According to a poll by Rasmussen Reports being trumpeted by right-wing media, a majority of American voters believe the Obama administration is "not aggressive enough in deporting those who are in this country illegally." The poll also found that a majority of white as well as minority voters "oppose a halt to deportations." But these results don't take into account the federal government's record on deportations and are contradicted by a veritable litany of polls taken this year and over the past two years.
Conservative media are promoting the poll as evidence that the country wants more undocumented immigrants deported and that this proves that the current border enforcement and deportation policies of the Obama administration are too lax.
The poll, a national survey of 1,000 likely U.S. voters conducted December 8-9, asked vague and out-of-context questions about a specific category of immigrants (those who overstay their visas) including:
But the first question -- which used the language "make them leave the country" instead of "deport" -- failed to put the overstays in context. According to a February 2013 study, overstays declined by 73 percent between 2000 and 2009 thanks to enhanced security measures by DHS in the years following the September 11, 2001, attacks. The Wall Street Journal reported in April that about 40 percent of the roughly 11 million undocumented immigrants currently in the country are those who overstayed their visas. The article continued:
Little is known about the demographics of the so-called overstayer population, but some studies suggest they tend to be better educated and more fluent in English than those who crossed the border illegally. They also are more likely to hail from European, Asian and African countries. And in many cases, they used tourist visas to enter the U.S.
Nearly four months after the Boy Scouts of America (BSA) changed its membership policy to allow openly gay scouts, WND continued its hysterical reaction to the policy change, publishing a column denouncing the organization's leaders for leading the BSA into "the darkness of sin."
In a September 4 column that drew heavily on the words of Heritage Foundation founder Paul Weyrich, Jeff Rayno suggested that acceptance of LGBT rights is making American culture "an ever-wider sewer." But for homophobic bigots, all is not lost, Rayno wrote:
The years it would take to correct the damage caused by one vote taken by the BSA this year would be monumental. Deep in the struggle, our young men would be growing up unattended, while parents fight a losing battle to save what was once the Boy Scouts of America. Countless amounts of money would be wasted battling in courts that are growing more and more liberal every day. What is truly needed is a new organization built on solid principles with bylaws that are stronger than those of the BSA which would allow godly families to begin a new chapter.
On Sept. 6 and 7, 2013, a group temporarily named "On My Honor" will meet in Nashville, Tenn., to form such a group. Using the American Heritage Girls as a template for their organization, a new name, logo and branding will take place, as well as the development of new programs that will teach practical life skills with an emphasis on leadership and character. It will be clearly understood by all members that the context for sexual relations is between a man and a woman in the covenant of marriage.
Perhaps this is the beginning of the Weyrich vision. We can change the program of society, but unlike the modern world, the remote control doesn't work. We have to get off the seat and make an effort. It's an investment of time, energy and patience. We will be scolded by those who love the darkness of sin, but the net result will be future culture warriors, our sons, who live in a light brighter than any neon screen. They walk in the truth - the only reality that matters.
A WND video blasting the "left-wing war on children" epitomized the central problem with conservative media's response to a new California law guaranteeing transgender students the right to use school facilities and participate in school programs that correspond to their gender identity. The five-minute video never once uses the word "transgender," instead peddling "bathroom panic" horror stories.
The video, posted on August 20, featured WND's Molotov Mitchell playing the part of the hip, edgy, no-nonsense conservative. Mocking the law as "comprehensive bathroom reform," Mitchell seized on right-wing fears - ginned up by outlets like Fox News - that the law would enable "horny adolescent boys" to sneak into girls' restrooms and locker rooms:
Thanks to this law, it's also legal for horny adolescent boys to join the girls' wrestling team if they so desire, to stand around in their locker rooms while they change, and even shower with them if they want. What a brilliant way to protect children!
Finally, at K through 8 schools, middle school boys can now go into little girls' bathrooms. What could possibly go wrong? I think we all know what can - and will - go wrong.
Conservative commentator Pat Buchanan added his voice to the chorus of right-wing defenders of Russia's crackdown on gays and their supporters, writing that international criticism of Russia shows people can no longer distinguish between "good and evil."
