‘Stand Your Ground’ Laws and Trying to Prevent the Next Trayvon Martin

From the Print Edition / Opinion   /   October 7, 2013  / 


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Image by Farragutful, via Wikimedia Commons.

There may always be intense debate about whether racial fear motivated George Zimmerman when he shot and killed Trayvon Martin in Sanford, Florida on February 26, 2012.

However, any attempt to dissect the inner workings of George Zimmerman’s mind diverts attention from the more profound problems revealed by Trayvon Martin’s death. Specifically, this tragedy highlights two crucial flaws in Florida’s legal system: 1) an ill-conceived and socially pernicious Stand Your Ground (“SYG”) law and 2) a lax and ludicrous gun control approach enabling Zimmerman—an individual with an alleged history of violence and domestic abuse1—to legally own and publicly carry firearms.2

SYG laws are not a problem exclusive to Florida—although it is undisputed that Florida’s decision to pass an “NRA-drafted” SYG law in 2005 “changed standard jury instructions, which previously held that a person had a duty to retreat by using ‘every reasonable means.’”3 Indeed, according to the National Conference of State Legislatures, “[l]aws in at least 22 states allow that there is no duty to retreat [from] an attacker in any place in which one is lawfully present.” “[A]t least nine of those states include language stating one may “stand his or her ground.””4

Although the destructive impacts of SYG laws are thus not isolated to Florida, it appears that Florida’s SYG law may have played a key role in Zimmerman’s controversial acquittal. The Miami Herald quoted a Zimmerman juror as saying that the jury found Zimmerman not guilty “based on the evidence and ‘because of the heat of the moment and…Stand Your Ground[,]’”although controversy remains as to “the degree to which Stand Your Ground led to the not-guilty verdict.”5

While trying to figure out how the Zimmerman case should have resulted in the absence of Florida’s SYG law is pointless, the fact that this law clearly may have influenced the outcome should lead us to examine what this case suggests about the future policy impacts of SYG laws.

Unfortunately, it appears that SYG laws are correlated with increased levels of lethal violence, and seem to be applied in a racially disparate manner. Given these facts, all SYG laws should be abolished immediately in order to protect the lives of our fellow Americans and eliminate a rule which appears to feed existing concerns about rampant racial inequality in our justice system.

I. The Dangerous Impact of “Stand Your Ground” Laws on Violence Levels

According to a recent Texas A&M study, SYG, or “castle doctrine,” states exhibited a “statistically significant 8 percent net increase in the number of reported murders and non-negligent manslaughters[,]” although they appear to enjoy no benefit in the form of reductions in “burglary, robbery, or aggravated assault.”6 The authors of the study go a step further by making the bold claim that “Stand Your Ground” laws cause this increase in non-negligent manslaughters and murders.7

Clearly, the issue of confusing correlation with causation is always present in sociological studies, making this conclusive statement inappropriate. However, the methodology employed by the authors and the mathematical proof provided in their paper suggests that it is more likely than not that there is, in fact, a causal relationship between SYG laws and lethal violence.

First, in terms of study design, the authors “compare[d] the within-state changes in outcomes of states that adopted laws to the within-state changes in non-adopting states over the same time period.”8 Furthermore, they “primarily identify effects by comparing changes in castle doctrine states to other states in the same region of the country by including region-by-year fixed effects.“9

Perhaps more importantly, the authors attempt to eliminate the possibility that differences in lethal violence rates between the groups of states that did and did not adopt “castle doctrine” laws were caused by the states simply experiencing different crime trends even prior to the adoption of SYG laws.10

Such a possibility seems highly unlikely given that “graphical evidence and regression results show that the outcomes of the two groups not diverge in the years prior to adoption.”11 In addition, the authors appear to have eliminated a number of possible confounding variables that could explain the differences in crime rates between the two groups of states. The authors’ results remained “robust” even when they included “time-varying covariates such as demographics, policing, economic conditions, and public assistance,” as well as when they added in “contemporaneous crime levels unaffected by castle doctrine laws [as a] proxy for general crime trends.”12

