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Critique: a worldwide student journal of politics The Electoral Disconnect and its Constitutional Implications Ryan Duffy Boston College The 113th Congress was among the least productive in modern history1 and most partisan and ideologically polarized ever2. The approval rating averaged at 15 percent, one of the lowest approval ratings on record3. Congressional inertia and gridlock manifested itself through a variety of non-resolved legislative issues. The 113th Congress’s tenure, lasting from January 3rd 2013 to January 3rd 2015, featured many impending economic, political, and cultural issues that waxed and waned in urgency and relevance. From the international threats of jihadi terrorism and nuclear proliferation to the domestic burdens of an aging population’s entitlements and deficit reduction, there was no paucity of pressing issues it faced. Both international and domestic in nature, one issue that Congress faced and continues to face carries great constitutional and democratic relevance: climate change. With no precedent in the history of American government and no explicit acknowledgement or implicit references in the Constitution, the issue has proven politically difficult to address. The Constitution’s bedrock principles, the rule of democracy and the guarantee of individual rights suggest that Congress should address climate change. Though the United States has a responsibility and capability to act on the issue, it has been relatively ineffective in doing so. This article intends to show, through the issue of climate change, how Congress has neglected its most critical responsibility: to represent the will and interests of the American people. With the centralization of public policy, a schism between constituents and their congressmen and congresswomen has developed, and has widened further from the growing influence wielded by special interest groups. The schism, which this article will refer to as the electoral disconnect, negates democratic and constitutional accountability. An apt example of this disconnect is the de-stabilization and postponement of climate change legislation. The Fall 2015 article will focus on how the US Congress has ceased to represent the interests of everyday Americans and why it is unable to tackle issues like climate change. First, the article will spell out the constitutional era models for American government. Then it will examine the evolution of power and responsibility at the state and national levels, explore the incursion of special interests into politics, and address the growing political apathy of the American public. Lastly, the article will employ the issue of climate change to exemplify the electoral disconnect, that is, how Congress has ceased to be representative to its constituency. The Constitution-Era Conversation Democracy in America, written by America’s first political commentator, French Statesman Alexis de Tocqueville, was a political almanac of sorts that categorized the political models and geographic diversity of the nascent United States. Since de Tocqueville was well-versed in the traditions of centralized French government highly autonomous from the will of the people, the advantages and drawbacks of America’s new political experiment were identifiable to him. He coined the name for New England local political system “town-hall politics” and admired it. “The New Englander is attached to his township because… he shares in its management…he invests his ambition and his future in it,” and eventually gains “clear, practical ideas about the nature of his duties and the extent of his rights”4. Thomas Jefferson also saw the importance of an engaged polity: “a well-informed electorate is a prerequisite to democracy”5. If this is the case, “They can be trusted with their own government; that whenever things get so far wrong as to attract their notice, they may be relied on to set them to rights”6. The levels of participation and engagement with local government, and political engagement of constituencies, made the political formula of the nascent United States functional and highly successful. Ultimately, while de Tocqueville was enchanted by the local civic and administratively-savvy polities of New England and their remarkable 52 Critique: a worldwide student journal of politics capability to self-manage, he noted that the central government was a necessary corollary. The system was efficient because the highly engaged citizenry was able to implement and monitor laws and policies while still operating as a subsidiary to a central, regulatory government. De Tocqueville’s passionate embrace of local government and reluctant acceptance of a national government foreshadowed the latent tension between the two that would threaten the Union. This antagonism erupted with the advent of the Civil War, where dissenting political states with localized interests and differentiated political goals seceded from the Union. The outcome of the Civil War reified the supremacy of the national government over state and local subsidiaries. Centralization since the Constitution Since de Tocqueville’s visit to America, the national government has accrued more responsibilities as policy development has centralized. As this centralization has occurred, Congress has enacted more sweeping and monumental legislation. Despite the increased autonomy of Congress, states and localities are essential in using region-specific and differentiated