Napoleon Legal Consulting, Inc.

January 7, 2013:  Read our article on gun control by click HERE

Keith Olbermann sued Current TV on April 5, 2012.  As our readers know, Current TV is owned, in part, by former Vice President Al Gore.  Olbermann was fired from his last job on MSNBC.  After his firing at MSNBC Al Gore hired Mr. Olbermann for a reported 50 million dollar, five year contract.  Given Current TV's abysmall ratings, the Olbermann 10 millionn dollar per year contract appears to be overly generous.  Nevertheless, Olbermann was accused by Current TV of being obstreperous, e.g., refusing to appear on election night coverage, failing to show up for work and a host of other non-compliant behaviors. 

Napoleon Legal Consulting, Inc. is providing to its readers the transcript of the hearings at the Supreme Court on the Affordable Care Act.  This transcript includes Q&A on the subject of the individual mandate.  The transcript may be downloaded by clicking on the link to the right.

No sooner had the President signed into law his legacy health care legislation when 13 attorney generals from across the United States filed civil suits challenging the constitutionality of the new law.  In particular, states took exception to the new law's requirement mandating the purchase of health insurance.  The administration's retort is expected to rely upon the court's interpretation and application of the Constitution's Commerce Clause, Article I, Section 8, to justify the mandated purchase of health insurance.

We note with some interest that the facile retort to the 13 attorney generals cites to  state government's ability to mandate the purchase of automobile insurance.  But we see a difference in kind between health and automobile insurance, in that driving an automobile is a privilege, not a right.  IF, and only IF, one wishes to exercise that privilege, then one must engage in that privilege in a responsible fashion, that is, purchase liability insurance.  In the instance of the mandated purchase of health insurance, that requirement would be triggered by the mere act of living.  In other words, by just existing, the federal government can, under Obama care, require a United States Citizen to purchase a product from a company or risk a penalty.   Imagine the implications of the federal government being able to mandate that its citizens purchase products or commodities because that same government has deemed such a purchase a socially desirable act. 

As with all legal considerations we draw the reader's attention to the formulary, not the content.  The reader may agree with the social benefits of everyone having medical insurance, but that is not the issue.  If the federal government can mandate the purchase of one particular commodity or product, it can mandate the purchase of another.  But you may say that our representatives would not, perhaps could not, force us to buy something that the American people rejected as a must buy.  Really?  There will come a time when YOU do not agree with the choice of commodity or product the federal government has added to its "must buy" list.  Sooner or later that is what happens when citizen's accede their freedoms to governments.  This government ignored the will of the majority of its citizens in order to ramrod through its social engineering agenda.  Payoffs, bribes, smoke-filled backroom deals and worse made Obama care happen over the objections of the vast majority of citizens of the United States. That should bother you, regardless of whether or not THIS TIME you happened to agree with the government's particular choice of the commodity it now requires you to purchase because you happen to be alive.

Dr. Anthony Napoleon, Ph.D., Napoleon Legal Consulting, Inc.

January 28, 2010

Justice Alito and the President:  With all due deference...


    To understand the context of my comments here one must watch Justice Alito and others react to the President’s critical comments about the Court’s recent decision in:  CITIZENS UNITED v. FEDERAL ELECTION COMMISSION.  
    The President's preface: "With all due deference to separation of powers," reminded me of that oft repeated dialogue in THE SOPRANOS.   When anyone was about to challenge Tony Soprano, the character would preface his comments with: "With all due respect." The President's preface was an admission that he was aware that he was either going to cross or come right up to that line that separates the Executive from the Judicial Branches of government.   
    The President did not limit himself to encroaching upon the Judiciary's sovereign purview, he threatened that unless the Legislative branch gave him what he wanted, he would issue an Executive order, essentially circumventing the purview of the Legislative branch.
    The bully pulpit is never more potent than during the State of the Union address. I think Justice Alito, and others, felt the encroachment of the Executive upon the Judicial and reacted with disdain over the implicit arrogance and disrespect that accompanies such an act by a sitting President. "With all due respect Mr. President....you were out of line."
    To add insult to injury, the President’s characterization of the Court’s opinion was vague and overly broad, if not an outright mischaracterization of the Court’s ruling.   The central issue before the Court in the Citizen case was whether or not First Amendment free speech protections applied to corporations.  In the instant case the non-profit corporation Citizens United funded a critical video about then Senator Hillary Clinton.  Justice Robert’s concurring opinion in the 5-4 decision (Justices Ginsburg and Stevens dissenting) is particularly well written, as is Justice Scalia’s concurring retort to Justice Steven’s dissent.

