Lennon's Loss

I'll admit that I'm a sappy, emotional guy. Once in a while, I'll settle into work, only to stumble across something on the web that hits me like an emotional ton of bricks.

This short New York Times piece on the 30th anniversary of John Lennon's death is not memorable for its contents — it's memorable for the hundreds of reader comments that follow the piece. It's page after page of short, detailed remembrances, each intimate and sketching a scene of shared yet private grief at the loss of this light.

I was 4 in 1980, so my grief at Lennon's loss wouldn't come until later.

Dried flowers from the funeral of Abraham Lincoln.

Ford's Theatre National Historic Site, Washington, D.C.

Religious Scratchiti

If you’ve been on New York City’s subways recently, you probably noticed the absence of spray-paint graffiti, long a symbol of urban decay though with its defenders in the art community. New York authorities have managed to defeat subway graffiti by using graffiti-resistant materials on subway cars. A new form of graffiti has emerged in its place: scratchiti, graffiti formed by scratching marks into glass.

This afternoon I observed some unusual scratchiti on the R train. It appears to be a Hebrew abbreviation. The first (right) letter is Bet. The second letter is He. It is an abbreviation for the phrase Baruch HaShem, which translates to “Blessed be God.”

Among some Orthodox Jews, it is customary to write this abbreviation in the upper right hand corner of letters. What it’s doing as subway scratchiti, however, is a mystery. Perhaps the scratchitist was trying to bless the train?

The Russians Get Fyodor Dostoevsky, We Get Pat Robertson

Historians have long suspected that Fyodor Dostoevsky, a Russian novelist of immense talent, had temporal lobe epilepsy. This condition – which also appears to have afflicted Lewis Carroll, Edgar Allan Poe, Gustave Flaubert, Philip K. Dick, & Sylvia Plath – can cause the individual to feel a euphoric connection with the divine, to experience an ecstatic array of visual images, and it may be implicated by some people who report UFO or other paranormal experiences.

I wonder if Pat Robertson has something like temporal lobe epilepsy.

You see, Pat's a wonder to me. I'm astonished that there is an individual who can time and again intrude upon our national consciousness, say something crazy, and then retreat back to his relative obscurity only to emerge later in the year. Here's like a hibernating bear of nuttiness. For a chronicle of Pat's previous predictions, threats, and promises, click here.

Of late, God's been talking to Pat. What's He/She/It been saying, you ask? Well, a couple things.

First, God told him the outcome of the upcoming U.S. Presidential election. Sadly, Pat's not going to tell us who the victor shall be, but if he is at all like Biff in Back to the Future Part II, we'd expect Pat to increase his already massive wealth by betting on the election.

Second, God has informed Robertson that China is going to by-and-large convert to Christianity. Since God didn't provide a timeline to Robertson, we'll just have to wonder when the miraculous mass conversion of China will occur. Tomorrow? How about 2010? Tell us, Pat. Please.

God told me you should tell us.

Suing God: Jurisdictional Purgatory? (Part II)

God has apparently answered the complaint and is – you guessed it – disputing jurisdiction.

The manifestation of the divine legal writ out of the ether brings new meaning to the phrase special appearance.

Earlier: Suing God: Jurisdictional Purgatory?

Suing God: Jurisdictional Purgatory?

To make a point about frivolous lawsuits, Nebraska state senator Ernie Chambers is suing God.

Although such a case might have political or social merits, my first thought was that a cheeky court willing to hear Chambers would come to the same conclusion as the court in Gerald Mayo v. Satan and His Staff, where a Pennsylvania court found that it lacked jurisdiction over Satan (who was being sued), as the defendant was "a foreign prince" probably beyond that court's jurisdictional reach.

It occurs to me, however, that suing God might present a different set of jurisdictional issues than suing Satan. I'll merely get the conversation started and hope that you all can expand it via the comments:

• Foreseeability: Here the omniknowledgeability (yes, I shall create that word) of The Almighty works against He/She/It if He/She/It wants to avoid lawsuit in Nebraska. Even if God is a non-resident of Nebraska (naturally, you'd need to test for domicile to determine its status), the ability of God to foresee that its actions would cause in-state injury could subject it to Nebraska's jurisdiction under Calder v. Jones, 465 U.S. 783 (1984). Of course, Chambers's complaint would still need to arise out of these Nebraska-directed-Almighty actions, as Calder concerns specific personal jurisdiction. To satisfy the broader general personal jurisdiction standard, God's actions would need to satisfy the continuous and systematic contacts that SCOTUS reiterated in Helicopteros Nacionales de Colombia v. Hall, 466 U.S. 408 (1984).


