Did COVID-19 Lockdowns Reach Back in Time to Affect Behavior Before They Were Imposed?

Rt-Mass

“By going into lockdown,” New York Times science writer Carl Zimmer matter-of-factly reports, “Massachusetts drove its reproductive number down from 2.2 at the beginning of March to 1 by the end of the month; it’s now at .74.” Zimmer is talking about the number of people the average carrier infects, and if the Massachusetts lockdown really did cut that number by two-thirds, it would be strong evidence that such policies are highly effective at reducing virus transmission. The truth, however, is rather more complicated.

Zimmer links to a chart that shows the reproductive number in Massachusetts falling precipitously in March. But that downward trend began more than three weeks before Gov. Charlie Baker issued his business closure and stay-at-home orders. By the time Massachusetts officially locked down on March 24, the number had fallen from 2.2 to 1.2. That decline continued during the lockdown, falling to a low of 0.8 by May 18, when the stay-at-home order expired and Baker began allowing businesses to reopen. It is therefore possible that closing “nonessential” businesses and telling people to stay home except for government-approved purposes reinforced the preexisting trend. But the lockdown had no obvious impact on the slope of the curve.

The reproductive number continued to fall sharply until the end of March, when it  dropped below one, which indicates a waning epidemic. The drop then slowed, and the number fluctuated, going up and down a bit but always staying below one. Since the lockdown was lifted, the picture has stayed pretty much the same. The estimate for yesterday was 0.8, which is a bit surprising if you believe the lockdown was crucial in keeping the number low. Although it has been more than a month since Baker started reopening the state’s economy, virus transmission has not been notably affected. Newly confirmed cases, hospitalizations, and daily deaths are all trending downward.

If you are a fan of lockdowns, you can look at these numbers and conclude that the policy has been a smashing success in Massachusetts, as Zimmer seems to believe. But if you are at all skeptical of the marginal impact that lockdowns had at a time when Americans were already moving around less and striving to minimize social interactions (as shown by cellphone and foot traffic data as well as estimates of the reproductive number), you have to wonder how Baker’s orders reached back in time to affect behavior that happened before they took effect. Trends in other states pose a similar puzzle.

Even if we give Baker’s lockdown full credit for positive trends in Massachusetts after March 24, it clearly is not responsible for reducing the reproductive number by 45 percent before then, even though Zimmer implies otherwise. And since the subsequent drop of 33 percent was smaller, it is logically impossible even to give the lockdown most of the credit for reducing transmission.

If voluntary changes in behavior account for the decline in transmission before the lockdown, it seems reasonable to assume that they played an important role after March 24 as well. How important is the crux of the dispute between Americans who think lockdowns were absolutely necessary to curtail the epidemic and Americans who question that belief.

The rest of Zimmer’s article, which focuses on the outsized role that superspreaders have played in the pandemic, lends support to the latter camp. “Most infected people don’t pass on the coronavirus to someone else,” he observes. “But a small number pass it on to many others in so-called superspreading events.”

Research in Hong Kong, for example, found that “just 20 percent of cases, all of them involving social gatherings, accounted for an astonishing 80 percent of transmissions.” Another 10 percent of carriers “accounted for the remaining 20 percent of transmissions,” meaning that 70 percent of people infected by the virus did not pass it on to anyone. Because the reproductive number is an average, it obscures the significance of superspreaders, which is nevertheless important in weighing COVID-19 control policies.

One hypothesis about superspreaders, Zimmer notes, is that some people tend to harbor more of the virus than others, making them more likely to pass it on. But environmental factors are also important. When a lot of people are packed together in an indoor space with poor ventilation, any carriers who happen to be there are much more likely to transmit the virus, especially if they are singing, talking loudly, coughing, or sneezing.

“A busy bar, for example, is full of people talking loudly,” Zimmer writes “Any one of them could spew out viruses without ever coughing. And without good ventilation, the viruses can linger in the air for hours.”

What are the policy implications? “Knowing that Covid-19 is a superspreading pandemic could be a good thing,” Zimmer notes. “Since most transmission happens only in a small number of similar situations, it may be possible to come up with smart strategies to stop them from happening. It may be possible to avoid crippling, across-the-board lockdowns by targeting the superspreading events.” He quotes British epidemiologist Adam Kucharski: “By curbing the activities in quite a small proportion of our life, we could actually reduce most of the risk.”

In other words, even if Zimmer is right to assume that locking down Massachusetts drove down virus transmission, that does not mean similar results could not have been achieved through less costly, more carefully targeted policies. If “it may be possible to avoid crippling, across-the-board lockdowns by targeting the superspreading events,” that seems like an option that politicians should have considered before closing down the economy.

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Gordon Johnson: Warranty Accounting Impropriety At Tesla Similar To Accounting At Wirecard

Gordon Johnson: Warranty Accounting Impropriety At Tesla Similar To Accounting At Wirecard

Tyler Durden

Tue, 06/30/2020 – 20:25

Right around the same time that Tesla was leaking to electrek that the company could break even in Q2 despite the pandemic, analyst Gordon Johnson of GLJ Research was putting his clients on notice about “continued deception” and “accounting impropriety” that is “similar” to Wirecard.

Of course, the stock responded on Tuesday to only one of these two reports, surging higher on the back of Musk’s comments and a continued gamma squeeze helped along by multi-million dollar sweeps of $1500 and $1800 calls on Monday. 

Options data via @CheddarFlow

Regardless, Johnson’s note about Tesla’s warranty accounting talks about serious issues that eventually may not be able to be ignored. Johnson estimates on Monday that Tesla has recognized just $1,427 per car in warranty reserves versus the $3,308 per car that it should. This has led to a gross profit overstatement of $148.93 million, according to Johnson:

If you take TSLA’s adjusted warranty reserve in 1Q20 of $78.95mn and divide by its adjusted aggregate cars on the road of 763,755, you arrive at a number of $103.37/car; thus, given TSLA provides an 8-yr battery/motor warranty, and thus every car sold is still under warranty, $103.37/car x 32 = $3,308/car of lifetime expense x 79,200 cars sold and on the road in 1Q20 = the amount TSLA should have taken in 1Q20 pre-adjustment warranty provision (~$275mn) ; yet, taking the adjusted 1Q20 warranty provision of $119mn vs. 79,200 cars on the road, TSLA recognized just $1,427/car in reserves in 1Q20.

