MR. KOJO NNAMDIAre First Amendment rights different for students on a college campus? Eleven Muslim students at UCLA's Irvine campus are facing criminal charges for disrupting the speech of the Israeli Ambassador in late December. Universities have been hotbeds of student activism since the 1960s and campuses across America exploded with protests, sit-ins and riots. While universities generally wish to be seen as places where open debate and dissent are welcome, the fear of disruption and controversy have often won out. The question then, as now, is what power does a university have to limit speech on campus?

MR. KOJO NNAMDIDespite numerous legal challenges, universities are still rife with speech codes, policies that restrict speech considered hurtful or controversial and the courts have not always provided clear guidance. Here to discuss the issue, joining us in studio is Mara Verheyden-Hilliard, co-founder of the Partnership for Civil Justice Legal Defense and Education Fund. Mara, thank you for joining us.

MS. MARA VERHEYDEN-HILLIARDThank you for having me.

NNAMDIJoining us by telephone from Raleigh, N.C. is Robert Shibley, Senior Vice President of the Foundation for Individual Rights in Education. Robert Shibley, thank you for joining us.

MR. ROBERT SHIBLEYIt's great to be here. Thank you.

NNAMDIMara, 11 students at the University of California Irvine facing criminal charges for disrupting a speech by the Israeli Ambassador. They're being called the Irvine 11. Can you describe for us what happened in that case?

VERHEYDEN-HILLIARDYes. Last year, the Israeli Ambassador Michael Oren was at the university, UC Irvine and giving a speech. And there were students in the audience who wanted to express their view and their political dissent to the programs and policies of Israel with regard to the Palestinians and opposition to the U.S. government's program with regard to Israel. And they -- a number of them stood up and spoke out accusing Ambassador Oren of war crimes, of being a war criminal. They were addressing the fact that in December 2008, the Israeli government, with support from the U.S. government, attacked Palestinians in Gaza, killing more than 1400 people. And they felt it was their moral imperative to stand up and speak out when they thought a war criminal was on campus.

VERHEYDEN-HILLIARDAs they were asked to leave, they left and ten of those students were arrested who spoke out and other students got up and walked out and one of those students was also arrested. Now, in addition to being brought before the school on disciplinary charges, the Orange County D.A. actually took the step of convening a Grand Jury, of hauling these students before a Grand Jury and then indicting them and charging them with offenses that would lead to six months in jail.

NNAMDIMost people would agree that that's pretty unusual, but, Robert Shibley, in this particular case, what's also interesting is that the Ambassador apparently was not able to finish his speech.

SHIBLEYYeah, that's right. According to the video of the event that's been posted -- I know the Orange County Register is one example of it -- the Ambassador gave up on trying to give his remarks after, I think, five or six disruptions and, you know, ended up, I guess, ending the speech before he could get to his question and answer session. So University of California Irvine did an investigation, issued their own punishment as well and that's where FIRE, which advocates for free speech on college/university campuses, that's -- you know, our concerns lie on the campuses alone. We don't have an opinion on what the D.A. is doing there, although I will say that we haven't heard of such a step being taken before.

NNAMDIFIRE, of course, being the acronym for Robert's organization. He is Senior Vice President of the Foundation for Individual Rights and Education. Robert, how would you characterize this case in legal terms? Does the term heckler's veto apply here?

SHIBLEYYeah, I think it did in this case because the students engaged in what seems to be an organized pattern of disruption in order to stop the Israeli Ambassador from being able to give his remarks. We've seen this in other campuses, and there's sort of a spectra, you could call it, you know, of heckling, some of which has to do with -- it implicates, I should say, First Amendment rights of the speaker and some of it which doesn't. So if you have a student who just merely stands up silently, which I think happened recently to Secretary of State Hillary Clinton at Georgetown, and then, you know, ends the -- you know, ends the thing and he sits down quietly or whatever -- I don't know if that's what happened in that particular case -- but, you know, sort of minor heckling needs to be tolerated.

SHIBLEYBut there's sort of the spectrum and at the very far end of the spectrum will be what happened at Columbia University back in '06 or '07 when there actually -- the students stormed the stage when the founder of the Minute Men, which is an anti-illegal immigration group, was speaking at Columbia, and a brawl actually started up on the stage. So that would be the very extreme form of the hecklers veto, which is, in fact, forbidden by the First Amendment.

