Contention 1: Islamophobia

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Contention 1: Islamophobia

Surveillance programs disproportionately target Muslim-American communities; places of worship, business, community centers, and even student organization are subject to forms of mass surveillance.

Shahabuddin ‘15 [Madiha Shahabuddin, Shahabuddin is the Editor of The Chapman Law Review and has a JD from University of California, 2/16/15, Chapman Law Review, “The More Muslim You Are, the More Trouble You Can Be: How Government Surveillance of Muslim Americans Violates First Amendment Rights” vol 18, issue 2, pg. 582-587] Accessed Online: 7/08/15

During World War II, the Japanese community in California was mapped much like the mapping of Muslim communities in the United States today, the justification then being that it would protect America from another attack after Pearl Harbor.36 Local law enforcement have recently implemented mapping and surveillance programs of Muslims, as evinced by the 2007 Los Angeles Police Department (LAPD) plan to map local Muslims and the more recent NYPD surveillance of East Coast/New York area Muslims, which “[e]erily . . . bears [a] striking resemblance to the mistreatment experienced by Japanese Americans in the wake of Pearl Harbor.” 37 In 1956, the Federal Bureau of Investigations (FBI) began its Counter Intelligence Program (COINTELPRO), which spied on individuals and groups identified as “subversive” to “neutralize . . . radical or immoral activity.” 38 Dr. Martin Luther King, Jr., the NAACP, civil rights groups, the ACLU, and even the Boy Scouts of America were targets of government spying in this era, for fear that these organizations or individuals were infiltrated, or influenced, by Communism.39 A few decades later, during the 1960s and 1970s, the government cast its net of surveillance wider, to include anti-Vietnam War advocates, the Black Panthers, the “New Left,” and women’s rights groups.40 It was around this time that local law enforcement set up their own programs to conduct surveillance on a local level, such as the “New York Red Squad,” which “was reported to have files on over one million people.”41 After the 1972 attacks at the Munich Olympic Games and “[a]s early as 1986, the government was considering plans to use two military bases to detain Arab- and Iranian-Americans in the same vein as the Japanese internment of World War II.” Most recently, the post-9/11 era has been characterized by government surveillance of Muslim American communities in the name of counterterrorism efforts.43 The government’s conduct in this surveillance program was highlighted in news stories that broke around August 2011 about the NYPD conducting mass surveillance of Muslim communities in New York.44 The Associated Press ran a series of investigative reports on this topic, noting that the NYPD effectively “monitored every aspect of Muslim life and built databases on where innocent Muslims eat, shop, work and pray.” 45 And in July 2014, it was revealed that the U.S. National Security Agency (NSA) had—at the minimum—spied on five “politically active” Muslim American leaders, including a past Bush administration official, a successful attorney, a Rutgers professor, a former California State University professor, and an executive director of the Council on American-Islamic Relations (CAIR).46 At the root of these investigations is the tool of profiling, which allows the NYPD, FBI, or other governmental entity to target certain groups of individuals solely based upon their religious affiliation and pursue an almost carte blanche “fishing expedition” for evidence condemning the targeted Muslim of some link to terrorist activity.47 Justification for this treatment of Muslim American communities has come from the idea that the post-9/11 era calls for “urgent” action to thwart mass destruction that can come from a potential terror attack, and therefore—as the argument goes—constitutional infringements like this are a “small price to pay for [America’s] safety.At the core of this issue is what Sahar F. Aziz has called “selective counterterrorism enforcement.”49 This manifests itself in: the disproportionate targeting of Muslims for surveillance;50 government-sent informants tasked with infiltration and what many have argued should be legally considered entrapment of individuals; 51 and mapping and spying on predominantly Muslim neighborhoods, Muslim-owned businesses, mosques, and Muslim Student Associations.52 Outside the scope of this Comment, but still critically troubling, are the deportations of religious leaders and imams for sermons “deemed too critical of the American government,” 53 the criminalization and prosecution of charitable and humanitarian aid organizations under sweeping material support statutes,54 and private acts of prejudice against Muslims in the form of mosque vandalism and employment discrimination.55 As author and investigative journalist Trevor Aaronson argues, in the context of surveillance of Muslims, the government has used intelligence gathering as a means of “manufacturing” counterterror prosecutions that result in “what a federal judge has called a ‘fantasy terror operation’” created and incited by a government informant.56 Such intelligence gathering assists the government “in furtherance of an adversarial system that prioritizes bolstering the number of terrorism investigations, prosecutions, and convictions of Muslims in America.” Additionally, Aziz refutes the presumption about domestic or “homegrown” terrorism in the United States being the result of radicalization of all Muslim Americans within their own communities.58 One category of these “homegrown terrorism” cases involve most often “young, vulnerable men with mental health or financial problems upon whom paid informants prey. Often, these informants also play leading roles in concocting and implementing the fake terrorist plot.” 59 Ironically, for all the emphasis placed on rooting out the “homegrown” terrorists in Muslim communities, Aziz argues that “[i]ndeed, Muslim communities know much less than law enforcement about these cases because, unlike community members, law enforcement has information drawn from extensive surveillance networks and intelligence databases at the local, state, and federal level.” 60 As a result of this “[p]ervasive government scrutiny of Muslim communities,” Muslims feel “pressured to downplay their religious identity” and “fear becoming too active in . . . religious activities” because they worry that these are “indicative” to the government of “terrorist inclinations.” 61 In a report prepared by the Muslim American Civil Liberties Coalition (MACLC), the Creating Law Enforcement Accountability & Responsibility (CLEAR) project, and the Asian American Legal Defense and Education Fund (AALDEF), East Coast Muslims were interviewed to assess their experiences with being a part of a community targeted by NYPD surveillance. Most interviewees acknowledged that the public appearance of a Muslim identity would “invite[] unwanted attention or surveillance from law enforcement.” 62 Traditional or Islamic garb, a beard, a hijab (headscarf), or a niqaab (face covering) were such displays of a Muslim identity which, to the NYPD, would “serve as indicators of ‘dangerousness.’” 63 Some Muslims have stopped religious expression through praying in public, wearing headscarves, growing beards (an Islamic tradition), or donning Islamic or “Muslim looking” garb.64 As one interviewee, an interfaith community organizer, put it, “[a] hijab or beard isn’t just about being different and not fitting in . . . it’s also that people will see me as [someone who is] prone to violence.” 65 One Muslim student attending Brooklyn College said his parents forbid him from attending Muslim Student Association events on campus and wearing the Islamic skullcap in public, out of fear of being openly identified as a Muslim based on appearances.66 In addition, “[l]aw enforcement scrutiny of outward manifestations of ‘Muslim’ characteristics” prompted some Muslims to alter their appearances and the practice of their faith. 67 A City University of New York (CUNY) student found that this scrutiny of outward Muslim appearances made some people “water down” the practice of their religion, an unfortunate and unwarranted consequence of the government surveillance.68 One professor at Baruch College stated that in a class discussion, her Muslim students told her that participating in a Muslim Student Association could lead to law enforcement scrutiny and being labeled an extremist.69 These actions by the government and the resulting response of fear by the Muslim community raise serious First Amendment concerns, including the chilling of free association, which is considered an expressive right. Implementing a form of guilt by association, government surveillance and law enforcement create a presumption that “Muslims . . . know more about each other than other communities with members that have engaged in domestic terrorism.”

