The effectiveness of counterterrorism efforts by the Bush Administration is compromised by flawed analyses based on sloppy scholarship by Marc Sageman and Bruce Hoffman—two leading experts heavily relied on by policymakers. The resulting programs of government surveillance and computerized data-collection are unnecessarily undermining the civil liberties of millions of Muslims and Arabs living in this country, as well as the rights of all Americans.
Accurate descriptions of targeted terrorist formations and potential terrorists, especially their ideology and methods, are crucial for effective government efforts to understand, predict, and prevent acts of domestic terrorism while abiding by Constitutional safeguards. This is because police and intelligence agencies embrace different investigative techniques with different levels of government intrusiveness depending on how they perceive the configurations of potential terrorist cells and movements.
Sageman and Hoffman are currently embroiled in a well publicized dispute over whether future acts of domestic terrorism by Islamic militants, such as those carried out on September 11th, will be generated by the international Qaeda network (Hoffman) or homegrown terrorism planned by Muslims living in the United States (Sageman).
The dispute gained public attention when Hoffman negatively reviewed Sageman’s recent book, Leaderless Jihad: Terror Networks in the Twenty First Century, in the prestigious journal Foreign Affairs. Hoffman’s book Inside Terrorism was published in 1998 and revised and expanded in 2006. Hoffman complained that Sageman’s book was a “brusque dismissal of much of the existing academic literature on terrorism in general and terrorist networks in particular,” and “employs historically groundless parallels.” Sageman responded in a following issue. The debate then was covered in the New York Times and other publications.
Both Sageman’s and Hoffman’s books examine how social movements are built, how terrorism is justified within small groups, and how people in activist underground cells can reinforce a decision that violence or terrorism is justified and necessary.
Behind the scenes, Hoffman’s analysis is favored by many analysts inside the Department of Homeland Security and other federal agencies, while the work of Sageman and other researchers affiliated with the New York Police Department is favored by the Senate Committee on Homeland Security and Governmental Affairs, chaired by Joe Lieberman, the Connecticut Independent. Lieberman is a supporter of Republican Presidential-hopeful John McCain and has launched a campaign to pressure the federal government to adopt a more hard-line policy toward the threat of domestic terrorism. Not coincidently, this helps McCain and applies pressure on Democratic Presidential hopeful Barack Obama to move to the political right on this and related issues such as U.S. policy in the Mideast. It also feeds a wave of Islamophobia sweeping the country.
A central aspect of the analyses by Sage- man and Hoffman involves examining the intersection of religiously motivated violence, insurgent right-wing movements in the United States, and an underground cell structure called “Leaderless Resistance.” Yet their research into this area is woefully inadequate and at times simply not accurate. They also fail to adequately distinguish between radical ideas and violent methods, which raises serious First Amendment issues. In fairness to Hoffman, the flaws in his book are confined to one area of analysis, while Sageman’s Leaderless Jihad lacks the citations generally considered appropriate in scholarly work, and in two instances constitute intellectual plagiarism.
A growing environment of flawed and superficial research has created a series of problems for public policy analysts studying terrorism, including:
- Pointless polarization of debate into two camps when there are numerous other valid analytical interpretations
- Failure to adequately distinguish radical ideologies from violent methods
- Flawed and sometimes woefully inaccurate information about right-wing violence in the United States
- Misreading of the concept of “Leaderless Resistance”
- Misapplication of contemporary social movement theories, and superficial analysis of the role of religion in political struggles and violence.
Marc Sageman’s first book, Understanding Terror Networks, published in 2004, was full of accurate and nuanced analyses of the role of social movement dynamics in the creation of terror cells, especially among Muslim émigrés. Sageman is a sociologist and psychiatrist who in 1984 joined the Central Intelligence Agency, working on the Afghan Task Force for a year before spending 1987 to 1989 in Islamabad coordinating support for the Afghan Mujahedin. Sageman left the CIA in 1991.
Sageman currently is a senior fellow at the Center on Terrorism, Counter-Terrorism, and Homeland Security of the Foreign Policy Research Institute, and a senior associate of the Center for Strategic and International Studies. Sageman has guided the anti-terrorism policies of the NYPD for several years, and in July 2008 was named the Police Department’s “Scholar-in-Residence.”
