Fort Hood Shooting

The media’s silly Fort Hood coverage

Everyone wants to debate terrorism and political correctness, but the real story is the failure of Army medicine

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The media's silly Fort Hood coveragein Fort Hood, Texas, Thursday, Nov. 5, 2009. (AP Photo/Michael Thomas)(Credit: Michael Thomas)

The conventional narrative of the Fort Hood shootings, one week later, has been distinguished by the reporting of unconfirmed — and sometimes incorrect — details and the drawing of dubious conclusions. The only thing that suggests the current story will withstand the test of time better than the initial Pat Tillman myth (that he died in combat, rather than by friendly fire), or the overheated tale of heroism by Jessica Lynch in 2003 (which Lynch herself protested), is that two basic facts seem clear: The shootings certainly happened, and given the number of eyewitnesses, it’s almost certain that Maj. Nidal Malik Hasan did it.

The fact that it was first incorrectly reported that Hasan died in the shootings, and that he was in cahoots with other perpetrators, may well be fairly chalked up to confusion during that first chaotic day. Other details, however, continue to unravel a week later. The media debate provoked by the Hasan incident is equally off-topic and unreliable. As someone who’s been asked to talk about the shootings because of my work covering the poor psychological care given to returning Iraq and Afghanistan veterans, I’ve had a front-row seat on the way preconceived biases are distorting the debate.

First, the ongoing factual unraveling of the narrative. As the New York Times reported this Thursday, initial information seized on by talk shows that Sgt. Kimberly Munley, a petite police officer, bravely brought down Hasan in a hail of gunfire in which she was also wounded was, well, also not true. Munley, it seems, just got shot. Senior Sgt. Mark Todd actually shot Hasan to the ground and cuffed him after Munley had already been wounded.

Also on Thursday, the Washington Post raised solid questions about previous reports that Hasan had tried to get out of his military service because of what he saw as a growing schism between his religious and military duties. While Hasan’s aunt has said he wanted to get out of the military, the Post quotes an Army source who claims Hasan “did not formally seek to leave the military as a conscientious objector or for any other reason.”

Despite some print publications attempting to keep track of these kinds of facts, a lot of media folks continue to ask the wrong questions and/or provide some of their own unlikely, or unsubstantiated, answers.

The Monday after the shootings, I got my first taste of how the story was embarking on a life of its own as I settled into a chair at one of MSNBC’s Washington studios to do Dylan Ratigan’s “Morning Meeting.”

“One question being asked, among many, is whether political correctness stalled the response to possible warning signs from Maj. Hasan,” Ratigan said in his introduction. Ratigan then asked me if there had been “too much tolerance in this instance.”

Too much political correctness in the military? You know, the place where they fire you if you admit you’re gay? The Army has its share of challenges, but in a decade of covering the military, I certainly haven’t come across any evidence that the institution is somehow paralyzed by the burden of gratuitous political correctness. And while that might provide a convenient way for Army officials to explain, anonymously, why nobody prevented Hasan from killing 13 people — “We are just too afraid of criticizing Muslims” — I haven’t seen a shred of evidence to suggest this might be true.

The cover of Time magazine depicts another befuddling sideshow to the Fort Hood story. The cover is a picture of Hasan with the word “Terrorist?” over his eyes. “It is a story about why Maj. Hasan is a terrorist,” Time managing editor Richard Stengel explained on MSNBC’s “Morning Joe” one week after the killings.

I’d heard this one before – the debate about whether we should label Hasan a terrorist, or the shooting as an act of terrorism. Right-wing media host Laura Ingraham railed at me on this subject on her radio show this week after I had referred to Hasan as being partly motivated by a “religious thing,” but I had failed to use the word “terrorism.” “I say that you won’t call it what it is,” she shouted, “which is terrorism!” (I had called it “Muslim extremism” but that wasn’t good enough for Ingraham.)

The obsession with that label “terrorist” seems beside the point. The real question is why the shootings were allowed to occur, and who, exactly, dropped the ball — not what we call it all afterward.

Stengel explained on “Morning Joe” why he thinks that label is so important that it should grace the cover of his magazine, and he anchored his argument with some of the same tenuous logic I’d tangled with on “Morning Meeting.” Once we come to terms with calling Hasan a religiously motivated terrorist, he argued, we can begin to tackle the real reason the Army failed to stop the shootings — political correctness.

