Whose freedom?

‘They are going to kill us.’

Stephen closed the door behind him and pulled off his face mask. Terry barely looked up from his book. ‘Who’s going to kill us?’

‘Our fellow human beings. Our democratically elected government. No more mask mandate and no more check-in app starting Monday.’

‘The case numbers are holding steady.’

‘For now. Assuming they’re accurate.’

‘Yeah, okay,’ said Terry, returning his eyes to the page.

‘There is no place to go,’ said Stephen. ‘New Zealand’s got it now.’

‘If New Zealand were still covid-free, you wouldn’t be able to go there,’ Terry pointed out.

‘We wouldn’t need to go to New Zealand if we’d kept it out here.’

‘This variant’s extremely contagious,’ said Terry. By this time he was only pretending to read.

‘It is. So close the borders. Unless tourism is more important than people’s lives.’

‘Okay,’ said Terry. He did not remind Stephen again that some people hadn’t seen family members in a year and a half.

‘They don’t care if people die. Old people, people with chronic conditions, they’re gonna die anyway, might as well die of covid. Thoughts and prayers.’

Terry said that 95 per cent of the Australian population were fully vaccinated and that most people followed the guidelines, stayed home, wore masks and kept their distance.

‘It just takes one,’ said Stephen.

‘I think most people are doing their best,’ said Terry.

‘It shouldn’t be up to individuals. Their best isn’t good enough.’

Terry said, ‘We’re doing better than they are in America.’

Stephen said he was very thankful he wasn’t in America where imbeciles refuse to get vaccinated for fear of being microchipped by Bill Gates. Where wearing a mask is treated as a personal choice about protecting yourself and no one is expected to protect other people. Where no one has a right to stay healthy but everyone has a right to believe complete nonsense and do whatever they like. Where the conduct of elected leaders amounts to negligent manslaughter.

Terry put the book down and let Stephen rant without interrupting. It was not a new rant. Stephen had been adamant, consistent and unyielding since the beginning, even as cities suffered one lockdown after another: close everything and keep it closed. Stay home. He had no patience for even mild complaints about restrictions, and the word ‘freedom’ sent him into a bitter, expletive-loaded rage. As one regulation after another was removed, Stephen’s anger and frustration increased. Now he seemed to be in a constant state of fear-tinged fury. 

Why is public health so difficult?

Just over three years after the novel coronavirus came to the world’s attention, it has been the cause of nearly 7 million deaths.¹

It’s not the first disease to take a grim toll in our time. Various influenzas have killed millions.² Even as vaccines are developed and distributed, viruses undergo genetic mutations and over time new strains of the disease arise.³ Health professionals, organizations and national governments⁴ urge everyone – especially those who are over 60, pregnant, or immunocompromised – to get the most up-to-date flu shot ­annually. Despite this strong message, flu vaccination rates globally are low.⁵ This poses an ongoing challenge for public health efforts. Why aren’t people getting vaccinated?⁶

False beliefs, suspicion, and alternative reality

Lack of access isn’t the only reason people fail to get vaccinated. In a world where a handful of corporations control the lion’s share of the media and training in critical thinking is patchy, scientists and educators face a constant struggle to check and correct false beliefs. Information isn’t always easy to understand⁷ and in the case of a new disease, knowledge is evolving and subject to change. It takes time for vaccination to become widely accepted as a routine health measure, even when the disease is not new.⁸

My memory of going to the doctor for a ‘shot’ is that it was just a good habit, like brushing your teeth or eating green vegetables, except that it stings a little. Right now, I am acutely aware that vaccination is by no means ‘routine’ in all communities around the world, and that it is under multiple threats, some of which have little to do with science and everything to do with increasing audience and ratings by spreading misinformation and stoking contrarianism.⁹

A lack of trust in government and medical institutions isn’t limited to the conspiracy-minded fringe. Black Americans, for example, have powerful historical reasons to be wary of the medical establishment, and some of that history is chillingly recent.¹⁰ Then there is cost. In the United States, the costs of visiting a doctor or getting a shot may include not only the consultation but also transport and time away from work, to which many American workers are not entitled.¹¹ It also takes some effort to find a free or inexpensive flu shot if you don’t have health insurance.¹² ‘Inexpensive’ is a relative term. Finally, there are people who have no financial impediments, lack of trust or personal objections to vaccination but simply fail to take the threat seriously enough to act.¹³ 