NNAMDII was about to say, if the courts agree that this was a case of heckler's veto, what would that mean legally?

SHIBLEYWell, I don't think that's actually -- and, again, I'm not an expert on California state law. You know, I think they've been indicted for a misdemeanor so, you know, I don't know -- you know, being a person who deals with federal law and constitutional law all the time, I don't know if the California D.A. has, you know, the right, you know, grounds or whatever to proceed against these students. I suppose that -- that's a Grand Jury and, you know, whatever trial happens and prosecution happens will bear out. We'll see a vis of violation of the law. But I think that, you know, it is pretty clear that a heckler's veto type thing happened here. Now, I want to...

VERHEYDEN-HILLIARDTo the contrary, in fact, a heckler's veto did not happen here.

NNAMDIBefore you say what happened, Mara Verheyden-Hilliard, can you explain a little bit why the heckler's veto was apparently in a later case rejected by the U.S. Supreme Court?

VERHEYDEN-HILLIARDWell, I want to -- I will address it, but I also want to step back because the presentation here makes it clear that in these cases these are politically charged cases and facts are everything and apparently so is political motivation. Because, in fact, in this situation, if Michael Oren decided that he no longer wished to speak -- because the only audience he wanted to speak to is one that was not going to question the policies and programs of the government of Israel and its attack and what many feel is genocide war crimes against the Palestinian people. I mean, even the U.N. repertoire has said that Israel committee war crimes in Gaza.

VERHEYDEN-HILLIARDNow, that he chooses to end his speech because students walked out and as the guest was saying that he ended before there were questions and answers, because he doesn't want to have to respond to that. He wanted to have a pristine environment to give his presentation, have nothing but applause and that would be it. And the situation with Gilchrist in Columbia -- in fact, we at the Partnership for Civil Justice Fund worked with students at Columbia University after they were being disciplined by the university for that protest.

VERHEYDEN-HILLIARDIn that situation, Gilchrist, realizing that he too was not going to have a pristine environment where people were going to stand by, where someone with an organization that has been associated with extreme violence against immigrants to the United States and has members of his organization that have affiliations with groups that have carried out really extraordinary violence against people and they -- so I'm coming to campus and they wanted to stand up and speak out against him and they did. The students there who supported the Minute Men, the racist Minute Men organization, were not disciplined, even though they engaged in physical acts of violence. The only students that were brought before discipline were those that were in opposition.

VERHEYDEN-HILLIARDSo again, the facts are important, but the politics are also making the clear defining element here as to what is being considered heckler's veto, what's being considered speech that rises to the level of discipline or criminal prosecution?

NNAMDIBut Mara, you make a relationship between what the speakers in both of these situations were associated with, the Israeli Ambassador and the Minute Men and the nature of the protests against them. What you seem to be saying is that when people are associated with what, in your view and the view of others, are certain heinous kinds of crimes, there is no such thing as a heckler's veto.

VERHEYDEN-HILLIARDNo, I'm not saying that.

NNAMDIOkay.

VERHEYDEN-HILLIARDWhat I am saying, however, is that...

NNAMDIBecause what I'm inferring from what you were saying is that because of the extreme acts with which they are associated, students are justified in using extreme acts against them regardless of how extreme those acts might be, including shutting them up completely.

VERHEYDEN-HILLIARDWell, I'm presenting two different issues here.

NNAMDIOkay.

VERHEYDEN-HILLIARDAnd one is the fact that I believe that students are justified in speaking out on matters of importance to them. Look at the anti-apartheid movement in the United States. That grew to a critical mass, that divestment movement when students were speaking out on campus, even where the universities told them not to. And they were setting up tent cities and shanty towns when they were demanding takeovers of school buildings, and they were demanding their schools divest from South Africa. It was important for them to do it and it had a political impact.

VERHEYDEN-HILLIARDThe reason that I'm raising this is because these students who were speaking on these issues are becoming demonized. And so this language about a heckler's veto that Ambassador Oren chooses to end his speech -- that the head of the Minute Men Gilchrist chooses to end his speech at a point at which they could have continued, but they chose not to, that goes more to the fact that they want to have an environment where there will be no questioning of them.

VERHEYDEN-HILLIARDAnd that goes back to your introduction, which is the idea that universities and academic environments sort of hold themselves out as this bastion of academic freedom, of intellectual thought of debate. But really very often what they want to do is have this very clean sanitized space for speakers to come. Speakers like that, and then particularly speakers in these controversial issues. Issues that people feel are of moral import. They want to not be challenged so they choose to go there.

