“Grading John Paul Stevens’ Work”: When Rewriting The Second Amendment, Be As Specific As Possible
As the gun nuts will surely point out, former Supreme Court Justice John Paul Stevens doesn’t know how to distinguish automatic from semi-automatic firearms. I’ve never understood why this distinction is so important to gun nuts. As a legal matter, obviously it is important to know the difference. But the reason that non-gun enthusiasts make this mistake so often is because the semi-automatic weapons are so incredibly lethal that the distinction doesn’t make any practical difference to them. Does anyone think Adam Lanza’s semi-automatic weapon was inadequate to the job of killing 20 kids and 6 teachers in a couple of minutes?
It’s really the ease and quickness that killers like Lanza and James Eagan Jones Holmes (the Aurora, Colorado shooter) can mow down large groups of people that is the concern.
In any case, Stevens’ proposed amendment to the Second Amendment is sloppy. It would make it impossible for a National Guard officer to disarm an insubordinate underling.
As a result of the rulings in Heller and McDonald, the Second Amendment, which was adopted to protect the states from federal interference with their power to ensure that their militias were “well regulated,” has given federal judges the ultimate power to determine the validity of state regulations of both civilian and militia-related uses of arms. That anomalous result can be avoided by adding five words to the text of the Second Amendment to make it unambiguously conform to the original intent of its draftsmen. As so amended, it would read:
“A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms when serving in the Militia shall not be infringed.”
As we know, the wording of these things can get twisted over time. So, if you want to rewrite the Second Amendment you should be as specific as possible. I’d go with:
A well regulated Militia is no longer necessary to the security of a free State. We now call those things the Army Reserve, the Navy Reserve, the Marine Corps Reserve, the Air Force Reserve, the Coast Guard Reserve, the Army National Guard of the United States, and the Air National Guard of the United States. If you serve in one of those Organizations, your weapon will be provided for you.
See, isn’t that better?
By: Martin Longman, Washington Monthly Political Animal, April 13, 2014
“When Serving In The Militia”: Justice Stevens, The Five Extra Words That Can Fix The Second Amendment
Following the massacre of grammar-school children in Newtown, Conn., in December 2012, high-powered weapons have been used to kill innocent victims in more senseless public incidents. Those killings, however, are only a fragment of the total harm caused by the misuse of firearms. Each year, more than 30,000 people die in the United States in firearm-related incidents. Many of those deaths involve handguns.
The adoption of rules that will lessen the number of those incidents should be a matter of primary concern to both federal and state legislators. Legislatures are in a far better position than judges to assess the wisdom of such rules and to evaluate the costs and benefits that rule changes can be expected to produce. It is those legislators, rather than federal judges, who should make the decisions that will determine what kinds of firearms should be available to private citizens, and when and how they may be used. Constitutional provisions that curtail the legislative power to govern in this area unquestionably do more harm than good.
The first 10 amendments to the Constitution placed limits on the powers of the new federal government. Concern that a national standing army might pose a threat to the security of the separate states led to the adoption of the Second Amendment, which provides that “a well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed.”
For more than 200 years following the adoption of that amendment, federal judges uniformly understood that the right protected by that text was limited in two ways: First, it applied only to keeping and bearing arms for military purposes, and second, while it limited the power of the federal government, it did not impose any limit whatsoever on the power of states or local governments to regulate the ownership or use of firearms. Thus, in United States v. Miller, decided in 1939, the court unanimously held that Congress could prohibit the possession of a sawed-off shotgun because that sort of weapon had no reasonable relation to the preservation or efficiency of a “well regulated Militia.”
When I joined the court in 1975, that holding was generally understood as limiting the scope of the Second Amendment to uses of arms that were related to military activities. During the years when Warren Burger was chief justice, from 1969 to 1986, no judge or justice expressed any doubt about the limited coverage of the amendment, and I cannot recall any judge suggesting that the amendment might place any limit on state authority to do anything.
Organizations such as the National Rifle Association disagreed with that position and mounted a vigorous campaign claiming that federal regulation of the use of firearms severely curtailed Americans’ Second Amendment rights. Five years after his retirement, during a 1991 appearance on “The MacNeil/Lehrer NewsHour,” Burger himself remarked that the Second Amendment “has been the subject of one of the greatest pieces of fraud, I repeat the word ‘fraud,’ on the American public by special interest groups that I have ever seen in my lifetime.”
