A University Tries to Evade an Open-Records Request By Invoking…the Copyright Act?

What's Latin for "legal sophistry"?The National Council on Teacher
Quality (NCTQ) conducts studies of the country’s teacher
preparation programs. Some educators don’t
think much
of its methodology; I don’t have an opinion about
that. What bothers me is when schools do not merely criticize the
group’s work but twist the law to keep the group from studying them
in the first place. Especially if they create a precedent in the
process that can be used to shield still more public
institutions from the public’s eyes.

That’s what the University of Missouri is doing. First it
refused to provide the NCTQ with the syllabi its education
professors use. When the group pointed out that this conflicted
with the state’s Sunshine Law, the school argued that this was
immaterial because a syllabus is a professor’s intellectual
property.

At this point, you might be thinking: Wait a minute. Even if
I accept the idea that a teacher owns his syllabus, how does it
violate his copyright to share the document with someone who has no
plans to publish it?
The Missouri Court of Appeals, which
sided
with the university in August, offers this answer:

[I]n order to disclose the syllabi as requested by the
NCTQ, the University would have to reproduce and distribute the
syllabi. Thus, while the Federal Copyright Act does not explicitly
protect against disclosure, it does protect against the means by
which the requested disclosure would be obtained.

Under this interpretation of the law, the university may be
required to let people inspect its syllabus in person, but it can
refuse to make copies. The court denied the obvious—that this makes
it easy for transparency-averse bureaucrats to impose new costs on
researchers—by claiming that if this were so, the practice “should
have run rampant by now.”

The judge backed up that odd argument by noting that the state
attorney general had opined way back in
1987 that the federal Copyright Act limited Missouri’s
disclosure law, and that the floodgates of obstructionism did
not open. But that 27-year-old statement emerged from a rather
different situation, when some libraries wanted to know if they
could enter a contract with a cataloging service that restricted
how its material could be used. If other agencies did not leap on
the opinion to protect their own documents, that may be because,
until now, it did not occur to any of them that they could do
so.

The NCTQ is
appealing
the decision. The group had to file similar suits in
Minnesota, where the courts
ruled
in the researchers’ favor, and in Wisconsin, where the
university system and the researchers eventually
reached an agreement
.

For further reading: Michael Podgursky, who teaches
economics at the University of Missouri,
denounces
the “absurd legal fiction that the syllabi
distributed to 35,000 MU students cannot be disclosed to an
organization making use of the state’s Sunshine laws.” George Leef
of Forbes
asks
whether faculty members really own those copyrights to
begin with.

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Argentine Stocks Continue Crash After Last “Moderate Voice” Resigns

The Argentina MERVAL stock index is down 16.5% since yesterday's news of the resignation of the last voice of reason among Argentina's policy-makers. As we noted previously, "this is not a good sign" and indicates a worrying escalation in the chances of hyperinflation..

 

This is the MERVAL's worst 2-day drop in 6 years.

"Fabrega was perceived to be a moderating voice and someone that really understood financial market dynamics."

What some money-printing gives, too much money-printing takes away…




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Why The Fed Is Full Of It: Reverse Repo Is A Fairy Tale

As we explained previously, the end-of-quarter catastrophe in reverse-repo window-dressing malarkey between The Fed and The Banks (that own it) shows the Fed simply has no idea (once again) how financial markets really work in the modern era. As Alhambra Partners Jeffrey Snider explains, “We don’t exactly know how it will work” should be stamped upon every message coming from the policymaking apparatus from this point forward, and then retroactively applied to every message in the age of risk and rate repression. Action in short-term money markets has heated up yet again, and that is not a positive statement toward vital function.

 

As we noted previously, at $407 billion, it far exceeded the $300 billion new cap on the program.

So yes: everyone can now admit that Reverse Repo was nothing more than Fed-mandated window dressing, no point in covering that up any more.

It is now empirically proven that the Reverse Repo is now meaningless and doomed as a means to allow the Fed to hike rates in a world in which the Fed Funds rates is irrelevant, and a parallel rate corridor somehow has to be established. Which means that only the IOER fallback exists, a rate hike environment fallback which as we wrote back in 2012 is also meaningless as it only controls for one half of the rate increase corridor.

So… still betting on a rate hike in mid-2015, when the Fed itself has just admitted, and the market has confirmed, it has no clue how it will hike rates?

