Religious liberty

The Price of the First Amendment "Is That We Must Put Up With … a Good Deal of Rubbish"

|The Volokh Conspiracy |

I was rereading one of my favorite opinions—Justice Jackson's dissent in U.S. v. Ballard (1944)—and I thought I'd pass it along. The defendants were convicted for using the mails to defraud people into joining (for money) the "I Am" movement. The alleged false claims were,

that Guy W. Ballard, now deceased, alias Saint Germain, Jesus, [and] George Washington, … had been selected … as a divine messenger; and that … the words of the alleged divine entity, Saint Germain, would be transmitted to mankind through the medium of … Guy W. Ballard;

that [the Ballards], by reason of their alleged high spiritual attainments and righteous conduct, had been selected as divine messengers through which the words of … Saint Germain[] would be communicated to mankind under the teachings commonly known as the "I Am" movement;

that [the Ballards] had, by reason of supernatural attainments, the power to heal persons of … [incurable] diseases …, … and … had in fact cured … hundreds of persons ….

The court concluded that it was permissible to convict the (surviving) Ballards based on a showing that they didn't sincerely believe what they were saying, though the jury couldn't consider the truth or falsehood of what they were saying. Justice Jackson dissented:

I should say the defendants have done just that for which they are indicted. If I might agree to their conviction without creating a precedent, I cheerfully would do so. I can see in their teachings nothing but humbug, untainted by any trace of truth. But that does not dispose of the constitutional question whether misrepresentation of religious experience or belief is prosecutable; it rather emphasizes the danger of such prosecutions….

In the first place, as a matter of either practice or philosophy I do not see how we can separate an issue as to what is believed from considerations as to what is believable. The most convincing proof that one believes his statements is to show that they have been true in his experience. Likewise, that one knowingly falsified is best proved by showing that what he said happened never did happen.

How can the Government prove these persons knew something to be false which it cannot prove to be false? If we try religious sincerity severed from religious verity, we isolate the dispute from the very considerations which in common experience provide its most reliable answer.

In the second place, any inquiry into intellectual honesty in religion raises profound psychological problems…. [I]t is not theology and ceremonies which keep religion going. Its vitality is in the religious experiences of many people …[:] "… conversations with the unseen, voices and visions, responses to prayer, changes of heart, deliverances from fear, inflowings of help, assurances of support, whenever certain persons set their own internal attitude in certain appropriate ways."

If religious liberty includes, as it must, the right to communicate such experiences to others, it seems to me an impossible task for juries to separate fancied ones from real ones, dreams from happenings, and hallucinations from true clairvoyance. Such experiences, like some tones and colors, have existence for one, but none at all for another. They cannot be verified to the minds of those whose field of consciousness does not include religious insight. When one comes to trial which turns on any aspect of religious belief or representation, unbelievers among his judges are likely not to understand and are almost certain not to believe him.

And then I do not know what degree of skepticism or disbelief in a religious representation amounts to actionable fraud…. Belief in what one may demonstrate to the senses is not faith. All schools of religious thought make enormous assumptions, generally on the basis of revelations authenticated by some sign or miracle. The appeal in such matters is to a very different plane of credulity than is invoked by representations of secular fact in commerce.

Some who profess belief in the Bible read literally what others read as allegory or metaphor, as they read Aesop's fables. Religious symbolism is even used by some with the same mental reservations one has in teaching of Santa Claus or Uncle Sam or Easter bunnies or dispassionate judges. It is hard in matters so mystical to say how literally one is bound to believe the doctrine he teaches and even more difficult to say how far it is reliance upon a teacher's literal belief which induces followers to give him money….

If the members of the ["I Am"] sect get comfort from the celestial guidance of their "Saint Germain," however doubtful it seems to me, it is hard to say that they do not get what they pay for. Scores of sects flourish in this country by teaching what to me are queer notions. It is plain that there is wide variety in American religious taste. The Ballards are not alone in catering to it with a pretty dubious product.

The chief wrong which false prophets do to their following is not financial. The collections aggregate a tempting total, but individual payments are not ruinous. I doubt if the vigilance of the law is equal to making money stick by over-credulous people.

But the real harm is on the mental and spiritual plane. There are those who hunger and thirst after higher values which they feel wanting in their humdrum lives. They live in mental confusion or moral anarchy and seek vaguely for truth and beauty and moral support. When they are deluded and then disillusioned, cynicism and confusion follow.

