A Summers’ mirror

Writing of President Barack Obama’s recent climb-downs on an attack on Syria and on a nomination of Lawrence Summers, Perry Bacon, Jr., writes that “Obama seems to have decided he is not ‘the decider,’ the term George W. Bush used in articulating his role as president.” Though Bacon disagrees with Obama’s initial decisions on both Syria and the Summers nomination, this is a largely fawning piece. “Some have suggested these moves point to a weakened president, lacking the ability to sway members of Congress or the American public to support him or the boldness and gumption to simply charge ahead anyway.” Bacon argues that Obama listens and “at times is ready to toss aside his opinions, and that should be applauded.”^[1]

Bacon does not wonder who Obama listens to, or when. In Bacon’s view, Obama responded to strong opposition and “showed wisdom, not weakness, in conceding to his critics on these issues.” Bacon does not question how these decisions, decisions that even he acknowledges to be wrong, came to be adopted in the first place.^[2]

But this is a question, really, that has dogged Obama throughout his presidency. Controversy arose over his initial appointments, following his election in 2008, and when he chose Rick Warren, an evangelical preacher with a reputation for homophobia to offer a benediction at his first inauguration. I wrote at the time:

The most stigmatized group in the United States is not blacks or poor people. It is certainly not evangelists, who have dominated policymaking since the presidency of Jimmy Carter. Rather, it is the group included by the initials GLBT–gay, lesbian, bisexual, and transgender.

But it is the evangelists whom Obama invites to the debate rather than the queers. He takes queers for granted just as he does progressives; after all, queers and progressives have no other (major) candidate to vote for. He selects as regressive a team of advisors and cabinet members as we might expect from a Blue Dog Democrat and claims that he’s the one who is responsible for coming up with ideas.

Obama is supposed to be about change we can believe in. He surrounds himself with a widely-touted team of rivals. And drawing all this together, progressives are to envision Obama at the center, hearing all these arguments for the status quo, in some grand debate, perhaps a little less rules-oriented, but with Obama in his vast wisdom meticulously picking apart the arguments, leading everyone to a conclusion that each of these situations demands a new approach.

“Understand where the vision for change comes from, first and foremost,” [Obama] said. “It comes from me. That’s my job, to provide a vision in terms of where we are going and to make sure then that my team is implementing [that vision].”^[3]

Five years later, and in the first year of Obama’s second term, it might be premature to write an obituary for his presidency. But surely, historians will question Obama’s role in the National Security State, his decision-making on Syria, and his imagination that he has done a good job on the economy. For me, a clue appears in his response to Summers’ decision to withdraw from the running to be nominated to chair the Federal Reserve Bank: “Larry was a critical member of my team as we faced down the worst economic crisis since the Great Depression,” Obama said, “and it was in no small part because of his expertise, wisdom and leadership that we wrestled the economy back to growth and made the kind of progress we are seeing today.”^[4]

It’s more than fair to observe that Obama has been remarkably callous about the economy. The situation with unemployment remains awful; to the extent that the unemployment rate is dropping, it has done so largely as the unemployed have given up and ceased to be counted in Bureau of Labor Statistics methodology as being in the labor force (figures 1 and 2).^[5] Two years ago, I cited Obama’s repeated refrain about how every day, he and his team have been working to get people back to work.^[6] He said it so much that it seemed more like a mantra than an actual project, as if the claim that he was doing something about it would substitute for actual deeds.

In reality, Obama has thrown underwater homeowners and the unemployed under the bus. He and his administration have devoted their energies to rescuing Wall Street fat cats, while leaving everyone else to twist in the wind with widening inequality.^[7] But he apparently believes the economy is recovering well.

Certainly, nobody outside the Wall Street and Washington, D.C., bubbles seriously believes the economy is doing well. But those bubbles don’t account for Obama’s other appalling decisions—on Syria and on the National Security State.

We cannot know what Obama knew as he minimized the intrusions of the National Security State, the intrusions that shred any semblance of privacy people pretty much anywhere in the world, including in the United States, may have thought they had,^[8] whether as a constitutional right^[9] or as a human right.^[10] What we do know is that it wasn’t the truth. And just as with the economy, we have to wonder, first, why Obama thinks what he thinks, and second, why Obama thinks he can get away with saying things that simply are not true.

