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Congressional Research Service on Whether the "Defund ACORN Act" Is an Unconstitutional Bill of Attainder:

Here's the report, published Tuesday. An excerpt from the Summary:

The two main criteria which the courts would likely look to in order to determine whether legislation is a bill of attainder are (1) whether "specific" individuals or entities are affected by the statute, and (2) whether the legislation inflicts a "punishment" on those individuals. Under the instant bills, the fact that ACORN and its affiliates are named in the legislation for differential treatment would appear to meet a per se criteria for specificity.

The U.S. Supreme Court has also identified three types of legislation which would fulfill the "punishment" prong of the test: (1) where the burden is such as has "traditionally" been found to be punitive; (2) where the type and severity of burdens imposed are the "functional equivalent" of punishment because they cannot reasonably be said to further "non-punitive legislative purposes;" and (3) where the legislative record evinces a "congressional intent to punish." The withholding of federal contracts or grants does not appear to be a "traditional" punishment, nor does the legislative record so far appear to clearly evince an intent to punish. The question of whether the instant legislation serves as the functional equivalent of a punishment, however, is more difficult to ascertain.

While the regulatory purpose of ensuring that federal funds are properly spent is a legitimate one, it is not clear that imposing a permanent government-wide ban on contracting with or providing grants to ACORN fits that purpose, at least when the ban is applied to ACORN and its affiliates jointly and severally. In theory, under the House bill, the behavior of a single employee from a single affiliate could affect not only ACORN but all of its 361 affiliates. Thus, there may be issues raised by characterizing this legislation as purely regulatory in nature. While the Supreme Court has noted that the courts will generally defer to Congress as to the regulatory purpose of a statute absent clear proof of punitive intent, there appear to be potential issues raised with attempting to find a rational non-punitive regulatory purpose for this legislation. Thus, it appears that a court may have a sufficient basis to overcome the presumption of constitutionality, and find that it violates the prohibition against bills of attainder.

My much more tentative thoughts on the subject are here.

Related Posts (on one page):

  1. Congressional Research Service on Whether the "Defund ACORN Act" Is an Unconstitutional Bill of Attainder:
  2. Would Defunding ACORN Be an Unconstitutional Bill of Attainder?
Anononymous314:
Funding ACORN violates the Constitution in the first place, as no such activity is authorized in the Constitution, and on top of that, it's prohibited by the 9th and 10th Amendments. How can following the Constitution, even if inadvertently and wholly without any intention to do so, be classified as an unconstitutional bill of attainder?
9.24.2009 5:33pm
Harry Schell (mail):
Rockwwell was debarred from bidding on government contracts in 1985 for time-charge fraud (charging cost-type contracts for work performed on fixed-price contracts to avoid lost revenue) at a unit in Dallas. They undertook a sweeping internal review and engaged outside independent auditors to review compliance with company policies throughout the company.

ACORN is overdue for some kind of investigation and perhaps defunding with the number of cases being pursued on voter fraud (as well as convictions), embezzlement and other issues. The attention focused on them now is no doubt a matter of timing and manner of disclosure rather than when or how long such activities have occurred. The murky connections between the housing unit and political arm, where funds have been used as opposed as to why they were granted...it appears defunding is about the only way to prevent further illegal use of taxpayer dollars while investigations proceed.

Yes, innocent until proven guilty, but if this were Exxon what do you think would be happening? Maybe that doesn't make it right, but if taxpayer money is being used illegally the only current damage control handle to pull appears to be defunding further ops pending a legit review (one that excludes Andy Stern, for example).

In the Rockwell case, the problem was confined largely to one unit and several contracts. There was no evidence of an endemic problem or culture that supported the illegal acts. ACORN is in a slightly different position...heh.

I spent most of 1985/6 at different units of Rockwell doing reviews, so I know a bit about that situation, and that is all I will say about it.
9.24.2009 5:39pm
rj (mail):
Anononymous314:

By that logic, we can deny Medicaid/Medicare to minorities because the program isn't enumerated in the Constitution.
9.24.2009 5:39pm
U. Va. Grad:
no such activity is authorized in the Constitution, and on top of that, it's prohibited by the 9th and 10th Amendments. How can following the Constitution,

If you want to argue that there's no authorization for funding ACORN or whomever else in the Constitution, fine, I understand that argument. But how does funding ACORN violate the 9th and 10th Amendments?
9.24.2009 5:45pm
dirc:
I'm sure some creative lawyers in Congress could construct a bill that removes the funding from ACORN without naming ACORN. After all, individual companies (such as Walmart) have been targeted by legislation without naming them. For example, Maryland planned to establish a tax on companies with more than 10,000 employees in the state, that did not spend more than some percentage of employee wages on health care. Of course, only Walmart fit the description. The law passed (over the governor's veto), and was overturned on the grounds that it was preempted by ERISA, but not on the grounds that it was a Bill of Attainder.