“People in the military say there is a lot of political correctness here,” Stengel explained. “There is a lot of fear of criticizing Muslims in the military and as a result, a guy like Hasan can get promoted up through the ranks. He became a major,” he explained. “I think we need to address this issue.”

In addition, one of Stengel’s key pieces of evidence that Hasan was a terrorist was the following: “This is a man who stood up before he killed people and said ‘God is great’ in Arabic,” Stengel announced.

That may be true, though I’ve been unable to find an original or credible source for this information. The original source seems to be a question from NBC’s Matt Lauer to Fort Hood’s Lt. Gen. Robert Cone on Nov. 6, the morning after the shootings. Lauer cited a relative of a witness to the shooting claiming that Hasan had said “God is great” in Arabic before opening fire. Cone responded: ”There are firsthand accounts here from soldiers that are similar to that.” Fort Hood, however, will not confirm this aspect of the story. “We are not at liberty to discuss questions related to this case,” spokesman Chris Haug said in an e-mail when I asked about the “God is great” story. “There is an ongoing investigation.”

Meanwhile, most members of the media continue to ignore the much more mundane, but seemingly more promising, avenues of inquiry that might explain why Hasan got away with murder.

Hasan was a military psychiatrist toiling in an overburdened, desperate Army healthcare system that will hold onto any warm body with a medical degree. Remember the Walter Reed scandal? The horrific treatment of traumatic brain injury and PTSD that has gone on for years? Army medicine has been dropping the ball on these issues for a long time. Given that history, it’s not hugely surprising they’d miss warning signs with Hasan and just let him go on being a doctor.

Army medical officials, at least to my knowledge, haven’t been asked even the most basic questions. Why, for example, was Hasan allowed to continue counseling troops suffering stress from combat in Iraq and Afghanistan after, for example, delivering a PowerPoint presentation in June 2007 at Walter Reed warning of “adverse events” if Muslims were forced to kill other Muslims in battle. It’s hard to imagine Hasan being particularly empathetic with his patients. Imagine coming back from Iraq with mental problems from combat, and this is the psychiatrist who is supposed to help you heal? So far, the only reaction from Army medical officials to these issues seems to have been the decision to move him to the war front in Afghanistan, so he could be even closer to the troops when they suffer adverse mental reactions. That’s odd.

As for Hasan getting promoted to major, the Washington Post Thursday suggested a more likely scenario than political correctness. They need more bodies. The Army is short 2,000 majors and the dearth is particularly acute in Army medicine. As the Post put it, “virtually all Army captains are being promoted to major.”

The passionate determination to hang the “terrorist” label on Hasan, or rail against “political correctness” in the military, are just more symptoms of media stars more excited about hot-headed debate than covering the real story. And the real story may be sadly familiar: It looks like Army medicine blew it, once again. 

Mark Benjamin is a national correspondent for Salon based in Washington, D.C. Read his other articles here.

Fort Hood and fetal personhood

Activists say the fetus of a pregnant shooting victim should be added to the official death toll

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While some conservatives are arguing that “Jihadism” is the only relevant factor in the Fort Hood massacre, it seems others have a mind to sneak another contentious issue into the fray: fetal personhood. They have found their moment of opportunity in one of the 13 victims of the shooting spree: Francheska Velez, a pregnant woman. Now, antiabortion activists are arguing that the official death toll should be raised to 14 in recognition of the loss of her 9-week-old fetus. 

I will admit that as soon as I learned about Velez’s death, I gasped. There is something especially tragic about a pregnant woman — someone who ideally embodies all of the hope and idealism of bringing a new life into the world — being senselessly gunned down. Upon hearing the news my imagination went wild conjuring up the joy of a soon-to-be father and expectant grandparents, and all of the potential they imagined within the fetus growing inside Velez. Then I pictured the family mourning the death of both this 21-year-old woman, a baby herself in the grand scheme of things, and her unborn offspring.

That doesn’t mean I agree with antiabortion activists that the victim count should be 14, though. There is acknowledging the devastating loss of a pregnancy and the profound mourning that can accompany it, and then there’s equating the loss of a fetus the size of a strawberry with the death of a fully realized human being. The latter is what Michelle Malkin, the folks at LifeNews.com and other fringe outlets are doing in trying to get one more person added to the Fort Hood casualty list. Where I see a 9-week-old fetus with the potential to develop into a person, they see full-fledged personhood. Thus, they argue an additional charge should be brought against accused shooter Maj. Nidal Malik Hasan for the death of the fetus under the Unborn Victims of Violence Act.

