The Sovereign Citizen Movement

Sovereign citizen movement 1 Sovereign citizen movement

The sovereign citizen movement is a loose grouping of American litigants, commentators, and financial scheme promoters, classified as an "extremist anti-government group" by the United States Federal Bureau of Investigation.[1] Self-described sovereign citizens take the position that they are answerable only to common law and are not subject to any statutes or proceedings at the federal, states or municipal levels, or that they do not recognize U.S. currency and that they are "free of any legal constraints."[2][3][4] They especially reject most forms of taxation as illegitimate.[5] Participants in the movement argue this concept in opposition to "federal citizens" who, they say, have unknowingly forfeited their rights by accepting some aspect of federal law.[6] In a 2010 publication, the Southern Poverty Law Center (SPLC) estimated that approximately 100,000 Americans are "hard-core sovereign believers" and another 200,000 are "just starting out by testing sovereign techniques for resisting everything from speeding tickets to drug charges."[7]

History The concept of a sovereign citizen originated in the Posse Comitatus movement as a teaching of Christian Identity minister William P. Gale. The concept has influenced the tax protester movement, the Christian Patriot movement, and the redemption movement—the last of which includes claims that the U.S. government uses its citizens as collateral against foreign debt.[6] Gale identified the Fourteenth Amendment to the United States Constitution as the act that converted sovereign citizens into federal citizens by agreeing to a contract to accept benefits from the federal government. Other commentators have identified other acts, including the Uniform Commercial Code,[8] the Emergency Banking Act,[8] the Zone Improvement Plan,[9] and the alleged suppression of the Titles of Nobility Amendment.[10] Many of those in the movement consider the term "sovereign citizen" an oxymoron, preferring to view themselves as sovereign individuals "seeking the Truth".[11]

Theories about sovereign citizens Sovereign-citizen leader Richard McDonald has established State Citizen Service Centers around the United States. Writing in American Scientific Affiliation, Dennis L. Feucht describes McDonald's theory, which claims that there are two classes of citizens in America: the "original citizens of the states" (or "States citizens") and "U.S. citizens." McDonald asserts that U.S. citizens or "Fourteenth Amendment citizens" have civil rights, legislated to give the freed black slaves after the Civil War rights comparable to the unalienable constitutional rights of white state citizens. The benefits of U.S. citizenship are received by consent in exchange for freedom. State citizens consequently take steps to revoke and rescind their U.S. citizenship and reassert their de jure common-law state citizen status. This involves removing one's self from federal jurisdiction and relinquishing any evidence of consent to U.S. citizenship, such as a Social Security number, driver's license, car registration, use of ZIP codes, marriage license, voter registration, and birth certificate. Also included is refusal to pay state and federal income taxes because citizens not under U.S. jurisdiction are not required to pay them. Only residents (resident aliens) of the states, not its citizens, are income-taxable, state citizens argue. And as a state citizen land owner, one can bring forward the original land patent and file it with the county for absolute or allodial property rights. Such allodial ownership is held "without recognizing any superior to whom any duty is due on account thereof" (Black's Law Dictionary). Superiors include those who levy property taxes or who hold Sovereign citizen movement 2

mortgages or liens against the property.[12] Critics of sovereign citizen theory assert that sovereign citizens fail to sufficiently examine the context of the case laws from which they cite, and ignore adverse evidence, such as Federalist No. 15, where Alexander Hamilton expressed the view that the Constitution placed everyone personally under federal authority.

Incidents involving members Convicted Oklahoma City bombing conspirator Terry Nichols was a member of the sovereign citizen movement, having asserted individual sovereignty in at least three court cases.[13] In 2010, two police officers in West Memphis, Arkansas were shot and killed by Joseph T. Kane after Kane and his father were the subject of a traffic stop. Kane and his father were later identified as members of the sovereign citizen movement.[14][15] In March 2011, a central figure in the sovereign citizen movement named Samuel Lynn Davis pleaded guilty to 31 counts of money laundering in Federal district court in Nevada. Davis was snared in a sting operation after he agreed to launder more than $1.29 million in what he believed to be illicit funds. Davis accepted $73,782 fees to launder the money, not realizing he was dealing with Federal law enforcement agents.[16] In October 2011, Davis was sentenced to four years and nine months in Federal prison, and was ordered to pay over $95,000 in restitution.[17] In September 2010, David Russell Myrland, an associate of a Sovereign Citizens group, sent emails and placed telephone calls to various officials of the City of Kirkland, Washington, telling them to "keep their doors unlocked", that they were going to be arrested, and that they "should not resist".[18] Myrland also reportedly threatened federal judges and the chief prosecutor of King County, Washington.[19] Myrland's threat to arrest the mayor of Kirkland came about after he was arrested by police. His vehicle had been impounded after he was found driving with a suspended license and expired vehicle-license tabs. An unloaded gun with ammunition nearby had been found on the seat of the car.[20] Although he was not a law enforcement officer, Myrland had claimed that he had the authority to form a group of private citizens to arrest felons in public office "as permitted by RCW 9A.16.020"[20] (the state statute governing lawful use of force).[21] On December 2, 2011, Myrland was sentenced to three years and four months in federal prison after pleading guilty in connection with the threats he made, including the threat to forcibly arrest the mayor of Kirkland, Washington.[18] Myrland is scheduled for release from Federal prison on December 20, 2013.[22] On February 1, 2012, Timothy Garrison, an accountant from Mount Vernon, Washington was sentenced to three and a half years in federal prison after having pleaded guilty to tax fraud. He admitted to having filed about 50 falsified tax returns. Federal prosecutors contended that Garrison's actions cost the Internal Revenue Service over 2.4 million dollars in tax revenues. Prosecutors also stated that the sixty year old accountant had described himself as a “sovereign citizen” beyond the reach of state and federal law. Garrison had previously served time in federal prison in the 1980s in connection with fraud against investors in a cattle ranch.[23] Garrison is scheduled for release from Federal prison on July 16, 2014.[24] On June 18, 2012, Francis Schaeffer Cox, who had asserted that he was a sovereign citizen, was found guilty in the United States District Court in Anchorage, Alaska, of several felony charges including conspiracy to commit murder.[25][26] On June 20, 2012, Anson Chi was arrested by federal authorities for allegedly trying to blow up a natural gas pipe line in a residential area of Plano, Texas.[27] Sovereign citizen movement 3

Legal status of theories Variations of the argument that an individual is "sovereign" have been rejected by the courts, especially in tax cases such as Johnson v. Commissioner,[28] Wikoff v. Commissioner,[29] United States v. Hart,[30] Risner v. Commissioner,[31] Maxwell v. Snow,[32] Rowe v. Internal Revenue Serv.,[33] Heitman v. Idaho State Tax Commission,[34] Cobin v. Commissioner,[35] Glavin v. United States,[36] and United States v. Greenstreet.[37] The Internal Revenue Service has included "free born" or "sovereign" citizenship in its list of frivolous claims that may result in a $5000 penalty when used as the basis for an inaccurate tax return.[38]

References

[1] "The Sovereign Citizen Movement" (http:/ / www. fbi. gov/ news/ stories/ 2010/ april/ sovereigncitizens_041310). Domestic Terrorism. Federal Bureau of Investigation. April 13, 2010. . Retrieved May 24, 2011.

[2] Yerak, Becky; Sachdev, Ameet (June 11, 2011). "Giordano's strange journey in bankruptcy" (http:/ / www. chicagotribune. com/ business/

ct-biz-0612-giordanos--20110611,0,1118609. story?page=1& utm_medium=feed& track=rss& utm_campaign=Feed: chicagotribune/ business

(Chicago Tribune news - Business)& utm_source=feedburner). Chicago Tribune.

[3] Also, see generally Kevin Johnson, "Anti-government 'Sovereign Movement' on the rise in U.S.", March 30, 2012, USA Today, at (http:/ /

www. usatoday. com/ news/ nation/ story/ 2012-03-30/ anti-government-militia-groups-freeman/ 53873496/ 1?csp=24&

kjnd=IONsWJEZfuX98uHXgTee5WButCv0+ am+ Il2wtC8icJGauL518LIGGYVRKAOccyCQ-96f274b1-547a-40c8-a767-4ad766b53fe2_tmD50Galgl0aSegJkkIJEkIv3EZD4pzQyPBUIBuQZyPhi8No3Q/ 6zyEmxwehI1EG).

[4] "'Sovereign Citizen' Suing State Arrested Over Traffic Stop," April 6, 2012, WRTV Indianapolis, at (http:/ / www. theindychannel. com/

news/ 30847368/ detail. html).

[5] The Sovereign Citizen Movement (http:/ / www. adl. org/ mwd/ students. asp#1. What is a "sovereign citizen"?). Militia Watchdog. Anti-Defamation League.

[6] Carey, Kevin (July 2008). "Too Weird for The Wire" (http:/ / www. washingtonmonthly. com/ features/ 2008/ 0805. carey. html). Washington Monthly. . Retrieved July 19, 2008.

[7] MacNab, J.J. "'Sovereign' Citizen Kane" (http:/ / www. splcenter. org/ get-informed/ intelligence-report/ browse-all-issues/ 2010/ fall/ sovereign-citizen-kane). Intelligence Report. Issue 139. Southern Poverty Law Center. Fall 2010. [8] Hall, Kermit; Clark, David Scott (2002). The Oxford Companion to American Law. [9] Fleishman, David (Spring 2004). "Paper Terrorism: The Impact of the 'Sovereign Citizen' on Local Government". The Public Law Journal 27 (2). [10] Smith, William C. (November 1996). "The Law According to Barefoot Bob". ABA Journal.

[11] J.J. MacNab, (February 13, 2012) "What is a Sovereign Citizen?" (http:/ / www. forbes. com/ sites/ jjmacnab/ 2012/ 02/ 13/

what-is-a-sovereign-citizen/ 2). Forbes.

[12] American Militias: Rebellion, Racism & Religion by Richard Abanes, review by Dennis L. Feucht in American Scientific Affiliation (http:/ /

www. asa3. org/ ASA/ PSCF/ 1997/ PSCF6-97Feucht. html) [13] Pepke, David Ray (1998) Heretics in the Temple

[14] Dan Harris, Deadly Arkansas Shooting By 'Sovereigns' Jerry and Joe Kane Who Shun U.S. Law (http:/ / abcnews. go. com/ WN/

deadly-arkansas-shooting-sovereign-citizens-jerry-kane-joseph/ story?id=11065285) (July 1, 2010), ABC News.

[15] Michael Braga, Economy Boosts Sovereign-Citizen Movement (http:/ / www. heraldtribune. com/ article/ 20110730/ ARTICLE/ 307309989) (July 30, 2011), Sarasota Herald-Tribune.

[16] John L. Smith. Conviction chips away at Sovereign Citizen guru's facade (http:/ / www. lvrj. com/ news/

conviction-chips-away-at-sovereign-citizen-guru-s-facade-118731494. html) (March 27, 2011). Las Vegas Review-Journal.

[17] German, Jeff (October 27, 2011). "Judge sentences anti-government leader to prison" (http:/ / www. lvrj. com/ news/

-sovereign-citizens-leader-sentenced-in-money-laundering-scheme-132733063. html). Las Vegas Review-Journal.

[18] "Kirkland Man Sentenced To 40 Months In Prison For Threatening Public Officials" (http:/ / www. justice. gov/ usao/ waw/ press/ 2011/

dec/ myrland. html) (Press release). Office of the U.S. Attorney for the Western District of Washington. December 2, 2011.