Jonathon Adler wrote on this blog that the proposed AIG tax would probably not be viewed by the federal courts as a Bill of Attainder.

I'm sure there are some defining characteristics for ACORN that will permit Congress to stop their funding, and only their funding, without naming them. Either that, or Congress can establish an ACORN tax of 100% of their federal funding.
9.24.2009 6:08pm
Badness (mail):
They could go back to the "defunds the military-industrial complex" version that avoids naming names.

Not so great for national defense in the short term, maybe, but think of the money we'd save down the line by holding all future contractors to the fire!
9.24.2009 6:09pm
einhverfr (mail) (www):
Um.........

The first discussion (between Oren and me) was over a Senate amendment. The Defund ACORN Act (H. R. 3571) seems to be less of an issue than the original Senate amendment proposed.

The House bill is clear and general, and by no means limited to ACORN. I cannot see how it would be a bill of attainder.

On the other hand, the Senate amendment prohibits use of certain funds to directly or indirectly fund ACORN by name and made no other provisions. I think that would be on the other side of the line.
9.24.2009 6:10pm
John Jenkins (mail):
@einhverfr: I am not sure that I agree. Specificity is only one half of the test for a bill of attainder.

I think everyone would agree that Congress does not have to fund ACORN, from the beginning. There is no right to federal funding for any group.

It follows, I think, that if Congress can choose not to fund the group at all, then Congress can choose to stop funding the group, otherwise any such funding would be perpetual. I doubt that a court will look behind Congress's decision not to fund any group (as opposed to the imposition of a fine or some kind of forfeiture of property). Consequently, I don't think that a court would find that Congress's decision merely not to fund any group with treasury funds has a punitive purpose.

[As an aside, why DOES Congress fund ACORN? Should the government really be funding political groups of any kind?]
9.24.2009 6:25pm
Andrew Hyman (mail) (www):
So, if Congress decides to specifically give me some funding on a continuing basis, they can never specifically take it away? Call me dubious.
9.24.2009 6:27pm
einhverfr (mail) (www):
John Jenkans:

The Senate amendment to an appropriations bill said that none of the funding could be used to directly or indirectly fund ACORN. This seems to attach conditions that none of the money could be used by any state or local government in any grant that could go to ACORN. Read broadly, the amendment might have prohibited any grants using any of this money to anyone who provides services (such as facilities for rent) to ACORN. Even a narrow reading however would be far beyond any direct federal funding. This strikes me as fundamentally punative.

The House bill is far narrower, banning direct federal grants, promotion, and certain types of agreements to the covered organizations.

The House bill is good. The initial Senate amendment that Oren brought up was IMO over the line (and if not it was a lot closer to it).
9.24.2009 6:34pm
einhverfr (mail) (www):
For comparison, here are the two Senate amendments in question

SA 2355. Mr. JOHANNS submitted an amendment intended to be proposed by him to the bill H.R. 3288, making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2010, and for other purposes; which was ordered to lie on the table; as follows:

After section 414, insert the following:

Sec. 4__. None of the funds made available under this Act may be directly or indirectly distributed to the Association of Community Organizations for Reform Now (ACORN).



SA 2356. Mr. JOHANNS submitted an amendment intended to be proposed by him to the bill H.R. 3288, making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2010, and for other purposes; which was ordered to lie on the table; as follows:

After section 414, insert the following:

Sec. 4__. None of the funds made available under this Act shall be distributed to--

(1) an organization which has a pending indictment for or has been convicted of a violation under Federal or State law relating to fraudulent voting in any Federal or State election; or

(2) an organization which employs an individual who has a pending indictment for or has been convicted of a violation under Federal or State law relating to fraudulent voting in any Federal or State election.


The first was approved and strikes me as bill of attainder-like. The second has not been approved and strikes me as entirely reasonable.

