Thoughts
are free and are subject to no rule.
— Paracelsus1
As we frantically race
into the third millennium, with microprocessors becoming faster, cheaper,
and smaller, with surveillance cameras proliferating in public spaces,
with the human genome program about to issue its first “working draft”
of the human DNA sequence, and with an out-of-control Frankensteinian
machine named the War on Drugs, all awhirl in the ocean of modern day
culture, it is imperative that we, as a society, expressly acknowledge the
fundamental human right to cognitive liberty and immediately begin to
define its contours.
Encroachments on cognitive liberty can take various forms. New
technologies such as biogenetic modification, human-computer interfacing,
brain-scanning, nanotechnology, neural-networking, so-called “neuro-therapy,”
and new pharmaceuticals, raise exciting possibilities for human
“evolution.” But, if not developed and used responsibly, they and the
legislation they spawn, could also pose new threats to cognitive freedom.2
The trend of technology is to overcome the limitations of the human body.
And, the Web has been characterized as a virtual collective consciousness
and unconsciousness. What are the implications for mental autonomy when
wearable computers become wet-wired to our own minds and memory is
augmented by a high-speed wireless connection to the Web? Similarly,
advances in biotechnology and drug-design increasingly raise legal and
ethical questions related to cognitive liberty, including what rights
people will have to access these and other technologies, and what rights
we will have to avoid them.
Calibrating Cognitive Liberty
Part of elucidating a theory of cognitive liberty is simply recognizing
when free cognition is being infringed. Restrictions on physical liberty,
for all their pain and terror, at least have the benefit of being
relatively easy to recognize and call attention to. During World War II,
the Nazi concentration camps for Jews, and the American internment camps
for Japanese Americans, were marked by the machinery of physical control:
fences, barbed wire, and guard towers. Similarly, from 1961 to 1989, a
concrete and barbwire wall overseen by 116 guard towers divided the city
of Berlin. Anyone who tried to cross that wall without a “special
authorization” risked a bullet in the back of his or her skull. In
contrast to the usual visibility of government restraints on physical
liberty, restraints on cognitive liberty are most often difficult to
recognize, if not invisible.
Consciousness is so complex and multifaceted that it may never be
understood. Unfortunately, the inability to understand consciousness does
not equate to an inability for others to control it. How then can we
recognize nefarious attempts to control consciousness? In one respect,
absolute control of one’s own consciousness is an impossibility. While
each of us carries our own brain in our own skull, the process of
consciousness itself is interactive. All our senses continuously feed data
into our brains, producing a dance of cognition that perpetually swirls
the exterior world with the interior world creating a seamless, edgeless,
apperceptive feedback loop. Our minds are continually changing,
continually interfacing with “the other.” Cognitive liberty clearly
cannot mean cognitive isolation.
Mind control, like most everything else, comes in degrees. A discussion
with a friend may make you change your opinion on a topic, it may even
change your life, but does that amount to “mind control?” Was your
cognitive liberty violated? Over $US200 billion dollars is spent each year
by companies unabashedly striving to manipulate our desires, to literally
make us want their product. If you see an advertisement (or many) for a
product and that advertisement, replete with imagery of the good life,
causes you to purchase the product, have you been the victim of mind
control? Has your cognitive liberty been violated?
What if the advertisement is embedded with auditory or visual subliminal
messages? What if the advertisement is embedded in prime-time television
programs, passing as program content, rather than demarked as a
“commercial?”3 Or, suppose you are a 12-year-old placed on Prozac®,
or Ritalin® largely because your schoolteacher has “diagnosed” you as
depressed or suffering from Attention Deficit Disorder. Has your cognitive
liberty been violated?
The answers to the above questions depend upon how finely one calibrates
cognitive liberty. But some scenarios, some infringements on mental
autonomy, are crystal clear and ought to present limit cases where general
policies and specific rules emerge in high-definition clarity. Yet, even
in so-called limit cases, the US government, including its legal system,
has often acted inconsistently.
