Issue 5 ReviewTHE HORACE MANN

Volume XXX - June 2021 THE HORACE MANN Letter From the Editors Table of Contents

Review DOMESTIC Who Won? Who Lost? INTERNATIONAL Alex Gerstenhaber page 2 Why Putin is Scared page 26 2 The 2020 Census and Redistricting Avi Rao Sasha Snyder Cycle 26 Editors-in-Chief Eshan Mehere China’s Fishing Fleet page 28 Andie Goldmacher Myra Malik Sonia Shuster Justice? Accountability? Punish- Executive Editors page 4 ment? The Trial Biden’s Promise to Withdraw US Adam Frommer Zahra Motwani Troops from Afghanistan: Long Over- Billy Leung due or Unwise Grandstanding? Republicans’ Automatic Assault on page 30 Oliver Steinman Sophia Liu Annabelle Xing Biden’s Gun Safety Agenda page 8 Managing Editors Ariela Shuchman QAnon’s Comeback: The Rise of Annabelle Chan Conspiracy Theory Across European Senior Designer The NCAA’s Day in Court : How It page 10 Countries page 32 n. 1 Went, and What Will Likely Hap- Cover image by Sarah Sun Alexander Cox pen Next Maya Westra Senior Editor - Domestic ello Horace Mann! It is our pleasure to present the final issue of Volume Leo Giorgini XXX of The Review. Ermeen Choudhury Investigating the Johnson & Johnson Senior Editor - International Vaccine Pause H COVID-19’s Impact on Global page 34 Yana Gitelman Warming Sophie Dauer During a year in which almost every week highlighted new questions about the Senior Editor - Features page 12 future of the United States, from the course of the pandemic to the election fallout Rachel Baez

Kurtis Chong FEATURES to vaccine rollouts, it was often difficult to look beyond our own borders. -How David Puckowitz The COVID-19 Crisis In India ever, as daily life continues encouragingly on its path back to normalcy, we are Senior Editors - Economics page 36 cognizant of the vast global disparities that this year has not only created but also Knight v. Trump and Digital Free 36 Karam Malhotra page 14 masked. Kush Malhotra Speech Senior Editor - Science and Technology Gavin Song The Unfolding Humanitarian Crisis in Thus, for Issue 5, our writers highlight the global south. Despite momentous glob- al progress in the realm of vaccine rollout, writers articulate the ways in which Corey Brooks Erik Hamel Venezuela and Its Effects on Women nations like India are still experiencing the pandemic’s tragic ramifications. Addi- Ria Chowdhry Tae Kyu Lee page 38 How Is Biden Doing So Far? Alexa Turteltaub tionally, contributors discuss other non-COVID related events such as the ongo- page 16 Logan Dracos Rowan Mally Simon Schackner ing humanitarian crisis in Venezuela. Theodore Ganea Walker McCarthy Leo Georgini Nathan Zelizer Comparing Governmental Responses Moreover, our writers express their views on other pressing topics both at home to COVID-19 in India and Australia Justin Gurvitch Should We Pack the Supreme and abroad by analyzing events and ideas such as Washington D.C.’s statehood, page 18 page 40 Court? the unprecedented rise of Bitcoin and cryptocurrency, and Biden’s promise to Junior Editors Owen Heidings withdraw all American soldiers from Afghanistan. Allison Markman

Jonathan Kotchian ECONOMICS As we conclude our time as co-editors-in-chief, we would like to thank all of our Avram Schlesinger Benefits of Investing in Bitcoin writers, members of the editorial board, and faculty advisors Dr. Kotchian and Mr. page 42 Faculty Advisors Why Washington D.C. Needs to 42 Schlesinger, for their tireless and determined work on the publication this year. It page 20 Jacob Silverstein The Horace Mann Review is a member of the Columbia Become a State has truly been a joy to present this publication to the Horace Mann community all Scholastic Press Association, the American Scholastic Press year, and we can’t wait to see what next year’s leadership has in store. Association, and the National Scholastic Press Association. Samantha Strasser Opinions expressed in articles or illustrations are not necessar- ily those of the Editorial Board or of the Horace Mann School. The $15 Minimum Wage: A Help or With much gratitude, we hope you enjoy our final issue. The Verdict Is In, But Are We Truly Hindrance? page 44 page 22 Fair Use Notice Done? Will Bramwell Sasha Snyder and Alex Gerstenhaber This publication contains or may contain copyrighted material, the use of which has not always been specifically authorized by the copyright owner. We Krish Gandhi Editors-in-Chief are making such material available in our efforts to advance understanding SCI-TECH Volume XXX of issues of economic, political, scientific, and humanitarian significance. We Millions of Americans Missing Second believe this constitutes a “fair use” of any such copyrighted material as provid- America’s Jobs Plan: Reconceptu- ed for in section 107 of the US Copyright Law. In accordance with Title 17 46 Vaccine Doses U.S.C. Section 107, this publication is distributed without profit for research alizing Infrastructure for a New page 46 and educational purposes. If you wish to use copyrighted material from this publication for purposes of your own that go beyond “fair use”, you must ob- Century page 24 Ria Chowdhry tain permission from the copyright owner. Isabel Mavrides-Calderón 1 Domestic Domestic

WHO WON? WHO LOST? The 2020 Census and Redistricting Cycle

Eshan Mehere

ast week’s release of the 2020 Unit- lina. Republicans only have to make up five All of this lines up with one major theme: ed States Population Census initi- seats to retake the House in 2022, and so this year’s census increased red states’ po- ated the tedious and contentious their incredible power over the redistricting litical representation and diminished blue processL of determining what Congress will state’s representation. Overall, Republicans, process will make reclaiming the majority look like in 2022, and for the next decade. easier. Indeed, it appears that redistricting armed with the control of many critical The census revealed that while the over- on its own is about to secure a Republican state governments, a small deficit of seats all U.S. population increased by roughly victory next November. The Cook Political to overcome, and a favorable result in the 25 million people over the past ten years, Report’s predictions of the maps estimate Census, are likely to be the early favorites to several states’ populations fell while others’ 20 Democrats to be at extreme risk of being retake control of the House in 2022.5 rose. The 435 seats in the House of Repre- taken out as a result of redistricting, com- It is not all bad news for the Democrats. sentatives are reallocated every ten years, pared to just 12 Republicans, and this ad- After all, as mentioned, Republicans’ path based on the results of the census. The 2020 vantage on its own is enough to propel the to power is heavily dependent on their count caused thirteen states to either gain G.O.P to a majority.3 ability to draw the maps and create con- or lose representation. This dynamic com- Although the G.O.P has a significant ad- gressional district combinations that are bined with the fact that the district lines in vantage via gerrymandering, they are also the most beneficial to them. Opposition to 46 out of the 50 states are about to be re- ecstatic with how the Census re-appor- gerrymandering is accelerating across the drawn, means that one party will come out tioned the Congressional districts through- country. Indeed, according to a 2019 na- of this census and redistricting cycle with a out the country. To explain, Texas voted for tional poll, both 59% of Republicans, and clear advantage over the other. As a result, Fmr. President Donald Trump by over 8% 65% of Democrats had an unfavorable view for the short term, the G.O.P. has won big.2 last November, and was one of the biggest of the practice. A second survey that year Republicans will benefit from their con- winners of the Census, gaining a whopping showed that over 70% of voters believed trol of most of the state governments in the two seats in Congress, a larger gain than any the Supreme Court should place restric- country. This control allows them, in many other state in the country.4 Furthermore, tions on the practice. This lack of public n. 9 cases, to redraw the maps in whatever way other states that went red up and down support, coupled with a bipartisan group advantages them politically. They also ben- the ballot including North Carolina, Flor- of politicians, including Republicans, Fmr. efit from the fact that the places gaining ida, and Montana were among those that Gov. John Kaisich and Fmr. Sen. John C. maps via a non-political commission, with for many years now, in recent years, they verse voters— and recent electoral history, representation in Congress, due to an in- gained seats. Meanwhile, several Democrat Danforth, calling for a regulation on the several other states likely to follow suit. have started to trend towards the G.O.P. indicate that they will probably move to- 8 crease in population, tilt to the right. How- strongholds, including , Califor- practice, means that the time of political Restrictions on gerrymandering will hurt , Pennsylvania, and were wards the Democrats in the future. ever, efforts to restrict gerrymandering, the nia, and lost seats, in addition to officials drawing maps may be ending. In Republicans, who have relied on the pro- either won twice or won once by Trump, af- Overall, while the Democrats may have 6 process of manipulating political maps with other states that voted for President Biden fact, several states, including G.O.P con- cess for decades. The more states that use ter being won twice, handily by Fmr. Pres- to swallow a defeat in the next few House a specific partisan lean, in addition to the last fall like Michigan and Pennsylvania. trolled Arizona and Ohio now draw their non-partisan processes to draw maps will ident Obama. Meanwhile, the states in the election cycles, a referendum on gerryman- fact that trends in population run in line likely result in a check on any GOP ill-got- South that have gained seats including Tex- dering and the U.S. population generally with the Democratic party’s long-term po- ten political gains. as, Florida, North Carolina, and Colorado shifting in line with their electoral pros- litical prospects, mean that they come out As detailed above, the reapportionment are mostly Republican strongholds for now, pects down the road, indicates that this of this cycle with a more robust long-term of seats in Congress benefits the G.O.P in but seem to be more reliable candidates to census and redistricting cycle is likely to advantage, even if it means they may have the short-term. However, demographic become a part of the Democratic coalition position Democrats in a favorable position, to bite the bullet in the near future. “Armed with the control of many critical state shifts revealed by the census line up with in the long-term. After years of Republican long-term. Republicans enter this decade’s cycle a long-term trend that excites Democrats. domination, 2020 was the first time in de- Republicans must provide alternative with the ability to draw the lines of over governments, a small deficit of seats to over- The census showed the shifting dynamics in cades that a Democratic presidential candi- policies to mitigate gun violence, or their 40% of Congressional districts, compared U.S. politics, as the overall trend was that date came within 6% of victory in Texas. In empty “thoughts and prayers” will contin- to a mere 17% for the Democrats. Republi- come, and a favorable result in the Census, high population states in the North and addition, Colorado has shifted from being ue to drive the mass exodus of American cans have full control over the redistricting Midwest lost seats, while states in the South a highly-contested swing state in 2012 to a youth from the party’s arms. HMR Republicans are likely to be the early favorites 7 commissions in up to 21 of the 50 states, in- and the Sunbelt gained seats. Though the state which Biden won by over 13%. Florida cluding the crucial, population-dense states to retake control of the House in 2022.” states that lost seats in the North, including and North Carolina are still controlled by of Florida, Texas, Georgia, and North Caro- New York, Illinois, Michigan, Pennsylvania, the G.O.P, but their shifting demograph- and Ohio, have voted in favor of Democrats ics—an increase in young, urban, and di-

2 The Horace Mann Review | Vol. XXX June 2021 3 Domestic Domestic

was a murder in the full light of day, and it torney for the Floyd family stated, “This is a the pending consequences, it is not true ripped the blinders off for the whole world victory for those who champion humanity accountability if Chauvin himself does not to see [systemic racism]...’‘I can’t breathe.’ over inhumanity…America where Breonna take responsibility. A comprehensive un- JUSTICE? We can’t let those words die with him. We Taylor gets an opportunity to sleep in peace derstanding of accountability requires both must not turn away.”23 Harris added, “A at night without the police busting in her a consequence and the active acknowledge- measure of justice isn’t the same as equal front door, and Ahmaud Arbery gets to run ment and apology of the perpetrator. With- justice…This verdict brings us a step closer. free and not be lynched for jogging while out Chauvin’s remorse, the verdict is sim- And the fact is we still have work to do. We Black.” Moreover, Floyd’s brother, Philonise ply punishment.27 Chauvin may be used ACCOUNTABILITY? still must reform the system.”24 Floyd, drew parallels between Emmett Till to feeling above the law and as though he Many activists echoed Harris’ belief that and : “To me, [Emmett Till] does not need to follow it due to the senti- the Chauvin conviction is only the begin- was the first George Floyd.” Emmett Till was ment of modern policing which immunizes ning of something new, not an end of social a child who was lynched on a false crim- police officers from consequences. Time justice. When both Biden and Harris spoke inal accusation in the 1950s. Till’s murder and time again police officers who murder PUNISHMENT? to the Floyd family, Harris thanked the is similar to Floyd’s because they were both Black people do not apologize and this has family for their courage and strength and killed on an accusation. The conviction is become normalized.28 Society has accepted erek Chauvin’s brutal murder of Biden discussed how “[n]othing is gonna a turning point, but one conviction doesn’t that punishment is the highest form of con- George Floyd sparked unprece- make it all better but at least, God, now change the whole system as cops still, “act sequence, not accountability, because of the dented nationwide unrest. Chau- there’s some justice.”25 Ben Crump, the at- with impunity.”26 Despite the verdict and lack of responsibility or apologies made by vin’sD conviction has provided some solace to Floyd’s family and Americans at large. THE DEREK Indeed, the jury’s unanimous decision even sparked some celebration. More broadly, however, neither justice nor accountability has truly been served. The publicly known, appalling, crime that took place on May CHAUVIN TRIAL 25, 2020, was when, in his former role as a police officer, Chauvin knelt on the neck of Floyd, a 46-year-old Black Zahra Motwani man, for 9 minutes and 29 seconds during 10 an arrest over an alleged counterfeit bill. result in up to 25 years, and second degree three charges.19 The jury included 12, seven In his final moments, Floyd pleaded, “I can’t 11 manslaughter can result in up to 10 years. women and five men of all different ages. breathe.” Floyd’s murder marked another Minneapolis guidelines suggest that Chau- Additionally, throughout the trial, there episode in the long history of police brutal- vin should be jailed for approximately 15 were contradicting opinions whether Floyd ity against Black Americans. Throughout years.15 Chauvin will be sentenced in June, died from force, drugs, a lack of oxygen, or the video of Floyd’s murder, Chauvin ap- but he is currently in solitary confinement a pre existing heart condition.20 pears indifferent, expressing no remorse as for his protection. The jury took ten hours to decide the ver- he stole away the life of a fellow American. There were a wide variety of perspectives dict while people anxiously waited around Though the Minneapolis Police Depart- on what the verdict would be, given the his- the country. There was also a crowd of peo- ment had investigated Chauvin for miscon- tory of racial injustice and the lack of con- ple outside the store “Cup Foods,” where duct seventeen times before Floyd’s death, sequences for vicious cops. Cities across the Floyd was killed, which is now known as he was still allowed to wield lethal weapons 21 12 country increased security in the lead-up to George Floyd Square. As the judge an- on May 25th. In stark, chilling contrast, a the verdict, fearing riots and after- nounced the verdict, Chauvin had no single accusation of using a counterfeit $20 ward.16 In Minneapolis, for example, there emotion on his face. Only his eyes rapidly bill led to Floyd’s murder. were barricades on government buildings, wandered around the room. After murder- Chauvin was ultimately convicted for the National Guard was called, and all ing an innocent Black man, Chauvin didn’t second degree unintentional murder, third schools were online during the week that show any external remorse. After Chauvin degree murder, and second degree man- the verdict was released.17 This increased was declared guilty on all three charges, slaughter. These convictions reflected a step protection shows how people were unsure celebration and relief echoed throughout towards justice, providing some hope that, about what the verdict would be, although the nation as the Floyd family was “able to in the future, cops who fail to carry out their it was quite clear that Chauvin was guilty breathe again.”22 oath to protect their communities will be 18 13 seeing the amount of tangible evidence. Activists and prominent individuals held accountable. The trial began on May In the trial, there were many witnesses, from the trial had a variety of perspectives 29, 2020, four days after Floyd’s death, and ranging from teenagers to senior citizens, on the verdict. While most felt a sense of the verdict wasn’t delivered until 11 months experts, medical officials, and people close joy, many acknowledged that there is still after Floyd was killed, following multiple 14 to Floyd who testified. Meanwhile, Chauvin work to be done. After the trial, President court hearings. The penalty for second de- invoked the Fifth Amendment, which the Joe Biden and Vice-President Kamala Har- gree unintentional murder can result in up judge declared was a “personal right,” re- ris spoke to the nation, and later to the to 40 years in jail, third degree murder can fused to testify, and pleaded not guilty to all Floyd family individually. Biden said, “It n. 29

4 The Horace Mann Review | Vol. XXX June 2021 5 Domestic Domestic

police officers. track funding, crimes, and uses of exces- least one verbal warning.”35 Together these The George Floyd Justice in Policing Act sive force. Additionally the act proposes to measures aim to reduce police officers’ un- Each and every person must continue fighting (GFJPA), created by House Democrats in increase the use of body and dash cameras warranted use of deadly force. The act also June 2020, proposes many new reforms for more evidence so the families of vic- states that there will be more subpoenas to injustice everywhere they see it, no matter how that, if enforced properly, could significant- tims can receive the footage. The act will let the US Attorney General investigate de- ly curb .30 The GFJPA mainly also decrease the criminal intent standard partments, stricter rules on sexual abuse by small or how insignificant it might seem. We tackles , data, and police which is when an officer commits an illegal police, and will become ille- violence.31 First, the act aims at decreas- act purposely.33 The act aims to change the gal.36 To incentivize the implementation of need to move further, past punishment, towards ing qualified immunity, which immunizes definition of ‘abuse of power’ from a will- the act, Congress is making federal funding the government and police from lawsuits. ful deprivation of Constitutional rights, to for local and state police departments con- accountability, and ultimately, to dismantle ineq- Ian Millhiser explains qualified immunity a reckless or knowing deprivation -- mak- tingent on conforming to the bill.37 Passing in the status quo: “[If the police officer or ing it easier to prosecute the officer on the act is imperative because it takes steps uitable systems, achieving true justice. government official] does not violate clear- charges of abuse of power.34 Next, the act toward ending police brutality and increas- 38 ly established statutory or constitutional would make chokeholds, carotid holds, and ing accountability. The act has already but that might be difficult because the first been taken alive and unharmed.45 The will- ness through social media and directly to rights of which a reasonable person would no-knock warrants illegal. Additionally, made it past the House twice with a major- two times it was voted on, there were no ingness to shoot first and ask questions lat- friends and family helps others gain new have known,” they are not held responsi- “deadly force” would only be used after ev- ity of Democratic votes, and no Republican Republican votes.39 er is clearly applied unequally across races, understanding and perspective on issues of 32 ble. The act also proposes the ‘National erything else has been tried, such as “dees- votes. To continue, there needs to be 10 Re- Ben Feist, an officer at the ACLU of Min- and until that disparity is remedied, no in- racial injustice and police brutality. Chau- Registry’ which would calation techniques, nonlethal force, and at publican votes to pass the bill in the Senate, nesota, said, “For us, true justice would be dividual verdict will solve the problem. The vin’s trial also demonstrated the power of for George Floyd to be alive today. But if we protests from over the large-scale protests and demonstrations. really want to work on finding justice going summer greatly impacted the Chauvin tri- Without the national awareness raised by forward, we really need to end police tar- al, and without them it is unlikely that the activists and demonstrations, there would geting and violence against communities case would have stayed in the public eye. have been far less momentum to achieve a of color.”40 America cannot bring George The joint-community efforts to bring some sense of justice for George Floyd. George Floyd back to life. But Americans can, and relief to the Floyd family paid off. Achiev- Floyd, his family, and the entire Black com- must, continue working towards justice. ing this goal warrants celebration. Howev- munity deserve more; Floyd’s murder never The verdict was not truly justice, as the sys- er, it is vital to keep fighting injustice for all should have happened. Each and every per- tems that allow police brutality to continue the other victims of police violence — to son must continue fighting injustice every- are still present.41 And although Chauvin honor the memories of those who will nev- where they see it, no matter how small or was given consequences for his actions, he er breathe again, just like George Floyd. how insignificant it might seem. We need did not take personal responsibility, leav- Congress must pass the George Floyd to move further, past punishment, towards ing much to be desired. Chauvin has been Justice in Policing Act, and police depart- accountability, and ultimately, to dismantle punished, that much is true, but until he ments across the U.S. must implement it. In inequitable systems, achieving true justice. accepts and acknowledges his wrongdoing, the meantime, there is much more ground HMR full accountability has not been achieved. work that can be done on a smaller scale. Police officers routinely use more force and On a personal level, spreading aware- violence against Black people, even in rou- tine stops and interactions.42 This is deeply intertwined with implicit bias. In a paper by Jennifer Eberhardt from Stanford Universi- ty, it was shown that white subjects drew a consistent association between Black peo- ple and apes, but not between apes and any other racial group.43 Additionally, when im- plicit bias in police officers was studied, it was found that police officers of all racial backgrounds exhibit implicit bias against Black people. This is the first step, and cer- tainly not the last. Indeed, during Chauvin’s trial, police officers killed 65 Americans, including 16-year-old Ma’Khia Bryant.44 Bryant was actually the one who called the police for help, but when they arrived, they shot her in the chest four times. Although officers routinely state they felt their lives were in danger as justification for using le- thal force against Black people, there have also been countless instances in which white mass shooters who were clearly armed have n. 46

6 The Horace Mann Review | Vol. XXX June 2021 7 n. 47 Domestic Domestic Republicans’ Automatic Assault on Biden’s Gun Safety Agenda