*  *  *

And Jeffrey Snider of Alhmabra Partners, explains how The Fed's Reverse Repo is a fairy tale…

“We don’t exactly know how it will work” should be stamped upon every message coming from the policymaking apparatus from this point forward, and then retroactively applied to every message in the age of risk and rate repression. Action in short-term money markets has heated up yet again, and that is not a positive statement toward vital function.

To “exit” from monetary policy as corruptive as it has been, the FOMC and its staff believes a European-style policy framework is “needed.” It is not to be an exact replica, mind you, only the general idea borne out under decidedly American conditions and characteristics. The Fed is trying to build a rate corridor where one never existed, and I would contend never should.

Part of the reason is that the federal funds rate applies less and less to anything of any import, more a relic than a policy measure. After 2007, unsecured overnight lending has been far more of a dream than anything of operational concern, thus the vastly increased relative importance of secured wholesale finance, i.e., repo. To get from fed funds targeting to repo is not an easy leap, particularly since we are again introducing the discrepancy of dollars vs. interbank currency (where it is often difficult to discern which one is more money-like at any one point in time).

The reverse repo program was supposed to provide “aid” toward establishing a hard(er) floor for rates. It obviously failed with the persistent spikes in repo fails, which denote effective repo rates at something between 0% and -3% (and closer to the latter than the former). Collateral, that interbank currency, is not getting out of the Fed “silo” (its vast SOMA holdings) to conduct business as needed.

Back in August, some FOMC comments in this direction show just how much they rely on unproven theory:

Officials plan to use the rate of interest the Fed pays on excess reserves deposited at the central bank as the “primary tool used to move the federal funds rate into its target range” while “temporary use” of the overnight reverse repo facility will be employed to “help set a firmer floor,” according to the July FOMC meeting minutes.

 

“If we can move those three rates in tandem, then I think it will be pretty clear signaling to markets as to where the Fed stands and where short-term interest rates stand,” Bullard said. “We’ve never done this before, so we don’t know exactly how it will work, but I do think that we are in pretty good shape.” [emphasis added]

They already had more than a little whiff of failure in repo fails, so the statement above was already stale at the point it was issued. They can try to convince themselves that repo fails are strictly limited to the size of the short position in UST, but that is largely irrelevant – it matters not why there is demand for collateral, the only focus should be on why the “market” cannot meet said demand. If an imprint of short selling in UST, expecting rates to rise (which I don’t buy as the primary problem in repo right now, at all!), can rattle repo as it has, then that is very a concerning sign for when there is much more demand for collateral under real, true strain; a condition that is inevitable.

As if that needed reinforcement, the quarter-end at the reverse repo “window” has shocked some of these same theorists. Not only were the bids well-past the “ceiling” set in the middle of September, the tendered rates left the issue at zero, 5 bps below the supposed floor – with who knows how much bid as low as -0.2%.

Most of the commentary so far has revolved around the $300 billion cap, which the Wall Street Journal explained back when it was announced:

The daily cap also seems to suggest the Fed is mindful of rising concerns that it is becoming the dominant destination to invest cash short term, displacing private-sector financial firms.

That is certainly a significant issue, but it also highlights the inherent contradiction in the Fed’s operations right now. They don’t want to be the dominant destination, but clearly they are. Which raises perhaps the more important issue, as to why predominantly MMF’s might be bidding -0.2% to “lend” “dollars” to the Fed on a collateralized basis (hint: because someone was speculating that they could get Fed collateral and flip it out at an even more negative rate to someone else who needed the UST that badly; in other words, we almost have the situation where a MMF or some other non-bank is aggressively bidding to “lend” cash at a negative rate to the Federal Reserve in order to “borrow” cash at an even lower negative rate, all done so that some piece of UST collateral can actually become mobilized and useful instead of frustratingly idle as QE has it; why do we have serial bubbles again?). I can no longer think of this as anything but the theater of the absurd.