I have no way, really, to test my hypothesis. But recently, as I was hunting for something else in one of my old textbooks, I came across this:

Groupthink

Groupthink is a term that describes the deterioration of group effectiveness that results from in-group pressure.²⁶ Highly cohesive groups are at greater risk of succumbing to group think. Bennis, Parikh, and Lessem suggest that “perhaps the most damaging disease to a group’s health is over-conformity, always the result of group pressure.”²⁷

Symptoms of Groupthink.

Irving Janis, a professor at Yale University, developed the theory of groupthink after recognizing patterns in what he termed policy-making fiascoes. He suggests that groupthink was a significant factor in several major policy decisions, including the Bay of Pigs invasion of Cubas, the escalation of both the Korean and Vietnam wars, the attack on Pearl Harbor, and the Watergate burglary and cover-up.²⁸ Groupthink may also have contributed to the explosion of the space shuttle Challenger.²⁹ After analyzing many of these policy decisions, Janis identified eight symptions of group think. The table shown in Figure 7.5 illustrates the symptoms and expressions of groupthink.^[11]

FIGURE 7.5	Groupthink Symptoms	Expressions of Groupthink
Groupthink	Invulnerability: Is overly confident; willing to take big risks.	“We’re right. We’ve done this many times, and nothing’s gone wrong.”
	Rationalization: Makes excuses; discounts warnings.	“What does Lewis know? He’s been here only three weeks.”
	Morality: Ignores ethical and moral consequences.	“Sometimes the end justifies the means.”
	Stereotyping outsiders: Considers opposition too weak and stupid to make real trouble.	“Let’s not worry about the subcommittee—they can’t even get their own act together.”
	Self-Censorship: Doubts his or her own reservations; unwilling to disagree or dissent.	“I guess there’s no harm in going along with the group—I’m the only one who disagrees.”
	Pressure on Dissent: Pressures members to agree.	“Why are you trying to hold this up! You’ll ruin the project.”
	Illusion of Unanimity: Believes everyone agrees.	“Hearing no objections, the motion passes.”
	Mindguarding: Shields members from adverse information or opposition.	“Rhea wanted to come to this meeting, but I told her that wasn’t necessary.”
Table reproduces information in figure 7.5,[12] fair use.

The rows on rationalization, stereotyping outsiders, and pressure on dissent seem particularly applicable to the Obama administration and its attitudes towards anyone with a contrary opinion, seen almost as soon as some progressives started noticing they’d been had.^[13] The row on mindguarding seems applicable to Obama himself—how else could he possibly believe what he is saying. Of course, this generously assumes good faith, that is, that Obama really does believe what he says.

Whatever its other failings—and they are legion—I believe the Obama administration suffers from a severe case of groupthink. That’s unlikely to go away on its own. Which means the remaining three years of the Obama presidency are likely to be as bad—if not worse, and possibly much worse—than the first five.

Update, September 17, 2013: Since this post was originally published, I have added figures 1 and 2. In addition, at the time I originally published this post, I was uncertain how to handle the footnoting for “figure 7.5” reproduced as a table from that old textbook.^[14] I’ve since figured it out. This alters footnote numbering from the original.