knowledge to implement the national policies. Since the Founding Era, though, states seem to have gone from being the primary proprietors of legislation and management in De Tocqueville’s “town-hall politics” model to the administrators and implementers. On many occasions the states push back or even lead the national government on legislation. For the most part, though, the passionate embrace of politics de Tocqueville adored has eroded as necessity dictated the build-up of a powerful national government and centralized system. As the national government has grown it has gained more relative power and policymaking capabilities vis-à-vis its subsidiaries. The growth in Congress’s policy development capabilities has been facilitated by many events of the 20th century. Watershed examples include the New Deal, government takeover during World 53 Fall 2015 War II, and the triumph of national government over state and local governments during the Civil Rights era. This gradual transition has bestowed much autonomy on the elite politicians, a reality that the Founding Fathers, specifically the Anti-Federalists, might have hoped to avoid. With more responsibility shifted to the national government, political decision-making has become more monumental and less conducive to state and local discretion. This top-down dynamic of governing is exemplified through the National Minimum Drinking Age Act of 1984 and the Americans with Disabilities Act of 1990; the former virtually coerces states to follow its provisions: “The 1984 National Minimum Drinking Age Act, requires that States prohibit persons under 21 years of age from purchasing or publicly possessing alcoholic beverages as a condition of receiving State highway funds,”7 while the latter explicitly does: “the Federal Government plays a central role in enforcing the standards established in this chapter on behalf of individuals with disabilities”8. This hierarchical style of lawmaking shows the merits of paternalistic and centralized top-down legislation: the former rose the drinking age to a more responsible and safe threshold while the latter secured rights for minorities and handicapped individuals. With these strengths there are also significant drawbacks, since state governments are not as able to act with localized discretion and pursue their differentiated political goals. Legislation is indiscriminately applied to the entire United States for issues that do not require national uniformity. Issues where national uniformity matter—such as military spending, interstate commerce, and minting currency—are delegated to Congress in Article 1 of the Constitution. Other issues not explicitly addressed by the Constitution have become de facto responsibilities of the national government, such as the guarantee and protection of minority constitutional rights. The aforementioned Americans with Disabilities Act represents one such example, since the national government forced state and local governments’ hand by mandating them to undergo an initiative they might have been unwilling to pursue 54 Critique: a worldwide student journal of politics otherwise. Congress’s safeguard of universal, constitutional rights exemplifies how it can effect change on its subsidiaries, whether necessary or not. When Congress sets national regulations all states must abide by them, even if the regulations are not applicable to their geographic or political circumstances. One example is the minimum wage: certain regions of the United States with lower costs of living are forced to enact a minimum wage that exceeds the minimum amount of money needed for economic sustenance9. This enactment of a national standard does not allow for the diversity of circumstances to dictate the appropriate wage, which means that minimum wages in places with a low cost of living may be unnecessary and unhelpful to local economies. This minimum wage example shows the latent tension possible with centralized policy decision-making, since balance of power between the levels of government is altered. The national government’s increase in autonomy—establishing a uniform minimum wage—reduces the autonomy of state and local governments, who would be able to gauge a fair minimum wage more accurately. The centralization of policy development has not negated the power of states and localities. Even though the size and scope of national government has grown, state and local levels of government are still very robust. Since the early 20th century, they have led the national government on questions of woman’s suffrage, abortion, same-sex marriage, and marijuana decriminalization. In recent years, as some states have pushed forward with marijuana decriminalization initiatives, they have acted in defiance of both national and local levels of government. State governments can and do project their interests onto the national government, though this pushback has become the exception rather than the norm. In de Tocqueville’s time, the states and localities were their own legislators and administers while the central government was a passive and uninvolved overseer. Now the model is more one of top-down rulemaking; Congress legislates and 55 Fall 2015 manages while the states and localities interpret and administer the law with their local knowledge10. At the time of the Founding, the national government did not engage in the multitude of activities that it does today. The size and scope of Congress’s policymaking abilities have increased since the writing of