By Michael Gryboski

September 19th, AD 2009

Preamble

In the continual conflict over the extent of church and state separation in the United States of America there are those who believe in a strict metaphorical wall being placed between religious piety and government policy. One organization that seeks this vision is Americans United for Separation of Church and State. As they declare, “We come from all backgrounds and represent all fifty states. In our work, we seek to preserve and protect religious freedom for every single American and have been dedicated to this since 1947.”¹ They believe that “religion and government must stay separate for the benefit of both. The government holds no religious viewpoint and leaves all decisions about faith and religious practice to its citizens”² and they pursue the endeavor fiercely. Despite this sense of universality to their charge, Americans United has a bias problem. It has been covered to an extent on this site³, but this work shall note a different dimension to their bias. Not only does Americans United take numerous liberal positions even when opposition is nonreligious in nature, they often look the other way when religious liberalism intrudes or attempts to intrude upon government. However much they try to rationalize this inequality, they remain biased to the point of hypocrisy.

I. Ignoring Advocacy from the Religious Left

Americans United denounces entanglements between religion and government, seeing itself as the watchdog guarding the barrier that divides them. To uphold this cause, the secularist organization performs many duties, including lawsuits, legislative action, and grassroots activism.⁴ The organization is wary of the manifestation of conservative Christian advocacy organizations, as they often chart their every action, especially efforts to influence government policy. Examples abound of this coverage:

From a recent article: ”Yesterday, [Focus on the Family] sent a letter to Congress opposing the Employment Non-Discrimination Act. The group argued that the legislation would harm religious freedom in the workplace…Here is the truth about the bill: While it does protect against discrimination based on sexual orientation, it also includes broad protections for religious freedom, something Focus on the Family fails to acknowledge.”⁵

In September 2000, Americans United reported on the Family Research Council getting a new president, Kenneth L. Connor. Americans United said the FRC has a “long and unfortunate history of promoting the Religious Right's intemperate perspective on religious and political issues” and continued its analysis by quoting Executive Director Rev. Barry W. Lynn, “The Family Research Council wraps its incendiary rhetoric around a narrow interpretation of the Bible…Connor appears to be a new conductor who will keep the FRC's train on the same intolerant track.”⁶

From a 1999 article: ”A church-based voter registration project set to get under way this Sunday is part of TV preacher Pat Robertson's Republican electioneering effort for the year 2000, and congregations should not participate…”⁷

As part of their efforts to defend the government from conservative Christian advocacy organizations, who they often track and report on, Americans United has attempted to track and monitor the pro-life movement whenever it is religious in nature. Americans United is a pro-choice organization and does what it can to note efforts by religious institutions to influence politicians on the matter. Below are some examples.

Sam Felder, former webmaster for Americans United’s website, wrote a blog entry defending pro-choice Catholic politicians against Catholic bishops who want to deny them Communion. “All churches have the right to set criteria for membership, of course. Such criteria will define the character of the religious community. But when church leaders coerce politicians in an attempt to enforce church doctrine by governmental force, it risks a church-state crisis,” wrote Felder.⁸

Through a publication named Church & State, Americans United reported on the firing of a Catholic school teacher allegedly over her pro-choice position. The work goes on to cite other incidents of this happening and concludes “Church-state separationists say these types of cases are relevant in the battle over voucher aid to religious schools. Employment discrimination, they say, should not be underwritten with taxpayer funds.”⁹

These and other examples show that they are concerned about the pro-life movement, especially those clergy in it who attempt to influence politics. Americans United does not want the Roman Catholic Church influencing its politically active members to initiate pro-life legislation and they do not want federal legislation that would be influenced by pro-life bishops, for that would be a violation of the Establishment Clause. Yet what about pro-choice clergy who want legislation passed and who desire to exert influence on the federal government? They exist and they to have their own source of political advocacy.

The organization is called Religious Coalition for Reproductive Choice (RCRC). According to their website, “The Religious Coalition for Reproductive Choice brings the moral power of religious communities to ensure reproductive choice through education and advocacy. The Coalition seeks to give clear voice to the reproductive issues of people of color, those living in poverty, and other underserved populations.”¹⁰

The RCRC is not an apolitical organization, as they boast of their proximity to Washington, DC, remarking “We have a strong presence on Capitol Hill, working for policies to ensure reproductive health services are available to all, regardless of income and to strengthen reproductive justice.”¹¹ They have acted as well, including decades long support for the Roe v. Wade decision, organizing convocations at national political conventions in 1996, developing a legislative advocacy program in 2003, and openly opposing the nomination of John Roberts to the Supreme Court of the United States.¹² All of this done by clergy to influence government policy, the very type of religion and government cooperation Americans United purports to oppose.