[19] "Man gets 3 years for threatening Kirkland mayor" (http:/ / www. bellinghamherald. com/ 2011/ 12/ 02/ 2295659/

man-gets-3-years-for-threatening. html#ixzz1fac8Sdml). The Bellingham Herald. December 2, 2011. [20] Phelps, Matt (October 4, 2010). "Reporter informs Redmond man of charges in alleged threats against Kirkland Mayor, Assistant City

Attorney" (http:/ / www. redmond-reporter. com/ news/ 104047203. html). Redmond Reporter.

[21] "RCW 9A.16.020: Use of force—When lawful." (http:/ / apps. leg. wa. gov/ rcw/ default. aspx?cite=9A. 16. 020) Revised Code of Washington. Washington State Legislature. Retrieved December 16, 2011 [22] David Russell Myrland, inmate number 40941-086, Federal Correctional Institution at Sandstone, Minnesota, Federal Bureau of Prisons,

U.S. Dep't of Justice, at (http:/ / www. bop. gov/ iloc2/ InmateFinderServlet?Transaction=NameSearch& needingMoreList=false&

FirstName=David& Middle=& LastName=Myrland& Race=U& Sex=U& Age=& x=53& y=19). Sovereign citizen movement 4

[23] Levi Pulkkinen, "Washington accountant sentenced to prison for 'crusade’ against IRS", Feb. 1, 2012, at (http:/ / www. seattlepi. com/

default/ article/ Washington-accountant-sentenced-to-prison-for-2883371. php). [24] Timothy Garrison, inmate # 13961-086, Federal Correctional Institution Herlong (southeast of Susanville, California), Federal Bureau of

Prisons, U.S. Dep't of Justice, at (http:/ / www. bop. gov/ iloc2/ InmateFinderServlet?Transaction=IDSearch& needingMoreList=false&

IDType=IRN& IDNumber=13961-086& x=95& y=17).

[25] Ben Anderson, "Alaska militia trial: Cox, Vernon found guilty of conspiracy to murder," June 18, 2012, Alaska Dispatch, at (http:/ / www.

alaskadispatch. com/ article/ alaska-militia-trial-cox-vernon-found-guilty-conspiracy-murder).

[26] Richard Mauer & Lisa Demer, "Jury convicts militiamen on most charges," June 18, 2012, Anchorage Daily News, at (http:/ / www. adn.

com/ 2012/ 06/ 18/ 2510097/ militia-jury-deadlocked-on-one. html#storylink=cpy).

[27] J.J. MacNab, July 3, 2012, "Sovereign Extremist Injured in Texas Bomb Explosion," Forbes, at (http:/ / www. forbes. com/ sites/ jjmacnab/

2012/ 07/ 03/ sovereign-extremist-injured-in-texas-bomb-explosion/ ). [28] 37 T.C.M. (CCH) 189, T.C. Memo 1978-32 (1978) (Phyllis Johnson's argument that she was not subject to the federal income tax because

she was an "individual sovereign citizen" was rejected by the Court), at (http:/ / scholar. google. com/ scholar_case?q="memo+ 1978-32"&

hl=en& as_sdt=4,192& case=9585876962061565923& scilh=0). [29] 37 T.C.M. (CCH) 1539, T.C. Memo 1978-372 (1978) (argument by Austin Wikoff that he was not subject to the federal income tax because

he was an "individual sovereign citizen" was rejected by the Court), at (http:/ / scholar. google. com/ scholar_case?q="memo+ 1978-372"&

hl=en& as_sdt=4,192& case=7008586957096578494& scilh=0). [30] 701 F.2d 749 (8th Cir. 1983) (per curiam) (Douglas Hart's argument -- in response to lawsuit against him for filing false lien notices against IRS personnel, that the U.S. District Court had no jurisdiction over him because he was a "sovereign citizen" -- was rejected by the District

Court and the United States Court of Appeals for the Eighth Circuit), at (http:/ / scholar. google. com/ scholar_case?q="701+ F. 2d+ 749"&

hl=en& as_sdt=4,113,128& case=93925117926571874& scilh=0). [31] Docket # 18494-95, 71 T.C.M. (CCH) 2210, T.C. Memo 1996-82, United States Tax Court (February 26, 1996) (Gregg Risner's argument that he was not subject to federal income tax because he was a "Self-governing Free Born Sovereign Citizen" was rejected by the Court as

being a "frivolous protest" of the tax laws), at (http:/ / scholar. google. com/ scholar_case?q="1996-82"& hl=en& as_sdt=4,192&

case=13617811365855506634& scilh=0). [32] 409 F.3d 354 (D.C. Cir. 2005) (Lawrence Maxwell's arguments -- that he was not subject to U.S. federal law because he was a "sovereign citizen of the Union State of Texas," that the United States was not a republican form of government and therefore must be abolished as unconstitutional, that the Secretary of the Treasury's jurisdiction was limited to the District of Columbia, and that he was not a citizen of the

United States -- were rejected by the Court as being frivolous), at (http:/ / scholar. google. com/ scholar_case?q="409+ F. 3d+ 354"& hl=en&

as_sdt=4,130,192& case=15464772622202031639& scilh=0). [33] Case no. 06-27-P-S, U.S. District Court for the District of Maine (May 9, 2006) (Heather Rowe's argument -- that she was not subject to federal income tax because she was not a "party to any social compact or contract," because the IRS had no jurisdiction over her or her property, because she was "not found within the territorial limited jurisdiction of the US," because she was a "sovereign Citizen of the State of Maine," and because she was "not a U.S. Citizen as described in 26 U.S.C. 865(g)(1)(A)..." -- was rejected by the Court and was ruled to be

"frivolous"), at (http:/ / scholar. google. com/ scholar_case?q=sovereign+ "Rowe"& hl=en& as_sdt=4,145& as_ylo=2006& as_yhi=2006&

case=1479537413933402175& scilh=0). [34] Case no. CV-07-209-E-BLW, U.S. District Court for the District of Idaho (June 29, 2007). [35] Docket # 16905-05L, T.C. Memo 2009-88, United States Tax Court (April 28, 2009) (John Cobin's arguments -- that he had the ability to opt out of liability for federal income tax because he was white, that he was a "sovereign citizen of Oregon," that he was a "non-resident alien of the United States", and that his sovereign status made his body real property -- were rejected by the Court and were ruled to be "frivolous

tax-protester type arguments"), at (http:/ / scholar. google. com/ scholar_case?q="2009-88"& hl=en& as_sdt=4,130,192&

case=4550806128621306932& scilh=0). [36] Case no. 10-MC-6-SLC, U.S. District Court for the Western District of Wisconsin (June 4, 2010) (John Glavin's argument -- that he was not subject to an Internal Revenue Service summons because, as a sovereign citizen, he was not a citizen of the United States -- was rejected by

the Court), at (http:/ / scholar. google. com/ scholar_case?q=Glavin+ "sovereign+ citizen"& hl=en& as_sdt=3,44&

case=9948202298890386105& scilh=0). [37] 912 F.Supp. 224 (N.D. Tex. 1996) (Gale Greenstreet's arguments — that he was of "Freeman Character" and "of the White Preamble Citizenship and not one of the 14th Amendment legislated enfranchised De Facto colored races", that he was a "white Preamble natural sovereign Common Law De Jure Citizen of the Republic/State of Texas", and that he was a sovereign, not subject to the jurisdiction of the

United States District Court — were ruled to be "entirely frivolous"), at (http:/ / scholar. google. com/ scholar_case?q="912+ F. + Supp. +

224"& hl=en& as_sdt=3,44& case=11282331993183073302& scilh=0).

[38] "The Truth about Frivolous Tax Arguments" (http:/ / www. irs. gov/ taxpros/ article/ 0,,id=159853,00. html). Internal Revenue Service. January 1, 2011. Sovereign citizen movement 5

External links

• SPLC Video Informing Law Enforcement on the Dangers of "Sovereign Citizens" (http:/ / www. youtube. com/ watch?v=d_y-gLm9Hrw)

• FBI page on the Sovereign Citizen movement (http:/ / www. fbi. gov/ news/ stories/ 2010/ april/ sovereigncitizens_041310)

• ADL page on the Sovereign Citizen movement (http:/ / www. adl. org/ learn/ ext_us/ scm. asp?xpicked=4)

• 60 Minutes documentary about Sovereign citizens (http:/ / www. cbsnews. com/ stories/ 2011/ 05/ 15/ 60minutes/

main20062666. shtml) Article Sources and Contributors 6 Article Sources and Contributors

Sovereign citizen movement Source: http://en.wikipedia.org/w/index.php?oldid=500748955 Contributors: Acroterion, Aitias, Alphabet55, Athos23, Bblurkin, Beeblebrox, BoogaLouie, Calmer Waters, Catgut, Chris Chittleborough, CityOfSilver, Connelly, Courcelles, Cybercobra, D, DaddyWarlock, Dale Free, Danger, Degarmo64, Dlrohrer2003, DocWatson42, Dougweller, Eastlaw, EoGuy, EviJien, Famspear, Fat&Happy, Firsfron, Flamarande, Flatterworld, Freedomfighter33, Futile Crush, Gogo Dodo, Grantmidnight, Gyrofrog, Indio, Insommia, Isoxyl, John Nevard, Johnkim100530, JzG, Karppinen, Kgf0, Kingsbench7, Lenin and McCarthy, Lokpest, Lousyd, MWShort, MarushiaDark, Merle rickard, MicaelaD, Motorizer, Muttenjeff, Nicolas.b, Nolte, Northwestgnome, Oatmealo, Oldmanklc, Orangemike, Pais, PamD, Patar knight, Ponydepression, Protectingmyrights, Rankiri, Reywas92, Rikelee, Ripogenus77, Riverpa, SQGibbon, Shadowfax0, Shotaro Makisumi, SiberioS, Sizzle Flambé, Skomorokh, Sovereign120, Steven J. Anderson, Succubus MacAstaroth, Terrace4, Thehelpfulone, Thingg, Tisane, Trasel, Tyciol, Uberhill, Verne Equinox, Visitor10001, Vt007ken, WAKEUPWPRLD, Wahoofive, Wilhelm meis, WillOakland, Wornsear, Xomoxnyc, Yeng-Wang-Yeh, Yintan, 147 anonymous edits License

Creative Commons Attribution-Share Alike 3.0 Unported //creativecommons.org/licenses/by-sa/3.0/ FBI — Sovereign Citizens http://www.fbi.gov/stats-services/publications/law-enforcement-bulletin/...

Home • Stats & Services • Reports and Publications • LEB • September 2011 • Sovereign Citizens Sovereign Citizens Table of Contents A Growing Domestic Threat to Law Enforcement Back to the Cover By the FBI’s Counterterrorism Analysis Section Focus on Terrorism

The Evolution of Terrorism Since 9/11 By Lauren B. O’Brien Understanding how terrorism trends have evolved can help agencies face today’s current threat environment.

Leadership Spotlight Tuesdays with Terry

Case Study The Hosam Smadi Case

Bulletin Honors Hazardous Device School Bomb Technician Memorial

Sovereign Citizens By the FBI’s Counterterrorism Analysis Section Law enforcement must become knowledgeable and aware of sovereign-citizen extremists.