NNAMDIHow does the university, Robert Shibley, strike a balance between the rights of students who choose to protest and the rights of students who would like to hear the speaker?

SHIBLEYWell, the -- I think what Mara is saying and I think you characterized it well -- do with, you know, there's a moral justification for extreme acts in response to people you think are guilty of extreme acts. You know, whether or not there's a moral justification, when you engage in a course of behavior, which I do think happened at Irvine and which definitely happened at Columbia for sure, where you get to the point where there's a fist fight up on the stage, I don't think it's reasonable to expect a speaker to continue in that sort of environment.

SHIBLEYI mean, speakers do have a right to be in an environment where they can finish a sentence, where they can, you know, actually make the presentation to the members of the audience who are there to hear, as opposed to there to express their, you know, disagreement or disappointment. You know, when it comes to (unintelligible) ...

NNAMDII guess -- I guess -- I guess...

SHIBLEY...speech like that, free speech -- the main part of free speech has to belong to the invited speaker who's up on the stage.

VERHEYDEN-HILLIARDWell, the very fact that you think that people standing up -- standing up nonviolently and speaking out, for example at Irvine, is an extreme act says a lot. That is not an extreme act. Or the situation that you were referring to...

NNAMDII guess -- well, I guess what you're talking about here, Mara...

SHIBLEYOh, I (unintelligible) ...

NNAMDIWait, before we go there, I guess what we're disagreeing on here is what constitutes a disruption and what does not constitute a disruption. What, in your mind, Mara, would constitute a disruption? I'd like to hear the same thing from Robert. Because we're talking about people who are standing up silently, as in the case when Secretary of State Hillary Clinton was speaking, and the individual was carted out, or people who stand up and speak fairly loudly while the guest is speaking or to the extreme that Robert says that -- and I did not witness this -- a fight onstage. In all of those situations what you seem to be saying is those things are not necessarily disruptions, if indeed the speaker can continue speaking afterwards.

VERHEYDEN-HILLIARDWell, again, going back to the facts of the situation, in the Columbia University incident when the student groups protested and stood up and spoke out, the physical violence came from the supports of the Minute Men. They attacked the protestors and they were not disciplined for engaging in an act of physical violence.

NNAMDISo why was there a fight on the stage?

VERHEYDEN-HILLIARDStudents had peacefully walked on the stage and unfurled a banner and were standing there holding a banner while he was speaking.

SHIBLEYWell, see there's (unintelligible) ...

VERHEYDEN-HILLIARDAnd they were jumped and physically assaulted by supporters of the Minute Men. Yet only the students who had taken the action of holding the banner and speaking out were the ones that were disciplined. And the situation at George Washington University recently, where Ray McGovern, who is a well-known peace activist, former 27-year CIA analyst, a former Vietnam veteran, he -- and I have to say we are -- have been representing Mr. McGovern at the Partnership for Civil Justice Fund.

VERHEYDEN-HILLIARDBut he stood up during the speech by Secretary of State Hillary Clinton last month in which she was speaking about lecturing other countries about freedom of speech and freedom of association. And he stood up and was saying not a word and turned his back and was absolutely silent. The disruption occurred because security physically and brutally assaulted him and hauled him out.

NNAMDIYeah. We've gone through that. We've gone through that on this broadcast before. Your turn, Robert. To what extent do you feel that the first amendments rights of a speaker are violated by certain forms of protest while that speaker is making his or her speech?

SHIBLEYWell, I think I have a much more, I guess, generous understanding, and I think it is, you know, backed up by court cases. And just the way that courts treat this is that the speaker who is up on the stage, the person who is, you know, who the venue has been reserved for, has to have the ability to address the audience, you know, who has come there to listen to the person, in a reasonable fashion.

SHIBLEYSo, I mean, in the case of Irvine, you know, there was a disruption that was pretty clearly organized. There were e-mails and that sort of thing, you know, talking about, you know, what we're going to do and that sort of thing. And I'm not saying that there can't be a moral justification for that. But when you get to the point where you are keeping other people from hearing a speaker, I think you've crossed over into civil disobedience from merely expressing your opinion.

SHIBLEYAnd when you're engaged in civil disobedience, one of the aspects of it is if you -- if you're determined to be violating the law, you have to take the punishment. And, you know, I supposed that Irvine decided they had broken the rules. In the case of the Minute Men...