1. ^[1]Perry Bacon, Jr., “Barack Obama: Not ‘the decider,’ but a president who listens,” Grio, September 16, 2013, http://thegrio.com/2013/09/16/barack-obama-not-the-decider-but-a-president-who-listens/↩
2. ^[2]Bacon, “Barack Obama.”↩
3. ^[3]David Benfell, “Arrogance in picking a preacher,” December 20, 2008, https://disunitedstates.org/?p=673↩
4. ^[4]Kevin G. Hall, “Summers drops bid to head the Fed,” McClatchy, September 15, 2013, http://www.mcclatchydc.com/2013/09/15/202212/under-fire-from-women-summers.html↩
5. ^[5]David Benfell, “Employment Calculations,” February 4, 2013, https://parts-unknown.org/wiki/index.php/Employment_calculations; Alejandro Reuss, “America Has a Triple-Decker Jobs Crisis,” Alternet, September 10, 2013, http://www.alternet.org/economy/america-has-triple-decker-jobs-crisis↩
6. ^[6]David Benfell, “Dickens redux,” August 3, 2011, https://disunitedstates.org/?p=4279↩
7. ^[7]Neil Barofsky, Bailout: An Inside Account of How Washington Abandoned Main Street While Rescuing Wall Street (New York: Free Press, 2012); David Benfell, “Dickens Redux,” August 3, 2011, https://disunitedstates.org/?p=4279; Silla Brush & Robert Schmidt, “How the Bank Lobby Loosened U.S. Reins on Derivatives,” Bloomberg, September 4, 2013, http://www.bloomberg.com/news/2013-09-04/how-the-bank-lobby-loosened-u-s-reins-on-derivatives.html; J. Andrew Felkerson, “Bail-out Bombshell: Fed ‘Emergency’ Bank Rescue Totaled $29 Trillion Over Three Years,” Alternet, December 15, 2011, http://www.alternet.org/story/153462/bail-out_bombshell%3A_fed_%22emergency%22_bank_rescue_totaled_%2429_trillion_over_three_years; Jacob Hacker and Paul Pierson, “What Krugman & Stiglitz Can Tell Us,” review of End This Depression Now!, by Paul Krugman, andThe Price of Inequality: How Today’s Divided Society Endangers Our Future, by Joseph E. Stiglitz, New York Review of Books, September 27, 2012,http://www.nybooks.com/articles/archives/2012/sep/27/what-krugman-stiglitz-can-tell-us/; Paul Krugman, “The Forgotten Millions,” New York Times, December 6, 2012,http://www.nytimes.com/2012/12/07/opinion/krugman-the-forgotten-millions.html; Paul Krugman, “Rich Man’s Recovery,” New York Times, September 12, 2013, http://www.nytimes.com/2013/09/13/opinion/krugman-rich-mans-recovery.html; Paul Krugman, “The Excel Depression,” New York Times, April 18, 2013, http://www.nytimes.com/2013/04/19/opinion/krugman-the-excel-depression.html; Paul Krugman, “The Big Shrug,” New York Times, June 9, 2013, http://www.nytimes.com/2013/06/10/opinion/krugman-the-big-shrug.html; Paul Krugman, “Defining Prsoperity Down,” New York Times, July 7, 2013,http://www.nytimes.com/2013/07/08/opinion/krugman-defining-prosperity-down.html; Paul Krugman and Robin Wells, “Getting Away With It,” review of The Escape Artists: How Obama’s Team Fumbled the Recovery, by Noam Scheiber, Pity the Billionaire: The Hard-Times Swindle and the Unlikely Comeback of the Right, by Thomas Frank, and The Age of Austerity: How Scarcity Will Remake American Politics, by Thomas Byrne Edsall, New York Review of Books, July 12, 2012, http://www.nybooks.com/articles/archives/2012/jul/12/getting-away-it/; Bob Ivry, Bradley Keoun and Phil Kuntz, “Secret Fed Loans Gave Banks $13 Billion Undisclosed to Congress,” Bloomberg, November 28, 2011, http://www.bloomberg.com/news/2011-11-28/secret-fed-loans-undisclosed-to-congress-gave-banks-13-billion-in-income.html; Gretchen Morgenson, “Questions From a Bailout Eyewitness,” New York Times, October 13, 2012, https://www.nytimes.com/2012/10/14/business/sheila-bairs-big-questions-about-bank-bailouts.html; Gretchen Morgenson, “One Safety Net That Needs To Shrink,” New York Times, November 3, 2012, http://www.nytimes.com/2012/11/04/business/one-safety-net-that-needs-to-shrink.html; Gretchen Morgenson and Louise Story, “In