Within 60 days, the Justice Department makers the relevant information required Ariela Shuchman plans to pass a policy that makes it clear to pass effective regulations. when a stabilizing brace effectively turns a Red flag laws are a huge priority for n April 8th, President Biden an- pistol or other hand gun into a short-bar- Biden, who has both included them in his nounced his plan to curb gun reled rifle, under the qualifications of the executive orders and hopes to to expand the violence through a series of ex- National Firearms Act. This policy will pre- policy nationally. Red flag laws allow family ecutiveO actions. Biden promised that gun vent someone from purchasing a pistol (a members and law enforcement to request a control would be a top priority in his ad- weapon with limited regulations) and then court order temporarily banning people in modifying it into a more powerful and ac- crisis or with serious mental health prob- ministration from day one, asserting that 52 56 gun violence in America is both an “epi- curate firearm. lems from accessing firearms. The ban is demic” and an “international embarrass- Third, Biden will focus on community lifted when the judge who issued the tem- ment.” For almost two months after his in- violence interventions. Through proven porary ban rules that the person no longer auguration, it seemed as though gun policy strategies and auxiliary programs, Biden presents a danger to themselves or others. had fallen off of Biden’s radar. However, the hopes to “reduce gun violence in urban Biden urges Congress to pass national red- n. 62 pair of high profile mass shootings in Colo- communities with tools other than incar- flag legislation and the Justice Department rado and Atlanta (that took a total of eigh- ceration.” For example, through the Amer- has published model legislation in hopes ican Jobs Plan, Biden proposes a $5 billion that states will soon follow suit. Flag laws is an infringement.” House Re- party has nominated originalist judges who adopt the originalist mindset and consider teen lives) thrust the issue to the forefront publican Leader Kevin McCarthy declared weaponize this legal doctrine against judi- the political and intellectual atmosphere of of his agenda in April.48 investment over eight years into interven- These five executive actions are a step in tion programs such as mental health care the right direction. But, as Biden himself that “Republicans will strongly oppose and cial activism. Conservatives argue that the the time, it is nearly impossible to justify Biden has announced five initial actions. pursue every option—be it legislative or ju- proper approach to constitutional inter- a constitutional right to semi-automatic First on the list is action on ghost guns. and drug rehabilitation, with an emphasis has admitted, the proposals are not near- on connecting individuals to job training ly enough. On the campaign trail, Biden dicial—to protect the right to keep and bear pretation is to discern what the founders weapons, a gun with a capability of destruc- Within 30 days, the Justice Department will 58 and employment opportunities.53 Five fed- promised much more, including a ban on ar s .” intended when writing the clause. Original tion that the founders never could have issue a “proposed rule” to curb the prolif- The gun control debate has been one intent contrasts with many Democrats’ phi- imagined. An originalist could certainly 49 eral agencies have also pledged to redirect importing assault weapons and a national eration of “ghost guns.” A ghost gun is a of the most contentious issues of the 21st losophy, which is to treat the Constitution present an argument for the right to bear kit that contains all of the materials and in- funds from twenty-six different programs gun buyback program. Biden’s moves have within their agencies into violence inter- underscored his limited power to act alone century.. One’s perspective on the Second as a living document whose principles and a musket, but that is about it; an automatic structions necessary to create a functioning Amendment is now an identity, an irre- writings, when interpreted, must be adapt- weapon and most of the weapons available firearm in under thirty minutes.50 Ghost vention initiatives as quickly as possible to on guns, as the head of the executive branch begin investments as we wait on Congress who is not delegated the task of legislating. movable characteristic dividing the right ed to changing historical and cultural cir- for purchase in 2021 are not covered by guns pose two unique security threats. 59 61 to appropriate additional (and more ade- However, the limitations of executive ac- and left. However, when it comes to the cumstances. supposed “original intent” protections. First, when ghost guns are found at crime 54 optics of gun control, the Democrats have Republicans conveniently ignore the President Biden’s announcement in April scenes, it is almost impossible to trace the quate) funds. tion are not Biden’s biggest barrier; the Re- Biden has also ordered an updated An- publican party is the true obstacle standing the clear upper hand. Unlike economic or flaws in their agenda an originalist inter- has once again revealed the problem Re- weapon back to its source (seller, manufac- tax policy, action on guns (or lack thereof) pretation of the Second Amendment would publicans face in the gun control debate. turer, or purchaser) because of the lack of a nual Report on Firearms Trafficking. In in his way. Unfortunately, Biden and gun 2000, the Bureau of Alcohol, Tobacco, and control advocates behind him are in a dif- will have a direct, visible, and virtually un- expose. Republicans claim that any and all Right now, the GOP priorities are skewed, serial number–– remember, these guns are deniable impact on human life. Opposing gun laws are of “constitutional overreach,” attempting to make voting harder while simply a combination of randomly gath- Firearms (ATF) issued a report summa- ficult situation because the most ambitious rizing its findings and investigations into components of Biden’s plan will need to be policies that save American lives can hurt because of the alleged scope and protection fighting to make buying a gun easier. Re- ered parts that together form the weapon. Republicans politically. And the GOP’s case of the Second Amendment.60 However, the publicans must provide alternative policies Second, it is challenging to regulate a ghost firearms trafficking. Firearms trafficking passed by the legislative branch, where it is describes the process in which weapons are almost a guarantee that Republicans will against such policies isn’t a great one. Second Amendment was written in 1791, a to mitigate gun violence, or their empty gun because a majority of gun control pol- For starters, a favorite Republican trope time when the most powerful weapon was “thoughts and prayers” will continue to icies place restrictions on specific classifi- diverted to the illegal market to be easily vote no on any gun law, ambitious or not. purchased by flagged or dangerous individ- Since Biden’s announcement, countless is the deployment of “original intent” phi- a musket that could shoot one round per drive the mass exodus of American youth cations of weapons; things get complicated losophy. For the past several decades, the minute with little aim or accuracy. If we from the party’s arms. HMR and loopholes are created when the kit is uals, while maintaining anonymity of the Republicans have taken to to ex- for sale, not the assembled gun, because the purchaser. Local, state, and federal policy press their outrage. Texas Governor Greg law technically only applies to a put togeth- makers rely on the ATF’s 2000 report to tar- Abbott described Biden’s actions as a “lib- get the specific areas of trafficking that are eral power grab” that “we will NOT allow in er version of the weapon. 57 Next, Biden hopes to address the “Sta- most prevalent and dangerous. However, T X .” He also expressed his plans to enact Republicans must provide alternative policies to mitigate gun vio- bilizing Brace” Loophole. Ahmad Al Ali- with the growth of the internet, dark web, legislation that would prevent Texas from wi Al-Issa, the perpetrator of the Boulder, and innovative weaponry loopholes such enforcing any gun measures implemented as ghost guns, trafficking has changed and by the federal government. Governor Kristi lence, or their empty “thoughts and prayers” will continue to drive CO shooting (ten deaths) on March 22nd, 55 2021, attached an arm brace to the pistol adapted significantly since 2000. The Jus- Noem of South Dakota echoed Abbott by the mass exodus of American youth from the party’s arms. used, making his weapon more stable and tice Department will issue a new report this tweeting that “taking away guns with Red accurate when firing, yet still concealable.51 year to be updated annually, giving policy

8 The Horace Mann Review | Vol. XXX June 2021 9 Domestic Domestic goes, these students would be better served price of a service (here, specifically, athletic to circumvent the Sherman Act. Pursuant by placing them in specialized classes and scholarships) by means of sellers conspir- to Congress’ constitutional power “[t]o reg- The NCAA’s sometimes even specialized majors, so they ing to form a cartel and raising the price. ulate commerce with foreign nations, and can learn at their own pace in an environ- The same year Alston filed his suit, -an among the several States, and with the In- Day in Court : ment tailor-made for like-minded people. other college athlete, former UCLA basket- dian tribes,” the Sherman Act only regulates This approach, however, has many flaws. ball player Ed O’Bannon, filed a similar suit activities in or affecting interstate or foreign First, it represents a moral failure, on the in the same court. O’Bannon’s suit, instead commerce, or in the District of Columbia. How it Went, part of the university, to guarantee all its of scholarships, focused on the value of NIL The NCAA argued that their activities are students an educational experience that rights, and was on behalf of “all others sim- actually not in or affecting interstate or for- and What Will leaves them not just more intelligent, but ilarly situated” as opposed to merely in his eign commerce, pointing to the historical also with a broader view of the world, than own name, but also based its arguments in exemption from antitrust laws afforded to Likely Happen they were going in. Second, it enables the the Sherman Act. The district court found professional baseball teams. But the NCAA NCAA to devote as much of these students’ in favor of both plaintiffs,71 and an appellate went further, arguing that as its student-ath- time as possible to developing their athlet- court affirmed.72 The Supreme Court de- letes are prohibited by NCAA rules from re- Next ic capabilities, to the benefit of the NCAA clined to hear the NCAA’s appeal of O’Ban- ceiving most forms of compensation, their and of the university and at the expense of non’s suit in 2016, but took up the NCAA’s activities are not commercial in nature, and the students’ right to learn and grow. And appeal of Alston’s suit in December 2020. so the Sherman Act does not bind them. third, it leaves such students woefully un- Why the difference in the treatment of Of course, the NCAA’s games are com- Leo Giorgini n. 74 prepared for life after college, especially the two cases? There are several possibil- mercial in nature, as it is a highly profit- those who do not go professional and who, ities. The most likely, according to your able industry which, as mentioned above, t is an oft-repeated story that the Su- which option seems the most lucrative of the NCAA presented their preliminary consequently, have far fewer skills and author, is that NIL rights were seen by the nets profits in the billions. Furthermore, preme Court building in Washington, at the time, to the detriment of the team copies of NIL reforms, which were final- qualifications than a person of a compara- high court as an issue not requiring further the games are broadcast throughout the D. C., is home to a basketball court di- and of the game. But this rule has clear ized in December and approved on Janu- ble age who had been accepted as an aca- clarification, while price-fixing is an issue United States, and bring in viewers and Irectly above the argument room, making downsides for the student-athletes, not ary 31, 2021. Under the new rules, which demic, rather than athletic, talent. The low which is frequently reexamined, requiring tickets from every State and territory. Even it the “highest court of the land.” In fact, least of which is the fact that, upon grad- become effective, absent further revision, odds of making it as a professional athlete new rulings to illustrate the reach of the if the student-athletes themselves do not the basketball court has a sign reading uation, many of them will be competing in August 2021, student-athletes will be do not outweigh the serious disadvantages statute for each different case. In any case, get paid, and are forbidden from hold- “PLAYING BASKETBALL AND WEIGHT for limited slots on professional teams allowed to make limited amounts of mon- this arrangement poses for student-athletes. the consolidated cases were argued March ing their own NIL rights, their activities LIFTING ARE PROHIBITED WHILE against athletes who have been represent- ey through licencing and promoting their Lastly, in order to understand the condi- 31, 2021, and the transcript of the argu- clearly constitute a part of interstate and THE COURT IS IN SESSION,” alerting ed by agents for several years and who NIL through other means, including social 66 tions for the suit now before the Supreme ment provides some insight as to how the foreign commerce. As such, the justices players, to use a legal term, to cease and are better suited to help their clients. An media and commercials. Nevertheless, the Court, it is necessary to look at the finan- justices view the NCAA’s practices in ques- appear convinced that the Sherman Act desist when oral arguments are being held agent can be a young athlete’s best bet change in rules does not apply retroactive- 63 cial world of college athletics. Given the tion, and how they may ultimately rule. does apply to the NCAA. All this points or when the justices are in conference. against underpayment and obscurity. ly, meaning all student-athletes who have high emphasis placed on the “amateur” na- Generally, the justices appeared skeptical to a likely affirmation by the Ninth Cir- The Supreme Court has once again con- Another controversial NCAA rule in- already completed their careers with the ture of college athletics, one might expect of the NCAA’s justification for their pol- cuit’s ruling, and a nationwide prohibition fronted athletics head on, but this case, in- volves the name, image, and likeness (NIL) NCAA will see no benefit whatsoever, and it not to entail more than a small amount icies, with two, Justices and of the NCAA’s challenged practices. HMR stead of an after-hours game between the rights of student-athletes. Under present those who are already years into college will of money. Instead, in any given year, from , insinuating the policies justices and their clerks, comes in the form guidelines, student-athletes may not re- see far less than they would have had the the “March Madness” tournament alone, in question constitute exploitation of stu- of a legal dispute. More specifically, it entails ceive compensation for their NIL during rule been in place when they first joined. the NCAA generally nets around $1 billion, dent-athletes.73 It did not help that one of a challenge to the structure and business their relationship with the NCAA. Once Finally, the NCAA has one last contro- with a further $8.5 billion wagered by pro- the NCAA’s legal justifications was an effort model of the National Collegiate Athletic again, this rule serves a logical purpose, versial practice. In order to attract talented fessional and individual gamblers alike.67 Association (NCAA), the organization re- that is, to delineate the boundary between athletes, they assist colleges in recruiting In 2019, the net profit was $1.05 billion; in sponsible for managing and regulating var- a professional athlete and a full-time stu- high-school students to find candidates for 2020, even with the tournament cancelled sity college sports throughout the United dent as well as to protect amateur athletes athletic scholarships. A student who re- due to the then-emerging COVID-19 pan- States and Canada. The NCAA maintains against professional competition. Never- ceives such a scholarship is able to attend demic, the NCAA gained $520 million.68 strict rules, at issue in the consolidated cases theless, the policy is lopsided in its terms, the college for a fraction of the normal tu- In March 2014, Shawne Alston, a former National Collegiate Athletic Association v. allowing the NCAA to profit off of the suc- ition, and in some cases, may not have to running back for the University of West Alston and American Athletic Conference cess and brand of their athletes, in ways pay any tuition at all. However, this sta- Virginia varsity football team, filed suit v. Alston, concerning the treatment and as varied as autographs, trading cards, tus is tied to their athletic performance: if in federal court alleging that the NCAA’s compensation of its athletes, who are full- and advertising contracts, while prevent- they stop playing the sport for which they method of determining the value of ath- time college students who also play sports. ing the student-athletes, who actually do were recruited, they lose their scholarship. letic scholarships violated the Sherman One rule forbids student-athletes to the work of playing the sports, from do- During their time at college, they wind up Antitrust Act of 1890.69 More specifically, contract with or make arrangements with ing the same.65 There is also the argument being treated more as a full-time athlete 64 according to Alston in his complaint, the agents until they graduate from college. that a person’s NIL rights are intimately than as a student who is also active in sports. NCAA colluded with member universities This rule no doubt serves genuine and connected with that person and should The reasoning behind that, of course, is to award athletic scholarships which were practical purposes. For one, it ensures that belong to no one but that person. To the that the student in question was recruited less valuable than the cost of the universi- student-athletes do not neglect their stud- people holding that belief, there is no right for their athletic talents, rather than aca- ties. The Sherman Act, as amended, pro- ies by focusing exclusively on a guaranteed to profit from another person’s identity. demic qualifications, and would therefore hibits any “contract, combination in the post-graduation career. It also preserves Beginning in 2019, the NCAA has en- not be expected to do as well in a class form of trust or otherwise, or conspiracy, the amateur nature of the sport by pre- gaged in efforts to reform its NIL policy. designed for students who intend to focus in restraint of trade or commerce.”70 The venting student-athletes and their coaches In September 2020, in response to lawsuits their college years on developing their in- NCAA’s practice, Alston claims, has the from making tactical decisions based on from student-athletes, the three divisions tellectual spheres. As such, this reasoning purpose and effect of manipulating the n. 75

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the global recession, which has made the tal pollutants worldwide.82 for it to be decomposed in separate parts, ordinary customer more price-conscious. The coronavirus had drastically affect- making it more convenient and more rap- Plastic-wrapped food products are the go- ed global warming. At the onset of the id. It would also cause less harm to ocean to for shoppers since they are universally pandemic, it seemed that the coronavirus life; animals see the masks as food. This less costly. During the pandemic, ordering was having a positive effect on the envi- “food” gets stuck in their system, which take-out was common amongst families ronment, but it quickly became clear that slowly begins the process of extinction for across the United States, and the plastics it was having a negative impact. Though this species. used were once again non-recyclable. Due communities weren’t aware that the pan- Even though the pandemic has caused to lockdown, there was a demand for on- demic was going to occur nor how long it environmental issues, negatively affect- line shopping, and the package material would last, there could have been measures ing global warming, it is never too late increased waste. This increase in online taken to prevent this current situation. to begin the process of recovering from shopping forced the progression in the use For instance, instead of not sorting waste, it. Sustainability takes a large part in this of plastics, which were often used to wrap while carrying the virus, one could have issue. Therefore, there needs to be actions items. This over time increases to a fright- waited to test negative to do so rather than taken towards promoting sustainable ening amount, since the whole world was not doing so at all. There were other op- products to consumers. Make prices more purchasing items, mainly unsustainable tions available in order to not pollute, such reasonable; for the majority of sustain- brands. as, not ordering from unsustainable loca- able products the prices are increasingly Recycling is beneficial to the earth, by tions, including Amazon, online clothing higher than non-sustainable ones, turning preventing pollution, preserving minerals stores, restaurants, etc. This would have the consumers away from purchasing the and water, saving energy, etc. In hopes to been beneficial as there would have been item. Another way to appeal to the buyer reduce the spread of the virus, countries significantly less plastics used. would be by displaying what not buying had postponed recycling activities. For Plastic pollution has always been an from sustainable locations does to our example, the United States limited near- issue but peaked during the pandem- environment; the majority doesn’t fully ly 46% of recycling programs, as the pan- ic, specifically because of the increase in comprehend the extent of global warm- demic worsened, in worries of transmitting protective gear and packaging. In order ing. This makes it difficult for some to care COVID-19.80 Other countries went a step to change this, treat single-use protec- since they aren’t directly affected by it, but further and prohibited residents who car- tive gear differently. For instance, instead will soon be facing the consequences if not 81 HMR n. 83 ried the virus from sorting their waste. In of putting our disposable masks into the dealt with sooner. general, the lack of recycling management trash, recycle them properly. To do so, the increased the landfilling and environmen- straps should be cut off, this would allow COVID-19’S IMPACT n. 84 ON GLOBAL WARMING

Rachel Baez

he coronavirus has affected all of gloves, face shields, and other tools were increase by 30%.77 our lives in one way or another. used by healthcare workers as well as many Though the use of personal protection At the start of the pandemic, it other citizens. Since we as a society had lit- equipment has increased the use of plas- seemedT as if the coronavirus had positive tle knowledge of the coronavirus, the pro- tics, the coronavirus has created a domino impacts on the climate. Transportation use tective equipment was discarded frequently effect. With the oil market crashing, plas- declined sharply, as did manufacturing, because the majority of the masks were sin- tics became cheaper than ever.78 Oil and lowering the amount of CO2 emitted into gle-use. It is estimated that there have been natural gases are essential in manufactur- the air.76 It became apparent that humans’ 129 billion face masks and 65 billion gloves ing plastic.79 These low prices discourage everyday life had been creating pollution, used across the globe since the beginning of buyers from using sustainable packaging, but as air pollution decreased, other pollut- the pandemic. These protection gears were since they are significantly more expensive. ants began to slowly destroy the environ- often made of synthetic polymers, which If buyers were to buy the more expensive, ment. contain plastic. Because these plastics can sustainable packaging, then they would As months went by during the pandemic, take years to decompose, this becomes a have to raise their prices, making them less it became clear that one of the largest pol- never ending cycle of pollution. The plas- competitive. lutants was from the increase in the usage tics unfortunately found their way to the Affordable products have taken priority of personal protective equipment. Masks, ocean, which caused the ocean pollution to over more sustainable goods as a result of

12 The Horace Mann Review | XXX June 2021 13 Domestic Domestic sentations of their office, and their replies as user who has blocked them. Effectively, the tional? While the First Amendment doesn’t a public forum. Politicians all over America blocked account is totally excluded from apply to Twitter, it’s the Knight Institute’s are becoming increasingly engaged with public discourse taking place on Trump’s view that it does apply to public officials’ ac- their constituents on social media, so dig- account. Even worse, Trump’s history of counts.98 A public official’s account is such a ital free speech will undoubtedly become blocking critics might discourage some distinct place for exchanging ideas that the one of the most important issues for both users from voicing their criticisms.96 Block- Constitution should apply to the account the courts and for us. In order to protect ing those critics thus undermined the First itself but not the platform that the account free speech rights and advance them into Amendment’s protection of free speech, the exists on. But if a public official were to the digital age, it’s critical that the Knight most critical feature of which is maintain- create a personal account (one that posted Institute’s view become standard. ing uninhibited and robust debate. information unrelated to their office), they To understand the Knight Institute’s ar- would be free to block any users from ac- gument, we have to first establish some cessing that account. definitions. First, “public forum” has to be Thus summarizes the Knight Institute’s defined. The Supreme Court has tradition- “Politicians all argument. In April 2021, the Supreme ally recognized restrictions on government Court vacated the judgement (declared power to control speech in certain fora.91 the previous Second Circuit ruling as no Among these are government-designated over America longer legally binding).99 Associate Justice public fora—places, physical or otherwise, published a concurrence designated for use by the public for speech are becoming with that ruling—when dismissing a case as and assembly.92 Designated public fora are moot, a concurrence effectively functions created when the government intentionally as a sort of op-ed from the judiciary, with opens a nontraditional forum (for example, increasingly en- no legal standing.100 Thomas’ concurrence an event held at a hotel, which is a place points out that Twitter’s power to block all n. 102 not ordinarily functioning as a forum) for gaged with their users’ speech is far greater, and therefore public discourse.93 But can a digital space more important, than the issue addressed qualify as a designated public forum? The in Knight.101 He seems to be correct about answer is, without a doubt, yes. Digital ex- constituents on that, but at this point it’s impossible to tell changes on social media have long replaced how the Supreme Court will go about bal- the physical interactions that once char- social media, ancing the rights of social media companies acterized most public discourse. A large with the reality of our reliance on social Knight v. Trump and number of people also engage with their media for public discourse. public officials (or even directly petition so digital free In any case, the Knight Institute’s ideas them) and other citizens on social media. will be invaluable for thinking about free Even the Supreme Court has called social speech will un- speech in the age of social media. Concep- media “the most important place [...]for the tualizing official accounts on all platforms exchange of views,” a sort of modern pub- as public fora allows us to ensure that the Digital Free Speech lic square—but far more democratic due doubtedly be- balance of power between citizen and state to the incredible ease of access.94 So, did guaranteed by the First Amendment re- Trump’s Twitter account count as a public come one of the mains relatively constant. And not only forum? The answer is also yes. Twitter’s re- does this understanding of such accounts ply feature allows any user’s account (pro- protect individual users from free speech Gavin Song vided that it’s public) to act as an interactive most important violations, but it also protects the general platform for digital discourse. In particular, public from distorted political discussion. ocial media’s influence on politics to the First Amendment, and from which the same reason.88 Following the Executive Trump’s Twitter account is accessible to the issues for both And as new digital technologies arise, we and public discourse is undeniably the government could not restrict speech Office’s petition, the Supreme Court grant- entire public, so its replies constitute public have to be cautious about how they might both unprecedented and ever-grow- on the basis of viewpoint.86 That’s not to say ed certiorari (i.e., agreed to hear the case), political discourse, and the account consti- influence our First Amendment rights. Af- ing.S That fact raises a major question about that all of Twitter constitutes a public forum but didn’t release a decision until after Pres- tutes a designated public forum.95 the courts and ter all, the Constitution’s guaranteed rights regulating and protecting twenty-first-cen- and therefore Twitter itself should be an- ident Biden’s inauguration, thus making the Since his account functions as a public were written to endure.HMR tury discourse: what role should social me- swerable to the First Amendment, but that case moot (the case name became Biden v. forum, did Trump’s blocking of dissenters for us.” dia companies and their platforms play in public accounts (accounts providing offi- Knight Institute after Biden took office).89 constitute a First Amendment violation? that effort? cial information) of public officials do and Stare decisis, the principle of following ju- A fundamental and familiar principle of In 2017, the Knight First Amendment should be.87 Under this view, Trump, or any dicial precedent, would compel only courts American democracy is that the govern- Here, an important distinction has to be Institute at Columbia University tried to other public official, is a state actor—even in New York, Connecticut, and New Hamp- ment cannot deny the use of a public forum made between the government and Twitter. answer that question by filing a lawsuit on Twitter—and his blocking of Twitter us- shire to follow the ruling. But not only that, to those whose views it finds objectionable. The First Amendment, and the Constitu- against then-President of the United States ers on the basis of viewpoint is equivalent the Supreme Court vacated the Second Cir- Trump’s (or his aides’) blocking of critics ab- tion as a whole, applies only to the gov- Donald Trump and his aides, who had to prohibiting speech in non-digital public cuit’s judgement, making it no longer legal- solutely met the criteria for denying speech ernment: “Congress shall make no law [...] blocked seven people from the @realDon- fora. The case reached the Court of Appeals ly binding.90 Essentially, the victory won in to those whose views he did not agree with. abridging the freedom of speech.”97 Twitter, aldTrump Twitter account.85 The lawsuit for the Second Circuit in 2019, where the the Second Circuit no longer has any legal On Twitter specifically, a blocked user can- a private company, isn’t legally obligated to alleged that Trump’s Twitter account con- Knight Institute prevailed. In 2020, the standing. Even so, it was critical in concep- not view tweets from the blocked account, follow the First Amendment. Then how can stituted a “public forum,” which was subject Knight Institute filed a second lawsuit for tualizing public officials’ accounts as repre- nor can they reply to any tweet from the it be that Trump’s blocking was unconstitu-

