Everything You Wanted to Know about Anti-BDS Laws, Part I

Correcting various misperceptions about the scope and constitutionality of laws barring state contractors from boycotting Israel-related people and companies.


Click here for Part II.

I've perhaps never seen as much misinformation and bad legal analysis regarding a given issue than about state laws that require state contractors to certify that they do not boycott Israel or those who do business with Israel, otherwise known as "anti-BDS laws." This has been a product of two factors: first, a thoroughly dishonest campaign against the laws by the American Civil Liberties Union, exaggerated further by anti-Israel bloggers such as Glenn Greenwald, and second, the near-absence of those who support the laws from the debate.

I have not been involved in promoting anti-BDS laws, I am not sure they are a good idea as currently written, and I think the Supreme Court's key relevant decision, Rumsfeld v. FAIR, should have come out the other way, philosophically-speaking if not based on precedent. And from my personal political interest, I'm in a heads-I-win, tails-you-lose position: either boycotts of Israel get treated the same as other discriminatory acts, or the ACLU succeeds in undermining antidiscrimination laws that grate on my libertarian sensibilities by establishing that refusals to deal are subject to First Amendment scrutiny.

So I don't have a strong dog in the fight, but given that I've been appalled at the misinformation campaign launched by the ACLU, I thought I'd correct the record:

Anti-BDS laws do not require anyone to "pledge loyalty to the state of Israel." This is any easy one. They simply don't. This is a lie (not the first one) that originates with Glenn Greenwald, who claimed, in a headline no less, that a Texas anti-BDS laws required a contractor to sign a "pro-Israel oath." Contractors must simply certify that they are not participating in anti-Israel boycotts. They not only don't have to take a pro-Israel oath but are free to criticize Israel as much as they like, donate to anti-Israel campaigns or candidates, and so on.

Anti-BDS laws do not prohibit individuals in their private capacity from boycotting Israel, even if their company has business with a state that has an anti-BDS law. Anti-BDS laws only apply to companies, not to individuals. This gets a bit confusing when it comes to sole proprietorships, but I think it's clear that, say, a computer technician who signs a contract with the state can't refuse to use Israeli-made software for his contract work, but he can refuse to buy Sabra humus for his family dinner.

Anti-BDS laws do not just protect the State of Israel, as such. Many commentators have stated that they don't understand why a foreign government should be given statutory protection from boycotts. The representative Texas law defines a boycott of Israel as "refusing to deal with, terminating business activities with, or otherwise taking any action that is intended to penalize, inflict economic harm on, or limit commercial relations specifically with Israel, or with a person or entity doing business in Israel or in an Israeli-controlled territory, but does not include an action made for ordinary business purposes." First, and importantly, the leading Israeli universities are all public, so banning boycotts of Israel prevent state contractors from boycotting students and faculty of Hebrew University, Tel Aviv University, and so on. Secondly, the laws prohibit state contractors from boycotting organizations that merely do business in or with Israel. This is a much broader category, and would include, for example, the 60% or so of American Jews who have visited Israel.

Pending federal legislation only makes the federal government neutral on state anti-BDS laws. The Senate recently passed a bill that has been widely described by opponents as trampling on freedom of speech. In fact, the Senate bill is a response to the possibility that courts will hold state anti-BDS laws as implicitly preempted by federal policy. By explicitly stating that the federal government does not wish to preempt such state laws, the danger of implied preemption goes away. But the bill doesn't impose any restrictions on anybody, so it can't be threatening anyone's free speech rights. If there is a threat to free speech, it comes from state laws. However:

Boycotts are, according to the Supreme Court, economic action, not speech protected by the First Amendment.

(1) The Supreme Court has several times upheld federal labor law's ban on secondary boycotts, ie a boycott of an employer with which a union does not have a dispute that is intended to induce the employer to cease doing business with another employer with which the union does have a dispute. In those cases, the Court has stated that boycotting a business is not protected by the First Amendment.

(2) There is no analytical distinction between a "boycott" and "refusal to deal." Refusal to deal is obviously a form of discrimination. Imagine, for example, that a state government asked its contractors to sign a pledge that they will not refuse to contract with subcontractors owned by members of protected minority groups. This is obviously constitutionally permissible under current doctrine. If a contractor responded, "but I am exercising my freedom of association" to refuse to deal with, say, contractors owned by African Americans, or "I am boycotting contractors owned by homosexuals to protest same-sex marriage" they would be laughed out of court.