    Memo:    If you would like to read the Court’s opinion I have included it below, in PDF format, for your review.

    Try to imagine the Supremes sitting just a few short feet from you.  Now imagine what it must have been like to look out over their heads and, for all intents and purposes, talk smack to them.  Even Justices Ginsburg and Sotomayor displayed non-verbal cues that confirmed the old adage:  "blood is thicker than water."  Now imagine what is was like to sit there and have the "other" sovereign branch stand and cheer the fact that the Judicial branch had just been "called out" by the Executive.  
    What you saw was directly related to the new Senator from Massachusetts.  His election forced the President's hand.  He could either move to the center (see our news archives in the month before the President took office that predicted that this issue would take center stage) or he would "dance with them what brung him," to quote the late writer Molly Ivins.  It is unseemly when decorum is abused in service to rallying the troops.  
    

On the passing of Professor Howard Zinn

Professor Zinn’s now monumental, if not infamous, “A Peoples History of the United States," was required reading for this young student while matriculating through an Arts and Sciences honors program at Indiana University.    Even back then I was very much interested in the origins and causes of human behavior.  I am interested in the universals that define what it is we are and do as people.  I found Professor Zinn’s uniquely harsh critique of America’s past behavior curious because implicit in his admittedly biased discourse is the fact that he believes that other cultures, other people, are better that we Americans. 

I aced the six month course based upon Zinn’s book over the resistance of the professor who was taken aback by my questions peppered in class throughout the six-month term.  My questions were directed at Zinn’s precis that other cultures and other people would have behaved better, when in fact, I argued that they may have acted worse if the shoe were on the other foot.  Fast forward:

About a year ago the son of a Viet Nam veteran, 25 years my junior, handed Zinn’s book to me as a “gift.” The gift was to enlighten me, I suppose.  Never mind that I had studied Zinn’s book in a challenging academic environment while this hot housed young man was being driven to grammar school by his doting mother, nor that I had helped to expose Zinn’s ulterior motive in writing his book.  When I gently informed this young man that I was familiar with Zinn’s work and that it concerned me that he had absolutely no idea that he had been brain washed by the likes of Zinn, I received that look that was described by the early psychoanalysts as “la belle indifference.”  That term was used to describe the remarkable indifference that patients have in response to their own florid psychopathology.

It is hard for us Americans to believe that at our core we are good.  That is probably a good thing in a world where other cultures are convinced of their righteousness without so much as one iota of introspection that maybe their culture shares all of the same flaws that we, as Americans, have been working to improve since our founding.  I thought of Zinn recently when a Somali cab driver refused to allow a friend with an elderly miniature poodle get in his cab.  "Dogs are dirty where I come from,"  he arrogantly spouted off.  My friend told him that "this is America, and we love our dogs,"  to which the Somali cab driver referred my friend to Zinn's book which, according to the driver, "exposes the inherent evilness and stupidity of America."

I include below a trenchant article by Daniel J. Flynn on the late Howard Zinn, who passed away yesterday at his home in Santa Monica, California.

By Daniel J. Flynn
Mr. Flynn is the executive director of Accuracy in Academia and author of the newly released, Why the Left Hates America: Exposing the Lies That Have Obscured Our Nation’s Greatness.