Recent guidelines have loopholes that justify profiling in the area of surveillance.

The Leadership Conference on Civil and Human Rights 15, 2/24/15, “Re: Concerns with the U.S. Department of Justice Guidance for Federal Law Enforcement Agencies Regarding the Use of Race, Ethnicity, Gender, National Origin, Religion, Sexual Orientation, or Gender Identity”, Advocacy Letter to President Barack Obama,

Dear Mr. President, On behalf of The Leadership Conference on Civil and Human Rights and the 80 undersigned organizations, we are writing to share our serious concerns regarding the Guidance for Federal Law Enforcement Agencies Regarding the Use of Race, Ethnicity, Gender, National Origin, Religion, Sexual Orientation, or Gender Identity (“the new Guidance”), issued in December of 2014 by the Department of Justice (“DOJ”). While the new Guidance included much-needed improvements to the 2003 Guidance Regarding the Use of Race by Federal Law Enforcement Agencies (“the 2003 Guidance”), many issues regarding the new Guidance remain. In particular, the new Guidance preserves loopholes from the 2003 Guidance and fails to address critical matters regarding its implementation, ultimately impeding Attorney General Eric Holder’s stated goal of eliminating discriminatory policing and profiling “once and for all.” We urge you to make addressing these concerns a priority so that your administration’s final policy and legacy truly upholds fair and equal treatment for all. Crafted under President George W. Bush and former Attorney General John Ashcroft, the 2003 Guidance was an important step forward in clarifying the Department of Justice’s (“DOJ” or “the Department”) position on racial profiling in law enforcement. Following the tragic events of September 11, 2001 and the initiation of our military campaigns in Iraq and Afghanistan, President Bush and Attorney General Ashcroft recognized that a federal directive was necessary in order to combat discriminatory law enforcement practices at home. Unfortunately, the 2003 Guidance that resulted from their efforts failed to accomplish this goal fully. Specifically, the Guidance failed to proscribe profiling on the basis of national origin or religion; included loopholes allowing law enforcement to profile on national security and border integrity grounds; did not expand the proscription on profiling to law enforcement surveillance activities; did not apply to state and local law enforcement agencies that work with federal law enforcement or receive federal funding; and failed to include enforcement mechanisms. Considering the events of this past year, now, more than ever, it is vitally important for these shortcomings to be addressed. The shooting deaths of Michael Brown in Ferguson, Missouri and Tamir Rice in Cleveland, Ohio, and the death of Eric Garner in Staten Island, New York, all at the hands of local police officers, along with the troubling pattern of unresolved cases of excessive use of force perpetuated by Customs and Border Protection agents along the southern border, have spurred a national movement calling for an end to discriminatory policing practices. The use of lethal force by police in Ferguson and New York City are extreme examples of the type of racial profiling that has occurred in those cities during traffic and pedestrian stops.[1]Both you and Attorney General Holder have spoken candidly about your own personal experiences with racial profiling. With the proliferation of new technologies and surveillance capabilities, state laws that target specific communities, and federal programs that involve state and local law enforcement in civil immigration enforcement, we are at a critical juncture in our nation’s history. We had hoped the new Guidance would make clear once and for all that our government would not tolerate discriminatory policing practices. But, unfortunately, there are still serious flaws with the new Guidance, as indicated below: The new Guidance preserves the loopholes that allow for profiling at the airports and in vast border regions by excluding Customs and Border Protection (“CBP”) and the Transportation Security Administration (“TSA”) from its requirements. These loopholes allow federal agents to target and search travelers solely because of their race, ethnicity, gender, national origin, religion, sexual orientation or gender identity. The new Guidance also fails to prohibit the pervasive practice of singling out and stopping individuals on suspected immigration violations for no reason other than baseless stereotypes. The new Guidance allows law enforcement to continue directing sources and informants to spy on particular communities based solely upon their protected characteristics—e.g., race, ethnicity or religion—regardless of any connection to criminal activity. This coercive practice allows for the continued and discriminatory infiltration of First Amendment protected spaces such as mosques or other houses of worship, and community organizations or events by FBI agents or informants so that they may observe, take notes and collect information, all without evidence of criminal activity. Allowing these practices to continue subjects entire racial, ethnic and religious communities to potential surveillance by law enforcement, the chilling effect of which cannot be overstated. For example, because of the New York Police Department’s (NYPD) Muslim spying program, many Muslims are afraid to attend mosques for fear of being targeted by law enforcement informants and officers. DOJ should announce a policy clarifying that this law enforcement practice violates the stated goals of the Guidance and end this discriminatory practice.

The constant surveillance of Muslim communities is part of a larger cultural climate that presumes Muslims to be guilty of terrorist activities purely by association

Smith 2012 (David Smith ,11 UCLA J. Islamic & Near E. L. 85 2012)

Since 9/11 the FBI has used a range of strategies to monitor or surveil the Muslim community. These strategies include placing confidential informants in mosques, registering lawful immigrants from predominately Muslim countries, mapping Muslim communities, and recruiting private individuals to report suspicious behavior by Muslim or Muslim-appearing persons. These strategies share this common theme: Islam itself is a threat. This theme captures the Post-9/11 national climate towards Muslim and Muslim appearing individuals. In March 2011, for instance, Congress member Peter King, who chairs the Congressional Homeland Security Committee, held a congressional hearing 65 focused only on the Muslim community. 66 In fact, King emphasized, "I believe it will have more of an impact on the American people if they see people who are of the Muslim faith and Arab descent testifying." 67 King believed that testimony would shed light on Muslims' and the Muslim community's lack of cooperation with law enforcement. Specifically, testimony would reveal that Muslim community members are ignoring the threat of radicalization within their own community. King viewed any focus on other forms of violent extremism "as political correctness at its worst."68 For example, King did not consider Jared Loughner's rampage in Arizona an equivalent national security threat. 69 Loughner opened fire at Congresswoman Gifford's constituent meeting in Tucson, Arizona at a supermarket, 70 killing six people and injuring seventeen others.71 King also declined to focus on the Oklahoma City bombing for the same reason, 72 arguing that the hearing's purpose was to address al-Qa'ida's active "targeting [of] the American Muslim community for recruitment."7 3 According to King's logic, al-Qa'ida targets Muslims in the U.S. because Muslims are more likely than non-Muslims to be sympathetic to al-Qa'ida's message. The current climate involves a presumption of guilt against Muslim and Muslim-appearing individuals. In particular, when implementing these strategies, the government targets Muslim or Muslim-appearing individuals without any facts indicating criminal or terrorist activity.

