—John Bolton, Undersecretary of State for Arms Control and
International Security Affairs in the current Bush administration.1

Illusions in the UN

AS THE Bush administration has sought to escalate its “war on terrorism” by preparing to launch a preemptive war against Iraq, many people have looked towards the United Nations (UN) as the key international institution to either ensure that such an attack would be legitimate, or to prevent military intervention in the first place. Opinion polls in the U.S. show that if Washington does not have UN approval, only a minority of the population would support war.² Meanwhile, many anti-war petitions and resolutions have cited lack of UN support as a reason to reject Bush’s plans. For example, an “Open letter from the academic community opposing a U.S. invasion of Iraq,” which has been circulating by email, and had collected over 28,000 signatures by late October, opposes military action on the grounds that “only the [UN] Security Council has legal authority to start wars.” The statement continues: “If pursued, war should be the last resort, undertaken collectively by a UN sponsored international coalition....”³ A resolution passed by the progressive United Electrical Workers of America at its national convention in September opposes a U.S. invasion of Iraq, and calls instead for “a genuinely multilateral diplomatic approach to the Iraq situation, sanctioned and directed by the United Nations.”⁴ The San Francisco-based human rights organization Global Exchange has called on activists to send faxes to the UN Security Council to “stop the rush to war.”⁵

But the belief that United Nations’ approval would offer real legitimacy to military intervention and the hope that the organization might provide some kind of shortcut to stopping Washington’s war plans, are based on an idealized and utopian view of the UN’s role in international relations. From its very beginning in 1945, rather than a force for peace, the UN has at various times been either a vehicle for the major powers to promote their own interests or an ineffectual irrelevance. Moreover, the U.S. government has time and again made it perfectly plain that it is prepared to make tactical use of UN cover for its actions when it can, but that is has no compunction in ignoring or bypassing the UN if it thinks that this will better serve its purposes. This is the message that George W. Bush took to the UN when he spoke before the General Assembly on September 12, telling the delegates that the United States would “make that stand” against Iraq, whether or not the UN did so as well.6 Bush repeated the message more bluntly at the Asian-Pacific Economic Cooperation forum in October: “If the UN does not pass a resolution which holds [Iraqi leader Saddam Hussein] to account and that has consequences, then, as I have said in speech after speech after speech, if the UN won’t act…we will lead a coalition to disarm him.” White House spokesperson Ari Fleischer added that “No one has ruled out the possibility that the UN will fail [to live up] to the challenge of the threat of Saddam Hussein,” and that it would be “[n]ot very hard at all” for the U.S. to attack Iraq without UN support.7

The fact that Washington manipulates or ignores the UN at its convenience, however, is not the only problem. As former UN Humanitarian Coordinator in Iraq, Denis Halliday has noted, hypocrisy, double-standards, and power politics are deeply embedded in the organization’s structure and actions.⁸

Much of the violence in the world today results from either the neglect by the powerful member states of the Security Council, or from actions designed to protect their vested interests. The cozy deal…among veto-wielding member states that allows the destruction of Chechnya [by Russia] to unfold before the eyes of the world without getting on the agenda of the Council, appalls. The self-protective hesitancy of the U.S., UK, and China as Indonesian army-supported militia slaughtered thousands in East Timor [in 1999], disgusts. The blatant use of Chapter VII of the UN Charter to attack carefully chosen enemies under hastily raised UN umbrellas, while protecting allies guilty of equal or even worse depredations, presents a double standard of approach that calls into question not only the integrity of the member states concerned, but far worse: the very credibility of the United Nations worldwide.⁹

This is the ugly reality that those who look to the UN as a basis for international legitimacy, or as a force for peace, all too often ignore.

History: Founding and structure

The actual record of the United Nations stands in sharp contrast to the high-minded ideals embodied in its founding Charter. According to that document, the purpose of the new organization was

to save succeeding generations from the scourge of war…to reaffirm faith in fundamental human rights…to establish conditions under which justice and respect for the obligations arising from treaties and other sources of international law can be maintained, and to promote social progress and better standards of life…and for these ends to practice tolerance and live together in peace with one another as good neighbors, and to unite our strength to maintain international peace and security, and to ensure…that armed force shall not be used, save in the common interest.¹⁰

