Satanism, Religion, and Racial Hegemony

Todd Bilsborough
A Satanist Reads the Bible
20 min readJun 6, 2020

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This essay is also available as a podcast on anchor.fm and other platforms.

On the evening of Monday, May 25th of this year, George Floyd, a 46-year old black man, purchased a pack of cigarettes from a convenience store in Minneapolis. Believing that Floyd had paid with a counterfeit bill, the employees of the store confronted him and then called the police. Minneapolis police officers Thomas Lane and J. Alexander Kueng arrived on the scene shortly after and detained Floyd until further backup arrived, that being the Minneapolis police officers Derek Michael Chauvin and Tou Thao, both of whom had a documented history of disciplinary violations and violence and brutality against black people. After a brief struggle with Floyd while he was handcuffed in the back of a police cruiser, Chauvin pulled Floyd from the vehicle onto the ground and kneeled down on his neck. Kueng and Lane assisted in the restraint. Floyd told the officers that he was unable to breathe, and repeated this continually. Bystanders observing and filming the incident expressed concern for Floyd’s safety, concerns which the officers casually dismissed. As Chauvin continued to kneel on Floyd’s neck, Floyd began to beg for his life. Bystanders continued to express concern for Floyd’s situation and condition, and the officers continued to ignore these complaints. Five minutes and fifty-three seconds after Chauvin had begun to kneel on George Floyd’s neck, Floyd became unresponsive. At the urging of bystanders, Kueng checked Floyd’s pulse and was unable to find one. Chauvin’s knee remained on Floyd’s neck during this time and afterwards, and the officers made no attempt at providing Floyd with medical treatment. Chauvin held his knee on George Floyd’s neck for a total of eight minutes and forty-six seconds, with Floyd being unresponsive for the final two minutes and fifty-three seconds of that duration. He was removed from the scene by emergency medical technicians and brought to the county medical center. During transit, he went into cardiac arrest. At 9:25 PM, he was pronounced dead. Both the official county autopsy and a private autopsy ordered by Floyd’s family determined that his death was a homicide. Combining this with the information from witnesses and video documentation of the above event, we can definitively say the following: Minneapolis police officer Derek Michael Chauvin, assisted by Minneapolis police officers Tou Thau, Thomas Lane, and J. Alexander Kueng, representing the governments of Minneapolis, Minnesota, and the United States of America, and acting in the capacity of and under the sanctioned authority of the same, murdered George Floyd (“Killing of George Floyd,” 2020; citations in the article checked where possible, but some official documents are unavailable, apparently due to strain on the hosting servers; however, this account is consistent with the video evidence; further documentation listed in the references as Hill et al., 2020; The Death of George Floyd, n.d.; and “The Last 30 Minutes of George Floyd’s Life,” 2020).

The Minneapolis police department fired all four officers the next day and charges have been brought against Chauvin, but regardless, protests spread across the country in the wake of George Floyd’s murder, opposing the brutality of this specific incident, the long legacy of police brutality against black people in particular, and police brutality in general. A week after Floyd’s murder, on the evening Monday, June 1st, protesters were peacefully demonstrating in Lafayette Square, a park in Washington D.C. located directly north of the White House. Lafayette Square, by the way, is named for Gilbert du Motier, Marquis de Lafayette, a French military leader who fought with the Americans in the Revolutionary War and who, in a 1790 speech, said, “When the government violates the people’s rights, insurrection is, for the people and for each portion of the people, the most sacred of the rights and the most indispensable of duties.”

At the time, President Donald Trump was in the White House Rose Garden, making a speech in which he vowed to escalate the use of police and military force against the citizens of the United States. Just before 7 PM, police officers and National Guard troops entered the square and dispersed the crowd with tear gas and flash bangs, apparently so that the President could walk from the White House to St. John’s Episcopal Church, which is located at Lafayette Square, for a publicity shoot in which he was photographed holding a Bible. A reporter asked if it was his Bible. “It’s a Bible,” he said. Responding to the incident, bishop of the church and of the Episcopal Diocese of Washington Mariann Budde said “He did not pray. He did not mention George Floyd, he did not mention the agony of people who have been subjected to this kind of horrific expression of racism and white supremacy for hundreds of years” (Rogers, 2020). “Let me be clear,” she added in a statement to the Washington Post, “The president just used a Bible, the most sacred text of the Judeo-Christian tradition, and one of the churches of my diocese, without permission, as a backdrop for a message antithetical to the teachings of Jesus” (O’Neil, 2020). This is yet another example of the use of the Bible as a symbol of oppression, in defiance of its actual contents.