A (Very) Brief History of US Government Mind
Control
In 1969, Justice Marshall wrote, without mincing words, “Our whole
constitutional heritage rebels at the thought of giving government the
power to control men’s minds.”4 Yet, contrary to Justice Marshall’s
strong pronouncement, the US government has not consistently respected or
protected cognitive liberty. Indeed, some of the government’s offenses
seem to come directly from the pages of a dystopian novel like George
Orwell’s Nineteen Eighty-Four.5
Imagine, for example, if the government passed a law mandating that all
citizens receive monthly injections of time-release sedatives, justifying
the law on the “public health” grounds that sedated people are more
productive at routine repetitive tasks, are less violent, and are less of
a drain on public resources. What if those who did not voluntarily report
at the time and place appointed for their injection were rounded up by the
police, and forcefully lobotomized? Would anyone doubt that such a law
infringed not just on one’s physical freedom but also on one’s
cognitive freedom? It’s not exactly an unthinkable scenario. From the
1920s through 1970, pursuant to the laws of at least 32 states, more than
60,000 people were deemed “eugenically unfit.” Many of these people
were involuntarily sterilized, in part because of low scores on
intelligence tests.6 When one of these laws was challenged, and the case
reached the United States Supreme Court, it was upheld—with Justice
Oliver Wendell Holmes smugly proclaiming, “Three generations of
imbeciles are enough.”7
Until 1973, “homosexuality” was listed as a psychiatric disorder in
the Diagnostic and Statistical Manual of Mental Disorders (DSM). People
who admitted being homosexual, or who were “accused” of being gay or
lesbian, were subject to involuntary confinement under mental health laws,
and subjected to “reparative therapy” or “conversion therapy”
designed to convert them into heterosexuals. “Treatment,” in addition
to counseling, included penile plesthysmograph (electronic shock triggered
by penile erection), drugging, and hypnosis. Even though homosexuality was
deleted from the DSM in 1973, it was not until December 1998 that the
American Psychiatric Association finally disapproved of “reparative”
or “conversion” therapy.8
In the 1950s, 60s, and early 70s, the US government illegally and
unethically drugged unwitting US citizens with psychoactive substances,
including LSD, as part of projects bluebird, artichoke, and mkultra, all
in an attempt to develop techniques of mind control. Richard Helms, the
chief planner of mkultra, wrote in a planning memorandum that the program
was designed in part to:
Investigate the development of chemical material which causes a reversible
non-toxic aberrant mental state, the specific nature of which can be
reasonably well predicted for each individual. This material could
potentially aid in discrediting individuals, eliciting information, and
implanting suggestions and other forms of mental control.9
While the mkultra program began with tests in the laboratory on willing
volunteers, the CIA quickly saw the need to expand the testing to
determine what the effects of drugs such as LSD would be on unsuspecting
people. Thus, in 1953, the CIA moved its mind control program into the
streets of America and began the “covert testing of materials on
unwitting US citizens.”10
In subsequent installments of this essay, we will see how the US
Government continues to promulgate certain policies that, while cloaked in
“public health” or “public safety” justifications, amount to an
impermissible government action aimed at policing thought and interfering
with the mental processes of citizens.
'Freedom'’s Invisible Landscape
The right to control one’s own consciousness is the quintessence of
freedom. If freedom is to mean anything, it must mean that each person has
an inviolable right to think for him or herself. It must mean, at a
minimum, that each person is free to direct one’s own consciousness;
one’s own underlying mental processes, and one’s beliefs, opinions,
and worldview. This is self-evident and axiomatic.
In assessing what rights are fundamental and thus entitled to the most
stringent legal protection, the US Supreme Court has stated that,
fundamental liberties are those “implicit in the concept of ordered
liberty,” such that “neither liberty nor justice would exist if [they]
were sacrificed.”11 Under another test, fundamental liberties were
characterized by the Court as those liberties that are “deeply rooted in
this Nation’s history and tradition.”12
Slightly over seventy years ago, Justice Brandies acknowledged in a
landmark privacy case that cognitive freedom was one of the principal
protections designed into the Constitution:
The makers of our Constitution undertook to secure conditions favorable to
the pursuit of happiness. They recognized the significance of man’s
spiritual nature, of his feelings and of his intellect. They knew that
only a part of the pain, pleasure and satisfactions of life are to be
found in material things. They sought to protect Americans in their
beliefs, their thoughts, their emotions and their sensations. They
conferred, as against the Government, the right to be let alone—the most
comprehensive of rights and the right most valued by civilized man.13
But, while certain justices have, at times, pointedly acknowledged the
fundamental nature of cognitive freedom and the nefarious nature of
government (or other “outside”) interference with the intellect, this
important freedom remains only obliquely defined within the US legal
system. Ironically, the lack of a comprehensive treatment may be because
cognitive freedom is so self-evidently a basic human right. Whatever the
reason, without a coherent cognitive liberty jurisprudence, present and
future infringements on cognitive liberty risk passing unnoticed or
unremedied. In the next installment of this essay, we will begin to dig
deep into privacy, due process, and First Amendment cases, in an attempt
to excavate a theoretical scaffolding for cognitive liberty. As I believe
the cases will show, cognitive liberty is the invisible landscape from
which springs some of our most cherished and protected freedoms.
