Could a Case Currently Before the Supreme Court Result in a Stronger Presidential Pardon?
This article discussed the potential implications of a case that was, at the time of writing, undecided by the Supreme Court. On 17 June 2019 the Supreme Court decided that case, rejecting arguments that could have resulted in a stronger presidential pardon. Far from Kavanaugh's being a deciding vote on the case, the court ruled 7-2 against the notion that Federal and State prosecution for the same crime violates the so-called double jeopardy clause of the Constitution. Justices Ruth Bader Ginsburg and Neil M. Gorsuch dissented. decided On 29 November 2015, a motorist named Terance Gamble, who had been convicted of second degree robbery seven years earlier, was pulled over by an Alabama police officer because of a faulty headlight on his vehicle. Upon searching the car, the officer found a handgun, among other items. It is illegal under both Alabama law and United States law for convicted felons to possess firearms, and Gamble was eventually sentenced to one year in prison on that charge by the state of Alabama. Terance Gamble During Gamble's prosecution under Alabama law for possession of a firearm as a felon, the Federal Government also charged him with the same crime. Gambles lawyers argued that this second conviction was a violation of the U.S. Constitutions ban on double jeopardy, which is intended to protect people from being prosecuted for the same crime more than once. The double jeopardy clause is found in Fifth Amendment to the U.S. constitution, which states (in part) that "No person shall ... be subject for the same offense to be twice put in jeopardy of life or limb. Specifically, the clause has been interpreted to be a prohibition on: interpreted Gamble has been in federal prison since entering a guilty plea on 18 October 2016 that allowed him to appeal his case. In June 2018, the Supreme Court agreed to hear his argument that he has been unconstitutionally punished multiple times for the same crime. While the case is about the constitutionality of a man being charged twice for the same gun possession incident in a narrow sense, the case more broadly has the potential to significantly alter 150 years of Supreme Court precedent. Since the 1850s, the Supreme Court has allowed for one explicit exception to the Constitutions double jeopardy protections: cases of dual sovereignty (or separate sovereigns) which stem from view that the federal government and state governments are distinct entities with occasionally overlapping jurisdictions. (Exceptions to this exception exist which seek to limit double prosecutions at the federal level, but as this case shows they do not always have that effect.) federal level, This separate sovereigns exception to double jeopardy, though built on several previous rulings, was made most explicit in a 1920s bootlegging case, United States v. Lanza, which allowed a man to be charged with bootlegging crimes by both the state of Washington and the federal government. With respect to that case, Chief Justice William Howard Taft argued: United States v. Lanza We have here two sovereignties, deriving power from different sources, capable of dealing with the same subject matter within the same territory. Each may, without interference by the other, enact laws to secure prohibition, with the limitation that no legislation can give validity to acts prohibited by the amendment. Each government, in determining what shall be an offense against its peace and dignity, is exercising its own sovereignty, not that of the other. The separate sovereigns exemption has for much of its history been a controversial precedent which critics maintain is not rooted in the original text of the Constitution but is instead cobbled together from different partially relevant Supreme Court decisions -- decisions rooted in a time when the federal government was less powerful and whose questions never directly sought to address the explicit matter of double punishment for the same crime in state and federal jurisdictions. This argument is reflected in Gambles filing. filing The government argues in this case that the precedent is well-established through myriad Supreme Court cases and consistent with the Founding Fathers' vision of state and federal government duality: The dual-sovereignty principle has been long held, and consistently endorsed by this Court, which has recognized its soundness as a matter of [p]recedent, experience, and reason alike, The Court explained the roots of the principle more than 150 years ago. And in 1959, the Court described a challenge to the dual-sovereignty doctrine as not a new question, having been invoked and rejected in over twenty cases" ... Each sovereign is entitled to exercis[e] its own sovereignty to determin[e] what shall be an offense against its peace and dignity and prosecute the offender without interference by the other. Under petitioners interpretation of the Double Jeopardy Clause, one sovereigns efforts (successful or not) to enforce its own laws would vitiate the other sovereigns similar law-enforcement prerogatives. But that cannot be squared with the Constitutions bedrock structure of governance. In this case, Gamble has explicitly asked the Supreme Court to rule on a single specific question: Whether the Court should overrule the separate sovereigns exception to the Double Jeopardy Clause. The reason Gamble v. United States is generating buzz from people other than constitutional law scholars is that the separate sovereigns exception also prevents President Trump from pardoning people for state crimes. Under current Supreme Court precedent, a presidential pardon of an individual does not prevent that individual from being prosecuted for the same or similar crimes under state law. Under the dual sovereignty doctrine, Adam J. Adler wrote in the Yale Law Review, as long as two offenses are defined by different jurisdictions, they cannot constitute the same offense. wrote The Congressional Research Service issued an August 2018 report on the potential ramifications of the case, and this report included a discussion of its possible effect on the presidential pardon power: report The Gamble case may nevertheless have significant collateral legal effects ... A win for Gamble could also indirectly strengthen the Presidents pardon power, by precluding a state from prosecuting an already-pardoned defendant who has gone to trial on an overlapping offense. Some pundits have speculated that the reason why certain politicians seem to be in a rush to seat Judge Brett Kavanaugh on the Supreme Court is that is that he has a notably strong view of presidential powers and therefore would be a vote in favor of Gamble and for an expansion of presidential pardon powers -- and the Supreme Court announced they would be hearing this case the day after Justice Kennedys retirement. This temporal proximity has prompted some commenters to opine that the rush might be motivated by a desire to limit the presidents legal liability in the Russia probe and other investigations: strong view day after   While we cannot speculate on the motives of politicians who are supporting Judge Kavanaugh's nomination, The Atlantic reported that prominent political legal scholars agree in a general sense with the view of this cases having importance with regard to President Trumps pardon power: reported Within the context of the Mueller probe, legal observers have seen the dual-sovereignty doctrine as a check on President Donald Trumps power: It could discourage him from trying to shut down the Mueller investigation or pardon anyone caught up in the probe, because the pardon wouldnt be applied to state charges. Under settled law, if Trump were to pardon his former campaign chairman Paul Manafort, for example -- he was convicted in federal court on eight counts of tax and bank fraud -- both New York and Virginia state prosecutors could still charge him for any crimes that violated their respective laws ... If the dual-sovereignty doctrine were tossed ... then Trumps pardon could theoretically protect Manafort from state action. If Trump were to shut down the investigation or pardon his associates, the escape hatch, then, is for cases to be farmed out or picked up by state-level attorneys general, who cannot be shut down by Trump and who generally -- but with some existing limits --can charge state crimes even after a federal pardon, explained Elie Honig, a former assistant U.S. attorney in New Jersey. The Atlantic also reported that at least one member of the Senate Judiciary Committee who approved Kavanaugh for a floor vote before the full Senate, Orrin Hatch, has publicly weighed in on the topic (unmotivated, he says, by the implications for the pardon power), filing an Amicus Curiae brief in favor of Gamble which argued that the pervasive federalization of criminal law to cover conduct that traditionally was prosecuted and punished by the states, and that falls within the states core legislative interests, threatens to undermine the protections of the Double Jeopardy Clause unless the dual sovereignty doctrine is overruled in this context. Amicus Curiae Oral arguments for the case have not been scheduled but will occur during this Supreme Court term. If confirmed, Judge Kavanaugh could become a deciding vote in the case. Supreme Court of the United States.  Brief for Petitioner (No. 17-646)."