So how often has Americans United sought to check the influence of the RCRC, much less state concern over their legislative agenda or efforts on the part of their churches to influence the state? Not once. As of September 17th, AD 2009, should one use the search engine on the Americans United website and search “RCRC” only one result comes up, a link offered as evidence regarding the abortion debate on a comment posted on their blog.¹³ Searching “Religious Coalition for Reproductive Choice” only offers six results, none of them critical in nature.¹⁴ This lack of criticality might be attributable to the fact that the RCRC is a religious outreach coalition partner with Americans United, alongside several other religious organizations like Catholics For a Free Choice, Hindu American Foundation, Progressive National Baptist Convention, and WICCA.¹⁵

According to their website Catholics For a Free Choice (more commonly known as Catholics for Choice) “was founded in 1973 to serve as a voice for Catholics who believe that the Catholic tradition supports a woman’s moral and legal right to follow her conscience in matters of sexuality and reproductive health.”¹⁶ Like RCRC, Catholics for Choice have a public policy arm. Their stated position reads as follows:

“Religious institutions have made enormous contributions to modern society. From humanitarian aid, including the provision of health care services and education, to a mediating role in resolving intractable civil conflicts, religion has been seen as a force for the good and a partner with government. At the same time, conservative religious groups have been aggressively political in their attempts to recraft social policy in what is traditionally defined as the private sphere: family life, women’s rights and roles in public life, sexuality and reproduction.”¹⁷

Observe how Catholics for Choice believes in religion and government working effectively together. Contrast this with the opinions of Americans United, who does not believe that religion should influence government at all. Despite the contradiction Americans United willingly affiliates with said organization. Is it because they are politically like-minded? Another case is the Methodist Federation for Social Action (MFSA), also deemed alongside RCRC and Catholics for Choice as a religious outreach partner of Americans United. “MFSA mobilizes clergy and laity within The United Methodist Church to take action on issues of peace, poverty and people’s rights within the church, the nation and the world.”¹⁸ The MFSA falls to the left of the United Methodist Church, espousing support for homosexuality, environmentalism, worker’s rights, antiwar activism, and other “progressive initiatives.” And yes, they have an advocacy arm, with action alerts encouraging members to influence both church and state.¹⁹

And the list goes on. There are numerous religious organizations affiliated with Americans United. Americans United would cry foul if the services done by many of these organizations were performed by religiously conservative groups instead. So why not also claim these religious groups dangerously blur the line between church and state? Some may reason it’s because none of them are powerful enough to truly influence government policy, least of all on the federal level. However that is a questionable thesis given the prominence of these religious organizations. Catholics for Choice has offices in numerous countries, representatives in European Parliament, and a $3,000,000 annual budget.²⁰ The MFSA has chapters in 35 of the 65 Annual Conferences of the United Methodist Church as well as a headquarters in Washington, DC.²¹ These and other religious organizations, largely if not completely leftwing, are affiliated with Americans United. As allies, it makes sense that Americans United would refrain from criticizing them. Yet does this friendship include looking the other way when one of them might cross the line of religious establishment and government edict? Most likely.

II. Ignoring Invocation Discrimination

Americans United professes a strict separation of religion and government, concluding that all combinations of the two are bad. Following this belief, Americans United officially opposes congressional prayers. As they state, “The lawmakers of today should get out of the prayer business. Such action would be better for religion, individual freedom and the Constitution.”²² The secularist organization has reasoned that prayers should not open government sessions at either the local or federal level. However this vigilance was apparently absent when a Hindu priest opened up a congressional session. It probably would have completely slipped their watchful eyes had it not been for the backlash, as reported by Americans United:

“Our nation’s Religious Right cabal carps constantly about a lack of religion in the public square and promotes the wildly misleading notion that the nation’s Founding Fathers envisioned a government devoted to Christianity. This morning an incident unfolded in the U.S. Senate that provided a glimpse of the nastiness that movement has wrought. Senate Majority Leader Harry Reid (D-Nev.) had invited a Hindu clergyperson to offer a prayer to open today’s session, and it was disrupted by angry howls from a gaggle of Religious Right protestors.”²³