The HR 3571 version is more or less broadly similar to the second amendment.
9.24.2009 6:42pm
Alex S. (mail):
Under that more reasonable version doesn't this pretty much require any organization (do local and/or state government, count?) who received funds to immediately fire any employee simply because they were indicted even if there is no claim that that the fraud were committed on behalf or even to the benefit of the organization?

I assume there'd be no compensation for this person if they were then later acquitted or otherwise cleared of the charges?
9.24.2009 7:05pm
second history:
Talk about unintended consequences. This bill is probably one of the most poorly thought out pieces of legislation while still being one of the shortest. It defines a "covered organization" as:
.....

(1) Any organization that has been indicted for a violation under any Federal or State law governing the financing of a campaign for election for public office or any law governing the administration of an election for public office, including a law relating to voter registration.

(2) Any organization that had its State corporate charter terminated due to its failure to comply with Federal or State lobbying disclosure requirements.

(3) Any organization that has filed a fraudulent form with any Federal or State regulatory agency.

(4) Any organization that:(A) employs any applicable individual, in a permanent or temporary capacity; (B) has under contract or retains any applicable individual; or (C) has any applicable individual acting on the organization's behalf or with the express or apparent authority of the organization.
....
(c) Additional Definitions-

(1) The term `organization' includes the Association of Community Organizations for Reform Now (in this subsection referred to as `ACORN') and any ACORN-related affiliate.
.....
(3) The term 'applicable individual' means an individual who has been indicted for a violation under Federal or State law relating to an election for Federal or State office....


Already some think it will also apply to other contractors, given their history of illegal campaign donations as well as other contractor fraud, which necessarily requires filing a "fraudulent form with any Federal or State regulatory agency." That list must be endless.

Members of Congress may have read the bill but certainly didn't comprehend the implications. But I'm sure it made them feel good to vote yes for a bill that won't be enacted. Or maybe they are leaving the dirty work up to the courts.
9.24.2009 7:06pm
Mark N. (www):
Naming it something other than the "Defund ACORN Act" would probably have been a good idea.
9.24.2009 7:08pm
second history:
einhverfr:

The House bill is good.

Do you believe the Defund ACORN Act (quoted in part above), is sufficiently narrowly drawn that it wouldn't apply to any other government contractor?
9.24.2009 7:16pm
Angus:
So, if Congress decides to specifically give me some funding on a continuing basis, they can never specifically take it away? Call me dubious.
They can choose not to renew it with no problems. Just delete it from appropriations and be done with it.

What Congress cannot do is pass a law that says "Andrew Hyman may not receive directly or indirectly any federal funds."
9.24.2009 7:18pm
steverino:
Well, this is certainly an informative blog.

As a layman, I was under the impression that the Constitution limited Congress' ability to tax me for the purpose of the common defense or the general welfare.

Since visiting here I've discovered that Congress' power to tax is the same as Genghis Khan's. As long as it calls it a tax, they can tax anything for any purpose whatsoever. I've even learned they can use their power to tax to regulate activity that would be unconstitutional for them to regulate directly. Which is why, based on previous precedent, it's perfectly legal for the federal government to force me to buy a commercial product under health care reform and tax me if I don't.

Now I'm learning that defunding an organization that has announced it engages in partisan political activities (in case you missed it, Ms. Lewis, ACORN's spokeswoman, has said it has become a target of the right because it supports progressive causes such as Obama's health care initiative) is an unconstitutional bill of attainder.

So, the Constitution gives advocacy groups a greater right to my money than I have.

This is just wonderful.
9.24.2009 7:27pm
Mark N. (www):
Now I'm learning that defunding an organization that has announced it engages in partisan political activities ... is an unconstitutional bill of attainder.

I don't think anyone would argue that a bill like you propose would be a bill of attainder. If Congress passed a Partisan Organizations Defunding Act, prohibiting any organization that engages in partisan political activities from receiving, directly or indirectly, any government funds, that would surely not be a bill of attainder. But Congress didn't do that.
9.24.2009 7:51pm
Steve:
Rockwwell was debarred from bidding on government contracts in 1985 for time-charge fraud (charging cost-type contracts for work performed on fixed-price contracts to avoid lost revenue) at a unit in Dallas.

Lots of companies have been taken off the list for committing some bad act or another. The Defense Department can certainly blacklist bad actors if it chooses to. The reason this particular case is an issue is because we're talking about an Act of Congress.

