John Locke and Contemporary American Resistance Movements
Introduction
This piece is written as a response to the use of John Locke’s political thought to justify recent resistance movements in the United States, with some special focus on Susan Liebell’s recent essay, “BLM vs. #BLM: The Dangers of the New Armed Rebellion Narrative.” My goal is to provide a point-by-point refutation of the misuses of Locke’s thought that are commonly employed today by popular culture and academic commentators alike. These abuses of Locke’s thought were anticipated in my 2021 book, John Locke and the Uncivilized Society: Individualism and Resistance in America Today (Lexington Books). I have argued therein that Americans who today employ Locke, especially in support of some resistance act, do so in an ideologically closed-minded manner to justify their partisan proclivities. The structure of Locke’s arguments facilitates and subtly encourages such interpretations of his work. I argue this is true because Locke’s work was itself a work of propaganda, not of political philosophy. Though I must refer the reader to my book for the development of this broader concept, I will here develop what a propagandistic employment of Locke looks like regarding contemporary American resistance movements. Indeed, the use of him today often represents the employment of propaganda as political theory, and may serve as a warning against this tendency in political philosophy today.
Locke is misapplied to American politics today for one basic reason. Locke’s work on resistance assumes that Civil Society has been vitiated and, specifically, that the process of providing consent to society has been interrupted, that thereby a state of war obtains between society members and society leaders.[1] In order for this to occur, it is imperative that the means of offering consent to government have become ineffective, as was the case during the American Founding. When the Declaration of Independence pointed to abuses of power in the English system, it referenced: first, policies carried out by the government as policy and, second, the lack of representation, the inability for colonists to participate in the consent giving process. The situation is fundamentally different today. In some but not all resistance movements, we find resistance to acts that are not even the policy of any government entity in America. And in some but not all resistance movements, we find resistance acts that do not even deign to argue that the consent process has been violated. The only recent episode of resistance that would possibly (not certainly) receive Lockean support is the January 6th uprising at Capitol Hill. Neither the right-wing occupation of publicly owned lands in the west nor the violence and public damage caused by Black Lives Matter uprisings would find support from Locke’s thought, though he would not have censured the expression of conscionably held beliefs by parties on either side of the aisle.
Lockean endorsements of our contemporary resistance movements are replete in popular and academic literature. Some authors overtly look to Locke to justify the Black Lives Matter (hereafter BLM) resistance movement.[2] Others look to Locke to justify the individual-level self-defense actions that have emerged in response to BLM protests.[3] In popular culture the references are generally towards the “social contract,” and framed in basic Lockean form. Trevor Noah did so on Comedy Central’s “The Daily Show with Trevor Noah” shortly after George Floyd’s death.[4] Another pop culture writer developed this idea:
“Furthermore, if we consider that the social contract itself has only ever been extended towards a certain type of person -historically a white male- as well as the American states’ roots in genocide and white supremacy, it would not be unreasonable to conclude that the United States made a mockery of the social contract from the moment of its existence.
Let me repeat. When your life does not matter to the leadership, the social contract no longer exists. The American state has proven, time and time again, that Black lives do not matter to them. Not only with regards to policing, but every facet of society: education, healthcare, housing, and so on.”[5]
These references to Locke and his ideas in our popular culture suggest a superficial identification with the concept of a social contract, but they don’t exhibit a sophisticated understanding of it; the inadequately developed claims of white supremacy and genocide are to be expected from these sources in today’s climate. A superficial recognition of the concept of social contract is enough to justify aggressive political action to the average ideologue. Rebuttals to the claim that “the American state has proven…that Black lives do not matter to them” could obviously point to the anti-slavery language in Locke, the Declaration of Independence, the Constitutional Convention, the abolition movement, the actions of The American Civil War, the 13th-15th amendments, the Civil Rights legislation of the late 1950s and 1960s, Supreme Court rulings from the 1950s to today which support racial equality (ie, Brown v Board, Heart of Atlanta, Loving v Virginia, etc.), the election of a Black two-term President in 2008 and 2012 and the election of a woman of color to the Vice Presidency in 2020, in addition to the election of Black officials to countless lower offices (beginning with Wentworth Cheswell in the year 1776) and surely to a number of other things. The American state has demonstrated, time and again, that Black lives matter very much to our society and that they contribute mightily to it; that those Black lives are worthy of taking governmental action to defend. Few causes have ever proven more meaningful to the American state throughout its history; we are not just dedicated to equality; we are thoroughly and profoundly dedicated to equality. That is truer today than it was when Locke, Jefferson, Lincoln or King Jr. argued it.