“Hindu Chaplain Rajan Zed, a Nevada resident, gave the opening prayer in the Senate at the invitation of U.S. Sen. Harry Reid (D-Nev.). As he began his remarks, two protestors interrupted the proceedings, asking for forgiveness from Jesus Christ for the ‘abomination’ of failing to pray to the “one true God.” (The sergeant-at-arms had to restore order.)”²⁴

“The two women and one man begged Christ’s forgiveness for ‘allowing a prayer of the wicked’ and shouted that Zed’s offering was an ‘abomination.’ The prayer was interrupted three times before the protestors were removed by the sergeant-at-arms. Now, the leader of the Religious Right’s most prominent voice in Washington says it’s ‘inappropriate’ for anyone other than a Christian or Jew to offer the legislature’s opening prayer.”²⁵

Americans United held a greater sense of outrage over the interruption of the Hindu prayer than they did the Hindu prayer being offered in the first place. Nowhere on the website of Americans United is there any proof that they opposed the Senator Reid’s decision to have a Hindu priest pray, no press releases or action alerts were sent out, and no suits filed. Contrast their absence of outrage over this supposed violation with their treatment of Christian clergy opening prayers:

When Reverend Jonathan Falwell delivered an opening prayer for Congress in 2009, he invoked the Name of Jesus. Sandhya Bathija, Communications Associate for Americans United, wrote this in response,

“First of all, the U.S. House is made up of members from the Christian, Jewish, Muslim and Buddhist traditions, as well as some who are unaffiliated or ‘unspecified.’ How can Falwell’s blatantly sectarian prayer be inclusive and welcoming to all those sitting in that House chamber? Second, courts have upheld prayer before legislative bodies, but only if it is non-sectarian. Praying in Jesus’ name hardly qualifies as that. Third, an official prayer before congressional sessions is an unnecessary exercise. Those members of Congress who want to pray have every opportunity to do so on their way to or from work at the many religious institutions that surround Capitol Hill.”²⁶

Were any of these points brought up by any in American United when the Hindu priest prayed his prayer? Judging by Americans United’s archives, the answer is no. When the Commonwealth of Virginia’s House of Delegates passed a piece of legislation allowing police chaplains to pray in the Name of Jesus Christ at public events, Americans United responded thusly, “Government-sponsored events should not involve prayer, Americans United wrote in a letter to the delegates before their vote on Tuesday. But if there is prayer, it should be non-sectarian, in keeping with U.S. Supreme Court decisions, rulings from lower courts and the Constitution.”²⁷

We meditate on the transcendental Glory of the Deity Supreme, who is inside the heart of the Earth, inside the life of the sky, and inside the soul of the Heaven. May He stimulate and illuminate our minds.²⁸

Any argumentative soul could construe this passage as sectarian. In it the priest endorses a monotheistic being (“The Deity Supreme”) who is pantheistic (“inside the heath of the Earth…life of the sky”), and masculine (“May He stimulate…”). One thing is certain, if a conservative Christian delivered such a prayer Americans United would be ready to denounce it as a violation of church-state separation.

III. Americans United’s Defense

The accusation of being a partisan body can be a hazardous one for Americans United. Nonprofit organizations found to be endorsing a specific political party often lose tax exemption status. For consistently acting the way it does, should this fate befall Americans United? They think otherwise. This essay is not the first work nor am I the first person to claim political bias on the part of Americans United. “Americans United has always taken heat from the Religious Right for allegedly turning in only ‘conservative’ churches to the Internal Revenue Service for candidate endorsements from the pulpit.,” wrote Communications Associate Sandhya Bathija.²⁹ Bathija goes on to record certain actions Americans United has taken against non-Christian or liberal Christian efforts to blur the church-state divide:

“After all, when AU first began monitoring church politicking, our first complaint was against the Rev. Jesse Jackson for attempting to use churches for fundraising during his 1988 presidential campaign. In 1996, we filed a complaint with the IRS against a Buddhist temple that held a fundraiser for the Democratic ticket of Bill Clinton and Al Gore. In 2000, AU filed a complaint against the Allen African Methodist Episcopal Church in New York for endorsing Gore.”³⁰