In summary, it appears that SYG states exhibit a statistically significant and larger number of violent deaths than do non-SYG states that are predominantly located in the same section of the nation. These results remain “robust” even when one considers some of the key factors unrelated to SYG laws that might drive such variation.
As such, it seems likely that SYG laws are actually responsible for producing a dangerous, negative impact on the health and safety of our society in general. Why exactly might that be? Cheng and Hoekstra help answer that question by observing that “[castle doctrine] laws reduce the expected cost of using lethal force. They lower the expected legal costs associated with defending oneself against criminal and civil prosecution, as well as the probability that one is ultimately found criminally or civilly liable for the death or injury inflicted.”13

II. Racially Disparate Application of SYG Protections

Not only do SYG laws seem to reduce the health and safety of our citizens more generally, but it does not seem that SYG protections are being applied in a fair, racially neutral manner. For example, the Tampa Bay Times conducted a survey of 200 SYG cases in Florida and found that “[d]efendants claiming ‘stand your ground’ are more likely to prevail if the victim is black. Seventy-three percent of those who killed a black person faced no penalty compared to 59 percent of those who killed a white.”14

Furthermore, the disparity in punishment under a SYG regime may actually be larger than these numbers suggest. Indeed, the Tampa Bay Times states that “[a] comprehensive analysis of ‘stand your ground’ decisions is all but impossible. When police and prosecutors decide not to press charges, they don’t always keep records showing how they reached their decisions. And no one keeps track of how many ‘stand your ground’ motions have been filed or their outcomes.”15 Given what we know about racial disparities and racial profiling, it seems probable that whites, more so than blacks, benefit from decisions not to press charges.

PBS Frontline also examined how race interacts with SYG laws. Their investigation revealed that SYG laws are correlated with a marked increase in the already massive disparity between the number of whites who are found not-guilty by virtue of self- defense after killing a black person and the number of whites who are found not-guilty by virtue of self defense after killing another white person. Specifically, “[i]n non-Stand Your Ground states, whites are 250 percent more likely to be found justified in killing a black person than a white person who kills another white person; in Stand Your Ground states, that number jumps to 354 percent.”16

Admittedly, PBS notes that “the figures don’t yet prove bias.” Indeed, the data has some weaknesses and limitations because “the data doesn’t show the circumstances behind the killings,” like “whether the people who were shot were involved in home invasions or in a confrontation on the street[,]” and because “there are far fewer white-on-black shootings in the FBI data — only 25 total in both the Stand Your Ground and non-Stand Your Ground states.”18

Despite these limitations, it is not tenable for us to simply sit and wait for more murders to provide us with more data points, so we should accept this admittedly imperfect measure as a valid approximation of reality in evaluating SYG laws. The disparities in the application of Stand Your Ground laws revealed by the Tampa Bay Times and PBS Frontline certainly help feed perceptions that we value white lives more than black lives.

Conclusion
Ultimately, the Trayvon Martin case may not matter very much in terms of what it says about George Zimmerman’s mindset and prejudices. But it should matter to us in terms of what it reveals about our society and what impacts SYG laws may have in the future. In many areas of the United States, we have condoned a legal regime that mixes SYG laws with weak gun control laws. This allows violent people like Zimmerman to gain access to firearms and reduces their fear of legal sanction should they use these firearms against unarmed individuals under the influence of their personal visions of right and wrong. In other words, the legal system of many states is currently structured to encourage violent vigilantism which may be driven by racial fears and other forms of paranoia.

This choice seems inexplicable given the clear evidence that civilians are very bad at making decisions about when to deploy lethal force. We know that “[f]or every time a gun in the home was used in a self-defense or legally justifiable shooting, there were four unintentional shootings, seven criminal assaults or homicides, and 11 attempted or completed suicides.”19 Furthermore, in life-or-death confrontations, human biological responses often result in impaired motor control and a reduced ability to perform high-level decision-making, which can make efforts to take down a “bad guy” more difficult.20 Given these, we really want a legal regime which eliminates a duty to retreat and thereby fails to encourage attempts to defuse such situations without resorting to force?

The answer to this question has to be no. George Zimmerman may not be guilty. But as long as we don’t do anything about existing SYG laws and a lax gun regime that allows alleged domestic violence abusers like Zimmerman to gain access to firearms, we are all guilty of failing to protect the next Trayvon Martin.