In recent years two profoundly important changes in the law have occurred. In 2008, by a vote of 5 to 4, the Supreme Court decided in District of Columbia v. Heller that the Second Amendment protects a civilian’s right to keep a handgun in his home for purposes of self-defense. And in 2010, by another vote of 5 to 4, the court decided in McDonald v. Chicago that the due process clause of the 14th Amendment limits the power of the city of Chicago to outlaw the possession of handguns by private citizens. I dissented in both of those cases and remain convinced that both decisions misinterpreted the law and were profoundly unwise. Public policies concerning gun control should be decided by the voters’ elected representatives, not by federal judges.
In my dissent in the McDonald case, I pointed out that the court’s decision was unique in the extent to which the court had exacted a heavy toll “in terms of state sovereignty. . . . Even apart from the States’ long history of firearms regulation and its location at the core of their police powers, this is a quintessential area in which federalism ought to be allowed to flourish without this Court’s meddling. Whether or not we can assert a plausible constitutional basis for intervening, there are powerful reasons why we should not do so.”
“Across the Nation, States and localities vary significantly in the patterns and problems of gun violence they face, as well as in the traditions and cultures of lawful gun use. . . . The city of Chicago, for example, faces a pressing challenge in combating criminal street gangs. Most rural areas do not.”
In response to the massacre of grammar-school students at Sandy Hook Elementary School, some legislators have advocated stringent controls on the sale of assault weapons and more complete background checks on purchasers of firearms. It is important to note that nothing in either the Heller or the McDonald opinion poses any obstacle to the adoption of such preventive measures.
First, the court did not overrule Miller. Instead, it “read Miller to say only that the Second Amendment does not protect those weapons not typically possessed by law-abiding citizens for lawful purposes, such as short-barreled shotguns.” On the preceding page of its opinion, the court made it clear that even though machine guns were useful in warfare in 1939, they were not among the types of weapons protected by the Second Amendment because that protected class was limited to weapons in common use for lawful purposes such as self-defense. Even though a sawed-off shotgun or a machine gun might well be kept at home and be useful for self-defense, neither machine guns nor sawed-off shotguns satisfy the “common use” requirement.
Thus, even as generously construed in Heller, the Second Amendment provides no obstacle to regulations prohibiting the ownership or use of the sorts of weapons used in the tragic multiple killings in Virginia, Colorado and Arizona in recent years. The failure of Congress to take any action to minimize the risk of similar tragedies in the future cannot be blamed on the court’s decision in Heller.
A second virtue of the opinion in Heller is that Justice Antonin Scalia went out of his way to limit the court’s holding not only to a subset of weapons that might be used for self-defense but also to a subset of conduct that is protected. The specific holding of the case covers only the possession of handguns in the home for purposes of self-defense, while a later part of the opinion adds emphasis to the narrowness of that holding by describing uses that were not protected by the common law or state practice. Prohibitions on carrying concealed weapons, or on the possession of firearms by felons and the mentally ill, and laws forbidding the carrying of firearms in sensitive places such as schools and government buildings or imposing conditions and qualifications on the commercial sale of arms are specifically identified as permissible regulations.
Thus, Congress’s failure to enact laws that would expand the use of background checks and limit the availability of automatic weapons cannot be justified by reference to the Second Amendment or to anything that the Supreme Court has said about that amendment. What the members of the five-justice majority said in those opinions is nevertheless profoundly important, because it curtails the government’s power to regulate the use of handguns that contribute to the roughly 88 firearm-related deaths that occur every day.
There is an intriguing similarity between the court’s sovereign immunity jurisprudence, which began with a misinterpretation of the 11th Amendment, and its more recent misinterpretation of the Second Amendment. The procedural amendment limiting federal courts’ jurisdiction over private actions against states eventually blossomed into a substantive rule that treats the common-law doctrine of sovereign immunity as though it were part of the Constitution itself. Of course, in England common-law rules fashioned by judges may always be repealed or amended by Parliament. And when the United States became an independent nation, Congress and every state legislature had the power to accept, to reject or to modify common-law rules that prevailed prior to 1776, except, of course, any rule that might have been included in the Constitution.