  24 October 2017. Cornell Legal Information Institute.  Double Jeopardy."
  Accessed 3 October 2018. U.S. Department of Justice.  9-2.031 - Dual and Successive Prosecution Policy ("Petite Policy")."
  Accessed 3 October 2018. Supreme Court of the United States.  United States v. Lanza, 260 U.S. 377."
  11 December 1922. Supreme Court of the United States.  Brief for the United States in Opposition (No. 17-646)."
  16 January 2018. Adler, Adam J.  "Dual Sovereignty, Due Process, and Duplicative Punishment: A New Solution to an Old Problem."
  Yale Law Journal.  November 2014. Hsin, S.  "When Does Double Prosecution Count as Double Jeopardy?"
  Congressional Research Service.  16 August 2018. Kirby, Jen.  "7 Legal Experts on How Kavanaugh Views Executive Power  And What It Could Mean for Mueller."
  Vox.  11 July 2018. Vazquez, Maegan.  "Supreme Court Agrees to Hear 'Double Jeopardy' Case in the Fall."
  CNN.  22 June 2018. Bertrand, Natasha.  "A Supreme Court Case Could Liberate Trump to Pardon His Associates."
  The Atlantic.  25 September 2018 Supreme Court of the United States.  Brief of Senator Orrin Hatch as Amicus Curiae in Support of Petitioner (No. 17-646)."
  11 September 2018. Updated [17 June 2019]: Added note that the Supreme Court ruled on this case.
Claim:  The drawback of a laborer's illiteracy frees him to become a success in another field. LEGEND Example:  [Brunvand, 1993] My grandfather used to tell  about a country lad who went to the big city to seek his fortune, but had no luck finding a job.  One day, wandering through the red light district, he spotted a Help Wanted sign in a window. They were looking for a bookkeeper, but after the madam quizzed the boy about his education and discovered that he could neither read or write, she turned him away. Feeling sorry for him, she gave him two big red apples as he left.  A few blocks down the street, he placed the apples on top of a garbage can while tying his shoe, and a stranger came along and offered to buy them. The boy took the money to a produce market and bought a dozen more apples,which he sold quickly.  Eventually he parlayed his fruit sales into a grocery store, then a string of supermarkets.  Eventually he became the wealthiest man in the state. Finally he was named Man of the Year, and during an interview a journalist discovered that his subject could neither read or write. "Good Lord, Sir," he said.  "What do you suppose you would have become if you had ever learned to read and write?" "Well," he answered, "I guess I would have been a bookkeeper in a whorehouse."1 Origins:  According to folklorist Jan Brunvand, after writer Somerset Maugham was accused of stealing the plot of his 1929 short story "The Verger," he explained that he'd heard the tale from a friend and that it was a well known bit of Jewish folklore.  Maugham's claim is supported by this find, harvested from a 1923 joke book: Some fifteen years ago there landed in New York a friendless and almost penniless Russian immigrant who found lodgings on the East Side and at once, with racial perseverance and energy, set out to earn a living. He was of a likeable disposition, and speedily made acquaintances who sought to aid him in his ambition.  One of them sponsored him for the vacant post of janitor, or shammos, to use the common Hebraic word, of a little synagogue on a side street.  But when the officers of the congregation found out the applicant was  entirely illiterate they reluctantly denied him employment, inasmuch as a shammos must keep certain records.  The greenhorn quickly rallied from his disappointment.  He got a job somewhere.  He prospered.  Presently he became a dabbler in real estate. Within ten years he was one of the largest independent operators in East Side tenement-house property and popularly rated as a millionaire.  An occasion arose when he needed a large amount of money to swing what promised to be a profitable deal.  Finding himself for the moment short of cash, he went to the East Side branch of one of the large banks. It was the first time in his entire business career that he had found it necessary to borrow extensively.  He explained his position to the manager, who knew of his success, and asked for a loan of fifty thousand dollars. "I'll be very glad to accommodate you, Mr. Rabin," said the banker.  "Just sit down there at that desk and make out a note for the amount." The caller smiled an embarrassed smile.  "If you please," he said, "you should be so good as to make out the note and then I should sign it." "What's the idea?" inquired the bank manager, puzzled. "Vell, you see," he confessed, "I haf to tell you somethings: Myself, I cannot read and write.  My vife, she has taught me how to make my own name on paper, but otherwise, with me, reading and writing is nix." In amazement, the banker stared at him. "Well, well, well!" he murmured admiringly.  "And yet, handicapped as you've been, inside of a few years you have become a rich man!  I wonder what you'd have been by now if only you had been able to read and write?" "A shammos," said Mr. Rabin modestly.2 Some like to question the legend's basis on the grounds that if the work-seeker couldn't read, he couldn't have made out what the sign in the window said. "Illiterate" is often mistakenly interpreted as "incapable of making head or tail out of so much as one written word." In real life, any number of folks who cannot read and thus have no hope of making sense of a printed page have learned to recognize by sight a goodly number of key words and phrases, including "help wanted." The illiterate among us manage to catch the right buses, "read" road signs, and order off menus, all by way of having memorized what certain words look like. They exist in mainstream society undetected for years, sometimes fooling even their immediate families. A good story never goes out of style, as this example shows: [Collected on the Internet, 2001] An unemployed man goes to apply for a job with Microsoft as a janitor. The manager there arranges for him to take an aptitude test  (Floors, sweeping and cleaning). After the test, the manager says, "You will be employed at minimum wage, $5.15 an hour. Let me have your e-mail address, so that I can send you a form to complete and tell you where to report forwork on your first day. Taken aback, the man protests that he has neither a computer nor an e-mail address. To this the MS manager replies, "Well, then, that means that you virtually don't exist and can therefore hardlyexpect to be employed. Stunned, the man leaves. Not knowing where to turn and having only $10 in his wallet, he decides to buy a 25 lb. flat of tomatoes at the supermarket. Within less than 2 hours, he sells all the tomatoes individually at 100% profit. Repeating the process several times more that day, he ends up with almost $100 before going to sleep that night. And thus it dawns on him that he could quite easily make a living selling tomatoes. Getting up early every day and going to bed late, he multiplies his profits quickly. After a short time he acquires a cart to transport several dozen