As another point in that projection, the general collateral rate yesterday was also negative, fully disproving, yet again, the reverse repo as an effective floor. Which brings about reminiscences of the father of all this, the great bubble-maker who turned monetary policy into soft central planning relying more and more on these kinds of esoteric and really deluded operations to maintain just the illusion of control:

One is that I don’t think we know enough about how the private financial system works under these conditions. It’s really quite important to make a judgment as to whether, in fact, yield spreads off riskless instruments – which is what we have essentially been talking about – are independent of the level of the riskless rates themselves. The answer, I’m certain, is that they are not independent. But how their dependency functions and how those spreads behaved in earlier periods is something I think we’ll need to know more about. The reason is that I don’t believe, as I said before, that we can construct an effective preemption strategy. Well, we can construct a strategy, but I’m fearful that it would not be very useful.

That was from the June 2003 FOMC transcript, where Alan Greenspan was addressing the possible downside of actually getting to the zero lower bound (“these conditions”). His candor was very much in opposition to his public persona, which was probably due to the time-delay between that discussion and its actual public release. Ben Bernanke, however, was in no shortage of confidence at that meeting, though he too speculated on what sounds an awful lot like the reverse repo problem, “…it [zero bound interest] works through mechanisms that depend on the imperfect substitutability of different assets.”

Getting it all to “unwork” is just as challenging, as he found out somewhat the hard way almost from the start with QE2’s disruption of bill supply. Substitutability was a huge problem and it did not answer as directly as he thought back in 2003 – that was the entire point of Operation Twist, to stop stripping all the bills out of the marketplace.

I said this before and I think it applies very well right now in light of these recent developments, the Fed does not know what it is doing. They don’t. They want you to think they do because that is the entire point of monetary policy to begin with. However, QE’s came with very real costs which they were willing to bear in the tradeoff of a robust economy – good and solid growth fixes many ills, inconsistencies and even downright false equivalences. That never happened, so the pressure is that much greater to maintain the message of credibility, particularly as all these markets depend so much on the “dominant destination”, Greenspan/Bernanke/Yellen.

If the system does not function as intended now, under if not ideal circumstances than certainly far from stressed, how is it going to perform under real strain and duress? Might that be a significant factor that is beginning to wind its way into the larger dollar system, the venue of the global dollar short? This bears repeating, maybe even included after the perpetual warning I asserted above, that liquidity is not what is evident right now, but what is expected when the things are really going wrong. “We don’t know exactly how it will work” is a hell of a liquidity program for that eventuality.




via Zero Hedge http://ift.tt/1rPRgM9 Tyler Durden

Is This Why Christine Lagarde Is Suddenly “Quite Worried” About Disconnect Between Market, Economy?

It appears the ruling elite have finally woken up to the reality in which the rest of the world’s laboring populace has been living. IMF head Christine Lagarde stated this morning she is “monitoring buoyant markets” with “lots of hesitation” while noting “weak economies.” We have one simple question for the oompa-loompa-colored ‘economic expert’ – what took so long?

  • LAGARDE SAYS DISCONNECT BETWEEN MARKETS, ECONOMY ‘QUITE WORRYING’
  • LAGARDE SAYS FED’S QE POLICY HAS ‘DONE MUCH TO AID RECOVERY’

You decide!

 

And then there’s this…

  • LAGARDE SEES WORRY MARKET, LIQUIDITY RISK MOVING TO ‘SHADOWS’
  • LAGARDE: GLOBAL RECOVERY `BRITTLE, UNEVEN AND BESET BY RISKS’
  • LAGARDE: WORLD ECONOMY NEEDS BOLD MOVES TO AVOID `NEW MEDIOCRE’




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Netflix Aims to Reinvent the Movie Business With Some Help From Adam Sandler

First it went after television.
Now Netflix is going after movies. Adam Sandler is involved. It’s
the future of cinema, people. Better get used to it.

The streaming online video company, which has helped
revolutionize delivery models and viewing habits for television
series, announced two separate deals to produce and distribute
original feature films this week, one of which—a sequel to 
the Oscar-winning 2000 martial arts epic Crouching Tiger,
Hidden Dragon
—will also
hit some movie theaters
on the same day it goes out to Netflix
subscribers.

The other deal involves the production of four new Adam Sandler
movies, reportedly with budgets comparable to his traditional
studio releases, which typically cost $40 million or more.

Why did Sandler take the deal? Here’s his explanation,
via
The New York Times: “When these fine people came
to me with an offer to make four movies for them, I immediately
said yes for one reason and one reason only….Netflix rhymes with
Wet Chicks.”

It’s that sort of brilliant verbal wit, folks, that makes
Sandler such a comedic force to be reckoned with.