The cultural fear of Islam did not begin with 9/11 – it begins with the forging of a unified western identity during the expulsion of Islam from western Europe – philosophical justifications of western white supremacy used against indigenous communities during colonization was also used to understand Islam as a race that needed correction or extermination.

Grosfoguel et al ’06 Grosfoguel, Ramón and Mielants, Eric (2006) "The Long-Durée Entanglement Between Islamophobia and Racism in the Modern/ Colonial Capitalist/Patriarchal World-System: An Introduction," Human Architecture: Journal of the Sociology of Self-Knowledge: Vol. 5: Iss. 1, Article 2.

ISLAMOPHOBIA AS A FORM OF RACISM IN WORLD-HISTORICAL PERSPECTIVE The challenge for our topic is to answer how it was possible that a religious difference in the pre-modern/colonial world turned into a racial/ethnic difference in the modern/colonial world. In the heterarchical conceptualization of the world-system used here, Islamophobia would be the subalternization and inferiorization of Islam produced by the Christian-centric religious hierarchy of the world-system since the end of the 15th century. The year 1492 is a crucial foundational year for the understanding of the present system. In this year, the Christian Spanish monarchy re-conquered Islamic Spain expelling Jews and Arabs from the Spanish peninsula while simultaneously “discovering” the Americas and colonizing indigenous peoples. These “internal” and “external” conquests of territories and people not only created an international division of labor of core and periphery, but also constituted the internal and external imagined boundaries of Europe related to the global racial/ethnic hierarchy of the worldsystem, privileging populations of European origin over the rest. Jews and Arabs became the subaltern internal “Others” within Europe, while indigenous people became the external “Others” of Europe (Mignolo 2000). The first marker of “otherness” in the “European/Euro-American Christian-Centric Capitalist/Patriarchal World-System” was around religious identity. Jews and Arabs were characterized as “people with the wrong religion” while indigenous people were constructed as “people without religion” (Maldonado-Torres 2006). In the global racial/ethnic hierarchy produced by the two major events of 1492, the “people without religion,” that is “people without God,” were at the bottom of the hierarchy, while “people with the wrong religion,” that is, “people with the wrong God,” occupied a different position in this hierarchy. How did “people with the wrong religion” turn into “people below the human,” that is, racially inferior people? The struggle of Christian Spain against Islam formed part of a long imperial struggle in the Mediterranean Sea that goes back to the crusades. The Christian vs. Islam struggle articulated what Walter Mignolo (2000) characterizes as the “imperial difference,” while the post-1492 Spanish vs. Indigenous struggle in the Americas articulated the “colonial difference.” The “imperial difference” after 1492 is the result of imperial relations between European empires versus Non-European Empires and we will characterize it here as the result of the “imperial relation.” The “colonial difference” is the result of colonial relations between European and non-European peoples and we will characterize it here as a result of the “colonial relation.” Historically, the expulsion of Arabs and Jews from Christian Spain in the name of “purity of blood” was a protoracist process (not yet fully racist, although the consequences were not that different). “Purity of blood” was not used as a racial term but as a technology of power to trace the religious ancestry of the population. However, “purity of blood” did not become a fully racist perspective until much later and only after the application of the notion of the “purity of blood” to indigenous peoples in the Americas. Indigenous peoples characterized in the late 15th and early 16th century as “people without God” in the Christian Spanish imaginary became inferior sub-human or non-human beings. It is this inferiorization below the “human,” to the level of animals, which turned indigenous peoples in the Americas into the first racialized subject of the modern/colonial world inaugurated in 1492 (Dussel 1994). This racist imaginary was extended to new “people without God” such as sub-Saharan Africans transferred massively to the Americas as part of the European slave trade after the infamous debate between Sepulveda and Las Casas in the School of Salamanca in the 1550s. Sepulveda argued that indigenous people had no soul and therefore were not humans and could be enslaved without representing a sin in the eyes of God (Wallerstein 2006). While Las Casas argued that they were savages with a soul, that is culturally inferior, childlike but ultimately humans to be Christianized rather than enslaved. Both represent the initial formal articulation of the two forms of racism that continued for the next five centuries. Sepulveda represented a biological racist discourse while Las Casas a cultural racist discourse. Las Casas argued that “Indians” should be incorporated in the encomienda (a form of semi-feudal coerced labor) and called for Africans to replace them as slaves in the plantations. After all, Africans were characterized by Las Casas not only as “people without religion” but also as “people without soul.” The argument here is that the racist imaginary that was built against the indigenous people of the new world was then gradually extended to all non-European peoples starting with the African slave trade in the mid-16th century. The important issue for our topic is how this racist imaginary was extended even to people that were characterized as “people with the wrong God” in the late 15 century. As the European Empires’ relations with the Islamic Empires turned from an “imperial relation” into a “colonial relation” (the Dutch colonization of Indonesia in the 17th century, the British colonization of India in the 18th century, the British colonization of the Middle East in the 19th century, and the demise and subsequent division of the Ottoman Empire among several European empires at the end of the First World War), the notion of “people with the wrong God” in the Theological Christian imaginary of the 16th and 17th centuries was secularized into a “scientific evolutionary hierarchical civilization” imaginary that turned the late 15th century “people with the wrong religion” (imperial difference) into the inferior “savages and primitives” of “people without civilization” (colonial difference) in the 19th century. The latter represented a crucial transformation from the inferiorization of non-Christian religions (such as Islam, Judaism, etc.) to the inferiorization of the human beings practicing those religions (such as Muslims and Jews). This discursive mutation was central to the entanglement between the inferiorization of religion and the racism against non-European human beings practicing those religions. The Christian-centric global religious hierarchy and the Eurocentric global racial/ethnic hierarchy were increasingly entangled and the distinction between practicing a non-Christian religion and being racialized as an inferior human became increasingly erased.