I don't know what cabinet department ACORN gets their funding from, but if that department had decided "no more money for ACORN, they're bad people," there's no bill of attainder problem. Decisions like that get made all the time.

Of course, the primary purpose of the Defund ACORN Act is not to defund ACORN, but to force Democratic lawmakers to cast a tough vote. That's why it's being handled this way.
9.24.2009 8:07pm
second history:
Of course, the primary purpose of the Defund ACORN Act is not to defund ACORN, but to force Democratic lawmakers to cast a tough vote. That's why it's being handled this way.

Not a very tough vote--it passed 345-75 2 days after it was introduced.
9.24.2009 8:14pm
Steve:
And Democrats who voted against it are already facing negative ads and criticism, while Democrats for it are facing anger and disappointment from liberal interest groups. For Republicans, of course, no repercussions at all for voting in favor. That's what makes it a tough vote for Democrats.
9.24.2009 8:26pm
J. Aldridge:
My re-post on the subject:

There is no case for a bill of attainder because no bill passed Congress declaring ACORN guilty or convicted of any kind of crime. You guys want to just focus on the defunding while ignoring there never was a bill of attainder for the conviction of some crime.

P.S. No one ever heard of a bill of attainder that ever demanded less than capital punishment in England. If pains and penalties was sought then a bill for pains and penalties was written. A bill of attainder was never negotiated down for lessor punishment. It was voted on as written, and if called for less than capital punishment it never was a bill of attainder in the first place.
9.24.2009 8:41pm
Mark N. (www):
J. Aldridge, you seem to be several hundred years behind the times, since in U.S. law, the term "bill of attainder" includes, as a subset, bills of pains and penalties, and has done so since the founding generation. Indeed much of the motivation for including that clause in the constitution was the passing by the English of laws confiscating property of colonists, which were referred to in the American colonial press as "bills of attainder".
9.24.2009 8:54pm
zuch (mail) (www):
Harry Schell:
ACORN is overdue for some kind of investigation and perhaps defunding with the number of cases being pursued on voter fraud (as well as convictions), embezzlement and other issues....
Care to explain how ACORN has done any of this, rather than rogue employees or temporary workers? As for the embezzlement, that was someone embezzling money from ACORN ... they were the victim, not the perp. Maybe the gummint should declare itself ineligible for gummint funding when people embezzle from it, eh?
The murky connections between the housing unit and political arm, where funds have been used as opposed as to why they were granted...it appears defunding is about the only way to prevent further illegal use of taxpayer dollars while investigations proceed.
What "political arm"? And care to elucidate? Allegations are a dime a dozen, facts are a bit more dear. Not to mention, "Sentence first, verdict afterwards", as the Rev. C.L. Dodgson would say.

Cheers,
9.24.2009 9:06pm
zuch (mail) (www):
This might make an interesting twist.

For those that care about gummint money continuing to go to corrupt businesses or organisations, here's a candidate list. Let's get cracking ... unless the animosity towards ACORN is politically motivated and not an honest effort to cut down on corruption and waste....

Cheers,
9.24.2009 9:10pm
J. Aldridge:
@Mark N: Just because a publication might have once compared land confiscation to a "bill of attainder" is pretty weak evidence to argue that it is the founding understanding of the phrase.

I repeat again, there was no bill seeking to find ACORN guilty of anything and calling for punishment because of a legislative conviction. Without there is no bill of attainder argument.
9.24.2009 9:13pm
Brian Garst (www):
If the mere impression of corruption is sufficient to justify first amendment violating bans on free speech, then I don't see how there's much question that eliminating funding to an organization like ACORN is a legitimate congressional function.
9.24.2009 9:22pm
RPT (mail):
ACORN has been a political target for years because it works with and registers minority voters. Unfortunately, the Democrats are bullied into supporting it, but not because there is good cause to do so. That is what this is about because, to GOP/conservatives minority voter registration is just about the only place one can find corruption. Look back at the Rove/USA scandal. This is a substitute for the indictments that have been brought and failed or properly not brought at all. The amount of federal funds involved (averaging $3M/year) are trivial. I'm waiting for Brent Bozell to issue his opinion on the unedited authenticity of the videos since their creator has a history of selective editing. Those genuinely concerned about corruption in government contracting would be more concerned about such characters as Wackenhut, Triple Canopy, Blackwater/Xe, etc.
9.24.2009 9:44pm
yankee (mail):
Those genuinely concerned about corruption in government contracting would be more concerned about such characters as Wackenhut, Triple Canopy, Blackwater/Xe, etc.
I'm not sure if it's funny or sad that a bill specifically defunding ACORN is a real possibility, but a bill defunding companies that have bilked the government out of billions of dollars is a political nonstarter.
9.24.2009 10:50pm
Psalm91 (mail):
Yankee:

It's sad not funny. ACORN has long been targeted by voter suppressionist and other lobbyists like the "Employment Policy Institute", "Laborfacts.com" aka Rick Berman. The theft of billions from the government is one of those IOKIYAR matters.
9.24.2009 10:59pm
Angus:
MarkN,
You won't be able to convince J. Aldridge. He and P.A. Madison are convinced that the founding generation were boobs who did not know what the Constitution meant. Only Aldridge and Madison in the entirety of U.S. history know the truth.
9.24.2009 11:09pm
J. Aldridge:
You won't be able to convince J. Aldridge. He and P.A. Madison are convinced that the founding generation were boobs who did not know what the Constitution meant.

I think you mistate the case there. It's you who have no ideal what the constitution means because you only see it through select, tainted court holdings.

P.S. P.A. Madison has you a little nervous or uncomfortable does he?
9.25.2009 12:03am
ArthurKirkland:
I see a teachable moment.

It might be worthwhile for the majority party to go after a couple of selected bad actors -- Xe/Blackwater comes to mind, or the contractor (KBR/Halliburton) accused of manslaughter with respect to the numerous electrocution deaths of American servicemen -- in much the way Republicans targeted ACORN. Not only would it score some political points -- forcing Republicans to cast some tough votes -- but also prevent some ugly companies from getting public dollars, correcting wrongs magnitudes worse than anything involving ACORN.

I doubt many Democrats would be pained by a vote against the likes of Blackwater or KBR/Halliburton. Add the democratic votes to the votes of Republicans who wouldn't want to be tied to electrocutions-for-profit or indiscriminate shooting at civilians and gun-smuggling, and a lopsided vote seems likely. Would there be any downside to excommunicating them?
9.25.2009 12:35am
egd:
ArthurKirkland:

I doubt many Democrats would be pained by a vote against the likes of Blackwater or KBR/Halliburton. Add the democratic votes to the votes of Republicans who wouldn't want to be tied to electrocutions-for-profit or indiscriminate shooting at civilians and gun-smuggling, and a lopsided vote seems likely. Would there be any downside to excommunicating them?

If it's such an easy vote to cast...where is the "De-fund Blackwater/Xe" bill? Or do you think that the party in control of both houses of Congress (now filibuster proof thanks to political chicanery in Massachusetts) has no power to propose its own bills?
9.25.2009 8:51am
Mikeyes (mail):
Which of the "Defund ACORN" bills passed with such lobsided numbers? The one that only mentioned ACORN or the one that defunds any person/corporation that has defrauded the government or violated a number of other laws and mentions ACORN specifically?

If it is the latter, what are the chances that it will survive confernence?
9.25.2009 10:02am
zuch (mail) (www):
egd:
If it's such an easy vote to cast...where is the "De-fund Blackwater/Xe" bill? Or do you think that the party in control of both houses of Congress (now filibuster proof thanks to political chicanery in Massachusetts) has no power to propose its own bills?
Maybe some folks aren't too keen on bills of attainder. But as pointed out above, the language in some of the proposed "Defund ACORN Act" bills might arguably require that quite a few other entities be defunded as well.

Cheers,
9.25.2009 10:04am
steverino:
I don't think anyone would argue that a bill like you propose would be a bill of attainder. If Congress passed a Partisan Organizations Defunding Act, prohibiting any organization that engages in partisan political activities from receiving, directly or indirectly, any government funds, that would surely not be a bill of attainder. But Congress didn't do that.


I was speaking about two slightly different aspects of this.

First, I was speaking about how the courts have apparently construed the Constitution over the years to confer a greater property interest to those receiving federal tax dollars in that money than it does to those paying those taxes in retaining it.

I recall the controversy when it was discovered that some artists producing works like "piss Christ" or "elephant dung Virgin Mary" were receiving NEA grants for their work. When people began to wonder if this was the sort of thing the NEA should be funding, the "arts community" got in front of the situation by screaming censorship.

Apparently, if they had screamed "bill of attainder" they'd have been on solid legal ground. And I am beginning to suspect that withdrawing their federal grant would probably have been construed by the courts as censorship as well.