14 The Horace Mann Review | Vol. XXX June 2021 15 Domestic Domestic

mitment to America’s international obli- that the Biden administration was “start- gations which represents a reversal of the ing from scratch” regarding the pandemic prior administration’s stances. He has made is not entirely true. Much of the vaccina- wearing masks in federal buildings manda- tion process is state controlled, meaning HOW IS tory, a sign of his commitment to fighting that the Trump administration was never COVID-19. Prior to the election, Biden vital to the vaccination effort. However, said he would appoint a cabinet that, in many states have complained that the lack terms of diversity, represents our country, of communication with the Federal Gov- BIDEN and proceeded to do so.104 Many of his other ernment under the Trump administration executive actions, which include reversing hurt their effort to innoculate their citizens. travel bans and making the Federal Gov- In terms of his promise of 100 million vac- ernment recognize violations of LGBTQ cines in 100 days, it seems that Biden has rights abroad, display a commitment to done a great job in fulfilling his promise. DOING fighting racial discrimination, homopho- His positive attitude towards vaccinations, bia, and xenophobia.105 These actions taken while hard to measure out its effects, has by the president show that he does, at least likely had a positive effect on the vaccina- on the surface, care about anti-discrimina- tion effort as well. Still, it remains unclear SO FAR? tory policy, something which he consistent- whether an efficient vaccination effort was ly emphasized during his campaign. How- Biden’s promise to make. ever, executive actions do not mean much Biden mentioned on the campaign trail in terms of creating change for the average some large promises regarding undocu- American citizen. mented immigrants and immigration into One of the Biden administration’s most this country. Biden said on the campaign Simon Schackner significant initiatives is the development trail that he would attempt to find a path to and expansion of vaccine eligibility. During citizenship for what he approximated to be a news conference on December 8, 2020, as the 11 million undocumented immigrants hen former Vice President Joe President-elect, he promised that the nation in the US. This promise, while important, Biden was finally acknowl- would get at least 100 million Covid vaccine has actually been made by all four presi- edged as the President-elect shots in the arms of US citizens within the dents before Biden.110 Although Biden has of Wthe United States on November 7, 2020, first 100 days of his presidency.106 The goal, proposed legislation for this issue, he has four days after the official election night, which initially seemed like a bold promise found little success in cooperating with the many people from the US and around the by the president, was shattered. The US ad- GOP, which has become increasingly hos- world were hopeful. The former Vice Pres- ministered 200 million vaccines within the tile towards undocumented immigrants in n. 118 ident, before taking office, seemed to have first 92 days of Biden’s presidency.107 It is recent years. The far more pressing prob- serious plans for the country. Many of these unclear, however, that this success is entire- lem for the Biden administration has been gee cap, which stayed at an incredibly low that he would be an across-the-aisle cen- The idea that Biden would bring back promised to strongly contest the visions of ly due to the Biden administration. Under holding the promise of raising the refu- number of 15,000 per fiscal year under the trist and that he would restore sanity to sanity to the White House is difficult to 114 former President Trump and the Republi- President Trump, the Federal Government Trump administration. Biden pledged to the White House. The American Rescue test, but it seems as if the president has held can-controlled Senate. At little more than pledged 18 billion dollars to support the eventually increase that number to 125,000 Plan, which was a huge, $1.9 trillion eco- on to this promise, at least in comparison 100 days in office, it is clear that Biden has creation of vaccines intended for the US cit- per fiscal year, with 62,500 this fiscal year. nomic stimulus bill passed by the govern- to Trump. reported taken a different path than his predecessor. izenry.108 Additionally, the administration The administration has failed to accom- ment in March, received zero support from that in the first 100 days of the presidency, 115 He has attempted to take action against a of vaccines has largely been controlled by plish this and is now announcing that they the GOP. In an increasingly partisan Trump made 99 false or misleading claims variety of issues that have been polarizing individual states, with not much significant will aim for a little over the 15,000 set pre- Congress, it is likely that Biden had no op- on Twitter. Biden made only one. Biden has Biden has called 111 our country, from COVID-19 to immigra- support from the Federal Government. It viously by the end of the fiscal year. Fur- portunity to negotiate with Republicans in also made 36 fewer speeches than Trump tion.103 As his presidency progresses, it will would still be unfair to say that Biden has thermore, because of Biden’s promises to what many felt was a much needed stimu- in his first 100 days, showing how the cur- be important to think about how Biden is not helped out, considering that Biden has on the US mili- increase immigration and the loss of Cen- lus. Still, the large amount of federally dis- rent president does not feel the need to living up to what he promised on the cam- called on the US military, a federally cen- tral American homes due to hurricanes, the tributed money guaranteed from this plan weigh in on situations that the President 116 paign trail and following being elected. Like tralized system, to help out with adminis- tary, a federally country has seen a huge uptick in the num- is quite a liberal concept and abandoned of the US need not talk about. While many presidents in their initial days in of- tering vaccines. Biden has deployed over ber of people seeking refuge at the border. much of the centrism that might have been running for President, Biden promised fice, he has found some success in living up 10,000 active duty service members to aid The number of those crossing the border expected from Biden. He is currently at- that he would not make “cancel culture” a centralized sys- 112 to the standards he created for himself but the effort.109 illegally has allegedly increased as well. tempting to seek bipartisan support for his topic of the campaign. He has more or less nevertheless struggles to realize all of his vi- The idea of using the military, like Op- The attempt to increase refugee numbers is proposed Infrastructure Plan, suggesting held this promise, having declined to com- sions for the nation. eration Warp Speed, was born under the tem, to help out a work in progress, and lack of willingness that perhaps the stimulus bill was an out- ment on the culture wars that have recently 117 In terms of executive actions and oth- Trump Presidency, making it unclear how from the Trump administration to transfer lier situation that Biden felt was necessary plagued this country. The president looks er choices made by the president himself, much of the credit Biden deserves here. with administer- information to the Biden administration is to get done as fast as possible. Biden has ig- to be committed to not stirring up trouble Biden has remained committed to a vari- Still, the rate of vaccinations, which never seemingly a large part of the problem here. nored left-wing Democrats who say that he and taking a side on the little arguments. 113 ety of promises that he made before tak- eclipsed over one million per day under the ing vaccines. Nevertheless, Biden has not delivered on should try and pass an Infrastructure Bill One might disagree with his policies, but ing office. He rejoined the Paris Climate Trump administration, has nearly tripled this promise. right away, showing that despite his liber- it would be hard to prove that Biden has Accord, which shows a commitment to under Biden. Nevertheless, the allegation Perhaps the most widespread and the al Rescue Plan, he still plans to commit to been more outspoken and polarizing than fighting climate change as well as a com- made by Vice President most unclear claims of the president were centrism. Trump.HMR

16 The Horace Mann Review | Vol. XXX June 2021 17 Domestic Domestic is broken. It is out of balance, and it needs tional amendment. Article 3 section 1 of the tempted to add more justices to the court to to be fixed,” stated the Democratic sena- Constitution states that “the Judges, both of help in passing his New Deal legislation.128 tor from Massachusetts, Ed Markey.122 He the supreme and inferior Courts, shall hold But, this time the Democrats have reason to continued,“too many Americans have lost their Offices during good Behaviour.” This want to take action. Republicans stalled the Should We Pack the Supreme Court? faith in the court as a neutral arbiter.” While means that they serve for their entire life- Garland nomination, effectively creating a Democrats questioned the court’s legitima- times, and to change this rule, we would Supreme Court with eight justices. If they cy, Republicans attacked Democrats for have to change the Constitution. Amend- are going to intentionally stall nominations scrutinizing the legitimacy of the judicial ing the Constitution is not easy. It would re- in order to put their own choice for justices Allison Markman branch. Mitch McConnell, Senate Minority quire a supermajority (two-thirds vote) in on the courts interrupting democracy to Leader, stated that Democrats were “threat- both houses of Congress, and then would promote an agenda, there is no reason why have to be ratified by three-fourths of state the Democrats cannot do the same. It is legislatures. However, in the Constitution, completely constitutional, and throughout it states nowhere a specific number of jus- history the number has changed to as low tices that must be on the court. Therefore, as six. the easiest path to creating more balance on Many Americans, myself included, are “The current the court would be through increasing the concerned about the precedent it sets, but number of judges. the current Supreme Court is not repre- Supreme Court While the U.S. Constitution states that sentative of the beliefs of the people, and Supreme Court justices and other feder- the most efficient way to change that is to is not repre- al judges “shall hold their offices during alter the number of judges. The court has good behavior,” many believe that Congress gone from an institution that is supposed should pass legislation limiting the number to interpret the Constitution, to a partisan sentative of the of years a justice can serve.127 Some crit- political institution. Change must be made, ics and scholars have proposed a 15 or 18 as they have the power to hear legal chal- beliefs of the year term. Implementing these limitations lenges to Biden’s agenda, and are a crucial would require a constitutional amendment branch of government. Packing the court people.” which would need approval by a two-thirds is not about adding more liberal judges to of the House and Senate, and three-quar- the court, rather it is necessary to undo the ters of the states. This explains why Dem- previous actions by Senate Republicans and ocrats are creating the bill which requires the Trump administration, in order to cre- only a simple majority of both chambers, ate balance from the unfair addition of two rather than the push for a constitutional conserative judges HMR ening judicial independence from the steps amendment. of the court.” Other statements made over In 1937, Franklin Delano Roosevelt at- social media, such as Senator ’s tweet, claimed that the Democrats actions would “destroy the court.”123 Republicans aren’t the only ones disagreeing with the Bill. The Democrat Speaker of the House, Nancy Pelosi, said that she had no inten- tions of bringing the bill to the floor. She supports the more moderate approach that n. 129 Biden proposed of a commission to study the possible expansion of the Supreme he Judiciary Act of 2021, which ly fast rate. Barrett’s nomination was made court, the bill could be setting a dangerous Court, though she has stated that expand- would raise the number of Supreme just over a month after the death of Ruth precedent for politicians to continue add- ing the Court is not completely out of the Court seats from 9 to 13, was cre- Bader Ginsburg; there were a mere 35 days ing more justices each time they are discon- question.124 Similarly, Senate Judiciary Tated by Democrats to combat the current between Barrett’s nomination and the 2020 tent with the balance of the judicial branch. Chairman Dick Durbin would also like to 6-3 Republican majority on the Supreme US Presidential Election.120 This marks the The court should be apolitical, and adding wait for the findings of the report before Court. The bill’s authors argue that with the shortest period of time in history between a justices to it corrupts this founding princi- taking action.125 current ideological balance on the Supreme justice’s nomination to the Supreme Court ple. However, in the course of U.S. history, President Joe Biden recently signed an Court, it is difficult for them to progress on and an election. Progressive groups are also Congress has changed the number of jus- executive order to study reforming the critical issues such as civil rights.119 Fur- upset about Donald Trump’s appointment tices seven times. The last time this was court. Among his inquiries is the question ther, Democrats want to ensure that some of Brett Kavanaugh, following the retire- done was directly after the Civil War.121 of the size of the court, and whether or not of President Joe Biden’s legislation has a ment of Anthony Kennedy, as well as Mitch Many Democrats believe that the Su- a justice should have the seat for their entire chance in the high court. Many Democrats McConnell’s blocking of ’s preme Court has become a partisan and lifetime. Though opposing the new bill, he disagreed with the way in which the Sen- nominee to the Supreme Court, Merrick political institution, rather than an impar- supports the committee to investigate pos- ate Republicans went about the Supreme Garland, for nearly a year. tial branch of government that stands for sible solutions.126 Implementing term limits Court nomination of , Though the bill is a direct response to integrity and equity. “We are here today to the position would require a constitu- as it was rushed through at an abnormal- prior changes to the composition of the because the United States Supreme Court n. 130

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resulted in support for statehood as well. entirely federal district because it’s meant The bill, H.R. 51, is now pending Senate ap- to be completely neutral and separate from proval. It requires the approval of at least 60 the state voting process. In the past, this The citizens senators, which is far less likely to happen idea may have been acceptable, but as the than the House vote’s success. H.R. 51 pro- population of people in D.C. grows, more of Washington poses shrinking the neutralized federal dis- and more people are demanding their voic- WHY WASHINGTON D.C. NEEDS trict into a two-square-mile enclave which es be heard. Hence, shrinking the federal D.C. deserve the would contain the most important build- neutral radius could solve both of these ings, such as the White House and the Cap- problems while maintaining the capital de- right to have itol. This area would be deemed the Nation- sign our constitution outlines. an equal say in TO BECOME A STATE al Capital Service Area.143 The Washington The Community of Washington D.C. de- D.C. for statehood website notes that “the serves equal representation and vocal rights the legislative constitution sets only a maximum size, ‘not in our government. However, the constant exceeding ten miles square,’” for the coun- debates and disagreements over the topic proceedings of try’s federal district.144 This new plan would make D.C. statehood a very unlikely reality. the country, and give citizens their full rights and voices HMR Samantha Strasser while also following constitutional law. The remaining land would become its own their requests state, which at the moment residents want are completely ashington D.C., our nation’s Aid, Relief, and Economic Security Act the radical leftist agenda,” to essentially in- to name the Douglass Commonwealth capital with over 712,000 resi- (CARES) provides at least 755 million dol- filtrate the government and reshape Amer- 145 138 (D.C.) after Frederick Douglass. reasonable and dents, has been vying for state- lars in emergency funds to the least popu- ica. This argument has become popular This part of the bill goes against another Whood for years. Though its people bear the lous states in the country, such as Wyoming among many, but other representatives popular counterargument, that D.C. is an achievable. same responsibilities of citizenship as any and Vermont. However, D.C. was denied have retaliated. For example, Representa- other state, their lack of representation in access to these funds even though it has a tive Gerald E. Connolly (D-VA) explained Congress limits their voices. The metropol- larger population.134 This is explicit proof that “how somebody votes cannot be a test itan federal district is famous for its federal of the federal government prioritizing res- of whether they have the right to vote in neutrality––but residents are beginning to idents of other states above D.C. residents democracy.”139 This one point sums up the stir over their lack of spokesmanship, tak- simply because they are barred state mem- entire argument for D.C. statehood. If one ing to the streets to speak out in . bership into the Union. bears all the responsibilities of a state, it The citizens of Washington D.C. deserve One of the major reasons Congressional deserves access to all the privileges of any the right to have an equal say in the legis- Republicans are so vehemently against the other state––irrespective of its political lative proceedings of the country, and their statehood of D.C. is because they believe agenda. requests are completely reasonable and the Democrats want this “deep-blue city” Interestingly, part of Washington D.C. achievable. to become a state only to add one Demo- did cede back to Virginia through the Alex- First of all, Washington D.C. not only crat vote to the House and two Democrat andria Retrocession Bill of 1846.140 Hence, pays more federal taxes than 22 states but votes to the Senate. However, as Mayor Mu- the other potential counterargument is that also pays more per capita to the federal riel Bowser (D-DC), made clear, the issue remaining Washington D.C. could sim- government than any other state.131 A pop- of statehood is most importantly centered ply become part of Maryland. All of D.C.’s ular slogan among supporters for statehood around “securing complete voting rights in land was originally ceded from Maryland hearkens back to the American Revolution: a plurality-Black area.”135 D.C. is known as and Virginia, so a retrocession does seem “Taxation without representation,” which a historically Black city. Today Black peo- probable for some as it has happened be- citizens have taken to using as bumper ple make up the lion’s share of their pop- fore; however, this doesn’t work for multi- stickers or signs.132 D.C. currently elects a ulation, at about 47%.136 Admitting D.C. ple reasons.141 Maryland’s citizens and its non-voting delegate to the House of Repre- to the union as a state would significantly legislature have by no means consented or sentatives. They are able to draft legislation amplify Black voices in congressional issues expressed any positivity towards this idea. but have no voting opportunities. Eleanor and raise their voting power from, “75 per- Additionally, though the growth in popula- Holmes Norton (D-DC), a key advocate for cent as much representation as the average tion would give D.C. representation in the Washington D.C. statehood, holds the cur- white American in the Senate,” something House, it wouldn’t earn any new presence rent delegate seat.133 However, in the Sen- that opponents of statehood are afraid of.137 in the Senate. In more current times this ate, D.C. has zero representation. So, if it is Black votes have historically been sup- option seems less accessible, and D.C. res- paying greater taxes than other states and pressed and the accurate representation of idents are more in favor of their own state- already has a representative in the House, these voices is crucial to true democracy, hood. why isn’t D.C. afforded the constitutional especially today. More recently, on April 20th, the Biden right to be heard in Congress? Other Congress members have worried administration formally announced their Furthermore, the fact that D.C. isn’t a about D.C.’s potential Democratic influ- support for D.C. Statehood.142 This state- state has limited it even more during the ence. Representative James Comer (R-KY) ment was noticeably right before the House coronavirus pandemic. The Coronavirus argued that “D.C. statehood is a key part of voted for statehood, which we now know n. 146