An alternative explanation is that Sandler’s last few movies
haven’t performed very well at theaters—but his movies are,
apparently, hugely popular on Netflix. According to the
Times, Netflix noticed how strong the numbers were for
Sandler’s movies on the service and approached the actor through
his agent about making a production deal.

The Sandler deal suggests the promise (and, okay, the peril) of
all-online, all-on-demand media, in which users not only choose
exactly what they want to see but leave a perfect digital record of
their choices. That means that entertainment companies can make
deals that more accurately capture and reflect the interests of
their customers, and that products—and let’s be clear, Sandler, the
movie star, is a product—that don’t or no longer have the mass
appear to make it at the box office can find other homes.

This touches on some of the issues involved in both media
ownership and Internet privacy debates as well: A company like
Netflix obviously collects an awful lot of data on its users, well
beyond the ratings that users submit about their tastes. But
collecting all that data allows Netflix to know its customers
better, and to create products they are more likely to enjoy. Other
studios would have a harder time doing business this way, in part
because they can’t collect data on viewership quite as easily, and
in part because they don’t have the built in distribution network
that Netflix has. (HBO is probably the closest competitor, and
certainly when it comes to original television series, it blazed a
trail for Netflix to follow and expand upon.)

The Crouching Tiger deal, on the other hand, is pretty
clearly aimed at helping to, ah, degrade and eventually destroy the
power of the big movie theater chains. The movie itself is not
unimportant, but what Netflix really wants to crack are the
distribution windows that give the theater industry a three-month
exclusive on most big releases. That’s why a big component of the
deal is simultaneous distribution on IMAX screens, many of which
are located in chain theater locations, but are operated somewhat
independently.

As Netflix chief content officer told The New York
Times
, “What I am hoping is that it will be a proof point that
the sky doesn’t fall. These are two different experiences, like
going to a football game and watching a football game on TV.”

The theater chains are
not happy about this
, and at least two have already
indicated
they won’t allow the movie to play on their screens.
So it may be that we’re in for a protracted business battle over
release windows and distribution rights.

Fundamentally, what’s happening here is that Netflix is taking
aim at the movie business in much the same way it took aim at the
television business—attempting to upend the old models and systems
that have dominated Tinseltown for so long. Whether or not Netflix
gets everything it wants, it’s eventually likely to shake up the
movie industry somehow. In the meantime, if the transformation of
the movie industry looks anything like the transformation of
television, we’ll benefit as consumers from the competition.

I have a long
look at how HBO, Netflix, ad-supported cable and others helped
reshape television programming
, and save it from decades of
public-interest focused awfulness, in Reason’s new,
TV-themed print
edition.

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Top Doctors: Ebola May Become Airborne … And May ALREADY Be Transmissible Via Aerosols

Michael T. Osterholm – director of the Center for Infectious Disease Research and Policy at the University of Minnesota – wrote in the New York Times last month:

Viruses like Ebola are notoriously sloppy in replicating, meaning the virus entering one person may be genetically different from the virus entering the next. The current Ebola virus’s hyper-evolution is unprecedented; there has been more human-to-human transmission in the past four months than most likely occurred in the last 500 to 1,000 years. Each new infection represents trillions of throws of the genetic dice.

 

If certain mutations occurred, it would mean that just breathing would put one at risk of contracting Ebola. Infections could spread quickly to every part of the globe, as the H1N1 influenza virus did in 2009, after its birth in Mexico.

 

Why are public officials afraid to discuss this? They don’t want to be accused of screaming “Fire!” in a crowded theater — as I’m sure some will accuse me of doing. But the risk is real, and until we consider it, the world will not be prepared to do what is necessary to end the epidemic.

 

In 2012, a team of Canadian researchers proved that Ebola Zaire, the same virus that is causing the West Africa outbreak, could be transmitted by the respiratory route from pigs to monkeys, both of whose lungs are very similar to those of humans. Richard Preston’s 1994 best seller “The Hot Zone” chronicled a 1989 outbreak of a different strain, Ebola Reston virus, among monkeys at a quarantine station near Washington. The virus was transmitted through breathing, and the outbreak ended only when all the monkeys were euthanized. We must consider that such transmissions could happen between humans, if the virus mutates.

