Another Bush-Like Proposal From the Obama Administration?

According to New York Times sources, the Obama administration is floating a proposal to delay presenting terrorism suspects to judges for an initial hearing. The initial hearing is a formal legal process during which a criminal suspect comes before a judge and learns of the charges against him or her and about the right to remain silent and to have an attorney. A judge could also set bail or require the detainee to remain incarcerated.

Recently, Eric Holder said that the Obama administration would ask Congress to change exceptions to the Miranda rule, which would likely violate current Supreme Court doctrine. The New York Times reports that changes to Miranda and to the initial hearing process could come in the same legislative proposal:

President Obama’s legal advisers are considering asking Congress to allow the government to detain terrorism suspects longer after their arrests before presenting them to a judge for an initial hearing, according to administration officials familiar with the discussions.

If approved, the idea to delay hearings would be attached to broader legislation to allow interrogators to withhold Miranda warnings from terrorism suspects for lengthy periods, as Attorney General Eric H. Holder Jr. proposed last week.

The devil is always in the details, but on the surface, this sounds does not sound good.

IMPORTANT NEWS ALERT: Former President George W. Bush Apparently Suffering from Acute Amnesia

An article in today's Washington Times indicates that former President George W. Bush is suffering from acute amnesia. The article covers a speech Bush delivered in Erie, Pennsylvania. After the speech, Bush answered questions from the audience.

The article reports that Bush, adhering to protocol that governs former presidents, declined to criticize President Obama directly. Bush's defense of many of his policies, however, implicitly criticize Obama (or at least validate many conservative critiques of Obama).

A closer reading of Bush's comments reveals that he is apparently suffering from acute amnesia. Bush, for example, stated that:

I know it's going to be the private sector that leads this country out of the current economic times we're in. . . . You can spend your money better than the government can spend your money.

This simple truism, however, hides some important issues, like the fact that Bush -- not Obama -- proposed TARP (or the "bailout") and signed it into law. Bush and Treasury Secretary Paulson advocated the passage of TARP on the grounds that pumping nearly $1 trillion of "our money" into the private sector would help end the financial crisis.

Furthermore, even after many Republicans criticized the idea of providing federal financial assistance to the automobile industry, President Bush (not Obama) proposed using TARP funds to bail out Detroit. TARP for banks and car companies began during the Bush administration, not with Obama.

To his credit, Bush resisted the opportunity to criticize Obama for closing the Guantanamo Bay detention center. Prior to leaving office, Bush said that he wanted to close the facility as well.

Nevertheless, Bush's comment on the danger of terrorists leaves the impression that he suffers from amnesia. For example, Bush stated:

[T]here are people at Gitmo that will kill American people at a drop of a hat and I don't believe that -- persuasion isn't going to work. Therapy isn't going to cause terrorists to change their mind. . . .

Although Bush mocked the idea of using therapy to reform terrorists, he sent many Saudi detainees from Guantanamo Bay to Saudi Arabia in order to participate in the "Prince Mohammed bin Nayef Centre for Care and Counseling" program, which uses a 12-step program, combined with therapy, to rehabilitate terrorists. The program enjoys mixed reviews, and some of the detainees Bush referred to the program have resumed their participation in Al Qaeda.

Furthermore, Bush seems unable to recall that President Obama apparently agrees with his comments about the dangers of Guantanamo Bay detainees. Obama, like Bush, has decided to use military tribunals, in addition to civilian courts, to prosecute suspected terrorists. Obama has also stated that the government will use the controversial practice of "preventive detention" for "dangerous" individuals who do not face prosecution in either civilian or military courts. The Washington Times article does not mention whether Bush acknowledged the overlap between his policies and Obama's policies related to terrorism, nor does it report the contradictions between Bush's words and his policies.

Finally, Bush seems unable to comprehend current proposals for health care reform. For example, he said that:

There are a lot of ways to remedy the situation without nationalizing health care. . . .I worry about encouraging the government to replace the private sector when it comes to providing insurance for health care.

Of course, President Obama has not proposed "nationalizing health care." Instead, at most, he supports a public plan option that will serve alongside private insurance. If this represents "nationalized" health care, then the country already has a nationalized system, because the federal government and the fifty states already serve as public payers of health care, under Medicare, Medicaid, the VHA, SCHIP, and various other programs. Although conservatives argue that an additional public plan option would cause the collapse of private insurance, this point is debatable, and it certainly is not a specific piece of Obama's proposals.