20 The Horace Mann Review | Vol. XXX June 2021 21 Domestic Domestic the verdict was being read, another Black forced his knee on this handcuffed man’s before reaching the courts, and therefore, teenager, Ma’Khia Bryant, was gasping for neck, this reform can revolutionize the way may entail extended delays. Besides the breath in Columbus, Ohio. While the list of police operate. This Act was introduced collaboration challenges, the civilian people-of-color perished in police violence in Congress last year and passed the population will need to be educated about does not necessarily end here, defunding House in March 2021. Forbidding racial the new resources and modes of access. the police may not be the right answer at and religious profiling by the local, state, Key to a well-oiled implementation will be the moment. Abolishing the funds entirely and federal law enforcement, this Act persistent training for all personnel in every will lead to reckless rises in other crimes will enforce anti-bias training as well as involved organization, stringent quality and most definitely will create levels of mandate data collection on race, sex, (dis) control and compliance practices, and social unrest unmanageable by other law ability, and religion when police force is more community awareness programs. All enforcement municipal authorities. At used. Drawing a clear line between lethal this may translate into additional funding the same time, reducing police funding and non-lethal use of force, this Act will requirements from the federal government. may take away the resources necessary not only ban the use of chokeholds, carotid Through the implementation of the for essential functions of policing such as holds, and no-knock warrants for federal George Floyd Justice In Policing Act, manning school premises or attending drug cases, but will also direct grants to the responsibility of public safety will be to 911 calls for medical emergencies. In the agencies that demonstrate adequate evenly shared between the police and fact, the recent attack on Capitol Hill on training in non-lethal de-escalation. While community organizations like BCJC, and January 6th, 2021 underscores one such essential function of police which is to protect our lawmakers. The events of that “Besides the collaboration challenges, the day can also present a counter-argument that the police may in fact need additional civilian population will need to be educated funding to overcome a sluggish response about the new resources and modes of n. 155 and lack of intelligence attributed to the attack. A more substantiated effort would access. Key to a well-oiled implementation be to reduce the scope of policing, not its will be persistent training for all personnel funding. Grassroots organizations that in every involved organization, stringent The Verdict is In, are better equipped for managing mental health needs, housing for the homeless, quality control and compliance practices, and education for incarcerated children can take away some load off of policing. and more community awareness programs.” But Are We Truly Done? One such organization, Brownsville Community Justice Center (BCJC) in some state books require body cameras the mission of equitable justice will become Krish Gandhi Brooklyn, NY provides alternatives to already, this Act will require all federal more realistically achievable. However, incarceration through programs such as police officers and vehicles to be equipped the reform legislation has to first pass in n the Fourth Judicial District court for all has been crisply written in our but had been simmering since long, given Learning Labs to offer educational support with body cameras and dashboard cameras the politically divided Senate. While both state of , the judge read out constitution since 1868, we still struggle the history of an uneven justice system and Belmont Revitalization Project to help respectively. Currently, police officers are Republicans and Democrats understand the verdict in Derek Chauvin’s murder to manifest the 14th Amendment into that disproportionately targets the people reimagine public spaces.152 Safe Summer insured by the protective shield of qualified an urgency of such reform and dispose Itrial at 4:05 pm CST on April 20th, 2021, action more than a century later and find of color. After all, the police force itself NYC 2021 is another initiative supported immunity that makes it harder to prosecute of the idea of police defunding, they do announcing him guilty. Jurors of varying sacrifice of innocent lives a valid excuse to evolved from 1800s slave patrols in the by Mayor de Blasio that will launch safe them. Changing the mens rea (guilty mind) not fully agree on issues such as qualified race, color, profession, and gender watched crawl another inch closer to an equitable South and colonial watch programs in the parks and gang-free zones in 31 sites across requirement from a ‘wilful’ standard to a immunity. With the bill stalled in the a painfully graphic trial for three weeks, society.148 Racial discrimination exists, North.149 The 1900s once again saw police the city. This program will create 800-1000 ‘reckless’ standard will make prosecution Senate, President Joe Biden is urging compared meticulous discourses by 38 resurfacing in different forms at different enforcing racial segregation, sometimes anti-violence youth employment slots, hold easier in the civil courts if the constitutional Congress to resolve and pass the bill before prosecution and seven defense witnesses, times, and this time, it took the shape of with the help of Klu Klux Klan, continually Saturday night light games in 100 sites, and rights of an individual are violated. Finally, the first death anniversary of the man who and observed tears of regret streaming from police brutality. Even though justice was defying equality. Recently, one Washington anti-violence fairs in 30 sites citywide. 153 the overarching goal of the George Floyd lent his name to it. Whether Bass, eye-witnesses.147 They deliberated fairly seemingly served for one man in Chauvin’s Post study reported that even today, for Policing and prisons have not solved the Justice In Policing Act is to reimagine public Democratic Representative from and impartially over two days to arrive at trial, there are miles to walk before equality every white person, five Black Americans problems of our society in more than 200 safety on the pillars of community-based and primary author of the bill, gets the a unanimous decision of finding Chauvin can be accomplished for the people of color will be imprisoned. Even more so, Black years. While protests, reduced funding, collaboration, accountability and tracking, Senate to vote for it in its entirety, or, Tim guilty on all three charges against George in America. Americans are three times more likely to be and revised scope can have an impact, and developmental training. Conceptually Scott, a Republican from South Carolina Floyd–second-degree unintentional The protests that followed George killed by the police.150 Interestingly enough, individually or in combination, we have a well-knitted idea, the implementation of it who has introduced a counter bill, succeeds murder, third-degree murder, and second- Floyd’s killing are one way to seek approximately 1000 people are killed every miles to walk. However, every single may come with its own perils. Taking away in his negotiations, is yet to be seen. What degree manslaughter. The country rejoiced equality. Another way is the proposal to year by the police. Spread nationwide with initiative could be equivalent to saving the central control of law enforcement from is certain is that George Floyd’s death and over the verdict. Phones began buzzing . ‘Defunding’ can be no particular ties to a red or a blue state, a Black life, and therefore, is worth an police and redistributing it among disparate, other similar sacrifices in the past year as congratulatory words passed from described as a moving marker between that number has remained steady since effort. President Joe Biden has proposed and often disconnected organizations have sparked the biggest outcry for racial the courtroom to White House to other completely abolishing the police force, 2014.151 As appalling as these numbers are, police reform measures such as enhanced will clearly create room for inclusivity justice and police reform in the U.S. thus countries to Floyd’s family, and the message collaborating with other agencies that are so is the scenery of the present day. While oversight and training, barring the use of and diverse voices. At the same time, far. While we still have miles to walk, the was clear: Black Lives Matter. But in usually supported by the municipality, and Chauvin was being tried for manslaughter chokeholds, increased funds for community achieving consistency in the enforcement George Floyd Justice In Policing Act will be reality, one more Black life was lost as we reorganizing the law enforcement agencies. and , Daunte policing, and more outlined in the “George of law may become a challenge, amongst a critical stepping stone in the new era of inched closer to justice in one of the largest The notion of defunding transpired out Wright was shot just a few miles away Floyd Justice In Policing Act.”154 Inspired other coordination hurdles when many police equality for people of color.HMR democracies of the world. While equality of anger in the aftermath of Floyd killing, from the courthouse. Within weeks, as by a Black man who lost his life pleading, organizations are involved. For instance, “I can’t breathe” to a police officer who each case may pass through several hands 22 The Horace Mann Review | Vol. XXX June 2021 23 Domestic Domestic

an alternative plan, which would allocate “5% to 10% of the $621 billion proposed for transportation infrastructure and $300 bil- AMERICA’S JOBS PLAN: lion earmarked for manufacturing to train women in the jobs being created in those respective fields.”171 In these unprecedented times, we should Reconceptualizing Infrastructure redefine what we need as a society and pri- oritize as a country. We can not separate the effect of systemic and historical bias from for a New Century the way we structure our society’s invest- ments. Defining infrastructure to include a broader conceptualization of what makes us productive as a society is crucial and neces- sary. In particular, it is time to create invest- ments that provide opportunities for all to Isabel Mavrides-Calderón contribute to the economy, avoiding band- aids, and thinking long-term. One of the he pandemic has had a devastat- industry, who in their majority are Black the workforce.164 Melissa Boteach, from the benefits of Biden’s plan is that most projects ing economic and human impact or brown workers. This encompasses set- National Women’s Law Center, believed are not “shovel ready”; they don’t provide across the United States, high- ting aside money to support disabled folk that before the pandemic the US had a defi- only a quick bolster of growth for the short lightingT underlying systemic inequalities and elderly people, and those who care cient care system, and therefore “That’s why term.172 Instead, projects in the propos- embedded in our society. To mitigate the for them.160 While Biden’s plan sounds we saw a total collapse of the care indus- al use federal spending spread over years, effects of the increase in unemployment, promising, it has been met with stark crit- try and also why we saw so many women providing social and economic support to the Biden administration had deployed a icism about its cost, who it leaves out, and pushed out of the labor force.”165 entire communities that needed long-term series of policies to revitalize the economy. a broader debate on what infrastructure During the pandemic, it was evident support.173 The emphasis on climate change After passing America’s Rescue Plan, Pres- should mean. that protections for older adults and the and sustainability also speaks of the long- ident Joe Biden recently proposed an am- Republicans in Congress have pushed one-quarter of Amricans currently living term mindedness of these investments in bitious two-trillion-dollar infrastructure back against the significant cost of Biden’s with a disability were inadequate. For the changing the future of the world. In addi- plan to further his vision for America.156 plan, which is proposed to be paid with many mothers working from home while tion, this plan’s focus recognizes the inter- Infrastructure plans are not new to the an increase in taxes for those earning raising young children, child care has also section between environmental justice and American presidency. President Franklin over $400,000. Leader McCarthy explains: proven to be of the utmost importance. racial justice. There is no doubt that there D. Roosevelt executed a revolutionary in- “When the president talks about not rais- People who care for those individuals have are fears of an increase in our nation’s defi- frastructure deployment through the New ing taxes on people under $400,000, that’s often been characterized as low-skilled cit that could cripple the ability of future Deal after the Great Depression. Using the a lie. Every day you watch the inflation workers and, therefore, receive minimum generations to achieve prosperity. How- Public Works Administration, Works Prog- that he is creating. This is the Biden Tax.”161 wage. These jobs are primarily held by ever, let’s stop and think about the kind of ress Administration, and other agencies, Despite the opposition to the bill, Biden’s women of color.166 future we will inherit if we don’t take care the New Deal built countless roads, dams, infrastructure proposal is revolutionary. It Republicans fear that many of the new of those that need us the most, provide so- schools, parks, and airports.157 These works recognizes that racial disparities are deeply care jobs will increase the number of cial stability for millions of disenfranchised are what is typically considered infrastruc- intertwined with infrastructure implemen- unionized people who typically vote Dem- individuals, and stop the effects of climate ture, but Biden’s plan has re-conceptualized tation. For instance, President Biden’s plan ocrat.167 More progressive Democrats, on change. We have to choose between avoid- this term to include non-traditional invest- includes a proposal to replace the lead-in- the other hand, criticize the plan for not ing a deficit and addressing issues head-on. ments with the aim to fight climate change fested pipes in Flint, Michigan, which af- doing enough for women and leaving them If we decide to take the leap and risk en- and systemic economic and racial inequi- fected the health of primarily Black chil- behind of some major investments. Ac- gaging in bold investments we, as a nation, ties.158 For example, The Hill, reported that dren. Another example is the cleaning up cording to a CNN article titled: “Joe Biden’s will assure the survival of the US as a global “Biden’s proposal includes repairing 20,000 of environmental hazards that have signifi- Infrastructure Plan Could Leave Too Many leader. HMR miles of roads and 10,000 bridges, expand- cantly affected Hispanic and Indigenous Women Behind,” while Biden’s plan will ing broadband access to rural and under- populations.162 In addition, Biden’s plan in- help create millions of jobs, many of those served communities, replacing the nation’s cludes policies for access to early education jobs are in male-dominated fields like con- lead pipes and service lines for clean water, for low-income families and communities struction and transportation.168 The em- investing in manufacturing, and expand- of color and access to broadband for rural phasis on women’s jobs is pressing, as the ing access to home and community-based America, which has proven to be sorely pandemic brought more women out of the c are .” 159 Specifically, a key part of Biden’s lacking during the pandemic.163 Further- workforce than men.169 Between February infrastructure plan is to dedicate billions more, Biden’s plan recognizes that investing and April of last year, 13.4 million wom- of dollars to help reverse systemic racism in the care for family members, the elderly, en lost their jobs, which is proportionally and racial disparities by improving condi- disabled, or children, should be considered more than their male counterparts.170 La- tions and salaries for individuals in the care “infrastructure”, as it allows millions to join bor economist Michelle Holder proposes n. 174

24 The Horace Mann Review | Vol. XXX June 2021 25 International International

tries, Putin turned back to a familiar tactic that he leans on when pressured. He did the same in the aforementioned 2014 an- nexation of Crimea, where he was able to unite his country against the new pro-West Ukranian government .180 By going back to his familiar tactics for stressful situations, Putin has shown that he is scared and that the US’s strategy is having an effect. Putin is also scared about the upcoming Russian parliamentary elections this year, which must be held by September. In the lead-up to the election, preliminary polling shows Putin with record-lows in approv- al and public trust. Among young voters, Putin’s approval rating dropped 17 points, his trustworthiness fell by 5%, and that of his opposition rose by 5%. In addition, the approval rating of his party, United Russia, fell to barely 30% from over 48% two years prior.181 And while it is widely expected that the elections will be corrupt and dominated by United Russia, the decrease indicates the rising popularity of the opposition, which n. 190 could lead to a return to the streets as Rus- sians protest unfair elections. In addition, even a slight decline in often biased Rus- n. 189 sian state polling suggests that there may “What Putin fears the most is not poli- be more parity in Russia’s elections than previously thought.182 Putin knows this, tics nor the US, but his own citizens.” too, which is why he’s desperately searching for a way to unify the nation. He attempt- Putin is truly scared of revolution.185 And offshore bank accounts to secretly build ed to do this through the aforementioned now, he has more to be scared of than ever, himself a $1,000,000,000 mansion on the Ukrainian power play, as whenever he feels WHY PUTIN IS SCARED as Russia has experienced unprecedented Black Sea, complete with thousands of se- vulnerable, he tries to unify the nation un- social unrest caused by the actions of one curity guards and over 17,000 acres of pri- der an anti-Western banner and make peo- Avi Rao man: Alexei Navalny. Navalny has been the vate land around it. That video currently has ple forget Russia’s own domestic issues. 177 Russian opposition leader for over ten years over 115 million views and nearly 5 million n April 20, 2021, a Russian military complex image. They show that for the first Trump. However, it was all for naught, Finally, what Putin fears most is not and has been described as the man Vladi- likes from people around the world, which force of over 100,000 men amassed time in a long while, Putin is scared. He’s as Biden won the election and immedi- politics nor the US, but his own citizens. itself at the Russo-Ukrainian bor- scared about a new, hostile United States. ately took decisive actions against Russia. mir Putin fears most. What makes him so combined equals over 80% of Russia’s pop- After all, Vladimir Putin is no stranger to 188 Oder on the command of Russian President He’s scared about his record-low polling for In March, he levied economic sanctions scary to Putin that Putin refuses to say his ulation. Through his charisma and ability revolution. He was a KGB representative in 176 name is his ability to turn the internation- to rally Russia’s people to his cause, Alexei Vladimir Putin as fleets of Russian assault the upcoming election; however, most against Moscow for the jailing of opposi- East Germany during the fall of the Berlin al spotlight onto the rampant corruption Navalny has created the first organized and ships patrolled the Azov Sea. The situation of all, Putin is scared of his people, and tion leader Alexei Navalny and a month Wall, during which he frantically destroyed in Russia that would otherwise go unno- powerful opposition to Putin and has taken was reminiscent of 2014 when Russia took the prospect of unprecedented widespread later expelled ten Russian diplomats in evidence of KGB espionage activities while ticed. After being poisoned with a Russian the first step towards restoration of democ- similar actions and annexed the previous- social unrest, furthered by Alexei Naval- response to the Russian SolarWinds hack. his commanders refused his requests for nerve agent and going through intensive racy in Russia. ly Ukrainian Crimea as retribution for ny—the man Putin fears most. And Putin’s Russia responded by expelling ten diplo- contact amidst the chaos.183 Years later, in care, Navalny returned to Russia, only to All in all, Russia is at an unprecedent- the pro-European Ukrainian Euromaidan growing anxiety has pushed him into a far mats in turn and blaming the US for in- 2004, Putin found himself again powerless be arrested on landing.186 His arrest, as well ed crossroads, that of which we have nev- protests earlier that year, which Russia de- more precarious position, one that he feels citing revolts in countries neighboring to respond to the anti-Russia Orange Rev- 178 as his deteriorating condition in a Russian er seen before. For the first time in a long nounced as an illegal coup. However, just as needs to be bolstered by any means possi- Russia. However, Russia’s most telling olution in Ukraine. Putin’s experience with Gulag, sparked massive protests in Russia time, Putin is truly worried, and Russia’s quickly as the buildup started, it stopped. ble. response to US sanctions was their person- these revolutions led him to vow “never and condemnation from around the world. people seem more primed than ever to fight Russian troops retreated, the force disband- The first reason for Putin’s fear is the re- al attacks on Joe Biden. A Russian Parlia- again.”184 He responded swiftly with mili- Hundreds of thousands of Russians took to for democracy. Now, however, it’s time for ed, and it became clear that Russia’s military turn of an active anti-Russia United States ment member said that Biden has “Polit- tary force to the 2008 Georgian Revolution the streets over three months to protest the the US to step in. The US cannot afford to buildup was solely for purposes of intimida- under President Joe Biden. Since 2016, ical Dementia,” a state TV anchor called and the 2014 Ukrainian Revolution, and in corruption and autocratic rule of Vladimir let up on Russia now. If we were to take an tion. When explained this way, Russia’s tac- Russia had enjoyed a relatively friendly re- Biden “the American patient,” and Putin 2016 he created the 350,000-troop-strong Putin.187 Their outrage only intensified -af even harder stance in support of Navalny, tics seem simple enough; a simple show of lationship with the Trump administration, rallied anti-West sentiment by condemning Russian National Guard as a response to 179 ter the release of a two-hour-long YouTube we could drastically speed up the inevita- power over their hostile Ukrainian neigh- with minimal American resistance to Rus- Biden’s comment that Putin is a “killer.” growing national unrest, commanded di- 175 documentary detailing the corruption in ble Third Russian Revolution and radically bors. However, when examined closely, sian activity. Putin even interfered in the By attacking Biden’s mental health and ral- rectly by him and led by his former per- Russia and how Putin used a network of change the state of global geopolitics forev- Putin’s actions in Ukraine and elsewhere US election in opposition to Biden, fearful lying anti-West sentiment by accusing the sonal bodyguard. The creation of this per- shell companies, business executives, and er. HMR these past weeks illustrate a much more that he would lose the leeway he had with US of interference in neighboring coun- sonal army shows that beneath his facade,

26 The Horace Mann Review | Vol. XXX June 2021 27 International International in Whitsun Reef, declared by the U.N. as a part of the Philippines’ nautical zone.196 Foreign fishing also threatens a country’s ecosystem. While in the Philippines, Chinese boats have been filmed harvesting giant clams, recently repopulated by Filipino scientists after they went virtually CHINA’S extinct. Ecuadorian officials have stated that Chinese fishing has endangered the biodiversity of the Galapagos, as many animals depend on the squid caught FISHING FLEET in large numbers by Chinese vessels.197 Chinese fishing off the Argentinian coast has similarly hurt the food chain in that Myra Malik area-- as Greenpeace concluded in 2019, this type of fishing has “devastated” the Argentinian coast’s seabed.198 Lastly, foreign fishing can harm a nation’s economy through its effects on the fishing sector. In Ghana, the size and scope of Chinese fishing vessels outcompetes the smaller fishing canoes of local fish farmers. Axim, a fishing town in Ghana, has suffered n. 208 greatly from the loss of income and resources to Chinese fishing.199 Because the Chinese trawlers catch so many fish within “The most effective way to curb Chinese the reserved Ghanaian fishery area, local fish farmers are forced to drive 80 miles neocolonialism would be for the U.S. to provide east to buy fish from Chinese fishermen. better foreign aid and trade services to countries This loss of income and resources is with heavy economic Chinese influence.” especially devastating to countries near bodies of water, such as Ghana, because built by a very rich country and a much such as the U.S. sending in Navy warships many waterfront towns in these countries poorer one -- as in the case of China and near Chinese vessels docked in Malaysia, depend largely on fishing for their income. its African endeavors -- ultimately has led but Malaysia expressed “displeasure” at In the nearby country of Sierra Leone, local to exploitation. For example, in Zambia, their arrival -- most likely because of authorities have stated that illegal Chinese China has acquired one-third of all national the portrayal as a country that needs fishing drains $29 million from Sierra debt and invested heavily in mining and “protecting” or “saving.”205 Leone’s economy annually -- with relatively infrastructure-- however, unemployment The most effective way to curb Chinese n. 207 200 little policing. has shot up in the South African nation and neocolonialism would be for the U.S. to The countries China exploits for fishing safety regulations in mining are commonly provide better foreign aid and trade services n recent decades, China has risen an extension of Chinese neocolonialism in Island waters, and Ecuadorian waters. are always smaller countries, and often disregarded.203 It is almost inevitable that to countries with heavy economic Chinese from an underdeveloped agrarian developing nations. Furthermore, the U.S. China’s fishing practices harm various island groups, such as Malaysia, Indonesia, this dynamic would spread from natural influence. The U.S. does not need to save any nation to the world’s most populous should step up to aid nations victimized by countries’ sovereignty, economies, and the Philippines, and the Galapagos. resources in terms of mining to those country; instead, providing other countries country,I with a booming population of China’s neocolonialism, instead of using ecosystems. While Chinese fishing has devastating in terms of biological resources, such as with choices in investments, credits, and 1.4 billion. Along with such an immense intimidation and empty words to condemn China’s illegal fishing infringes upon environmental effects on these island fishing. Additionally, while China accounts aid reduces the risk of exploitation at the population comes the inevitable burden of China. the law within multiple nations, especially coasts’ biodiversity, the economic effects for a third of the world’s fish consumption, hands of neocolonialism. Because China food. How is one nation to procure enough China’s fishing fleet is by far the world’s those in the Pacific Ocean and in Africa. In are felt most heavily in African countries. over 150 million Chinese people are offers soft-power, generous foreign aid in food to feed 1.4 billion people every day? largest, estimated at anywhere between June 2020, Ghana’s marine police detained Both Ghana and Sierra Leone suffer high malnourished.204 Although China’s rates the form of roads, railways, and pipelines, it 193 China, in recent years, has turned to 200,000 to 800,000 boats. Some of its Chinese-owned trawler boats, as they were economic losses in the fishing sector due of malnourishment have been on the becomes more approachable than the U.S., fishing. China is the largest global exporter most controversial techniques include using accused of using illegally large fishing to powerful Chinese fishing. However, decline, the high number of people still which has been known to use intimidation 195 of fish and fishery products, producing 65 banned equipment and fishing in other nets. Malaysian maritime authorities because of China’s neocolonialist reach experiencing food insecurity points to the and ‘strings-attached’ policies in the way of million tonnes of food fish in 2015 alone.191 nations’ waters. These dangerous, and in detained Chinese fishing vessels after in these nations, there is little they can fishing fleets being tactics of intimidation aid.206 The U.S. must stop using intimidation The demand, however, has grown to exceed some cases unlawful, practices cause harm accusing them of trespassing in their waters do to push back. In Sierra Leone, China rather than of self-sustenance. of revoking foreign aid to gain votes in the the readily available supply. While China to the environment and to local economies. in October 2020. Indonesian authorities has invested billions of dollars into Solutions to the problems of Chinese U.N., instead taking a more open approach accounts for a third of the world’s fish Between 2010 and 2019, Chinese vessels also began investigating a Chinese tuna the nation’s infrastructure and mining fishing -- and on a much broader scale, to foreign relations. It must step up to help 201 consumption, over 150 million Chinese accounted for 21% of all fishing offenses trawler in May of the same year, when it was sectors. China has also invested billions Chinese neocolonialism -- are difficult other countries, instead of pointing at people are malnourished.192 Chinese recorded by the fishing crime database discovered that four Indonesian fishermen of dollars into Ghana’s infrastructure, in to come across, because of China’s global China with its own dirty finger. 194 HMR fishing fleets have been stirring waters Spyglass. China’s most notable fishing had died on that boat in the South Pacific exchange for access to the same value of economic power. It may seem important 202 around the world in their fishing locations boat incidents took place in the East and Ocean. Chinese ships’ presence in the natural resources. At surface-level it may for allies of smaller countries to help out and behaviors, as well as their position as South China Seas, Ghanaian waters, Pacific Philippines also broke the law by docking seem generous, but the power dynamic in infringements of national sovereignty, 28 The Horace Mann Review | Vol. XXX June 2021 29 International International