• One Person, All Persons? If we're talking about a Triune God, it's unclear to me whether getting jurisdiction of One Person is sufficient, or whether jurisdiction of all Three Persons must be obtained. Since tag jurisdiction – transient jurisdiction where notice is served on a party while that party is physically in the jurisdiction (e.g. visiting friends) – does not apply to corporations, an analogous jurisdictional limit might apply to a deity with multiple instantiations. See Burnham v. Superior Court, 495 U.S. 604, 609 n.1 (1990).


• Book of Mormon Connection? Although various Mormon scholars believe that the Book of Mormon describes God as physically present in the Great Lakes region several hundred years ago, it is unclear if God was physically present in Nebraska at this time, or whether these corporeal contacts should even factor in to determining jurisdiction several hundred years later.


• Other jurisdictional possibilities are out there, – Agency Law, Foreign Relations, etc. – so please feel free to add them in the comments section. Also note that Australian cinema has already addressed this question.

Many thanks to Dan & Colin for many of the above points. Where the points sound inspired, that's them. Where they sound insipid, that's me.

Update (9/21/07): God has answered the complaint and is disputing jurisdiction.

2008 GOP Candidates: U.S. Founded as Christian Nation.1797 Congress: No It Wasn't.

(Crossposted from the American Constitution Society :: Columbia Law School)

In Conroy v. Aniskoff, 507 U.S. 511, 520 (1993), Antonin Scalia includes a comment that he repeated here at Columbia Law School in 2006 — that the use of legislative history to bolster one's own position is "the equivalent of entering a crowded cocktail party and looking over the heads of the guests for one's friends." As much as I agree with Scalia here, I find it heartening to stumble across this bit of congressionally approved language from the 5^th Congress:

Treaty of Peace and Friendship, signed at Tripoli November 4, 1796 (3 Ramada I, A. H. 1211), and at Algiers January 3, 1797 (4 Rajab, A. H. 1211). Original in Arabic. Submitted to the Senate May 29, 1797. (Message of May 26, 1797.) Resolution of advice and consent June 7, 1797. Ratified by the United States June 10, 1797. As to the ratification generally, see the notes. Proclaimed Jane 10, 1797.

ARTICLE 11

As the government of the United States of America is not in any sense founded on the Christian Religion,-as it has in itself no character of enmity against the laws, religion or tranquility of Musselmen,-and as the said States never have entered into any war or act of hostility against any Mehomitan nation, it is declared by the parties that no pretext arising from religious opinions shall ever produce an interruption of the harmony existing between the two countries.

What Passes for Truth is Stranger than Fiction

For some folks, Wikipedia (the online resource deceiving college students everywhere) leaves something to be desired. The creators of Conservapedia created their site as "a much-needed alternative to Wikipedia, which is increasingly anti-Christian and anti-American."

This is not a parody site. Parody is entirely unnecessary. I submit for your approval the Conservapedia's entry for "unicorn."

As an aid to future historians, looking to understand the odd things that "conservative" came to represent during the 00's, here's "unicorn" as it stood on the morning of 2/24/07:


"Great Job on the Unicorn page!" Conservapedia contributor PhilipB writes to Rich P, the primary author of this scholarly contribution. Great job indeed.

Hat tip to Sadly, No!

The Last Will Be First, The First Will Be Last, and This Supersedes Any Prior Agreement or Understanding

In some traditions, the law and religion are cut from the same cloth. Although few may agree with me when I say that law has become its own type of religion – in the all-is-religion view that similarly permits baseball, politics, and Star Trek to also serve as religion to their followers/adherents – the kinship of law and religion is most amusing when it rears its head in unlikely places.

This, from a model acquisition agreement in the back of Gilson & Black's The Law and Finance of Corporate Acquisitions:

XVII. Miscellaneous
. . .
B. The singular shall include the plural and the plural shall include the singular; any gender shall include all other genders—all as the meaning and context of this Agreement shall require.