So ($3,308/car x 79,200 cars on the road) – ($1,427/car x 79,200 cars on the road) = gross profit overstatement of $148.932mn. This is a pretty big deal, and not only overstates gross margin, but also overstates net income – see below for TSLA classifying warranty cost as “goodwill”.

Johnson then posted several examples of the company accounting for warranty costs as goodwill, thus artificially boosting its gross margin and net income.

Interestingly, Johnson also noted last week that Tesla’s end of quarter push didn’t seem to be going well, which contradicts what has apparently been leaked to electrek. Johnson noted that Florida and Texas were very important markets to monitor since they were the closest to “real-time” of any U.S. Tesla data sets. New York and California, he noted, were 1-2 months behind. 

Johnson noted the following trends last week:

  • OVERALL THIS WEEK (i.e., the most important week for TSLA’s 2Q20 numbers): Model 3 slowing in FL; Model Y slowing in FL; Model Y slowing in TX; Model 3 accelerating, slightly, in TX.
  • FLORIDA THIS WEEK (i.e., the most important week for TSLA’s 2Q20 numbers): Last week TSLA was averaging 54 3+Y/day; this week, so far, it’s 40.
  • TEXAS THIS WEEK (i.e., the most important week for TSLA’s 2Q20 numbers): Last week TSLA was averaging 36 3+Y/day; this week, so far, it’s 39 (the data come in much stronger than expected today – the strength is 100% from the Model 3).

Johnson concluded that “the end-of-quarter push is the weakest it’s been since they ran out of cars in 4Q19 (unlike then, however, this time they have a record level of inventory)”.

And for those note familiar with accounting who still want the gist of Johnson’s note, we’ll refer you to this Tweet, which popped up yesterday:

 

via ZeroHedge News https://ift.tt/2YN2FD1 Tyler Durden

General Flynn To The ‘Silent Majority’: “Wake Up! America’s At Risk Of Being Lost”

General Flynn To The ‘Silent Majority’: “Wake Up! America’s At Risk Of Being Lost”

Tyler Durden

Tue, 06/30/2020 – 20:05

Authored by General Michael Flynn (ret.), op-ed via WesternJournal.com,

I was once told if we’re not careful, 2 percent of the passionate will control 98 percent of the indifferent 100 percent of the time.

The more I’ve thought about this phrase, the more I believe it. There is now a small group of passionate people working hard to destroy our American way of life. Treason and treachery are rampant and our rule of law and those law enforcement professionals who uphold our laws are under the gun more than at any time in our nation’s history. These passionate 2 percent appear to be winning.

Despite there being countless good people trying to come to grips with everything else on their plates, our silent majority (the indifferent) can no longer be silent.

If the United States wants to survive the onslaught of socialism, if we are to continue to enjoy self-government and the liberty of our hard-fought freedoms, we have to understand there are two opposing forces: One is the “children of light” and the other is the “children of darkness.”

As I recently wrote, the art and exercise of self-governance require active participation by every American. I wasn’t kidding! And voting is only part of that active participation. Time and again, the silent majority have been overwhelmed by the “audacity and resolve” of small, well-organized, passionate groups. It’s now time for us, the silent majority (the indifferent), to demonstrate both.

The trials of our current times, like warfare, are immense and consequences severe and these seem inconquerable.

As a policewoman from Virginia told me, “People don’t feel safe in their homes and our police force is so demoralized we cannot function as we should. In my 23 years with my department, I have never seen morale so low.”

Another woman from Mississippi told me that we need our leaders to “drop a forceful hammer. People are losing patience. It simply must be stopped! Laws MUST be enforced … no one is above the law.”

Don’t fret. Through smart, positive actions of resolute citizen-patriots, we can prevail. Always keep in mind that our enemy (these dark forces) invariably have difficulties of which we are ignorant.

For most Americans, these forces appear to be strong. I sense they are desperate. I also sense that only a slight push on our part is all that is required to defeat these forces. How should that push come?

Prayers help and prayers matter, but action is also a remedy. Our law enforcement professionals, from the dispatcher to the detective and from the cop to the commissioner, are a line of defense against the corrupt and the criminal. It is how we remain (for now) in a state of relatively peaceful existence.

We must support them with all our being. They are not the enemy; they bring light to the darkness of night through their bravery and determination to do their jobs without fanfare and with tremendous sacrifice.

The silent majority (the indifferent) tend to go the way of those leading them. We are not map- or mind-readers; we are humans fraught with all the hopes and fears that flesh is heir to. We must not become lost in this battle. We must resoundingly follow our God-given common sense.

Seek the truth, fight for it in everything that is displayed before you. Don’t trust the fake news or false prophets; trust your instincts and your common sense. Those with a conscience know the difference between right and wrong, and those with courage will always choose the harder right over the easier wrong.

I believe the attacks being presented to us today are part of a well-orchestrated and well-funded effort that uses racism as its sword to aggravate our battlefield dispositions. This weapon is used to leverage and legitimize violence and crime, not to seek or serve the truth.

The dark forces’ weapons formed against us serve one purpose: to promote radical social change through power and control. Socialism and the creation of a socialist society are their ultimate goals.

They are also intent on driving God out of our families, our schools and our courts. They are even seeking the very removal of God from our churches, essentially hoping to remove God from our everyday lives.

Remember, we will only remain united as “one nation under God.”

And yes, there is a “resistance movement” by the forces of darkness. However, we must also resist these onslaughts and instead take an optimistic view of our situation. Like war, optimism can be pervasive and helps to subdue any rising sense of fear.

We must, however, be deliberate about our optimism. Otherwise, we may get lost in discouragement and despair of any failings we encounter. We must be tenacious in the ultimate end we wish to gain. That end is to remain an unwavering constitutional republic based on a set of Judeo-Christian values and principles. We must not fear these and instead embrace each.

Our path requires course corrections. To move our experiment in democracy forward, we should fight and reject the tired and failed political paths and instead pursue a more correct path that shines a bright light on liberty, a path with greater and greater control of our livelihoods instead of being controlled by fewer and fewer of the too-long-in-power politicians. They have discarded us like old trash.

Our will, our individual liberties and freedoms, remain powerful forces and must be understood and applied smartly. We must not be overly stubborn. Following the Constitution as our guide and adapting to change as we have throughout history, we learn more about what freedoms humans desire.