Who is the most influential historian in America? Could it be Pulitzer Prize winners Arthur Schlesinger, Jr. or Joseph Ellis or David McCullough, whose scholarly works have reached a broad literary public? The answer is none of the above. The accolade belongs instead to the unreconstructed, anti-American Marxist Howard Zinn, whose cartoon anti-history of the United States is still selling 128,000 copies a year twenty years after its original publication. Many of those copies are assigned readings for courses in colleges and high schools taught by leftist disciples of their radical mentor.

“Objectivity is impossible,” Zinn once remarked, “and it is also undesirable. That is, if it were possible it would be undesirable, because if you have any kind of a social aim, if you think history should serve society in some way; should serve the progress of the human race; should serve justice in some way, then it requires that you make your selection on the basis of what you think will advance causes of humanity.”

History serving “a social aim” other than the preservation or interpretation of a historical record is precisely what we get in A People’s History of the United States. Howard Zinn’s 776 page tome, which after selling more than a million copies, has been recently re-released in a hardback edition.  What accounts for the massive sales figures? One odd answer for a work by a university professor is that A People’s History of the United States has been the beneficiary of fawning celebrities, who are not normally associated with academia. Zinn has discussed politics with Pearl Jam’s Eddie Vedder and was on Rage Against the Machine’s reading list (note: beware of rock bands that issue reading lists). In Good Will Hunting, Matt Damon’s “Will Hunting” tells his psychiatrist that A People’s History of the United States will “knock you on your ass.” Damon and co-star Ben Affleck, who grew up near Zinn outside of Harvard Square, are said to be producing a miniseries based on their neighbor’s magnum opus. Zinn repaid the actors’ youthful infatuation by including them in an inconsequential paragraph in the book’s new edition.

The New York Times’s reviewer (no doubt a cousin of Jayson Blair) declared that the book should be “required reading” for students. Professors have heeded this counsel. Courses at the University of Colorado-Boulder, UMass-Amherst, Penn State, and Indiana University are among dozens of classes nationwide that require the book. The book is so popular that it can be found on the class syllabus in such fields as economics, political science, literature, and women’s studies, in addition to its more understandable inclusion in history. Amazon.com reports in the site’s “popular in” section that the book is currently #7 at Emory University, #4 at the University of New Mexico, #9 at Brown University, and #7 at the University of Washington. In fact, 16 of the 40 locations listed in A People’s History’s “popular in” section are academic institutions, with the remainder of the list dominated by college towns like Binghamton (NY), State College (PA), East Lansing (MI), and Athens (GA). Based on this, it is reasonable to wonder if most of the million or so copies sold have been done so via coercion, i.e., college professors and high school teachers requiring the book. The book is deemed to be so crucial to the development of young minds by some academics that a course at Evergreen State decreed: “This is an advanced class and all students should have read Howard Zinn’s A People’s History of the United States before the first day of class, to give us a common background to begin the class.”  And what “common background” might that be?

Through Zinn’s looking-glass, Maoist China, site of history’s bloodiest state-sponsored killings, becomes “the closest thing, in the long history of that ancient country, to a people’s government, independent of outside control.” The authoritarian Nicaraguan Sandinistas were “welcomed” by their own people, while the opposition Contras, who backed the candidate that triumphed when free elections were finally held, were a “terrorist group” that “seemed to have no popular support inside Nicaragua.” Castro’s Cuba, readers learn, “had no bloody record of suppression.”  The recently released updated edition continues to be plagued with inaccuracies and poor judgment. The added sections on the Clinton years, the 2000 election, and 9/11 bear little resemblance to the reality his current readers have lived through.

In an effort to bolster his arguments against putting criminals in jail, aggressive law enforcement tactics, and President Clinton’s crime bill, Zinn contends that in spite of all this “violent crime continues to increase.” It doesn’t. Like much of Zinn’s rhetoric, if you believe the opposite of what he says in this instance you would be correct. According to a Department of Justice report released in September of 2002, the violent crime rate has been cut in half since 1993.