NNAMDIBut in the case of Irvine...

VERHEYDEN-HILLIARDNo. In fact…

NNAMDIOkay. One second. In the case of Irvine -- in the case of Irvine, we're not talking about university administrators here. We're talking about the local law enforcement officials taking it into their own hands. In either case, we've got to take a short break. So if you'd like to join the conversation, call us at 800-433-8850, or send e-mail to kojo@wamu.org. We're talking about free speech on college campuses. I'm Kojo Nnamdi.

NNAMDIWelcome back. We're discussing speech on college campuses in the wake of 11 students on the campus of the University of California Irvine facing criminal charges as a result of their actions at a speech being made there by the Israeli Ambassador. We're talking with Robert Shibley, senior vice president for the Foundation for Individual Rights and Education, FIRE is the acronym, and Mara Verheyden-Hilliard, co-founder of the Partnership for Civil Justice, Legal Defense and Education Fund.

NNAMDIMara, although universities hold themselves up as centers of debate and the free exchange of ideas, you think they've become less and less tolerant of dissent on campus, a far cry from the '60s glory days of student protest. But as I recall in the '60s, the Columbia University repeatedly brought in the New York City police back then against the students.

VERHEYDEN-HILLIARDOh, I think that there's always been a long history of this issue, which is student who become the core of any movement for social justice, taking a stand and speaking out, and then what the universities do in response. And we saw that in the '60s, we saw that in the '70s and '80s as I was mentioning before, the anti-apartheid movement. And now, again, and we're seeing it a lot now with students who are, for example, in support of the Palestinians.

VERHEYDEN-HILLIARDStudents for Justice in Palestine and groups like that are being frequently targeted. So it goes back again to the issue of the political nature of the speech, and disfavored speech become targeted. There was a recent incident at Florida State University where an Israeli counselor official was on a tour where he's been going around and talking about the works that Israeli government did to support the people of Haiti.

VERHEYDEN-HILLIARDAnd a Palestinian-American student very respectfully stood up, she got in line at the microphone, she waited her turn, and, uh, she made positive comments about the support for Haiti, but then asked about the Palestinian people, and she was removed by security because of the political nature of her comments.

NNAMDIGonna get to that 800-pound gorilla in the room in just one second, but first Robert, your organization has researched this and found something interesting about the difference between public and private universities on free speech, and that is there really isn't much different at all in terms of actual policies.

SHIBLEYUh, yeah. I, you know, I agree with Mara that universities have begun to restrict more and more expression over the, you know, past couple of decades. We have a systematic way. We look at 400 universities and college across America, and the most prestigious and largest ones. We found that this last year, 67 percent of them had a rule on campus, what we call a free speech code, that restricted speech that would be protected for those who are off campus.

SHIBLEYAnd actually, the difference between private and public universities, like you mentioned, really isn't that different. Public schools, 67 percent of those got a red light rating from us, and private schools, 65 percent received a red light rating. So actually, since the Constitution applies to public schools, you would like to think that they would actually have wider open areas for free speech, but we found that actually private schools are slightly better, although I don't think in a significant -- statistically significant way.

NNAMDIAnd that 800-pound gorilla in the room that I mentioned, the Palestinian Israeli conflict, I'll get two different points of view. We will start first with Patrick in Arlington, Va. Patrick, you're on the air. Go ahead, please.

PATRICKHello. Thank you. Very quickly, I just wanted to support the district attorney in Orange County for his efforts to bring the students to justice. I think it's worth pointing out that the university suspended the Muslim Student Association, I believe, for a number of months. And that the advocacy of violent and threats of violence is not -- that's not protected speech.

VERHEYDEN-HILLIARDThere was no...

NNAMDIOkay. Wait a minute, before you respond to that...

PATRICKThank you, goodbye.

NNAMDI...here we got -- here we have from Keith in Silver Spring. "This would not have gone this far is the speaker wasn't the Israeli ambassador. Someone got scared that Muslin students might get out of control." Now, Mara, your turn.

VERHEYDEN-HILLIARDWell, first of all, telling the Israeli ambassador, a student standing up and accusing the Israeli government of war crimes or calling the Israeli ambassador a war criminal is not a threat of violence. It is not violence to stand up and speak your mind and speak an opinion like they did. And the very fact that the caller is equating a political viewpoint like that and a statement which, again, is the same as what the UN special Rapporteur said about what happened in Gaza, as if that is a threat of violence, says a lot about the atmosphere these students are forced to contend with.

