Académique Documents
Professionnel Documents
Culture Documents
6, 2013 30
LSD Journal
I. INTRODUCTION
White supremacy ideology endures in the
United
States.
White
supremacy
adherents
America.
Members
pledge
on
their
membership card of the Knights Party, a Klanaffiliated white supremacist group, to work for the
protection of the White race and to advance their
cause in all areas of society, whether economic,
judicial,
social,
educational,
scientific,
or
Professor Chin teaches Race and the Law and Legal Analysis and
Writing at Lewis and Clark Law School. The author thanks Qing
Wang for her thorough research assistance and Paul L. Boley Law
Library staff members for their assistance.
1
Nebraska v. Henderson, 762 N.W.2d 1, 10 (Neb. 2009) (emphasis
added).
Chin
Vol. 6, 2013 31
LSD Journal
supremacists
seek
to
infiltrate
the
political
article
focuses
on
white
supremacists
white
law
enforcement
supremacists
with
positions
training,
2
Betty A. Dobratz & Stephanie L. Shanks-Meile, White Power,
White Pride! The White Separatist Movement Inside the United
States 212 (1997).
3
Fed. Bur. Of Investigation, Counterterrorism Division, Intelligence
Bulletin, Ghost Skins: The Fascist Path of Stealth, 2 (Oct. 17,
2006), available at
https://www.documentcloud.org/documents/402522-doc-27-ghostskins.html.
4
Natl Gang Intelligence Center, 2011 National Gang Threat
Assessment 33 (2011), available at http://www.fbi.gov/statsservices/publications/2011-national-gang-threat-assessment/2011national-gang-threat-assessment-emerging-trends.
5
Jerome P. Bjelopera, Congressional Research Service, The
Domestic Terrorist Threat: Background and Issues for Congress, 16
(2013), available at http://www.fas.org/sgp/crs/terror/R42536.pdf.
Chin
Vol. 6, 2013 32
LSD Journal
superiority of
whites
over
other
population
enforcement
employers
need
to
officers8
whose
beliefs
mandate
carry
out
their
law
enforcement
Chin
Vol. 6, 2013 33
LSD Journal
white
supremacist
infiltration
of
law
11
Chin
Vol. 6, 2013 34
LSD Journal
In
the
1700s,
South
Carolina
Chin
Vol. 6, 2013 35
LSD Journal
of
captain
and
subordinates.16
16
Id. at 46.
Sally E. Hadden, SLAVE PATROLS: LAW AND VIOLENCE IN VIRGINIA
AND THE CAROLINAS, 84 (2001).
18
John Hope Franklin & Loren Schweninger, RUNAWAY SLAVES:
REBELS ON THE PLANTATION, 152 (1999).
19
Id. at 152-53.
20
Id. (emphasis added).
17
Chin
Vol. 6, 2013 36
LSD Journal
anxieties
about
losing
racial
control
21
Ira Berlin, GENERATION OF CAPTIVITY: A HISTORY OF AFRICANAMERICAN SLAVES, 10-11 (2003) (emphasis added).
22
Randall Robinson, THE DEBT: WHAT AMERICA OWES TO BLACKS,
74 (2000).
23
Sally E. Hadden, SLAVE PATROLS: LAW AND VIOLENCE IN VIRGINIA
AND THE CAROLINAS, 168 (2001).
24
Id. at 203.
25
Nancy Maclean, BEHIND THE MASK OF CHIVALRY: THE MAKING OF
THE SECOND KU KLUX KLAN, 169-70 (1994).
26
Sally E. Hadden, SLAVE PATROLS: LAW AND VIOLENCE IN
VIRGINIA AND THE CAROLINAS, 192-93 (2001).
Chin
Vol. 6, 2013 37
LSD Journal
Id.
Kristan Williams, O UR ENEMIES IN BLUE: POLICE AND POWER IN
AMERICA, 78 (2007).
29
Id.
30
Id.
31
Id.
32
Id.
33
Id. at 79.
34
Id.
28
Chin
Vol. 6, 2013 38
LSD Journal
B. Twentieth-Century Period
White supremacy and law enforcement
remained intertwined in the twentieth century. In
the period between World War I and World War II,
right-wing groups, like the Ku Klux Klan, formed
the primary domestic threat because they adhered to
principles of racial supremacy, or embraced
antigovernment and antiregulatory beliefs in favor
of individual freedoms. 35 William J. Simmons, an
Imperial Wizard of the Klan, stated that there is
never a stand taken unless an officer of the law
supervise[s] Klan violence. 36 Rooting-out Klan
influence by prosecuting those who engaged in
Klan violence was difficult for officials because
Klan members penetrated all levels of local
governments including police departments. 37 For
example, in one North Carolina town in the 1960s,
it was widely known in the community that
35
Chin
Vol. 6, 2013 39
LSD Journal
Id. at 190.