Change Alert: Indefinite Detention in the USA -- Not Guantanamo Bay

In late April, Secretary of Defense Robert Gates announced during a Senate briefing that there are between 50 and 100 detainees at Guantanamo Bay whom the government would not transfer to other countries or prosecute in civilian or military tribunals. Last week, major media outlets, confirming previous "chatter," reported that the Obama administration would retool and revive the highly disparaged military courts.

And just when it seemed that all of these changes in anti-terrorism policy were too good to be true, today's Wall Street Journal reports that the Obama administration might indefinitely detain some Guantanamo Bay inmates in the United States following the closure of the facility. Presumably, the indefinitely detained individuals would include the 50-100 people Gates described in late April.

The Senate, however, has already launched an effort to block the potential policy. Today, the Senate will consider legislation that would give Obama emergency money he has requested to fund the closure of the Guantanamo Bay prison. The legislation, however, would grant the funds only if the President agrees not to transfer any suspected terrorists to locations within the United States.

If the Senate measure fails, then the Obama administration could potentially implement the indefinite detention policy. According to the Wall Street Journal article, possible plans include indefinite detentions within the United States authorized by a newly created "National Security Court."

The use of a special National Security Court to determine whether the government could detain suspects would go against Obama's campaign assertion that these individuals should have full habeas corpus rights. The idea of indefinite detention contradicts his campaign rhetoric that condemned this practice.

Dissenting Justice has frequently commented on the Obama administration's commitment to indefinite detention, despite the Left's vehement opposition to the practice. Even the mainstream media has begun reporting on how Obama's policy choices either anger the Left or defy his campaign promises. Two articles in today's Washington Post, for example, examine how Obama's recent flip-flop on the release of detainee abuse photos might impact his relationship with his liberal base.

Concluding Questions
If Congress blocks the transfer of Guantanamo Bay detainees to the United States, will Obama stop the process of closing the facility? Was this the plan all along? How does the indefinite detention of terrorism suspects in the United States, as opposed to Guantanamo Bay, represent an improvement over the Bush administration's policies?

Recent Articles on Dissenting Justice:

Earth to GOP: Branding Democrats as "Socialists" Is a Stupid and Futile Move

President Obama: Less Talk, More Action on GLBT Rights Issues!

Promises, Promises. . .

Obama's "Interesting" Comments About Rendition

President Obama recently completed a 35-minute interview with the New York Times. During the interview, Obama addressed several domestic and foreign policy issues. A very wasteful moment occurred when the interviewer asked Obama if he was a "socialist"? When he said "no," the desperate interviewer asked: "Is there anything wrong with saying yes?"

Beyond this frivolous inquiry, however, the interview covered important terrain. Nevertheless, individuals who carefully scrutinize political news will not find a lot of new information in the discussion, but it is still worth reading.

Obama on Rendition
During Obama's interview with the New York Times, the following exchange concerning rendition occurred:

Q. Leon Panetta has said that we’re going to continue renditions, provided we’re not sending people to countries that torture. Why continue them at all?

A. Well, I think that you’re giving a slightly more definitive response than Director Panetta provided, but what I’ll say is this: We are now conducting a review of the rendition policy, there could be situations, and I emphasize – could be – because we haven’t made a determination yet, where let’s say we have a well-known Al Qaeda operative, that doesn’t surface very often, appears in a third country, with whom we don’t have an extradition relationship, or would not be willing to prosecute him, but we think is a very dangerous person. I think we will have to think about how do we deal with that scenario in a way that comports with international law and abides by my very clear edict that we don’t torture, and that we ultimately provide anybody that we’re detaining an opportunity through habeas corpus to answer to charges.

How all that sorts itself out is extremely complicated because it’s not just domestic law its also international law, our relationship with various other entities. And so, again, it will take this year to be able to get all of these procedures in place and on the right footing.

Analysis

I. Obama chided the interviewer for overstating Panetta's position.

Although this is a fair criticism, Panetta strongly indicated during his confirmation hearings that rendition would continue. He said that the government "may very well" transfer individuals to other countries for the purpose of interrogation and that "hopefully" rendition for legal process abroad would also continue. Many press accounts of Panetta's confirmation hearings (see here for example) construed his remarks as indicating that the United States would continue rendition, but that the government would seek diplomatic assurances against torture.

II. Obama would consider rendition of Al Qaeda suspects, so long as international law and his anti-torture rules are followed.