The Second Amendment expressly endorsed the substantive common-law rule that protected the citizen’s right (and duty) to keep and bear arms when serving in a state militia. In its decision in Heller, however, the majority interpreted the amendment as though its draftsmen were primarily motivated by an interest in protecting the common-law right of self-defense. But that common-law right is a procedural right that has always been available to the defendant in criminal proceedings in every state. The notion that the states were concerned about possible infringement of that right by the federal government is really quite absurd.
As a result of the rulings in Heller and McDonald, the Second Amendment, which was adopted to protect the states from federal interference with their power to ensure that their militias were “well regulated,” has given federal judges the ultimate power to determine the validity of state regulations of both civilian and militia-related uses of arms. That anomalous result can be avoided by adding five words to the text of the Second Amendment to make it unambiguously conform to the original intent of its draftsmen. As so amended, it would read:
“A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms when serving in the Militia shall not be infringed.”
Emotional claims that the right to possess deadly weapons is so important that it is protected by the federal Constitution distort intelligent debate about the wisdom of particular aspects of proposed legislation designed to minimize the slaughter caused by the prevalence of guns in private hands. Those emotional arguments would be nullified by the adoption of my proposed amendment. The amendment certainly would not silence the powerful voice of the gun lobby; it would merely eliminate its ability to advance one mistaken argument.
It is true, of course, that the public’s reaction to the massacre of schoolchildren, such as the Newtown killings, and the 2013 murder of government employees at the Navy Yard in Washington, may also introduce a strong emotional element into the debate. That aspect of the debate is, however, based entirely on facts rather than fiction. The law should encourage intelligent discussion of possible remedies for what every American can recognize as an ongoing national tragedy.
By: John Paul Stevens, Associate Justice of The Supreme Court from 1975 to 2010. This essay is excerpted from his new book, “Six Amendments: How and Why We Should Change the Constitution.”; The Washington Post, April 11, 2014
“5 Things Conservatives Lie Shamelessly About”: A Neat Little Rhetorical Trick, Tell Lies So Fast Your Opponents Can’t Keep Up
Mark Twain once famously said, “A lie can travel halfway around the world while the truth is putting on its shoes.” Twain wasn’t praising lies with this comment, of course, but modern-day conservatives seem to think he was dishing out advice instead of damning the practice of dishonesty. Conservatives have figured out a neat little rhetorical trick: One lie is easy for your opponents to debunk. Tell one lie after another, however, and your opponent’s debunkings will never catch up. By the time the liberal opposition has debunked one lie, there’s a dozen more to take its place.
Science educator Eugenie Scott deemed the technique the “Gish Gallop,” named for a notoriously sleazy creationist named Duane Gish. The Urban Dictionary defines the Gish Gallop as a technique that “involves spewing so much bullshit in such a short span on that your opponent can’t address let alone counter all of it.” Often users of the Gish Gallop know their arguments are nonsense or made in bad faith, but don’t particularly care because they are so dead set on advancing their agenda. Unfortunately, the strategy is so effective that it’s been expanding rapidly in right-wing circles. Here are just a few of the most disturbing examples of the Gish Gallop in action.
1. Creationism. It’s no surprise creationists inspired the coining of the term Gish Gallop, as they have perfected the art of making up nonsense faster than scientists can refute it. The list of false or irrelevant claims made by creationists, as chronicled by Talk Origins, numbers in the dozens, perhaps even hundreds, and more are always being spun out. Trying to argue with a creationist, therefore, turns into a hellish game of Whack-A-Mole. Debunk the lie that the speed of light is not constant, and you’ll find he’s already arguing that humans co-existed with dinosaurs. Argue that it’s unconstitutional to put the story of Adam and Eve in the science classroom, and find he’s pretending he was never asking for that and instead wants to “teach the controversy.”
“Teaching the controversy” is a classic Gish Gallop apology. The conservative wants to make it seem like he’s supporting open-minded debate, but instead he just wants an opportunity to dump a bunch of lies on students with the knowledge that they’ll never have the time and attention to carefully parse every debunking.
2. Climate change denialism. This strategy worked so well for creationism it makes perfect sense that it would be imported to the world of climate change denialism. Climate change denialists have many changing excuses for why they reject the science showing that human-caused greenhouse gases are changing the climate, but what all these reasons have in common is they are utter nonsense in service of a predetermined opposition to taking any action to prevent further damage.
