Saturday, June 18, 2011

Georgia Supremes reverse murder conviction due to "Irrelevant" Goth evidence

BORING,
v.
STATE.

S11A0536.
Supreme Court of Georgia.

Decided: May 31, 2011.
HUNSTEIN, Chief Justice.

Appellant Courtney Boring was convicted of murdering her mother, Debra Boring, and sentenced to life imprisonment plus a consecutive five-year term for firearm possession.[1] Because the trial court allowed the State to introduce improper and prejudicial character evidence at trial, appellant's conviction must be reversed.

Construed in the light most favorable to the verdict, the evidence adduced at trial established as follows. On the evening of December 23, 2005, Rodney Boring, the victim's husband, placed a 911 call to report the shooting of his wife. Rodney told police that he had been at a catfish pond approximately one-quarter of a mile away from their home, where he typically went after work to drink liquor, when he heard what he recognized as a gunshot from a large caliber gun. He reported that, a few minutes later, he received a phone call from appellant, his 15-year-old daughter, who was in hysterics and mostly unintelligible but managed to communicate that "momma shot herself." Rodney immediately went to their home, where he found appellant sobbing and his wife lying dead in the doorway of the front door on top of her purse and some WalM-art shopping bags, with a gaping gunshot wound to the back of the head and his .270 bolt-action rifle on the floor nearby.

Appellant told police that late that afternoon she had been at home taking a shower while her mother went to Wal-Mart; that she was getting dressed after her shower when she heard her mother call out her name, which she ignored; and that, a short time later, she heard a loud noise and walked into the living room to find her mother lying in the doorway with the rifle beside her. Appellant stated that she did not attempt to render aid to her mother or call 911 but rather immediately grabbed the phone, ran outside, and called her father. She reported neither seeing nor hearing any other person in or around her house before, during, or after the shooting; a police search of the home found no one else present. The investigator who interviewed appellant at the scene described her demeanor as "very unusual" for one experiencing such a traumatic event, in that appellant was calm, seemed "agitated with me like it was a bother," and did not exhibit sadness.

The State's firearms expert determined through testing that Rodney's rifle was in fact the murder weapon. Rodney told investigators that he had cleaned the rifle that morning in preparation for a hunting trip and had left it in the house on a love seat with live rounds of ammunition on an adjacent table. Though fingerprints were lifted from the rifle, they were of insufficient quality to use for identification. Gunshot residue was found on the victim's hands, which, according to one of the State's forensics experts, was consistent with the theory either that she had fired the weapon or that she was less than eight to ten feet from the weapon when it was fired. However, the State's forensic pathologist, who performed the autopsy, opined that the manner of death was homicide, not suicide. Two other expert witnesses agreed with the conclusion that the fatal wound was not self-inflicted: the State's crime scene specialist testified to his conclusion that the gun had been fired from a particular area inside the house near the front door; the State's firearms expert likewise opined that the shot had been fired from inside the house, by someone other than the victim, from a distance of four to nine feet away.

The condition of the Borings' home, as observed by responding investigators and documented in photographs admitted at trial, was filthy and, according to the testimony of one investigator, not fit for a child to inhabit. A neighbor of the Borings testified that he had on previous occasions heard arguments coming from their home and had seen patrol cars at the house. There was also evidence that Rodney was an alcoholic who was verbally abusive to both his wife and daughter.

The lead investigator in the case, GBI special agent Natalie Brunner, testified that appellant became the target of the investigation based on "mostly a matter of elimination, simply the fact that we could not put a third party there and both the rifle and ammunition came from inside the Boring residence, and to the best that we could establish, there were no other parties present." There was no evidence of forced entry into the house, and both the Borings' neighbor and Rodney's brother, Ricky, who had driven past the Boring home between 6:15 and 6:30 p.m. that day, told police they did not recall seeing any activity or vehicles at the Boring home around the time of the shooting. Though appellant told police she had the light on in her bedroom at the time of the shooting, Ricky reported having noticed that no lights were on in the residence when he drove by. There was evidence that appellant knew how to operate small caliber rifles but that she had had no instruction with respect to large caliber weapons such as the gun used in the shooting.

The State adduced evidence that, seven to ten days before the shooting, appellant had had a dispute with her parents after having been caught sneaking out of the house to meet up with her boyfriend, 19-year-old Joel Linville. After this incident, appellant, with the victim's approval, arranged to live with her aunt, Anita Ingle, though within a few days of the move Ingle and the victim agreed that appellant would return home because Ingle had discovered the teenager had again left the house with Linville without permission.