Western identity is privileged at an epistemic level by the production of knowledge concerning an Other that does conform to the western standards of civilized life – This prevents honest cross-cultural dialogues and justifies mass-scale racial violence.

Grosfoguel et al ’06 Grosfoguel, Ramón and Mielants, Eric (2006) "The Long-Durée Entanglement Between Islamophobia and Racism in the Modern/ Colonial Capitalist/Patriarchal World-System: An Introduction," Human Architecture: Journal of the Sociology of Self-Knowledge: Vol. 5: Iss. 1, Article 2.

Occidentalism created the epistemic privilege and hegemonic identity politics of the West from which to judge and produce knowledge about the “Others.” The egopolitics of knowledge of Rene Descartes in the 17th century where Western men replace God as the foundation of knowledge is the foundational basis of modern Western philosophy. However as Enrique Dussel (1994), Latin American philosopher of liberation, reminds us, Descartes’ ego-cogito (“I think, therefore I am”) was preceded by 150 years of the ego-conquirus (“I conquer, therefore I am”). The God-eye view defended by Descartes transferred the attributes of the Christian God to Western men (the gender here is not accidental). But this was only possible from an Imperial Being, that is, from the panoptic gaze of someone who is at the center of the world because he has conquered it. The myth about Western males’ capacity to produce a knowledge that is universal beyond time and space was fundamental to imperial/global designs. The Cartesian egopolitics of knowledge inaugurated what Colombian philosopher Santiago Castro-Gomez called the “point zero” perspective. The “point zero” perspective is the Western myth of a point of view that assumes itself to be beyond a point of view. This myth allowed Western men to claim their knowledge to be universal, neutral, value-free and objective. Contemporary authors like Samuel Huntington (1996) reproduce a combination of old Occidentalism with Orientalism. The superiority of the West is taken for granted and the epistemic privilege of Western identity politics from which to produce judgments of the “Other” and global/imperial designs around the world is an unquestioned presupposition. Moreover, in a male dominated academic culture such as Harvard, a scholar and national defense apologist such as Huntington (2004) specifically links geopolitical concerns and security threats to ‘internal’ American identity issues, most notably coming from those impoverished immigrants who may have the audacity to challenge Western male privilege, socioeconomically, politically and ultimately epistemologically (Etzioni 2005). What is the relevance of this epistemic discussion to Islamophobia? It is from Western hegemonic identity politics and epistemic privilege that the ‘rest’ of the epistemologies and cosmologies in the world are subalternized as myth, religion and folklore, and that the downgrading of any form of non-Western knowledge occurs. The former leads to epistemic racism, that is, the inferiorization and subalternization of non-Western knowledge, while the latter leads to Orientalism. It is also from this hegemonic epistemic location that Western thinkers produce Orientalism about Islam. The subalternization and inferiorization of Islam were not merely a downgrading of Islam as spirituality, but also as an epistemology. Islamic critical thinkers are considered inferior to the Western/Christian thinkers. The superiority of Western epistemology allows the West to construct with authority the Islamic “Other” as an inferior people or culture frozen in time, and leads Western scholars to write entire books about what went wrong with Islam (e.g. Lewis 2002), as if problems in the Middle East or poverty in In our view, it is more difficult for the West to swallow a moderate Islamic thinker critical of both Eurocentric fundamentalism and Islamic fundamentalism than a declared Islamic fundamentalist thinker. The latter confirms all of the Orientalist Islamophobic prejudices that the West constructs against Islam, while the former challenges those representations. This is why both the New York Times and Le Monde have dedicated front pages of their daily newspaper to the “Tariq Ramadan affair.”4 All over Western Europe, Tariq Ramadan is very popular among Muslim European youngsters. His message to Muslim youth is that you can be European and Muslim at the same time. This challenges one of the most sacred myths of European identity politics, which is that in order to be European you have to be Christian or secular (identified with Western thought and Christian cosmology/values even if you are not a believer). Moreover, he calls Muslim youth to exercise their citizenship rights as Muslim Europeans and intervene in the public sphere making claims for equality and contributions to the society. This has been too subversive both for Islamic fundamentalists and for mainstream Eurocentric Europeans to accept (e.g. Fourest 2004; cf. Bruckner 2007), hence the Islamophobic campaign against his thinking. Ever since he was banned from France in the mid-1990s, the French newspaper Le Monde has been actively attacking Ramadan as an Islamic fundamentalist that uses a “double discourse.” Later, when the ban was lifted, Le Monde’s campaign against Ramadan’s “double language” nevertheless continued. What is interesting is the double standard and epistemic racism behind this accusation. Those who promote it apply different rules of judgment when dealing with a European intellectual thinking from Western tradition, than a European intellectual thinking from the Islamic tradition. An intellectual that is attacked as a promoter of a “double discourse,” that is, accused that “what he/she says and writes is not really what he/she believes,” has no way to defend himself/herself. The rule of judgment about the work of any intellectual is based on what he/she says and writes. But if the accusation is that what she/he says and writes are false because he/she has a “double discourse,” then there is no self-defense against this accusation. Whatever the accused intellectual argues, it becomes tautological. No matter how many times Tariq Ramadan has publicly denounced the oppression of women, terrorism and Islamic fundamentalism, his brother’s fundamentalist views on Islam, Saudi Arabia and Taliban fundamentalist views on Islam, suicide bombers and so on, Le Monde keeps attacking Tariq as a believer in these things without any evidence nor serious reading of his work and public speeches because the claim is that he has a “double discourse.” These standards of judgment are never applied to Western intellectuals. The rare occasions that Muslims (and by extension Muslim intellectuals) are not presented in extremely ambiguous terms, is when they happen to be ‘natives’ converted to Islam such as Ayyub Axel Koehler, president of the Central Committee of Muslims in Germany, or Muslims such as Ayaan Hirsi Ali (2007) who have abandoned or who consistently criticize Islam. The double standard shows that Islamophobia forms part of Western epistemic racism. In sum, Islamophobia as a form of racism against Muslim people is not only manifested in the labor market, education, public sphere, global war against terrorism or the global economy, but also in the epistemological battleground about the definition of the priorities in the world today.