Withdrawing U.S. troops would be ben- n. 231 eficial for Afghanistan because, other than diminishing the threat of terrorist attacks in Afghanistan, the military’s efforts at in- creasing democracy or women’s rights in Afghanistan have been unsuccessful. The United States has historically turned a blind eye to the corruption within the Afghan government, such as the reelection of for- mer president Hamid Karzai. Additionally, although the United States has spent over IMAGE GOES HERE $126 billion on reconstruction programs in Afghanistan, about $15.5 billion of that money was wasted in part to fraud and abuse.218 In many cases, the U.S. military fueled corruption and instability by bribing politicians, funneling money to opium war- lords, and even paying off religious leaders for information.219 One such example of the United States allying with shady figures was their relationship with Mohammed Qasim Fahim Khan, a Tajik military commander well known for his brutality.220 Despite his violent history, the United States invited him to the Pentagon and even greeted him with the ceremonial guard.221 n. 232 Biden’s Promise to Withdraw US Troops from Afghanistan: The military has made little long-term change in regards to women’s rights. While itive close to a lengthy process that was al- lar level of self-sufficiency.227 women are now able to hold government ready occurring. The concerns of women’s rights in Af- Long Overdue or Unwise Grandstanding? positions and be educated, these advances Despite the number of positives that will ghanistan need to be officially addressed, in women’s rights effectively only apply to come with the United States’ withdrawal, including women from all backgrounds Sophia Liu urban women, who make up about 24% of there are still a number of issues the U.S. and classes. Afghanistan has one of the the population of women.222 In rural areas, needs to address to withdraw successful- highest maternal mortality rates in the n April 14, 2021, President Joe is founded in fear that the withdrawal will U.S. intelligence has shown that the women still suffer from the same problems ly. In order for this withdrawal to be suc- world, as well as one of the lowest life ex- Biden announced that he would result in increases in Taliban activity, and threat of terrorist attacks against the United they did before American intervention, if cessful, the Biden administration must be pectancy rates.228 Education for females is withdraw all US troops from Af- undo wins for democracy and women’s States is no longer solely or even primarily not more. Because of American military Oghanistan by September 11 of this year, the rights in Afghanistan. Despite these risks, from Afghanistan. The United States was equipped for the risk that the Taliban will also extremely low, with most girls receiv- intervention, women’s lives are continually gain power. After all, when the Obama ad- ing barely any schooling.229 Considering 20th anniversary of the 9/11 terrorist attack the pros clearly outweigh the cons. Presi- somewhat successful in their initial goal disrupted by persistent violence between ministration withdrew soldiers out of Iraq, that neither the Taliban nor the Afghan on the Twin Towers. “With the terror threat dent Biden’s decision to withdraw soldiers to decrease the threat of terrorism in Af- the Taliban and government forces.223 the Islamic State of Iraq and Syria (ISIS) government have been particularly forth- now in many places, keeping thousands of from Afghanistan was certainly justified, if ghanistan; Al-Qaeda’s influence is signifi- Therefore, it is apparent that the United was quickly able to rise in strength once coming about improving women’s rights troops grounded and concentrated in just not long overdue. cantly weaker, and other radical Islamic States military champions in Afghanistan again. Without as much American military on their own, the United States should feel one country at a cost of billions each year It is important to note that despite the groups, like the Islamic State of Khorasan, have been largely ineffective and possibly 215 support, Afghanistan is in danger of the obligated to continue fighting for gender makes little sense to me and to our lead- United States’ plans to withdraw troops are being attacked by the Taliban. As detrimental. same thing happening to them. equality through foreign aid or contribut- ers,” President Biden said in his address. from Afghanistan, they do not plan to stop one senior administration official to Pres- Additionally, American troops have It is also crucial that the Biden adminis- ing to international efforts like NATO.230 “We cannot continue the cycle of extending fighting the Taliban through other means. ident Biden stated, “Afghanistan just does gradually withdrawn from Afghanistan for tration is more upfront about where their If these prerequisites are met, Biden’s or expanding our military presence in Af- Biden expressed that the U.S. will contin- not rise to the level of those other threats several years without any negative impacts. financial aid is going, to prevent corruption plan to bring soldiers back home is a nec- ghanistan, hoping to create ideal conditions ue to provide humanitarian, diplomatic, at this point...That does not mean we’re Whereas the number of American sol- within the Afghan government and pro- essary and beneficial step for the United for the withdrawal, and expecting a differ- and security assistance to the Afghan gov- turning away from Afghanistan. We are go- diers in Afghanistan was around 98,000 in 209 212 ductively spend their resources. The U.S. States to focus on more diplomatic ap- ent result.” Since Biden’s speech, Repub- ernment. On April 21, 2021, Secretary ing to remain...committed diplomatically. 2011, the number of soldiers diminished to should focus on counteracting the massive proaches to ending the warfare in Afghan- licans and Democrats alike have attacked of State Antony Blinken announced that But...we believe that other priorities merit around 2,500 as of January 2021––the few- 216 opium industry and boosting economic istan. Withdrawal from Afghanistan will his remarks for their risks to the Ameri- the United States plans on giving an extra that investment.” Instead of Afghanistan, est number of soldiers since the initiative development. As of 2018, Afghanistan is give the United States the opportunity to can people. Although former Presidents $300 million of financial aid to Afghanistan countries like Somalia, Mali, and Yemen, first began in 2001.224 The drop in numbers 213 responsible for 80% of global illicit opi- reassess their priorities in terms of funding, George W. Bush and Barack Obama both this year, which supports Biden’s claims. where terrorist groups like al-Shahab and has largely been due to the Trump admin- um production, despite the United States both in terms of reorganizing their foreign vocally support his decision, their endorse- Thus, the belief that the Biden administra- other affiliates with ISIS and Al-Qaeda are istration, which was also planning on fully spending $10 billion on counternarcotics aid in Afghanistan and reallocating funds ments have not swayed everyone’s opin- tion “has decided to abandon U.S. efforts in growing in power and prominence, making withdrawing soldiers from Afghanistan.225 210 217 in the past.226 As the majority of Afghans to larger threats in North Africa. It is clear ion. As CIA Director William Burns said Afghanistan which have helped keep radi- them the real threats. If troops are with- Considering that so few soldiers are cur- 214 continue to live in poverty, with over 25% that President Biden’s decision to withdraw in a hearing on April 14, “the U.S. govern- cal Islamic terrorism in check” is simply drawn from Afghanistan, the United States rently in Afghanistan, total withdrawal of them being unemployed, the U.S. should troops from Afghanistan can be viewed as ment’s ability to collect and act on threats untrue, as the President is only changing will have more soldiers and resources to would result in little change from the status 211 strive to choose where their funding goes to the correct decision. will diminish.” This bipartisan concern the status of the U.S.’s military presence. stop real threats internally and externally. quo. Biden’s plan would only bring a defin- HMR most assistAfghanistan in retaining a simi- 30 The Horace Mann Review | Vol. XXX June 2021 31 International International

for unblamable problems.234 According impacting the French middle class, their adopted QAnon in Europe are much less to Mark Scott of , “It’s not difficult demonstrations have become increasingly focused on Q’s theories themselves —other QAnon’s Comeback: for someone who lost his job and hasn’t violent.239 Though the Yellow Vest group than those about Angela Merkel— but been affected by the coronavirus to come still remains bipartisan, more and more associate more with what QAnon stands across these ideas online and jump to the far-right beliefs have appeared at their for. conclusion that something is going on.” demonstrations, including Islamophobia, QAnon’s increasing popularity poses a The Rise of Conspiracy Theory QAnon gave its followers people they could homophobia, anti-semitism, and racism. global threat to security. In the US, we have blame COVID and other problems in the After footage of Yellow Vest protests leaked, seen the effects of QAnon in capital riots, world on.235 QAnon took notice of the Yellow Vest superspreader events, vaccine hesitancy, Across European Countries Additionally, QAnon resonates with group. For the Yellow Vests, QAnon’s theory and explicit discrimination against those who do not acknowledge COVID’s of bizarre crime among the international minorities. Additionally, if this continues existence: it has relentlessly promoted elite attracted them. Since mid-December, to spread we will be fighting a global force disinformation about the virus, even Yellow Vest protests have become flooded attacking the bonds between society and Maya Westra stating that COVID was a hoax meant to with QAnon signs. government. This is a significant threat damage Trump’s re-election campaign and In response to QAnon’s recent growth, due to QAnon’s massive appeal. Blaming n. 241 supporting anti-vaccine propaganda.236The Mike Rothschild, an American economist, misfortunes on the government takes the spread of QAnon poses a great threat to tweeted “I really feel like we’re heading blame off of those who feel they have been society, for it also means the spread of for a Q movement where Q[‘s title] isn’t disappointed. It is scary to see that what vaccine hesitancy. With more people tied necessary,” which sums up the spread of was once a 4Chan account has turned into to QAnon, it can spread its anti-vaccine QAnon in Europe.240 In other words, the a global far-right group that threatens the propaganda even further, increasing growth of QAnon is fostering the spread lives and livelihoods of millions through vaccine hesitancy. Vaccines save lives; every of racism, anti-vaccine propaganda, and anti-vaccine propaganda, discrimination, seed of doubt planted in a person’s mind can conspiracies to populations not affiliated and violence against the state. It must be translate to a life thrown away to COVID. with QAnon. The groups which have stopped. HMR QAnon’s damaging effects are more than just vaccine disinformation. Recently, QAnon supporters organized a protest they called the “Second Uprising,” mobilizing Where does free over 7,000 Germans, who marched through the streets carrying QAnon posters, Nazi speech end and flags, and other offensive attire. QAnon spread its discriminatory message loud and clear through the march. People were on extremism begin? high alert with the threat of these protesters possibly storming the capital as they did in the US.237 The riot came as a result of QAnon’s theories about Angela Merkel, the chancellor of Germany. QAnon spread false rumours that NATO maneuvers in Germany during the beginning of the pandemic were an attempt by Trump to liberate Germany from Merkel and thus caused even more widespread disdain for her among the far right. Though it originally surprised many that QAnon was able to spread so quickly in Germany, people later realised that Germany’s far right party, The National Democratic Party of Germany, supported QAnon’s anti- semitism. QAnon used this together with 233 he right wing conspiracy QAnon even cannibalism. The theories QAnon in France. the promotion of anti-vaccine propaganda has spread its contagion across produced have helped polarize the U.S. COVID enabled QAnon to gain to draw in the far right, amassing 200,000 Europe. Formed in 2017 during politically into believing opponents are not popularity and spread to Europe. German followers.238 DonaldT Trump’s presidency, QAnon is an only ideologically wrong, but dangerous Historically, people have relied on QAnon has also drawn in members antisemitic, far-right conspiracy group criminals who must be stopped at all costs. conspiracy theories most in times when of the yellow vest group that started in which has falsely accused many liberal The QAnon group has infected Europe too, they feel they have no control, because France. Originally created as a bipartisan public figures of plotting war against fueling the debate over Angela Merkel, conspiracies offer an answer to many group to contest new tax reforms, raised Trump, sex trafficking, Satanism, and anti-vaxxers in Italy, and the Yellow Jackets unanswerable questions and a scapegoat cost of living, and other changes negatively n. 242

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lic to understand the relative threat posed. About one in 500,000 people experienced clotting from the J&J vaccine, and it is es- timated that one out of every 1,000 wom- en on birth control and one of every 1,000 smokers develop a blood clot each year.248 When one thinks of birth control or smok- ing, they do not think of the risk of blood clotting, and the risk of blood clots in the J&J vaccine is practically nonexistent com- pared to the risk that these actions pose. Looking at the alternative to being vacci- nated, one in five COVID patients are hos- pitalized.249 Weighing all of these statistics makes it evident that the benefits far out- weigh the risks. The FDA stated that their decision to halt the vaccine was made “out of an abundance of caution,” but even so, their decision has exacerbated vaccine hesi- tancy due to an insignificant risk.250 As the United States approaches 150 million vaccinated people, the pace of vaccinations has been slowing. Since the peak number of vaccinations in one day, at 3.4 million, on April 13th, the average n. 258 number of people receiving their first or n. 257 single dose has dropped by around fif- “We must focus on encouraging ty percent.251 Not only was April 13th the height of vaccinations, but it was also the date that health officers announced a pause vaccination and combating misinforma- of the J&J vaccine. On a national level, the number of individuals receiving both Pfizer tion to put the pandemic behind us.” Investigating the Johnson & Johnson and Moderna vaccines, along with J&J vac- cines, is decreasing.252 We have reached a enough Pfizer and Moderna vaccines to oping countries feel like the vaccines they point where most Americans who wanted make up for the J&J slowdowns. However, rely on are second-class or that their lives Vaccine Pause to be vaccinated have already been vacci- pauses in poorer countries, where there is matter less. In these ways, the harmful J&J nated, and now it is a matter of convincing less vaccine availability, could have major halt could contribute to ongoing global vac- Sophie Dauer hesitant people to go get their shot. So, it impacts. A major piece of the vaccination cine disparities and lead to an even-longer is mostly a coincidence that the national effort in developing countries is COVAX, pandemic. a global network working to distribute The J&J vaccine pause has done far more n April 13, 2021, United States true that ignoring the risk would have sent which are cell fragments that stop blood decrease is concurrent with the J&J halt; vaccines fairly across nations, particularly harm than good. While one in 500,000 ex- health officials announced a the message that health officials are lying to loss. Platelets help to avoid and fix the clot- however, the halt definitely exacerbated the poorer ones.255 COVAX relies heavily on perience clotting from the vaccine, one in pause of the distribution of the public, the pause has prompted fewer ting process, so these very rare instances of decrease, given that one in five unvaccinat- the J&J vaccine as well as the AstraZeneca five unvaccinated people have reported that theO Johnson & Johnson (J&J) COVID-19 Americans to get vaccinated. Given that the the mixture of low platelets and dangerous ed people have reported that the pause on vaccine which is another single-dose vac- the pause on J&J’s vaccine changed their vaccine because of rare complications in- statistics prove just how small the threat is, clotting have struck the concern of some. J&J’s vaccine changed their mind about get- 253 cine that has caused similar blood clots, so mind about getting the vaccine in some volving blood clots. Eleven days later, U.S. the FDA and CDC should not have ordered Of the sixteen people who developed blood ting the vaccine in some way. Given that questions surrounding their safeties could way. Even worse, the pause came at a crit- federal health officials lifted the pause, al- the halt of the J&J vaccine. Additionally, clots from the vaccine, the majority were only around 150 million people have been jeopardize this group and those coun- ical time for the United States in which lowing states to continue distributing it but because single-dose shots like the J&J vac- women, but it is currently unclear as to why vaccinated in the U.S., according to Antony tries that it helps. The pandemic’s contin- Americans that want to be vaccinated have with the warning of rare blood clotting.243 cine play such an integral role in the vac- this is so.246 Although the risk of danger Fauci, director of the U.S. National Institute uation in Africa is especially concerning been vaccinated and the focus has shifted to Many European countries and South Af- cination of developing countries, the pause from the J&J vaccine exists, it is incredibly of Allergy and Infectious Diseases and the because of new variants, minimal access persuading hesitant people to be vaccinated rica followed paths similar to the U.S., will probably be most deeply felt in poorer unlikely that one would develop these clots. chief medical advisor to the president, we to vaccines, and a very slow rollout pro- in order to reach herd immunity. Interna- temporarily halting the vaccine and then countries and result in greater international The rate of a dangerous clotting reaction need another 80 to 130 million individuals cess. While Africa accounts for 17% of the tionally, the pause could increase vaccine implementing a warning with its distribu- vaccine disparities. is sixteen in eight million. This means that vaccinated in order to reach herd immuni- 254 world population, it accounts for only 2% inequalities, harming primarily impover- tion.244 As the United States and other parts As of April 24, of the eight million peo- one is twice as likely to get hit by lightning ty and end the pandemic. The downward of all shots administered globally, while the ished countries the most. At this point, we of the world begin to enter a new phase in ple in the United States vaccinated with the once a year than they are to experience this vaccination trend in the U.S. makes the end United States, accounting for about 4% of must focus on encouraging vaccination and which vaccine supply exceeds demand, the Johnson & Johnson vaccine, about sixteen reaction.247 Why is this risk -- one that is of the pandemic look quite distant. the world’s population, accounts for almost combating misinformation to put the pan- message sent by federal health officials and individuals had developed these blood half as likely to occur as the former-- ap- The J&J vaccine is cheap, easy-to-trans- 30% of shots.256 Another perspective is that demic behind us. HMR other authorities is incredibly important clots.245 The clots have occurred in the proached with so much more caution? It port, and requires only one dose, making it the rejection of the J&J vaccine by rich to minimize vaccine hesitancy. While it is brain and are associated with low platelets, has been extremely difficult to get the pub- ideal for use in developing countries. Pres- ident Biden announced that the U.S. had countries like the U.S. could make devel-

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three months later, India had vaccinated less than 2% of its population of over 1.3 billion, and vaccine centers have stated THE COVID-19 CRISIS IN INDIA they are running out of supply.271 The prime minister’s plan was in shambles as the sec- ond wave of COVID approached, and Indi- Karam Malhotra an citizens were undefended as the vaccine program in India had failed. The original egular travelers to India, who are lifted restrictions brought the arrival of due to the sheer number of COVID cases in plan for distribution had been that the used to the government’s inepti- 3,900 reported cases in just 24 hours.266 Ab- India. government would purchase vaccines and tude, are not surprised by the fact surdly, the government did not respond to The lack of vaccine coverage in India Rthat the task of quelling a pandemic be- distribute them equally among states for this outbreak, leading to citizens’ disregard also contributed to the quick spreading of seniors and healthcare workers, but what came too large to handle. With hospitals of the disease. Epidemiologist Jayaprakash COVID. Times Now News reported that happened was a panicked frenzy to procure quickly overrun with serious COVID-19 Muliyil, an advisor for the Indian govern- during India’s phase of vaccination for as many vaccines as possible. The craze to cases, home became the best place if you ment, said citizens “are willingly going out people in the 18-44 age range beginning procure vaccines from a dwindling supply were seriously ill with COVID. Continuous into the market today and taking fewer on May 1st, many states including Delhi, led to more conflict.272 A better way to have positive airway pressure therapy devices precautions to protect themselves.”267 “Con- West Bengal, Uttarakhand, Odisha, Andhra dealt with the vaccine distribution would (CPAP) required for serious COVID cases sequently, at least in cities, the epidemic is Pradesh, and Punjab stated that they do not have been to create health infrastructure became invaluable as supply diminished growing very rapidly. And we know it is have enough doses to vaccinate individuals throughout India and make people aware and thus oxygen became scarce. Even if spreading in rural areas too. The whole tra- in the age group.269 The amount of vaccines of the issues. Instead, India has become the n. 283 you could afford to pay, the task of finding jectory of the infection is moving upwards required for these large states in India made largest manufacturer and exporter of vac- oxygen became quixotic. So how was India more sharply than in many other countries. it difficult for India to properly distribute cines and the home of the most COVID overrun so quickly? What happened in many Western countries the vaccine despite the Prime Minister’s cases worldwide. India’s use of app-based With a population of over 1.3 billion, and is that when a big city like London was af- original claims that, “Our preparation has technology for its vaccine drive was not “The steps the government a population that is largely unhoused, it is fected, other cities reacted strongly and re- been such that vaccine is fast reaching ev- almost impossible to effectively quarantine effective, as it excluded millions of Indians duced transmission. So, everywhere else, ery corner of the country.” He further states 273 259 from the program. everyone in India. So the size and densi- the doubling time got longer, but in some that India is completely self-reliant and is claimed to have made simply If you are unlucky enough to get a seri- ty of the population are leading causes for Indian cities it is short.”268 The lack of con- actually helping other countries with vac- ous COVID case in India, you might not the speed at which the crisis overwhelmed cern about the virus is troubling especially cines.270 These statements held no water as India. Major cities like Delhi and Mumbai even be able to get the necessary equipment created more problems.” were hit the hardest due to the large num- to survive. The CPAP devices and oxygen ber of people congregating daily.260 In tan- necessary for survival are in short supply lack of transparency from the government enough to vanquish the virus.”279 They have dem with the lack of health infrastructure, in India. China suspended all cargo flights is cause for worry. The steps the govern- actively tried to silence people who speak COVID has become so devastating that to India, which disrupted the private trade ment claimed to have made simply created up about the situation in India, in fact: In- India cannot accurately quantify the death for oxygen and other medical supplies that more problems. dia’s supreme court had to warn the gov- count.261 With a population of over 31 mil- would help patients in India survive. This Most of the issues that I have discussed ernment against silencing people’s pleas lion, and a high infection rate, Delhi has suspension is due to the changes in the are symptomatic of a government that suf- for help by dismissing them as false griev- become a very difficult place to avoid the epidemic situation, according to Sichuan fered from a superior and apathetic atti- ances.280 Modi has exacerbated the situa- 274 virus.262 While at the beginning of the cri- Chuanhang Logistics. This suspension, tude when COVID started, causing India, tion by stating that the state governments sis India boasted one of the lowest COVID while unfortunate, is logical. It is a heavy ironically, to become the country with the were pandering to Muslims by spending rates in the world, a second wave was bound blow that India must take, as a resurgence highest number of cases in the world while more on Muslim graveyards than Hindu to happen due to India’s large population.263 of COVID in China would not help any- being the largest distributor of vaccines. It cremation grounds, further dividing the However, India did not recognize this fact, one. The lack of oxygen in India is partly seems as though the Indian government population.281 Instead of uniting the popu- so when the second wave hit India was ill due to the government taking eight months took few steps towards setting up any lation against COVID the Prime Minister prepared. to invite bids for 162 oxygen generation health infrastructure, while claiming that is pitting the Hindus against the Muslims. Initially, India had a relatively low plants, machines that generate oxygen, and they were best prepared. When COVID The apathy displayed by the Indian gov- infection rate, and Prime Minister Narendra most still weren’t up and running months began to flood India, the Indian govern- ernment during and before the surge of 275 Modi confidently stated that “The country, later. Supriya Sharma and her colleagues, ment waited eight months before creating COVID in India exhibits the ineptitude of which comprises of 18% of the world’s pop- Arunabh Saikia and Vijayta Lalwani, called any oxygen plants.278 Then later, when only the government. While the task of quar- ulation, has saved the world from disaster the hospitals that were supposed to have five were operational, the country was des- antining a country with over 1.3 billion by bringing the situation under control.”264 oxygen plants installed. Of those, only perate for oxygen. When the new variant citizens is certainly very difficult especial- Modi started to relax restrictions on the eleven had been installed, and five were of COVID started spreading from Maha- ly with a large homeless population, the 24th of May 2020, allowing some shops and operational. The lack of these machines in rashtra to its borders and other states, the insufficient effort from the government workplaces to open despite Dr. Randeep hospitals have caused many deaths in India, Indian government decided to focus on an made it clear that the fault of the crisis lies Guleria, the director of the All India Insti- with hospitals running out of oxygen in election victory in West Bengal. When mil- with the government.HMR tute of Medical Sciences, having stated that many major cities, resulting in 14 deaths in lions gathered for Kumbh Mela, a religious 276 he was concerned that there was no down- Anantapur and 12 more in Delhi. How- celebration, the chief minister of the state ward trend in the coronavirus data.265 These n. 282 ever, these cases are just those in hospitals, claimed that “the blessings of mother Gan- and families caring for a serious COVID ga [the most sacred river to Hindus] were patient must fight for oxygen as well.277 The

