The Sandinista Revolution and the “Fifth Freedom”

This month will mark the 25th Anniversary of the overwhelmingly successful Literacy Crusade spurred by the Sandinista Revolution. This article examines the various programs implemented during the revolution, the US reaction to the revolution, and Nicaragua’s present situation.


FSLNOn July 19, 1979 a broad-based popular revolution, inspired by the legacy of Augusto Cesar Sandino and led by the Sandinista National Liberation Front (FSLN), overthrew the US-supported Somoza dictatorship in Nicaragua.  The Sandinistas inherited a country ravaged by a ruthless dictatorship of more than 40 years that accumulated massive debt and a revolution that took the lives of more than 50,000 people.  The Sandinista philosophy was to govern by the “logic of the majority.” As a 1984 Latin American Studies Association election delegation put it, “Nicaragua’s poor majority would have access to, and be the primary beneficiaries of, public programs.”1 That, of course, signaled alarms in Washington.

The social programs of the Sandinistas were truly quite remarkable, all the more so because they were carried out in the face of economic warfare and a campaign of terror waged by the United States.  Upon taking power, the Sandinistas implemented welfare, health, education, agrarian, and housing programs to improve the quality of life for Nicaragua’s people.  The vast property holdings of the Somoza family were confiscated and turned into state farms and cooperatives with the intent of making the country more self-sufficient in food production.  More importantly, peasants were provided access to land, and large-scale agricultural estates were limited in size, which also significantly restricted the power of the agro-export elites.2 Sandinista agrarian policies “redistributed more land . . . to dispossessed campesinos . . . than all other Central American countries together in the course of their entire history”3 According to the Inter-American Development Bank, the Sandinistas were “laying a solid foundation for long-term socio-economic development.”4 Within a few years, the policies of the Sandinistas yielded positive outcomes.  From 1979 through 1983, Nicaragua’s GDP per capita grew 7% while that of its neighbors as a whole declined more than 14%.5

Adelante Brigadistas!On the education front, more than 739 schools were built in the first two years, mostly in rural areas.6 The Literacy Crusade gained international prominence because, through the mobilization of 80,000 volunteers, it significantly reduced the adult illiteracy rate and intended to prepare the poor to become “genuine authors of development,” resulting in Nicaragua earning the UNESCO 1980 literacy award.7 A massive health campaign began as well.  Similar to the Literacy Crusade, volunteers carried out preventative health programs.  Polio, diphtheria, measles, and tuberculosis were either eliminated or greatly reduced.  During this period, the National Unified Health System was created with the intention “to make government health care open to all.”8 Infant mortality was significantly reduced, leading UNICEF to praise Nicaragua for “one of the most dramatic improvements in child survival in the developing world.”9 Even the Reagan-appointed Kissinger Commission had to concede that “Nicaragua’s government has made significant gains against illiteracy and disease.”10

Mother Earth, Children's Hospital, Nicaragua (1989)

“Mother Earth,” Children’s Hospital, Nicaragua (1989)

A Nicaraguan Social Security and Social Welfare Institute (INSSBI) was established.  Senior care facilities, foster homes, rehabilitation centers, and nutrition programs beneficial for mothers were built, highlighting “the Sandinista commitment to the society as a whole.” The proportion of the population covered under these programs was five times larger than under Somoza. Despite the country’s limited resources and constant US attacks, coverage went from 202,518 people in 1979 to nearly two million in 1989.11

Along with the mass participatory social campaigns, government institutions were democratized.  National elections, four interdependent government branches, and a multiparty political system were created.  Susanne Jonas and Nancy Stein note that the Law of Political Parties, for the first time in Nicaraguan history, guaranteed opposition parties a competitive role rather than a cooperative role with the government.  Moreover, a system of proportional representation was implemented to provide smaller parties a voice.  The Constitution guaranteed, similar to the US, the right to free speech, assembly, counsel, and religion.  However, in contrast to the US, it also guaranteed the right to education, health care, social security, housing, and a sustainable environment.12 Even though the Sandinistas were being terrorized by a military superpower, they were still able to conduct elections in 1984 and 1990 that were recognized by international observers as fair and legitimate.  Moreover, the political spectrum of candidates was much broader than in other countries in the region and even the US.13