Notes
1 J. Jacobi, ed., Selected Writings (New York: Pantheon Books, 1951).
2 One example of fiction-like technology looming just over the horizon was
recently discussed by MIT-educated futurist Ray Kurzweil, who has
forecasted the coming of nanobot brain scanners. These nanobots would be
blood-cell-sized robots that travel through capillaries in the brain and
take high-resolution scans of the neural features. These bots would be
tied together on a wireless LAN, and comprise a distributed parallel
computer with the same power as the brain that was scanned. (“The Story
of the 21st Century” in Technology Review Jan./Feb. 2000, 82-83.)
Kurzweil says that every aspect of this scenario is feasible today
“except for size and cost.” For more of Kurzweil’s ideas, see his
book The Age of Spiritual Machines: When Computers Exceed Human
Intelligence (New York: Viking, 1999).
3 See “Big Brother Puts a New Twist on the Telescreen,”infra, 60.
4 Stanley v. Georgia (1969) 394 U.S. 557, 565.
5 G. Orwell, Nineteen Eighty-Four (New York: Harcourt, Brace & Co.,
Inc., 1949).
6 J. Robitscher, ed., Eugenic Sterilization (Springfield, Il: Charles C.
Thomas, 1973), 118-119 [listing sterilization data for most states]; E.
Brantlinger, Sterilization of People with Mental Disabilities: Issues,
Perspectives, and Cases (Westport, Con.: Auburn House, 1995) 25; E.J.
Larson & L. Nelson III, “Involuntary Sexual Sterilization of
Incompetents in Alabama: Past, Present, and Future,” 43 Alabama L. Rev.
399 (1992), 407.
7 Buck v. Bell (1927) 274 US 200, 207. Eugenic sterilization, including
the Norplant contraceptive device, will be further discussed in subsequent
installments of this essay.
8 “American Psychiatric Association Rebukes Reparative Therapy,” Press
Release No. 98-56, December 14, 1998. Viewable online at http://www.psych.org/news_stand/rep_therapy.html.
[Accessed: 23 January 2000.]
Alan Turing, one of the founding fathers of artificial intelligence
theory, was arrested for violation of British homosexuality statutes in
1952 after he admitted having a homosexual affair. Believing that his
sexual orientation was a personal matter, neither a sin nor a crime, he
presented no defense at his trial, which occurred on 31 March 1952. In
lieu of prison, he was ordered to submit to estrogen injections for a
year. Following a period of depression, likely the result of the
injections, he committed suicide on June 7, 1954.
9 “Memorandum from ADDP items to DCI Dulles, 4/3/53” quoted in The
Mind Manipulators (Paddington Press, 1978), 132.
10 Inspector General’s Report on mkultra, (August 14, 1963), 7, quoted
in The Mind Manipulators, supra, 133.
For more details on the government’s bluebird, artcichoke, and mkultra
programs (at least those details not lost forever when Richard Helms,
ordered the destruction of all records related to the projects in January
1973) see A. Scheflin & E. Opton, “Tampering With The Mind (l) &
(ll),” in The Mind Manipulators, supra, (1978), 106-212.
11 In Palko v. Connecticut (1937) 302 U.S. 319, 325, 326.
12 Moore v. East Cleveland (1977) 431 U.S. 494, 503 (opinion of Powell,
J.).
13 Olmstead v. United States (1928) 277 U.S. 438, 478 (Brandies, J.,
dissenting).
An Introductory Note on Banned Books and other Controlled Substances
As you read this sentence you are receiving information. Words are
carriers of thoughts, whether spoken from mouth to ear, digitized and
passed electronically, or downloaded into ink and passed on paper across
time and space. Because words are vehicles for thoughts, words can change
your opinion, give you new ideas, reform your worldview, or foment a
revolution.
