Posted by Eugene Volokh:
Political Terrorism in America:
http://volokh.com/archives/archive_2009_09_06-2009_09_12.shtml#1252709832


   Very bad, not just for the victims, but for public debate more
   broadly; I very much hope that it remains an aberration, or else the
   consequences will be bad for speakers with a vast range of views. From
   [1]CNN:

     Authorities have charged an Owosso, Michigan, man with two counts
     of first-degree premeditated murder in the Friday shooting deaths
     of an anti-abortion activist and another man, a prosecutor's office
     said.

     Authorities say the suspect, Harlan James Drake, was offended by
     anti-abortion material that the activist had displayed across from
     [a local high] school all week.

     Drake, 33, is accused of shooting anti-abortion activist Jim
     Pouillon, 63, and Michael Fuoss, 61, who were killed in separate
     locations Friday morning, the prosecutor's office in Shiawassee
     County said.

     Authorities also have charged Drake with a felony firearm count and
     carrying a dangerous weapon with unlawful intent, the prosecutor's
     office said.

     Drake also is suspected of "attempting to locate a third victim
     without success," the office said....

   I've labeled killings and threats against abortion providers as
   anti-abortion terrorism before (see [2]here, [3]here, and [4]here).
   This likewise appears to be a domestic terrorist attack, though as I
   said I hope that it will remain a rare isolated incident.

References

   1. http://www.cnn.com/2009/CRIME/09/11/michigan.shooting/
   2. http://www.volokh.com/2003_05_25_volokh_archive.html#200344868
   3. http://www.volokh.com/2003_08_17_volokh_archive.html#106131139826045431
   4. http://www.volokh.com/2003_10_12_volokh_archive.html#106597843568092919

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