The political stakes are high for the oil and gas industry, which is desperate to preserve its dominance amid cascading environmental policy shifts, broadening support for the renewable energy revolution, and ever more visible, sensed, social, and economic effects of climate change. This desperation is partially why conditions for climate protest and dissent are getting worse, not better, in countries around the world.[i] In the U.S. alone, we risk the federalization of anti-protest laws and policies that are now being deployed across many states. This corporate-backed effort not only threatens to undermine climate action, it also perpetuates the use of a similar legal and judicial playbook against other social movements.
The roots of climate protest criminalization
The oil industry has been laying the groundwork for climate protest suppression for decades by manufacturing climate denial and framing activists as an extremist, eco-terrorist, or violent threat.[ii] These disinformation tactics are dangerous because they provide the justification for harsh policing and legal treatment.[iii] New research shows that a global web of think tanks called the Atlas Network has created trailblazing marketing materials and supported “thought leaders” who vilify climate activists in Europe, Africa, Australia, and the Americas.[iv] The Atlas Network was founded in 1981, after landing early support from Shell, BP, and Charles and David Koch. Its member organizations include Koch-affiliated groups such as the Cato Institute, Heritage Foundation, and American Legislative Exchange Council (ALEC). The rhetorical framings pushed by the Atlas Network have spread far and wide partly because they are easy for private and government actors to adopt for their own reasons, regardless of association with the network.
The backlash against the Indigenous-led Standing Rock movement shows how vilifying rhetoric opens the door to forceful suppression and criminalization. During the height of the movement in 2016, North Dakota law enforcement officials, aided by Energy Transfer’s lead security firm TigerSwan, made frequent public claims that prayer and resistance camps harbored violent criminals.[v] Leaked documents reveal that TigerSwan even communicated internally about water protectors with much the same language that they used to describe “jihadist” fighters and insurgents.[vi] But it was the police and security forces who arrived at Standing Rock with armored vehicles, rifles, teargas grenades, and water cannons.[vii] Hundreds of protesters would be injured during encounters with the police and security, and countless more were left traumatized.[viii] Of nearly 15,000 water supporters at the Standing Rock protests, 837 people would face criminal charges in North Dakota with 26 ending in convictions at trial.[ix]
In many states, we have yet to implement policies that protect frontline activists from the physical, emotional, and financial burden caused by police and private security harassment and prosecutions.[x] But grassroots initiatives such as the Water Protector Legal Collective have emerged to defend frontline activists asserting their First Amendment rights.[xi]
Anti-protest laws spread across the U.S.
Following Standing Rock and since 2017, state lawmakers across the U.S. have introduced more than 280 bills that restrict the right to protest, with at least 25 introduced in the first two months of 2024.[xii] Some of these bills respond to the massive surge in climate activism that originated with Standing Rock. Fossil fuel anti-protest bills, as they can be called, contain severe penalties for protest-motivated infractions near pipelines and other fossil fuel sites, and they have been enacted into law in 22 U.S. states representing 60 percent of U.S. oil and gas production.[xiii] A particularly harsh version of the law was enacted in North Carolina in 2023: now, protesters can face more than 15 years in prison and a mandatory $250,000 fine for impeding pipeline construction in the state.[xiv]
The fossil fuel and energy industry has played a key role in the creation and spread of anti-protest laws. In 2017, oil companies and trade groups used ALEC as a vehicle for pushing model fossil fuel anti-protest legislation to state lawmakers across the country.[xv] ALEC-affiliated lawmakers have sponsored or authored the legislation in 18 out of the 22 states where it has been enacted.[xvi] Since 2017, dozens of energy companies and trade groups have lobbied for fossil fuel anti-protest bills in at least 20 states.[xvii]
Once adopted into the conservative playbook, anti-protest laws more broadly have become a go-to measure used by right-wing lawmakers to punish and deter progressive organizing, especially the Black Lives Matter and pro-Palestine movements.[xviii] Some laws eliminate driver liability for hitting protesters, create felony offenses for demonstrations construed as “riots,” and more.[xix] Since 2016, ExxonMobil, Marathon Petroleum, Chevron, Duke Energy, and Koch Industries have each donated between $150,000 and $538,800 to the sponsors of anti-protest bills covering this full spectrum.[xx] In 2020 alone, Marathon Petroleum donated more than $110,000 to 83 anti-protest bill sponsors. Although the individual donations can seem small, they can represent a significant share of the total amount that candidates in small districts raise for state elections. The industry’s support for anti-protest laws reflects its desperation to stamp out the groundswell of support for climate and social justice, but we cannot allow it to succeed.