The Foreign Policy Research Institute (FPRI) and the Center for Strategic and International Studies (CSIS) are centers of right-wing militarist analysis, with FPRI representing old hardline conservative militarists and CSIS allied with the militarists of the neoconservative movement. Both sectors of the Right are in a coalition backing aggressive U.S. foreign policy in the Mideast by the Bush Administration a coalition that is sometimes at odds with more pragmatic and diplomacy-oriented forces in the State Department, Central Intelligence Agency, and Department of Homeland Security.
Bruce Hoffman has more mainstream credentials. Between 2004 and 2006 Hoff man was the Scholar-in-Residence for Counterterrorism at the Central Intelligence Agency. Hoffman has held the Corporate Chair in Counterterrorism and Counterinsurgency at the RAND Corporation, and served in 2004 as Acting Director of RAND’s Center for Middle East Public Policy.
During the period Hoffman was at RAND, his colleagues John Arquilla and David Ronfeldt originated and developed an analysis of what they called “Netwar,” which overlaps with and complements the concept of Leaderless Resistance.
Hoffman is currently a professor at Georgetown University in Washington, D.C., affiliated with the Security Studies Program at the Edmund A. Walsh School of Foreign Service.
Terrorism, Religion, & Violence
Given the role of religious and secular ideological beliefs in acts of violence and terrorism during the past twenty years, a thorough public debate over scholarly theories and public policy assessments is needed to ensure public safety while protecting civil liberties. A central question in this regard is the role of the concept of Leaderless Resistance in assisting right-wing insurgency, violence, and terrorism, such as the rightist bombing of the federal building in Oklahoma City in 1995. Does Leaderless Resistance lead to Leaderless Jihad?
The terms “Leaderless Resistance” and “phantom cells” refer to spontaneous, autonomous, unconnected underground cells organized by insurgents seeking to carry out acts of violence, sabotage, or terrorism against a government or occupying military force. As scholar Simson L. Garfinkel points out, the term is sometimes used too loosely “to refer to networked organizations with hub-and-spoke architecture. Such terminology is incorrect.”1Garfinkel, author of Database Nation, wrote one of the first major studies of Leaderless Resistance in 2003, and is now an associate professor at the Naval Postgraduate School. Garfinkel argues that Leaderless Resistance “applies specifically to groups that employ cells and that lack bidirectional vertical command links— that is, groups without leaders.”2
Leaderless resistance is widely discussed among U.S. right-wing insurgents, many with ties to militant religious ideologies, and this form of underground cell structure is frequently discussed among government analysts and policymakers investigating ways to combat domestic terrorism. Like many other scholars and journalists, neither Sageman nor Hoffman conveys an accurate picture of the history of Leaderless Resistance.
The concept of Leaderless Resistance as a series of unconnected autonomous underground cells was developed by anticommunist theoretician Ulius Louis Amoss in 1953 to encourage resistance to Soviet repression in Eastern Europe. “Pete” Amoss worked for the Office of Strategic Services (OSS) during World War II, which later was reorganized in the postwar period as the Central Intelligence Agency. Amoss, who had established a private group called International Services of Information (INFORM), warned that traditional hierarchical underground cells organized by the CIA in Eastern Europe were being penetrated and liquidated by Soviet and Eastern Bloc counterintelligence operations.
In 1961, anti-Castro Cuban exiles and their allies with close ties to the CIA airdropped leaflets over Cuba. The leaflets used the concept of Leaderless Resistance and called for the creation of “phantom cells” (celulasfantasmas). There is no apparent connection between Amoss and the leaflets, according to Michael Paulding, who is writing a book on an early OSS figure and has studied Amoss and his work. Amoss died in November 1961, a few months after the failed CIA-orchestrated Bay of Pigs invasion of Cuba. Amoss’s Leaderless Resistance essay was republished posthumously in 1962 in Amoss’s INFORM newsletter, having been rewritten from the 1953 original by a freelancer, according to Paulding.
The term was repopularized in 1983 by racist organizer Louis Beam in a very different essay that borrowed the title and concept of “Leaderless Resistance.” This essay was reprinted by Beam in 1992.3 In both versions, Beam credits the original idea to Amoss. Beam is a White supremacist and former Ku Klux Klan leader tied to neonazi and race hate organizing in the United States.