The sentiments were noble, but from the beginning they were little more than a cover. The UN was set up by the victorious Allied powers—and in particular the U.S., the Soviet Union, and Britain—at the end of the Second World War in order to enforce a world order congenial to their own interests. There were, of course, differences among them as to what such a world should look like. Britain was determined to hold on to its empire, while Russia was determined to construct its own sphere of influence in Eastern Europe. The U.S., which had emerged from the war as far and away the world’s most dominant economic power, was more concerned to open new markets for American business. At the same time, it was determined to maintain its own spheres of influence in Latin America and the Pacific. As John McCloy, the U.S. assistant secretary of war, put it: “We ought to be able to have our cake and eat it too.… [W]e ought to be free to operate under this regional arrangement in South America, and at the same time intervene promptly in Europe.”¹¹

The negotiations that set up the UN were complex,¹² but as the most powerful nation, the U.S. got its way on most issues. Indeed, to ensure that it would control the final outcome, the U.S. spied on the other participants. Intelligence documents released a few years ago reveal that

for months prior to, as well as during the San Francisco founding conference, U.S. intelligence agencies were bugging the offices and rooms of the other delegations, and intercepting and breaking coded diplomatic messages—including those of Washington’s closest allies—in an operation known as “Ultra.” The intercepts allowed the U.S. team to know ahead of time what were the positions, special concerns or interests, potential pressure points and vulnerabilities of competitors and allies alike. The spying worked. By the end of the conference, the U.S. delegation had won support for structural, economic, and mandate decisions that effectively guaranteed Washington’s domination of the UN for years to come.¹³

According to one historian who has studied the documents, “The U.S. apparently used its surveillance reports to set the agenda of the UN to control the debate, to pressure nations to agree to its positions, and to write the UN Charter mostly according to its own blueprint.”¹⁴

The structure that emerged from this process was one dominated by the great powers. All member countries were given an equal vote in the General Assembly, but real power lay with the Security Council, dominated by five permanent members—the U.S., the USSR, Britain, France, and China¹⁵—each of which was given veto power over Council decisions, ensuring that its own vital interests would never be threatened. An internal February 1948 State Department memorandum criticized what it called “the universalistic principle of the UN” in which all nations would be subject to the same rules and argued that “a truly stable world order can proceed, within our lifetime, only from the older, mellower, and more advanced nations of the world.”¹⁶ The reality was, though, that from the start the “universalistic principle” was a sham and power lay with the “more advanced nations.” In the words of Denis Halliday, “this United Nations of ours, with its Charter of high ideals, is built on the vested interests of a very few….[T]he five victorious nations of the Second World War in 1945 created an instrument designed to sustain their newly won power through the entirely undemocratic and North-dominated machine termed the Security Council.” The result has been that the Council is largely controlled by “those permanent members that dominate and manipulate [it] through raw military and economic power.”¹⁷

The Cold War

Soon after the UN was founded, the temporary wartime alliance between the U.S. and the USSR broke down, and for the next forty years, global politics were dominated by the Cold War between the two superpowers. For most of this time, this meant that the UN could not be an effective instrument of U.S. foreign policy, since Moscow could use its Security Council veto to block U.S. plans. But there was one big exception to this rule. Following the Chinese revolution in 1949 which brought the communists to power, the Russians demanded that the new regime—rather than the remnants of the old nationalist government that had retreated to Taiwan—be recognized by the UN and given the Chinese seat on the Security Council. When Washington predictably refused to allow this change,¹⁸ the Soviets began a short-lived boycott of the Security Council in 1950. The boycott came just at the moment when tensions between North and South Korea (the former backed by the USSR and China, the latter by the U.S.) were about to break out into open war. The General Assembly first called for mediation, but Washington intervened with troops on the side of its puppet government in the South. In the temporary absence of the Russians, the U.S. took the opportunity to get the Security Council to allow it to get UN cover for its action. As a result, a multinational UN force was assembled—but despite its blue helmets, it fought under U.S., not UN, command. So within a few years of its founding, the United Nations was being used by Washington to support one side in a proxy war between the superpowers that was to drag on for three years and leave close to three million people dead.