On the international level as well, the Sandinistas broke new ground.  Nicaraguan foreign policy would no longer be captive to US mandate.  According to Harry Vanden and Waltraud Morales, “Greater diversification in diplomatic and economic relations was sought as a way to achieve the new national goals.” The principles included nonalignment, anti-imperialism and participatory democracy.14

US Reaction

From the beginning, Washington was determined to destroy the Sandinista revolution. After hearing Secretary of State Alexander Haig describe US policy toward Nicaragua before a House Foreign Affairs Committee, one Congressperson declared, “If I were a Nicaraguan, I’d be building a bomb shelter this afternoon.”15 The US reaction to the revolution is reflective of its historical relations to Nicaragua.  Furthermore, it illustrates the threat the US felt to the legitimacy of its own institutions.

In an effort to deter the Sandinista’s successful social programs and institutional policies from benefiting the poor majority, the US conducted a multifaceted program of military and economic warfare against the Nicaraguan population with the intent to destroy the programs and overthrow the government.  According to Noam Chomsky and Edward S. Herman, the reasons the US opposed the Sandinista government “were based more on its virtues than on its alleged defects.”16 The Sandinistas were showing an alternative to the institutional framework of capitalism that was efficient, popular and more equitable.  The Reagan Administration found it unacceptable that the Sandinista government “had rather successfully portrayed itself as an open and democratic society and thus gained a good deal of support in world public opinion,” says former CIA analyst David MacMichael.17

There was only one problem for the Reagan Administration: Nicaragua was not a military threat to the US, nor did Washington have any plausible justifications to intervene in the country.  In an effort to portray the Sandinistas as a threat, as well as justify intervention, the Reagan Administration used all available resources and set up three fronts to conduct their battle: military, economic, and mass media/propaganda.  The military (and part of the economic) aspect of the battle was conducted by the CIA and the contras, a proxy army of Nicaraguan exiles organized by the US.  The objective was to have the contras “fit the facts to fit the policy,” in the words of Senator Fulbright.18 To Reagan, the contras provided a means to destabilize and discredit the Sandinista revolution by weakening the regime’s ability to govern as well as undermine its image internationally.19 As Chomsky notes, if the US could not achieve all of its objectives, “then at least [it] must ensure that no successful social and economic development can take place there; the rotten apple must not be allowed to infect the barrel.”20

The ideological framework for the intervention in Nicaragua was outlined in a 1979 article by former Democrat turned neoconservative Jeane Kirkpatrick titled “Dictatorships and Double Standards,” which later became a book.21 The article centered around her critique of President Carter’s foreign policy and the difference between “authoritarian” and “totalitarian” governments.  Kirkpatrick declared her support for ruthless dictators like Somoza and the Shah of Iran because they were anti-Communist and “regularly supporting American interests and positions even when these entailed personal and political costs.” She categorized the two dictators — “who had not been selected by free elections . . . and occasionally . . . torture[d] their opponents” and “relied for public order on police forces whose personnel were said to be too harsh, too arbitrary, and too powerful” — as “traditional rulers.”22 She claimed that “right-wing autocracies . . . sometimes evolve into democracies” and “are more compatible with U.S. interests.”23 Kirkpatrick argued that “traditional autocrats tolerate social inequalities, brutality, and poverty” while “revolutionary autocracies create them.” Although these “traditional rulers” are criticized for “violating civil and human rights,” they do not “disturb the habitual rhythms” of life — most importantly, the distribution of wealth and resources that favor an elite minority.24 To Kirkpatrick, this is an excellent quality “because the miseries of traditional life are familiar, they are bearable to ordinary people who, growing up in the society, learn to cope [and] acquire the skills and attitudes necessary for survival in the miserable roles they are destined to fill.”25