Modern Islamophobia is not limited to domestic racial violence but justifies a militaristic foreign policy against Islam. The rhetorical connection of Islam to fanatic and terroristic violence has been deployed in every major military intervention in the Middle East

Semati ‘10 [Mehdi Semati, Mortimer House, 3/02/10, “ISLAMOPHOBIA, CULTURE AND RACE IN THE AGE OF EMPIRE” vol no. 24, pg 256-275]

Although today’s major geopolitical concern is security/terrorism, other developments have contributed to the contemporary rise of the profile of “Islam” in the West. The 1967 Arab-Israeli war, the 1970s Arab oil embargo, and the ensuing oil crisis were among these developments. The ‘vulnerability’ of the United States to Arab manipulation of ‘oil as weapon’ solidified the caricature of Muslim Middle East as oil suppliers in the political and popular narratives. The next major development was the Iranian revolution of 1979 led by Ayatollah Khomeini that culminated in the overthrow of American-backed monarchy in Iran. The leader of the Iranian revolution was steadfast in his criticism of the United States for its support of the Iranian dictator. In this context, another caricature of Muslims, mobs of chanting fanatics, was added to the list of negative images that shape the discourse of Islam (Said 1981, p. 7). The next incident was the taking of American embassy employees as hostage by radical students in Tehran. The episode, which lasted for 444 days, was an emotionally charged issue for American audiences. The publication of Salman Rushdie’s Satanic Verses in 1988, and the fatwa issued by Ayatollah Khomeini against him, stirred passion and created violent controversies throughout the world. The involvement by the United States in the Gulf War in 1990 to remove Saddam Hussein from Kuwait put the Middle East on the front pages once more. The first World Trade Center bombing in 1993 was yet another development in this context. One of the striking elements of the reaction to the bombing in 1993 was the degree to which Muslims in America were viewed as a potential ‘network of sympathizers.’ 3 The Oklahoma City bombing raised the profile of Muslims in America in the initial media coverage of the bombing. Countless terrorism ‘experts’ testified about ‘the sizable community of Islamic fundamentalists in Oklahoma City,’ about the ‘earmarks of Islamic car-bombers of the Middle East,’ and about the parallels that have ‘roots in the Middle East.’ Before the real perpetrators were caught, brown ‘men of Middle Eastern descent’ were being sought by media and authorities.4 Finally, the events of September 11, 2001, brought issues of ‘Islam,’ ‘Muslims,’ and the Middle East to the fore on a scale not seen previously. Today’s discourse of Islam and Muslims is inextricably bound with the issue of terrorism, which tends to frame all other issues concerning the Middle East. The present day notion of terrorism, however, has a relatively short history. The origin of today’s terrorism discourse is located in the 1980s American foreign policy during the presidency of Ronald Reagan. This era has been characterized as the era of aggressive militarism and a ruthless foreign policy as a response to the perceived erosion of American power and standing in the international political arena. The preceding presidency of Jimmy Carter had entailed events and policies that contributed to a real and perceived decline in America’s credibility as a superpower. Those policies and events include the ‘loss’ of Nicaragua and Iran to revolutions with no sympathies towards America’s interests in their respective regions, the invasion of Afghanistan by the Soviet Union, a protracted hostage crisis in Iran and the failure to release those hostages militarily, and President Carter’s emphasis on human rights. These policies and events, viewed as symptoms of a weakened America, led to a call for a renewal of the projection of American power around the globe. A central theme of the Reagan presidency and its approach to foreign policy was ‘resurgent America’ (Prince 1993). The call for projecting American power in this era required aggressive intervention policies around the globe. To project American power around the globe the United States became involved in the invasion of Grenada, the sponsorship of the Contra’s war in Nicaragua, the bombing of Libya, and a host of other CIA’s secret wars and covert actions around the world.5 This aggressive militarism, which culminated in the military operation in the Persian Gulf in 1991, was part of a renewed Cold War by the Reagan administration to reassert American leadership after a period of perceived decline. The major thrust of foreign policy in the 1980s was formulated in response to (perceived) Soviet Union aggression. Accordingly, conflicts around the world were constructed ideologically as a struggle between the United States and the Soviet Union (i.e. the free world versus the evil empire). The ideological struggle in this context, however, could not be won with the red scare of the 1950s, for anxieties about colossal communist takeover did not have the political resonance they had had in the 1950s. In its place, ‘terrorism’ emerged as one of the most potent ideological signifiers of the era. In Prince’s (1992) view, ‘terrorism’ became ‘a term which functioned essentially as a synonym for communism but was sufficiently new and vivid that it could carry a great deal of political freight, unlike the somewhat discredited anti-communism’ of an earlier period (p. 31). The threat of terrorism, as ‘Russia’s secret weapon,’ thus became a major theme in the new Cold War, as reflected in various mainstream media discourses of the period (Prince 1993). A cursory look at the popular narratives during this decade reveals the ways in which the prevailing ideology of the era was worked into the popular films and was embodied in the heroic gestures of the celluloid heroes. Films such as Red Dawn (1984), Invasion USA (1985), Rambo: First Blood Part 2 (1985), Rocky IV (1985), Rambo III (1986), and Top Gun (1986) responded to, and embodied, the theme of resurgent America. They celebrated militarism, patriotism, and superior American military technology and power. As Kellner (1995) argues, the Hollywood films of the 1980s ‘nurtured this militarist mindset and thus provided cultural representations that mobilized support’ for an aggressive foreign policy (p. 75). Hollywood’s response to America’s ‘aggressive international posture,’ in Prince’s (1993) argument, was to produce a ‘cycle of invasion-and-rescue films that collectively argued for the need to project strong American military power overseas’ (p. 240). Drawing from the Cold War imagery, films such as Top Gun (1986) and Rambo II (1985) ‘dramatized heroic ideals of empire’ and depicted heroes that ‘functioned as personification of a national will and warrior spirit encoded by the foreign policy rhetoric of the Reagan period’ (p. 240). This new Cold War in the context of a crumbling (and later disintegrated) Soviet Union ushered in a new evil enemy. Thus, enters the evil ‘Arab’ enemy. Films such as Delta Force (1986), Iron Eagle (1986), and Iron Eagle II (1988) presented Arab ‘super enemy which eventually found its incarnation in Saddam Hussein and Iraq’ (Kellner 1995, p. 83).6 The same Orientalist cultural worldview that produced such films provided the interpretive framework to render intelligible the historical political conflict that was the Persian Gulf War. That worldview depicted Arabs as backward, as savages (in the eternal struggle with our forces of civilization), and as incompetent (Prince 1993).7 The Otherness of the Muslim Other is sharpened beyond abstract foreign policy frameworks and fictional world of Hollywood blockbuster fare with the events of 9/11.8 These popular narratives provided the initial framework for the media and state discourses that followed the events of 9/11 to facilitate the construction and intensification of the generic category of ‘Arab-Middle Eastern-Muslim’ Other


The United States federal government should require all relevant federal agencies conducting surveillance of first amendment activities possess reasonable suspicion of criminal activity excluding minor offenses and technical immigration offenses.