Skeptical Science, a website devoted to debunking right-wing lies on this topic, has compiled a dizzying list of 176 common claims by climate denialists and links to why they are false. Some of these lies directly contradict each other. For instance, it can’t both be true that climate change is “natural” and that it’s not happening at all. No matter, since the point of these lies is not to create a real discussion about the issue, but to confuse the issue so much it’s impossible to get any real momentum behind efforts to stop global warming.
3. The Affordable Care Act. It’s not just science where conservatives have discovered the value in telling lies so fast you simply wear your opposition out. When it comes to healthcare reform, the lying has been relentless. There are the big lies, such as calling Obamacare “socialism,” which implies a single-payer system, when in fact, it’s about connecting the uninsured with private companies and giving consumers of healthcare a basic set of rights. In a sense, even the name “Obamacare” is a lie, as the bill was, per the President’s explicit wishes, written by Congress.
But there are also the small lies: The ACA funds abortion. Under the ACA, old people will be forcibly euthanized. Obamacare somehow covers undocumented immigrants. Congress exempted itself from Obamacare (one of the lies that doesn’t even make sense, as it’s not a program you could really get exempted from). Healthcare will add a trillion dollars to the deficit.
The strategy of just lying and lying and lying some more about the ACA has gotten to the point where Fox News is just broadcasting lies accusing the Obama administration of lying. When it was reported that the administration was going to hit its projections for the number of enrollments through healthcare.gov, a subculture of “enrollment truthers” immediately sprang up to spread a variety of often conflicting lies to deny that these numbers are even real. It started soft, with some conservatives suggesting that some enrollments shouldn’t count or arguing, without a shred of evidence, that huge numbers of new enrollees won’t pay their premiums. Now the lying is blowing up to the shameless level, with “cooking the books” being a common false accusation or, as with Jesse Watters on Fox, straight up accusing the White House of making the number up. Perhaps soon there will be demands to see all these new enrollees’ birth certificates.
4. Contraception mandate.The ACA-based requirement that insurance plans cover contraception without a copay has generated a Gish Gallop so large it deserves its own category. Jodi Jacobson of RH Reality Check chronicled 12 of the biggest lies generated by the right-wing noise machine in just the past couple of years since the mandate was even announced. It is not “free” birth control, nor is it “paid for” by employers. The birth control coverage is paid for by the employees, with benefits they earn by working. The mandate doesn’t cover “abortifacients,” only contraception. No, birth control doesn’t work by killing fertilized eggs, but by preventing fertilization. It’s simply false that the prescriptions in question can all be replaced with a $9-a-month prescription from Walmart, as many women’s prescriptions run into the hundreds and even thousands a year. No, it’s not true that the contraception mandate is about funding women’s “lifestyle”, because statistics show that having sex for fun instead of procreation is a universal human behavior and not a marginal or unusual behavior as the term “lifestyle” implies.
5. Gun safety. The gun lobby is dishonest to its core. Groups like the NRA like to paint themselves like they are human rights organizations, but in fact, they are an industry lobby whose only real goal is to protect the profit margins of gun manufacturers, regardless of the costs to human health and safety. Because their very existence is based on a lie, is it any surprise that gun industry advocates are experts at the Gish Gallop, ready to spring into action at the sign of any school shooting or report on gun violence and dump so many lies on the public that gun safety advocates can never even begin to address them all?
A small sampling of the many, many lies spouted by gun industry advocates: That guns prevent murder, when in fact more guns correlates strongly with more murders. That gun control doesn’t work. That gun control is unpopular. That any move to make gun ownership safer is a move to take away your guns. That a gun in the home makes you safer when it actually puts your family at more risk. That guns protect against domestic violence, when the truth is that owning a gun makes abuse worse, not better. Even the standard line “guns don’t kill people, people kill people” is a distracting bit of dishonesty, since most gun deaths aren’t murders but suicides.
How do you fight the Gish Gallop, when trying to debunk each and every lie is so overwhelming? There are a few tactics that help, including creating websites and pamphlets where all the lies can be aggregated in one place, for swift debunking. (Bingo cards and drinking games are a humorous version of this strategy.) A critical strategy is to avoid lengthy Lincoln-Douglas-style debates that allow conservatives to lie-dump rapidly during their speaking period, leaving you so busy trying to clean up their mess you have no time for positive points of your own. Better is a looser style of debate where you can interrupt and correct the lies as they come. I’ve also found some luck with setting an explicit “no lies” rule that will be strictly enforced. The first lie receives a warning, and the second lie means that the debate is immediately terminated. This helps prevent you from having to debunk and instead makes the price of participation a strict adherence to facts.