The Guardian reports today:

There is a ‘nightmare’ chance that the Ebola virus could become airborne if the epidemic is not brought under control fast enough, the chief of the UN’s Ebola mission has warned.

 

Anthony Banbury, the Secretary General’s Special Representative, said that aid workers are racing against time to bring the epidemic under control, in case the Ebola virus mutates and becomes even harder to deal with.

But perhaps most challenging to the mainstream assumption that Ebola can only be spread through physical contact with a person who is showing symptoms of infection is the following explanation by two national experts on infectious disease transmission, both professors in the School of Public Health, Division of Environmental and Occupational Health Sciences, at the University of Illinois at Chicago (footnotes omitted):

We believe there is scientific and epidemiologic evidence that Ebola virus has the potential to be transmitted via infectious aerosol particles both near and at a distance from infected patients, which means that healthcare workers should be wearing respirators, not facemasks. [Aerosols are liquids or small particles suspended in air. An example is sea spray:  seawater suspended in air bubbles, created by the force of the surf mixing water with air.]

The important points are that virus-laden bodily fluids may be aerosolized and inhaled while a person is in proximity to an infectious person and that a wide range of particle sizes can be inhaled and deposited throughout the respiratory tract.

 

***

 

Being at first skeptical that Ebola virus could be an aerosol-transmissible disease, we are now persuaded by a review of experimental and epidemiologic data that this might be an important feature of disease transmission, particularly in healthcare settings.

 

***

 

Many body fluids, such as vomit, diarrhea, blood, and saliva, are capable of creating inhalable aerosol particles in the immediate vicinity of an infected person. Cough was identified among some cases in a 1995 outbreak in Kikwit, Democratic Republic of the Congo, and coughs are known to emit viruses in respirable particles. The act of vomiting produces an aerosol and has been implicated in airborne transmission of gastrointestinal viruses. Regarding diarrhea, even when contained by toilets, toilet flushing emits a pathogen-laden aerosol that disperses in the air.

 

***

 

There is also some experimental evidence that Ebola and other filoviruses can be transmitted by the aerosol route. Jaax et alreported the unexpected death of two rhesus monkeys housed approximately 3 meters from monkeys infected with Ebola virus, concluding that respiratory or eye exposure to aerosols was the only possible explanation.

 

Zaire Ebola viruses have also been transmitted in the absence of direct contact among pigsand from pigs to non-human primates, which experienced lung involvement in infection. Persons with no known direct contact with Ebola virus disease patients or their bodily fluids have become infected.

 

***

 

Experimental studies have demonstrated that it is possible to infect non-human primates and other mammals with filovirus aerosols. [Ebola is a type of filovirus]

 

Altogether, these epidemiologic and experimental data offer enough evidence to suggest that Ebola and other filoviruses may be opportunistic with respect to aerosol transmission. That is, other routes of entry may be more important and probable, but, given the right conditions, it is possible that transmission could also occur via aerosols.

In other words, these two infectious disease experts believe that Ebola is already – in its current form – transmissible via aerosols.  They therefore urge all doctors and nurses working with Ebola patients to wear respirators.

If they're right, the government's assumptions about and strategies towards Ebola are all wrong. At the very least – as the two experts quoted above urge – all frontline healthcare workers should wear respirators.  And it may be necessary to consider travel restrictions until the epidemic is contained.




via Zero Hedge http://ift.tt/1rNkDOQ George Washington

Russell 2000 Collapses To Negative Year-over-Year For First Time Since 2012

From a 40%-plus year-over-year in late Dec 2013, the Russell 2000 small-caps index has just hit a crucial milestone to trade negative year-over-year.

 

 

This is the first time since mid-2012 that small-caps have been under-water year-over-year and what saved them then was the promise of QE4EVA…

*  *  *

While Trannies are still up over 11% year-to-date, Russell 2000 is now down over 6.8% and The Dow is rapidly heading red YTD…

*  *  *

How far can it go?




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Japanese Stocks Have Crashed Over 1000 Points Since Friday

After ticking just above 110.00, USDJPY has been a one-way street lower and that means only one thing… Japanese stocks are cratering. From Friday’s highs, The Nikkei 225 has crashed over 1000 points (despite Abe’s promises yet again of more pension reform buying of stocks).

 

 

Of note, perhaps, is that, Japanese investors bought a net $3.6 billion of foreign stocks last week – the most since January 2009 – perfectly top-ticking global equities… Well played Mrs. Watanabe.