At times, however, we have to fall back on what got us here. We cannot afford to lose our God-given human rights and the strong inner desire for freedom to choose and to breathe the fresh air of liberty. We must stand up and speak out to challenge our so-called “leaders” of government. We put them in charge; we can remove them as well.

It is through our rights and privileges as American citizens that we challenge the political class and leverage our election process so “we the people” can decide who will govern.

We must not allow a small percentage of the powerful to overtake our position on America’s battlefield. We, as free-thinking and acting individuals, must control how we will live and not allow a few passionate others to change our way of life.

To the silent and currently indifferent majority: Wake up. America is at risk of being lost in the dustbin of history to socialism. The very heart and soul of America is at stake.

In war, as in life, most failure comes from inaction. We face a pivotal moment that can change the course of history of our nation.

We the people must challenge every politician at every level.

We also must stand and support our law enforcement professionals: They are the pointy end of the spear defending us against anarchy.

Now is the time to act.

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India Sends Tanks Along Border To Prevent China “Redefining” Line Of Actual Control

India Sends Tanks Along Border To Prevent China “Redefining” Line Of Actual Control

Tyler Durden

Tue, 06/30/2020 – 19:45

Last week satellite imaging analysts based in the West observed a significant build-up of Chinese PLA forces along the India-Chinese border Line of Actual Control (LAC) in Galwan Valley. This included the expansion of what appeared permanent or semi-permanent bases, as well as tanks and artillery units, after the deadly June 15 Galwan Valley clash which left 20 Indian troops dead and an untold number of PLA casualties.  

The Indian Army responded by sending its quick reaction surface-to-air missile systems known as Akash to the disputed border region, reported widely in Indian media Saturday. New Delhi is also now said to be seeking rapid S-400 acquirement from Russia.

India has further apparently answered China’s tank build-up with its own in a continuing tit-for-tat deployment of additional forces. This despite ongoing deconfliction talks between the opposing military delegations. The Hindustan Times reports Tuesday the army has sent at least six T-90 Bhishma tanks to the LAC, along with additional defensive hardware such as shoulder fired anti-tank missiles for infantry troops.

Image via Defence.Capital

The Hundustan Times describes the extra force deployment as specifically in answer to the PLA’s own tanks along the border:  

The army’s decision to deploy the T-90 Bishma tanks was taken after the Chinese People’s Liberation Army (PLA) had beefed up its positions on the river bed with armoured personnel carriers and troop tents. The Indian Army is occupying the dominant heights in the sector within its side of the Line of Actual Control (LAC).

Infantry combat vehicles along with 155mm howitzers have been deployed all along 1597 km long LAC in East Ladakh with two tank regiments deployed in Chushul sector to repel any aggressive plans of the adversary through the Spanggur Gap. While Chinese PLA wants to make a deal on the LAC in this sector as part of withdrawal, the Indian Army is no mood to give an inch as the military aggression came from the Western Theatre Command of China with the intention of redefining the LAC.

The report adds further that Indian commanders are prepared for a “long haul” deployment of additional forces and tanks to the border. 

Hindustan Times image: “T-90 missile firing tank deployed in Galwan Valley sector.”

This also as India’s air force and navy are said to be in their “highest state of alertness” according to widely circulating Indian media reports. 

India’s military has been saying the “extraordinary circumstances” warrant both the build-up and altered rules of engagement giving local commanders “freedom of action” ability if provoked or attacked. 

“There is no change in the rules as such. Our side will only react to provocations and in case of extraordinary circumstances,” former Indian director-general of military operations, Lt. Gen. Vinod Bhatia, previously said.

via ZeroHedge News https://ift.tt/2BpvCMg Tyler Durden

Did COVID-19 Lockdowns Reach Back in Time to Affect Behavior Before They Were Imposed?

Rt-Mass

“By going into lockdown,” New York Times science writer Carl Zimmer matter-of-factly reports, “Massachusetts drove its reproductive number down from 2.2 at the beginning of March to 1 by the end of the month; it’s now at .74.” Zimmer is talking about the number of people the average carrier infects, and if the Massachusetts lockdown really did cut that number by two-thirds, it would be strong evidence that such policies are highly effective at reducing virus transmission. The truth, however, is rather more complicated.

Zimmer links to a chart that shows the reproductive number in Massachusetts falling precipitously in March. But that downward trend began more than three weeks before Gov. Charlie Baker issued his business closure and stay-at-home orders. By the time Massachusetts officially locked down on March 24, the number had fallen from 2.2 to 1.2. That decline continued during the lockdown, falling to a low of 0.8 by May 18, when the stay-at-home order expired and Baker began allowing businesses to reopen. It is therefore possible that closing “nonessential” businesses and telling people to stay home except for government-approved purposes reinforced the preexisting trend. But the lockdown had no obvious impact on the slope of the curve.

The reproductive number continued to fall sharply until the end of March, when it  dropped below one, which indicates a waning epidemic. The drop then slowed, and the number fluctuated, going up and down a bit but always staying below one. Since the lockdown was lifted, the picture has stayed pretty much the same. The estimate for yesterday was 0.8, which is a bit surprising if you believe the lockdown was crucial in keeping the number low. Although it has been more than a month since Baker started reopening the state’s economy, virus transmission has not been notably affected. Newly confirmed cases, hospitalizations, and daily deaths are all trending downward.

If you are a fan of lockdowns, you can look at these numbers and conclude that the policy has been a smashing success in Massachusetts, as Zimmer seems to believe. But if you are at all skeptical of the marginal impact that lockdowns had at a time when Americans were already moving around less and striving to minimize social interactions (as shown by cellphone and foot traffic data as well as estimates of the reproductive number), you have to wonder how Baker’s orders reached back in time to affect behavior that happened before they took effect. Trends in other states pose a similar puzzle.

Even if we give Baker’s lockdown full credit for positive trends in Massachusetts after March 24, it clearly is not responsible for reducing the reproductive number by 45 percent before then, even though Zimmer implies otherwise. And since the subsequent drop of 33 percent was smaller, it is logically impossible even to give the lockdown most of the credit for reducing transmission.

If voluntary changes in behavior account for the decline in transmission before the lockdown, it seems reasonable to assume that they played an important role after March 18 as well. How important is the crux of the dispute between Americans who think lockdowns were absolutely necessary to curtail the epidemic and Americans who question that belief.

The rest of Zimmer’s article, which focuses on the outsized role that superspreaders have played in the pandemic, lends support to the latter camp. “Most infected people don’t pass on the coronavirus to someone else,” he observes. “But a small number pass it on to many others in so-called superspreading events.”