Michael Novick, WHITE LIES, WHITE POWER, 70 (1995).
41
Andrew B. Lewis, THE SHADOWS OF YOUTH: THE REMARKABLE
JOURNEY OF THE CIVIL RIGHTS GENERATION, 133 (2009).
42
Norm Stamper, BREAKING RANK: A TOP COPS EXPOS OF THE
DARK SIDE OF AMERICAN POLICING, 100 (2005).
40
Chin
Vol. 6, 2013 40
LSD Journal
Id. at 103.
Id.
45
Id. at 100.
46
Id.
47
Id.
44
Chin
Vol. 6, 2013 41
LSD Journal
during
the
Southeast
Investigations
48
Id. at 102.
Id. at 101.
50
Id.
51
Bobby White, Bias Lawsuits Rattle Richmond Police Force, WALL
STREET J., Nov. 14, 2012, available at
http://online.wsj.com/article/SB100014241278873244398045781150
22118616866.html.
49
Chin
Vol. 6, 2013 42
LSD Journal
57
52
Chin
Vol. 6, 2013 43
LSD Journal
inmate
jail
gangs,
especially
white
supremacists.60
58
Klan Rallies for Policeman, TIMES DAILY, May 28, 1990, at 8A,
available at
http://news.google.com/newspapers?nid=1842&dat=19900528&id=ll
keAAAAIBAJ&sjid=Z8gEAAAAIBAJ&pg=4373,5201774.
59
Hector Tobar, Deputies in Neo-Nazi Gang, Judge Found, L.A.
TIMES, Oct. 12, 1991, available at http://articles.latimes.com/199110-12/local/me-107_1_deputy-county. See also Thomas v. County of
Los Angeles, 978 F.2d 504, 511 (9th Cir. 1992).
60
Matt Reynolds, Deputies Say Racist Gang Wields Power at Top of
L.A. Sheriffs Dept., COURTHOUSE NEWS SERVICE, Apr. 16, 2013,
available at http://www.courthousenews.com/2013/04/26/57064.htm.
Chin
Vol. 6, 2013 44
LSD Journal
website
explained
that
although
individual
police
officers
who
are
Infiltrate
your
local
governments!
61
Robin D. Barnes, Blue by Day and White by (K)Night: Regulating
the Political Affiliation of Law Enforcement and Military Personnel,
81 IOWA L. REV. 1079, 1091 (1996).
62
Fed. Bur. of Investigation, Counterterrorism Division, Intelligence
Assessment, White Supremacist Infiltration of Law Enforcement, 6
(Oct. 17, 2006), available at
https://www.documentcloud.org/documents/402521-doc-26-whitesupremacist-infiltration.html.
Chin
Vol. 6, 2013 45
LSD Journal
Infiltrate
your
school
board!
Infiltrate
law
Chin
Vol. 6, 2013 46
LSD Journal
numerous
attempts
to
infiltrate
law
66
Chin
Vol. 6, 2013 47
LSD Journal
including
recruiting
law
enforcement
gangs,
states: Gangs
encourage
70
Fed. Bur. of Investigation, National Gang Intelligence Center,
Gangs Infiltrating Law Enforcement and Correctional Agencies, 3
(Jan. 2010), available at http://info.publicintelligence.net/NGICGangInfiltration.pdf.
71
Id. at 4.
72
Id.
73
Natl Gang Intelligence Center, 2011 National Gang Threat
Assessment, 10 (2011), available at http://www.fbi.gov/statsservices/publications/2011-national-gang-threat-assessment/2011national-gang-threat-assessment-emerging-trends.
Chin
Vol. 6, 2013 48
LSD Journal
Id. at 33.
Smith v. Wilson, 705 F.3d 674, 677 (7th Cir. 2013).
76
Id.
77
Id.
78
Id. at 682.
75
Chin
Vol. 6, 2013 49
LSD Journal
supremacists
penetrate
law
79
Id.