A CIA-sponsored abduction without the consent of the foreign country in which it occurs violates that country's sovereignty. If that country has an extradition treaty with the United States, an unauthorized rendition would invade that country's sovereignty and it could potentially violate the terms of the extradition agreement.

III. Obama states that the U.S. should "ultimately provide" habeas corpus relief to "anybody we are detaining."

This statement conflicts with the Department of Justice position on this issue. DOJ has adhered to the Bush administration's conclusion that detainees at Bagram Air Force Base in Afghanistan do not qualify for habeas corpus relief. Accordingly, the United States is already detaining individuals without affording them access to United States courts. If the CIA abducts terrorism suspects and ultimately transfers them to Bagram, these individuals would not qualify for access to the federal courts under DOJ's analysis.

Furthermore, if the government renders Al Qaeda suspects to officials in other countries, these individuals would not have a right to challenge their detention in United States courts because the transfer would place them beyond the custody and jurisdiction of the United States. Also, the United States could not prevent torture of individuals once they are transferred.

Finally, Attorney General Eric Holder and Solicitor General nominee Elena Kagan have both argued that the government could indefinitely detain suspected members of Al Qaeda as "enemy combatants" because the country is at war with the terrorist organization. This reasoning, together with the government's legal argument concerning Bagram detainees, would support the indefinite detention of and denial of habeas corpus to Al Qaeda suspects who are captured through rendition and subsequently held by the United States at Bagram, as opposed to a CIA black site.

Final Thoughts
The Obama administration has indicated that rendition will continue and that it, like Bush, will not utilize rendition to torture. Obama's executive orders close CIA black sites, but they do not close other United States-run facilities, such as Bagram, which can (and already) house terrorism suspects. Because the administration has claimed legal authority to deny habeas corpus relief to Bagram detainees and to detain indefinitely Al Qaeda suspects, Bagram could become the functional equivalent of Guantanamo Bay.

Rendition raises very strong issues concerning a country's sovereignty and an individual's right to a fair process and freedom from torture. For this reason, some human rights activists believe that the CIA must abandon the practice altogether. Many liberals strained to parse the differences between "good" rendition and "bad" extraordinary rendition once it became clear that Obama would continue the practice. Some liberal commentators who initially defended Obama's rendition plans, however, have begun to question the practice (see, e.g., statement of Glenn Greenwald).

Marjorie Cohn, a law professor and human rights advocate, complicates liberal efforts to distinguish the two types of rendition in her persuasive essay which concludes that: "There a slippery slope between ordinary rendition and extraordinary rendition." President Obama's recent comments regarding rendition are very careful, ambiguous and tentative. Rendition, however, raises serious questions that the government and the public must continue to scrutinize and debate.

Two Important Terrorism Updates...But You've Heard Them Before

FIRST
Today, the Obama administration decided to maintain the Bush adminstration's legal position, which asserts that individuals detained at the Bagram Air Force Base near Kabul, Afghanistan do not have a right to seek judicial review of their detention. The Department of Justice argues that, unlike Guantanamo Bay, the base is located in the "theater of war" and this makes judicial review impracticable." Also, the government argues that the Bagram detainees are not entitled to habeas corpus because they are subject to the Military Commissions Act of 2006 -- a statute that Obama denounced.

This military base is not subject to Obama's executive orders which require the review and subsequent closure of Guantanamo Bay. Also, the facility is not a longterm CIA prison which the executive orders also require the government to shutter. Presumably, the government can indefinitely detain individuals at Bagram -- rather than Guantanamo Bay -- without judicial review. Solicitor General Elena Kagan and Attorney General Eric Holder essentially validated this position when they endorsed indefinite detention of terrorism suspects during their confirmation hearings.

SECOND
Obama's executive orders create a task force to study Guantanamo Bay and then subsequently to close it. Today, the Pentagon, responding to a request by President Obama, released an 85-page report which concludes that the maligned facility complies with the Geneva Convention. During the Bush administration, many individuals in the human rights community passionately disputed this position.

While the study finds that the facility complies with international law, it concludes that some of the more dangerous individuals should now receive play time:

The report recommended some changes, including an increase in group recreation for some of the camp's more dangerous or less compliant prisoners, according to a government official familiar with the study. The report also suggested allowing those prisoners to gather in groups of three or more, said the official, who spoke on condition of anonymity because the report has not officially been released.