According to Zinn, it was Mumia Abu-Jamal’s “race and radicalism,” as well as his “persistent criticism of the Philadelphia police” that landed him on death row in the early 1980s. Nothing about Abu-Jamal’s gun being found at the scene; nothing about the testimony of numerous witnesses pointing to him as the triggerman; nothing about additional witnesses reporting a confession by Abu-Jamal—it was Abu-Jamal’s dissenting voice that caused a jury of twelve to unanimously sentence him to death.

Predictably, Zinn draws a moral equivalence between America and the 9/11 terrorists. He writes, “It seemed that the United States was reacting to the horrors perpetrated by the terrorists against innocent people in New York by killing other innocent people in Afghanistan.” Scare quotes adorn Bush’s “war on terrorism,” post-9/11 “patriotism,” and other words and phrases Zinn dislikes.  Readers of A People’s History of the United States learn very little about history. They do learn quite a bit, however, about Howard Zinn. In fact, the book is perhaps best thought of as a massive Rorschach Test, with the author’s familiar reaction to every major event in American history proving that his is a captive mind long closed by ideology.

Theory First, Facts Second
If you’ve read Marx, there’s really no reason to read Howard Zinn. The first line of The Communist Manifesto provides the single-bullet theory of history that provides Zinn with his narrative thread— “The history of all hitherto existing societies is the history of class struggle.” It is the all-purpose explanation of every subject that Zinn covers. On other hand, why study history when theory has all the answers?

Thumb through A People’s History of the United States and you will find greed as the motivating factor behind every act of those who don’t qualify as “the people” in Zinn’s book. According to Zinn, the separation from Great Britain, the Civil War, and both World Wars all were the result of base motives of the “ruling class” -- rich men to get richer at the expense of others.  Zinn’s Marxist explanation of the New World begins with Columbus who like every other settler in the New World was driven by the (evil) profit motive. “Behind the English invasion of North America, behind their massacre of Indians, their deception, their brutality, was that special powerful drive born in civilizations based on private profit.” This malicious view of people who often came to the New World to escape persecution in the old, who sometimes championed the rights of indigenous peoples and who mostly attempted to live peacefully alongside them is characteristic of the extreme anti-European, anti-white, any American prejudice of this book. The idea that the Indians who themselves were “invaders” by Zinn’s standards (they came on a land bridge from Asia and exterminated the then native peoples) somehow owned the continent is a much a fantasy as the idea that they were simply passive victims of the settlers. Zinn’s account omits the unprovoked aggressions of the Indians on each other and on the settlers. But then doing so, would spoil his leftist melodrama.

Case Study: The Pequot War
This melodrama depends on simplistically dividing mankind into two groups – and only two: oppressors and oppressed. This is how Zinn describes and utterly distorts the early settlement of North America. The Pequot War serves as his example, as it will ours.
The war was climaxed when the Pequot stronghold in Fort Mystic was burned in battle and all its inhabitants incinerated in May of 1637. Finding themselves severely outnumbered the attackers had set fire to the Pequot compound. This is a tragic enough story, but Zinn won’t be satisfied until it becomes a story of native American innocence and victimhood versus rapacious and evil white settlers.

Thus the Pequot violence against whites that led to the war is almost entirely absent from the text. The most Zinn can bring himself to admit is that “Massacres took place on both sides.” In fact, the author details only the atrocities committed by one side: the Puritans. While graphic descriptions of Puritan violence are highlighted, Pequot atrocities are brushed aside. Here are some examples not to be found in Zinn::“[T]hey took two men out of a boat, and murdered them with ingenious barbarity, cutting off first the hands of one of them, then his feet,” writes 19th century historian John Gorham Palfrey about the Pequots’ assaults upon settlers. “Soon after, two men sailing down the river were stopped and horribly mutilated and mangled; their bodies were cut in two, lengthwise, and the parts hung up by the river’s bank. A man who had been carried off from Wethersfield was roasted alive. All doubt as to the necessity of vigorous action was over, when a band of a hundred Pequots attacked that place, killed seven men, a woman, and a child, and carried off two girls.” It doesn’t take a rocket scientist to figure out why the settlers might have decided to resort to violent means to deal with the Pequots. But it does take someone more honest than Zinn.