Fed. Bur. of Investigation, Counterterrorism Division, Intelligence
Assessment, White Supremacist Infiltration of Law Enforcement 4
(Oct. 17, 2006), available at
https://www.documentcloud.org/documents/402521-doc-26-whitesupremacist-infiltration.html.
80
Chin
Vol. 6, 2013 50
LSD Journal
enforcement
in
order
to
alert
white
Chin
Vol. 6, 2013 51
LSD Journal
group,
demonstrations,
instructed
Sieg-Heiling
that,
and
during
waving
84
Chin
Vol. 6, 2013 52
LSD Journal
88
Chin
Vol. 6, 2013 53
LSD Journal
supremacist
infiltration
of
law
See Pappas v. Giuliani, 290 F.3d 143, 147 (2d Cir. 2002).
See Id.
96
Natl Gang Intelligence Center, 2011 National Gang Threat
Assessment, 33 (2011), available at http://www.fbi.gov/statsservices/publications/2011-national-gang-threat-assessment/2011national-gang-threat-assessment-emerging-trends.
97
Id.
95
Chin
Vol. 6, 2013 54
LSD Journal
100
As
See Id.
Id.
100
See State of Nebraska v. Henderson, 762 N.W.2d 1, 17 (Neb.
2009).
101
Id.
102
Pappas v. Giuliani, 290 F.3d 143, 147 (2d Cir. 2002).
103
See Mings v. Dept of Justice, 813 F.2d 384, 389 (Fed. Cir. 1987).
99
Chin
Vol. 6, 2013 55
LSD Journal
police
department
shirks
its
unbiased
104
Id.
Pappas v. Giuliani, 290 F.3d 143, 147 (2d Cir. 2002).
106
Id. at 146-47.
107
Id. at 147.
108
Juby E. Towler, THE POLICE ROLE IN RACIAL CONFLICTS, 4-8
(1964), reprinted in THE ROLE OF POLICE IN AMERICAN SOCIETY: A
DOCUMENTARY HISTORY, 174 (Brian Vila & Cynthia Morris eds.,
1999).
109
Pappas v. Giuliani, 290 F.3d 143, 147 (2d Cir. 2002).
105
Chin
Vol. 6, 2013 56
LSD Journal
Thus,
the
presence
of
white
supremacist
harms
infiltration
society
because
of
law
white
Id.
Id.
112
Natl Gang Intelligence Center, 2011 National Gang Threat
Assessment 33 (2011), available at http://www.fbi.gov/statsservices/publications/2011-national-gang-threat-assessment/2011national-gang-threat-assessment-emerging-trends.
113
See Id.
114
Pete Simi & Robert Futrell, AMERICAN SWASTIKA: INSIDE THE
WHITE POWER MOVEMENTS HIDDEN SPACES OF HATE, 90-91 (2010).
111
Chin
Vol. 6, 2013 57
LSD Journal
authority
requires
greater
Id. at 91.
Natl Gang Intelligence Center, 2011 National Gang Threat
Assessment 33 (2011), available at http://www.fbi.gov/statsservices/publications/2011-national-gang-threat-assessment/2011national-gang-threat-assessment-emerging-trends.
117
Tim Prenzler, ETHICS AND ACCOUNTABILITY IN CRIMINAL JUSTICE:
TOWARDS A UNIVERSAL STANDARD, 29 (2009).
116
Chin
Vol. 6, 2013 58
LSD Journal
118
Id.
This article focuses on discharge which is a post-hiring remedy.
But another remedy is screening out racists in the pre-hiring phase.
For example, a police chief in a Tennessee town is using lie detectors
to screen out racists during the applicant process. Associated Press,
Lie-Detector Tests Used to Keep Racists off Troubled Tennessee
Police Force, Mar. 8, 2013, available at
http://www.nj.com/news/index.ssf/2013/03/liedetector_tests_being_used.html.
120
Norm Stamper, BREAKING RANK: A TOP COPS EXPOS OF THE
DARK SIDE OF AMERICAN POLICING, 107 (2005).
119
Chin
Vol. 6, 2013 59
LSD Journal
forces
organizations
are
tasked
essentially
paramilitary
with
mission
the
of
Chin
Vol. 6, 2013 60
LSD Journal
police
officers,
and
the
dismissed
officers
125
See, e.g., Pruitt v. Howard County Sheriffs Dept, 623 A.2d 696
(Md. 1993).
126
See, e.g., Weicherding v. Riegel, 981 F. Supp. 1143 (C.D. Ill.