boxes of tomatoes, only to have to trade it in again so that he can buy a pickup truck to support his expanding business. By the end of the second year, he is the owner of a fleet of pickup trucks and manages a staff of a hundred former unemployed people, all selling tomatoes. Planning for the future of his wife and children, he decides to buy some life insurance. Consulting with an insurance adviser, he picks an insurance plan to fit his new circumstances. At the end of the telephone conversation, the adviser asks him for his e-mail address to send the final documents electronically. When the man replies that he has no e-mail, the adviser is stunned, "What, you don't have e-mail? How on earth have you managed to amass such wealth without the Internet, e-mail and e-commerce? Just imagine where you would be now, if you had been connected to the internet from the very start!" After a moment of thought, the tomato millionaire replied, "Why, of course! I would be a floor cleaner at Microsoft!" Moral of this story: 1. The Internet, e-mail and e-commerce do not need to rule your life.  2. If you don't have e-mail, but work hard, you can still become a millionaire. 3. Since you got this story via e-mail, you're probably closer to becoming a janitor than you are to becoming a millionaire. 4. If you do have a computer and e-mail, you probably have already been taken to the cleaners by Microsoft. The   legend's message is twofold: that sometimes seeming adversity is actually the Hand of God arranging future events in our favor, and that often the most momentous decisions we make swing on little more than the expediency of the moment. Taking the second point first, we observe that if the young farm boy in the first example had been able to read and write, he would have gained the job he sought, that of a bookkeeper in a brothel, and thus would never have become the grocery tycoon he ultimately turned out to be. As to what led him to seek the bookkeeping position, he quite by happenstance chose to walk down a particular street, coincidentally on a day when a "Help Wanted" sign was posted in one of the windows. On another day, that sign wouldn't have been there, or he would already have had a job somewhere else.  It is ever thus  the directions of lives change depending upon which ad is answered, which interview is given, even which bus is taken. A chance encounter can lead to a marriage and the begetting of children, and just as certainly the slightly different choice of ad or bus can result in those two people's never meeting. Career direction is likewise up for grabs. As much as we like to feel we're masters of our fate, often we're the very last factor to have much influence on unfolding events, even within the confines of our own lives. But there's another message to this legend, one of the power of divine intervention and why it doesn't pay to second-guess God.  Today's disappointment can be a necessary, though momentarily painful, ingredient in tomorrow's success, as the snubbed bookkeeper or janitor finds out. Children of the moment that we are, we tend to forget this truth when caught up in sorrow over not getting what we'd set our hearts on, and tend only to remember it again when things ultimately turn out far better than they would have if we'd gotten our shortsighted way.  Barbara "father of the chide" Mikkelson Sightings:  In Somerset Maugham's 1929 short story "The Verger," an illiterate church caretaker is fired by the vicar when his lack of education comes to light. The ousted verger goes on to become a tobacconist, eventually owning a string of shops in London. Last updated:  20 April 2011 The Baby Train   2.  Cobb, Irvin S.  A Laugh a Day Keeps the Doctor Away.  New York: Garden City Publishing, 1923  (pp. 190-191).  Asimov Laughs Again   Botkin, B.A.  Sidewalks of America.  Indianapolis-New York: Bobbs-Merrill Company, 1954  (pp. 430-431).   The Big Book of Urban Legends.  New York: Paradox Press, 1994.  ISBN 1-56389-165-4  (p. 196). The Big Book of Urban Legends Snopes is still fighting an infodemic of rumors and misinformation surrounding the COVID-19 pandemic, and you can help. Find out what we've learned and how to inoculate yourself against COVID-19 misinformation. Read the latest fact checks about the vaccines. Submit any questionable rumors and advice you encounter. Become a Founding Member to help us hire more fact-checkers. And, please, follow the CDC or WHO for guidance on protecting your community from the disease.  fighting Find out Read Submit Become a Founding Member CDC WHO In October 2020, shortly after U.S. President Donald Trump tested positive for COVID-19, a rumor started circulating on social media that the White House gift shop was selling a "Trump Defeats COVID-19" commemorative coin:   WhiteHouseGiftShop.com is selling a "Trump Defeats COVID-19" commemorative coin. However, this website is not the official gift shop of the White House, the government does not dictate what this business sells, and the Trump administration does not make a profit from its sales.  WhiteHouseGiftShop.com This isn't the first time this misleadingly named gift shop has caused confusion online. In April 2020, a similar rumor went viral after social media users claimed that the United States government was selling "Coronavirus Task Force" coins at its gift shop. Again, while the coins were real, the website selling them was not officially affiliated with the government. The website's owner, Anthony Giannini, told us at the time that the White House Gift Shop "is not affiliated with The White House, nor is The White House involved in any of our decisions, products, or operations." While this website does not have any current ties to the government, it does have a long (and somewhat convoluted) history that can reportedly be traced back to the 1950s when U.S. President Truman set up a gift shop in the basement of the White House: While it traces its history to a 1950 authorization by President Harry Truman, the headquarters of the White House Gift Shop has been in Lititz since 2012. Its operated by Lititz (Pennsylvania) resident Anthony Giannini with his wife, Helen. Its very weird and very cool, Giannini says of the shops curious history and its current location. After a failed assassination attempt of Truman in 1950 left one member of White House Police dead, Truman authorized a fund to benefit the family of the slain officer and the others who were injured in the attack by two Puerto Rican nationalists. When the White House Police became the Secret Service, the Truman-authorized fund became the Secret Service Uniformed Division Benefit Fund. The fund was replenished from the sale of items from a gift shop originally set up in the basement of the White House but eventually relocated to the nearby executive mansion. While Giannini was granted a trademark to use the name "White House Gift Shop," this business has not been officially affiliated with the government since at least 2012.  Umble, Chad.  "From 1600 Pennsylvania Ave. to Warwick Center: How the White House Gift Shop wound up in Lititz."