Research in Hong Kong, for example, found that “just 20 percent of cases, all of them involving social gatherings, accounted for an astonishing 80 percent of transmissions.” Another 10 percent of carriers “accounted for the remaining 20 percent of transmissions,” meaning that 70 percent of people infected by the virus did not pass it on to anyone. Because the reproductive number is an average, it obscures the significance of superspreaders, which is nevertheless important in weighing COVID-19 control policies.

One hypothesis about superspreaders, Zimmer notes, is that some people tend to harbor more of the virus than others, making them more likely to pass it on. But environmental factors are also important. When a lot of people are packed together in an indoor space with poor ventilation, any carriers who happen to be there are much more likely to transmit the virus, especially if they are singing, talking loudly, coughing, or sneezing.

“A busy bar, for example, is full of people talking loudly,” Zimmer writes “Any one of them could spew out viruses without ever coughing. And without good ventilation, the viruses can linger in the air for hours.”

What are the policy implications? “Knowing that Covid-19 is a superspreading pandemic could be a good thing,” Zimmer notes. “Since most transmission happens only in a small number of similar situations, it may be possible to come up with smart strategies to stop them from happening. It may be possible to avoid crippling, across-the-board lockdowns by targeting the superspreading events.” He quotes British epidemiologist Adam Kucharski: “By curbing the activities in quite a small proportion of our life, we could actually reduce most of the risk.”

In other words, even if Zimmer is right to assume that locking down Massachusetts drove down virus transmission, that does not mean similar results could not have been achieved through less costly, more carefully targeted policies. If “it may be possible to avoid crippling, across-the-board lockdowns by targeting the superspreading events,” that seems like an option that politicians should have considered before closing down the economy.

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The Roberts Court Slowly Inters Justice Kennedy’s Ephemeral “Jurisprudence of Doubt”

Two years ago, Justice Kennedy announced that he would retire from the Supreme Court. One of my earliest thoughts was, “I will never have to edit another Kennedy opinion for the casebook!” My follow-up thought was, “How long will I have to keep the Kennedy opinions in the casebook, once they are overruled or whittled away.” The whittling away has already begun. The Roberts Court is slowly, but surely interring Justice Kennedy’s ephemeral “jurisprudence of doubt.” Blue June has already buried at least three precedents with Justice Kennedy in the majority: Boumediene v. BushWhole Woman’s Health, and Footnote 3 of Trinity Lutheran.

Boumediene v. Bush

Boumediene suffered two major blows during Blue June. The first hit came in DHS v. Thuraissigiam (see here and here). Justice Alito’s majority required a very precise fit between history and the Petitioner’s claim.

Despite pages of rhetoric, the dissent is unable to cite a single pre-1789 habeas case in which a court ordered relief that was anything like what respondent seeks here.

Justice Kennedy’s 2008 majority opinion relied on history in a very fluid fashion. In dissent, Justice Sotomayor wrote that Boumediene “never demanded the kind of precise factual match with pre-1789 case law that today’s Court demands.” She’s right.

As I read Thuraissigiam, the Court has closed the door to any future expansion of the Suspension Clause jurisprudence, unless there is a close analogue to historical practice in 1789. Indeed, Mike Dorf finds an even greater limitation:

In both St. Cyr and Boumediene v. Bush, the Supreme Court said that the Suspension Clause protects a right to habeas that is “at the absolute minimum” as expansive as the scope of habeas in 1789, leaving open the possibility of further expansion. Justice Alito’s opinion (1) finds that the scope in 1789 does not benefit Thuraissigiam and (2) does not go beyond that minimum.

The Court has now rejected any possible “evolving” notion of habeas. The Great Writ is solidified in amber.

Boumediene took another hit in a sleeper case of the term, Agency for Int’l Development v. Alliance for Open Society. Justice Kavanaugh’s nine-page decision resolved a really important constitutional question with very little fanfare. He wrote:

First, it is long settled as a matter of American constitutional law that foreign citizens outside U. S. territory do not possess rights under the U. S. Constitution. Plaintiffs do not dispute that fundamental principle. Tr. of Oral Arg. 58–59; see, e.g., Boumediene v. Bush, 553 U. S. 723, 770– 771 (2008); Hamdi v. Rumsfeld, 542 U. S. 507, 558–559 (2004) (Scalia, J., dissenting); United States v. Verdugo-Urquidez, 494 U. S. 259, 265–275 (1990); Johnson v. Eisentrager, 339 U. S. 763, 784 (1950); United States ex rel. Turner v. Williams, 194 U. S. 279, 292 (1904); U. S. Const., Preamble.

Justice Kavanaugh posed this precise question during oral argument:

JUSTICE KAVANAUGH:  Good morning, counsel. I want to clarify, first, one thing from your colloquy with Justice Ginsburg. You agree, I assume, that unaffiliated foreign entities acting abroad have no constitutional rights under this Court’s precedents.

MR. BOWKER: We do, Your Honor.

This concession was unwise. And I also think it was wrong.

Justice Breyer’s dissent explains the Court has never actually reached this sweeping conclusion.

Even taken on its own terms, the majority’s blanket assertion about the extraterritorial reach of our Constitution does not reflect the current state of the law. The idea that foreign citizens abroad never have constitutional rights is not a “bedrock” legal principle. At most, one might say that they are unlikely to enjoy very often extraterritorial protection under the Constitution. Or one might say that the matter is undecided. But this Court has studiously avoided establishing an absolute rule that forecloses that protection in all circumstances.

Breyer explains that Boumediene, which Kavanaugh cited, rejects such a categorical rule.

Nor do the cases that the majority cites support an absolute rule. See ante, at 3. The exhaustive review of our precedents that we conducted in Boumediene v. Bush (2008), pointed to the opposite conclusion. In Boumediene, we rejected the Government’s argument that our decision in Johnson v. Eisentrager, (1950),”adopted a formalistic” test “for determining the reach” of constitutional protection to foreign citizens on foreign soil. This is to say, we rejected the position that the majority propounds today. Its “constricted reading” of Eisentrager and our other precedents is not the law. See Boumediene, 553 U. S., at 764.

The law, we confirmed in Boumediene, is that constitutional “questions of extraterritoriality turn on objective factors and practical concerns” present in a given case, “not formalism” of the sort the majority invokes today.