Perspective Radicalization of Islamist Terrorists in the Western World

Wanted: Notable Speeches

Bulletin Reports

They could be dismissed as a nuisance, a loose network of individuals living in the United States who Patch Call call themselves “sovereign citizens” and believe that federal, state, and local governments operate LEB Home illegally. Some of their actions, although quirky, are not crimes. The offenses they do commit seem minor: They do not pay their taxes and regularly create false license plates, driver’s licenses, and even currency. However, a closer look at sovereign citizens’ more severe crimes, from financial scams to impersonating or threatening law enforcement officials, gives reason for concern. If someone challenges (e.g., a standard traffic stop for false license plates) their ideology, the behavior of these sovereign-citizen extremists quickly can escalate to violence. Since 2000, lone-offender sovereign- citizen extremists have killed six law enforcement officers. In 2010, two Arkansas police officers stopped sovereign-citizen extremists Jerry Kane and his 16-year-old son Joseph during a routine traffic stop on Interstate 40. Joseph Kane jumped out of the vehicle and opened fire with an AK-47 assault rifle, killing both officers.

The sovereign-citizen threat likely will grow as the nationwide movement is fueled by the Internet, the economic downturn, and seminars held across the country that spread their ideology and show people how they can tap into funds and eliminate debt through fraudulent methods. As sovereign citizens’ numbers grow, so do the chances of contact with law enforcement and, thus, the risks that incidents will end in violence. Law enforcement and judicial officials must understand the sovereign-citizen movement, be able to identify indicators, and know how to protect themselves from the group’s threatening tactics.

Ideology and Motivation

The FBI considers sovereign-citizen extremists as comprising a domestic terrorist movement, which, scattered across the United States, has existed for decades, with well-known members, such as Terry Nichols, who helped plan the Oklahoma City, Oklahoma, bombing. Sovereign citizens do not represent an anarchist group, The FBI considers nor are they a militia, although they sometimes use or buy illegal sovereign-citizen weapons. Rather, they operate as individuals without established extremists as leadership and only come together in loosely affiliated groups to comprising a domestic train, help each other with paperwork, or socialize and talk about their ideology. They may refer to themselves as terrorist movement… “constitutionalists” or “freemen,” which is not necessarily a connection to a specific group, but, rather, an indication that they

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are free from government control. They follow their own set of laws. While the philosophies and conspiracy theories can vary from person to person, their core beliefs are the same: The government operates outside of its jurisdiction. Because of this belief, they do not recognize federal, state, or local laws, policies, or regulations.1

One prevalent sovereign-citizen theory is the Redemption Theory, which claims the U.S. government went bankrupt when it abandoned the gold standard basis for currency in 1933 and began using citizens as collateral in trade agreements with foreign governments. 2 These beliefs can provide a gateway to illegal activity because such individuals believe the U.S. government does not act in the best interests of the American people. By announcing themselves as sovereign citizens, they are emancipated from the responsibilities of being a U.S. citizen, including paying taxes, possessing a state driver’s license, or obeying the law.

Illegal Activity

The Redemption Theory belief leads to their most prevalent method to defraud banks, credit institutions, and the U.S. government: the Redemption Scheme. Sovereign citizens believe that when the U.S. government removed itself from the gold standard, it rendered U.S. currency as a valueless credit note, exchanging one credit document (such as a dollar bill) for another. They assert that the U.S. government now uses citizens as collateral, issuing social security numbers and birth certificates to register people in trade agreements with other countries. Each citizen has a monetary net worth, which they believe is kept in a U.S. Treasury Direct account, valued from $630,000 to more than $3 million. These accounts, they claim, are in a third-party’s name, a “strawman,” that they can access, which they commonly refer to as “freeing money from the strawman.” In essence, it is extorting money from the U.S. Treasury Department. Sovereign citizens file legitimate IRS and Uniform Commercial Code forms for illegitimate purposes, believing that doing so correctly will compel the U.S. Treasury to fulfill its debts, such as credit card debts, taxes, and Alfred P. Murrah Federal Building, Oklahoma City. mortgages. 3

At a minimum, these activities create a voluminous influx of documents that clog the courts and other government agencies. But, the idea behind the Redemption Theory also leads sovereign citizens to find criminal sources of income as they travel the country, teach fraudulent tactics to others for a fee, and participate in white collar crimes. The latter offenses include mail, bank, mortgage, and wire fraud; money laundering; tax violations; and illegal firearms sales and purchases.

At seminars, sovereign citizens charge participants a fee in exchange for information on Redemption Theory schemes and other methods to avoid paying taxes, sometimes even selling materials, such as CDs or DVDs. They also sell fraudulent documents—including drivers’ licenses, passports, diplomat identification, vehicle registrations, concealed firearms permits, law enforcement credentials, and insurance forms—to other sovereign citizens and illegal immigrants and charge fees for “consultant services” to prepare sovereign-citizen paperwork. Several recent incidents highlight their activities.

In Sacramento, California, two sovereign-citizen extremists were convicted of running a fraudulent insurance scheme, operating a company completely outside of state insurance regulatory authorities. The men sold “lifetime memberships” to customers and promised to pay any accident claims against members. The company collected millions of dollars, but paid only small auto insurance claims and ignored large ones.4 In Kansas City, Missouri, three sovereign-citizen extremists were convicted in a phony diplomatic credential scandal. They charged customers between $450 and $2,000 for a diplomatic identification card that bestowed “sovereign status,” supposedly to enjoy diplomatic immunity from paying taxes and from stops and arrests by law enforcement. 5 In Las Vegas, Nevada, four men affiliated with the sovereign-citizen-extremist movement were arrested by the Nevada Joint Terrorism Task Force on federal money laundering, tax evasion, and weapons charges. The undercover investigation revealed that two of the suspects allegedly laundered more than a million dollars and collected fees for their services. 6

One example of a white collar crime that escalated into a standoff includes a New Hampshire husband and wife convicted of federal income tax evasion, failure to honor federal payroll taxes, and other conspiracy fraud charges. Elaine A. and Edward L. Brown, both sovereign-citizen extremists in their 60s, never appeared at their 2007 trial or at sentencing. In protest, the Browns barricaded themselves in their home during the summer and fall of 2007, receiving supporters, issuing militant and threatening statements, and stockpiling weapons and explosives. They were charged with weapons offenses after their arrest in October 2007 when law enforcement discovered pipe bombs, improvised explosive devices made of gun powder cans with nails and screws taped to the outside, and a large cache of handguns and rifles that included .50-caliber rifles. 7

However, even when sovereign citizens go to prison for crimes, they continue criminal activity behind bars. Inmates provide a new population for them to sway to adopt the sovereign-citizen ideology; they then can train these inmates to help them defraud banks, credit institutions, and the U.S. government.

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They can create fraudulent businesses from inside prison walls and complete fraudulen t financial documents to receive lines of credit from legitimate banks. The learning system goes both ways—inmates can teach sovereign citizens new criminal methods that they can use either from inside the prison or when they are released.

Indicators

Sovereign citizens often produce documents that contain peculiar or out-of-place language. In some cases, they speak their own language or will write only in certain colors, such as in red crayon. Several indicators can help identify these individuals. It is important to realize sovereign References to the Bible, The Constitution of the United citizens’ tactics to States, U.S. Supreme Court decisions, or treaties with harass and intimidate 8 foreign governments law enforcement, Personal names spelled in all capital letters or interspersed court, and government with colons (e.g., JOHN SMITH or Smith: John) officials, as well as Signatures followed by the words “under duress,” “Sovereign Living Soul” (SLS), or a copyright symbol (©) financial institution Personal seals, stamps, or thumb prints in red ink employees. The words “accepted for value” 9

They also carry fraudulent drivers’ licenses to indicate their view that law enforcement does not have the authority to stop their vehicle or may write “No Liability Accepted” above their signature on a driver’s license to signify that they do not accept it as a legitimate identification document.

Intimidation, Obstruction, and Protection

It is important to realize sovereign citizens’ tactics to harass and intimidate law enforcement, court, and government officials, as well as financial institution employees. Methods can range from refusing to cooperate with requests, demanding an oath of office or proof of jurisdiction, filming interactions with law enforcement that they later post on the Internet, and filing frivolous lawsuits or liens against real property. They convene their own special courts that issue fake but realistic-looking indictments, warrants, and other documents. They also can use real government documents, including suspicious activity reports, in an attempt to damage the credit or financial history of specific individuals.

While these efforts may seem obviously fraudulent, it is important to address these actions, which can have devastating outcomes for the individuals they target. The sovereign citizens’ efforts also can be a gateway for them to harass, terrorize, and target others in hopes of changing behaviors that they perceive as threatening.

The Court Security Improvement Act of 2007 is one protection for officials who the sovereign citizens could target. The provisions under Title 18 created a new criminal offense for false liens against the real or personal property of officers or federal government employees, including judges and prosecutors. It also created as a new crime the disclosure of personal, identifying information to intimidate or incite violence against these individuals. 10

Conclusion

Although the sovereign-citizen movement does not always rise to violence, its members’ illegal activities and past violent—including fatal—incidents against law enforcement make it a group that should be approached with knowledge and caution. It is important that law enforcement be aware of sovereign citizens’ tactics so Although the agencies can warn the public of potential scams, spot illegal sovereign-citizen activity and understand its potential severity, and be prepared for movement does not and protect against violent behavior or backlash through always rise to violence, intimidation and harassment. its members’… Endnotes activities…make it 1 U.S. Department of Justice, Federal Bureau of Investigation, a group that should Domestic Terrorism Operations Unit and Domestic Terrorism be approached with Analysis Unit, Sovereign Citizen Danger to Law Enforcement knowledge and (Washington, DC, 2010). caution. 2 U.S. Department of Justice, Federal Bureau of Investigation, Domestic Terrorism Operations Unit II, Sovereign Citizens: An Introduction for Law Enforcement (Washington, DC, 2010).

3 U.S. Department of Justice, Federal Bureau of Investigation, Domestic Terrorism Analysis Unit, Sovereign Citizen Extremist Movement (Washington, DC, 2011).

4 U.S. Attorney’s Office, Eastern District of California, “Two ‘Sovereign Citizens’ Sentenced in Illegal Insurance Scam,” press release, 2/24/2010; http://sacramento.fbi.gov/dojpressrel/pressrel10 /sc022410.htm (accessed June 14, 2011).

5 U.S. Attorney’s Office, Western District of Missouri, “Three Men Sentenced for Conspiracy to Use

3 of 4 7/26/2012 5:40 AM FBI — Sovereign Citizens http://www.fbi.gov/stats-services/publications/law-enforcement-bulletin/...

Fake Diplomatic Identification,” press release, 2/8/2010; http://kansascity. fbi .gov/dojpressrel/pressrel10 /kc020810.htm (accessed June 14, 2011).

6 U.S. Department of Justice, U.S. Attorney, District of Nevada, “Members of Anti-Government Movement Arrested on Federal Money Laundering, Tax Evasion and Weapons Charges,” press release, 3/6/2009; http://www.justice.gov/usao/nv/press/march2009/davis030609.htm (accessed June 14, 2011).

7 U.S. Department of Justice and U.S. Attorney’s Office-District of New Hampshire, press releases, 1/18/2007 and 7/9/2009, “Jury Convicts Lebanon Dentist and Husband in Tax Case,” and “Edward and Elaine Brown Convicted”; http://www.justice.gov/tax/usaopress/2007/txdv07WEM_Browns.pdf and http://www.atf.gov/press/releases/2009/07/070909-bos-edward-and-elaine-brown-convicted.html (accessed June 14, 2011).

8 The authors wish to stress that the majority of individuals who carry or refer to these resources are law-abiding citizens. However, in some instances, possession of these items may serve as one indicator of a sovereign-citizen extremist.

9Sovereign Citizens: An Introduction for Law Enforcement .

10 Court Security Improvement Act of 2007; http://www.gpo.gov/fdsys/pkg/PLAW-110publ177 /pdf/PLAW-110publ177.pdf (accessed June 14, 2011).

Mr. Hunter is an intelligence analyst in the FBI’s Counterterrorism Analysis Section.