VERHEYDEN-HILLIARDAnd the other caller which -- the e-mail which sort of suggests that they -- that it's gone too far because of they're afraid of what the Muslims students might be -- I mean, that's frankly a fairly racist assumption about Muslim and Arab students.

NNAMDIWell, I beg to -- on behalf of Keith who wrote that e-mail, is suggesting that the someone got scared Muslim students might get out of control, it seems to me that -- and this is my inference of course -- that Keith is saying that if this was not the Israeli Ambassador, this would not have happened. And as I was saying, Robert, it seems to me that what makes this case stand out so much is not only the fact that there were criminal charges brought, but that it's a part of the ongoing, I guess, wrenching debate the country is having over the Palestinian/Israeli Conflict.

SHIBLEYWell, of course. I think it's pretty obvious in this case, is that when it comes to Israeli/Palestinian issues, I think it's very difficult for people to separate their own feelings on the issue from the way the law should work. One of the fundamental bases that the first amendment operates on is that it shouldn't matter who's being shouted down, whether it's the Israeli ambassador, Michel Oren, whether it's, you know, just a random student who wants to stand up on a soapbox and give his opinion on something, that should not have any effect all on our analysis of whether or not that person is being forced to endure a heckler's veto by people who won't let them finish a sentence or anything else.

SHIBLEYWhen it comes to death threats, those do happen. We had a case in Washington State where people were actually shouting death threats at an African-American playwright. They were offended by his play, "The Passion of the Musical" which was a take-off of "The Passion of the Christ," and it made fun pretty much every ethnic and religious group imaginable, and they actually had to stop the play because people were shouting death threats and they were gonna follow them to their car and beat them up or kill them, things like that.

SHIBLEYSo it does happen, and that's obviously a really extreme version of the heckler's veto. I don't think anybody thinks that's what happened at UC Irvine, and I don't want to imply that that is what happened. But the heckler's veto is a real problem, and I don't think it's fair to expect speakers, actors, playwrights, to try to go on with their speech or play when people screaming at them down, not letting them continue with things, or making them just generally inaudible.

SHIBLEYI don't think threats of violence have to be part of what's happening for it to be a heckler's veto. It's unreasonable for a speaker to keep on going if they can't, you know, get their message out. They're out there to get the message out. That doesn't mean people shouldn't be allowed to disagree with them, they should. But there has to be some sort of organization...

NNAMDIWhere does one draw the line...

SHIBLEY…about how everybody can share their opinion.

VERHEYDEN-HILLIARDWell, right there, there's...

NNAMDIAnd who decides where the line should be drawn?

VERHEYDEN-HILLIARDRight there in that analysis that he just gave, it's completely faulty, and a faulty premise because he's talking about the first amendment, and that's a fundamental misunderstanding of what the first amendment is. The first amendment prohibits state action -- state action, that restricts freedom of speech. So for example, it prohibits the government from stopping people from speaking out, or at public university, it prohibits that's university and its officials from stopping people from being able to exercise a political or express a political point of view.

VERHEYDEN-HILLIARDUnless you’re arguing that there's joint action which requires that a public official is working hand in hand with a private party, you can't accuse students of violating someone's first amendment rights in that context, because again, the first amendment requires state action.

NNAMDISo in the '80s and '90s we...

SHIBLEYWell, I think what the first amendment requires is for the state to make a, you know, in the case that it is a public university, obviously, it doesn't apply to private universities. I think it requires the state to make it possible for a speaker to go ahead with their speech, to protect the safety of the speaker, and to, you know, just generally allow the event to go forward more or less as planned.

VERHEYDEN-HILLIARDAnd that's what was allowed.

SHIBLEYSo you're right, a student can't violate other student's first amendment right, per se, but the state does have a responsibility to make an environment where the speaker can actually, you know, say their piece.

VERHEYDEN-HILLIARDWell, I don't think you can take the first amendment and extend it to sort of an elementary school, you know, attitude toward students of sit down and shut up. I mean, students speak out and they want to speak out, and they should speak out. Now, the fact that the political nature of the attack on the Irvine 11 is explicit because of the criminal prosecution, you could not make it more clear that this is a political attack on them for political speech.