  Lancaster Online.  27 May 2019. On 27 October 2018, a Facebook account bearing the face of controversial 19th-century Canadian Prime Minister John H. Macdonald shared a post that alleged two facts about Cesar Sayoc, the accused perpetrator of several attempted mail bombings: that he used to work as a stripper, and that he was long known to support Obama during that time: controversial post   It is unclear what the author of this post meant to imply by combining the fact that Sayoc worked in strip clubs with the false assertion that he was an Obama supporter, but of the two claims raised, there is only support for the first. In the days following Sayocs arrest, several media outlets attempted to profile the man who had covered his live-in van with Trump memes and sent what appeared to be pipe bombs to Trumps political and media opponents. These profiles describe a directionless individual who worked at strip clubs in various capacities throughout his life, but who only found a political awakening in the run-up to the 2016 presidential election, when he became a supporter of President Trump. several media outlets Was Cesar Sayoc a Stripper? Several individuals have stated that Cesar Sayoc has not only been employed at strip clubs, but worked as a stripper himself. Ohio event promoter Tony Valentine told the Washington Examiner that he hired Cesar Sayoc to strip on multiple occasions during the 1990s and that Sayoc, now 56, traveled the country for similar appearances. told "He really couldn't find his niche in life, and I guess he found it now," Valentine told the Washington Examiner. "Back in the '90s, he was running around from Minnesota to the Carolinas to Florida. He was like a gypsy." For two months in 2004, according to a profile in the New York Times, Sayoc was married to a woman who was also a stripper. That womans mother told the Times that the two went on the circuit together as dancers: profile He had a short-lived marriage to a woman identified in court papers as Roberta Altieri that ended in divorce in Oklahoma City in 2004, according to court records. Billie Mode, the mother of his ex-wife, said the couple worked in strip clubs and were married just two months. They were dancers, Ms. Mode said. They went on the circuit together. According to Valentine (the event promoter who had worked with Sayoc in the 1990s), he had heard that, as of about five years ago, Sayoc was working as an employee at a female strip club while performing on the side at an all-male strip club in Florida. More recently, he has appeared in posts on the Facebook page "Chippen Fellas," apparently run by Sayoc himself to promote his Hard Rock International Entertainment brand. This page advertised all-male shows and in one instance included a dated picture of someone who appears to be Sayoc alongside more recent photos of younger men. It is unclear whether he ever performed with this group or merely served as a manager: appeared   According to the Times, Sayoc showed up to work as a DJ at a West Palm Beach strip club named Ultra the day before he was arrested. work Did Sayoc Support Obama and Other Democrats In The Past? There is no evidence to support the claim that Sayoc, who sent a pipe bomb to the Obama family, ever supported President Obama. Sayoc registered to vote as a Republican in Florida on 4 March 2016, just ahead of the March 2016 Republican primary, according to the Associated Press. Some have attempted to use doctored images from a MyLife.com background check to assert he was a registered Democrat, but this claim is not rooted in reality. A check of the official Florida voter registry indicates he is currently registered as a Republican. according doctored images voter registry By all accounts, Sayoc lived a fairly apolitical life leading up to the 2016 presidential election. Ronald Lowy, a lawyer for the Sayoc family who represented Cesar during a 2002 case in which he threatened to bomb an electric company over a bill he disputed, told the Times that although Sayocs family members were Democrats, Cesar himself seemed to have no outspoken partisan views during the 2002 case. told Lowys recollection jibes with what a different lawyer, Daniel Lurvey (who represented Sayoc against theft charges in 2013 and 2014), remembers of the mans political leanings. He told the Washington Examiner that he could not recall Sayoc ever discussing politics. Instead, it appears that Sayocs chief interests during this time were bodybuilding and wrestling: told When they first met [over the 2002 bomb threat case], Mr. Lowy said, Mr. Sayoc brought in a scrapbook filled with notes and photographs he had collected from wrestlers, bodybuilders and strippers, table scraps from a world that he idolized. He comes across like a 15-year-old, Mr. Lowy said. He has a total lack of maturity. [...] He said that Mr. Trumps angry rhetoric and his appeals to the forgotten man and woman during the 2016 campaign seemed to strike a deep chord with Mr. Sayoc, whose father had abandoned the family when he was a child. By 2015, it became clear that Sayoc was an outspoken and enthusiastic Trump supporter. That year, In what may have been an effort to make a false insurance claim, he reported to police that $45,000 worth of suits and costumes he needed for his business were stolen from his van. According to the Times, that police report noted that of the 139 pieces he said were taken, 11 were the presidents clothing brand. According Sayoc also attended a Brevard College alumni event with members of his college soccer team that year, during which he quickly made clear he was a fanatical supporter of Mr. Trump, and bombarded them with racist and misogynist conspiracy theories. Two managers at a pizza shop where Sayoc worked in 2017 recall the man making racist remarks while explicitly attacking President Obama and praising President Trump: He loved Adolf Hitler; he talked about Adolf Hitler a lot, said Debra Gureghian, 56, a manager at the Fort Lauderdale pizza shop where Mr. Sayoc worked for about a year in 2017. He would say, I like his politics, we should have more people like him. Mr. Sayoc went on paranoid, racist screeds, saying that blacks and Hispanics were taking over the world. He referred to Mr. Obama with a racist slur and said he was not a citizen. ... Teresa Palmer, 48, another manager, said that she also recalled [his pro-Trump-stickered white] van, and that Mr. Sayoc would say nasty things about minorities. She remembered him mentioning Mr. Trump, but only recalled him saying that Mr. Trump made a great president. During this time, Sayoc was an outspoken proponent of conservative conspiracy theories and pro-Trump memes, which he shared both on social media and the windows of his sticker-covered white van. There is no such support for the notion that he was pro-Obama, pro-Democrat, or even political at all prior to 2015. proponent Hopper, Tristin.  "Here is What Sir John A. Macdonald Did to Indigenous People."