Sageman and Hoffman both mistakenly suggest that White supremacists originated the idea—Sageman blames Beam, and Hoffman traces it to the White supremacist adventure novel Hunter, William Pierce’s sequel to The Turner Diaries—before weaving it into claims about the terrorist threat posed by White supremacist insurgents in the United States.4
Sageman claims that Louis Beam developed the theory of Leaderless Resistance “to continue the right-wing militias fight against the U.S. government.” Beam played a role in the development of the militia movement in the early 1990s, but certainly did not develop the concept of Leaderless Resistance for the militias when he wrote the essay in 1983. The militias overlapped with the organized White supremacist movement, but according to most scholars, was distinct and independent from it.5
Hoffman offers no credible evidence that the idea’s “impact on the militia movement has been profound.” Hoffman is wrong when he asserts Beam’s version of Leaderless Resistance (1983) was based on the novel Hunter, which was published in 1989. Furthermore, Hunter is primarily about a lone wolf terrorist, although small cells are also mentioned.
This is not just semantics. Are acts of violence and terrorism in the United States being carried out by right-wing insurgents engaged in “Leaderless Resistance?” There is little evidence to support this widespread fear.
According to Garfinkel, the clearest examples of Leaderless Resistance in the United States are in the ecological group Earth First! and several Animal Liberation movements—movements that generally avoid harming people with their acts of vandalism. Small splinter groups have recently engaged in intimidation against people, but while this is evidence of criminal acts, it does not fit traditional definitions of terrorism.
Almost all incidents reported as examples of Leaderless Resistance by White supremacists in the United States actually appear to have involved small groups of persons with previous ties to other groups promoting armed resistance or violent methodology. This is not Leaderless Resistance.
There have been examples of “lone wolf” terrorism, where individuals act on their own, but these incidents mostly appear to involve persons who were at least briefly involved with existing groups advocating armed resistance or violence. This is not Leaderless Resistance.
There are a handful of incidents where a debatable argument can be made for Leaderless Resistance cell structure being used by the White supremacist movement, but even these offer dubious lessons for U.S. counterterrorism policy relating to isolated Muslims and Arabs living in the United States.
For example, Timothy McVeigh, who blew up the Oklahoma City federal building in 1995, was thoroughly embedded in the Armed Citizens Militia movement for years, but had adopted a neonazi ideology before turning to the methodology of terrorism assisted by a small group of cohorts. The most plausible explanation for motive was McVeigh’s anger at the federal government for domestic policies involving what he saw as tyranny and government political repression. Antiterrorism “experts” originally wrongly blamed the blast on Middle Eastern terrorists angry at U.S. foreign policies.
For counterterrorism, the distinction between connected cells, unconnected cells, and a lone wolf activist unconnected to previous group participation is important because different investigative techniques with different levels of government intrusiveness are required depending on the type of target. Therefore accurate descriptions of target terrorist formations and potential terrorist cells are crucial for stopping actual acts of terrorism.
Sageman writes that:
The leaderless social movement has other limitations. To survive, it requires a constant stream of new violent actions to hold the interest of potential newcomers to the movement, create the impression of visible progress toward a goal, and give potential recruits a vicarious experience before they take the initiative to engage in their own terrorist activities.
If this is true, I should be able to locate a list of terrorist bombings of U.S. steakhouses by vegetarians. The Internet has helped create and extend numerous leaderless social movements, the vast majority of which have not engaged in violence of any kind, much less terrorism.
Actually, Sageman has borrowed this idea and plagiarized some specific wording from Garfinkel, who wrote in 2003:
Causes that employ Leaderless Resistance do not have these links because they are not organizations: They are ideologies. To survive, these ideologies require a constant stream of new violent actions to hold the interest of the adherents, create the impression of visible progress towards a goal, and allow individuals to take part in actions vicariously before they have the initiative to engage in their own direct actions.
Garfinkel, however, is defining Leaderless Resistance as specifically referring to “a strategy in which small groups (cells) and individuals fight an entrenched power through independent acts of violence and mayhem.” This accurately refers to Beam’s thesis, not generally to all social movements that are “leaderless” but not engaged in acts of “resistance” in Sageman’s overbroad derivation.