[Ch/H]a[n/nn]u[k/kk][a/ah]

Sometime reader of this blog and fellow Columbia Law student CSK has conducted a bit of a holiday investigation:

Andy,

As we approach the holiday season, I thought I'd investigate the various spelling of the Jewish holiday. I have found four common binary variations: Ch/H, n/nn, k/kk, and a/ah. The following is a list of the sixteen permutations, in order of the number of results from a Google search of each permutation.

Perhaps readers of your blog would appreciate this analysis?

Hanukkah — 12,100,000
Chanukah — 3,400,000
Hanukah — 1,010,000
Hannukah — 790,000
Chanuka — 545,000
Hanuka — 518,000
Channukah — 437,000
Chanukkah — 315,000
Chanukka — 301,000
Hanukka — 107,000
Hannuka — 62,500
Hannukkah — 44,200
Channuka — 18,800
Channukka — 1,750
Hannukka — 821
Channukkah — 741

Note that Microsoft Word reports that all but the top three spellings are incorrect.

CSK

I suspect that the inclusion of all these terms on my blog will change the context-sensitive Google Ads on this page through the end of the year.

Update (12/06/06): CSK's roommate ASL weighs in:

Working hard, aren't you?

The two variables about which I feel most strongly are the doubled consonants. The correct answer: one N, two K's. In proper Hebrew pronunciation, the kaf is doubled because it contains a dagesh chazak. In other words, the word would be broken into syllables as ha-nuk-kah rather than ha-nu-kah. (Several other Hebrew loan words are spelled with doubled consonants for the same reason - e.g. sabbath, hallelujah.) Granted, since most people don't pronounce dagesh chazak properly any more, I suppose it's reasonable to write only one K. The thing that's definitely wrong, though, is two N's. I'd guess that those spellings come largely as a result of people remembering that there's a doubled consonant but getting the wrong one.

As to the H vs. CH, question, obviously H with a dot underneath is the most ideal option, but that's hard to do on most word processors. I tend to use H here, but I admit that I sometimes use CH for het in some other contexts. If there's no option of having a dot, I'd say the CH is the best bet. Another spelling that occurs 1,290 times on Google is Khanuka (and variants), but I think it would be better to reserve KH for khaf and CH or H-dot (or h-bar!) for het. That distinction has been lost in Ashkenazi and modern Israeli Hebrew, but I'm pretentious that way. Another neat option is what Bryan/Aviel and other Sephardim do: Januk(k)a(h) (along with Pesaj).

As to the final H, it seems at first glance that the Hebrew spelling (with a hei) would mandate the H. However, a deeper analysis of Hebrew linguistics actually offers a rather compelling argument not to include the H. The details are too complicated to explain here, though.

When It Says Religious Test, It Doesn't Mean Test Like the S.A.T.

(Crossposted from the American Constitution Society :: Columbia Law School)

The American Family Association – worried that newly-elected Representative Keith Ellison (D-MN), who happens to be Muslim, will be sworn in with his hand on the Koran (instead of the Christian Bible) – is urging its members to do the following:

1. Send an email asking your U.S. Representative and Senators to pass a law making the Bible the book used in the swearing-in ceremony of Representatives and Senators.


2. Forward this email to your friends and family today!

Never mind that Representatives don't place their hands on anything when they're sworn in en masse. How the AFA-proposed law wouldn't violate Article VI, Section 3 is beyond me:

The Senators and Representatives before mentioned, and the members of the several state legislatures, and all executive and judicial officers, both of the United States and of the several states, shall be bound by oath or affirmation, to support this Constitution; but no religious test shall ever be required as a qualification to any office or public trust under the United States. (emphasis added)

Too many more oversights like this and I'm going to stop turning to the American Family Association for my constitutional theory.

Failed Amendments We Have Known & Loved

(Crossposted from the American Constitution Society :: Columbia Law School)

Barring an unexpected Lame Duck attempt to amend the U.S. Constitution, Democratic control of Congress will probably result in a temporary moratorium on proposed amendments to the Constitution that would ban gay marriage or ban burning Old Glory.

Of course, the G.O.P. does not have a monopoly on converting a Congressional majority into failed attempts to amend the Constitution. During the next 2 years of their pending majority, if the Democrats need to find examples of entertaining failed attempts to amend the U.S. Constitution, history provides some real doozies.

In this post, we'll explore three prominent categories of failed Constitution amendments.