Well, with AMK in the middle, Boumediene rejected “formalism.” But now “formalism” is the law with JGR in the middle. And five votes endorse Justice Jackson’s observation from Eisenstrager.

Boumediene is basically a dead letter. Never overruled, but currently interred.

Whole Woman’s Health v. Hellerstedt

Whole Woman’s Health was decided in June 2016, shortly after Justice Scalia passed away. The vote was 5-3. Justice Breyer’s majority opinion expanded upon the framework from Planned Parenthood v. Casey: courts should balance two factors: (1) whether the law imposed an “undue burden” on abortion access and (2) whether the law provides an actual benefits. Of course, Justice Kennedy assigned that majority opinion to Justice Breyer. And Kennedy no doubt realized that Breyer was departing from Casey. But 2016 was a bizarre year. Justice Kennedy also reversed his own opinion on affirmative action from Fisher I to Fisher II, that conflicted with his vote in the Michigan affirmative action cases. In any event, 2016 was so four years ago.

In June Medical, Chief Justice Roberts vote to uphold the Louisiana abortion law–and only the Louisiana abortion law. His concurrence casts serious doubt on Whole Woman’s Health. Indeed, he seems to suggest that WWH departed from Casey. Yesterday, I noted:

Going forward, there are five votes to limit the Court’s abortion framework to consider a a law’s burdens, without weighing the law’s benefits.  The Chief has effectively overruled Whole Woman’s Health to the extent it departs from Casey. The Chief didn’t swing to the left; at most, he feinted left for this Blue June.

For reasons unknown, Roberts considers the Casey plurality (three votes) a valid precedent, but the WWH majority (five votes) is not a valid precedent. In any event, Justice Kennedy’s 2017 vote on abortion will be interred. But his 1992 vote on abortion is now, apparently, settled law. Go figure.

Trinity Lutheran v. Comer—Footnote 3

The vote in Trinity Lutheran was deceiving. On its face, the Court split by a 7-2 vote. But the majority was fractured. Justice Breyer only concurred in judgment. Chief Justice Roberts, and Justice Kennedy, Alito, and Kagan joined the majority opinion in full. And Justices Thomas and Gorusch joined the majority opinion, except for Footnote 3. Footnote 3 stated:

This case involves express discrimination based on religious identity with respect to playground resurfacing. We do not address religious uses of funding or other forms of discrimination.

In other words, Trinity Lutheran only concerned a case in which the state denies funding to the church because of its status as a house of worship. The case did not involve a denial of funding to the church because it would use money for “religious uses.” For example, instead of using funds to purchase tire scraps for the playground, the church could purchase funds to purchase books for religious instruction.

In a partial concurrence, Justice Gorsuch, joined by Justice Thomas, wrote that this distinction is flimsy.

First, the Court leaves open the possibility a useful distinction might be drawn between laws that discriminate on the basis of religious status and religious use. Respectfully, I harbor doubts about the stability of such a line.

In any event, the bulk of Trinity Lutheran was precedent, but Footnote 3 was not; it only garnered four votes. And could be disregarded just as quickly. Fast-forward to today, with Espinoza. Chief Justice Roberts wrote a majority opinion that was joined in full.

The Chief flagged the status/use distinction from Trinity Lutheran:

Some Members of the Court, moreover, have questioned whether there is a meaningful distinction between discrimination based on use or conduct and that based on status. See Trinity Lutheran, (GORSUCH, J., joined by THOMAS, J., concurring in part). We acknowledge the point but need not examine it here. It is enough in this case to conclude that strict scrutiny applies under Trinity Lutheran because Montana’s no-aid provision discriminates based on religious status.

Later, Roberts suggested that he was not tied to Footnote 3.

A plurality declined to address discrimination with respect to “religious uses of funding or other forms of discrimination.” Trinity Lutheran at n. 3. The plurality saw no need to consider such concerns because Missouri had expressly discriminated “based on religious identity,” which was enough to invalidate the state policy without addressing how government funds were used.

The key word is “plurality.” Not a majority. It seems that the Chief added Footnote 3 in Trinity Lutheran to assuage Justices Kagan and/or Kennedy. For the Chief, FN 3 was just another move in a game of 87-dimensional chess. He sacrificed a pawn to set up the Espinoza checkmate. Now, three years later, he no longer needs Justice Kennedy’s vote, and will not need to secure Justice Kagan’s on this case.

Trinity, and now Espinoza, also move away from the Rehnquist-Court era decision, Locke v. Davey. Michael Moreland observes that “Chief Justice Rehnquist wrote a narrow, almost case-specific holding (a characteristic Rehnquistian move)” in that case.

Justice Breyer seems miffed that the Court has abandoned the “play in the joints” line from Locke:

Although the majority refers in passing to the “play in the joints” between that which the Establishment Clause forbids and that which the Free Exercise Clause requires, its holding leaves that doctrine a shadow of its former self.

He’s right. There is no longer any need to appease Anthony Kennedy or Sandra Day O’Connor.

Going forward, I presumptively treat any 5-4 decision with Kennedy in the majority as persuasive, at best.

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UCLA Academic Freedom Committee Statement Related to the Gordon Klein Controversy

Just posted by the UCLA Academic Senate Committee on Academic Freedom, about the controversy discussed here on June 10:

Statement of the Academic Freedom Committee

June 30, 2020

In response to a recent controversy surrounding an e-mail reply to a student by Gordon Klein (a Lecturer in Accounting at the Anderson School), the UCLA Senate Committee on Academic Freedom underlines all instructors’ freedom (protected by APM-010) to express their views on grading policy as they determine to be appropriate.

Some people may well disagree with Prof. Klein’s views, and think that he should have responded differently to a student’s request that the grading structure be changed to “exercise compassion and leniency with Black students in our major.” But instructors are entitled and empowered to say “no” to such requests;[1] and, just as students have every right to express their views on such matters to faculty and to others, instructors are entitled to explain their views in turn to students. When any of us ask people to do things, especially based on a moral or political argument about current events, those people are entitled to respond with their own moral or political views.

The process of evaluating the situation is proceeding at the Anderson School, and our committee has no direct role in that process. Our concern instead is that any public announcement that an instructor is being placed on administrative leave for what appears to be a particular statement—whether the statement happened in class, in an e-mail responding to a student, on social media, or wherever else—creates a chilling effect for other instructors, especially untenured ones. It is the committee’s role to try to prevent such chilling effects.