36 The Horace Mann Review | Vol. XXX June 2021 37 Features Features

pregnant as a result of six assaults by a the next generation of Venezuelans unable necessary, there are still broad sanctions neighborhood predator, and her desperate to create a prosperous and functioning imposed on Venezuela by the United States abortion implicated both her mother and economy and society.290 Students across the that do not directly target corrupt individ- teacher. Her mother took her to a doctor, country have been dropping out of school uals or institutions, but instead dispropor- and when they were told the pregnancy due to economic burdens such as the cost tionately affect the struggling population. endangered her life, her teacher provided of transportation and lack of the previously The sanctions and aid are important to note abortion pills.289 Both women were sub- guaranteed meals at schools.291 Of course, because they directly impact the Venezue- sequently arrested. There are examples of children being out of school exposes them lan population, and they contribute to the many tragedies that clearly evidences why to situations and malicious people such as economic tragedies that have put women in governments cannot abolish abortion; they the predator who took advantage of the vulnerable positions. can only deprive women of safe abortions aforementioned young girl. The respon- Something interesting to consider when and medical care. Abortion has always sibility for the trauma that this young girl examining questions of political and eco- been illegal in Venezuela, but the poverty faced can be traced all the way back up to nomic sanctions is the adverse effect not on induced by the economic decline has exac- the arguably unelected yet persistent leader the corrupt government leaders and indi- erbated the issue in the country and pushed of Venezuela. viduals as intended, but on the vulnerable women towards unsafe and dangerous Nicolás Maduro is incompetent, unpre- and innocent populations who are strug- abortion tactics. This backwards situation pared, and completely unqualified to run a gling under that particular government. is one example that allows us to evaluate government as it should be run. The eco- In the case of Venezuela, the population the precarious and unbalanced Venezue- nomic crisis is certainly his fault, and the that is most affected is women of all ages. lan society right now and the implications humanitarian crisis that has emerged as a Is it worthwhile to punish Nicolás Maduro of this society for women, both young and result mostly falls on his shoulders as well. for his corrupt elections and human rights old, as they struggle to survive during this But the United States and our sanctions abuses if, in reality, it is the impoverished humanitarian crisis. Widening the lens on have exacerbated the issue, and such ac- civilians who are bearing the brunt of the this tragedy shows that it bleeds into oth- tions seem to value economic strategy over economic burdens? This question does not n. 294 er issues, such as the economic decline and human rights. Venezuela was a target of have a concrete answer, but it must be con- what I would call an educational crisis. sanctions under the Trump administration, sidered by the Biden administration as it This young girl was vulnerable because, specifically from U.S. Secretary of State moves forward with foreign policy endeav- having been forced out of school by eco- Mike Pompeo.292 Venezuela was identified ors and cultivates the ever so precarious re- nomic despair, she no longer had the basic with the likes of Iran and Cuba, and strict lationship between morals and internation- The Unfolding Humanitarian Crisis in protection and routine of an educational in- sanctions swiftly impacted its economy. It is al relations. HMR stitution. Education is a human right. Basic important to note that the United States has Venezuela and its Effects on Women protection is a human right. Control over given 1.2 billion dollars in aid to Venezuela one’s body is a human right. This young girl since 2017, excluding COVID-19 supple- has had all three stripped from her in her mentary funding, while denouncing Madu- Alexa Turteltaub first thirteen years of life. ro as an illegitimate president and support- Since Maduro came into power and Ven- ing Juan Guaidó, his political opponent, as here is a governmental and econom- gree, it is safe to say that women are the wrecking Venezuelan citizens and endan- ezuela sunk into economic decline, the ed- the democratically elected president.293 ic crisis unfolding in Venezuela, in- most hard-hit victims, particularly those gering the lives of women and children. ucational crisis that has emerged will leave While this aid is moral and absolutely ducing poverty, hunger, lawlessness, of a lower socioeconomic status who are The pandemic is adding yet another lay- Texploitation, and humanitarian violations. without protection, both sexually and lit- er of distress, both economic and medical, Venezuelan President Nicolás Maduro has erally. Venezuelan women have little to no to Venezuela and to Venezuelan women not only neglected his duties, but his reck- access to birth control and contraceptives. in particular. The Venezuelan government “This backwards sit- less, corrupt and harmful policies and ac- reported that around reported that COVID-19 cases have in- uation is one ex- tions have meant that an estimated 94 per- Caracas, Venezuela’s capital, a pack of three creased 86 percent since January 2021, and ample that allows cent of Venezuelans live below the poverty condoms costs $4.40 — almost three times this statistic likely underrepresents the facts line, with millions lacking access to food, Venezuela’s monthly minimum wage of due to the secretive nature of Maduro’s au- us to evaluate the water or medical supplies.284 Let that statis- $1.50, with birth control pills costing twice thoritarian government.287 precarious and un- tic sink in, because that is more than twen- as much. The rising prices are likely due to General instability and lawlessness also ty-five million people.285 the scarcity of contraceptives, whose stock have resulted in a catastrophic rise in sex- balanced Venezuelan Nicolás Maduro claimed to be a feminist, has decreased by 90 percent since 2015.286 ual violence against women in Venezuela society right now and his political success was boosted in part Abortion is illegal in Venezuela, amd these where a severe lack of consequences em- and the implications by the hope that he brought to Venezuelan outrageously high prices along with the boldens offenders. A heartbreaking and women. Not only is Nicolás Maduro not a economic crisis, plummeting wages and deeply upsetting story serves as an exam- of this society for feminist, but both his direct actions and the loss of jobs essentially means that women ple of how many challenges Venezuelan women, both young indirect consequences of his actions have have no choice but to continue bearing chil- women face impact not only their lives, her crippled the lives and livelihoods of wom- dren whom they cannot feed. This issue not family and friends around them. In April of and old, as they en. only compounds the impact of Venezuela’s 2021, a teacher and a mother were thrown struggle to survive While the humanitarian crisis has af- crisis on women, but is also an active factor in jail while a child rapist walked free.288 A during this humani- fected all Venezuelan citizens to some de- in the cycle of poverty and despair that is thirteen-year-old Venezuelan girl became n. 295 tarian crisis.”

38 The Horace Mann Review | Vol. XXX June 2021 39 Features Features

ing “a number of emergency measures to relieve the burden on states and hospi- t a l s .” 301 By this point, however, most of “the damage was done.” Modi not only failed to “The light at the end of the COMPARING GOVERNMENTAL RESPONSES prepare for a second wave but also “encour- aged mass gatherings at Hindu festivals and pandemic’s tunnel is getting political rallies.”302 Modi also used the pan- TO COVID-19 IN INDIA AND AUSTRALIA demic as a PR move, putting stamps of his face on vaccine cards and tying his prime closer and closer. However, Owen Heidings minister title to the country’s COVID-19 relief fund.303 By relating his name with many countries are “jumping these positive measures, Modi tried to con- vince the country that he was doing a good job, hiding his negligence. the gun” in easing COVID-19 OVID-19, the deadly virus with little to no safety protocols whatso- the pandemic; by mid-April, the country In Australia, the reaction to COVID has sweeping the country, is not as ever. By mid-March, India’s cricket board was averaging more than 100,000 cases per been a completely different story. As of May restrictions.” frightening anymore. There is a let 130,000 fans, a majority of whom were day.300 8, 2021, Australia has reported just nine vaccine,C but getting the COVID-19 vac- unmasked, watch two international crick- India’s increase in overall cases was wors- new cases. “When Covid-19 first became a cine isn’t as easy as it looks. In fact, multiple et games between India and England in ened by the government’s slow response. real threat to Australia in March last year, obstacles are obstructing Black Americans person. Weeks later, India found itself in Prime Minister Narendra Modi stayed si- the Federal government responded quickly n. 309 from getting the vaccine, including system- the midst of a disastrous second wave of lent on the situation until April 20, launch- closing international borders and imple- ic racism, access barriers, and medical mis- menting a mandatory home isolation pro- trust. medical system. gram for returning Australian citizens. Po- Since March of 2020, the COVID-19 lice were dispatched to homes to check that pandemic has ravaged the globe, killing a returned travelers were adhering to quar- reported 3.14 million people, with thou- antine requirements and when breaches sands more deaths occurring daily. Cur- were discovered, Australia quickly moved rently, India is experiencing the largest to a mandatory hotel quarantine system wave of COVID-19 yet, with a reported in which hotel rooms were often guarded daily increase of 276,110 cases as of May by police or military.”.304 Because of these 19, 2021.296 India is being hit harder by the preventative measures, Australia stopped virus for many reasons, including a lack of the rapid spread of the virus early, mean- adherence to safety protocols and poor gov- ing that their healthcare systems were not ernment management. On the other hand, overwhelmed. countries like Australia have found ways to The ability of Australia’s government to mitigate the impact of the virus, by impos- work quickly and effectively contributed to ing strict lockdowns and travel restrictions their successful mitigation of the spread of to keep the number of infections low. COVID. Although the country’s two main At the beginning of March 2021, report- political parties have their differences, ed COVID cases in India began to rise rap- when COVID struck they put aside their idly. By the end of the month, the number disputes and arguments to focus on keeping of daily cases was six times higher than it the country safe. “Early in the pandemic, 297 had been at the start of it. This increase the federal government introduced a $130 quired most businesses to shut down. Po- and closer. However, many countries are was not unprecedented; the country had billion economic bailout which included a lice checkpoints were imposed on highways “jumping the gun” in easing COVID-19 experienced a wave of COVID cases in six-month wage subsidy scheme.”305 Aus- to ensure residents were not more than 25 restrictions, and it will be important to see September 2020, but at that time, India was tralia’s Parliament passed the legislation kilometers from their homes, and offenders how nations might handle a potential sec- prepared. Cases declined steadily in the in a single day, giving citizens immediate faced a fine of up to $1,300.306 Australia is ond or even third wave. If managed poor- months following, and Minister of Health relief. This legislation was extremely im- an island, which allows the nation to have ly, we might see more countries fall victim Harsh Vardhan declared that the country portant for two reasons. First, it relieved near-complete control of who can enter and to similar catastrophes as the one in India. 298 was “in the endgame” of the pandemic. economic stress caused by lockdowns, giv- exit the country. Only those traveling from If countries mandate vaccinations and re- Subsequently, COVID-19 restrictions be- ing residents an early stimulus to survive New Zealand, Australian citizens, perma- strict travel, they might have outcomes sim- came lax. Social distancing plummeted, off of, ultimately leading to less disparity. nent residents, and immediate family of ilar to Australia, with few cases present at and mask-wearing was at an all time low. It also meant that Australians, not having residents can enter, and an arrival cap of all. HMR At the end of February 2021, state elections to go to work, could comply with lockdown 6,362 people has been set as of March 10, were announced; 186 million people would restrictions more willingly. When Australia 2021.307 be eligible to vote for 824 governmental suffered from a second wave of COVID-19 As more time passes, the light at the end 299 seats. Campaigning began immediately, n. 308 in the summer of 2020, authorities re- of the pandemic’s tunnel is getting closer

40 The Horace Mann Review | Vol. XXX June 2021 41 Economics Economics

Nixon moved the US off the gold standard However, if you believe that the federal gov- tributes to Bitcoin’s durability over time. in 1971, the federal government has been ernment might print more money to pay off Bitcoin provides a much-needed alterna- able to print as much currency as it wants. debt or to allow itself to spend more mon- tive to government-issued currency. Before Each year, the US government prints some ey, then you might invest in Bitcoin. On the Bitcoin and cryptocurrency, if you didn’t amount of money. This is a main cause of whole, Bitcoin seems like a sustainable busi- trust the government controlling a curren- inflation, and why a small amount of mon- ness model: in the US, the amount of peo- cy, the only option was to exchange for a ey was worth much more decades ago. As ple who trust the federal government has different government-issued currency. The the national debt cruises towards $29 tril- been continuously declining since 2001.315 issue is that all government-issued curren- lion, it seems increasingly likely that the Another benefit of Bitcoin is lack of com- cies have similar problems, mainly the risk US will eventually have to massively inflate petition. Many new cryptocurrencies have of inflation. However, Bitcoin allows a con- the currency to escape the debt. This in- been launched since 2008, including Ethe- sumer to hedge against government bureau- flation would deeply hurt Americans who reum and Dogecoin. Recently, has cracy and massive inflation. As Bitcoin only have money in the form of the US dollar. backed , a cryptocurrency controlled has to compete against government-issued Bitcoin attempts to solve those issues with by the non-profit Diem Association. In most currency, and trust in government contin- fiat currencies. It is a decentralized curren- industries, competition would drastically ues to decline, the currency’s value will, cy, meaning that the Bitcoin blockchain is harm a company. However, in the cryptocur- in the long-term, strictly increase. HMR not controlled by any one person or insti- rency space, one can support multiple cryp- tution. This is the primary advantage to Bit- tocurrencies by accepting them as payment, coin: no single entity controls the amount for example, in the same way that one can iaphs.org of currency in circulation in the same way support the euro and the dollar by accepting that the federal government controls the either as payment. The fact that cryptocur- dollar or the European Central Bank con- rency is not a zero-sum industry, meaning trols the euro. The value of Bitcoin is deter- that gain for one cryptocurrency does not n. 316 mined mainly by how much people believe necessarily mean loss for another, only con- it is worth. In other words, the value of Bitcoin is determined by the demand for it. By inflating and deflating the currency, governments forcibly shift supply and de- mand curves, creating a top-down system BENEFITS OF in which powerful institutions control the value of the currency. On the other hand, theguardian.com no one controls the supply of Bitcoin; we INVESTING IN BITCOIN know exactly how many Bitcoin will be in circulation at any given point in the future. Hence, Bitcoin’s price is determined only by demand, creating a bottom-up system Jacob Silverstein in which consumers determine the value of the currency. Of course, this demand-based n 2008, an Internet user silver, or another commodity.312 However, of paper is worth almost nothing, yet you currency valuation has drawbacks: if peo- called Satoshi Nakamoto published a regardless of whether or not a currency is can enter a Walmart with an $100 bill and ple fall out of love with Bitcoin, or invest in paper titled “Bitcoin: A Peer-to-Peer a fiat currency, it relies on the same prin- buy almost anything. Why is that bill worth a different cryptocurrency, demand would IElectronic Cash System,” proposing the ciple. Consider a simple example in which more than any regular piece of paper? Be- fall, causing a drop in price. On the other creation of a digital currency. In the be- one farmer grows corn and the other cot- cause a large enough group of people be- hand, if Bitcoin becomes a more common ginning of 2009, Bitcoin hit the web.310 ton. If the corn farmer wants cotton, but the lieve that the $100 bill is worth a certain form of payment, the price will rise as de- The way that Bitcoin worked was fairly cotton farmer doesn’t want corn, the cotton amount and can be traded for a commodity. mand grows. For example, when Elon simple: Bitcoin miners verified transac- farmer can trade cotton in exchange for a However, governments often try to con- Musk announced that Tesla would begin tions by using computers to solve com- promise from the corn farmer to give the trol the value of their currency by manually to accept Bitcoin as payment for cars, and would not convert that Bitcoin to a fiat plex cryptography problems, and were cotton farmer a certain amount of goods inflating or deflating it (by printing more or 314 rewarded for their efforts in Bitcoin. later. This promise is called an IOU. Then, buying it back).313 Although controlling the currency, the price of Bitcoin rose 5.1%. When a transaction was verified, it was if the corn farmer trades corn for apples, value of currency is beneficial in some ways, In essence, the most likely reason you stored on a blockchain, an online data- and the cotton farmer wants apples, the like promoting international trade and in- would invest in Bitcoin is that you don’t base that stores large amounts of data.311 cotton farmer can cash in that IOU and re- vestment through fixed exchange rates, giv- trust the federal government. If someone To understand the fundamental differ- ceive some apples. Now, imagine that IOU ing the government such power is not al- did trust the federal government, they ence between Bitcoin and the dollar, for comes in the form of gold. If both the corn ways good. For example, governments have would keep money in the dollar. Alterna- example, it is important to understand and cotton farmers believe gold is valuable, the power to devalue their own currency. tively, they would invest money in govern- how currency works. The dollar, like most and are willing to trade their crops for it, it Under the gold standard, countries were ment bonds, essentially arguing that the n. 317 modern paper currencies, is a fiat cur- serves as an IOU. Basically, currency works restricted in how much money they could bond yields, annual interest payments paid rency, meaning it is not backed by gold, as a placeholder for a commodity. A piece print by the amount of gold they had. Since to a bond owner, will outpace inflation.

42 The Horace Mann Review | Vol. XXX June 2021 43 Economics Economics mandating a higher wage, the government job reservation left in the building industry, purchasing power of consumers. A study in effect prevents these workers from rising and in the circumstances I support the rate on McDonald’s by the National Bureau up the wage ladder, or even entirely inhibits [minimum wage] for the job as the second of Economic Research found a “full or them from getting jobs and entering the best way of protecting our white artisans.”329 near-full price pass-through of minimum- workforce. This is not to say that advocates of a wage-induced higher costs of labor.”332 This As Congress pushes for a $15 minimum higher minimum wage are eugenicists means that the near entirety of the gains wage, it should be aware of the policy’s or social Darwinists by any stretch of the in workers’ purchasing power through the potential risks. The Congressional Budget imagination, but the laws of supply and minimum wage hike were offset by higher Office estimated in February of 2021 that demand have not been overturned over the prices. In effect, it would be a regressive a minimum wage would permanently course of the 20th century. Raising the price tax on consumers, as lower wage workers’ eliminate approximately 1.3 to 1.7 million of a good or service above the equilibrium expenditures are proportionally more on “The minimum wage also heightens existing disparities between small and big businesses. Small businesses are simply unable to pay as high wages as big businesses are, as they lack the billions in funding and resources that big corporations and publicly traded companies possess. Thus they would be crushed by any increase in