The wrong of these things, as I see it, is not in the money the victims part with half so much as in the mental and spiritual poison they get. But that is precisely the thing the Constitution put beyond the reach of the prosecutor, for the price of freedom of religion or of speech or of the press is that we must put up with, and even pay for, a good deal of rubbish….

I do not doubt that religious leaders may be convicted of fraud for making false representations on matters other than faith or experience, as for example if one represents that funds are being used to construct a church when in fact they are being used for personal purposes. But that is not this case, which reaches into wholly dangerous ground.

When does less than full belief in a professed credo become actionable fraud if one is soliciting gifts or legacies? Such inquiries may discomfort orthodox as well as unconventional religious teachers, for even the most regular of them are sometimes accused of taking their orthodoxy with a grain of salt. I would dismiss the indictment and have done with this business of judicially examining other people's faiths.

NEXT: We Don't Need a Psychiatric Diagnosis To Assess the President's Obvious Faults

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  1. Is this decision still good law?

    Because if it is, I can sure think of several past and present “prophets” who almost certainly can and should be convicted of fraud. For starters, how about the purported psychic in Los Angeles who was revealed on the Johnny Carson show to be faking his “mind reading” via radio?

    Then there are the harmful cults that put their followers through imprisonment and brainwashing, and promote supposed healing technologies that have been disproven and banned by the FDA but are still using them. I’m thinking of Scientology (which has been banned in Germany for the same reasons) but there are others….

    1. “…promote supposed healing technologies that have been disproven…”

      That’s a pretty slippery slope. Doesn’t the Catholic church still do exorcisms from time to time?

      1. The Catholic Church still does exorcisms, but they added in another layer, in that the exorcist seeks to determine if it is mental illness first before they bother.

        Healing, though, is not what an exorcism is supposed to do, it’s rather pushing out demonic influence. It’s not purported to be faith healing, like say, the televangelist Benny Hinn says he does.

        1. Also, and importantly, the Church believes in what it is doing.

          That’s crucial. If some day, the Pope decided “this exorcism thing is BS, but let’s keep it going and charge our parishoners to do it so we can raise some money”, that would be where Ballard comes into play.

          1. And how do you know that the pope hasn’t said such a thing?

            Ever hear of the clergy project? It’s the brainchild of Richard Dawkins. In essence, there is apparently a significant number of older clergymen who have quietly come to the conclusion that religion is humbug, but they keep doing what they do because their economic security depends on it. Middle aged former pastors with no marketable skills aren’t exactly a hot commodity on the job market. I’ve seen estimates that as many as 20% of pastors may be closet atheists, including some who went into it as closet atheists to begin with, but wanted to be pastors because they saw it as a chance to do humanitarian work. The clergy project offers support for those who wish to transition out of ministry, and provides safe space for those who feel they have to stay.

            I would think that the higher up the ecclesiastical ladder one goes, the more likely it would be that a thinking person would begin to see through the BS. I suspect the percentage of closet atheists is far higher among cardinals than among parish priests.

            In my youth, I once spent a summer working at the national headquarters of a denomination which I will not here identify. Still being a true believer in those days, I expected that the people I encountered would be godly, pious, righteous men who walked with God, figuratively if not literally. Boy, was I surprised. The self-interest, personal ambition and cutthroat politics I encountered there rival those at any biglaw firm.

            1. I won’t disagree much. In fact, the biggest problem with the Catholic clergy, especially the feckless bishops, is a lack of supernatural faith.

            2. “I suspect the percentage of closet atheists is far higher among cardinals than among parish priests.”

              I think that’s trivially true, whether or not a higher position on the ecclesiastical ladder exposes more BS – because my experience is that in _any_ organization that has long outlived its founders, the higher levels are dominated by sociopaths and others who use the organization for their own self-interest, and the percentage of sociopaths increases at the higher levels. (The Pope in modern years may appear to be an exception – the lowest levels of the Catholic church contain a few sociopathic priest, bishops are worse, the College of Cardinals and the leaders of the Vatican bureaucracy are quite corrupt, but they often choose a simple and honest patsy for the Church’s figurehead. But who wields the actual power?)

    2. The holding is certainly limited by various First Amendment cases that have come later, most particularly the various cases on false speech and defamation.