Vaccines help to develop immunity. They don’t guarantee that you won’t get sick, but they decrease the chances of severe illness and death if you do get sick. It’s natural to want assurance that the payoff outweighs the risk of side effects. But most of us are poor at assessing probabilities.¹⁴ Moreover, when individuals are asked ‘How serious a threat is [the flu, swine flu, bird flu, monkeypox, covid]?’, their answers may reflect how likely they think it is to affect them personally. Perceptions, fears, and feelings of identification or connection can have little to do with the number of cases or deaths, or the likelihood that some random person will get sick. Where there is widespread suspicion and distrust of the government, science, and ‘the media’,¹⁵ alternative views of reality grow like mushrooms. This puts multiple burdens on those who have a professional or ethical commitment to public health.

Misinformation that finds a receptive environment isn’t always the result of a calculated agenda. Sometimes it’s simply a result of scientific knowledge not being immediately obvious. Early in the covid pandemic, health experts believed that the virus was spread chiefly by coughing, sneezing, and touching things. People were advised to wash their hands frequently (a sensible measure, to be sure), to use alcohol-based hand sanitizers, and to wipe down hard surfaces before and after touching them. Subsequent evidence indicated that the main way the virus is spread is by smaller droplets in the air, best addressed by ventilation and face masks.¹⁶ The change of advice was based on new evidence. But ‘flip-flopping’ has long been seen as a sign of weakness or incompetence, and the segment of the populace primed for skepticism found a reason to dismiss experts’ knowledge and advice.

It had been six months since the state border opened. Many people had returned to work outside their homes. Some had no choice, others were going stir-crazy. Still others had discovered that they were more productive working from home and were lucky enough to be allowed to do so. Cities and states suffered resurgences and restrictions, recovered, were hit again, retreated, cautiously re-emerged. Terry was phlegmatic and unflappable, as usual. Stephen was less belligerent than he had been and there hadn’t been any fits of fury lately. Terry thought it was a good thing Stephen had a comfortable desk chair, fast broadband and an empathetic boss.

On a brisk autumn morning, Stephen announced that he had to go to Sydney for a few days. 

‘Lucky you. What for?’

‘Work. Meeting with some people,’ said Stephen. ‘Someone’s coming over from Singapore, someone else from I forget where. It’s the first big thing to happen in person rather than Zoom.’

‘That’s great,’ said Terry. He studied Stephen, who was looking a bit healthier, less like a cave creature. The gym had reopened and people including Stephen were getting out more and socializing. Stephen always wore a face mask, even though it was now optional in many places. ‘Are you looking forward to it?’

‘Are you serious?’

‘Well, yeah,’ said Terry. He suspected that despite the theatrical eye-rolling, Stephen was definitely looking forward to it.

Give me liberty even if it gives you death

During the pandemic, an American living abroad and reading the news might be forgiven for thinking that although the whole world had gone mad, America had turned the madness dial up to eleven.¹⁷ Fifty states, a nation deeply divided socially, politically and economically, and a federal government headed by a narcissistic fool anxious to avoid a stock market catastrophe¹⁸ were the ingredients for a dystopian stew. As the daily cases and deaths accelerated, skeptics continued to insist that covid was no worse than the flu; that whether vaccinated or not, you could still get covid and either way would have a 99 percent chance of survival, so why bother;¹⁹ and that a business, school or any other entity requiring vaccination before entering is violating fundamental rights. Republican politicians such as governors Greg Abbott (Texas) and Ron DeSantis (Florida) have opposed vaccine mandates, and rhetoric about choice and liberty has found a ready following. While some refuse the vaccine because it’s new and they don’t trust it, others use refusal as a defiant gesture, ‘a way to defend their freedom and resist this “tyranny”’, said Ken Resnicow, a professor in the school of public health at the University of Michigan. ‘There’s not many countries that have this dynamic’.²⁰

Preoccupation with individual rights is hardly a new phenomenon in the United States. Freedom from constraints on what a person can do and say is enshrined in the US Constitution’s Bill of Rights. These are ‘negative rights’, which limit the government’s power to control people’s acts or words. The United States has affirmed a constitutional right to own and carry guns, for example,²¹ but while state and federal laws can and do prohibit some acts committed using a firearm, there is no constitutional right to be safe from other people’s use of firearms. As the Constitution is the ‘supreme law of the land’²² no law can be passed that contradicts it.