For most of the Cold War, the UN simply stood on the sidelines as the permanent members of the Security Council overthrew governments, fought to maintain their colonial empires, invaded their neighbors, and slaughtered millions. Britain fought using brutal tactics to defeat the independence movement in Kenya in the 1950s, and France fought equally cruel wars in order to hold onto its colonies in Indochina and Algeria. The USSR invaded Hungary in 1956, Czechoslovakia in 1968, and Afghanistan in 1980. The U.S. helped to overthrow governments in Iran, Guatemala, Chile, and elsewhere, and took over in Indochina were France had left off. In none of these cases did the UN do anything meaningful. Only on one occasion after the Korean war did the UN act against the interests of any of the major powers. That was in 1956 when Britain and France (along with Israel) invaded Egypt in an attempt to seize control of the recently nationalized Suez Canal. On this occasion the U.S. felt its own interests in the Middle East were being compromised, so it used its clout in the General Assembly to condemn the invasion and force London and Paris to retreat.

By contrast, when U.S. allies have violated international law, squelched human rights, or carried out massacres which promoted—or at least did not threaten—U.S. interests, Washington’s veto makes it impossible for the UN to act. The UN did nothing serious to oppose South African apartheid. It turned a blind eye when Indonesia invaded East Timor in 1975 and slaughtered hundreds of thousands of people. And it has failed to defend the rights of the Palestinians or to end Israel’s illegal occupation of the West Bank and Gaza Strip.

As the process of decolonization gathered steam in the 1950s and 1960s, and more Third World countries joined the UN, the General Assembly became a less favorable venue for the U.S. to look to for support. By the 1970s, it was common for the Assembly to issue criticisms of U.S. actions. When the Reagan administration invaded the tiny island of Grenada in 1983, for example, the General Assembly denounced this as “a flagrant violation of international law.”¹⁹ But the Assembly has no real power, so it could simply be ignored. “One hundred nations in the UN have not agreed with us on just about everything that’s come before them where we’re involved,” Reagan responded, “and it didn’t upset my breakfast at all.”²⁰ Three years later, when the World Court, the UN’s main judicial arm, found the U.S. government to be in violation of international law for mining Nicaragua’s harbors and other acts of aggression, Washington refused to recognize the Court’s jurisdiction.²¹ To show its displeasure at such acts of impertinence, however, the U.S. began withholding a portion of its membership dues, driving the UN into a severe financial crisis.

From the Gulf War to the present

With the collapse of the Soviet bloc and the end of the Cold War, however, the U.S. began to see new opportunities to use the UN for its own purposes again. When Saddam Hussein, who had been a close U.S. ally throughout the 1980s, invaded Kuwait in August 1990, his great sin was to threaten Washington’s control of Middle Eastern oil supplies. From the very beginning George Bush Sr. was committed to a military solution in order to expand U.S. domination in a crucial strategic region. But with the Soviet Union in it last days and increasingly dependent on western loans to shore up its economy, it became possible once again to win UN backing for a U.S. attack.

According to the Australian journalist John Pilger:

It was one of the most shameful chapters in the history of the United Nations, and is about to be repeated.… [T]he full UN Security Council capitulated to an American-led war party and abandoned its legal responsibility to advance peaceful and diplomatic solutions. On 29 November [1990], the United States got its war resolution. This was made possible by a campaign of bribery, blackmail, and threats, of which a repetition is currently under way.²²

The Russians agreed not to block the U.S. war after they were promised $4 billion in loans. China was brought on board when Washington ended the diplomatic isolation Beijing had experienced since the 1989 Tiananmen Square massacre and offered economic development aid from the World Bank. The non-permanent members of the Council were offered economic support and arms deals. Other countries in the Middle East, such as Egypt, Jordan, Turkey, and Iran were given billions of dollars in debt relief and new loans. Syria received a billion dollars of arms and was given a green light to eliminate its opponents in Lebanon.

In the end, only two Security Council members, Cuba and Yemen, opposed the U.S. war drive. Washington had little leverage over Cuba, but it threatened Yemen, the only Arab country on the Council, with retaliation if it didn’t switch its position. In the end, Yemen stood its ground and voted against the war resolution. “That will be the most expensive ëno’ vote you ever cast,” a U.S. diplomat immediately told the Yemeni ambassador.²³ Within a few days, the U.S. cut off economic aid to Yemen and hundreds of thousands of Yemeni workers were expelled from Saudi Arabia. Sudan, another country that opposed the U.S., was denied food aid at a time when it was experiencing a famine.