 

Chart: Bloomberg




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ECB’s Asset Monetization Advisor Says There Will Be No Full-Blown QE

When two months ago, the ECB announced it would hire Blackrock as an advisor for its “Private QE” ABS and Covered Bond purchase program, many eyebrows were raised, mostly out of cynical curiosity whether the ABS purchased would be those structured by the “advisor” itself. Well, according to today’s detailed fresh off the printer, pardon the pun, term sheets on the program, it appears that the eligible securities will be almost exclusively of European origin, so one can probably exclude Blackrock advising the ECB on buying ABS structured by Blackrock itself.

However, what one can not exclude is that Blackrock, having worked with the ECB for an indefinite period of time, is intimately familiar with the long-term strategy of the biggest jawboning back in the world: Mario Draghi’s ECB. Because while Draghi will say anything, as he started two years ago with his infamous “Whatever it takes” speech, his actual policy options are painfully limited. It is in this context that all those betting that public, US-style, QE will inevitably follow the private QE which is set to last at least two years, may want to sit down and read the following note from Reuters, which warns “investors loading up on some of the euro zone’s riskiest government bonds on expectations that the European Central Bank will buy them are making a mistake” according to none other than BlackRock’s head of European and global bonds said on Wednesday.

Trust us, if anyone knows, he does. From Reuters:

Market expectations that the ECB will be forced to resort to sovereign bond-buying as part of a broad-based quantitative easing (QE) scheme have shot up in recent months as the bloc tips towards deflation.

 

“The market is very much taking for granted that quantitative easing through a government bond purchase programme is coming and I think there are many, many obstacles to that still to come,” Scott Thiel, who oversees assets worth around $100 billion for BlackRock, told Reuters.

 

“If people are buying Spanish and Italian bonds because they think the ECB is going to buy them from them, I think that is a mistake.

It doesn’t get any clearer than that, muppets:

Many bank analysts predict a full-blown QE programme in the next six months, while some see it as early as November, as the ECB’s efforts to ensure the recovery appear to be falling short.

Economists polled by Reuters saw a 40 percent probability of the ECB purchasing sovereign bonds, up from 25 percent at the start of the month.

It will be further ironic if as part of his depature, Bill Gross knew all of this, and upon his departure left Pimco, which remains overweight on Italian government debt, left the Newport beach fund with the biggest easter egg yet. Because the last thing the Total Return Fund can afford is to not only be pillaged by redemptions but also to see a substantial plunge in the market value of its holdings.

At the start of the year, Pimco, which manages $2 trillion (1.58 trillion euros) worth of assets globally, said its position in high-yielding government bonds of the euro zone periphery, such as Italy’s and Spain’s, was the largest ever.

 

BlackRock, the world’s biggest asset manager, said in May that one of its main bond funds – which Thiel oversees – had cut its holdings of peripheral euro zone government debt to their lowest since the height of the crisis.

So who will be right: Pimco, which is in disarray, and deserpately scrambling for any yield anywhere in the world, or the company which the ECB has hired to advise it on what increasingly appears will be the ECB’s only foray into monetization?




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Steve Chapman: Dangerous People and Deadly Force

taserWhen a man jumped over the White House fence, ran
across the lawn and entered the residence, the Secret Service
failed and failed again. One of the most conspicuous and surprising
failures was that though it had armed agents on the ground and
snipers on the roof, no one fired a shot to stop him.

In fact, the agency bragged about not using their guns, saying
that “the officers showed tremendous restraint and discipline in
dealing with this subject.” The agents didn’t shoot Omar Gonzalez
because they “apparently concluded that he was not armed and did
not appear to be carrying anything that might contain explosives,”
reported The New York Times.

Lucky guess. As it turned out, he was carrying a folding knife
with a 3 1/2-inch blade, which could have been put to deadly use.
But agents were able to subdue him without bloodshed. A man
reported to be mentally ill didn’t hurt anyone and wasn’t killed
unnecessarily.

The problem lies in the limited nature of the agency’s options:
shoot the trespasser or hold off in the hope that he is unarmed and
can be captured alive. What the Secret Service needs is something
every law enforcement agency needs: weapons that can incapacitate
threatening suspects without inflicting deadly wounds.

View this article.

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