The contras were a result of Kirkpatrick’s ideology.  Their purpose was to punish the Sandinistas for disturbing the “habitual rhythms” of US hegemonic interests.  Chomsky describes the essence of US interests as the “Fifth Freedom,” based on Franklin Delano Roosevelt’s Four Freedoms: freedom of speech and worship, freedom from want and fear.  The “Fifth Freedom” — “the freedom to rob, to exploit and to dominate, to undertake any course of action to ensure that existing privilege is protected and advanced” — is left unmentioned in official discourse, and yet it is the most important to Washington.26 Reagan’s policies toward Nicaragua illustrated that “it is only when the fifth . . . freedom is threatened that a sudden and short-lived concern for other forms of freedom manifests itself, to be sustained for as long as it is needed to justify the righteous use of force and violence to restore the Fifth Freedom, the one that really counts.”27 To the Reagan Administration, the Sandinistas violated the “Fifth Freedom,” by seeking to eliminate the institutions that perpetuate the “habitual rhythms” of class exploitation and polarization.  David Forsythe contends that despite public statements to the contrary, it was “completely irrelevant to the [Reagan] Administration that the Sandinistas had shown far more concern for real rights, including socio-economic rights, than the previous Somoza dynasty” or most countries in the region.  “References to human rights and collective self-defense were essentially belated and secondary efforts to develop a public rationale for the real policy objective . . . [dismantling an alternative to the US model] . . . not because of an intrinsic interest in rights.” This explains why “the increasing degree of democracy did not lead to a decreasing amount of violence against it orchestrated by the USA.”28

:From its inception,” explains Peter Kornbluh, “former officials of Somoza’s widely despised Nicaraguan National Guard dominated the [contras] leadership.”29 According to an Americas Watch report, the contras practiced “terror as a deliberate policy,” implementing a strategy of assassination, torture, rape, kidnapping, and mutilation against the population.30 When Reagan felt that the contras were not doing an adequate job, he had the CIA perform the operations. By 1982, “U.S. operatives assumed direct command and control of the paramilitary campaign.”31 US leadership turned the contras from a band of malcontents launching largely ineffective attacks to a ruthless force capable of better coordinated terrorist operations.

However, the contra/CIA terrorist attacks on Nicaragua were more than just a military strategy; they were also intended to damage the Nicaraguan economy.  The CIA prepared a manual for the contras that provided instructions for numerous methods of economic warfare with the goal of “paralyzing” the Nicaraguan economy. Along with oil facilities, the contras  blew up “key bridges and attacked industrial plants, fishing boats, agricultural cooperatives and private farms, health clinics and hospitals, schools, childcare centers, and food storage facilities.”32 The Reagan Administration was deliberately attacking the popular and successful institutions developed by the Sandinistas.  According to one contra defector, “We attack a lot of schools, health centers, and those sorts of things.  We have tried to make it so that the Nicaraguan government cannot provide social services for the peasants, cannot develop its project . . . that’s the idea.”33 The economy was the greatest weakness of the Sandinistas and the Reagan Administration “consciously focused upon that vulnerability,” argues Michael Conroy.  In addition to the strategic military attacks on the economic infrastructure, the US eliminated all bilateral funding and aid while blocking loans and grants from international lending institutions.  Moreover, Washington imposed a trade embargo on Nicaragua. As the “economic aggression” increased, the Sandinistas were forced to concentrate more resources on defense and the military.  In 1980, social services constituted half of the national budget while defense spending accounted for less than 20 percent. By 1987, those numbers reversed.34 Conroy concludes that “One whole generation of younger Nicaraguans and the best of the older generations were seeing their lives allocated to defense against the contra.”35

In addition to the economic and military war, there was also a media/propaganda war, primarily conducted by the State Department’s Office of Public Diplomacy for Latin America and the Caribbean (S/LPD).  Seemingly housed in the State Department, S/LPD was in fact directed by the National Security Council.  The S/LPD was considered by a US official as “a vast psychological warfare operation of the kind the military conducts to influence a population in enemy territory,” where the enemy was not Nicaraguans but the US public (and occasionally Congress).36 The S/LPD flooded the media with reports, op-ed pieces, leaks and speeches that contained lies and misinformation.  Despite the fact that most of the charges were disproved, allegations put forth by the administration, no matter how exaggerated, were constantly being reinforced by the S/LPD and amplified by the mainstream media.  More importantly, it allowed Reagan to set the agenda of debate as well as its limitations.  According to Eldon Kentworthy, “The administration staked out that privileged place in American political discourse of offering the only reasonable option bracketed by two unacceptable choices.”37 By exploiting the fears of a post-Vietnam public that did not want to commit US troops, the administration claimed that the only alternative was supporting the “freedom fighters,” as Reagan preferred to call them.