Yeah, about that act. “Fetal rights” laws have long been a favored weapon in antiabortion activists’ arsenal — in large part because they appear deceptively nonthreatening. Under the guise of protecting pregnant women, they champion laws that actually take rights away from women and give them to fetuses. As Lynn M. Paltrow, executive director of the National Advocates for Pregnant Women, once told Salon: “In the name of fetal rights and protection, pregnant women have been forced to have unnecessary C-sections (in one case both the woman and fetus died), been civilly committed to mental hospitals and drug treatment programs, been arrested as child abusers for using marijuana to cope with morning sickness, and been charged and, in some cases, convicted of murder for suffering an unintentional stillbirth.” The ultimate ploy here is to legally secure fetal personhood and then overturn Roe v. Wade — because suddenly a woman who terminated her pregnancy would not only be considered guilty of an illegal abortion but also murder.

That’s the danger in these heartstring-plucking arguments. Anyone familiar with the devastation of a miscarriage or the joy of an ultrasound can very well understand a pregnant woman’s conviction that the stirring in her belly is a person, even if on an intellectual level she knows its potential for personhood is still unrealized. But these activists aren’t interested in having a nuanced discussion about the emotional complexities involved in defining personhood. They’re interested in one thing and one thing only: outlawing abortion.

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Tracy Clark-Flory

Tracy Clark-Flory is a staff writer at Salon. Follow @tracyclarkflory on Twitter.

Radio host Ingraham distorted my words, then cut my mike

I tried to have a real conversation about Fort Hood with the conservative talker, but she wasn't interested

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Note to Laura Ingraham: If you are going to selectively edit my TV quotes to construct a straw man argument, don’t invite me on your radio show to discuss it. The problem, of course, is that it is pretty easy to point this out when I appear as a guest. And the wonders of Google allow anybody to pull my full quotes, later, and write about it.

Of course, you could always just cut off my microphone if you don’t like what I have to say about that. It worked today.

(I didn’t know who Ingraham was either. She is a right-wing radio host, sort of a poor man’s Ann Coulter. I say poor man’s Ann Coulter because, for example, earlier on Tuesday Ingraham’s Web site featured photos of Nancy Pelosi and Steven Tyler side-by-side, with a caption that reads, ‘Separated at Birth?’ That’s so funny. Get it? Nancy Pelosi looks like a man!)

Laura outlined my role as Straw Man within minutes of my picking up the phone for the interview. My part, it seemed, was to play the lefty who denied that Muslim extremism might have played a role in the motivation behind the Fort Hood massacre. I was the guy arguing that as an Army psychiatrist, Maj. Nidal Malik Hasan suffered stress from counseling soldiers back from war and he snapped, simple as that.

“You are stating that you don’t think religion, or the religious fervor of this particular person, Hasan, had, really, any impact on this whatsoever,” she alleged early on.

Hmmm, I thought. That’s strange. “No,” I pointed out. “That’s not what I’m saying at all. I think we have a complicated situation here.”

Not complicated to her. Ingraham’s investigation has already resulted in some conclusive results, which she shared with me. “What’s complicated?” she stammered. “He is screaming Allah-u-Akbar! He is e-mailing al-Qaida and asking one of the procurement officers for Osama bin Laden what he can do to forward the Jihad in the United States,” she announced. “And we are saying this is all that complicated?”

She then ran a quote from my appearance on “The Rachel Maddow Show” last Thursday: “I certainly have met mental healthcare providers in the military who, after sitting all day long and listening to some really disturbing tales,” I said — in part — “and in combination with the fact that they are overwhelmed, overworked, don’t have resources to do their jobs, become extremely stressed and frazzled. There is no reason to not think that this could ultimately lead to that kind of a conclusion.”

Aha! Ingraham pounced. “So you did say that someone who is stressed and frazzled could be led to do this horrible act!” she said, calling my analysis “lazy.”

“You never talked about the crazy Jihadi ideas,” she went on, “I don’t believe, with Rachel Maddow. Did you?”

“I believe I did,” I responded.