Financial Crisis, No Prosecutions of Top Figures,” New York Times, April 14, 2011, https://www.nytimes.com/2011/04/14/business/14prosecute.html; Michael Powell and Andrew Martin, “Foreclosure Aid Fell Short, and Is Fading,” New York Times, March 29, 2011, https://www.nytimes.com/2011/03/30/business/30foreclose.html; Yves Smith, “Quelle Surprise! San Francisco Assessor Finds Pervasive Fraud in Foreclosure Exam (and Paul Jackson Defends His Meal Tickets Yet Again),” Naked Capitalism, February 16, 2012, http://www.nakedcapitalism.com/2012/02/quelle-surprise-san-francisco-assessor-finds-pervasive-fraud-in-foreclosure-exam-and-paul-jackson-defends-his-meal-tickets-yet-again.html; Matt Taibbi, “Why Obama’s JOBS Act Couldn’t Suck Worse,” Rolling Stone, April 9, 2012, http://www.rollingstone.com/politics/blogs/taibblog/why-obamas-jobs-act-couldnt-suck-worse-20120409; Jim Tankersley, “As rich gain optimism, lawmakers lose economic urgency,” Washington Post, May 20, 2013,http://www.washingtonpost.com/business/economy/as-rich-gain-optimism-lawmakers-lose-economic-urgency/2013/05/20/0e4104d2-bf09-11e2-9b09-1638acc3942e_story.html; Matthew Yglesias, “Statistical Discrimination Against the Long-Term Unemployed,” Slate, April 23, 2013,http://www.slate.com/blogs/moneybox/2013/04/23/long_term_unemployed_face_ferocious_statistical_discrimination.html; Matthew Yglesias, “Amy Klobuchar Asks Bernanke a Great Question and the Fed Chairman Has No Good Answer,” Slate, May 22, 2013, http://www.slate.com/blogs/moneybox/2013/05/22/klobuchar_asks_the_question_on_the_federal_reserve_and_the_dual_mandate.html↩
8. ^[8]James Ball and Spencer Ackerman, “NSA loophole allows warrantless search for US citizens’ emails and phone calls,” Guardian, August 9, 2013, http://www.theguardian.com/world/2013/aug/09/nsa-loophole-warrantless-searches-email-calls; James Ball, Julian Borger and Glenn Greenwald, “US and UK spy agencies defeat privacy and security on the internet,” Guardian, September 5, 2013, http://www.theguardian.com/world/2013/sep/05/nsa-gchq-encryption-codes-security; James Bamford, “The NSA Is Building the Country’s Biggest Spy Center (Watch What You Say),” Wired, March 15, 2012, http://www.wired.com/threatlevel/2012/03/ff_nsadatacenter/; James Bamford, “They Know Much More Than You Think,” New York Review of Books, August 15, 2013,http://www.nybooks.com/articles/archives/2013/aug/15/nsa-they-know-much-more-you-think/; Dashiell Bennett, “Obama Administration Defends Its Right to Take All Your Phone Records,” Atlantic Wire, June 6, 2013, http://www.theatlanticwire.com/politics/2013/06/obama-administration-verizon-phone-records/65954/; Max Blumenthal, “Obama and His Allies Say the Govt Doesn’t Listen to Your Phone Calls — But the FBI Begs to Differ,” Alternet, June 16, 2013, http://www.alternet.org/news-amp-politics/obama-and-his-allies-say-govt-doesnt-listen-your-phone-calls-fbi-begs-differ; Alexander Bolton, “Senators: NSA phone sweeping has been going on since 2007,” Hill, June 6, 2013, http://thehill.com/homenews/news/303891-senators-nsa-phone-sweeping-has-been-going-on-since-2007; Stephen Braun, Anne Flaherty, Jack Gillum, and Matt Apuzzo, “Secret to Prism program: Even bigger data seizure,” Associated Press, June 15, 2013, http://bigstory.ap.org/article/secret-prism-success-even-bigger-data-seizure; Philip Bump, “The NSA Admits It Analyzes More People’s Data Than Previously Revealed,” Atlantic Wire, July 17, 2013,http://www.theatlanticwire.com/politics/2013/07/nsa-admits-it-analyzes-more-peoples-data-previously-revealed/67287/; Democracy Now!, “Exposed: Inside the NSA’s Largest and Most Expansive Secret Domestic Spy Center in Bluffdale, Utah,” March 21, 2012, http://www.democracynow.org/2012/3/21/exposed_inside_the_nsas_largest_and; Democracy Now!, “National Security Agency