      But there’s certainly some room remaining for prosecutions for fraudulent promises within the context of a religion. For instance, let’s say a person charges money for faith healing that he knows to be bogus. I would assume that, so long as sufficient scienter were shown, the person could be prosecuted and the First Amendment would not be a defense.

      1. For instance, let’s say a person charges money for faith healing that he knows to be bogus. I would assume that, so long as sufficient scienter were shown, the person could be prosecuted and the First Amendment would not be a defense.

        I would assume that too, but I would think it would take something along the lines of catching him actually saying, “Boy, these rubes will believe anything. Ha!”

        1. That’s what I was thinking, but perhaps there are other ways of revealing fraudulent intent. E.g., is that guy, who rolled up in a wheelchair for faith healing and walked away praising the preacher and the lord, a never-crippled plant in the pay of the preacher? It may take a lot of work to prove this, but it’s more likely to succeed than waiting for the preacher to confess and be overheard.

  2. The reason religion is protected is simply because it was important in 1789 very similar to how slavery was also protected in the Constitution. So religion was merely a preexisting power structure useful as a Montesquieuian power divider in order to prevent tyranny. So why fight religion like the communists or French revolutionaries when one can use religion as a power structure in order to prevent tyranny. Religion isn’t important today but it is still in the Constitution so from a constitutional perspective we must treat it as important. As hobbies go it seems like a fulfilling one so who am I to judge??

    1. I think you’re missing the boat here. While religions have been useful in upholding a power structure, they have just as often been against it and subvert the power of the state. Christianity was on both ends of this during the Roman Empire. Likewise, Buddhism in China.

      More importantly, there is a longing in humanity that only religion, or spirituality for those who have an individualistic bent, can fulfill. Therefore, it was important in 1789 from that respect as it is today, because the same needs go back to the first humans and their mythology.

      Also, fresh in the memory of the 1789 American, were rather pointless European religious wars. Religion was therefore protected from the federal government as much as the federal government was isolated from an official religion (like no religious
      tests to hold office), to prevent a religious war.

      1. The Revolution was a religious war — Puritans v. Anglicans, with the same thing happening a century earlier in England with Cromwell.

        1. No, it wasn’t. Please show me in this list where religion was mentioned, or where religion was the motivation of any of them, and why it would take primacy over any of the others on the list such that the war was a religious war.
          ————————————————————–
          He has refused his Assent to Laws, the most wholesome and necessary for the public good.

          He has forbidden his Governors to pass Laws of immediate and pressing importance, unless suspended in their operation till his Assent should be obtained; and when so suspended, he has utterly neglected to attend to them.

          He has refused to pass other Laws for the accommodation of large districts of people, unless those people would relinquish the right of Representation in the Legislature, a right inestimable to them and formidable to tyrants only.

          He has called together legislative bodies at places unusual, uncomfortable, and distant from the depository of their public Records, for the sole purpose of fatiguing them into compliance with his measures.

          He has dissolved Representative Houses repeatedly, for opposing with manly firmness his invasions on the rights of the people.

          He has refused for a long time, after such dissolutions, to cause others to be elected; whereby the Legislative powers, incapable of Annihilation, have returned to the People at large for their exercise; the State remaining in the mean time exposed to all the dangers of invasion from without, and convulsions within.

          He has endeavoured to prevent the population of these States; for that purpose obstructing the Laws for Naturalization of Foreigners; refusing to pass others to encourage their migrations hither, and raising the conditions of new Appropriations of Lands.

          He has obstructed the Administration of Justice, by refusing his Assent to Laws for establishing Judiciary powers.

          He has made Judges dependent on his Will alone, for the tenure of their offices, and the amount and payment of their salaries.

          He has erected a multitude of New Offices, and sent hither swarms of Officers to harrass our people, and eat out their substance.

          He has kept among us, in times of peace, Standing Armies without the Consent of our legislatures.

          He has affected to render the Military independent of and superior to the Civil power.

          He has combined with others to subject us to a jurisdiction foreign to our constitution, and unacknowledged by our laws; giving his Assent to their Acts of pretended Legislation:

          For Quartering large bodies of armed troops among us:

          For protecting them, by a mock Trial, from punishment for any Murders which they should commit on the Inhabitants of these States:

          For cutting off our Trade with all parts of the world:

          For imposing Taxes on us without our Consent:

          For depriving us in many cases, of the benefits of Trial by Jury:

          For transporting us beyond Seas to be tried for pretended offences

          For abolishing the free System of English Laws in a neighbouring Province, establishing therein an Arbitrary government, and enlarging its Boundaries so as to render it at once an example and fit instrument for introducing the same absolute rule into these Colonies:

          For taking away our Charters, abolishing our most valuable Laws, and altering fundamentally the Forms of our Governments:

          For suspending our own Legislatures, and declaring themselves invested with power to legislate for us in all cases whatsoever.