Contention 2: Solvency

The government can regulate federal surveillance practices by requiring that federal agencies provide evidence of criminal activity before engaging in surveillance of first amendment activities.

Fisher 4

Linda E. Fisher Nov. 5, 2004 (Assistant Professor in Residence at University of Connecticut) “GUILT BY EXPRESSIVE ASSOCIATION: POLITICAL PROFILING, SURVEILLANCE AND THE PRIVACY OF GROUPS” ARIZONA LAW REVIEW [Vol. 46:621

In the political surveillance context, the application of balancing should result in a threshold presumption: a particular situation will be presumed not to involve a sufficiently compelling state interest if there is no reasonable suspicion of criminal activity before a full investigation of First Amendment activity is conducted.221 Criminal activity should be defined to exclude minor offenses such as violations of municipal ordinances, technical misdemeanors—such as minor traffic code offenses—or technical immigration offenses.222 If there is no indication of unlawful activity, full investigations are not permitted; the presumption is irrebuttable, although I also propose an emergency exception. This standard is an appropriate alternative to political or religious profiling, as it permits legitimate law enforcement while disallowing investigations based purely on politics, which contravene the First Amendment. Its deployment would eliminate virtually all of the abuses that have occurred in the past, as detailed in Section I, supra. At the same time, terrorism investigations that focus on meaningful evidence of terrorism can proceed unimpeded. This presumption also represents a conclusion that political surveillance will, on balance, be harmful and intrusive with an insignificant likelihood of gain in useful intelligence if the initial evidentiary standard is not met.223 Stated differently, the general compelling state interest in investigating terrorism does not exist sufficiently in a particular case when evidence of criminality is lacking; mere suspicion or political profiling cannot justify intrusions into a group’s private affairs. Thus, the generalized compelling need to uncover terrorist activities does not constitute a sufficient reason to surveil a particular mosque unless there is a reasonable suspicion of criminality at that particular mosque, such as that the imam preaches extremist doctrine and raises funds for what appears to be an affiliate of a terrorist organization.224 It is not acceptable to investigate and compile dossiers on all mosques holding radical views, even if the surveillance is limited to mosques whose members come from countries that have produced terrorists, such as Saudi Arabia.225 The standard of reasonable suspicion for political surveillance is similar to, and borrowed from, the Fourth Amendment standard employed in criminal procedure226 to determine the constitutionality of a stop-and-frisk situation. I adopt it here because it provides a suitable delineation point between political surveillance and legitimate law enforcement. In order for a stop-and-frisk investigation to be lawful, a police officer must “reasonably . . . conclude in light of his experience that criminal activity may be afoot”227 and “point to specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant” a search.228 Recognizing the public safety interest in thwarting crimes before they occur, this standard is lower than the probable cause standard required for a police officer to actually make an arrest.229 What constitutes reasonable suspicion in a particular situation depends upon “whether a reasonably prudent [person] in the circumstances would be warranted in the belief that his safety or that of others was in danger.”230 While this is a somewhat nebulous determination, reasonable suspicion never exists based on mere “hunch[es]” or general suspicion.231 Rather, police “must have a particularized and objective basis for suspecting [that] the particular person” being investigated has committed or plans to commit a crime.232 In a First Amendment context, the standard should not be interpreted identically to the reasonable suspicion standard employed in a pure Fourth Amendment situation where no expressive activity is involved. Courts have developed a number of “special needs” exceptions to the pure Fourth Amendment standard.233 Those exceptions must be limited where First Amendment rights implicated, because most courts likely would consider prevention of terrorism a “special need” in situations not involving First Amendment expression. In order to preserve fragile First Amendment rights, the scope of the exceptions should be confined. Further, even if the Fourth Amendment’s special needs doctrine applies, the existence of a special need is not always dispositive. In some respects, this situation is analogous to that in Ferguson v. City of Charleston, 234 one of the Supreme Court’s most recent pronouncements on the special needs exception. In that case, the Court balanced the state interest in conducting drug testing on pregnant women to prevent fetal drug abuse against the women’s interest in avoiding dissemination of personal—and potentially incriminating—information to law enforcement. Striking down the drug testing policy, the Court held it unconstitutional because “the gravity of the threat alone cannot be dispositive of questions concerning what means law enforcement officers may employ to pursue a given purpose.”235 A policy designed to obtain information for criminal prosecution by means of nonconsensual drug-testing is draconian. Analogously, the fundamental right to engage in First Amendment-based association should override the State’s interest in having free rein to monitor all group activity whenever any suspicion of terrorism arises. Given the risk of misuse of religious and political information, as well as of disruption of organizational functioning, the end does not justify the means.236 There is ample precedent for adopting a reasonable suspicion of criminality standard for political surveillance. This standard remains as a requirement for police departments accepting federal aid.237 Its substantial equivalent was successfully employed in the FBI’s domestic surveillance guidelines for over twenty-five years.238 It was also incorporated into the Chicago Red Squad consent decree.239 The Church Committee endorsed the reasonable suspicion standard as a predicate for terrorism investigations in 1976.240 Notably, it was recently adopted in the Denver police spying consent decree.241 And it was enacted in a Seattle ordinance.242 Other political surveillance litigation was not as successful.243 However, the Dale Court’s affirmation of a robust right of association strengthens and reinforces those First Amendment arguments previously available. Additionally, reasonable suspicion is a relatively lenient evidentiary standard that allows legitimate law enforcement activity.244 Absent even this indicia of crime, it is difficult to imagine—outside of an imminent threat of serious violence—how the government could present a state interest sufficiently compelling to ever outweigh harm to First Amendment rights. A lower standard would unduly interfere with the integrity of associations and contravene the Supreme Court’s many pronouncements concerning the centrality of associational rights to preservation of the First Amendment.245 And the standard does not apply at all to investigations not based on First Amendment conduct, such as investigation of an individual because of his purchase of explosives. Indeed, one could readily question whether the reasonable suspicion standard is sufficiently high to deter excessive, unnecessary surveillance. But the need to investigate terrorism where evidence of crime exists does not permit imposition of a higher standard, such as probable cause.246 The purpose of the investigation is to obtain probable cause. That standard is the result of an investigation, rather than its predicate. While the reasonable suspicion standard is a relatively low threshold, it is effective. The history of political surveillance reveals that almost all of the abuses could have been avoided had a reasonable suspicion threshold been observed.247 Requiring reasonable, articulable evidence of crime prevents investigations based on pure politics, mere whim, or baseless suspicion.248 Its use should practically eliminate political profiling. In opposition to this standard, Attorney General Ashcroft argues that only an investigation can uncover evidence, and that a standard requiring prior evidence therefore undermines law enforcement by prohibiting the very process that compiles relevant evidence in the first place.249 His logic is superficially appealing, but ultimately unpersuasive; in reality, surveillance is only conducted when a reason or suspicion triggers it. Resource limitations prevent either random or total surveillance; thus, investigations are begun for a reason. Historically, illegitimate reasons such as dissident political views have frequently triggered investigations.250 By contrast, this standard requires that the inevitable triggering reason must reasonably relate to criminal behavior. Finally, in certain circumstances where the need is exceptionally compelling, brief preliminary inquiries using a lower threshold may be conducted. True terrorist emergencies may occasionally necessitate immediate investigation of First Amendment conduct with less than an individualized reasonable suspicion of crime.251 I propose the standard recommended by the Church Committee: “The FBI should be permitted to conduct a preliminary preventive intelligence investigation . . . where it has a specific allegation or specific or substantiated information that the [subject(s)] will soon engage in terrorist activity.”252 Where the First Amendment is implicated, exceptions to the reasonable suspicion threshold should be limited to situations involving a serious risk of imminent violence, to avoid swallowing the reasonable suspicion threshold with an exception invoked any time an officer suspects terrorism.253 The need to protect First Amendment activity requires the qualification, as well as durational limits and approval by high-ranking personnel.254 Advocacy of specific terrorist violence in the U.S. could meet the terrorist emergency definition in some situations and lead to a preliminary inquiry, but only to determine if the advocacy constitutes a real threat. To hold otherwise would disable law enforcement from dealing with the likely prospect of severe and imminent danger solely because First Amendment activity is involved. It is important, however, that this exception be limited by additional restrictions to ensure that the emergency authority is not misused. For instance, use of infiltrators or electronic surveillance could be prohibited.255 The underlying principle is that the intrusiveness of the inquiry must be proportional to the threat presented.