Whistleblower William Binney on Growing State Surveillance,” April 20, 2012, http://www.democracynow.org/2012/4/20/exclusive_national_security_agency_whistleblower_william; Democracy Now!, “Whistleblower: The NSA Is Lying–U.S. Government Has Copies of Most of Your Emails,” April 20, 2012, http://www.democracynow.org/2012/4/20/whistleblower_the_nsa_is_lying_us; Democracy Now!, “NSA Whistleblowers: “All U.S. Citizens” Targeted by Surveillance Program, Not Just Verizon Customers,” June 6, 2013, http://www.democracynow.org/2013/6/6/nsa_whistleblowers_all_us_citizens_targeted; Democracy Now!, “Glenn Greenwald on How NSA Leaker Edward Snowden Helped Expose a ‘Massive Surveillance Apparatus’,” June 10, 2013, http://www.democracynow.org/2013/6/10/glenn_greenwald_on_how_nsa_leaker; Democracy Now!, “‘On a Slippery Slope to a Totalitarian State’: NSA Whistleblower Rejects Gov’t Defense of Spying,” June 10, 2013, http://www.democracynow.org/2013/6/10/on_a_slippery_slope_to_a; Democracy Now!, “‘You’re Being Watched’: Edward Snowden Emerges as Source Behind Explosive Revelations of NSA Spying,” June 10, 2013, http://www.democracynow.org/2013/6/10/youre_being_watched_edward_snowden_emerges; Democracy Now!, “More Intrusive Than Eavesdropping? NSA Collection of Metadata Hands Gov’t Sweeping Personal Info,” June 12, 2013, http://www.democracynow.org/2013/6/12/more_intrusive_than_eavesdropping_nsa_collection; “Edward Snowden Q&A: Dick Cheney traitor charge is ‘the highest honor’,” Guardian, June 17, 2013, http://www.guardian.co.uk/world/2013/jun/17/edward-snowden-nsa-files-whistleblower; “Edward Snowden Interview: The NSA and Its Willing Helpers,” by Jacob Appelbaum and Laura Poitras, Spiegel, July 8, 2013,http://www.spiegel.de/international/world/interview-with-whistleblower-edward-snowden-on-global-spying-a-910006.html; Peter Eisler and Susan Page, “3 NSA veterans speak out on whistle-blower: We told you so,” USA Today, June 16, 2013, http://www.usatoday.com/story/news/politics/2013/06/16/snowden-whistleblower-nsa-officials-roundtable/2428809/; Conor Friedersdorf, “3 Former NSA Employees Praise Edward Snowden, Corroborate Key Claims,” Atlantic, June 18, 2013, http://www.theatlantic.com/politics/archive/2013/06/3-former-nsa-employees-praise-edward-snowden-corroborate-key-claims/276964/; 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Siobhan Gorman and Jennifer Valentino-DeVries, “New Details Show Broader NSA Surveillance Reach,” Wall Street Journal, August 20, 2013, http://online.wsj.com/article/SB10001424127887324108204579022874091732470.html; Glenn Greenwald, “Are all telephone calls recorded and accessible to the US government?” Guardian, March 4, 2013, http://www.guardian.co.uk/commentisfree/2013/may/04/telephone-calls-recorded-fbi-boston; Glenn Greenwald and Spencer Ackerman, “NSA collected US email records in bulk for more than two years under Obama,” Guardian, June 27, 2013, http://www.guardian.co.uk/world/2013/jun/27/nsa-data-mining-authorised-obama; Glenn Greenwald, Laura Poitras and Ewen MacAskill, “Edward Snowden: US surveillance ‘not something I’m willing to live under’,”Guardian, July 8, 2013, http://www.guardian.co.uk/world/2013/jul/08/edward-snowden-surveillance-excess-interview; Glenn Greenwald and Ewen MacAskill, “NSA Prism program taps in to user data of Apple, Google and others,” Guardian, June 6, 2013, http://www.guardian.co.uk/world/2013/jun/06/us-tech-giants-nsa-data; 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Niels Lesniewski, “Durbin Predicted NSA, Verizon Controversy in 2009,” Congressional Quarterly Roll Call, June 6, 2013, http://blogs.rollcall.com/wgdb/durbin-predicted-nsa-verizon-controversy-in-2009/; Eric Lichtblau, “In Secret, Court Vastly Broadens Powers of N.S.A.,” New York Times, July 6, 