In his August 13 syndicated column, Buchanan took America's "moral and cultural elites" to task for their opposition to Russian laws banning the positive depiction of homosexuality and the adoption of Russian children by any foreign couples from countries with marriage equality. Buchanan pined for the days when society ostracized gays, while lauding Russian President Vladimir Putin for seeking to restore a "moral compass" to Russia by implementing its anti-gay policies:
Our moral and cultural elites have put Putin on notice: Get in step with us on homosexual rights -- or we may just boycott your Sochi games.
What this reveals is the distance America has traveled, morally and culturally, in a few short years, and our amnesia about who we Americans once were, and what it is we once believed.
Putin is trying to re-establish the Orthodox Church as the moral compass of the nation it had been for 1,000 years before Russia fell captive to the atheistic and pagan ideology of Marxism.
"The adoption of Christianity," declared Putin, "became a turning point in the fate of our fatherland, made it an inseparable part of the Christian civilization and helped turn it into one of the largest world powers."
Anyone ever heard anything like that from the Post, the Times or Barack Hussein Obama?
Buchanan is fond of mourning "who we Americans once were." He's made a career of predicting the imminent collapse of American civilization as a result of Latino immigration, cozied up to white supremacists, and traced the decline of a once-great America to the historical moment when Americans started to affirm "[t]hat women and men are equal ... and that all races, religions, and ethnic groups are equal." It's no surprise, then, that he finds a kindred spirit in the retrograde Putin.
Stansberry & Associates, an investment research firm catering to right-wing audiences' fears of President Barack Obama, has been fined $1.5 million for engaging in "deliberate fraud" and profiting from "false statements." Despite its shoddy history, numerous conservative outlets and personalities including Newt Gingrich, Fox Business, Glenn Beck, Mike Huckabee, Alex Jones, WND, and The Washington Times, have helped legitimize the firm and its wild investment schemes. The firm has also enlisted the help of former Fox News contributor Dick Morris, who has frequently promoted the firm in sponsored video pitches.
Stansberry & Associates was founded in 1999 by Porter Stansberry and claims to have "been predicting the most promising emerging trends and the most influential economic forces affecting the market - with uncanny accuracy - for the past 13 years." Stansberry advertises its services to right-wing audiences with attacks on President Obama and warnings about a forthcoming apocalyptic type collapse of the American government and financial system. Stansberry emails carry subject lines like, "A Survival Secret That Could Save Your Life."
In 2007, Stansberry and his firm -- then called Pirate Investor LLC -- were ordered by a district court to pay $1.5 million in restitution and civil penalties as a result of a Securities and Exchange Commission complaint. As reported by the Baltimore Sun, Stansberry was accused of "disseminating false stock information and defrauding public investors through a financial newsletter ... They claimed investors could double their money if they paid $1,000 for a stock tip involving Bethesda energy company USEC Inc. In total, 1,217 people purchased the report, although 215 of them got their money back after complaining."
A judge in 2007 ruled that Stansberry's activity "undoubtedly involved deliberate fraud" and "making statements that he knew to be false." An appeals court later found that "it would take an act of willful blindness to ignore the fact that Appellants profited from the false statements." Stansberry's defense of his actions can be found here, and a group of publishers, including The New York Times ("The Right to Be Wrong"), defended Stansberry's case on First Amendment grounds.
The Social Security Administration's Office of the Inspector General announced on September 12, 2011, that Stansberry & Associates "agreed to pay a $55,000 civil monetary penalty to the Social Security Administration" for violating the Social Security Act. The firm settled the case by paying the fine while not admitting a violation. SSA's complaint alleged that Stansberry advertised it services by claiming to have information from "insiders" on how to increase your Social Security check, and "the SSA OIG believed that the characterization of Stansberry's SSA contacts as 'insiders' falsely implied that the information was not available to the public. The claimed 'insider' information was, in fact, available to anyone upon request."
"Ludicrous." That's how San Antonio City Councilman Diego Bernal described the effort by right-wing media outlets - including Fox News - to smear a proposed anti-discrimination ordinance aimed at combating bias against LGBT people.
On July 23, the right-wing website OneNewsNow published an article criticizing an effort by the San Antonio City Council to update its non-discrimination policy to include discrimination against LGBT people.