Dr. Heinke is the counterterrorism coordinator for the State Ministry of the Interior in Bremen, Germany.

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Home • News • Stories • 2010 • April • Sovereign Citizens Movement Story Index Domestic Terrorism The Sovereign Citizen Movement By Date

04/13/10 By Subject Domestic terrorism—Americans attacking Americans - Art Theft because of U.S.-based extremist ideologies—comes - Civil Rights in many forms in our post 9/11 world. - Counterterrorism - Crimes Against Children To help educate the public, we’ve previously outlined - Criminal Justice Information Services two separate domestic terror threats - Cyber Crimes —eco-terrorists/animal rights extremists and lone - Director/FBI Leadership offenders. - Field Cases - Foreign Counterintelligence Today, we look at a third threat—the “sovereign - General citizen” extremist movement. Sovereign citizens - History are anti-government extremists who believe that - Intelligence even though they physically reside in this country, Some examples of illegal license plates used by so-called - International they are separate or “sovereign” from the United sovereign citizens. - Lab/Operational Technology States. As a result, they believe they don’t have to - Linguist/Translation Program answer to any government authority, including courts, taxing entities, motor vehicle departments, or law - Major Thefts/Violent Crime enforcement. - Organized Crime/Drugs This causes all kinds of problems—and crimes. For example, many sovereign citizens don’t pay their - Partnerships taxes. They hold illegal courts that issue warrants for judges and police officers. They clog up the court - Public/Community Outreach system with frivolous lawsuits and liens against public officials to harass them. And they use fake money - Public Corruption orders, personal checks, and the like at government agencies, banks, and businesses. - Recruiting/Diversity - Responding to Your Concerns That’s just the beginning . Not every action taken in the name of the sovereign citizen ideology is a - Technology crime, but the list of illegal actions committed by these groups, cells, and individuals is extensive (and - Training puts them squarely on our radar). In addition to the above, sovereign citizens: - White-Collar Crime Commit murder and physical assault;

Threaten judges, law enforcement professionals, and government personnel; Impersonate police officers and diplomats; Use fake currency, passports, license plates, and driver’s licenses; and Engineer various white-collar scams, including mortgage fraud and so-called “redemption” schemes.

Sovereign citizens are often confused with extremists from the militia movement. But while sovereign citizens sometimes use or buy illegal weapons, guns are secondary to their anti-government, anti-tax beliefs. On the other hand, guns and paramilitary training are paramount to militia groups.

During the past year, we’ve had a number of investigative successes involving sovereign citizens . A few recent cases:

In Sacramento, two sovereign citizens were convicted of running a fraudulent insurance scheme. Operating outside state insurance regulatory guidelines, the men set up their own company and sold “lifetime memberships” to customers, promising to pay any accident claims against their “members.” The company collected millions of dollars, but paid out very few claims. More In Kansas City, three sovereign citizens were convicted of taking part in a conspiracy using phony diplomatic credentials. They charged customers between $450 and $2,000 for a diplomatic identification card, which would bestow upon the holder “sovereign” status—meaning they would enjoy diplomatic immunity from paying taxes and from being stopped or arrested by law enforcement. More In Las Vegas, four men affiliated with the sovereign citizen movement were arrested by the Nevada Joint Terrorism Task Force on federal money laundering, tax evasion, and weapons charges. The investigation involved an undercover operation, with two of the suspects allegedly laundering more than a million dollars from what they believed was a bank fraud scheme. More

You can help. First, “be crime smart”—don’t fall for the bogus claims and scams of sovereign citizens. And second, if you have information on any suspicious activities or crimes, please contact us.

Resources : - Lone Offenders - Eco-terrorists and animal rights extremists

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- Anarchist extremism - Treasury Inspector General for Tax Administration: Fact Sheet on Sovereign Citizen Movement

2 of 2 7/8/2012 2:11 AM AUTHOR

Christian Michelides

Police in Vienna separate “Fight Against the Right” and PEGIDA (“Patriotic Europeans Against the Islamisation of the Occident”) activists during a February 2015 demonstration.

84 | FEATURES PRISM 6, no. 1 Right-Wing Extremism and Terrorism in Europe Current Developments and Issues for the Future

BY DANIEL KOEHLER

urope has experienced a revival of militant right-wing extremist groups, networks, and incidents in recent years, with a surge of anti-immigration and Islamophobic violence, as Ewell as anti-government attacks and assaults on political opponents, ethnic minorities, and homosexuals. Although not as significant as in Europe, the United States has also seen an upsurge in political violence considered to be “right-wing extremist” in nature (for example, white supremacist, neo-Nazi, racist, or anti-government sovereign citizen). For the international audience, only a few of these incidents gained broad media attention; right-wing extremist attacks are seen mostly as isolated events when compared with other attacks, such as those by Islamist extremist terrorists. In Germany, a right-wing terrorist group calling itself the National Socialist Underground was discovered in 2011. Despite having assassinated at least 10 people and committed 2 bombings over the course of almost 14 years, it had gone undetected. That same year, Anders Behring Breivik killed 77 people in a bomb attack in Oslo and a mass shooting in Utøya, Norway. In the United States, white supremacist Michael Page shot and killed six people and wounded four others in an attack against a Wisconsin Sikh temple in August 2012. Only one day after Charles Kurzman had argued in the New York Times that right-wing terrorism might be the most severe security threat in the United States, Dylann Roof killed nine people in his shooting rampage at the Emanuel African Methodist Episcopal Church in Charleston, South Carolina, on June 17, 2015.1 Similar events have been recorded in many Western European countries, as well as in Russia and Eastern Europe. However, the public debate has not ascribed the same level of Daniel Koehler is the Director of the German Institute on Radicalization and De-radicalization Studies (GIRDS) and a Fellow at George Washington University’s Program on Extremism at the Center for Cyber and Homeland Security.

PRISM 6, no. 2 FEATURES | 85 KOEHLER

importance to the threat from the extreme nine such attacks between 2006 and 2013, right as it has regularly with Islamist extrem- though only two were in Western Europe. ism. TWEED also reveals three main waves of Nevertheless, statistics clearly show the attacks: France in the early 1960s, Italy in the significant risk posed by violent right-wing 1970s, and Germany in the early 1990s. These extremists in Western countries. In the United three nations also dominate the aggregate States, for example, the Combating Terrorism country share of casualties.8 Center’s Arie Perliger counted 4,420 violent Regarding the TE-SAT statistics, it is impor- incidents perpetrated by right-wing extremists tant to note that the national definitions and between 1990 and 2012, causing 670 fatalities selection criteria vary significantly and that the and 3,053 injured persons.2 After three peaks vast majority of violent crimes committed by in 2001, 2004, and 2008, with each wave sur- individuals or groups motivated by an extreme passing the previous one, the general trend is right-wing agenda are not categorized as ter- again upwards.3 Professor Christopher Hewitt’s rorism by Europol, based on the national legal valuable studies about terrorism in the United frameworks. Although all available national States also show that “white racist/rightist” ter- and international statistics in Europe and rorism accounts for 31.2 percent of the inci- North America show increasing trends in dents and 51.6 percent of terrorism-related extreme right-wing violence/terrorism, the fatalities between 1954 and 2000, making it basic phenomenon is by no means new: both the number one threat ahead of “revolutionary Europe and the United States have experienced left-wing” or “black militant” terrorism.4 In significant extreme right-wing attacks and both the United States and Canada, a wide- waves of violence during the past several spread lack of coherent analysis about the decades. threat posed by extreme right-wing militants Despite this, only a very small number of stands in stark contrast to the level of concern academic studies have thus far focused on this about such individuals expressed by police form of political violence9, which has created officials and other law enforcement agencies.5 a dangerous level of ignorance and a worrying As a means of comparison, Islamist and right- lack of expertise regarding the threat assess- wing extremists have caused 45 and 48 casual- ment of the far-right.10 This article will provide ties in the United States, respectively, since the an introduction to the current situation regard- September 11, 2001 attacks.6 ing right-wing violence in Western Europe, In Europe, academic and official statis- with a focus on its tactical and strategic tics—including the University of Bergen’s aspects, and review related implications for Terrorism in Western Europe: Events Data security in Europe and the United States. This (TWEED) and Europol’s annual European article argues that this specific form of political Union Terrorism Situation and Trend Report violence bears a number of unique character- (TE-SAT)—show a number of right-wing istics that make it harder for security agencies attacks since World War II.7 TWEED registered to detect and appropriately react to, especially 648 right-wing terrorist attacks between 1950 because the comparison with Islamist extrem- and 2004 (approximately 6 percent of a total ism has created political and tactical biases of 10,239 attacks), while TE-SAT registered that hinder the adaptations needed to address

86 | FEATURES PRISM 6, no. 2 RIGHT-WING EXTREMISM AND TERRORISM IN EUROPE this threat. An in-depth case study of Germany support for extreme right-wing parties and is provided to illustrate what that threat could may be linked to peaks of right-wing terrorism look like and to reveal the potentially devastat- and violence.13 Bold and rhetorically violent ing consequences for a nation’s security that anti-immigration and Euro-skeptic platforms may result. It is necessary, however, to see this of right-wing parties arguably might also form of organized violence in the context of increase support for more violent actions by the wider far-right movement in Europe, and small clandestine groups. After the Paris terror the West, as right-wing groups typically are attacks of January 7 and November 13, 2015, very well connected across borders, display sig- the extreme right-wing party the National nificant collective learning, and to some extent Front scored the highest results in local French see each other as inspiration for their own tac- elections, winning approximately 30 percent tics and modes of operation.11 As only a brief of the national vote in December 2015 (com- overview is within the scope of this article, pared with 11 percent in the 2010 election).14 another goal is to raise awareness about the Although it was ultimately defeated in the final lack of knowledge and understanding regard- round of voting, this defeat did not denote a ing extreme right-wing violence, which poses decrease in voter support. Rather, it was merely a severe threat to internal security in many a result of the tactics employed by the opposi- Western countries. tion parties, which utilized special characteristics of the French electoral system. After the The Far-Right: Interplay of International and National Affairs 9/11 attacks, anti-Muslim hate crimes and right-wing terrorism (it should be noted the Throughout the last decade, Europe has seen a relationship between the two is heavily major surge of electoral successes for national- debated) jumped 1,600 percent in the United ist and far-right parties.12 Currently, 39 States.15 Following the London bombings in European countries have nationalist and July 2005, police reported a six-fold increase extreme right-wing parties represented in their in the rate of right-wing violence against parliaments (excluding Turkey and Russia). Muslims. In the aftermath of the Charlie While in many cases these parties have gained Hebdo attacks in January 2015, similar inci- only minor influence or nominal representa- dents rose by 281 percent in France.16 tion, they have seen major—and unexpected— As such, possible links and supportive col- successes in a number of other countries, laboration, if not outright institutionalized including France (National Front), Sweden cooperation, between clandestine or extra- (Sweden Democrats), Greece (Golden Dawn), parliamentary groups and established political Poland (Law and Justice), the Netherlands parties from the right-wing spectrum must be (Party for Freedom), and Denmark (Danish taken into account when considering right- People’s Party). It is especially noteworthy that wing terrorism and political violence. Though far-right parties seem to have gained strong a highly under-researched topic, a few studies support as a result of the ongoing refugee crisis have looked at this intersection and found as well as Islamist-motivated terrorist attacks. mixed results. For example, while Paul These external events directed against a specific Wilkinson, the former director of the country have been shown to increase electoral University of St. Andrews’ Centre for the Study