Policy makers must include the critique. This does not indicate the need to stop the critique after legislation or a validation of the term ‘terrorist’ but rather must include voices from the state and ‘terrorists’.

Gunning 7

Jeroen Gunning. Gunning is deputy director of the Centre for the Study of Radicalisation and Contemporary Political Violence at the University of Wales. “A Case for Critical Terrorism Studies?”, Government and Opposition, Volume 42, Issue 3, pages 387–390, Summer 2007,

The notion of emancipation also crystallizes the need for policy engagement. For, unless a ‘critical’ field seeks to be policy relevant, which, as Cox rightly observes, means combining ‘critical’ and ‘problem-solving’ approaches, it does not fulfil its ‘emancipatory’ potential.94 One of the temptations of ‘critical’ approaches is to remain mired in critique and deconstruction without moving beyond this to reconstruction and policy relevance.95 Vital as such critiques are, the challenge of a critically constituted field is also to engage with policy makers – and ‘terrorists’ – and work towards the realization of new paradigms, new practices, and a transformation, however modestly, of political structures. That, after all, is the original meaning of the notion of ‘immanent critique’ that has historically underpinned the ‘critical’ project and which, in Booth’s words, involves ‘the discovery of the latent potentials in situations on which to build political and social progress’, as opposed to putting forward utopian arguments that are not realizable. Or, as Booth wryly observes, ‘this means building with one’s feet firmly on the ground, not constructing castles in the air’ and asking ‘what it means for real people in real places’.96 Rather than simply critiquing the status quo, or noting the problems that come from an un-problematized acceptance of the state, a ‘critical’ approach must, in my view, also concern itself with offering concrete alternatives. Even while historicizing the state and oppositional violence, and challenging the state’s role in reproducing oppositional violence, it must wrestle with the fact that ‘the concept of the modern state and sovereignty embodies a coherent response to many of the central problems of political life’, and in particular to ‘the place of violence in political life’. Even while ‘de-essentializing and deconstructing claims about security’, it must concern itself with ‘how security is to be redefined’, and in particular on what theoretical basis.97 Whether because those critical of the status quo are wary of becoming co-opted by the structures of power (and their emphasis on instrumental rationality),98 or because policy makers have, for obvious reasons (including the failure of many ‘critical’ scholars to offer policy relevant advice), a greater affinity with ‘traditional’ scholars, the role of ‘expert adviser’ is more often than not filled by ‘traditional’ scholars.99 The result is that policy makers are insuffi- ciently challenged to question the basis of their policies and develop new policies based on immanent critiques. A notable exception is the readiness of European Union officials to enlist the services of both ‘traditional’ and ‘critical’ scholars to advise the EU on how better to understand processes of radicalization.100 But this would have been impossible if more critically oriented scholars such as Horgan and Silke had not been ready to cooperate with the EU. Striving to be policy relevant does not mean that one has to accept the validity of the term ‘terrorism’ or stop investigating the political interests behind it. Nor does it mean that each piece of research must have policy relevance or that one has to limit one’s research to what is relevant for the state, since the ‘critical turn’ implies a move beyond state-centric perspectives. End-users could, and should, thus include both state and non-state actors such as the Foreign Office and the Muslim Council of Britain and Hizb ut-Tahrir; the Northern Ireland Office and the IRA and the Ulster Unionists; the Israeli government and Hamas and Fatah (as long as the overarching principle is to reduce the political use of terror, whoever the perpetrator). It does mean, though, that a critically constituted field must work hard to bring together all the fragmented voices from beyond the ‘terrorism field’, to maximize both the field’s rigour and its policy relevance. Whether a critically constituted ‘terrorism studies’ will attract the fragmented voices from outside the field depends largely on how broadly the term ‘critical’ is defined. Those who assume ‘critical’ to mean ‘Critical Theory’ or ‘poststructuralist’ may not feel comfortable identifying with it if they do not themselves subscribe to such a narrowly defined ‘critical’ approach. Rather, to maximize its inclusiveness, I would follow Williams and Krause’s approach to ‘critical security studies’, which they define simply as bringing together ‘many perspectives that have been considered outside of the mainstream of the discipline’.101 This means refraining from establishing new criteria of inclusion/exclusion beyond the (normative) expectation that scholars self-reflexively question their conceptual framework, the origins of this framework, their methodologies and dichotomies; and that they historicize both the state and ‘terrorism’, and consider the security and context of all, which implies among other things an attempt at empathy and cross-cultural understandingnn.102

Countering Islamophobic rhetoric requires demystifying the common held association of Muslisms being affiliated with terrorism. However, it is also necessary to support and engage in critical approaches that recognize Islamophobia as part of a larger apparatus of oppression with institutional support.