The updated policy would prohibit the city government and its contractors or vendors from discriminating on the basis of sexual orientation in employment. In addition, it would also prohibit anti-LGBT discrimination in housing and places of public accommodation. It would also allow City Council members to consider a person's history of anti-LGBT bias when making appointments to boards and commissions, stating:
No person shall be appointed to a position if the City Council finds that such person has, prior to such proposed appointment, engaged in discrimination or demonstrated a bias, by word or deed, against any person, group or organization on the basis of race, color, religion, national origin, sex, sexual orientation, gender identity, veteran status, age, or disability.
That provision drew the ire of conservatives, who claimed that the ordinance was an attempt to limit Christians' freedom of speech.
Before long, several right-wing media outlets picked up on the controversy, with each new iteration of the story presenting even wilder claims about the ordinance's supposed threat to religious liberty.
Right-wing media outlets have smeared a proposed measure in San Antonio to expand the city's non-discrimination policy to include sexual orientation and gender identity, falsely claiming that the revised measure would limit free speech and religious liberty.
WND columnist Les Kinsolving declared that the big winners from the Supreme Court's rulings on marriage equality weren't just LGBT Americans, but also those who practice pedophilia, incest, polygamy, necrophilia, and bestiality.
In a July 1 column Kinsolving - who has a penchant for linking homosexuality with bestiality and pedophilia - asserted that legal protections for such practices are the inevitable consequence of the Court's rulings on the Defense of Marriage Act (DOMA) and California's Proposition 8:
To quote Sen. Cardin:
"There is no place for discrimination in America based on sexual orientation."
That should be an absolute boon for those alternate Mormons who still believe in polygamy - as well as the polyandrous (women who would like to have more than one husband at a time).
Then, consider the great joy of members of the North American Man/Boy Love Association, or NAMBLA, which was allowed to march - men with their small boy lovers - in gay parades in both New York and San Francisco.
Among the many other alternate sexual orientations that may well be counted upon to cite this Supreme Court decision are:
- The incestuous;
- Necrophiliacs (providing they properly and healthily preserve the corpses);
- Zoophiliacs, who practice bestiality (providing this form of sexual expression is applied only to freely consenting beasts).
Kinsolving cites the myth - popularized by the American Family Association, a notorious anti-gay hate group - that the American Psychiatric Association recognizes 30 different sexual orientations, including the aforementioned practices, to baselessly push this prediction. In reality, the association does no such thing. But stubborn things like facts won't stand in the way of WND and its ensemble of conspiracy cranks, bigots, and homophobes.
In the short time since the Supreme Court invalidated provisions of the Defense Of Marriage Act (DOMA), conservatives who have opposed marriage equality for years have been painting themselves as the unfairly persecuted victims of the ruling.
Having always had difficulty explaining how extending equal rights to gay couples somehow infringes upon their own personal freedoms -- "you're being intolerant of our right to think gays are an abomination" isn't a particularly compelling argument -- right-wing media figures are now concocting elaborate scenarios in which their future rights will be infringed as a result of the DOMA ruling.
Fox News' Todd Starnes got the ball rolling yesterday, writing on Twitter that it "won't be long before they outlaw the Bible as hate speech," and asking: "How long before federal agents haul pastors out of the pulpit?" Conservative radio host Laura Ingraham wondered aloud whether Catholics in America will be "persona non grata."
According to Farah, the justices who struck down DOMA made "no real effort at making a constitutional case" against the legislation, instead relying on the argument "that anyone who opposes same-sex marriage does so for no other reason than bigotry against homosexuals."
In a column at conspiracy website WND, gun activist Jeff Knox is promoting a company that sells bullets coated with "pork-infused paint" that are theoretically designed to "deter Islamists from martyrdom."
Knox heads a fringe gun group called the Firearms Coalition which recently proposed a successful resolution at the annual National Rifle Association conference urging the NRA to oppose any future restrictions on guns.
In his piece, Knox points to the May terror attack in London and asks why the two assailants didn't flee the scene and merely "waited around for the armed police." Knox posits that the men were waiting to be killed by police in order to become martyrs so they could receive "their tickets to Paradise - and 72 virgins."
While he says that there is debate among Muslims about whether "martyrs for Allah actually receive a reward of 72 virgins," Knox writes that the belief is pervasive enough to raise the question: "how do you deal with religious extremists who believe that dying for their faith is an Express Ticket to Paradise?"