The author mentions only briefly the atrocity the precipitated the war, which was the killing of a settler named John Oldham. Zinn morally justifies the murder by labeling the victim a “trader, Indian-kidnapper, and troublemaker.” This loaded account helps Zinn persuade his readers that it was the white man’s greed that led to the Pequot War. The settlers, writes Zinn, “wanted [the Pequots] out of the way; they wanted their land.”

Also absent from Zinn’s devious narrative are the atrocities that the Pequots committed against other Indians of the Connecticut Valley. The Pequots not only waged war on whites, but on their fellow native Americans as well. They were a belligerent people feared by weaker tribes.  Consequently, while Zinn portrays the Pequot War as a Puritan-versus-Indian conflict, the fact is that both Puritans and Indians fought against the Pequots, nothing could be further from the truth. Indian tribes—for example, the Narragansett—repeatedly urged the English newcomers to attack their enemies, namely the Pequots. Zinn writes that “Indian tribes were used against one another” by the Puritans when, in fact, the reverse was true. Indian tribes used the Puritans and their superior firepower to eradicate their fellow Indians who posed a threat to them.

In fact Indians were the majority in the attacking force at Fort Mystic, and by a vast margin. Whites comprised less than 15 percent of the 500-plus men who attacked the Pequot stronghold and burned it to the ground. After the horrific conflagration ended, it was the Mohegans who executed the Pequots’ captured chief.  Zinn’s account of the Pequot war is a microcosm of his book as a whole which is little more than an 800-page libel against his country.

The Founding
“Around 1776,” A People’s History informs readers, “certain important people in the English colonies made a discovery that would prove enormously useful for the next two hundred years. They found that by creating a nation, a symbol, a legal unity called the United States, they could take over land, profits, and political power from the favorites of the British Empire. In the process, they could hold back a number of potential rebellions and create a consensus of popular support for the rule of a new, privileged leadership.” Forget about all men are created equal, forget about liberty and the pursuit of happiness, America’s founding can be reduced to the pursuit of exploitation and profit. Well maybe for academics with lifetime subsidies and rock stars with drug-fried brains.

Zinn continues (without irony): “When we look at the American Revolution this way, it was a work of genius, and the Founding Fathers deserve the awed tribute they have received over the centuries. They created the most effective system of national control devised in modern times, and showed future generations of leaders the advantages of combining paternalism with command.” Rather than an event that inspired movements for freedom and self-government throughout the world through the present, the American Founding is portrayed as a virtually totalitarian system of oppression. If the Founders wanted a society they could direct, why didn’t they establish a dictatorship or a monarchy and model their rule on what was the universal form of government at the time? Why go through the trouble of devising a Constitution departing from a repressive status quote and guaranteeing individual rights, mass political participation, jury trials, and checks on governmental power? Apparently inhabiting an alternate reality, Zinn doesn’t feel the need to account for this and merely explains it away as a charade designed to prevent class revolution. This is conspiracy theory with a vengeance.

As his fictional narrative gathers steam, Zinn paints antebellum America as a uniquely cruel slaveholding society subjugating human beings for profit. The fact that America was half free and the site of an anti-slavery crusade that put an end to a 3,000 year old institution goes unnoticed or so severely discounted as to be of no account. The civil war that ended slavery becomes in Zinn’s malicious deconstruction a campaign to change the form of oppression and make it more profitable. “It is money and profit, not the movement against slavery, that was uppermost in the priorities of the men who ran the country.” Rather than welcoming emancipation, Zinn is depressed by it. “Class consciousness was overwhelmed during the Civil War,” the Marxist laments. The efficiency of the Zinn formula is impressive to behold. Both slavery and emancipation, are explained by the same factor: greed. Whether the U.S. tolerates or eradicates slavery, its evil motives remains the same. To Zinn the important thing about the emancipation of the slaves and the Civil War that brought that about is that they served as distractions from the impending socialist revolution. This is history as religious fantasy.