1997).
127
See, e.g., Hicok v. Iowa Employment Appeal, 808 N.W.2d 755
(Iowa App. 2011) (Table).
128
See, e.g., Nebraska v. Henderson, 762 N.W.2d 1 (Neb. 2009).
129
See, e.g., Pruitt v. Howard County Sheriffs Dept, 623 A.2d 696
(Md. 1993); Weicherding v. Riegel, 981 F. Supp. 1143 (C.D. Ill.
1997); Hicok v. Iowa Employment Appeal, 808 N.W.2d 755 (Iowa
App. 2011) (Table); Nebraska v. Henderson, 762 N.W.2d 1 (Neb.
2009).
Chin
Vol. 6, 2013 61
LSD Journal
the
court
weighs the
employer
and
130
Chin
Vol. 6, 2013 62
LSD Journal
afforded
constitutional
protection. 136
134
See, e.g., Id.; Pappas v. Giuliani, 290 F.3d 143, 151 (2d Cir.
2002).
135
Pruitt v. Howard County Sheriffs Dept, 623 A.2d 696, 700 (Md.
1993).
136
Id.
137
Tindle v .Caudell, 56 F.3d 966, 971 (8th Cir. 1995). In Tindle, a
case involving suspension rather than discharge, the court affirmed
the suspension of a police officer for attending a private party dressed
in blackface, carrying a watermelon, and wearing a black, curly wig.
Id. at 968. The officers speech did not address a matter of public
concern he was merely [a]musing guests at private party with no
showing of any intended message . . . . Id. at 970. By contrast, the
Berger court ruled a police officer who was ordered to stop
performing in blackface makeup in taverns and clubs did express
speech on a matter of public concern because members of the
Chin
Vol. 6, 2013 63
LSD Journal
officers
were
not
entitled
to
First
Amendment protection when they engaged in Nazilike conduct because their speech did not concern
public issues. 138 Their conduct included imitating
German World-War II characters from a television
show called Hogans Heroes, using exaggerated
German accents, performing the Hitler hand salute
and heel clicks, and uttering terms such as
achtung and sieg heil.139 Their Nazi parody was
not protected free speech because it failed to meet
the Pickering tests public concern threshold
requirement.140 First, regarding their speechs
content, they intended their parody to amuse and
joke, rather than comment on social issues, provoke
debate, or address current public issues. 141 Second,
regarding their speechs location, their parody was
community willingly attended and sometimes paid to see his acts.
Berger v. Battaglia, 779 F.2d 992, 993, 999 (4th Cir. 1985).
138
Pruitt v. Howard County Sheriffs Dept, 623 A.2d 696, 699 (Md.
1993).
139
Id. at 699 n.1.
140
Id. at 702.
141
Id. at 701-02.
Chin
Vol. 6, 2013 64
LSD Journal
agency
employees,
including
Id. at 702.
Id. at 699.
144
Mings v. Dept of Justice, 813 F.2d 384, 386 (Fed. Cir. 1987).
143
Chin
Vol. 6, 2013 65
LSD Journal
Id.
Id. at 388.
Chin
Vol. 6, 2013 66
LSD Journal
Id.
Id. at 388-89.
149
Id.
148
Chin
Vol. 6, 2013 67
LSD Journal
Americans. 151
This
racial-stereotyping
includes
action
embodying
the
150
Pruitt v. Howard County Sheriffs Dept, 623 A.2d 696, 700 (Md.
1993).
151
Locurto v. Guiliani, 447 F.3d 159, 183 (2d Cir. 2006).
152
Robert Crawford et al., The Northwest Imperative: Documenting a
Decade of Hate, A-8 (1994) (emphases added).
153
Locurto v. Guiliani, 447 F.3d 159, 164 (2d Cir. 2006).
Chin
Vol. 6, 2013 68
LSD Journal
of
the
firefighters
simulated
break
154
Id.
Id.
156
Id.
157
Id.
158
Id.
159
Id. at, 165.
160
Id. at 167.
161
Id. at 183.
155
Chin
Vol. 6, 2013 69
LSD Journal
responded
based
on
that
likely
162
Id. at 175. The Locurto court bypassed the public concern test for
two reasons. First, the public concern test might not apply to offduty situations. Id. at 174. According to the court, the public
concern test was intended by courts to address on-the-job
expressive activity rather than off-duty activity at issue in the
Locurto case. Id. Second, the court was free to assume the employee
met the public concern part of the test because this assumption would
not alter the outcome of the case for the reason that under the
balancing part of the test, the court ruled in favor of the government
employer. Id. at 175. As the court noted, given our resolution of the
Pickering balancing test, infra [where the court weighed in favor of
the employer], we can assume arguendo that the plaintiffs speech in
this case did in fact relate to a matter of public concern. Id.