PRISM 6, no. 2 FEATURES | 87 KOEHLER

of Terrorism and Political Violence, found no carried out on April 19, 1995 by Timothy clear correlation between electoral results of McVeigh and two accomplices, who used a car extreme right-wing political parties and vio- bomb to attack the Alfred P. Murrah Federal lence from small right-wing groups, he did Building in Oklahoma City. Planned by affirm that the ambivalent standpoint of far- McVeigh, who was inspired by the right-wing right parties toward violence, as well as their extremist novel The Turner Diaries, the bomb- racist and xenophobic propaganda, were con- ing killed 168 and wounded more than 600.22 ducive to right-wing terrorism.17 In other It is one of the deadliest terrorist attacks in the words, right-wing parties and movements do history of the United States. have an influence on levels of everyday and In 2009, Ian Davison, a British neo-Nazi general xenophobia and racism that are, in and white supremacist, and his son were turn, intensified and made explicit in smaller, arrested for planning chemical weapons more extremist groups.18 In addition, more attacks using homemade ricin as part of the nuanced studies showed a significant rise in right-wing terrorist organization Aryan Strike right-wing-motivated arson attacks following Force.23 Authorities uncovered the plot, and verbal shifts in the mainstream political debate Davison was sentenced to 10 years in prison. toward more xenophobic language.19 While He is currently the only British citizen arrested not the focus of this article, it is reasonable to for and convicted of manufacturing a chemical deduce from the existing research that right- weapon. Two years later, on July 22, 2011, wing terrorism and violence cannot be com- Anders Behring Breivik, a right-wing extremist, pletely separated from far-right parties and detonated a car bomb in Oslo city center, kill- mass movements, although the specific rela- ing 8, and then drove to the island of Utøya to tionships between the two remain unclear. continue his attack, killing a further 69 people, many of them children, in a mass shooting.24 Decades of Right-Wing Extremism in the Seventy-seven people in total were killed dur- West ing the rampage. Prior to carrying out the Right-wing extremism has motivated some of attack, Breivik had published a manifesto that the deadliest acts of domestic terrorism in a laid out his ideology, which was based on number of Western countries. The following Christian fundamentalism and cultural racism. examples represent only a very small selection These examples demonstrate that the West of more widely known attacks committed by has a long history of violent acts perpetrated far-right extremists in recent decades. In by extreme right-wing actors. Since 2012, the August 1980, two members of a splinter cell of refugee crisis across Europe has contributed to the Italian right-wing terrorist group New an upsurge in support for right-wing parties Order bombed the Bologna train station, kill- and violent networks. Xenophobic and anti- ing 85 and wounding more than 200.20 That immigration crimes and social movements same year, the deadliest terrorist attack in post- have increased in almost all European coun- World War II Germany—the bombing of the tries. Thus a major question for researchers, Munich Oktoberfest by at least one neo- policymakers, and law enforcement personnel Nazi—left 13 people dead and another 2,011 in Europe and North America is whether wounded.21 Another devastating attack was extreme right-wing terrorism and violence

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display unique tactical or strategic characteris- “hate crimes attack society at large by attacking tics that make it harder to detect and counter. its norms, targeting dearly held values of equality, liberty, and basic human rights.”32 The Nature of Right-Wing Violence and Terrorism Such a conception of hate crimes aligns them with the “upward” nature of terrorism, refuting Defining the Threat claims that hate crimes are only a “downward crime.” Not attempting to solve this concep- One problematic issue connected to identify- tual debate here, it is still reasonable to assume ing and adequately classifying right-wing ter- that there is a relationship between “hate rorism is the lack of clarity among the different crimes” and “terrorism,” both in their effects concepts used to describe this form of political (that is, creating fear) and in the way their per- violence. In fact, many incidents of right-wing petrators operate. It is also reasonable to terrorism have been analyzed under the con- assume that the step from committing hate cept of “hate crime,”25 which does share a crimes to committing terrorism is much number of similar characteristics with terror- smaller and easier to take than that from “ordi- ism.26 A hate crime—defined as “a criminal act nary crime” (or no criminal activity) to terror- that is motivated by a bias toward the victim ism. Hate crimes seem to provide a bridge and or victims real or perceived identity group”27— an ideological testing phase for catalyzing can include, for example, the desire to “terror- potential motivations for violent action (for ize a broader group”28 or to create a specific example, hate, fear, aggression, power) with intimidation, including through hate speech, the ideological call to act. which has been described as simply another Case Studies manifestation of terrorism.29 The similarities between hate crimes and terrorism have led In order to assess the tactical and strategic some scholars to call the former a “close dimensions of right-wing political violence cousin” of terrorism because “the target of an and terrorism, it is critical to find a suitable offense is selected because of his or her group empirical database. Those countries with the identity, not because of his or her individual largest and most violent right-wing move- behaviour, and because the effect of both is to ments, in addition to having adequate statis- wreak terror on a greater number of people tics and a minimum of good quality research, than those directly affected by violence.”30 are the United States, Germany, and Russia. Other scholars have disagreed, however, and Without the need to recapitulate the history argued that the two are in fact distinct forms and structure of the violent extreme right-wing of violence more akin to “distant relatives” movements in these countries, this section than close cousins based on key differences focuses on some key strategic lessons learned such as the lack of planning and the spontane- for policymakers and law enforcement person- ous character of hate crimes, the downward nel regarding the character of right-wing ter- nature of hate crimes (minority group as tar- roristic violence.33 get), and the lack of publicity.31 Reviewing the similarities and differences between hate crimes and terrorism, Mills et al. maintain that

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United States American lone-actor terrorists showed that Numerous high-quality assessments have been right-wing attackers represented the largest possible in recent years as a result of detailed group (39 percent), ahead of even al Qaeda- databases on domestic extremism and terror- inspired perpetrators (34 percent).38 ism compiled from a variety of projects. These It thus appears that, although far from include the Terrorism and Extremist Violence exclusively right-wing, lone-actor terrorism is in the United States (TEVUS) database at the a highly preferred tactic of right-wing violence. National Consortium for the Study of A number of studies have looked at the special Terrorism and the Responses to Terrorism characteristics of far-right lone-actor attacks (START); the Global Terrorism Database and homicides, both in relation to non-right- (GTD); the U.S. Extremist Crime Database wing homicides39 and to organized right-wing (ECDB); the American Terrorism Study (ATS); extremist groups.40 In the first case, the major and the Profiles of Perpetrators of Terrorism in findings reveal that far-right lone-actor attacks the United States (PPT-US) database. have significantly decreased since the early One of the core findings regarding the 2000s (with a total of 96 homicides between characteristics of right-wing violence based on 1990 and 2008), have been perpetrated by the U.S. sample is that the extreme right has individuals much more likely to display men- not just developed strategic concepts based on tal health issues (40 percent), and targeted small-unit or lone-actor tactics (for example, mostly strangers.41 Lone-actors also seem to “leaderless resistance”), but has also shown a target government and military installations strong use of these tactics in practice. Whether more frequently and are older on average than or not this is due to a lack of organizational other domestic extremists who are part of an skills,34 many studies have shown that lone- organized group.42 Compared with other lone- actor terrorism is the most prominent tactic for actor terrorists (Islamist extremist or single the American extreme right. Perliger’s dataset, issue), right-wing terrorists are significantly for example, shows that 54 percent of 4,420 more likely to have previous military experi- incidents between 1990 and 2012 were com- ence, work in construction, and interact face to mitted by single perpetrators and 20 percent face with a wider network, and are less likely by 2-person groups.35 The Southern Poverty to receive help or be part of any command and Law Center, examining 63 incidents between control structure.43 April 2009 and February 2015, found that 74 These studies of lone-actors have revealed percent of the attacks were carried out by lone- profiles of right-wing extremists that are seem- actors.36 In analyzing 198 lone-actor attacks, ingly detached (but not uninfluenced) by sociologist Ramón Spaaij found that right- right-wing groups, perhaps because of mental wing actors constituted the second-largest cat- health issues and a tendency to focus on gov- egory (17 percent), following only attacks in ernment-related targets, both of which would which the perpetrator’s ideological conviction increase the risks of detection and interference remains unknown.37 A similar study of 119 by government authorities for organized right- lone-actors found that 34 percent had an wing groups.44 This picture, however, does not extreme right-wing background; a subsequent, fit into a conscious strategy of “leaderless resis- more detailed analysis of 111 European and tance” by the far-right; rather, it is more likely

90 | FEATURES PRISM 6, no. 2 RIGHT-WING EXTREMISM AND TERRORISM IN EUROPE

a concept designed to fit a certain type of activ- restaurant in 2005, attacks on police stations ist who would act alone anyway and to label and railways, or the live broadcast of execu- the occurring violence as part of a “master tions—show the escalation of violence and the plan.” radicalization process of the Russian far-right, which can be compared with the situation in Russia Germany since 2011.48 It is worth noting that One key lesson learned from the Russian case strategic concepts behind these acts of violence is how the government’s weak response to the have been framed as “counter-state terror” rise of more militant right-wing groups in the with the goal “to destabilise the state system early 2000s provided political opportunities and to induce panic in society, which accord- for formal organizations to interact and join ing to theorists of counter-state terror, will lead forces with violent skinhead groups and local to a neo-Nazi revolution.”49 This approach is community-based movements.45 As in other similar to what has been called a “strategy of countries, the Russian far-right is not homog- tension” used by Italian, Belgian, and German enous, and consists of many different groups right-wing terrorists.50 and styles. According to Martin Laryš and Mirslav Mareš, the most important of these are Germany unorganized individuals, short-term local The Federal Office for the Protection of the mass movements evolving around ethnic con- Constitution (Bundesamt für flicts, violent youth gangs, and uniformed Verfassungsschutz [BfV]), the German domes- paramilitary structures (including terrorist tic intelligence service, estimated that there groups).46 These groups appear to be united by were 21,000 far-right extremist activists in their common use of Russian nationalism and 2014, including approximately 7,200 from the imperialism. One particularly worrying trend subcultural milieu (for example, “skinheads”), is the potential for large numbers of Russian 5,600 neo-Nazis, and an estimated 6,850 military veterans with combat experience in members of far-right parties.51 Of these 21,000 Chechnya, Ukraine, or Georgia to be incorpo- extremists, German authorities regard a full 50 rated into highly militant right-wing under- percent (10,500) as “violence oriented,” mean- ground cells. ing they are prepared to use violence to Research on the Russian extreme right has advance their political goals.52 Although the provided valuable insights into different types number of activists has decreased slightly over of right-wing crimes and group structures, such the last few years—from an estimated 22,150 as ad hoc hate crimes, large-scale mass in 2012—the number of right wing-motivated pogroms organized by right-wing organiza- crimes certainly has not. In 2014, German tions around individual conflicts, and orga- authorities counted 1,029 violent hate crimes nized violence (including paramilitary (“right-wing politically motivated”), including branches of existing extremist organizations, more than 900 cases of criminal assault, an violent street gangs, terrorist groups).47 increase of 22.9 percent and 23.3 percent, Terrorist incidents—such as the bomb attack respectively, from the previous year.53 This on the Cherkizovsky Market in Moscow in surge occurred even before 2015, when the 2006, the attempted bombing of a McDonald’s largest numbers of refugees arrived in