Judicial harassment: the other side of the coin
At the same time, fossil fuel companies and public prosecutors are targeting climate activists with sweeping civil litigation claims and criminal charges that seem intent to crush dissent altogether.[xxi] Court systems are being exploited to saddle activists with burdensome legal fees, court dates, and the threat of prison time, largely for exercising their First Amendment rights. Often, these lawsuits dangerously and illogically mischaracterize anyone expressing dissent as part of a criminal enterprise.
Since 2012, fossil fuel companies have targeted more than 190 defendants with judicial harassment tactics such as strategic lawsuits against public participation (SLAPPs) and abusive subpoenas.[xxii] Greenpeace is facing one such lawsuit brought by Energy Transfer for uplifting the Indigenous-led movement at Standing Rock.[xxiii] Although a federal judge dismissed Energy Transfer’s initial RICO complaint in 2019, the company filed a new lawsuit in North Dakota state court that is scheduled to go to trial in July.[xxiv] In Virginia, Mountain Valley Pipeline has sued more than 40 individuals alleged to have slowed construction on the controversial fracked gas pipeline.[xxv] Activists that have opposed the Mountain Valley Pipeline have also reportedly been held in jail for days without bail.[xxvi]
Georgia authorities’ ruthless effort to crush the Stop Cop City movement, which is mobilizing to save Atlanta’s Weelaunee Forest and resist police intensification, has a high degree of crossover with Big Oil’s desperate legal playbook to undermine climate protest. Last year, prosecutors with DeKalb County and Fulton County arrested more than 40 individuals who were not accused of injuring or attempting to injure anyone under a state law passed in 2017 that classifies actions intended to disable public facilities or energy infrastructure as “terrorism.”[xxvii] In September, Georgia Attorney General Chris Carr indicted more than 60 individuals on RICO charges, citing First Amendment-protected conduct, such as writing “ACAB” and making zines, as evidence.[xxviii] The attack on protest and free speech rights in Georgia has continued this year, as one Democrat and nine Republican senators introduced a bill that would normalize such prosecutions despite indications that expanding RICO in this direction would be unconstitutional.[xxix] Our legal system should protect all of us, but the fossil fuel industry and aligned politicians have sought to weaken or control it for their own gain.
Our problems could still grow worse
Although the U.S. federal government has contributed deeply to protest suppression through programs that militarize state and local police forces and frame activists as terrorist suspects, it has stopped short of the legal abuses described above.[xxx] Still, anti-protest laws and arbitrary prosecutions similar to those in some U.S. states could be brought to a national level, following the anti-abortion playbook of the U.S. Right. These tactics can also spread globally. Anti-protest laws passed in Alberta, Canada and New South Wales, Australia since 2020 both have the same general structure as their U.S. counterparts.[xxxi] In Brazil, the Canadian mining company Belo Sun is suing 40 individuals—many of them small-scale farmers, Indigenous community leaders, and members of environmental NGOs—for standing against the development of a massive gold mine on illegally acquired land.[xxxii] We must also attend to the risk of worsening violence against environmental defenders, which already occurs at staggeringly high rates in some countries including Columbia and the Philippines.[xxxiii]
There is no hope for a habitable planet without protest. Defending this right will require organizing at every level, from the local to the global, but it is especially incumbent upon those of us living in the U.S. to mobilize, because the U.S. wields considerable global influence as a massive fossil fuel producer and consumer. Moreover, the U.S. is one of only a few countries in the world that has large oil and gas reserves, relatively open civic space, and a diversified economy. If the U.S. cannot leave fossil fuels in the ground, who will?[xxxiv]
Hundreds of grassroots movements have demonstrated the power of protest, and the path forward is clear.[xxxv] As my Greenpeace USA colleagues describe in our Dollars vs. Democracy 2023 policy recommendations, we need to unite our movements to defend the right to protest and dissent, and to reaffirm and fight for Indigenous sovereignty and the redress of human rights violations.[xxxvi] We must also strengthen the rights of communities to defend themselves against the harms of fossil fuel infrastructure and to prevent law enforcement from serving as an arm of the fossil fuel industry.