n. 335 the minimum wage.” jobs. Additionally, Congress should set by the market inevitably results in less necessities such as food than higher wage consider the disastrous effects of a recent $13 of that good or service being purchased, no workers. minimum wage hike in Seattle.323 When the matter the intentions of the policy makers. Ultimately, the minimum wage is a bad Seattle City Council passed a $13 minimum The minimum wage also has disparate policy because it targets employment, The $15 Minimum Wage: the total number of hours worked by low effects across the country. States with rather than poverty. If raising the minimum wage earners in the city fell by 3.5 million lower standard of living costs, typically the wage were truly a solution to poverty, what per quarter.324 On average, these low wage poorest states in the US, will face higher is stopping current developing countries earners lost $120 per month.325 Moreover, unemployment as a result of high minimum from doing so and immediately alleviating Help or Hindrance? since the passage of its $13 minimum wage wage laws. A study done by the Bureau economic hardship and disparity? In 2015, in April of 2015, Seattle has seen the greatest of Economic Analysis found that a $15 the Census Bureau found that out of the decrease in the size of its labor force over minimum wage would be the equivalent people considered in poverty in the United Will Bramwell a three month period in its history, even of over $20 in states such as South Dakota, States, 11% worked full time, while 63% greater than during the Great Depression or Alabama, and Mississippi, but in rich states did not have jobs at all. Meanwhile, only he fight for a $15 minimum a wage. As a result, the first jobs to be lost this reality when he was forced to cut the the Great Recession of 2009.326 like New York and California, it would be 2% of all full time workers were considered wage has recently become an would be those held by workers with the hours of his employees in his presidential Some progressive economists claim barely over $15.330 The result would be in poverty.333 The solution to alleviating important and controversial lowest wages, as they are not productive campaign as funds dried up.319 that a $15 minimum wage would not that in comparison to richer states, the poverty and helping the needy is therefore topicT in political discourse. Though it was enough to employers to be paid what the The minimum wage would also prevent increase unemployment. However, the poorer ones would become even more poor to make job opportunities less scarce, rather eventually dropped in the Senate, President new minimum wage mandates. These less privileged and educated workers from first minimum wage proposals intended through increased unemployment. A one than making them even more difficult to Biden attempted to include a $15 minimum workers thus find themselves structurally increasing their productivity. Though in to do exactly that. Some social scientists size fits all policy makes no sense in such an find through a higher minimum wage. wage provision in his $1.9 trillion stimulus unemployable. As economist and political the very short term they are not paid too and economists around the turn of the economically and socially diverse country. A much better government policy would bill. The policy is touted and has been commentator Thomas Sowell oncewell, they can in the near future increase nineteenth century were growing sick with The minimum wage also heightens be to streamline welfare services into pushed by several progressive politicians, keenly observed, “Unfortunately, the real their wage by learning the skills of the job the free market’s ability to raise the wages existing disparities between small and big cash transfers (a universal basic income including the most prominent members of minimum wage is always zero, regardless and therefore justify a higher wage. This and living standards of everyone, regardless businesses. Small businesses are simply or negative income tax for example), the Progressive movement Senator Bernie of the laws, and that is the wage that many income mobility is seen in the fact that of race, color, creed, or previous disposition. unable to pay as high wages as big businesses eliminating the perverse unemployment Sanders of Vermont and Congresswoman workers receive in the wake of the creation more than two thirds of minimum wage Many notable and mainstream economists are, as they lack the billions in funding and incentives the current system encourages. Alexandria Ocasio-Cortez of New York. or escalation of a government-mandated workers earn higher wages within a year of the area recognised that instituting a resources that big corporations and publicly A high minimum wage sounds like it However, the minimum wage is in fact a minimum wage.”318 of employment.320 In addition, minimum minimum wage would be akin to preventing traded companies possess. Thus they would would protect low wage workers from the very regressive measure, as it heightens Furthermore, what will not be lost wage induced unemployment creates a the “inferiors” from getting jobs and rising be crushed by any increase in the minimum vicious greed of their employers. However, previous economic disparities. in employment will instead be lost in drag on productivity growth, and has been through the market. As British socialist wage. In fact, Amazon is lobbying for the as Milton Friedman once quipped, “One The minimum wage is a regressive total earnings or benefits like pension or linked to lower income mobility and lower Sydney Webb wrote, “Of all ways of dealing $15 minimum wage.331 They are not doing of the great mistakes is to judge policies by measure for two primary reasons. First, it healthcare plans. Often, instead of laying wages in the long run (i.e. over the course of with these unfortunate parasites, the most this out of some noble commitment to their intentions rather than their results.”334 heightens the gap between workers with off workers, a business will instead cut their a career) for workers earning the minimum ruinous to the community is to allow the common worker, but because it would In the end, the results of this policy would high and low productivity, ultimately hours. Thus, while many workers hold onto wage.321 By raising the minimum wage, one them to unrestrainedly compete as wage bankrupt their small business competitors be that those less productive, less privileged, hurting those who are less educated and their jobs and their wage rate increases, merely inhibits a process by which young earners.”327 A more recent example of racist who do not have the hundreds of billions and less educated workers are hurt most, of lower socioeconomic status. Required their real earnings fall. Bernie Sanders, workers get better jobs and higher pay in the minimum wage laws can be found in the of dollars in resources that Amazon does. while big corporations reap the benefits to follow a higher minimum wage, an ardent supporter of the $15 minimum future. A fact often ignored by progressive South African apartheid state.328 The head of Having cornered the market, Amazon of the minimum wage over their small employers are forced to keep only those wage who had boasted of having unionized policy makers is that the median age of the South African Builders’ Union in 1987 would be able to charge high monopoly business competition. HMR employees whose work would justify such workers on his campaign trail, learned of the minimum wage worker is 24.322 By released a statement declaring, “There is no prices on goods, thereby lowering the

44 The Horace Mann Review | Vol. XXX June 2021 45 Science and Technology Science and Technology

are common with the second dose. Other times, the specific brand of vaccine, Mod- erna or Pfizer, is unavailable at the location of the second dose or the appointment it- The science shows that both Millions of Americans self gets canceled. As such, it is clear that there are many logistical factors that influ- ence a person’s ability to receive the second doses of the vaccine are Missing Second dose.338 To ensure that the United States’ population is protected from COVID-19, addressing each of these causes will aid in what protects an individual. reducing the number of people missing Vaccine Doses their second dose. According to the Kaiser Family Founda- RIA CHOWDHRY tion (KFF) COVID-19 Vaccine Monitor, the right brand in stock were forced to no- supplies. If a certain pharmacy online has from 3.4% in February, the CDC said that a research project that gauges American “ tify recipients that they would be unable Moderna, then the provider themselves this gap was to be expected as the eligibility adults’ response to the vaccines, in Decem- to receive their next dose. Many of these should not book an appointment for some- requirements eased and access increased.343 ber 2020, roughly 13-15% of the Ameri- individuals then scrambled to find a new one who requires Pfizer. The millions of Currently, many authorities are working can population “definitely would not” get location at which they could receive their Americans missing vaccines demonstrates on ways to increase access and improve vaccinated and 9% would receive vaccina- vaccine, but those locations did not have that our vaccine providers need to take logistics when distributing and providing tions only if it became mandated. In April the right brand or were in limited stock ei- more responsibility and initiative, espe- vaccines, specifically encouraging vaccine 2020, the number of those who “definitely ther. Walgreens, currently one of the big- cially since these providers signed up to providers to carefully look at which brands would not” get vaccinated has remained ” gest vaccine providers in the United States, provide millions of Americans with both of are being provided at those locations. En- constant while the percentage of those get- has been under scrutiny as their pharma- their COVID-19 vaccine doses. suring responsibility during this time is ting vaccinations if mandated dropped to cies often don’t have enough supply and All in all, despite millions missing their especially critical, and as the United States 6%.339 Many more Americans fall into the vaccine brands on hand. In , any- second dose, the overall percentage of in- passes the one-third mark, there is much “waiting and seeing” category, indicating where from 10 to 20 people have been sent dividuals following through with the vacci- hope for a future of an almost entirely vac- that a portion of the United States clearly back because the pharmacies only stocked nation process sits at 92%, a record high by cinated population and a return to more IMAGE GOES HERE remains hesitant in receiving the first dose the Moderna vaccine, and they needed a historical standards. Compared to shingles, normal circumstances.HMR of vaccine. With symptoms such as a fever second shot of Pfizer.341 Especially since so against which only 75% of adults were fully and chills, the worry of getting sick after many are receiving COVID vaccine doses vaccinated, the number of individuals com- the second dose has deterred individuals through pharmacies like Walgreens, phar- pleting their vaccination has been much from taking their next dose. Almost all macies need to be more organized when stronger.342 While the percentage of people vaccines have various side effects, some figuring out appointment schedules and missing second doses more than doubled more painful than others. The common side effects after the second dose, chills and high fever, are side effects of almost every other vaccine that adults and children are required to receive.340 Despite this infor- mation, many are still worried that these n. 344 side effects are worse than others. To add to this problem, the misconcep- fter almost six months since the Central for Disease Control and Prevention tion that one is protected after the first dose first American, Sandra Lind- (CDC), more than five million individuals adds to the number of people who think it say, received her first dose of - nearly 8% of Americans - received their is acceptable to miss their second appoint- theA COVID-19 vaccine, over 263 million first shot of the Moderna or Pfizer vaccines ment. A single shot of the vaccine triggers Americans have received their first dose. and missed their second dose.337 a weaker immune response. Even though Of those who have received first doses, 116 While there is a portion of the country the first dose does provide protection, it million are completely vaccinated, over a that is wary of even receiving the first dos- still remains unclear as to how long the third of the United States’ population.336 age, another problem that health authori- protection will last. The science shows that Americans can choose between Moderna ties are facing is the growing number of both doses of the vaccine are what protects and Pfizer, both of which require two doses Americans missing the second dosage. Lo- an individual. Fearing side effects, most of in order to be considered completely vacci- cal authorities and the CDC are working on which are common for all vaccines, and nated, as well as Johnson & Johnson, which making sure that those who do get inocu- believing that one dose is enough is one only requires one dose. Moderna and Pfiz- lated once are completely vaccinated. How- aspect of the problem that the CDC and er vaccines have an 95% efficacy rate, while ever, in order to do so, they must identify health authorities must counter. Johnson & Johnson has a 72% overall effi- the root causes of vaccine hesitancy. Over A more common reason for missing cacy. However, the two-dose vaccines only the past few months, multiple reasons have second doses has been scheduling conflicts have a 95% efficacy rate with both doses. reduced vaccinations. Sometimes individu- and errors on the part of vaccine distribu-

With only the first shot, the vaccines are als believe that they are protected with one tors and providers. Many vaccination sites n. 345 not deemed as effective. According to the dose or are scared of the side effects that who ran out of supplies or did not have 46 The Horace Mann Review | Vol. XXX June 2021 47 rors In The Chauvin Trial, MPR News, April 20, 2021, pars. 1, they show his limits,” AP News, April 9th, 2021, par 5. 81 Rume, “Environmental effects,” NCBI. 2. https://www.npr.org/sections/trial-over-killing-of-george- https://apnews.com/article/joe-biden-violence-merrick-gar- 82 Rume, “Environmental effects,” NCBI. Endnotes floyd/2021/04/20/989149400/what-we-know-about-the-jurors-in- land-gun-politics-gun-violence-7ddb30681ca3abbf1a0faa286e3df7b2 83 https://pixabay.com/photos/corona-world-mask-virus-dis- 1 Diariocritico de Venezuela, https://www.flickr.com/photos/ the-chauvin-trial 56 Jaffe, par 7-9. ease-4912807/ diariocriticove/12504304594; https://creativecommons.org/licenses/ 25 Wright, “13 Key Moments,” pars. 9, 13, 24, 25. 57 Oma Seddiq, “Republicans criticize Biden’s gun safety 84 https://theowp.org/reports/climate-change-in-the-21st-cen- by/2.0/ 26 West, “What We Know,” par. 18. executive actions as an ‘infringement’ of Second Amendment rights,” tury-mitigating-greenhouse-gasses/ 2 Dan Merica and Liz Stark, Census Bureau announces 331 27 Levenson and Cooper, “Found guilty of all three charges” Business Insider, April 8th, 2021, 2-3. 85 Knight Institute v. Trump,” Knight First Amendment Insti- million people in US, Texas will add two congressional seats, CNN, par. 12. https://www.businessinsider.com/republicans-criti- tute at Columbia University, accessed May 13, 2021, https://knightco- April 26, 2021, https://www.cnn.com/2021/04/26/politics/us-census- 28 Emily Shapiro, George Floyd’s family reacts to Derek cize-bidens-gun-actions-as-unconstitutional-2021-4 lumbia.org/cases/knight-institute-v-trump. 2020-results/index.html. Chauvin guilty verdict: ‘Today, we’re able to breathe again’, ABC, 58 Seddiq, par 4-5, 8-9. 86 “Knight Institute,” Knight First Amendment Institute at 3 David Wasserman, 2020 Census: What the Reapportion- April 20, 2021, par. 1. https://abcnews.go.com/US/hes-histo- 59 Randall Balmer, “Where are the ‘originalists’ in the debate Columbia University ment Numbers Mean, The Cook Political Report, April 26, 2021, ry-george-floyds-family-reacts-derek-chauvin/story?id=77195061 over gun safety?” Des Moines Register, Feb. 21st, 2018, par 1-3. 87 “Knight Institute,” Knight First Amendment Institute at https://cookpolitical.com/analysis/house/redistricting/2020-cen- Levenson and Cooper, “Found guilty of all three charges,” par. 12. https://www.desmoinesregister.com/story/opinion/columnists/ Columbia University sus-what-reapportionment-numbers-mean 29 Lorie Shaull, March 2021, https://commons.wikimedia.org/ iowa-view/2018/02/22/conservatives-originalists-gun-control-sec- 88 “Knight Institute,” Knight First Amendment Institute at 4 Mike Schnieder, Winners and losers from first release of wiki/File:A_person_holds_a_Rest_In_Power_sign_outside_the_Hen- ond-amendment/356436002/ Columbia University 2020 census data, AP, April 26, 2021, https://apnews.com/article/ nepin_County_Courthouse_in_downtown_Minneapolis,_Minne- 60 Seddiq, par 11. 89 “Knight Institute,” Knight First Amendment Institute at electoral-college-census-2020-government-and-politics-poli- sota_as_the_trial_of_former_Minneapolis_police_officer_Derek_ 61 Balmer, par 9-10. Columbia University tics-86e1a31aeeea02004a3c71abd58097ee Chauvin_began_Monday_morning._(51017270611).jpg 62 https://pxhere.com/en/photo/650695 90 “Knight Institute,” Knight First Amendment Institute at 5 Mike Schnieder, Winners and losers from first release of 30 Wise, “‘A Moment Of Significant Change,” pars. 3, 7. 63 Sports Illustrated, The Highest Court in the Land, https:// Columbia University 2020 census data, AP, April 26, 2021, https://apnews.com/article/ 31 Shapiro, “George Floyd’s Family Reacts,” pars. 14, 15. www.si.com/nba/2018/07/25/supreme-court-building-basket- 91 Knight First Amendment Institute at Columbia University electoral-college-census-2020-government-and-politics-poli- 32 Wise, “‘A Moment Of Significant Change,” par. 10. ball-court v. Donald J. Trump, No. 18-1691 (2d Cir. ). Brief of Amici Curiae tics-86e1a31aeeea02004a3c71abd58097ee 33 Alana Wise, Biden Says Chauvin Guilty Verdict Can 64 AthleticScholarships, Accepting Payment From Agents in Support of Plaintiff-Appellees. https://knightcolumbia.org/docu- 6 Adam Liptak, Prominent Republicans Urge Supreme Court Be ‘A Moment Of Significant Change’, NPR, April 20, 2021, par. Results in Loss of NCAA Eligibility, ments/a4a507b3fb. to End Gerrymandering, New York Times, September 6, 2017, 9. https://www.npr.org/sections/trial-over-killing-of-george- https://www.athleticscholarships.net/ncaa-loss-eligibility-pay- 92 Knight First Amendment Institute at Columbia University https://www.nytimes.com/2017/09/06/us/politics/prominent-republi- floyd/2021/04/20/989095728/watch-live-biden-to-respond-to-chau- ment-agent.htm v. Donald J. Trump, No. 18-1691 (2d Cir. ). Brief of Amici Curiae cans-urge-supreme-court-to-end-gerrymandering.html vin-guilty-verdict 65 Next College Student Athlete, NCAA Name, Image, and in Support of Plaintiff-Appellees. https://knightcolumbia.org/docu- 7 State-by State redistricting procedures, Ballotpedia, https:// 34 Shapiro, “George Floyd’s Family Reacts,” pars. 14, 15. Likeness Rule, ments/a4a507b3fb. ballotpedia.org/State-by-state_redistricting_procedures 35 Shapiro, “George Floyd’s Family Reacts,” par. 9. https://www.ncsasports.org/name-image-likeness 93 Knight First Amendment Institute at Columbia University 8 David Wasserman, The 32 House Incumbents in the 36 Wise, “‘A Moment Of Significant Change,” par. 10. 66 Ibid. v. Donald J. Trump, No. 18-1691 (2d Cir. ). Brief of Amici Curiae most redistricting danger, the Cook Political Report, April 27, 2021, 37 Wise, “‘A Moment Of Significant Change,” pars. 3, 7. 67 Investopedia.com, How Much Does the NCAA Make off in Support of Plaintiff-Appellees. https://knightcolumbia.org/docu- https://cookpolitical.com/analysis/house/redistricting/32-house-in- 38 The Four Parts of Accountability: How To Give A Genu- March Madness? ments/a4a507b3fb. cumbents-most-redistricting-danger ine Apology Part 1, WordPress, December 18, 2019, par. 29. https:// https://www.investopedia.com/articles/investing/031516/how-much- 94 Knight First Amendment Institute at Columbia University 9 https://commons.wikimedia.org/wiki/File:2020_US_Cen- leavingevidence.wordpress.com does-ncaa-make-march-madness.asp v. Donald J. Trump, No. 18-1691 (2d Cir. ). Brief of Amici Curiae sus_Yard_Sign.jpg 39 Wise, “‘A Moment Of Significant Change,” par. 10. 68 Ibid; see also NCAA, Consolidated Financial Statement, in Support of Plaintiff-Appellees. https://knightcolumbia.org/docu- 10 Melanie Grayce West, The Derek Chauvin Verdict: What 40 Wise, “‘A Moment Of Significant Change,” pars. 3, 7. 2021 ments/a4a507b3fb. We Know, CNN, April 21, 2021, par. 1. https://www.wsj.com/arti- 41 Collins, “George Floyd Justice in Policing Act,” par. 6. 69 ESPN, Shawne Alston Suing NCAA, Others, 95 Knight First Amendment Institute at Columbia University cles/the-derek-chauvin-verdict-what-we-know-11618956250; Eric 42 Collins, “George Floyd Justice in Policing Act,” par. 6. https://www.espn.com/college-football/story/_/id/10558893/ v. Donald J. Trump, No. 18-1691 (2d Cir. ). Brief of Amici Curiae Levenson and Aaron Cooper, Derek Chauvin found guilty of all three 43 Collins, “George Floyd Justice in Policing Act,” pars. 6, 27. ncaa-conferences-sued-scholarship-value] in Support of Plaintiff-Appellees. https://knightcolumbia.org/docu- charges for killing George Floyd, CNN, April 21, 2021, par. 7. https:// 44 Collins, “George Floyd Justice in Policing Act,” pars. 6, 27. 70 15 U.S.C. §1 ments/a4a507b3fb. www..com/2021/04/20/us/derek-chauvin-trial-george-floyd-de- 45 Collins, “George Floyd Justice in Policing Act,” par. 6. 71 375 F. Supp. 3d 1058 (N. D. Cal. 2019) 96 Knight First Amendment Institute at Columbia University liberations/index.html 46 Tony Webster, https://www.flickr.com/photos/di- 72 958 F. 3d 1239 (9th Cir. 2020) v. Donald J. Trump, No. 18-1691 (2d Cir. ). Brief of Amici Curiae 11 Cooper, “Found guilty of all three charges,” par. 7. versey/51130053644; https://creativecommons.org/licenses/by-nc- 73 Heritage Reporting Corporation, Transcript of Oral Argu- in Support of Plaintiff-Appellees. https://knightcolumbia.org/docu- 12 Watch as judge reads out verdict in Chauvin trial, CNN, nd/2.0/ ment in No. 20-512, pp. 17, 32 ments/a4a507b3fb. https://www.cnn.com/videos/us/2021/04/20/jury-verdict-derek- 47 https://commons.wikimedia.org/wiki/File:Fist_.svg 74 Steve Cheng, https://www.flickr.com/photos/126753091@ 97 U.S. Const. amend. 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47 The Horace Mann Review | Vol. XXX June 2021 48 Vaccinations in the First 100 Days. It Won’t Be Easy.” Kaiser Health bill into uncharted territory, The Washington Post, 2021, April 22, 156 Tim Tankersley, “Biden Details $2 Trillion Plan to Rebuild 189 https://commons.wikimedia.org/wiki/File:Vladimir_Pu- News, January 20, 2021. https://www.washingtonpost.com/local/dc-politics/dc-statehood- Infrastructure and Reshape the Economy,” The New York Times, tin_(2017-01-17).jpg 107 Daniela Santamarina, Matt Viser. “At the 100-Day Mark, house-vote/2021/04/22/935a1ece-a1fa-11eb-a7ee-949c574a09ac_sto- March 31, 2021], accessed April 19, 2021, https://www.nytimes. Has Biden Kept His Campaign Promises?” ry.html com/2021/03/31/business/economy/biden-infrastructure-plan.html. 190 https://pixabay.com/photos/the-flagpole-russia-state- 108 “Operation Warp Speed: Implications for Global Vaccine 133 DC Statehood, Why statehood for DC. 157 https://www.history.com/news/new-deal-infrastruc- flag-2877540/ Security.” The Lancet Global Health. 134 DC Statehood, Why statehood for DC. ture-projects-fdr 191 The People’s Republic of China, Food and Agriculture Orga- 109 “DOD Identifies More Troops to Help Administer 135 Breuninger, K. Biden administration backs D.C. statehood, 158 Tankersley, “Biden Details,” nization of the United Nations, par. 10 COVID-19 Vaccine.” U.S. DEPARTMENT OF DEFENSE. urges swift action as house prepares to vote on bill. CNBC, 2021, 159 https://thehill.com/homenews/sunday-talk-shows/552503- http://www.fao.org/fishery/facp/chn/en 110 Daniela Santamarina, Matt Viser. “At the 100-Day Mark, April 20, https://www.cnbc.com/2021/04/20/biden-administration- senate-republicans-have-proposed-a-counter-600-billion-plan 192 World Food Programme, World Food Programme, par. 2, Has Biden Kept His Campaign Promises?” backs-dc-statehood-urges-swift-action-as-house-prepares-to-vote- 160 Tankersley, “Biden Details,” https://www.wfp.org/countries/china#:~:text=Almost%20150.8%20 111 Daniela Santamarina, Matt Viser. “At the 100-Day Mark, on-bill.html 161 Jordan Williams, “McCarthy slams Biden infrastructure million%20people%20are,significant%20national%20and%20glob- Has Biden Kept His Campaign Promises?” 136 DC Statehood, Why statehood for DC plan for misplaced priorities,” The Hill, May 9th, 2021 https://thehill. al%20burdens; Ian Urbina, How China’s Expanding Fishing Fleet 112 Rep. Scott Franklin (R-Fla.), Opinion contributor. “The 137 DC Statehood, Why statehood for DC com/homenews/sunday-talk-shows/552503-senate-republicans-have- Is Depleting the World’s Oceans, Yale Environment 360, August 17 Biden Border Crisis Is a Self-Inflicted Disaster That Can Be Solved.” 138 Flynn, M. House Democrats pass D.C. steroid, launching proposed-a-counter-600-billion-plan 2020, par. 3, https://e360.yale.edu/features/how-chinas-expand- TheHill. The Hill, May 4, 2021. bill into uncharted territory 162 Ibid ing-fishing-fleet-is-depleting-worlds-oceans#:~:text=Estimates%20 113 Rubin, Jennifer. “Opinion | Hey, Whatever Happened to the 139 Flynn, M. House Democrats pass D.C. steroid, launching 163 Ibid of%20the%20total%20size,of%20the%20world’s%20fishing%20 Border Crisis?” The Washington Post. WP Company, May 2, 2021. bill into uncharted territory 164 https://www.marketwatch.com/story/biden-infra- activity.&text=By%20comparison%2C%20the%20United%20 114 140 Brownell, R. The Alexandria retrocession of 1846. Boundary structure-plan-seeks-to-shift-more-elder-care-to-at-home-set- States,has%20fewer%20than%20300%20vessels. 115 “Roll Call Vote 117th Congress - 1st Session.” U.S. Senate: Stones, 2016, July 8, https://boundarystones.weta.org/2016/07/08/ tings-11618255693 193 Ian Urbina, How China’s Expanding Fishing Fleet Is De- U.S. Senate Roll Call Votes 117th Congress - 1st Session, January 16, alexandria-retrocession-1846 165 https://www.politico.com/news/2021/04/07/biden-infra- pleting the World’s Oceans, Yale Environment 360, August 17 2020, 2020. 141 Brownell, R. The Alexandria retrocession of 1846. structure-child-care-479675 par. 5, https://e360.yale.edu/features/how-chinas-expanding-fish- 116 Glenn Kessler, Adrián Blanco. “Analysis | The False and 142 Breuninger, K. Biden administration backs D.C. statehood, 166 Tankersley, “Biden Details,” ing-fleet-is-depleting-worlds-oceans#:~:text=Estimates%20of%20 Misleading Claims President Biden Made during His First 100 Days urges swift action as house prepares to vote on bill. 167 https://www.marketwatch.com/story/biden-infra- the%20total%20size,of%20the%20world’s%20fishing%20activity- in Office.” The Washington Post. WP Company, April 30, 2021. 143 Describing our state, DC Statehood Coalition, (n.d.) http:// structure-plan-seeks-to-shift-more-elder-care-to-at-home-set- .&text=By%20comparison%2C%20the%20United%20States,has%20 117 Collins, Michael. “From Dr. Seuss to Mr. Potato Head, www.dcstatehoodcoalition.org/what-s-the-51st-state/ tings-11618255693 fewer%20than%20300%20vessels. Biden Steers Clear of Polarizing Culture Wars.” USA Today. Gannett 144 DC Statehood, Why statehood for DC. 168 Anneken Tappe, “Joe Biden’s infrastructure plan could leave 194 Chuin-Wei Yap, China’s Fishing Fleet, the World’s Largest, Satellite Information Network, April 5, 2021. 145 Describing our state, DC Statehood Coalition too many women behind,” CNN Business, April 18, 2021, accessed Drives Beijing’s Global Ambitions, Wall Street Journal, April 21 2021, 118 The White House, January 2021, https://commons.wikime- 146 https://swling.com/blog/wp-content/uploads/2015/04/ April 19, 2021, https://www.cnn.com/2021/04/18/economy/wom- par. 8 dia.org/wiki/File:President_Joe_Biden_2021.jpg Washington_Capitol.jpg en-infrastructure-care-stimulus/index.html. https://www.wsj.com/articles/chinas-fishing-fleet-the-worlds-largest- 119 Nina Totenberg, Krishnadev Calamur, “Democrats Unveil 147 Eric Levenson, “Derek Chauvin found guilty of all three 169 Tappe, “Joe Biden’s,” drives-beijings-global-ambitions-11619015507 Long-Shot Plan To Expand Size Of Supreme Court From 9 To 13,” charges for killing George Floyd,” CNN, April 21st, 2021, https:// 170 Ibid 195 Chuin-Wei Yap, China’s Fishing Fleet, the World’s Largest, NPR, April 19 2021 par 1. www.cnn.com/2021/04/20/us/derek-chauvin-trial-george-floyd-de- 171 Ibid Drives Beijing’s Global Ambitions, Wall Street Journal, April 21 2021, https://www.npr.org/2021/04/15/987723528/democrats-unveil-long- liberations/index.html 172 https://www.nytimes.com/2021/03/31/business/economy/ par. 13 shot-plan-to-expand-size-of-supreme-court-from-9-to-13 148 “Amdt14.S1.4.1.1 Race-Based Classifications: Overview,” biden-infrastructure-plan.html https://www.wsj.com/articles/chinas-fishing-fleet-the-worlds-largest- 120 Totenberg, Calamur, par, 5-6. Constitution Annoted, https://constitution.congress.gov/browse/es- 173 Ibid drives-beijings-global-ambitions-11619015507 121 “The Court as an Institution,” SupremeCourt.gov, https:// say/amdt14_S1_4_1_1/ 174 https://www.flickr.com/photos/scottishgovern- 196 Leilani Chavez, Chinese ‘fishing fleet’ anchored www.supremecourt.gov/about/institution.aspx 149 Connie Hassett-Walker, “How You Start is How You Finish? ment/6466748015/ on Philippine reef raises tensions, Mongabay, March 26 122 Totenberg, Calamur, par, 2, 9. The Slave Patrol and Jim Crow Origins of Policing,” American Bar 175 Anton Troianovski, ‘A Threat From the Russian State’: 2021, par. 4 https://news.mongabay.com/2021/03/chi- 123 Totenberg, Calamur, par 11. Association, January 12, 2021, https://www.americanbar.org/groups/ Ukrainians Alarmed as Troops Mass on Their Doorstep, New York nese-fishing-fleet-anchored-on-philippine-reef-raises-ten- 124 Sarah Ferris, “Pelosi dismisses progressive ‘court packing’ crsj/publications/human_rights_magazine_home/civil-rights-re- Times, Apr 22, 2021, pars 1-6 sions/#:~:text=English)%20(%E0%A4%B9%E0%A4%B- legislation,” Politico, April 15 2021, par 1-3. imagining-policing/how-you-start-is-how-you-finish/ 176 Felix Light, Russia in 2021: Looming Elections Dominate F%E0%A4%82%E0%A4%A6%E0%A5%80)-,Chinese%20’fishing%20 https://www.politico.com/news/2021/04/15/pelosi-dismiss-progres- 150 Julie Tate, Jennifer Jenkins, Steven Rich, John Muyskens, the Domestic Scene, The Moscow Times, January 5 2021, pars 8-12 fleet’%20anchored%20on%20Philippine%20reef%20raises%20ten- sive-court-packing-bill-481895 Joe Fox, David Fallis, Danielle Rindler, “985 people have been shot 177 Joey Garrison, ‘We could have gone further’: Biden expels sions,lays%20claim%20to%20the%20area. 125 Andrew Chung, David Morgan, “Cool reception for Dem- and killed by police in the past year,” The Washington Post, May 5, Russian diplomats, imposes new round of sanctions, USA Today, 197 Chuin-Wei Yap, China’s Fishing Fleet, the World’s Largest, ocratic proposal to expand U.S. Supreme Court,” Reuters, April 15 2021, https://www.washingtonpost.com/graphics/investigations/po- April 14, 2021, par 3 Drives Beijing’s Global Ambitions, Wall Street Journal, April 21 2021, 2021, par 9. lice-shootings-database/ 178 Garrison, pars 1-6 par. 23 https://www.reuters.com/world/us/democrats-unveil-bill-expand-us- 151 Julie Tate, Jennifer Jenkins, Steven Rich, John Muyskens, 179 Robyn Dixon, Russia’s Putin pumps up the swagger in https://www.wsj.com/articles/chinas-fishing-fleet-the-worlds-largest- supreme-court-by-four-justices-2021-04-15/ Joe Fox, David Fallis, Danielle Rindler, “985 people have been shot swipes at Biden, Washington Post, March 28, 2021, pars 1-4 drives-beijings-global-ambitions-11619015507 126 Ferris, par, 3. and killed by police in the past year,” The Washington Post, May 5, 180 Dixon, pars 4-9 198 Natasha Niebieskikwiat, Chinese Fishing Fleets Are Sweep- 127 US Const, Art. 3, § 1. 2021, https://www.washingtonpost.com/graphics/investigations/po- 181 Tom Balmforth, Putin’s approval rating holds steady despite ing South American Oceans Dry, Worldcrunch, March 17 2021, par. 128 NCC Staff, “How FDR lost his brief war on the Supreme lice-shootings-database/ Navalny crackdown: poll, Reuters, February 4, 2021, pars 3-8 6 Court,” National Constitution Center, February 5 2021, par 2, 5. 152 “The Brownsville Community Center,” Center for Court 182 Light, pars 7-12 https://worldcrunch.com/world-affairs/chinese-fishing-fleets-are- https://constitutioncenter.org/blog/how-fdr-lost-his-brief-war-on- Innovation, https://www.courtinnovation.org/programs/browns- 183 Marvin Kalb, What Does Vladimir Putin Fear? His Own sweeping-south-american-oceans-dry the-supreme-court-2 ville-community-justice-center/more-info: People, TIME Magazine, November 28, 2017, par 8 199 Chuin-Wei Yap, China’s Fishing Fleet, the World’s Largest, 129 Joe Ravi, CC-BY-SA 3.0, https://commons.wikimedia.org/ 153 “A Recovery For All of Us: Mayor de Blasio Announces Safe 184 Kalb, par 8 Drives Beijing’s Global Ambitions, Wall Street Journal, April 21 2021, wiki/File:Panorama_of_United_States_Supreme_Court_Building_at_ Summer NYC To Combat Gun Violence,” April 20, 2021, NYC.gov, 185 Kalb, pars 7-9 par. 16 Dusk.jpg https://www1.nyc.gov/office-of-the-mayor/news/284-21/recovery-all- 186 Chris Hughes, Alexei Navalny: The man Vladimir Putin https://www.wsj.com/articles/chinas-fishing-fleet-the-worlds-largest- 130 Phil Roeder, March 15, 2011, https://www.flickr.com/pho- us-mayor-de-blasio-safe-summer-nyc-combat-gun-violence fears so much he won’t even speak his name, Mirror, January 19 2021, drives-beijings-global-ambitions-11619015507 tos/tabor-roeder/5554035521; https://creativecommons.org/licenses/ 154 “H.R.1280 - George Floyd Justice in Policing Act of 2021,” pars 2-20 200 Chuin-Wei Yap, China’s Fishing Fleet, the World’s Largest, by/2.0/ Congress, April 28, 2021, https://www.congress.gov/bill/117th-con- 187 Vanessa Romo, At Least 1,700 Protesters In Russia Arrested Drives Beijing’s Global Ambitions, Wall Street Journal, April 21 2021, 131 DC Statehood, Why statehood for DC. Washington DC for gress/house-bill/1280 After Nationwide Anti-Putin Rallies, NPR, April 22 2021, pars 1-6 par. 28 Statehood, (n.d.), https://statehood.dc.gov/page/why-statehood-dc 155 https://www.flickr.com/photos/fibonacciblue/49940537367; 188 Alexei Navalny, Putin’s Palace:History of the World’s largest https://www.wsj.com/articles/chinas-fishing-fleet-the-worlds-largest- 132 Flynn, M. House Democrats pass D.C. steroid, launching https://creativecommons.org/licenses/by/2.0/ bribe, Palace for Putin, January 19, 2021 drives-beijings-global-ambitions-11619015507