What Ingraham did not say is that she had deleted the sentences I said immediately prior to the quote she used. Immediately before that Maddow quote, I had noted, “Well, it certainly could be a combination of factors. There are people who believe that this is a person who is suffering from some kind of secondary post-traumatic stress from treating soldiers,” I noted. “And there are people who believe he was somehow influenced by Muslim extremism. I think it could be a combination of both.”

I then noted on Ingraham’s radio show that there “obviously was a religious thing” going on with the story, as I said on TV.

“I’m surprised you are saying that,” she fired back. “I’m glad you are saying that.”

“I’ve been saying that for days,” I pointed out. “I’ve done five TV hits in the past week, which obviously you did not watch.” (In fact, the day after Maddow, I appeared on “Countdown With Keith Olbermann.” On Olbermann’s show I said, in part, “I mean, we’ve got a guy who clearly had a pretty twisted version of Islam and was getting, you know, increasingly militant.”)

“Well,” Ingraham admitted. “I don’t watch MSNBC often. Nor does anybody,” she said. “I did see the Rachel Maddow piece and I’m pretty sure you did not mention Jihadism.”

True. I mentioned “Muslim extremism.” And in the world of pixie dust, fairies and death panels, I guess that’s not the same. Up is down. Black is white. I didn’t say what I said.

At one point, Ingraham went so far as to suggest I was blaming U.S. troops for the massacre, since their experiences in war were so troubling. She summarized my alleged argument as, “Yeah. We suck.”

Later, via e-mail, I sent Ingraham my entire quote from Maddow and asked her if what she did on her show “was an accurate portrayal of my position.”

“Not playing an entire previous interview of a guest is hardly misrepresentation,” she responded, though I had not sent along the full transcript.

During the radio interview Tuesday, Ingraham apparently became frustrated with my efforts to discuss this matter, telling her producer to “put down his mike or this ends right here.”

I then found that my end of the conversation had become muted. I could no longer be heard on the radio — only she could. So, I hung up. In an e-mail afterward, Ingraham recounted this as, “It was your choice to hang up before the interview was over.”

Finally, something accurate. Technically.

“Oh, he hung up,” she’d said on the radio after she cut off my mike. “The left really don’t want to have a conversation.”

Audio of the interview is below. Thanks to Media Matters for providing it.

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Mark Benjamin is a national correspondent for Salon based in Washington, D.C. Read his other articles here.

Obama speaks at Fort Hood memorial service

"Your loved ones endure through the life of our nation," the president tells grieving families

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(Updated below with video and text excerpt of remarks.)

President Obama went to Fort Hood Tuesday in order to speak at a memorial service for the 13 people killed in the attack that happened at the Army post last week.

“This is a time of war. And yet these Americans did not die on a foreign field of battle. They were killed here, on American soil, in the heart of this great American community. It is this fact that makes the tragedy even more painful and even more incomprehensible,” Obama told the grieving family members who’d come to the service, according to prepared remarks released by the White House.

“But here is what you must also know: your loved ones endure through the life of our nation. Their memory will be honored in the places they lived and by the people they touched. Their life’s work is our security, and the freedom that we too often take for granted. Every evening that the sun sets on a tranquil town; every dawn that a flag is unfurled; every moment that an American enjoys life, liberty and the pursuit of happiness — that is their legacy.”

The president also made very brief remarks about each of the 13 people killed, talking about their lives in and out of the military and giving a little of their history. Perhaps the most striking aspect of his speech, though, the part that will have people talking later, was the way he talked about the U.S., mentioning diversity within the Army and freedom of religion in the country as a whole.

More excerpts from Obama’s remarks:

It may be hard to comprehend the twisted logic that led to this tragedy. But this much we do know — no faith justifies these murderous and craven acts; no just and loving God looks upon them with favor. And for what he has done, we know that the killer will be met with justice — in this world, and the next.

These are trying times for our country. In Afghanistan and Pakistan, the same extremists who killed nearly 3,000 Americans continue to endanger America, our allies, and innocent Afghans and Pakistanis. In Iraq, we are working to bring a war to a successful end, as there are still those who would deny the Iraqi people the future that Americans and Iraqis have sacrificed so much for.