(3) NAACP v. Claiborne Hardware is being misinterpreted. Contrary to at least one district court decision on BDS, the Claiborne Hardware case does not state that engaging in a boycott is constitutionally protected speech; rather, it says that urging others to boycott is constitutionally protected speech. So, a state could not ban individuals or groups from urging people to boycott Israel, and probably could not make such a ban a condition of a state contract. However, it can ask a contractor to certify that it is not boycotting Israel.

The closest Supreme Court case on point, Rumsfeld v. FAIR is a unanimous decision rejecting an analogous free speech/compelled speech argument.

Various law schools refused to allow military recruiters to recruit their law students on the same terms as other employers. In other words, the law schools were discriminating against, refusing to deal with, or boycotting military recruiters. In response, Congress passed the Solomon Amendment. This amendment specified that if any part of an institution of higher education denies military recruiters access equal to that provided other recruiters, the entire institution would lose federal funds. Just like those challenging the anti-BDS laws argue that their free speech rights are violated by anti-BDS laws, the law schools in FAIR argued that their free speech rights are violated by the anti-boycott-the-military Solomon Amendment.

The Supreme Court's made short shrift of its argument, in language that is equally applicable to the anti-BDS laws. "Because the First Amendment would not prevent Congress from directly imposing the Solomon Amendment's access requirement, the statute does not place an unconstitutional condition on the receipt of federal funds. The Solomon Amendment neither limits what law schools may say nor requires them to say anything. Law schools remain free under the statute to express whatever views they may have on the military's congressionally mandated employment policy, all the while retaining eligibility for federal funds. … As a general matter, the Solomon Amendment regulates conduct, not speech. It affects what law schools must do—afford equal access to military recruiters—not what they may or may not say."

As for the claim that requiring the law schools to assist with military recruiting constituted compelled speech, "In this case, accommodating the military's message does not affect the law schools' speech, because the schools are not speaking when they host interviews and recruiting receptions. Unlike a parade organizer's choice of parade contingents, a law school's decision to allow recruiters on campus is not inherently expressive. Law schools facilitate recruiting to assist their students in obtaining jobs. A law school's recruiting services lack the expressive quality of a parade, a newsletter, or the editorial page of a newspaper; its accommodation of a military recruiter's message is not compelled speech because the accommodation does not sufficiently interfere with any message of the school."

As Eugene has reminded us, while the FAIR case dealt with the disposition of federal funds, the Court's opinion suggested that boycotts/refusals to deal are not protected by the First Amendment, period.

NEXT: Screening of Saint Judy at Emory Law School, Fri 2/22 at 7 p.m.

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  1. Thank you for sharing some good points.

    However, the real issue is why does Israel get this special protection?

    1. Because the legislature says so. Why do members of motorcycle gangs in Minnesota get protection? Because the legislature says so. That’s as a constitutional matter. As a policy matter, I think the arguments pro and con are obvious, but one argument, that BDS is in effect anti-Semitic, will be discussed for its constitutional relevance in Part II.

      1. Does the Texas constitution explicitly authorize the legislature to enact legislation protecting the state of Israel?

        Why shouldn’t libertarians mercilessly attack any state which seeks to condition any concern doing business with the state contingent upon certifying, in writing, that such concern will not boycott any nation state?

        Liberty must always come first – even if to do so conflicts with one’s empathy for, or ties to, another nation state.

        1. The liberty issue isn’t so clearcut in this case. Let’s say the government contract with a company for cybersecurity. The company boycotts Israeli software. By far the best software for the job is Checkpoint, which will cost $50 million. The company, however, goes with inferior McAfee software, which costs $75 million. The state winds up with with worse software and a bill for an extra $25 million. Why would any state agree to contract with someone who might do this?

          1. Of course the liberty issue is clearcut: Does the Texas constitution specifically authorize its legislature to enact statutes which require contractors doing business with the state to sign certifications that the contractor does not, and will not, participate in any boycott of a foreign nation?

            Why indulge the state? In a free society, how can we tolerate any extra-constitutional legislation, no matter how noble the same is characterized by its proponents and defenders?

            1. Every state puts all sorts of restrictions on its contractors, few if any of which are specifically authorized by the state constitution.