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51 The Horace Mann Review | Vol. XXX June 2021 52 280 “COVID India: Several States, Including Delhi, Odisha, 297 Yeung, Jessie. 2021. “India Is Spiraling Deeper Into 21 2019, https://www.foxnews.com/politics/bernie-sanders-cam- 340 “Possible Side Effects After Getting a COVID-19 Vac- West Bengal Defer COVID Vaccination for 18-44 Years Group.” Lat- Covid-19 Crisis. Here’s What You Need To Know”. CNN. https:// paign-announces-it-will-cut-hours-to-pay-staffers-15-minimum- cine,” The CDC, May 25, 2021, https://www.cdc.gov/coronavi- est News by Times now News. Accessed May 21, 2021. https://www. www.cnn.com/2021/04/26/india/india-covid-second-wave-explainer- wage-prompting-mockery. rus/2019-ncov/vaccines/expect/after.html timesnownews.com/india/blog/covid-india-cases-live-updates-coro- intl-hnk-dst/index.html. 320 Michael A.Schultz, The Wage Mobility of Low Wage Work- 341 Robbins, par. 21 navirus-vaccination/635. 298 Biswas, Soutik. 2021. “Covid-19: How India Failed To ers in a Changing Economy, Russell Sage Foundation, September 342 Robbins, par. 14 281 “Arundhati Roy on India’s Covid Catastrophe: ‘We Are Wit- Prevent A Deadly Second Wave”. BBC News. https://www.bbc.com/ 2019, https://www.jstor.org/stable/10.7758/rsf.2019.5.4.06. 343 Ivan Pereira, 2nd vaccine shot statistics show majority nessing a Crime against Humanity’.” The Guardian. Guardian News news/world-asia-india-56771766. 321 Ibid. getting it, only 5 million missing it: CDC, ABC News, April 26, 2021, and Media, April 28, 2021. https://www.theguardian.com/news/2021/ 299 Ibid. 322 Percentage distribution of workers paid hourly rates with par. 3, https://abcnews.go.com/Health/millions-missing-2nd-vaccine- apr/28/crime-against-humanity-arundhati-roy-india-covid-catastro- 300 Ibid. earnings at or below minimum wage in the U.S. 2020, by age, April 22 dose-rounds-cdc/story?id=77300383 phe. 301 Hollingsworth, Julia. 2021. “Modi Could Have Prevented 2021, Statista, https://www.statista.com/statistics/298866/percentage- 344 https://www.thedailyvox.co.za/separating-the-myths-from- 282 Rafiq Maqbool/AP , https://www.ny1.com/nyc/all-bor- India’s Devastating Covid-19 Crisis, Critics Say. He Didn’t”. CNN. of-low-wage-workers-in-the-us-by-age/. the-facts-about-the-vaccine-roll-out/ oughs/coronavirus/2021/04/29/nyc-leaders-covid-19-india https://www.cnn.com/2021/04/30/india/covid-second-wave-naren- 323 The Budgetary Effects of the Raise the Wage Act of 2021, 345 Marco Verch, https://www.flickr.com/photos/30478819@ 283 Ganesh Dhamodkar, 2 September 2020, https://commons. dra-modi-intl-hnk-dst/index.htm Congressional Budget Office, February 2021, pg. 6, https://www.cbo. N08/51061378867; https://creativecommons.org/licenses/by/2.0/ wikimedia.org/wiki/File:COVID-19_antigen_testing_centre_Waro- 302 Ibid. gov/system/files/2021-02/56975-Minimum-Wage.pdf ra_Maharashtra_India.jpg; https://creativecommons.org/licenses/ 303 Ibid. 324 The Minimum Wage Study, Evans School of Public Policy by-sa/4.0/deed.en 304 Ibid. and Finance, https://evans.uw.edu/faculty-research/research-proj- 284 2020 | Topics: News | Tags: Food Security USUN Rome 305 Ibid. ects-and-initiatives/the-minimum-wage-study/. Mission | 5 August, “Under Maduro, Nearly All Venezuelans Live in 306 “Australia Crushes COVID-19 Second Wave With Aggres- 325 Ibid. Poverty,” U.S. Mission to the UN Agencies in Rome, August 5, 2020, sive Lockdowns”. 2020. Youtube.Com. https://www.youtube.com/ 326 Tim Worstall, Check Seattle’s $15 Minimum Wage: https://usunrome.usmission.gov/under-maduro-nearly-all-vene- watch?v=9sFNjlHwYis. Look There are the Job Losses, Forbes, October 23 2015, para- zuelans-live-in-poverty/#:~:text=Based%20purely%20on%20in- 307 Staff, CNN. 2021. “Travel To Australia During Covid-19: graph 6, https://www.forbes.com/sites/timworstall/2015/10/23/ come%2C%20the,percent%20live%20in%20extreme%20poverty. What You Need To Know Before You Go”. CNN. https://www.cnn. checking-seattles-15-minimum-wage-look-theres-the-job-loss- 285 “Venezuela Population (LIVE),” Worldometer, accessed May com/travel/article/australia-travel-covid-19/index.html. es/?sh=3d9734705705. 17, 2021, https://www.worldometers.info/world-population/venezue- 308 Dhiraj Singh/Bloomberg, https://www.bloomberg.com/ 327 Deirdre McCloskey, The Secret History of the Minimum la-population/. news/articles/2021-04-05/india-cases-at-record-thailand-finds-new- Wage, Reason, July 16, paragraph 5, https://reason.com/2016/06/12/ 286 Arianna Kohan and Moises Rendon, “From Crisis to Inclu- clusters-virus-update the-secret-history-of-the-mini/. sion: The Story of Venezuela’s Women,” From Crisis to Inclusion: The 309 https://www.flickr.com/photos/kedubesaustra- 328 Walter E. Williams, 1998, FEE, paragraph 8, March 2007, Story of Venezuela’s Women | Center for Strategic and International lia/50146862247; https://creativecommons.org/licenses/by/2.0/ https://fee.org/media/5133/0703williams.pdf. Studies, January 21, 2021, https://www.csis.org/analysis/crisis-inclu- 310 Zoë Bernard and Grace Kay, “The many alleged identities of 329 Ibid. sion-story-venezuelas-women , par 5. Bitcoin’s mysterious creator, Satoshi Nakamoto,” Business Insider, Feb 330 Mark J. Perry, August 7 2016, AEI, https://fee.org/me- 287 Julie Turkewitz and Mitra Taj, “After a Year of Loss, South 26, 2021, pars. 1-3, https://www.businessinsider.com/bitcoin-histo- dia/5133/0703williams.pdf. America Suffers Worst Death Tolls Yet,” The New York Times ry-cryptocurrency-satoshi-nakamoto-2017-12 331 Kate Taylor, February 28 2021, Business Insider, The real (The New York Times, April 29, 2021), https://www.nytimes. 311 Will Kenton, “Bitcoin Mining,” Investopedia, October 1, reason why Amazon is lobbying for a $15 minimum wage as it tries com/2021/04/29/world/americas/covid-latin-america.html?action=- 2020, par. 3, https://www.investopedia.com/terms/b/bitcoin-mining. to squash unionization efforts, https://www.businessinsider.com/ click&module=Top+Stories&pgtype=Homepage. asp amazons-15-minimum-wage-push-is-a-strategic-business-deci- 288 Julie Turkewitz and Isayen Herrera, “The Only Ones Ar- 312 James Chen, “Fiat Money,” Investopedia, April 16, 2021, sion-2021-2. rested After a Child’s Rape: The Women Who Helped Her,” The New par. 1, https://www.investopedia.com/terms/f/fiatmoney.asp#:~:tex- 332 Orley C. Ashenfelter and Štěpán Jurajda, “Wages, Min- York Times (The New York Times, April 13, 2021), https://www.ny- t=Fiat%20money%20is%20a%20government,U.S.%20dollar%2C%20 imum Wages, and Price Pass-Through: The Case of McDonald’s times.com/2021/04/13/world/americas/venezuela-abortion-assault. are%20fiat%20currencies. Restaurants”, Forbes, February 2021, https://www.forbes.com/sites/ html?searchResultPosition=3 , par 4 313 Caroline Banton, “How are International Exchange Rates timworstall/2015/10/23/checking-seattles-15-minimum-wage-look- 289 Turkewitz, par 3. Set?”, Investopedia, March 4, 2021, par. 6, https://www.investopedia. theres-the-job-losses/?sh=3d9734705705. 290 Anatoly Kurmanaev and Isayen Herrera, “Students Fainting com/ask/answers/forex/how-forex-exchange-rates-set.asp#cita- 333 Bernette D. Proctor, September 2016, The Congressional From Hunger in Venezuela’s Failing School System,” The New York tion-3= Budget Office, https://www.census.gov/content/dam/Census/library/ Times (The New York Times, November 30, 2019), https://www.ny- 314 Katrina Nicholas, “Tesla Now Accepts Bitcoin as Pay- publications/2016/demo/p60-256.pdf. times.com/2019/11/30/world/americas/venezuela-students-hunger. ment for Cars, Musk says,” Bloomberg News, March 24, 2021, 334 Steve Denning, April 1 2013, Milton Friedman and the html#commentsContainer, par 8. par. 4, https://www.bloomberg.com/news/articles/2021-03-24/ Fallacy of Good Intentions, Forbes, https://www.forbes.com/sites/ste- 291 Kurmanaev, par 14. you-can-now-buy-a-tesla-with-bitcoin-elon-musk-says#:~:tex- vedenning/2013/08/01/milton-friedman-and-the-fallacy-of-good-in- 292 Lara Jakes, “Pompeo, Who Led Trump’s Mission at t=Tesla%20Now%20Accepts%20Bitcoin%20as%20Payment%20 tentions/?sh=61a4bec152c6. State Dept., Leaves With a Dubious Legacy,” The New York Times for%20Cars%2C%20Musk%20Says&text=He%20added%20 335 Fibonacci Blue from Minnesota, USA, 29 November 2016, (The New York Times, January 18, 2021), https://www.nytimes. that%20Tesla%20will,will%20be%20priced%20in%20dollars.&tex- https://commons.wikimedia.org/wiki/File:Rally_demanding_$15-hr_ com/2021/01/18/us/politics/mike-pompeo-secretary-of-state.html?- t=Bitcoin%20climbed%20as%20high%20as%205.1%25%20to%20 minimum_wage_(31326059165).jpg searchResultPosition=1 %2457%2C204. 336 Audrey Carlsen, How Is The COVID-19 Vaccination Cam- 293 Michael R. 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Hours to Pay Staffers $15 minimum wage, prompting mockery, July poll-finding/kff-covid-19-vaccine-monitor-april-2021/

53 The Horace Mann Review | Vol. XXX June 2021 54