The propaganda photos that Trump produced from this incident demonstrate the relevance of this issue to my work here at A Satanist Reads the Bible. Racial hegemony and police violence in America are inextricable from religion, and Satanism, while not necessarily partisan in either direction, is necessarily political. Christianity cannot be disentangled from American politics, and so neither can Satanism. America is a Christian nation: founded by Puritans for religious reasons, ideologically based on Christianity, and demographically and culturally Christian, and as Satanism is dialectically opposed to Christianity, so too must Satanism be dialectically opposed to America. I’ll emphasize once again that this is not at all the same as being anti-American; to the contrary, the aim is not to destroy America but to uphold and strengthen it. Satanism represents opposition to dogma and hegemony, and it’s impossible to stand in opposition to the dogma and hegemony of something intrinsically political — Christianity — without the opposition being political as well, and indeed, American politics are rife with dogma and hegemony even aside from its relationship to Christianity. All this in addition to Satan clearly representing opposition to tyranny, as we see in the Miltonian narrative of Paradise Lost.

What’s more, Trump is signalling that he intends to use his power to silence political opposition. On Sunday, May 31st, Trump declared that he would designate antifa as a terrorist group, despite antifa not being a group of any sort but rather a catch-all descriptor for anti-fascist political movement (Nguyen, 2020). While such a designation would likely be legally impossible (Clarke, 2020), it does signal Trump’s intent to silence ideological opposition to his authoritarian leadership. While I doubt that Satanism itself is very high on the Trump administration’s radar, given this action and Trump’s fetishism of Christianity, this threat to ideological opposition is something that is relevant to and should be highly concerning for Satanists, thus necessitating our political action and opposition to this presidency.

The history of racism is long and complex, and religion plays a prominent role throughout. Race itself is a social construct: biologically-speaking, people of all ethnicities are members of the same human species, and there is no biological reason to divide humanity up into distinct races. The Israeli historian Yuval Noah Harari describes these kinds of social constructs as imagined orders, which, in general and not with regards to this particular order, are necessary, but which are often used as a means of social control and which must be sustained through violence and through belief that the imagined order is the objective, natural order (2015), belief which has historically often been inculcated through religion. Professor of religious studies Jason Bivens notes (2018) that cultures and religions have historically imposed hierarchical characteristics onto these constructed racial divisions, such as rational versus emotional or sophisticated versus primitive, and these differences are believed to have been the result of the divine hand of creation and an indication of God’s intentions for humanity. Professor Bivins also notes that historical racism was often Biblically justified: some American protestants believed that, for the crime of murdering Abel, Cain was marked by God with dark skin, and that dark-skinned peoples were thus indicated by God as being predisposed towards violence (Genesis 4:15, though this verse states that God marked Cain in order to protect him from human retribution for his crime); or that dark-skinned peoples were descendants of Ham, son of Noah, who was, in retribution for Ham having looked on Noah when he was naked and drunk, cursed to be, along with his descendants, the “lowest of slaves” (Genesis 9:25, though this verse states that the Caananites are to be servants only to Ham’s brothers). I’ve personally encountered at least one person who still believes this. And to this day, God is widely believed by Christians — whether explicitly or implicitly — as being a white man (Bivens, 2018). Do a google image search for “Jesus” and you’ll find, almost exclusively, images that depict him as a white European rather than as the Palestinian Jew that he actually was. Jesus is, of course, believed by Christians to be God, and the Google image search results for “God” are similar.

The treatment of the indigenous peoples of the Americas by Christopher Columbus and his party, along with their treatment by English colonists, which eventually resulted in one of the worst genocides in human history, was, in their view, justified through Bible verses and other religious language (Zinn & Arnove, 2015). In the 19th-century, British missionaries used a Bible to convert and educate slaves, a Bible that had been edited to exclude passages that might inspire rebellion and to emphasize passages that reinforced obedience (Martin, 2018). In the second of the Federalist Papers, a collection of essays by some of the Founding Fathers urging the ratification of the United States Constitution, Founding Father John Jay stated

Providence has been pleased to give this one connected country to one united people — a people descended from the same ancestors, speaking the same language, professing the same religion, attached to the same principles of government, very similar in their manners and customs, and who, by their joint counsels, arms, and efforts, fighting side by side throughout a long and bloody war, have nobly established their general liberty and independence.