An academic institution like UCLA must remain a place for the expression of a wide diversity of views and interpretations. It should also be a site of vigorous debate—including by students, by faculty, and by others—so that those exposed to or participating in these discussions have the opportunity to hear a range of opinions as they formulate their own views.

[1] See, e.g., Academic Senate Memo on Spring 2020 Final Exams, which reaffirms that instructors have “the flexibility to change their method of final assessments” so long as the final grade “reflect[s] the student’s achievement in the course” and is “based upon adequate evaluation of the achievement,” but does not require instructors to make any particular changes.

Disclosure: I am one of the several members of the Committee.

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The Problem With Government “Contact Tracing”

The Problem With Government “Contact Tracing”

Tyler Durden

Tue, 06/30/2020 – 19:25

Authored by James Ketler via The Mises Institute,

As states move through phases of reopening, “contact tracing” has remained a topic of national interest. For months now, talking heads in the government and media have hailed the strategy as the country’s saving grace. One NBC headline read, “Coronavirus contact tracing could stop COVID-19 and reopen America,” and a CNN article declared, “the US — or really any country — can’t safely reopen without significant amounts of contact tracing and testing”.

With this starry-eyed perception, dozens of states have rushed to train and hire tens of thousands of contact tracers – what former CDC director Tom Frieden gleefully described as an “army” of tracers. 

It’s true that contact tracing has been an indispensable asset many times in the past – helping to snuff out viruses by diligently tracking their spread. So it’s no mystery why some health experts are flocking to it in the current crisis. 

In short, this is how it works: contact tracers conduct short, over-the-phone interviews of newly-diagnosed patients about who they have recently been in close, physical contact with. The fear is that these recent contacts could have contracted the virus from the patient before he was diagnosed. These contacts are then phoned by tracers, informing them of this risk and encouraging them to seek testing and self-quarantine immediately. Tracers continue this process on down the line, with the aim of reducing the instances where the virus is transmitted

A few states have also begun developing smartphone apps to conduct a digital form of contact tracing. Phones running the app exchange unique, encrypted numbers via Bluetooth, which are then stored on their devices. If an app user is diagnosed with COVID, he’s supposed to notify the app, which then publishes the log of numbers his phone received in the last fourteen days. If one of these numbers matches one stored on the device of another user, the app will send that user an alert that he’d been in recent contact with a newly-diagnosed COVID patient. 

So far, the adoption of these apps has been left completely voluntary in the US, unlike other countries like China and South Korea. Overall, though, most of the states have yet to show much excitement towards digital tracing. The main focus remains on building an “army” to track the virus’ spread, no matter what it might cost the country.

Financial Costs

Contact tracing job positions are temporary—lasting for months or up to a year, with annual salaries ranging from $40,000 to $70,000. Those numbers are about on-par with the entry-level salaries of registered nurses, for a job that anyone completing a free, six-hour course can be hired for. Few, however, have questioned whether such pay is excessive or this use of taxpayer money prudent. It’s all been blindly okayed under the hallowed pretense of “public health”.

With experts recommending that the country hire a total of 150,000 contact tracers, these programs may end up costing the states somewhere between $1 billion and $10.5 billion altogether. On top of that sum lie whatever additional costs the handful of states developing digital tracing apps incur. Worse, bills currently floating around the House and Senate would, if made law, establish a federally-led contact tracing program with a price tag as high as $100 billion. To government budget-breakers, that may just look like zeros and decimal places, but there’s a serious economic toll to be reckoned with. 

Increased government spending is often accompanied by a rise in taxes, and almost always by an expansion of the money supply. In either case, people’s wealth is subsequently decreased. Individuals and their families must, accordingly, cut back on the amount of money they save, which in turn decreases the stock of loanable funds from the level that would have otherwise been available. As a result, the amount of investment in the economy falls, dulling the momentum of economic growth. That could severely dampen the economy’s post-recession recovery. 

In our present crisis—unlike any before—many businesses were shut down for months not by economic circumstance, but by state decree. That contributed to the sharpest ever employment crisis in the US, with more than 20 million workers being cut from payrolls in April alone. Some of these cuts were temporary furloughs, but a part of that number reflects permanent job loss—either from companies being forced to slash operating costs or going bankrupt outright.

Some of the proponents of the state’s contact tracing programs see themselves as killing two birds with one stone—helping to eliminate COVID, while also putting people back to work. Senator Kamala Harris (D-CA) made this clear when stumping for the federal contact tracing bill she co-sponsored: “Our policies must meet the needs of the current moment, and that means getting creative about how we get people back to work”. 

But government jobs programs don’t actually create employment in any way besides superficially. The reality is that they siphon labor away from potentially productive ventures at wages propped up at artificially high rates. This too will defer the economy’s recovery and must—for the good of private enterprise—be halted immediately. But by the looks of it, the program will continue forward uninterrupted, as it plays perfectly into the narrative that the state can solve all of society’s ills—no matter what the economics and epidemiology really say about it.

Public Health Doublethink

Much of how the public should respond to the virus hinges on the question of how common asymptomatic transmission of it is. Unfortunately, the research available on this is limited and contradictory, allowing cunning politicians to play both sides of the fence in order to get their way.

Some early findings suggest that the virus undergoes considerable shedding in patients not showing symptoms, meaning that asymptomatic transmission is indeed common. Viewed through this narrow lens, it would seem that there’s cause to worry. However, the data suggesting the prevalence of asymptomatic transmission is ultimately rather paltry, and there’s evidence pointing to the contrary.

WHO spokeswoman Maria van Kerkhove recently claimed that based on “a number of reports from countries who are doing very detailed contact tracing,” asymptomatic transmission is “very rare”—directly contradicting what public health officials had long assumed about the virus. If the risk of contagion remains low until after symptoms appear, patients are far less likely to spread the virus to others. This notion too, though, is based on data that is, as of yet, incomplete, leaving the question of asymptomatic transmission unsolved and open to further inquiry. But whatever the underlying reality is, a significant problem must inevitably emerge for defenders of the government’s pandemic response efforts. 

At the outset, governors imposed the lockdowns for fear that asymptomatic carriers were spreading the virus. Since anybody could unknowingly be infected and contagious, lockdowns were put in place as a proactive quarantine on the entire population. But according to Dr. Don Printz, a former research leader at the CDC, if there’s “shedding 2-5 days before any signs or symptoms, I would think [contact tracing] would be almost impossible”. Indeed, with an incubation period lasting between two and fourteen days, many patients would remain contagious for a long time without ever showing symptoms. New chains of transmission would easily emerge, generating exponential growth in the number of new cases. By the time contact tracers tried to map the probable path of transmission, the virus would have already spread to a number of other people—and on and on after that. 