The social contract is employed to assault American order in the above and similar examples by cherry-picking historical events to encourage the political views preferred by the individual making the argument. But the plea that “the social contract has been broken” simply does not comport with the long history of laws in this nation that have attempted to advantage Blacks, nor does it comport with the social tenor of recent history, in which an advancing of Black interests occurs presently in pronounced fashion, for instance, through the preferencing of minority owned business interests, the calls to place minorities on boards of corporations, or through the trend of prosecuting police officers involved in confrontations with persons of color who are allegedly involved in the commission of some crime. We must acknowledge the oddity that Locke is being used to justify activism whose motivations do not turn on objective facts or objective policy matters about which all parties can agree: though some argue that the social contract is in fact being used to diminish Black interests, others might argue that it is being used to advance Black interests. Conscience cannot objectively and factually identify aggressor and victim in a clear-cut manner, as if our times were an example from Locke’s text, of, for instance, a robber stealing a purse on a highway, in a clear violation of natural and positive law.[6] Through a closer diagnosis of academic uses of Locke to justify resistance ideas, we can detect just how difficult it is to create a Lockean justification for resistance in an established liberal society in which consent is widely offered through popular sovereignty.
Susan Liebell’s Argument
Susan Liebell has penned the clearest ideological academic use of Locke’s thought as it regards contemporary resistance movements. In “BLM vs. #BLM: The Dangers of the New Armed Rebellion Narrative” she excoriates the resistance movements on the right, specifically the movements that opposed President Barack Obama’s Bureau of Land Management’s confiscatory land policies and the January 6th protest as violating basic Lockean tenets. Meanwhile, she lauds the BLM movement as embodying proper Lockean resistance principles. Those who participated in the Malheur occupation to protest the confiscation of private lands and the January 6th petitioning of Congress for a redress of an electoral grievance are portrayed as gun-crazed maniacs set to undo American’s constitutional order, while the BLM movement is downplayed as peaceful and intent upon upholding our nation’s fundamental principles. In John Locke and the Uncivilized Society, I criticized both the Malheur occupation and the Black Lives Matter Movement for their fundamental similarity regarding an inability to defer to elected officials whose power was authorized through the electoral process. My book was sent to press prior to the January 6th incident and it is not addressed therein. But I do not find January 6th compatible with BLM or Malheur, and will address its unique situation regarding consent below. We discover the heart of the problem here: while my analysis demonstrates that Lockean thought would not justify either of these recent resistance movements, Liebell falls into the trap – a tempting trap for any American living our ideological age – of blaming her ideological opponents for behavior that is mirrored in the ideology she endorses. Her work in this area is therefore worth diagnosing carefully.