the Constitution, as watershed points in history have necessitated a centralization of public policy. The corollary to this centralization has been the wider latitude of discretion afforded to Congress on issues with which they have historically had little engagement. The Decline in Public Interest and Incursion of Special Interests De Tocqueville praised the inclination of Americans to form associations and celebrated these groups as a key element of democracy. To him, they contributed to the democratic character of the American political system: “In no country in the world has the principle of association been more successfully used, or applied to a greater multitude of objects, than in America”11. These groups were formed to tackle social and political issues and reflected a strong democratic culture, yet they have taken a very different—and undemocratic—turn in recent years. With the political changes of the past few decades, many powerful special interest groups and corporations have been able to underwrite, bankroll, and influence costly political campaigns to promote their agenda. Since the most sweeping and influential public policy is adopted and drafted by Congress, interest groups target individual representatives to promote their agenda and influence the legislative process. Interest groups and corporations, due to their specialized and technical knowledge of specific issues, are regarded as experts by members of Congress and allowed to draft and influence legislation. Additionally, media has increasingly turned to subjective rather than fact-based reporting, which contributes to the political obscurity between constituents and Congress. From special interest groups and partisan-saturated media 56 Critique: a worldwide student journal of politics stem legislation that represents the determination and agenda of special interests, rather than the constituents of Congress. The most politically potent issues and causes are centered with the groups that have the most capital and willingness to effect change. Wealthy interest groups and corporations have increasingly held sway in elections by attaching conditions to campaign money and gaining favor with political candidates. In the past 40 years, Congress and the Supreme Court have provided avenues for increased private spending in elections. In the 1970s Congress passed amendments to the Federal Election Campaign Act (FECA), which set contribution limits and spending caps for candidates. In 1976, with the case Buckley v. Valeo, some of these amendments were challenged as violations to free speech rights. The Supreme Court ruled that individuals and groups “are free to spend as much as they want to promote the candidate and his views,” so long as they explicitly refrain from using the terms “vote for,” “defeat,” or “elect”12. In 1979, amendments were made to FECA that created a loophole allowing individuals, unions, and corporations to give unlimited amounts of money to parties for “party-building” purposes. In the past 15 years, the Supreme Court has declared the production of ads paid for by corporations or unions in the weeks leading up to elections, unlimited spending of corporations and unions for political campaigns, and unlimited individual donations to federal campaigns and political parties constitutional. As a result of these amendments and rulings, wealthy and powerful individuals, unions, special-interest groups, and corporations have been given the opportunity to unduly influence elections. As special interests have gained influence at the national stage, constituencies have become recalcitrant and unengaged. The infusion of special interest capital into national government has been coterminous with a decrease in political confidence among voters. In 2014, Congress’s approval rating averaged at 14%, and yearly approval averages have not exceeded 20% for the past five years13. In the 40 years before 2008, Congress’s job approval only dipped below 20% 57 Fall 2015 twice (in 1979 and 1992)14. This downward trajectory is a result of low productivity and ideological polarization. Political gridlock and highlypartisan politicking are influenced and exacerbated by special interest politics and are unrepresentative of the political views and divides between the average, centric-oriented Americans. Additionally, over the past 50 years, voter turnout has not been sufficiently robust: on average, roughly two-fifths of the United States eligible voting population did not turn out for presidential elections and nearly threefifths for midterm elections15. These figures, coupled with low Congress approval rating16, suggest that the American electorate is collectively disappointed and unengaged17. The decrease in Americans’ political efficacy, coupled with federal legislation that is more unilaterally applied and less contoured to local realities and specific circumstances, have disconnected constituents from their congressmen and congresswomen. As Thomas Jefferson noted, a prerequisite to political rule is the mandate of the people. Citizens appear less interested and confident in a national government that has broad powers and capital-backed interests. This disconnection between average Americans and their political representatives has created a vacuum of political legitimacy. This schism—the electoral disconnect—has weakened democratic procedures and ushered in an era characterized by the prioritization of special interests and polarized ideology. Contemporary America is