  National Post.  28 August 2018. Nelson, Steven.  "Mail Bomb Suspect Cesar Sayoc Was a 'Big Muscle Head' Stripper, Says Former Boss."
  Washington Examiner.  26 October 2018. Healy, Jack, et al.  "Cesar Sayoc, Mail Bombing Suspect, Found an Identity in Political Rage and Resentment."
  New York Times.  27 October 2018. Balsamo, Michael, et al.  "Florida Trump Supporter Charged in Chilling Mail-Bomb Plot."
  Associated Press.  26 October 2018. Lopez, German.  "The Pipe Bomb Suspect Made Vitriolic, Threatening Posts Against Democrats on Social Media." On 18 January 2017, web site GotNews posted an article reporting that U.S. Rep. John Lewis, a Georgia Democrat who is perhaps most famous for participating in the Civil Rights Movement at the side of Martin Luther King, Jr., didn't pay property taxes on a $1 million townhouse located in the Capitol Hill neighborhood of Washington, D.C.: article Trump-hating Democratic Georgia congressman John Lewis didnt pay property taxes on his nearly $1 million fancy Washington, D.C. townhouse on Capitol Hill, despite being in Congress for decades, where the salary for a Representative starts at $174,000 per year. Lewis was in the news recently for saying he doesnt see President-elect Donald J. Trump as a legitimate president because of the #RussianHackers Democratic conspiracy theory. The article displayed a table showing annual property tax payments for the home in question and a legal notice from 2010 alerting Lewis of a court action against him (the case was later dismissed). It's unclear how this table supposedly documents that Lewis "didnt pay property taxes on his nearly $1 million fancy Washington, D.C. townhouse," given that it lists tax payments due on the property for each of the last several years and shows nothing owing other than the most recent payment (for the last half of 2016):  Moreover, a different view from the same D.C. Office of Tax and Revenue web site shows that the taxes on Lewis' property have indeed been collected, as due, for each of the last several years:  We contacted Lewis's spokeswoman, Brenda Jones, who told us that he bought the home years before property values soared, that he still owns it, and that he is not behind on his taxes: He pays property taxes annually, just as all homeowners in DC do, and his taxes are paid and up to date. Any report that he avoids paying taxes grasps at straws and is a desperate and unnecessary attempt to tarnish his credibility, instead of debating the substance of issues he has raised. Neither the home in question, nor any properties under Lewis' name, appearedon a database search of properties seized and placed on sale for failure to pay property taxes. database A second item of alleged proof offered by GotNews.com was a 2010 "notice of pendency of action," a legal notice ofcourt actions relating to real property. The document appears to be a notice of a foreclosure hearing. That case, however, was dismissed on 11 February 2011: notice  According to current public records available as of 19 January 2017, Lewis still owns the property, confirming that the case was dropped. It was purchased in 1988 (for an unknown price) and is currently valued at $865,790. An explanation offered by Lewis's office states that in 2010 he nearly lost his home to foreclosure but was able to stop the process: explanation Rep. Lewiss Washington, DC property was purchased decades ago for a fraction of its current value today. As most Washingtonians and any real property expert know, property values in the city have risen exponentially in the last 10 to15 years. Rep. Lewis is delighted that he made a wise investment years ago, and that his propertys value has skyrocketed. He also realizes he likely could not afford to purchase his own home were he seeking to buy it today. In 2010, he was subjected to attempts to foreclose upon his home, like many Americans during that period. He is fortunate that he was able to stop that process, though many Americans, including many hundreds of his constituents, were not as successful. His property taxes are paid and currently up to date. GotNews.  "Trump-Hating Democratic @RepJohnLewis DIDNT PAY TAXES On His Nearly $1 Million Fancy DC Townhouse."
18 January 2017. Seipel, Brooke."Rep. John Lewis: Trump Isn't a 'Legitimate President.'"
The Hill.13 January 2017. Wootson, Cleve R. "In Feud With John Lewis, Donald Trump Attacked 'One of the Most Respected People in America.'"