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Germany. In 2014, 26 violent attacks on A recent project to build a database on mosques were perpetrated by right-wing right-wing terrorism and strategic political vio- extremists—a number dwarfed by the explo- lence has produced a number of important sive increase in violent right-wing attacks insights about the characteristics of German against refugee homes in recent years.54 While far-right terrorists since 1963.60 Analysis of authorities counted 58 of these incidents in qualitative and quantitative data reveals that, 2013 55, right-wing extremists attacked refugee since 1971, 91 right-wing terrorist actors homes 175 times in 2014. In 2015, the Federal (groups and individuals that could be identi- Criminal Police (Bundeskriminalamt [BKA]) fied) have carried out 123 attacks (including counted 901 violent acts against refugee shel- both successful and unsuccessful attempts) ters by individuals with a right-wing back- using explosives; 2,173 arson attacks; 229 ground, out of 1,005 total attacks.56 Ninety- murders; 12 kidnappings; 56 cases of extor- four of these attacks were arson, compared tion; and 174 armed robberies. This database with just six arson attacks in 2014. This allows for additional strategic analysis, largely increase reflects a strong radicalization within supporting the findings from other countries. the German far-right, especially in regard to Of the 91 identifiable German right-wing ter- the open use of violence, resembling the wave rorist actors, approximately 70 percent are of arson attacks against refugee homes in the either small cells with 2-3 members, small early 1990s following German reunification. groups of 4-9 members, or lone-actors. Although the German far-right movement These actors utilize mainly small-unit tac- historically has been extremely violent—offi- tics (for example, explosives, targeted assassi- cially, 69 right-wing attacks between 1990 and nations, arson, and, on occasion, hostage-tak- 2015 caused 75 casualties, though civil society ing and kidnapping) against government watchdogs counted up to 184 deaths—this representatives, Jews, leftists, and “foreigners.” widespread use of non-clandestine political Throughout the last 50 years, bombings have violence can be seen as extraordinary.57 been the main tactic of choice, especially since Currently, there are no extensive and detailed 1990. In earlier decades, assassinations were statistics regarding the level of right-wing also used widely, but the last 20 years have extremist violence and terrorism directed seen a significant decrease in the employment against Muslim persons or institutions, but the of this tactic. Prior to 2000, government repre- rise of the new European “Counter-Jihad” sentatives (for example, police officers, politi- Movement (ECJM) is indicative of the growing cians, and military personnel) made up importance of Islamophobic violence perpe- approximately half of the intended targets. trated by the extreme right.58 Based on cultural Since then, however, the groups and individu- nationalism, ECJM has identified Islam and als targeted by right-wing extremists have var- Muslim immigration as major threats to ied more widely. The vast majority of German Europe.59 In recent years, a number of right- right-wing terrorist actors (approximately 72 wing terrorist cells that had planned to attack percent) are active for no longer than a year mosques, Salafist preachers, and refugee shel- before they are either killed, detected and ters have been detected in Germany. arrested by the authorities, or disbanded. If an actor survives for more than a year, however,

92 | FEATURES PRISM 6, no. 2 RIGHT-WING EXTREMISM AND TERRORISM IN EUROPE the chances of long-term activity rapidly responsibility through letters, statements, and increase, with approximately 14 percent communiqués). In Germany, only about 24 remaining active for between 1 and 5 years and percent of perpetrators actually send out any 13 percent for more than 5 years. These long- form of claim or note. One possible reason for term clandestine cells are also much more this may be their desire to employ a “strategy likely to conduct attacks without being of tension” in connection with their attacks, detected and to develop highly professional that is, to produce chaos and insecurity among tactics to avoid arrest. the population in order to increase electoral Another common characteristic of right- support for (right-wing) “law and order” par- wing terrorism in general, as well as in ties.61 This strategy could also be used to dem- Germany, is the lack of public communication onstrate the weakness and powerlessness of regarding attacks (for example, claiming the targeted government. Another theory Maximilian

The ongoing conflict in Syria has spurred the largest wave of refugees seeking shelter in Europe since World War II.

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brought forward more recently argues that the and law enforcement officials to detect and use of terrorism by right-wing extremists is a counter such attacks. Further, while the orga- natural consequence of extreme-right ideolo- nizational characteristics of these attacks cer- gies and therefore does not require any com- tainly did not fit the typical picture of “terror- municated explanation.62 Many right-wing ism” in Germany at that time, the perpetrators’ attacks might be self-explanatory (e.g., a bomb intent did. In the majority of cases, the rela- attack against a synagogue or a mosque moti- tionship between victim and perpetrator was vated by anti-Semitism or Islamophobia) and irrelevant; the main motive was to achieve a can achieve the result of terrorizing the tar- high media impact to convey a message geted victim group even without any commu- against the government and a large hated nication. A third approach to explaining this group of immigrants.67 lack of strategic communication draws on Although the quality of the political mes- right-wing extremist tactical concepts such as sage and signal was not sophisticated or leaderless resistance, in which public state- embedded in a long-term, group-based strat- ments are seen as a risk factor for detection.63 egy, the combination of violent protest against immigration and the attempt to force refugees Collective Right-Wing Anti-Immigration Violence to leave the country through fear shows the terrorist quality of large and spontaneously In addition to organized right-wing clandes- acting groups based in a joint understanding tine cells and groups, another highly problem- and unity, guided by right-wing extremist ide- atic development became evident in recent ology. The violent potential of a large and infu- years across Europe: anti-immigration mass riated crowd has become especially visible in movements and collective radicalization the second wave of right-wing violence against towards violence. refugee homes that started in 2013. Again, the Between 1991 and 1994, authorities upsurge in violence appears to have been counted 1,499 right wing-motivated arson caused by a widespread negative public debate attacks against refugee shelters in Germany.64 about immigration, as was the case in the first Between 1990 and 1995, the 295 individuals wave of attacks in the early 1990s.68 Since the convicted in these attacks, which account for outbreak of conflicts in Syria, Iraq, North about 60 percent of the incidents, displayed a Africa, and the Middle East in the aftermath of very atypical perpetrator pattern at that time.65 2011’s “Arab Spring,” the number of refugees Sixty-three percent of the perpetrators had not and asylum seekers in Germany has steadily been previously convicted of any crime and risen to an estimated 1.5 million in 2015. The only 21 percent were known to be active in a number of violent attacks against housing right-wing party or skinhead group. installations for refugees has mirrored this Approximately 68 percent of the perpetrators increase.69 This time, however, right-wing were intoxicated during the attack, and in 60 extremists have diversified their violent tactics percent of the cases documented by courts to include arson attacks against designated there was almost no time invested in planning (but uninhabited) refugee homes, direct or preparing the attack.66 These characteristics threats against politicians, violent clashes with make it extremely challenging for intelligence the police tasked to protect the refugees, and

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the use of car bombs and explosives. Still, the were able to identify the perpetrators and twofold objective of the attacks was to protest gather enough evidence to charge or convict against the government’s immigration policies them in only 5 percent of the cases.75 The same and to either force refugees out of certain areas study also reveals that almost half of the 93 or threaten them not to come in the first place. arson attacks against refugee shelters within Although no statistical evaluations or sci- the same timeframe were directed at inhabited entific studies about this second wave of large- buildings, signifying a continuing escalation scale violence against refugee homes exist thus of violent tactics. far, the initial data suggests that there are at Parties such as the National Democratic least some similarities to the first wave. For Party of Germany and The Third Way have example, in one analysis, out of 148 perpetra- been involved in organizing protest groups tors identified by the authorities, only 41 (27.7 online (typically via Facebook) and stirring up percent) had been convicted of previous anti-refugee sentiments with falsified statistics crimes; the majority were not active in any of immigrants’ crimes or claims of specific organized right-wing group.70 Different, how- events witnessed by friends and colleagues, ever, seems to be the role of alcohol. Only 32 such as incidents of rape or child abduction by perpetrators (21.6 percent) were intoxicated refugees.76 Parties like The Third Way have also during the attacks, compared to a full 68 per- published guidebooks on how to organize cent in the early 1990s. This picture was sup- large-scale protests, and have officially regis- ported by a subsequent police analysis of 228 tered demonstrations that, in the majority of perpetrators.71 Of these, just 14 people had cases, devolved into violent action or took committed two or more of the attacks, and place shortly before arson attacks.77 In this alcohol was only rarely involved.72 Although way, right-wing parties, although not proven about 50 percent of the perpetrators were to be directly involved in the attacks, have con- known to the police due to previous crimes, tributed to a rise in levels of hostility through- only one-third had committed right-wing out Germany and provided the opportunity for crimes of any sort before attacking a refugee right wing-motivated violence. In addition, home.73 right-wing political parties have tried to gain Focusing exclusively on the arson attacks, support from the rather new phenomenon of another internal study conducted by the BKA right-wing populist protest movements such as shows a clear radicalization and escalation of PEGIDA (Patriotic Europeans against the the violence used, which shifted from targeting Islamization of the Occident) and its fran- uninhabited to inhabited buildings in 40 of chises across Germany.78 Though some attacks the 61 cases. The majority of the perpetrators have been carried out by organized neo-Nazis in these attacks were not part of an organized who took part in anti-immigration rallies, right-wing group.74 An additional study by the most of these violent acts were seemingly per- German newspaper Die Zeit, which examined petrated by individuals with no ties to the for- only attacks carried out against refugee shelters mal extreme right-wing movement, but whose between January and November 2015 (a total motivations mirrored those deeply embedded of 222 incidents) that seriously harmed or in right-wing anti-immigration protest move- endangered refugees, found that authorities ments. It is known that in some instances

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militant right-wing extremists have co-orga- political violence usually associated with ter- nized or participated in these demonstrations, rorism, this right-wing collective violence dis- thereby creating a direct, but completely non- plays other essential characteristics that place institutional, link between organized, militant, it into that very category. One of the first goals and experienced neo-Nazis and otherwise of right-wing collective violence is to directly “normal” citizens (that is, citizens not previ- challenge the government’s monopoly of force. ously known for right-wing extremist involve- Second, these collective attacks create terror ment) protesting primarily against immigra- and fear in a wide target group beyond the vic- tion and refugee policies. The Bavarian tims of the attack itself. Third, these acts of franchise of PEGIDA, for example, was orga- violence, especially arson, are carried out with nized by two neo-Nazis who were sentenced a strong motivation to send a signal or create to prison on terrorism charges in 2003.79 In a public symbol of resistance for a wide audi- addition, the organizers and speakers at the ence. Fourth, this type of tactic allows the per- PEGIDA franchises in Düsseldorf, Duisburg, petrator to strategically attack and hide imme- and Thuringia are mostly hard-core right-wing diately afterward in the large crowd of extremists.80 bystanders or to escape from the location alto- Although the aspects of spontaneity, large gether. In this way, collective right-wing vio- crowds without hierarchy or organization, and lence is akin to core terrorist tactics, although intoxication are atypical for the type of less coordinated and strategic. Right-wing blu-news.org

January 2015 PEGIDA demonstration in Dresden, Germany. One protester (left) holds sign appealing to Russian President Vladimir Putin: “Putin! Help us, save us from the corrupt, enemy-of-the-people BRD [Federal Republic of Germany] regime and from America and Israel!”