Hamilton et al., 2014, pg. 8

And racist organizations and movements such as the KKK and Christian Identity explicitly believe that their actions are fulfilling God’s plan for America (Bivins, 2018).

In the contemporary United States, Christianity, whiteness, and American national identity are tightly interconnected. In The Nationalist Revival (2018), political analyst John Judis describes how the “Euro-American” became the widely-accepted archetype of the true American, as espoused primarily by right-wing American nationalists. According to a poll cited by Judis, in 2004, 60 percent of Americans believed that the only true American were English-speaking Christians who had lived in America most of their lives. The nationalist and religious connection to whiteness can be seen in the treatment of President Barack Obama by the nationalist Tea Party movement. Judis provides a quote from the book Change They Can’t Believe In: The Tea Party and Reactionary Politics in America by sociologists Christopher Parker and Matt Barreto (2014) which states:

We submit that the strength of the Tea Party opposition has something to do with, frankly, the threat associated with a nonwhite commander in chief and what he represents to supporters of the Tea Party: a threat to the cultural dominance of “real Americans.”

Judis continues:

What was probably at work here was an implicit acceptance of the Euro-American prototype. The acceptance of that prototype allowed some Americans to believe, even in the face of contrary evidence, that a black man whose views they detested was not really an American — that he was born in Africa, where his father resided.

p. 63

More recently, supporters of Donald Trump have claimed that “the success of the United States is part of God’s plan,” and that “the federal government should declare the United States a Christian nation” (Judis, 2018, p. 68), and while I noted earlier that the United States is indeed a de facto Christian nation, it should by no means be declared one as a matter of official policy. During Judis’s coverage of Donald Trump’s 2016 presidential election campaign, Judis found that this same demographic cited black Americans in particular as contributing to America’s moral decline (2018, p. 71).

President Trump himself is overtly and notoriously racist, with journalists David Leonhardt and Ian Prasad Philbrick having compiled and published an extensive list in the New York Times in January of 2018 documenting racist statements and behavior going back to the 1970’s. Donald Trump’s rhetoric has an indirect but nevertheless causal relationship to incidents of racial violence in the United States and around the world. In a piece on the radio program Here and Now titled “Communities Still Reeling After 2 Deadly Attacks On Worshippers” (2019), security analyst and counterterrorism expert Juliette Kayyem discusses the rise of domestic terrorism incidents and stochastic terrorism in general in the United States — with stochastic terrorism being terrorism that is statistically predictable despite being unpredictable on the individual level — stating that a key factor in this growing problem is the terrorists’ “sense of acceptance in the public space.” Having a president who holds and expresses racist sentiments is surely a strong indicator of public acceptance of those sentiments.

And yet President Trump enjoys very strong support among white evangelical Christians, who, by a nearly 2-to-1 margin over other Americans, are more likely to describe Trump as “morally upstanding” and “honest” (Survey, 2020, with data drawn from “Americans’ Views on Trump, Religion and Politics,” 2020), and this despite Trump — though he has argued to the contrary — being clearly nonreligious himself and unfamiliar with the Bible (O’Neil, 2020), and consistently acting in direct contradiction to supposed Christian values and the teachings of Jesus and of the Bible (Serwer, 2018). Indeed, a scholarly analysis of the 2016 election by political scientists Brian Schaffner, Matthew MacWilliams, and Tatishe Nteta, indicates that Trump’s support among his base exists not despite his racism (and sexism), but because of it (2018).

This is the nature of Christian hegemony in the United States. This is why I am a Satanist.