The Washington Post.15 January 2017. ]In May 2015, a fraudulent offer for $200 Home Depot coupons started circulating on Facebook. The message contained a link that redirected bargain hunters to a web site adorned with Home Depot's logo that has nothing to do with the real Home Depot:   The $200 Home Depot coupon scam is very similar to other schemes that targeted Costco, Amazon, and Kroger shoppers. While each scam has slight variations, they all feature three main components. First, they require people to like or share the message on Facebook in an attempt to spread the scam around the Internet. Second, they direct people to complete a survey that extracts personal information such as email addresses, telephone numbers, dates of birth and credit card numbers. Lastly, these scams never end with a "free" rewards, because users must first agree to sign up for several costly, difficult-to-cancel "Reward Offers" hidden in the fine print to claim their coupons. Costco Amazon Kroger In April 2017, another Facebook coupon scam targeted Home Depot. In that iteration the chain was purportedly doling out $50 coupons "to celebrate Mother's Day, and links directed users to www.homedepot.com-grabitnow.us (a URL clearly unaffiliated with the legitimate Home Depot website): Home Depot   Home Depot didn't address the 2017 Facebook coupon scam on their social media channels as of 24 April 2017, but it was nevertheless clearly not a legitimate promotion affiliated with the chain. The Better Business Bureau gave these three tips to identify scams on Facebook: Facebook Don't believe what you see. It's easy to steal the colors, logos and header of an established organization. Scammers can also make links look like they lead to legitimate websites and emails appear to come from a different sender.Legitimate businesses do not ask for credit card numbers or banking information on customer surveys. If they do ask for personal information, like an address or email, be sure there's a link to their privacy policy. Watch out for a reward that's too good to be true. If the survey is real, you may be entered in a drawing to win a gift card or receive a small discount off your next purchase. Few businesses can afford to give away $50 gift cards for completing a few questions. In April 2017, an advertisement for a diet product called "Refresh Garcinia Cambogia" or "Garicinia Slim" was disguised as a genuine news report and published on web sites such as Running Evolutions.com and The Platinum Beard:  Running Evolutions.com The Platinum Beard   Student from Cornell University Cuts 31lbs On University Budget! Amanda Haughman, a student at Cornell University, was able to drop 31lbs off her waist in 1 month without ever using a dime of her own money. Amanda is studying nutrition sciences at Cornell, and for a required research project Amanda thought it would be perfect to use university funds to find out how to 'hack' her weight loss. According to Amanda, "the most expensive piece of it all was actually finding what worked. But the actual solution only cost about $5." "I had struggled with my weight my whole life. I tried things like Weight Watchers and Jenny Craig, which just didn't work as good as they promised. I am a single Mom with a kid at home and I am also working towards my degree, so I don't have any time to be at the gym. When I was assigned this big research project, I saw it as a perfect opportunity to get a deeper look at the natural weight loss opportunities that are out there, and that is when I found out about combining Refresh Garcinia Cambogia and apple cider vinegar. The best part of it all, I can tell that my daughter is proud of me." - Amanda Haughman These reports included a number of false and misleading claims. For instance, the lead photograph purportedly showing Amanda Haughman's tremendous weight loss is actually Rachel Graham, who lost nearly 100 pounds in a year. Graham told Today in 2016 that she credited her weight loss to exercise and a healthy diet. Graham did not mention the alleged magic formula of apple cider vinegar and garcinia cambogia: Rachel Graham Today Ask Rachel Graham how shes managed to lose almost 100 pounds in one year and the formula is simple: Healthy food and exercise. No secrets. No gimmicks. No quick fixes. Shes also honest about the impact of going from 235 pounds to 144 pounds, especially the loose skin on her stomach, thighs and arms.  [...] I want people to know that it is 110 percent possible, Graham told TODAY. I used to feel as though it wasn't. That I didn't have what it takes, and that it was just too far out of reach... If you want to make changes, it is completely possible with healthy food and exercise. This weight loss advertisement also fabricated an interview with CNN and claimed that the network ran a segment on this Cornell student's "amazing discovery":   We sat down with Amanda to ask her more about how she found out about Refresh Garcinia Cambogia and whether or not that is all that she used to lose 31lbs so quickly. CNN: Tell us, how did you know where to start? Amanda: To be honest, I really didn't. I was given a budget for the project by the university, and I spent nearly all of it researching everything under the sun. I looked into other previous research, case studies, and even successful weight loss stories of others.   This story never appeared on CNN.  Not surprisingly the Platinum Beard post links to a site selling Garcinia Cambogia. The Running Evolutions article links instead to what is apparently borrowed content from Barry's Boot Camp, a personal training program. We reached out to Barry's Boot Camp for comment, but have not yet received a reply.  Although we can't speak to the effectiveness of drinking apple cider vinegar with Refresh Garcinia Cambogia, we can say that this text did not originate in a genuine news article. This is an advertisement that used a fabricated interview, falsified claims, and an unrelated photograph to sell a diet product. Pawlowski, A.  "Mom gets real about weight loss: Here's how she shed 90 pounds in a year."
