On August 5, 2012 a right-wing, racist terrorist named Wade Michael Page entered into a Sikh house of worship where he shot and killed six people before a police officer shot him; he then turned the gun on himself. He supposedly only utilized a 9-millimeter, semi-automatic pistol for the attack. Mr. Page was part of the white-power movement and was active in a band that produced racist musical lyrics. He had multiple tattoos indicative of his racist lifestyle, including a totenkopf, initials for “White Power,” and the number 14 that designates the fourteen words of the white power movement: “we must secure the existence of our people and a future for white children.” There should be little doubt this was a domestic act of right-wing terrorism.

Since 9-11, America has openly discussed Islamic terrorism and brought the topic to the forefront of national security debates. However, this is not the only kind of terrorism that exists. America has a long history of a variety of terrorist attacks that range from the anarchists of the turn of the century who killed President McKinley, communists in the 1960’s like the Weather Underground, black and Puerto Rican nationalists in the 1970’s, and right-wing militia groups in the 1990’s. The U.S. needs to not only focus on Islamic terrorism if it wishes to remain safe.

During the 1990’s, America was gripped by dozens of right-wing terrorists. The majority of this movement faded out, but that does not mean the U.S. should become complacent about any group of terrorists. In April 1996 Larry Wayne Shoemake killed a black man and wounded seven others in a shooting spree in Mississippi. In the summer of that same year, Eric Rudolph bombed the Olympics killing one and injuring a hundred. The following two years he would also bomb several abortion clinics. There was also the most famous right-wing terrorist– Timothy McVeigh. McVeigh used a car-bomb to attack the Alfred P. Murrah Federal Building in Oklahoma City; he killed 168 people and injured 500.

There is also a history of left-wing terrorism in America. The Weather Underground, a far left terrorist group, had a series of bombings in the late 1960’s and early 1970’s. Eco-terrorists like the Earth Liberation Front have committed multiple arsons. Like right-wing terrorism, extreme leftists still pose a threat. On August 15, 2012 a violent extremist associated with The DC Center for the LGBT Community went into the Family Research Council, a Christian group, and opened fire. It was a security guard, Leo Johnson, which prevented the leftist terrorist from killing anyone. Domestic terrorism takes many forms, and it is important for America’s national security apparatus to focus on its variety of forms.

The FBI and Homeland Security need to continue to put resources towards domestic terrorism, especially towards hate groups in the U.S. One of the major problems of trying to deal with right-wing terrorists is that they act as lone wolves. There are many militias and hate groups, but the list of right-wing terrorist attacks is predominately done by individuals. To go after domestic terrorists the government should actively seek to break apart hate groups and monitor suspicious individuals, much the way they do with other terrorist groups. Government agencies should actively break apart hate groups that pose the possibility of a terrorist threat. Some will argue that hate speech in any kind is the price people have to pay to exist in a democracy that guarantees freedom of speech. However, there are two specific limitations to the freedom of speech that apply to people like Mr. Page and the groups to which he belongs. The Supreme Court has held that freedom of speech is limited when there is a “clear and present danger” or the production of “fighting words.”

Although the clear and present danger test was superseded by the imminent lawless action concept in Brandenburg vs. Ohio, to adequately deal with domestic terrorism it is important to return to the ideas of Schenck vs. U.S. In the former case a KKK member was arrested for participating in a rally that supported violence against Jews, blacks, and their supporters. The Supreme Court held in that case that it was inappropriate to charge someone for merely advocating abstract concepts of violence. This is a wholly inadequate approach to countering domestic hate groups. Schenck vs. U.S.’s clear and present danger test should return and the government should apply it to right-wing hate groups that advocate violence, even if it is only in an ethereal manner. The other court case has to do with “fighting words,” which the government should also use as a basis for breaking apart hate groups. In Chaplinsky vs. New Hampshire the Supreme Court held that limitations on the freedom of speech “include the lewd and obscene, the profane, the libelous, and the insulting or ‘fighting’ words — those which, by their very utterance, inflict injury or tend to incite an immediate breach of the peace.”
The primary purpose of the government is to keep its citizens safe from threats both foreign and domestic. Although for the past decade,focus on Islamic extremism has been paramount, the government should not slack on keeping track of other forms of terrorists. This includes right-wing terrorists, left-wing terrorists, eco-terrorists, narco-terrorists, and religious terrorists. There needs to be vigilance against all forms of terrorism to keep the country safe.

Treston Wheat | Georgetown University | @TrestonWheat