FINAL WORD
I have written many articles which track the similarities between Bush's and Obama's anti-terrorism policies. For the record, I do not necessarily disagree with some of these practices. For example, I have argued that the government should probably receive wide latitude to invoke the state secrets privilege and that courts should defer to the government's conclusion that a potential item of evidence qualifies for the privilege.

Also, asserting executive authority to do a particular act, does not mandate the use of such power. So, even if the government believes it can detain terrorism suspects indefinitely, this does not mean that it will.

My purpose for engaging this subject arises from my belief that the Left must hold consistent positions and that it must rethink the uncritical approach it took with respect to Obama during the Democratic primaries and the general-election campaign. If McCain (or probably even Clinton) had won the election and began validating Bush's policies, my fellow liberals would condemn him as Bush III.

In order for our arguments to have legitimacy, we must remain consistent or explain why we shift. If progressives now believe that they overreached in condemning Bush, they should make this clear. If progressives simply wanted to drum Republicans out of power, they have made a mockery of the very values they claim to embrace. Criticism and consistency, rather than partisan defense of "our" candidate, can permit greater accountability. Silence and acquiescence do not. I hope I am not the lone progressive who sees this. Ok - that was a melodramatic ending. And for the record, outside of Ron Paul, I have not seen many conservatives criticize other conservatives for not taking Bush to task on his extravagant fiscal policies.

So Exactly When Does "Change" Begin, Take 45345234524523452452: Elena Kagan Says Government Can Indefinitely Detain Terrorism Suspects

Let me say upfront: I am a cynic. Accordingly, I never took the "change" mantra too seriously. But I certainly thought that after eight years of frenetic liberal criticism of the Bush administration, Obama would indeed offer some important differences. But even that tiny hope has been dashed. After the recent announcements that Obama would continue the practice of rendition and that the CIA would seek approval for "harsher" interrogations "if necessary," the small space I reserve in my heart for idealism and for surprisingly good decisions (or at least decisions that fulfill promises) by politicians has diminished substantially. But after today's news, the space has completely vanished.

What happened today? Elena Kagan, Dean of Harvard Law School and nominee for Solicitor General, announced that she believes that the government has the authority to detain indefinitely terrorism suspects because the country is "at war" with Al Qaeda. Because I am busy finishing edits on a law review article, can someone please explain to me how this differs from Bush's position, which liberals condemned, bashed and burned in effigy?

Related Readings on Dissenting Justice:

Rendition, Secrecy and Torture: Inseparable?

Just As I Predicted: Obama Administration Invokes State Secrets Privilege in Anti-Torture Lawsuit

Panetta: Rendition Will Continue, Would Ask Obama to Authorize Harsher Interrogation Methods "If Necessary"

Elevating Form Over Substance: Liberals Now Argue that They Oppose the Label of Bush's Program, Not the Substance

Still a Flip-Flop: My Fellow Liberals Push Back Against Allegations of Inconsistency Concerning Rendition

Major Flip-Flop by Human Rights Watch: Organization Waiting for Obama to Develop Kinder, Gentler Rendition Program

Hold Them Accountable Part II: If Conservatives Caused the Economic Crisis, They Had a Lot of Help from Democrats!

Hold Them Accountable Too: Many Democrats Supported Policies of the "Worst President" (Part I)

Major Flip-Flop by Human Rights Watch: Organization Waiting for Obama to Develop Kinder, Gentler Rendition Program

For an analysis of Obama's comments on rendition during his interview with the New York Times, visit this link: Obama's "Interesting" Comments About Rendition.

I can stomach some political flip-flops. Politicians run with the popular opinion for the most part, but sometimes their positions legitimately change in the face of new factual information.

But I think it's pretty deplorable to flip-flop on the issues of human rights and torture. Unfortunately, in an effort to defend the new administration in Washington, Human Rights Watch has apparently modified its position on the issue of rendition, which it previously viewed as inherently abusive and inhumane.

Today's L.A. Times contains an article which reports that President Obama will continue the highly criticized program of "rendition." Through the rendition program, the CIA transfers terrorism detainees to foreign countries (I wrote about the L.A. Times article and rendition generally in a blog post earlier today).

Many human rights activists condemned rendition during the Bush administration, arguing that the government either intentionally transferred individuals to countries so that they would be tortured, or that it could not guarantee the safety of detainees once they were transferred to other countries.