Zine in 2004(Jasmin, teaches graduate courses in the Department of Sociology and Equity Studies in Education at the Ontario Institute for Studies in Education of the University of Toronto, “Anti-Islamophobia Education as Transformative Pedadogy: Reflections from the Educational Front Lines,” The American Journal of Islamic Social Sciences 21:3)

As an anti-racism scholar and educator, fellow colleagues and I realized from as early as September 12 that there was an urgency to frame a critical pedagogical response to address and challenge the rampant Islamophobia affecting the realities of Muslims from all walks of life and social conditions. Among the most vulnerable were children and youth, who received little support from schools in dealing with the backlash that many were experiencing on a routine basis. Most schools were reluctant to engage in any response beyond the politically neutral arena of “crisis management.” Among the school districts that I was in contact with, there was a clear resistance to addressing or even naming issues of racism and Islamophobia. In fact, the discursive language to name and define the experiences that Muslims were encountering on a day-to-day basis did not even exist within the educational discourse. While schools were reluctant to name specific incidents as racism – part of an all-too-common denial – the notion of “Islamophobia” did not have any currency at all. In fact, it was not a part of the language or conceptual constructs commonly used by educators, even by those committed to multicultural and antiracist pedagogy. I realized the urgency to map a new epistemological and pedagogical terrain by creating an educational framework for addressing Islamophobia. Within the existing equity-based educational frameworks, one could find the conceptual and pedagogical tools to address issues of racism, classism, sexism, homophobia, ableism, and anti-Semitism. However, the discursive foundations for dealing with Islamophobia and the accompanying educational resources simply did not exist. Developing a new framework to fill this gap involved coining a new term: “Anti-Islamophobia Education.” Being able to name and define the experience of Muslims as the result of Islamophobia was critical to shaping the kind of interventions that would take place from a critical educational standpoint. Before outlining a methodology for conducting anti-Islamophobia education, it was necessary to develop some discursive foundations, arrive at a definition of Islamophobia, and create an understanding of what it was that we sought to challenge and resist. From a socio-psychological standpoint, the notion of Islamophobia is often loosely translated as an “attitude of fear, mistrust, or hatred of Islam and its adherents.” However, this definition presents a narrow conceptual framework and does not take into account the social, structural, and ideological dimensions through which forms of oppression are operationalized and enacted. Applying a more holistic analysis, far from being based on mere “ignorance,” Islamophobic attitudes are, in fact, part of a rational system of power and domination that manifests as individual, ideological, and systemic forms of discrimination and oppression. The idea that discrimination, be it based on race, class, gender, sexuality, ability, or religion, simply stems from “ignorance” allows those engaged in oppressive acts and policies to claim a space of innocence. By labeling Islamophobia as an essentially “irrational” fear, this conception denies the logic and rationality of social dominance and oppression, which operates on multiple social, ideological, and systemic levels. Therefore, to capture the complex dimensions through which Islamophobia operates, it is necessary to extend the definition from its limited conception as a “fear and hatred of Islam and Muslims” and acknowledge that these attitudes are intrinsically linked to individual, ideological, and systemic forms of oppression that support the logic and rationale of specific power relations. For example, individual acts of oppression include such practices as name-calling or personal assault, while systemic forms of oppression refer to the structural conditions of inequality regulated through such institutional practices as racial profiling or denying jobs or housing opportunities. These exclusionary practices are shored up by specific ideological underpinnings, among them the purveyed notions designed to pathologize Muslims as “terrorists” and impending threats to public safety. Understanding the dimensions of how systems of oppression such as Islamophobia operate socially, ideologically, and systemically became a key component of developing educational tools that would help build the critical skills needed to analyze and challenge these dynamics. From a discursive standpoint, I locate anti-Islamophobia education within a integrative anti-racism framework5 that views systems of oppression based on race, class, gender, sexuality, ability, and religion as part of a multiple and interlocking nexus that reinforce and sustain one another. Based on this understanding, I have mapped some key epistemological foundations for anti-Islamophobia education.6 This includes the need to “reclaim the stage” through which Islam is represented from the specter of terrorists and suicide bombers to a platform of peace and social justice. “Reclaiming the stage” requires adopting a pedagogical approach that shifts the popular media discourse away from the negative, essentialized referents and tropes of abject “Otherness” ascribed to Muslims. This move involves presenting a critical counter-narrative in order to reframe the Manichean worldview and “clash of civilizations” narratives typically being purveyed in order to present a more nuanced, reasoned, and critical perspective of the global sociopolitical realities that Muslim individuals and societies are confronting, engaging, and challenging. Another foundational aspect of anti-Islamophobia education involves interrogating the systemic mechanisms through which Islamophobia is reinforced, by analytically unraveling the dynamics of power in society that sustain social inequality. Racial profiling, which targets groups on the basis of their race, ethnicity, faith, or other aspects of social difference, and similar issues are major systemic barriers that criminalize and pathologize entire communities. In schools, the practice of “color-coded streaming,” whereby a disproportionate number of racially and ethnically marginalized youth are channeled into lower non-academic level streams, is another example of institutionalized racism. Negative perceptions held by teachers and guidance counselors toward racialized students have often led to assumptions of failure or limited chances for success, based on such false stereotypes as the notion that “Islam doesn’t value education for girls” or “Black students won’t succeed.” These negative attitudes are relayed to students through the “hidden curriculum” of schooling and lead to lower expectations being placed upon youth from specific communities.7 Developing critical pedagogical tools to analyze and develop challenges to these systems of domination is part of building a transformative and liberatory pedagogy, one geared toward achieving greater social justice in both schools and society. Another key goal of anti-Islamophobia education involves the need to demystify stereotypes. Since 9/11, renewed Orientalist constructions of difference have permeated the representation of Muslims in media and popular culture. Images of fanatical terrorists and burqa-clad women are seen as the primary markers of the Muslim world. Deconstructing and demystifying these stereotypes is vital to helping students develop a critical literacy of the politics of media and image-making. Critically examining the destructive impact of how these images create the social and ideological divide between “us” and “them” is important to exposing how power operates through the politics of representation.

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