  Today  3 October 2016. On 27 June 2018 the Facebook page Uncle Sam's Misguided Children shared the photograph reproduced below, purportedly showing women "screaming" at United States President Donald Trump, but somehow through their vaginas: shared photograph   Text on the image read: Not a joke. They gathered to scream at Trump through their vaginas. These are the people who want to control the government and teach your kids. Predictably, no documentary information was presented to support the claim, and Facebook users were both expected to  and did take the explanation on its face. However, a reverse image search indicated that the image had been circulating since at least February 2016, well before President Donald Trump was elected. A number of backstories were previously attributed to the photograph. In February 2018, YouTube videos and blogs claimed that the images showed "a new trend" known as "raising your skirt for diversity": videos blogs claimed I follow a few accounts on Instagram that post hilarious feminist stuff (or, I suppose, anti-feminist stuff), and on one of those accounts today, I came across this: [Image.] Obviously, I had to investigate to see if Raising The Skirt is an Actual Thing, which is what led me to the sourcelink. And you guys, their About page is positively insane. It says, in big bold letters across the top, "Reclaim your c*nt. Reclaim our c*nt." Only without the polite asterisks. The disgusting feminists of the world have officially outdone themselves. They've now launched a new project dubbed "Raising the Skirt," which calls on women to perform a sick act in public. Case in point: Some of the more enthusiastic social justice warriors of the feminist movement have begun a project called "Raising the Skirt," aimed at "celebrating the diversity of vaginas." This is not a drill. There are actual women gathering with the sole purpose of raising their skirts, exposing their most intimate part to complete strangers. And they call it a celebration. At that point, the photograph was at least two years old, and had circulated once again on Reddit in July 2017: old Reddit     Originally reported articles about the "new feminist trend" of skirt-raising dated back to September 2015, but did not include the photograph seen above: articles "Raising the Skirt" by artist Nicola Canavan is exploring [women's relationships with their genitals] in her series of portraits of everyday women, as they share the beauty of their bodies, while exploring their relationships with their vaginas and what they symbolise to them. A photograph labeled as "feminists ... screaming through their vaginas" at President Trump was taken in or earlier than February 2016, and was later attributed to artist Nicola Canavan's "Raising the Skirt" series of portraits. Canavan's work was not a "feminist trend," but rather a photography project undertaken on a relatively small scale. We contacted Canavan, who confirmed that this is one of her images. Further, we found no evidence that either skirt-raising or vagina-screaming had become a popular activity for any reason. Sinclair, Leah.  "This Artist Is Pushing For Recognition Of Vagina Diversity."   Dazed.  15 September 2015. Chicks on the Right.  "Raising Your Skirt To Celebrate Vagina Diversity Is a Thing Now."   20 February 2018. Mad World News.  "Disgusting Feminists Launch 'Raise the Skirt' Project, Want Women To Do SICK Act in Public."   20 February 2018. Raising The Skirt.  "About."   Accessed 27 June 2018. On 8 January 2016, the entertainment web site The Reporterz published an article reporting that Delaware had created a new "child support card" that controlled "what mothers can and cannot buy" with their child support funds: This measure was taken to prevent parents from misusing funds that are meant to help with costs associated with raising children, such as school related expenses, food, etc. This card will not be allow the parent to purchase alcohol, cigarettes or pay car payments the card will be used exactly like a food stamp card. We spoke to Tasha Brown who was upset after she couldn't purchase a bottle of Hennessy at her local liquor store. she says "Its' [sic] unfair its [sic] my money I should be able to do what i want with it how will I pay for my new weave?"   The article was ambiguous about whether the card would apply to all funds received for the care of children (such as support monies paid by former spouses) or funds made available through government assistance programs. It didn't matter either way, though, as the story was a complete fabrication that originated with a fake news web site that does not publish factual stories. A disclaimer on The Reporterz states that "every article is based on a true story, only the facts have been changed." In this case, Delaware really does have a card that makes it easier for single parents and guardians to receive funds. The First State Family Card is a pre-paid debit card that does not require bank account: The First State Family Card is a pre-paid VISA card that is credited whenever a payment is posted to any/all of a client's child support case(s). Benefits to the debit VISA card include: While Delaware does have a card that makes it easier for parents to collect child support, the handbook for the First State Family Card (not the "Child Support Card") does not mention any restrictions on how the funds may be utilized. mention A photograph supposedly showing two women in the moment just before they were executed by an unidentified man is often shared with the claim that the gunman seen in the picture is the Argentine-born Cuban revolutionary figure Che Guevara, despite the fact that the executioner's face is not visible in the photograph:   This photograph is nearly always shared with anti-socialist sentiments and often posted along with barbs directed at politicians such as Bernie Sanders orAlexandria Ocasio-Cortez. Most commonly it is shared as a meme with the caption "This is the image of Che Guevara that should be seen on t-shirts." Bernie Sanders Alexandria Ocasio-Cortez meme caption Che Guevara is a controversial historical figure, regarded as anything from a cultural hero to little more than a wanton murderer. A number of articles, books, movies, and documentaries can assist those curious about the Marxist revolutionary in forming an educated opinion about his legacy, but this photograph should not be included in a hypothetical course on the subject, as it doesn't show Che Guevara. articles books movies documentaries Our investigation into the origins of this photograph took us from baseless claims on social media to archival photographs documenting wars in places such as El Salvador and Yugoslavia. Ultimately, however, our search ended in an unlikely location: Atlanta, Georgia. Before this image was first associated with Che Guevara in late 2017, the photograph was circulated attached to a different claim. In 2011, this picture was included in a gallery about the Farabundo Mart National Liberation Front (FMLN) during the Salvadorian Civil War, a bloody conflict which started in 1980 (thirteen years after Guevara's death): included   However, we could not confirm that this photograph truly shows a member of the FMNL during the Salvadorian Civil War. When we reached out to Martn lvarez Alberto, an El Salvadorian historian with a special interest in the FMNL, to ask if he was familiar with this photograph, he told us that he had never seen it and that he doubted that the picture was taken in El Salvador. Alberto noted that the men looked Caucasian, not Salvadorian, and that the building in the background was more typical of locations such as Europe or the United States. Susan Meiselas, a documentary photographer who worked in El Salvador during the Civil War, came to a similar conclusion: The buildings in this image did not resemble those in El Salvador. Meiselas also hypothesized that the photograph was taken in eastern Europe. The relatively modern wardrobe of the two women, and the suggestion that this photograph was taken in Eastern Europe, led us to examine photographs of theYugoslav Wars in the early 1990s. An image of DraganVasiljkovi, the