As we face these challenges, the stories of those at Fort Hood reaffirm the core values that we are fighting for, and the strength that we must draw upon. Theirs are tales of American men and women answering an extraordinary call — the call to serve their comrades, their communities, and their country. In an age of selfishness, they embody responsibility. In an era of division, they call upon us to come together. In a time of cynicism, they remind us of who we are as Americans.

We are a nation that endures because of the courage of those who defend it. We saw that valor in those who braved bullets here at Fort Hood, just as surely as we see it in those who signed up knowing that they would serve in harm’s way.

We are a nation of laws whose commitment to justice is so enduring that we would treat a gunman and give him due process, just as surely as we will see that he pays for his crimes.

We are a nation that guarantees the freedom to worship as one chooses. And instead of claiming God for our side, we remember Lincoln’s words, and always pray to be on the side of God.

We are a nation that is dedicated to the proposition that all men and women are created equal. We live that truth within our military, and see it in the varied backgrounds of those we lay to rest today. We defend that truth at home and abroad, and we know that Americans will always be found on the side of liberty and equality. That is who we are as a people ….

So we say goodbye to those who now belong to eternity. We press ahead in pursuit of the peace that guided their service. May God bless the memory of those we lost. And may God bless the United States of America.

Update: Obama’s speech is being hailed as one of the best he’s given, perhaps his best since being inaugurated, and with good reason. You can see why in the video of his remarks below.

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Alex Koppelman is a staff writer for Salon.

FBI reassesses past look at Hasan

Agency to conduct internal review to see whether it mishandled early warning signs

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Nearly a year before Maj. Nidal Hasan allegedly went on a shooting rampage at Fort Hood, terrorism investigators conducted an “assessment” of him before deciding he did not pose a threat.

After the shooting, the FBI is doing a new assessment — of its own conduct.

The Army psychiatrist is believed to have acted alone despite repeated communications — intercepted by authorities — with a radical imam overseas, U.S. officials said Monday. The FBI will conduct an internal review to see whether it mishandled early information about the man accused in the bloody rampage that killed 13 people and wounded 29.

President Barack Obama was joining grieving families and comrades of the victims Tuesday at a memorial service at the sprawling Texas Army base. Hasan, awake and talking to doctors, met his lawyer Monday in the San Antonio hospital where he is recovering, under guard, from gunshot wounds in the assault.

In Washington, an investigative official and a Republican lawmaker said Hasan had communicated 10 to 20 times with Anwar al-Awlaki, an imam released from a Yemeni jail last year who has used his personal Web site to encourage Muslims across the world to kill U.S. troops in Iraq. Despite that, no formal investigation was opened into Hasan, they said.

Investigative officials spoke on condition of anonymity because they were not authorized to discuss the case. Republican Rep. Pete Hoekstra of Michigan, the top Republican on the House Intelligence Committee, said it was his understanding Hasan and the imam exchanged e-mails that counterterrorism officials picked up.

Officials said Hasan will be tried in a military court, not a civilian one, a choice that suggests his alleged actions are not thought to have emanated from a terrorist organization.

Meanwhile, The Washington Post reported Tuesday that Hasan warned his medical colleagues a year and a half ago that to “decrease adverse events” the U.S. military should allow Muslim soldiers to be released as conscientious objectors instead of fighting in wars against other Muslims. Hasan, an Army psychiatrist, made the recommendation in a culminating presentation to senior Army doctors at Walter Reed Medical Center, where he spent six years as an intern, resident and fellow before being transferred to Fort Hood.

“It’s getting harder and harder for Muslims in the service to morally justify being in a military that seems constantly engaged against fellow Muslims,” Hasan said in the presentation, a copy of which was obtained by the Post.

FBI Director Robert Mueller ordered the inquiry into the bureau’s handling of the case, including its response to potentially worrisome information gathered about Hasan beginning in December 2008 and continuing into early this year.

Based on all the investigations since the attack, the investigators said they have no evidence that Hasan had help or outside orders in the shootings.

Even so, they revealed the major had once been under scrutiny from a joint terrorism task force because of the series of communications going back months. Al-Awlaki is a former imam at a Falls Church, Va., mosque where Hasan and his family occasionally worshipped.

In 2001, al-Awlaki, a native-born U.S. citizen, had contact with two of the Sept. 11 hijackers, and on Monday his Web site praised Hasan as a hero.