Having gained UN “legitimacy” for its attack, the U.S. launched a devastating war which deliberately destroyed Iraq’s infrastructure, including its water system, and its economy, and killed as many as 200,000 people. Since then, Washington has refused to allow UN sanctions, which were imposed in 1990, to be lifted, leading to the deaths of over a million people, and has conducted regular bombing campaigns from its self-declared no-flight zones over the country. As Halliday notes,

The sustained economic sanctions imposed on the people of Iraq since 1990 demonstrate the corruption of Security Council decision-making and its disregard for the UN Charter and other international Conventions. Their full knowledge that these sanctions kill thousands of Iraqi children every month makes the member states, and especially those like the U.S. and the UK who force their unpopular view on the rest of the UN, guilty of genocide. That the governments were and are fully aware of the consequences of their sanctions policy, was confirmed by the infamous 1996 statement of then-UN Ambassador, [later Clinton’s] Secretary of State Madeleine Albright, that the 500,000 deaths of children the sanctions caused were “worth it” to contain President Saddam Hussein.²⁴

In the years since the 1991 Gulf War, the UN’s role, according to Phyllis Bennis, “has increasingly become one of authorizing and facilitating the unilateral interventionist policies of its most powerful member states—especially those of the U.S.”²⁵ Today we are witnessing an attempt by the second Bush administration to repeat the strategy of the first and cloak a unilateral intervention with UN support. This time the debates amongst the permanent members of the Security Council have been sharper, with France and Russia in particular less willing to give Washington a blank check for a new war against Iraq. But this is not because either country has suddenly gained a new appreciation of human rights or international law.

The public rhetoric is all about high-minded matters of principle—mainly the now-familiar complaint from overseas that the Bush administration does whatever it wants, with no regard for international law or principle.

But a closer look shows the real horse-trading in the UN Security Council is about oil, domestic politics, and future economic ties with a postwar Iraq. Iraq’s estimated oil reserves of 100 billion barrels could be the largest in the world—a huge economic prize for whoever has access to them after a war.

From the outside, the UN debate may look like a clash of foreign policy philosophies. But on the inside, U.S. officials say, it’s more often like a group of state legislators haggling over pork.²⁶

Both France and Russia have developed close economic ties with Iraq over the past decade. The French oil company TotalFinaElf has negotiated the rights to develop two of Iraq’s richest oilfields when sanctions are finally lifted. Russia has also signed oil development deals potentially worth tens of billions of dollars with the Iraqi regime. Both countries want assurances that their interests will be protected if the U.S. succeeds in overthrowing Saddam Hussein. In addition, Russian President Vladimir Putin wants Washington to give him a free hand for his continuing war in Chechnya. Both Paris and Moscow will be happy to cut a deal if the Bush administration is able to offer them satisfactory guarantees. No serious antiwar activist can pin their hopes on such horse trading between rival imperialist powers.

As I write this article, no agreement has yet been reached in the Security Council, but it is already clear that there are only two likely outcomes. Either the U.S. will offer France and Russia enough to win their acquiescence, and it will then use whatever UN mandate it is granted as an excuse for military action, or no agreement will be reached and the U.S. will simply bypass the UN in its drive to war. Washington has made it perfectly clear, for example in its National Security Strategy [Bush Doctrine] document published in September, that it is quite prepared to act unilaterally if it sees fit. As the Chicago Tribune put it recently, “the administration views UN approval of action against Iraq like the option of air conditioning in a car: nice to have, but the vehicle will move just fine without it.”²⁷ For that reason it is futile to look to the UN as a means of preventing war. The only way that can be done is by building an antiwar movement that can mobilize massive opposition on the ground.

Can the UN be reformed?

Despite the UN’s long history of failing to live up to its stated ideals and acting in the interests of the major powers, many still hope that it can be somehow transformed into a vehicle for international justice. Even some of the organization’s sharpest critics, such as Denis Halliday and Phyllis Bennis, hold out hope that in some way the UN can be reformed. In recent years a variety of proposals for changes have been made, from adding permanent members on the Security Council to eliminating the veto. Others have proposed establishing a permanent military force under direct UN control. But there are two insurmountable problems with any such proposal. First, there is no way that any of them could be enacted if any one of the permanent members wishes to veto them. Second, it is not clear what good any of the proposed changes would do. As one expert on international relations puts it:

[E]ach member of the UN tries to use its membership to further its own interests. States have not joined out of respect for the “UN idea,” or with a view to creating a stronger organization by transferring some of their powers to it. Rather they are in the UN for what they can get out of it. Of course, some states may see it as in their interests to increase the deference which is paid to the opinions of the UN—as expressed particularly, in the resolutions of the General Assembly. This is likely to be much more true of the weaker than of the stronger members.… But even weaker states show little signs of wanting to endow the UN with any general authority.²⁸

The hope that the UN can be made into some kind of democratic, suprastate body ignores the very nature of the organization. It is a body that brings together the governments of various states. Those states are not all equal, but have a pecking order, defined by their economic and military power. Therefore, by definition, any organization of nations will inevitably be dominated by those states.

The rhetoric that opposes “international law” and “the international community” to Washington’s unilateralism is in reality little more than an ideological echo of the very real struggle between the major European states, which represent the interests of European capital, and the U.S. state, fighting for the interests of U.S. capitalism. Since European ruling classes cannot compete with the U.S. militarily, they seek to promote their interests by other means. The U.S. ruling class wants to dominate the world in its own interests. The Europeans oppose this not because they want to see a world of democracy and equality, but because they want a piece of the action. The fight is not over whether the rich nations have the right to intervene, but over when and how such intervention will take place. The British writer Peter Gowan explains this clearly:

The Europeans put forward the world order concept of “multilateralism,” the rule of the “international community,” which means that there should be joint leadership around the G7 leading industrial nations and behind that the OECD [Organization for Economic Cooperation and Development]. This conception, counterposed to what they see as American “unilateralism,” does in turn mean undermining the sovereignty of nations. It means the G7’s right to intervene if it doesn’t like what a particular state is doing—as with Zimbabwe today.

The problem for the Europeans is that the Americans see this as a competitive strategy to their own, in fact the main competitor. They see the Europeans as trying to set the rules for the Americans or to bind the U.S. to its own past rules. The U.S. should be in some way subordinate to the G7, thematized as “the international community.” That’s why Condoleezza Rice, presidential security advisor, says, “there’s no such thing as an international community.”²⁹

There are no international forces capable of creating a global organization that could “police” the world independently of the most powerful states, or in the interests of forces outside of these ruling states (and the very powerful economic interests they represent). To suggest otherwise and to place hopes in the idea that the UN could be turned into such an institution, can only weaken our movement by creating illusions. There can be no “internationalism from above” that will ride in and save the day. The real alternative must be based on international solidarity and struggle from below.

The capitalist system places the rulers of different states in competition with each other for economic markets, raw materials, and control of territory. At the same time, states are forced to cooperate with one another in various ways, including trade agreements and strategic and military alliances—but these agreements are always temporary. Over the years a whole variety of international treaties, institutions, and organizations have been established—from NAFTA to NATO—with the job of regulating the relations between competing states. When the political and economic forces that tend to promote cooperation are stronger than the forces that promote conflict, then international regulations can function relatively effectively. But the world capitalist class is made up of “hostile brothers,” as Marx put it. In times of increased political and economic crisis, competition sharpens, and the tendency towards conflict increases. In such circumstances, the idealistic dream that international regulations or a body like the United Nations, can create a peaceful world, is exposed as an absurd utopia. That is the fundamental reason why the UN cannot be effectively reformed. But this is no reason to abandon the dream of a world without war. Rather it is to recognize that war can only be ended by getting rid of the economic system that produces it to begin with, not by tinkering with institutions such as the UN, which were designed to keep that system in place.

1 Speech at the Global Structures Convocation, Washington, D.C., February 1994. Quoted in Phyllis Bennis, Calling the Shots: How Washington Dominates Today’s UN, Updated Edition (New York: Olive Branch Press, 2000) p. xxiii. Bolton was an assistant attorney general in the Reagan administration and assistant secretary of state for international organization affairs in the first Bush administration. He assumed his current position in May 2001.

2 For example, a September USA Today/CNN/Gallup Poll found that 79 percent of Americans would support military action against Iraq if the United Nations supported it. If Washington does not have UN backing, only 37 percent would support war. (By midñOctober, Gallup reported that support for war had fallen to 56 percent. As always, polls should be taken with a large grain of salt. As the media critic Norman Solomon notes: “Opinion polls don’t just measure; they also manipulate, helping to shape thoughts and tilting our perceptions of how mÉst people think.” From “Polls: When measuring is manipulating,” October 17, 2002, online at www.fair.org/media-beat/021017.html.)