Covid and the criminal law

A person who transmits a disease does risk legal consequences, even if he had no intent to cause harm. For example, suppose he knows he has covid, yet with deliberate disregard of the risk of infecting other people, goes about his life as usual without taking any precautions. Most states in the US (and many jurisdictions elsewhere) have ‘communicable disease laws’ that make it a crime to expose people to a disease, either intentionally or recklessly. In December 2020, a couple boarded a plane in California and flew home to Hawaii, knowing that they had each tested positive for covid and having been instructed by airport officials to isolate. They were charged with reckless endangerment (recklessly engaging in conduct that creates a substantial risk of serious injury or death to other people).²³ Nevertheless, each element of a criminal offense must be proved, and scenarios involving crowds, such as a festival or football game, do not offer much to discourage individuals from reckless behavior.

Civil remedies

Another potential consequence of recklessly transmitting a disease is litigation. To bring an action against someone in the tort of negligence, you must be able to establish that the person breached a duty of care owed to you, and that the breach caused you harm. In the covid context, neither of these elements is easy to prove. At least 30 states in the US have enacted statutory ‘liability shields’ to protect businesses against lawsuits by persons who claim to have contracted covid as a result of the businesses’ conduct, for example failing to screen people entering the premises or to provide protective equipment to employees. Suing an individual for transmitting covid raises even higher hurdles, particularly establishing the cause and proving that there was a breach of a duty of care.

Freedom’s just another word   

I’d like to think that the idea of a duty to refrain from conduct that puts other people’s health and lives at risk is intuitively compelling, and that most people feel that this obligation outweighs inconvenience or disappointment about forgone fun. But even if such a commitment is widely shared, it didn’t always exert influence during the pandemic.

The fixation on freedom took on a belligerent character in relation to pandemic measures. Hostility to supposed authoritarianism drove demonstrations in Canada, Europe, Australia, New Zealand, and the United States, with ‘freedom convoys’ converging on capital cities to protest any and all regulations. Posts on social media listed all the things people felt they shouldn’t be prevented from doing (visiting relatives, hosting weddings, attending funerals) or compelled to do (getting vaccinated, wearing a mask), and things they simply didn’t like (being called conspiracy theorists, having their access to public places limited because they hadn’t been vaccinated). A recurring theme in their objections is that each of us is responsible for our own health, and nobody else, including the government, should be able to tell us what to do. It was expressed in these fulminations on social media in the second year of the pandemic:

‘Covid isn’t going away so if you’re advocating masks, you’re advocating permanent masks. If you’re anxious, at risk, or immunocompromised, you can wear an N95. Then whether other people are wearing cloth masks or surgical masks makes no difference. It’s time to move on!’

‘You’ve had two years. Two years to eat better, take vitamins, sleep well, exercise, and get a shot. You should feel completely safe at this point, but if you don’t, if you’re still that scared, you stay home. Stay out of restaurants, don’t fly on planes, don’t go to sporting events. If you’re still that scared, you probably deserve the names we used to call each other as kids – the names that questioned your manhood/womanhood, bravery, silly things like that. Regardless of what you chose – shot or no shot – you should be confident of your decision by now!’

The first quote arises from a failure to grasp the concept of probability (understandable and very common – probability is difficult) and the belief that masks are worn to protect oneself (when in fact they are more effective if worn by those who may be contagious, to protect others), seasoned with petulance and a hint of condescension. The second quote takes it one step further: ‘Come on, wake up and be a man, you lily-livered, cowering wimp – you expect everybody else to tippy-toe around, stay home and skip the football just to keep you safe?’. Neither comment betrays any recognition that a contagious disease is not an individual matter like allergies or tinnitus. Like the freedom from restrictions on gun ownership, freedom from vaccines, closures and limits on public gatherings has consequences for many more people than those whose choices and voluntary behavior are directly affected.

The only time Stephen realized that he missed living in Sydney was when he came back to visit friends, and that hadn’t happened for two and a half years. Although this trip was chiefly for work, he had rung a few friends and made plans to get together. He made judicious choices as to whom to call. They were all people who were comfortable sharing their recent whereabouts, habits and vaccination status.

Stephen arrived at the hotel in the afternoon. It was luxurious. Everything was triple-sanitized and there were signs suggesting that guests practice social distancing. Some but not all of the staff were wearing face masks. No one else was.

The familiar feeling of doom and panic started to stir in his gut. He reminded himself that he was up to date on the jabs and that even if he did get sick, it was likely to be milder.