VERHEYDEN-HILLIARDThe fact that in California, in the midst of a bunch of crisis, is convening a grand jury, spending tens of thousands of dollars hauling these students before a grand jury because they stood up and spoke out?

NNAMDIWell, let's stay with the politics for a second. Here's Danny in Fairfax, Va. Danny, you're on the air. Go ahead, please.

DANNYHi. Thanks for taking my call. I think it's a fascinating subject to look at this free speech issue. And even outside of the context of colleges and universities, it reminds me the disruptions that occurred back when the health care reform bill was being proposed, and, you know, in a number of cases, people associated with -- I guess it was perhaps the Tea Party, were seen as disruptive to some of the town hall-esque type speeches that politicians were giving.

DANNYAnd it does seem like the panel has covered the issue so far from kind of a politically entrenched position. And I'm just wondering if they have a view on what happened with those disruptions and if it also aligns with the standards that they've proffered so far.

VERHEYDEN-HILLIARDWell, indeed, that's a point to be made there, that when the health care town halls were going around the country and Tea Party-affiliated and other people were going and disrupting these meetings, and in some cases visibly standing around outside with guns, people were not being prosecuted for that. Nor were they...

NNAMDIIndeed. We got an...

VERHEYDEN-HILLIARD...being prosecuted for threats. And I would just point out, when Obama gave his speech to Congress, remember Congressman Joe Wilson...

NNAMDIYou lie.

VERHEYDEN-HILLIARD...stood up and yelled, you lie.

NNAMDIWell, here's a post we got on our website from Desiree. "Why should these students face different charges than protestors in Congressional hearings? I have been detained or arrested numerous times for disrupting hearings on Capitol Hill, and never faced criminal charges other than a misdemeanor." Robert Shibley, I guess that's what makes this University of California Irvine case different, isn't it?

SHIBLEYWell, I think that, you know, I said at the outset of the program, it is unusual. We haven't actually heard this, you know, happening before where students who, you know, I -- whether or not they disrupted, you know, and caused the heckler's veto or not, we haven't actually seen, in my experience anyway, them being prosecuted by the civil criminal justice system. So that is, I think, unusual, and I think the important thing there is just the same as it is with the university, I would say.

SHIBLEYIt's important that there not be a double standard, that it not be more impermissible to heckle the Israeli ambassador than, you know, say the, you know, Egyptian or Jordanian ambassador. That...

NNAMDIWell...

SHIBLEYSo we have a responsibility. Public officials have a responsibility to be even handed. But I will say that, you know, to the extent that Tea Party people or anybody else were disrupting town halls and making it impossible for Congressmen to finish a thought or sentence, they could be, you know, taken out by the police, and that's, you know, that's how it is.

NNAMDIWe're almost out of time, and we haven't had a chance, Mara, to discuss either speech codes or free-speech zones that have been introduced on campus. Give me your general observation on those.

VERHEYDEN-HILLIARDWell, as I was saying before, it's clear that universities are increasingly wanting to present themselves as, you know, the sight of academic freedom and debate, and public officials also like that image so they can appear to go speak to the university. But, in fact, it's a totally sanitized environment. They want to put students out of sight, out of mind, and they want to be able to control the image of what's coming out and it works for both sides. But it doesn't work for free speech and debate.

NNAMDIRobert, I remember the free speech zone at the Democratic convention in Boston in 2004 that was way far away from the mainstream of the convention and nobody wanted to go there. Your thoughts in 30 seconds or less about free-speech zones on campuses.

SHIBLEYFree speech zones on campus are an abomination. I know we had one at the University of Massachusetts Amhurst. They've loosened it up a little, but for a while you're restricted to having rallies between I believe 12:00 and 1:00 on the steps of the library. You know, just -- imagine being at the Democratic National Convention in Boston, but every day that's what free speech zones are like on college university campuses.

NNAMDIRobert Shibley, senior vice...

VERHEYDEN-HILLIARDAnd they certainly are offensive.

NNAMDIRobert Shibley is senior vice president of the Foundation for Individual Rights and Education, FIRE. Thank you for joining us. Mara Verheyden-Hilliard is co-founder of the Partnership for Civil Justice, Legal Defense, and Education Fund. Mara, thank you for joining us.

VERHEYDEN-HILLIARDThank you so much.

NNAMDIAnd thank you all for listening. I'm Kojo Nnamdi.