          He has abdicated Government here, by declaring us out of his Protection and waging War against us.

          He has plundered our seas, ravaged our Coasts, burnt our towns, and destroyed the lives of our people.

          He is at this time transporting large Armies of foreign Mercenaries to compleat the works of death, desolation and tyranny, already begun with circumstances of Cruelty & perfidy scarcely paralleled in the most barbarous ages, and totally unworthy the Head of a civilized nation.

          He has constrained our fellow Citizens taken Captive on the high Seas to bear Arms against their Country, to become the executioners of their friends and Brethren, or to fall themselves by their Hands.

          He has excited domestic insurrections amongst us, and has endeavoured to bring on the inhabitants of our frontiers, the merciless Indian Savages, whose known rule of warfare, is an undistinguished destruction of all ages, sexes and conditions.

        2. Puritans only settled New England, and by the 1770’s, there were no Puritans left, even in Massachusetts. The leadership of the Revolution in New England may have been descended from Puritans, but a good many of them were Unitarians (a religion whose American branch was strongly shaped by rejecting Puritanism) or Deists. South of Connecticut, the only colonies with a religious foundation were Pennsylvania (Quakers – when actual Puritans ran Massachusetts, they _hanged_ Quakers), and Maryland (a refuge for English Catholics).

          The southern colonies tended to be a mix of Baptists, Methodists, and Presbyterians (although much of the Scots-Irish immigration occurred after 1798), with an Anglican aristocracy, and many of the Revolutionary leaders came from that aristocracy. None of them were Puritans, and only the Catholics had ancestors who ever fought Anglicans over religion.

          The Revolutionaries were already as free of the Anglican church as they wanted to be (millions of Americans still identify with it, as “Episcopalians”), and were fighting to be treated like Englishmen in regards to Parliament, taxes, and tax collection methods.

    2. “Religion is no different than slavery” seems like a bold argument. Let’s see how that goes for you.

      1. It is no different in that it was important to that particular society in 1789. Just because something was important at that time doesn’t mean it should be important in present day America.

        1. While it may be true that just because something was important in 1789 doesn’t mean it has to be important today…it’s also true that enough people in this democracy currently think it’s important, thus in this exercise in self-government being thus far somewhat successful, that means it *is* important.

          It’s also equally true that you’re free to carry on attempting to convince people religion shouldn’t be important. People like minded to you have had some success of late. I’m sure that is cheery news to you.

          1. I don’t have to convince anyone of anything—religion in America is not that important. So as far as hobbies go it is as popular as hobbies like bridge or yoga and not nearly as popular as fantasy football.

            1. You have to convince lots of OTHER of people that religion is not important, because right now it gets special protections in the Constitution, which is difficult to change, as you may well be aware.

              You’re right, though, that you don’t have to try to convince me of anything, because as harebrained as you sound here, it ain’t gonna work regardless.

              BTW, since you’re making the argumentum ad populum fallacy here, what exactly is regular temple/mosque/church attendance on a given week compared to bridge clubs, yoga studios (which is a type of spiritualism akin to religion ya know) or membership in fantasy football clubs?

              1. Religion isn’t important at a societal level today in America. I have no doubt religion is very important to many Americans just like playing bridge and doing yoga is important to many Americans.

                I agree with Justice Thomas the Establishment Clause jurisprudence is wrong and Establishment Clause should be limited to a federalism provision. And free exercise is covered by free speech and free association so if it makes you feel better about your hobby that it is mentioned in the BoR then more power to you.

                1. More than 80% of Americans describe themselves as “religious”.
                  70% of Americans say that religion is “important” or “very important” to them.
                  50% of Americans attend a church/etc at least once a month, while 25% do so every week. Only 20% report never attending a church.
                  Americans spend about $1.2 TRILLION per year on donations/religious services. A third of that is donations alone.

                  I don’t know about you, but that certainly seems to suggest that religion is an important part of American society.