References
1. See Salamishah Tillet, Domestic Violence and George Zimmerman’s Defense, THE NATION (Jul. 15, 2013, 11:35 AM), http://www.thenation.com/blog/175270/domestic-violence-and-george-zimmermans-defense#.
2. See Press Release, Brady Center, Brady Campaign Statement on Verdict in Case Against George Zimmerman (Jul. 13, 2013) (“In the end, George Zimmerman’s mentality, and what emboldened him to approach Trayvon, may be debatable. What is not debatable, though, is the fact that Trayvon Martin is dead because Zimmerman had a gun. Zimmerman was given a concealed carry permit by the state of Florida despite an arrest record and a history of violence, as a direct result of the influence of the gun lobby, and if it weren’t for that, this tragedy never would have happened.“), available at: http://www.bradycenter.org/?q=brady-campaign-statement-on-verdict-in-case-against-george-zimmerman.
3. See Caputo, Mark, Juror: We talked Stand Your Ground before not-guilty Zimmerman verdict, MIAMI HERALD, Jul. 18, 2013, http://www.miamiherald.com/2013/07/16/3502481/juror-we-talked-stand-your-ground.html.
4. Self Defense and Stand Your Ground, NATIONAL CONFERENCE OF STATE LEGISLATURES, http://www.ncsl.org/issues-research/justice/self-defense-and-stand-your-ground.aspx.
5. See Juror.
6. Cheng Cheng & Mark Hoekstra, Does Strengthening Self-Defense Law Deter Crime or Escalate Violence? Evidence from Expansions to Castle Doctrine, forthcoming in JOURNAL OF HUMAN RESOURCES, available at: http://econweb.tamu.edu/mhoekstra/castle_doctrine.pdf.
7. See id. at 4.
8. See id. at 1−3.
9. Id. at 3.
10. See id.
11. See id.
12. See id. at 3, 28.
13. Id. at 1.
14. See Kris Hundley, et al., Florida ‘Stand your ground’ law yields some shocking outcomes depending on how law is applied, TAMPA BAY TIMES (June 12, 2012), available at: http://www.tampabay.com/news/public-safety/crime/florida-stand-your-ground-law-yields-some-shocking-outcomes-depending-on/1233133.
15. Id.
16. Sarah Childress, Is There Racial Bias in “Stand Your Ground” Laws?, FRONTLINE (Jul. 31, 2012), available at: http://www.pbs.org/wgbh/pages/frontline/criminal-justice/is-there-racial-bias-in-stand-your-ground-laws/.
17. Id.
18. Id.
19. Kellerman, Al, et al., Abstract, Injuries and Death Due to Firearms in the Home, 45 JOURNAL OF TRAUMA, 263−7 (1988), available at: http://www.ncbi.nlm.nih.gov/pubmed/9715182.
20. Amanda Ripley, Your Brain in a Shootout: Guns, Fear, and Flawed Instincts, TIME, (Jan. 16, 2013), available at: http://swampland.time.com/2013/01/16/your-brain-in-a-shootout-guns-fear-and-flawed-instincts/.

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16 Responses to ‘Stand Your Ground’ Laws and Trying to Prevent the Next Trayvon Martin

  1. The penultimate example of liberal bullshit drivel (not that the entire commentary is not full of nonsense and erroneous conclusions):

    “civilians are very bad at making decisions about when to deploy lethal force. We know that “[f]or every time a gun in the home was used in a self-defense or legally justifiable shooting, there were four unintentional shootings, seven criminal assaults or homicides, and 11 attempted or completed suicides.”19 Furthermore, in life-or-death confrontations, human biological responses often result in impaired motor control and a reduced ability to perform high-level decision-making, which can make efforts to take down a “bad guy” more difficult.”

  2. As usual, Harvard is pimping for the liberal cause by using falsehoods, etc. Zimmerman was NOT a Stand your Ground matter – it was a self defense matter.

    • Jonathan Maginn

      He actually addressed that point. The jurors mentioned that SYG was a factor in their decision-making process. As to how much a factor, that’s pretty much impossible to prove, but if it was a factor, then clearly it was at least a piece of the matter.

  3. Ah, the deranged musings of the liberal mind.

    If one’s life is threatened, one should be able to defend it without “retreating”. Period. Stand your ground laws do far more good than evil.

    All that said, the TM case didn’t involve “stand your ground” at all. GZ had no opportunity to retreat, he was being assaulted and his head smashed into concrete. Your invocation of “stand your ground” in relation to the GZ trial is called a “straw man”.