According to Liebell, Ammon Bundy and the right-wing protesters who occupied government property in Oregon and Nevada “rely on a cherry-picked version of Locke’s social contract to justify armed rebellion or assassination.”[7] As my own research has demonstrated, I agree with the first half of this statement, and we will analyze their use of Locke momentarily. First, however, we must notice that Liebell includes assassination in the Lockean and American right-wing resistance formula. Though a reading of Locke might endorse assassination as a reasonable act of resistance,[8] assassination was never a goal of Bundy’s group, and the assassination attempt of the Michigan governor that she cites[9] is now known to be an FBI election-year entrapment[10]: assassination is not a goal of any recent well-known right-wing domestic organization. The inclusion of misleading assassination arguments is troublesome, and designed to create a false sense of danger about these groups. In Lockean language, there is an attempt to position these groups as introducing a state-of-war, which would justify an aggressive reaction against them. Some might consider this fear-mongering designed to mislead her audience. Before we even examine why the Malheur protesters were not Lockean, we must notice that Liebell has mischaracterized her subjects, attributing to right-wing protesters arguments and motives that never existed.
It is indeed a cherry-picked version of Locke that attempts to justify the right-wing occupations of government property in western states. The argument is quite simple: Barack Obama’s Bureau of Land Management policies, while unsavory to those individuals, were authorized by the American people through the election process. The election process also offered a means of rectifying their grievance: upon Trump’s election, not only did land management policies change, but the FBI agents who had engaged in nefarious actions during the occupation (such as shooting and killing one man in the back as he fled a vehicle the FBI had intentionally wrecked after inviting some occupiers to a negotiation in bad faith) were prosecuted and found guilty by bench juries, and juries found several protesters not guilty of charges brought by an exuberant government. In other words, although the group exceeded Lockean logic by ignoring the electoral process, the American public was sympathetic to their cause, and the election of Trump represents, among other things, the effectiveness of elections as a means of thwarting factional policies. The case shows both that an over-eager desire for resistance can be inspired by the basic Lockean formula of ‘life, liberty and property,’ but it also shows that the general recipe of consent as articulated by Locke is an effective means of expressing resistance through the ballot. We learn from this case the importance of subordinating resistance to consent within a functioning liberal society.
But it is also a cherry-picked Locke that attempts to justify BLM. This cherry-picked BLM Lockeanism violates each of the principles that Liebell properly detects as Lockean and properly applies to her critiques of the right-wing. According to Liebell, Locke would require three things to occur prior to rebellion. She does not believe that any apply to BLM. First, Locke would have called for a redress of grievances through all existing channels, especially elections and the courts, prior to violent resistance.[11] As my remarks above demonstrate, I am in agreement with Liebell on this important point. Yet, BLM has proven insensitive to the electoral and legal proceedings relevant to their cause. BLM has never alleged that electoral malfeasance is at the root of their movement. Time and again, in those cases accentuated by the media, indictments were sought by proper government officials through the proper channels, usually by convening a grand jury of American citizens. In many of these cases, grand juries denied charges, due to various factors specific to each case. In other cases, such as George Floyd’s, charges were brought and justice ultimately served by the courts. In the Ahmad Arbury case, state and federal officials bypassed the grand jury process to assure that charges would be brought against his alleged killers. If anything, the government has demonstrated a strong dedication to the principle of equality espoused by Locke by providing due process of law to alleged victim and alleged perpetrator alike, and even demonstrated a preferential treatment of victim over alleged perpetrator in the Arbury case. The legal channels and electoral channels to BLM have been robustly provided and exercised. Some cases have not panned out as BLM advocates would like; others have panned out just as they would prefer. Most important, however, no government agency involved in any BLM case has a policy of harming individuals because of their race. This stands in stark contrast to the actions taken by the British government, as a matter of policy and without providing the colonists with representation in government, which were conscionably objected in the Declaration of Independence. BLM cannot cite a policy of racial police discrimination, even if they can point to troubling incidents of racist acts by individuals acting outside of their authorized legal capacities.