Despite the administration’s full frontal assault on Nicaragua, most of the US public did not see eye to eye with the president.  In his autobiography, Reagan lamented, “For eight years the press called me the ‘Great Communicator.’ Well, one of my greatest frustrations during those eight years was my inability to communicate to the American people and to Congress the seriousness of the threat we faced in Central America.” Reagan was not able to rally enough concern that the Sandinistas were governing by the “logic of the majority.” Nor was he able to clearly describe the threat that the Sandinistas agenda “meant that Nicaragua’s poor majority would have access to, and be the primary beneficiaries of, public programs.” He really did not need to, Congress was there for him (most of the time) to provide his “freedom fighters” with military, economic and political support.  The few times Congress did not obey orders, Reagan merely depended on his “international terrorist networks of mercenary states”38 like Saudi Arabia and Israel to take up the slack in assaulting Nicaragua.  Moreover, the Reagan Administration did exactly what they publicly accused Nicaragua of doing, such as engaging in terrorism, drug trafficking, and abrogating international law.

Ronald Reagan would not see his dream fulfilled during his presidency; he would have to wait until 1990.  On February 25 of that year, the Sandinistas were defeated by the US-financed National Opposition Union (UNO) in the national elections.  After more than 10 years of terrorism and economic strangulation, the citizens of Nicaragua gave in to US aggression.  According to US lawyer Paul Reichler, who represented the Nicaraguan government, “Whatever revolutionary fervor the people once might have had was beaten out of them by the war and the impossibility of putting food in their children’s stomachs.”39 While the Sandinista institutional development was popular and benefited the majority of the population, stability and the need for food were the primary concerns due to a decade of US terror.  Reagan Administration policy towards Nicaragua supports Jeane Kirkpatrick’s assertion that “small bands of men who possessed the instruments of government could wreak mayhem and murder on large populations.”40

Neoliberal Nicaragua

Brett Kaffee, Neoliberal Nicaragua

Photo by Brett Kaffee

Brett Kaffee, Neoliberal NicaraguaFollowing the defeat of the Sandinistas, the US did not hesitate to restructure the institutional framework of Nicaragua that supported the “habitual rhythms” of class exploitation and marginalization.  The US Agency for International Development (USAID) Strategy Statement would provide a blueprint for dependence on the neoliberal path in Nicaragua.  The strategy intended to bring “major transformation” to Nicaragua’s institutions through privatization reforms.41 Rather than rely on traditional forms of coercive repression, the US imposed an “international economic straitjacket” on Nicaragua.  Structural adjustment programs favored “exporters, large-scale producers, and commercial and financial conglomerates tied to transnational capital.” Numerous “free-trade zones” were set up around Nicaragua to provide low-wage, non-union workers to transnational corporations free of tax.42 According to Central American activist Toni Solo, the economic institutions were a throwback to the Somoza era and small farmers were hurt because the state denied them credit and subsidies.  More than 300 small state enterprises were privatized between 1990 and 1995.  The state immediately reduced spending on health care, social services, education, and public wages and also issued massive layoffs.  Wages were frozen while basic prices rose, and since 1990, the cost of water and electricity has increased fivefold.  Now, more than 60% of the population live on less than two dollars a day.43

Brett Kaffee, Neoliberal NicaraguaNicaragua neoliberal foreign policy practiced Somoza-style subservience to the US.  This was apparent in 1991 when Nicaragua, at the behest of the US, withdrew its International Court of Justice suit that demanded $12 billion in reparations from the US.  In 1986, the World Court had condemned the US for their “unlawful use of force” (or what is simply described as terrorism) against Nicaragua, which the US disregarded.  Five years later, the domestic elites disregarded it as well.44

The political institutions became (and still are) the most unstable in Nicaragua. Following the Sandinista defeat, the US, once again, imposed its influence to create political stability suitable to their interests and ideology.  According to Frederick S. Weaver, this meant a political democracy acceptable to the US and Nicaraguan possessing classes: “an electoral political system without substantial changes in extant patterns of social power.” Or more properly stated, “‘Somozaism’ without Somoza”45, the same policy the US had tried to impose shortly before the Sandinistas took power.