Donald Trump’s racism and the racism of many Americans exists in the context of a systemic oppression of nonwhites that is deeply intertwined with religion and which has prevailed on this continent ever since the first white colonists arrived here. Many of these systems are so old that those now in control of them may have nothing at all to do with their origination, and they may perpetuate these systems despite having the best of intentions. Racist police violence — which often goes unprosecuted and unpunished (Mapping Police Violence, n.d.) — is one example. As another example, many of the laws created as part of the War on Drugs were established during the Nixon administration. John Ehrlichman, one of Nixon’s top advisors, said of these laws:

We knew we couldn’t make it illegal to be either against the war or black[s], but by getting the public to associate the hippies with marijuana and blacks with heroin, and then criminalizing both heavily, we could disrupt those communities. We could arrest their leaders, raid their homes, break up their meetings, and vilify them night after night on the evening news. Did we know we were lying about the drugs? Of course we did. (LoBianco, 2016, with some edits made to punctuation for clarity)

Similarly, until 2010, prison sentences issued for crimes involving crack cocaine required only one one-hundredth as much of the drug for the same sentence. Crack and powder cocaine are two different forms of the same drug, but crack cocaine has historically been used primarily by black Americans. Under the 2010 Fair Sentencing Act, this disparity was reduced from 100:1 to 18:1, though the American Civil Liberties Union maintains that, while this mitigates this disparity, it fails to eliminate it, as the only truly fair ratio would be 1:1 (Fair Sentencing Act, n.d.). Those who prosecute and prescribe sentences for drug crimes may not be racist at all, but they nevertheless perpetuate racist systems created by racist people for racist purposes.

Now I’m going to proceed into what I’ve always done with this project, which is looking at sacred texts and seeing what they really say. Over the course of this project, I’ve found that my understanding of what “sacred text” really means has broadened considerably. For example, it makes sense to talk about the U.S. Constitution and Bill of Rights as sacred texts. Likewise, we can talk about the Code of Conduct of the Minneapolis Police Department as a sacred text. This is, after all, a social document setting forth guidance for ethical behavior, so it certainly plays at least a roughly similar role in society to documents like the Bible or the Qur’an. I’m certain that many or all police forces throughout the country have similar codes of conduct.

The Minneapolis Police Department Code of Conduct begins at section 5–100 of the Minneapolis Police Department Policy and Procedure Manual. The first section of the Code states the authority and purpose of the document:

The code of conduct of the Minneapolis Police Department is promulgated by the Chief of Police by authority of the City Charter, Chapter 6, Section 1, as amended. This code is established to promote efficiency, discipline, and good public relations in setting forth policy governing the conduct of all Department employees.

Section 5–102.01 is the Code of Ethics, which appears to be structured as a sort of oath:

“As a Minnesota Law Enforcement Officer, my fundamental duty is to serve mankind; to safeguard lives and property; to protect the innocent against deception, the weak against oppression or intimidation, and the peaceful against violence or disorder; and to respect the Constitutional rights of all to liberty, equality and justice.…

“I will never act officiously or permit personal feelings, prejudices, animosities or friendships to influence my decisions. With no compromise for crime and with relentless prosecution of criminals, I will enforce the law courteously and appropriately without fear of favor, malice or ill will, never employing unnecessary force or violence and never accepting gratuities.

“I recognize the badge of my office as a symbol of public faith, and I accept it as a public trust to be held so long as I am true to the ethics of the police service. I will constantly strive to achieve these objectives and ideals, dedicating myself before God to my chosen profession…law enforcement.”

Honestly I don’t think I need to say much about this. Just reading it is damning enough and yet another example of supposedly authoritative documents being misused, misrepresented, or ignored. Clearly all of this is just empty talk. Why? For what reason? Why even bother writing this or putting it on your website if you’re not going to abide by it? Who benefits from this? Whom do the police officers of the Minneapolis Police Force serve?

The answer to that last question is an interesting one. Ostensibly the people. That’s what the oath I just quoted says, after all. “As a Minnesota Law Enforcement Officer, my fundamental duty is to serve mankind.”

On Monday, June 27, 2005, the Supreme Court of the United States ruled on the matter of Town of Castle Rock, Colorado v. Jessica Gonzalez. In a New York Times Article titled “Justices Rule Police Do Not Have a Constitutional Duty to Protect Someone,” journalist Linda Greenhouse (2005) reports:

For hours on the night of June 22, 1999, Jessica Gonzales tried to get the Castle Rock police to find and arrest her estranged husband, Simon Gonzales, who was under a court order to stay 100 yards away from the house. He had taken the children, ages 7, 9 and 10, as they played outside, and he later called his wife to tell her that he had the girls at an amusement park in Denver.

Ms. Gonzales conveyed the information to the police, but they failed to act before Mr. Gonzales arrived at the police station hours later, firing a gun, with the bodies of the girls in the back of his truck. The police killed him at the scene.