Attempts to control the written word date from at least AD 325 when the
Council of Nicaea ruled that Christ was 100 percent divine and forbade the
dissemination of contrary beliefs. Since the invention of the printing
press in 1452, governments have struggled to control the printed word.
Presses were initially licensed and registered. Only certain people were
permitted to own or control a printing press and only certain things could
be printed or copied. (This was the origin of today’s copyright rules.)
Works printed without prior authorization were gathered up and destroyed,
the authors and printers imprisoned.
Scholars disagree as to the exact date, but some time around 1560, Pope
Paul IV published the Index Librorum Prohibitorum a list of forbidden
books (i.e., controlled substances) enforced by the Roman government. When
the Index was (finally) abandoned in 1966, it listed over 4,000 forbidden
books, including works by such people as Galileo, Kant, Pascal, Spinoza
and John Locke.2 The history of censorship has been extensively recorded
by others. My point is simply the obvious one that efforts to prohibit
heterodox texts and to make criminals out of those who
"manufactured" such texts, were not so much interested in
controlling ink patterns on paper, as in controlling the ideas encoded in
printed words.
I submit that in the same way, the so-called "war on drugs" is
not a war on pills, powder, plants, and potions, it is war on mental
states — a war on consciousness itself — how much, what sort we are
permitted to experience, and who gets to control it. More than an
unintentional misnomer, the government-termed "war on drugs" is
a strategic decoy label; a slight-of-hand move by the government to
redirect attention away from what lies at ground zero of the war — each
individual’s fundamental right to control his or her own consciousness.
Free
Thought and the First Amendment
Benjamin Cardozo, one of the most respected and influential American legal
scholars of the last century and a former Justice of the U.S. Supreme
Court, affirmed cognitive liberty as central to most every other freedom:
...freedom of thought…one may say…is the matrix, the indispensable
condition, of nearly every other form of freedom. With rare aberrations a
pervasive recognition of that truth can be traced in our history,
political and legal. 11
Cognitive liberty jurisprudence must begin, then, with an effort to
distill the legal principles that support some of our most cherished and
well-established freedoms, and then, over time, crystallize these
principles into the foundation for a coherent legal scheme governing
issues related to an individual’s right to control his or her own
consciousness. Given the importance of the First Amendment to U.S. and
even international law, we will begin by examining how courts have
construed the First Amendment—searching for evidence that the right of
each person to autonomy over his or her own mind and thought processes is
central to First Amendment jurisprudence.
Congress shall make no law respecting an establishment of religion, or
prohibiting the free exercise thereof; or abridging the freedom of speech,
or of the press; or the right of the people peaceably to assemble, and to
petition the Government for a redress of grievances. (The First
Amendment.)12
The First Amendment’s guarantees were designed to bar the government
from controlling or prohibiting the dissemination of unpopular or
dissenting ideas. Central to all five guarantees is the acknowledgement
that people must be treated by the government as ends not means; each
person free to develop his or her mind and own belief system, and
encouraged to express his or her thoughts in the so-called
"marketplace of ideas."13 As U.S. Supreme Court Justice Felix
Frankfurter emphasized in 1949, the freedom of expression guaranteed by
the First Amendment guards against "thought becom[ing] checked and
atrophied."14
Free speech, free exercise, free association, a free press and the right
to assemble, are all moot if the thought that underlies these actions has
already been constrained by the government. If the government is permitted
to prohibit the experiencing of certain thought processes, or otherwise
manipulate consciousness at its very roots—via drug prohibitions,
religious indoctrination, monopolizing media, or any number of
methods—it need not even worry about controlling the expression of such
thoughts. By prohibiting the very formation of mind states—by strangling
the free mind itself—free expression is made meaningless. Thus, in order
to prevent the erosion of the First Amendment’s protection of
expression, the Amendment must also provide at least as strong a
protection for the underlying consciousness that forms the ideas that are
later expressed. Indeed, the First Amendment was infused with the
principle that each individual—not the government—ought to have
control over his or her own mind, to think what he or she wants to think,
and to freely form and express opinions and beliefs based on all the
information at his or her disposal. The First Amendment, in other words,
embraces cognitive liberty not simply as the desired outcome of the
articulated guarantees (i.e., a right to express one’s ideas), but also
as a necessary precondition to those guaranteed freedoms
(i.e., a right to form one’s own ideas).