nominally more democratic today than at the time of the Founders; all ethnic and gender constituencies, barring felons and non-citizens, have been enfranchised. While this does signify a more democratic system, in actuality democracy has been crippled by the incursion of special interests into politics: the corollary of this incursion is the influx of capital and divisive ideology. Ideas that are backed by money receive higher precedence than those without money, and groups deeply-committed to a single idea will go to greater lengths to transpose their wishes onto representatives—regardless of whether these groups reside within the constituencies of the 58 Critique: a worldwide student journal of politics representatives they are seeking to influence. As a result, private interests can override citizens in other constituencies, and certain issues are institutionalized without public backing. The electoral disconnect has developed from the co-existence of a powerful Congress, an unengaged citizenry, and groups willing and able to influence political agendas. From these political developments, a deeply divisive and polarized political system beholden to special interests has emerged. While it may seem that the country as a whole is politically polarizing beyond compromise, it is important to note the Congress-constituency synecdoche at play. When considering polarization, Americans should be disentangled from their Congress because the latter does not represent the former and the two bodies do not necessarily have comparable aims. The gridlock and deep partisan divide of the 113th Congress does not accurately reflect the divide in ideology between Americans. Congress’s inability to forge bipartisanship is a testament to how “institutionalized” special interests have become in national politics18. Actors, most notably single-interest groups; a partisansaturated media; and hefty campaign-donors exert undue power on the political system by investing significant amounts of time, attention, and capital into affecting their representatives’ political agenda. Unbeknownst to the public, Congressional discourse is “disembodied” from their best interests. James Davison Hunter best describes this phenomenon when he makes the case that because of electoral detachment, “public discourse is more polarized than the American public itself”19. The New Congressional Accountability System and Climate Change The electoral disconnect, the constitutionality of the factors that give rise to it, and its consequences are perfectly exemplified through the issue of climate change. From a constitutional perspective, the issue threatens Americans’ inalienable rights, and representatives are making 59 Fall 2015 decisions at the expense of their constituents. Democratically speaking, the debate has been influenced by special interests to the point where minority interests are promoted at the expense of a majority of American citizens. A schism exists between what a well-enlightened citizenry should want and what their representatives actually want. This schism partially exists because of a special-interests sponsored campaign to deny the existence of climate change, a phenomenon which is accepted almost unanimously among climate scientists20. Ultimately, the issue has been undemocratically influenced, and the proceedings of Congress are unconstitutional because of the real endangerment of “life, liberty, and the pursuit of happiness”—safety, freedom, and wellbeing—that climate change carries. Climate change is a systemic phenomenon that can result in the destruction of property and lives. There is empirical evidence that corroborates the proposition that changes in global climate patterns are attributed to man and his institutions21. There is also copious evidence of its deleterious ramifications: natural disasters are intensified22, drought is exacerbated23, and crop yield is lessened24. All of these issues pose a threat to Americans’ inalienable rights and thus necessitate a political response. Despite this, Congress has, for the most part, proceeded in a recalcitrant and reckless manner by blocking international treaties to reduce emissions and postponing climate change legislation. Future consequences of climate change include wildfires of increased frequency and intensity, sea level rise, declining water supplies, heat-related health impacts, flooding, and erosion25 . These ramifications pose a risk to the welfare of every state in the United States, most notably those with high-density coastal communities. The National Aeronautics and Space Administration (NASA) concluded that if left unchecked, climate change will continue to impose massive economic and environmental hardships on the United States26. For current and future occupants of the earth, there will be systemic changes that will affect everyone’s safety and well-being. Therefore, it 60 Critique: a worldwide student journal of politics is appropriate to construe climate change as a threat to the inalienable rights of “life, liberty, and the pursuit of happiness” guaranteed by the Constitution. Political recognition of the existence of climate change and the direct impacts on safety and wellbeing it carries is a natural first step towards attempting to stop it, yet many in Congress appear unwilling to accept the phenomenon due to bad-faith debates of its existence or an aversion to short-term costs. These politicians, who prefer expedient political favor and short-term economic gain, are mortgaging the