We will not be silenced. We must protest, and to do so we must make protest possible, in order to breathe on our planet. Already, anti-protest bills are being challenged in multiple state courts and many states have passed strong “anti-SLAPP” laws that protect against abusive lawsuits.[xxxvii] Last year, a Minnesota judge dropped the charges that were pending against Indigenous environmental defenders who resisted the Line 3 pipeline, writing that “to criminalize their behavior would be the crime.”[xxxviii] With only a handful of years left to defeat the fossil fuel industry before we rocket past climate thresholds, the time is now for transformative change.
Endnotes
[i] “Rights Reversed: A Downward Shift in Civic Space” (CIVICUS Monitor, January 2024), https://monitor.civicus.org/rights-reversed-2019-to-2023/.
[ii] Phoebe Keane, “How the oil industry made us doubt climate change,” BBC News, September 20, 2020, https://www.bbc.com/news/stories-53640382; Katie Jennings, Dino Grandoni and Susanne Rust, “How Exxon went from leader to skeptic on climate change research,” Los Angeles Times, October 23, 2015, https://graphics.latimes.com/exxon-research/; Amy Westervelt and Geoff Dembicki, “Meet the Shadowy Network Vilifying Climate Protestors,” DeSmog, September 12, 2023, https://www.desmog.com/2023/09/12/atlas-network-vilifying-climate-protestors/; “API: Illegal actions to turn off cross border pipelines pose danger to human life, communities, and the environment,” American Petroleum Institute, October 12, 2016, https://www.api.org/news-policy-and-issues/news/2016/10/12/illegal-actions-to-turn-off-cross-border; Andrew M Harris and Tim Loh, “Energy Transfer Suit Claims Greenpeace Incites Eco-Terrorism”, Bloomberg, August 23, 2017, https://www.bloomberg.com/news/articles/2017-08-22/energy-transfer-sues-greenpeace-claims-it-incites-eco-terrorism. The oil industry, acting through a network of trade groups, think tanks, and lobby organizations, has funded contrarian research and used public relations tactics to shed doubt on the science of global warming since at least the early 1990s (1-2). Climate denial is used to discredit climate activists (and support for climate policy, more generally) by suggesting them to be alarmist or unreasonable. There is also evidence that the oil industry-connected Atlas Network has capitalized on framing environmentalists as extremists since at least the 1990s (3). Notably, the American Petroleum Institute used the “extremist” framing to condemn the non-violent activists who turned the shut-off valves on several oil pipelines in October 2016 (4), and Energy Transfer Partners falsely accused Greenpeace of “plant[ing] radical, violent eco-terrorists” to oppose the Dakota Access Pipeline in an August 2017 federal lawsuit that was dropped in 2019 (5).
[iii] Grace Nosek, “The Fossil Fuel Industry’s Push to Target Climate Protesters in the U.S.,” Pace Environmental Law Review 38, no. 1 (January 19, 2021), https://papers.ssrn.com/abstract=3769485; Kay Whitlock, “Reconsidering Hate,” Political Research Associates, June 1, 2012, https://politicalresearch.org/2012/06/01/reconsidering-hate. Whitlock raises additional concerns about the usage of a “hate frame,” which can serve to “focus on individuals and groups considered to be ‘extreme’ in their political views and actions, [while drawing] attention away from structural inequalities, exclusions, and violence that are foundational to the ordinary workings of so-called ‘respectable’ public and private institutions.”
[iv] Westervelt and Dembicki, “Meet the Shadowy Network.”
[v] Steve Horn and Curtis Waltman, “Emails Show Iraq War PR Alums Led Attempt to Discredit Dakota Access Protesters,” DeSmog, July 20, 2017, https://www.desmog.com/2017/07/20/emails-bush-iraq-war-pr-delve-off-the-record-strategies-dakota-access-pipeline/; Michael Sainato, “Police Restart Propaganda Campaign Against Standing Rock Water Protectors,” The Observer, January 17, 2017, https://observer.com/2017/01/police-restart-propaganda-standing-rock/; Alleen Brown and Naveena Sadasivam, “Pipeline Company Spent Big on Police Gear to Use Against Standing Rock Protesters,” The Intercept / Grist, May 22, 2023, https://theintercept.com/2023/05/22/standing-rock-energy-transfer-tigerswan/.