May I Control My Own Consciousness?
In (the apropos year of) 1984, the Tenth Circuit Court of Appeal issued an
opinion in a case involving a man who was involuntarily drugged with the
"antipsychotic drug" thorazine while he was being held for trial
on murder charges.15 The threshold issue was whether pretrial detainees
have a fundamental right to refuse treatment with anti-psychotic drugs. To
answer this question, the Tenth Circuit analogized to a 1982 case in which
the U.S. Supreme Court held that "’[l]iberty from bodily restraint
always has been recognized as the core of the liberty protected by the Due
Process Clause from arbitrary governmental action.’"16 The Tenth
Circuit reasoned that if freedom from bodily restraints is a fundamental
right, then individuals must also have a liberty interest in freedom from
"mental restraint of the kind potentially imposed by antipsychotic
drugs."17
Thus, the Tenth Circuit found that freedom from government imposed mental
restraints was just as fundamental as freedom from government imposed
physical restraints – both were protected by the Due Process Clause.
Furthermore, the Tenth Circuit found that the First Amendment was also
implicated when the government attempts to involuntarily psycho-medicate a
person awaiting trial. In unequivocal language, the Tenth Circuit
explained "[t]he First Amendment protects communication of ideas,
which itself implies protection of the capacity to produce ideas."18
As professor Laurence Tribe of Harvard Law School has cautioned:
In a society whose ‘whole constitutional heritage rebels at the thought
of giving government the power to control men’s own minds,’ the
governing institutions, and especially the courts, must not only reject
direct attempts to exercise forbidden domination over mental processes;
they must strictly examine as well oblique intrusions likely to produce or
designed to produce, the same result."19
Prohibiting an otherwise law-abiding person from using entheogens is more
than merely an "oblique intrusion" on the right to control
one’s own mental processes, or a slight trespass on the "protected
capacity to produce ideas" — it is a direct frontal attack. Under
the recently released National Drug Control Strategy 2000, the federal
government will spend just shy of $20 billion ($20,000,000,000) on an all
out attempt to keep people from evoking alternative states of
consciousness by the use of controlled substances.20
As I will show in the next installment of this essay, the government’s
War on Unapproved Mental States, besides violating core principles of the
First Amendment, also violates the very essence of the right to privacy.
Notes
1 Kovacs v. Cooper (1949) 336 U.S. 77, 97 (concurring opinion of J.
Frankfurter)
2 For a fascinating survey of suppressed literature, see the multi-volume
set Banned Books, published by Facts on File, which covers literature
suppressed on religious, social, sexual, and political grounds.
3 George Orwell, Nineteen Eighty-Four (New York: Harcourt, Brace &
Co., Inc., 1949), Appendix "The Principles of Newspeak" 246.
4 Ibid., 46.
5 The substances initially listed in Schedule I as "hallucinogenic
substances" were: (1) 3,4-methylenedioxy amphetamine; (2)
5-methoxy-3,4-methylenedioxy amphetamine; (3) 3,4,5-trimethoxy
amphetamine; (4) Bufotenine; (5) Diethyltryptamine; (6) Dimethyltryptamine;
(7) 4-methyl-2,5-dimethoxyamphetamine; (8) Ibogaine; (9) Lysergic acid
diethylamide; (10) Marihuana; (11) Mescaline; (12) Peyote; (13)
N-ethyl-3-piperidyl nezilate; (14) N-methyl-3-piperidyl benzilate; (15)
Psilocybin; (16) Psilocyn; (17) Tetrahydrocannabinols. (PL 91-513, Oct.
27, 1970; 21 U.S.C. sec. 812, subd. (b) (1970).)
The list of Schedule I "hallucinogenic substances" now numbers
31 items. (21 CFR § 1308.11(d) (April 1999)).
6 For more on the historic and pre-historic use of entheogens, see Peter
Furst, Hallucinogens and Culture (Novato, CA: Chandler & Sharp
Publishers, Inc., 1976); R.E. Schultes, and A. Hofmann, The Botany and
Chemistry of Hallucinogenic Plants (Springfield, IL: Charles C. Thomas,
1973).
7 H. Munn, in, Hallucinogens and Shamanism, ed. M. Harner (New York:
Oxford University Press, 1973), 88-89.