By: Amanda Marcotte, AlterNet, April 2, 2014
“Are Guns A Public Health Issue?”: Let Us Count The Ways…
Is calling guns a public health issue a political statement? That’s become the underlying issue in the nomination of the White House’s pick for surgeon general, Vivek Murthy. In 2012, Murthy sent out a tweet: “Tired of politicians playing politics w/ guns, putting lives at risk b/c they’re scared of NRA. Guns are a health care issue.” The NRA got Senators to hurl the words back at him during a confirmation hearing, and seems to have convinced not just Republicans but some Democrats to vote against him. Now nobody is talking about bringing his nomination to the floor.
Let’s leave aside the issue of whether a Tweet should be the grounds for an opposition campaign, and of whether Murthy, best known for running an advocacy organization to support Obamacare’s launch, is the most qualified person for the job. If the question at hand is whether it’s partisan to believe that gun violence should be under the purview of the nation’s top doctor, it seems the answer is no. As Lucia Graves at National Journal chronicled last week, Ronald Reagan and George H.W. Bush’s surgeon generals, C. Everett Koop and Louis W. Sullivan, have professed the same view as Murthy without ruffling feathers. “Promoting reasonable gun policies does not make [public health professionals] ‘antigun’ any more than the Insurance Institute for Highway Safety is ‘anticar,’” wrote David Hemenway of the Harvard School of Public Health in his 2004 book Private Guns, Public Health.
Gun violence impacts health in all kinds of ways. There are the more obvious ones, like death and injury. As Olga Khazan pointed out at The Atlantic, suicide rates are higher in states where gun ownership is more common. In 2010, 19,392 people took their own lives with guns, while “justifiable homicides”—self-defense shootings that may have saved a life—numbered only 230. Over two-thirds of homicides and over half of successful suicides involve the use of a gun, and accidental gun deaths average about two a day. The U.S. spends $2 billion a year on medical care for victims of gun injuries; one out of three people hospitalized after shootings is uninsured, according to The Huffington Post.
Then there are the less obvious health effects of gun violence: Lead in the ground from ammunition. Loss of hearing from gunshots. Widespread PTSD that effects everyone from shooters, to victims, to bystanders. “Gun violence traumatizes whole communities,” Hemenway told me. This creates a cycle: “People with PTSD in inner cities often don’t have good access to mental health care, and it makes them more likely to be aggressive.”
Public health experts have a list of possible solutions that fall outside the most fractious debates over firearms. Stephen Teret, a public health expert at Johns Hopkins University, has pushed for the engineering of “smart guns,” which could only be fired by their owners: No more weapons finding their way into the black market, or becoming deadly playthings in the hands of children. (The NRA has fought the new technology.) Teret’s idea would address both intentional and accidental gun hazards, but there are lots of ways to approach the latter—from mandated child safety locks, to features that would make it more obvious if a weapon was loaded.
Hemenway also suggested changing the culture around some aspects of gun use, as a sustained campaign did for drunk driving in the 20th century. “One of the social norms should be that it’s your responsibility, if you’re a gun owner, to make sure your gun is not stolen,” he said.
The power of the surgeon general lies mostly in the ability to shape public conversation, and to do so he or she needs to maintain a high degree of trust, on both ends of the political spectrum. But sometimes advocating for public health means wading into controversial issues, like AIDS or smoking, because people’s lives are at stake. That means a surgeon general must be ready and willing to speak out on all kinds of hazards, even ones with powerful constituencies behind them. Those can include carcinogens from cigarettes, poisons from pollution, and, yes, bullets from guns.
By: Nora Caplan-Bricker, The New Republic, April 3, 2014
“Lethal But Legal”: Rethinking Our ‘Rights’ To Dangerous Behaviors
In the last few years, it’s become increasingly clear that food companies engineer hyperprocessed foods in ways precisely geared to most appeal to our tastes. This technologically advanced engineering is done, of course, with the goal of maximizing profits, regardless of the effects of the resulting foods on consumer health, natural resources, the environment or anything else.