rights and welfare of their constituents. For example, Senator Ted Cruz of Texas recently said “For the last 17 years, there’s been zero warming”27. This comment was made some 4 months before record storms and floods killed over 30 in Texas and Oklahoma. Some congressmen and congresswomen, who refer to themselves as climate skeptics, doubt the existence of climate change or any anthropogenic connection to it. Included in this cohort are leaders in the Senate including Senator John Cornyn, Senator Jim Inhofe, Congressman Fred Upton, and Senator Mitch McConnell. The authenticity of their doubts is questionable; over the last few decades the scientific community has strengthened its certainty that climate change is happening and is induced by man. Contrary to the beliefs of the politicians referred to above, 97 percent of climate scientists agree that “climate-warming trends over the past century are very likely due to human activities”28. As indicated, this phenomenon is a systemic reality that has affected, and will continue to affect, the American citizenry negatively. Notable leaders, including US President Barrack Obama, Pope Francis, and US navy admiral Samuel J. Locklear III have all referred to climate change as the biggest threat to “long-term security”29. The potential to curb climate change and its effects exists with the option to replace carbon emitting energy sources, accounting for climate change’s externalities, or enacting cap-and-trade policies. Despite the constitutional rationalization of attaining these measures, entrenched 61 Fall 2015 special interests promote denial campaigns to stave off reform and thereby obstruct democratic accountability. Curbing climate change is an issue which merits national uniformity and is therefore meant for the national government; the collective effort of its subsidiaries is insufficient for the enactment of sweeping climate-action and fossil-fuel mitigation reform. Climate change is simultaneously a regional and a macroscopic issue—it will affect and endanger nation, states, and localities with the same destruction. Therefore, in accordance with the Constitution’s safeguard of inalienable rights, Congress should attempt to curb climate change’s causes and mitigate its effects. Congress is neglecting its core responsibilities: to represent the will the American people and to protect their rights and welfare. Certain Congress members are disseminating false information and accommodating special interests rather than that of their constituencies. The oil, coal, and natural gas industries have entrenched interests antagonistic to any climate regulation because it will threaten their runaway wealth accumulation30. For example, the Koch brothers alone have committed millions of dollars to denying climate change and to de-railing reform31. These industries’ credo is clear: nature is a resource for prosperity, regulation of the environment threatens free enterprise, and it would be economically indefensible to change paths now. Unfortunately, their credo does not account for the negative externalities the current system imposes on the public, and thus, as it is promoted politically over the constitutional goal of protecting inalienable rights, electoral accountability is negated. As a result of this electoral disconnect, some representatives of Congress are acting in the interests of special groups or individuals rather than in the interests of their constituencies and states. The interference of capital and special interests into national level politics distorts democracy, since the politicians being influenced may not be representatives of the groups or people paying and supporting them. When representatives accept money from those in the fossil- fuel 62 Critique: a worldwide student journal of politics industry or any other industry with an active interest in postponing action to curb emissions, they are directly violating their democratic mandate to serve the interests of their states and constituencies. Since climate change is a threat to every citizen of the United States, this means that congressional representatives have offered to mortgage the rights and safety of their constituents and act in a myopic nature according to the will of the moneyed interests. Accountability to short political windows, economic expediency, and special groups are replacing Congress’s mandate to serve the People’s best interests. Climate change denial tactics obscure fact and disillusion Americans. An indisputable issue like whether changes in climate patterns are caused by man is debated in Congress by politicians who are funded by groups and corporations with enormous stakes in the conversation. Political provocateurs have jabbed that the intensity of recent winters disprove the notion that the climate is changing; Glenn Beck posited “I don’t think it takes a genius to see through the ‘more snow is proof of global warming’ claim”32 while Sean Hannity stated “It’s one of the most severe winter storms in years, which would seem to contradict Al Gore’s hysterical global warming theories”33. Bill O’Reilly referred to the science of climate change as “guesswork”. At best, these claims are misguided and made by those unfamiliar with climate science, but at worst they are an attempt to justify congressional inaction and the preservation of the status quo at everyone’s expense. Jefferson and de Tocqueville stipulated that a pre-requisite for democracy was an informed and engaged citizenry. Denial tactics