              1. Thus, why attack BDS supporters and / or Greenwald?

                Instead, why not attack the state for placing such extra-constitutional restrictions on the contractors?

                1. Literally no one is publicly making that argument. And in fact the ACLU, BDS supporters, Greenwald, etc., almost universally like all the other restrictions, such as antidiscrmination clauses, states put on their contractors. They only think that contractors should be free to discriminate against those who do business with Israel or Israelis.

                  1. That neither Glenn Greenwald nor the ACLU or the BDS supporters are making the argument misses the point: A libertarian should always examine the source of the state’s power to enact the statute / policy in question.

                    True, the ACLU, BDS et al are not ideologically consistent and would never support true freedom of association across the board.

                2. “extra-constitutional ”

                  Restrictions are either constitutional or not constitutional.

              2. “Every state puts all sorts of restrictions on its contractors…”

                We know, that’s why he’s asking about the liberty issue. If you were concerned with the liberty issue, wouldn’t you want the narrowest restriction? (I.e., one that says the state will only pay $50M?)

            2. Does the Texas constitution specifically authorize its legislature to enact statutes which require contractors doing business with the state to sign certifications that the contractor does not, and will not, participate in any boycott of a foreign nation?

              You’re confused about our constitutional system. While the federal government is one of enumerated powers, state governments have a general police power. (Whether you like that philosophically or not, it’s firmly established.)

          2. But what if the actual best solution is Omar’s Awesome Cybersecurity Suite which only costs $25 million but, since Omar, Inc boycotts Israel, this option isn’t available?

            In your example, the contractor who bids the McAfee solution will lose the bid anyway.

            These stupid political statements should be eliminated from public spending — governments should be paying for the most cost effective solution since it’s not their money. Of course, politicians and taxpayers remain free to allocate their personal assets based on their personal beliefs.

        2. “Does the Texas constitution explicitly authorize the legislature to enact legislation protecting the state of Israel?”

          Go ahead and read it. The PDF is only 252 pages long.

          1. There is no such provision.

            1. Sure there is, Article II, Section 1:

              “The Legislative power of this State shall be vested in a Senate and House of Representatives”

              States, unlike the federal government, have plenary powers so other than the limits placed by the Texas Bill of Rights, they can place whatever conditions on their contracts they like.

              1. No, that is your statist interpretation.

                The proposition that states of the United States have plenary powers is not a proposition enshrined in either federal constitution or the state constitutions.

                The Legislative power is not absolute; it is not all powerful; and it is manifestly does not reach to the point where it usurps the natural rights of individuals. There is nothing in the Texas constitution which unambiguously asseverates that the legislative power of the state enables it to enact anti-BDS laws.

                1. Moreover, a republican form of government is one in which legislative power is not plenary; to the contrary, the power of a legislative assembly is limited and narrowly construed.

                2. “natural rights of individuals”

                  Thee is no natural rights of individuals to enter into contracts with a state government.

              2. I’m not that familiar with the Texas Constitution, but the US Constitution is one of limited powers. Those expressly granted to the government by the People.

                Hence the 10th Amendment. Now, as a Libertarian. I am deeply offended by the abuse the 10th has suffered at the hands of the Supreme Court since at the latest, the New Deal, but I’m pretty sure the whole point of the Federalist Society is to get back to a limited Federal Government.

                Allowing Congress to forbid me from boycotting a foreign country, ally or not, seems to not be anywhere in the Constitution or the Amendments.

                1. The congress and president set foreign policy. They can stop you from dealing with enemies.

                2. “Allowing Congress to forbid me from boycotting a foreign country,”

                  The law (as bad as it is) doesn’t do that. It says that it won’t do state business with your company if it engages in the boycott. You’re free — as an individual — to boycott, or to criticize Israel and fund supercilious, boycotting assholes, to your heart’s content.

                  But it’s a terrible, chilling law that will hurt Israel and Jews in general. It’s new fodder for the “Jewish lobby” canard.

      2. It’s unfortunate that Reason has to put up with a tendentious hack like D.Bernstein.
        Anti-BDS DOES make requirements equivalent to an oath, anti-BDS DOES uniquely favor Israel.
        It’s scribblers like D.Berstein who give substance to the antisemites: For him, race trumps the facts, and blood is thicker than reason.