                2. Calling someone’s faith a “hobby” is rather insulting, is it not? Go to a mosque somewhere and shout that out, I dare you. I’ve said it before, and I’ll say it again, leftist are should be happy that Christianity, and for that matter Buddhism, tell their adherents to suffer for their faith.

                  So aside from your logical mistakes and fallacies on display, you add some insults. yep. Real winning arguments there, boy I tell ya.

                  1. mad_kalak, you can’t make me care about something that is important to you. So from my perspective it is a hobby, from your perspective it is something more important than a hobby. The only reason I am even discussing religion is because it is part of Con Law due to the 1A, other than that I don’t have an opinion about religion one way or the other.

                    Toranth, sports and especially football generates a lot of money in America. And many Americans were raised religious and just say they are some religion without really being religious. All of the data says religion is becoming less important in America and in Europe it is already unimportant. And the fact Europe has state religions and quasi state religions makes me not even care about the Establishment Clause because if a state were to establish a religion it would turn people off and end up being counterproductive. I care so little about religion I would tell an acquaintance whatever they want to hear because I think it is so unimportant.

                    1. I don’t think I can make you care about your personal spirituality, and neither am I trying. Why don’t you get that? Your solipsism is astounding.

                      I’m trying to get you to understand, LOTS of OTHER people care about religion, thus it matters for the rest of us because we live in a democracy. By extension, it matters for you whether you want it to or not, since presumably you live in America.

            2. No doubt this is how things seem to you. And no doubt this what the people you know think.

              If one stays within a narrow circle, one encounters no evidence to contradict the idea that the world is flat.

              Same Here.

        2. People thought “Life,” “Liberty,” and the “Pursuit of Happiness” were important in 1789 too…

          1. A.L. — it’s “life, liberty, and property” — Jefferson changed it to “pursuit of happiness” because he was writing in the era of property requirements for voting.

            And it was 1776, not 1789.

      2. I would not say that it’s like slavery. I would say that Marx was dead on accurate when he said that it’s the opiate of the masses. Opium, of course, is a powerfully addictive drug that takes over one’s life and makes people do things they would not do in their right minds.

        1. In modern day America religion is fairly innocuous which is why it isn’t that important at a societal level. Obviously in modern day Iraq and Iran religion is very important and those societies are dysfunctional.

          Also the 1A mentions the press which is not necessary in light of free speech but the fact it is mentioned makes the press feel important…so I don’t have a problem with religious people feeling special because the 1A mentions religion…but religion isn’t important in America today.

          1. It would be innocuous if not for our nutty election system that results in right wing religion having far more political power than their actual numbers. You can thank Mississippi being able to cancel out New York in the Senate.

    3. No, Sebastian, slavery wasn’t “protected in the Constitution” the way free exercise is. There’s no “Congress shall make no law” provision protecting slavery. Many of the new US States set about ending slavery, because the Constitution allowed them that power; as British colonies they hadn’t been able to do that, but under the Constitution they could. Under the Constitution, the feds could — and did — outlaw the trans-Atlantic slave trade; many thought that would end slavery within a generation, but it didn’t work out that way. The federal govt., it’s true, had only limited power to intefere with slavery in States that wanted to keep it. That was the price of national unity. It turned out to be a high price indeed. Free exercise of religion is nothing like that.

      1. I will give you an “A” for effort. State governments could abolish slavery in their state but they still had to obey the Fugitive Slave Clause. And the 1A is limited to Congress so state governments could regulate speech although I am sure most of their state constitutions protected free speech…that is why we have Incorporation Doctrine although if one reads Heller the 2A shouldn’t need to be incorporated because it applied to all Americans when it was ratified…such a head scratcher then that McDonald was needed. 😉

        1. WHAT Fugitive Slave Clause? These were Acts of 1793 and particularly 1850.

          1. Article 4, section 2, clause 3

          2. There’s a clause in the Constitution that authorized and perhaps even required the Fugitive Slave Acts. However, enforcement of those acts was often difficult (and when successful, it often turned those mildly against slavery into radical Abolitionists). Before the Progressive era, short of a military occupation the federal government lacked the means of effectively enforcing a federal law in a state that strongly opposed it. Just collecting a tax on whiskey once required calling out the US Army!

    4. It is because they are used to maintain power that they are forbidden from gaining ascendancy over other religions using mechanisms of the state. The First Amendment protects these others.

  3. I like this bit:

    The most convincing proof that one believes his statements is to show that they have been true in his experience. Likewise, that one knowingly falsified is best proved by showing that what he said happened never did happen.