Second, Liebell correctly argues that Locke would enforce a tight distinction between individual and group rights.[12] Liebell even adroitly cites Locke’s passage, “examples of an unfortunate man, moves them not.”[13] The point here is that the government must have demonstrated one of a few specific but pervasively damaging actions, according to Locke, before resistance by a majority would be countenanced. The most liberal of readings would only restrict resistance to widespread violations of trust, occurring repeatedly and forming a pattern of harm against the majority of individuals over time.[14] A more stringent reading would limit resistance to corruption of the election process or accepting bribes from a foreign nation.[15] Liebell is in foul territory here by asserting that a group grievance exists in BLM. In each of the prominent policing incidents that have inspired the movement, a specific individual was harmed by another specific individual acting outside of their legally authorized capacity. The protest chants specifically invoking participants, who were themselves not harmed, to “say their name” provide clear evidence of this: many individuals, themselves not harmed, were perfectly free to bring attention to the cause of the individual who was harmed. Liebell estimates that 15-26 million people participated in protests inspired by Floyd’s death. She does not explain how the death of one individual harmed the millions of protesters, but this is precisely the point. At this juncture we are asked to believe that those who protested in support of the Hammond family in Oregon lacked justice for doing so, because they were not themselves harmed, but that those who protested in support of Floyd do possess justice for their fundamentally similar actions: protesting in response to a perceived wrong against another individual. This is a fundamental contradiction, and I argue it is motivated by an ideological preferencing for one faction over another.
Third, Liebell correctly argues that Locke would not countenance resistance carried by individuals “with axes to grind.”[16] She writes that Locke would have “feared people like Trump and the members of the domestic terrorist groups pursuing their own ‘ambition, revenge, covetousness, or any other irregular passion.”[17] This part of her analysis further betrays its ideological motivation. A partisan Republican reader might believe that Liebell is grinding an axe. Such an individual might contend those characterizations of ‘revenge’ and ‘irregular passion’ should be applied to the lootings and arsons found at BLM protests as equally as they are applied to Malheur. The BLM movement has indeed been framed by many of its adherents as an exercise in axe grinding, for instance, one group of demonstrators chanting of police officers: “pigs in a blanket, fry ‘em like bacon.” Liebell does not explain why these adjectives should apply to former President Trump’s supporters, but not to protesters that opposed him by advocating for the assassination of innocent police officers; she does not explain why right-wing groups are “terrorist groups” but left-wing militant organizations are not, nor why Trump is responsible for right-wing political activity that he did not endorse but why left-leaning political leaders are not responsible for the left-wing activity that some have endorsed. These are also fundamental contradictions and inconsistencies in Liebell’s analysis, and they appear because of an ideological motivation for the analysis.
In addition to the three limitations to violence Liebell notices, Locke would make an additional limitation that is the cornerstone of his political thought, and serves as the nexus of a Lockean liberal system in an already established liberal democracy such as the United States. Once a Civil Society is established, elections and not violence become the primary mechanism by which society is maintained; it is the possibility of resistance, not the actual act, that serves in a civil society to motivate leaders to wield power responsibly.[18] Hence, acts of resistance should be discouraged when the electoral process provides the opportunity to consent to government. Liebell continues that Locke:
“…explicitly rejected armed rebellion to protect the rights of a ‘raving mad-man’ or a ‘heady malcontent.’ The language Locke used seems ripped from 21st-century headlines because the American 2020 election cycle — with its questions about the peaceful transition of power, challenges to certification, etc. — departed from the very core of liberal democratic politics that Locke articulated: rule of law, due process, and the social contract.”[19]
Liebell has again adroitly summarized important components of Lockean thought, while misapplying them in an ideological manner to her contemporary circumstance. Liebell demonstrates that she misunderstands the primacy of elections in our Lockean political system. The social contract is animated by the electoral process.[20] If elections are vitiated, the social contract is void.[21] Accordingly, if any recent resistance movement would receive Lockean support, it would be the January 6 act of resistance against the certification of the 2020 Presidential electoral votes on that date. A clear Lockean grievance existed in that resisters believed the election had been corrupted, and they believed that partisan or establishment actors within government prevented any good faith investigation into the election’s validity. It cannot be overstated this is the most fundamental of justifications for resistance in a Lockean society, and thoroughly represents the loss of trust between society members and leaders. Locke writes:
“if the Mischief and Oppression … seem to threaten all, and they are persuaded in their Consciences, that their Laws, and with them their Estates, Liberties and Lives are in danger … how they will be hindered from resisting illegal force, used against them, I cannot tell. This is an Inconvenience, I confess, that attends all governments whatsoever …. The most dangerous state which they can possibly put themselves in: wherein they are less to be pitied, because it is so easy to be avoided.”[22]
As of this writing, some 66% of republicans and 28% of independents still believe the election was stolen (29% of all survey respondents).[23] These numbers have not abated since the election, despite persistent media allegations that this belief constitutes a “big lie.” It is not objectively clear whether this is a lie or not. The inherent corruptibility of paper ballots, and their widespread use in 2020, make investigating this election both difficult and necessary. State-level reviews in Michigan and Arizona, despite being conducted by Republicans, were partisan efforts by Establishment Republicans, enemies of former President Trump, and both relied on dubious methodologies (the Arizona investigation, for instance, did not even review paper ballots, merely computer returns). The certification of the electoral college results signified the closing of the final channel through which any opportunity to discover the truth of the election might occur in a time and manner to prevent the formation of a potentially unauthorized government. The 6-3 decision by The Supreme Court not to rule on the merits of Trump’s claims, which otherwise might have forced an investigative effort, reflects a profound dereliction of duty to the solemnity of elections in the American political system and is a violation of the justices’ sworn oaths in a very fundamental way. Locke’s “so easy to be avoided” is vastly applicable here: an open and non-partisan review of the credibility of each paper ballot cast in the 2020 election would potentially cut-off the January 6 narrative at the knees, but the American people have not been provided one. When Democrats cast the 2016 election as incredible, President Trump appointed an Independent Special Counsel to investigate the alleged improprieties, and doing so allayed fears that the 2016 election was improperly influenced by foreign agents. President Biden should do the same to allay fears that the 2020 election was corrupted by fake paper ballots. This move would be consistent with Lockean theory, and more important, depending on its outcome, alleviate this “most dangerous state which they can possibly put themselves in.”
The denial of impropriety without offering thorough and credible investigations into the 2020 elections, therefore, does represent each of the conditions described by Liebell: 1. All channels to rectify or even to investigate the election’s credibility were denied to Trump and his supporters 2. A group grievance did exist: if the election was stolen (the public still does not know, despite the tired refrain that we do), that would constitute a fundamental harm to every single American citizen and 3. Based upon 1 and 2, the heart-felt, desperate pleas to investigate the possible corruption of an election by approximately one third of the nation’s population is neither the work of any derangement or irregular passion, but a square reflection of a popular American devotion to popular sovereignty. Indeed: no passion in the United States could be more regular or more proper than a passionate defense of our electoral processes, as the issue is commonly and positively framed in left-wing media outlets when leftists challenge states’ voting laws. Moreover, this passion is not felt by an isolated madman, but by the majority of the opposition party and nearly one third of the entire nation. Majority action cannot be the standard to justify even an investigation under these circumstances: such is the recipe for majoritarian tyranny. The possibility of January 6 should have encouraged an open and transparent investigation into the election, instead of barricading the Capitol behind barbed wire. January 6 was a Lockean example of a sizeable group of Americans, having exhausted all legal channels, attempting to reinstitute a Civil Society in which consent may actually occur in a trusting environment.
To be clear: had they been protesting almost any act other than an election by which consent authorizes government, they would not have found Lockean support. Had an honest and transparent investigation been provided, by actors who were not tied to the Democratic Party or to Trump’s opponents within the Republican Establishment, and had such an investigation provided no evidence of fraud in the return of paper ballots, those protesters would also not have found Lockean support. The fundamental mistrust of the democratic process exhibited in the protesting of an election result does not characterize Malheur or BLM. Malheur and BLM actors were afforded investigations by average citizens in grand juries and bench juries; objective review by non-partisan actors was not offered to Trump’s supporters. January 6th is potentially though not certainly Lockean in spirit.