2013, http://www.nytimes.com/2013/07/07/us/in-secret-court-vastly-broadens-powers-of-nsa.html; Ewen MacAskill, Julian Borger, Nick Hopkins, Nick Davies and James Ball, “GCHQ taps fibre-optic cables for secret access to world’s communications,” Guardian, June 21, 2013, http://www.guardian.co.uk/uk/2013/jun/21/gchq-cables-secret-world-communications-nsa; Declan McCullagh, “DOJ: We don’t need warrants for e-mail, Facebook chats,” CNET News, May 8, 2013, http://news.cnet.com/8301-13578_3-57583395-38/doj-we-dont-need-warrants-for-e-mail-facebook-chats/; Declan McCullagh, “NSA spying flap extends to contents of U.S. phone calls,” CNet News, June 16, 2013, http://news.cnet.com/8301-13578_3-57589495-38/nsa-admits-listening-to-u.s-phone-calls-without-warrants/; Declan McCullagh, “Feds tell Web firms to turn over user account passwords,” CNet, July 25, 2013, http://news.cnet.com/8301-13578_3-57595529-38/feds-tell-web-firms-to-turn-over-user-account-passwords/; Declan McCullagh, “FBI pressures Internet providers to install surveillance software,” CNet, August 2, 2013, http://news.cnet.com/8301-13578_3-57596791-38/fbi-pressures-internet-providers-to-install-surveillance-software/; Claire Cain Miller, “Tech Companies Concede to Surveillance Program,” New York Times, June 7, 2013, http://www.nytimes.com/2013/06/08/technology/tech-companies-bristling-concede-to-government-surveillance-efforts.html; Ellen Nakashima, “Obama administration had restrictions on NSA reversed in 2011,” Washington Post, September 7, 2013,http://www.washingtonpost.com/world/national-security/obama-administration-had-restrictions-on-nsa-reversed-in-2011/2013/09/07/c26ef658-0fe5-11e3-85b6-d27422650fd5_story.html; New York Times, “Unlocking Private Communications,” September 5, 2013, http://www.nytimes.com/interactive/2013/09/05/us/unlocking-private-communications.html; Ron Nixon, “U.S. Postal Service Logging All Mail for Law Enforcement,” New York Times, July 3, 2013, http://www.nytimes.com/2013/07/04/us/monitoring-of-snail-mail.html; Alex Pareene, “The government has all your info,” Salon, June 6, 2013, http://www.salon.com/2013/06/06/the_nsa_has_all_your_info/; Nicole Perlroth, Jeff Larson, and Scott Shane, “N.S.A. Foils Much Internet Encryption,” New York Times, September 5, 2013,http://www.nytimes.com/2013/09/06/us/nsa-foils-much-internet-encryption.html; Laura Poitras, Marcel Rosenbach, and Holger Stark, “‘Follow the Money’: NSA Monitors Financial World,” Spiegel, September 16, 2013,http://www.spiegel.de/international/world/how-the-nsa-spies-on-international-bank-transactions-a-922430.html; Bill Quigley, “Twenty Examples of the Obama Administration’s Assault on Domestic Civil Liberties,” Truthout, December 7, 2011, http://truth-out.org/news/item/5454:twenty-examples-of-the-obama-administrations-assault-on-domestic-civil-liberties; Dan Roberts and Spencer Ackerman, “US intelligence outlines checks it says validate surveillance,” Guardian, June 15, 2013, http://www.guardian.co.uk/world/2013/jun/16/nsa-the-nsa-files; Marcel Rosenbach, Laura Poitras and Holger Stark, “How the NSA Accesses Smartphone Data,” Spiegel, September 9, 2013, http://www.spiegel.de/international/world/how-the-nsa-spies-on-smartphones-including-the-blackberry-a-921161.html; Steven Rosenfeld, “How Obama Became a Civil Libertarian’s Nightmare,” Alternet, April 18, 2012, http://www.alternet.org/story/155045/how_obama_became_a_civil_libertarian%27s_nightmare; Charlie Savage, “N.S.A. Said to Search Content of Messages to and From U.S.,” New York Times, August 7, 2013,http://www.nytimes.com/2013/08/08/us/broader-sifting-of-data-abroad-is-seen-by-nsa.html; Charlie Savage and Edward Wyatt, “U.S. Is Secretly Collecting Records of Verizon Calls,” New York Times, June 5, 2013, http://www.nytimes.com/2013/06/06/us/us-secretly-collecting-logs-of-business-calls.html; Charlie