negate transparency in the government for the advancement of special interest agendas. A knowledgeable and involved constituency can calculate its best interests and keep political representatives beholden to its agenda. The advancement of any special agenda through the percolation of false information threatens the political clout and knowledgeability of voters and reduces a democracy’s legitimacy. As Thomas Jefferson warned, if the government is to effectively protect 63 Fall 2015 the rights of its citizens, they must engage it and give consent to its decisions. The electoral disconnect represents the dangers of a democratic, representative government no longer representing the interests of Americans or protecting their rights. Climate change underscores the perils of the electoral disconnect. The schism between a non-engaged citizenry and a special interests-laden Congress has ushered in an era of irresponsible lawmaking and a failure to represent and protect the interests of all Americans. Endnotes Sherfinski, David. 2014. "113th Congress Narrowly Avoids ‘Least Productive’ Status: Report." Washington Times, December 29. 2 "The Polarized Congress of Today Has Its Roots in the 1970s." 2014. Pew Research Center RSS. June 12. 3 Blumenthal, Mark and Ariel Edwards-Levy. 2015. “Congress’ Approval Rating Remains Dismal.” The Huffington Post, January 14. 4 Alexis De Tocqueville. 1840. Democracy in America Chapter V. 5 “Thomas Jefferson to Richard Price.” 1789. January 8. Available at http://www.loc.gov/exhibits/jefferson/60.html 6 Ibid. 7APIS - The 1984 National Minimum Drinking Age Act. 8 Americans with Disabilities Act of 1990. Public Law 101-336. 108th Congress, 2nd session (July 26, 1990). 9 "Why Some Economists Oppose Minimum Wages." 2014. The Economist. January 22. 10 As a result of policy centralization, states and localities are protective of, and directly accountable to, their constituencies, while Congress is the level of government increasingly targeted by special-interest lobbying efforts. State accountability is shown by the efforts of states in recent years to lead the national government on certain social issues or push back on unfavorable national initiatives. 11 Alexis De Tocqueville. 1840. Democracy in America Chapter VII 12 Buckley v. Valeo, 424 US 1. 1976. 13 Riffkin, Rebecca. 2014. “2014 U.S. Approval of Congress Remains near All-Time Low.” Gallup. December 15. 14 Ibid. 1 64 Critique: a worldwide student journal of politics "Voter Turnout." FairVote.. Available at http://www.fairvote.org/voter_turnout#voter_turnout_101 16 Blumenthal, Mark and Ariel Edwards-Levy. 2015. “Congress’ Approval Rating Remains Dismal.” The Huffington Post, January 14. 17 Kohnle, Ian. 2013. "Angry, Yet Apathetic: The Young American Voter” Harvard Political Review, December 4. 18 Grossmann, Matt. 2007. "Institutionalized Pluralism: Advocacy Organization Involvement in National Policymaking." Paper presented in Annual Meeting of the American Political Science Association. 19 Hunter, James Davison, and Alan Wolfe. 2006. Is There a Culture War? A Dialogue on Values and American Public Life. Washington, D.C.: Pew Research Center, p. 30. 20 “The consequences of Climate Change” Climate Change: Vital Signs of the Planet. Available at: http://climate.nasa.gov/effects/ 21 Oreskes, Naomi. 2004. "The Scientific Consensus on Climate Change." Science v. 306, no. 5702, p. 1686; Thomas, Chris D. et al. 2004. "Extinction Risk from Climate Change." Nature v. 427, no. 6970, pp.145-148; Parry, Martin, Jean Palutikof, Clair Hanson, and Jason Lowe. 2008. "Squaring up to reality." Nature Reports Climate Change, pp. 68-71. 22 Van Aalst, M. K. 2006. The Impacts of Climate Change on the Risk of Natural Disasters. Disasters, v. 30, pp. 5–18. 23 “Climate Change Indicators in the United States.” Environmental Protection Agency. Available at http://www3.epa.gov/climatechange/science/indicators/ 24 Seifert, Cristopher and David Lobell. 015, ‘Response of Double Cropping Suitability to Climate Change in the United States’, Environmental Research Letters, vol. 10, no. 2, pp. 1-6. 25 “The consequences of Climate Change” Climate Change: Vital Signs of the Planet. Available at: http://climate.nasa.gov/effects/ 26 Ibid. 27 Senator Ted Cruz (R-TX), Fox News Interview. 2015. 28 W. R. L. Anderegg. 2010. “Expert Credibility in Climate Change,” Proceedings of the National Academy of Sciences vol. 107, no. 27, pp. 12107-12109. 29 Park, Madison. 2015. "Obama: No Greater Threat to Future than Climate Change” CNN, January 21; Winfield, Nicole. 2015. "Pope Francis On Climate Change: Man Has 'Slapped Nature In The Face'" The Huffington Post; January 15; Bender, Bryan. 2013. “Chief of US Pacific Forces Calls Climate Biggest Threat” The Boston Globe, March 9. 30 Klein, Seith. 2012. "Inequality Undermines Collective Action on Climate Change." Behind the Numbers, May 24. 31 Carrk, Tony. 2011. "The Koch Brothers: What You Need to Know About the Financiers of the Radical Right." Center for American Progress, April 4. 65 15 Fall 2015 Glenn Beck, 2010. Fox News, February 10. Cited in DiMaggio, Anthony. 2010. “Conspiracy” Science” Mass Media and the Conservative Backlash on Global Warming" Monthly Review, March 10. 33 Armbruster, Ben. 2010. “Hannity: Snow Storms ‘Seem To Contradict Al Gore’s Hysterical Global Warming Theories’. Think Progress, February 9. Cited in DiMaggio, Anthony. 2010. “Conspiracy” Science” Mass Media and the Conservative Backlash on Global Warming" Monthly Review, March 10. 32 66