    Finally, regardless of GZ’s past, there was absolutely no indication he did anything improper the night TM lost his life. As best we can tell, TM made the unfortunate decision to backtrack and attack GZ. Was it the drugs? Poor upbringing? Stupidity? We will never know – but it is truly unfortunate that TM never had a chance to turn his life around.

    • ONE juror used the words “stand your ground.” She also said that she had no regrets about the acquittal and would do it again.

  4. Guy who actually watched the trial

    What a strange article. It repeatedly admits the errors in the statistics it uses, or acknowledges that they don’t actually support the conclusions being drawn, but proceeds to use them anyway. Did you consider the possibility that white-on-black SYG claims are more successful than black-on-white ones not because of racism, but because white people are more likely to have actually been threatened and standing their ground? After all, that would fit perfectly with what we know about the racial breakdown of violent crime.

    Why is this article even focusing on black versus white when Mr. Zimmerman is Hispanic? And please don’t feed me the liberal media canard about “white Hispanic.” President Obama is just as white as Zimmerman, yet nobody says “the first black and white president.”

    I’m also curious what gun control measure you want to prevent people who are merely accused of domestic violence (or any other crime) from exercising their Constitutional right to own a gun. Seeing as Zimmerman was never convicted of any crime, there is no legal justification for depriving him of his rights. Still, it’s funny how you moralize about his firearm while ignoring the fact that Trayvon’s phone held a photo of himself holding a handgun that was actually illegal for him to possess.

    Racebaiters just don’t understand that they’ve lost all credibility to opine about this case. The jury unanimously acquitted Zimmerman. The prosecutor is facing an ethical probe for lying under oath. The prosecutor’s IT employee was illegally retaliated against (fired) for blowing the whistle about the suppression of exculpatory evidence that should have been turned over to the defense. The medical examiner is suing the county for illegal retaliation, after being fired for giving testimony that the prosecutor didn’t like at trial. Multiple mainstream news organizations are being used for defamation after they were caught red-handed editing the 911 tapes to make Zimmerman sound racist. The federal government will be forced to return Zimmerman’s gun, as they obviously have no basis to file “hate crime” charges.

  5. Uh, Robert.
    Zimmerman didn’t raise the stand your ground defense.
    Therefore your whole article is nonsensical….but lets’ not quibble.

    You assert at the outset…”There may always be intense debate about whether racial fear motivated George Zimmerman when he shot and killed Trayvon Martin…”

    What was proven court….someplace you may get to watch real lawyers at work one day…was that Zimmerman shot Martin when Martin was sitting astride him bashing his head into the concrete. Intense yes, but nothing racial there.

    Uh, Robert?
    If retreating is a good thing…why didn’t Martin do so? Why did he confront Zimmerman after circling back….you know, like they proved in court?
    Here is the scoop….this was Zimmerman’s home and community and Zimmerman had every right to drive, walk, watch, and talk to anyone he darn well pleased. Martin had the same right. BUT the minute that little thugee knocked Zimmerman down, sat on him, and started banging his head into concrete til it bled and then broke his nose…..Martin crossed the line and death found him there. It is called self defense, not stand your ground….but gee, a it is new legal theory…only been around since the 3rd millennium BC….and still used in the courts of FL after all these years. Wonder why?

    BTW…..with SYG, statistically more blacks proportionally WILL be killed than whites, whether by whites or blacks. Why? Because blacks commit, statistically, more numerous violent attacks on BOTH whites or blacks than whites, or Asians, or Hispanics.

  6. Skippy Thedread

    Failing to protect the next Trayvon Martin?

    You obviously didn’t watch the trial because the only thing the state proved is that Trayvon Martin was guilty of assault and possibly attempted murder.

    Had he survived the gunshot he would have been arrested.

    And, sorry, all those social science studies are made up BS. Didn’t Barack and Michelle go to Harvard Law, lol?

  7. What drivel.

    First, or a moral basis, no one should have to abandon their home or their property to someone intent on taking it. You ask, “is a TV worth killing someone?” The answer is clearly yes. That’s because it’s not about the TV, it’s about the sanctity of your home and personal belongings. Once you acquiesce to something like a TV, then there will be something else more valuable next. Where does it stop? Should a person stand by and be robbed of all their possessions merely out of respect for the life of the perpetrator? A coward would say yes.