Here we come to the real secret of the commercial success of A People’s History. It is a case of simple ideas for simple minds – a broken record for the tone deaf. When we come to World War I, it sounds very much like the Civil War. “American capitalism needed international rivalry—and periodic war—to create an artificial community of interest between rich and poor,… supplanting the genuine community of interest among the poor that showed itself in sporadic movements.” Yet another conspiracy to distract the proletariat from its destined revolution.

The account of World War II made slightly more interesting by author’s preposterous account of its origins. According to Zinn, suggests that America, not Japan, was to blame for Pearl Harbor, provoking the Empire of the Sun and forcing it to attack us. It’s the devil made them do it theory of history, which is great fallback position of the left when confronted with the imperialistic aggressions of “people of color.” Like the war to end slavery, the fight against fascism was an optical illusion. It was really a struggle by American capitalists to rule the world. Regarding America’s neutrality in the Spanish Civil War, which preceded World War II, Zinn asks: “Was it the logical policy of a government whose main interest was not stopping Fascism but advancing the imperial interests of the United States? For those interests, in the thirties, an anti-Soviet policy seemed best. Later, when Japan and Germany threatened U.S. world interests, a pro-Soviet, anti-Nazi policy became preferable.”

Thus is reality inverted or more accurately twisted. Zinn – a pro-Communist supported Stalin’s monster regime at the time, elides the fact that it was the Soviet Union that pretended to be anti-fascist in Spain, then signed a pact with Hitler and then – when Hitler double-crossed his Communist ally and invaded the Soviet Union became anti-fascist again. The United States was isolationist in 1936 and until Pearl Harbor. But it was always anti-fascist. Zinn projects the Soviet Union’s schizophrenic policies (and his own schizophrenic allegiances) onto America. While the Hitler-Stalin Pact is awkwardly excused, Zinn all but invents a Hitler-Roosevelt Pact to serve his social aims.

But this deceptive ingenuity is fleeting and the text returns to its state of terminal boredom as Zinn tells his readers that the Second World War was really about money. “Quietly, behind the headlines in battles and bombings, American diplomats and businessmen worked hard to make sure that when the war ended, American economic power would be second to none in the world. United States business would penetrate areas that up to this time had been dominated by England. The Open Door Policy of equal access would be extended from Asia to Europe, meaning that the United States intended to push England aside and move in.” Zinn does not explain if it was America’s agenda to create a global empire why Americans helped to rebuild Japan and Germany and thereby create its chief economic rivals in the postwar world.

It is not that economics does not influence events. It is just that Marx’s simplistic reduction of all historical motives to profit motives has been discredited – not least by the 100 million people whom Marxists killed in the 20th Century to make their theories work. There is no reason to resurrect them now, despite what Eddie Vedder and Matt Damon think.

Uncooperative Facts & Convenient Omissions
When fact and theory clash, the ideologue chooses theory. Time and again, A People’s History of the United States distorts or simply ignores the truth to make the facts, or the alleged facts, or the invented facts, fit the theory that justifies his “social aims.”  Zinn claims that “George Washington was the richest man in America.” He wasn’t, but it makes for a good Marxist tale. George Washington certainly rose to accumulate great wealth in his lifetime—even if he was chronically cash-poor. (For example, he had to borrow money to travel to New York upon his election to the presidency.) It is generally conceded that Robert Morris was the Founding era’s wealthiest merchant, while Moses Brown, whose family’s name graces an Ivy League university, was another Washington contemporary whose wealth exceeded his.