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organizations, parties, and groups have been against the U.S. government by sovereign citi- careful not to directly coordinate or lead these zen members, including the murders of six attacks, but rather to stir up the climate of police officers and at least three planned ter- panic, fear, hate, and urgency to act among the rorist attacks since 2010, the FBI has labeled local population. the network as a “domestic terrorist move- Similar waves of arson attacks against ref- ment.”86 ugee shelters carried out by members of large Although European anti-immigration protest movements have also occurred in mass movements like PEGIDA are still very dif- Sweden,81 Finland,82 and other European coun- ferent from the highly armed and often tries. The formation of violent vigilante groups extremely violent sovereign citizens, they do as part of anti-immigration movements across share a number of important characteristics, Europe, with the proclaimed goal of “protect- signaling a new strategic and tactical era in the ing” European citizens against criminal immi- militant extreme right. By diversifying further grants is a very recent and completely new and moving away from a reliance on lone- development, and poses the risk of collabora- actor attacks (although not returning to the tion between highly organized and experi- large-scale, paramilitary organizations of the enced clandestine cells and individuals from 1980s and 1990s), this new type of fluid net- mass movements who have no previous crim- work, centered around shared opposition to inal records but are ready to commit violence. the democratic government and immigration, A comparable movement in the United can mobilize large numbers of activists from States, the sovereign citizen movement, is com- mainstream society and create something I posed of a highly diverse and loosely con- would call “hive” terrorism: terrorist acts or nected network of individuals and groups who violent hate crimes committed by a spontane- reject U.S. laws, taxation, currency, and the ously formed crowd that quickly disbands after government’s legitimacy, especially regarding the incident. Western European law enforce- the control of firearms.83 Frequent overlap in ment agencies are currently struggling to the membership of more militant and violent understand this new threat and formulate militias and white supremacists has resulted in adequate responses. It is comparable to neither a number of violent attacks by both individu- an Islamist extremist terror attack in regard to als and groups, as well as clashes with law detectable communication, structures, and enforcement agencies.84 For example, Timothy preparation, nor to the other end of the typol- McVeigh’s accomplice in the Oklahoma City ogy, the neo-Nazi lone-actor. bombing, Terry Nichols, was a member of the Conclusion sovereign citizen movement. There also have been a number of violent standoffs between Right-wing terrorism has operated both tradi- sovereign citizen members and federal law tionally and tactically using very small groups, enforcement agencies (for example, the cells, and lone-actors to target mainly govern- “Bundy standoffs” in 2014 and 2016), and the ment representatives and minorities with murders of a number of police officers have explosives and targeted assassinations. These been attributed members of the network.85 As attacks, which usually do not attempt to inflict a result of increased lethal violence directed indiscriminate mass casualties (a tactic which

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nevertheless seems to be gaining increased been increasingly blurred. As the characteris- prominence), have only very rarely been tics of the perpetrators of xenophobic arson accompanied by some form of public commu- attacks show, security agencies will be facing a nication (that is, the public claiming of the different type of threat: spontaneous and rarely attack). This indicates that right-wing terrorists planned, violent and often lethal attacks do not need or want to communicate their against refugee homes, mosques, police, or course of action to a potential audience. One left-wing activists, carried out by individuals or reason for this is that right-wing attacks are small groups without previous criminal often self-explanatory (for example, bombing records or even history of involvement in orga- a mosque can successfully generate fear and nized far-right groups. terror within the target group even without In sum, the key lessons for law enforce- someone claiming the attack). As Professor ment personnel and policymakers are: Mark Hamm points out, right-wing political 1. Right-wing terrorism is a unique form violence can, in fact, be both hate crime and of political violence with fluid boundar- terrorism.87 This also implies that terrorist vio- ies between hate crime and organized lence is inherently part of the right-wing terrorism. In general, right-wing terror- extremist ideology and is not perceived by the ism does not aim for individual and perpetrators as something in need of explana- concentrated high-effect results, but tion. In addition, this raises the danger that the rather for long-term, low-intensity “war- intent and nature of an attack will be mis- fare” against their enemies. The effects judged as unplanned, erratic, spontaneous, or of creating horror and fear in their tar- as an isolated incident. The findings above, get group, however, are similar to other however, suggest otherwise. Right-wing terror- forms of terrorism. ism is a highly dangerous form of political 2. Lone-actor tactics have declined in violence and a significant threat because it tac- recent years, although they still domi- tically and strategically aims to blend in with nate the militant right-wing movement. the surrounding societies in order to minimize A distinct type of collective “hive” ter- repression and countermeasures and to maxi- rorism has developed in Europe, mize the effects regarding the main goal: win- embedded in and carried out by large- ning a long-term war against their enemies scale, right-wing, anti-immigration and (that is, democratic governments and foreign- anti-government movements, with the ers). peripheral involvement of organized Another development caused by the mas- and more militant right-wing organiza- sive influx of refugees that poses potential risks tions. Having created manuals and to Western societies is the spread of anti-immi- guidebooks on how to organize these gration, right-wing, populist mass movements protest movements and use online across Europe, which have displayed a steady social media platforms to stir up hatred, process of radicalization toward the use of vio- this structure could become a blueprint lence. In addition, the boundaries between for the United States as well. The high large-scale anti-immigration protest move- number of attacks currently being com- ments and organized militant groups have mitted in the wake of these movements

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in Western Europe could potentially In sum, right-wing terrorism or racist become more dangerous if transferred political violence remains one of the most to the better-armed sovereign citizen dangerous threats to Western democracies, movement or other networks in the especially because these extremist groups have United States. developed and used violent tactics designed to 3. Law enforcement personnel cannot be overlooked and misinterpreted by security hope that focusing on the detection of agencies. White supremacists, sovereign citizen communication and group structures members, neo-Nazis, and other right-wing before an event will bring adequate extremist groups widely deploy a very dynamic results. Biographical backgrounds may and flexible form of collective or “hive” terror- increasingly involve individuals without ism that does not provide traditional angles previous connection to an extremist for security agencies to identify hierarchies, movement, and small groups could long-term plots, or group structures. The lethal form spontaneously during or shortly and terrorizing effect remains intact, however. after protests and rallies in order to In addition, the corroding effect against demo- carry out arson attacks, shootings, or cratic societies and community resilience can other terrorist attacks. be much higher in cases of right-wing terror- 4. While it is not to be expected that the ism than compared with other forms because refugee situation will escalate to the the underestimation by the authorities essen- level of significance in the United States tially proves right the suspicion of minorities that it has in Europe, the situation in and other at-risk groups that they are without countries like Germany, France, Sweden, equal protection. PRISM and Denmark have taught neo-Nazis and other organized right-wing extremists how to evade government crack- down and detection before attacks. Even small numbers of refugees could potentially be used to catalyze similar protest movements on platforms already established in the United States. 5. A last potential threat from organized clandestine or open violence can be reciprocal violence between right-wing extremist groups and those opposed to them. Violent clashes between right- wing populists and Salafists in Germany, for example, have led to further radicalization on both sides. Recent clashes in Anaheim, California between Ku Klux Klan members and opponents are another example of this mechanism.88

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Notes pubs/papers/2005/P7029.pdf>; Daniel Koehler, “German Right-Wing Terrorism in Historical Perspective. A First Quantitative Overview of the 1 Charles Kurzman and David Schanzer, “The ‘Database on Terrorism in Germany (Right-Wing Growing Right-Wing Terror Threat,” The New York Extremism)’ – DTG rwx ’ Project,” Perspectives on Times, June 16, 2015, ; html?partner=rssnyt&emc=rss&_r=1>. Daniel Levitas, The Terrorist Next Door: The Militia 2 Arie Perliger, “Challengers from the Sidelines. Movement and the Radical Right (1st ed.) (New York: Understanding America’s Violent Far-Right,” West Thomas Dunne Books/St. Martin’s Press, 2002); JJ Point: Combating Terrorism Center (2012): 86. MacNab, The Seditionists: Inside the Explosive World of . Right Wing Extremism and Terrorism in the USA (New 3 Ibid, 87. York: Routledge, 2003); Arie Perliger, “Challengers 4 Christopher Hewitt, Understanding terrorism in from the Sidelines. Understanding America’s Violent America: from the Klan to al Qaeda (New York: Far-Right,” West Point: Combating Terrorism Center Routledge, 2003): 15. (2012). ; James Piazza, “The Determinants of About Lone Wolves, Far-Right Criminality, and Domestic Right-Wing Terrorism in the USA: Far-Right and Islamic Jihadist Criminal Economic Grievance, Societal Change and Political Collaboration,” Studies in Conflict & Terrorism 33, no. Resentment,” Conflict Management and Peace Science, 11 (2010); Barbara Perry and Ryan Scrivens, “Uneasy (2015). ; Brent Smith, Movement in Canada,” Studies in Conflict & Terrorism Terrorism in America : Pipe Bombs and Pipe Dreams (Feb 5, 2016). (Albany: State University of New York Press, 1994); 6 New America Foundation, “Deadly Attacks Ehud Sprinzak, “Right-Wing Terrorism in a Since 9/11,” . Deligitimization,” in Tore Bjørgo (ed.), Terror from the 7 The TWEED dataset is available at . TE-SAT is available at Max Taylor, Donald Holbrook, and PM Currie, . York: Continuum International Pub. Group, 2013); 8 See: Jacob Ravndal, “A Thugs or Terrorists? A Leonard Weinberg, “On Responding to Right-Wing Typology of Right-Wing Terrorism and Violence in Terrorism,” Terrorism and Political Violence 8, no. 1 Western Europe,” Journal for Deradicalization, Summer (1996). . article/view/16>. 10 Pete Simi, “Why Study White Supremacist 9 E.G. Tore Bjørgo, Terror from the extreme right, Terror? A Research Note,” Deviant Behavior 31, no. 3 (London: Frank Cass, 1995); Kathleen Blee, “Women (2010). . Studies in Conflict & Terrorism 28, no. 5 (2005),< 11 For example, see: Daniel Koehler, “The http://www.tandfonline.com/doi/ German ‘National Socialist Underground (NSU)’ and abs/10.1080/10576100500180303>; Mark Hamm, Anglo-American Networks. The Internationalization American skinheads: the criminology and control of hate of Far-Right Terror,” in Paul Jackson & Anton crime (Westport, Conn.: Praege, 1993); Bruce Shekhovtsov (eds.), The Post-War Anglo-American Far Hoffman, Right Wing Terrorism in Europe (Santa Right: A Special Relationship of Hate (Basingstoke: Monica: RAND, 1982), ; Bruce Hoffman, Right-Wing 12 The terms “Far-Right” and “Extreme Right” are Terrorism in Europe since 1980. (Santa Monica: RAND, used similarly in this article and describe a family of 1984),

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based on racism, white supremacism, militant Neo-Nazi Murderer Really Act Alone?,” Spiegel, nationalism, anti-government activism and/or September 14, 2010, . Relationship Between Terrorism and Hate Crime,” 22 Sheryll Shariat, Sue Mallonee, and Shelli Crime & Delinquency 58, no. 5 (2012). ; Colleen Injuries,” Oklahoma State Department of Health Mills, Joshua Freilich, and Steven Chermak, “Extreme (December 1998), Relationship to Determine Whether They Are ‘Close 23 Jeremy Armstrong, “Nicky Davison, Son of a Cousins’ or ‘Distant Relatives,’” Crime & Delinquency Right Wing Extremist, Found Guilty of Part in Plot to (2015). . . Opening Round in France’s Regional Elections,” The 24 Mark Lewis and Sarah Lyall, “Norway Mass Guardian, December 7, 2015. . com/2012/08/25/world/europe/anders-behring- 15 Oliver Laughland and Spencer Ackerman, breivik-murder-trial.html?_r=2>. “For a teen aspiring to be president, being Muslim is a 25 James Jacobs and Kimberly Potter, Hate hurdle in post-9/11 America,” The Guardian, crimes: criminal law & identity politics (New York: September 26, 2015, ; and Federal Bureau of Green, Laurence McFalls, & Jennifer Smith, “Hate Investigation, “Uniform Crime Reports: Hate Crime,” Crime: An Emergent Research Agenda,” Annual Review (2001), . stable/2678630>; Mark Hamm, American Skinheads : 16 Michelle Mark, “Anti-Muslim Hate Crimes The Criminology and Control of Hate Crime (Westport, Have Spiked After Every Major Terrorist Attack: After Conn.: Praege, 1993); Gregory Herek, Jeanine Cogan, Paris, Muslims Speak Out Against Islamophobia,” & J. Roy Gillis, “Victim Experiences in Hate Crimes International Business Times, November 18, 2015, Based on Sexual Orientation,” Journal of Social Issues ; Alan paris-2190150>. Krueger, & Jitka Malecková, “Does Poverty Cause 17 Paul Wilkinson, “Violence and terror and the Terrorism?” The New Republic, June, 24 2002, . 0/09546559508427319?journalCode=ftpv20>. 27 Randy Blazak, “Isn’t Every Crime a Hate 18 Philomena Essed, Understanding everyday Crime? The Case for Hate Crime Laws,” Sociology racism: An interdisciplinary theory (Newbury Park: Sage Compass 5, no. 4 (2011): 245. Publications, 1991). 28 Donald Green, Laurence McFalls, and Jennifer 19 Frank Neubacher, Fremdenfeindliche Smith, “Hate Crime: An Emergent Research Agenda,” Brandanschläge. Eine kriminologisch-empirische Annual Review of Sociology 27, (2001): 435. Untersuchuchng von Tätern, Tathintergründen und 29 Gregory Herek, Jeanine Cogan, and J. Roy gerichtlicher Verarbeitung in Jugendstrafverfahren, Gillis, “Victim experiences in hate crimes based on (Godesberg: Forum, 1998): 48-49. sexual orientation,” Journal of Social Issues 58, no. 2 20 “Bologna blast leaves dozens dead,” BBC (2002). News, . poverty cause terrorism?” The New Republic, June, 24 21 Jan Friedmann, Conny Neumann, Sven Röbel, 2002, .