    As far as the increase in murders, what the disingenuous author doesn’t tell you is that the increase in deaths is due to the deaths of the perpetrators. Anyone watching will notice that home invaders are being dispatched with regularity. Murder is a justifiable action when threatened. The difference is that with SYG laws, you are not obligated to run and hide the corner of the bedroom and wait until the come for you when you are at your most disadvantaged. Taking out the perp on your terms or as close to it as you can is by far the preferred action.

    Lastly, the so-called racial disparity…this is an exercise in deception. The fact is the Blacks are invoking and being acquitted on the basis of SYG laws far more than whites are. Their so-called victims? Other Blacks. Just weeks before the Zimmerman trial a Black man was acquitted of the murder of another Black man based on SYG. We didn’t heard about it because no one wanted to admit that the law is not racist, nor it its application.

    The bottom line is that this screed is just another example of the twisted and degenerate thoughts of a future Democrat official being vomited onto the nearest sympathetic pages and being sprayed with the fraudulent odor of academia.

  8. If this is the type of false reas0ning being taught at Harvard Law, the people had better be careful of such lawyers in the future.

    The truth is that Stand Your Ground was not a defense in the trial., Your entire premise and conclusions are the result of ignorance or deliberate fiction.

    Pleasing your liberal professors is not the real world.

  9. Why is the author so obsessed with Zimmerman’s supposed history violence, especially the absurd child molestation claims made after the fact by a person who is clearly mentally disturbed and lacking credibility, but completely silent about Trayvon’s history of crime and violence–including randomly punching a bus driver in the face for no reason, attempting to buy an illegal gun via text message, stealing women’s jewelry (for which he was suspended from school), and being in a fight club? Trayvon bragged about being a “gangsta” (his word, not mine) on Twitter, so why are liberals telling us that he was actually an upstanding honor roll student who would never hurt a fly?

  10. Larry hit the nail on the head. The study cited uses “murder” interchangeably with “homicide,” so that murderous thugs killed by victims in self-defense become “murder victims.” It’s all about the medical model of considering wounded or dead thugs as “victims.” IMHO, dead thugs are a boon to society, not a problem that needs correcting.

    Also, as Dane points out, blacks are disproportionately the “victims” of such defensive shootings for the simple reason that they are disproportionately the perpetrators of violent felonies. Perhaps it has to do with the notion, as exemplified by the views of the Jesse Jacksons and Al Sharptons, that African-Americans are the “victims” of past slavery and present racial discrimination. This produces a perceptual filter in which the actions of non-blacks in general and whites in particular are viewed as being motivated by racial animus. The result is that some blacks react with violence to their perceptions of being “dissed” by whites, or view theft and violence against whites as somehow justified in retaliation for slavery and discrimination. If the black community can’t get past this barely suppressed institutional rage, the carnage will continue.

  11. If the author’s mindset is prevalent in legal circles, this country is in bigger trouble than I thought.

    The Left has been against SYG even before it was enacted as it empowered the citizen and not the State. During the debate in Florida, they set the tone by having the Brady Bunch at airports handing out flyers warning tourists not to approach locals as they might get shot by edgy Stand Your Grounders. (We are not dealing with ethical people here.)

    When the Martin-Zimmerman case broke, the Left attempted to get the ball rolling to repeal the law by using their sock puppets in the media, under the smoke screen of racism. Unfortunately for them, it backfired when the Race Hustlers got out of hand and completely overshadowed them.

    The aim then, as now, is to repeal the law so liberal judges in SYG states can use the repeal as “precedence”, dismantle it in their jurisdictions and prevent it from being enacted. Al “bullhorn” Sharpton inferred that when he let the cat out of the bag, saying that if the law could be repealed in Florida, it could be repealed in other states.

    All stand your ground laws do is codify a constitutional right that already exists in order to make it harder for a prosecutor to deny your right to self-defense. Those against SYG want you to depend upon the good will of the person attacking you – in effect, replacing it with OTD (Obligation To Die).

  12. Its seems that the prospect of getting shot and killed if you decide to sucker punch someone then beat them sensless on the ground for the next 45 seconds is a good way of preventing the next Trayvon MArtin….