Appellant has at all times denied shooting her mother. In several interviews with police during an approximately two-month period after the murder, she consistently denied any involvement, albeit with minor variances in certain details, and likened her conflicts with her parents to those of the typical teenager. Though police interviewed 20 to 30 people, including appellant's friends as well as teachers and school officials, these efforts yielded no evidence implicating appellant in the shooting or any other act of violence. Police also enlisted Linville's assistance in questioning appellant about the shooting, but Linville conveyed nothing that incriminated her. Appellant did not testify at trial, but the jury viewed videotapes of two of her lengthy interviews with police, in which she resisted investigators' repeated efforts to elicit a confession.

Linville was considered as a suspect by investigators and ruled out, as there was evidence corroborating his testimony that he had been at work at a nearby fast food restaurant at the time of the shooting. Cell phone records confirmed Rodney's testimony that a phone call was placed to his cell phone from the Borings' home phone around the time that the shooting occurred, followed a few minutes later by a call from Rodney's cell phone to 911.

1. We find that the evidence, while far from overwhelming, was sufficient to enable a rational trier of fact to conclude beyond a reasonable doubt that appellant was guilty of the crimes of which she was convicted. Jackson v. Virginia, 443 U.S. 307 (99 SC 2781, 61 LE2d 560) (1979). See also OCGA § 24-4-6 (evidence must be sufficient to exclude all reasonable hypotheses save that of defendant's guilt to warrant conviction on circumstantial evidence).

2. Appellant contends that the trial court committed reversible error by allowing the State to present irrelevant and highly prejudicial character evidence. We agree. At the conclusion of Agent Brunner's direct examination, the State introduced, over defense objections, various items of evidence seized from the 15-year-old's bedroom during the police investigation, including photographs of appellant with dyed black hair and dark make-up; a document bearing the words of a "curse" to be recited "while burning the letter over a black candle"; and seven different inscriptions, one typewritten and the rest handwritten on the bedroom walls, of song lyrics and quotations attributed to various singers and other artists, bearing themes of anguish, enslavement, atheism, and violence.[2] Though the State elicited no elaboration from any of its witnesses regarding the import of these items, the State explicitly sought in both opening and closing to link these items with the so-called "gothic lifestyle" and to characterize them as evidence of "satanic influences."

Specifically, in opening, the prosecutor stated:

We want to show you, and it will be extremely important, this Defendant's what we call state of mind in law. We all have some state of mind. We have a bent of mind, things that we think about that make us what we are, our thoughts. We believe there even is a depravity of mind here.
You will see certain things about [appellant's] lifestyle. I, in voir dire, mentioned some things about gothic lifestyle. . . . We're attempting to show you by these things what's going on in this Defendant's mind at the time of this killing.
We will show you also that she had there inscriptions on the wall. I won't go through all of them. You will see them. Pay close attention to writings that this 15-year-old has on her wall. We . . . believe you will see some inkling of satanic influences here.[3]
In his closing argument, the prosecutor's recitation of the evidence both began and ended with references to these items. After displaying the photographs and reading aloud the inscriptions, the prosecutor acknowledged that these items do not "prove" that appellant killed her mother but went on to state: "It's not the point. The point is . . . that these are pieces of a puzzle, and you have to consider all of the evidence together." The prosecutor further contended in closing that some of the inscriptions were quotations from the "founder of the Satanic Church" — despite the absence of any evidence of record to support this claim — and again emphasized that these items "must be taken as pieces of a puzzle." The prosecutor ended his closing by reading the words of the aforementioned "curse." In sum, this evidence was clearly integral to the State's strategy of portraying appellant as a deviant capable of murdering her mother, in the absence of any other evidence suggesting she had a violent or angry nature.