If we understand domestic terrorist tendencies as more properly modeled as an outside contagion, rather than as something spontaneously generated, then it would be more proper to monitor known terrorists, rather than conducting sweeps of all potential terrorists. Ironically, these techniques are similar to those advocated by Marc Sageman in his first book. Yet government agencies are reportedly analyzing secret intelligence data scanning for networks, patterns of interaction, etc. in a search for different kinds of underground terrorist cells. Tracking an actual “Leaderless Resistance” cell that is truly spontaneous, autonomous, and unconnected requires an intrusive penetration of a larger community in which these cells achieve some level of anonymity. Everyone in the community would be suspect until their innocence had been proven.
In other words, how police believe terrorists are organizing affects their counterterrorism tactics.
Garfinkel in 2003 observed that:
The U.S. appears to be fighting Leaderless Resistance networks… with an eradication strategy based on crime-fighting: the goal is to create very high penalties for individuals who participate in direct action. The danger of this approach is that the eradication effort itself may inadvertently serve to attract new recruits to a violent ideology, by making the cause appear a just response to an unjust enemy.
Religious Motivations for Violence
Religiously justified violence is at the core of much terrorism carried out in the name of Islam, but neither Hoffman nor Sageman have a firm grasp on the intricacies and nuances of current social science that studies the phenomenon among the Christian Right in the United States (see sidebar on Hoffman).
Hoffman’s inability to detect the factors making the militia movement distinct from neonazi terrorists is especially troubling in terms of civil liberties because Hoffman exaggerates the role of terrorism in the militias. Militias are a subset of the broader Patriot Movement, as are the Christian Patriots, which overlap with both the militias and the White supremacist movement. The White supremacist movement has more of a history of violence and terrorism, but with the exception of those eras when the Ku Klux Klan had a mass following, the violence has been carried out by a tiny armed underground linked to the larger social movement.
Sageman tends to dismiss the role of religion in motivating political violence because the terrorists he studied are in his appraisal not religious scholars nor devout.6 But neither factor is needed for religious belief to be a powerful motivator for a social movement activist to turn to violence in the name of religion. Among the scholars who have discussed the role of religion in terrorism are Jessica Stern (Terror in the Name of God: Why Religious Militants Kill) and Mark Juergensmeyer (Terror in the Mind of God: The Global Rise of Religious Violence). Sageman’s claims are a refutation of these works without a detailed discussion of them.
Not so Sage Scholarship
Sageman cites few scholars, which could lead the reader to believe he is a kind of “leaderless scholar” whose work in unconnected to that of other social scientists. As with Sageman’s exaggeration of Leaderless Resistance as a mode of terrorist organization, the truth is much less spectacular.
Much of Leaderless Jihad draws from sociologists and anthropologists and other scholars who study collective behavior, social movements, organized supremacist groups, religious theology, millenarianism, apocalypticism, and political violence. Almost none of this work over the past twenty years is cited by Sageman. Yet Sageman was recently featured in a major profile in the newsletter of the American Sociological Association… which he wrote himself.
Sageman’s lack of citations is more than a problem of attribution because it does not allow other researchers to trace the documentation for his numerous uncited claims nor make his readers confident that he is engaging with whole swatches of recent social science research. This is a serious problem for someone whose work is influencing government policies. Critical praise for Sageman’s Leaderless Jihad as groundbreaking and innovative seems to be inversely proportional to the reviewer’s knowledge of social movement theories developed over the past thirty years.
For instance, Sageman’s discussion of conspiracism is underdeveloped.7 He provides no cites to the standard works in the field, which in recent years has explored the role of conspiracy theories in generating narrative stories that can justify the use of scapegoating and violence. Most egregious is the following:
A global conspiracy theory is different. It is comprehensive in nature and points to the existence of a vast, insidious, and effective international network designed to perpetrate acts of the most evil sort.
This seems quite perceptive, as it should, since the sentence is lifted virtually intact from an early passage and central thesis of Richard Hofstadter’s classic work, The Paranoid Style in American Politics.
Hoffman notes that in Sageman’s book “the reader is told that ‘until recently, a large part of the literature on terrorism concentrated on definitions of terrorism’—with the citation justifying this fatuous assertion referencing a book published in 1984.”
Sageman’s explanation of how individuals are recruited into dissident social networks and social movements is well-rounded, yet fails to cite the standard sociological works in which those concepts were developed.8
Sageman discusses “heroic sacrifice,” “martyrdom,” “absolute evil,” and the creation of a “personified villain.”9 Yet readers might be interested in knowing the underlying scholarly studies that look at dualism, scapegoating, demonization, apocalypticism, millenarianism, and the sacralization of politics.