On the flip-side, if asymptomatic transmission is “very rare,” as van Kerkhove asserted, contact tracing may be a successful strategy. If only symptomatic patients are spreading the virus, though, the whole rationale for the lockdowns is then completely destroyed. For all the economic, political, social, and psychological damage the lockdowns caused, they would have yielded absolutely no public health benefit. It boils down to this: it’s either (1) that the lockdowns were effective or (2) that the contact tracing is effective, but politicians can’t have it both ways. 

Still, the government’s big-spenders have pushed forward without delay. In fact, they’ve doubled down on their self-contradictions. The CDC, for instance, declared that “asymptomatic transmission enhances the need to scale up the capacity for … thorough contact tracing”. That is, of course, a repetition of the perennial call for more funding—oh, how our problems would disappear if only we spent more. Funneling more money towards programs that are inherently faulty won’t lead to better or more effective results, but to programs just as faulty, only with larger personnels.

Trying to Trace COVID Probably Won’t Work Anyway

Even casting aside politicians’ obvious public health duplicity, their contact tracing plans don’t stand up to scientific scrutiny. Whatever the case with asymptomatic transmission may be, COVID’s characteristics pose contact tracers unique and probably insurmountable challenges, leaving the US’ tracing “army” already besieged.

The first problem is that catching COVID is not activity-specific, unlike other viruses like, say, HIV. Anyone in close proximity to a contagious COVID patient is at-risk for inhaling virus-ridden droplets that had been coughed, sneezed, or breathed out—it doesn’t matter where people are or what they’re doing. That suggests that the virus may often be transmitted between complete strangers, in which case contact tracing is rendered impossible, as tracing relies upon patients recalling their recent contacts. 

This has only been exacerbated over the past month with the Black Lives Matter riots springing up across the country—a perfect storm for the virus’ spread. Research has shown activities like yelling, singing, and chanting to extend the distance that infectious droplets are spewed into the air. Not only does this lead to more new cases, but it also makes it much more difficult—even impossible—for tracers to figure out who passed the virus to whom.

The second problem arises once symptoms begin to show. The way COVID manifests itself is multifarious, with some patients only exhibiting irregular symptoms not usually associated with the virus, like loss of smell, rash, and delirium. Many of its key symptoms—including dry cough, fever, and shortness of breath—are found in a variety of other illnesses, further muddying the waters. That leaves gaping holes in the health record and may lead to new, hard-to-trace outbreaks.

Though meant to increase efficiency and efficacy, digital tracing apps are also riddled with significant problems. If the apps aren’t downloaded by enough residents, many may easily fall through the cracks and infect others. The apps only confer public health boons if they’re in common and widespread use. But today, nearly 20% of Americans still don’t own smartphones and a recent poll indicated that only half of those who do would consider downloading a tracing app. And that’s not even to mention the fact that people don’t always have their phones on their person, meaning that many interactions could take place untraced and under the radar.

In focusing entirely on proximity, digital tracing continues to get it wrong. Indoor air flow poses a risk of spreading infectious droplets across rooms and throughout entire buildings—far beyond the six-foot proximity the apps look for. This summer, that risk may be augmented by AC ventilation. Then there’s also the risk of touching infected surfaces, which may harbor traces of the virus for hours or up to a few days. The apps simply can’t account for this sort of spread, chipping further away at their overall effectiveness.

Moreover, there are some instances where people who are physically close together are extraordinarily unlikely to become infected, like in a supermarket checkout line, separated from the clerk by a plexiglass shield. Nonetheless, this would trigger an alert to be sent to people’s phones, warning them of possible COVID exposure with no further explanation—triggering a false alarm and probably a lot of worry and confusion. Divorcing the human factor from the process takes an undeniable toll on its reliability, when it was never that reliable in the first place.

Why should anyone still have faith in the government when it’s made fatal stumbles at every step of the pandemic? Public health officials were unable to stop the first instances of community spread of COVID in late January and even remained in denial that the virus was spreading uncontrollably until the end of February. The notion that contact tracing is right now serving as a useful strategy in the US—with active cases hovering around 1 million—is preposterous.

Officials may feign confidence in the decisions they make, but that’s fueled by pure optics, not science. Across all fifty states, these programs are on track to reroute billions of dollars and more than one hundred thousand workers away from otherwise valuable uses. And for what? All to spin our wheels and sink into a false sense of hope and security.

via ZeroHedge News https://ift.tt/38fgmgZ Tyler Durden

Trump Never Briefed On Unvetted Russian Bounty Intel Because NSA “Strongly Dissented”  

Trump Never Briefed On Unvetted Russian Bounty Intel Because NSA “Strongly Dissented”  

Tyler Durden

Tue, 06/30/2020 – 19:05

On Tuesday, the same day that Joe Biden finally emerged to hold his first press conference in 89 days in order to lash out at what he called Trump’s “dereliction of duty” over the NY Times Russian bounties for Taliban militants to kill American troops in Afghanistan story, The Wall Street Journal issued this bombshell:

The National Security Agency strongly dissented from other intelligence agencies’ assessment that Russia paid bounties for the killing of U.S. soldiers in Afghanistan, according to people familiar with the matter.

The disclosure of the dissent by the NSA, which specializes in electronic eavesdropping, comes as the White House has played down the revelations, saying that the information wasn’t verified and that intelligence officials didn’t agree on it.

NSA headquarters in Maryland, file image.

As we noted before, it appears a return this week to mainstream media’s prior years of near daily breathless Russiagate reporting, with “anonymous intelligence sources” issuing new leaks of unvetted raw intel to the press.

The WSJ points out that it was primarily the NSA’s firm dissent that kept the Russian bounties allegation out of the president’s daily briefing  which both further confirms the White House’s denials of the initial Friday Times reporting, as well as contradicts the NYT “revelation” itself. 

Because of that [NSA dissent], President Trump was never personally briefed on the threat, the White House said, although a key lawmaker said the information apparently was included in written intelligence materials prepared for Mr. Trump,” WSJ underscores.

No details were given as to precisely how the NSA differed in its assessment of the Russian bounty allegations. For those keeping score, this marks the third major formal distancing from the substance of the NYT reporting by US intelligence agencies and intel community leadership.