163
Id. at 176.
164
Id.
Chin
Vol. 6, 2013 70
LSD Journal
disruptions
to
police
department
although
Officer
Locurtos
First
Id. at 178.
Id. at 165.
167
Id.
168
Id. at 178.
169
Id. at 182.
166
Chin
Vol. 6, 2013 71
LSD Journal
170
Id. at 183.
Pappas v. Giuliani, 290 F.3d 143, 151 (2d Cir. 2002).
172
Id. at 144.
171
Chin
Vol. 6, 2013 72
LSD Journal
the
police
as
oppressors
rather
than
Id. at 144-45.
Id. at 144.
175
Id. at 146.
176
Id. at 147.
177
Id. at 146-47.
174
Chin
Vol. 6, 2013 73
LSD Journal
fellow
officers.179
Thus,
the
law
Eaton,
the
government
employer
Id.
Id.
180
Id.
181
Eaton v. Harsha, 505 F. Supp. 2d 948, 953 (D. Kan. 2007).
Although Eaton involves suspension rather than discharge, this case
is still instructive by showing how courts favor law enforcement
employers over employees in litigation. Public employees must
successfully navigate a series of steps to succeed in their free speech
claims. George Rutherglen, Public Employee Speech in Remedial
Perspective, 24 J.L. & POL. 129, 135 (2008). The steps pose a nearly
insurmountable series of obstacles to the employee. Id. The
obstacles include the employee needing to first establish that the
speech in question is protected at all. Id. Second, the interest in
protecting such speech must be shown to outweigh any legitimate
interest asserted in good faith by the employer. Id. Moreover, the
government employer is granted considerably greater power to
control the speech of its workers than the speech of the general public
179
Chin
Vol. 6, 2013 74
LSD Journal
the
NAACP
as
Government
Chin
Vol. 6, 2013 75
LSD Journal
Id.
Chin
Vol. 6, 2013 76
LSD Journal
measures
Amendment
rights,
violated
but
the
their
First
Eaton
court
Id. at 951.
Id. at 953.
188
Id.
189
Id. at 949.
190
Id. at 971.
191
Id. at 964.
187
Chin
Vol. 6, 2013 77
LSD Journal
disrupted
supervisors
day-to-day
the
chief
duties
and
other
because
the
Further,
officers
talked
about
the
Officers
for
Off-Duty
from
disciplinary
192
action
by
law
Id. at 965.
Id. at 966.
194
Id. at 967.
195
See, e.g., Locurto v. Guiliani, 447 F.3d 159, 183 (2d Cir. 2006).
See also David L. Hudson, Jr., Balancing Act: Public Employees and
Free Speech, 3 FIRST REPORTS 1, 26 (2002), available at
http://www.firstamendmentcenter.org/madison/wpcontent/uploads/2011/03/FirstReport.PublicEmployees.pdf.
193
Chin
Vol. 6, 2013 78
LSD Journal
Chin
Vol. 6, 2013 79
LSD Journal
200
Chin
Vol. 6, 2013 80
LSD Journal
Departments
interest
in
effectively
his
despise
for
African-Americans
Id. at 937.
Id.
207
Spetalieri v. Kavanaugh, 36 F. Supp. 2d 92, 106 (N.D.N.Y. 1998).
208
Id.
209
Id. at 100 n.3.
206
Chin
Vol. 6, 2013 81
LSD Journal
could
undermine
the
publics
trust,
Id.
Benjamin D. Steiner & Victor Argothy, White Addiction: Racial
Inequality, Racial Ideology, and the War on Drugs, TEMP. POL. &
CIV. RTS. L. REV. 443, 447 (2001).
212
See Spetalieri v. Kavanaugh, 36 F. Supp. 2d 92, 106 (N.D.N.Y.
1998).
213
Id.
214
Id.
211
Chin
Vol. 6, 2013 82
LSD Journal
The
head
of
an
important
Id.
Id.
217
Allen v. Lewis-Clark State College, 670 P.2d 854, 867 (Idaho
1983).
218
Id. at 856.