Justice Antonin Scalia’s opinion on the ruling opens by stating that:

We decide in this case whether an individual who has obtained a state-law restraining order has a constitutionally protected property interest in having the police enforce the restraining order when they have probable cause to believe it has been violated. (Castle Rock v Gonzales (2005), n.d.)

The 7–2 ruling of the court was that no such constitutionally protected property interest exists. Apparently this ruling upholds that of an earlier case, Warren v. District of Columbia. That case describes a horrific incident that I really have no words to describe and I’m not going to try. I’ll include the link to the Wikipedia article for the case in my references and you can check it out if you want, and I’ll just give a content warning of horrific violence towards women (“Warren v. District of Columbia,” 2020). The 4–3 ruling of the court in that case was, similarly, that the police do not have a constitutional duty to protect people.

So that answers our question about whom the police serve. They are instituted by the authority of the state; it is the state that gives them power and authority, and ostensibly, in a republic, that power flows from the people, but if that’s not the case — and the Supreme Court of the United States has ruled that it is indeed not the case — then that leaves the police serving only the interests of the state. And if that’s the case, and if the power and authority of municipal police departments include the power to take lives with impunity, as they evidently do, then this country is de facto, by definition, no longer a republic. What is it, then?

In Politics as a Vocation, from 1919, sociologist Max Weber famously set forth his thesis that a state is defined as the regional authority with the monopoly on violence (“Monopoly on Violence,” 2020). And that seems entirely reasonable to me as a definition for the state. Certain organizations in the United States have the legitimate authority to use violence on citizens. The United States stops exactly where that legitimate authority ends. Nowhere where that authority does not exist is part of the state. That means they’re logically equivalent. The monopoly on violence is a necessary and sufficient condition for the regional existence of the state. Remember that in the account of the murder of George Floyd, there were numerous bystanders who, while doing the best they could to intervene by expressing concern and by documenting the event, clearly recognized the authority of the police. If a group had seen a civilian kneeling down on another person’s neck in that fashion, I believe that people would have physically intervened. And let me emphasize again that I would not in any way have expected the bystanders to physically intervene and I respect their courage for standing and filming when the police have used violence in the past against people who were merely observing police interactions.

So, the state is defined as the ones with the regional monopoly on violence. If that power is vested in police forces but ultimately flows from the people, then the state is the people and the state is a republic. If that is not the case, then the state is the police themselves.

The United States is a police state.

Let’s turn now to the philosophical literature on the legitimacy of government authority, starting with Leviathan by the English philosopher Thomas Hobbes, published in 1651. In Leviathan, Hobbes argued for the absolute power of the monarch, based on the reasoning that rule under a monarch was better than the natural state of humankind, which Hobbes famously described as being “solitary, poor, nasty, brutish, and short,” a “war of all against all.” This would seem to leave the present police state as being justified, but quoting the Stanford Encyclopedia of Philosophy regarding Hobbes’ opinion on the matter, we read that, in Hobbes, “Political legitimacy depends not on how a government came to power, but only on whether it can effectively protect those who have consented to obey it; political obligation ends when protection ceases” (Lloyd & Sreedhar, 2019, emphasis mine).

But Hobbes is arguably one of the more extreme of the social contract theorists and did not have as much of a direct influence on the American political system as, for example, John Locke, whom I’ve talked about in this project before. Locke’s Two Treatises on Government, from 1689, like Leviathan, discuss the justification for political authority, but come to much different conclusions. The work of John Locke was a major influence on the founding fathers, and Lockean language can be found throughout America’s founding documents. Section 232 of the Second Treatise begins:

Whosoever uses force without Right, as every one does in society, who does it without Law, puts himself into a state of War with those, against whom he so uses it, and in that state all former Ties are cancelled, all other Rights cease, and every one has a Right to defend himself, and to resist the Aggressor.

And earlier, in section 229, Locke states:

The end of Government is the good of Mankind, and which is best for Mankind, that the People should be always expos’d to the boundless will of Tyranny, or that the Rulers should be sometimes liable to be oppos’d, when they grow exorbitant in the use of their Power, and imploy it for the destruction, and not the preservation of the Properties of their people?

And I’ll conclude with the words of Thomas Jefferson, who, in a letter to William S. Smith, written in 1787, asked “What country can preserve its liberties if their rulers are not warned from time to time that their people preserve the spirit of resistance?” (Jefferson & Peterson, 1984, punctuation changed to reflect modern conventions). According to every philosophical foundation on which this country is based, resistance to and rebellion against the police state is justified and warranted. To the furthest extent possible, I hope that this movement against tyranny will be peaceful and safe for all those involved.