But then there was his friend Laurie. She’d had all the jabs too, but then when the latest variant came along, she fell like an Acme anvil in a Road Runner cartoon.

Stephen fingered his phone, wondering whether it might be a good idea to cancel some of the social engagements. As if on cue the phone played its incoming call song.

It was his boss, Lesley, who preferred to be introduced as ‘a senior colleague’ and whom Stephen quite liked. She wanted to know if Stephen could do some meeting and greeting the following evening.

‘Sure,’ said Stephen. ‘What’s up?’

‘I feel a bit crook.’

‘You’d better not come then. Have you got a rat?’

‘A what?’

‘Rapid Antigen Test.’

‘Oh. Yes.’

‘Don’t put it off.’

‘Okay. It’s probably just a cold.’

‘Very likely,’ said Stephen.

He liked his job. He’d done professional development, mentored new staff, made presentations, attended events, reaped a promotion and a pay rise. For the past two and a half years, however, he’d been less interested in career advancement than in staying alive. On the matter of the meet and greet tomorrow night, he was torn between anticipation and trepidation.

It was a mistake to hold this conference, he thought. It’s too soon to go back to normal.  

Making the world safe for capitalism

Countries around the world now have firsthand experience of the difficulties of running an economy (meaning, at its most basic, the distribution of goods and services) during a pandemic. Efforts to mitigate effects such as broken chains of supply and transport and workers’ loss of income took various forms, and some nations did better than others, depending on the degree to which government intervention in markets is permitted.

In the industrialized world, covid provided an opportunity to rethink the ways in which we buy, sell and trade. Instead of the providers of capital continuing to reap the benefits of the economic system and passing a tiny fraction of the rewards on to the people who do the work, we could have moved the needle a little to the left. We could have tried some small changes, perhaps at the workplace level, as an empirical test. It’s conceivable that policies such as job security for part-time workers, uniform provisions for sick leave, and taking health care out of the hands of employers and insurance companies could contribute to a society that is not only physically healthier, but less competitive, combative and defensive. Public health is harder when we become mean, self-righteous and unwilling to let anybody get something to which they’re not entitled.

Stephen’s phone rang again as he was getting ready to go out. It was Terry, and he got right to the point. ‘I think you’d better get tested.’

‘Please tell me you’re joking.’

‘Why would I joke about it? I did a rat and it’s positive.’

‘I feel fine,’ said Stephen, stricken in equal measure by terror and disbelief. 

‘Do a rat. You know the drill.’

‘Dammit, I just got here.’

‘I thought you were the one who was convinced that it’s a death sentence,’ said Terry. ‘Thanks for your concern.’

‘Sorry. How do you feel? Is it horrible?’ said Stephen, ashamed of himself.

‘I’m sneezing and coughing and it hurts to swallow.’

‘Can you drive? Do you want to see a doctor?’

‘Yes I can drive. No I don’t need to go to the doctor. Really, it just feels like a bad cold. Not that you were actually worried.’

‘I am worried,’ said Stephen.

‘I’ll be okay. If I need anything I’ll get stuff delivered. Just do a rat, isolate if you need to and don’t come home for a week.’

‘I think there’s more to it than that,’ said Stephen.

‘Whatever. Google it. Consult somebody.’

After they hung up Stephen got the box out of his suitcase. There were ten test kits. He took one out, put it on the desk and sat there looking at it, still wrapped. He had tested before, several times. The result had always been negative.

He went into the bathroom, got a glass of water and took a swig of it, swallowed experimentally. Did his throat hurt? He couldn’t tell. He guessed it didn’t. There was a bit of a tickle at the back of his throat but maybe that was the power of suggestion. He didn’t have a headache and he wasn’t sneezing or coughing.

Suppose I hadn’t got that phone call. I wouldn’t have any clue that I might have been exposed. I could just go to dinner with Ellen and her friends, get up tomorrow morning, do some sightseeing, dress to impress, swot up a little and go to the meet and greet.

Stephen sneezed. Then he sneezed again.

Maybe it’s allergies. If I don’t do the test I can just assume it’s allergies.

He went back to the bathroom and washed his hands, returned to the desk and unwrapped the test kit. He unwrapped the cotton swab and stuck it up one nostril, twirled it around and stuck it up the other. He put the swab in the tube and squeezed it ten times, took the swab out and squeezed the contents of the tube onto the indicator paper, drop by drop. He set the timer on his phone and waited.