“When the Scottsboro case unfolded in the 1930s in Alabama,” Zinn writes in an even more egregious fit of historical amnesia, “it was the Communist party that had become associated with the defense of these young black men imprisoned, in the early years of the Depression, by southern injustice.” Perhaps the Party had become “associated” with the defense of the Scottsboro Boys, but in reality the Communists merely used the embattled youngsters. Richard Gid Powers points out in Not Without Honor that the Communists had raised $250,000 for the Scottsboro Boys’ defense, but had put-up a scant $12,000 for two appeals. At the time, a black columnist quoted a candid Party official who stated, “we don’t give a damn about the Scottsboro boys. If they burn it doesn’t make any difference. We are only interested in one thing, how we can use the Scottsboro case to bring the Communist movement to the people and win them over to Communism.” As a fellow-traveler, Zinn has the identical view. He is only interested in history so long as it serves as a weapon of socialist ideology.

“Unemployment grew in the Reagan years,” Zinn claims. Statistics show otherwise. Reagan inherited an unemployment rate of 7.5 percent in his first month in office. By January of 1989, the rate had declined to 5.4 percent. Had the Reagan presidency ended in 1982 when unemployment rates exceeded 10 percent, Zinn would have a point. But for the remainder of Reagan’s presidency, unemployment declined precipitously.

Not surprisingly, Zinn’s book contains not a single source citation (perhaps footnotes would discourage his Pearl Jam fans).
More striking than Zinn’s inaccuracies—intentional and otherwise—is what he leaves out. Washington’s Farewell Address, Lincoln’s Gettysburg Address, and Reagan’s speech at the Brandenburg Gate all fail to merit a mention. Nowhere do we learn that Americans were first in flight, first to fly across the Atlantic, and first to walk on the moon. Alexander Graham Bell, Jonas Salk, and the Wright Brothers are entirely absent. Instead, the reader is treated to the exploits of Speckled Snake, Joan Baez, and the Berrigan brothers. While Zinn sees fit to mention that immigrants often went into professions like ditch-digging and prostitution, American success stories like those of Alexander Hamilton, John Jacob Astor, and Louis B. Mayer—to name but a few—are off the Zinn radar screen. Valley Forge rates a single fleeting reference, while D-Day’s Normandy invasion, Gettysburg, and other important military battles are skipped over. In their place, we get several pages on the My Lai massacre and colorful descriptions of U.S. bombs falling on hotels, air-raid shelters, and markets during the Gulf War of the early 1990s.

Conclusion
Zinn utters perhaps the most honest words of A People’s History of the United States in the conclusion of the book’s 1995 edition, conceding that his work is “a biased account.” “I am not troubled by that,” he adds, “because the mountain of history books under which we all stand leans so heavily in the other direction—so tremblingly respectful of states and statesmen and so disrespectful, by inattention, to people’s movements—that we need some counterforce to avoid being crushed into submission.” Perhaps the reason they lean so heavily in the other direction is that they are based on facts, not leftwing prejudice.

“I wanted my writing of history and my teaching of history to be a part of social struggle,” Zinn remarks in an interview conducted long after the release of A People’s History of the United States. “I wanted to be a part of history and not just a recorder and teacher of history. So that kind of attitude towards history, history itself as a political act, has always informed my writing and my teaching.” Indeed it has. Only let’s not call it history. Howard Zinn is a master of cheap Marxist propaganda. His book is a dagger aimed at the heart the country that has given him more freedom than most of the writers who have ever written and made him a millionaire in the process.

The anniversary volume of A People’s History of the United States comes with an encomium from one of the academic profession’s most honored figures, Eric Foner the DeWitt Clinton Professor of History at Columbia College. A former president of the American Historical Assocation, Foner reviewed Zinn’s book for the New York Times. A quote from Foner’s review is featured on the cover of the anniversary edition: “Historians may well view it,” writes Foner, “as a step toward a coherent new vision of American history.” This makes a kind of sense because Foner himself is an unreconstructed leftist, whose judgments are evidently colored by his “social aims” as well.

This slanderous tome and its popular and academic success are monuments to human credulity and delusion, and to the disgraceful condition of American letters.