"Whether to admit evidence is a matter resting in the trial court's sound discretion, and evidence that is relevant and material to an issue in the case is not rendered inadmissible because it incidentally places the defendant's character in issue. [Cit.]" (Emphasis added.) Wolfe v. State, 273 Ga. 670, 674 (4) (a) (544 SE2d 148) (2001). Though we have on numerous occasions affirmed the admission of evidence regarding a defendant's affiliation with controversial organizations or belief in unpopular ideologies, in all such instances this evidence was directly relevant to a contested issue in the case such as motive, identity, or intent. See, e.g., id. at 674 (4) (trial court properly admitted evidence of gang involvement where State adduced evidence that defendant committed crimes at request of fellow gang members and was required to participate therein under gang's code of conduct); Clark v. State, 271 Ga. 6, 9 (4) (515 SE2d 155) (1999) (evidence of defendants' "membership in an unsavory group," though incidentally bearing on their character, admissible when alleged motive for crime "directly involve[d]" such membership); Mize v. State, 269 Ga. 646 (3) (501 SE2d 219) (1998) (trial court properly allowed evidence of defendant's racist beliefs and leadership role in Ku Klux Klan-like organization because was relevant to State's theory as to motive). In this case, by contrast, the State theorized that appellant had committed the murder to avenge her mother's interference in the teenager's relationship with Linville; appellant's alleged "gothic"/satanic beliefs bore no specific nexus with the crime. Compare McIntyre v. State, 266 Ga. 7 (1), (6) (463 SE2d 476) (1995) (evidence regarding defendant's membership in satanic cult properly admitted where testimony showed murder was in retaliation for victim's refusal of defendant's sexual advances and where defendant performed satanic ritual over victim's dead body); Whitener v. State, 261 Ga. 567 (2) (407 SE2d 735) (1991) (admission of defendant's notebook containing references to occult proper where defendant told witness he hoped to become a vampire and had wanted to drink the victim's blood and keep his head). Agent Brunner in fact affirmatively conceded that she had discovered no such nexus, testifying on cross-examination that she had contacted an expert on satanic rituals as part of her investigation but was unable to link any of the evidence surrounding the murder with any such ritual. Compare Corza v. State, 273 Ga. 164, 166 (2) (539 SE2d 149) (2000) (evidence of appellant's gang membership admissible where witnesses described "ritualistic gestures" believed to be gang signs appellant made immediately after shooting); McIntyre, supra at 8 (1) (evidence of satanic ritual performed over victim's body).

In addition, in the numerous cases such as those cited above in which we have upheld the admission of evidence of a defendant's association with an "unsavory" organization or ideology, there was actual evidence adduced at trial affirmatively linking the defendant to the organization or ideology in question. Here, by contrast, nothing in the evidence adduced explicitly referenced satanism or "gothic" beliefs or subculture, and there was no testimony actually linking the inscriptions and other evidence in question to any such ideology; rather, that link was forged only via the State's opening statement and closing argument, which itself was improper. See Sumlin v. State, 283 Ga. 264, 266 (2) (658 SE2d 596) (2008) (prosecutor "improperly injected new evidence" during closing argument); Alexander v. State, 270 Ga. 346 (2) (509 SE2d 56) (1998) (prosecutor's description of defendant's alleged gang ties in opening statement held reversible error where no evidence of such presented at trial).

In sum, "one is left with the feeling that the [evidence in question] was employed simply because the jury would find these beliefs morally reprehensible." Dawson v. Delaware, 503 U.S. 159, 167 (112 SC 1093, 117 LE2d 309) (1992) (finding improper the admission of evidence of defendant's membership in organization called "the Aryan Brotherhood"). In admitting this evidence, which bore no specific connection with the crime and operated merely to impugn appellant's character by suggesting she held satanic beliefs, the trial court abused its discretion. Both because the nature of this evidence was highly inflammatory, and because the evidence of appellant's guilt was entirely circumstantial and not overwhelming, "`we cannot say that it is highly probable that the error did not contribute to the jury's verdict.' [Cit.]" Lindsey v. State, 282 Ga. 447, 450 (2) (651 SE2d 66) (2007) (applying harmless error standard for nonconstitutional error).[4]

3. We find appellant's remaining enumerations unlikely to recur on retrial and thus decline to address them. See Ward v. State, 288 Ga. 641 (5) (706 SE2d 430) (2011).

Judgment reversed. All the Justices concur.

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And yet:

Advanced, sophisticated profiling could prevent the next Columbine or Virginia Tech
by James Ottavio Castagnera
While the “War on Terror” typically is taken to designate the actions, foreign and domestic, directed at Al Qaeda and its allies (e.g., the Taliban), and although the attacks of September 11, 2001, were and remain unprecedented, America’s homegrown terrorists pose a far more serious threat to public safety and the commonwealth. These native sons and daughters fall into three principal categories:
--Disgruntled individuals with an ax to grind. They are exemplified by the government scientist who the FBI now believes perpetrated the Anthrax attacks, which followed close on the heals of 9/11, in 2001;
--The obsessed, represented by the radical animal-rights activists.
--The mentally disturbed, characterized by those who have committed individual acts of murder and mayhem on college campuses, most notably the Virginia Tech massacre of 2007.
The threat posed by these homegrown terrorists to plague our democracy, challenging our ability to remain a free and open society, will remain long after radical Islam has been eradicated or otherwise pacified. To better understand these three varieties of domestic terrorists, they may be viewed as comprising three breeds within a single species. If that is a fair assumption, then preventative measures, found to be effective in one arena, may be applicable in all. These may include advanced profiling procedures.
The Anthrax Attacks
In the weeks, months, and, inevitably, years following the 9/11 attacks, Rider University was impacted by the resulting War on Terror in a wide variety of ways, as was all of American higher education. The first such impact was felt as early as September 18, 2001, when letters postmarked from Trenton-area post offices and containing anthrax spores arrived in the offices U.S. Senators Patrick Leahy and Tom Daschle, and several news media organizations, ultimately killing five people and making another 17 or so ill.
The FBI visited the biology labs on every college campus along the Route One corridor between New York and Philadelphia, including Rider’s single science building. Nothing suspicious was found there. Nor was anything suspicious found in any other university lab in the region. However, the nearby Hamilton post office, which had handled some of the letters, was closed, not to reopen until three-and-a-half years later.
The FBI also intensely investigated Uncle Sam’s own bio-weapons facilities, including Fort Detrick in Frederick, Maryland. The investigation proved to be one involving needles and haystacks, but eventually FBI suspicions focused on a bio-weapons researcher named Steven Hatfill. Indeed, after years of investigating, the agency’s only “person of interest” was this Fort Detrick alumnus. Although never indicted, Hatfill’s scrutiny was enough to make him a leper to his profession, essentially unemployable.
After pursuing the wrong suspect for some six years, the government finally admitted it was trailing the wrong guy. In June 2008, Hatfill received a $5.85 million settlement.
With Hatfill off the (exceedingly short) FBI hit list, old leads were reviewed, witnesses revisited, and a new suspect emerged. On July 29, 2008, amidst rumors that this time indictments would be forthcoming, another Fort Detrick denizen, 62-year-old Bruce E. Ivins, killed himself. Attorneys representing Ivins in the government investigation, put their client’s death down to a fragile personality that succumbed to pressure.
“The relentless pressure of accusation and innuendo takes its toll in different ways on different people,” Bethesda criminal-defense attorney Paul Kemp commented of the client he had represented for more than a year. “In Dr. Ivins’s case, it led to his untimely death.”
The publicly available evidence against Ivins was circumstantial but somewhat compelling. Of some 33 years as an Army scientist, Ivins’s last 18 were spent at Fort Detrick and apparently were devoted in large part to anthrax. Between December 2001 and April 2002, Ivins secretly swabbed and bleached some 20 work areas that he claimed had been contaminated with anthrax by a sloppy lab technician and then kept his cleanup under wraps. When those illegal activities came to light, he claimed he couldn’t recall whether or not he had gone back to re-swab the contaminated spots to insure that no spores remained. A former, unnamed co-worked commented in the media, “That’s bull. If there’s contamination, you always re-swab. And you would remember doing it.”
If Ivins was guilty, one irony in the case is that he had earlier helped the FBI analyze the anthrax sent to the senators’ offices. The newspaper reports indicated that the second round of FBI investigations benefited from better genetic technology that made a match between the spores sent through the Postal Service and those with which Ivins had worked, but unless the Department of Justice has some direct evidence yet to be made public, it can’t be certain that Ivins’s death closes the case. What, for instance, may have been his motive? Reports read by this author to date don’t seem to say.