        1. It’s more unfortunate that this blog has to put up with commenters who cannot make their points without adding gratuitous personal insults.

    2. “Why does Israel get this special protection?”

      Because it’s been near uniquely targeted and persecuted? And because the Jewish people have been targeted? Repeatedly. And because Israel serves as a wonderful target for those who dislike the Jewish people?

      And because the legislatures and governments of our states and nation feel that this level of persecution isn’t right? So when they see the persecution, they decide to do something about it?

      I mean, you could see a BDS movement against Morocco or China, but for some reason, you never do….

      1. I dislike the Israeli government immensely, but I also dislike every government immensely. It is telling how many BDSiots praise Arab governments, where “government” is a very loose translation of “strong man dictatorship”, and then pretend they aren’t bigoted beyond belief.

      2. “I mean, you could see a BDS movement against Morocco or China,…”

        Or Russia, or Venezuela, or Iran, or Iraq, or …. let me pause for breath, the nations deserving such action are legion, and free from the BDS cabal’s ire.

      3. “Because it’s been near uniquely targeted and persecuted? And because the Jewish people have been targeted?”

        Ah, hello affirmative action! The best way to end discrimination against other countries is to stop discriminating against other countries.

    3. Asking this question is anti-Semitic because it implies that the Jews have hypnotized us all. You don’t want to be an anti-Semite, do you?

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  2. I don’t agree with the criticism of the ACLU, which is just doing what any good advocate does.

    But this is a very good, substantive post. Underlying all of this (and referenced in Prof. Bernstein’s reference to his libertarian priors) is that it is very hard to draw lines that permit the government to bar discrimination in private business dealings while at the same time protecting an absolute right to boycott a business. That’s what makes this issue so fraught, and if you agree with the ACLU, that’s the issue they have to persuade the Court on. Because you know that a good judge will pepper them with questions about the implications of their position.

    1. Not really. The line you draw is between discrimination based on (immutable) status, such as gender, race, sexual orientation and, being generous, religion, and discrimination based on opinions or behaviour.

      1. “Immutable status” is a nice sounding rhetorical argument, but it has nothing to do with the Constitution. Religion and political views and alienage are not immutable, and yet are protected classes for purpose of heightened scrutiny. Looks and disability are immutable, and are not protected classes.

        So that doesn’t work as a way to distinguish the cases.

        1. Correct. And if the issue is, “are boycotts speech,” the answer so far from the Court has been no, so the target is irrelevant.

      2. (1) So your position is that boycotts are a form of freedom of speech, unless they are directed at classifications involving immutable status?

        (2) Which means that a baker who boycotts a same-sex wedding, but otherwise serves gay people, is protected? That’s certainly not the ACLU’s position.

        (3) If the argument is that same-sex weddings are closely associated with the gay community, so it counts as anti-gay discrimination (as several state courts have held), then Israel is closely associated with Jews.

        (4) So you are back to where you started.

        1. Yeah.

          It’s a really difficult issue. I don’t really have your libertarian priors, so I am fine with a line that would be drawn somewhere other than “everyone has the right to do business with whoever they want”. But once that governmental power to preclude discriminatory business transactions is recognized as permissible under the First Amendment, well, you need to do some serious salami-slicing to say that there’s no governmental power to preclude contractors from discriminating against Israel or Israelis.

          It will be interesting, when push comes to shove, to hear how the ACLU lawyers attempt slice the salami at oral argument.

          1. In my opinion, Prof. Bernstein’s “libertarian priors” are AWOL on this matter.

            1. Libertarians are allowed to write about current precedent.

              Indeed, I wish more would. I get frustrated reading long pieces about how “the Constitution” prohibits this or that without dealing with 80 years of contrary caselaw.

              This is a good piece. He makes clear that he would prefer a legal rule that would protect the rights of members of the public to make private business decisions (including those that punish Israel). Those are his priors. But he is dealing with the applicable caselaw as it has come down.

              1. Libertarians are also allowed to write about the ideal gas law.

                Of course, it is important to set forth current precedent about an issue. That, however, does not thereby mean that a libertarian should refrain from asking abecedarian questions such as upon what constitutional authority does the state rely in enacting the statute at issue.

                1. Again, he actually makes clear that his ideal position would protect the right of people to make private business decisions, including boycotting Israel. That’s why he calls this case heads I win tails you lose.