Savage, Edward Wyatt, Peter Baker, and Michael D. Shear, “Obama Calls Surveillance Programs Legal and Limited,” New York Times, June 7, 2013, http://www.nytimes.com/2013/06/08/us/national-security-agency-surveillance.html; Bruce Schneier, “What We Don’t Know About Spying on Citizens: Scarier Than What We Know,” Atlantic< June 6, 2013, http://www.theatlantic.com/politics/archive/2013/06/whats-scarier-than-the-verizon-leak/276607/; Bruce Schneier, “New NSA Leak Shows MITM Attacks Against Major Internet Services,” Schneier on Security, September 13, 2013,https://www.schneier.com/blog/archives/2013/09/new_nsa_leak_sh.html; Scott Shane, “Court Upbraided N.S.A. on Its Use of Call-Log Data,” New York Times, September 10, 2013, http://www.nytimes.com/2013/09/11/us/court-upbraided-nsa-on-its-use-of-call-log-data.html; Scott Shane and Nicole Perlroth, “Legislation Seeks to Bar N.S.A. Tactic in Encryption,” New York Times, September 6, 2013, http://www.nytimes.com/2013/09/07/us/politics/legislation-seeks-to-bar-nsa-tactic-in-encryption.html; Falguni A. Sheth, “Q&A with Glenn Greenwald: Americans’ reaction ‘surprising and gratifying’,” Salon, July 13, 2013, http://www.salon.com/2013/07/13/qa_with_glenn_greenwald_americans_reaction_surprising_and_gratifying/; David Sirota, “What if the president lied to us?” Salon, August 16, 2013,http://www.salon.com/2013/08/16/what_if_the_president_lied_to_us/; Spiegel, “NSA Can Spy on Smart Phone Data,” Sptember 7, 2013, http://www.spiegel.de/international/world/privacy-scandal-nsa-can-spy-on-smart-phone-data-a-920971.html; Christian Stöcker, “The Power of Britain’s Data Vacuum,” Spiegel, July 7, 2013, http://www.spiegel.de/international/world/snowden-reveals-how-gchq-in-britain-soaks-up-mass-internet-data-a-909852.html; WashingtonsBlog, “Americans Are The Most Spied On People In World History,” December 5, 2012, http://www.washingtonsblog.com/2012/12/americans-the-most-spied-on-people-in-world-history.html; Shaun Waterman, “Whistleblower’s NSA warning: ‘Just the tip of the iceberg’,” Washington Times, June 7, 2013, http://www.washingtontimes.com/news/2013/jun/7/the-national-security-agencys-collection-of-phone-/; Rachel Weiner, “Mark Udall: I tried to expose NSA program,” Washington Post, June 6, 2013, http://www.washingtonpost.com/blogs/post-politics/post/mark-udall-i-tried-to-expose-nsa-spying/2013/06/06/6e567a52-cee8-11e2-8573-3baeea6a2647_blog.html; Pete Yost, “NSA Spying Under Fire: ‘You’ve Got a Problem’,” Military.com, July 18, 2013, http://m.military.com/daily-news/2013/07/18/nsa-spying-under-fire-youve-got-a-problem.html↩
9. ^[9]Griswold v. Connecticut, 381 U.S. 479 (1965).↩
10. ^[10]International Covenant on Civil and Political Rights, United Nations, December 16, 1966, U.N.T.S. 171.↩
11. ^[11]Isa N. Engleberg and Dianna R. Wynn, Working in Groups: Communication Principles and Strategies, 3rd ed. (Boston: Houghton Mifflin, 2003), 160-161.↩
12. ^[12]Isa N. Engleberg and Dianna R. Wynn, Working in Groups: Communication Principles and Strategies, 3rd ed. (Boston: Houghton Mifflin, 2003), 161.↩
13. ^[13]Blue Texan, "Stop Whining, Liberals!" Firedoglake, September 27, 2010. http://firedoglake.com/2010/09/27/late-night-stop-whining-liberals/; Greg Sargent, "Liberal blogger directly confronts David Axelrod, accuses White House of 'hippie punching'," Washington Post, September 23, 2010. http://voices.washingtonpost.com/plum-line/2010/09/liberal_blogger_directly_confr.html; Sam Youngman, "White House unloads anger over criticism from 'professional left’," Hill, August 10, 2010. http://thehill.com/homenews/administration/113431-white-house-unloads-on-professional-left↩
14. ^[14]Isa N. Engleberg and Dianna R. Wynn, Working in Groups: Communication Principles and Strategies, 3rd ed. (Boston: Houghton Mifflin, 2003), 161.↩