In 2007 Tony Perkins of the Family Research Council criticized Americans United’s Executive Director Barry W. Lynn for apparently ignoring an all-Democratic forum hosted by a theologically moderate evangelical group. In response, Lynn wrote,

“Tony, you should have called me first. I had serious concerns about the Call to Renewal debate. To me, it seemed legally dubious to invite only three candidates. I communicated these concerns to Jim Wallis, head of Call to Renewal. He assured me everything was above board and sent a letter his attorneys had prepared saying the forum met IRS guidelines. Just to be sure, I asked a law firm in Washington that specializes in this issue to give an opinion. Attorneys there cited an IRS revenue ruling that states that 501(c)(3) groups may apply ‘neutral criteria’ when deciding which candidates to invite to an open forum when the field is crowded. Call to Renewal invited only those candidates who have cracked 10 percent in polls, which qualifies as neutral criteria.”³¹

In many respects Americans United is an equal opportunity separationist outfit, expressing concern of overall violations, be they committed by conservative Christians, liberal Christians, or non-Christians. They have indeed expressed concern and offered opposition to some religiously liberal efforts to breach the wall. Yet Americans United definitely skews towards the left, as seen with their disproportionately higher rate of denunciation and monitoring of the Religious Right. It’s pervasively evident. As of September 18th, AD 2009, search their site for pages containing the term “Religious Left” and two pages of results come up, most of which is found in the comments left by readers.³² Search them for “Religious Right” and 23 pages totaling 224 entries come up.³³

Regarding the two preachers President Barack Obama chose for invocation and convocation prayers at his Inauguration, progressive activist Joseph Lowery garners only three results³⁴ while conservative evangelical Rick Warren got seven pages totaling 67 results.³⁵ These seven pages were overwhelmingly negative and among them are included all three results that came up for Lowery. Of the results for “Religious Right”, the very first one posted was an Americans United webpage entitled “Religious Right Research”, which details various rightwing religious organizations. Its beginning declaration reads as follows:

“The single greatest threat to church-state separation in America is the movement known as the Religious Right. Organizations and leaders representing this religio-political crusade seek to impose a fundamentalist Christian viewpoint on all Americans through government action. Americans United, as part of our educational responsibility, regularly monitors the agenda and activities of the Religious Right.”³⁶

At least one disgruntled comment poster on Americans United’s blog took note of this and wrote the following:

“Barry you’ve said that AU is politically neutral. I noticed that the ‘category’ this article/blog is listed under is the, ‘Religious Right Watch’. Could you please point me to the category, ‘Religious Left Watch’ please? I’d like to get your politically unbiased thoughts and those of AU about the Religious Left. My guess is that your looking for those abuses as hard as OJ is looking for the ‘real’ killers!”³⁷

Now other posters countered his accusations, reaffirming Americans United’s view that the Religious Right deserves a specific section more so than the Religious Left. Yet this is a subjective conclusion, given there are probably just as many or more religiously liberal political organizations with large amounts of resources and membership. Do not forget the substantial number of Democratic politicians who have spoken at black churches as well as the following statement made by liberal Democratic figurehead Howard Dean: “We need to talk about Christian values and how they're Democratic values...Jesus taught to help the least among us. He spent his life reaching out to the disenfranchised. The Democratic Party is the party of that value, not the Republican Party.”³⁸ Unsurprisingly, Americans United uttered no concern about this statement.

Resolution

Evidence upon evidence shows a strong liberal bias at Americans United for Separation of Church and State. Religious liberalism often gets a free pass across the church-state lines Americans United claims to fiercely defend. The question reminds why. Why is this bias so blatant and so tolerated? There are various possibilities. Maybe it is the fact that conservative-minded community watchdogs rarely go to Americans United when a leftwing religious group takes liberties with government assistance. After all, these days conservatives can go to plenty of other organizations instead. Maybe it is the individual backgrounds of the figures of high-ranking members that creates the bias. Executive Director Reverend Barry W. Lynn is an ordained minister of the United Church of Christ, considered one of the most theologically progressive Protestant denominations. Senior Policy Analyst Rob Boston is an avowed Liberal and Secular Humanist. Communications Associate Sandhya Bathija formerly worked for the American Civil Liberties Union (ACLU).