Brett Kaffee, Neoliberal NicaraguaThe elections have been manipulated to favor US-puppet regimes, which is why leaders since the 1990s have received limited support and legitimacy.  The biggest obstacle to US hegemony over Nicaraguan institutions, however, are the majority of Nicaraguans.  One of the great Sandinista legacies was politicizing the majority of the population to become “genuine authors of development.” The US and domestic elites wanted to restructure the value system established by the Sandinistas and tried to do this by assaulting the education system.  USAID provided funds to replace textbooks, and the Education Minister had the old ones burned.  The new schoolbooks began with the Ten Commandments and emphasized order and “obedience to parents and legitimate authorities.”46 Overall, the goal was for “a depoliticalization of the population, to eclipse the more militant grass-roots social movements, and to incorporate key sectors into an emergent historic bloc under the hegemony of a reconstituted private sector.”47

Brett Kaffee, Neoliberal NicaraguaAccording to the 2005 CIA World Factbook, Nicaragua is one of the poorest countries in the Western Hemisphere that “faces low per capita income, massive unemployment, and huge external debt.  Distribution of income is one of the most unequal on the globe.” In addition, “While President Bolanos enjoys the support of the international financial bodies, his internal political base is meager.” Without any sense of irony, the CIA credits this result to its “successful performance under its International Monetary Fund policy program and other efforts . . . .” 48 In short, the bleak state of affairs in Nicaragua is due to its institutions functioning correctly.

Brett Kaffee, Neoliberal NicaraguaOne Red Cross worker has noted, “They’re trying to erase the Sandinista years.”49 Comparing the priorities and achievements of the Sandinistas to conditions in Nicaragua since 1990, the statement seems quite accurate.  Poverty and treatable diseases are rampant, infant mortality and illiteracy rates have risen and access to primary education, despite its universal pretext, is more difficult due to IMF imposed “user fees.” Additionally, Nicaragua now rivals Haiti in the unenviable distinction of being the Western Hemisphere’s most destitute nation.50 Post-Sandinista Administrations have consistently dismantled or undermined social programs that empower the majority of Nicaraguans, who, consequently, are also the most vulnerable.51  The neoliberal policies that eroded the institutional structure developed by the Sandinistas supports Toni Solo’s assertion that “the hopes of the poor majority for a decent life have disappeared.”52 The Central America Free Trade Agreement (CAFTA) seeks to make matters worse.  As one Nicaraguan lawyer has lamented, “The situation in Nicaragua now is one of despair.”53 Unfortunately, this is irrelevant to the US/international corporate community; what matters most to them is that the “Fifth Freedom” is alive and well.

Brett Kaffee, Neoliberal Nicaragua


[The photographs of neoliberal Nicaragua are all courtesy of Brett Kaffee. — Ed.]

1 LASA delegation cited in Noam Chomsky, Turning the Tide: U.S. Intervention in Central America and the Struggle for Peace (Cambridge: South End Press, 1985), p. 82. Book hereafter cited as Tide.

2 Jon Jonakin, “Agrarian Policy,” in Thomas W. Walker (ed.), Nicaragua without Illusions: Regime Transition and Structural Adjustment in the 1990s (Wilmington: Scholarly Resources, 1997), p. 98. Book hereafter cited as Illusions.

3 Andrew Reding, “Nicaragua’s New Constitution: A Close Reading,” World Policy Journal 4.2 (Spring 1987).

4 Bank cited in Noam Chomsky, Hegemony or Survival: America’s Quest for Global Dominance (New York: Metropolitan/Owl, 2003), p. 98.  Book hereafter cited as Hegemony.

5 Walker, Illusions, p. 9.

6 Harvey Williams, “The Social Impact in Nicaragua,” in Thomas W. Walker (ed.), Reagan Versus the Sandinistas: The Undeclared War on Nicaragua (Boulder: Westview Press, 1987), p. 249.  Book hereafter cited as Reagan.

7 Holly Sklar, Washington’s War on Nicaragua, (Cambridge: South End Press, 1988), pp. 37, 43.

8 Williams, op. cit., p. 249, 252.

9 UNICEF cited in Chomsky, Hegemony, p. 98.

10 Kissinger Commission cited in Walker, Illusions, p. 9.

11 See Williams, op. cit., p. 250, 258 and Karen Kampwirth, “Social Policy,” in Illusions, p. 116.

12 Susanne Jonas and Nancy Stein, “The Construction of Democracy in Nicaragua,” Latin American Perspectives 17.3, 1990, p. 15, 21.

13 For a comprehensive examination of the 1984 Nicaraguan elections, see Edward S. Herman and Noam Chomsky, Manufacturing Consent: The Political Economy of the Mass Media (New York: Pantheon Books, 1988, 2002), Ch. 3.