216
Chin
Vol. 6, 2013 83
LSD Journal
Officers
for
Potential
Id. at 857.
Id. at 866.
221
David Pilgrim & Phillip Middleton, Ni[][]er and Caricatures, JIM
CROW MUSEUM OF RACIST MEMORABILIA,
http://www.ferris.edu/jimcrow/caricature/ (last visited Oct. 11, 2013).
222
Eaton v. Harsha, 505 F. Supp. 2d 948, 967 (D. Kan. 2007)
(quoting Waters v. Churchill, 511 U.S. 661, 673 (1994).
220
Chin
Vol. 6, 2013 84
LSD Journal
223
Chin
Vol. 6, 2013 85
LSD Journal
and
Freedom
of
Id. at 968.
Piscottano v. Murphy, 317 F. Supp. 2d 97, 105 (D. Conn. 2004).
230
Weicherding v. Riegel, 981 F. Supp. 1143, 1148-49 (C.D. Ill.
1997).
229
Chin
Vol. 6, 2013 86
LSD Journal
of the Ku
Klux
The
Department
of
Corrections
membership
on
231
Id. at 1147.
Id. at 1147, 1148-49.
233
Id. at 1148.
234
Id. at 1148-49.
232
Chin
correctional
facility
Vol. 6, 2013 87
LSD Journal
interest
outweighed
the
public
have
affirmed
administrative
Chin
Vol. 6, 2013 88
LSD Journal
black
suspects,
wearing
tee-shirts
unique
individuals
aka
SHITHEADS
Sergeant
Hicok
printed
racially
238
Chin
Vol. 6, 2013 89
LSD Journal
Id. at *2-*3.
Id. at *3.
244
Id.
245
Id. at *6.
246
Id. at *8.
247
Id. at *6.
243
Chin
Vol. 6, 2013 90
LSD Journal
Chin
Vol. 6, 2013 91
LSD Journal
252
public
servants
enforce
laws
252
Chin
Vol. 6, 2013 92
LSD Journal
that
the
historical
Klan
represents
257
Id. at 10.
Id.
259
Id. at 14.
260
Id. at 14-16.
258
Chin
Vol. 6, 2013 93
LSD Journal
comments. 263
Although
involving
policy
prohibiting
workplace
Id. at 18.
Id.
263
Hartford v. Casati, No. CV000599086S, 2001 WL 1420512, at *2
(Conn. Super. Ct. Oct. 25, 2001).
264
Id.
265
Id. at *5.
262
Chin
Vol. 6, 2013 94
LSD Journal
vulgar
language
directed
against
women,
included
ni[
][
]er,
raisin
head,
reinstatement
behavior
and
decision
thus violated
excused
public
policy. 268 First, the court found clear and welldefined public policy prohibited racial (and gender)
workplace discrimination, based on state and
federal statutes, case law, a federal consent order
prohibiting offensive language by Hartford police
officers, and the Hartford police departments Code
of Conduct. 269 Second, the court found that the
arbitrators decision violated this clear public policy
even though Officer Casati did not direct his slurs at
specific
individual,
and
that
police
officers
266
Id. at *4.
Id.
268
Id. at *5.
269
Id. at *4.
267
Chin
Vol. 6, 2013 95
LSD Journal
who
uttered
racial
slurs
in
the
officers
to
discuss
potential
work
270
Id. at *5.
Id. at *6.
272
Westbrook Police Union v. Town of Westbrook, 6 A.3d 1164,
1166 (Conn. App. Ct. 2010).
273
Id.
274
Brenda J. Allen, Racial Harassment in the Workplace, in
DESTRUCTIVE ORGANIZATIONAL COMMUNICATION: PROCESSES,
CONSEQUENCES & CONSTRUCTIVE WAYS OF ORGANIZING, 164, 173
(Pamela Lutgen-Sandvik & Beverly Davenport Sypher eds., 2009).
275
Westbrook Police Union v. Town of Westbrook, 6 A.3d 1164,
1166 (Conn. App. Ct. 2010).
271
Chin
Vol. 6, 2013 96
LSD Journal
CONCLUSION
These cases show the persistence of white
276
Chin
Vol. 6, 2013 97
LSD Journal
racially-biased
law
enforcement
supremacy
supremacists
ideology
strategically
endures;
white
infiltrate
law
and
282
civilization,
is
the
surfeit
of
Chin
Vol. 6, 2013 98
LSD Journal
Chin