  13. The study failed to correctly identify true SYG ground states.

    See for example, here:
    http://www.volokh.com/2013/07/17/duty-to-retreat/

    In point of fact, many states were “stand your ground” *at common law* way before the self defense statues were written. Illinois for example was SYG at common law at least as far back as the early 1900s, but the defense was only codified into statute in the 1950s. Illinois v. Harris, 260 N.E. 2d 325, 329 (Ill. App. Ct. 1970): “The State has cogently pointed out that Illinois has not required retreat for the right to self-defense since the case of Hammond v. People, 199 Ill. 173, 64 NE 980 (1902).”

    At noted, on Volokh, 31 (not 22) states are SYG states. Vermont is a SYG at common law (google the Vermont model jury instructions, as approved by the state courts, they impose no duty to retreat).

    Some states, like Maryland (where self defense is also at common law), are considered “duty to retreat” but the reality is somewhat different: the model jury instructions say you have no duty to retreat if you are being robbed. You can repel force with force.

    Bottom, the study and this article are garbage. A real criminal defense attorney will tell you self defense is far more nuanced.

  14. Wow.. all this from Harvard. No wonder it turns out varmints like Barak Insane Obama. Truth is it turned out Felix Frankfurter as well and he, not just a Supreme Court Justice, was a devout Communist. No wonder we are having issues with activist judges that will not obey the Constitution but seem just fine in perverting it. The Constitution states that every judge is bound by it but hey, don’t let that “progress” get slowed by out dated provisions. Never mind that there is a Lawful method of amending the Constitution. Of course these sneak thieves would not make open statement in public because they People would demand their heads. Instead they violate the law while the cry that they represent the Supreme Law of the Land, as long as they get to do it their way. Obviously they are criminals. Poor Joe McCarthy was dead on point and too bad he did not live to see his warning vindicated.

    But I digress…. Stand your ground is just plain old self-defense. The law does not have to exist, it is a fundamental liberty the right of every human being on the face of the earth. The only reason that such a law was instituted is because self-defense had become encroached upon that the individual was constrained by laws that favored an attacker. This faulty line of reasoning fly’s in the face of assumption of risk. The attacker assumed the risk when they broke the law. Do you think the police have a duty to retreat??? Hell no! If a person takes part in a felony and someone dies as a result they are or can be charged with murder as well. Why is it that the citizen is made to bear the humiliation and injury of an attack upon their person before they may respond with a defense? This gives the attacker a free pass, if you happen to die from just the first right blow to the head no one even knows why. I work in a place that is frozen for long periods. A fellow some time ago fell and hit the back of his head, he merely slipped on the ice, he died on the spot.

    George Zimmerman had his head repeatedly bash onto the concrete. Any one of those blows could have been the one, it was not. He was over powered and could not escape his attacker. After repeating a call for help that did not come, he did the only thing he could do when it seemed his attacker was relentless and did not appear that he was going to cease the attack, he fired one shot into his attacker. This was not a “stand your ground” incident, this was defend your life. There was no way for George to escape. Even in “Duty to Retreat” jurisdictions all the elements were present to support Zimmerman’s actions. Martin lost Zimmerman and decided to return and confront the man who was merely watching. There are neighborhood watches in Russia. Police organize neighborhood watches in many parts of the country, it is a lawful activity and Zimmerman did nothing wrong, he did not attack Martin it was the other way around.

    If there is some otherworldly reason Black people, or anyone for than matter, should get a free pass to commit assault and battery because their perception is that they are being targeted, then they need to change their perception. If someone acting on their false presumption creates the very condition that are their perception and presumption I am not to blame. The responsibility lies with the individual whose stilted perception instills in them the impetus to do physical violence on an innocent person. This is called a violent psychological disorder. I am not the cause of their negative condition. Evidently a persecution complex is worthy of a free pass on committing assault and battery. In some cases it has resulted in loss of life and permanent disability. In what world is this OK????

    If you attempt to attack me for exercising my freedom, I will respond with the force necessary to repel or neutralize the attack. I am trained in several open hand disciplines, I am able to adapt almost any common articles to a weapons role. I practice situational awareness all the time, I can walk up on deer and animals in the wild. I am a certified firearms trainer and a very good shot I am armed in all lawfully permissible places, always. Some people would say that I am inviting a confrontation by being so prepared. I say what fool will not prepare themselves in such a violent world. It appears illusion and delusions are the qualities of the current culture, I say that they are fruits of a mind in denial.

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