Military officials were made aware of communications between Hasan and al-Awlaki, but because the messages did not advocate or threaten violence, civilian law enforcement authorities could not take the matter further, the officials said. The terrorism task force concluded Hasan was not involved in terrorist planning.

Officials said the content of those messages was “consistent with the subject matter of his research,” part of which involved post-traumatic stress disorder stemming from U.S. combat operations in Iraq and Afghanistan.

A law enforcement official said the communications consisted primarily of Hasan posing questions to the imam as a spiritual leader or adviser, and the imam did respond to at least some of those messages.

No formal investigation was ever opened based on the contacts, the officials said.

They said the decision to bring military charges instead of civilian criminal charges against Hasan did not mean it wasn’t a terrorism case. But it is likely authorities would have had more reason to take the case to federal court if they had found evidence Hasan acted with the support or training of a terrorist group.

Investigators tried to interview Hasan on Sunday at the military hospital where he is being held, but he refused to answer and requested a lawyer, the officials said.

Hasan’s new civilian and military attorneys met him for about half an hour at Brooke Army Medical Center in San Antonio, said retired Col. John P. Galligan, who was hired by Hasan’s family. Galligan said Hasan asked for an attorney even though he is on sedatives and his condition is guarded.

“Given his medical condition, that’s the smart move,” Galligan told The Associated Press on Monday night. “Nobody from law enforcement will be questioning him.”

Galligan said both he and Maj. Christopher E. Martin, Fort Hood’s senior defense attorney, met Hasan. Galligan questioned whether Hasan can get a fair trial at Fort Hood, given Obama’s visit to the base and public comments by the post commander, Lt. Gen. Robert Cone. Galligan also said he plans to raise the issue of Hasan’s mental condition.

The most serious charge in military court is premeditated murder, which carries the death penalty.

The Army has not yet appointed a lead prosecutor in the case, said Fort Hood spokesman Tyler Broadway.

——

Associated Press writers Angela K. Brown at Fort Hood and Pamela Hess in Washington contributed to this report.

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Military retains religious zealot, boots gays

The Army -- ever-vigilant about "Don't Ask, Don't Tell" -- failed to follow up on suspicions about shooter

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President Obama correctly stated that people should not “rush to judgment” regarding the motivation of Nidal Hasan — the individual who killed 13 people at the Fort Hood military base. Unfortunately, the public often races to assign a collective narrative to extremely violent events. Typically, the earliest narratives rest on gross stereotypes and, consequently, miss the mark. For example, many commentators assumed that Arab terrorists bombed the Oklahoma federal building, until they learned that Timothy McVeigh — a disgruntled, white former member of the military — committed the heinous crime.

Recent acts of mass violence have pitted liberals and conservatives against one another. Both sides have argued that the killers’ ideologically laced statements prove the bankruptcy of the others’ political views. Neither side, however, seems to understand or appreciate the deep psychosis that causes acts of mass violence.

While mass murderers often embrace extreme political or religious views, mental illness makes them susceptible to extremism in the first place. According to Dr. Steven Dinwiddie, a professor of psychiatry and behavioral neuroscience at the University of Chicago, commentators who blame religious zealotry for Hasan’s killing spree miss the mark. Dinwiddie says:

I think it would be a mistake for people to theorize [he did this] because he is an adherent of this or that religious faith … The mental illness comes first, then flowing from that is the adoption of perhaps, unusual, religious beliefs.

When commentators adhere to political agendas and discard intellectual integrity, facts rarely matter.

“Don’t Ask, Don’t Tell” and Hasan

Recent reports indicate that military officials knew that Hasan’s upcoming deployment to Afghanistan caused him severe emotional distress. Also, according to unnamed sources quoted by ABC News, the military knew months ago that Hasan tried to establish contact with al-Qaida. Nevertheless, Hasan remained in the military and did not face discharge proceedings or questions about his fitness to serve.

Apparently, the military retained a person who suffered from known (or reasonably discoverable) psychological problems and who attempted to contact an anti-U.S. terrorist group. Meanwhile, the military continues to enforce “Don’t Ask, Don’t Tell” and to discharge mentally fit and loyal gay and lesbian service members. No theory of military preparedness can justify this perverse outcome.

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Professor Darren Hutchinson teaches Constitutional Law, Critical Race Theory, Law and Social Change, and Equal Protection Theory at the American University, Washington College of Law.

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