Along the vein of this theory, possibly the affiliates and allies of Americans United, for whom there are close ties, are the root cause. It is easier to criticize those who one does not frequently associate with than those who profess kinship. Maybe lacking substantial non-conservative allies shifts the organization more to the left, just as having more conservative allies could shift them more to the right. All these thoughts on the origin of this liberal bias could be right, they could be wrong, or they could be partial factors in a collection of forces that pushed this continual hypocrisy on the part of Americans United. As long as they adamantly claim to defend the principle of church and state separation while also letting so many like-minded peers get away with so much, what better word than hypocrisy?

Sources:

1. ”About Us”, Americans United for Separation of Church and State, http://www.au.org/about/, accessed September 16th, AD 2009.

2.” Why Church-State Separation Is Our Issue”, Americans United for Separation of Church and State, http://www.au.org/issues/why-church-state-separation.html, accessed September 16th, AD 2009.

3. Gryboski, Michael, “Americans United for Separation of Church and State’s Ignoring of Secular Opposition”, September 9th, AD 2009, http://cross-nation.com/dapl-AmericansUnited-problems02.html, accessed September 16th, AD 2009.

4.”What We Do”, Americans United for Separation of Church and State, http://www.au.org/what-we-do/, accessed September 16th, AD 2009.

5. Bathija, Sandhya, “Focus’ Hocus Pocus: Religious Right Group Not So Kinder And Gentler After All”, Wall of Separation, September 4th, AD 2009, http://blog.au.org/2009/09/04/focus-hocus-pocus-religious-right-group-not-so-kinder-and-gentler-after-all/, accessed September 17th, AD 2009.

6. “New President Of Family Research Council Has Track Record Of Hard Line On Social Issues”, Americans United for Separation of Church and State , September 25th, AD 2000, http://www.au.org/media/press-releases/archives/2000/09/new-president-of.html , accessed September 17th, AD 2009.

7. “Christian Coalition Voter Registration Project Advances Republican Agenda, Watchdog Group Charges”, Americans United for Separation of Church and State , June 30th, AD 1999, http://www.au.org/media/press-releases/archives/1999/06/christian-coalit.html, accessed September 17th, AD 2009.

8. Felder, Sam, “More Bishops Deny Communion To Pro-Choice Politicians”, Wall of Separation, August 6th, AD 2004, http://blog.au.org/2004/08/06/bishops_deny_co/, accessed September 16th, AD 2009.

9. “Pro-Choice Teacher Sues Roman Catholic School Over Job Dismissal”, Church & State, January 2004, http://www.au.org/media/church-and-state/archives/2004/01/pro-choice-teach.html, accessed September 17th, AD 2009.

10. “Our Mission”, Religious Coalition for Reproductive Choice, http://rcrc.org/about/index.cfm, accessed September 17th, AD 2009.

11. Ibid.

12. “A Proud History as a Voice of Conscience”, Religious Coalition for Reproductive Choice, http://www.rcrc.org/about/history.cfm, accessed September 17th, AD 2009.

13. http://au.org/search/?cx=015092546853082832047%3Aeyh7fj2x-84&cof=FORID%3A9&ie=UTF-8&q=RCRC#215, accessed September 17th, AD 2009.

14. http://au.org/search/?cx=015092546853082832047%3Aeyh7fj2x-84&cof=FORID%3A9&ie=UTF-8&q=%22Religious+Coalition+for+Reproductive+Choice%22#625 , accessed September 17th, AD 2009.

15. “Religious Groups”, Americans United for Separation of Church and State, http://www.au.org/take-action/activist/religious-groups.html , accessed September 17th, AD 2009.

16. “About Us”, Catholics for Choice, http://www.catholicsforchoice.org/about/default.asp , accessed September 18th, AD 2009.

17. “Public Policy”, Catholics for Choice, http://www.catholicsforchoice.org/topics/politics/default.asp , accessed September 18th, AD 2009.

18. “Mission”, Methodist Federation for Social Action, http://mfsaweb.org/index.php?page_id=58, accessed September 18th, AD 2009.

19. “Advocacy Alerts”, MFSA, http://mfsaweb.org/index.php?page_id=154 , accessed September 18th, AD 2009.

20. “About Us”, Catholics for Choice, http://www.catholicsforchoice.org/about/default.asp , accessed September 18th, AD 2009.

