minorities, like Asians, who typically are at the short end of preferences. And the logic of the Sixth Circuit's decision would also make it illegal to ban discrimination and preferential treatment through simple legislation, which would call into question a colorblind law like the 1964 Civil Rights Act, as well as state-constitutional civil-service rules.
Of concern is how the conservative misinformation advanced by NRO (and elsewhere by conservative Wall Street Journal columnist James Taranto) cropped up in the Schuette oral arguments. For example, in addition to the mistaken insistence that the U.S. Constituton is colorblind, the NRO also repeated the theory that those who get into elite positions through affirmative action, such as Justices Antonin Scalia and Sonia Sotomayor, are possibly doomed to failure. This "mismatch" argument as applied to higher education admissions, a favorite of right-wing media, has been widely debunked, but was still advanced at oral arguments by Michigan solicitor general John Bursch - and echoed favorably by both Chief Justice John Roberts and Justice Scalia.
On October 15, the Supreme Court will hear oral arguments in Schuette v. Coalition to Defend Affirmative Action, a case that challenges a 2006 ballot initiative in Michigan that amended the state's constitution to prevent state universities from using race or sex as one of many equal factors in admissions. Although proponents of what was formerly known as Proposal 2 say this resulting affirmative action ban is consistent with the law, it appears to be specifically prohibited by the "political restructuring" doctrine of the Supreme Court.