Liebell views all activity associated with January 6th in any way as terroristic. By contrast, she is careful to point out the “peaceful” nature of “93 percent” of BLM protests (a claim that cannot be accurately measured).[24] The occupation of Malheur was 100 percent peaceful, but the fact that it was more peaceful than BLM protests does not discourage Liebell from chastising it. We could, of course, also speculate that 93 percent of individuals who participated in the protest at the Capitol on January 6 were peaceful. It would not change the fact that violence did occur. The same is true for BLM: violence did occur, private property was destroyed, lives of public servants and innocent bystanders were lost. To ignore or minimize this element of either movement is to ignore a fundamental equality between the two. To ignore or minimize the distinctions regarding consent between the two cases is to ignore a fundamental inequality between the two. The hard truth behind this debate is that violence is a component of human nature; the peaceful protesters involved honorably with BLM could no more forestall violence than could the peaceful protester involved honorably with January 6th. There is some indelible truth to Jefferson’s observation that the “blood of patriot’s and tyrant’s” must be occasionally shed in the defense of civilization. Indeed, it remains true that when honest recourse to true facts is forestalled by those with the power to do so, no other recourse exists. BLM continues to have a recourse at the ballot box, exercisable through persuasion. This may have affected the outcome of the 2020 election, just as the Malheur incident may have affected the outcome of the 2016 election. It remains fundamentally unclear whether this recourse through the ballot box was also true of Trump’s candidacy in 2020, making it a recent example that might have occasioned a just act of resistance, at least by Lockean standards.
The advocates of BLM and Malheur understand that their movements aspire for social justice, not political justice. Tacitly, this is an acknowledgment that there is nothing fundamentally wrong with the political system, that they merely lacked the votes which would empower their respective causes. A tenable criticism of my argument above would be that protesting is an essential method through which persuasion occurs in democratic systems: that both movements merely represent proper exercises of the First Amendment, and that both, again, may have affected the outcomes of political elections. Though this is a tenable argument, it is an argument for resistance that is not Lockean in nature. Neither movement has proven, neither has attempted to demonstrate, that their grievances were the product of policies which were conceived through undemocratic means. Both could be interpreted fairly as factional pursuits of power within the democratic system, that relied on the presentation of their social grievances as rectifiable through politics. Jockeying for power is proper and normal within any society, as we have known since Aristotle’s Politics. But this does not mean that political philosophy should become debased by engaging in factional conflicts. By doing so the primacy of consent within liberal societies is denigrated to the factional goal of an ideologue and expressed as a plea for resistance. The role of the political philosopher is to seek the best possible regime for all of society, and not to engage in this factional warfare. Finally, it is not clear that exercises of violence by BLM or by January 6th nor the intimidating tactics of Malheur, actually advanced the causes of the respective movements: we must consider that the same attention may have been achieved for their respective causes through less violent and intimidating means. In each case, it is possible that a softer form of persuasion facilitates change without incorporating coercive tactics into their movements. Such a course of action would be fitting for a civilized society.
Many in our society today would dispute my defense of January 6th as Lockean in nature. To defend that movement at this time appears to many to be engaging in the same factional or ideological behavior that I am criticizing. This is not true, although it is true that this argument is divisive along partisan fault lines. This is amongst the problems with a persistent claim that every grievance in America is consistent with some violation of the social contract, and that every grievance therefore justifies resistance in Lockean terms. When an incident that does engage the fundamental violation of the consent offering process, it is too easily lost in the cacophony of resistance claims within a divided pluralistic society. The little boy appears to be crying wolf. When everything looks like a wolf, of course, it becomes difficult to defend against real wolves. The defense of Civil Society requires us to more carefully dissect and more properly label movements which are factional in the pursuit of some ideological goal, and those which seek the defense of civilization through the defense of Civil Society and its most essential mechanism, the provision of consent to government.