commander of a Serb paramilitary unit called the Kninde who was found guilty of war crimes by the Republic of Croatia, appears to show similar fatigues: war crimes   This, of course, is not hard evidence that the photograph was taken during the Yugoslav Wars. In fact, when we talked tophotojournalistRon Haviv, who documented the Yugoslav Wars, he told us that he did not recognize the uniform of the man in the viral picture. So where was this photograph taken and whom does it show? Although our focus so far has been on war crimes, we had our doubts that this photograph even documented such a historical event. The nonchalant posture of the second man watching this alleged execution, the various people in the background who seem to be wearing backpacks, and the smoking bucket (which we hypothesize could be a makeshift fog machine), lead us to believe that this might be a photograph taken on the set of an obscure film production:   As it turns out, that's pretty much what this photograph shows. We uncovered another copy of this image on the web site for CISPES, the Committee in Solidarity with the People of El Salvador (CISPES), where it is presented as a photograph taken in 1989 of a "Guerrilla Theatre" performance at Emory University in Atlanta, Georgia: CISPES   We reached out to CISPES for more evidence that this was a theatrical production and they provided us with images showing a physical copy of this photograph which featured the words "Emory College Atlanta Mar 89" scrawled on the back:   This photograph does not document Che Guevara executing two women. It was taken in the late 1980s at Emory University in Atlanta, Georgia, and depicts a performance by a local "guerrilla theater" group. Mastinu, Luca.  "Bufala Acchiappalike 'Quanto Era Benevolo Il Che.'"   Bufale.net.  12 October 2017. Cosgrove, Ben.  "Che Guevara: The Rorschach Revolutionary."   TIME.  28 October 2014. El Torogoz.  "Album 12 De La Memoria Historica."   Retrieved 28 July 2018. Magnay, Jacquelin.  "Captain Dragan Convicted of War Crimes."   The Australian.  27 September 2017. Claim:  Former New York mayor Ed Koch delivered a radio address on anti-semitism.  Example:  [Collected on the Internet, 2002] We are now going through the most virulent anti-Semitic period since Hitler and Stalin. Nearly 60 years after the end of World War II almost every country on the European continent, including England, France, Germany, Holland, Belgium and the Scandinavian countries, has seen major outbreaks of physical violence against their Jewish citizens, and against Jewish institutions, including synagogues and cemeteries. At the same time, open hostility toward the State of Israel is at an all-time high.  Only in the United States have we seen a full acceptance of Jews as citizens and the Jewish state treated as a friend and ally by an overwhelming number of fellow citizens. In the U.S., Jews have been permitted to rise and fall based on their individual talents, virtues and faults. In one elite bastion after another, Jews have been selected to head institutions heretofore seen as beyond their reach. Today the presidents of Harvard and Yale Universities are Jews, as are recent former presidents of Columbia and Princeton. Having been elected three times as mayor of the City of New York, I have been the beneficiary of this country's generosity and freedom from bigotry, and I will be eternally grateful.  Americans traditionally make New Years resolutions. Before I list my own resolutions, I want to thank President George W. Bush and his advisers, Vice President Dick Cheney, Secretary of Defense Donald Rumsfeld, Secretary of State Colin Powell and National Security Adviser Condoleezza Rice for their support of the State of Israel. They could easily have jettisoned Israel as a liability in their efforts to forge an international coalition against worldwide terrorism. I will be forever grateful to them, and I hope that many other supporters of the State of Israel will recognize and appreciate what they have done.  Fortunately for Jews and the State of Israel, American support of the Jewish nation has been bipartisan. Particularly helpful has been the Democratic leadership in both houses including Senator Tom Daschle, outgoing Minority Leader Dick Gephardt, as well as former President Bill Clinton and Senator Hillary Clinton. There are many others on both sides of the political aisle who deserve similar praise.  In the religious sector, I am grateful to the Reverends Pat Robertson and Jerry Falwell, both of whom have stood up time and again in support and defense of the Jewish nation. Regrettably, there have been many clergy who have unfairly attacked Israel for attempting to defend itself against near-daily terrorist acts against its citizens. We were made privy to the true thoughts of Rev. Billy Graham caught on tape telling President Nixon his real feelings about Jews and Israel. He has since apologized, but what is an apology without contrition and efforts to right the wrong done? Worthless.  Now to my personal New Years resolutions. I will avoid France as a place to vacation. France leads those countries in the Security Council who are the enemies of the State of Israel. So too is Mexico, joining as a consistent supporter of resolutions unfairly denouncing Israel at the U.N. Security Council.  I will not support National Public Radio in any way. NPRs reporters and management delight in unfairly attacking Israel.  I will no longer lend financial support to New Yorks Channel Thirteen public television station. That station recently showed a documentary that was blatantly biased against Israel and has refused to acknowledge the bias or to try to correct it.  I will not watch ABCs World News Tonight anchored by Peter Jennings. For many years, Jennings has specialized in vicious and unfair portrayals of Israel intended to injure the Jewish state and lionize Palestinians.  BBC News is horrifically anti-Israel and I will shun it completely.  Susan Sontag will occupy the Ninth Circle of Hell for her outrageous assaults on Israel. I will no longer read her works.  Regrettably, there are many others whom I could include on this list, but I will leave that for another day. I must confess I got enormous pleasure from the defeat of Congresswoman Cynthia McKinney and her father in the recent primary elections in Georgia. In my view, both are anti-Semitic and anti-Israel. No longer able to feed at the public trough, I doubt that either will make a comparable living in the private sector.  I must close now to get ready for my Chanukah and Christmas shopping. I enjoy celebrating those holidays with Jewish and Christian friends whose goodwill and affection I will always cherish. Origins:  Ed Koch, mayor of New York City from 1978 to 1989,   mayor  was a regular commentator on Bloomberg Radio until his death in 2013.  On 7 December 2002, he delivered a commentary dealing with his perception that western society is experiencing its most"virulent anti-Semitic period since Hitler and Stalin" and offered a list of new year's resolutions regarding people and institutions he would shun for being anti-Israel.  Transcripts of that commentary (reproduced above) have since been posted to a variety of web sites. Bloomberg Radio Just to be sure this information was accurate, we contacted Bloomberg Radio for verification and received an affirmative response: Hello and thank you for your inquiry. Former Mayor Ed Koch is a regular commentator on Bloomberg Radio.  On 7 December 2002, Mr. Koch delivered a commentary on our "Bloomberg On the Weekend" broadcast in which he postulated a growing anti-semitism in America and elsewhere in the western world.  He asserted that public broadcasting  had an anti-Israeli attitude and declared he would no longer contribute.  I hope this answers your question, and I invite you to listen to us each weekend for Ed Koch and much more.   If you are in the greater New York area you will find us on Bloomberg Radio, WBBR, 1130 on your AM radio dial. Elsewhere we can be heard on the internet at http:/www.bloomberg.net/radio. http:/www.bloomberg.net/radio Sincerely,Wes Richards, Host. Last updated:  6 January 2014