According to Knox, a company in Idaho called "Jihawg Ammo" has come up with a "culturally sensitive" solution:
A company in northern Idaho has come up with a culturally sensitive approach. Jihawg Ammo has developed a proprietary system for infusing ballistic paint with pork. The special pork-infused paint is then applied to the bullets of loaded ammunition. The inclusion of pork in the paint makes the bullets haraam, or unclean. Under Islamic law, anyone who comes in contact with any haraam item is then unclean and must engage in a cleansing ritual. No unclean person can be admitted into Paradise. Do not pass Go. Do not collect 72 virgins.
WND has published a series of unhinged and flagrantly homophobic columns in response to the vote to allow openly gay youth into the Boy Scouts of America.
In the week following the Boy Scouts' May 23 decision to accept openly gay youth into the organization, WND has published responses from some of America's most notorious anti-LGBT activists, each peddling the myth that the BSA's decision will increase rates of pedophilia and other forms of sexual abuse.
In a May 24 column, Liberty Counsel spokesman Matt Barber claimed that the BSA's decision was "rooted in pure evil" and joked that camping trips would have to include a disco ball to accommodate gay scouts:
Ultimately, this decision had nothing to do with "tolerance" or "inclusivity." Neither did it concern the best interests of the boys who make up Boy Scouting. Instead, this decision was rooted in pure evil. It had everything to do with money. "For the love of money is a root of all kinds of evil. Some people, eager for money, have wandered from the faith and pierced themselves with many griefs" (1 Timothy 6:10).
And wandered from the faith they have.
Now come the many griefs.
What a camping trip! Imagine the pup tent. Your son and Jimmy - who's got a crush on him - along with Billy and Billy's boyfriend Bobby, all snuggly warm in the middle of nowhere. But make room for Sammy (formerly Suzie) and Sammy's boyfriend Gary (formerly Gertrude).
Don't forget to hang the disco ball.
In a May 27 column, conservative commentator Mychal Massie warned that boys would be "brainwashed" into accepting homosexuality and claimed that boys would be "coerced into homosexual behavior" because of their hormones:
Why should we be spending money fighting lawsuits and/or endangering our children by knowingly giving predators and the deluded access to our boys? Sensitivity is about not picking on someone who is different. Sensitivity is not synonymous with having our children brainwashed into accepting that which is aberrant as normal.
Let me also point out there is a reason boys and girls are separated in organizations such as this. Amongst other reasons, it has to do with hormones. Are we now supposed to believe that some of our boys will not be coerced into homosexual behavior?
In a May 26 column titled "Texas Boy Scout Massacre," Linda Harvey, founder of the anti-gay hate group Mission America, claimed that the BSA would actively cover up instances of sexual abuse by scouts in order to defend their gay-inclusive membership policy:
They have power now, they will use it and it won't be done responsibly. It won't be child-friendly and it will cost the families of America.
As time rolls on, there will be incidents of abuse. Will the Boy Scout organization report these? Let's not kid ourselves. They just showed how compromised/intimidated/clueless they are. Expect cover-up upon cover-up in the future, eventually resembling the Catholic Church scandal.
And sadly, many parents have no clue, thinking, what's the harm? Where's the threat? An openly homosexual 12 year old in my son's troop - what's the big deal? They don't know the possible risks, because compromised churches have bought the lie and are too sheltered to know what they are dealing with.
Notoriously homophobic WND columnist Les Kinsolving recycled his go-to anti-gay talking point, that accepting gay youth had paved the way for the Boy Scouts to accept other "sexual orientations," including bestiality:
This 60 percent actually approved a measure that said no youth may be denied membership in the Boy Scouts "on the basis of sexual orientation or preference alone."
Can you believe this?
Believe it - and realize that this statement inevitably proclaims that the Boy Scouts will not reject any boy who has engaged in coprophilia, pedophilia, bestiality or any of the many other alternative sexual orientations.
854 adults stamped a "bull's eye" on the Boy Scouts as pederast targets.
Now, bigger and/or more manipulative lads, with cell phones and other pornography resources stirring their sinews, will greedily entrap any and all boys who seem easy prey.
Eroticize the campsite and you eroticize boys to one another and to their leaders. "Gay Scoutmasters" will arrive soon to "help" "their" lads, to train and encourage them - to believe they are naturally "that way."
WND columnist Les Kinsolving equated homosexuality to bestiality, suggesting that people who engage in bestiality should receive the same legal protections afforded to gay people in same-sex relationships.