Human Rights Watch: Before
Human Rights Watch, a very respected and passionate defender of civil liberty, was one of the most vocal critics of the CIA's rendition program. In fact, Human Rights Watch prepared a comprehensive document that reports incidents of alleged torture of rendered individuals. The report makes the following policy recommendations:

The US government should:

Repudiate the use of rendition to torture as a counterterrorism tactic and permanently discontinue the CIA's rendition program;

Disclose the identities, fate, and current whereabouts of all persons detained by the CIA or rendered to foreign custody by the CIA since 2001, including detainees who were rendered to Jordan;

Repudiate the use of "diplomatic assurances" against torture and ill-treatment as a justification for the transfer of a suspect to a place where he or she is at risk of such abuse;

Make public any audio recordings or videotapes that the CIA possesses of interrogations of detainees rendered by the CIA to foreign custody;

Provide appropriate compensation to all persons arbitrarily detained by the CIA or rendered to foreign custody (emphasis added).

Human Rights Watch rightfully opposed the practice of torture by the Bush administration, but it also demanded the cessation of rendition and that victims of the practice receive compensation.

The organization's recommendations went even farther, however. In order to make sure that the program ended, Human Rights Watch recommended that other countries should:

Refuse to cooperate in secret detention and rendition efforts, and disclose all information about past cooperation in such efforts (emphasis added).

Human Rights Watch: After
Now that the L.A. Times reports that rendition will continue during the Obama administration, Human Rights Watch has apparently altered its position. According to Tom Malinowski, the organization's "Washington advocacy director," the risk of torture and other abuses does not mandate the prophylactic cessation of rendition. Instead (quoting the L.A. Times):

"Under limited circumstances, there is a legitimate place" for renditions, said Tom Malinowski, the Washington advocacy director for Human Rights Watch. "What I heard loud and clear from the president's order was that they want to design a system that doesn't result in people being sent to foreign dungeons to be tortured -- but that designing that system is going to take some time."

Malinowski said he had urged the Obama administration to stipulate that prisoners could be transferred only to countries where they would be guaranteed a public hearing in an official court. "Producing a prisoner before a real court is a key safeguard against torture, abuse and disappearance," Malinowski said (emphasis added).

This certainly looks like a flip-flop to me. What do you think?

Update: Several liberal bloggers have responded by claiming that no "flip-flop" has occurred. Naturally, I disagree: Still a Flip-Flop: My Fellow Liberals Push Back Against Allegations of Inconsistency Concerning Rendition

Waffling or Just Filling in the Details: Obama's Statements on Guantanamo Bay Raise Questions

Recent statements by Obama which suggest he will take a cautious approach to closing the Guantanamo Bay detention facility have led some observers to accuse him of backpedaling on the subject. During the Democratic primaries and in the general election campaign, progressives frequently cited to Obama's promise to close Guantanamo Bay in order to portray him as the candidate who would do the most to repair the image of the United States in world affairs.

Obama's Campaign Rhetoric on Guantanamo Bay
During his campaign, Obama promised that he would make closing the facility a priority of his administration. The following language taken from a brochure on BarackObama.Com details his position on the subject:

Guantanamo has become a recruiting tool for our enemies. The legal framework behind Guantanamo has failed completely, resulting in only one conviction. President Bush’s own Secretary of Defense, Robert Gates, wants to close it. Former Secretary of State Colin Powell wants to close it. The first step to reclaiming America’s standing in the world has to be closing this facility. As president, Barack Obama will close the detention facility at Guantanamo. He will reject the Military Commissions Act, which allowed the U.S. to circumvent Geneva Conventions in the handling of detainees. He will develop a fair and thorough process based on the Uniform Code of Military Justice to distinguish between those prisoners who should be prosecuted for their crimes, those who can’t be prosecuted but who can be held in a manner consistent with the laws of war, and those who should be released or transferred to their home countries.

Obama made similar statements in a speech on foreign policy that he delivered in August 2007:

I also will reject a legal framework that does not work. There has been only one conviction at Guantanamo. It was for a guilty plea on material support for terrorism. The sentence was 9 months. There has not been one conviction of a terrorist act. I have faith in America's courts, and I have faith in our JAGs. As President, I will close Guantanamo, reject the Military Commissions Act, and adhere to the Geneva Conventions. Our Constitution and our Uniform Code of Military Justice provide a framework for dealing with the terrorists.

Progressives Banked on Obama to Close Guantanamo Bay
As they did on many issues, progressives promoted Obama as the better candidate on this issue, even though both he and Hillary Clinton promised to shut down the detention facility (see Clinton statement). In January 2008 -- one week prior to Super Tuesday -- several prominent lawyers who represent detainees at Guantanamo Bay wrote an open letter endorsing Obama.