    I have never liked criminalizing fraud itself. If fraud assists in a crime, then it is just more evidence that the crime was intentional; if fraud does not result in a crime, where is the harm — what is criminal about it?

    But I have also believed that anyone who speaks with authority must be consistent. Whether as an official spokesperson with the intent to lie, or a politician who says one thing one day and something diametrically opposed the next day, that inconsistency to me is worse than fraud and ought to remove that politician from office. A law which purports to reduce poverty or pollution and has the opposite effect in reality ought to be voided altogether. These match what I like about that quote: if you say something which most people believe a lie, but do actually believe it, that is not fraud, even if people give you money because of what you said. Fraud requires the intent to deceive.

    Thanks for posting this.

    1. The harm in it is that it’s a form of theft by deception. If I tell desperate cancer patients that if they take my snake oil, at a thousand bucks a bottle, it will make them well again, I’ve taken their money and given them false hope. And, if they abandon conventional medicine because they believe my humbug, I may even be killing them earlier than they would have died otherwise. What’s the argument that that shouldn’t be a crime?

      1. “Think of it as evolution in action.”

  4. As far as the actual case is concerned, I am much less impressed with the irrelevant Jackson than I am with the to-the-point Stone in his dissent.

    The issue in the case is proving that the defendants did not believe their religious statements. To paraphrase Stone, if someone says they met an angel in SF, and sells religious tracts based on what that angel reveals, then the legal issue in a fraud case depends on the prosecution proving that the defendant never went to SF. If he did not, he could not have met the angel, and a jury can then accept his revelations are false, and selling books about them is fraud. The trial judge and the majority opinion make it clear that belief itself was not on trial. Only sincerity. Other proofs of fraud could be letters exchanged between defendants where they admit the deceit, or records of phone calls of a similar nature. Alas, the record does not contain any such proof. But the majority opinion assumes they are there when it accepts the conviction.

    I am also impressed by Stone’s pointing out that our courts down to that day allowed belief to be unlimited [that’s Jackson’s sole argument] but that action on beliefs may be limited by law. For example, I am allowed to believe that the smoke from an incinerated human heart will carry my prayers to Heaven. I am not allowed to murder someone to steal their heart to place on the altar. Jackson discusses only belief. Stone and the majority discuss action.

    It was the actions of the defendants that was on trial, and their actions were the basis of indictment and conviction. But the record I saw does not say much about the proof offered at trial.

  5. “Religious symbolism is even used by some with the same mental reservations one has in teaching of Santa Claus or Uncle Sam or Easter bunnies or dispassionate judges.”

    That made me laugh. Dispassionate judges are as real as Santa Claus. Hah hah hah!

    1. Yes, I liked that touch.

  6. “In the first place, as a matter of either practice or philosophy I do not see how we can separate an issue as to what is believed from considerations as to what is believable.”

    A pretty sentence but I don’t believe it. A single documented exchange between two schemers (“they’ll never buy that, but if we throw in another prophet and change the first one’s name to Francis the Kind and proclaim that eternal flames will be theirs out to the third generation should they not give without restraint (which recall bumped the collection 50% for several years over at JoyfulGiving South),” etc.) would clinch the matter of belief without so much as a glance at believability. Is there a chance in Hell Jackson didn’t realize this?

    “The collections aggregate a tempting total, but individual payments are not ruinous. I doubt if the vigilance of the law is equal to making money stick by over-credulous people.”

    Translation (or please correct me): Scamming people isn’t a big deal so long as they’re not wiped out. Besides, that it worked at all only shows the victims up as suckers who were going to get scammed anyway. Do you find this persuasive? Do you think that even Jackson did (as a general principle I mean, not just as a lame rationalization for excusing scamming in certain privileged contexts)?

    1. If wiping people out were illegal, there would be no TV home shopping channels, as they are built on the business model of making retirees think they are their friends, then draining their life savings.

      1. While you may(?) find the quoted sentences persuasive as a general principle, it’s pretty clear that Jackson himself did not. He doesn’t apply it, for example, to misuse of church funds. Why might that be?
        I mean, it’s almost as if he trumped it up ad hoc for the purpose of defending what he was defending.

  7. The “I Am” movement never completely perished, it hung on until a Ballard progeny marketing major changed the name to “Me Too”. The movement has since taken off and is finally financially sound.

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