Works Cited and Referenced

5–100 Code of Conduct. (n.d.). Retrieved June 3, 2020, from http://www.ci.minneapolis.mn.us/police/policy/mpdpolicy_5-100_5-100

Americans’ Views on Trump, Religion and Politics. (2020, March 12). Pew Research Center’s Religion & Public Life Project. https://www.pewforum.org/2020/03/12/white-evangelicals-see-trump-as-fighting-for-their-beliefs-though-many-have-mixed-feelings-about-his-personal-conduct/

As Trump Calls Protesters ‘Terrorists,’ Tear Gas Clears a Path for His Walk to a Church. (n.d.). Retrieved June 3, 2020, from https://www.nytimes.com/2020/06/01/us/politics/trump-governors.html

Bivins, J. (2018). Thinking about Religion and Violence. https://www.thegreatcoursesplus.com/thinking-about-religion-and-violence

Castle Rock v Gonzales (2005). (n.d.). Retrieved June 3, 2020, from http://law2.umkc.edu/faculty/projects/ftrials/conlaw/CastleRock.html

Clarke, J. M. B., Colin P. (2020, June 1). Why Trump Can’t Designate Antifa as a Terrorist Organization. Slate Magazine. https://slate.com/news-and-politics/2020/06/antifa-terrorist-organization-designation-trump.html

Communities Still Reeling After 2 Deadly Attacks On Worshippers. (2019, December 30). https://www.wbur.org/hereandnow/2019/12/30/religious-attacks-texas-new-york

Fair Sentencing Act. (n.d.). American Civil Liberties Union. Retrieved June 3, 2020, from https://www.aclu.org/issues/criminal-law-reform/drug-law-reform/fair-sentencing-act

Greenhouse, L. (2005, June 28). Justices Rule Police Do Not Have a Constitutional Duty to Protect Someone. https://www.nytimes.com/2005/06/28/politics/justices-rule-police-do-not-have-a-constitutional-duty-to-protect.html

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Hill, E., Tiefenthäler, A., Triebert, C., Jordan, D., Willis, H., & Stein, R. (2020, May 31). 8 Minutes and 46 Seconds: How George Floyd Was Killed in Police Custody. The New York Times. https://www.nytimes.com/2020/05/31/us/george-floyd-investigation.html

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Lloyd, S. A., & Sreedhar, S. (2019). Hobbes’s Moral and Political Philosophy. In E. N. Zalta (Ed.), The Stanford Encyclopedia of Philosophy (Spring 2019). Metaphysics Research Lab, Stanford University. https://plato.stanford.edu/archives/spr2019/entries/hobbes-moral/

LoBianco, T. (2016, March 24). Report: Nixon’s war on drugs targeted black people. CNN. https://www.cnn.com/2016/03/23/politics/john-ehrlichman-richard-nixon-drug-war-blacks-hippie/index.html

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Martin, M. (2018, December 9). Slave Bible From The 1800s Omitted Key Passages That Could Incite Rebellion. NPR.Org. https://www.npr.org/2018/12/09/674995075/slave-bible-from-the-1800s-omitted-key-passages-that-could-incite-rebellion

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O’Neil, L. (2020, June 2). What do we know about Trump’s love for the Bible? The Guardian. https://www.theguardian.com/us-news/2020/jun/02/what-do-we-know-about-trumps-love-for-the-bible

Parker, C. S., & Barreto, M. A. (2014). Change They Can’t Believe In: The Tea Party and Reactionary Politics in America — Updated Edition (Revised edition). Princeton University Press.

Rogers, K. (2020, June 1). Protesters Dispersed With Tear Gas So Trump Could Pose at Church. The New York Times. https://www.nytimes.com/2020/06/01/us/politics/trump-st-johns-church-bible.html

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The death of George Floyd: What video shows about his final minutes. (n.d.). Retrieved June 3, 2020, from https://www.youtube.com/watch?v=FMGUAHBFmjk

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Warren v. District of Columbia, 444 A. 2d 1 (Court of Appeals 1981).

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Zinn, H., & Arnove, A. (2015). A people’s history of the United States (Thirty-fifth anniversary edition). HarperPerennial.

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