[vi] Alleen Brown, Will Parrish, and Alice Speri, “Leaked Documents Reveal Counterterrorism Tactics Used at Standing Rock to ‘Defeat Pipeline Insurgencies,’” The Intercept, May 27, 2017, https://theintercept.com/2017/05/27/leaked-documents-reveal-security-firms-counterterrorism-tactics-at-standing-rock-to-defeat-pipeline-insurgencies/; “Internal TigerSwan Situation Report” (Contributed to DocumentCloud by The Intercept), 2, February 27, 2017, https://www.documentcloud.org/documents/3868812-Internal-TigerSwan-Situation-Report-2017-02-27. From the TigerSwan Report: “What the anti-DAPL protesters have called an ‘indigenous decolonization movement’ was, essentially, an externally supported, ideologically driven insurgency with a strong religious component. And, as it generally followed the jihadist insurgency model while active, we can expect the individuals who fought for and supported it to follow a post-insurgency model after its collapse. The archetype of a jihadist post-insurgency is the aftermath of the anti-Soviet Afghanistan jihad. While many insurgents went back to their pre-war lives, many, especially the external supporters (foreign fighters), went back out into the world looking to start or join new jihadist insurgencies. Most famously this ‘bleedout’ resulted in Osama bin Laden and the rise of Al Qaeda […]” (5).
[vii] Seth Kershner, “Police Are Still Getting Surplus Army Gear—and They’re Using It to Crack Down on Standing Rock,” In These Times, November 2, 2016, https://inthesetimes.com/article/police-are-still-getting-surplus-military-gearand-theyre-using-it-to-crack; “Water Protector Legal Collective Files Suit for Excessive Force against Peaceful Protesters,” National Lawyers Guild, November 28, 2016, https://www.nlg.org/water-protector-legal-collective-files-suit-for-excessive-force-against-peaceful-protesters/.
[viii] Julia Carrie Wong, “Dakota Access Pipeline: 300 Protesters Injured after Police Use Water Cannons,” The Guardian, November 21, 2016, sec. US news, https://www.theguardian.com/us-news/2016/nov/21/dakota-access-pipeline-water-cannon-police-standing-rock-protest; “Unlicensed #DAPL Guards Attacked Water Protectors with Dogs & Pepper Spray,” Democracy Now!, September 4, 2016, https://www.democracynow.org/2016/11/24/standing_rock_special_unlicensed_dapl_guards.
[ix] “ND State Criminal Cases,” August 22, 2020, https://web.archive.org/web/20200822124507/https://waterprotectorlegal.org/nd-state-criminal-defense/.
[x] “Reforms Introduced to Protect the Freedom of Assembly,” ICNL, November 20, 2023, https://www.icnl.org/post/analysis/reforms-introduced-to-protect-the-freedom-of-assembly. ICNL has tracked efforts to implement many reforms that better protect the freedom of peaceful assembly such as restrictions on less lethal weapons, restrictions on guns at protests, restrictions on surveillance technology, and reforming public order laws.
[xi] “Water Protector Legal Collective,” Water Protector Legal Collective, accessed March 27, 2024, https://www.waterprotectorlegal.org.
[xii] ICNL, “US Protest Law Tracker,” International Center for Not-for-profit Law, accessed May 24, 2024, http://www.icnl.org/usprotestlawtracker/.
[xiii] Andres Chang, Kelly Boehms, and Eli Vargas, “Dollars vs. Democracy 2023: Inside the Fossil Fuel Industry’s Playboook to Suppress Protest and Dissent in the United States” (Greenpeace USA, October 2023), 9, https://www.greenpeace.org/usa/reports/dollars-vs-dissent/, https://www.greenpeace.org/usa/reports/dollars-vs-dissent/. Fossil fuel anti-protest laws, which the industry prefers to call “Critical Infrastructure” laws—”a term that diverts attention from the use of these laws in stifling protest”—have been passed in Oklahoma, Louisiana, North Dakota, Indiana, Tennessee, Ohio, Texas, Missouri, Kentucky, Wisconsin, West Virginia, South Dakota, Mississippi, Arkansas, Kansas, Montana, Alabama, North Carolina, Iowa, Oregon, Georgia, and Utah. See also Greenpeace USA, “Supplementary Analysis: Fossil Fuel Anti-Protest Laws and Barricaded Oil and Gas Production” (2023), https://docs.google.com/document/d/1mRCX2sGBpzy5cbg7SfyGC7Wuwb-KrHnk3MR….