On the contrary, the Washington Post reported on August 1, 2009 that in 2003, “Ivins and two of his colleagues at the…U.S. Army Medical Research Institute of Infectious Diseases at Fort Detrick…received the highest honor given to Defense Department civilian employees for helping solve technical problems in the manufacture of anthrax vaccine.” That doesn’t sound like the same man whom five years later the DOJ was ready to indict. And yet, added the Post, prosecutors were considering including a request for the death penalty.
Closure of this case, which is older even than the war in Iraq, would add a note of finality to at least one ugly incident in the eight-year-old War on Terror. We probably aren’t there yet, but if Ivins is guilty as charged, two motives may explain his mad acts, at least as to the extent that they were directed at Senators Leahy and Daschle:
--He believed they were bad Catholics because of their pro-abortion stance, and
--He blamed them for blocking funding for work on an anthrax vaccine.
The Animal Rights Radicals
Expert David DeGrazia identifies three gradations of standards subscribed by activists:
Sliding-scale model: “Animals may be used in research only where their use is consistent with giving their interests appropriate moral weight in view of the animals’ cognitive, emotional, and social complexity.”
Utilitarianism: “Animals may be used in research only where their use is likely to maximize the overall balance of benefits – factoring in likelihood of success – over harms, where all parties’ (including animals’) interests are impartially considered.”
Strong animal-rights view: “Animals may be used in research only where (1) their involvement does not harm them or (2) their involvement is in their overall best interests (therapeutic research). This view might also permit animals to be used in research where (3) their involvement poses only minimal risk to them.”
Clearly, the third level is the most demanding. Indeed, the definition proffered by DeGrazia masks the extreme nature of this last position. The devil, as they say, is in the details. For example, whether what a scientist does to his animals harms them or not depends entirely on the definition of the word “harm.” If one includes under harm the mere caging of an animal, then it is virtually impossible for a research scientist to work with animals in his lab. Similarly, if one deems the anxiety caused to an animal by the mere handling of that animal to be “harm,” then, once again, the definition would make it well-nigh impossible for a researcher to work with any such animals.
On February 24, 2008, a U.C.-Santa Cruz breast-cancer scientist and her family were enjoying a birthday party, when a loud knock came from their home’s front door. The researcher’s husband responded and was greeted by six masked visitors, one of whom smacked him on the hand before they got back into their car and drove off. This was not the first such incident at Santa Cruz, where the cancer researchers use mice in their labs. Earlier intrusions included graffiti, such as “murderer” and “torturer,” and strewn garbage in front of other scientists’ homes. Similar assaults were reported in Los Angeles and Salt Lake City.
UCLA’s Dr. Edythe D. London, who uses primates to study addiction, has been a particular target of ALF adherents. Her house has been both firebombed and flooded.
UCLA’s Center for Neurovisceral Sciences and Women’s Health describes Dr. London’s work as follows:
Dr. London's research has advanced the study of substance abuse and the development of new approaches and probes for studies of brain function. She has edited several books and authored over 200 original research articles and over 60 reviews. Her most recognized accomplishments involve PET scanning of human subjects who suffer from addictions. Dr. London's group was the first to show a relationship between drug craving and activity of brain regions that link memory with emotion. She also showed that drug abusers have structural abnormalities in prefrontal cortex and deficits in decision-making tasks that depend on prefrontal cortex function. Her work influenced other researchers to look toward the frontal lobe for an understanding of the compulsive self-administration of drugs despite detrimental effects, which characterizes drug addiction. Most recently, she and her colleagues have developed new probes for external imaging of those receptors in the brain where nicotine binds to produce its behavioral actions.
By contrast, on March 13, 2008, the Animal Liberation Front website (http://www.animalliberationfront.com/) posted the following anonymous notice:
At the start of last week, in Irvine, Calif., a van owned by UCLA went up in flames. For all of those affected you have the UCLA primate vivisection program to blame.
It is unacceptable for us to see, hear, and know what is going on in our animal labs without taking action. Every time we pass someone like Arthur in the hallways and have to witness his stomach churning grin or watch Joaquin double checking the door locks on his little red Mercedes we have to choke back a crippling amount of disgust and hatred. It is becoming almost impossible to hold back. Then we hear the monkeys wailing and screaming and we find the strength to stay put.
We are driven to show the world the compassionless support that UCLA gives to these monkey killers and to do anything we can to end the needless suffering that the primates are forced to face.
The end of UCLA vivisection is coming. We urge you to start switching over to non-animal protocol without haste.
--LA ALF