Also recall this isn’t the first instance of significant NSA pushback concerning explosive charges aimed at Russia: 

On Saturday Director of National Intelligence John Ratcliffe said in a statement that he had “confirmed that neither the President nor the Vice President were ever briefed on any intelligence alleged by the New York Times in its reporting.” 

CIA Director Gina Haspel also appeared to vindicate the White House’s assertion of lack of credible intelligence behind it in a Monday statement. Essentially the CIA director seemed to reference the danger of “cherry-picking” from lower level unvetted raw information.“When developing intelligence assessments, initial tactical reports often require additional collection and validation,” Haspel said.

“Leaks compromise and disrupt the critical interagency work to collect, assess, and ascribe culpability,” she added, strongly suggesting that indeed there was not enough to go on concerning the Russian bounty allegations for it to rise to the level of the commander-in-chief. In actually this was further a CIA condemnation of the “anonymous” leakers out of which the whole narrative was spun. 

via ZeroHedge News https://ift.tt/3gezUF3 Tyler Durden

Think The “Cancel” Mobs Can’t Get Any Worse? Think Again

Think The “Cancel” Mobs Can’t Get Any Worse? Think Again

Tyler Durden

Tue, 06/30/2020 – 18:45

Authored by Harlan Hill via RealClearPolitics.com,

America is in the midst of one of the great moral panics in our nation’s history. If we don’t stand up for our nation’s core values, the situation could get even worse – and soon. If you’ve spent any time on social media in the last three weeks, you’ve probably noticed the organized campaigns to get college and even high schoolstudents expelled or denied admission based on their political views. You’ve also seen gleeful mobs celebrating as Americans lose their jobs for running afoul of someone’s momentary political obsessions.

In every sector of American society, people are having their careers destroyed to the pitiless baying of the “woke” masses. It’s happening in business. CrossFit CEO Greg Glassman spent 20 years building the fitness brand into a multi-billion dollar company, only to be thrown out of the empire he built for declining to go along with the “racism is a public health crisis”  dogma.

It’s happening in journalism. New York Times editor James Bennet, a liberal, was fired for publishing an op-ed by a sitting Republican senator advocating for a military response to nationwide rioting — a position the majority of Americans agreed with. The same fate befell Philadelphia Inquirer editor Stan Wischowski, who was terminated for approving an article that condemned looting and arson.

It’s happening in entertainment, in academia, and pretty much anywhere someone can be found who is not sufficiently supportive of the Black Lives Matter movement.

It’s even happening to people who didn’t do anything at all. An L.A. Galaxy soccer player was forced to resign because his wife tweeted that rioters should be shot. A lawyer in San Francisco was fired because his wife was rude to a man she thought was spray-painting BLM propaganda on a building that wasn’t his (it was). On Thursday, this Stasi-esque trend reached another level when a company called Equity Prime Mortgage fired the stepmother of the officer charged in the controversial shooting of drunk driver Rashad Brooks after he fought with and fired a taser at police. The stepmother was apparently fired for no reason other than family loyalty.

On Monday, the panic reached what one can only hope will be its peak when a San Diego Gas and Electric employee lost his job for “making a white supremacist hand gesture.” We’ve long since debunked the notion that the OK sign is somehow racist — that was just a fiction perpetrated by internet trolls — but in this case, this man lost his livelihood despite the fact he wasn’t even making an OK sign. He was apparently cracking his knuckles as he drove.

What America is going through right now is not merely another, more intense round of “cancel culture.” We’re now in the midst of a full-force, totalitarian remolding of our society, one that seeks to place the petty resentments of an outraged minority of leftist activists above everything else in American life. Because of their willingness to riot, loot, and assault anyone they perceive to be insufficiently sympathetic to their cause, leftists are able to bully ordinary people into submission. As a result, television shows such as “Cops” and “Live PD,” classic films such as “Gone With the Wind,” and iconic brands such as Aunt JemimaMrs. Buttersworth, and Uncle Ben’s rice are consigned to the “dustbin of history.”

I used to speak frequently to nervous conservatives who were convinced that if we only allowed the left to tear down Confederate war memorials, they would be satisfied. How quickly events have disproved that wishful thinking. From Christopher Columbus, George Washington, Thomas Jefferson, and the western pioneers, activists are now coming after cartoon sports mascots and college fight songsEverything — from the core of our country’s history to the values and norms undergirding American culture — must be uprooted to appease the mob. 

They are tearing down dozens of statues and facing no consequences whatsoever for vandalizing our public spaces — including memorials to our nation’s greatest heroes. When private citizens try to do the job the government won’t and protect our culture, our history, and our public property from destruction, local officials step in and remove the statues on behalf of the vandals, lest they injure themselves while imitating Iraqis celebrating the fall of Saddam Hussein.

These people are not seeking change at the margins. They are demanding a total cultural revolution, and cowardly public officials are giving it to them. If you look at this national outpouring of hatred and recrimination with horror verging on despair, I assure you that you are not alone. Tens of millions of Americans feel exactly the same way.

President Trump is doing exactly what an American president should do in a crisis like this. He is working to maintain law and order and prevent cowed local officials from allowing political violence to flare again. He issued an executive order to add to his legacy of reform and address legitimate concerns about law enforcement in this country. He also issued a separate executive order targeting the systemic bias in Silicon Valley’s censorship offices, which has allowed our social media platforms to become echo chambers for left-wing extremism and “cancel culture.”

The only thing that could make the situation worse at this moment would be handing the White House to a doddering and unprincipled establishment politician beholden to the “cancel culture” mob. Presumptive Democratic nominee Joe Biden would immediately delegate de facto control over the vast justice, civil rights, and regulatory apparatus of the federal government to the loudest voices in his coalition: the woke activist class.

At this moment, there is a veritable army of lawyers and bureaucrats who have spent the last three and a half years subsisting on resentment and salivating at the prospect of regaining power. Things are bad enough now, but conditions will become much worse if the “cancel culture” born on social media is augmented with the force of law and given the full attention of Biden appointees imbued with the sweeping powers of the federal bureaucracy.

Dark forces have been unleashed in this country. Even now, we are only seeing the tip of the iceberg. If we don’t want to find out how much damage it can inflict on the ship of state, we must prevent those forces from taking control of the federal government.

via ZeroHedge News https://ift.tt/3dL0MuM Tyler Durden