[xiv] “Senate Bill 58” (2023), https://www.ncleg.gov/Sessions/2023/Bills/Senate/PDF/S58v7.pdf.
[xv] Jennifer A Dlouhy, “Oil Companies Persuade States to Make Pipeline Protests a Felony,” Bloomberg, August 19, 2019, https://www.bloomberg.com/news/articles/2019-08-19/oil-companies-persuade-states-to-make-pipeline-protests-a-felony; Lee Fang, “Oil Lobbyist Touts Success in Effort to Criminalize Pipeline Protests, Leaked Recording Shows,” The Intercept, August 19, 2019, https://theintercept.com/2019/08/19/oil-lobby-pipeline-protests/.
[xvi] Chang, Boehms, and Vargas, “Dollars vs. Democracy 2023: Inside the Fossil Fuel Industry’s Playboook to Suppress Protest and Dissent in the United States,” 30.
[xvii] “Ranking Companies Lobbying for State Anti-Protest Laws, 2017 - 2023,” December 9, 2023, https://docs.google.com/spreadsheets/u/1/d/1n_OC3utkowaNWAxcKwJJa91y4yhJjslTRf8KegEsMq8/edit?usp=embed_facebook.
[xviii] “U.S. Current Trend: New Wave of Legislation Targeting Black Lives Matter Protesters,” ICNL, January 15, 2021, https://www.icnl.org/post/analysis/u-s-current-trend-new-wave-of-legislation-targeting-black-lives-matter-protesters; Darryl Li, “Anti-Palestinian at the Core: The Origins and Growing Dangers of U.S. Antiterrorism Law,” Center for Constitutional Rights and Palestine Legal, February 2024, https://ccrjustice.org/node/10201.
[xix] “Analysis of US Anti-Protest Bills,” ICNL, February 25, 2023, https://www.icnl.org/post/news/analysis-of-anti-protest-bills.
[xx] “Analysis: Fossil Fuel & Energy Sector Contributors to Anti-Protest Bill Sponsors,” accessed March 27, 2024, https://docs.google.com/spreadsheets/d/1as9I7Hxb1ejW79GBI8GpRPSBgX0IIxCy_eCRYi7zhdA/edit?usp=embed_facebook.
[xxi] EarthRights International, “The Fossil Fuel Industry’s Use of SLAPPs and Judicial Harassment in the United States” (EarthRights International, September 2022), https://earthrights.org/publication/the-fossil-fuel-industrys-use-of-slapps-and-judicial-harassment-in-the-united-states/ .
[xxii] EarthRights International; Laurence Hammack, “Mountain Valley Pipeline Sues Its Opponents,” Roanoke Times, September 11, 2023, https://roanoke.com/news/local/government-politics/mountain-valley-pipeline-protesters-lawsuit-resistance/article_41163394-50f0-11ee-bd8f-33c5ea279fd2.html. This total combines 152 cases between 2012 and 2022 identified by EarthRight International and more than 40 individuals that were named in a lawsuit filed by Mountain Valley Pipeline in 2023.
[xxiii] “Big Oil Greed v the Truth: Greenpeace on Trial Over Standing Rock - Greenpeace USA,” Greenpeace USA, February 28, 2024, https://www.greenpeace.org/usa/big-oil-greed-v-the-truth-greenpeace-on-trial-over-standing-rock/.
[xxiv] Pamela King, “Judge Dismisses Racketeering Suit against Protesters,” E&E News (Politico), February 18, 2019, https://subscriber.politicopro.com/article/eenews/2019/02/18/judge-dismisses-racketeering-suit-against-protesters-032471.
[xxv] Hammack, “Mountain Valley Pipeline Sues Its Opponents.”
[xxvi] Appalachians Against Pipelines (@stopthemvp), “7 (!!!) People Are Currently Being Held without Bail after Being Aggressively Chased by Police through the Woods Yesterday,” Twitter, March 5, 2023, https://twitter.com/stopthemvp/status/1765035069633143090.
[xxvii] Ryan Fatica and Chris Schiano, “Behind the #StopCopCity Domestic Terrorism Warrants,” Unicorn Riot, March 21, 2023, https://unicornriot.ninja/2023/behind-the-stopcopcity-domestic-terrorism-warrants/; “Georgia House Bill 452 (2017-2018 Regular Session) - Enrolled Version,” May 8, 2017, https://legiscan.com/GA/text/HB452/id/1584927/Georgia-2017-HB452-Enrolled.pdf.