Sageman dismisses scholarship on totalitarianism and totalist groups as the “myth” of “brainwashing,” ignoring the scholarly work of Robert J. Lifton, Charles Strozier, and others on the role of totalist systems in shaping a belief justifying violence and terrorism.10 Since the 1990s there has been a resurgence of scholarly interest in totalitarian groups, and there is even a scholarly journal of Totalitarian Movements and Political Religions with articles detailing the relationship to terrorism.11
In his scathing review of Sageman’s Leaderless Jihad, Hoffman offers a list of authors who have done significant work in computerized analysis of terrorist groups, and then notes that “No references to any of these authors of standard studies are found in Leaderless Jihad’s citations.”12 Hoffman puts it bluntly: “Sageman’s historical ignorance is surpassed only by his cursory treatment of social networking theory.”
Sageman describes social movements as not being affiliated with institutions, but there are numerous different types of social movements, many of which interact with institutions or create their own. Sageman contradicts much social movement scholarship when he claims that social movements “do not have a formal structure… [and] do not have members but participants.”13 Most sociologists recognize that some social movements have no membership requirements, but many have formal members who often pay dues or agree to at least “principles of unity.”
Understanding the ideology, frames, narratives, and recruitment methods of a social movement is important for law enforcement officers concerned about potentially illegal acts yet attempting to work within the legal boundaries set by the First Amendment. By blurring the distinction between ordinary social movements, gangs, and violent terrorist cells, Sageman provides a justification for federal policy-makers who want to loosen restrictions of the surveillance of political dissidents.
Policy and Civil Liberties
Sageman’s views have been popularized and distorted, most recently by the Senate Committee on Homeland Security and Governmental Affairs. It has been holding hearings on Islamic Terrorism for the past year. In Sageman’s June 2007 testimony, he declared:
“…we must analyze the process transforming normal young Muslims into people willing to use violence for political ends. The understanding of this process of ‘radicalization’ is critical to assessing the threat facing the West and should be the basis guiding our interventions to counter it…. [T]hese new groups are physically isolated but connected through Internet forums, inspired by the extremist ideology and hoping that they will be accepted as members of al Qaeda through their terrorist operations.
On May 8, 2008 a report emerged from the Committee’s office. Titled Violent Islamist Extremism, the Internet, and the Homegrown Terrorism Threat, the report did not represent the views of the entire committee, many of whom were not even aware of the report until after it was issued. It was primarily prepared by Lieberman’s staff, and published under his name and that of Republican Susan Collins of Maine, the ranking minority member of the committee. The Lieberman/Collins report picked up on Sageman’s concerns about the Internet, but amplified them into a set of hyperbolic warnings that stereotyped Muslims and fed Islamophobia.
According to the Muslim Advocates, Muslim Public Affairs Council, Council on American Islamic Relations, and the American-Arab Anti-Discrimination Committee:
The report heavily relied upon a widely criticized and deeply flawed New York Police Department study on domestic radicalization that claimed that typical “signatures” of radicalization include wearing traditional clothing, growing a beard, or giving up cigarettes, drinking, and gambling. The advocacy groups also expressed dismay with the fact that the Committee, while citing the value of increasing outreach to American Muslim and Arab-American communities, heard testimony from only one witness from the American Muslim community.14
A letter signed by over 20 groups warned that:
Focusing the discussion of homegrown terrorism on Muslims may actually increase the potential for violent radicalization in the United States. Many witnesses before the Committee spoke of the growth of Islamophobia and the polarization of the Muslim community as risk factors that raise the potential for extremist violence. Unfairly focusing suspicion on a community tends to create the very alienation these witnesses said could lead to homegrown terrorism.15
Ironically, while the Senate committee channeled a distorted version of Sageman’s work on the Internet in its report, it overlooked some worthwhile recommendations at the end of his recent book. They include:
- The United States should reduce the sense of “moral outrage” among Muslims by “withdrawing from Iraq,” and on the local level showing “restraint in the aftermath of terrorism operations.”
- Western countries “should regain the moral high ground and condemn any atrocity or persecution committed by any government, including some of our staunchest allies in the Middle East, often in the name of the ‘war on terror.’”