In a May 20 column titled "Why Not An Additional 'B' To LGBT?," Kinsolving suggested that people engaged in bestiality should be allowed to legally marry animals, equating homosexuality with bestiality and suggesting that animals are capable of consenting to sex with humans:
If lesbians, male homosexuals, bisexuals and transsexuals should have the right to marriage licenses - as a few states, including Maryland, now provide - why should the real animal lovers (whose orientation is bestiality) not be allowed to marry?
The argument that animals are incapable of making a choice is surely invalid in that some animals choose to run away when fondled by humans, while others do not - which certainly indicates their ability to choose.
Have there ever been any reports that apprehended practitioners of bestiality have as high a rate of AIDS and syphilis as do homosexuals?
WND's Kinsolving is a notorious homophobe. During the debate over Maryland's marriage equality law in 2012, he claimed that voters would repeal the measure because gay people are more likely to have syphilis.
The membership of the National Rifle Association has unanimously adopted a resolution proposed by a WND columnist expressing opposition to any and all additional restrictions against guns during the session of its annual meeting. This position puts the activists in attendance out of step not only with the American people, but with the broader membership of the organization.
The resolution was offered by fringe gun activist Jeff Knox during the open session of the May 4 meeting. Knox is head of the Firearms Coalition, a hardline organization that promotes the "unencumbered right to arms" and opposes "any moves toward more restrictive and/or intrusive gun laws." He also writes a column about gun policy for WND, a discredited right-wing website known for its conspiracy theories. Knox's father Neal is credited with leading NRA hard-liners to crush the group's moderate wing in the 1970s and 1990s, helping to establish the organization as a no-compromises right-wing lobbying powerhouse.
The text of Knox's resolution cites its necessity as "a public repudiation of the lies and distortions from the media and politicians suggesting that the majority of NRA members support the expansion of gun control laws as clearly and unequivocally we do not." Polling indicates that the public -- including self-described NRA members -- overwhelmingly support at least one proposal to strengthen gun laws, the expansion of the background check system.
Speaking on behalf of the resolution, Knox claimed it was necessary to establish that "the members here gathered soundly and solidly oppose any and all new restrictions on our Second Amendment rights." John Fafoutakis of Sheraton, Wyoming, seconded Knox's resolution, saying that "we will not compromise. To all those gun-grabbers in Washington, to all their members of the lapdog presstitute news media, and to the gun-grabbers of the United Nations who want to disarm all law-abiding Americans, I have these kind words for you: fill your hand you son of a bitch."
After voting to strike a clause of the resolution requiring its text be published in the NRA's magazine, the membership in attendance passed it unanimously.
After lashing out at critics for highlighting his "sarcastic" tweet that all Muslims should be killed following the Boston Marathon bombings, frequent Fox News guest Erik Rush doubled down on his anti-Muslim rhetoric, calling Islam "wholly incompatible with Western society" and saying America is at war with the religion.
In the wake of the bombings at the Boston Marathon, Rush tweeted, "Everybody do the National Security Ankle Grab! Let's bring more Saudis in without screening them! C'mon!" After another Twitter user criticized Rush for blaming Muslims, Rush responded, "Yes, they're evil. Let's kill them all." Rush later claimed that the now-deleted tweet was "sarcasm," but in his weekly WorldNetDaily column, Rush lashed out by calling his critics "dhimmis" and smearing Islam as "wholly incompatible with Western society." Rush went on to claim that America is at war with Islam and that "While killing people is definitely undesireable, that is what war tends to be about":
It is important that we know the extent to which many of our fellow citizens have been indoctrinated into this suicidal worldview. Despite the interpretations of my words and liberals' tiresome claims that the right is prone to violence, we know that with very few exceptions, violence is the way of the left (as well as Islamists). This also gives rise to curiosity as to what evil deeds large numbers of these dhimmis might be willing to do if properly motivated. As we have seen relative to the Occupy movement, violence -- whether throwing rocks, Molotov cocktails, or engaging in recreational rape -- is a natural progression.
In the end, of course, this is just another case of the words of someone on our side (as it were) being manipulated to malign and discredit, whereas our enemies and those on the left - whether in the press, politics, entertainment, or elsewhere - are allowed to say whatever dangerous, irresponsible, malicious, slanderous things they like with impunity.