Today’s philosophical irresponsibility is predictable based upon the manner in which Locke’s original formula was constructed. Locke pieces together an effective articulation of liberal values, but it is an ideological and propagandistic presentation; the diminishment of his own values by his followers today is baked into the original Lockean cake. This does not mean that liberalism has failed; it does mean that we should look to other seminal liberals, like Algernon Sidney, for deeper philosophical defenses of liberalism, to craft a breed of liberalism that is dedicated to the common good instead of to factional warfare.
Conclusion
The struggle and failure demonstrated by Liebell to shove Lockean thought into her ideological box is revealing. Each of her three points are indeed attributes of Locke’s political thought; and if we were for some reason using Locke as a gospel for rebellious action, she would indeed have correctly articulated certain limits to action. She has correctly noted that the Malheur occupation failed to meet Lockean standards, though she fails to notice January 6th’s unique relation to consent. She, moreover, fails to detect that all three of her own criteria for a Lockean resistance are violated by the BLM movement she so vociferously endorses. I contend that this is an ideological use of Locke, designed to rile factional differences and not an exercise of political philosophy, and emerges from Locke himself. Liebell is interpreting Locke exactly as we would expect a 21st century Lockean ideologue to interpret him. Lockean inspiration for ideological employments of resistance narratives are indeed very true to the spirit in which The Second Treatise was conceived and penned.
Notes
[1] John Locke. The Second Treatise of Government. §142
[2] Susan Liebell, “BLM vs. #BLM: The Dangers of the New Armed Rebellion Narrative.” Brennan Center for Justice, 2021.
[3] Lieder, Robert. The State’s Monopoly of Force and the Right to Bear Arms. Northwestern University Law Review. Forthcoming no. 116
[4] Liebell, 5
[5] Mara, The Aeiperon Blog. July 11, 2020. “BLM: The Social Contract Has Been Broken. What Now? According to John Locke this Makes the US Due for a Revolution, but in what Form?” accessed on 8/11/2021. Bold face and underlined type was the original author’s.
[6] John Locke. §18
[7] Liebell, 3
[8] Locke, §207,239
[9] Liebell, 2
[10] Lexi Lonas. The Hill. 7/20/21 “Men Accused of Whitmer Kidnapping Plot Say FBI Set Them Up.” Accessed on 8/18/21. https://thehill.com/homenews/state-watch/563902-men-accused-of-whitmer-kidnapping-plot-say-fbi-set-them-up-report
[11] Liebell, page 4
[12] Ibid., page 4
[13] Ibid.
[14] Locke, § 221-22
[15] Locke, § 214-220
[16] Liebell, 4
[17] Ibid.
[18] Locke, § 226
[19] Liebell, 4
[20] Locke § 95, 104-110, 138, 153
[21] Ibid., § 216
[22] Ibid., § 209
[23] Dickson, Caitlyn. August 4, 2021. Yahoo News. “Poll: Two-thirds of Republicans still think the 2020 election was rigged.” Accessed on 9/1/2021. https://news.yahoo.com/poll-two-thirds-of-republicans-still-think-the-2020-election-was-rigged-165934695.html?guccounter=1&guce_referrer=aHR0cHM6Ly93d3cuZ29vZ2xlLmNvbS8&guce_referrer_sig=AQAAANxVO3iPbwaEKkDhAemRMGEIsBE7gZjizJulGuUGEYvkZGnqXYjvNXV-NuN_W8MN-8eI6_c3qZN4Qov00vw0EIg5US-0B7Z3Xe-AbaKptqqaXoXN7urS4S4uxfZqBNPxJHKIT0JFhlCkF_oDK_lWOM6toCMcXutzJMn2HxVeUQ6n
[24] Liebell, 5
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