Reference

The Business Research Company, Gambling Global Market Report 2023 (January 2023). See https://www.thebusinessresearchcompany.com/report/gambling-global-market-report

Photo and artwork credits

Self-Portrait with the Spanish Flu, by Edvard Munch, creator QS:P170,Q41406, NGM 01867, National Museum of Art, Architecture and Design, on Wikimedia Commons, licensed under CC Attribution 4.0 International (CC BY 4.0)

The First Vaccination: Dr. Jenner, n.p. print, by Georges-Gaston Mélingue, courtesy MedlinePlus, National Library of Medicine

Habits in color, Las Vegas Strip, United States, by John Schnobrich on Unsplash

Gun violence memorial, 15 April 2021, by Victoria Pickering on Flickr, licensed under CC Attribution – NonCommercial – NoDerivs 2.0 Generic (CC BY-NC-ND 2.0)

Life Under Quarantine, San Francisco, 8 September 2021, by Christopher Michel on Flickr, licensed under CC Attribution – NonCommercial – NoDerivs 2.0 Generic (CC BY-NC-ND 2.0)

Walmart workers strike on Thanksgiving in Medford, Oregon, by David Blackman, UFCW International Union, on Flickr, licensed under CC Attribution – NonCommercial 2.0 Generic (CC BY-NC 2.0)

Paramedics transporting a patient using an EpiGuard isolation pod, by EpiGuard AS from Pexels.com

Citation

Please cite as: Miller, L. Elaine, ‘Whose Freedom?’, It Could Be Words (blog), 29 April 2023, https://it-could-be-words.com/whose-freedom?