• Zombie Amendments:
  These Amendments will not die.
• Let's Remake America Amendments:
  Amendments that would dramatically change our country.
• No Way, José Amendments:
  These are not going in the Constitution.
  

Zombie Amendments:
Approved, Not Ratified, No Expiration Deadline

Starting in the early 20^th century, Congress began placing deadlines on the amendments it sent to the states for ratification. Typically, the states were given seven years to ratify an amendment. After the passage of the deadline, the proposed amendment would expire and Congress would need to start the process all over again to raise the issue. (In the past 50 years, two amendments expired after Congressional approval: the 1972 Equal Rights Amendment & the 1978 D.C. Voting Rights Amendment)

However, absent explicit sunset provisions, approved yet unratified amendments do not expire.¹ Instead, they linger eternally, pending ratification. As shown with the 27^th Amendment, an amendment which floated around for 200 years before finally being ratified in the 1990's, each of these amendments has the potential of becoming law.

Congressional Apportionment Amendment: This proposed amendment was the first of the original twelve amendments proposed to Congress (The original 2^nd Amendment eventually became the 27^th Amendment mentioned above). If passed, the amendment would have restricted the original size of the House of Representatives to 100 representatives, with later enlargements to be determined by Congress. From 1789 to 1792, 11 states ratified this amendment, leaving it two states short of ratification.

Titles of Nobility Amendment: Proposed in 1810, this amendment would strip U.S. citizenship from any citizen accepting, claiming, retaining, or receiving a foreign title of nobility without the consent of Congress.

Believed by some [See here and here. For a rebuttal, see here. (Apply salt liberally to the arguments on these web pages.)] to have been ratified and then supressed by a conspiracy of lawyers (who – so the theory goes – would lose their citizenship via their esquire title), this amendment was approved by 12 states, just one shy of full ratification. Since, at the time, it came within one house of the South Carolina legislature of being ratified, some 19^th century printings of the Constitution erroneously include it as the 13^th Amendment.²

Pro-Slavery Amendment: A last-ditch effort to avoid a civil war, this amendment – approved by the House and Senate on Februrary 28 & March 2, 1861, respectively – stated simply:

No amendment shall be made to the Constitution which will authorize or give to Congress the power to abolish or interfere, within any State, with the domestic institutions thereof, including that of persons held to labor or service by the laws of said State.

Apart from its subject matter, the language of this amendment raises an important issue in U.S. Constitutional theory: Can a Constitutional amendment prohibit a later amendment through an entrenched clause?

Although this amendment was ultimately ratified by Ohio and Maryland, neither legislature ratified it before the start of Civil War hostilities with the Battle of Fort Sumter on April 12, 1861.

Child Labor Amendment: Proposed in 1924 and ratified by 28 states, this still-pending amendment requires the approval of 10 more states in order to restrict to the federal government all power to regulate labor of persons under 18 years old.

This amendment is a direct reaction to the Child Labor Tax Case,³ which found Congress had overstepped the boundaries of the 10^th Amendment with the scope of the taxes it placed on factories employing child labor.

Let's Remake America Amendments:
Ambitious Attempts to Change this Country

Had they been ratified, these proposed amendments would dramatically change the way our country works.

• 21^st Amendment Redux: Occasionally, lawmakers propose repealing previous Amendments. In 2005, now House majority leader Steny Hoyer proposed repealing the 22^nd Amendment, which limits the President to two terms. In 2004, Senator Zell Miller proposed the repeal of the 17^th Amendment, which allows for democratic election of the Senate.
  


• International Impediments: The Ludlow Amendment, proposed in 1938, would require a national referendum to declare war except in cases of direct attack. Prior to SCOTUS's holding in Reid v. Covert,⁴ which held that the Constitution was supreme over any treaty, the Bricker Amendment proposed to limit the scope of the treaty power.
  


• First Amendment, Schmirst Amendment: Time and again, various people have decided that the Constitution lacks the appropriate shout-outs to the deity of their preference. From the 1860's through the 1950's, numerous proposals to exclaim our country's obedience to the Christian God were considered by Congress. In 2003, Frank Lucas (R-OK) introduced a house bill to preserve the Red-Scare-Era "under God" in the Pledge of Allegiance. In 2005, Representative Ernest Istook (also R-OK) proposed an amendment to explictly endorse school prayer.