- Individuals arrested on suspicion of being terrorists “are entitled to due process and the impartial application of justice in order to win over the worldwide Muslim community and refute claims that Muslims are treated unfairly.”
Public attention to the dispute between Hoffman and Sageman has focused on who is right or whether they’re both partially right—but this is the wrong lesson to take from the debate. The problem is that they’re both substantially wrong in ways that jeopardize our safety and our civil liberties.
Flaws and errors in both Sageman’s and Hoffman’s analyses are making suspects out of millions of U.S. citizens and noncitizen residents, and justifying increased domestic surveillance on a scale that could dwarf the now million-name-long “watch list” for airline passengers. Furthermore, in some cases there are other antiterrorism policy advisors who are using a superficial reading of Leaderless Resistance, while ignoring some of Sageman’s more sensible recommendations in his final chapter. This is what is feeding Senator Lieberman’s recent overwrought efforts.
The public dispute between Hoffman and Sageman needs to be widened to include a broader discussion of the U.S. “War on Terror.” While public policy attention over the past few years has focused on the polarized positions of Sageman and Hoffman, a broad range of differing (and often more complex and nuanced) analyses from a number of scholars is being overlooked by the White House and Congress. Here I’m thinking of Jessica Stern, and Fawaz A. Gerges, author of The Far Enemy: Why Jihad Went Global, to name only two.
The work of Hoffman and Sageman also must be closely analyzed and critiqued by social scientists who study religion, violence, state repression, social movements, and collective behavior. And Sageman needs to be held accountable for his lack of citations.
Is this just scholarly semantic duels and pointless academic nitpicking? No. By failing to fully explore a range of social science research, policymakers are doomed to commit analytical or conceptual errors. An accurate understanding of social movement boundaries helps predict potential violence within some social movements, while accurately assessing others as simply exercising First Amendment rights. The level of surveillance and infiltration by government agencies is supposed to be regulated by these considerations. Drawing distinctions between radical ideology and violent methodology is at the heart of the First Amendment. In the United States, stopping ideological radicalization is not a job for government agencies.
Antiterrorism policy and civil liberties deeply affects us all—we deserve better.
- Garfinkel and I discussed Leaderless Resistance in 2003.
- Simson L. Garfinkel, “Leaderless Resistance Today”, First Monday, online journal, 2003.
- Louis Beam, “Leaderless Resistance,” Inter-Klan Newsletter & Survival Alert, undated, circa May 1983, pages not numbered. On file at Political Research Associates; Louis Beam, “Leaderless Resistance,” The Seditionist, 12 (February 1992); 1213.
- Marc Sageman, Leaderless Jihad: Terror Networks in the Twenty-first Century, ( Philadelphia: University of Pennsylvania Press, 2007),143; Bruce Hoffman, Inside Terrorism (New York: Columbia University Press, 1999), 114, 115.
- This differentiation has been covered in detail by Mark S. Hamm, Joel Dyer, Martin Durham, Steven M. Chermak, Lane Crothers, Carolyn Gallaher, Lorna L. Mason, Matthew N. Lyons, and me.
- Sageman, Leaderless Jihad, 59-60, 80.
- Sageman, Leaderless Jihad, 8182.
- For instance, John D. McCarthy and Mayer N. Zald., “Resource Mobilization and Social Movements: A Partial Theory,” American Journal of Sociology, vol. 82, no. 6, May 1977: 1212–1241; Doug McAdam, Political Process and the Development of Black Insurgency,1930–1970, (Chicago: University of Chicago Press, 1985).
- Sageman, Leaderless Jihad, 82.
- Sageman, Leaderless Jihad, 50-51.
- I am on the editorial advisory board of the journal.
- Hoffman mentions “the pathbreaking work of Stephen Borgatti, Kathleen Carley, David Krackhardt, and Jeffrey Reminga on covert social networks; Aparna Basu, Valdis Krebs, Ami Pedahzur, and Arie Perliger on the structural and sociological characteristics of terrorist social networks; and David Jones, Shaul Mishal, and Michael Smith on how terrorist networks operate.”
- Sageman, Leaderless Jihad, 31.
- “American Muslim & Arab Organizations Issue Statement on Homeland Security Committee Report,” The American Muslim, May 14, 2008.
- “Memorandum to Members of the Senate Committee on Homeland Security and Governmental Affairs,” Defending Dissent Foundation, May 30, 2008.