21. http://mfsaweb.org/index.php?page_id=103, accessed September 18th, AD 2009.

22. Leaming, Jeremy, “Invocation Discrimination”, Church & State, December 2003, http://www.au.org/media/church-and-state/archives/2003/12/invocation-discr.html, accessed September 17th, AD 2009.

23. Leaming, Jeremy, “Prayer War On The Hill: Hindu Invocation In Senate Reveals Religious Right Rancor”, Wall of Separation, July 12th, AD 2007, http://blog.au.org/2007/07/12/prayer-war-on-the-hill-hindu-invocation-in-senate-reveals-religious-right-rancor/, accessed September 18th, AD 2009.

24. “Disruption Of Hindu Chaplain's Senate Prayer Shows Religious Right's Intolerance, Says Americans United”, Americans United for Separation of Church and State, July 12th, AD 2007, http://www.au. org/media/press-releases/archives/2007/07/disruption-of-hi.html, accessed September 18th, AD 2009.

25. Smith, Lauren, “Tony’s Tantrum: After Hindu-Led Prayer In Senate, FRC President Perkins Boosts Bigotry In U.S. Government”, Wall of Separation, July 13th, AD 2009, http://blog.au.org/2007/07/13/tonys-tantrum-after-hinduled-prayer-in-senate-frc-president-perkins-boosts-bigotry-in-us-government/, accessed September 18th, AD 2009.

26. Bathija, Sandhya, “Falwell Fast One?: Lynchburg Preacher’s Sectarian House Prayer Doesn’t Track Chaplain’s Online Version”, Wall of Separation, August 3th, AD 2009, http://blog.au.org/2009/08/03/falwell-fast-one-lynchburg-preachers-sectarian-house-prayer-doesnt-track-chaplains-online-version/, accessed September 18th, AD 2009.

27. Bathija, Sandhya, “Chaplain Controversy: Virginia Legislators Endorse Christian Police Prayer”, Wall of Separation, February 5th, AD 2009, http://blog.au.org/2009/02/05/chaplain-controversy-virginia-legislators-endorse-christian-police-prayer/, accessed September 18th, AD 2009.

28. Carney, Mike, “Christian Protestors disrupt Hindu prayer in U.S. Senate”, USAToday.com, July 13th, AD 2007, http://blogs.usatoday.com/ondeadline/2007/07/christian-prote.html, accessed September 18th, AD 2009.

29. Bathija, Sandhya, “Is AU Biased?: Church Politicking Complaints Spur Unfair And Inaccurate Allegations”, Wall of Separation, October 29th, AD 2008, http://blog.au.org/2008/10/29/is-au-biased-church-politicking-complaints-spur-unfair-and-inaccurate-allegations/, accessed September 18th, AD 2009.

30. Ibid.

31. Lynn, Barry W., “Critical Comment: A Response To Some Of AU’s Opponents”, Wall of Separation, June 20th, AD 2007, http://blog.au.org/2007/06/20/critical-comment-a-response-to-some-of-aus-opponents/, accessed September 18th, AD 2009.

32. http://au.org/search/?q=%22Religious+Left%22&cx=015092546853082832047%3Aeyh7fj2x-84&cof=FORID%3A9&ie=UTF-8#1060, accessed September 18th, AD 2009.

33. http://au.org/search/?q=%22Religious+Right%22&cx=015092546853082832047%3Aeyh7fj2x-84&cof=FORID%3A9&ie=UTF-8#1077, accessed September 18th, AD 2009.

34. http://au.org/search/?q=%22Joseph+Lowery%22&cx=015092546853082832047%3Aeyh7fj2x-84&cof=FORID%3A9&ie=UTF-8#397, accessed September 18th, AD 2009.

35. http://au.org/search/?q=%22Rick+Warren%22&cx=015092546853082832047%3Aeyh7fj2x-84&cof=FORID%3A9&ie=UTF-8#1045, accessed September 18th, AD 2009.

36. “Religious Right Research”, Americans United for Separation of Church and State, http://www.au.org/resources/religious-right-research/, accessed September 18th, AD 2009.

37. http://blog.au.org/2007/06/28/wall-of-separation-a-carefully-constructed-edifice-of-misinformation/comments/, accessed September 18th, AD 2009.

38. The Art of Politics, http://www.theartofpolitics.com/archives/2005_04.html, accessed September 18th, AD 2009.