No Way, José Amendments:
That's Just Crazy Talk

These proposed amendments were going exactly nowhere, but that's why we like 'em.

• Focus on the, er... Family: On March 31, 2003, former Representative and all-around class act Mark Foley proposed an amendment to remove U.S. citizenship from the children of illegal immigrants. (Insert Mark Foley joke here.)
  


• Cross of Gold, Revisited: Representative Ron Paul (who, awesomely, supports the Gold Standard) proposed the following amendment on January 26, 2005:

  H. J. RES. 14 — Proposing an amendment to the Constitution of the United States relative to abolishing personal income, estate, and gift taxes and prohibiting the United States Government from engaging in business in competition with its citizens.

  Yeah... Good luck with that one, Mr. Paul.
  


• A Big Day for Jesse Jackson, Jr.: Never one to bite off more than he could chew, Representative Jesse Jackson, Jr. introduced a large number of amendments on March 2, 2005. Combined, these amendments would grant:
  1. The right to U.S. citizens to health care of equal high quality.
  2. The right to U.S. citizens to a public education of equal high quality.
  3. The right to vote.
  4. The right to a clean, safe, and sustainable environment.
  5. The right to decent, safe, sanitary, and affordable housing.
  6. Equality of rights and reproductive rights (bolstering Roe v. Wade).
  7. The right to full employment and balanced growth.
  8. Taxing the people of the United States progressively.
  
  

---

¹ Coleman v. Miller, 307 U.S. 433, 454 (1939) (Finding that all amendments are considered pending before the states indefinitely unless Congress establishes a deadline within which the states must act.)

² In Campion v. Towns, 2005 WL 2160115 at *1 (D. Ariz. 2005), a tax protester produced an 19^th century archival copy of the Constitution incorrectly listing the Titles of Nobility Amendment as the 13^th Amendment. Needless to say, the argument based on the existence of this document did not go very far with the Court.

³ Bailey v. Drexel Furniture Co., 259 U.S. 20 (1922)

⁴ 354 U.S. 1 (1957)

I Hear the Chicken Dance Is Next

I was unaware that Pope Benedict XVI had the authority to abolish limbo, but apparently he does.

Without limbo, how will the remarkably flexible show off in public?

If You Take Her to Be Your Lawfully Wedded Wife, Say "Hoo-Rah"

This weekend, Steph & I attended a lovely wedding ceremony on a military base. You see, the bride spent her childhood as a military brat, traveling from base to base. Ultimately, it was Fort Knox that became her home.

It was a lovely Catholic ceremony, followed by a grand and riotous reception. Both halves of the day were long enough for Steph and me to discover a couple of the lighter elements oddly present when your wedding is on a military facility.

The Ceremony: In the Book of Worship for United States Forces, hymn #197 is Bless Thou the Astronauts Who Face, a classic that I'm sure we all know by heart.




The Reception: When you have your reception at the officers' club, you know there will be some military-themed art hanging over the mantle.

As Fort Knox is home of U.S. Army Armor Center and the U.S. Army Armor School, it's not too suprising that armor and cavalry feature heavily in a number of these works.

In Cold War-era painting below, I think the mushroom cloud really ties the whole thing together.

Pat Robertson, Man of Iron

It's hard to ignore Pat Robertson's kookiness, even when you're vacationing in Sicily.

This time, he's claiming he can leg press 2,000 lbs thanks to his miracle health shake.

p.s. Sicily is beautiful, but their driving resembles a real life version of Grand Theft Auto without as much shooting.

Pat Robertson Kookwatch: Episode 6

As I've said time and again, Pat Robertson's going to say something kooky to get in the news roughly every 50 days.

This time, he's claiming "If I heard the Lord right about 2006, the coasts of America will be lashed by storms," possibly even a tsunami.

66 days ago, it was satanic radical Muslims.
137 days ago, it was divine anger at Israel.
188 days ago, it was divine anger at Dover, PA.
220 days ago, the 2^nd coming appeared en route.
268 days ago, he called for the assassination of Hugo Chavez.

I wonder if he sets a reminder in Microsoft Outlook to say something crazy, or if his reliability is just innate.

You Can ______ 20% of the People 20% of the Time

In the most recent Washington Post-ABC News poll, 47 percent of voters "strongly" disapproved of Bush's job performance, a deeply foreboding number for GOP'ers seeking election this fall. In this same poll, 20 percent of respondents said they "strongly approve" of the job President Bush is doing.

