Good morning, Your Honour. We appear before you this morning to argue for the proposition that the defendant, the National Rifle Association of America, hereafter referred to as the NRA, is properly classified as a terrorist organization. And, accordingly, that the NRA’s directors and officers have been engaged in a campaign of terror against civilian populations.
Our indictment of the NRA, as you know, arises out of section 802 of the USA Patriot Act, No. 107-52, which has expanded the definition of terrorism to cover “domestic,” as opposed to international, terrorism.
Therein, the Patriot Act, which was overwhelmingly supported and passed by all parties in Congress, sets out that a person has engaged in domestic terrorism if they do something that is “dangerous to human life,” which the NRA has in fact done since the earliest days of its 1871 charter in New York State.
To be successful in prosecuting a crime under the Patriot Act, it must be shown that the NRA, one, intimidated or coerced the civilian population — which they have done, ceaselessly, for generations.
Two, that they have influenced the policy of a government by intimidation or coercion — which they have done, with armies of millionaire gun lobbyists threatening elected representatives with defeat and disgrace if they do not do the NRA’s bidding.
And, three, most crucially, we must show the NRA has attempted to affect the conduct of our government by “mass destruction, assassination or kidnapping.”
We cannot state for a fact, Your Honour, that the NRA has actively engaged in assassinations or kidnappings. We can state, however, that the NRA will be shown to have energetically advocated measures that are bound to lead to mass destruction, even in the wake of the killings of 20 children in Newtown.
One of their recent advertising campaigns even offers up the former president’s own children as rhetorical fodder, and is ample evidence of the NRA’s willingness — like any terrorist organization — to terrorize children and parents to achieve its political goals.
We also take the view that at the time Thomas Jefferson and other founders ratified the Second Amendment, they did not intend it to be applied to the mass murder of six-year-olds using assault weapons. It was to be applied to flintlocks, which were what existed at the time of the amendment’s promulgation.
We are aware that the definition of terrorism is broad, Your Honour, and there is a robust debate about when it applies.
But under section 802 of the Patriot Act, we remind you that this court need only find the NRA has — within the territorial confines of the United States — engaged in a campaign of intimidation or coercion of our government, and our citizens.
You need only find that the NRA seeks to affect the conduct of government by advocating “mass destruction.”
Lobbying for guns in schools is that, Your Honour. So is openly threatening members of Congress so that they will lift bans on assault weapons. So is helping teenagers to purchase AK-47 assault weapons at gun shows. So is calling law enforcement “jack-booted government thugs.”
So is suggesting the last same president of the United States facilitates murder. So, most of all, is assassinating minimal efforts to prevent something like Newtown from ever happening again.
All these things the NRA has done, Your Honour. All of these acts of intimidation and coercion are not dissimilar to the campaigns of the Taliban or al-Qaida.
They may wear expensive suits, Your Honour, but the NRA is not much different from the terrorists. They deserve to be treated as such by this court.