3 “An open letter from the academic community opposing a U.S. invasion of Iraq,” online at www.NoIraqAttack.org.

4 “Oppose U.S. invasion of Iraq,” United Electrical, Radio and Machine Workers of America convention resolution, online at www.ranknfile-ue.org/policy_iw.html.

5 “Write the UN Security Council to stop the rush to war,” Global Exchange Action Alert, October 15, 2002, online at www.globalexchange.org/campaigns/iraq/StopWar101502.html.

6 President’s remarks at the United Nations General Assembly, September 9, 2002, online at www.whitehouse.gov/news/releases/2002/09/20020912-1.html.

7 Associated Press, October 27, 2002.

8 Denis Halliday resigned from the United Nations and from his position as “Humanitarian Coordinator” in Iraq in 1998 (after over 30 years as a UN diplomat), to protest the genocidal impact of the UN-imposed sanctions.

9 Denis Halliday, “Introduction to the New Edition,” in Bennis, p. xii.

10 The Charter is published as an appendix in Bennis, pp. 313ñ31.

11 Quoted in Gabriel Kolko, The Politics of War (New York: Pantheon, 1990), p. 479.

12 They were also sometimes petty. It took the delegates at the founding convention in San Francisco two days to decide who would chair the meetings.

13 Bennis, p. 4.

14 Stephen Schlesinger, “Cryptanalysis for peacetime: Codebreaking and the birth and structure of the United Nations,” Cryptologia, Vol. 19, no. 3 (July 1995), p. 220. Quoted in Bennis, p. 4.

15 After the collapse of the Soviet Union in 1991, the Russian Federation took over the Soviet seat although the Charter did not permit such a change and there was no debate in the General Assembly.

16 Policy Planning Staff, “Review of current trends: US foreign policy,” February 24, 1948, FRUS, 1948, Vol. I, pp. 526, 528. Quoted in Mark Curtis, The Great Deception: Anglo-American Power and World Order (Sterling, VA: Pluto Press, 1998), pp.180ñ1.

17 Halliday, p. xi.

18 The Chinese Security Council seat remained in the hands of the renegade Taiwanese government until the early 1970s, when it was finally transferred to the People’s Republic.

19 Quoted in John Baxter, “Is the UN an alternative?” International Socialism 85, Autumn 1999, p. 61.

20 New York Times, November 4, 1983.

21 Holly Sklar, Washington’s War on Nicaragua (Boston: South End Press, 1988), pp.169ñ70, 314.

22 Bennis, pp. 21ñ39.

23 Ibid., p. 33.

24 Halliday, p. xiiiñxiv.

25 Bennis, p. xxiv.

26 Bill Nichols and Ellen Hale, “Oil and trade play part in UN debate on Iraq,” USA Today, October 15, 2002.

27 Chicago Tribune, October 12, 2002.

28 Alan James, “The United Nations,” in David Armstrong and Erik Goldstein (eds.), The End of the Cold War (London: Frank Cass & Co., 1990), p.187. Quoted in Baxter, p. 69.

29 “America’s global gamble,” International Viewpoint 339, April 2002.

30 Michael Ellison, “Nobel for peacemaker Annan: ëRock star of diplomacy’ shares honor with UN, which he helped to revitalize as its secretary general,” Guardian (UK), October 12, 2001.

31 Philip Gourevitch, We Wish to Inform You that Tomorrow We Will Be Killed with our Families: Stories from Rwanda (New York: Picador, 1998),
pp. 103ñ7.

32 Richard Holbrooke, To End a War (New York: Random House, 1998),
p. 99.

33 Ibid., p. 103.

34 Barbara Crossette, “Kofi Annan seems good bet for reelection and U.S. is pleased,” New York Times, March 23, 2001.

35 Maggie Farley, “Annan bows out of the tug of war between the U.S. and Iraq,” Los Angeles Times, September 20, 2002.

36 Stephen Zunes, “United Nations Security Council resolutions currently being violated by countries other than Iraq,” October 2, 2002, online at www.fpif.org.

37 Guardian (UK), September 24, 2002.

38 Institute for Public Accuracy news release, October 9, 2002, online at www.accuracy.org/press_releases/PR100902.htm.