Second, I was speaking about how little reason their is to have faith in the federal government regulating anything.

ACORN's website says it is a non-profit, non-partisan organization. I was under the impression that this was so it could receive certain types of federal grants. Certainly, federal tax dollars can't be used for partisan political purposes, can they?

But then ACORN's own official spokeswoman has shattered that facade by defending her organization, in this incident that sparked the defunding, as having been targeted by the right wing because ACORN promotes progressive causes such as Barack Obama's health care reform.

It seems to me we shouldn't really need a "Partisan Organization DeFunding Act" because the federal government shouldn't be in the business of funding them in the first place. In fact, don't we have a few laws against federal money being used for these purposes?

Apparently, a partisan organization can slip by the regulators and get their money by putting the right words on their website or grant application. Which are taken at face value. Then they can go on TV and spout off about what everyone knows to be the truth, which is quite the opposite.

If they can do that and get the money in the first place, I doubt they'll have much trouble evading the cooperative watchdogs tasked with defunding partisan organizations.

Seriously, wouldn't it be proper to suspend the funding to this officially non-partisan but now self-admittedly very partisan organization in order to investigate whether any money was used improperly and any fraud was involved in getting the money?

Obviously not.
9.25.2009 11:05am
Harry Schell (mail):
Zuch,
As to who committed voter fraud, embezzlement, etc. oabviously individuals did those acts. That there is a pattern certainly of voter fraud associated with ACORN personnel in more than a dozen states calls into question the culture of the company.

As I noted with Rockwell, the government had no problem punishing the whole company for the actions of maybe a dozen indviduals. Ditto Arthur Andersen. So if you imply ACORN should be excused as an organization due to the acts of individuals, you call into question any action taken against any corporation. Which actually is not a half-bad idea. The Enron scheme should not have led to the demise of AA, not even close.

As to the murkiness of where money has gone and whether it is for the purposes it was intended, an article appeared today in WaPo, about Sen. Grassley's investigation. See http://hotair.com/archives/2009/09/25

Now, Ms. Lewis, CEO, pretty much says at the end of the article that she cleaned up all the problems (sic) with how funding has been channeled and documented. Er, if there were no problems then what was there to clean up, Bertha?

Ms. Lewis' attitude and explanations about the BigGovernment tapes, you will recall, has migrated from denial to "a local problem" to "thank you for pointing this out" to "we are suing" and starting a funding appeal to fend off "right-wing dirty trick attacks". For such an honest woman with deep insight and control of the organization, er, I find the evolution of her position interesting.
9.25.2009 1:29pm
zuch (mail) (www):
Harry Schell:
As to who committed voter fraud, embezzlement, etc. oabviously individuals did those acts.
OK. Progress. You should also note that ACORN brought many of these incidents to the attention of the authorities.
That there is a pattern certainly of voter fraud associated with ACORN personnel in more than a dozen states calls into question the culture of the company.
Assumes facts not in evidence. Republican allegations are not a "pattern" of evidence. I'd say that the "pattern of evidence" WRT KBR electrocuting U.S. troops is far more compelling.

Cheers,
9.25.2009 5:43pm
einhverfr (mail) (www):
Second History:


Do you believe the Defund ACORN Act (quoted in part above), is sufficiently narrowly drawn that it wouldn't apply to any other government contractor?


Actually it would apply to ANY government contractor who ever submitted a padded invoice.

Of course, I am all for cleaning house.
9.25.2009 5:55pm
Harry Schell (mail):
Zuch,
You want to play lawyer with me and pretend the indictments and convictions for voter fraud, involving multiple individuals in multiple states "are not in evidence", do have fun.

You are playing with yourself and lost the arguement, IMO.

And the second part, about where the money went and political activities funded by ACORN?
9.25.2009 8:21pm
Harry Schell (mail):
Zuch,
Also, was it KBR who electrocuted those employees? Can you "progress" with me?

Or does it depend on whose ox is being gored, that old subjective reasoning that excuses murder in support of la revolucion but punishes people who kill revolucionaires, such as Pinochet?

He is so far as I know, the only dictator in modern times, let's say the last 110 years, who seized power, built democratic institutions and resigned, turning over power to an elected civilian government.

A real embarassment to the Mugabes of the world, so naturally the left hates the man. Blows their promises and actual performance to hell. They promise, he did it.
9.25.2009 8:29pm

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