                  1. Okay, that is a good point.

                    I always want more Lochner and more loathing of Leviathan.

                2. “That, however, does not thereby mean that a libertarian should refrain from asking abecedarian questions such as upon what constitutional authority does the state rely in enacting the statute at issue.”

                  As the opponents of the anti-BDS state laws have been bringing the challenges in federal courts, it’s an irrelevant question when it comes to predicting how the federal cases will be resolved. Federal courts have no authority to decide state constitutional issues.

          2. Even with libertarian priors, the issue here isn’t obvious. A law that forbids boycotting Israel would obviously violate libertarian principles. But a law that merely places conditions on government contractors? does not inherently violate one’s rights; one can boycott if one wants and just not do business with the government. (That having been said, the line can get blurred because if the state can do that, can it also condition general government benefits on non-boycotts?)

            ?Kind of an ironic complainant for a libertarian, anyway.

        2. “So your position is that boycotts are a form of freedom of speech, unless they are directed at classifications involving immutable status?”

          That sounds consistent with a European view of freedom of speech, where even speech directed at classifications involving immutable status is not protected speech.

  3. Prof. Bernstein, what do you view the impact of Citizens United to be on your analysis?

    1. None. Citizens United (along with prior precedent) says corporations have free speech rights. The Supreme Court has said that economic boycotts are not speech. So Citizens United isn’t relevant. Now if the point is, “if money can be speech, why can’t boycotts,” that’s a fair question, but fact is the same Justices in the majority in CU joined the unanimous opinion in FAIR, so political contributions are protected by the First Amendment, and boycotts are not. Like I said, I think FAIR was wrong…

      1. Money is speech insofar as, when donated to politicians, the vast majority of it is used to buy ads AKA the mass production and distribution of speech.

        The boycotted money would buy very little speech in general if it weren’t boycotted, and is not the money’ss main purpose, and denying buying speech is not the main purpose, but rather the arm twisting of general economic harm.

  4. Greenwald has this amazing ability to oscillate between respectable, insightful analysis and unfettered batshit crazy.

    … which is why I tend to discount even his good side, such as it is.

    1. Which decade is he going to pivot back to the insightful kind?

  5. “he can refuse to buy Sabra humus for his family dinner”

    A mark in his favor. Humus of any brand is like eating liquid dirt.

    1. Humus is a terrorist group. You’re thinking of tahini.

      1. You’re thinking of A Good Place.

    2. Liquid Dirt is the name of my band.

    3. Are you saying there’s something wrong with dirt? They grow crops from that stuff!

  6. I think this argument is somewhat disingenuous: “This gets a bit confusing when it comes to sole proprietorships.”

    My understanding is that the most common scenario objected to is when a state or local government employs an individual as a “sole proprietor contractor.” They do this to save money (i.e. school district does not pay benefits, they can fire the employees at will, etc). In that situation the “contractor” does not in fact have the ability to act in an individual capacity, and has lost their ability to decide on a personal level whether or not they want to boycott Israel.

    This seems screwy: if that same person worked for the school district, or worked for a larger company, they would be able to exercise their first amendment right to boycott / etc. But because the “contractor” is a single person (for the convenience / benefit of the state) they lose that right.

    Or am I missing something? Everything else you wrote seems fine and logical. But I believe I’ve read about the scenario above quite a bit and it does not feel like an acceptable result.

    1. What you’re describing sounds like the ‘sham contractor’ problem that got Microsoft in so much trouble. Not that it doesn’t happen but it should no longer be “the most common scenario” even in the public sector.

      More likely is the outsourcing of a specialized service that the school or agency can’t or won’t do itself. For example, a geographically isolated school might outsource computer maintenance or lawn care to a small local company. And, yes, that small, local company might sometimes be a sole proprietorship.

      Remember that a sole proprietorship means the small company has just one owner, not necessarily just one employee. A sole proprietorship is still a separate entity from the proprietor. They are the same for tax purposes and, if not quite identical, very close for liability purposes but they are different for insurance and, I think, employment law. They are also very clearly different under the public accommodations doctrine. That your sole-proprietorship bakery must accept all comers does not mean you must let random people walk into your home. Bernstein argues (and I agree) that the anti-BDS rules are more like the public accommodation rules than like taxation. It restricts your business activities without restricting your private activities.