Philosopher and ethnobotanist Terence McKenna suggested that early man’s
ingestion of visionary plants may have been the very catalyst that led to
the sudden expansion of human brain size between three and six million
years ago, and the event which spawned the subsequent emergence of
language itself. (See Terence McKenna, Food of the Gods (New York: Bantam
Books, 1993), 25.)
8 Peter Lamborn Wilson, "Neurospace," in 21-C (Newark, NJ:
Gordon and Breach Publishers, 1996), (3)32.
9 George Orwell, Nineteen Eighty Four, supra, Appendix: "The
Principles of Newspeak," 246.
10 Stephen Arons and Charles Lawrence, "The Manipulation of
Consciousness: A First Amendment Critique of Schooling" in 15(2)
Harvard Civil Rights-Civil Liberties Law Review 309-361 (Fall 1980), 312.
11 Palko v. Connecticut (1937) 302 U.S. 319, 326-327.
12 Although the First Amendment only mentions "Congress," the
U.S. Supreme Court has held that the Fourteenth Amendment’s Due Process
Clause incorporates the First Amendment guarantees and thus makes those
guarantees applicable to State governments as well as Congress. (See
Gitlow v. New York (1925) 268 U.S. 652, 666; Board of Education v. Pico
(1981) 457 U.S. 853, 855, fn. 1.)
13 The concept of a laissez faire marketplace where ideas compete for
buyers appears to date from 1919 when U.S. Supreme Court Justice Holmes
wrote in Abrams v. United States (1919) 250 U.S. 616, 630 "[T]he
ultimate good desired is better reached by free trade in ideas ... the
best test of truth is the power of the thought to get itself accepted in
the competition of the market") (Holmes, J., dissenting).
Using a "marketplace" analogy for the interaction and acceptance
or rejection of ideas is problematic.
Using market mechanisms to determine the logic or merit of ideas reduces
ideas to commodities. When this happens the circulation of ideas is
determined by their sales profiles. The ‘consumer’ is described as
voting for the products of the Consciousness Industry [a term coined by
Hans Magnus Enzensberger in his 1974 collection of essays of the same
name] with his or her dollars (consumer sovereignty). Such metaphors
suggest democracy and freedom of choice. They deflect attention away from
the tightly controlled decision-making process that actually determine
what ideas will gain entry into the commodity system. That is, they render
the control system of the capitalistic consciousness industry invisible
and thereby permit subterranean censorship based upon both market and
political considerations. In sum, they permit elites to rule but preserve
the semiotics of democracy. (Sue Curry Jansen, Censorship: The Knot that
Binds Power and Knowledge (New York; Oxford: Oxford University Press,
1988), 134.)
14 Kovacs v. Cooper, supra, at p. 95
15 Bee v. Greaves (10th Cir. 1984) 744 F.2d 1387, 1393 , cert. denied,
(1985) 469 U.S. 1214
16 Youngberg v. Romeo (1982) 457 U.S. 307, 316.
17 Bee v. Greaves, supra, at p. 1393.
18 Ibid., 1393-1394; Accord, Rogers v. Okin (D.Mass. 1979) 478 F.Supp.
1342, 1366-1367. Other courts have held that inmates in mental hospitals
have a constitutional "liberty interest" in maintaining the
autonomy over their own minds in the face of doctors who want to
involuntarily medicate them. (See, e.g., United States v. Charters (4th
Cir.1988) (en banc) 863 F.2d 302, 305 (antipsychotic drugs intrude
sufficiently upon "bodily security" to implicate a "protectable
liberty interest"); And, still other courts have held that there is a
constitutional "privacy protection" that encompasses "the
right to protect one’s mental processes from governmental
interference." See, e.g., Rennie v. Klein (D.N.J. 1978) 462 F. Supp.
1131, 1144 ("the right of privacy is broad enough to include the
right to protect one’s mental processes from governmental
interference").
For a comprehensive survey of forced mental treatment cases, see Bruce J.
Winick, "The Right to Refuse Mental Health Treatment: A First
Amendment Perspective," University of Miami Law Review (September
1989), 44(1) 1-103.
19 L. Tribe, American Constitutional Law Sec. 15-5, at p. 889 (1978)
(quoting Stanley v. Georgia (1969) 394 U.S. 557, 565.)
20 The National Drug Control Strategy 2000 can be read online via the
Alchemind Society’s Drug Law Library at www.cognitiveliberty.org/links.htm
[Accessed: May 17, 2000.]
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