But the issues go way beyond food, as the City University of New York professor Nicholas Freudenberg discusses in his new book, “Lethal but Legal: Corporations, Consumption, and Protecting Public Health.” Freudenberg’s case is that the food industry is but one example of the threat to public health posed by what he calls “the corporate consumption complex,” an alliance of corporations, banks, marketers and others that essentially promote and benefit from unhealthy lifestyles.
It sounds creepy; it is creepy. But it’s also plain to see. Yes, it’s unlikely there’s a cabal that sits down and asks, “How can we kill more kids tomorrow?” But Freudenberg details how six industries — food and beverage, tobacco, alcohol, firearms, pharmaceutical and automotive — use pretty much the same playbook to defend the sales of health-threatening products. This playbook, largely developed by the tobacco industry, disregards human health and poses greater threats to our existence than any communicable disease you can name.
All of these industries work hard to defend our “right” — to smoke, feed our children junk, carry handguns and so on — as matters of choice, freedom and responsibility. Their unified line is that anything that restricts those “rights” is un-American.
Yet each industry, as it (mostly) legally can, designs products that are difficult to resist and sometimes addictive. This may be obvious, if only in retrospect: The food industry has created combinations that most appeal to our brains’ instinctual and learned responses, although we were eating those foods long before we realized that. It may be hidden (and borderline illegal), as when tobacco companies upped the nicotine quotient of tobacco. Sometimes, as Freudenberg points out, the appeals may be subtle: Knowing full well that S.U.V.’s were less safe and more environmentally damaging than standard cars, manufacturers nevertheless marketed them as safer, appealing to our “unconscious ‘reptilian instincts’ for survival and reproduction and to advertise S.U.V.’s as both protection against crime and unsafe drivers and as a means to escape from civilization.”
The problems are clear, but grouping these industries gives us a better way to look at the struggle of consumers, of ordinary people, to regain the upper hand. The issues of auto and gun safety, of drug, alcohol and tobacco addiction, and of hyperconsumption of unhealthy food are not as distinct as we’ve long believed; really, they’re quite similar. For example, the argument for protecting people against marketers of junk food relies in part on the fact that antismoking regulations and seatbelt laws were initially attacked as robbing us of choice; now we know they’re lifesavers.
Thus the most novel and interesting parts of Freudenberg’s book are those that rephrase the discussion of rights and choice, because we need more than seatbelt and antismoking laws, more than a few policies nudging people toward better health. Until now (and, sadly, perhaps well into the future), corporations have been both more nimble and more flush with cash than the public health arms of government. “What we need,” Freudenberg said to me, “is to return to the public sector the right to set health policy and to limit corporations’ freedom to profit at the expense of public health.”
Redefining the argument may help us find strategies that can actually bring about change. The turning point in the tobacco wars was when the question changed from the industry’s — “Do people have the right to smoke?” — to that of public health: “Do people have the right to breathe clean air?” Note that both questions are legitimate, but if you address the first (to which the answer is of course “yes”) without asking the second (to which the answer is of course also “yes”) you miss an opportunity to convert the answer from one that leads to greater industry profits to one that has literally cut smoking rates in half.
Similarly, we need to be asking not “Do junk food companies have the right to market to children?” but “Do children have the right to a healthy diet?” (In Mexico, the second question has been answered positively. Shamefully, we have yet to take that step.) The question is not only, “Do we have a right to bear arms?” but also “Do we have the right to be safe in our streets and schools?” In short, says Freudenberg: “The right to be healthy trumps the right of corporations to promote choices that lead to premature death and preventable illnesses. Protecting public health is a fundamental government responsibility; a decent society should not allow food companies to convince children to buy food that’s bad for them or to encourage a lifetime of unhealthy eating.”
Oddly, these are radical notions. But aren’t they less “un-American” than allowing a company to maximize its return on investment by looking to sell to children or healthy adults in ways that will cause premature mortality? As Freudenberg says, “Shouldn’t science and technology be used to improve human well-being, not to advance business goals that harm health?” Two other questions that can be answered “yes.”
By: Mark Bittman, Contributing Op-Ed Writer, The New York Times, February 26, 2014
Share This Blog
Unknown Feed- An error has occurred; the feed is probably down. Try again later.
mykeystrokes.com 