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31 Deloughery, King, and Asal (2012). (September 2013), ; Jeff Gruenewald, Steven Chermak, and Terrorism Relationship to Determine Whether and Joshua Freilich, “Distinguishing “Loner” Attacks They Are ‘Close Cousins’ or ‘Distant Relatives,’ Crime from Other Domestic Extremist Violence,” Criminology & Delinquency (2015), . Freilich, “Far-Right Lone Wolf Homicides in the 33 Daniel Koehler, “Rechtsterrorismus in der United States”, Studies in Conflict & Terrorism 36, no. Bundesrepublik Deutschlan. Ein Profil,” Kriminalistik, 12 (2013). no. 3, (2015); Martin Laryš and Miroslav Mareš, 42 Ibid, 80. “Right-Wing Extremist Violence in the Russian 43 Paul Gill, Lone-actor terrorists: a behavioural Federation,” Europe-Asia Studies 63, no. 1 (2011); JJ analysis (New York, NY: Routledge, 2015): 124; Daryl Macnab, The Seditionists: Inside the Explosive World of Johnson, Right Wing Resurgence: How a Domestic Anti-Government Extremism in America (New York: St. Terrorist Threat is Being Ignored (Lanham, MD: Martin’s Press, 2016); George Michael, Confronting Rowman & Littlefield, 2012). Right Wing Extremism and Terrorism in the USA (New 44 Paul Gill, 107. York: Routledge, 2003); Thomas Parland, The extreme 45 Mihai Varga, “How political opportunities nationalist threat in Russia: the growing influence of strengthen the far right: understanding the rise in Western rightist ideas (New York: Routledge, 2004); far-right militancy in Russia,” Europe-Asia Studies 60, Stephen Shenfield, Russian Fascism: Traditions, no. 4, (2008). Tendencies, Movements (New York: M.E. Sharpe, 2001). 46 Martin Laryš and Miroslav Mareš, “Right-Wing 34 George Michael, Confronting Right Wing Extremist Violence in the Russian Federation,” Extremism and Terrorism in the USA (New York: Europe-Asia Studies 63, no. 1 (2011). Routledge, 2003): 125. 47 For example, approximately 450 right-wing 35 Arie Perliger (2012), 86. motivated killings between 2004 and 2010; See: 36 Southern Poverty Law Center, “Age of the Martin Laryš and Miroslav Mareš (2011). Wolf: A Study of the Rise of Lone Wolf and Leaderless 48 Martin Laryš and Miroslav Mareš (2011), Resistance Terrorism,” (2015), . 50 Franco Ferraresi, Threats to Democracy: The 37 Ramon Spaaij, Understanding lone wolf Radical Right in Italy after the War (Princeton, NJ: terrorism: Global patterns, motivations and prevention Princeton University Press, 2012). (London: Springer, 2011). 51 BMI, Verfassungsschutzbericht (Berlin: 38 Paul Gill, John Horgan, & Paige Deckert, Spangenberg, 2015), . Antecedent Behaviors of Lone-Actor Terrorists,” 52 Ibid. Journal of Forensic Sciences 59, no. 2, (2014); Paul Gill, 53 BMI, Politisch Motivierte Kriminalität im Jahr Lone-actor terrorists: a behavioural analysis. (New York, 2014 (Berlin: Spangenberg, 2015), . Extremists,” Homicide Studies 15, no. 2, (2011); Jeff 54 German Parliament’s Answer to an Gruenewald, Steven Chermak, and Joshua Freilich, Information Request by the Die Linke Party: Federal “Distinguishing “Loner” Attacks from Other Domestic Government, Islamophobia, and anti-Muslim crimes Extremist Violence,” Criminology & Public Policy 12, in 2014. Federal Government’s answer to the no. 1, (2013). information request by delegates Ulla Jelpke, Jan 40 Kathleen Deloughery, Ryan King, & Victor Korte, Sevim Dağdelen, one additional delegate Asal, “Understanding Lone-actor Terrorism: A [presumably anonymous?], and the Die Linke Comparative Analysis with Violent Hate Crimes and parliamentary party. Printed document 18/4067– Group-based Terrorism,” National Consortium for 18/4269. Berlin: German Parliament. the Study of Terrorism and Responses to Terrorism

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55 ZeitOnline, “Zunehmend Angriffe auf reuters.com/article/us-europe-migrants-germany-poll- Flüchtlingsheime,” Zeit, 2015, . gesellschaft/zeitgeschehen/2015-02/asyl-fluechtling- 70 Spiegel, “Attacken auf Asylunterkünfte: BKA sheime-uebergriffe-zahl-steigend>. fürchtet Ausbreitung ‘völkischer Ideologie,’”Spiegel, 56 Von Jorg Diehl, “Gewaltwelle: BKA zählt mehr July 31, 2015, . zaehlt-mehr-als-1000-attacken-a-1074448.html>. 71 Von Lena Kampf and Georg Mascolo, “Gewalt 57 Anna Brausam, “Todesopfer rechtsextremer gegen Flüchtlinge alarmiert BKA,” Sueddeutsche, und rassistischer Gewalt seit 1990,” MUT, July 30, October 21, 2015, . rassistischer-gewalt-seit-1990/>; DPA, “Seit 1990 fast 72 Ibid. 70 Mordanschläge mit rechtsextremem Hintergrund,” 73 Ibid. Sueddeutsche, July 27, 2015, . urn-newsml-dpa-com-20090101-150727-99-00045>. 75 Paul Blickle, Kai Biermann, Philip Faigle, 58 Alexander Meleagrou-Hitchens and Hans Astrid Geisler, Gotz Hamann, Lenz Jacobsen, and Brun, A Neo-Nationalist Network: The English Defence Sascha Venohr, “Es brennt in Deutschland,” Zeit, League and Europe’s Counter-Jihad Movement (London: December 3, 2015, . urteile>. 59 Ibid. 76 See: “13-jährige Schülerin aus Berlin: 60 For example: Daniel Koehler, Angeblich entführtes Mädchen war bei einem “Rechtsterrorismus in der Bundesrepublik Bekannten” [Translation: “13-year-old student from Deutschland. Ein Profil.” Kriminalistik 3 (2015). Berlin: Allegedly kidnapped girl was with a friend”], 61 Franco Ferraresi, Threats to democracy: the Spiegel, January 29, 2016, ; 62 Koehler, “Right-Wing Terrorism in the 21st Von Patrick Gensing, “Proteste gegen Flüchtlinge: Century.” Routledge, Series on Fascism and the ‘Anti-Asyl-Initiativen’ - vom Netz auf die Straße” Far-Right, in print (2016). [Translation: “Protests against refugees: ‘anti-asylum 63 Jeffrey Kaplan, “Leaderless resistance,” initiatives’ - from the network to the road”], tagess- Terrorism and Political Violence 9, no.3 (1997). chau.de, August 10, 2015, ; and Bundesministerium des Innern, 1992). HOAXmap, , which docu- 65 Frank Neubacher, Fremdenfeindliche ments claims, posted online by far-right groups, that Brandanschläge. Eine kriminologisch-empirische asylum seekers perpetrated incidents of rape, theft, Untersuchuchng von Tätern, Tathintergründen und assault, and so on, and which have been definitively gerichtlicher Verarbeitung in Jugendstrafverfahre disproven, either by the police or press. (Godesberg: Forum, 1998): 104. 77 Von Patrick Gensing, “Anti-Asyl-Initiativen, ” 66 Ibid, 177-207. tagesschau.de, August 10, 2015, . 69 Caroline Copley, Thorsten Severin, “Merkel’s 78 Lukas Boehnke, Malte Thran, “The Value- deputy expects Germany to get over a million refugees Based Nationalism of PEGIDA” Journal for in 2015,” Reuters, October 11, 2015, .

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79 John Welte, “Wo Bagida draufsteht, stecken 88 James Queally, Richard Winton, “Violence at Neonazis drin,” TZ, January 14, 2015, . . 2015, . 81 “This is not the Sweden we want to see,” The Local, October 20 2015, . first Pegida demonstration. From < https://commons. 82 “Arson attack attempted on planned refugee wikimedia.org/wiki/File:No_Pegida_Wien_6185_Mi- centre in Turku,” Finland Times, December 26 2015, chelides.jpg>. Licensed under the Creative Commons . deed.en>. Photo unaltered. 83 ADL, The Lawless Ones: The Resurgence of the sovereign Citizen Movement (New York City: ADL press, Page 93. Photo by Maximilian Dörrbecker. 2015. Map 2010), ; FBI, commons.wikimedia.org/wiki/File:Map_of_the_Euro- “Sovereign Citizens. A Growing Domestic Threat to pean_Migrant_Crisis_2015.png>. Licensed under the Law Enforcement,” Law Enforcement Bulletin 80, no. 9, Creative Commons Attribution-Share Alike 2.0 Ge- (2011); David Fleishman, “Paper Terrorism: The neric license. . Photo unaltered. Government,” The Public Law Journal, (2004), ; JJ MacNab, The Page 96. Photo by blu-news.org. 2015. Pe- Seditionists: Inside the Explosive World of Anti- gida Demonstration in Dresden am 05.01.2015 Government Extremism in America, (New York: St. (16084446507). From . Licenses under Racism and Religion (Downers Grove, IL: Intervarsity the Creative Commons Attribution-Share Alike 2.0 Press, 1996); Lane Crothers, Rage on the right: the Generic license. . Photo unaltered. security, (Lanham, Md.: Rowman & Littlefield, 2003); Joshua Freilich, American militias: State-level variations in militia activities (El Paso Texas: LFB Scholarly Publishing, 2003); Daniel Levitas, The terrorist next door: the militia movement and the radical right (1st ed.), (New York: Thomas Dunne Books/St. Martin’s Press, 2002). 85 For a list of incidents see: . 86 Counterterrorism Analysis Section, “Sovereign Citizens: A Growing Domestic Threat to Law Enforcement,” Federal Bureau of Investigation (Sept 2011), . 87 Mark Hamm (1993): 197.

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