14 Harry E. Vanden and Waltraud Queiser Morales, “Nicaraguan Relations with the Nonaligned Movement,” Journal of Interamerican Studies and World Affairs 27.3, 1985, p. 146.

15 US Representative quoted in Sklar, op. cit, p. 95.

16 Herman and Chomsky, op. cit., p. xiii.

17 MacMichael quoted in Sklar, op. cit., p. 99.

18 Fulbright quoted in Sklar, op. cit., p. 57.

19 Peter Kornbluh, “The Covert War,” in Reagan, p. 23.

20 Chomsky, Tide, p. 71.

21 Jeane Kirkpatrick, Dictatorships and Double Standards (New York: Simon and Schuster, 1982). Quotes featured in this paper are from the book, not the article.

22 Kirkpatrick, op. cit., pp. 24-25

23 Kirkpatrick, op. cit., pp. 32, 49. Emphasis mine. Note that it is irrelevant to Kirkpatrick if the autocracies decide to democratize.

24 Kirkpatrick, op. cit., pp. 25, 49.

25 Kirkpatrick, op. cit., p. 50.

26 Noam Chomsky, The Culture of Terrorism (Cambridge: South End Press, 1988), p. 1.

27 Chomsky, Tide, p. 47.

28 David Forsythe, “Democracy, War, and Covert Action,” Journal of Peace Research 29.4, 1992, p. 391.

29 Kornbluh, op. cit., p. 26.

30 Americas Watch report cited in Reed Brody, Contra Terror in Nicaragua (Cambridge: South End Press, 1985), p. 7.

31 Kornbluh, op. cit., p. 25.

32 Brody, op. cit., p. 10.

33 Contra defector quoted in Noam Chomsky, Understanding Power: The Indispensable Chomsky, Peter R. Mitchell and John Schoeffel (eds.), (New York: The New Press, 2002). The quote may be found online at <> p. 7, n. 12. Book hereafter cited as U.P.

34 William Blum, Killing Hope: U.S. Military and CIA Interventions Since World War II (Monroe: Common Courage Press, 1995), p. 302.

35 Michael E. Conroy, “Economic Aggression,” in Reagan, pp. 57-76.

36 Official quoted in Martin A. Lee and Norman Solomon, Unreliable Sources: A Guide to Detecting Bias in News Media (New York: Lyle Stuart Book, 1991), p. 131.

37 Kentworthy, “Selling the Policy,” in Reagan, p. 165.

38 See Chomsky, U.P., pp. 4-6.

39 Reichler quoted in Blum, op. cit., p. 304.

40 Kirkpatrick, op. cit., p. 12. She was referring to Hitler, Stalin, and Pol Pot.

41 William I. Robinson, “Nicaragua and the World: A Globalization Perspective,” in Illusions, p. 39.

42 Robinson, op. cit., p. 35.  For an example of the working conditions in a “free-trade zone,” see Robert J.S. Ross and Charles Kernaghan, “Countdown to Managua,” The Nation, September 4, 2000.

43 Toni Solo, “Neo-Liberal Nicaragua: a Neo-Banana Republic,” Z Magazine, September 2003..

44 Robinson, op. cit., p. 38.

45 Frederick S. Weaver, Inside the Volcano: The History and Political Economy of Central America (Boulder: Westview Press, 1994) pp. 234-235, 218.

46 Robinson, op. cit., p. 32 and Kampwirth, op. cit., pp. 120-123.

47 Robinson, op. cit., p. 33.

48 Central Intelligence Agency, “Nicaragua,” The World Factbook 2005.

49 Kevin Baxter, “Under the Volcano: Neoliberalism Finds Nicaragua,” The Nation, April 6, 1998, Vol. 266, Issue 12.

50 Baxter, op. cit. and Kampwirth, op. cit., p. 125, Solo, op. cit.  See also Hugh O’Shaughnessy, “Nicaragua Vies with Haiti as West’s Nightmare,” The Observer, September 12, 1993; and Nicaragua Solidarity Campaign Action Group, “Trade Unions in Nicaragua Briefing 2005.”

51 Kampwirth, op. cit., p. 126 and references in footnote 50.

52 Solo, op. cit.

53 Lawyer quoted Baxter, op. cit.

Mark Major is a master’s candidate in the Public Policy and International Affairs Graduate Program at William Paterson University. Special thanks to Stephen R. Shalom for his valuable comments and suggestions.  Feedback is greatly appreciated:>.