When I see the latter number, I find myself amazed at the resilience of these people. With all that President Bush has done for them, 20% still strongly approve of him.

What are some other things that roughly 20% of Americans believe in or practice?

22% of adults believe "human beings evolved from earlier species"
     (Harris, 7/6/05)

23% of surveyed Americans don't identify themselves as Christian
     (ARIS, 2001)

26% of "born again" people support marijuana reform & legalization
     (Zogby, 3/24/06)

22% think doctors should always try to save a patient's life
     (Pew, 1/5/06)

22% smoke
     (Harris, 3/9/06)

21% believe in reincarnation
     (Harris, 12/14/05)

21% believe immigation is a very big problem in their community
20% believe immigation is a moderately big problem " "
22% believe immigation is a small problem " "
     (Pew, 3/30/06)

28% strongly oppose gay marriage
     (Pew, 3/22/06)

Well, It Is Nearly Passover

Having named their firstborn Apple, Gwyneth Paltrow and Chris Martin's second child is named Moses.

Update (4/15): The New York Times has a great piece on the names that stars give to their offspring.

Dude. Jason Lee (My Name is Earl) named his kid Pilot Inspektor.

Pat Robertson: Regular Like Prune Juice

The man is a force of nature and can be counted on come hell or high water. By Jove, Pat Robertson's going to say a kooky thing to get into the news just about every 50 days.

Today, Pat Robertson announced his opinion that radical Muslims are satanic.

67 days ago, Pat Robertson announced that Ariel Sharon's recent stroke could be God's punishment for Israel ceding Gaza to the Palestinians.

122 days ago, he warned voters in Dover, PA that the Almighty might send a disaster their way — since he thinks God's a big ID supporter.

154 days ago, he announced that an increased frequency of hurricanes – coupled with some knockout earthquakes – is probably evidence of the 2^nd coming of Christ.

202 days ago, he asked the US government to assassinate Venezuelan President Hugo Chavez.

The man is no less than the Energizer Bunny of Kookiness.

Mel Gibson Appears in Apocalypto Trailer for a Single Frame

...at about 1:45 into the trailer available at the movie website.



Yes, Mel probably still thinks his wife might go to hell. And, yes, Mel's father is probably still pretty sure that the Holocaust was kinda made up.

Bush v. Science, Round 37: George Carlton Deutsch III

After it became clear that he had been less than truthful on his résumé, George C. Deutsch III resigned his post at NASA yesterday, where he had taken it upon himself to see that NASA's online references to the "Big Bang" were amended to read the "Theory of the Big Bang."

His rationale for the change? "It is not NASA's place, nor should it be to make a declaration such as this about the existence of the universe that discounts intelligent design by a creator," moreover, he explained to one NASA employee that the Big Bang "not proven fact; it is opinion."

The 24-year old Mr. Deutsch's credentials for his post as a writer and editor in NASA's public affairs office in Washington? He worked the Bush/Cheney reelection war room in 2004 (It turns out he does not, in fact, have a Bachelor of Arts in journalism, Class of 2003, Texas A&M — hence the resignation.)

Of course, Mr. Deutsch's choice of preface for "Big Bang" is technically correct, but for profoundly incorrect reasons. I love the way Josh Marshall sums up the problem:

(The Big Bang is) not just some idea someone thought up which stands on an equal footing with any other idea anyone else could cook up. Among cosmologists today, it's the dominant theory about how the universe began. It is based on various theoretical work (which I won't try to understand or explain) and supported by a lot of astrophysical data.

The theory could turn out to be wrong. And it will almost certainly end up being revised in one or more ways. But it is not 'opinion'.

It's worth taking note of the word choice because it captures the mix of obscurantism and relativism which has characterized all the Bush administration's attitude about science and, really, pretty much all empirically based knowledge...

The rub here is the failure to see that knowledge which has been subjected to and survived – indeed been strengthened by – empirical and theoretical scrutiny stands on a higher footing than information that hasn't. This isn't pedantry. Nor is this some obscure alcove in the science curriculum.

This mindset – obscurantism and relativism duking it out to be of most use in the pursuit of power – suffuses the Bush administration: a lack of respect for facts and the set of tools we use to discern factual information from chatter and bombast.