[xxviii] Timothy Pratt, “‘Alarming and Absurd’: Concern as ‘Cop City’ Activists Charged with Racketeering,” The Guardian, September 7, 2023, sec. US news, https://www.theguardian.com/us-news/2023/sep/07/atlanta-cop-city-racketeering-charges-protests.
[xxix] Kristal Dixon, “Georgia Bill Would Expand RICO Law to Include Littering, Other Misdemeanors,” Axios, January 24, 2024, https://www.axios.com/local/atlanta/2024/01/24/georgia-rico-law-changes.
[xxx] Charlotte Lawrence, Cyrus J. O’Brien, and Maritza Perez, “It’s Past Time to End the Federal Militarization of Police,” American Civil Liberties Union, May 12, 2021, https://www.aclu.org/news/civil-liberties/its-past-time-to-end-the-federal-militarization-of-police; Michael German, Rachel Levinson-Waldman, and Kaylana Mueller-Hsia, “Ending Fusion Center Abuses,” Brennan Center for Justice, April 20, 2022, https://www.brennancenter.org/our-work/policy-solutions/ending-fusion-center-abuses.
[xxxi] “Explainer: Alberta’s Controversial Critical Infrastructure Defence Act,” Canadian Civil Liberties Association, April 14, 2022, https://ccla.org/get-informed/talk-rights/explainer-albertas-controversial-critical-infrastructure-defence-act/; Heath Parkes-Hupton, “New Laws Pose $22,000 Fines, Two Years in Jail for Protests That Cause ‘Economic Chaos,’” ABC News, April 1, 2022, https://www.abc.net.au/news/2022-04-01/nsw-new-protest-laws-target-major-economic-disruption/100960746. These laws, similarly to fossil fuel anti-protest laws in U.S. states, are for trespassing upon—or simply obstructing—”critical infrastructure” (U.S. and Alberta) or “major facilities” (New South Wales), a term defined to include pipelines and other energy facilities.
[xxxii] “Belo Sun Mining Seeks to Criminalize Amazon Defenders,” Amazon Watch, February 1, 2024, https://amazonwatch.org/news/2024/0201-belo-sun-mining-seeks-to-criminalize-amazon-defenders; Daniel Haidar, “Lula urged to cancel Bolsonaro’s agreement with Canadian mining company for largest gold mine in the Amazon,” Repórter Brasil, February 26, 2024, https://reporterbrasil.org.br/2024/02/lula-urged-to-cancel-bolsonaros-agreement-with-canadian-mining-company-for-largest-gold-mine-in-the-amazon/.
[xxxiii] “Standing Firm: The Land and Environmental Defenders on the Frontlines of the Climate Crisis” (Global Witness, September 15, 2023), https:///en/campaigns/environmental-activists/standing-firm/.
[xxxiv] Damian Carrington and Matthew Taylor, “Revealed: The ‘Carbon Bombs’ Set to Trigger Catastrophic Climate Breakdown,” The Guardian, May 11, 2022, https://www.theguardian.com/environment/ng-interactive/2022/may/11/fossil-fuel-carbon-bombs-climate-breakdown-oil-gas.
[xxxv] Arnim Scheidel et al., “Environmental Conflicts and Defenders: A Global Overview,” Global Environmental Change 63 (July 2020): 102104, https://doi.org/10.1016/j.gloenvcha.2020.102104.
[xxxvi] Chang, Boehms, and Vargas, “Dollars vs. Democracy 2023: Inside the Fossil Fuel Industry’s Playboook to Suppress Protest and Dissent in the United States,” 57–58.
[xxxvii] “Litigation Challenging New Anti-Protest Laws” (ICNL, July 21, 2023), https://www.icnl.org/post/assessment-and-monitoring/litigation-challenging-new-anti-protest-laws; “Updates to the Anti-SLAPP Report Card,” Institute For Free Speech, accessed March 27, 2024, https://www.ifs.org/blog/updates-to-the-anti-slapp-report-card/.
[xxxviii] Randy Furst, “Judge Dismisses Charges against Activists Accused of Disrupting Enbridge Line 3,” Star Tribune, accessed March 27, 2024, https://www.startribune.com/judge-dismisses-charges-against-activists-accused-of-disrupting-enbridge-line-3/600305634/.