For the record, I still maintain that Islam is, by its nature, wholly incompatible with Western society. I analogize liberalism, which is promoting this dhimmitude, to Stage 3 cancer in America's body politic. For the record: While killing people is definitely undesirable, that is what war tends to be about.
And we are at war -- just study the history of Islam, or ask any Islamist.
As advocates prepare for oral arguments in the challenge to California's Proposition 8 and the federal Defense of Marriage Act (DOMA), the right-wing media, typified by The Wall Street Journal, is wrongly pushing the idea that ruling in favor of same-sex couples would lead to the problems they claim resulted from the Court's Roe v. Wade decision, which struck down laws banning abortions.
Perry v. Hollingsworth, which will be argued on March 26, is a challenge to a California constitutional provision that excludes same-sex couples from marriage. Windsor v. U.S., to be argued March 27, challenges a federal statute, Section 3 of DOMA, which denies married same-sex couples and their families protections and benefits provided to different-sex married couples under federal law.
Some in the right-wing media have taken this opportunity to push a parade of falsehoods about marriage equality. For example, after Sen. Rob Portman (R-OH) announced his support for marriage equality, which he attributed to having an out gay son, WND editor Joseph Farah wrote "I guess we should all be grateful Rob Portman's son didn't choose to become a polygamist or a serial killer." Fox News contributor Cal Thomas promoted the same myth that marriage equality leads to polygamy.
However, with support for marriage equality rapidly on the rise, this faulty logic is not likely to persuade a majority of Americans or of the justices. The right-wing media have pivoted to another scare tactic: if the Court strikes down democratically-enacted laws, then the country will have a political and cultural backlash similar to the one they say the Court unleashed in Roe v. Wade, which struck down abortion bans 40 years ago.
Radio host Rush Limbaugh attempted to draw this comparison between Roe and the gay marriage cases. On the March 25 edition of his radio show, Limbaugh claimed that the reason "abortion so roils our culture is that it hasn't been democratically decided. The Supreme Court, nine people in black robes just decided one day that abortion is in the Constitution, and that has led to constant acrimony."
Former federal Judge Michael McConnell invoked a similar argument when he wrote in an op-ed for The Wall Street Journal:
We learned from Roe v. Wade that the Supreme Court endangers its own legitimacy and exacerbates social conflict when it seeks to resolve moral-legal questions on which the country is deeply divided without a strong basis in the text of the Constitution. The court sometimes intervenes when the legislatures of the 50 states are approaching a consensus. When it jumps into a live political controversy, the justices look like they are acting like legislators.
A March 25 Wall Street Journal editorial states that "the two cases before the High Court are less about the institution of marriage than the sanctity of democratic institutions and the proper role of the courts." It warns against the Justices interrupting "the give-and-take on contentious moral and social issues the Constitution is designed to encourage." It compares this possibility to abortion:
The Supreme Court does not have a good record legislating cultural change. A ruling on behalf of same-sex marriage could enshrine Hollingsworth and Windsor with Roe v. Wade, the 1973 abortion decision that imposed a judicial diktat even as laws in many states were liberalizing. Instead of finding a rough consensus inside the political mainstream, abortion became an all-or-nothing combat that still rages.
This characterization of abortion laws 40 years ago is flatly inaccurate. As Linda Greenhouse, a veteran Supreme Court writer and lecturer at Yale Law School, and Yale Law Professor Reva Siegel wrote,
Before Roe, despite broad popular support, liberalization of abortion law had all but come to a halt in the face of concerted opposition by a Catholic-led minority. It was, in other words, decidedly not the case that abortion reform was on an inevitable march forward if only the Supreme Court had stayed its hand.
After Roe: The entanglement of abortion in party realignment explains how, over time, Republicans and Democrats came to switch position on the abortion issue, leaders before base, and assume their current polarized positions on abortion, an evolution that took nearly twenty years after the Court handed down Roe. Our paper argues that when you line up the evidence, political realignment better explains the timing and shape of political polarization around abortion than does a court-centered story of backlash.
To the question of whether one can avoid conflict over such issues by avoiding courts, the answer from an accurate pre-history of Roe v. Wade is: no. The abortion conflict escalated before the Supreme Court ruled.
And because a strong majority of Americans believes that Roe should not be overturned, Roe might not be a particularly persuasive cautionary tale.