      How you document that to prove that the “private” nature is not a shame- that’s where it gets tricky. But courts are used to sorting out those kinds of sham allegations.

  7. If I understand correctly, a contractor could promote BDS, donate to BDS promoters, advertise on its website which of its products do or don’t violate BDS, and be in compliance with the law as long as the business itself does not participate in the boycott.

    In other words, bake the d??ned cake.

    1. “In other words, bake the d??ned cake.”

      An interesting comparison. There is a similarity in that the cake baker and the BDSer both want to opt out of doing business with a potential customer. The baker’s action is in the purely symbolic realm–the creation of statements or artifacts that express an opinion the baker finds morally objectionable. The BDSer goes beyond that by trying in concert with others to harm the customer economically. That may be the step too far that leads the law in question to be held constitutional.

  8. Texas law defines “boycott Israel” to include “taking any action that is intended to penalize, inflict economic harm on, or limit commercial relations specifically with Israel, or with a person or entity doing business in Israel or in an Israeli-controlled territory, . . . .” Are you reading “any action” to exclude any speech urging a boycott or joining an organization advocating a boycott or donating money to any such group? It seems to me that this is a reasonable interpretation, especially if you employ the rule of statutory construction of avoiding constitutional problems. But, including these actions within the statute seems entirely plausible as well. I don’t believe there’s any Texas case construing the statute. Point being, unless and until that get’s decided by the courts, I don’t think it’s unreasonable for critics to fear such an interpretation of the law.

    1. Yes, any action excludes speech. Everyone involved in promoting the legislation has said it was not intended to encompass speech. It would be better if the laws (a) made that clearer; and (b) excluded sole proprietors, who often are not repeat players and are legally unsophisticated, who might be intimidated by a provision that isn’t 100% clear, which legal provisions tend not to be.

  9. My questions have to do with enforcement.
    1) If I certify that I am not boycotting Israel, and then later decide that I want to boycott Israel… I’ve met my burden of certifying that I’m not boycotting Israel. Now, even more deviously, I AM boycotting Israel, but I’m presented with a requirement that I certify that I am not. So, for a brief moment, I cease my boycott, sign the pledge, and then immediately resume my boycott.

    Is there a penalty (other than cancellation of the contract) permitted for simply not signing the pledge?

    2) what if I want to boycott a company, not because it’s Israeli, but because (insert perfectly valid reason). Is there anything in the various statutes that lets me refuse to deal with a company because they don’t fulfill their contractual obligations… they deliver late, not what was promised, or just disappear with the money?

    1. The Texas law, excerpted above, states, “but does not include an action made for ordinary business purposes.”

      1. And the purpose is to virtue signal to Israel you are hurting them. If they don’t know it’s happening…

  10. Regardless of the power of state governments to pass and enforce anti-BDS laws, the purpose of these laws is to benefit Israel. Why is that important to US states? How does it benefit the citizens of those states to have these laws?

    These laws are only a result of the power of the pro-Israel lobby, have everything to do with suppression of a movement that the Israeli government does not like, and are in no way designed to benefit the citizens of the states.

    The suggestion that opposition to anti-BDS laws is anti-Semitic is absurd. The BDS movement is meant to be a counter to the policies of Israel, not a way to oppress Jews.

    1. Yep. This terrible law is an opening for people to throw about the “Jewish lobby” canard (and yes, I used “Jewish” instead of “pro-Israel” on purpose).

    2. The BDS movement is meant to be a counter to the policies of Israel,

      It’s meant to be a counter to Israel’s policy of existing.

      1. I have more confidence that Israel will survive the BDS movement, even without Texas’s help.

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  12. It’s unfortunate that Reason has to put up with a tendentious hack like D.Bernstein.
    Anti-BDS DOES make requirements equivalent to an oath, anti-BDS DOES uniquely favor Israel.
    It’s scribblers like D.Berstein who give substance to the antisemites: For him, race trumps the facts, and blood is thicker than reason.

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  14. This is a helpful article, but Glenn’s statement is accurate and it’s quite a stretch to say otherwise. Certifying that you won’t participate in an ostensibly anti-Israel action is making a pro-Israel promise, and the speech therapist was legally compelled to make that promise to keep her job. I’m not sure why you think otherwise.

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