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1. World Health Organization, WHO Coronavirus (COVID-19) Dashboard, https://covid19.who.int/. See also Edouard Mathieu, Hannah Ritchie, Lucas Rodés-Guirao, Cameron Appel, Charlie Giattino, Joe Hasell, Bobbie Macdonald, Saloni Dattani, Diana Beltekian, Esteban Ortiz-Ospina and Max Roser, ‘Coronavirus Pandemic (COVID-19)’ (2020), https://ourworldindata.org/coronavirus [↩]
2. Centers for Disease Control and Prevention, Past Pandemics, Influenza (Flu), https://tinyurl.com/yacmwkr8 [↩]
3. Centers for Disease Control and Prevention, Influenza (Flu), ‘How Flu Viruses Can Change: “Drift” and “Shift”’, https://www.cdc.gov/flu/about/viruses/change.htm [↩]
4. For example: Australia https://tinyurl.com/2524be4a, the European Union https://tinyurl.com/28l634mz, Japan https://tinyurl.com/28h6bjky, and the USA https://www.cdc.gov/flu/prevent/whoshouldvax.htm [↩]
5. Can Chen, Xiaoxiao Liu, Danying Yan, Yuqing Zhou, Cheng Ding, Lu Chen, Lei Lan, Chenyang Huang, Daixi Jiang, Xiaobao Zhang, Zhou Guan, Xiaofang Fu, Yuxia Du, Yushi Lin, Changtai Zhu, Jie Wu, Lanjuan Li, Shigui Yang, ‘Global influenza vaccination rates and factors associated with influenza vaccination’, International Journal of Infectious Diseases, December 2022, https://tinyurl.com/254yjbjn [↩]
6. The reasons for low uptake in less affluent countries are not limited to affordability. They may also include limited data about the cumulative consequences of the disease, lack of awareness of or about the disease and about vaccines’ effect on public health, and technical challenges in the provision of vaccines: Justin R. Ortiz and Kathleen M. Neuzil, ‘Influenza Immunization in Low- and Middle-Income Countries: Preparing for Next-Generation Influenza Vaccines’, Journal of Infectious Diseases 2019 (Issue Supplement 1), 15 April 2019, pp. S97–S106, http://doi.org/10.1093/infdis/jiz024; C. M. Gaskin, D.R. Woods, S. Ghosh, S. Watson, L. R. Huber, ‘The Effect of Income Disparities on Influenza Vaccination Coverage in the United States’, Public Health Reports 138(1), January–February 2023, pp. 85–90, http://doi.org/10.1177/00333549211069190 http://doi.org/10.1177/00333549211069190 [↩]
7. For example, the difference between efficacy and effectiveness: World Health Organization, ‘Vaccine efficacy, effectiveness and protection’, 14 July 2021, https://tinyurl.com/yf2fqjps [↩]
8. In the USA, the combined measles, mumps and rubella vaccine was licensed in 1971: Paul Gastanaduy, Penina Haber, Paul A. Rota, Manisha Patel, ‘Epidemiology and Prevention of Vaccine-Preventable Diseases’, Centers for Disease Control and Prevention, August 2021, https://tinyurl.com/462v7app [↩]
9. On the role of powerful commercial interests in spreading falsehoods, see Kirsten V. Brown, ‘Fox News coverage sowed vaccine hesitancy, study says’, Bloomberg, 11 March 2023, https://tinyurl.com/25ewzb7r. In a study published in March 2023 in the journal Political Communication, Professors Matthew Motta (Boston University) and Dominik Stecula (Colorado State University) concluded that following negative coverage of covid vaccines by Fox News, there was an increase in reports of side effects of covid vaccines, and Fox viewers were more reluctant to get the vaccine. [↩]
10. See for example E.A. Rusoja and B.A. Thomas, ‘The Covid-19 pandemic, Black mistrust, and a path forward’, eClinicalMedicine, 6 May 2021, https://tinyurl.com/22r9lnjd; and Sanjana Manjeshwar, ‘America’s Forgotten History of Forced Sterilization’, Berkeley Political Review, 4 November 2020, https://tinyurl.com/ybo8hedt [↩]
11. See Molly Weston Williamson,‘The State of Paid Sick Time in the US in 2023’, Center for American Progress, 5 January 2023, https://tinyurl.com/2ddvof6c [↩]
12. Mikayla Morell, ‘Five places you can get a flu shot without insurance’, Health, 5 December 2022, https://tinyurl.com/29sg8yrp [↩]
13. David Mitchell, ‘Survey reveals common misconceptions about flu, vaccination’, American Academy of Family Physicians News, 22 January 2020, https://tinyurl.com/22s49hj3; Deb Gordon, ‘As experts brace for flu season, new survey shows Americans aren’t prepared’, Forbes, 6 October 2022, https://tinyurl.com/2byv6u6t [↩]
14. Lila Thulin, ‘Why it’s so hard to make risk decisions in the pandemic’, Smithsonian Magazine, 10 May 2022, https://tinyurl.com/y6qt5qzg; A.C. Shilton, ‘Why you’re probably not so great at risk assessment’, The New York Times, 30 June 2020, https://tinyurl.com/27c33yrt [↩]
15. A handful of corporations control the dissemination of news, public broadcasting hangs on by the thin lifeline of fundraising campaigns and is at the mercy of governments that may be (and have been) ideologically hostile. Yet the conviction that news organizations have a left-wing bias persists. Eric Alterman’s What Liberal Media?: The Truth About Bias and the News (Basic Books, 2003) is still as pertinent as it was twenty years ago. [↩]
16. Tanya Lewis, ‘How the US pandemic response went wrong – and what went right – during a year of COVID’, Scientific American, 11 March 2021, https://tinyurl.com/ycp9ta3s [↩]
17. No doubt plenty of people from other countries – India, Brazil, Mexico, Turkey, Russia, the UK and Belarus, to name a few ­– thought the same of their own governments and their fellow citizens. [↩]
18. See Maggie Haberman and Noah Weiland, ‘Inside the coronavirus response: a case study in the White House under Trump’, New York Times, 16 March 2020, https://www.nytimes.com/2020/03/16/us/politics/kushner-trump-coronavirus.html [↩]
19. See for example Arijeta Lajka and Jude Joffe-Block, ‘Survival rates for COVID-19 misrepresented in posts’, AP News, 24 July 2021, https://apnews.com/article/fact-checking-970830023526 [↩]
20. Alana Wise, ‘The political fight over vaccine mandates deepens despite their effectiveness’, NPR, 17 October 2021, https://tinyurl.com/yf9ugmqk [↩]
21. The US Supreme Court’s current interpretation of the Second Amendment, as held in District of Columbia v Heller, 554 US 570 (2008), is that it ‘protects an individual right to possess a firearm unconnected with service in a militia, and to use that arm for traditionally lawful purposes, such as self-defense within the home’. [↩]
22. US Const. art. VI, cl. 2 [↩]
23. ‘Couple face charges for boarding plane to Hawaii after positive Covid test’, The Guardian, 4 December 2020, https://tinyurl.com/y3gqfnfm [↩]