The letter does not mention Clinton by name, but it distinguishes Obama from other "some politicians" who "are all talk and no action." It also states that "America needs a President who will not triangulate this issue" and that Obama would certainly keep his word "because he truly feels these issues in his bones."

Although it speaks in code, the letter clearly attacks Clinton. During the Democratic primaries, the Left derided Clinton as someone who was insincere and untrustworthy and as someone who, rather than feeling issues "in her bones," simply takes positions to get elected. Also, "triangulation" is synonymous with leftist hatred of the Clintons.

Obama's Most Recent Statements on Guantanamo Bay
During a recent interview on ABC's This Week, Obama took a cautionary approach that differs from his campaign statements which describe closing the facility as "the first step" towards repairing the nation's image in the international community. Obama refused to commit to closing facility during his first 100 days in office. Instead, his comments suggest a more drawn out process of winding down operations. And rather than portraying the facility as a complete failure, he suggests that that the interrogations at Guantanamo Bay, lawful or otherwise, may have actually helped the United States identify and secure terrorists. Here is Obama's full statement:

It is more difficult than I think a lot of people realize and we are going to get it done but part of the challenge that you have is that you have a bunch of folks that have been detained, many of whom who may be very dangerous who have not been put on trial or have not gone through some adjudication. And some of the evidence against them may be tainted even though it's true. And so how to balance creating a process that adheres to rule of law, habeas corpus, basic principles of Anglo American legal system, by doing it in a way that doesn't result in releasing people who are intent on blowing us up. . . .

That's a challenge. I think it's going to take some time and our legal teams are working in consultation with our national security apparatus as we speak to help design exactly what we need to do. But I don't want to be ambiguous about this. We are going to close Guantanamo and we are going to make sure that the procedures we set up are ones that abide by our constitution. That is not only the right thing to do but it actually has to be part of our broader national security strategy because we will send a message to the world that we are serious about our values.

Waffling or Just Providing the Details?
So, is Obama waffling as some progressives argue, or is he simply providing the details concerning a broad promise to close down the facility? I believe that both things are at play. Obama's campaign statements about Guantanamo Bay do not describe a complicated process that will take into consideration a plethora of factors that make shutting it down more difficult than most people realize. Instead, they make closing the facility the "first step" towards repairing the nation's international reputation.

Also, while Obama's earlier statements emphasize the need to adhere to the Geneva Convention and to rely upon federal courts to try terrorists, he now indicates that he will need to balance his reform with the fact that "tainted evidence" nonetheless indicates the guilt of some detainees. But if Obama wishes to prosecute alleged terrorists in federal courts, then the use of tainted evidence will prove difficult (especially if by "tainted," Obama means the evidence was obtained through coercion).

Although Obama's recent statements with respect to Guantanamo Bay are in fact much more guarded and nuanced than what he said during his presidential campaign, progressives must accept responsibility for uncritically assessing his political rhetoric. Progressives tried to turn Obama's campaign message of change into a leftist social movement. They believed that his success meant the country had become more liberal and that Obama would have a tremendous amount of deference to implement his campaign promises.

Progressives constructed Obama as the "change they had been waiting for," rather than someone who would deliver centrist and triangulating politics. But, as I have argued before, an election is not a social movement. Although social movements use elections in order to place their messages in public discourse and to secure political support for their agendas, elections alone do not create or even necessarily indicate the possibility of social change.

Regardless of whether Clinton or Obama won, progressive social movements would have to engage in activism to secure the implementation of liberal reform. Apparently, some progressives have only recently begun to understand this reality. The use of progressive symbolism by Obama's campaign led many leftists to believe that he alone could bring progressive reform. But once the poetry and emotion of a campaign subsides, governing truly happens in prose. For failing to accept this earlier, progressives must blame themselves.

Related Readings on Dissenting Justice:

If Obama Emulates Lincoln, Will Progressives Follow Abolitionists and Radical Republicans?

2008 Is Not 1964: Why Liberal Mania and Conservative Panic Are Nothing But Melodrama

Chicken Little Politics: Moderate Obama Causes Progressive Panic

Progressives Awaken from Obama-Vegetative State

Governing In Prose: Obama's Cabinet Picks Defy Campaign Narrative That Emphasized "Hope," "Change," and "Washington-Outsider" Status