The Mentally Ill: the 2007 Virginia Tech Massacre
In the Virginia Tech killer’s case, future mass-murder Seung-Hui Cho set off numerous red flags at the university prior to becoming the single deadliest killer in U.S. history on April 16, 2007 when he murdered 32 people and wounded 17 others before taking his own life. In the fall of 2005, a Virginia Tech poetry professor had Cho removed from her class. Nikki Giovanni told media after the massacre that she found the young man’s poetry so intimidating and his presence so menacing that, when two students who shared her anxiety stopped attending class, she moved to remove Cho. Describing Cho as “mean,” Giovanni told CNN, “I knew when it happened that that’s probably who it was.”
In November 2005, following up on an harassment complaint lodged by a female student, Cho, a South Korean citizen with permanent U.S. resident status, was directed to the university’s Office of Judicial Affairs. The complainant declined to press charges, saying that Cho’s unwelcome attentions were merely annoying, not truly harassing.
A month later another female student filed a complaint against Cho with the campus police. Shortly after the campus police interviewed Cho, another student called to claim that Cho appeared to be suicidal. This call resulted in issuance of a detention order. The troubled young man was subsequently evaluated at Carilion St. Albans Behavioral Health, an independent mental-health facility. Following this counseling intervention, say police, they received no more student complaints about Cho.
These facts beg the questions: In the fall of 2005 should Cho have been removed from more than just Giovanni’s poetry class? Should he have been kept in custody – institutionalized – when he was taken to the mental-health facility?
A May 8, 2007, editorial in the Roanoke Times complained of “No Teeth in Mental Health Laws in Virginia.” The piece went on to contend that Cho’s fall 2005 release from custody was inappropriate because he was diagnosed as “depressed and imminently dangerous.” In eerie emulation of the 1966 University of Texas tower-massacre, where a University of Texas psychiatrist’s had suggested that tower-sniper Whitman make an appointment for the following week, Cho was ordered to pursue outpatient treatment and then released. As with Whitman, the 23-year-old Cho’s next appearance on the radar screen was with guns in hand.
Is Profiling One Answer?
Is it possible to identify those individuals who are primed to become the next Ivins, freelance Animal Liberation Front sympathizer, or Cho? Our justice system takes a dim view of profiling. When the police use profiling, it’s condemned as racist. When customs service does it, it’s similarly assailed as discriminatory and unconstitutional. Still, it’s being done. Travel & Leisure Magazine reported in January 2007, “The Transportation Security Administration (TSA) recently began rolling out a new security program, Screening Passengers by Observation Techniques (SPOT), at dozens of airports around the country.” Time Magazine explained, “TSA employees will be trained to identify suspicious individuals who raise red flags by exhibiting unusual or anxious behavior, which can be as simple as changes in mannerisms, excessive sweating on a cool day, or changes in the pitch of a person's voice.” Although such techniques invariably arouse the ACLU, should those charged with protecting our campuses from domestic terrorism be encouraged to adopt them?
Some experts have emerged who claim to be capable of raising profiling to a new level of sophistication and reliability. For example, Consultant Dan Korem’s book, Rage of the Random Actor: Disarming Catastrophic Acts and Restoring Lives, makes the following claims on its dust jacket:
In the early 1990s, Dan Korem, a critically acclaimed investigative journalist and author, identified the Random Actor profile. He used it to solve the riddle of why there were mass shootings as the Post Office, but not at UPS. And why mass company shooters work in accounting or on an assembly line, but not in the art department.
In the mid-1990s, he used the same profile to predict student-led terrorist incidents in American schools. He even identified Denver suburbs as a candidate for a bombing massacre two months before the attack. After Columbine, he warned that adult-teen Random Actor killer cells would appear; in 2002 the Muhammad-Malvo “sniper” duo opened fire in DC and Maryland suburbs. He also believed that suicide bombers had the Random Actor profile, and he was right.
Mr. Korem’s book presents in great detail his carefully considered method of identifying potential terrorists of the “mad” variety such as Cho. The depth and breadth of his study illustrates the sophistication to which profiling may aspire. While an article of this length cannot adequately capture techniques that Korem devoted some 500 pages to explicating, a few of his indicia can be ticked off here:
Potential “Random Actors” often threat to and/or attempt suicide.
“Random Actors” only rarely are African-American or female.
“Random Actors” are often into the “bunker syndrome,” shutting themselves off from the people and society around them.
Many “Random Actors” are the products of broken homes.
Obsession with weapons is a common characteristic of “Random Actors.”
Some “Random Actors” have claimed adherence to a fabricated or “hinky” religious doctrine.
And some have been pedophiles.
Can we afford to ignore tools of such sophistication and potential?
Recognizing that the major types of campus terrorists have much in common, campus security experts are increasingly answering “no.”
For example, many colleges and universities, making an about-face from their pre-VTU passion for student privacy, have organized cross-divisional committees charged with tracking troubled members of their student bodies. Borrowing a page or two from Korem, they monitor students who have isolated themselves in their dorm rooms rather than mixing with friends outside the classroom; have engaged in cutting and other self-destructive behavior; have admitted to college counselors or psychologists that they are having violent thoughts or impulses; or who have had either classroom or other campus confrontations bordering upon violent outcomes.
In short, they are profiling in an attempt to make their campuses the safe havens they should be.

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